City of Yes for Housing Opportunity: Brooklyn Borough President Antonio Reynoso Issues Formal Public Review Recommendation

Published by Stephon Snell on

Reynoso Recommends Strategies to Promote Larger Increase in Housing Supply, Including Redefined Inner and Outer Transit Zones, Addition of Core Transit Zones, Higher Density Allowances, and Maximum Dwelling Unit Factors

Reynoso Declares Support for City of Yes is Contingent Upon the Inclusion of Proposal to Legalize Accessory Dwelling Units

“My advice to the Department of City Planning is simple: Do not back down; do not scale back; do not shy away. If you’re going to do anything, do more.” – Antonio Reynoso

BROOKLYN, NY – Today, Brooklyn Borough President Antonio Reynoso issued his official public review recommendation to approve with conditions and modifications Mayor Adams’ City of Yes for Housing Opportunity zoning text amendment. Borough President Reynoso recommends significant adjustments to ensure the text amendment maximizes opportunities for new housing around transit, deepens affordability, and encourages every neighborhood to do their part in building our way out of the housing crisis. Measures include the redefinition of Inner and Outer Transit Zones, the creation of additional Core Transit Zones, increased density opportunities, new parking maximums, the decoupling of parking costs and rent costs, and more.

Notably, Borough President Reynoso declares in his recommendation that his support for City of Yes for Housing Opportunity is contingent upon the legalization of Accessory Dwelling Units (ADUs). If legalizing ADUs is removed as a proposal, Borough President Reynoso will withdraw his support for the text amendment in its entirety.

On the NYC Department of City Planning’s (DCP) proposed City of Yes for Housing Opportunity zoning text amendment, Brooklyn Borough President Antonio Reynoso stated:

“We need to be realistic about what City of Yes for Housing Opportunity is and what it is not. It is not an affordability strategy, it is not a production plan, and it is not a panacea for our city’s housing crisis.

“City of Yes is remarkably modest; DCP testified that the package will add less than one additional unit per acre across New York City. This is at a time when homelessness has reached the highest level since the Great Depression, and more than half of New York City renters are rent-burdened – losing 30% or more of their income to rent.

“In the face of growing housing insecurity, New Yorkers deserve honest policy – and the truth is that City of Yes is all about possibility when what we need is a promise. It is a zoning solution to a planning problem. It is a mere chapter in a much larger book. Do we need it? Yes. But do we need a citywide comprehensive plan more? Absolutely.

“In City of Yes, DCP has the opportunity to pave the way for future large-scale planning efforts by setting the standard citywide that no neighborhood is exempt from doing their part for the greater good and contributing new housing.

“My advice to DCP is simple: Do not back down; do not scale back; do not shy away. If you’re going to do anything, do more. Nothing is more important than ensuring every New Yorker and every family has a place to call home for generations to come – not politics, not parking, not even the character of a neighborhood.”

Brooklyn Borough President Antonio Reynoso’s full public review recommendation is available HERE. Select priorities and proposals are summarized below.


Several proposals within City of Yes for Housing Opportunity revolve around a “Greater Transit Zone,” which amends the existing Transit Zone that was established in 2016.

The existing Transit Zone established in 2016 loosely corresponds with the subway network; however, the relationship between the transit zone boundary and actual transit stations is hazy and includes several conspicuous carveouts. In Brooklyn, several neighborhoods are excluded from the zone altogether: much of Borough Park, Brighton Beach, Bensonhurst, and the entirety of Bay Ridge are excluded despite much of these neighborhoods being a stone’s throw from a rail station. The land use rationale for these inconsistencies and exclusions is not stated in the Zoning Resolution or other planning documents.

If at all, how does City of Yes for Housing Opportunity address these unclear and arbitrary exclusions? Through City of Yes, DCP proposes a new “Greater Transit Zone” to be composed of two parts: an Inner Transit Zone and an Outer Transit Zone.

DCP’s proposed Inner Transit Zone consists of the currently existing Transit Zone from 2016 as well as the Manhattan Core and Long Island City Areas.

DCP’s proposed Outer Transit Zone consists of:

  1. Fixes: All blocks within a half-mile radius of a subway station that are not already within the 2016 Transit Zone.
  2. Commuter rail stations: All blocks within a half-mile radius of LIRR, MNR, and SIR stations.

In other words, through the text amendment, DCP proposes to patch the holes of the existing Transit Zone through the creation of a new “Outer Transit Zone.”

Borough President Reynoso supports the general effort to fill in these gaps but believes that these areas should have been included in the Transit Zone from the beginning and therefore should be incorporated into the Inner Transit Zone.

City of Yes is an opportunity to correct unclear and arbitrary exclusions of the past and clearly state a land use rationale for what the Inner and Outer Transit Zones represent going forward.


When you look at the differing policies applied by DCP to each of these geographies, the difference between the Inner and Outer Transit Zones is minimal.

As seen in Table 1 below, the Inner and Outer Transit Zones apply the same allowances for the Town Center Zoning and Transit-Oriented Development proposals. The Lift Costly Parking Mandates proposal includes some distinctions between the two zones for mixed-use parking waivers but the brunt of the proposal – the lifting of residential parking requirements – is identical across the entire city.

Overall, there are few aspects of the proposal that apply exclusively to the Outer Transit Zone. Rather than defining any unified principles of transit-oriented development or urban design, the Outer Transit Zone’s main function is to correct the gaps in the previous Transit Zone. The Outer Transit Zone should be a distinct geography with its own land use rationale and vision, not just a corrective measure for carveouts to previous versions of the Transit Zone.

Borough President Reynoso believes the Outer Transit Zone should be repurposed around Select Bus Service (SBS) corridors: areas with access to frequent, express-style bus service with dedicated travel lanes but farther than a 10-15-minute walk to the rail network.

The updated Inner and Outer Transit Zones as proposed by Borough President Reynoso are depicted in the map below.


Borough President Reynoso also believes an additional “core” geography should be expanded to Brooklyn and other outer boroughs to further facilitate transit-oriented development near significant transit and jobs hubs such as Downtown Brooklyn, Atlantic Terminal, and the Northside of Williamsburg.

There is already precedent for Core Transit Zones in the Zoning Resolution: the Manhattan Core and Long Island City geographies include various controls on parking. Borough President Reynoso believes this precedent should be extended to Brooklyn.


By implementing Borough President Reynoso’s changes, the Greater Transit Zone would therefore be composed of three parts:

Core Transit Zones, defined as transit and job hubs.

The Inner Transit Zone, defined as all parts of the city with access to the subway and rail network.

The Outer Transit Zone, defined as all parts of the city with access to frequent bus service, but beyond the extent of the rail network.


The potential for growth in Brooklyn facilitated by City of Yes for Housing Opportunity is surprisingly modest. Borough President Reynoso recommends DCP strengthen City of Yes for Housing Opportunity by encouraging greater density and making the following modifications.

Town Center Zoning

Borough President Reynoso recommends DCP create additional housing capacity by increasing the residential equivalency from R5 to R6 in Town Center areas.

Transit-Oriented Development

Borough President Reynoso recommends DCP allow slightly higher densities of 5-6 stories within the Borough President’s proposed Inner Transit Zone.

While there are nearly 90,000 parcels identified in Brooklyn’s low-density districts within DCP’s proposed Greater Transit Zone, fewer than 4,000 meet the criteria of being larger than 5,000 square feet and being located either on the short end of a block or facing a wide street.

In many cases, the buildings on these parcels are currently overbuilt. Of the 3,637 eligible parcels in Brooklyn, one quarter are currently overbuilt and would remain overbuilt with the new proposed densities. No new development would be facilitated by the proposed changes at these sites. The fact that a quarter of eligible sites would still be overbuilt after the proposed changes shows that buildings of this scale are already common in these areas of the borough.

At another quarter of eligible parcels, a portion of the proposed density bonus would be eaten up by merely legalizing the existing building. At many of these sites, the new floor area leftover after legalizing the existing density would be small, and also unlikely to facilitate any new construction.

These bits and pieces add up: although the proposal is adding 4.6 million square feet of residential floor area to these overbuilt lots, this area is only estimated to allow a little over 5,000 residential units. While critical to bring existing units into compliance, we should be clear-eyed that additional zoning capacity is needed to unlock additional development in these areas.

Small and Shared Housing

Borough President Reynoso recommends eliminating dwelling unit factors within the boundaries of the Borough President’s proposed Inner and Outer Transit Zones. As presented, dwelling unit factors would only be eliminated in the Transit Zone as it exists today.

Borough President Reynoso also recommends that DCP include a maximum dwelling unit factor that would apply in Core Transit Zones. A maximum dwelling unit factor would protect multi-family buildings (e.g., brownstones) from being consolidated into single-family mansions.

Many census tracts in Brooklyn have lost housing units since 2014. Currently, it is easier for a property owner/developer to eliminate a residential unit than to eliminate a parking space required by zoning.

Lift Costly Parking Mandates

Borough President Reynoso prioritizes the production of housing – whether market rate or affordable – over the provision of car storage.

He is supportive of the removal of parking minimums as costly barriers to development and recommends DCP go further by amending the proposal to introduce parking maximums that could be tiered relative to the Transit Zone. The City already has established parking maximums within the Manhattan Core and Long Island City Area.

Borough President Reynoso recommends that DCP create a new “flexible-use” parking definition. This designation would serve as a mechanism for better parking demand management by enabling extra parking spaces in new and existing developments to be leased or used by other nearby developments, including neighbors and commercial uses.

The Borough President also recognizes that it is critical to unbundle parking to better align cost-savings to tenants without cars. While understanding that developers handle the leasing of parking in different ways, the cost of building parking is incorporated into the costs that all tenants pay in rent – whether they use it or not.

Table 2 below identifies Borough President Reynoso’s modifications in red, bolded text.

Table 3 below compares DCP’s proposal and Borough President Reynoso’s proposal across Inner and Outer Transit Zones and outlines Borough President Reynoso’s proposal for Core Transit Zones.

These are only a selection of Borough President Reynoso’s priorities and proposals. To read the Borough President’s public review recommendation in full, please find the document HERE.

In October 2023, Borough President Reynoso released “The Comprehensive Plan for Brooklyn,” a vision to address the borough’s dual crises of housing and public health through land use, policy, and budgetary recommendations. The Plan for equitable growth is based on a comprehensive analysis of boroughwide data and information and contains over 100 maps visualizing inequities in everything from housing production to life expectancy. The Plan is not a rezoning proposal but is used by the Borough President to guide land use recommendations and decision-making. The Comprehensive Plan for Brooklyn is the first borough-specific large-scale planning effort ever in NYC and a model for planning citywide. Read the full Comprehensive Plan for Brooklyn HERE.


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