This month, the City of New York released a thorough plan that outlines strategies to advance fair housing in New York over the next five years. The draft plan is the result of a two-year process called Where We Live NYC (WWL), led by the NYC Department of Housing Preservation and Development (HPD).

As advocates for racial equity and deeply affordable housing in New York, we appreciate HPD’s desire to address structural racism and other forms of exclusion baked into our city’s housing, education, transportation, and more. While this report does examine how race has shaped our neighborhoods (something the de Blasio administration has repeatedly ignored in the context of the East New York, East Harlem, Jerome and Inwood rezonings), we believe the city has an obligation to go far beyond the measures proposed. 

The Fair Housing Act of 1968 requires that governments receiving federal housing assistance take affirmative steps to advance fair housing. For years, local governments did little to live up to this mandate until the Obama administration attempted to increase enforcement in 2015 by requiring cities to submit detailed plans that outlined how they would work to meet their fair housing goals. Despite the Trump administration quickly peeling back these requirements, New York City prepared the WWL report to assess how it can better live up to their Fair Housing obligations.

The report provides information about the policies and practices that have created and maintained segregated, unequal neighborhoods in New York as well as snapshots of where New Yorkers of various demographics live today. The report goes to lengths to illustrate the consequences of residential segregation and neighborhood inequality. Several sections address the intersections between race, poverty and health, underscoring that Black and Latino New Yorkers are disproportionately likely to live in high-poverty neighborhoods with fewer amenities and opportunities. 

This context is valuable in building an understanding of New York’s landscape of inequality. That being said, we were disappointed to see that fully 80 percent of the report addresses where we are today, not where the city hopes we’ll go. This breakdown is frankly disappointing for a document that bills itself as a “plan,” and for which hundreds, if not thousands of solutions were proposed by community members and advocates.

Unfortunately, of the recommendations that are included, most seem to double down on existing policies or use ambiguous language rather than identifying specific new policies not yet being utilized by the city. A mere willingness to “explore” strategies like Community Land Trusts, legalizing basement apartment units, addressing discrimination on co-op boards, and other policies or proposals that would be new to New York City is not enough. Specific, firm policies and goals need to be identified and committed to, especially strategies not already being utilized in New York. 

Additionally, there are notable absences from the list of strategies the city proposes to implement over the next five years, including:

New Solutions for NYCHA

Though the report emphasizes the unique role of public housing as NYC’s largest source of deeply affordable housing, the proposed strategies to address NYCHA’s deficit of over $32 billion go no further than a reiteration of NYCHA 2.0, a plan housing advocates have repeatedly expressed serious concerns about, that relies on private investment and management as well as the construction of market-rate housing on NYCHA land. The WWL plan could have instead pledged to give residents a meaningful role in determining NYCHA’s future plans, committed to designating a public development entity for NYCHA, proposed the creation of public value recovery tools to secure funding and ensure public housing benefits from city land use actions, and/or joined advocates in calling for a significant increase in state funding to support NYCHA. These proposals could also help the city to abandon the parts of NYCHA 2.0 that have faced the greatest resistance from residents and advocates. 

Deeply Affordable Housing – Not Just Growth

The WWL report also emphasizes the need to increase housing supply to support fair housing goals in the long term, going so far as to praise the Greenpoint-Williamsburg rezoning: a plan that our research shows led to the massive displacement of Latinx residents, and one that many communities of color, who have disproportionately been targeted for rezonings, regard as a cautionary tale. But the plan says little about the importance of deeply affordable housing to meet the need where it is greatest. This is an issue that the de Blasio administration and affordable housing advocates have butted heads over for years, but for a plan that centers racial equity and acknowledges that Black and Latino families form a disproportionate share of the city’s lowest-income households, the absence of clear targets for addressing the needs of households making $15,000 a year and less is beyond disappointing. The WWL plan says little about strategies to end homelessness in our city, beyond directing readers to  another plan created outside the WWL process. 

Comprehensive & Community Planning

Unfortunately, the WWL plan doesn’t explicitly support the calls for community-based planning and comprehensive, citywide planning that many of us have been making for years. Contrary to what the de Blasio administration has often suggested, low-wealth communities of color aren’t anti-growth; they just want to make sure that development benefits them and doesn’t repeat the mistakes of the past.

While the WWL report acknowledges these concerns, we hope that the final draft of the plan goes further and adopts some of the suggestions for comprehensive planning we and the Thriving Communities Coalition developed. We believe that thoughtful citywide planning that centers racial equity and is responsive to local priorities can move us forward past the impasse that occurs when the city ignores residents’ concerns about racialized displacement, an issue that factored heavily into the annulment of the Inwood rezoning, the impasse over the Bushwick rezoning and opposition by Councilmember Salamanca to the Southern Boulevard rezoning.

How We Live

The fact that the city plans to track and publish data on housing development, “as well as demographic and socioeconomic data, to inform priorities in decision-making,” and to “Develop standardized race and social equity tools to help evaluate and guide the city’s capital planning and budgeting processes” is an encouraging first step towards providing more transparency in how public dollars are invested. 

However, the city needs to do more to track indicators of opportunity and community well-being over time. As the city’s own report makes clear, segregation and inequality have major effects on health outcomes, employment opportunities, and more. To know if plans adopted pursuant to WWL are succeeding, we need to know if and when people start to see the effect in their everyday lives. Cities like St. Louis track equity indicators to help assess if programs are having a positive impact on marginalized groups and communities, and New York should do the same.

The city is soliciting public comments on the draft plan, which we plan to submit before the deadline in March. We will also continue to fight for racial equity impact legislation to assess the impact of the city’s  land use actions, a requirement we believe advances the goals of WWL in a tangible way. As James Baldwin said, “Not everything that is faced can be changed, but nothing can be changed until it is faced.” We are glad that the WWL plan has forced New York to face some hard truths about the kind of city we are, but we will continue the fight to secure changes that have been too long in coming.

Maxwell Cabello is the senior policy and land use analyst at Churches United For Fair Housing. Adrien Weibgen is a racial justice policy advocate.