Regional Plan Association Written Submission to the 2019 Charter Form Commission in Support of Comprehensive Planning in NYC

In 2017 Regional Plan Association (RPA) released its Fourth Regional Plan (4RP). Guided by the core values of equity, prosperity, health, and sustainability, the 4RP provides a big picture framework for moving our metropolitan region – 3 states, 31 counties, 782 cities – to be more inclusive. Among our many recommendations, reforming land-use processes rose up as a priority to rebuild trust, create more equitable outcomes and provide the City with the housing, jobs and commercial and public spaces that it needs. This can only be achieved if we make the planning and development process more inclusive, predictable, and efficient. Realizing that goal can be accomplished in part by developing a comprehensive planning framework for the City.

RPA projects that New York City could potentially add 1.2 million new people and over 800,000 new jobs by the year 2040. However, we are already dealing with the continuing decline of vital infrastructure, looming threats from climate change, housing affordability and displacement risks, and inequitable development outcomes. If we want to ensure our City continues to maintain its lead in attracting talent, innovation, jobs and culture, we need to do better in investing in our existing neighborhoods and creating a more predictable framework for growth. Changes to the land-use process won’t solve all our problems, but a comprehensive plan would help us develop a more in-depth understanding of our needs as a City and a roadmap for targeting projects, programs and policies transparently for all New Yorkers to understand.

Our existing planning framework is often inadequate to resolve issues facing large-scaledevelopment proposals, as seen with Amazon’s HQ2, and challenges to local rezoning designed to bring in new density, as recently reported for the South Portland Avenue development in Fort Greene. Rezoning efforts where we’ve tried to be more proactive over the last several years haveattempted to address some of the most urgent challenges facing marginalized communities - an increase in affordable housing, better infrastructure and more economic activity. However, they have resulted in unanticipated development impacts, calling investment decisions into question and further eroding trust in our existing processes.

The City has several strategic documents that currently guide planning decisions. We have OneNYC, a housing plan and a NYCHA plan, agency strategic plans and comprehensive neighborhood plans. While we are embarking on the Where We Live process to address fair housing and highlight how challenges like discrimination impact residents, this process is voluntary and will not force other agencies to do anything. In his State of the City address, Speaker Cory Johnson also indicated his interest in requiring a master plan for NYC streets every five years. This is a worthwhile endeavor that will help reduce inefficiencies, improve accountability, and create a predictable process for managing our streets. But this would also add to this list of almost-but-not-quite comprehensive plans. These documents are valuable in seeing

what an agency or administration sees as a priority, but they offer siloed approaches to investing and developing our City.

This charter reform process should improve both transparency and predictability with values- driven requirements that align planning and expenditures to create a 10-year holistic roadmap for the City. Decisions across implementation areas, including capital and expense budgeting, should align with the long-term plan while still allowing for flexibility to address urgent or unanticipated needs. This type of approach to land-use is already undertaken by major U.S. cities. Done right, it would objectively and equitably establish citywide targets based on shared values, ensure we plan for both existing and new communities, and give more deference to community plans. Local planning, development and policies would align with citywide goals established through a comprehensive evaluation of existing and future needs.

Building off our work developing the Inclusive City coalition and report, we have been collaborating with Association for Neighborhood and Housing Development (ANHD) as a member of the Thriving Communities Coalition (TCC). Stakeholders represented by this group, including grassroots organizations, legal service providers, affordable housing developers and planning research organizations, have settled on core principles that should be driving any land-use reforms. These principles are:

  • Fair distribution of resources and development

  • Enforceable commitments

  • Integration without displacement

  • Transparency and accountability

  • Real community power and ownership

    In addition to equity concerns shared by the coalition, we share principles raised by the Progressive Caucus that our land-use process needs to be more proactive in responding to the City’s needs, including long-term challenges such as new growth, resiliency and infrastructure.

    We have worked with our partners to brainstorm a mechanism to carry out a comprehensive planning process, as detailed below. We want any new process that is created to be flexible so that we are not reliant on charter reform to tweak it. However, we do believe the charter needs to include some important components of a comprehensive planning framework, such as:

  • Establishing guiding principles

  • Mandating the City carryout a 10-year comprehensive planning process

  • Requiring the adoption of existing conditions, needs assessments and historical analysis

  • Improving equity in capital budgeting and aligning budgeting with long-term planning

  • Specifying scheduled updates to the comprehensive plan to align with utilizing the most

    up-to-date census data

  • Establishing clear and robust community engagement requirements

  • Requiring more robust Community Board Needs Assessments

It is important to keep in mind that a comprehensive planning process is a very common tool. Some examples are listed below:

  • London has maintained a comprehensive plan, the London Plan, since 2004. The plan is a framework that ties sub-strategic plans (e.g. transportation, economic development, culture, etc.) together in a comprehensive vision. Their process requires a public input, protocol for responding to comments and feedback, and a robust impact assessment to look at how proposals are impacting a set of basic issues and indicators. Each subsequent Mayor must adhere to a certain set of principles, but maintains flexibility in determining priorities for the next iteration of the plan.

  • Denver, CO is about to complete a similar process after a three-year planning period. Denveright, a 2040 framework, along with specific sub-plans are all being adopted simultaneously. The process also includes a neighborhood equity index that will be used in making some investment decisions.

  • Affordable housing in Atlanta, GA has improved thanks to strong comprehensive planning policies combined with their state-level comprehensive planning program. Their charter has an aggressive timeline, requiring updates every 3-5 years. The also set implementation schedules, responsibility and identify funding sources for projects within the plan.

  • California requires that plans look at a combination of elements but provides municipalities some flexibility in how to implement a comprehensive plan. The state’s mandatoryelements provide a foundation for goal-setting by municipalities. If additional challenges are identified, such as environmental concerns, the municipality is required to include strategies to address them in their plan.

  • Washington D.C. requires District Elements to establish local needs to feed into a broader comprehensive planning framework. The comprehensive plan sets high level targets andhas shifted from “ward level” to “area elements” as the local planning district. This moves them away from having to deal with shifting boundaries of a ward, while still enabling more place-based strategies to be developed at the local level.

    There is a range of language that cities have chosen to include in their governing documents. Examples from Austin, Los Angeles, Baltimore, and London are attached to this submission.

The mechanism described below is a combination of RPA staff thoughts along with work completed by the Thriving Communities Coalition. Where appropriate, we have also referenced the Progressive Caucus proposal that was submitted.


This step is the most crucial in establishing a foundation of information to develop a comprehensive plan from. A transparent process needs to be managed by an entity that can maintain independence and be held accountable. The Civic Engagement Commission createdduring through the Mayor’s 2018 Charter Revision process could play a lead role if given theresources and independence needed to carry out this work.

The quantitative and qualitative information gathered during this period should:

  • Be the core information used to make decisions around the city, not just for the comprehensive planning process

  • Always be publically accessible in a format the general public can interpret

  • Reflect the changing landscape of data and toolsets to be more accurate, real-time and

    useful as time goes on

  • Have a dispute mechanism so that inaccurate information can be objectively amended

    outside of the traditional 10-year update timeframe

    Assessing City Needs

    It’s not possible to list every category of citywide assessment that needs to take place and priorities will change as time goes on. However, the principles established by the Thriving Communities Coalition should serve as a basis for assessment around issues such as:

  • Displacement risks for both residents and businesses

  • Historical inequities in investment

  • Fair share siting of municipal facilities

  • Access to opportunity

  • Public health and safety

  • Climate change and the environment

  • Infrastructure needs and expansion

    The London Plan went through an Integrated Impact Assessment, which looked at how proposals included in their comprehensive plan update might impact a range of categories such as the ones listed above. This is a good framework to follow.

    We do need to ensure that we address inequitable outcomes resulting from our existing development process so that traditionally marginalized communities have a say in the future of our City. There have been several reports recently highlighting the challenges low and moderate- income residents face and how our existing processes are not setup to address these problems:

  • Pushed Out: Housing Displacement in an Unaffordable Region

  • Flawed Findings How NYC’s Approach to Measuring Displacement Risk Fails Communities

  • A Tale of Two Rezonings: Taking a Harder Look at CEQR

    That is why we support the Progressive Caucus’ (PC) proposal to adopt both a Displacement Risk Index and an Access to Opportunity Index. It is also important that we conduct an analysis of outcomes associated with various land-use processes and decisions over the prior 10 years. This would enable us to identify what is actually happening on the ground to everyday New Yorkers and whether strategies that have been implemented are delivering the expected outcomes. Such an analysis should be used to analyze disparities across geographic areas and across particularly vulnerable groups such as people of color, immigrants, youth, seniors, etc.

    Assessing Local Needs

    Our existing system for capturing community needs citywide rests predominantly on a Community Board District Needs Statement. This statement would wind up being one of the few, if not only, methods of collecting qualitative information at the community level. In order to ensure this statement is robust and truly reflective of community needs, we would like to see boards better resourced with stricter requirements in place for conducting the needs assessment. Some ideas for standardizing and strengthening this process are:

  • Requiring digital and print content include basic requirements for things like events calendars, engagement tools, website information, ways to get involved, etc.

  • Basic engagement tools and requirements for representative samples when conducting surveys or public meetings as part of the needs assessment.

  • Require boards get resources to hire and utilize technical staff (e.g. urban planners) to carry out complex portions of the needs assessment.

  • In alignment with the 10-year update, require community boards participate in assessing potential flaws in census data.

    Assessing Future Needs

    The City would need to project impacts over a 10-year timeframe along the indicators established during the existing conditions analysis. Such a process will need to utilize up-to-date modeling methods and should include estimates from City agencies on projected needs based on factors such as infrastructure depreciation, population growth, job growth, real estate development trends, etc. The process should identify areas with capacity to address future goal setting. For example, communities well served by infrastructure and services with a capacity for growth would need to accommodate more density.

Establishing Existing Conditions and Future Needs

The analysis completed above will need to be discussed around the City. Communities and their representatives should be given a chance to review and weigh in on the information before being adopted by the City. Borough presidents should be required to submit summaries of critical borough-wide needs at this stage, to be incorporated into the final report. These public engagement opportunities can also be used to begin the process to set goals for the 10-year comprehensive plan.

Charter Reforms:

  • Establish principles to guide comprehensive land-use decisions across agencies and administrations

  • Assessment timeframe to coincide with latest Census data release

  • Require agencies to utilize data included in the final approved assessment

  • Update community board needs assessment language to reflect more robust requirements

  • Include dispute mechanism with strict guidelines for triggers to avoid overuse

  • Establish community engagement requirement and protocol for addressing input


    We want the comprehensive plan to be objective, but understand that all decisions are inherently political. For citywide objective setting, we think the London Plan has a good system for requiringMayor’s to abide by certain principles, but giving flexibility in setting their priorities and updatingthe comprehensive plan to reflect how those priorities would impact a range of indicators. Utilizing the information established in Step 1 and administration priorities, a Mayor can work with City agencies to put together a set of overarching goals that would get reflected in specific projects, policies, and programs embedded in the plan.

    A decentralized borough-based steering committee system should be setup to help establish local targets, with a standard centralized group helping to align local and city-wide goals. Such a steering committee could be appointed by some combination of DCP, elected officials, city agencies, etc. At a minimum, steering committees should include borough-based:

  • Technical experts

  • Advocacy groups

  • Business leaders

    We support the setting of 10-year local targets as outlined in Step 2B of the PC proposal. The public should be made aware of strategies being developed to address those communities that rank high on the Displacement Risk or low on the Access to Opportunity indices.

    Establishing Citywide and Local Goals:

    Similar to Step 1, there should be a public engagement process to review both sets of goals and solicit feedback from New Yorkers. Such feedback would need to be incorporated or commented on before adoption of any goals. The Steering Committee would then adopt the two sets of goals to establish baseline requirements for developing draft comprehensive plans.

    Charter Reforms:

  • Require a decentralized steering committee with standard representation across groups

  • Require 10-year target setting be based on principles and assessment from Step 1

  • Establish community engagement requirement and protocol for addressing input


In developing draft comprehensive plan scenarios, we support Step 3 of the PC proposal. We would add that there should clearly be four components for each scenario:

  • Land-use framework

  • Policy and programming framework

  • 10-year capital budgeting plan

  • 4-year expense budgeting plan

    As part of the budgeting plan, gaps in financing or expectations of sources not within the City’scontrol should be noted. We know that financing major projects, such as transportationinfrastructure or climate resiliency, cannot be done on the City’s dime alone. The public deservesto know to what extent the City has control over the changes being proposed. If, for example, value-capture from added density is necessary to complete a new transportation project, that financing strategy should be clearly articulated for the public to understand what is and is not feasible under different scenarios.

    Establishing Preferred Scenarios

    The public will be presented with various draft scenarios for their district and Community Boards will have to vote on a preferred alternative.

    Charter Reforms:

  • List minimum components of a comprehensive plan

  • Establish community engagement and voting requirements along with protocol for

    addressing input.


    Since this type of work has never been completed under existing guidelines, it is not easy to specify a mechanism for reviewing and finally adopting the 10-year comprehensive plan. The PC and TCC groups have proposed a GEIS process to be followed by a citywide ULURP. Under the existing system, such a process could take an enormous amount of time and resources to getright. That does not mean we shouldn’t consider it since a GEIS process is supposed to apply to comprehensive planning, but there may also be ways to adapt existing procedures to this endeavor. For example, creating mechanisms to expedite CEQR, ULURP, or rezonings that align with the comprehensive plan in some way, while still piecemeal, could be a less expensive and more flexible option. We welcome the opportunity to continue thinking this through in collaboration with the Commission.


    The 10-year plan would become the guiding framework for land-use and budgeting decisions around the City. It would also provide a system to allow more robust community planning and adoption of 197-A plans. We also support the process included in Step 5 of the PC proposal.However, we’d like to see a timeline associated with how long CPC takes to certify compliance ornon-compliance.

    Charter Reforms:

  • Process for certifying compliance with comprehensive plan

  • Amending ULURP to reflect expediting projects in compliance

  • Call-up procedure to dispute compliance

As stated earlier, we know that this idea will not solve all our problems or be apolitical. However, a comprehensive plan in NYC will help rebuild accountability, predictability, and trust in our land- use decision-making and governance. More and more people strive for urban life every day and the pressures of inequality threaten to displace vulnerable residents. We need to do more to be transparent about the challenges facing our City and clear in our aspirations to do better. This process will not give everyone what they want, but asking New Yorkers to confront reality andenvision for themselves how that plays out in their community is an important step we shouldn’t be afraid to take. We have spent years planning for small portions of the City. Let’s make a bold move and plan with all New Yorkers.