Members and staff of the Charter Revision Commission,
Thank you for your thoughtful work on this process so far. Addressing our city’s housing crisis requires collaboration from all levels of government. I share your commitment to finding actionable steps we can take now to encourage development, especially in parts of the city that have not done their fair share. Though I was unable to attend the last Brooklyn hearing, I wanted to share my thoughts on some of the potential solutions discussed in your Preliminary Report:
First, regarding creating a “fast track” land use review process, I generally agree that ULURP takes too long and costs too much for many types of projects. To solve this, we need an agreed-upon set of principles that will guide when and how specific projects can be approved on a less intensive timeline. I would generally support creation of a “fast track” for 100% income-restricted housing development, resiliency projects as described in the report, and housing development in areas that have underproduced new housing. Conversely, I would not recommend allowing a “fast track” only for low-density projects, given that we don’t want to incentivize low-density development, especially not adjacent to public transit.
Regarding disposition of public land, as a supporter of the Community Land Act and Intro 00782024 (aka the “Public Land for Public Good” bill) I believe strongly that public land is our best opportunity to create much-needed deeply affordable housing. Therefore, I would support an accelerated disposition process for developable public land outside of manufacturing zones only to mission-driven, non-profit developers for 100% income-restricted housing developments. Ideally these developments would also contain community amenities, as determined by public input, where possible.
The ideal “fast-track” option, in my opinion, would be for projects that comport with a citywide comprehensive plan. As you note in your report, I have long been advocating for creation of a citywide comprehensive plan. There is a misconception that comprehensive planning will be too time consuming and slow down development. However, the actual goal is just the opposite – to create a comprehensive vision for our city’s future and to speed up projects that are in line with that vision, rather than having to consider every project individually. This also can help address an issue that could result from too many “fast track” projects in one area: lack of consideration for cumulative impacts. As you note, comprehensive planning, and especially tying that planning to the Capital Budget, ensures that development is balanced with other needs such as infrastructure and transit.
As an interim measure on the road to comprehensive planning, I would support the concept outlined in the report that would create a “fast-track” for compliance with fair housing targets. In practice, once the Fair Housing Framework targets are finalized, community boards should have one year to develop a plan for how to implement them in their districts; if they don’t, the City should develop that plan for them. Projects that are in line with the community board’s plan would then be fast-tracked.
So what does this “fast track” look like? Your report notes that the most common recommendation for streamlining ULURP is to combine community board, borough board, and Borough President review timelines. However, this suggestion disempowers communities, who understand their own neighborhood’s needs best. While I may not always agree with every board’s recommendation (especially as a boroughwide representative who is particularly interested in equitable development and fair housing), their opinions always inform mine, and my recommendations benefit from having their review done first. Instead, I suggest a process wherein the CPC can certify a project as “fast tracked” based on the set of principles outlined above. If a fast-tracked project receives a “yes” vote from the community board and the Borough President, it is approved. If the project receives a “no” vote from either or both, the City Councilmember would then be given the option to call it up.
Admittedly, this process does not necessarily solve for member deference, which as you note, can shrink or even stop proposals and may even deter developers from trying to add housing in certain parts of the city at all. I agree with the proposal outlined in the report wherein the Mayor, the Council Speaker, and the Borough President would have the option to call up a Council “no” with a two-thirds vote needed to override. In developing this idea, the Commission should consider two important questions: first, who has the power to initiate a call-up? I would suggest that all three members of this body should be able to do so. Second, what is the timeline for their review process and vote? It is important to acknowledge that ULURP provides the opportunity to negotiate for community benefits, so it will be necessary to balance expediency with the time needed for these negotiations. I would also note that this three-person body is a more appropriate option for a potential Council “no” override than a CPC supermajority, as suggested by CHPC. The CPC is appointed, not elected, so should not be given the power to override an elected body.
Finally, I want to address the report’s proposed changes to the City Mapping process. My office’s Topography division plays a very important role in the development process, including:
- Conducting technical review based on borough-specific standards;
- Rectifying any issues with underlying tax lots;
- Mapping and demapping streets;
- Assigning addresses (note: each borough’s addressing system is different based on its history, so consolidating and digitizing one City Map would be more difficult than is immediately apparent);
- Making discretionary decisions about vanity addresses (not a task I would recommend leaving up to a mayor) and coordinating with the Post Office to ensure our neighbors receive their mail accordingly; and
- Enforcing the use/display of addresses, which seems minor but is vital for first responders such as EMS and FDNY to quickly find Brooklynites who need help.
These procedures are complicated, yes, but they are necessary. Brooklyn has consistently been one of the fastest growing boroughs, and I am proud to say that our Topography division has been keeping pace with a growing and changing borough. Rather than slowing down development, as your report suggests, working with our Topography team can actually streamline the process. For example, developers of a large-scale project in eastern Brooklyn met with my team many times in advance of certification. My team helped them design their traffic plan and name their streets in advance, reducing their review time later. While I do think some consolidation of roles could be helpful (for example, the City could hire one or two engineers to consult with all five boroughs, saving both money and time), I will continue to advocate for the important and unique role that Brooklyn’s Topography division serves.
Thank you again for the work you are doing on this Commission, and for considering the feedback that I am providing here. I look forward to continuing the conversation with you and your staff, and to working with you to clean up our processes and address the housing crisis together.