‘Upon close examination, the speaker’s proposal falls short and leaves the door wide open for the continuation of City Planning’s top-down, developer-driven rezonings by offering them a new shroud of legitimacy: a comprehensive plan engineered by city officials that fast-tracks rezonings.’

Adi Talwar

A view of Gowanus, Brooklyn.

I was pleasantly surprised by the bold new call for comprehensive planning emanating from the New York City Council. “Planning Together: A New Comprehensive Planning Framework for New York City” was issued by City Council Speaker Corey Johnson in December 2020. It is a long overdue and bold proposal that deserves close attention from community activists and critics of the Department of City Planning’s zoning policies and their role in the displacement of low-income communities of color.

However, upon close examination, the speaker’s proposal falls short and leaves the door wide open for the continuation of City Planning’s top-down, developer-driven rezonings by offering them a new shroud of legitimacy: a comprehensive plan engineered by city officials that fast-tracks rezonings. Both the plan and the planning process would continue to be controlled from the top, where lobbies with outsized influence rule. Community involvement would continue to center around weak, underfunded and often unrepresentative community boards. There are no guard rails to protect against the city’s shallow community participation games, disconnected from decision-making. Community boards remain understaffed, underfunded and underrepresented, and members continue to be appointees of the powerbrokers sitting in the offices of the borough presidents. 

Planning should be an on-going process at the neighborhood, city and regional levels. The goal should be transformative planning—dedicated to socio-economic equality and environmental justice while also being comprehensive. It should guarantee the participation and enfranchisement of historically excluded populations, not merely as endorsers but as central participants. As communities of color and immigrant communities—the majority of our population—continue to face wide environmental, public health and economic disparities, transformative planning must seek to change the balance of political power from real estate to real democracy, from Wall Street to Main Street, and from a City Hall overcharged with lobbyists to people power. For comprehensive planning to be truly democratic and equitable it must be an ongoing process led by a diverse assembly of those who live and work in the city, and not a technocratic elite under mayoral control. 

I have often pointed out how New York City is the only major city in the country that has never had a comprehensive long-range planning strategy. Instead it has relied on zoning, a piecemeal and patchwork system for regulating the use of land that too often serves the interests of developers. As the threats of climate change, sea level rise, and pollution intensify, and the city confronts huge challenges to reduce energy use and waste, it is now more urgent than ever that government at all levels break with business as usual and engage all New Yorkers in the search for deep transformations in the ways we live, work and play. Comprehensive planning could be the means for undoing and replacing antiquated and unsustainable environmental policies.

A decade ago City Limits recognized the significance of comprehensive planning in its special issue, Five Boroughs, One City, No Plan. However, subsequent efforts to put comprehensive planning on the agenda have been blocked by City Hall. In the most recent Charter Revision hearings, the chair of the City Planning Commission openly ridiculed planning. The City Planning Department has long nurtured the myth that its nearly inscrutable and overly complicated Zoning Resolution is a reasonable alternative to planning. In reality, zoning encourages the city’s decision makers to look only at individual proposed projects in limited areas. 

The strongest calls for comprehensive planning come from community activists, not planning professionals. Starting in 1977, following community demands for a greater say in planning decisions, the city’s Uniform Land Use Review Procedure (ULURP) gave 59 community boards an advisory role by allowing them to review zoning changes. Communities developed their own plans and in 1989, civil rights, environmental justice and housing advocates won changes to the city’s Charter allowing for the approval of community plans. Fulfilling its self-fulfilling prophecy that planning is just a fruitless exercise, the city’s political leadership has created one-shot “plans”—really flashy reports—that mostly end up on the proverbial shelf.

While the new City Council proposal calls for an “ongoing participatory planning process” to help plan for our infrastructure, “participation” by itself is no guarantee of democracy. We’ve had enough of DCP’s “participation games” and tightly engineered ULURP public hearings. The council proposal foresees the development of “scenarios” for every neighborhood in the city, but allows community votes to remain only “advisory,” a term meaning they will not count. 

The most unfortunate part of the City Council proposal is its utter failure to break with DCP’s fixation on growth in real estate development as the driver of planning. Even when it calls for “equitable growth,” the implication is that equity will occur only when there is growth. To understand what is wrong with this philosophy we only need to look at the results from two decades of both voluntary and mandatory inclusionary zoning, when the number of people without homes skyrocketed, public housing deteriorated, and “affordable housing” became unaffordable. 

To its credit, the council’s proposal recognizes displacement and inequality as categories for analysis. However, we need much more than development of their “displacement index.” The city must actively interfere with the forces driving the displacement of communities of color.

In sum, “Planning Together” is a first step but needs serious amendment. It should include the following:

  • Make fully-funded community-based planning an integral part of the comprehensive planning process.
  • Establish a planning leadership that reflects the diversity of the population at both citywide and neighborhood levels by incorporating representatives from community, racial justice, and environmental justice organizations in the leadership of the planning process. 
  • Fully fund the city’s 59 community boards to develop their own plans in close coordination with the citywide planning process.
  • Make comprehensive planning an on-going process at all levels and not just a once-in-a-decade occurrence. 
  • Undertake a comprehensive revision of the Zoning Resolution with wide participation by communities, and revisions that guarantee zoning’s consistency with comprehensive plans.

Planning can be difficult and time consuming in such a large and diverse city with hundreds of neighborhoods, but that doesn’t mean it shouldn’t be done. Over a century of rule by zoning has left us with an aging building stock that is a major contributor to global warming, a chaotic and inadequate street network, a public transit system in need of repair, outmoded systems for energy and waste, an ineffective system of public safety, and one of the most racially and economically unequal populations on the planet. 

Tom Angotti is Professor Emeritus of Urban Policy & Planning at Hunter College and The Graduate Center at CUNY, as well as the author of “New York For Sale” (2008) and editor of “Transformative Planning” (2020).

15 thoughts on “Opinion: Top-Down Comprehensive Planning Will Further Empower Those on Top

  1. The type of planning that we are all upset about is more than a matter of the haves versus the have-nots. Riverdale (Bronx) which is considered middle-class to upscale finds itself fighting continuously with as-of-right projects that are increasing density. In unacceptable most cases, we also lose.

    • If a project is as-of-right, it’s nearly impossible to stop. You need to organize and ask your Councilmember to propose a downsizing of the effected areas. It’s not an easy process but it can be done.

  2. NYC is too large to have ‘Comprehensive Plan’. Rezonings are basically a local issue and the impetus for them should come from local elected officials, not from some Comprehensive Plan.

    • Do we even have “local elected officials” in New York City?
      Those on the Community boards are appointed from above and even their take on a rezoning is advisory; they aren’t required to assess or represent a dominant perspective in a community anyway because they aren’t community representatives. And then there is the city council elected who represent on average 160,000 individuals, they employ no method to gather a collective community perspective on planning actions. But of course, they don’t think they need to, they are the “smart people” after all who know best. So long as they “teach” us, through top-down run propaganda sessions, just what kind of planning we want, these council representatives then feel confidant in branding themselves as on the side of good, at least as they see it. But it hard to completely fault them, how could anyone gauge a community of 160,000 individuals with no lower filtering, or democratic structure to do so?

      • ‘ And then there is the city council elected who represent on average 160,000 individuals, they employ no method to gather a collective community perspective on planning actions. ‘

        But at least the city councilmember is elected. Some councilmembers are better than others when it comes to local planning. The process is not perfect.

        The east an south shores of Staten Island were downzoned in 2005-06 after years of work by our local councilmembers and our borough president. All involved were very conscientious, including the numerous local civic groups involved. Maybe New Yorkers have to elect better people.

        SI downzonings – https://www.nytimes.com/2005/10/10/nyregion/in-a-stillgrowing-city-some-neighborhoods-say-slow-down.html

  3. As a member of Open New York, I have been advocating for more affordable housing in New York City but when it comes to the Gowanus rezoning, I want to thank the community for their help in better understand all the environmental problems that the EPA have been dealing with and other major environmental issues on the surrounding land. With this knowledge, I can no longer support the rezoning and wish that the Mayor De Blasio and Councilmember Brad Lander would take note of the communities valid concerns and not allow for the rezoning till all the environmental issues have been fully addressed.

  4. Thank you, Tom Angotti. I, too, read the Speaker’s Comp Planning proposal as too top down and I’ve contributed ideas for more community empowerment in the process to a coalition of civic & community groups studying the proposal. Your 5 points for “serious amendment” provide a good template for what to try to get changed in the bill as it proceeds thru the legislative process. One question: What pieces of what you (Tom) are asking for have to be accomplished in this one bill to make it acceptable, and what might be OK to fight for separately?

  5. Just because something is “as of right” does not mean that the plans are correct. The architects and engineers can not build unless the project is according to the appropriate zoning and follows the rules of the Zoning Code. Do not be fooled by “as of right” comments. Check plans and Zoning Diagrams.

    Also, you must know what the Zoning Lot is. Just try to figure out, in many cases, the metes and bounds of the original Zoning Lot.

  6. Look carefully at ALL the mayoral candidates and their housing/development platforms.
    So far, although it’s early, only Andrew Yang has explicitly supported community basing planning.

    • Scott Stringer has also proposed community-based planning; or at least he has said so on the stump. Though whether Yang, Stringer, or any other candidate, try to dig deeper than their catch phrases to find out what they really mean. How will they ensure that planning is really community-led or community-driven, and not just community-based in name only.
      One caveat, though, elections have consequences. So it makes sense for the mayor & council to set policy goals for communities to strive to meet thru their planning. Otherwise we could have too many communities planning as if they should have no role in solving city problems, such as lack of deeply affordable housing, segregation of neighborhoods & schools, tremendous inequality, or other issues. But how each community contributes to the solutions should be up to each community in its planning process.

  7. Tonight February 9, 2021 at 7 pm
    Professor Angotti will be presenting to the Community via Comunity Board 9 land use committee on this Bill. Folks are welcome to attend via Virtual and ask him questions on this Bill.
    Virtual ULURP/Land Use Committee Meeting –
    Tuesday, February 09, 2021, at 7PM
    Meeting ID: 918 5951 1080
    Passcode: 357999
    Mobile: +1(646) 876 9923 US (New York)

  8. The Speaker’s plan seeks to create new non elected bodies to further isolate land use decsion makers from the people. It’s so transparent. Just like the charter changes that created new levels of non elected agencies to oversea/ block public comment and effect involvement in other city decisions. It’s all about ending democratic government and confining the control of the oligarchs.

    What this new infrastructure will guarantee is the quality of life, community networks, small business, affordable housing as well as light and air will be sold off to the highest bidder with no effective oversight. Community boards have already be neutered.

    It’s appalling. A nice plan for pay to pay politicians but a bad idea for neighborhoods and human being.

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