The Real Estate Board of New York to The City Planning Commission on CEQR No. 24DCP065Y, “Green Fast Track for Housing”

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REBNY thanks the City Planning Commission (CPC) for a chance to comment on the proposed rule amendment to create a “Green Fast Track for Housing,” CEQR. No. 24DCP065Y.

REBNY supports the Commission's proposed rule amendments, which aim to fast track certain housing projects by modifying the Type II CEQR list. Type II actions are determined to have no significant environmental impact and are exempt from environmental review. As part of the city's "Get Stuff Built" initiative, the rules will accelerate housing development by reducing red tape, streamlining processes, and removing bureaucratic obstacles, all aligned with the city's housing and climate objectives.

This is a crucial step in addressing the housing crisis in New York City. The proposed rules will exempt climate-friendly housing projects, contingent on size and location, from environmental review, contributing to the administration's goal of creating 500,000 new units over the next decade. The longer the review process takes, the higher the costs will be, which often will dissuade smaller projects. For example, a two-year long review process is estimated to increase costs by 15% or $58,000 for low-rise projects. The proposed amendment to streamline the environmental review process is estimated to cut up to two years and $100,000 in housing proposal costs, per project.

The time and resources involved in completing environmental reviews significantly contribute to the city's housing crisis and often leads to determinations that proposed developments pose no significant adverse environmental impacts. The proposed amendment will simplify the process, promoting the development of small and medium-sized housing projects while reducing costs for applicants. Simultaneously, the proposal aligns with essential climate goals.

REBNY appreciates the extensive analysis of past environmental reviews of housing projects to determine the size and location of future housing projects that can safely be issued a Type II determination. That research amply supports the proposed rule amendments.

While REBNY commends the goals of the department to speed up the approval of housing projects, it is crucial to anticipate potential delays that may arise due to staffing issues at city agencies. Projects are still required to meet various prerequisites involving multiple agencies, necessitating careful consideration of staffing requirements and close interagency coordination. While the goal is that these projects will ultimately move quicker via the Green Fast Track compared to completing a full Environmental Assessment Statement (EAS), we strongly suggest that the Commission explore options for expediting and prioritizing the review of these projects to prevent them from getting stuck in a backlog or within interagency disagreements on prerequisites.

Thank you for the consideration of these points.