Green Fast Track for Housing Rulemaking

Good morning, Chair Garodnick and Commissioners. My name is Camille MacLean and I’m a Policy Analyst at Citizens Housing and Planning Council, an independent, nonprofit organization dedicated to the well-being of New York City’s housing stock and the residents it serves. I am delivering testimony on behalf of the organization today.

The proposed Green Fast Track rules aim to eliminate costly, time-consuming, and unnecessary procedural requirements for a category of land use actions that would enable new housing development. The proposed rules offer potential benefit to a category of small housing developments that is least able to absorb higher process costs. This is consistent with the type of process reforms that CHPC promotes through our “This is How We Do It?!” initiative to enable government to better address pressing needs and priorities.

There is a simple, reasonable premise behind this proposal: make it easier for people to do good things. This proposal combines sound, achievable standards for green buildings with accelerated administrative processing, and eliminates review that adds time and expense without better informing decision making. These changes will make at least some affordable housing development faster and less costly and doing a better job of housing more New Yorkers benefits the environment; it doesnt harm it.

At the same time, the limitations of the proposed rulemaking highlight the importance of broader legislative reforms. The system of SEQRA and CEQR stacks the deck in favor of inaction on our housing and climate crises. The limited “hacks” available to us under current statutes can be helpful at the margin but fall far short of the fixes needed if we want government to be responsive to the scale of the issues we face.

CHPC applauds the Department and the Administration for advancing this rulemaking. Continued reform in this same direction is essential if we aim to not just Get Stuff Done, but to Get Lots of Good Stuff Done.