On July 10, 2024, CHPC delivered testimony to the City Planning Commission at its public hearing on the City of Yes for Housing Opportunity zoning text amendment.

Read the testimony below, or download the full testimony with recommended modifications here.



Mark Ginsberg, CHPC President

Thank you for the opportunity to testify today. My name is Mark Ginsberg, and I am the President of Citizens Housing & Planning Council (CHPC) and a partner at Curtis + Ginsberg Architects, with decades of experience in the design of affordable housing.

I am here to testify in very strong support of the proposed citywide text amendments. For many years, CHPC has advocated for zoning reforms to advance affordability, fair housing, equity, sustainability, and housing quality. Our 2022 Onward and Upward report recommended many of the changes DCP has proposed today. These changes would be the biggest and most important single set of zoning reforms since 1961 and are an essential step for New York City to find a way out of our affordable housing crisis. They are, for people who rely on zoning to build housing, the best thing since sliced bread.

I’d like to highlight a couple of the most important changes:

  • The step from AIRS (Affordable Independent Residences for Seniors) to UAP (Universal Affordability Preference) is a common-sense expansion of an existing program. It isn’t an upzoning but rather a way to create a wider range of affordable housing options for different populations, including housing for seniors and multi generational groups together.
  • This proposal puts our society’s needs for housing ahead of its needs for vehicle storage. The cost of a structured parking space can add as much as $75,000 or $100,000 to the cost of an apartment! Under the proposal, we can design buildings with an amount of parking that makes sense based on the building’s program, rather than trying to find ways to make a building program work around inflexible zoning requirements.

I would like to applaud the Department for these text amendments and urge the Commission to keep the following principles in mind as you consider potential improvements to them:

  • In addition to allowing a bit more housing in every neighborhood, it’s important that we not lose any of the new housing that todays regulations would allow.
  • Keep it simple complex regulations can limit design solutions and trip up or delay projects, particularly for affordable housing.
  • We need to maintain a long-term perspective. Adequate flexibility will enable regulations to be usable in the future as unanticipated changes occuras they always doand as the demands placed on individual buildings evolve.
  • As we update zoning regulations, let’s smooth the path for existing projects to be completed. Delays in the affordable housing pipeline create challenges for the financing and staffing of projects, which can be exacerbated by the volatility of regulations and programs. The proposal can make future-oriented changes without disrupting projects already in progress.

Later today you will also hear testimony from Howard Slatkin, CHPCs Executive Director. We will share in written testimony our complete comments about the proposal and how it can be made most effective.

I urge the Commission to approve the proposed text amendments, with only those changes needed to enable them to be most effective in accomplishing their goals rather than watering them down. Thank you.



Howard Slatkin, CHPC Executive Director

My name is Howard Slatkin, and I am Executive Director of Citizens Housing and Planning Council. I am testifying in support of the proposed zoning text amendments, which are an important and sorely needed step forward for zoning in New York City.

Sixty-three years ago, the 1961 Zoning Resolution launched an era of “zoning for scarcity” by cutting the city’s housing capacity by an estimated 80 percent. Over decades, with the help of numerous downzonings, this has landed us in a persistent housing shortage.

Zoning for scarcity creates a Hunger Games of unintended consequences that hurts everyone, but most of all those who have the least. Single adults who cant find small apartments band together to occupy housing that could otherwise house families. As affluent residents stave off new housing in their neighborhoods, their children flow to nearby areas along with other housing seekers, kindling gentrification and displacement.

Under zoning for scarcity, we debate whether proposed new housing is the “right” ind of housing. We can make thoughtful choices about how subsidies and programs make housing better meet specific needs, but the only “wrong” kind of housing is no housing at all.

Today’s regulations create absurd results:

  • We have beautiful neighborhoods that are losing housing units overall because subtractions outnumber additions not because more people don’t want to live there, but because we won’t let them.
  • You can combine two units into one, but you often can’t do the opposite! A family of four can live together in a house, but if the parents separate and want the same four people to live in separate units, this may trigger impossible parking requirements or require rezoning of the whole block.
  • True story: Mrs. Velez, in her 90s, has a two-family house in the Bronxat least she bought it thinking it was a two-family housewith a downstairs unit she rents to a man who helps her with chores and groceries, and pays $800 a month in rent that supplements her Social Security income. But this is illegal, and cannot be legalized today.

The simple summary of this long, complex proposal is that it will help reverse zoning for scarcity, so that regulations better align with the housing needs of New Yorkers:

  • Softening rising rents and displacement pressures,
  • Prioritizing housing over motor vehicle storage,
  • Favoring building that provide affordable housing over those that dont,
  • Letting homeowners modify their homes to meet their needs and increase the range of housing options in their neighborhoods, and
  • Enabling the legalization of safe basement apartments, keeping tens of thousands of vulnerable people housed.

Better zoning must be accompanied by sustained public investment including the $2B in additional capital for affordable housing provided in this years final budget and by other regulatory changes that make it easier to do the right thing. But without these zoning changes, our housing crisis will only get worse.

Our written testimony details a number of important modifications the Commission should make to the proposal to enable it to best address our housing needs. These include:

  • Providing a permanent off-site option everywhere UAP applies, helping supportive housing and other 100% affordable housing get built in high-cost areas;
  • Vesting existing Inclusionary Housing development rights and housing currently in the process;
  • Closing of loopholes to ensure that the UAP floor area increase is only for affordable housing;
  • Fixing recreation space requirements to accommodate existing buildings and a wider range of good designs;
  • And several more modifications we urge the Commission to make.

Thank you for the opportunity to testify today. I will be happy to answer any questions.


Download CHPC’s full written testimony, including recommended modifications.

CHPC's testimony, delivered July 10, 2024
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