NYC’s Draft Fair Housing Growth Strategy Misses the Mark

ANHD fought alongside the City Council to pass the Fair Housing Framework (Local Law 167) in 2023 to help create a more equitable distribution of new housing development throughout the city, and create a plan for housing with equity as an explicit goal, not an afterthought. We eagerly awaited the City’s first Fair Housing Growth Strategy.

Now, having reviewed the draft report, we are disappointed and deeply concerned.

Most fundamentally, the draft report does not seem to undertake the type of analysis that is required by the law: a nuanced look at not just the total amount of housing that’s needed in our city, but the amount of affordable, deeply affordable, and supportive housing that’s needed to truly serve New Yorkers.

By forgoing this analysis, the City makes the same fatal error that so many past administrations have made – it sets a huge, mostly market rate unit count goal, with the implicit assumption that this housing will trickle down to serve the needs of the low income New Yorkers who have borne the brunt of our City’s housing affordability crisis for years.

Roughly three-quarters of the total new housing units the Administration aims to create would be market rate, and less than half of the “affordable” units would serve those below 60% of Area Median Income. This is an alarming approach from an administration focused on affordability. And the report never justifies this breakdown against its own housing needs data, because that data is never presented in the first place.

This same market-rate heavy breakdown persists in the City’s Community District targets. While the law required the City to weigh such factors as displacement risk, access to transit and jobs, and climate impacts when setting housing targets for each community district, the methodology shared in this draft report relies almost entirely on one factor, recent production, and does not show how the other required factors shaped the numbers.

ANHD has said for years that New York needs more housing, at various income levels and across neighborhoods. But a report mandated by a fair housing law has to do more than set a large top-line number and call it equity. It has to show, district by district, how the plan closes gaps this city’s housing market has never closed on its own. Otherwise, we aren’t planning for affordability; and we aren’t planning in a way that will actually reduce the racial and economic disparities that are so pervasive in the housing market.

The comment period is open through September 19, and the final report is due October 1. We are calling on the City to immediately publish the full methodology used to arrive at the targets in the draft report, and to perform any additional analysis necessary to ensure that the citywide targets, community district targets, and strategic interventions in the final report are fully responsive to the the breakdowns and criteria outlined in the law. We also call on the City Council to emphasize to the administration the importance of addressing these gaps before the report is finalized.

ANHD believes in the potential of the Fair Housing Growth Strategy as originally laid out in the law. And we have been impressed by many of the housing commitments and strategies laid out thus far by the Mamdani administration. But this draft misses the mark. The City has an opportunity and an obligation to take a stand and make clear that it takes seriously the need to affirmatively pursue fair housing – as it did with the commitment to continue producing the Where We Live plan even as the federal government has abandoned the mandate to affirmatively further fair housing. We hope that in the final version of the report, the City will look honestly and with nuance at current conditions and needs, develop realistic goals to build a more equitable and accessible housing landscape, and outline strategies to tackle the real barriers that stand in our way.