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TESTIMONY
Testimony by Hope Cohen on reforming the city's environmental review process (CEQR)
2:50:05
·
3 min
Hope Cohen, former Manhattan Community Board 7 member, proposes reforms to make the city's environmental review (CEQR) process more efficient and useful. She suggests narrowing its scope by exempting more project types (especially affordable housing reliant on public funds) and focusing reviews only on direct impacts on infrastructure and municipal services, while also addressing the lack of follow-up on required mitigations.
- Recommends expanding "Type II" exemptions to exclude more projects with minimal impact, especially affordable housing projects needing only funding approval.
- Advocates streamlining review topics to focus solely on infrastructure/service impacts.
- Highlights the need for better tracking and enforcement of mitigation commitments.
Hope Cohen
2:50:05
okay.
2:50:05
I am unmuted.
2:50:06
Hi.
2:50:07
As you heard, my name is Hope Cohen.
2:50:10
Thank you for the time, members of the commission.
2:50:14
I'm here to offer some ideas about making the New York City environmental review process known as SEEKR more efficient, less expensive, and more useful.
2:50:28
In twenty o seven, I published these ideas in Rethinking Environmental Review, a handbook on what to be done, a link to which I can provide upon request.
2:50:39
Charter section one ninety two e assigns to the city planning commission responsibility for rulemaking regarding environmental reviews.
2:50:46
You, the Charter Revision Commission, may choose to leave all as is, to assign the responsibility to a different entity, or through amendment to the Charter, to impose guidance that supersedes CPC's authority.
2:51:01
Over the decades, environmental reviews have become big business for lawyers and specialized professionals.
2:51:07
All too often, environmental impact statements and even the less detailed environmental assessments range well beyond analysis of impacts on the natural environment, infrastructure or municipal services.
2:51:20
They are protection against litigation rather than true planning documents.
2:51:24
We should be using this tool to focus on projects that will require additional infrastructure and or services.
2:51:31
Currently, requirements for environmental review encompass too many projects and too many topics.
2:51:38
As the rules stand, virtually any development that involves government funding or some kind of special approval must go through the process.
2:51:46
We can filter out many of those as clearly not having any negative impact, that is by declaring them to be something we'll call type two actions.
2:51:56
These would include projects that require review only because they include government funding.
2:52:02
Otherwise, they wouldn't need it.
2:52:04
And that is a significant problem for affordable housing.
2:52:07
Projects where height and or bulk are redistributed, but actually the dentist density is not increased, and very small residential projects that clearly would not increase demands on infrastructure.
2:52:21
It is entirely within the city's power to do this.
2:52:25
In fact, just last year, the city took a step in the right direction by creating green fast track green fast track for housing.
2:52:32
This program defines as type two those projects that are of a certain size, use clean energy, and meet standards for citing, hazardous materials, emissions, and noise.
2:52:42
The city should also streamline the topics for review.
2:52:45
Environmental reviews need not include policy discussions or descriptions of socioeconomic conditions.
2:52:52
The review should examine only topics that implicate infrastructure and or municipal services, including those needed to protect the natural environment.
2:53:01
Finally, there is the question of whether required mitigations are actually implemented.
2:53:06
From my experience being on Manhattan Community Board seven, I know that it falls to community boards and local advocates to monitor a developer's compliance mitigation requirements.
2:53:16
Till 2018, that was the case with city sponsored rezonings as well, but now we can use the rezoning commitment extractor to check progress on promised sewage upgrades, park improvements, and advocacy.
Richard R. Buery Jr.
2:53:30
Oh, but I'm sorry to interrupt.
2:53:31
We're out of time.
2:53:32
Can you please wrap up?
Hope Cohen
2:53:34
That's it.
2:53:35
Perfect timing.
2:53:37
I'm done.