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Pratt Center Project

Democratizing Planning

City Environmental Quality Review and Community Impacts

Evaluating how NYC measures indirect displacement risk to residents and businesses

To better understand how New York City evaluates residential and business displacement, Pratt Center undertook a step-by-step evaluation of the CEQR Technical Manual guidance on indirect displacement as well as a review of dozens of Environmental Impact Statements to see how this guidance has been applied over the past 15 years.

BACKGROUND

Zoning and land use decisions in New York City are managed through the Uniform Land Use Review Procedure (ULURP), a city charter-mandated process that requires review by community boards, borough presidents, the City Planning Commission, the City Council and the Mayor. Every major land use action that goes through ULURP, including rezonings, must also go through the City Environmental Quality Review (CEQR) process to evaluate and disclose a project’s environmental impacts, most often in the form of an Environmental Impact Statement (EIS). While CEQR outlines the scope of environmental review, it does not provide the methodologies for how this analysis should be done. To fill this gap, in the early 1990s the City developed a Technical Manual that details specific methods for evaluating the various areas required for review, including residential and business displacement.

CEQR is intended to inform the public and those with decision-making authority under ULURP an understanding of a project’s effects. Most importantly, for projects that are deemed to have significant adverse impacts through CEQR, potential mitigation measures are required to be listed. Funding and implementing mitigation measures are not part of CEQR, but often are part of the final negotiations in ULURP. As a result, while the EISs - the long and technical outputs that are most often the culmination of CEQR - may seem perfunctory, they are in fact a key tool for decision-making, and in the case of displacement, the City’s sole vehicle to evaluating displacement risk.

As communities across the city face increased displacement pressure, more accurate evaluation tools are urgently needed. To better understand how the City, through CEQR, evaluates residential and business displacement, Pratt Center undertook a step-by-step evaluation of the Technical Manual guidance on indirect displacement as well as a review of dozens of EISs to see how this guidance has been applied over the past 15 years. 

IMPACT

This research revealed a distressing finding: the Technical Manual’s displacement methodology is based on a series of unjustified assumptions, subjective determinations and circular logic that makes a positive finding of adverse impact, virtually impossible.

In 2018, Pratt Center released Flawed Findings Part 1, which details the inadequate way the City currently evaluates indirect residential displacement. In our companion report, Flawed Findings Part 2, we take a similar deep dive into the City’s approach to indirect business displacement, coming to the same conclusion: key steps to effectively evaluate and address displacement pressure, as well as a revamp of the City’s CEQR Technical Manual, are direly needed.

 

Flawed Findings Reports

Click to see Pratt Center's research detailing the myriad ways CEQR's Indirect Displacement analsysis fails communities.

Part I: Residential Displacement READ MORE >>

Part II: Business Displacement READ MORE >>