The Real Estate Board of New York to The New York City Department of Buildings Regarding a Major Projects Development Program

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The Real Estate Board of New York (REBNY) is the City’s leading real estate trade association representing commercial, residential, and institutional property owners, builders, managers, investors, brokers, salespeople, and other organizations and individuals active in New York City real estate. REBNY thanks the Department of Buildings (DOB) for the opportunity to comment on a proposed rule that would create a major projects development program.

Real estate development is essential to New York City. Not only does development create a space where New Yorkers live, work, learn, socialize, or more, it contributes to the city’s vitality and directly helps our economy by creating good jobs and increasing tax revenue to be used on public services. As the city begins its recovery from the economic downturn caused by the COVID-19 pandemic, development will be crucial.

The major projects development program would allow for certain significant development projects to apply and pay a fee to participate in a program that provides dedicated services and guidance from DOB staff throughout the project development, including pre-review of plans, permits, and occupancy requests. It would also create a dedicated staff member to help shepherd participating projects through DOB processes, giving the developer a single point of contact assigned to that end. Qualified projects would include:

·       New buildings 20 stories or greater;

·       New buildings with a total floor area of 500,000 square feet or more;

·       New buildings that increase the existing floor area by 100,000 square feet or more; and

·       New or existing buildings facing unique hazards associated with demolition or construction.

REBNY strongly supports this proposed rule, which will be a benefit to economic development and also help improve public safety by working more directly with developers and ensuring compliance with Code and safety standards.

To improve the program, REBNY encourages the DOB to consider the below, which we believe complement the program’s intention and would help strengthen its impact.

 

Expand the Program’s Eligibility

The threshold to participate in the proposed program is high and as a result relatively few projects will reach the scale necessary to participate. While the program would grant discretion to the Commissioner to allow projects that do not meet the required size to participate, the criteria for which those applicants would be judged remains vague.

If the intent of the program is to meaningfully improve the development process - shortening the timeframe it takes for projects to receive approvals and permitting as well as increase project safety – REBNY strongly believes the DOB should lower the threshold to allow more projects to be able to participate. As DOB considers this proposed rule, we would welcome the chance to understand the resources needed to expand eligibility and the extent that higher fees would be necessary to allow more projects to participate in the program.

Include Coordination Between Agencies in the Project Scope

Building development, while heavily steeped in requirements from the DOB, also include significant administration with other agencies, including but not limited to the Fire Department, the Department of Transportation, and the Department of Environmental Protection. Many projects, unfortunately, experience delays because of disconnect or misunderstanding between agencies.

For that reason, REBNY would encourage the DOB to expand the scope of the program’s services to explicitly include DOB liaising with other agencies when necessary to ensure that a major project receives appropriate approvals from the DOB.

Thank you for the consideration of these points.