Parking Rule Erects Barriers to Affordable Housing

Testimony to the Subcommittee on Zoning & Franchises of the New York City Council
Residential Streetscape Preservation Text Amendment
April 7, 2010

Thank you for the opportunity to testify on this seemingly obscure but ultimately very significant proposed change. The Pratt Center for Community Development has a 45 year history of providing technical assistance to moderate income communities to assist them in the realization of their plans for their own communities, in line with the mission of creating a more sustainable, just and equitable City.

With full acknowledgement of the work of the Department of City Planning (DCP), the City Council and the attempt to balance multiple interests that the proposed zone text amendment embodies, we respectfully but strongly urge that the amendment not advance. Despite the effort and many of the worthy goals that it attempts to address, the proposed change fails to strike the proper balance and ultimately would both 1) create barriers to the creation of affordable housing in multiple ways and 2) prematurely enact a significant parking policy change in advance of a comprehensive analysis that is currently underway.

By requiring a new parking space for a new dwelling unit created in an existing residence in R3 and R4 districts, the proposed amendment erects a significant barrier to the creation of new units in these zones. Currently, informal conversions of a safe space within one- and two-family homes to a rental unit are commonplace, but existing burdens to the legal conversion of these units are most often prohibitive to their achieving official status. Yet because these units provide badly-needed income to struggling homeowners as well as provide safe and affordable units in the face of immense citywide need, there is strong interest and demand by owners for assistance through the formalization process that would bring compliance with fire and entrance/exit requirements. It is in the City’s interest that unnecessary barriers to formalizing these units be removed, so that their safety can be ensured, the population can be more accurately counted and services better provided for, whether they may be sanitation, schools, emergency services or more. Instead of reducing these barriers, the proposal would create a new one, effectively increasing the pressure that creates the informal and unregulated housing that is problematic for tenants, owners and communities alike.

Furthermore, this same parking requirement may influence building patterns to preference detached housing over attached or semi-detached housing, in order to accommodate space on the lot for parking. This runs counter to the widely accepted principles of smart growth which require us to encourage denser and more energy efficient housing development.

From an even broader perspective, it is unclear why these substantial changes to parking ratios are being pursued while DCP’s citywide parking demand analysis is currently underway. Since that effort is intended to provide a comprehensive view of City needs that would inform local policies, it seems premature to enact this or other rezonings/zone text amendments that will impact parking policy in a major way before that study is finished and digested.

In light of these considerations, as well as the fact that virtually none of the stakeholders that would be impacted by the adverse housing and transportation consequences of this amendment have had the meaningful opportunity to fully evaluate it and weigh in, we urge the Council:

• to oppose the zone text resolution at this time,
• to await and review the results of the comprehensive study on parking demand that is underway at Department of City Planning and
• to work with DCP and a broader set of constituents – including community-based organizations working on issues of affordable housing and non-profit organizations working on transportation and land-use issues – to craft a proposal that:
• addresses the aesthetic and environmental considerations the proposed zone text is attempting to treat,
• but that does so in synch with comprehensive city parking policies and without creating barriers to improving and increasing the City’s affordable housing stock.

We applaud many of the intentions behind this proposed zoning text amendment and would welcome the opportunity to collaborate with the Council and DCP to craft a more appropriate pathway toward their realization, while protecting and enhancing opportunities for the creation of affordable housing and sensible transportation policies. Thank you for your time and careful attention to the serious unintended consequences of this proposal.