Exemption of Certain Housing and Related Actions from State Environmental Quality Review Act and City Environmental Quality Review Procedures

Online comments: 15

• Steven Mahoney

  If an environmental analysis isn’t conducted how are we to know whether or not there could be an adverse environmental impact?

  Comment added January 15, 2024 9:36pm

• Carlo Casa

  Re: Support for the Green Fast Track Initiative

  Dear Chair Garodnick and members of the City Planning Commission,

  The Building Congress represents over 500 constituent organizations and over 250,000 skilled tradespeople and professionals dedicated to the growth and prosperity of our city. We write to express our full support for the “Green Fast Track” initiative, a proposal firmly grounded in data from a decade of meticulous research.

  The “Green Fast Track” initiative, categorizing environmentally responsible residential developments as ‘Type II’ actions, is a welcome and common-sense approach. By expediting reviews for projects that we already know won’t significantly impact the environment, we not only save valuable time and resources but also accelerate the delivery of much-needed housing. We are in a dire housing crisis — and only bold, innovative initiatives like the Green Fast Track can pull us out of it.

  Central to this initiative is its environmentally sound methodology. The Green Fast Track is exclusively applicable to projects with a proven track record of no environmental impacts. This careful selection underscores the proposal’s commitment to preserving the environment while addressing the city’s housing needs in the urgent manner that they deserve.

  Importantly, the proposal does not alter the public review process or any zoning rules. This commitment ensures that the public remains an integral part of the decision-making process, preserving the transparency and inclusivity that are hallmarks of our city’s planning endeavors.

  In conclusion, the “Green Fast Track” initiative is a thoughtful, innovative-yet-common-sense policy, crafted by our city’s foremost planning experts. Our members look forward to the opportunity to leverage this vital policy to help combat our city’s growing housing crisis.

  Thank you for your consideration.

  Comment attachment
  Green-Fast-Track-Testimony-2.7.24.pdf

  Comment added February 1, 2024 3:47pm

• Bill Murray

  The American Council of Engineering Companies of New York (ACEC New York) is an association representing nearly 300 engineering and affiliate firms with 30,000 employees in New York, with a concentrated presence in New York City. Many of our members have a business footprint and also live within the five boroughs. Our members design the structural, electrical, mechanical, plumbing, civil, environmental, fire protection and technology systems of buildings and infrastructure throughout New York City.

  ACEC New York as an organization, and many of our members, have a proud history of providing the technical expertise required to update, advance and amend city laws and codes to address critical modern needs.

  We submit these comments in support of the proposed rule put forth by the Mayor’s Office of Environmental Coordination, referred to as “Green Fast Track for Housing,” which would exempt certain housing development and related actions from review under the State Environmental Quality Review Act and City Environmental Quality Review procedures.

  We believe this evidence-based approach to exempting new housing developments, up to a certain size, and accompanying small commercial developments, from time-consuming reviews will help the city to deliver more housing supply, faster.

  By streamlining the environmental review process this measure will support the production of small- and medium-sized housing projects across the city. This will generate a variety of benefits in terms of housing creation, housing affordability, and design/construction job creation.

  We encourage the Mayor’s Office to do everything in its power to provide much-needed housing supply to the city while ensuring public health and safety.

  If ACEC New York’s membership can be of assistance or serve as a resource, please contact us any time.

  Comment attachment
  ACEC-New-York-comments-on-Green-Fast-Track-Housing-proposed-rule-1.pdf

  Comment added February 2, 2024 2:32pm

• Bria Donohue

  Chair Dan Garodnick
  City Planning Commission
  120 Broadway
  New York, NY 10271

  February 7, 2024

  RE: AIA New York Testimony to the City Planning Commission in Support of the Green Fast Track for Housing

  Dear Chair Garodnick,

  American Institute of Architects New York writes to express our support for the proposed amendment to Chapter 5 of the City Planning Commission’s rules to exempt certain housing and related actions from review under SEQRA and CEQR procedures, also known as the Green Fast Track for Housing. AIANY represents more than 5,000 architects and design professionals committed to positively impacting the physical and social qualities of our city.

  With the housing crisis in NYC raging on, the Green Fast Track for Housing will make important changes to address the lengthy and costly environmental review process. Among the many costly factors to building housing in NYC, the time and resources required to complete environmental reviews that are ultimately unnecessary can potentially derail a project. The proposed rule changes will make commonsense adjustments to the environmental review process to streamline the process for climate-friendly housing by up to 24 months and save each project approximately $100,000. Eligible projects are housing that uses all-electric heating instead of fossil fuels, are located outside of vulnerable coastal areas, in areas with industrial emissions or away from major roads, and that meet specific mitigation standards for areas with hazardous materials or in ambient noise.

  The Green Fast Track for Housing will be a valuable tool for achieving the city’s goal of building 500,000 new homes by 2033. Housing production has lagged far behind job growth, with housing increasing by 4% compared to 22% job growth in the same period. This proposal will be critical to breaking down some of the barriers to building housing and start delivering quicker for New Yorkers.

  AIANY urges the City Planning Commission to approve the proposed amendment, Green Fast Track for Housing, and get New York building housing faster.

  Sincerely,
  Jesse Lazar, Executive Director

  Comment attachment
  AIANY-Testimony-on-Green-Fast-Track-for-Housing-2.7.24.pdf

  Comment added February 6, 2024 12:40am

• Sara Lind

  Chair Dan Garodnick
  City Planning Commission
  120 Broadway
  New York, NY 10271
  February 7, 2024
  RE: Open Plans Testimony to the City Planning Commission in Support of the Green Fast Track for Housing

  Open Plans writes to express our support for the proposed amendment to Chapter 5 of the City Planning Commission’s rules to exempt certain housing and related actions from review under SEQRA and CEQR procedures, also known as the Green Fast Track for Housing. Open Plans is a nonprofit organization with the mission to create a livable city for all New Yorkers. We promote a people-first street culture that prioritizes community, safety, joy, mobility and empowerment.

  A modern city can’t operate under clunky policies that hinder good progress. Too often environmental review is weaponized to block projects that would objectively be good for the environment, from housing projects to transit and public space projects. These outdated environmental review laws are making it harder to addres our overlapping housing and climate crises by imposing unecessary costs and delays on climate-friendly housing projects.

  By taking a critical eye to environmental review, this proposal will fast-track projects that help us reach urgent climate, housing, and livability goals. With this reform, the environmental review process can work as intended, setting important climate standards while encouraging beneficial development. The result is a streamlined government that can better respond to the needs of New Yorkers.

  This reform is a good first step that will make a positive difference while not making major changes:
  To be eligible, a project must have fewer than 250 units (in a high density area) or 175 (in lower density areas).
  The building must be all-electric; it can’t be near polluting sources; and it can’t cast shadows on sunlight sensitive sources. A project also has to go through rigorous health and safety screening.
  But if it meets these criteria, it will have a shortened timeline (about 50% shorter). This reform will avoid months and years of delay, and tens of thousands in costs, associated with needless review. 

  Open Plans urges the City Planning Commission to approve the proposed amendment, Green Fast Track for Housing, as one piece of the puzzle to building a livable city.
  `
  Sincerely,
  Sara Lind, Co-Executive Director

  Comment attachment
  Green-Fast-Track-Comment-Open-Plans.pdf

  Comment added February 7, 2024 10:43am

• Daniel Rowen

  Hi, I am writing as Chair of the Environment and Sanitation Committee of Bronx Community Board 8 and with the full support of the committee. We are opposed to this new rule change as we feel that no development can be entirely low risk of significant adverse environmental impacts, and even so, the point of an environmental review is to make sure it is low or no risk before proceeding with possible adverse impacts. That the community boards are being cut out of this process is also a significant area of concern. Please reconsider passing this rule change before all aspects of City of Yes have been implemented.

  Comment added February 12, 2024 2:22pm

• Calder Orr

  Please see attached PDF with comments

  Comment attachment
  Green-Fast-Track-Comments-DCP.pdf

  Comment added February 13, 2024 8:55pm

• Andrea Goldwyn

  Please see attached comments.

  Comment attachment
  Green-Fast-Track-2.7.24.pdf

  Comment added February 14, 2024 6:42pm

• Lei Zhao

  I serve as the Fourth Vice-Chair of Queens Community Board 7 and also Recording Secretary of the NY Community Aviation Roundtable LGA Committee. I draw on my experiences serving on these bodies to inform my comments about the following clause in the Green Fast Track proposed rule changes:

  “confirmed that all developable sites are outside the 65 Day Night Average Sound Level contours established in the Noise Exposure Map (NEM) Report for John F. Kennedy Airport and LaGuardia Airport” (found on page 9 of the proposal here: https://home.nyc.gov/assets/planning/download/pdf/plans-studies/green-fast-track/green-fast-track-cpc-rules.pdf)

  You may be aware that there are a few issues with the 65 DNL contour:
  – First, there is evidence that 65 DNL exposure still constitutes unhealthy levels of noise exposure.
  – Second, the contour itself doesn’t fully account for noise exposure caused by low-flying planes executing departure and arrival procedures from the area airports. Since 2012, and the implementation of NEXTGEN navigation, planes have been using precision GPS guided vectors, placing plane after plane over the same narrow corridor. The FAA has not studied or measured the impacts of this noise in any scientific manner, so it’s not clear to me if these exceed 65 DNL. Regardless, they do factor into the lived experience of residents on the ground and it would be prudent to factor that into your considerations on this proposal. You can see what I’m talking about yourself with this tool: https://webtrak.emsbk.com/panynj4

  Comment added February 14, 2024 8:22pm

• Thomas Devaney - Municipal Art Society

  MAS Comments on Green Fast Track for Housing

  Dear Chair Garodnick and Commissioners,

  If Green Fast Track ultimately cuts red tape and leads to more housing without burdening neighborhoods with undue impacts, it is a rule change MAS supports. However, a closer examination is needed to ensure its goals are met and unintended consequences avoided. From MAS’ viewpoint as a leading CEQR reform advocate, we have the following recommendations and questions.
  Recommendations and Questions
  With the rule changes, projects will still require significant agency oversight. We request that the City pass the rule changes with a built-in pilot program so that after a determined time there would be a lookback to assess whether application review time is saved, and impacts are addressed.
  Green Fast Track should exclude sites in the current and future flood plain (year 2100). By only restricting projects in the six designated Special Coastal Risk Districts, it does not go far enough to protect people and property from climate change risks.
  Because Type II actions do not require further analysis, this may leave the public, community boards, and other interested parties with insufficient information. This is important because Type II projects would still need to go through ULURP. We recommend the City provide Type II memos that include the rationale supporting its determinations that no impacts would occur and correspondence from involved agencies tasked with providing written determinations about hazardous materials, air quality, noise, and historic resources.
  Excluding projects that use fossil fuels supports the City’s efforts to achieve carbon neutrality. However, the City should go further and require projects subject to CEQR, regardless of whether they are Type II actions, to demonstrate how they would comply with Local Law 97, and include a life-cycle energy analysis that considers comprehensive energy demand for demolition and material costs of construction. In doing so, the City would also be disclosing the environmental benefits of a project.
  The City should not exempt projects in manufacturing districts. Manufacturing districts are vital to the City’s economy and need to be protected. Between 2007 and 2015, the City lost over 4,000 acres of manufacturing zoned land due to rezonings.
  How would cumulative impacts of multiple projects occurring in the same area at the same relative time be evaluated if individually they would be listed as Type II actions under the new rules? This is particularly important when considering impacts on traffic, public school capacity, transit, and open space.
  Green Fast Track could create opportunities for applicants who own large sites to deliberately keep multiple housing projects under the 250-unit threshold or phase them over a period of time to avoid or segment the CEQR process. Has the City identified mechanisms to prevent this from occurring?
  One way to address cumulative impacts and prevent segmentation is to use Generic Environmental Impact Statements or programmatic environmental reviews, which are done at the federal level under the NEPA. These comprehensive reviews can address impacts of multiple ongoing, planned, or foreseeable projects occurring in the same area at the same relative time.
  Conclusion
  Green Fast Track shows the City’s commitment to closing the current housing gap. While it remains to be seen if review time is reduced and more housing produced, we hope our recommendations are given ample consideration and look forward to continuing the conversation on this important rule change.

  Comment attachment
  Green-Fast-Track-Comments-to-CPC-02-15-24.pdf

  Comment added February 15, 2024 11:38am

• Chris Walters

  See attached

  Comment attachment
  Green-Fast-Track-Written-Testimony-ANHD-.pdf

  Comment added February 16, 2024 1:59pm

• Frank Taylor

  Please see the attached PDF from Queens Community Board #3.

  Comment attachment
  The-Green-Fast-Track-for-Housing.pdf

  Comment added February 16, 2024 2:15pm

• Jeff Mulligan

  Please see attached.

  Comment attachment
  Green-Fast-Track-Written-Testimony.pdf

  Comment added February 16, 2024 4:10pm

• Chad Purkey

  Dear Chair Garodnick,
  We are in a housing crisis. A crisis requires urgent yet sensible action to ensure proper responses and cures. The proposed Green Fast Track for Environmental Review proposed rule change does just that, bringing forth sensible adjustments to the review process to ensure needed quality housing can become available to New Yorkers faster.

  The Association for a Better New York (ABNY), established in 1972, is a member-based civic organization with nearly 250 members, that is dedicated to the advancement and support of New York City’s people, businesses, and communities. One of the simplest ways to move New York forward at this moment is to unlock more housing.

  To actualize the mantra of “Get Stuff Built,” the city must implement innovative solutions that reduce the barriers for new quality housing.
  Thanks to the Department of City Planning’s thorough research of more than 1,000 past development sites, The Green Fast Track’s changes provide a needed balance between reducing regulatory burdens while maintaining necessary opportunities for public review and participation.

  In addition to speeding up the production of new housing in limited but appropriate instances, the proposed rule changes create additional benefit by incentivizing the development of sustainable housing and contributes to the development of a more resilient city in the face of climate change.

  In conclusion, the Green Fast Track will significantly contribute to addressing the city’s housing shortage through well-researched and environmentally sound rule changes that will continue to preserve public engagement and should be approved.

  We look forward in continuing to work with the Commission, the NYC Department of City Planning, and the Adams administration to Get Stuff Built and move New York City forward.

  Comment attachment
  ABNY-Testimony-_-Green-Fast-Track-_-CPC-2024.2.16.pdf

  Comment added February 16, 2024 4:53pm

• Henry Euler

  AUBURNDALE IMPROVEMENT ASSOCIATION, INC.
  P. O. BOX 580331, STATION A
  FLUSHING, NY 11358

  Feb. 15, 2024
  To NYC City Planning Commission:

  Testimony regarding the Green Fast Track for Housing proposal
  Copy to NYC Board of Standards and Appeals and others

  My name is Henry Euler and I am the President of the Auburndale Improvement Association. My civic organization represents several hundred members in the Auburndale Flushing/Western Bayside area of Northeast Queens. The organization was founded in 1905 and incorporated in 1915, and is the largest in area in Queens County. We have concerns regarding the implementation of the City Planning Commission’s Green Fast Track proposal, which will delete the requirement of an environmental review for much new construction in an attempt to build more housing quickly in our City. We are opposed to this proposal in its present form as a result.
  It is our understanding that projects that would be eligible for Green Fast Track consideration would be buildings which would add 175 or fewer units in R1-R4 residential districts, or projects which would add 250 or fewer units in R5-R10 residential, commercial, or manufacturing districts. This is described as small and medium sized development. In my civic area, that would not be considered to be small or even medium sized development. This would be major sized development that should certainly still need to have an environmental review.
  On the CPC Green Fast Track summary page, it states, “The Department of City Planning (NYC Planning) analyzed more than 1,000 environmental reviews over the last decade. NYC Planning consistently found that modest housing projects with certain characteristics had no negative impacts on the environment. By shifting these projects onto the Green Fast Track for Housing, NYC will eliminate as much as two years of environmental review and more quickly deliver homes.”
  What about the portion of the more than 1,000 projects that might have negative impacts on the environment? Under Fast Green Track, those projects would fall through the cracks and the environmental consequences of allowing them to be constructed would fall on the new owners or occupants. How can you tell if a project has a potential environmental problem unless you do an environmental analysis on the project?
  Bypassing environmental review even on so-called “modest” projects could open all sorts of problems and issues in the future. When these requirements were first considered and approved by the City, there must have been a reason for them or the City would not have required an environmental analysis to be conducted. Rushing through project construction without considering all aspects of the environmental impact of the project jeopardizes the safety and well-being of the people who will live in them as well as the safety and well-being of those people who live near these projects.
  I would also like to mention that the fact that the Green Fast Track proposal does not go through the ULURP process is very troubling. The ULURP process gives all community boards throughout the City the opportunity to weigh in on proposals and gives Board members and local residents the chance to learn about, ask questions, and give opinions regarding proposals that will affect their communities. Even though City Planning held meetings and a public hearing regarding Green Fast Track, this does not have the same impact that local participation has at the community board or civic association levels. Few people in my area were even aware of the Green Fast Track proposal because they do not keep up with CPC or other City agency announcements. They are more likely to notice and react to city-wide issues and proposals through their local community board or civic association. There has to be outreach to such organizations by the CPC and other City agencies when proposals and issues arise so that all are informed. Transparency is a must!
  Thank you for taking the time to read this testimony.
  Henry Euler, President
  Auburndale Improvement Association, Inc.
  Copies to: NYC Board of Standards and Appeals
  Queens Civic Congress
  City Council Speaker Adrienne Adams
  Borough President Donovan Richards
  Council Member Vickie Paladino
  Council Member Sandra Ung
  Council Member Linda Lee
  Community Board 7
  Community Board 11

  Comment added February 17, 2024 10:41am