Comments on City of Yes for Economic Opportunity Zoning Text Amendment
Testimony Re: Application Number N 240010 ZRY
Pratt Center for Community Development works for a more just, equitable and sustainable New York City through participatory planning, applied research, and policy advocacy in collaboration with community-based organizations. City of Yes for Economic Opportunity importantly addresses outdated zoning regulations that can prevent businesses from setting up shop in certain areas, and below we offer some suggestions to improve two of its proposals to accomplish the intended goals and ensure a more equitable outcome. The final part of this testimony comments on the shortcomings of the public review process for this citywide zoning text amendment.
Proposal 15: Facilitate local commercial space on residential campuses
Pratt Center is concerned that this proposal alone will not necessarily benefit NYCHA residents because it lacks requirements or incentives for NYCHA resident participation in the creation of new commercial space. According to the Center for Urban Future, from 2012 to 2021 there was a nearly 500% increase in NYCHA residents reporting business income. The City should be creating opportunities for these entrepreneurs to meaningfully benefit from this zoning change by prioritizing their access and reducing bureaucratic and economic barriers to accessing commercial spaces that are developed on their campuses. NYCHA residents know how to best serve their neighbors and create opportunities for them through hiring and providing goods and services more conveniently.
We are also concerned that allowing for larger-scale commercial spaces without requiring NYCHA resident input nor requiring applicants—who will likely not be NYCHA residents‚—to partner with NYCHA residents is a missed opportunity. As with all public policy, we should be seeking to maximize public benefit and while enabling entrepreneurship within NYCHA campuses is an important goal, we should be centering NYCHA residents’ ability to start or expand businesses on their own residential campuses.
Proposal 18: Create new kinds of zoning districts for future job hubs
As a longtime advocate for land use policies that support the retention and expansion of New York City’s industrial sector, Pratt Center is largely supportive of Proposal 18. However, there are changes we would like to see to strengthen the new proposed zoning districts’ ability to encourage and incentivize the development of space for manufacturing businesses. They are outlined below.
Core Districts (M3A)
- Restrict all non-industrial uses to 10,000 square feet per zoning lot
- Create two additional M3A districts with the following FAR:
- 4.0 FAR
- 5.0 FAR
- Limit non-industrial uses in these new districts to 10,000 square feet or 1 FAR
- Include requirements that at least a portion of the ground floor is dedicated to Qualifying Uses, with access to loading docks and freight elevators
Growth and Transition Districts in general
- These two new districts must support a sustained balance of industrial and commercial uses as opposed to a predominance of the latter. Any additional capacity for commercial development must include requirements or strong incentives for industrial space to be included in new developments. As such, we support slightly decreasing the maximum FAR for other uses to incentivize the development of buildings that include 25% Qualifying Uses (i.e., industrial) in Transition Districts and 15% Qualifying Uses (i.e., industrial) uses in Growth Districts.
Transition Districts (M2A)
- Increase the size of the incentive bonus for Qualifying Uses to promote developments with 25% of floor area for industrial uses, across M2A zoning districts
- Include requirements that at least a portion of the ground floor is dedicated to Qualifying Uses, with access to loading docks and freight elevators
Growth Districts (M1A)
- Include an incentive bonus for Qualifying Uses along the lines of Transition Districts, to promote developments with 15% of floor area for industrial uses, across M1A zoning districts
- Include requirements that at least a portion of the ground floor is dedicated to Qualifying Uses, with access to loading docks and freight elevators
Comments on the public review process
The 60-day public review window has been insufficient for a Citywide text amendment as multifaceted as this one. DCP staff briefed 59 community boards within these 60 days, and while it is not required that community boards weigh in, they are a vital component of public feedback. After community board members across the city sent a letter requesting more time and a deadline extension, DCP rejected the request and assured them that the CPC would review their votes and resolutions as long as they are received before the vote. Receiving Community Board feedback before a hearing can inform the questions that the commissioners ask during the session. As of the evening before the January 24th hearing, only 19 of the 59 Community Boards had submitted their vote. While there are post-hearing follow-ups where commissioners may ask more questions, the main hearing itself is an important opportunity to provide a complete picture of what community boards and other stakeholders think about a proposed action.
Additionally, calendaring this hearing with 29 other items on the agenda made it so time-consuming that it was difficult for community members to testify. A major citywide proposal such as this one should have had a stand-alone hearing with more accommodating opportunities to testify such as pre-recorded video testimony.