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City Club: Fighting For New Yorkers

We represent New Yorkers on complex matters of urban planning which affect us all.  Our blog is here to help supporters from every background learn more about development in our city and the Club's advocacy. 


For Everyone:

We share news articles, position statements, and op-eds, and more.  


For Planning Professionals (and anyone who has a strong background in zoning!):

Find legal documents, testimony, and more.

BY TOM FOX | The U.S. Army Corps of Engineers recently released a preliminary flood control plan for Manhattan’s West Side waterfront in Hudson River Park between Battery Park City and W. 34th Street. Their simplistic approach to resiliency is to build a 12-foot-high concrete wall along 3 miles of the waterfront — in the Hudson River Park.

The proposed wall would displace the busiest bike path in America, diminish public use and enjoyment of a $1 billion public park visited by 17 million people a year, impede public access to the river, increase air and noise pollution and block views of the river. It would significantly impact the desirability of the park, undermine the quality of life in adjacent neighborhoods, and erode the value of adjacent real estate and the city’s tax base
Let’s take a look back at another West Side waterfront project. In 1985, after an 11-year legal battle forced the withdrawal of a U.S. Army Corps Westway permit for an interstate highway buried under 236 acres of landfill in the Hudson River, the governor and mayor established a unique city/state task force. That body brought together agency commissioners and local elected officials, along with community, environmental, business and civic stakeholders to craft a new vision for the West Side waterfront.

Read the full article in The Village Sun, March 2024

Fox was a Westway opponent and the first president of the Hudson River Park Conservancy, which completed the final plan and environmental approval of the park, and represents the City Club of New York on the Hudson River Park Advisory Council. His first-person history of the creation of the park will be published by Rutgers University Press in spring 2024.

Sent to NYC City Planning Commission

November 5, 2023

Since 1892, The City Club has been a civic organization advocating for sound urban policies for all New Yorkers. The City Club of New York promotes good governance and urban planning responsive to the needs of our communities.

In that spirit we offer the following recommendations to improve the scope of work for the environmental review of the proposed City of Yes for Housing Opportunity:

Open Space (Task 5): The importance of open space is emphasized by the Covid pandemic and by climate change. Covid showed the need for quality outdoor space as a public health issue. Climate change shows the usefulness of porous surfaces to mitigate flooding and landscaping to reduce heat and humidity. The analysis of open space needs to go beyond the amount of space related to the number of users and examine the usefulness of the space.

During Covid, the City’s parks and public spaces were intensely used. Private space (interior and exterior) should have sunlight, if at all possible, and landscaping should be addressed, inclusive of passive and active recreation for adults, teens, and children. Neighborhoods like Jackson Heights and Sunnyside are excellent examples of housing with quality open space that could be used as a standard. In addition, the shadowing of public space, such as parks and playgrounds, by new buildings should be addressed by permitting envelope flexibility when configuring the development.

The analysis should consider how open space, including streets as well as front and rear yards, can be designed to absorb flooding and planted to mitigate the heat island effect.

Energy (Task 13): The analysis of energy in CEQR is currently limited to the energy used to operate buildings. This provides an incomplete picture of the energy impacts of developing a new building. The energy analysis should be expanded to include the embodied energy that is lost when structures are demolished to make a site available as well as the energy used in the demolition, transport, and disposal of debris from the old building. It should also include the energy to create, transport and assemble the materials for the new building. Such a life cycle analysis would provide a more complete picture of the energy impacts of the proposed action.

Addressing only the energy used to operate the building prejudices the analysis in favor of new construction designed to be energy efficient. Including the energy used to prepare the site, including the embodied energy of structures removed, and the energy used to create the new building and to maintain and repair it would favor reuse and modification of existing buildings.

Alternatives (Task 22): The proposed 20% increase of FAR in medium and high density districts to compensate developers for providing affordable housing and the relaxation of envelope controls to accommodate the additional floor area may result in buildings that are not in keeping with their built context. Existing contextual districts were selected to reflect the building and street wall heights where they are mapped. Changing the allowed zoning envelope abandons this consistency and makes it likely that new buildings will negatively impact neighborhood character and urban design. This is illustrated in Appendix A of the draft scope. An alternative to the proposed action would be to mandate a percentage of affordable housing without granting additional FAR to pay for it. This is done in other jurisdictions and should be examined here.

There are other matters that seem problematic. For example:

• How will the environmental review evaluate the impact of reduced minimum lot sizes and lot widths, especially in the lowest density areas?

• What would be the process for adjusting the areas covered by Transit- Oriented Development Areas when a new rail station is established or a bus line is relocated?

• The draft scope says the environmental review will assume renewal of some version of 421a tax abatement. Will it also examine the impacts of different or no tax abatements?

We also offer the following comments which probably have more to do with the

proposal than with CEQR. The proposed revisions do not seem to address the structure of the current, complex, Zoning Resolution. It is part of the problem. Assuming the structure of the resolution stays the same, the proposal appears to be missing any mention of an online code that would be query-able to show all zoning and other regulations governing a zoning

lot. Also graphics should be used for a better understanding of the Zoning Resolution and what can be done on a zoning lot. While the Zoning Handbook provides a good illustrated overview, many, if not most developments are on sites which are more complicated than the handbook addresses. A more illustrated zoning text would be better.

It is unclear how the proposal deals with mismatches between the existing built context and their zoning districts. For example, much of Harlem, is zoned R7-2. The context on the mid-blocks is 3-4 story row houses (see the Environmental Simulation Center (ESC) website for a study, done for the MAS in 2000, “Comparative Zoning Analysis” comparing the original and then proposed modifications to the contextual height and setback regulations).

This mismatch between the existing physical context and the underlying zoning is problematic and not unusual. Notwithstanding, the proposal’s use of wide and narrow streets to determine the height and setback regulations, it is in most cases a crude match to existing context.

If the intent is to match the zoning lot’s context while allowing for change over time, as each new building both adds to and changes the context for the next new building, there are other approaches that deserve to be considered. Housing Quality Zoning (HQZ), the precursor to Contextual Zoning, is a performance-based system that self-adapts to any site. HQZ’s Neighborhood Impact section is essentially an urban design analysis of the development’s built context, inclusive of each new building. In 1973, before the IT revolution, this was a demanding task for architects, but with computers, not difficult at all. HQZ can be found on the ESC website.

A study done by the ESC and Phillips Preiss and Shapiro for the Public Advocate in 2005 identified C8 districts as potential redevelopment zoning districts. The study is available on the ESC website. C8 districts allow automobile related uses but not residential use. Why this exclusion now when residential and commercial uses are compatible and automobile related uses diminished? Coney Island Avenue in Brooklyn is a good example of a wide street with auto related and other uses fronting Coney Island Avenue but with residential use on the other half of the block fronting the narrow parallel street. The proposal and the scope of the environmental analysis should be expanded to add residential use in C8 districts. Separate from the residential FAR 1 FAR of commercial use should be included to subsidize affordable housing and to encourage commercial continuity along the street. The City Club appreciates this opportunity to offer comments.

NYC City Council's Subcommittee on Zoning and Franchise

Chair of The City Club of New York's Transportation Committee, Liam Blank (Urban Mobility Strategist), testified before the NYC City Council's Subcommittee on Zoning and Franchise in opposition to the 10 year proposed extension of Madison Square Garden's Special Permit to lease its current space atop Penn Station. Madison Square Garden's coexistence with the station reduces the tri-state area's vibrancy, functionality, and economic competitiveness. The City Club of New York recommends a shortened extension, of three years or less, to push towards a genuine relocation plan for MSG which will open up possibilities for an optimized Penn Station. Listen to his full testimony here.


  • Revamping Penn Station to meet the future needs of the tri-state area is not possible while MSG exists above it; Penn's functionality is substantially compromised by coexistence with MSG.

  • Penn Station struggles with safety issues which are directly created by the structural needs of MSG. The supports holding up MSG also create congest congestion in Penn, and make it difficult for users to navigate the station.

  • Above ground, MSG inhibits pedestrian and vehicle traffic in the area

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