Vice President, Government Affairs•
March 13, 2022
REBNY thanks the New York City Council Committee on Housing and Buildings for the opportunity to provide testimony regarding the FY2023 preliminary budget.
The Department of Buildings and the Department of Housing Preservation and Development are critical partners to the real estate industry, and REBNY appreciates the longstanding working relationships between members and the agencies to further initiatives across a broad spectrum of issues, including sustainability, fair housing, and eviction prevention.
Department of Buildings (DOB)
For FY2023, REBNY encourages that additional funding be provided for the Department of Buildings to fund the full implementation of Local Law 97 of 2019 (LL97). Reaching our shared goals requires collective effort from both the public and private sectors to deal with the crisis at hand. REBNY supports City and State emissions reductions goals, and we are proud to represent members who are innovating in the fields of building construction and technology to reduce carbon footprints, increase energy efficiencies, and take concrete steps to strengthen climate resilience.
Adequate funding for the Office of Building Energy and Emissions Performance (OBEEP) at the Department of Buildings is critically important to realizing these goals. OBEEP was created to ensure implementation of LL97, including the overseeing of advisory boards currently facilitating the law’s technical details, and ultimately for executing compliance as the law requires, beginning in 2024. As such, funding is required for the Office to ensure the successful implementation of the law.
REBNY along with other stakeholders including 32BJ, ConEd, the Regional Plan Association (RPA), the Sierra Club, Urban Green Council, the National Resources Defense Council (NRDC) and New York Communities for Change recently penned a letter to the City Council calling for OBEEP to be prioritized for funding. Specifically, funding is needed for:
Analyses required under the law. Local Law 97 requires OBEEP to work with the advisory board to develop recommendations on a wide range of complex subjects, such as the economic impact and benefits of achieving the energy and emissions performance requirements. The Office needs staff and funding to deliver on that mandate.
Rulemaking, compliance, and enforcement. Major details of the law must be settled in the next 10 months, and in less than two short years, the law’s carbon limits will take effect. A fully staffed OBEEP is vital to finalizing the law’s technical details and issuing rules that will ensure a smooth and timely rollout and effective compliance for up to 50,000 buildings.
Outreach and education. OBEEP needs dedicated staff and funding to support a major market transition for tens of thousands of buildings. The office needs resources to help building owners understand their obligations and pathways to compliance, and to coordinate with existing support entities like the NYC Accelerator. This is particularly important for harder-to-reach sectors, like co-ops and smaller buildings with fewer resources.
REBNY joins this group of stakeholders in recommending that OBEEP staffing is increased by an additional 10 to 15 staff lines to carry out the activities described above. In addition, REBNY also shares the belief that funding should be secured to ensure the City’s own requirements under Local Law 97 are met, which include reducing emissions from government operations 40 percent by 2025 and 50 percent by 2030. Since DOB is projected in FY23 to generate $338.6 million in revenue from licensing, construction permitting, franchise fees and other sources, and with total expenditures projected to be $216.1 million, REBNY believes this would be funding well utilized.
Department of Housing Preservation and Development (HPD)
REBNY shares the Council’s goals of identifying greater opportunities to expand housing access, including for the most vulnerable amongst us and those who have experienced homelessness. As such, ensuring appropriate funding for the Department of Housing Preservation and Development (HPD) to create or preserve affordable and supportive housing is critical.
Combatting our housing crisis requires the city to prioritize and invest in the tools necessary to create and preserve affordable and supportive housing. In the Mayor’s preliminary budget, for example, the HPD preliminary capital budget shows no increase from the $1.7 billion in spending projected for fiscal year 2023 by former Mayor Bill de Blasio’s administration. The New York Housing Conference has reported that $4 billion in City capital is required to help to begin to alleviate our housing crisis. This includes $2.5 billion in housing investment for new construction and preservation. REBNY believes that it would behoove the Council to consider additional investments in affordable housing through dollars being allocated for the new construction of affordable and supportive housing, and through the preservation of existing affordable and supportive housing.
In addition, greater funding should be considered for staffing to help facilitate the processing of Emergency Housing Vouchers through NYCHA and HPD. While these vouchers could assist thousands of New Yorkers facing homelessness, they must be utilized by the end of 2023. For this reason, funding in this fiscal year to facilitate their utilization is a worthy use of City dollars.
Thank you for your consideration on these points.