From: "Anne Z. Whitman"
Subject: Fwd: Statement on AIA Zoning Text Amendments
To: "Jordi Reyes Montblanc" firstname.lastname@example.org
From: "Simeon Bankoff"
To: "Simeon Bankoff"
Subject: Statement on AIA Zoning Text Amendments
Date: Tue, 29 Jan 2008 19:29:46 -0500
Attached is HDC's statement on the proposed amendments to the Zoning Resolution. You can also find them at http://hdcvoice.blogspot.com/2008/01/hdc-response-to-aia-zoning-text.html
Sample letters to come tomorrow.
Historic Districts Council
232 East 11th Street
New York, NY 10003
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Tuesday, January 29, 2008
The Value of Contextual Zoning to Communities
The Zoning Resolution determines the physical height and shape of New York City by guiding development. Among the various existing zoning districts, contextual zones have been specifically drafted to produce buildings that are consistent with existing neighborhood character. In an attempt to preserve their quality of life and the scale and character of their neighborhoods, communities throughout New York City, have worked long and hard to alter their zoning appropriately. Over the past few years , due to the unprecedented development pressure affecting every neighborhood in the city, the Department of City Planning and community groups have worked together to create balanced, contextual zoning on hundreds of blocks in all five boroughs. Numerous other neighborhoods have been working, in some cases for years, to try to gain these protections.
The citywide zoning text amendments proposed by the American Institute of Architects/New York City Chapter seek to undo this hard work and revert to blanket rules that not only allow but encourage out-of-context development. One-size-fits-all, blanket zoning measures do not fit the rich variety of New York City’s neighborhoods. The Historic Districts Council is opposed to the adoption of these amendments.
Flawed Proposal Process That Circumvents Public Review
In addition to objections to individual parts of this proposal, HDC objects to the way in which these amendments have been proposed, which sought to circumvent the public review process which allow communities to have a voice in guiding development in their own neighborhoods. These amendments, which affect the majority of New York City residents and property owners, have largely gone without review at the majority of New York City’s 59 community boards and are now scheduled to consideration of adoption by the City Planning Commission.
The AIA claims that it has been working on the proposed amendments for three years, during which time many communities were working on their own rezoning campaigns and unprecedented number of blocks within the city have been rezoned. However, the first public disclosure of their effort was in late October 2007, which did not allow for the issue to be brought up at Community Board meetings until December during the holiday season. In addition to Community Boards and neighborhood organizations, elected officials have also been caught off guard by these amendments and their timetable. Only once public concern began to mount, was the initially projected an approval date of January 7th revised. Since this proposal is coming from a private organization and not the City Planning Commission, the city is not responsible for necessary educational outreach these changes require. Instead, the AIA, an industry group which represents 4,000 professionals, has taken the lead in determining the development agenda for the city.
Regardless of any possible merit of any aspect of the proposals, HDC believes that the process by which they have been proposed is flawed in the extreme and runs counter to every notion of community-based planning.
Runs Counter to City Goals for Future Development
In addition to disregarding the years of work from communities about how the people of who live in neighborhoods would like to see them thrive, these amendments also disregard and ignore many of the planning principles articulated in Mayor Bloomberg’s PlaNYC 2030. A principle tenet of the Mayor’s plan is the goal of making New York the world’s greenest city over the next generation. Three of the proposals (nos. 2,4 and 6) act to encourage the demolition of existing buildings to clear the way for larger development. Preservation and adaptive reuse is “green;” restoration produces less waste and less landfill than demolition, rehabilitating older buildings uses less energy than new construction and preservation efforts create a market for skilled local labor. As the AIA’s Newsletter of the Committee on the Environment noted in Spring 2007, reporting on the National Summit of the Greening of Historic Properties, “the greenest building is the one already built”. Furthermore, the decrease in open space suggested by two of the zoning amendments (proposals 1 and 6) would probably result in less plantings and landscape, which in addition to its esthetic detriment, would diminish needed absorption of ground water – a situation which the recently-approved yard amendments have sought to remedy. Finally, the overall probable loss of air and light due to many of these proposals (specifically nos. 2,3,4 and 5) certainly does nothing to improve the quality of life for residents.
Affordable Housing Trojan Horse
Additionally, PlaNYC 2030 proposes the development of affordable housing to remedy both the existing affordable housing crisis as well as the projected shortage. It should be noted that while affordable housing is mentioned as a goal of these proposed changes, nothing states that these must or will be used for such housing. Developers could just as easily, and most likely will, build larger, market-rate residences whenever possible. This is a given. HDC finds it particularly galling for citywide zoning text to be revised with such broad strokes for more “flexible design” and “more efficient floor plans” while ignoring the very real problem of providing adequate affordable housing.
What Should Happen
In the best possible scenario, this proposal would be withdrawn and the City Planning Commission would embark on a study of these amendments, which, if deemed desirable, could be introduced individually by the agency to all its community partners. Anything less would a betrayal of New Yorkers’ faith in our planning commission and an enormous and unnecessary concession to those who wish to spur development at any cost to the welfare and continued health of our city.
The Proposed Amendments
Note: None of these amendments increase allowable Floor Area Ratio (F.A.R.). What they do is maximize buildable F.A.R. by modifying and increasing the allowable building envelopes. In practice, this may result in larger building than what would otherwise be built. Also please note that all image and diagrams courtesy of AIA/NYC.
Proposal 1: Full Lot Coverage on Small Corner Lots in R6-R10
Posted by Simeon Bankoff at 6:36 PM