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TESTIMONY

Lucie Levine from the Historic District Council on the City of Yes for Housing Opportunity (COYHO) proposal's impact on historic neighborhoods

10:33:38

·

3 min

Report an issue

Lucie Levine, representing the Historic District Council (HDC), provides testimony on the City of Yes for Housing Opportunity (COYHO) proposal. She outlines HDC's support for certain aspects of the proposal, expresses concerns about others, and states opposition to some elements, particularly focusing on the impact on historic neighborhoods and affordable housing.

  • Supports relegalizing shared and supportive housing, Town Center zoning, and commercial to residential conversion
  • Expresses concerns about accessory dwelling units, transferable development rights, and streamlining of special district regulations
  • Opposes the lack of affordable housing requirements and potential loss of public oversight in development projects
  • COYHO will have a significant impact on historic neighborhoods and districts
  • Concerns about creating market-rate and luxury housing while incentivizing demolition of historic neighborhoods
  • Support for relegalizing shared and supportive housing, Town Center zoning, and commercial to residential conversion
  • Support with caveats for accessory dwelling units and expanded transferable development rights
  • Opposition to the lack of affordable housing requirements in COYHO
  • Concerns about streamlining regulations and removing public oversight
  • Need to address loss of affordable housing through building combination, unit warehousing, and 'big footing'
  • Suggestion to include historic preservation as a tool for housing opportunity
  • Historic districts retain rent-subsidized units at a higher rate than non-designated areas

[EXPERIMENTAL]

Which elements of City of Yes for Housing Opportunity were discussed in this testimony?

  • Residential Conversions
  • Town Center Zoning
  • ADU
  • Campuses
  • Small and Shared Housing

The following are AI-extracted quotes and reasoning about which elements of the proposal were discussed in this testimony.

This is a quick, close approximation. Occasionally, the connection between a testimony's transcript and specific elements of City Planning's proposal is tenuous.

Read about this AI-generated analysis here.

Residential Conversions

"We also strongly support commercial to residential conversion and adaptive reuse citywide aligning COYHO with financial incentives like historic tax credits will allow property owners to maximize funding for conversion and restoration."

This quote explicitly mentions support for commercial to residential conversions, which is a key aspect of the Residential Conversions element of the proposal.

Town Center Zoning

"We also endorse Town Center zoning"

This quote directly mentions and endorses the Town Center Zoning element of the proposal.

ADU

"HTC supports accessory dwelling units, but seeks confirmation from the Landmark's preservation commission that they will have jurisdiction over ADU design and placement in his districts and on landmark sites."

This quote directly mentions accessory dwelling units (ADUs) and expresses support for them with a caveat about preservation in historic districts.

Campuses

"We are not opposed to infill on major campuses, but we believe that any new housing on public lands should be 100% affordable and prioritize the voices of nicer residents."

This quote discusses the Campuses element of the proposal, expressing conditional support for infill development on campuses with a focus on affordability and community input.

Small and Shared Housing

"HCC supports relegalizing existing typologies such as shared and supportive housing."

This quote directly addresses the Small and Shared Housing element of the proposal by expressing support for relegalizing shared housing typologies.


About this analysis:

This analysis is done by AI that reasons whether or not a quote from the testimony discusses a particular element of the proposal.

All the prompts and data are open and available on Github.

You can search for testimonies that mentioned a specific element in the table on the main meeting page.

When an element is explicitly stated in the testimony (e.g. "Universal Affordability Preference" or "UAP"), the analysis is accurate.

But the connection between a quote from the testimony and an element of the proposal is sometimes implicit.

In these cases, the AI might eagerly label a testimony as discussing a proposal when the connection is tenuous, or it might omit it entirely.

↗ Why are there transcription and diarization errors?
Lucie Levine
10:33:38
Hi.
10:33:39
Okay.
10:33:40
Mike is on.
10:33:40
Hello, everybody.
10:33:41
Thanks for being here.
10:33:42
So late.
10:33:44
My name is Lucy Levine.
10:33:45
I'm speaking on behalf of the Historic District Council.
10:33:47
We've submitted in-depth comments on City of Yes for Housing Opportunity.
10:33:51
And I brought copies of our full testimony, which is also available on our website athgc.org.
10:33:56
What follows is our abbreviated testimony.
10:33:59
Of all three city of yes proposals, COYHO, will have the greatest impact on New York's historic neighborhoods and historic districts.
10:34:06
HCC supports some pieces of the proposal but fears that COYH Joe will create a glut of market rate in luxury housing while incentivizing demolition of historic neighborhoods and replacement of existing affordable and regulated housing with denser and less affordable housing.
10:34:21
First, some things we support.
10:34:23
HCC supports relegalizing existing typologies such as shared and supportive housing.
10:34:28
We also endorse Town Center zoning and we strongly support commercial to residential conversion and adaptive reuse citywide aligning COYHO with financial incentives like historic tax credits will allow property owners to maximize funding for conversion and restoration.
10:34:45
2nd, some things we support with caveats and concerns HTC supports accessory dwelling units, but seeks confirmation from the Landmark's preservation commission that they will have jurisdiction over ADU design and placement in his districts and on landmark sites.
10:35:00
HCC supports expanded transferable development rights for individual landmarks, but is concerned that zoning lot mergers could allow TBRs to be transferred further than COYHO proposals.
10:35:11
We are concerned that COYHO's effort to streamlined special districts regulations, will compromise the character of special districts, and in cases like Hudson Square special districts, may incentivize demolition of rent regulated housing.
10:35:25
We are not opposed to infill on major campuses, but we believe that any new housing on public lands should be 100% affordable and prioritize the voices of nicer residents.
10:35:36
Things HTC opposes.
10:35:38
HCC decries the fact that COYHO does not require any affordable housing.
10:35:43
Luxury housing won't solve the housing crisis it will lead to the loss of more affordable units.
10:35:48
The city must require affordable housing.
10:35:51
HCC is also seriously concerned that COYHO's efforts streamlined housing development regulations will remove these projects from public oversight, items which are not addressed in COI show.
10:36:02
The city is losing affordable housing through building combination, affordable unit warehousing, and big footing, a term coined by planning expert George James to describe the trend of demolishing smaller buildings with rent regulated housing for much larger luxury buildings with fewer units.
10:36:17
COYHO must address this.
10:36:19
COHOs also incentivized restoration of underutilized units by expanding programs like the unlocking doors pilot.
10:36:27
Finally, HDC's 2016 report on affordable housing and historic districts demonstrated that rent subsidized units remain within historic districts at a higher rate than outside them.
10:36:37
Therefore, the city risks losing much of its rent regulated historical portable housing simply because it's not designated.
10:36:43
We urge DCP to include historic preservation as a tool for housing opportunity.
10:36:48
Thank you.

Follow-up discussion/remarks

QUESTION

Commissioner Douek clarifies affordable housing requirements in City of Yes proposal

10:36:49

·

3 min

Commissioner Joseph Douek addresses concerns raised by Lucie Levine of the Historic District Council regarding affordable housing requirements in the City of Yes for Housing Opportunity proposal. He explains that while the Universal Affordability Preference (UAP) is voluntary, it incentivizes developers to create 100% affordable housing for additional floor area ratio (FAR).

  • Douek emphasizes that the proposal does not upzone areas, but allows developers to opt-in for additional FAR if they make it 100% affordable
  • Levine expresses concern that developers may not take advantage of the voluntary incentive
  • Douek mentions that mandatory inclusionary housing already exists for certain upzonings, and that coupling the proposal with state incentives like 485-a creates strong motivation for affordable housing development
  • COYHO will have a significant impact on historic neighborhoods and districts
  • Concerns about creating market-rate and luxury housing while incentivizing demolition of historic neighborhoods
  • Support for relegalizing shared and supportive housing, Town Center zoning, and commercial to residential conversion
  • Support with caveats for accessory dwelling units and expanded transferable development rights
  • Opposition to the lack of affordable housing requirements in COYHO
  • Concerns about streamlining regulations and removing public oversight
  • Need to address loss of affordable housing through building combination, unit warehousing, and 'big footing'
  • Suggestion to include historic preservation as a tool for housing opportunity
  • Historic districts retain rent-subsidized units at a higher rate than non-designated areas

[EXPERIMENTAL]

Which elements of City of Yes for Housing Opportunity were discussed in this testimony?

  • Residential Conversions
  • Town Center Zoning
  • ADU
  • Campuses
  • Small and Shared Housing

The following are AI-extracted quotes and reasoning about which elements of the proposal were discussed in this testimony.

This is a quick, close approximation. Occasionally, the connection between a testimony's transcript and specific elements of City Planning's proposal is tenuous.

Read about this AI-generated analysis here.

Residential Conversions

"We also strongly support commercial to residential conversion and adaptive reuse citywide aligning COYHO with financial incentives like historic tax credits will allow property owners to maximize funding for conversion and restoration."

This quote explicitly mentions support for commercial to residential conversions, which is a key aspect of the Residential Conversions element of the proposal.

Town Center Zoning

"We also endorse Town Center zoning"

This quote directly mentions and endorses the Town Center Zoning element of the proposal.

ADU

"HTC supports accessory dwelling units, but seeks confirmation from the Landmark's preservation commission that they will have jurisdiction over ADU design and placement in his districts and on landmark sites."

This quote directly mentions accessory dwelling units (ADUs) and expresses support for them with a caveat about preservation in historic districts.

Campuses

"We are not opposed to infill on major campuses, but we believe that any new housing on public lands should be 100% affordable and prioritize the voices of nicer residents."

This quote discusses the Campuses element of the proposal, expressing conditional support for infill development on campuses with a focus on affordability and community input.

Small and Shared Housing

"HCC supports relegalizing existing typologies such as shared and supportive housing."

This quote directly addresses the Small and Shared Housing element of the proposal by expressing support for relegalizing shared housing typologies.


About this analysis:

This analysis is done by AI that reasons whether or not a quote from the testimony discusses a particular element of the proposal.

All the prompts and data are open and available on Github.

You can search for testimonies that mentioned a specific element in the table on the main meeting page.

When an element is explicitly stated in the testimony (e.g. "Universal Affordability Preference" or "UAP"), the analysis is accurate.

But the connection between a quote from the testimony and an element of the proposal is sometimes implicit.

In these cases, the AI might eagerly label a testimony as discussing a proposal when the connection is tenuous, or it might omit it entirely.

↗ Why are there transcription and diarization errors?
Dan Garodnick
10:36:49
Don't don't go anywhere.
10:36:50
Okay.
10:36:50
Commissioner, do I have a question?
Joseph Douek
10:36:52
I think more of a statement, I just want to clarify.
10:36:56
You mentioned that there's no requirement for affordable housing.
Gail Benjamin
10:37:00
I think
Joseph Douek
10:37:01
the main driver for building or development under this program would probably be the UAP, and that requires that every additional foot of SAR is 100% affordable in perpetuity.
10:37:15
So there is a component built in that provides for affordable housing.
Lucie Levine
10:37:20
But it's voluntary.
10:37:21
And so because FAR has already been lifted, we don't feel that the sort of voluntary ability to get higher FAR when FAR has already been left listed.
Joel Siegel
10:37:33
Exactly.
10:37:34
On FAR.
10:37:35
So just to
Joseph Douek
10:37:37
I would say clarify.
10:37:38
FAR is not being listed.
10:37:40
The it's voluntarily it's up to the developer or the builder or the owner to build the extra foot FAR.
10:37:50
And if they do so, it has to be 100% affordable.
10:37:54
We're not upzoning any Right.
10:37:56
At our
Lucie Levine
10:37:56
point is that it's up to them, and we believe it should be mandatory as others have said.
10:38:03
So, again, the the fact that developers can opt in I would love for every developer in the city of New York to opt fully in and this this city to have as much affordable housing as the city needs.
David West
10:38:16
So that
Lucie Levine
10:38:16
is But
10:38:16
we are
10:38:17
afraid that they will not.
10:38:18
And so we we wish that the city would mandate it.
Joseph Douek
10:38:20
And we would also I believe I would I could speak for myself.
10:38:23
I would love to see everyone opt in on the affordable option.
10:38:27
But we can't mandate that as a matter of law from my understanding that they take their private land and build affordable housing.
10:38:34
However, we did put in place in 2017.
10:38:37
I had the honor of being on this commission at the time.
10:38:39
Mandatory and
10:38:40
inclusionary housing, which requires every up zoning to have a every up zoning over a certain threshold to be mapped mandatory inclusionary housing, which requires a component that is 100 that is portable in perpetuity.
10:38:56
So what you're asking, we actually addressed already and this proposal does address.
10:39:01
Am I speaking to the ADUs or things like that?
10:39:05
I'm speaking to the the crux of it, which would probably be the UAP proposal.
10:39:09
It does require everything to be affordable.
10:39:11
It is voluntary because we cannot force a private landowner to build or not to build.
10:39:16
We cannot force them to do it.
10:39:17
It's private land.
10:39:18
It's privately owned.
10:39:19
But if they do build, we've created an incentive them to build 100% affordable in perpetuity and probably in aligns well with other state programs.
10:39:29
I just wanted to clarify that that too.
Lucie Levine
10:39:32
Great.
10:39:32
And we're afraid they won't take that incentive.
10:39:35
And so I agree with you that zoning might not be able to mandate that, and so that's City Council issue.
10:39:40
And so that's that's another issue.
10:39:43
We just have the fear that they won't voluntarily take that opportunity.
Joseph Douek
10:39:49
So the state has thought about that, and I think the state has come out with I'm familiar with the new 485 accent.
10:39:57
Coupled with what we're proposing or what is being proposed to us that creates a tremendous incentive for any developer to create that affordable housing without having to mandate them, which we cannot legally do.
Dan Garodnick
10:40:13
Okay.
10:40:14
Thank you.
REMARKS

Chair Garodnick clarifies affordability requirements in City of Yes for Housing Opportunity

10:40:15

·

20 sec

Chair Dan Garodnick of the City Planning Commission addresses concerns about affordable housing requirements in the City of Yes for Housing Opportunity proposal. He emphasizes that additional floor area ratio (FAR) is only available for 100% affordable housing projects.

  • No extra FAR is granted for non-affordable housing developments
  • The City Council cannot override this requirement
  • This clarification is made in response to testimony from the Historic District Council
  • COYHO will have a significant impact on historic neighborhoods and districts
  • Concerns about creating market-rate and luxury housing while incentivizing demolition of historic neighborhoods
  • Support for relegalizing shared and supportive housing, Town Center zoning, and commercial to residential conversion
  • Support with caveats for accessory dwelling units and expanded transferable development rights
  • Opposition to the lack of affordable housing requirements in COYHO
  • Concerns about streamlining regulations and removing public oversight
  • Need to address loss of affordable housing through building combination, unit warehousing, and 'big footing'
  • Suggestion to include historic preservation as a tool for housing opportunity
  • Historic districts retain rent-subsidized units at a higher rate than non-designated areas

[EXPERIMENTAL]

Which elements of City of Yes for Housing Opportunity were discussed in this testimony?

  • Residential Conversions
  • Town Center Zoning
  • ADU
  • Campuses
  • Small and Shared Housing

The following are AI-extracted quotes and reasoning about which elements of the proposal were discussed in this testimony.

This is a quick, close approximation. Occasionally, the connection between a testimony's transcript and specific elements of City Planning's proposal is tenuous.

Read about this AI-generated analysis here.

Residential Conversions

"We also strongly support commercial to residential conversion and adaptive reuse citywide aligning COYHO with financial incentives like historic tax credits will allow property owners to maximize funding for conversion and restoration."

This quote explicitly mentions support for commercial to residential conversions, which is a key aspect of the Residential Conversions element of the proposal.

Town Center Zoning

"We also endorse Town Center zoning"

This quote directly mentions and endorses the Town Center Zoning element of the proposal.

ADU

"HTC supports accessory dwelling units, but seeks confirmation from the Landmark's preservation commission that they will have jurisdiction over ADU design and placement in his districts and on landmark sites."

This quote directly mentions accessory dwelling units (ADUs) and expresses support for them with a caveat about preservation in historic districts.

Campuses

"We are not opposed to infill on major campuses, but we believe that any new housing on public lands should be 100% affordable and prioritize the voices of nicer residents."

This quote discusses the Campuses element of the proposal, expressing conditional support for infill development on campuses with a focus on affordability and community input.

Small and Shared Housing

"HCC supports relegalizing existing typologies such as shared and supportive housing."

This quote directly addresses the Small and Shared Housing element of the proposal by expressing support for relegalizing shared housing typologies.


About this analysis:

This analysis is done by AI that reasons whether or not a quote from the testimony discusses a particular element of the proposal.

All the prompts and data are open and available on Github.

You can search for testimonies that mentioned a specific element in the table on the main meeting page.

When an element is explicitly stated in the testimony (e.g. "Universal Affordability Preference" or "UAP"), the analysis is accurate.

But the connection between a quote from the testimony and an element of the proposal is sometimes implicit.

In these cases, the AI might eagerly label a testimony as discussing a proposal when the connection is tenuous, or it might omit it entirely.

↗ Why are there transcription and diarization errors?
Dan Garodnick
10:40:15
Wait before you go.
10:40:17
I will also note that there is no extra FAR there's no additional development, right, if it is not affordable.
10:40:25
So in a scenario in which you are not providing 100% affordable, there's no extra FRA are available to you.
10:40:31
So I think that that's the point and the city council can't do it either.
10:40:35
Just let me go to commissioner Sorio.
QUESTION

Commissioner Osorio seeks clarification on UAP and affordable housing concerns

10:40:35

·

3 min

Commissioner Juan Camilo Osorio asks Lucie Levine from the Historic District Council to clarify her concerns about the Universal Affordability Preference (UAP) and potential scenarios where developers might choose options that increase Floor Area Ratio (FAR) without including affordable housing components.

  • Levine expresses fear that market-rate or luxury housing alone will not solve the housing crisis
  • She emphasizes the need for truly affordable housing at lower AMI bands and 100% affordable housing on public lands
  • Levine advocates for adaptive reuse of historic structures citywide, coupled with historic tax credits to maximize funding for larger housing structures and deeper affordability
  • COYHO will have a significant impact on historic neighborhoods and districts
  • Concerns about creating market-rate and luxury housing while incentivizing demolition of historic neighborhoods
  • Support for relegalizing shared and supportive housing, Town Center zoning, and commercial to residential conversion
  • Support with caveats for accessory dwelling units and expanded transferable development rights
  • Opposition to the lack of affordable housing requirements in COYHO
  • Concerns about streamlining regulations and removing public oversight
  • Need to address loss of affordable housing through building combination, unit warehousing, and 'big footing'
  • Suggestion to include historic preservation as a tool for housing opportunity
  • Historic districts retain rent-subsidized units at a higher rate than non-designated areas

[EXPERIMENTAL]

Which elements of City of Yes for Housing Opportunity were discussed in this testimony?

  • Residential Conversions
  • Town Center Zoning
  • ADU
  • Campuses
  • Small and Shared Housing

The following are AI-extracted quotes and reasoning about which elements of the proposal were discussed in this testimony.

This is a quick, close approximation. Occasionally, the connection between a testimony's transcript and specific elements of City Planning's proposal is tenuous.

Read about this AI-generated analysis here.

Residential Conversions

"We also strongly support commercial to residential conversion and adaptive reuse citywide aligning COYHO with financial incentives like historic tax credits will allow property owners to maximize funding for conversion and restoration."

This quote explicitly mentions support for commercial to residential conversions, which is a key aspect of the Residential Conversions element of the proposal.

Town Center Zoning

"We also endorse Town Center zoning"

This quote directly mentions and endorses the Town Center Zoning element of the proposal.

ADU

"HTC supports accessory dwelling units, but seeks confirmation from the Landmark's preservation commission that they will have jurisdiction over ADU design and placement in his districts and on landmark sites."

This quote directly mentions accessory dwelling units (ADUs) and expresses support for them with a caveat about preservation in historic districts.

Campuses

"We are not opposed to infill on major campuses, but we believe that any new housing on public lands should be 100% affordable and prioritize the voices of nicer residents."

This quote discusses the Campuses element of the proposal, expressing conditional support for infill development on campuses with a focus on affordability and community input.

Small and Shared Housing

"HCC supports relegalizing existing typologies such as shared and supportive housing."

This quote directly addresses the Small and Shared Housing element of the proposal by expressing support for relegalizing shared housing typologies.


About this analysis:

This analysis is done by AI that reasons whether or not a quote from the testimony discusses a particular element of the proposal.

All the prompts and data are open and available on Github.

You can search for testimonies that mentioned a specific element in the table on the main meeting page.

When an element is explicitly stated in the testimony (e.g. "Universal Affordability Preference" or "UAP"), the analysis is accurate.

But the connection between a quote from the testimony and an element of the proposal is sometimes implicit.

In these cases, the AI might eagerly label a testimony as discussing a proposal when the connection is tenuous, or it might omit it entirely.

↗ Why are there transcription and diarization errors?
Dan Garodnick
10:40:35
Just let me go to commissioner Sorio.
Kyle Jeremiah
10:40:37
Thank you, Jerry.
10:40:38
I just have
Juan Camilo Osorio
10:40:39
a question to understand your point.
10:40:41
Are you wondering about a scenario where you may have the choice to take on some of the incentives propose here, for example, TDR, for example, town center opportunities to increase the FAR that where a developer may could choose between the UAP option, which would require the affordable housing portion or not.
10:41:08
That what you're asking?
10:41:09
In in other words, are you thinking about a scenario where if the developer had the choice, we should require it?
Lucie Levine
10:41:19
I'm sorry.
10:41:19
Can you say that one more time?
Juan Camilo Osorio
10:41:20
Sorry.
10:41:20
I I just I I I wanted to understand a little bit this scenario that you were that you're you're posing, which is very interesting to me, because I just want to understand if your concern is that there may be opportunities to increase consolidated amount of SAR without necessarily using UAP, which is which is which would require the the affordability portion.
10:41:46
In other words, if if you can take if you can get the FER through TDR, whether you would, you know, consider or not having UAP, which which wouldn't necessarily give will give you the FCR, but not the wouldn't have the requirement for affordability.
Lucie Levine
10:42:02
Right.
10:42:03
And so that's our fear.
10:42:06
We fear that simply market rate or luxury housing will not solve the housing crisis.
10:42:12
I can speak I will say that I have been speaking for the short district council, but I'll just speak for myself now as a renter and as a New Yorker.
10:42:21
I have when I go on the housing connect website personally, I have never been able to afford what is called affordable housing.
10:42:29
Right?
10:42:30
And so when you have a situation where there is simply market rate housing being built, or there's affordable housing at bands of AMI that are too high.
10:42:45
That's something that I fear.
10:42:47
Personally, and then in terms of I'll go back to h HCC for whom I have been speaking on behalf of, but just not in that one moment.
10:42:55
We want to see a livable city.
10:43:04
And so we hope that in situations where there is contextual infills such as on metro campuses that prioritize the voices of site residents, and that that be 100% affordable.
10:43:20
We also know that there is both creation and also retention.
10:43:25
Of affordable housing.
10:43:26
So we hope that there are provisions in city it is, which we know can create and also maintain our livable city.
10:43:40
And so something that I keep saying more extremely in favor of is adaptive reuse city wide and connecting adaptive reuse of historic structures, which are generally many of which are overbuilt.
10:43:52
In terms of current SAR.
10:43:54
We connect that with historic housing credits I'm sorry.
10:44:00
Historic tax credits, we can do 2 things at once, which is with that we can maximize funding for the creation of both larger housing structures because those structures already exist.
10:44:16
And also make them more deeply affordable.
10:44:19
So that's both the goal is to maintain and create at the same time.
10:44:23
Thanks.

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