Introduction
New York City's current land use process was established through the 1989 Charter Revision.
The revisions made significant improvements to the prior structure, which heavily empowered
the Board of Estimate to dictate the City's land use actions. The 1989 revision significantly
increased the small-d democratic oversight of land use decisions by placing veto power with the
City Council. However, with 30 years of hindsight, .it is clear that significant shortfalls are
present within the process. Fundamentally, the current regime is one of approval/disapproval of
individual actions, lacking a mechanism to engage in long-term, holistic, rational urban planning.
Furthermore, the practice of member deference has made it difficult for the City to address
citywide needs in a fair and equitable manner. We are also witnessing a heightened level of
conscientiousness and distrust around the land use process at a time when we are facing some of
the greatest development challenges in a generation.
New York City is unusual in that it does not require some form of a long-term plan to guide the
City's development and address its future needs. It is increasingly clear that we cannot meet the
significant challenges the City faces without engaging in true long-term planning. A
comprehensive plan will require the transparency, accountability, equity, and predictability that
is currently lacking in the current land use process. Additionally, comprehensive planning will
disincenti vize the parochialism that has penetrated the current process and encourage a rational
approach based on community engagement and data analysis. Requiring the City of New York to
develop a comprehensive plan will reform our land use process for the better, ensuring that our
decisions are not driven by politics, but rather a commitment to fairness and informed decision
making. The process proposed in this document is a fundamental reorientation of our land use
process away from reactionary measures and towards long-term, needs-based and fair share
urban planning.

Current Challenges
There are no shortage of planning and development challenges facing New York City. These
challenges are shared by numerous constituencies; communities feel unfairly targeted by land
use actions and distrust the process; developers have little ability to predict if a given project will
ultimately be approved; the City lacks a framework through which to plan for and meet its long
term needs. Below are failures of the current system that can be addressed through a
comprehensive plan:
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The affordability crisis causing residential displacement across the city;
An urgent need to focus on sustainability and resilience in the face of sea level rise &
climate change;
Aging infrastructure and no meaningful long-term planning for investment;
Inequitable growth resulting in persistent socioeconomic and racial inequality and
segregation
A broken Fair Share system where resources and facilities are unevenly distributed
throughout the City, with no process to redistribute (for the purposes of equity and
fairness) over time;

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Lack of strategic, proactive planning resulting in neighborhood rezonings that leave
communities feeling targeted, frustrated, and fatigued;
Lack of overarching public framework driving land use decisions;
A reactive, exclusive ULURP process that shuts residents out of the process until it is too
late to affect decisions;
Community benefit commitments resulting from rezonings that are difficult to enforce;
Processes for evaluating and approving proposed development projects that are timeconsuming, expensive, arcane and inefficient.

Why is action required through Charter Revision?
While a number of components of this proposal could be achieved through legislative action, it
cannot be accomplished in its entirety and much of its usefulness and intent would be lost
through a piecemeal approach. The following outlines the most critical components of the
proposed comprehensive planning process that must be included in the Charter:
• A comprehensive planning mandate that aligns with principles of equity and fairness,
responsive and proactive planning, inclusiveness, sustainability and resilience,
transparency and accountability.
• Reorganization of planning responsibilities among the various agencies and Mayor's
office.
• A robust and proactive community engagement process.
• A mandated Equity Assessment that must be completed once every 10 years, including a
citywide Displacement Risk Index and Access to Opportunity Index that will inform
community decisions about growth and development for the decade.
• Incorporating the capital budget into the comprehensive planning process.

Comprehensive Planning Mandate:
The City will be required to put together a comprehensive plan every 10 years in accordance
with the following principles:
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Equity and Fairness
Affordability
Responsive and Proactive planning
Inclusiveness
Sustainability and Resilience
Transparency and Accountability

Steps of Comprehensive Planning
To be effective in both its planning and goal setting stages up to implementation, a city-wide
long term comprehensive plan should include the following five steps.
1. Analyzing Existing Conditions & Citywide Goals
2. Establishing Community District Goals
3. Creating Draft Scenario Plans
4. Publishing a final IO-Year Comprehensive Plan with Associated GEIS
5. Incentivizing Rezonings that Comply with the Plan
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 Step 1: Existing Conditions & Citywide Goals
Goal: To analyze city conditions, including existing plans and recent rezonings, to better
understand current trends in the City, identify critical capital investments and project the City's
future growth and needs, informed by data and community engagement.
Key Actors: Mayoral Office, Community Boards, General Public
Timing: This analysis should be synced with the Census process, to ensure the City has access to
the most up-to-date data. The entirety of phase one should be completed within 12 months.
lA. Community District Needs: The Charter would require and standardize the process
and contents of a Community Board's Needs Statement. Under this new process, a
Mayoral office would create a standard survey, including both qualitative and
quantitative questions for Community Boards to submit. Their response should also
include public input, informed by Community Board meetings in which the public is
invited to provide input and testify on local needs.

The Community Board would vote to adopt this District Needs statement and submit that
statement to the Mayoral office.
18. Assessing NYC's Alignment with Principles: A Mayoral office, in collaboration
with City Agencies, would be tasked with doing an initial analysis of existing conditions
which would include an assessment of critical indicators at the Citywide and Community
Board level. In this process, the Charter should require this Mayoral office to complete an
Assessment of NYC's Alignment with the Principles which shall include an
assessment of:
• Equity and Fairness
• Affordability
• Inclusiveness
• Sustainability and Resilience

That assessment should also include:
• A Displacement Risk Index, with consideration of the following
indicators: people of color, linguistic isolation, housing tenancy, housing
cost-burden, educational attainment, proximity to transit, median rent,
development capacity, proximity to civic infrastructure, proximity to highincome neighborhoods, among other factors;
• An Access to Opportunity Index, with consideration of the following
indicators: school performance, graduation rate, access to college or
university, proximity to employment, property appreciation, proximity to a
location that sells produce, proximity to a healthcare facility, proximity to
transit, among other factors.
1C. Identifying Current & Future Needs: Following this assessment of existing
conditions, the Mayoral office would be tasked with identifying key challenges in the
current system and future projected needs. This would include but not be limited to:
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Key challenges that a 10-year comprehensive plan would seek to address;
Citywide population and job projections;
Citywide targets for accommodating population and job projections,
including affordable housing units and school seats;
Infrastructure investments required to bring communities up to an
appropriate level of service;
Infrastructure investments required to support growth;

lD. Feedback on Draft Existing Conditions: The Charter would require these analyses
to be released as a public draft report, followed by series of required, borough-based
information sessions and opportunities for the public to provide feedback and suggested
revisions online, in-person and in-writing.

lE. Articulation of Goals & Publication of Final Existing Conditions: The Mayoral
Office would then articulate the citywide goals for the forthcoming Comprehensive Plan.
Incorporating feedback from the public, the Mayoral office would publicize the final
existing conditions & Equity Assessment report online.
lF. Vote of the CPC & Council: The CPC should vote to approve, approve with
modifications or disapprove this document. Within 30 days, the full Council must also
vole lo approve, approve with modifications or disapprove this document.

Step 2: Establishing Community District Goals
Goal: In collaboration a new Steering Committee, a Mayoral Office would establish targets for
growth, investment, and fair share at Community District level.
Key Actors: Mayoral Office, Steering Committee
Timing: This phase should take 6 months to complete.
2A. Steering Committee: Informed by the key challenges identified in the Existing
Conditions and Equity Assessment report, a Steering Committee would be appointed to
provide initial feedback on the process moving forward. The Charter would require a
Steering Committee of at least 15 members, appointed by the Chair of the CPC and
approved by a¾ supermajority of the CPC.
28. Methodology & Community District-level Targets: In collaboration with the
Steering Committee and City Agencies, a Mayoral Office should define a method for
how to set neighborhood-specific goals, which should include, but not be limited to:
• Existing conditions
• Principles (displacement risk & access to opportunity)
• Fair Share, with respect to facility sitings specifically
• Recent development & rezonings
• Market conditions / demand
• Community Board Needs Stateme nts

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 Using this methodology, the Mayoral office will set 10-year community district targets
for the following (no map):
• Affordable Housing, including depth of affordability
• Jobs
• City Facilities, as defined by Fair Share (e.g. parks, libraries, shelters)
• School seats
• Infrastructure investments necessary to bring existing conditions up to
appropriate levels of service
• Infrastructure investments necessary to accommodate proposed growth
2C. Steering Committee Review: Prior to making these goals public, the targets must be
approved by a vote of the Steering Committee.
Step 3: Draft Scenario Plans

Goal: Based on the analysis and feedback gathered in Phase 2, develop a Community District
level map that describes specific goals for growth and investments.
Key Actors: Mayoral Office, Department of City Planning, Community Boards, General
Public Timing: This phase should take 12 months to complete.
3A. DCP generates and presents a number of potential scenarios for meeting a districts'
goals.
• This could encompass facility sitings in a number of different locations,
transit oriented growth along different train lines, etc.
38. A round of community engagement is done to establish preference for a given
scenario, a blend of the given options, or an alternative.
• Engagement here should be done with both the CBs, as it pertains to their
District Needs Statement, as well as the broader community. CB meetings,
large public meetings, etc.
• Critical that quality informational materials are available at this step to
illustrate the precise outcomes of a given scenario.
JC. Draft 10-year capital plan: In conjunction with the draft scenario plans, the City
will develop its I 0-year capital budget. The capital budget must account for potential
needs associated with the implementation of the various draft scenarios (schools, parks,
etc.) This will likely require the development of multiple capital plan scenarios to
respond to the various draft plans, giving communities the opportunity to more fully
understand the potential capital dollars associated with each draft scenario.
3D. Community Board Vote on preferred scenario and finalization of the ten-year
capital plan. This should be done at a public meeting in which members of the General
Public should be given the opportunity to speak. Lots of public meeting notice
requirements.

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 Step 4: Submit Final 10-Year Comprehensive Plan with Associated GEIS for Public
Review
Goal: Prepare a Generic Environmental Impact Statement (GEIS) and publish final
comprehensive plan
Key Actors: Mayor's Office
Timing: 12 month GEIS process
4a-- GEIS for Preferred Scenario Preferred Scenario (now called "Comprehensive
Plan") goes through a Generic Environmental Impact process (DGEIS, etc.)
4b-- Community engagement Public hearings and comment periods on GEIS
4c-- Comprehensive Plan goes through ULURP process, final approval by City
Council
4d--Issuance of final Comprehensive Plan with companion capital budget. Plan should
be available online. Future rezonings that align with the comprehensive plan benefit from
the GEIS and only supply supplemental/technical memos as necessary.
Step 5: Incentivizing Rezonings that Comply with the Plan
Goal: Implementation of the I0-year Comprehensive Plan
Key Actors: Cily Planning Commission, Deparlmenl of Cily Planning, Communily Boards,
Borough Presidents, Council Members & Private Developers
Timing: Ongoing of subsequent Comprehensive Plan
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Upon filing documents with the Department of City Planning, the applicant is required to
submit documents defining how the rezoning action does or does not comply with the
comprehensive plan.
Upon certification, the City Planning Commission shall certify compliance or noncompliance with the Comprehensive plan.
If the applicant is in compliance, they need only submit any required supplemental
environmental review analysis .

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If the rezoning action does not comply, the application will go through ULURP as
written currently in the Charter. (Note: If the rezoning action does not comply, and they
did not submit a full Environmental Review Statement, they will need to complete a full
EIS prior to certification.)
If the application does comply, it will be subject to the following expedited process:
o The application is sent to the City Council, Community Board and Borough
President upon certification.
o The Community Board and Borough President would have the option to hold a
public hearing and notify the public within 30 days (total/simultaneous, not oneafter-the-other) of receiving the application.
o If either the Borough President or Community Board hold a public hearing, they
may submit recommendations directly to the City Council and CPC.
o The CPC will approve, modify or disapprove the application within 30 days.

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The City Council member(s) that represents the district in which the rezoning
would be applied can initiate a "call up" within 30 days of receiving the CPC's
decision. A call-up would require:
• An analysis that is made available to the public, describing how the
rezoning action either does not comply with the comprehensive plan, or
making the case for why the comprehensive plan no longer meets the
needs of the community.
• Approval from at least l l members of the Land Use Committee including
the Chair of the Land Use Committee.
Upon a call-up, the City Council would have 30 days to hold a hearing and vote
to approve, approve with modifications or disapprove.
If the Council does not act, the CPC decision would be made final.

Conclusion:
The Charter Revision Commission convened by the New York City Council provides a once in a
generation opportunity to bring meaningful reform to our City's land use process. However, it is
not enough to simply reform a broken process • we must reimagine what urban planning looks
like in our City. This proposal does not seek to create policy, but rather a process through which
policy can be developed in an equitable, thoughtful, and efficient way. It is critical that we seize
this moment to embed in our City's constitution principles and processes that will aid us in
meeting the significant planning challenges we face. Our current mechanisms for addressing the
housing crisis, rising seas, overcrowded schools, and a broken transportation system are
insufficient. A comprehensive plan is a significant undertaking, but it is also the only way we as
New Yorkers can address our City's many needs in a holistic, cohesive, equitable way. s. We
strongly encourage the Charter Commission to adopt this Comprehensive Planning proposal.

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