Parking Policy Is Housing Policy

Other cities in the northeast have taken bold actions in repealing parking requirements for new buildings. Last December, Boston repealed parking requirements citywide for affordable housing developments. More recently, the City of Cambridge removed its requirements for all new buildings, not limited to residential or those with affordable housing.

Parking requirements—often referred to as ​“minimum parking requirements” or ​“parking minimums”—are ratios set by municipal zoning codes that require the construction of a certain number of parking spaces per a certain number of housing units or overall square footage constructed. In practice, parking requirements mean that a developer must earmark a certain portion of development funds, and a portion of the parcel area, for parking facility construction and maintenance. By lowering or waiving parking requirements, greater percentages of budgets and parcel areas can be used not for parking facilities but more housing units, better addressing our city’s housing shortage. This trade-off better serves the needs of city residents. More than half (54%) of New York City households do not own a car. Meanwhile, 46% of NYC residents responded to a recent survey that affordable housing is the most important issue in addressing inequality.

Regional Plan Association (RPA) analyzed the impact that reduced minimum parking requirements have already had on housing development, in the limited contexts in which they have been employed. We found that where parking minimums have been abolished, it has not only encouraged overall new housing production, but yielded a greater number of affordable units annually compared to geographies where parking minimums remained in place. In other words, amending zoning codes toward the citywide abolition of minimum parking requirements can enable more robust housing production, both affordable and overall.

New York City eliminated parking minimums in the core of Manhattan (below 96th street on the East Side and 110th street on the West Side) in 1982 in the context of the Clean Air Act amid the desire to reduce emissions and improve air quality. In 2011, the City further exempted much of Long Island City from parking minimums. The City has made more recent efforts, too, particularly for affordable and senior housing. The largest step forward came following Mayor’s De Blasio’s 2014 plan, Housing New York: A Five-Borough, Ten-Year Plan.

The Zoning for Quality and Affordability (ZQA) amendment to the NYC Zoning Resolution, adopted in March 2016, was another policy supplement that gave affordable and senior housing production a particular lift. Among other provisions granting more flexibility to bulk, height, and floor area for new buildings, ZQA waived parking minimum requirements for affordable and senior housing within certain districts found to be rich with transit options and only a half mile from a subway station throughout (dubbed the ​“Transit Zone”). In addition to waiving parking requirements for new affordable housing, ZQA also made it easier for parking at existing affordable housing developments to be eliminated within the Transit Zone, as long as ensuing construction was affordable or supported the existing affordable development.

RPA looked into the city’s housing production data to help determine how the degree to which eliminating parking requirements through ZQA furthered affordable housing. We focused on new construction only, even though some provisions of ZQA can facilitate affordable housing preservation as well. To understand citywide patterns of affordable development around the passage of ZQA, we examined the data for new buildings and units citywide that were constructed using Low Income Housing Tax Credits (LIHTC) funding. LIHTC is a state-administered, federal tax credit mechanism that is often indispensable for making affordable development financially feasible for developers.

Since ZQA’s passage at the end of Q1 of 2016, the annual number of affordable units introduced to the Transit Zone housing market has shot up. When comparing housing productivity in the aggregate Transit Zone areas post-ZQA until the Coronavirus pandemic (which interrupted regular development), to pre-ZQA times, production of new affordable units rose by 36%. Units with the deepest affordability rose most precipitously, with a 64% increase in units for 50% AMI households and a 63% increase in units for 30% AMI households.

Because the Transit Zone area is relatively large geographically and encompasses most of the areas in the outer boroughs where denser development is allowed, it was already the largest contributor of newly constructed affordable units citywide. The passage of ZQA bolstered this trend even further, with the Transit Zone’s share of newly constructed affordable units rising from 63% in 2015, to 74% in 2016, and to 81% in 2017. While the share declined after 2017, this was due mainly to an increase in overall affordable housing, rather than a decrease in affordable units built in the Transit Zone.

There was an even more significant rise in the number of LIHTC buildings developed in the Transit Zone after parking requirements were waived, indicating a pattern of increasing development of smaller buildings. The rise in LIHTC building development in the Transit Zone has continued over the years, shifting development to the Transit Zone and away from other areas of the city where parking requirements remain. In addition to the geographical shift in LIHTC-driven development, with the gross majority of LIHTC building development now clustering in the Transit Zone, the city has seen more new LIHTC buildings (and units) overall than it did in the pre-ZQA context.

This demonstrates that the elimination of parking requirements in the Transit Zone under ZQA has unlocked more possibilities for mid-size parcel development. Before ZQA, in order to make a development financially feasible, affordable housing developers needed to acquire parcels large enough to accommodate parking facilities and zoned highly enough to allow for high-unit count design. After ZQA, mid-sized lots have become developable as well. In this way, ZQA has been especially effective in incentivizing the construction of mid-sized LIHTC buildings and lots. After ZQA’s passage, new LIHTC buildings in the Transit Zone are more plentiful but smaller on average, falling from an average of 97 total units, to 59 total units, to 50 units following the Coronavirus pandemic. The new feasibility of these smaller buildings also enables smaller developers, often M/WBE firms or nonprofit housing providers, to have access to more development opportunities.

The shift toward smaller developments correlates with a shift of LIHTC-driven development away from Manhattan Core and Long Island City – which already had eliminated parking minimums—toward the newly created Transit Zone areas after the passage of ZQA. Total development in Manhattan Core/LIC fell from around 5,200 units in 23 buildings in 2015 to around 2,300 units in 13 buildings in 2017. This shift may be because of the lower market of the new Transit Zone, where affordable housing development is able to compete more easily for sites with market-rate development.

The shift toward more affordable development in this area is noteworthy. In years before ZQA’s passage, LIHTC-driven building development in the Transit Zone area at times comprised between 29% and 36% of the city’s total LIHTC development. Once the Transit Zone was formalized, the area attracted significant amounts of affordable development, accounting for three-quarters of city-wide LIHTC buildings in both 2020 and 2021, more than doubling its share of affordable building contribution in four years.

RPA recommends the following actions:

• Expand the boundaries of the Transit Zone, and incorporate additional transit-rich areas that were initially excluded during the ZQA negotiations in 2016. A new Transit Zone should also include areas served by Select Bus Service and places where the MTA is redesigning and improving bus networks for more frequent, dependable service.
• Expand the types of developments that are exempt from parking requirements, including extending the waivers to all market-rate residential development via the yet-to-be-defined City of Yes text amendments.
• Change zoning incentives that encourage more affordable or senior housing to ensure the amount of affordable housing does not fall short of goals. This would be especially helpful in a scenario where market-rate housing is exempted from parking requirements.