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TESTIMONY

Michael Parley, President of Development Consulting Services, on proposed changes to Midtown and Lower Manhattan zoning regulations

6:50:47

·

3 min

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Michael Parley, president of Development Consulting Services, expresses support for the overall goals of the City of Yes for Housing Opportunity initiative but protests two specific provisions. He criticizes the lack of expansion for off-site affordable housing options and opposes changes to the Floor Area Ratio (FAR) regulations in Midtown and Lower Manhattan special districts.

  • Argues against mandating affordable housing for the 10-12 FAR increment in 12-15 FAR zones of Midtown and Lower Manhattan, calling it economically unfeasible and a potential downzoning
  • Recommends making the residential FAR a flat 12 in these areas instead of the proposed changes
  • Urges the City Planning Commission to reconsider aspects of the housing opportunity initiative
  • Supports overall goals of housing opportunity
  • Protests the lack of expansion for off-site affordable housing option
  • Opposes mandating affordable housing in 12-15 FAR zones of Midtown and Lower Manhattan Special Districts
  • Argues that mandating affordable housing in high-value areas is economically unfeasible
  • Suggests making the residential FAR a flat 12 in Midtown and Lower Manhattan
  • Urges the commission to reconsider aspects of the housing opportunity proposal

[EXPERIMENTAL]

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

  • UAP
  • Residential Conversions

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.

UAP

"The first is that the off-site affordable option is not being expanded. And where it is being preserved for as an option. It is not being it's being diminished to possible insignificance."

This quote discusses the affordability aspect of the proposal, which is related to the Universal Affordability Preference (UAP). The speaker is criticizing changes to affordable housing options, which is a key component of the UAP.

"It is unclear in the text whether you affordable must be on-site or can be off-site. But either way, it is clear that this is very misguided."

This quote directly addresses the affordability component of the proposal, discussing on-site vs off-site affordable housing options, which is related to the UAP element.

"It is clearly uneconomic to mandate affordable housing where land prices are already stratosphere."

This quote criticizes the economic feasibility of mandating affordable housing in high-cost areas, which is a key aspect of the UAP proposal.

Residential Conversions

"I support the overall goals of housing opportunity and applaud the effort to generate more affordable housing expand opportunities for office conversions, and advance numerous changes which can facilitate building in New York."

This quote directly mentions 'office conversions', which is a key aspect of the Residential Conversions element of the proposal.


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?
Michael Parley
6:50:47
Let us begin.
6:50:49
My name is Michael Parley.
6:50:50
I'm the president of development consulting services, a consulting firm in New York City advising developers architects, and institutions on the workings of the zoning resolution.
6:51:01
Some of my comments today relate to the Midtown Special District, I have special expertise in that since I was the principal drafter of these regulations in 1980 to 81 when I worked for this agency.
6:51:15
I support the overall goals of housing opportunity and applaud the effort to generate more affordable housing expand opportunities for office conversions, and advance numerous changes which can facilitate building in New York.
6:51:28
However, my comments today at length are are to protest 2 ill advised and self defeating provisions.
6:51:35
The first is that the off-site affordable option is not being expanded.
6:51:40
And where it is being preserved for as an option.
6:51:44
It is not being it's being diminished to possible insignificance.
6:51:50
This is absolutely not in the city's interest.
6:51:53
Others will and have spoken about this more fully.
6:51:56
The second proposed provision would mandate that in the 12 to 15 FIR zones of the special Midtown And Special Lower Manhattan Districts that the increment of residential dues from 10 to 12 FAR will be by the provision of affordable housing, changing from the current mechanism, which permits the 10 to 12 f a r increase by providing residents' recreation space.
6:52:21
It is unclear in the text whether you affordable must be on-site or can be off-site.
6:52:26
But either way, it is clear that this is very misguided.
6:52:30
Number 1, it is a downzoning when we should be upzoning given our NIFA housing.
6:52:35
It is clearly uneconomic to mandate affordable housing where land prices are already stratosphere.
6:52:41
Particularly without any economic analyses to validate this.
6:52:45
And 3, because the 2 FER of affordable housing will predictably not be provided more resident nonresidential use will be required to fill the gap between 1015 f a r, contrary to corrections occurring in the office market today.
6:53:01
The residual 5 FAR of commercial use is not enough to be a critical mass for office, too much for retail, and undesirable for hotels since the commission prohibited them, they got by special permit.
6:53:15
In 1981, we originally wanted to make the SAR for residential, a flat 12.
6:53:21
Late in the drafting of the Midtown Tech, someone suggested an innocuous and cost free basis to get from 10 to 12, and that was the recreation space.
6:53:30
My re my recommendation is to now make the residential f a r a flat well in Midtown And Lower Manhattan, and I urge the commission to rethink its position on of aspects of the housing opportunity.
6:53:47
Thank you.

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