Opposition to “Zoning for Quality and Affordability”

June 9, 2015

Gigi Li, Chair 
Community Board 3, Manhattan 
59 East 4th Street 
New York, NY  10003

re: NYC DCP’s Proposed “Zoning for Quality and Affordability”

Dear Ms. Li:

Lower East Side Preservation Initiative is writing to ask Community Board 3 to oppose the NYC Department of City Planning’s proposed “Zoning for Quality and Affordability” text amendments. Our concerns focus on the city’s historic neighborhoods, some but not all of which are NYC historic districts, particularly within the traditional Lower East Side which extends from East 14th Street to south of Chinatown.

Our primary objection to this proposal is that, despite recent modifications to the plan, the rezoning treats the city with too broad a brush. Certain areas of the city may be suitable for this kind of upzoning. But many areas are not, including those where:

* Their special character is defined by low rise buildings, where light and open space predominate. This includes many historic neighborhoods both landmarked and not landmarked.

* The area has been built to a density where light and air have become limited, and severe wind tunnel effects have become more commonplace. Much of Manhattan as well as certain neighborhoods of Brooklyn and Queens fall within this group.

* Increased development pressure will result in further loss of the area’s existing low and moderate income residents and small businesses, which contribute significantly to neighborhood character and are often its “heart and soul.” A lot of new development results in the loss of these groups.

Although we are very supportive of income diversity and affordable housing for New Yorkers, we believe that this proposal’s broad brush approach to zoning disempowers communities, and relies on one-size-fits-all solutions which will necessarily show poor results.

We respectfully request that Community Board 3 request that the DCP review potential rezonings on a community-by-community basis.


Richard D. Moses 

cc: Bruce Monroe, Lower East Side Preservation Initiative