The Commission received over 300 publicly submitted Charter revision proposals, which it spent months reviewing and soliciting input on from subject area experts. The Commission staff incorporated this extensive feedback into its recommendations for which proposals to pursue, as published in the Preliminary Staff Report. CHPC weighed in on the report’s land use and planning components.
Good evening Chair Benjamin and Commissioners:
Thank you for allowing me to testify today. My name is Jessica Katz and I am the Executive Director of the Citizens Housing and Planning Council. CHPC has followed this process carefully and commends the incredibly diligent work of the Commission and its staff. Your work as a Commission has been deeply impressive, especially to the true ULURP nerds among us.
A city as huge and diverse as New York requires decision-driven land use and planning processes that balance local and citywide needs. We also need a process that is robust, transparent, and predictable. There is no process where all parties will be happy, but we can do better to ensure that all parties are heard. But I also want to point out that it is impossible to legislate consensus, and that even small changes to this process could disrupt the delicate balance ULURP was created to achieve.
You’ve heard a lot of concerns about ULURP. Communities want more information, sooner, on projects in their neighborhoods, and more time to meaningfully influence them. Any changes should directly address those concerns by advancing transparency and meaningful community engagement.
CHPC is in full support of requiring Community Boards be notified of ULURP applications prior to their certification. Building discourse and trust early on is beneficial for both applicants and communities. Local stakeholders will have more time to prepare for ULURP to begin.
However, duplicating a ULURP comment period will only add opacity, confusion, and conflict. Certification precedes ULURP so that applications reach technical compliance before undergoing public review. A community that spends time and energy commenting on an uncertified application will only encounter more frustration if it is then significantly revised to satisfy DCP feedback, especially if changes conflict with community wishes. And since residents will have only very little time to engage and participate before comments begin, the pool of voices contributing to the process will become narrower and more exclusive.
Pre-certification is different for every project. It needs to remain fluid so that the subsequent ULURP itself is clear and transparent.
In this spirit, we support an extension of the Community Board comment period from 60 to 75 days throughout the entire calendar year. Coupled with early notification, the extension will give Community Boards more time to host multiple meetings or hearings, diversifying who gets to participate and how.
How to participate- this is the critical question. The current process means that the primary form of participation is to testify at a hearing. This puts parties in opposition, instead of encouraging them to better understand one another’s wishes and constraints, ask questions, and strive for consensus. Hearings can be long, crowded, and intimidating; they amplify only the voices of those with the time and temperament to testify. Additional meetings set aside for information and discussion would engage a wider range of residents: those who want to weigh in but not to testify and those who need more information to form an opinion. They would also give evening workers and people with childcare needs more opportunities to learn about projects in their neighborhood.
CHPC is optimistic that these changes will help capture more community voices and amplify their role in land use decisions. It is our hope that outside the charter reform process, we can experiment with ways to help capture the voices and needs of those not well served by our current system, including homeless New Yorkers and the future residents of proposed housing developments. It is our responsibility to ensure a process where those needs are kept in sight.
On that note, I’d like to commend and thank the staff for focusing on proposals that clarify, streamline, and synchronize existing plans. It is only with a clear understanding of where the gaps in our current plans are that we can begin to fill them.
Our planning documents should identify local and citywide needs, goals, and priorities, along with strategies to address them on a cohesive timeline. They should set out the data and context necessary to frame and assess how individual policies, programs, and land use decisions will collectively advance our overarching vision for the city.
CHPC is happy to support the Commission and its staff in the exploration of such solutions. Thank you for your time.