November 29, 2017
The City’s Flawed Process and Results In Planning Inwood’s Future
By Maggie Clarke, Paul Epstein, Allegra LeGrande, Cheryl Pahaham, Nancy Preston, Susanna Schaller, Philip Simpson, Maria Luisa Tasayco and David Thom
Bill de Blasio just became the first Democrat re-elected Mayor of New York City in 32 years. His first term was marked by new, progressive policies promising to make our city more equitable, including Universal Pre-K and more broadly available sick leave for many thousands more workers. But everyday New Yorkers across the city also oppose the Mayor’s housing and land use policies. Nor is his administration listening to the people who have the most to lose from rezonings integral to those policies – including the rezoning of our neighborhood, Inwood.
Instead of “community-driven” and “comprehensive” planning as promised by the Mayor, residents are being ignored, even while participating in numerous workshops and hearings. Our concrete suggestions and advice never seem to make it into the plans of City officials. Regrettably, we conclude that opportunities for public participation seem designed solely as photo opportunities.
Drawing on expertise from such fields as urban planning, law, and environmental science, we recently submitted comments on the August 2017 “Draft Scope of Work” (DSOW) related to the Inwood rezoning proposal. Our conclusion: While the rezoning is intended to catalyze housing production, it may well endanger more families with displacement than it helps, as it offers new, mostly higher-rent “affordable” units. It also will lead to small business displacement, infrastructure overload, and reduced climate change resilience.
Inwood is an economically, racially, and ethnically diverse community where locally and immigrant-owned businesses still thrive, and a high proportion of affordable housing ensures that residents of different incomes and backgrounds can live as neighbors. We value these characteristics. We also know that analogous rezoning efforts in other communities have strongly influenced their elimination.
Safeguarding and producing deeply affordable housing in line with Inwood’s income distribution is crucial, as a significant proportion of our neighbors fall below 30 percent of area median income (AMI). But adding limited affordable housing in exchange for flooding this and other neighborhoods with market-rate and luxury housing is not the solution. Inwood’s existing diversity should not be threatened by the acceleration of speculation and gentrification induced by rezoning.
The rezoning also will endanger the immigrant and independently-owned businesses that are crucial to Inwood’s economic and social infrastructure. Many of these occupy “soft sites” that can be developed on the three major connected corridors encompassing Inwood’s current commercial area. The DSOW’s estimates of soft sites on this “Commercial U” is based on an unsound methodology. Displacement of small businesses remains a perpetually under-emphasized impact of rezonings past and present.
The City’s development assumptions in the DSOW are flawed in ways that severely underestimate detrimental economic, social, and environmental impacts. For example, the rezoning would enable a build-out of 15.2 million square feet of housing across 188 tax lots. Yet the City concludes that only 33 of those lots will be redeveloped in 15 years, with only 36 percent of potential new housing built. This grossly underestimates the potential number of units and new residents the proposed rezoning will actually enable. Even a conservative 50 percent build-out will add 6,022 apartments and 16,742 more residents. That’s a 40 percent increase to the neighborhood population, which would tremendously strain infrastructure, including mass transit, water, sewer, gas, electricity, and public schools, and threaten the natural environment.
The City’s scope of work mostly extends only a quarter-mile beyond the rezoning area, which will miss broader impacts on sewage, subways, schools, and traffic. It will also overlook residential displacement not just in Inwood, but in neighboring northern Washington Heights and Marble Hill/Kingsbridge. Market pressures from over 4,800 new market rate apartments in Inwood are sure to cause rents to rise on existing apartments in all these neighborhoods, and encourage landlords to do all they can to free apartments from rent regulation. About 30 percent of rent-regulated apartments in these neighborhoods have preferential rent riders; these often little-understood lease clauses permit sharp rent increases whenever the lease is renewed. This creates high displacement risk for over 9,200 families, which the City has not recognized in its assumptions.
To fully assess the rezoning impact, the City needs better and more comprehensive data than it proposes to use. For example, to study displacement of minority-, women-, and locally owned businesses, underlying data are needed from a study of the Inwood business environment by the City’s Department of Small Business Services, as well as from the City’s Department of Finance and other agencies. For residential displacement, the City needs to account for apartments covered by preferential rent leases and also employ State data to project apartments that leave regulated status. The City appears to be using floodplain maps that don’t take into account the higher sea levels and greater flood risks expected within the next 15 years. Similarly, the City uses air quality simulations based on conditions in 2010, which won’t be valid for the impacts of climate change by 2032. Nor does the City’s energy demand analysis consider how climate change will increase the number of future cooling degree days. Finally, all such datasets must be made publicly available, so that City assumptions and assessments can be independently evaluated.
We address these and other questions in detail in our 60-page DSOW response which you can download here. We do not need land use planning experts to help us. We do need the City to engage in truly collaborative and holistic planning as it promised from the outset, with meaningful dialogue, equally exchanged.