HDC Statement on NYC’s Fair Housing Growth Strategy
The Historic Districts Council (HDC) recognizes the urgent need to address New York City’s housing crisis and supports the Fair Housing Growth Strategy’s goal of expanding affordable housing opportunities and giving New Yorkers greater choice in where they live.
HDC has demonstrated its own commitment to supporting the increase in supply of affordable housing stock through our ongoing advocacy. Recent examples include testifying in support of large-scale, 100% affordable housing developments in historic districts and supporting the recently proposed South of Prospect neighborhood rezoning.
While we support the strategy’s stated goal of increasing housing opportunity, HDC has three primary concerns with its approach:
- Overemphasis on new, primarily market-rate construction: The strategy does not adequately recognize rehabilitation, adaptive reuse, and conversions as ways to create and preserve housing, and offers limited detail on its goal of preserving 100,000 homes.
- Threats to existing affordable housing: Aggressive production targets could encourage demolition or consolidation of smaller multifamily buildings, replacing rent-stabilized and naturally affordable homes with larger majority market-rate developments.
- Failure to account for neighborhood conditions: Housing targets and the Affordable Housing Fast Track do not adequately reflect differences in existing density, development capacity, infrastructure, historic building stock, and displacement risk.
The strategy calls for 700,000 new homes over the next decade, yet its approach gives insufficient weight to housing retained or improved through rehabilitation and adaptive reuse. Losing existing affordable homes while adding market-rate units undermines its broader goals. We also question whether its emphasis on market-rate production will adequately advance affordability for low-income New Yorkers: of the 350,000 homes targeted by 2030, only 85,000 (24%) would be income-restricted affordable housing, and just 25,500 (7.3%) would be affordable to households earning 60% of Area Median Income (AMI) or less. While the final Fair Housing Growth Strategy provides limited detail on how it will achieve its target of preserving 100,000 homes, we do appreciate the more substantive preservation measures outlined in the Mayor’s Block by Block plan. HDC’s new initiative Preserving Affordability: Unlocking Historic Tax Credits for Housing explores how historic tax credits can help close critical rehabilitation financing gaps and extend the life of existing affordable buildings. We urge the City to incorporate these and other preservation tools into its broader housing strategy, ensuring that efforts to expand housing supply also safeguard the affordable homes New Yorkers already occupy.
HDC is also concerned that the strategy’s housing production targets do not adequately reflect the very different conditions of New York City’s neighborhoods. While we support distributing growth more equitably across all 59 community districts, the targets do not directly account for existing residential density, development capacity, infrastructure constraints, or displacement risk. It does not make sense that a densely developed neighborhood with substantial rent-stabilized housing should be assessed under the same basic framework as a lower-density neighborhood with significantly more underdeveloped land.
The Upper West Side illustrates the shortcomings of this approach. Despite its substantial existing density and limited vacant land, the neighborhood has been designated for the Affordable Housing Fast Track because, by the strategy’s metric, it has produced relatively few new affordable housing units in recent years. As Council Member Gale Brewer has pointed out, this calculation only counts new construction while overlooking affordable housing created through rehabilitation and conversion, as well as the neighborhood’s existing stock of SROs, supportive housing, and other affordable homes. The calculation inherently devalues and ignores adaptive reuse and conversions as viable sources of housing, despite the fact that these projects have spiked across the city—having produced roughly 19,745 units in the past two years, as reported by the New York Times.
HDC urges the City to adopt a more comprehensive approach to housing growth that protects existing rent-regulated homes; recognizes rehabilitation, adaptive reuse, and conversions alongside new construction as essential components of housing production; and considers drastically different neighborhood conditions when applying housing targets.