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  • February 15, 2024
    Yes to Housing Coalition Letter to Speaker Adams on City of Yes for Housing

    February 15, 2024

    Speaker Adrienne Adams
    City Hall
    New York, NY 10007

    Dear Speaker Adams,

    Our coalition of housing advocates, experts, developers and civic leaders are reaching out to express support for the City of Yes for Housing Opportunity zoning text amendment. The Yes to Housing coalition believes the proposals in the City of Yes will generate more affordable housing and also make it easier to add housing in every neighborhood across the city, even in neighborhoods that have seen little new housing added in recent decades.

    This is a critical moment—New York City is experiencing a severe and growing housing and affordability crisis. Nearly 600,000 households are severely burdened in the city, paying more than 50% of their income on rent, while more than 145,000 people experienced homelessness and stayed in a city shelter on a single night last month. The solution to the crisis is more housing and more affordable housing.

    In addition, housing production, especially affordable housing production, is not shared equitably across the city. Some neighborhoods are doing more to improve their neighborhoods and address the crisis than others. Data from our NYC Housing Tracker shows that 16 City Council districts produced more than 2,000 units of new affordable housing from 2016-2022, mostly in neighborhoods in the South Bronx, Central Brooklyn, East River waterfront in Brooklyn and Queens, and Southeast Queens. Meanwhile, 17 districts produced fewer than 400 units over that time, with nine districts producing less than 200 units over the nine years. The disparity in neighborhood affordable housing production is particularly stark when analyzed by race and ethnicity: in the top third of districts in terms of affordable housing production, on average 72 percent of residents are Black or Latinx, while in the bottom third of districts by housing production just 35 percent of residents are Black or Latinx.

    Our zoning resolution is severely outdated and riddled with decades of zoning barriers to building affordable housing. Zoning is a powerful tool that can ease barriers to housing production and ensure that every neighborhood does its part to add to our affordable housing supply.

    As a coalition of more than 100 members, we enthusiastically support the provisions in the City of Yes for Housing Opportunity, which will allow for housing growth across the city and encourage all neighborhoods to add housing. We support giving a density bonus for affordable housing, removing barriers to moderate density in more neighborhoods including around transit and on campuses, allowing for more conversions to residential housing, and removing parking mandates. We expect more details and look forward to discussing potential modifications, but these proposals cannot be weakened.

    The City of Yes for Housing Opportunity will modify outdated zoning rules to allow NYC to combat its housing shortage. We need forward-thinking, citywide solutions like this to ensure that we are adding critically needed housing in each neighborhood. We look forward to working with you and the rest of the City Council further to shape a more equitable and affordable city for all.

     

    Sincerely,

    American Institute of Architects New York

    Amie Gross Architects

    The Arker Companies

    Ascendant Neighborhood Development Corporation

    Asian Americans For Equality

    Association of Tenants of Lincoln Towers

    BRC

    Breaking Ground Bright Power, Inc.

    Broadway Community, Inc.

    Bronx Pro Group LLC

    C&V Consulting

    Camba

    Camber Property Group

    Catholic Charities POP Development

    Catholic Community Relations Council

    Chinatown BID/Partnership

    Citizens Housing and Planning Council

    CLOTH

    Community Housing Improvement Program (CHIP)

    Community Preservation Corporation

    Concern Housing

    Corporation for Supportive Housing (CSH)

    Curtis + Ginsberg Architects LLP

    Dattner Architects

    The Delaine Companies

    Designing the WE

    Douglaston Development

    East End YIMBY

    Fair Housing Justice Center

    Fifth Avenue Committee

    Fordham-Bedford Housing Corporation

    Forsyth Street Advisors

    FXCollaborative Architects LLP

    Genesis Companies

    Geto & de Milly, Inc.

    Gotham Organization

    Habitat for Humanity New York City and Westchester County

    The Health & Housing Consortium

    HELP USA

    Homeless Services United

    Housing and Services, Inc.

    Housing Rights Initiative Interfaith Assembly on Homelessness and Housing

    JASA

    Joy Construction

    K2New Business Development

    L+M Development Partners

    Lantern Community Services

    LISC NY

    Low income Investment Fund (LIIF)

    Macquesten Development

    Maddd Equities

    Matrix New World Engineering

    MBD Community Housing Corp.

    Mega Contracting

    Milestone Development LLC

    Neighborhood Housing Services of NYC

    Neighborhood Restore HDFC

    New Destiny Housing

    NYC Housing Partnership

    New York Building Congress

    New York Housing Conference

    New York State Council of Churches

    The NHP Foundation

    The NRP Group

    NYSAFAH

    Open New York

    Open Plans

    Perci PBC

    Phipps Houses

    PRC

    Project Renewal

    Purpose by Design Architects

    Real Estate Board of New York (REBNY)

    Red Stone Equity Partners

    Regional Plan Association

    Riders Alliance

    RiseBoro Community Partnership

    Robin Hood Rockabill Development, LLC

    Safe Horizon

    Selfhelp Realty Group

    Services for the Underserved Settlement Housing Fund, Inc.

    Shams DaBaron, Da Housing Hero

    SKA Marin

    Slate Property Group

    SMJ Development

    St. Nicks Alliance

    Supportive Housing Network of New York

    TF Cornerstone

    Trinity Financial

    UHAB

    Unique People Services

    University Neighborhood Housing Program, Inc.

    Urban Architectural Initiatives RA P.C.

    Urban Pathways

    VIP Community Services

    Volunteers of America-Greater New York

    Wavecrest Management

    Westhab

    West Side Federation for Senior and Supportive Housing

    WHEDco

    Xenolith Partners LLC

    Youth Action Programs and Homes Inc.

    Yuco Management

    Zillow

     

    CC:
    Councilmember Pierina Sanchez
    Chair, Committee on Housing and Buildings

    Councilmember Rafael Salamanca
    Chair, Committee on Land Use

    Councilmember Kevin Riley,
    Chair, Subcommittee on Zoning and Franchises

    February 14, 2024
    AIANY Testimony for the 2024 Joint Legislative Budget Hearing on Housing

    February 14, 2024

    AIA New York Testimony for the 2024 Joint Legislative Budget Hearing on Housing

    Thank you, Senator Krueger, Assemblymember Weinstein, Senator Kavanagh, Assemblymember Rosenthal, and members of the joint legislative budget committee for your consideration of American Institute of Architects New York’s (AIANY) budget testimony. AIANY represents more than 5,000 architects and design professionals committed to positively impacting the physical and social qualities of our state.

    AIANY is deeply grateful for the Legislature’s commitment and partnership in addressing the challenges associated with the housing crisis by enacting policies and providing critical funding resulting in the development of thousands of affordable units. However, there is still much more to be done to dig New York out of the crippling housing crisis it faces.

    The current housing crisis in New York is undeniable and has created a precarious set of circumstances for many households that is unsustainable. As a result, we have seen a sizable out-migration of working-class families earning between $32,000 and $65,000 followed by those earning $104,000 to $172,000 a year; a disproportionate amount of those families leaving the city are Black and Hispanic, according to a recent study by the Fiscal Policy Institute. According to the Community Service Society of New York’s 2023 Unheard Third Survey, 47% of New Yorkers under 200% of the Federal Poverty Level (FPL) and 31% of New Yorkers over 200% of the FPL said their biggest housing problem was being able to afford rent, mortgage, and maintenance costs. Over 1 million households (53%) in NYC were considered rent burdened, and approximately 60% of this group was considered severely rent burdened, according to the State Comptroller’s 2021 Report on the Cost of Living in NYC. The report also found that the average rental price in Manhattan is over $5,000, which is no doubt connected to the failure to build affordable housing.

    The high housing costs are compounded by extremely low vacancy rates in NYC leaving New Yorkers in a tenuous situation where tenants have little to no power leaving them with no choice or mobility in the housing market, especially at the lowest levels of rent. The recent NYC Housing and Vacancy Survey, conducted by the US Census Bureau every three years, found that citywide vacancy rates are the lowest they have been since 1968 at 1.41%, which is down from 4.5% in 2021. In New York, a vacancy rate of less than 5% is deemed a “housing emergency;” based on the recent survey findings, it’s evident that the current situation is dire for New Yorkers. The 2023 survey found that the average NYC household has an income of $70,000 and spends more than half of their income on rent, making them “severely rent burdened”. Vacancy rates are lowest – under 1% – for lower rent levels, but the 2023 survey found that 3.39% of homes renting for more than $2,400 were vacant and available, which is a monumental drop from the 12.64% vacancy rate in 2021. Housing of all types is needed in New York to tackle the current situation.

    In addition to the housing crisis, New York is seeing record office vacancy rates as a result of the COVID-19 pandemic. The cost of commercial properties is at rates unseen since 2002, which has created a unique opportunity for office to residential conversion projects where office vacancy rates are higher than normal and residential vacancy rates are significantly lower than demand. To maximize this opportunity, there are necessary changes to state law and zoning regulations to be made to create a feasible pathway for conversion projects. Office-to-residential conversions have been identified as a key tool in the toolbox for generating housing of all types and at all levels in a sustainable way; therefore, the state must make the following changes to expand the number of eligible properties, revise regulations and requirements to allow flexibility for the nuances of conversion projects, and enact a tax incentive program to enable the inclusion of affordable units in conversion projects.

    AIA New York strongly supports multiple housing related proposals included in Governor Hochul’s Fiscal Year 2025 Executive Budget in the Education, Labor, and Family Assistance Article VII Legislation. We encourage the Legislature to consider the following proposals as you negotiate and authorize the final State Budget.

    • Part Q: Authorize New York City and the New York State Urban Development Corporation to Allow for Denser Residential Development

    Since 1961, there has been a cap on floor area ratio in New York City at 12.0, which limits the size of residential buildings to 12 times the size of the lot on which they are built. The challenge with the FAR cap for conversion projects is that the cap only applies to residential buildings and many commercial buildings are greater than 12 FAR, so the cap serves as an impediment to office to residential conversions. This proposed amendment to the Multiple Dwelling Law will authorize New York City and Urban Development Corporation to determine floor area ratio via a zoning law, ordinance, or resolution, and it will remedy one of the first roadblocks to office to residential conversions.

    • Part R: Authorize Tax Incentive Benefits for Converting Commercial Property to Affordable Housing

    Without government incentives or subsidies, conversion projects with affordable units are effectively impossible. Conversion projects are expensive to start with, and adding on affordable units without balancing the cost with government assistance is not feasible. As seen with the 421g program, the tax incentive was a valuable tool for converting commercial space to residential use in Lower Manhattan; however, because the program lacked affordability requirements, there were no affordable units produced as a result of the 421g program.

    A key lesson learned from the 421g program is that there are three things that need to align in order for conversions to be feasible:

    1. Economic – There needs to be a significant decline in office value where there is high vacancy levels and buildings are functionally obsolete leaving owners at a fork in the road where they need to reinvest in their buildings anyway given their point in the depreciation cycle.
    2. Physical – The floor plate must work for residential use.
    3. Regulatory – The conversion must be allowed under the city’s zoning regulations and the state’s Multiple Dwelling Law, and it must not be subjected to the FAR cap.

    In the current economic climate where interest rates and construction costs are high, a new tax incentive program is essential to producing housing in NYC and creating an opportunity for the inclusion of affordable units to be feasible. This bill would establish the Affordable Housing from Commercial Conversion Tax Incentive Benefits program. This proposal is critical for conversion projects to include affordable housing and create a pathway for these projects to be financially feasible.

    • Part S: Enable the City of New York to Create a Pathway to Legalize Pre-Existing Basement and Cellar Dwelling Units in New York City

    This bill would authorize NYC to establish by local law a program to provide amnesty to landlords who convert basement and cellar dwelling units currently in existence to legal dwelling units, provided they are consistent with the protection of health and safety requirements. Since these units are currently illegal and unregulated, tenants lack basic rights and may be living in unsafe conditions. This proposal would create a pathway to regulate these units and bring them up to code. Additionally, AIANY recommends defining which units should be eligible in terms of light and air, rather than the current distinction between basement and cellar units. With the goal of this proposal being the creation of safe units, light and air standards must be prioritized.

    • Part T: Extend the Project Completion Deadline for Vested Projects in the Real Property Tax Law 421a

    This bill would extend the deadline to complete a vested Real Property Tax Law 421a project from June 15, 2026 to June 15, 2031. As a result of the pandemic, construction on many residential buildings slowed leaving many projects in the 421a pipeline at risk of missing the completion deadline and no longer being eligible for the program. Many of the projects currently in the pipeline at various stages of the design and construction process are facing tough decisions about how to move forward with their project and if a change of course needs to be made. Some projects have switched from affordable to market rate or rental to co-op, which has placed a number of these valuable affordable rental units at risk. To avoid additional projects stuck in the pipeline from facing this difficult decision, AIANY urges the Legislature to extend the completion deadline for the former 421a program.

    • Part U: Create New Tax Abatement for Rental Housing Construction

    The need for an equivalent 421a program cannot be overstated. In the wake of the former program sunsetting, the challenges to build housing in NYC have been compounded by soaring interest rates and construction costs, resulting in the production of new affordable housing being unfeasible. Even with existing government subsidies, the current high-cost environment makes it difficult to build rental housing at rents that New Yorkers can afford. Many developers have indicated that they plan to wait until a new program is implemented before moving ahead with housing projects, which leaves New Yorkers is a tenuous position as the affordable housing crisis forges on. This bill would establish the Affordable Neighborhoods for New Yorkers Tax Incentive Program to replace to expire 421a program. This proposal would apply to both homeownership developments and rental units. AIANY heartily supports to create of new housing of all types and prices, and this proposal is an essential tool to do so.

    An additional change to the Multiple Dwelling Law missing from the FY2025 Executive Budget that is needed to be made in order to open up the fully scale of opportunities for office to residential conversion projects is to amend the date conversions are permitted from 1961 to 1990. Currently, this arbitrary date is restricting conversions of a number of commercial sites to residential use. By extending the date to 1990, approximately 120 million square feet of office buildings will be eligible for conversion.

    In addition, the 1961 date restricts conversion projects with tenants in unit. One of the many challenges with conversion projects is that buildings are often not entirely empty, and it is often too costly to buy or wait out tenants’ leases. For buildings built before 1961, this is not an issue, and conversions can begin with tenants in unit and the construction can take place around the tenant; however, for buildings built after 1961, they are prohibited from conversion with a single tenant in place.

    Additionally, AIANY is supportive of legislation – S05560/A2508, A06670, and S05172-A/A05342-A – to encourage transit-oriented development and legalize accessory dwelling units. Transit-oriented development is an important tool to increase housing stock, encourage use of public transit, reduce greenhouse gas emissions, promote local economic development, and increase social and economic mobility for New York’s population across the state. Additionally, it helps to create neighborhoods with a mix of affordable and market rate housing, which can help to reduce income and racial segregation in the city. Accessory dwelling units (ADU) are another tool in the toolbox to generate housing and create opportunities to build wealth. For homeowners, ADUs can create a supplemental source of income that can be used to help pay for property taxes and expenses. They can also serve as supportive housing to enable seniors to age in place and have live-in caretakers or provide housing at a manageable price for adult children. This tool can help allow people to live in their neighborhood of choice as the cost of housing rises dramatically, and it provides a housing option for people who are unable to live near their job or family in exclusionary neighborhoods with little to no affordable housing.

    AIANY encourages the legislature to consider these proposals as you negotiate and authorize the final Fiscal Year 2025 State Budget.

    February 07, 2024
    AIANY Testimony for the 2024 Joint Legislative Budget Hearing on Environmental Conservation

    February 7, 2024 

     AIA New York Testimony for the 2024 Joint Legislative Budget Hearing on Environmental Conservation  

     Thank you, Senator Krueger, Assemblymember Weinstein, Senator Harckham, Assemblymember Glick, and members of this joint legislative budget committee, for your consideration of American Institute of Architects New York’s budget testimony. AIANY represents more than 5,000 architects and design professionals committed to positively impacting the physical and social qualities of our state. 

     AIANY strongly supports Part P of the Fiscal Year 2025 Executive Budget Transportation, Economic Development, and Environmental Conservation Article VII legislation, the Affordable Gas Transition Act. This proposal would make critical changes to the Public Service Law related to the mission of the Public Service Commission by eliminating the “100 foot” rule and making other amendments to meet the Climate Leadership and Community Protection Act (CLCPA) greenhouse gas emission reduction requirements. The “100 foot” rule requires utilities to supply gas to any customers who want it and demands that ratepayers foot the bill to hook them up if those customers live within 100 feet of an existing line.  

     The current law requires gas companies to expand natural gas infrastructure at the request of consumers regardless of the cost of the expansion or if more climate friendly alternatives would be more cost-effective. These rules constrain the Public Service Commission from meeting the CLCPA’s emission reduction requirements and meeting evolving demands of the marketplace. The CLCPA is one of the most aggressive and ambitious climate laws in the United States; the law sets significant greenhouse gas emission reductions in all sectors of New York’s economy and directs agencies to focus on equity in the transition.  

     The Affordable Gas Transition Act will allow customers who want to use gas to do so while enabling the cost-effective transition to clean, energy efficient electric heating and other alternatives to natural gas. This bill will reduce New York’s reliance on gas, make progress on the transition to more sustainable utilities, and prevent utilities from passing the costs of new gas lines onto existing customers.  

     Additionally, this proposal will protect existing customers from the financial burden of investment in fossil fuel infrastructure while not impacting the safe and reliable service they already receive.  

    As we move towards a fully electric future, it is vital our building codes and appliance efficiency standards modernize with this transition in order to meet New York’s ambitious climate goals. 

    AIANY encourages the legislature to consider the proposal as you negotiate and authorize the final State Budget. 

    February 07, 2024
    AIANY Testimony to the City Planning Commission in Support of the Green Fast Track for Housing

    Chair Dan Garodnick
    City Planning Commission
    120 Broadway
    New York, NY 10271

    February 7, 2024

    RE: AIA New York Testimony to the City Planning Commission in Support of the Green Fast Track for Housing

    Dear Chair Garodnick,

    American Institute of Architects New York writes to express our support for the proposed amendment to Chapter 5 of the City Planning Commission’s rules to exempt certain housing and related actions from review under SEQRA and CEQR procedures, also known as the Green Fast Track for Housing. AIANY represents more than 5,000 architects and design professionals committed to positively impacting the physical and social qualities of our city.

    With the housing crisis in NYC raging on, the Green Fast Track for Housing will make important changes to address the lengthy and costly environmental review process. Among the many costly factors to building housing in NYC, the time and resources required to complete environmental reviews that are ultimately unnecessary can potentially derail a project. The proposed rule changes will make commonsense adjustments to the environmental review process to streamline the process for climate-friendly housing by up to 24 months and save each project approximately $100,000. Eligible projects are housing that uses all-electric heating instead of fossil fuels, are located outside of vulnerable coastal areas, in areas with industrial emissions or away from major roads, and that meet specific mitigation standards for areas with hazardous materials or in ambient noise.

    The Green Fast Track for Housing will be a valuable tool for achieving the city’s goal of building 500,000 new homes by 2033. Housing production has lagged far behind job growth, with housing increasing by 4% compared to 22% job growth in the same period. This proposal will be critical to breaking down some of the barriers to building housing and start delivering quicker for New Yorkers.

    AIANY urges the City Planning Commission to approve the proposed amendment, Green Fast Track for Housing, and get New York building housing faster.

    Sincerely,

    Jesse Lazar, Executive Director

    January 24, 2024
    AIANY Testimony to City Planning Commission in Support of City of Yes for Economic Opportunity

    January 24, 2024

    AIA New York Testimony to the City Planning Commission on City of Yes for Economic Opportunity Zoning Text Amendment Proposal

    Thank you, Chair Garodnick and members of the City Planning Commission, for holding this hearing today. I am Bria Donohue, Government Affairs Manager at AIA New York. We represent more than 5,000 architects and design professionals committed to positively impacting the physical and social qualities of our city.

    AIA New York strongly supports Mayor Adams’s proposed citywide zoning text amendment, City of Yes for Economic Opportunity. The proposed changes in the amendment make much needed updates to modernize New York City’s zoning regulations to support small businesses, create thriving commercial corridors, and bolster New York City’s economic recovery.

    AIANY is particularly supportive of the proposals that would allow for more mixed-use potential in neighborhoods, permit more adaptive reuse, and develop a commercial streetscape framework that is pedestrian friendly.

    In recent years, living patterns have shifted such that economic revitalization needs to be distributed throughout the city more evenly than how the city’s economy has existed in the past. City of Yes for Economic Opportunity would enable the city to unlock the economic potential in both historically economically significant neighborhoods and historically economically depressed neighborhoods. These proposals are ambitious and will require significant interagency coordination and collaboration as well as sufficient agency staff to be successful.

    City of Yes for Economic Opportunity is a commonsense initiative that will make necessary changes to New York City’s antiquated rules that date back to 1961 to create more opportunities for small businesses and commercial corridors to thrive and support the economic growth and innovation that are the cornerstone of the city’s economy. AIA New York urges the City Planning Commission to approve the proposed zoning text amendment.

    January 22, 2024
    AIANY Letter to Governor Hochul on FY25 Executive Budget

    The Honorable Kathy Hochul
    Governor of New York State
    NYS State Capitol Building
    Albany, NY 12224

    January 22, 2024

    RE: AIA New York’s Support for Governor Hochul’s FY25 Executive Budget

    Dear Governor Hochul,

    American Institute of Architects New York writes to express our support for a number of housing, sustainability, and transportation and infrastructure policies in the Fiscal Year 2025 New York State Executive Budget. AIANY represents more than 5,000 architects and design professionals committed to positively impacting the physical and social qualities of New York.

    New York is facing crises like never before with affordable housing being out of reach for many New Yorkers, more frequent extreme weather events, and an uncoordinated use of public space. We applaud the Governor’s approach to tackling these core issues burdening New Yorkers, specifically affordable housing. While there is always more to be done, the policies outlined in the FY25 Executive Budget are important incremental steps towards addressing these challenges and are essential towards achieving these overarching goals of change.

    AIANY is particularly supportive of the housing policies included in the FY25 Executive Budget. A comprehensive approach combining incentives and the elimination of key barriers for adaptive reuse and development are essential steps towards addressing New York’s housing affordability crisis. By extending the expired 421a program’s completion date to 2031, it will allow the housing units stuck in the pipeline to be developed as initially planned instead of forcing developers to reevaluate plans to make projects economically feasible. Creating a new program similar to the former 421a program will be a tool to encourage development, and more specifically, the development of more affordable units. In the current economic climate, tax incentives are necessary tools for developers to build affordable units, and without it, these projects are nearly impossible.

    In looking at adaptive reuse, enabling office to residential conversions and eliminating a number of key barriers to conversion projects will be valuable in tackling the ongoing crisis. Any additional housing unit created takes pressure off of the housing market, which is being tied down by extremely low vacancy rates leaving tenants with little to no options and creating poor and unaffordable living situations; this is a particularly sensitive issue for the working-class New Yorkers who are leaving the state due to the lack of affordability. One of the main barriers to office to residential conversions is the FAR cap. Commercials buildings are permitted a greater FAR than residential buildings, so conversions of commercial buildings greater than 12 FAR face an immediate roadblock. AIANY strongly supports providing NYC with the authority to use the local land use review process to allow for denser residential development.

    Additionally, AIANY supports creating a pathway to legalize basement dwellings by giving NYC the authority to provide amnesty for units that meet health and safety standards. As long-time advocates of health and safety standards, particularly around light and air, we want to ensure that the tenants living in these basement units have access to the full spectrum of protections available to them and make sure these are not subpar units. AIANY also supports the directive to DEC to identify efficiencies in its SEQR regulations to promote environmentally friendly housing growth.

    In terms of climate and sustainability policy, AIANY supports the Affordable Gas Transition Act proposed in the FY25 Executive Budget. The elimination of the “100 foot” rule will have significant impact on reaching the state and city’s ambitious electrification and emission reduction goals, while allowing the elimination of burdens on existing customers.

    AIANY also supports the continued expansion and investment in NYC’s public transit network and are pleased to see the extension of the Second Avenue Subway westward on 125th Street and the Interborough Expressway project in the FY25 Executive Budget.

    New Yorkers need to see the state taking action to improve their daily lives, and AIANY believes these policies are a step in the right direction towards remedying the most pressing housing, sustainability, and transportation and infrastructure challenges. AIANY looks forward to continuing to work with the governor and the state legislature on a final budget.

    Sincerely,

    Jesse Lazar, Executive Director, American Institute of Architects New York (AIANY)

    December 18, 2023
    AIANY Testimony to NYS Assembly Committees on Housing and Cities on Affordable Housing Policy Recommendations

    December 18, 2023
    Subject: AIA New York Recommendations on New York State Affordable Housing Policy  

      Thank you, Assemblymember Rosenthal, Assemblymember Braunstein, and members of the New York State Assembly Committees on Housing and Cities, for holding this hearing today. I am Bria Donohue, Government Affairs Manager at American Institute of Architects New York. We represent 5,000 architects and design professionals committed to positively impacting the physical and social qualities of New York.  

     AIA New York strongly supports a comprehensive approach to increasing affordable housing supply by authorizing and eliminating the barriers to alternative solutions such as office to residential conversions and accessory dwelling units as well as creating incentive programs to encourage affordable housing development. 

    To address the ongoing affordable housing crisis, AIANY recommends the following state legislative solutions. 

    • Create a tax incentive program for affordable housing production that replaces and improves on the expired 421-a real property tax rebate  
    • Facilitate office to residential conversions with incentives for including affordable housing units (S05080); eliminate state floor area ratio (FAR) cap and give authority to NYC to determine FAR  
    • Legalize accessory dwelling units and create incentive program (S05172-A/A05342-A); establish an amnesty program for reporting basement apartments to bring units up to code without penalization (S02276-A/A01075-A) 
    • Encourage transit-oriented development (S05560/A2508 & A06670) 

    At its core, the solution to the current affordable housing crisis is to build more housing. Increasing the supply of housing will relieve some of the pressures on the housing market that negatively impact tenants. With an incredibly low vacancy rate, tenant protects are effectively nonexistent as there are little to no options. Vacancy rates are as low as 0.78% in the Bronx and 2.73% in Brooklyn, according to the 2021 NYC Housing Vacancy Survey; a healthy housing market has a vacancy rate between 7-8%.  

    The current affordable housing crisis in New York is undeniable and has created a set of circumstances that are unsustainable for many New Yorkers. As a result, we have seen a sizable migration out of New York City of working-class families earning between $32,000 and $65,000 followed by those earning $104,000 to $172,000 per year; a disproportionate amount of those families leaving the city are Black and Hispanic, according to a recent study by the Fiscal Policy Institute. These findings are reinforced by the Community Service Society of New York’s 2023 Unheard Third Survey data on housing challenges for low-income New Yorkers. According to the 2023 UHT, 52% of New Yorkers below 200% of the Federal Poverty Line and 42% of New Yorkers above 200% FPL choose affordable housing as what would increase their potential to get ahead economically. 47% of New Yorkers under 200% FPL and 31% of New Yorkers over 200% FPL said their biggest housing problem was being able to afford rent, mortgage, and maintenance costs. 27% of New Yorkers have fallen behind on rent, and low-income working mothers are most likely to have fallen behind or expect to fall behind on rent, at 45%. 

    One tool that was essential for developing affordable housing and proven effective for decades was the 421a tax abatement. This program accounted for a significant portion of all completed new housing citywide, according to a report from NYU Furman Center. The 421a program was a vital tool to increase the supply of non-luxury housing, which is the majority of new developments in New York City. Reinstating a similar tax incentive program to encourage affordable housing production is critical to making Mandatory Inclusionary Housing and the Universal Affordability Preference included in City of Yes for Housing Opportunity successful and effective for adding housing citywide across multiple income tiers.  

    Another tool to increase affordable housing supply is giving NYC the authority to determine the FAR cap and raising the FAR cap. The current FAR cap regulations are one of the key barriers to office to residential conversions. For the vast majority of development taking place in NYC, as well as throughout the rest of NYS, raising the FAR cap above 12 will have no impact; however, it is a critical hinderance to office to residential conversion projects, which are often above 12 FAR. By providing the city with the authority to determine FAR, more housing will be created via office to residential conversions.  

    An additional strategy to offset pressure on the housing market is to legalize accessory dwelling units. ADUs are a valuable tool for homeowners to use to unlock economic opportunity and build generational wealth. It is evident from the interest in the “Plus One ADU” pilot program, included in the FY2022 NYS Capital Budget, that there is an appetite for ADUs, with over 1,300 homeowners submitting a preliminary application for the program to receive financing of up to $395,000 to build an ADU.  

    We acknowledge that these policy recommendations will not resolve the entire affordable housing crisis; however, we firmly believe the solutions we have outlined in our testimony today will set New York on the right track and encourage new development while offsetting key pressures on the market that are having detrimental effects on New Yorkers. AIANY urges the New York State Assembly to pass policies to both encourage and eliminate barriers to development. New Yorkers need to see a shift in the housing market, and AIANY believes these policies are the right step towards remedying our affordable housing market. 

    December 15, 2023
    AIANY 2024 Legislative Agenda

    AIA New York 2024 Legislative Agenda

    American Institute of Architects New York (AIANY) is thrilled to present our 2024 Legislative Agenda for New York City and New York State. AIANY represents over 5,000 architects and design professionals committed to positively impacting the physical and social qualities of our city. The purpose of this document is to share an overview of the top policy priorities of the architecture and design community for the coming year and present recommendations to improve the built environment. Our attention in 2024 will be set on affordable housing, sustainability, public realm, transportation and infrastructure, and procurement policy. New York City is facing crises like never before with affordable housing being out of reach for many New Yorkers, more frequent extreme weather events, and an uncoordinated use of public space. This document presents a number of recommendations to remedy these persistent challenges for New Yorkers and details opportunities to take legislative action.

    Housing

    State

    • Create a tax incentive program for affordable housing production that replaces and improves on the expired 421-a real property tax rebate
    • Facilitate office to residential conversions with incentives for including affordable housing units (S05080); eliminate state floor area ratio (FAR) cap and give authority to NYC to determine FAR
    • Legalize accessory dwelling units and create incentive program (S05172-A/A05342-A); establish an amnesty program for reporting basement apartments to bring units up to code without penalization (S02276-A/A01075-A)
    • Encourage transit-oriented development (S05560/A2508 & A06670)

    City

    • Support City of Yes for Housing Opportunity—specifically proposals to incentivize affordable housing with Universal Affordability Preference, make office to residential conversions easier, encourage transit-oriented development, legalize housing above businesses on commercial streets to encourage mixed-use communities, eliminate parking mandates, and allow for accessory dwelling units.

     

    Sustainability

    State

    • Support the NY HEAT Act (S2016-A)
    • Investment in decarbonizing and increasing energy grid capacity
    • Establish an incentive program to reduce embodied carbon in new development and encourage material reuse

    City

    • Support City of Yes for Carbon Neutrality—specifically the elements that enable and reward energy efficient design and retrofits, building electrification and associated equipment, rooftop and other elevated solar, battery storage, electric vehicle charging, and infrastructure to support bicycles and other micromobility options
    • Support Local Law 97 implementation as the first emission limit goes into effect for buildings over 25,000 square feet
    • Invest in citywide resiliency measures to protect at-risk communities from extreme weather events

     

     

    Transportation and Infrastructure

    State

    • Support congestion pricing without excessive exemptions
    • Maintain robust and reliable funding for MTA Capital Program
    • Assure funding for ongoing state-of-good repairs for local transportation infrastructure to maintain and protect critical assets
    • Secure funding for critical transportation projects during the planning, design, or construction phases – specifically, Penn Station Redevelopment, Penn Access, Gateway, Brooklyn-Queens Expressway, Cross Bronx Expressway, Inter-Borough Expressway, and Second Avenue Subway Phase Two

    City

    • Full fund expansion of citywide bike network and busway to improve NYC streetscape as recommended by the NYC Streets Plan to meet City Council mandates
    • Amend zoning to allow for higher density development within ¼ mile of subway or commuter rail stations and major bus interchanges

     

    Public Realm

    City

    • Support Dining Out NYC program implementation and Kit of Parts design guidelines
    • Support City of Yes for Economic Opportunity—specifically proposals that would allow for more mixed-use potential in neighborhoods, permit more adaptive reuse, and develop a commercial streetscape framework that is pedestrian friendly
    • Develop comprehensive and thoughtful approach to curb management on issues ranging from micro-distribution hubs to commercial loading zones to on-street charging
    • Increase public bathroom access and improve maintenance of existing facilities
    • Create a comprehensive citywide waste plan to address waste distribution and reuse of compost on the building and neighborhood level; reduce trash by containerizing waste for commercial buildings

     

    Government Agencies, Policies, and Rules

    State

    • Eliminate low bid procurement for capital projects and use quality-based selection (QBS)
    • Improve and reform project delivery methods and procurement reforms
    • Support alternative delivery methods, such as CM-at-risk, CM-build, and progressive design build
    • Streamline and modernize SEQRA

    City

    • Fill agency staffing vacancies and reduce vacancy rate at key agencies (DOB, DDC, DCP, HPD, LPC)
    • Amend city procurement rules to follow Best Value Procurement in lieu of lowest first cost (low bid) awards
    • Support Get Stuff Built to streamline and modernize CEQR
    • Encourage SCA to provide a reference for fee rates for design contracts and pay a stipend for required design services prior to contract award
    • Improve MWBE and small firm accessibility to DDC contracts

    For more information about AIANY’s Legislative Agenda, please contact Bria Donohue (bdonohue@aiany.org)

    December 14, 2023
    AIANY & AIANYS Testimony to the New York State Assembly on Local Government Procurement

    NYS Assembly Standing Committees on Cities and Local Governments Public Hearing on Local Government Procurement
    Thursday, December 14, 2023

    Testimony Submitted by:
    AIA New York State and the AIA New York Chapter

    Introduction
    AIA New York State (AIANYS) and the AIA New York (AIANY) chapter are state and local components of the American Institute of Architects (AIA), a storied organization founded by New York architect Richard Upjohn in 1857 with the goal to promote the scientific and practical perfection of its members and elevate the standing of the profession.

    Today, our mission here in New York and across the country continues the commitment to advancing excellence in all facets of the architecture profession, to be the voice of the architectural community, and a resource for its members in service to society. We represent more than 9,000 architects and design professionals committed to positively impacting the physical and social qualities of New York.

    AIANYS and AIANY urge the New York State Assembly to expand the procurement tools available to New York City with the authorization of alternative delivery methods to allow for increased use of qualifications-based selection and improve fairness and transparency in the project development process.

     

    Qualifications-Based Selection (QBS)
    The use of a qualifications-based approach to procuring architectural and engineering services on publicly funded projects was codified into law (P.L. 92-582) by the U.S. Congress in 1972. Also known as the “Brooks Act,” this law requires architects and engineers to be selected for all federal government projects on the basis of qualifications, subject to negotiation of fair and reasonable compensation. Today, over 48 states follow QBS procedures for procuring architectural and engineering services, including the state of New York.

    In 1980 the New York State Legislature passed, and the governor signed into law, Chapter 562, requiring all State agencies to use QBS when procuring architectural and engineering services in excess of $25,000. Since that time, §136-a of the State Finance Law has been expanded to include geological, landscape architecture, and land surveying services. QBS is endorsed by the American Bar Association as part of its “Model Procurement Code for State and Local Governments,” and is a recommended best practice in the New York State Education Department’s “Manual of Planning Standards for School Buildings.”

    In sum, the process of procuring professional design services through a QBS process has an extensive history and is widely regarded as a best practice.

     

    The Benefits of QBS
    As QBS is predicated on the notion that qualifications, not price, should be the determining factor in selecting an architect, it places fee negotiation at the end of the selection process. While price may have its place within the selection process, it alone should not be the determining factor.

    The reason for this is clear: Projects that are contracted solely on price do not take into account the myriad additional factors that go into architectural design. Architectural design is an evolving process and much goes into it after the drawings are signed, sealed and delivered. In fact, one of an architect’s principal duties is to ensure that the construction process goes smoothly.

    It is an architect’s experience, expertise and ability to resolve unforeseen problems creatively that will keep a construction project moving forward. These intangibles are
    common throughout the process. As a result, owners who rely only on a submitted bid as the project cost may be placed in a difficult position if the final cost is significantly higher.

    QBS helps resolve the projected vs. final cost dilemma by negotiating the project’s cost with the most qualified firm among the applicants. QBS also fosters a collaborative environment, so the roles of all stakeholders are known, documented and understood.

     

    Transparency and Accountability to the Taxpayer
    QBS recognizes that design professionals play a critical role in the public building process. The quality of design services provided by the architect or engineer is the single most important factor in determining the overall construction and life-cycle costs of a building and it is in the taxpayers’ best interest to ensure that the most qualified firms are selected for public projects.

    As QBS is a well-documented and defensible process, decisions the owner makes are more likely to stand up to public scrutiny. The selection of a firm is centered around a consistent set of objective criteria established by the public owner and used for evaluating, interviewing, and ranking firms. Within a model QBS process, the public owner’s selection team will use its criteria to review RFQs, shortlist no more than three firms, interview the finalists, and score the firms in various areas. Both the successful firm and the unsuccessful firms are provided with their scores. The procuring entity will then enter the negotiation phase with the highest ranked firm to develop a detailed and comprehensive scope of services and compensation. If an agreement between the procuring entity and the highest ranked firm cannot be reached, the owner may terminate negotiations and proceed on to the next highest ranked firm.

    It should be noted that while price is not the predominant factor in the initial selection of the design firm, the owner still maintains discretion to negotiate a fair price. As mentioned previously, the reliance on price alone when procuring professional design services limits the ability of the owner in their search for the most qualified design firm with the experience and competence to bring a project in on time and within the budget. Experienced and competent design firms, construction managers, and contractors are much more likely to avoid change orders that will cause delay and add costs to the owner and the taxpayer.

     

    Fairness
    The use of QBS is both fair to the design firms competing for a contract and the public owner. Questions may arise related to whether the selection of a firm based on experience limits other firms with less experience from participating in public projects. However, the criteria established by the public owner may provide weight and value to certain design specialties, their status as a SBE, SDVOB, or MWBE, and other factors deemed valuable to the public owner.

    For the public owner, the ability to select a design firm based on qualifications enables flexibility that permits owners to tailor the procurement of professional design services to meet their specific needs. QBS works for sophisticated owners who consult with architects often and owners who do not have prior experience working with an architect. QBS provides both groups with a selection process that is not only straightforward and easy to implement, but is objective and fair.

     

    Progressive Design
    Progressive design is best suited for owners with the ability to use the QBS process. Under a progressive design framework, the highest ranked design firm may proceed with preliminary design and preconstruction services. Within a project delivery scenario where the design team is selected immediately before or simultaneously with a construction manager and/or general contractor, the parties may maximize collaboration to better define the scope of work, programming, and provision of accurate cost estimates for the proposed work.

    When a design has progressed to a point acceptable to the owner, the parties may move to establish a contract price for the second phase which includes a final design and construction services. If the owner and the parties cannot come to an agreement on a contract price, the owner may retain the option to move forward with another contract strategy for phase two.

    However, under no circumstance should the design team work for free. Bidding on projects is an expensive endeavor in and of itself. The provision of professional design services must be compensated and owners should not be allowed to compel a design team to provide a design without fair compensation for services rendered. This may be avoided through separate contracts for phase one and phase two of the project, or a single contract for both phases, as some phase two work may be required prior to the establishment of a final contract price. This may take increased upfront effort and time, but the ultimate goal is to progress a project toward construction and completion, and to do so with the most qualified design and construction team.

    If the Legislature is serious about authorizing New York City to adopt a progressive design procurement approach, it should start with a legislative proposal to require local governments to procure professional design services using the QBS framework outlined in State Finance Law §136-a.

     

    The Procurement of Professional Design Services
    As a matter of public policy, the AIA supports public policies, requirements, and administrative procedures in public procurement processes that mandate the open selection of architects on the basis of qualifications and oppose hiring architects on the basis of fees as the sole determining factor when awarding a contract to provide professional design services. This longstanding public policy works to support design excellence in publicly funded projects, as the AIA believes society is best served by public buildings and places that represent the highest ideas of citizens and their elected government.

     

    Conclusion
    AIA New York State and AIA New York strongly encourage the New York State Assembly to expand the procurement tools available to New York City with the authorization of alternative delivery methods to expand the use of quality-based selection instead of lowest bid procurement. With these additional tools, the city will be able to ensure quality project delivery, provide accountability and transparency at all stages, and embed robust workforce engagement and community participation in the process.

    Licensed design professionals are obligated to protect the health, safety, and welfare of the public. This ethical and statutory obligation is fortified through their education, training, experience, and expertise in the design of the built environment and dedication to the improvement of the public realm. The impact of professional design services on the overall health and safety of building occupants is too important to be relegated to a low-bid procurement process meant for the purchase of common commodities. The establishment and expansion of QBS should be the grand strategy and objective in the universe of potential procurement tactics.

    The AIA and its state and local components around the country strongly support the continued use and expansion of QBS when procuring professional design services and we look forward to continuing our collaborative efforts to standardize the use of QBS at all levels of government.

    December 01, 2023
    AIANY Testimony to NYS Building Codes Council on Building Electrification Code Implementation

    December 1, 2023

    RE: Comments on NYS Building Code Council’s Uniform Code and Energy Code Update

    Thank you, members of the New York State Fire Prevention and Building Code Council, for holding this hearing today. I am Bria Donohue, Government Affairs Manager at AIA New York. AIA New York represents more than 5,500 architects and design professionals committed to positively impacting the physical and social qualities of New York.

    The passage of the All-Electric Buildings Act earlier this year in the fiscal year 2024 New York State budget was a major step forward towards reaching New York’s 2050 net zero carbon goals. However, without appropriate implementation into energy codes, these ambitious goals are unachievable if New York fails to address the energy efficiency and energy sources of buildings. In New York, buildings are the largest source of greenhouse gas emissions at 32%. It is critical we electrify appliances and utilize electric heat pumps, heat pump water heaters, induction ovens, and electric dryers to reduce energy unit pollution as well as improve savings for homeowners.

    It is important that the Division of Codes and Standards updates the 2024 Building and Energy Code to reflect New York’s electrification laws prior to the new proposed building and energy code being filed in the State Register and commencing the SAPA process.

    Additionally, AIA New York strongly encourages NYSERDA include additional externalities in their new Cost Effectiveness Methodology. The original proposal did not include calculations regarding the benefits of averted health impacts or decarbonizing disadvantaged communities. It is important that the indirect implications of electrifying buildings are a factor in cost calculations.

    As a staunch supporter of the All-Electric Buildings Act, AIA New York strongly encourages the Building Code Council, NYSERDA, and the Department of State full comply with the law to ensure we meet New York’s bold decarbonization goals.

    November 20, 2023
    AIANY Comments on DOT Proposed Rules on Dining Out NYC

    Michelle Craven, Assistant Commissioner
    New York City Department of Transportation, Office of Cityscape and Franchises
    55 Water Street, 9th Floor
    New York, NY 10041

    November 20, 2023

    RE: Comments on New York City Department of Transportation Proposed Rules on Dining Out NYC Program

    Dear Assistant Commissioner Michelle Craven,

    American Institute of Architects New York writes to express our support for New York City Department of Transportation’s (DOT) proposed rules on the Dining Out NYC program and present recommendations to improve the implementation of the permanent outdoor dining program.

    During the COVID-19 pandemic, the temporary outdoor dining program served as a lifeline for restaurants. After more than a year of negotiations, Intro 31-C was signed into law by Mayor Adams, creating a permanent outdoor dining program in NYC. Dining Out NYC demonstrates how the city is reimagining the use of public space to improve quality of life and create vibrant, safe, and accessible outdoor dining experiences. The permanent program allows for sidewalk cafes to operate year-round and roadway dining to operate from April to November. DOT’s proposed rules provide valuable guidance on the design requirements for outdoor dining structures, with a focus on maintaining accessibility and sanitation.

    AIANY makes the following recommendations to improve DOT’s proposed rules for the Dining Out NYC program.

    Recommendation 1: Provide clarity on design requirements for slopes, accessibility, alternative materials to fill barriers other than water, easily removable umbrellas and coverings, and screening on roadway side of structures. As written, the rules leave many design elements up for interpretation. Sloping needs to be defined in terms of slope steepness. ADA accessible is a term used loosely to define accessibility guidelines and needs to be made explicitly clear. While the rules include a metric to determine the alternative materials allowed to be used to fill barriers other than water, it would be useful to include what the approved materials are. For the requirements on umbrellas and coverings, a clarification on what “easily removable” means is necessary. Add in a metric such as “it should take one person one hour to remove” or “three people one day”. The current language leaves room for broad interpretation. In terms of the screens on the roadway side of the dining structures, the degree of visibility must be defined. Are plantings and plexiglass acceptable materials?

    Recommendation 2: Host design competition to give design professionals an opportunity to demonstrate the possibilities for the design of dining structures with the permanent program rules for restaurant owners to use as a reference and guide. While the Kit of Parts will be a valuable resource for restaurant owners, hosting a design competition where design professionals have an opportunity to demonstrate the various design possibilities for dining structures with the permanent program rules will be immensely helpful for restaurant owners. Given that an architect, engineering, or licensed design professional is not required for restaurant owners to submit an application, providing owners with a variety design proposals and ideas will improve the quality of designs put forward in restaurant’s applications and provide additional variety for owners in a multitude of spaces and typologies.

    Recommendation 3: Clarify and restructure the timeline for applications, compliance, and removal. Decouple the application timeline from the compliance date. Restaurants should have the flexibility to apply for outdoor dining set ups prior to the November 1, 2024 removal deadline. This would allow approved and compliant setups to be built before the deadline, without risk of demolition and waste. This would create an incentive for restaurants to submit their applications to the permanent program early and would reduce waste while also giving DOT a head start in evaluating applications prior to the start of the 2025 seasonal program. This would allow approved and compliant setups to be built before the deadline, without risk of demolition and waste. This would create an incentive for restaurants to submit their applications to the permanent program early and would reduce waste while also giving DOT a head start in evaluating applications prior to the start of the 2025 seasonal program. The current timeline for applying for the permanent program permit and removing temporary structures is unclear and unrealistic. The timeline in the rules disincentives restaurant owners for submitting their application early because once approved they need to take down their temporary structure to comply with the permanent program rules. The reason this disincentives owners is because restaurants will be required to take down their roadway structures in November regardless as the permanent program makes roadway dining seasonal; therefore, many owners would view this as double the work and bad for business and wait to apply until the November deadline. As a result, DOT will be swarmed with applications slowing down the review process and potentially impacting businesses for the April start date in 2025. Our recommendation to incentivize owners to submit their application early is to decouple the application approval from the teardown date for the temporary structure. In this scenario, businesses can apply early and know the fate of their application and make revisions, if necessary, without the stress of the impact on their business of take down and putting up new structures in a short time period. All restaurants whether they have applied or not will be required to take down their roadway dining structures in November and begin complying with the permanent program rules. Additionally, this will make coordinating with the Department of Sanitation easier because it will be a defined period when restaurants will be disposing of their temporary structures.

    Recommendation 4: Provide clear guidance for denied applications on the reason the application was not approved to allow restaurant owners to remedy their application to appropriately comply with the program rules. With architects, engineers, or licensed design professionals not being required to be involved in restaurant’s applications, providing owners with as much clear guidance as possible on the reason an application was denied will be essential. Owners need to know what changes they need to make to comply and be approved without having to spend money to hire a licensed professional. This will be key in making the permanent program equitable.

    Recommendation 5: Add section on the waste removal plan and rules for the temporary program structures with the Department of Sanitation. The amount of waste created by the removal of the temporary program dining structures will be significant and require strong interagency coordination to avoid waste mania that negatively impacts quality of life and the public realm. Specialty carting will likely be necessary for the removal of most of the materials, so the development of a waste removal plan with the Department of Sanitation is important to effectively and efficiently removing the temporary structures.

    AIA New York looks forward to continuing our partnership with DOT, Chief Public Realm Officer Ya-Ting Liu, and Mayor Eric Adams to ensure successful implementation of Dining Out NYC and to serve as a resource and advocate for meeting the city’s public realm improvement goals.

    Sincerely,

    Matthew Bremer, 2023 President, AIA New York; Founder, Architecture in Formation

    October 24, 2023
    AIA New York Comments on DOB Local Law 97 Proposed Rules

    Mona Sehgal, Associate Commissioner and General Counsel
    New York City Department of Buildings, Office of the General Counsel
    280 Broadway, 7th Floor
    New York, NY 10007

    October 24, 2023

    RE: Comments on New York City Department of Buildings Proposed Rules on Local Law 97: Articles 320 & 321

    Dear Associate Commissioner Mona Sehgal,

    American Institute of Architects New York writes to express our support for New York City Department of Building’s (DOB) proposed rules on Local Law 97—Articles 320 and 321—and suggest opportunities for additional guidance to ensure the goals of Local Law 97 are achievable.

    In May 2019, Local Law 97 was passed, setting greenhouse gas emission limits on buildings over 25,000 square feet starting in 2024. Local Law 97 is intended to reduce emissions from buildings by 40% by 2030 and achieve an 80% reduction citywide by 2050. The rules for implementing this ambitious policy provide critical details building owners need to comply, explaining how Local Law 97’s substantial penalties can be temporarily avoided. The rules incentivize long-term carbon reduction planning, establishes a “credit” that can be applied towards emission reduction targets to encourage early adoption of electrification projects, and limits on the use of renewable energy credits (RECs) for offsetting emissions. Further, the proposed rule provides guidance for buildings with affordable housing and other circumstances which have alternative emission reduction goals.

    The proposed rules also provide a pathway for buildings that do not comply by the 2024 deadline to demonstrate a “good faith effort” through a decarbonization plan that could delay penalties. While the proposed rules provide flexibility that will benefit buildings not yet on the path to decarbonization, there needs to be greater specificity to the requirements of these plans and the oversight of their execution. Leaving these requirements open to interpretation will increase the demand on DOB staff and will lead to inconsistent enforcement.

    The rules must also address the subsequent deadlines for emissions limits. The owners of buildings which comply with the 2024 standards but exceed the 2030 limits need to understand whether the same process for establishing a decarbonization plan will apply to them. While the majority of buildings already meet the 2024 emission standards, it is essential that building owners are provided with guidance on complying with 2030 standards now as they will need to begin the process of retrofitting soon to meet the stringent 2030 limits. AIA New York recommends adding additional guidance to the rules to help buildings prepare and proactively comply with 2030 and 2050 deadlines.

    DOB’s proposed rules are a step in the right direction towards achieving our ambitious climate goals and for New York to continue to lead the way in fighting climate change.  AIA New York looks forward to continuing our partnership with DOB to ensure robust implementation of Local Law 97 and to serve as a resource and advocate for meeting the city’s net-zero emission building goals.

    Sincerely,

    Matthew Bremer, 2023 President, AIA New York; Founder, Architecture in Formation

    October 17, 2023
    AIANY Letter of Support for City of Yes for Housing Opportunity

    Chair Dan Garodnick
    City Planning Commission
    120 Broadway
    New York, NY 10271

    October 17, 2023

    RE: Support for City of Yes for Housing Opportunity Citywide Zoning Proposal

    Dear Chair Garodnick,

    American Institute of Architects New York (AIANY) writes to express our support for Mayor Eric Adams’ proposed citywide zoning text amendment, City of Yes for Housing Opportunity.

    The proposal is a historic effort to tackle New York City’s housing shortage and affordability crisis by making several small changes to the city’s outdated zoning resolution to support the creation of affordable housing in every neighborhood of the city. The need for these changes cannot be overstated as New Yorkers struggle from the persistent burden of the housing and affordability crises.

    AIANY has been a long-time advocate of many of the proposals included in City of Yes for Housing Opportunity. We are particularly supportive of the proposals to make office to residential conversions easier, encourage transit-oriented development, incentivize affordable housing with the Universal Affordability Preference, legalize housing above businesses on commercial streets to encourage mixed-use communities, eliminate parking mandates, and allow for accessory dwelling units. These proposals are common sense changes to the city’s zoning-based housing challenges and are sensible solutions to promote the creation of quality housing across our city.

    In recent decades, housing production has been dramatically low, and the cost of housing has risen faster than wages. The City of Yes for Housing Opportunity proposal will not only create an opportunity for the production of 100,000 housing units in the next 15 years, but it will also generate around 260,000 temporary jobs and 6,300 permanent jobs.

    The City of Yes for Housing Opportunity proposal is an ambitious and meaningful approach to addressing the city’s housing needs, and AIANY looks forward to continuing to be an advocate for the proposal and a resource to provide insight and expertise wherever possible to ensure these consequential proposals are achieved.

    We applaud DCP’s leadership and staff for bringing forth the proposals within City of Yes for Housing Opportunity. We hope that the Community Boards, Borough Presidents, Planning Commission, and City Council vote to approve this zoning text amendment that enables New York City to modernize regulations to support a more dynamic economy.

    Sincerely,

    Matthew Bremer, President of AIA New York; Founder, Architecture in Formation

    October 04, 2023
    AIANY Testimony to the City Council Subcommittee on Zoning and Franchises on the City of Yes for Carbon Neutrality Zoning Text Proposal

    October 4, 2023

    AIA New York Testimony to the City Council Subcommittee on Zoning and Franchises on City of Yes for Carbon Neutrality Zoning Text Proposal

    Thank you, Chair Riley and members of the Subcommittee on Zoning and Franchises, for holding this hearing today. I am Bria Donohue, Government Affairs Manager at AIA New York. We represent architects and design professionals committed to positively impacting the physical and social qualities of our city.

    AIA New York strongly supports Mayor Adams’ proposed citywide zoning text amendment, City of Yes for Carbon Neutrality. The proposal makes critical updates to NYC’s zoning regulations to help us meet our emission reduction goals and remove existing barriers and expand opportunities for decarbonization projects. We are particularly supportive of the elements of the proposal that enable and reward: energy efficient design and retrofits; building electrification and associated equipment; rooftop and other elevated solar; battery storage; electric vehicle charging; and infrastructure to support bicycles and other micromobility options.

    While AIANY strongly supports the zoning text amendment, we urge the council to make adjustments to proposal 8 to “Fix Zone Green”. We support the goals laid out to create more ultra-low energy buildings in the city; however, the proposal’s language has raised concerns regarding the feasibility of the targets outlined.

    AIANY makes the following recommendations with the purpose of adding more nuance so that the goals are ambitious, achievable, and specific to various building typologies.

    Recommendation #1: Reconsider a 50 percent reduction from the ASHRAE 90.1. Instead, consider setting a very progressive yet potentially achievable reduction factor or adopting a tiered approach for energy reduction, such as 30 percent reduction for 3 percent area exclusion and 50 percent reduction for 5 percent area exclusion.

    Recommendation #2: Amend EUI language from 38kbtu source EUI to 38kbtu site EUI. Consider EUI targets specific to building use, as energy use will differ significantly amongst different building uses. These targets could be similar to goals and thresholds set by other local laws.

    Recommendation #3: Establish an expert group to review and refine the Ultra-Low Energy Building criteria.

    Without these changes, today’s most progressive design will not be able to achieve the current performance standard in proposal 8 for most building typologies. This will result in a net worsening of energy performance since Zone Green incentives will effectively disappear, leaving practitioners with little motivation to strive towards the out of reach current definitions of ultra-low-energy buildings.

    City of Yes for Carbon Neutrality will be essential to meeting our climate targets, decarbonizing building stock, deploying renewables, and enabling New Yorkers to access a wide variety of low-carbon transportation options. We urge the City Council to pass the proposed zoning text amendment with the recommended changes to proposal 8.

    October 02, 2023
    Congestion Pricing Now Coalition Letter to TMRB with Recommendations on Toll Credits and Taxis/FHVs

    October 2, 2023

    Members of the Traffic Mobility Review Board
    Carl Weisbrod, Chair
    John Banks
    John Durso
    John Samuelson
    Elizabeth Velez
    Kathryn Wylde
    Governor Kathy Hochul
    Janno Lieber, MTA Chair and CEO

    To Whom It May Concern,

    We, the Congestion Pricing Now Coalition, write to express our continued support for New York’s Central Business District (CBD) Tolling Program and to thank the members of the Traffic Mobility Review Board (TMRB) for your service.

    We would like to express our strong support for the use of bridge and tunnel toll credits to be included as part of the TMRB’s recommendations. Crediting bridge and tunnel tolls can significantly reduce excess travel, particularly through environmental justice communities. It is incredibly important for the TMRB, the State, and the MTA to ensure the implementation of congestion pricing is equitable, and that no communities are disproportionately impacted by toll shopping, to the greatest extent possible.

    As it currently stands, about two-thirds of drivers enter the CBD for free, while about a third pay a variety of different toll rates depending on the route used. This increases traffic congestion in neighborhoods that host the free crossings, causing substantial health and environmental impacts. Ideally, the congestion pricing program would try to avoid a CBD tolling system that would not only maintain existing toll shopping but likely increase it. While much of the focus of toll credits has been on the Hudson River crossings, we believe that toll shopping could be even more significant on the East River crossings, with congestion—and vehicular emissions—increasing in neighborhoods surrounding the free bridges.

    In order to do this, the congestion pricing program will need to apply toll credits, or off-sets, to reduce any incentive to drive further to avoid a particular toll as much as possible. This will require looking at the total cost of trips and to consider MTA and Port Authority tolls rather than simply looking at the congestion pricing charge in isolation. Working to achieve cost equalization between bridges and tunnels entering the Manhattan CBD will allow drivers to use the most efficient crossing without the need for toll shopping, allowing for a more even, equitable flow of traffic into the area.

    Additionally, our coalition strongly advocates for a per-ride surcharge paid by the passenger, rather than a once-per-day toll paid by the driver. For-hire vehicles (FHVs) are a significant cause of congestion and vehicular emissions within the central business district. However, the Federal Highway Administration (FHWA) has determined FHV drivers are an important environmental justice (EJ) community. As a result, the Environmental Assessment approved by FHWA limits tolling on FHVs to once per day. Our coalition firmly believes that eliminating the once-per-day toll and replacing it with a per-ride surcharge will do far more to reduce congestion, protect drivers, and generate revenue for public transit. However, our coalition does not believe that a per-trip surcharge should be applied to taxis, which have already been burdened by required medallion investment.

    We thank you for your dedication to this important issue.

    Thank you,

    Congestion Pricing Now
    congestionpricingnow@gmail.com
    congestionpricingnow.org

    September 26, 2023
    AIANY Testimony to the City Council Committee on Housing and Buildings on Int 1031 to Create a Fair Housing Plan

    September 26, 2023

    AIA New York Testimony to the City Council Committee on Housing and Buildings on Intro 1031

    Thank you, Speaker Adams, Chair Sanchez, Chair Salamanca, and members of the Committee on Housing and Buildings and Committee on Land Use, for holding this hearing today. I am Bria Donohue, Government Affairs Manager at AIA New York. We represent architects and design professionals committed to positively impacting the physical and social qualities of our city.

    AIA New York strongly supports the City Council’s efforts to create a fair housing plan. Intro 1031 will require city agencies, specifically HPD, DCP, and DOB, to put together a report on social indicators, equity, true cost of living measures, and fair housing every five years. The data and assessment needed for this report—such as, analysis of housing units produced, displacement risk and vulnerability, infrastructure capacity, and climate change vulnerability—will demand resources from city agencies that we are concerned they do not have the capacity to allocate at this time to an additional project.

    While we are supportive of this well-intentioned plan, implementation is key to the success of this proposal, and funding is the essential element missing from this bill. For city agencies to effectively develop a fair housing plan, they require adequate funding and staffing. City agencies are already overburdened and struggling with limited staff capacity, so requiring additional reporting and analysis risks further delaying work and not providing the desired outcome for the city.

    This bill is a great opportunity to increase transparency on citywide data related to fair housing and a citywide assessment of the need and supply of affordable housing, but the lack of financial support for agencies makes the bill’s intensions a challenge to achieve, particularly in the desired timeline. Mayor Adams’ recent announcement on impending budget cuts of 15% to all city agencies by FY2025 as well as a hiring freeze only exacerbates these challenges.

    A Fair Housing Plan will add significant value to New York City and our understanding of the city’s need for affordable housing. It is vital that the city funds its agencies accordingly to produce this valuable assessment and catch up to other states who have already been conducting similar analysis.

    September 22, 2023
    AIANY, NY Building Congress, CHIP & STA Letter to the NY Congressional Delegation on Federal Aid for New York for the Asylum Crisis

    September 22, 2023

    RE: Federal Aid for NY for Asylum Crisis in Wake of Mayor’s Call for 15% Budget Cuts to City Agencies

    Dear Members of the New York Congressional Delegation,

    American Institute of Architects New York (AIANY), New York Building Congress (NYBC), Community Housing Improvement Program (CHIP), and Subcontractors Trade Association (STA) strongly urge the New York Congressional Delegation to take immediate action to assist New York with federal aid to address the current asylum seeker crisis. The financial burden on the City to support the unprecedented increase in migrants has led Mayor Adams to call for agency budget cuts of 15 percent by fiscal year 2025. These cuts will further exacerbate the challenges felt by agencies due to existing staffing shortages.

    The combination of looming budget gaps due to the loss of emergency Covid-19 federal aid and the overwhelming cost of the migrant crisis puts the economic future of New York City in peril. City agencies, already struggling from tremendous staffing shortages, are now being asked to cut their budgets by five percent for each of the financial plans in November, January, and April. City agencies had expressed concerns prior to these budget cuts about further degradation of services due to staffing shortages. Additional budget cuts to agencies such as DOB, DOT, DDC, HPD, etc. will severely impact work in the city done by the architecture, construction, and design communities and have long lasting repercussions on the built environment and public realm.

    Even with every agency cutting their budget by 15%, the cuts would not generate sufficient savings to cover the city’s budget gaps, and additional federal aid would still be necessary. While the budget gaps are not solely due to the migrant crisis, $6.1 billion of the $13.8 billion budget gap is attributable to the migrant crisis for FY2025. The $104.6 million from FEMA already provided to New York is nowhere near enough to support New York City given the billions of dollars the crisis is projected to cost.

    Federal aid is critical for the economic well-being of New York City and to prevent other services from suffering as a result of the costly asylum crisis. AIANY, NYBC, CHIP, and STA ask you all to interpret this action by the Adams Administration as sign of the severity of the situation and the dire need for assistance, and to push the Biden Administration and your colleagues in Congress to provide financial assistance to New York to relieve the burden of this national crisis.

    Sincerely,

    Matthew Bremer, 2023 President, AIA New York; Founder, Architecture in Formation
    Carlo Scissura, Esp., President & CEO, New York Building Congress
    Jay Martin, Executive Director, Community Housing Improvement Program (CHIP)
    Felice Farber, Executive Director, Subcontractors Trade Association (STA)

    September 12, 2023
    AIANY & APANYM Letter of Support for City of Yes for Economic Opportunity

    Chair Dan Garodnick
    City Planning Commission
    120 Broadway
    New York, NY 10271

    September 12, 2023

    Dear Chair Garodnick,

    American Institute of Architects New York (AIANY) and American Planning Association New York Metropolitan Chapter (APANYM) write to express our support for Mayor Eric Adams’ proposed citywide zoning text amendment, City of Yes for Economic Opportunity.

    The proposed changes in the amendment make much needed updates to modernize New York City’s zoning regulations to support small businesses, create thriving commercial corridors, and bolster NYC’s economic recovery.

    AIANY and APANYM are particularly supportive of the proposals that would allow for more mixed-use potential in neighborhoods, permit more adaptive reuse, and develop a commercial streetscape framework that is pedestrian friendly.

    In recent years, living patterns have shifted such that economic revitalization needs to be distributed throughout the city more evenly than how the city’s economy has existed in the past. City of Yes for Economic Opportunity would enable the city to unlock the economic potential in both historically economically significant neighborhoods and historically economically depressed neighborhoods. These proposals are ambitious and will require significant interagency coordination and collaboration as well as sufficient agency staff to be successful.

    AIANY and APANYM will remain involved in these ongoing conversations to serve as advocates for City of Yes for Economic Opportunity and as a resource to provide insight and expertise whenever possible to ensure these ambitious proposals are achieved. While we support DCP’s proposals, we want to underscore the importance of having broad citywide support for these ideas by providing strategic incentives to allow these changes to flourish and active communication with the business community about these new opportunities for economic growth.

    We applaud DCP’s leadership and staff for bringing forth the proposals within City of Yes for Economic Opportunity. We hope that the Community Boards, Borough Presidents, Planning Commission, and City Council vote to approve this zoning text amendment that enables New York City to modernize regulations to support a more dynamic economy.

    Sincerely,

    Matthew Bremmer, 2023 President, AIA New York; Founder, Architecture in Formation
    Paul Onyx Lozito, President, American Planning Association New York Metropolitan Chapter

    July 26, 2023
    AIANY Letter to CPC on City of Yes for Carbon Neutrality

    City Planning Commission
    120 Broadway
    New York, NY 10271

    July 26, 2023

    Dear Members of the City Planning Commission,

    The American Institute of Architects New York (AIANY) writes to express our strong support of the City of Yes for Carbon Neutrality. Nonetheless, after a close review of the proposal, AIANY has identified some concerns with proposal 8 to “Fix Zone Green”. While we support the goals laid out to create more ultra-low-energy buildings in the city, the proposal’s language has raised concerns regarding the feasibility of the targets outlined. We understand the below issues were referenced in Monday’s review session, so we thought it may be helpful to share them formally here as well.

    AIANY makes the following recommendations for the City Planning Commission to consider, specifically in regard to proposal 8 to fix Zone Green of the City of Yes for Carbon Neutrality plan:

    Recommendation #1: Reconsider a 50 percent reduction from the ASHRAE 90.1. Instead, consider setting a very progressive yet potentially achievable reduction factor or adopting a tiered approach for energy reduction, such as 30 percent reduction for 3 percent area exclusion and 50 percent reduction for 5 percent area exclusion.

    Recommendation #2: Amend EUI language from 38 kbtu source EUI to 38 kbtu site EUI. Consider EUI targets specific to building use, as energy use will differ significantly amongst different building uses. These targets could be similar to goals and thresholds set by other local laws.

    Recommendation #3: Establish an expert group to review and refine the Ultra-Low-Energy Building criteria.

    The purpose of our recommendations is to add more nuance to the text amendment so that the goals outlined are ambitious, achievable, and specific to various building typologies. We want to emphasize the benefits of making our recommended changes to proposal 8 for occupants, not just practitioners. By setting achievable targets, we are setting practitioners up for success to meet the sustainability and resiliency requirements and goals set out in Local Law 97. Without these changes, today’s most progressive design will not be able to achieve the current performance standard in proposal 8 for most building typologies. This will result in a net worsening of energy performance since Zone Green incentives will effectively disappear, leaving practitioners with little motivation to strive towards the out of reach current definitions of ultra-low-energy buildings.

    Thank you,

    Matthew Bremer, President of AIA New York & Founder of Architecture in Formation
    Yasemin Kologlu, Co-Chair of AIA New York Committee on the Environment
    Mallory Taub, Co-Chair of AIA New York Committee on the Environment

    July 18, 2023
    AIANY Statement on CPC's Recommendation on MSG's Special Operating Permit and Penn Station Redevelopment

    July 18, 2023

    For too long commuters and visitors have suffered from the inadequate accessibility, efficiency, and connectivity at Penn Station. Right now, there is a unique opportunity to shape the future of Penn Station, create transformative change to improve the customer experience of both Penn Station and Madison Square Garden (MSG), and design a space that meets the current demands of the largest transit hub in North America. Since MSG was first granted a special operating permit 60 years ago, the needs of Penn Station have evolved.  These needs, in conjunction with the incompatibilities of the shared space between the railroads and the arena, have created a heightened burden on the public experience.  

    The City is currently considering two actions related to the application by the owners of MSG for a renewal of its Special Operating Permit: 

    • NYCDCP’s proposed text amendment to Zoning Resolution ZR 74-41, which introduces additional findings criteria to be used in evaluating an application for MSG’s Special Permit; 
    • MSG’s application for a Special Operating Permit in perpetuity for Madison Square Garden Arena. The arena’s current ten-year Special Permit expires on July 24, 2023. 

    Recognizing the extraordinary significance of MSG’s location directly above Penn Station and the millions of riders who use the station, we believe that the following key principles must be considered in helping to inform the decision-making process for these actions. 

    Civic importance of the public realm surrounding Penn Station and MSG 

    Penn Station is the busiest public transportation hub in the nation, with more than 600,000 daily commuters and visitors served by the region’s rail networks. Yet the current street entrances are difficult to find, often congested, and lack the civic presence appropriate for public gateways to the station. The NYC Department City Planning’s (DCP) text amendment to ZR 74-41 would for the first time acknowledge the civic importance and impacts of an arena of the scale of MSG on the local neighborhood, users of Penn Station as well as MSG, and the broader public. The new criteria elevate the primacy of the public realm by providing a strong basis for ensuring high-quality outdoor public space surrounding MSG and Penn Station, improved pedestrian access and circulation to the facilities, more specific criteria for MSG’s truck-loading/unloading operations, and a much-needed requirement for consistency and compatibility with existing and proposed transit facilities at Penn Station. 

    Need for a transformation of Penn Station 

    Despite its fundamental importance as a linchpin to the city and regional economy, Penn Station has not benefited from a complete reconstruction since the destruction of the original superstructure in 1963. Significant expansions of service to Penn Station are being planned by the MTA, Amtrak, and NJ Transit;  the station’s users deserve a better facility. The railroads who own and operate out of Penn Station developed the Penn Master Plan, outlining goals and objectives necessary to upgrade the station to modern standards for a regional transportation hub. These improvements were further developed in the MTA’s proposed Penn Reconstruction Project and will be refined in the next design and review phases. The design addresses critical life safety deficiencies within the station; rationalizes station operations; improves station circulation at the street, concourse, and platform levels; provides ADA accessibility through the station complex; and enhances user experience through a consolidated concourse featuring high ceilings, extensive daylighting, and more visible and generous station entrances oriented to passenger destinations. 

    Interrelationship of Madison Square Garden and Penn Station 

    By recognizing the complex, interconnected nature of MSG and Penn Station’s physical properties and operations, the city has the opportunity to implement appropriate mechanisms to ensure that the highest quality design for a truly transformative Penn Station can be achieved. Under the new DCP text amendment, MSG is required to be “consistent and compatible” with Penn Station, and the transfer of property rights to the mid-block taxiway, MSG staging area, and Eighth Avenue entrances are critical to achieving the vision for the project.  

    AIANY supports an appropriate limited-term extension of MSG’s Special Permit tied to DCP’s criteria that prioritize the creation of vibrant public spaces in and around Penn Station and MSG, as well as the realization of a modernized Penn Station with the civic presence and scale envisioned by the MTA and the region’s railroads. New Yorkers have suffered long enough with an inadequate and disjointed station, and now is the time to return the major transportation hub to a design that New Yorkers deserve. 

    July 14, 2023
    Congestion Pricing Now Coalition Letter to TMRB on Tolls and Exemptions Recommendations

    July 14, 2023

    Dear Members of the Traffic Mobility Review Board,

    We, the Congestion Pricing Now Coalition, write to express our strong support for New York’s Central Business District (CBD) Tolling Program and to thank the members of the Traffic Mobility Review Board (TMRB) for your service. In the NYC metropolitan area, congestion in the central business district creates untenable delays for emergency vehicles, buses, delivery vehicles and drivers who have no other choice but to take cars and trucks into the zone. Chronic disinvestment in transit has meant an unreliable, inaccessible system that lurches from crisis to crisis. Congestion pricing would create a multi-billion dollar investment to modernize and upgrade public transportation and lessen the burden of traffic congestion that would otherwise continue to undermine our economy and pollute our air. Congestion pricing is a win-win-win for the region that will fund public transit, reduce traffic congestion, and clean our air.

    Members of the Congestion Pricing Now Coalition make the following recommendations for the TMRB to consider:

    Recommendation #1: Use bridge and tunnel toll credits to reduce excess travel—particularly through environmental justice communities

    Right now, about two thirds of drivers enter the CBD for free, while about a third pay a variety of different toll rates depending on the route used. This increases traffic congestion in neighborhoods that host the free crossings, causing substantial health and environmental impacts. Ideally, the congestion pricing program should equalize tolls and reduce so-called “toll shopping” to the greatest extent possible. A priority should be given to reducing any disproportionate burden on environmental justice communities in both New York and New Jersey.

    In order to do this, the congestion pricing program will need to apply toll credits, or off-sets, to reduce any incentive to drive further to avoid a particular toll as much as possible.

    This will require looking at the total cost of trips and to consider MTA and Port Authority tolls rather than simply looking at the congestion pricing charge in isolation.

    Recommendation #2: On for-hire vehicles, assess a per-ride surcharge paid by the passenger, rather than a once per day toll paid by the driver

    For-Hire Vehicles (FHVs) are a significant cause of congestion and vehicular emissions within the central business district. However, the Federal Highway Administration (FHWA) has determined FHV drivers are an important environmental justice (EJ) community. As a result, the Environmental Assessment approved by FHWA limits tolling on FHVs to once per day. Our coalition firmly believes that eliminating the once-per-day toll and replacing it with a per-ride surcharge will do far more to reduce congestion, protect drivers, and generate revenue for public transit.

    It is important that vulnerable communities are not negatively impacted by the program’s implementation. A per-ride surcharge is designed to be passed along to the customer, reducing the financial burden of the program on drivers compared to a once-per-day toll.

    A per-ride surcharge also has significant revenue-generating potential. According to the NYC Taxi and Limousine Commission, in 2022, the existing congestion zone surcharge of $2.75 for for-hire vehicles (FHV) and $2.50 for yellow taxis, raised $343 million, including $91 million from taxis and $252 million from HVFHVs.

    We urge you to give special consideration to FHVs who are transporting people with disabilities to maintain alignment with the equity goals in the MTA Reform and Traffic Mobility Act of 2019.

    Given the clear benefits to reducing congestion and to FHV drivers, we strongly urge the TMRB to include a per-ride surcharge for FHVs in the chosen congestion pricing tolling scenario. Doing so will ensure that FHV drivers are protected, and that the tolling system generates substantial revenue, effectively combats traffic congestion, improves air quality, and aligns with the objectives of the MTA’s capital plan. This can also help offset the revenue impact of other recommendations.

    Special consideration for taxis: The Congestion Pricing Now Coalition does not believe that a per-trip surcharge should be applied to taxis. Taxi drivers have suffered greatly and are already burdened by the investments taxi owners have made in medallions that are now valued at significantly less than the original investment.

    Recommendation #3: Commuter buses, both public and private, must be exempt from tolls

    We support the exemption of both public and private commuter buses. One of the many goals of the program is to disincentivize private car trips into Manhattan’s CBD and incentivize more commuters to use mass transit. To support this goal, we believe that private and public commuter buses should be exempt. The coalition defines ‘public’ as those buses owned or operated by any municipal transportation entity (ex: MTA Bus, NJ Transit, etc.) and defines ‘private’ as privately-owned buses that operate on behalf of any municipal transportation entity and/or provides a supplemental service that connects riders to a fixed, intermodal transportation hub located within the congestion pricing zone.

    Incentivizing commuters to travel by bus will decrease the number of private vehicles entering Manhattan by consolidating commuters into high-occupancy vehicles and reduce emissions per passenger mile. This move will encourage the use of public and group transportation and discourage the use of private vehicles.

    Note, the coalition does not believe this exemption should apply to tourism buses, which carry significantly fewer passengers.

    Recommendation #4: No additional exemptions should be granted besides commuter buses and legislatively mandated exemptions

    The 2019 legislation provides exemptions for disabled riders, including those utilizing the Access-A-Ride program, and for those within the CBD earning less than $60,000 a year. Earlier this year, the MTA pledged an additional $207M to mitigate possible adverse effects to the policy, which included additional exemptions under a low-income driver toll discount program.
    Outside of these exceptions, any additional exemptions will raise the base toll paid by all other commuters, as the legislation requires the program to generate enough revenue to fund $15 billion for the MTA capital plan. Allowing for additional exemptions will deteriorate the effectiveness of the program. The Congestion Pricing Now coalition does not support further exemptions (other than for those included in the 2023 mitigation package and commuter buses as defined in Recommendation #3).

    Recommendation #5: Trucks and large vehicles should pay a per axle toll

    Trucks and large vehicles have a significantly greater impact on regional infrastructure and air quality. Therefore, the coalition believes that these vehicles should pay more than passenger vehicles and that they should be charged an increasingly graduated amount based on the number of axles, which is a proxy for their size, weight and impact. Similar graduated pricing schemes are currently used on existing MTA bridge and tunnel facilities. The introduction of an escalating charge per axle is a proven tolling method in the trucking industry, which provides an incentive for both private and public investment in other modes of transportation for moving goods in a more environmentally sustainable fashion.

    Thank you for your attention to these important issues. We trust that you will carefully consider our requests and make decisions that serve the best interests of the region. Should you require any additional information or wish to discuss these recommendations further, please do not hesitate to contact us.

    Thank you,

    Congestion Pricing Now
    congestionpricingnow@gmail.com
    congestionpricingnow.org

    The Congestion Pricing Now Coalition members who sign this letter include:

    American Institute of Architects New York Chapter (AIANY)
    Bike Hoboken
    Bike New York
    Bike Weehawken
    Environmental Advocates NY
    Environmental Defense Fund
    Environment New Jersey
    Families for Safe Streets
    Hudson Square BID
    Make Queens Safer
    Move NY
    Municipal Arts Society
    The Nature Conservancy
    Natural Resources Defense Counsel
    New Jersey Policy Perspective
    New York Lawyers for Public Interest
    New York League of Conservation Voters
    North Brooklyn Neighbors
    NYPIRG Straphangers Campaign
    Open Plans
    Permanent Citizens Advisory Committee to the MTA (PCAC)
    Regional Plan Association
    Riders Alliance
    Right Track for Long Island
    Rise and Resist Elevator Action Group
    SafestreetsJC
    StreetsPAC
    Transportation Alternatives
    Tri-State Transportation Campaign
    Trust for Public Land
    Two Trees

    Cc:
    Janno Lieber, MTA Chair and CEO
    Andrew Albert, MTA Board Member
    Jamie Barbas, MTA Board Member
    Gerard Bringmann, MTA Board Member
    Norman Brown, MTA Board Member
    Samuel Chu, MTA Board Member
    Michael Fleischer, MTA Board Member
    Randy Glucksman, MTA Board Member
    Haeda Mihaltses, MTA Board Member
    Frankie Miranda, MTA Board Member
    John Ross Rizzo, MTA Board Member
    John Samuelsen, MTA Board Member
    Sherif Soliman, MTA Board Member
    Lisa Sorin, MTA Board Member
    Vincent Tessitore, Jr, MTA Board Member
    Midori Valdivia, MTA Board Member
    Neal Zuckerman, MTA Board Member
    Nivardo Lopez, Deputy Secretary for Transportation, Governor’s Office
    Marie Therese Dominguez, NYSDOT Commissioner
    Diane Gutierrez Scaccetti, NJDOT Commissioner
    Ydanis Rodriguez, Commissioner, NYC Department of Transportation

    May 19, 2023
    AIANY Statement on Int 0031-2022 Version B, also known as the Permanent Open Restaurants Bill 

    May 19, 2023 

    Yesterday, Thursday, May 18, 2023, the New York City Council advanced a permanent Open Restaurants bill, enabling the NYC Department of Transportation to develop new rules for sidewalk cafes and roadbed structures that AIA New York broadly supports.  

    Restaurants already participating in the emergency program, which started in June 2020, will be permitted to keep their existing dining structures until November 2024, which will create sufficient time for DOT to develop and test new rules for the program and for restaurants to adapt to them.   

    The new program will introduce a new fee system for restaurants based on location, striking a balance that will provide DOT with necessary funding to enforce the program effectively while also remaining widely accessible to many restaurants.  

    The bill also provides DOT with significant flexibility to develop rules on the design of roadbed structures, allowing designs to be developed, tested, and iterated in partnership with relevant stakeholders.   

    AIA New York has been a strong supporter of Open Restaurants since the program’s inception. The chapter commends the City Council and the Adams administration for reaching an agreement on the Open Restaurants bill, effectively enshrining a program that saved thousands of businesses and jobs and brought new vitality to New York’s streets. The bill establishes a framework that we believe will lead to a successful transition to a new program that preserves many of the strengths of the emergency program while embedding a process that will make it appropriately accessible for restaurants and neighborhoods across all boroughs while allowing for innovation and iteration for years to come.  

    April 22, 2023
    AIANY, Urban Green Council & NYLCV Letter of Support for City of Yes for Carbon Neutrality

    April 22, 2023

    Chair Dan Garodnick
    City Planning Commission
    120 Broadway
    New York, NY 10271

    Subject: Support for City of Yes for Carbon Neutrality citywide zoning proposal

    Dear Chair Garodnick,

    Urban Green Council, American Institute of Architects – New York, and the New York League of Conservation Voters are writing to express our shared support for Mayor Eric Adams’ proposed citywide zoning text amendment, City of Yes for Carbon Neutrality.

    The proposed changes in the amendment are critical because they will update New York City’s zoning regulations to make our world-leading efforts to prepare for climate change easier, and ensure that zoning is not standing in the way of climate progress.

    Climate change is an existential threat to the future of New York City.

    New York City is already at risk from the increasing threats of climate change—coastal flooding, extreme heat, and heavy rain events are all too familiar to most residents. To prevent the worst impacts of climate change in the future, the Intergovernmental Panel on Climate Change urges a rapid shift away from burning fossil fuels.

    New York has been a global leader in this charge to combat climate change with ambitious greenhouse gas reduction targets, the nation’s first carbon cap for buildings, and aggressive statewide renewable energy goals. But NYC’s zoning regulations were created before these climate priorities became evident, and outdated elements in the city’s current zoning resolution are preventing progress on key decarbonization activities.

    City of Yes for Carbon Neutrality will help us reach NYC’s climate goals by removing outdated barriers in our zoning code.

    Our organizations support the Department of City Planning’s overall zoning proposal outlined in City of Yes for Carbon Neutrality because it will remove the existing barriers to and expand new opportunities for decarbonization projects in the NYC zoning code. There is growing awareness that we need to modernize the code so New Yorkers can fully implement what’s required to lower carbon and improve energy efficiency in buildings, install solar and storage onsite, and offer adequate electric vehicle charging.

    The proposal includes recommendations supported by industry experts to reach those goals, and will help reduce emissions from the buildings, energy, transportation, and waste sectors. We are particularly supportive of the elements that enable and reward:

    • Energy efficient design and retrofits;
    • Building electrification and associated equipment;
    • Rooftop and other elevated solar;
    • Battery storage;
    • Electric vehicle charging; and
    • Infrastructure to support bicycles and other micromobility options.

    These measures will be essential to meeting our climate targets, decarbonizing our building stock, deploying renewables, and enabling New Yorkers to access a wider variety of low-carbon transportation options.

    We applaud DCP’s leadership and staff for bringing forth the proposals within City of Yes for Carbon Neutrality. We hope that the Community Boards, Borough Boards, Board Presidents, Planning Commission, and City Council vote to approve this strong zoning text amendment that enables New York City to fulfill our climate targets.

    Sincerely,

    Urban Green Council
    John Mandyck; CEO

    American Institute of Architects-NY (AIA-NY)
    Matthew Bremer, 2023 President

    New York League of Conservation Voters (NYLCV)
    Alia Soomro; Deputy Director, New York City Policy

    March 19, 2023
    Rise to Resilience Coalition Comments on NYNJHATS

    March 2023

    U.S. Army Corps of Engineers
    NYNJHAT Study Team, Planning Division
    26 Federal Plaza, 17th Floor
    New York, NY 10279-0090

    RE: New York—New Jersey Harbor and Tributaries Study, Tentatively Selected Plan

    Dear Mr. Bryce W. Wisemiller and Ms. Cheryl R. Alkemeyer:

    We, the 45 undersigned members of the Rise to Resilience Coalition, appreciate the opportunity to submit public comments on the Draft Integrated Feasibility Report and Tier 1 Environmental Impact Statement for the New York-New Jersey Harbor and Tributaries Study (“NYNJHATS”) and for the U.S. Army Corps of Engineers’ (“Corps”) commitment to reducing coastal storm risk in the New York and New Jersey Harbor region.

    The Rise to Resilience Coalition, comprised of over 100 organizations representing residents, leaders in business, labor community and justice, volunteer organizations, scientists, environmental advocates, and design professionals, have been engaged on NYNJHATS since its inception.

    As part of the March 2023 public comment period, the Rise to Resilience Coalition puts forward the
    following recommendations:

    1. Give greater consideration to environmental justice through an iterative approach,
    2. Prioritize natural and nature-based features (“NNBFs”) and non-structural solutions, and
    3. Address multiple climate hazards.

    These priorities reflect the input of multiple community and environmental organizations with on-the ground experience in vulnerable communities and technical expertise in resilience, align with the Water Resources Development Act (“WRDA”), and are consistent with several executive and agency policy directives and memos, such as Executive Order 14008, the Justice40 Initiative, and the Assistant Secretary of the Army for Civil Works’ Implementation of Environmental Justice and the Justice40
    Initiative memorandum.

    Additionally, Appendix A captures comments and questions from more than 50 organizations that participated in a HATS comment sharing workshop, hosted by Waterfront Alliance, Rebuild by Design, and Environmental Defense Fund on February 17, 2023. Appendix B references the Guiding Principle for Coastal Infrastructure, developed with over 80 attendees at a meeting hosted by Rebuild by Design on December 2nd, 2022.

    Since 2019, the Rise to Resilience Coalition has worked closely with Congressional leadership and local sponsors to secure modifications to the NYNJHATS authorization. The Coalition advocated for adjustments to the study to incorporate more holistic and equitable approaches that address multiple flood threats. Specifically, the Coalition sought to include tidal flooding associated with sea level rise and low-frequency precipitation events (along riverine floodplains) as individual threats and as compounding threats during a coastal storm. Additionally, the Coalition advocates for increased public engagement in communities most impacted by the project’s design and most vulnerable to flood risk. Of equal importance, was an articulation of how community values, lived experiences, and expertise will be considered in alternative selection and design.

    This is the largest public infrastructure project proposal in our region in recent history, and it is the critical responsibility of the Corps to work closely together with the non-federal sponsors and communities to develop a plan that is rooted in the most accurate science, prioritizes social equity and public values, ensures access to the waterfront for all communities, and preserves our diverse cultural and ecological landscape for the most beneficial outcome for all. Our region faces significant climate challenges, and we urge the Corps to move forward with solutions that ensure the equitable resilience, accessibility, and ecological integrity of our communities.

    1. Greater Environmental Justice Considerations Through an Iterative Approach

    The Corps must recognize the disproportionate climate risks that puts low-income communities and communities of color at greater risk of flooding. These communities experience greater hardship in recovering after disasters, resulting in compounding personal and societal impacts to health, livelihoods, and the environment.

    Recommendation 1(A): Center Disadvantaged Communities and Align NYNJHATS with the Water Resources Development Act of 2020 and 2022, Executive Order 14008, and the Justice40 Initiative Guidance.

    The Rise to Resilience Coalition worked with members of Congress to expand the authorization of NYNJHATS via the Water Resources Development Act of 2020 (WRDA 2020), including a specific directive in Section 203 to consult with affected communities and have since had several discussions in 2021 and 2022 with the non-federal sponsors of NYNJHATS who are aligned in this perspective.

    The model to date has been to bring community stakeholders in to comment on what has already been done. An equitable route, as it pertains to centering disadvantaged communities, would require bringing those communities in from the beginning, so that lived experiences and expertise can be a part of the design and implementation stages.

    In addition to WRDA 2020 and 2022, consideration of greater consultation with environmental justice and disadvantaged communities is consistent with the Biden Administration’s Executive Order 14008, Executive Order 13985, and the Justice40 Initiative. To that end, the Assistant Secretary of the Army for Civil Works, Michael Conner, issued interim environmental justice implementation guidance to the Corps on March 15, 2022, titled Implementation of Environmental Justice and the Justice40 Initiative. In Section 10 of Assistant Secretary Conner’s memorandum, he makes it clear that the Corps will take more
    proactive measures toward achieving environmental justice in their scoping, planning, and construction phases.

    “For projects which are in the study and planning phases, we will take a more proactive approach towards achieving environmental justice. This may take time to achieve, but the end result will be an approach to studies which will focus on a comprehensive evaluation of the total benefits of each plan including equal consideration of applicable benefit types in the study scope of work where the disadvantaged communities play a key role in the effort to advance their needs. This new approach goes beyond “doing no harm” to focus on putting the disadvantaged communities at the front and center of studies. This will require a commitment starting at the earliest phase in the process. USACE is directed to initiate outreach and engage disadvantaged communities early in the process to identify and address problems.”

    To date, the Corps has not taken the necessary steps to center disadvantaged communities in NYNJHATS as outlined in the above-mentioned legislation, Executive Order, and implementation guidance. Before moving to the agency milestone and Chief’s Report, we urge the Corps to demonstrate environmental justice considerations in the tentatively selected plan, which requires a more proactive approach to engagement with disadvantaged communities.

    Recommendation 1(B): Update the Cost-Benefit Analysis and Thoroughly Evaluate Coastal Storm Risk for All Citizens in the Study Area, Centering Disadvantaged and Environmental Justice Communities.

    The current model for prioritization of flood protection does not sufficiently capture environmental justice considerations. Economic impacts, particularly where property values are higher, hold greater consideration. This imbalance results in several environmental justice communities not receiving equal or equitable access to flood protection as a result of historic injustices and disinvestment.

    We recommend the Corps thoroughly evaluate coastal storm risk for all citizens in the study area, centering disadvantaged communities and environmental justice communities, in accordance with Justice40, Water Resources Development Act of 2020, and the interim guidance issued by Assistant Secretary of the Army for Civil Works Michael Connor.

    The Corps should improve or modify its cost-benefit analysis and decision-making process to address equity and environmental justice. The Corps’ plan was created and selected using a cost benefit analysis of different possible scenarios to address the needs of the New York-New Jersey Harbor region. In order to equitably address the needs of low-income communities and communities of color, the cost-benefit analysis used for project selection must be revised to assign value to communities most impacted by climate change that do not have a high level of residential mobility, prioritizing population density or replacement value. To do this, we need to remove the bias towards wealthy neighborhoods and housing stock. In areas where there is a scarcity of low-income housing, existing low-income residential properties should be given a higher value, reflecting scarcity not the resale value of that property.

    Going forward, the Corps must include social and economic costs to show the full impact of these studies and proposed solutions, as well as clearly articulating the residual economic and social risks. If cost-benefit analyses are not modified, the Corps must develop an alternative method to effectively capture the value of protecting low-income communities, renters, communities of color, and environmental justice communities. In doing so, the Corps should also account for the multiple benefits of natural infrastructure, as well as the true costs of flood threats and disasters to a community. The Corps can address disproportionate flood risks and begin to address systemic inequalities by considering the cumulative impacts of flood disasters to communities and improve the cost-benefit methodologies to make more equitable investment decisions.

    The tentatively selected plan leaves several environmental justice communities with flood risks out of the project, including, but not limited to, Hunts Point, Sunset Park, and South Williamsburg.

    Recommendation 1(C): Create an Iterative Process and Extend the Public Comment Period.

    In a letter to Colonel Matthew Luzzatto, New York District Commander and District Engineer, on July 27, 2022, regarding the establishment of an Environment and Climate Justice Working Group for NYNJHATS, several members of the Rise to Resilience Coalition called for a more iterative approach to finalizing NYNJHATS, as described by the following timeline.

    This proposed timeline includes a Refined EIS ahead of the agency decision milestone, where the Corps would host additional public meetings on revisions made to the Tier 1 EIS based on feedback received to date. The feedback gathered through this process should be used to refine the plan in an iterative way, ensuring communities are a thoughtful partner to the Corps and the non-federal sponsors throughout the entirety of NYNJHATS.

    Through this updated timeline, we urge the Corps to partner with the non-federal sponsors and communities most affected by NYNJHATS to extend the public comment period and host several additional convenings. The current public comment period, although extended twice, does not provide sufficient time, access to resources, or community input to shape the future of the plan.

    Recommendation 1(D): Develop a Robust and Equitable Public Engagement and Community Empowerment Strategy That Prioritizes Regular Communications with Environmental Justice Communities.

    Building upon Recommendation 1(C), we advise the Corps to develop a robust public engagement and community empowerment strategy to foster an ongoing dialogue between the communities affected by NYNJHATS. One of the steps to achieving this result is the formation of the Environmental and Climate Justice Working Group (“the Working Group”).

    This Working Group would support and advise on how to ensure that the concerns, priorities, and proposed solutions of those most impacted by the threats of climate change are centered in the final plan. These goals would be accomplished by bringing together the project sponsors and partners (the State of New York, the State of New Jersey, and the City of New York), groups that represent large alliances of environmental and environmental justice groups, and frontline community organizations directly impacted by the area of NYNJHATS in one space. Specifically, the Working Group would support efforts to develop a robust outreach strategy and timeline, including target geographies and community organizations; a process for how frontline organizations will inform the selected plan, including strategy and tactics for reaching, listening to, and incorporating frontline community priorities into the design, including considering how funding for community participation can be provided; a process for how the states of New York, New Jersey, City of New York, and Corps will work together to maximize engagement and coordination/consistency review with other resilience projects; how the Corps will meet the statutory obligations of WRDA 2020 and 2022 to evaluate and address the impacts of low-frequency precipitation and sea level rise on the study area, value ecosystems services more effectively, and include a summary of any nature-based features that were considered and provide an explanation if nature-based features are not recommended.

    Further, the a working group should have the opportunity to review the outcomes of the engagement strategy the Corps employs for the NYNJHATS, and provide suggestions on possible immediate remedies, if gaps are found, as well as improvements for processes in the future.

    Together, we hope to build an effective strategy for ensuring that these perspectives are heard and incorporated into the final plan.

    2. Prioritize Natural and Nature-Based Features and Non-Structural Solutions

    The Corps’ International Guidelines of Natural and Nature-Based Features for Flood Risk Management, published in 2021, highlights the five foundational principles for the overall success of natural and nature-based features:

    1. Expect change and manage adaptively.
    2. Identify sustainable and resilient solutions that produce multiple benefits.
    3. Use a systems approach to leverage existing components and projects and their interconnectivity.
    4. Engage communities, stakeholders, partners, and multidisciplinary team members to develop innovative solutions.
    5. Anticipate, evaluate, and manage risk in project or systems performance.

    Nature-based solutions have a significant role to play in resilient infrastructure investments. The Corps’ own guidelines find that “effective and timely implementation of NNBF to address the future [flood risk management] challenges will depend on progress in three overarching areas of activity—developing and delivering, communicating and collaborating, and elevating and educating.”

    We recommend that the Corps utilize the best practices outlined in these guidelines and prioritize the immediate implementation of natural and nature-based features as part of NYNJHATS. The Tier 1 EIS lacks specifics on how the Corps will include natural and nature-based features and non-structural solutions in the tentatively selected plan. We urge the Corps to outline how these solutions will be embedded into the plan, ahead of the agency decision milestone and Chief’s Report.

    Recommendation 2(A): Prioritize Multi-Beneficial, Natural and Nature-Based Approaches and Consider Quality of Life, Economic, and Environmental Impacts.

    Recognizing that investments go farther when multi-beneficial approaches are taken, Section 116 of WRDA 2020 explicitly requires the prioritization of natural and nature-based features and ecosystem services in cost-benefit analysis.

    The tentatively selected plan relies too heavily on in-water barriers for protection and does not adequately study or model natural and nature-based features; for example, berms, dunes, increased elevation of waterfront sites, the use of pervious surfaces, daylighting streams (i.e., activating historic pathways for water for absorption and overflow), and other inland green infrastructure utilized to protect neighborhoods and mitigate both inland and coastal flooding.

    We recommend the Corps employ and study the use of natural and nature-based features to reduce wave damage from smaller, more frequent storms. Examples include significant wetland, coastal shrubland, and edge forest restoration, provided that vulnerable structures are either sited outside of the future floodplain or meet design flood elevation and durability guidance. Nature-based features provide multiple benefits, and can be effective in reducing impacts from smaller, more frequent storms and gradual erosion.

    Where structural solutions do move forward, we recommend the Corps employ natural and nature based features, such as naturalized slope and shape on stabilization features, plantings embedded within ripraps and revetments, and products such as specially textured concrete that attract marine and plant life, as well as consideration for beneficial gray infrastructure solutions, such as permeable pavement and ecologically enhanced concrete.

    In accordance with WEDG standards, we recommend that if hardened or structurally reinforced edges and components are necessary, the Corps not use materials preserved with potentially toxic substances such as chromated copper arsenate, creosote, or others that can leach into the aquatic environment. Avoid materials containing PFAS contaminants. We encourage the Corps to use edge materials that have a chemical composition, alkalinity, toxicity, pH, and other features that support the native biological community and attachment of characteristic aquatic organisms. Standard steel and concrete structures do not meet these criteria, nor do some of the most common rock materials used for riprap. Additionally, design and enhance structural features to provide more heterogeneity and habitat supporting complexity than conventional stabilization methods:

    • Use rough, textured, surfaces or varied gradation of rock that create interstitial spaces of varied size and shape, using a material with a pH that fosters attachment or provides refugia for native aquatic organisms. Examples include habitat and reef modules, oyster reefs, form liners, molds, pile casings, and structural enhancements.
    • Use water retaining ecological features to increase diversity of habitat and maintain some intertidal zonation, such as precast tide pools.
    • Incorporate nature-based features that provide multiple benefits, such as tiered reinforced edges with native plantings, oysters, mussels, and salt marsh grasses.
    • Incorporate temporary stabilization strategies for wave attenuation and erosion reduction until vegetation is established.
    • Consider additional external attachments such as hanging or floating habitats which can be utilized on seawalls and other hardened structures.

    Additionally, as the Corps begins to analyze natural and nature-based features, we recommend increasing and expanding wetland areas at site edges where relevant. This includes restoring or designing wetlands at the interface between the land and water at a site to provide habitat, aesthetic value, and buffer zones. Coastal wetlands can serve as storm attenuation systems, reducing wave action before waves are able to make landfall. They can also serve as debris capture systems, reducing the impact of high velocity debris at the site. Wetlands should be designed to be wide and flat to maximize the surface area available for risk reduction potential. The Corps should consider relevant vegetation for different elevation scenarios, considering the potential for marsh migration with rising sea levels in the planting plan. Wetland areas should gradually slope to the upland regions of the side to reduce risk of erosion.

    Recommendation 2(B): Pursue a Phased-Approach that Enables Implementation of Short- and Long-Term Measures.

    The interim NYNJHATS report suggested that the tentatively selected plan may include provisions for adaptation, such as near-, mid-, and long-term options. Given the uncertainty in the planning horizon, we encourage the Corps to pursue a phased approach that enables understanding the relationship between local and more regional approaches, thoughtful decision-making accounting for the many local structural and non-structural projects now underway, and implementation of different options over different time scales and scenarios.

    This approach should also enable implementation of near-term measures for which there is high confidence and support. It is critical that the Corps ensure the phased approach and resulting projects are designed with financial feasibility. The Corps should finalize plans through this study that reach holistic goals and can be completed given projected funding levels from local, state, and federal
    sources.

    The study should be pursued through a phased approach to authorization and development, prioritizing environmental justice, critical infrastructure, and nature-based features. This approach should be included in the final tentatively selected plan and Chief’s Report (by planning region or measure and including cost-share information) to move forward with elements of the plan while allowing for refinement of those that require further study.

    We recommend the Corps move forward quickly with measures that protect critical infrastructure and environmental justice communities that are aligned with the best available science. The Corps should prioritize measures that protect critical infrastructure and communities most vulnerable to the impacts of climate change, using the public comment period and social vulnerability and environmental justice analysis to inform prioritization.

    Recommendation 2(B-2): Ensure Structural Capacity to Heighten Resilience Features in the Future

    Risk projections do not carry absolute certainty. Antarctic ice is melting at an accelerating rate and sea level rise projections for the New York-New Jersey Harbor region have increased over time. Climate projections rely on assumptions about human behavior and policy change that are difficult to predict and subject to drastic change. (Please see related comments in recommendation 3B). The design life of these projects is long enough that the sea level rise and storm surge projections may be inadequate to protect those communities that they were designed to protect. As such, they should be designed to accommodate additional protection in the future.

    While designing for adaptability can involve additional upfront costs, these features may encourage a longer project lifespan. The Corps should consider increasing the capacity of any structural systems to allow more cost-effective future upgrades to accommodate additional fill, heightened or additional seawalls, taller barriers, or other flood mitigation features.

    By building to accommodate the possible expansion of systems in the future, the Corps ensures that it provides the resources to protect against today’s sea level rise and climate projections, while also ensuring that the region remains protected if climate change proves more severe than anticipated.

    Recommendation 2(C): Thoroughly Evaluate Buyouts as an Option Equal in Value to Structural Solutions, Including Extensive Modeling on Costs and Long-Term Benefits, Ahead of the Agency Decision Milestone.

    In addition to natural and nature-based features, the Corps should detail non-structural solutions, such as buyouts, as a legitimate solution for coastal storm risk. Examples of successful buyout solutions exist in both New York and New Jersey. Buyouts have not been thoroughly considered as part of a nonstructural solution to date. These solutions are among the few long-term strategies that eliminate risk where they occur, and therefore should be considered especially in areas expected to experience regular tidal flooding in the future.

    The further refinement of the non-structural areas should explicitly include and evaluate buyouts as a strategy, detailing that this approach would be conducted in partnership with the relevant local sponsor. Working closely with cost-share and local partners, the Corps should incorporate the utility of non-structural and building-scale measures, including buyouts and relocation, for areas with certain risk profiles.

    As an initial step, we recommend that the Corps develop a criteria and evaluation mechanism for prioritizing both individual properties and neighborhood-level or block-level buyout or relocation programs. A data-driven approach is a critical component of ensuring that such a program would be managed equitably (i.e., considerations of fair market pricing, pathways for public housing residents, and upward mobility). A prioritization scheme would need to be informed and led by a broad set of communities and residents to ensure that environmental justice and equity were centered. The results of such a study would help identify for which areas managed retreat is a reasonable option. A comprehensive risk reduction plan like NYNJHATS is incomplete without at least some reliable assessment of this option.

    3. Address Multiple Climate Hazards

    It is important and urgent to identify and prioritize federal investments in large-scale solutions to address the full suite of flood risk and build resilience across the region. The objectives of HATS have been limited to storm surge as the primary coastal climate hazard. This shortcoming of the study results in HATS not fully integrating the impacts and solutions for sea level rise and extreme precipitation and the ways in which they are connected, and compounding, storm surge.

    Recommendation 3(A): Plan Holistically for Compounding Flood Risks in the Study Area and Pursue Solutions that are Effective Against Multiple Flood Threats.

    The tentatively selected plan may differ if the objectives are expanded to manage the multiple flood risks across the region. The Rise to Resilience Coalition is concerned that solutions developed to mainly address coastal storms and storm surge can exacerbate the flood risk from sea level rise and low frequency precipitation events.

    When stormwater systems across the region have their capacity reduced as a result of sea level rise and storm surge, precipitation-based and pluvial flood risks become an impact of storm surge and sea level rise. These must be addressed together. Every land-based solution should be designed in a way that enhances stormwater systems. A “do no harm” approach is insufficient when storm surge and sea level rise will actively harm the region’s stormwater discharge capacity.

    The tentatively selected plan does not appear to address the full projected risks of sea level rise, as the storm surge gates would remain open except during storm conditions. High-tide projections in 2080 will flood many areas and the storm surge gates will have little-to-no impact on this expected “sunny-day flooding.”

    We urge the Corps to follow the directive of Section 8106 of WRDA 2022, which directs the Corps to formulate alternatives to maximize the net benefits from the reduction of the comprehensive flood risk within the geographic scope of the study from the isolated and compound effects of:

    • a riverine discharge of any magnitude or frequency;
    • inundation, wave attack, and erosion coinciding with a hurricane or coastal storm;
    • flooding associated with tidally influenced portions of rivers, bays, and estuaries that are hydrologically connected to the coastal water body;
    • a rainfall event of any magnitude or frequency;
    • a tide of any magnitude or frequency;
    • seasonal variation in water levels;
    • groundwater emergence;
    • sea level rise;
    • subsidence; or any other driver of flood risk affecting the area within the geographic scope of the study.

    Recommendation 3(B): Use Local Climate Projections, as Authorized by the Water Resources Development Act of 2020 and 2022.

    The Rise to Resilience Coalition has long been calling for the Corps to use local climate projections. The current sea level projections used for design, analysis, and effectiveness of alternatives are based on outdated projections. The draft analysis is based on ER 1100-2-8162 (June 2019), which states that it uses “… the most recent trends on relative sea level change from NOAA…” (main report p.176). The graph on that page indicates that the intermediate SLR prediction used by USACE for 2100 will be 1.8 feet. A 2022 NOAA publication projects a year 2100 intermediate SLR for the Northeast US of 1.3 meters (4.3 feet), more than double the design criteria.

    Additionally, state and local projections for the region exceed the Corps’ projections and are based on regional models developed through extensive peer-review. The New York City Panel on Climate Change (“NPCC”), for example, estimates 2 to 4.2 feet of sea level rise in their moderate projections. The Rise to Resilience Coalition secured language in WRDA 2020 directing the Corps to use updated, local peer reviewed projections. Section 113(A) in WRDA 2020 calls for the Corps to “coordinate the review with the Engineer Research and Development Center, other Federal and State agencies, and other relevant entities. Section 113(B) in WRDA 2020 calls for the Corps “to the maximum extent practicable and where appropriate, utilize data provided to the Secretary by such agencies.”

    Additionally, a letter from 18 members of Congress on May 26, 2021 reaffirmed this language, calling for the Corps to “ensure that the implementation guidance directing [the Corps] work related to NYNJHATS reflects the intent of the language included in WRDA 2020.” The letter also stated that “WRDA 2020 calls for a revision of existing planning guidance documents and regulations to ensure they are reflective of best available peer-reviewed data and the effects of sea level rise regardless of storm surge inducing events and inland flooding on communities in Section 113. The ability for cost-share partners to request use of local, peer-reviewed data should be clearly articulated in the guidance for this section. Authorization specifically for NYNJHATS (Section 203) was expanded to evaluate and address sea level rise and low-frequency precipitation events. For the NYNJHATS study, the [Corps] should use regionally down-scaled peer reviewed climate data like those developed by the New York City Panel on Climate Change and Rutgers University and the Mayor’s Office of Resiliency to model and map future flood risk in New York City.”

    Lastly, the New York City Mayor’s Office of Climate and Environmental Justice (“MOCEJ”), penned a letter on March 8, 2022, requesting the Corps “use the New York City Panel on Climate Change (NPCC) [sea level rise] projections for the New York City Region.” The letter goes on to state that “NPCC [sea level rise] projections use a probabilistic approach drawing on an ensemble of 35 global climate models, integrated with observations of vertical land movement, glacio-isostatic adjustment and other important regional factors (e.g., ocean circulation) identified in [Corps’ sea level rise] guidance. The [Corps’] relative sea level change projections do not account for regional variation and are lower than the NPCC’s projections. Consequently, the NPCC projections provide a more accurate estimate based on New York City’s unique conditions, and are considered the best available, peer-reviewed data on SLR for the New York region. The use of the NPCC SLR projections would:

    • Result in a better analysis of the onshore high frequency flooding needs and approaches;
    • Facilitate a better benefits comparison analysis in the National Economic Development (NED), Regional Economic Development, Environmental and Other Social Effects categories; and
    • Better inform the closure frequency analysis that feeds into the environmental impacts assessment and would have impacts on navigation channels and port operations.”

    We encourage the Corps to conduct a residual risk study of the tentatively selected plan to quantify the costs associated with tidal flooding and permanent inundation from sea level rise over time using local projections. This should be used as a filter to determine which proposed measures within the study address multiple hazards, and to inform prioritization of which measures may need further analysis and refinement before being recommended for construction.

    Conclusion

    Adapting to this new reality offers an opportunity to create healthy, resilient, accessible, and equitable waterways that are alive with commerce and recreation, and exciting waterfront destinations that reflect the vitality and diversity of the communities that surround them. As the region’s premier Coalition advocating for climate resilience and adaptation, we strongly encourage the Corps to prioritize:

    1. Give greater consideration to environmental justice through an iterative approach,
    2. Prioritize natural and nature-based features (“NNBFs”) and non-structural solutions, and
    3. Address multiple climate hazards.

    These comments and recommendations are geared toward developing the best project for our region that addresses the full suite of climate hazards that lay ahead. We appreciate the Corps’ work to study options for increasing the resilience of our region. The New York and New Jersey Harbor Region remains highly vulnerable to climate change, and we need solutions that ensure the equitable resilience, accessibility, and ecological integrity of our communities. There is no silver bullet to address our increasing vulnerability. The contexts are nuanced, and the solutions varied.

    The undersigned members of the Rise to Resilience Coalition thanks the Corps for this opportunity to submit public comments. We look forward to your response, and to changes in the tentatively selected plan that capture and address the recommendations put forward here, and of those across the Harbor region.

    Sincerely,
    American Institute of Architects (AIA) New York
    American Littoral Society
    Bronx River Alliance
    Center for NYC Neighborhoods (CNYCN)
    Columbia University Climate School, Center for
    Sustainable Urban Development
    Coney Island Beautification Project
    Coney Islanders for an Oceanside Ferry
    Environmental Defense Fund
    Friends of Bushwick Inlet Park
    Future City Inc.
    Hackensack Riverkeeper
    Hudson River Waterfront Conservancy, Inc.
    Jamaica Bay-Rockaway Parks Conservancy
    13
    LES Ready!
    The Municipal Art Society of New York
    NAACP New Jersey State Conference
    National Parks Conservation Association (NPCA)
    Northeast Region
    Natural Areas Conservancy
    Natural Resources Defense Council (NRDC)
    New Jersey Future
    New Jersey League of Conservation Voters
    New Jersey Progressive Equitable Energy
    Coalition (NJPEEC)
    New Jersey VOAD (Voluntary Organizations
    Active in Disaster)
    New York City Chapter of the Surfrider
    Foundation
    New York City Soil & Water Conservation
    District
    New York Disaster Interfaith Services (NYDIS)
    New York City VOAD (Voluntary Organizations
    Active in Disaster)
    Newtown Creek Alliance
    New York League of Conservation Voters
    NY/NJ Baykeeper
    Ocean Bay Community Development
    Corporation
    Rebuild by Design
    Regional Plan Association
    Regional Ready Rockaway
    RISE (Rockaway Initiative for Sustainability &
    Equity)
    RETI Center
    Save the Sound
    Sierra Club Atlantic Chapter
    South Bronx Unite
    Stormwater Infrastructure Matters (SWIM)
    Coalition
    Trust for Public Land
    Urban Ocean Lab
    Waterfront Alliance
    WE ACT for Environmental Justice
    Wildlife Conservation Society

    February 22, 2023 | 80x50 Initiative
     AIA New York Statement on New York State Governor Hochul’s Budget proposal 

    February 21, 2023 

    Since our founding in 1857, the American Institute of Architects New York Chapter (AIA New York) and our members have worked to advance the quality of life of New Yorkers and protect the public’s health, safety, and welfare. AIA New York supports Governor Hochul’s budget proposal and its efforts to tackle climate change, the housing crisis, and much-needed infrastructure improvements. However, we would like to express concern that the budget does not address some of these issues aggressively enough. 

    We congratulate Governor Hochul for planning to implement multiple programs that will end our dependence on fossil fuels for both new and existing buildings. However, as the budget is currently written, there are multiple exceptions for large buildings and certain types of buildings three stories or below that would be permitted to continue to use fossil fuels past 2025. We believe that a January 1, 2025 deadline for all small buildings would be a more appropriate target, as time is of the essence in the fight against climate change. With the right level of urgency and commitment, we are confident that New York can lead the way in creating a more sustainable and livable future for all. 

    We also applaud the Governor’s forward-thinking approach to addressing the ongoing housing crisis by committing to the construction of 800,000 new affordable housing units over ten years, including a five-year, $25 billion housing plan to create and preserve 100,000 affordable homes. This critical investment will provide much-needed relief to families struggling to find affordable and safe places to live. The budget will also extend the completion deadline for vested 421a projects by four years to June 2030, offering projects that suffered delays during the COVID-19 pandemic the opportunity to seek the tax abatement. However, we are concerned that the budget does not tackle the housing crisis quickly enough to address the serious shortage in affordable and supportive housing. More should be done to incentivize the construction of affordable housing, including a replacement for the J-51 tax abatement and a total rehaul of 421a. While considerably more housing than outlined in the budget will need to be created and preserved in the years to come, it is nonetheless reassuring to see the Governor acknowledging this issue with greater emphasis. 

    In addition to addressing critical social and environmental issues, the budget proposal also recognizes the importance of investing in our state’s infrastructure. The Central Business District Tolling Program, also known as the congestion pricing plan, will address gridlock in Manhattan and help finance the MTA’s capital improvements. Improving accessibility by making 70 more subway stations ADA-accessible and continuing work on Second Avenue Subway Phase 2 to extend service from 96th street to 125th street and connect with Metro-North are crucial steps towards a modern, efficient, and accessible transportation system. These infrastructure investments will not only improve the quality of life for our communities but will also drive economic growth and competitiveness for years to come. 

    Together, these initiatives in the budget proposal will not only protect our environment and combat climate change but also improve the lives of all New Yorkers. We commend Governor Hochul for pushing these initiatives forward in her budget proposal. 

    January 25, 2023
    AIA New York Statement of Support for Governor Hochul’s New York Housing Compact

    The American Institute of Architects New York (AIA New York) is expressing its strong support for Governor Hochul’s “New York Housing Compact.” The Compact is intended to create 800,000 new units over the next decade, helping New York reduce its significant housing deficit and creating countless new jobs. The lack of housing construction has caused home prices and rents to skyrocket, making the state unaffordable to many New Yorkers. 

    No single policy change will provide the housing New York needs, which is why the Governor’s multi-prong effort is so laudable. The establishment of Local housing targets, promotion of transit-oriented development, adjustment of the Multiple Dwelling Law and FAR cap, legalization of ADUs in NYC, and replacement of 421a will go far towards achieving the Governor’s ambitious goal. These policies should be prioritized to ensure sufficient housing is created in a timely manner. 

    While the Governor is strongly supportive of building new housing, greater policy changes are needed to incentivize the improvement of dilapidated existing housing and vacant housing. New York City alone has up to 90,000 vacant rent-stabilized units, and bringing those units back into the market would go far towards hitting the Governor’s 800,000-unit goal. A number of policies should be enacted in Albany to enable this, including a replacement for the J-51 tax abatement, a “rent reset” to cover the cost of retrofitting currently vacant units, and property tax reform to reduce the disproportionate burden on multifamily building owners. 

    A cohesive set of policy proposals to simultaneously spur the creation of new housing and the improvement of existing housing is the best path forward. This is the most effective means of creating new housing, as well as ensuring those vacant units are retrofitted and affordable. Architects applaud the Governor’s Compact and look forward to working with her to create more housing as quickly as possible. 

    September 28, 2022
    Int. 549-2022 Solitary Confinement Ban Testimony

    Thank you to the City Council for holding this hearing today. My name is Andrea Lamberti and I represent the American Institute of Architects New York, also known as AIA New York, as 2022 board president. AIA New York represents New York City’s architects employed in government agencies, professional service firms, and academia.

    Some of our members are employed in the design of criminal justice facilities, including jails, in New York City and other areas. Many of our members have spoken out against the design of spaces for incarceration. Others, when called to design such spaces, have advocated for revising traditional designs to consider the mental health of occupants.

    For years, AIA has taken strong positions, both locally and nationally, against the design and construction of spaces for solitary confinement. AIA New York strongly supports Intro 549’s prohibition of solitary confinement in city jails.

    Solitary confinement is not an effective strategy for the reduction of violence in detention facilities. Spaces for solitary confinement are designed to be punitive to detainees. Those we have seen in New York City are usually windowless boxes or cages, crafted to be oppressive environments that are intended to harm occupants’ psychological wellbeing.

    This is particularly troubling considering that a majority of the detainees in New York City suffer from mental illness. It is both cruel and poor policy to further strain the mental health of those who are already mentally ill. In fact, forcing mentally ill detainees into solitary confinement further aggravates their wellbeing, making them even more likely to resort to violence and putting guards and their fellow detainees in greater danger.

    Nevertheless, we recognize that detainees should have an option to spend time alone. For both safety and comfort, it is important that detainees have their own individual living quarters. The city’s justice facility design standards in Local Law 194-2019 mandate “individual occupancy housing units” for detainees. If new jails legally require individual living quarters, there is no need for solitary confinement as a safety measure at all.

    The consensus of architects is that the design and construction of spaces for solitary confinement is a bad policy. We need laws in New York City that reflects the best architectural practices, and we endorse the possibility that our city can serve as the bellwether for the country on this issue. Therefore, we ask the City Council to pass Intro 549 to make our city safer and more humane. Thank you.

    June 27, 2022 | 80x50 Initiative
    Testimony to the Committee on Housing and Buildings, Committee on Environmental Protection and Committee on Civil Service and Labor on Local Law 97

    Thank you, Chair Sanchez, Chair Gennaro, and Chair De La Rosa, for holding this hearing today and the opportunity to testify. The American Institute of Architects New York, also known as AIA New York, is the professional association representing nearly 6,000 of New York City’s architects and related professionals. Since our founding in 1857, AIA New York and our members have worked to advance the quality of life of New Yorkers and protect the public’s health, safety, and welfare. Working alongside our partners in City government, AIA New York has and will continue to be a strong supporter of Local Law 97 (LL97).

    As you know, buildings contribute two-thirds of the city’s total greenhouse gas emissions. LL97 is the centerpiece of the city’s climate strategy for large buildings and is crucial to delivering NYC’s low-carbon future. The law will also bring important co-benefits, like lower pollution and greater health and comfort to New Yorkers across the five boroughs. Among the weak spots in this endeavor is a workforce capable of delivering high performance buildings and electrifying everything possible. It is our belief that, at all levels, we do not yet have the necessary workforce to comply with LL97.

    We have the means for building zero emissions, high performance buildings today. These are market ready solutions, and more and more products are coming into the market. These are buildings that will be easier and simpler to operate, and more durable buildings that require far fewer inputs. High performance buildings are conservative in nature—they cost less to operate with little or no cost premium to construct buildings to comply with the 2050 requirements of LL97.

    At best, the vast majority of our new buildings are barely complying with the status quo (compliance with the energy code) let alone meeting the demands of 2030 and 2050. Each building built or renovated that doesn’t meet the 2050 requirements is a lost opportunity. We know it can be done. We have colleagues who are building buildings today that meet the 2050 goals of LL97.

    We find there is a major discrepancy in the marketplace demand for workers and the projected supply of workers estimated to meet the goals of LL97 and the New York State’s Climate Leadership and Community Protection Act. Not only is it an issue of the quantity of workers, but also of the quality of their training. On the demand side, our members report that most clients are not requesting performance higher than required by the building code for renovations or new construction. This will not get to 2030 emissions levels, let alone 2050. Local law 154 of 2021, the all-electric buildings law, helps but doesn’t address decarbonizing existing buildings. All this puts the onus of decarbonization on the grid rather than assisting with lowering loads through higher efficiency, and decarbonizing the grid alone is not sufficient to meet carbon targets. We will not get a second chance.

    On the supply side, the entire building ecosystem will need training and preparation that we suggest be done in phases, and that supports the growth of the nascent high performance retrofit industry in NYC: Owners, developers, building managers, contractors, leadership in architecture and engineering firms, policymakers and lenders—these are the makers of demand and we need them trained first to get retrofit projects in the pipeline. The generated projects will then induce a demand for training of the next level of workers, these including professionals such as architects, engineers, façade designers, energy analysis and scientists, regulators such as the Department of Buildings and their examiners and inspectors, members of the construction trades, construction managers, electricians, and HVAC mechanics, as well as certification professionals (PHIUS, PHI, HERS, etc.).

    In technical education, we have levels of competency: awareness, understanding, and ability. We need to extend this to the different sectors. The general public needs an awareness of how buildings operate and how to transition to a fossil fuel free future. The average American spends 90% of their time indoors. They should have an understanding of how comfort is obtained and where electricity comes from. Leadership in the building sector should have an understanding of what is required for high performance buildings to meet LL97 and 80×50. Most still do not understand that a passive house quality enclosure is—the first step for getting nearly every building type in NYC on its way to meeting 80×50. Specific ability to realize high performance buildings is eventually needed in all trades and professions.

    The specific ability training we recommend is Passive House. Our members who have been trained in this standard all attest to how much it has fundamentally changed their practice. It is a data-driven and scientific approach to high-performance building design; it is holistic and comprehensive. This training has been extensively subsidized by NYSERDA, training hundreds of design professionals and hundreds more tradespersons. Please note that NYSERDA subsidized these trainings without a clear market demand for these skills.

    We would even invite the members of these committees to undertake such a course. We are confident that this level of understanding will help produce more productive policy decisions. Again, thank you to for holding this important hearing. Our organization and members remain committed to working with the Council and Administration to deliver NYC’s low-carbon future.

    April 13, 2022 | 80x50 Initiative
    Testimony to the Committee on Housing and Buildings and Committee on Environmental Protection on Local Law 97

    Thank you, Chair Sanchez and Chair Gennaro, for holding this hearing today. The American Institute of Architects New York, also known as AIA New York, is the professional association representing nearly 6,000 of New York City’s architects and related professionals.

    Since our founding in 1857, AIA New York and our members have worked to advance the quality of life of New Yorkers and protect the public’s health, safety and welfare. Working alongside our partners in City government, AIA New York has and will continue to be a strong supporter of Local Law 97 (LL97).

    As you know, buildings contribute two-thirds of the city’s total greenhouse gas emissions. LL97 is the centerpiece of the city’s climate strategy for large buildings and is crucial to delivering NYC’s low-carbon future. The law will also bring important co-benefits, like lower pollution and greater health and comfort to New Yorkers across the five boroughs.

    AIA New York is committed to working with the Council and the Administration to successful implement Local Law 97 and ensure compliance within the design, construction and building industry. With important milestones approaching, increased funding is essential to continued climate progress, and to ensure all New Yorkers benefit from a recovery that boosts green jobs and healthy, low-carbon and efficient buildings.

    The City must commit to properly funding the Office of Building Energy and Emissions Performance (OBEEP), which is housed within the Department of Buildings. The office is severely understaffed, with only a handful of staffers overseeing compliance for thousands of the city’s largest buildings, making enforcement more difficult. In addition, the staff shortage complicates the office’s ability to take on further responsibilities and initiatives related to compliance with LL97, such as providing education on sustainable design techniques. We applaud Speaker Adams and the Council’s response to the FY 23 Preliminary Budget, calling on the Administration to include baseline funding of $450,000 in the Executive Budget for six additional positions within OBEEP to assist with Local Law 97 implementation.

    AIA New York also urges the City to lead by example, by increasing funding to achieve the City’s own requirements under LL 97, which include reducing emissions from government operations 40 percent by 2025 and 50 percent by 2030. The Department of Citywide Administrative Services is in charge of overseeing much of this work, and they have developed a comprehensive plan for meeting the targets. The city should invest further in those agencies that oversee capital works, as they are integral in ensuring that city buildings comply with the law’s provisions. Additional funding is needed to ensure the Department of Design and Construction and other agencies can pay for the work and are sufficiently staffed to oversee this significant increase in retrofits.

    We have seen already that a lack of funding has decreased confidence in the ability of the city to effectively enforce the law. The best way for the city to rebut these concerns is to properly fund those city agencies who oversee its compliance.

    Again, thank you for holding this important hearing today. Our organization and members remain committed to working with the Council and Administration to deliver NYC’s low-carbon future.

    April 06, 2022
    Testimony to the Twin Parks Citywide Taskforce on Fire Prevention

    Thank you to the City Council for holding this hearing today. The American Institute of Architects New York, also known as AIA New York, is the professional association representing nearly 6,000 of New York City’s architects and related professionals.

    Since our founding in 1857, AIA New York and our members have worked to advance the quality of life of New Yorkers and protect the public’s health, safety and welfare. Working alongside our partners in City government, AIA New York is committed to resolving the fire safety challenges that our city faces and looks forward to working with the City Council to take actions that will prevent future tragedies from taking place.

    In the wake of the tragedy on January 9, architects and others saw how the deaths from the fire were entirely preventable. While self-closing doors have long been mandatory and the dangers that space heaters pose are well-established, a lack of proper enforcement of building codes meant that Twin Parks Northwest had broken self-closing doors and a faulty heating system, forcing tenants to supplement with space heaters.

    AIA New York applauds the Council and the Twin Parks Fire Safety Task Force for their work creating the sensible legislation being introduced today. This multifaceted approach, which includes inspection, communication, and prevention strategies, will ultimately help save lives. In particular, we are in support of Introductions 104, 105, 106, and 131. Intro. 104 effectively adds the term “self-closing door” to the Housing Maintenance Code. The Department of Buildings should consider issuing a corresponding Building Notice upon enactment of this legislation. Intro. 105 reduces the time allowed to correct a violation regarding self-closing doors and increases penalties for false certification. Intro. 106 prohibits the sale of electric space heaters without automatic shut-off, which we saw contributed to the start of the fire on January 9. Finally, Intro. 131 provides for additional fire safety education and outreach through the Fire Department.

    Of the legislation under consideration today, AIA New York is in opposition to Intro. 115, which raises the required minimum temperatures to be maintained in residential buildings. Recognizing that this legislation will increase the use of fossil fuels and the release of harmful emissions into our City, we hope to work with Council to provide alternative solutions that keep New Yorkers warm during the coldest months. The City and the private sector have each committed to significantly reduce greenhouse gas emissions through the Climate Mobilization Act and Local Law 97, whose goals run counter to this proposed legislation.

    Thank you again for your timely and important work addressing our city’s fire safety. Today’s actions are an essential step towards preventing another tragedy from ever occurring again and we look forward to continuing this critical work together.

    February 24, 2022
    Committee on Civil Service and Labor Testimony

    Thank you for holding this hearing today. I am Ben Prosky, Executive Director of the American Institute of Architects New York, also known as AIA New York. We represent New York City’s public-sector and private-sector architects, who are employed at government agencies, firms, and universities. Our members include unionized and non-unionized architects, as well as workers and management.

    This hearing’s topic is very timely, since architects at some of New York City’s architecture firms are in the process of unionizing. Support for unionization has arisen from the poor compensation architects receive, as well as the workplace issues working for low wages creates. The US Department of Justice does not allow AIA New York to collectively bargain for our members or organize work stoppages. This means we cannot work with agencies, owners, and developers to set fair fees and wages for their employees.

    According to the 2021 AIA Compensation Report, the average salary in New York City for a recent architecture school graduate is $58,000 per year. This is not enough to cover hundreds of thousands of dollars in student debt accrued over a decade of education, nor the high cost of living convenient to most offices. Comparatively, first-year associates at New York City law firms earn $215,000 per year.

    In addition to being underpaid, architects are pressed to work incredibly long hours. Agencies rarely receive sufficient funding for staffing, leading agency leadership to overwork their architects. Meanwhile, firms are unable to collectively bargain for fees, allowing owners and developers to set high work requirements for low fees. As a result, firm owners push their architects to work incredibly long hours, with 60- to 70-hour work weeks not being uncommon.

    Unionization in architecture is an important tool to strengthen workers’ rights but it will not solve many of the industry’s core problems. Our unionized members at agencies are paid less than our non-unionized members at firms. For instance, the starting salary for a Department of Design and Construction Junior Project Manager is $51,000 a year.

    Fortunately, Council Members can strengthen workers’ rights for architects. They can assign larger budgets for agencies, specifically to hire more architects and pay architects higher wages. The Council can also require that agencies stop demanding free work from architecture firms. Agencies regularly require a significant amount of upfront work from firms before awarding a contract, yet that work is not compensated. Combined with unionization, changes like these will create a better working environment for architects.

    October 21, 2021
    AIA New York Statement of Support for Open Restaurants

    October 20, 2021

     

    The American Institute of Architects New York is expressing its strong support for the Open Restaurants program. The program, which allows for expanded outdoor dining, must be made permanent. Restaurants are a key part of the culture, street life, and economy of our city. As such, the City should ensure that our restaurants remain economically viable business by allowing them to continue serving customers on sidewalks and streets.

    Design is an integral part of dining, and therefore must be strongly considered by the city in the process of making the Open Restaurants program permanent. We are glad that the zoning text amendment will open more parts of the city to outdoor dining. This will create more vibrant neighborhoods with greater street life, while allowing the sidewalk café and roadway café programs to operate as a single entity, easing compliance for restaurateurs and designers.

    Furthermore, the program’s parameters, which will be determined later by agency rulemaking, must incorporate key aspects of good design based off design guidelines for outdoor dining. Design guidelines will not only assist agencies in crafting rules but will also provide insight for restaurateurs. These design guidelines must be written by those with expertise; they should be authored by architects who design outdoor dining spaces for restaurants and architects who work in agencies overseeing compliance with the program.

    The city must also recognize the importance of a well-functioning compliance scheme for the program. Sufficiently high fees should be instituted to ensure that the program has the requisite staff to oversee it. Architects should also have to sign off on applications for more long-lasting structures to ensure rules are followed. Without proper oversight, some restaurants may abuse their privileges to use public space and create safety hazards.

    Open Restaurants has been a very successful program throughout the pandemic, keeping countless restaurants in business and their staff employed. However, there are inherent risks to providing private businesses with public space. These potential challenges can be avoided by following principles of good design in the rulemaking process.

    August 05, 2021 | 80x50 Initiative
    Design and Construction Industry Letter in Support of the American Jobs Plan

    Members of the New York Congressional Delegation,

    We are writing on behalf of New York’s design and construction industry professionals to thank you for your strong support of the American Jobs Plan. As outlined, the jobs plan would dramatically improve the quality of New York’s infrastructure, all while reducing inequality, mitigating against the effects of climate change, and creating thousands of good-paying jobs.

    As the jobs plan is being debated in Washington, we want to reaffirm our support for its provisions and highlight some areas of improvement that we believe would benefit all New Yorkers:

    • Increase funding for mass transit: New York alone requires hundreds of billions of dollars to fund mass transit improvements. We are pleased to know that necessary levels of funding will be dedicated to move the Gateway Program forward, however, we ask that other mass transit projects in New York also receive sufficient funding. Transporting New York’s people and freight more efficiently is imperative to our overall economic growth.
    • Fund transportation alternatives: Allocate robust funding to fix our transit challenges through relatively lower-cost design and construction solutions, such as bus lanes, bike lanes, and the pedestrianization of streets. These solutions will reduce the strain on existing infrastructure and improve the quality of life for cyclists, pedestrians, seniors, and people experiencing disabilities. New York has numerous programs and legislation in place to do this, but they require more funding to be implemented successfully.
    • Invest in reimagining urban highways: Highways have been critical to the success of modern cities, allowing for people and goods to move with ease, however, they have tremendous social costs, including polluting and dividing marginalized communities. We need dedicated federal funding to reimagine these transportation infrastructure assets into places that provide equitable access to open space, enhanced placemaking, and protection from the effects of climate change.
    • Provide funding for New York to implement sustainability legislation: At the state and city level, New York is in the process of implementing, respectively, the Climate Leadership and Community Protection Act (CLCPA) and Local Law 97-2019. These ambitious pieces of legislation require our state and city governments to spend billions of dollars upgrading energy infrastructure and retrofitting government buildings. Yet, funding is needed to make these projects move ahead so that government can lead the way towards a greener, cleaner future.
    • Increase funding for affordable housing: NYCHA alone requires at least $40 billion, most of which is expected to come from the federal government. Without significant federal investment, NYCHA’s residents will continue to live in dangerously dilapidated buildings.
    • Couple funding for housing with removal of exclusionary zoning: The federal government has a long history of driving local policy through mandates and making the receipt of federal funding contingent upon compliance with important national objectives. Therefore, funding to local governments for the development of housing should be contingent upon the elimination of exclusionary zoning practices that are overly restrictive, decrease affordability, and harm our local and regional economies, i.e., single-family zoning. These policies have seriously hampered efforts to combat the housing crisis in New York City and its surrounding counties, increased segregation and inequality, and ultimately prevented the housing supply from matching the needs of New York’s residents. The jobs plan offers a unique opportunity to combat exclusionary zoning policies across all of New York.

    Again, we thank you for your strong advocacy on behalf of New York’s built environment. We are committed to ensuring that the jobs plan becomes law and that billions of dollars of funding support New York’s economy. Please consider our members in the design and construction industries as a resource while you examine the jobs plan and other similar proposals.

    Sincerely,

    Benjamin Prosky, Assoc. AIA
    Executive Director
    American Institute of Architects New York

    Carlo A. Scissura, Esq.
    President & CEO
    New York Building Congress

    John T. Evers, PhD
    President/CEO
    American Council of Engineering Companies of New York

    June 23, 2021 | 80x50 Initiative
    Statement of Support for Int. 2317, Fossil Fuel Ban Bill

    AIA New York strongly supports the electrification of buildings by ending their reliance on fossil fuels for power and other uses. Fossil fuels in buildings have been largely phased out throughout New York State and the rest of the country, both by mandate and by choice. However, this is not the case in New York City, making legislation necessary to accomplish this goal. Int 2317-2021 would do just this, by not allowing new or significantly altered buildings to use high-carbon-emitting substances.

    Eliminating fossil fuel use in new buildings and those undergoing major alterations would have numerous positive impacts. As 70% of carbon emissions in New York City originate from buildings, electrification would reduce greenhouse gas emissions, since electric power will soon originate from a clean wind and solar-powered grid. Reducing greenhouse gas emissions would mitigate climate change and improve air quality while also decreasing the city’s reliance on non-renewable energy sources. The 2019 gas moratorium showed the supply of fossil fuels is unreliable, which makes the design and construction of buildings dependent on them challenging. Lastly, fossil fuels create an unnecessary fire hazard at construction sites and in occupied buildings. This endangers design and construction industry professionals, as well as everyday New Yorkers.

    We hope this bill is just the start of reducing the city’s reliance on fossil fuels. Future legislation is needed to address existing buildings, most of which are still reliant upon these non-renewable energy resources. As comparatively few buildings undergo the types of alternations covered in this bill, additional legislation is needed to cover most other existing buildings. For instance, further action by the City Council and NYC Department of Buildings should be taken to encourage or mandate the replacement of boilers.

    While AIANY is strongly supportive of the concepts in this bill, changes should be made to the existing legislation to ease implementation and compliance. These recommendations are outlined below and would ensure that the bill is as effective as intended.

    Recommendations:

    * Move to new portion of the code not relating to fuel signage, perhaps Section 24-173 (use of solid fuel) or a new section (24-178).

    * Define covered buildings as “new buildings” and those undergoing renovations that fall in the ALT1 category, “Major alterations that will change use, egress or occupancy.”

    * Lower kgs from 50 to 40 to make it essentially impossible for “clean” fossil fuels to emerge as an alternative in the future.

    * Carbon dioxide, not carbon, should be used as the unit of measurement, since it is the industry standard.

    * The exemption should be clarified and simplified and should require a formal application process to reduce loopholes. Language should be taken from LL97-2019 and DOB rules relating to its implementation.

    * The law should take effect after one year for smaller buildings, two years for mid-size buildings, and three years for large buildings to allow the industry to adjust.

    February 22, 2021
    Statement of Support for Int. 2186, Comprehensive Plan Bill

    Comprehensive planning is a necessary addition to New York’s land use policies. For too long, public- and private-sector design and construction have been uncoordinated in addressing the city’s needs around housing, open space, and transportation. The only way to achieve this level of citywide coordination is through the implementation of a long-term comprehensive plan, like the one envisioned in Int. 2186. As the professionals charged with implementing many of the bill’s provisions, architects are strongly supportive of this effort. However, there are some important changes that AIA New York believes should be instituted to improve the bill.

    First, the amended bill should accelerate the timeline for the final adoption of the comprehensive plan. It is unclear whether elected officials and city agencies will continue to pursue necessary projects while the plan is in development, as they may opt to wait years until the plan is in effect to ensure that these projects are in accordance with it. An adoption date of June 2025 may therefore significantly delay both design and construction.

    The bill should also consider more precise geographic boundaries than community districts, which are based on demographic realities from decades ago and can be far too large to be effective for planning purposes. Five community districts (Manhattan 8, 12; Queens 12, 13; Brooklyn 18) have populations larger than or approximating Rochester’s, our state’s third largest city, and one community district (Queens 12) has a population approaching Buffalo’s, our state’s second largest city. As such, district-level targets may not be able to fully address the needs of a district, particularly the needs of more marginalized communities.

    Lastly, the power instilled in the Director of the Office of Long-Term Planning is concerning. The bill would allow for the director, an unelected official, to hold sway over much of the comprehensive planning process and at times make unilateral decisions on design and construction. Furthermore, there are no professional qualifications required for this director position, and there is no mandate that the director to be an architect, engineer, planner, or any other type of land use professional. A single government official who is both unaccountable to voters and lacking professional expertise should not be given such great power over the design of our buildings, public spaces, and transportation systems.

    Int. 2186 is an important first step in instituting a much-needed comprehensive plan for our city. We hope our recommendations are strongly considered in an amended version of the bill. Architects want to design a more equitable city, and we believe our recommendations would help the city achieve this goal. Thank you to Speaker Johnson and the rest of the bill’s sponsors for proposing this important legislation.

     

    Board of Directors, AIA New York

    December 08, 2020
    AIA New York Statement of Support for SoHo/NoHo Rezoning

    Equitable design is a key component of solving New York City’s ongoing affordability crisis. Without new housing, rents and home prices will continue to rise, making the city unaffordable for most New Yorkers. While there has been a significant amount of new residential construction in the city over the last few years, it has primarily been in more economically distressed and non-white communities in the outer boroughs. It is time that wealthier white neighborhoods start to accept new residences and new residents.

    Architects strive to design integrated neighborhoods, ones with residents from diverse backgrounds and economic circumstances. True integration requires a diversity of housing typologies, not only market-rate units, but affordable and supportive units as well. The city has many tools to encourage diverse typologies, including the NYC 15/15 Rental Assistance Program, Supportive Housing Loan Program, Mandatory Inclusionary Housing (MIH), and Zoning for Qualify and Affordability (ZQA). All of these should be utilized for rezoning SoHo, NoHo, and other neighborhoods.

    The proposed rezoning of SoHo and NoHo offers a first step towards making our city’s housing policies more equitable. The current proposal shows that new construction can occur within established neighborhoods and historic districts, respecting older forms of architecture and current residents. Most crucially, plans for 800 units of legally mandated affordable housing would make one of our country’s most expensive areas affordable for thousands of New Yorkers.

    SoHo and NoHo have not undergone significant zoning changes in half a century, despite transforming from industrial to primarily residential and retail in use. Rezoning the area would enable compliance with more recent housing policies, such as MIH, which requires around 25% of new units to be affordable. Furthermore, it would also remove burdensome restrictions on small businesses which do not exist in neighborhoods with more updated zoning.

    It is the duty of architects to ensure that neighborhoods are open and accessible to all, not only those of means. Therefore, AIA New York is expressing its strong support for the rezoning of SoHo and NoHo to allow for more residential construction. We encourage the city to allow for even greater amounts of affordable housing as the proposal is refined through discussions with the community. The current debate over this rezoning will set the precedent going forward of whether affordable housing can be designed and built in wealthier white neighborhoods.

    It is time that zoning be used to make our city, particularly those centrally located neighborhoods like SoHo and NoHo, livable for all New Yorkers. In 2022, we will have a new Mayor and City Council, and we hope a rezoning of SoHo and NoHo will spur them to allow more affordable housing in similar parts of the city.

     

    Board of Directors, AIA New York

    September 30, 2020
    AIANY Criminal Justice Facilities Statement

    September 30, 2020

    As architects, we must take on difficult conversations within our workplaces about the broader social implications of our work, and the practices we allow our work to perpetuate. For too long, architects have been complicit in upholding intrinsic racism within the American criminal justice system. While many architects have attempted to mitigate injustice by applying their professional skills to associated built structures, ultimately it is beyond the role of design professionals to alleviate an inherently unjust system. Until more comprehensive policy changes are made on a national scale, good design alone is not enough to remove or overcome the racism inherent within the criminal justice system. It is time we listen to Black, Brown, and Indigenous communities that have long suffered due to unjust societal norms and outcomes.

    We must all take actionable steps to address the racism sustained by our criminal justice system.

    Until there is measurable reform in the American criminal justice system to apply the law without racial bias, AIA New York is taking leadership on this issue. We are calling on architects no longer to design unjust, cruel or harmful spaces of incarceration within the current United States justice system, such as prisons, jails, detention centers, and police stations. We instead urge our members to shift their efforts towards supporting the creation of new systems, processes, and typologies based on prison reform, alternatives to imprisonment, and restorative justice.

    As part of this policy, AIANY will embark on several initiatives:

    • Through programming starting in late Fall 2020 and exhibitions, we will examine architecture’s role in the criminal justice system, using open and interdisciplinary
      discussions to increase awareness and knowledge within our professional community,
      while highlighting the voices of those who have suffered within the system.
    • Through government advocacy, we will push to limit construction of new criminal justice facilities. AIA New York Political Action Fund, our chapter’s political action committee, will actively support candidates who believe in reducing criminal justice facility construction and implementing further criminal justice reforms.
    • Our Architecture for Justice Committee will be reconstituted to increase focus on largescale justice issues and reduce the current emphasis on the design of criminal justice facilities.
    • We will advocate that AIA National, AIA New York State, and our fellow chapters adopt similar positions to discourage design of criminal justice facilities that uphold the current system.
    • Projects in this typology may be submitted to the AIANY Design Awards program; however, Jury Instructions for judging will prioritize projects that demonstrate excellence in the support of systems, processes, and typologies based on prison reform, alternatives to imprisonment, restorative justice, and investment in communities of color.

    While we recognize that the United States is not the only country with a flawed justice system and that architects have been complicit in bias and mistreatment abroad as well, we hope these changes in chapter policy will further advance racial justice within our city, state, and country. Over the coming months and years, AIANY and its members have a great deal of work ahead ofus. We embrace this challenge knowing that effective advocacy can change policies and attitudes within our society.

    Board of Directors, AIA New York

    June 08, 2020
    Testimony in Support of Temporary Outdoor Dining Areas

    Consumer Affairs and Business Licensing Committee Testimony on Int. 1957-2020

    Thank you, Chair Cohen, for holding this hearing today. We also want to thank Speaker Johnson, Council Member Reynoso, and the other sponsors of this bill. The American Institute of Architects New York, also known as AIA New York, is strongly supportive of the Council’s innovative effort to help restaurants and street vendors, as well as restore normal street life. As architects, we understand the importance of utilizing our open space for a variety of public purposes, including dining.

    Nevertheless, some critical changes should be made to the bill in order to protect the safety of the public and ensure its effective enactment. We have attached recommended language revisions which are summarized below. We recognize that the events of the last few days may change the city’s outlook on public space. Therefore, these comments are made solely regarding this bill as currently written, with the understanding that the city may need to adjust its laws and rules regarding access to public space.

    The bill currently states that, “a proposed layout for such space may be submitted to the department [of Consumer Affairs] without the seal and signature of an architect or engineer licensed by the state of New York.” As currently written, this bill allows restaurants to undertake unsafe and unsupervised work that bypasses Department of Buildings plan reviews. Rather, the bill should allow restaurants to make minor alterations that do not necessitate the seal and signature of a registered architect or professional engineer.

    Furthermore, the bill places the burden largely on the Department of Transportation. Other agencies should be included as well, particularly the Parks Department and Department of City Planning. They supervise parks and privately owned public spaces (POPS), respectively, which should also be considered for temporary outdoor dining areas, where safe. There is no reason to limit this effort to streets and plazas, as parks and POPS also provide opportunities for dining. The city faces the worst financial crisis in nearly fifty years, which means that every agency’s resources will be strapped. Under these circumstances, a single agency should not be held responsible for this bill’s provisions.

    While we strongly recommend the Council amend the bill to include these changes and others, we are also very supportive of the concept of the bill. We hope the Council incorporates these comments to write a safer and more effective bill.

    Sincerely,

    Benjamin Prosky, Assoc. AIA
    Executive Director, AIA New York

    Kim Yao, AIA
    2020 President, AIA New York

    April 16, 2020
    AIA New York Statement of Support for Suspension or Deferment of Rent and Eviction

    The COVID-19 crisis has seriously imperiled the financial stability of many businesses in New York State, including architecture firms. Much-needed regulation limiting and/or stopping almost all construction activity, coupled with clients suspending and/or canceling projects due to financial uncertainty, has significantly limited work opportunities. While government financial support has been helpful, expenses for firms remain burdensome.

    Commercial rent is straining the finances of businesses that currently have little to no income. The dining, retail, and hospitality sectors have been particularly hard hit, much to the detriment of New York City. Many architecture firms that serve these and other important parts of the economy have suffered greatly as well, as they currently have little to no revenue. While some landlords have been forgiving, many have been unwilling to provide any leeway for their struggling tenants.

    Therefore, AIA New York is expressing its strong support for legislation to suspend or defer commercial rent payments during the current health and financial crisis. This would provide critically helpful assistance to companies and businesses throughout the city. The risks are too great if architecture firms begin folding; affordable housing, public works, historic preservation, and other crucial areas of architectural work would be hampered by the loss of significant numbers of architecture firms.

    We strongly support those efforts in the New York State Legislature to eliminate or defer the burden of financial rent. During this financial crisis, our government must do everything it can to support our local economy and keep architecture firms and other businesses afloat.

    April 03, 2020
    COVID Public Sector Work Letter to Mayor de Blasio

    April 2, 2020

    Honorable Bill de Blasio
    City Hall
    New York, NY 10007

    Mayor de Blasio,

    During this crisis, we understand that difficult decisions must be made and thank the City and State for their tireless efforts in keeping the public safe and informed. We trust that the City will meet the ensuing challenges in the short term, while considering the steps necessary to support the long-term vitality of its businesses, industries, and workers.

    As such, we write to you asking that the City reconsider its decision to immediately halt design work for public projects. Design work is essential to construction projects, and, as you know, necessary for public projects to be shovel-ready. Additionally, unlike other aspects of construction, design work can be safely and properly completed in the safety of our homes.

    As we explore ways to maintain basic levels of economic activity, permitting design work for public projects to continue will serve as an important opportunity to keep workers safely employed with wages and benefits during the current crisis, and to help prepare New York for the groundbreaking of construction projects that will employ tens of thousands of union construction workers once this crisis has been overcome.

    Delays to work that can safely continue from our homes will further hinder our city’s recovery efforts and create challenges for middle-class New York families, including many union construction workers and MWBE architects, engineers, and general contractors.

    We strongly recommend that you allow design and construction work to continue to the maximum extent permitted under New York State guidance. Furthermore, we ask that all design and construction that has already occurred be compensated.

    This is a very difficult time for all New Yorkers, and we understand the gravity of the City’s circumstances. We all share a common goal of ensuring that our economy gets back on its feet once the virus passes and we believe construction will take the lead in our city’s recovery.

    Sincerely,

    American Council of Engineering Companies New York
    American Institute of Architects New York
    Building and Construction Trades Council of Greater New York
    Building Trades Employers’ Association of New York City
    New York Building Congress
    New York City Central Labor Council

    CC: New York City Council Speaker Corey Johnson

    March 03, 2020 | National Advocacy
    AIA New York and NY Delegation Letter of Opposition to Classical Architecture Executive Order

    March 3, 2020

    President Donald Trump President
    The White House
    1600 Pennsylvania Avenue North West Washington, DC 20500

    Dear President Trump,

    As members of the U.S. House of Representatives representing the state of New York, we are deeply troubled to learn of a draft executive order titled “Making Federal Buildings Beautiful Again,” which would officially designate “classical” architecture as the preferred style for all federal courthouses, all federal public buildings in the Capital region, and all other federal public buildings whose cost exceeds $50 million. (1)

    We unequivocally oppose this policy to promote one style of architecture for many federal buildings across the country. Restricting many federal buildings to one architectural style disregards the vast artistic diversity and creativity of the American people. The needs and specific characteristics of a community—including its history, regional preferences, topography, weather, and the style of surrounding buildings—may make another architectural style much more appropriate.

    As you know, the American Institute of Architects (AIA)—a national association of architects and designers with nearly 10,000 members in the State of New York—recently wrote to you opposing the proposed executive order. (2) We share AIA’s concern that the order will establish an overly bureaucratic process that could eliminate alternate design options that reflect the preferences of local communities. We agree that our federal buildings should be designed with input of, by, and for the people that they directly serve, not political appointees.

    We strongly support the mission of the General Services Administration’s Design Excellence Program, which encourages the propagation of different architectural styles with local design preferences and different regional cultural histories. The program also emphasizes the importance of sustainable design, energy efficiency, and the environmental impact of building materials. These are complex issues that often require diverse architectural solutions.

    This order also contradicts the federal government’s own “Guiding Principles for Federal Architecture,” written in 1962 by the late New York Senator Daniel Patrick Moynihan. In this document, Senator Moynihan wrote, “The development of an official style must be avoided. Design must flow from the architectural profession to the government, and not vice versa.”(3) Straying from these long-standing principles with tat the top-down approach designated by this order will set a dangerous precedent for future Administrations.

    Therefore, we believe you should reject this draft executive order and not pursue any policy change that would replace local input within the design process with a predetermined national mandate.

     

    1) Rogers, Katie, and Robin Pogrebin. “Draft Executive Order Would Give Trump a New Target: Modern Design.” The New York Times. The New York Times, February 5, 2020. https://www.nytimes.com/2020/02/05/arts/design/trump-modern-architecture.html.

    2) “AIA Issues Letter to President Trump Opposing Proposed Executive Order.” The American Institute of Architects. Accessed February 19, 2020. https://www.aia.org/press-releases/6264391-aia-issues-letter-to-president-trump-oppos.

    3) “Guiding Principles for Federal Architecture.” GSA, August 13, 2017. https://www.gsa.gov/real-estate/design­ construction/design-excellence/design-excellence-program/guiding-principles-for-federal-architecture.

    February 06, 2020 | National Advocacy
    AIANY Letter on Draft Executive Order on Classical Architecture

    President Donald Trump
    White House
    1600 Pennsylvania Avenue North West
    Washington, DC 20500

    Mr. President:

    We are writing on behalf of the American Institute of Architects New York, a nearly 6,000 member association of architects and designers based in New York City. We are deeply troubled to learn that a draft executive order is circulating among White House staff that, if signed by you, would officially designate “classical” architecture as the preferred style of all federal courthouses, all federal public buildings in the Capital region, and all other federal public buildings whose cost exceeds $50 million.

    We strongly and unequivocally oppose this policy to promote any one style of architecture for federal buildings across the country. Classical architecture has tremendous value, but so do other architectural styles. Depending on the needs of the community—including regional preferences, topography, weather, the style of surrounding buildings, the history of the community—a different approach may be much more appropriate. The topdown approach designated by this order will effectively cut local community voices out of the design process.

    Other considerations for the design approach proposed by an architectural team include cost of materials and constructability, the environmental impact of building materials, requirements for implementation of modern building systems, and long-term efficiencies of building operations. These complex issues require diverse architectural solutions.

    We agree our federal buildings should evoke respect; but that respect comes from the power of our system of self-government. Federal buildings should incorporate local design preferences and different regional cultural histories. Ultimately, the architecture should be designed with input of, by, and for the people whom it directly serves. Historically, the imposition of a single architectural style has set a dangerous precedent, representing an assault on a free and open society.

    We urge you to reject this draft executive order and not pursue any policy change that would replace local input within the design process with a predetermined national directive.

    Sincerely,
    Kim Yao, AIA
    2020 President, American Institute of Architects New York Chapter

    January 30, 2020 | 80x50 Initiative
    Statement of Support for Int. 1816-2019, NYC Energy Conservation Code

    AIA New York in consultation with advisors on its Committee on the Environment offers its support for Intro No 1816, which would make NYC’s Energy Conservation Code one of the most advanced building energy codes in the country and would make a major contribution toward advancing the goals of energy efficiency and carbon reduction that the city has set for 2030 and beyond. While the new Code takes significant steps to reduce energy consumption and hence emissions, it is not stringent enough on its own to meet the 80×50 goal and the targets set by Local Law 97.

    There are many improvements to lighting and mechanical systems that can improve a building’s energy performance and the updated regulations do address these to some extent, but as architects we have a particular awareness of the impact a building’s envelope can have on energy efficiency, and occupant health and comfort. High performance glazing, more effective insulation, and airtight construction should be the standard for all of our buildings, not just the exceptional few.

    The new code does take steps toward envelope improvement, but there is still a long way to go. The argument is often made that setting standards for glazing, insulation, and airtightness will result in significantly higher construction costs and will have negative impacts on real estate values. But in fact, the opposite is true: high performing envelopes lead to lower upfront mechanical costs, increased leasable area, higher productivity from occupants, lifetime energy savings, and increased resilience.

    While we think that this legislation is undeniably a step in the right direction and will help architects design better, more energy-efficient buildings, and we are unanimous in our opinion that adoption of the new code is far preferable to the alternative, our enthusiasm for the progress it offers is tempered by the knowledge that it simply does not go far enough to respond to the current climate emergency.

    October 10, 2019 | 80x50 Initiative
    AIA New York Arthur Kill Terminal Support Letter

    October 4, 2019

    The Honorable Andrew M. Cuomo
    Governor of New York State
    NYS State Capitol Building Albany, NY 12224

    Dear Governor Cuomo:

    We are writing on behalf of the American Institute of Architects New York (AIANY) to express our support for the Arthur Kill Terminal project being developed by Atlantic Offshore Terminals in Staten Island, New York. AIANY and its nearly 6,000 members have proudly maintained a long-standing commitment to sustainability in architecture, seeing it as a vital component to the modern industry’s approach to design and construction.

    New York is on the precipice of change. The enactment of the Climate Leadership and Community Protection Act and the state’s commitment to 9,000 megawatts of offshore wind by 2035, as well as the awarding of 1,700 megawatts—the nation’s largest procurement of offshore wind—signaled to the rest of the country that New York leads the nation in clean energy. The State is primed to become the supply chain hub for the multi-billion-dollar offshore wind industry. Therefore, the State must support the design and construction of port infrastructure to spur the development of offshore wind.

    The Arthur Kill Terminal is uniquely positioned to handle the challenges of developing the offshore wind industry. Due to vessel access constraints, such as bridges and other barriers, most existing U.S. ports are unsuitable for wind turbine staging. Located on Staten Island’s Charleston neighborhood, the Arthur Kill Terminal is able to bypass these constraints with its completely unrestricted access to the Atlantic Ocean and facilitate offshore wind projects across the coast. As it stands today, the Arthur Kill Terminal is the only port in New York where offshore wind turbines can be staged and assembled onshore and brought out to sea.

    AIANY is committed to fostering sustainable design and construction. We are pleased to express our support for the Arthur Kill Terminal project and look forward to working with you in advancing the development of offshore wind in New York.

    Sincerely,

    Benjamin Prosky, Assoc. AIA
    Executive Director

    Hayes Slade, AIA
    2019 President

    September 05, 2019
    AIA New York Supports Int. 1482, Bird-Friendly Glass Bill

    AIA New York (AIANY), the professional association representing nearly 6,000 of New York City’s architects and related professionals, is expressing its support for Int. 1482. This bill would require bird-friendly glass be used in new construction for ninety percent of glass 75 feet and below.

    Buildings in New York City kill 90,000 to 200,000 birds each year. Many of these deaths could be easily preventable through the use of fritted glass, screens, and other design solutions. These materials and techniques have other benefits related to sustainability, as they keep sunlight out, making buildings cooler.

    Bird-friendly design is already widespread in the industry. The American Bird Conservancy’s Threat Factor rating is an existing reference standard used by design professionals to evaluate the dangers materials and techniques pose to birds. Furthermore, LEED provides a pilot credit for bird collision deterrence.

    While AIANY supports Int. 1482, one shortcoming of the current version is that it only applies to new construction. With LL97 of 2019 mandating retrofitting in many large buildings to stay under carbon emission limits, the City has a rare opportunity to ensure that bird friendly glass is installed en masse. Therefore, it is important that buildings that are undergoing retrofits also be required to comply with the bill’s provisions.

    Bird collisions are a fixable problem, requiring the implementation of materials and techniques that some architects already utilize. Action by the City Council would significantly decrease bird deaths from collisions. Therefore, AIANY calls on the City Council to pass Int. 1482 and the Mayor to sign it into law.

    July 22, 2019
    AIA New York Opposition to Contractor Monitoring Software Bill

    AIANY is expressing its strong opposition to Int. 1602, a New York City Council bill which would push the City to use software to monitor City contractors. Contractor monitoring software tracks computer usage of individual employees of government contractors, such as architecture firms. A private corporation, which develops and monitors the software, would have access to information on the computer usage of individual architects at any firm doing business with the City; this would include the ability to take screenshots of contract workers’ computers, as well as logging keystrokes and mouse movements.

    It is unknown what this information could and would be used for, and how safe it is from hacking threats. Furthermore, it is impossible to quantify the quality of design based on computer usage, as much design work takes place away from computers. Evaluating the quality of design work based on computer usage is a poor practice that no client, including the City, should follow.

    Throughout the country, a single company that produces contractor monitoring software has been paying lobbyists to introduce similar pieces of legislation. During the recently concluded 2019 session of the New York State Legislature, a similar piece of legislation, S5398, was defeated. Fortunately, legislation enabling the monitoring software’s use has not passed in any state or municipality.

    In order to protect privacy of its members, and ensure a fair evaluation of their work, AIANY strongly opposes Int. 1602. AIANY calls on the City Council and Mayor de Blasio to prevent this dangerous bill from becoming law.

    Sincerely,

    Benjamin Prosky, Assoc. AIA
    Executive Director

    Hayes Slade, AIA
    2019 President

    March 14, 2019
    AIA New York Statement on Final Inspections

    In August 2018, the NYC Department of Buildings (DOB) issued Bulletin 2018-008, which required that an architect or engineer perform final inspections for significant amounts of work, a service formerly performed by DOB inspectors. AIA New York has given the repercussions of this bulletin time to be felt, and our initial fears about it seem justified.

    The privatization of building inspections and other duties of DOB represents a threat to public safety. Lapses in judgement or bad decisions can occur in design as in any other field. Limiting inspections by DOB, even in work that does not affect egress or occupancy, can put members of the public in serious physical danger. Final inspections provide another set of eyes to examine work. Without these, some mistakes may not be caught, threatening the safety of building users.

    Removing the option of having final inspections performed by DOB inspectors is also an equity issue. Final inspections protect rent-regulated tenants from abuses by owners, especially in cases where work is self-certified. Furthermore, the firms most heavily affected by this bulletin tend to be smaller firms who can face pressure from owners to both act as the architect of record and perform the final inspection on the same work. This creates a liability concern, falling hardest on those firms who can least afford these risks.

    The Directive 14 of 1975 (D14) program, which this bulletin would make mandatory for a significant amount of work, was instituted at a very different time for New York City. In 1975, the City was on the brink of bankruptcy, forcing essential services like building inspections to be cut. Today, the City is in far better financial shape. When essential services are cut, the most vulnerable, such as rent-regulated tenants, are more likely to suffer.

    We hope that the new DOB Commissioner, whoever that may be, will rescind the bulletin. AIANY understands the budgetary concerns within DOB, and the desire to expedite processes. However, when privatization sacrifices safety and equity, we will oppose it.

    Sincerely,
    Benjamin Prosky, Assoc. AIA
    Executive Director

    Hayes Slade, AIA
    2019 President

    March 14, 2019
    AIA New York Statement on Void and Ceiling Heights

    The New York City Zoning Code establishes various development controls, including floor area ratios (FAR), to ensure development goals such as equitable access to sunlight and air for occupants and pedestrians alike.

    There have been some instances recently where luxury residential buildings have skirted regulations around zoning. These buildings include unusually large mechanical voids, which do not count towards FAR. This allows buildings to be taller than normally permissible in order to enhance views, while making the lower floors devoid of life, creating an unwelcome feeling for pedestrians. The NYC Department of City Planning’s (DCP) proposal to limit mechanical void height for residential buildings to 25 feet, with 75 feet separating voids, is an attempt to address this issue.

    AIA New York believes the height limit should be 25 feet to 35 feet clear of structure, which is within range of DCP’s proposal. In the rare cases where a building’s mechanical systems require more than the allotted height, designers and developers would maintain the ability to do so, though this would count towards FAR. AIANY has long been an advocate for quality design that contributes positively to communities and promotes equitable access to the city’s multiple and diverse assets, including light, air, and a welcoming public realm.

    However, AIANY is against prescriptive limits on residential building ceiling height. Bills such as New York State’s A5026/S3820, which would count any residential building floor with ceiling height above 12 feet twice towards FAR, represent overreactions to the abuse of mechanical voids. This would affect all floors, whether their predominant use is as a mechanical space, a lobby, residences, or amenity space.

    Furthermore, prescriptive limits on ceiling height would cause new construction to become far more monotonous, creating fewer opportunities for differentiation and variety, qualities that distinguish great cities. Neighborhoods with significant amounts of new construction, which are often less well off, would be impacted most.

    AIANY will continue to advocate for good design for all New Yorkers. Buyers able to afford units above the ground plane do not have a right to purchase their home-with-a-view at the expense of the streetscape. At the same time, the State does not have the right to subject poorer areas of the city to endless rows of identical apartment buildings that could result from city-wide ceiling-height mandates. We need action by the City and State that is in line with good design, and good city planning practices to alleviate these problems.

    Sincerely,
    Benjamin Prosky, Assoc. AIA
    Executive Director

    Hayes Slade, AIA
    2019 President

    February 27, 2019
    AIA New York Responds to MTA Fee Reduction

    Dear AIA members,

    AIA New York wants to bring to your attention a newly announced MTA cost reduction program. Vendors providing professional, technical, and advisory services will be required to implement a 10% reduction in the current per-hour unit rate, effective March 31, 2019. It should also be noted that the MTA already has limits in place for the fee portion of markups. The MTA requests email confirmation by March 8, 2019, and no response will be interpreted as commitment to comply.

    AIA New York is working with ACEC, New York Building Congress, and other stakeholder organizations to find out more information and determine how we can jointly advocate for our members. As this initiative was implemented without prior notice, we are still in the process of gathering more details. We would like to note that AIA New York is not legally allowed to negotiate over specific amounts of compensation.

    If you are affected or concerned, please email Adam Roberts, Director of Policy, at aroberts@aiany.org.

    You can find a link to the letter that the MTA has been distributing here. We will be reaching out soon with updates and potential courses of action.

    Sincerely,

    Benjamin Prosky, Assoc. AIA
    Executive Director, AIA New York

    Hayes Slade, AIA
    2019 President, AIA New York

    February 19, 2019
    AIA New York Workplace Harassment Testimony

    February 13, 2019

    Thank you to Governor Cuomo, Speaker Heastie, and Majority Leader Stewart-Cousins for supporting these hearings today, and to Senators Biaggi, Skoufis, and Salazar, and Assembly Members Crespo, Walker, and Titus for chairing them.

    Workplace harassment has long been a significant problem in the construction industry, including in architecture. AIA New York, the professional organization representing nearly 6,000 architects working and living in Manhattan, has worked hard to limit workplace harassment in the profession.

    Last year, following multiple accusations of workplace harassment in our industry, we publicly retracted prestigious design awards from notable architects. We also supported an effort to amend our national organization’s code of ethics to more explicitly address sexual harassment. This helped instigate a conversation in New York’s architecture community about the need for better and safer working conditions. Condemning harassers can be a powerful tool, but it alone is not enough to curb workplace harassment.

    Further action by our state government is needed not only to punish harassers, but also to protect victims. As a professional association, there is limited action we can take to legally protect our members from workplace harassment. It is the duty of New York State’s government to protect its residents. New York State’s laws around protecting victims are flawed and need to be improved. We support efforts that make it easier for a victim to take legal action against an employer committing or enabling harassment.

    AIA New York will continue to do its part to fight workplace harassment however we can. Nevertheless, our members need help from Albany to fully protect them. We again thank all the elected officials supporting these hearings and hope that impactful legislative solutions will result from them.

    Sincerely,
    Benjamin Prosky, Assoc. AIA
    Executive Director

    Hayes Slade, AIA
    2019 President

    December 05, 2018 | 80x50 Initiative
    Statement of Support for Retrofitting Legislation

    AIA New York strongly advocates for a more sustainable and equitable built environment. Through programming and by supporting various pieces of legislation, we have encouraged our 5,600 members to design in a more environmentally conscious manner.

    Despite advances in sustainable design over the years, far more can be done to make our cities green. Crucially, we need to support efforts to retrofit existing buildings. While sustainable design for new buildings is increasingly widespread, far more New Yorkers live and work in older buildings, most of which have not been retrofitted according to the latest technologies and design practices.

    If we do not retrofit our existing building stock en masse, we jeopardize the health and safety of ourselves and future generations. Right now, around 70% of New York’s carbon emissions are generated by buildings. In order to tackle issues around climate change, resiliency, and air quality, we need to retrofit our existing building stock.

    Furthermore, continuing to overlook the retrofitting of existing structures may lead to greater inequity in our built environment. It should not be a luxury to live or work in a well-insulated building, though in New York City this is often the case. Those with sustainably designed apartments and offices often pay less in energy bills, which further exacerbates financial divides. If we do not address this issue now, our city will increasingly be divided between those who can afford to live and work with all the benefits of sustainable design, and the less fortunate who live and work in deteriorating buildings.

    For these reasons, we applaud Council Member Costa Constantinides’ pieces of legislation, Int. 1252 and Int. 1253, which require existing buildings over 25,000 square feet to meet energy efficiency targets. For years, market forces and government incentives have led to slow but steady increases in retrofitting. Unfortunately, we do not have time for a process that does not require immediate improvements. We need the City to require that the bulk of our large building stock start retrofitting as soon as possible.

    These pieces of legislation have the potential to significantly improve the daily lives of millions of New Yorkers, while also spurring the growth of the green sector. New Yorkers deserve to live and work in better conditions, and for that reason we ask the City Council to pass, and the Mayor sign, Int. 1252 and Int. 1253.

    Sincerely,

    Gerard F. X. Geier II, FAIA, FIIDA, LEED AP
    President

    Benjamin Prosky, Assoc. AIA
    Executive Director

    October 30, 2018
    AIA New York Charter Ballot Proposal Statement

    AIA New York Urges “Yes” Vote for the 2018 Charter Ballot Proposals

    Earlier this year, Mayor de Blasio organized a Charter Revision Commission to examine potential changes to the New York City Charter. Much like the constitution, the Charter is the guiding document of New York City’s government. The Charter Revision Commission has released three recommendations, which will appear on the ballot on Tuesday, November 6. Voters will have the opportunity to vote “Yes” or “No” on these ballot proposals.

    The proposals are summed up as follows:

    1. Campaign Finance: Should contribution limits be lowered, and public matching funds be increased?
    2. Civic Engagement Commission: Should a Civic Engagement Commission be created to establish a citywide participatory budgeting program and support civic engagement efforts?
    3. Community Boards: Should term limits be imposed for community board members, should there be new application and reporting requirements for applicants, and should land use professionals be provided to assist community boards?

    You may read the full ballot proposal questions here. While the first proposal is not directly related to the practice of architecture, the latter two are very much connected with the profession.

    The Civic Engagement Commission would oversee a citywide participatory budgeting program, which would increase public involvement in, and commitment to, crucial capital projects for public buildings. Meanwhile, the commission’s work to provide land use professionals to community boards and further general civic engagement efforts would be very beneficial.

    Regarding the third proposal, opportunities for architects to serve on their community boards are often stifled by a lack of turnover among current board members. This prevents community boards from having access to members who understand land use policies. Not only could term limits help solve this issue, but the ballot proposal would go further by requiring that community boards have access to land use professionals who are employed by the city, if the Civic Engagement Commission is established.

    AIANY encourages its members to vote on Tuesday, November 6, and recommends that they vote “Yes” for Ballot Proposal #2 in favor of establishing the Civic Engagement Commission, and “Yes” for Ballot Proposal #3 in favor of Community Board term limits and access to land use professionals.

    As part of AIANY’s 2018 Presidential Theme, “Architect Activist,” we have encouraged our members to become more engaged in public service. We are fortunate that this year, there will be two ballot proposals which can increase the involvement of architects in New York City’s government.

    October 15, 2018
    AIA New York Statement on Immigration Detention Facilities

    AIA New York Statement on Immigration Detention Facilities

    October 11, 2018

    The dignity of people and recognition of human needs must be foremost in every detention facility plan and design. We advocate for the following functional and design principles in any detention project, irrespective of legal status:

    Normative Environment – The detention setting should provide a safe and secure environment, access to daylight and fresh outdoor air, comfortable furniture, and a healthy atmosphere. Design should allow for positive social opportunities between people, without compromising the safety and security of detainees or their custodians. Specific design elements must consider the human occupants, favoring glazing over bars, using modesty panels where appropriate, and providing activities space to reduce idleness.

    Access to Support – Detainees are often confined without access to support from their friends, families, and social service providers, which will inevitably impact their emotional and financial condition. The planning and design of a detention facility must provide space and accommodate access to a support network that facilitates communication and interaction between detainees and those who are able to help them. Facilities must also provide space for medical care, including mental health support, which is critical where both mind and body are at risk due to the often-stressful experiences surrounding detention.

    Access to Justice – Location and design of a detention facility play key roles in access to justice. Every detention facility should provide adequate space for legal counsel to consult with detainees, and facilities should be located at sites with convenient access to counsel and courts of law. The infrastructure of a detention facility should support access to legal research material to help detainees better understand their legal standing and advocate for themselves. The planning and design of a facility should work in favor of the rights of a person to access justice.

    Design alone is not capable of solving our immigration crisis; however, poor design can be an element of the problem. AIA New York stands strongly on behalf of the wellbeing of those inside these facilities, and in favor of design solutions that benefit them and their families.

    October 15, 2018
    AIA New York Statement on the Borough Correctional Facilities

    AIA New York Statement on the Borough Correctional Facilities

    October 11, 2018

    The proposed borough correctional facilities that are to replace Rikers Island are incredibly sensitive projects, where considerations regarding work quality, neighborhood integration, and safety must be primary concerns. Rikers Island is widely considered to be flawed in its design; it is essential that the new facilities not repeat past mistakes.

    When New York City was given design-build (D-B) authority by the State for the construction of the new borough correctional facilities, it brought up many questions about the benefits of using design-build for jail construction.

    AIA New York recommends that the City follow these best practices when using design-build authority to construct the borough correctional facilities:

    • The architect should report directly to the client. This will prevent design decisions about safety or quality of life from being overlooked due to cost or time savings.
    • To ensure quality, use a two-step process to select the D-B team: request for qualifications (RFQ) followed by request for proposals (RFP) from shortlisted firms. Contractors and design professionals should have experience in design-build or jail design/construction, or ideally both. Stipends should be provided to incentivize firms to respond to the RFQ.
    • Hire a “criteria architect” to work with stakeholders to help determine programming. The criteria architect should be separate from the D-B team, hired directly by the City, and should remain throughout the entirety of the project. A major part of this role is to build trust with the community and local officials, ensuring that they are included in discussions about architectural programming.
    • The City needs to minimize delays at all costs, as the entire D-B team is working on the same schedule. To stay on schedule, the City should employ an attorney with significant D-B experience to handle contracts and approvals.
    • A manual on D-B should be available for reference so the D-B team understands the parameters and expectations of D-B work in New York City, including the role of the community in the projects.

    This unique opportunity to physically redesign our correctional system offers a chance to solve the design problems seen in Rikers Island. To provide the maximum benefit to community members, detainees, and city workers, it is imperative that the City follow the aforementioned best practices.

    Sincerely,
    Gerard F. X. Geier II, FAIA, FIIDA, LEED AP
    President

    Benjamin Prosky, Assoc. AIA
    Executive Director

    July 16, 2018 | National Advocacy
    Response of AIA New York’s President and Executive Director to the Janus Decision

    Response of AIA New York’s President and Executive Director to the Janus Decision

     

    Recently, the US Supreme Court ruled in Janus v. AFSCME that nonunion workers cannot be forced to pay fees to public sector unions representing them in collective bargaining. There is reason to believe that this will deplete the power and protections that unions afford public sector workers.

    The results of this ruling are of deep concern to AIA New York. We are proud to represent a diverse range of architects and allied professionals, including many who work for the government at the federal, state, and local levels.

    We recognize the potential threats of this ruling to the livelihood of our public sector members. While the US Department of Justice does not allow us to advocate for architects’ wages or fees, we are permitted to advocate on their behalf with regards to issues affecting the livelihood of our members.

    Many of the issues most paramount to our public sector members are among our highest priorities. Increased mass transit funding, safer and better designed correctional facilities, and more sustainably designed City-owned office buildings are just some of the issues for which AIANY is currently advocating.

    AIANY has and will continue to be in communication with public sector unions to ensure that the voices and interests of architects remain strongly represented within federal, state, and city agencies.

    If you have any questions about the advocacy work AIANY is doing on your behalf, please reach out to Adam Roberts, Government Affairs Coordinator, at 212-358-6116 or aroberts@aiany.org.

     

    Sincerely,

    Gerard F. X. Geier II, FAIA, FIIDA, LEED AP
    President

    Benjamin Prosky, Assoc. AIA
    Executive Director

     

    June 18, 2018
    Statement in Support of New York City Transit's Fast Forward Plan

    New York City Transit’s Fast Forward Plan

    Why is this Important?

    AIA New York (AIANY) is a professional organization representing over 5,500 architects dedicated to the quality of life of New York City’s residents, workers, and visitors. Recognizing the importance of access to high-quality, reliable, efficient and equitable mobility for all users, we support the region’s public transit systems as necessary to the vitality of the City and region. The goals of New York City Transit’s (NYCT) recently released Fast Forward Plan align with the guiding principles of AIANY’s Transportation + Infrastructure Policy Framework issued in 2017 which addresses the issues of mobility, placemaking, sustainability, building better and funding/financing.

    Background of Subway Action Plan (2017)
    In June 2017, Governor Cuomo declared a state of emergency for New York City’s subway system, citing a debilitating increase in train and equipment breakdowns and resultant service. This follows a decade-long fall in bus ridership, a two-year decline in subway ridership, and a 14% loss in overall MTA ridership since 2007. In response to the Governor’s declaration, the MTA created the NYC Subway Action Plan, outlining a strategy for immediate repairs due to disinvestment and deferred maintenance. $836M in emergency funding was allocated for short-term repairs, shared by the State and City.
    While the emergency stabilization plan did produce incremental improvements in the past year, it did not directly address long-term needs, including the modernization of the outdated signal system, replacement of obsolete subway rolling stock, lack of universal access to most subway stations, lags in communications and fare technologies, normal maintenance and repair, and endemic cost and schedule overruns on capital projects.

    Fast Forward Plan (2018)
    In May 2018, Andy Byford, the new President of NYCT, addressed these long-term needs with the Fast Forward Plan, which outlines improvements to the NYCT bus and subway systems over 10 years. The plan aims to:
    • Accelerate the replacement of signal system on 11 subway lines
    • Provide universal accessibility at an additional 180 subway stations
    • Make state-of-good-repair improvements at 300 subway stations
    • Implement a new fare payment system
    • Purchase 6,500 new subway cars
    • Purchase 4,900 new buses
    • Redesign all bus routes in the City

    To meet this ambitious timeframe, more frequent weekend and evening service disruptions will be required. Coupled with management and service improvements as well as efficiencies in procurement, this proposal has the potential to renew the City and region’s transit systems in the decades to come.

    AIANY supports the strategy to prioritize state-of-good-repairs, modernization and equal access as the first and best investments in public transit. To this end, we call on the public and businesses impacted by public transportation, government agencies responsible for the maintenance and operation of the networks, and government bodies tasked with securing the necessary capital funding to cooperate in implementing the plan within the 10-year timeframe.

    We commend the MTA on its willingness to engage in a forthright analysis of its needs and look forward to the release of further details on the costs, schedule, and funding mechanisms required to achieve this bold plan.

    May 24, 2018
    Statement on the Expansion of the Frick Collection by Selldorf Architects

    Dear Chair Srinivasan, Commissioners,

    The American Institute of Architects New York Chapter (AIANY) is expressing its support for the proposed expansion of the Frick Collection by Selldorf Architects.

    AIANY advocates for more access to architecture, particularly those great buildings that have been designated by the Landmarks Preservation Commission. The proposed expansion to the Frick Collection would allow for the public to gain access to the beautifully designed upstairs rooms in the original structure of the Frick House, while only slightly changing the original exterior by Carrère and Hastings.

    We find it important to note how well the proposal actually maintains the Beaux-Arts exterior. The addition draws inspiration from the style with the use of bronze, a material frequently associated with Beaux-Arts architecture. Yet, the bronze also distinguishes the addition from the original masonry exterior, clearly delineating which aspects of the exterior are part of the original design.

    Furthermore, the massing of the expansion does not overshadow the grandiosity of the original design, nor does it appear out of place with the historic apartment buildings and townhomes nearby. Open spaces, such as the famed Russell Page garden, are also untouched.

    The proposed expansion of the Frick Collection by Selldorf Architects manages to give the public greater access to historic interiors, without compromising the landmarked exterior. For this reason, AIANY strongly urges the Landmarks Preservation Commission to grant approval for this proposed expansion.

    March 29, 2018
    AIA New York Expresses Concerns Regarding Proposed Demolition of 270 Park Avenue

    March 29, 2018

    The American Institute of Architects, New York Chapter (AIANY) is expressing concerns regarding the proposed demolition of 270 Park Avenue, formerly known as the Union Carbide Building. Designed in 1961 by Skidmore, Owings & Merrill, the building is a notable example of the International Style.

    AIANY appreciates the level of discussion and awareness that has been brought to International Style buildings and Modern architecture’s heritage as a result of recent news regarding 270 Park Avenue. The International Style has become widely representative of the modern office building.

    AIANY’s chief concern is the precedent this may set for sustainable design in New York. Currently, buildings are responsible for 70% of carbon emissions in New York City. The Union Carbide building was recently retrofitted in 2012, achieving LEED Platinum status, the highest possible rating. Without a better understanding of how it will be dismantled and what is going to replace it, demolishing such a recently renovated green building, particularly one as prominent as 270 Park Avenue, implies that sustainable design is a low priority.

    Furthermore, if demolished, 270 Park Avenue would be the tallest building ever purposely razed. Demolition and construction are particularly energy intensive activities. As mentioned in AIANY’s recently-released Zero Waste Design Guidelines, construction and demolition waste account for 25-45% of the solid waste stream by weight nationwide. Construction and demolition waste is also often contaminated – with paint, adhesives, and fasteners. Demolition of 270 Park Avenue would represent a shift away from the values of sustainability and responsibility in building design, which are championed by architects in New York and beyond.

    AIANY asks that JPMorgan Chase and our elected officials find a way to address these pressing concerns. We hope there will be studies to investigate adaptive reuse approaches, which may retain or work with the existing structure, in order to minimize the environmental impact of demolition. As architects, we strongly believe in new and innovative design, but also recognize the value of historically influential architecture and champion sustainability. The Chapter hopes to be a resource to JP Morgan Chase and our elected officials, as we strive for the common goal of keeping New York vibrant and economically competitive.

    March 23, 2018
    AIA New York Project Policy Statement - Amtrak Gateway Program and Infrastructure Plan

    The economic vitality and quality of life for the regions served by Amtrak’s Northeast Corridor route between Washington, D.C and Boston depend on a robust transportation system. Hundreds of thousands of riders on NJ Transit and Amtrak pass through the rail tunnels under the Hudson River each day. The Gateway Program would construct much needed additional rail tunnels to supplement the currently existing ones, which are overcapacity and damaged from Hurricane Sandy. President Trump’s resistance to providing federal funding for Gateway represents a serious threat to the future of the project. Without Gateway, it is impossible to repair the existing tunnels without dramatically reducing capacity.

    Moreover, the Trump Administration’s infrastructure plan has signaled its intent to reduce federal investment in all infrastructure projects. The President’s infrastructure plan would provide only $200 billion in federal grants over 10 years to fund up to only 20% of approved project costs.

    The success of our nation’s cities and towns are dependent upon their access to transportation. For too long, our federal, state, and local governments have not invested in infrastructure. As cities and towns with good transit options have witnessed remarkable construction booms, those with worse infrastructure have remained stagnant.

    Withdrawing or minimizing funding for Gateway represents a threat to the continued vitality of one of our nation’s most dynamic regions, the Northeast. Meanwhile, a federal withdrawal from infrastructure spending would further punish those regions most in need of substantial investments to spur development.

    Recognizing the importance of robust transportation networks to the growth and vitality of the City, region, and nation, AIANY strongly supports Amtrak’s Gateway Program and the continuation of the Federal Government’s role in significantly funding infrastructure projects.

    AIANY supports the following as necessary actions by program sponsors and government bodies at all levels to realize Amtrak’s Gateway Program:

    • Maintain the Federal Government’s role as a substantive partner with local and state governments to build and maintain infrastructure critical to the nation’s economic vitality. Continue federal TIGER, Fast Track and New Starts programs with adequate funding for qualified public transportation projects across the country.
    • Break out the Gateway Program components into discrete projects that can be funded, designed and constructed separately. Prioritize early completion of the most critical elements of the program. Identify alternative funding sources for later components of the program by capitalizing on momentum from completing earlier portions.
    • Create new revenue sources at the state and local levels to supplement funding from the federal level and require that all project partners can meet their funding commitments. These can include new user fees, updated fuel taxes or vehicle miles traveled (VMT) fees indexed to inflation, new dedicated taxes for critical transportation projects, congestion pricing, and implementation of value recapture strategies.

    The economic vitality of our country is inextricably tied to robust national and regional mass transit networks. Providing substantial federal support for Gateway and other infrastructure projects is in the regional and national interest. As architects, we strive to improve the way people experience the built environment, which can only be done by improving our nation’s infrastructure.

    October 25, 2017
    Transportation + Infrastuture Policy Framework

    AIANY Transportation and Infrastructure Committee Policy Framework developed to support the goal of sustainable growth for the New York City Region.

    October 24, 2017
    2017 Mayoral Campaign Green Building Roadmap

    Policy roadmap for local candidates to maintain New York City’s national leadership on climate change by upgrading its buildings, training its workforce and streamlining energy efficiency. Developed by AIANY, Urban Green Council, REBNY & 32BJ SEIU.

    June 27, 2017
    Testimony Before the New York City Council Committee on Environmental Protection

    Testimony before the New York City Council Committee on Environmental Protection on a series of energy-related: Intro 1629; Intro 1637; Intro 1644; Intro 1651.

    Testimony Before the NYC Council Committee on Housing and Buildings

    Testimony before the New York City Council Committee on Housing and Buildings on Intro 1307-A, a bill to amend the City Charter in relation to the minimum qualifications for Department of Building inspectors.

    June 05, 2017 | National Advocacy
    AIA New York President Letter: Paris Climate Accord

    AIA New York opposes the administration’s decision to withdraw the United States from the Paris Agreement.

    January 31, 2017 | Zero Waste Design Guidelines
    Testimony Before the NYC Council Committee on Sanitation and Solid Waste Management

    On 1.31.17, AIANY testified before the NYC Council Committee on Sanitation and Solid Waste Management in favor of Intro 201, a bill to require recycling of discarded carpet from commercial buildings.

    January 05, 2017 | National Advocacy
    AIA New York Position Statement: Education

    The public school system is the hallmark of our democracy and public education is an inalienable right of our citizens. Public schools should provide all students with the quality learning environments and education the deserve.

    January 05, 2017 | 80x50 Initiative
    AIA New York Position Statement: Sustainability and the Environment

    In 2014, U.S. greenhouse gas (GHG) emissions totaled 6,870 million metric tons of carbon dioxide equivalents, a per capita total of 17 metric tons for each resident of the United States.

    January 05, 2017 | National Advocacy
    AIA New York Position Statement: Transportation and Infrastructure

    The transportation infrastructure of New York City and the surrounding tristate area directly impacts the welfare and livelihood of its over 20 million residents and those of hundreds of millions of visitors and travelers each year.

    January 05, 2017 | National Advocacy
    AIA New York Position Statement: Housing

    Section 8, created by the Housing and Community Development Act of 1978, provides rental subsidiaries to approximately 4.8 million low-income households nationwide.

    January 05, 2017 | National Advocacy
    AIA New York Position Statement: Historic Preservation

    For more than thirty-five years, the federal Historic Tax Credit (HTC) has successfully facilitated a national policy of connecting the insistent evolvement of our present with the accomplishments of our past by preserving our historic resources.

    January 05, 2017 | Aging in Place Guidelines
    AIA New York Position Statement: Design for Aging
    The world population of people over the age of 65 is increasing. By 2020, it is estimated that people aged 65 and older will outnumber children under the age of five for the first time in human history; by 2050, over 15% of the world’s population will be 65 or older, topping out at 1.5 billion people.
    November 15, 2016 | National Advocacy
    AIANY Board of Directors Letter to Membership Regarding the 2016 Election

    The statement made post-election by AIA National of behalf of you, the largest chapter within its network of 89,000 members, pledged your support to an administration that many strongly denounce.

    October 11, 2016
    Testimony Before the NYC Landmarks Preservation Commission on the Richard Gilder Center

    On 10.11.16, AIANY testified in favor of the Richard Gilder Center for Science, Education, and Innovation at the American Museum of Natural History, designed by Studio Gang architects.

    September 20, 2016
    Testimony Before the New York City Council Committee on Cultural Affairs, Libraries and International Intergroup Relations on the Public Design Commission

    AIANY testified before the New York City Council Committee on Cultural Affairs, Libraries and International Intergroup Relations on the Public Design Commission. The Oversight Hearing introduced a bill (No. 1276-A) that would require the PDC to submit an annual report.

    June 22, 2016 | 80x50 Initiative
    Testimony Before the New York City Council Committee on Housing and Buildings on a Series of Energy-related Bills

    AIANY testified before the City Council Committee on Housing and Buildings with Urban Green Council. The hearing addressed: Int. No. 1160, Int. No. 1163, Int. No. 1165, and Int. No. 1169, which would update NYC’s Energy Code.

    May 04, 2016
    Testimony on Water Street Upgrades Text Amendment Before the New York City Council Committee on Zoning and Franchises

    AIANY testified at the City Council hearing on the Water Street Upgrades Text Amendment on 05.04.16.

    April 25, 2016
    Letter in Support of Water Street Upgrades Text Amendment

    On 04.21.16 AIANY submitted a letter in support of the Water Street Upgrades Text Amendment to the City Planning Commission before the 04.25.16 vote.

    February 10, 2016
    Testimony Before the City Council Committee on Zoning and Franchises on Zoning for Quality and Affordability

    AIANY testified at the City Council hearing on the Department of City Planning’s Zoning for Quality and Affordability proposal on 02.10.16.

    January 29, 2016
    Statement Submitted to the NYS Department of State

    AIANY submitted a statement requesting that the effective date of the State Energy Code be extended to January 1, 2017.

    January 15, 2016
    Statement Submitted to the New York City Council Committee on Environmental Protection on Intro. 478

    AIANY submitted testimony supporting AIANY supports Intro. 478 in its effort to encourage the elimination of fossil fuels and the implementation of photovoltaic systems but suggested that the best approach to achieving this would be to focus on whole building analyses.

    December 16, 2015
    Zoning for Quality and Affordability

    AIANY testified before the City Planning Commission on the Department of City Planning’s Zoning for Quality and Affordability proposal on 12.16.15.

    December 14, 2015 | 80x50 Initiative
    Testimony Before the City Council Committee on Recovery and Resiliency and Committee on Environment Protection on OneNYC

    AIANY submitted testimony at the oversight hearing on the resiliency and sustainability sections of the OneNYC plan.

    November 16, 2015
    Zoning for Quality and Affordability

    On 11.16.15, AIANY testified at the Manhattan Borough President’s public hearing on the Zoning for Quality and Affordability and Mandatory Inclusionary Housing proposal.

    November 12, 2015
    Testimony Before the NYC Landmarks Preservation Commission on the Kaufmann Conference Rooms

    On 11.12.15, AIANY testified in favor of landmarking the Edgar J. Kaufmann Conference Rooms at 809 United Nations Plaza, designed by Alvar Aalto. The hearing was the final hearing dedicated to clearing LPC’s 95-item backlog.

    October 25, 2015
    Response to Hearing on Intro. 775 and Improving the Landmarks Process

    The five chapters of the American Institute of Architects in New York City distributed a memo in response to the hearing on Intro. 775.

    October 21, 2015
    Testimony Before the Landmarks Preservation Commission on the Park Avenue Historic District

    On October 21st, AIANY executive director, Rick Bell, FAIA presented testimony in regard to the proposed the Park Avenue Christian Church Annex site.

    October 20, 2015
    Reissued Statement in Support of Landmarking the IRT Powerhouse

    AIANY originally supported the landmarking of the IRT Powerhouse in 2009. There will be another hearing on the site in November 2015 as part of LPC decalendaring efforts.

    September 30, 2015
    Testimony Before the Landmarks Preservation Commission on the Proposed 140 West 81st Street Project

    On September 30, AIANY Executive Director Rick Bell, FAIA, presented testimony in favor of the proposed 140 West 81st Street project designed by DXA Studio.

    September 25, 2015
    Testimony Before the City Council Committee on Housing and Buildings

    On 09.25.15, AIANY submitted testimony on Intro. 721-A, green building standards for certain capital projects.

    September 22, 2015
    Testimony Submitted to the New York City Council Committee on Environmental Protection

    AIANY submitted testimony for the record on Intro. 609 regarding ground source heat pumps.

    September 21, 2015
    Statement from the Five AIA Chapters of New York City in Support of the NYC Department of City Planning’s Zoning for Quality and Affordability Proposal

    AIANY joined with the other four AIA chapters in NYC to issue a brief statement in support of DCP’s ZQA after it was certified on 09.21.15. A more detailed statement to follow.

    September 09, 2015
    Testimony Before City Council Committee on Land Use on Intro. 775

    On 09.09.15, David Burney, FAIA, AIANY Interim Executive Director, testified on behalf of the five AIA chapters in NYC. Our testimony was in opposition to Intro. 775, which would change processes at the Landmarks Preservation Commission.

    May 05, 2015
    AIANY Testimony before LPC on 28 Liberty Project by SOM

    AIANY testified in favor of SOM’s proposed renovation of 28 Liberty.

    May 01, 2015
    Comments on LPC Decalendaring

    AIANY submitted comments on the NYC Landmarks Preservation Commission effort to address its backlogged calendar

    April 24, 2015
    5 AIA Chapters of NYC Memo on Intro. 775

    All 5 AIA Chapters of NYC came together in response to City Council Intro. 775, which proposes significant changes to Landmarks Preservation Commission. AIANY supports reforms to LPC to increase transparency and efficiency; however, the proposed solutions go too far and threaten NYC’s historic sites.

    April 23, 2015
    AIANY Testimony Before the New York City Council Subcommittee on Zoning and Franchises on One Vanderbilt Avenue

    AIANY submitted a statement for the record in favor of the proposed One Vanderbilt Avenue.

    April 15, 2015 | Aging in Place Guidelines
    AIANY Testimony Before the New York City Council Committee on Aging

    AIANY Design for Aging Committee provided testimony on an Aging in Place Guide.

    March 25, 2015
    Testimony Before City Planning on the Zoning for Quality and Affordability Proposal

    On 03.25.15, AIANY Executive Director Rick Bell, FAIA, submitted testimony at the NYC Department of City Planning public scoping meeting for the Housing New York: Zoning for Quality and Affordability proposal.

    February 27, 2015
    AIANY Testimony Before the New York City Council Committee on Environmental Protection

    This oversight hearing and conference covered on site-sourced and stored renewable energy. AIANY provided testimony on select technologies.

    February 04, 2015
    Testimony Before the City Planning Commission on the proposed Vanderbilt Corridor rezoning and One Vanderbilt project

    On 02.04.15, AIANY Executive Director Rick Bell, FAIA, testified in favor of the NYC Department of City Planning proposal to rezone the Vanderbilt Corridor and the One Vanderbilt project, designed by KPF.

    January 01, 2015
    New York City Construction Codes Effective Date Letter to Commissioner Chandler

    AIANY joined BOMA, BTEA, NYSAFAH, NYBC, and REBNY in writing a letter to NYC Department of Buildings Commissioner Rick Chandler to ask the Department to delay the effective date of the 2014 Construction Codes until three months after Codes have been printed, or January 1, 2015. The additional lead time will only help to ensure compliance and provide relief.

    January 01, 2015
    New York City Construction Codes Effective Date Letter to Speaker Mark-Viverito

    AIANY joined BOMA, BTEA, NYSAFAH, NYBC, and REBNY in writing a letter to NYC Department of Buildings Commissioner Rick Chandler to ask the Department to delay the effective date of the 2014 Construction Codes until three months after Codes have been printed, or January 1, 2015. The additional lead time will only help to ensure compliance and provide relief.

    November 18, 2014
    Testimony Before the Landmarks Preservation Commission on the Proposed 346 Broadway/108 Leonard Project

    AIANY submitted testimony in favor of the proposed 346 Broadway aka 108 Leonard project designed by Beyer Blinder Belle.

    November 03, 2014
    AIANY Testimony Before the New York City Council Committees on Transportation and Economic Development

    AIANY testified at an oversight hearing on Assessing the Economic Impact of New York’s Failing Infrastructure, focusing on Transportation

    October 30, 2014 | Aging in Place Guidelines
    AIANY Testimony Before the New York City Council Committee on Aging

    AIANY testified at an oversight hearing on Age-Friendly NYC Aging Improvement Districts-Successes and Future Challenges

    October 23, 2014
    AIANY Testimony Before the New York City Council Committee on Environmental Protection

    AIANY testified in favor of Int 0378-2014, A Local Law to amend the administrative code of the city of New York, in relation to reducing greenhouse gases by eighty percent by 2050.

    July 22, 2014
    Testimony Before the Landmarks Preservation Commission on the Proposed One Vanderbilt Avenue Project

    On July 22nd, AIANY President Lance Jay Brown, FAIA, and AIANY Executive Director Rick Bell, FAIA, presented testimony in favor of the proposed One Vanderbilt Avenue project designed by Kohn Pedersen Fox.

    AIANY Design for Aging Committee Testimony Before the New York City Council Committee on Aging

    This oversight hearing addressed “How Can the City Expand and Preserve Affordable Housing Options for Seniors?” and Int 0337-2014, a Local Law to create a senior housing task force. AIANY DFA testified in favor of the proposed legislation.

    May 20, 2014
    Letter in Support of a Stand-alone Sustainable Development Goal on Cities

    We wrote to Ambassador Elizabeth M. Cousens in support of the proposed Sustainable Development Goals on cities and human settlements by the Open Working Group on Sustainable Development Goals.

    May 15, 2014
    AIANY Support an MTA Transportation Reinvention Commission

    AIANY wrote to MTA Chairman Prendergast in support of Governor Cuomo’s recommendation that the Metropolitan Transit Authority create a Transportation Reinvention Commission tasked to develop a reinvention plan for the future of the region. AIANY would like to recommend commission members who could lend valuable expertise.

    April 28, 2014
    Testimony Before the New York City Council Committee on Consumer Affairs on Intro 265

    On April 28th, AIANY provided testimony to express serious concerns about Intro 265. AIANY feels that Intro 265 would add an unnecessary layer of bureaucracy to architects’ already highly regulated processes.

    Council Members, Advocates and Business Leaders Call on Mayor To Make Sustainability & Resiliency High Priorities in Next 100 Days

    A broad coalition of City Council members, business leaders and advocates from transportation, environmental and health organizations called on Mayor Bill de Blasio to make sustainability and climate resiliency high priorities for the next 100 days of his administration and beyond.

    April 02, 2014
    Testimony Before the New York City Council Housing and Buildings Committee on T2014-0702 and T2014-0701

    On April 2nd, AIANY submitted testimony in regard to two proposed bills in the City Council. AIANY supports the passage of T2014-0702 and T2014-0701 in relation to public access stairs and hold-open devices.

    February 25, 2014
    Letter in Favor of the Proposed Domino Sugar Refinery Site

    On February 25th, AIANY and AIA Brooklyn submitted a letter in favor of the proposed site plan by SHoP Architects for the Domino Sugar Refinery site in Brooklyn to Carl Weisbrod, Chair of the City Planning Commission. We support the affordable housing, resiliency, and building height aspects of the project.

    February 11, 2014
    Testimony Before the Landmarks Preservation Commission on the Proposed Park Avenue Historic District Expansion

    On February 11th, AIANY executive director, Rick Bell, FAIA presented testimony in regard to the proposed Park Avenue Historic District, and, in particular, the Park Avenue Christian Church Annex site. AIANY supports the creation of a Park Avenue Historic District and the idea of inserting a residential structure, proposed by Beyer Blinder Belle, where the Park Avenue Christian Church Annex has been located adjacent to the sanctuary.

  • February 10, 2020
    BQE in Context: Report from AIANY BQE Taskforce

    As the Mayor’s Expert Panel worked on their report, members of the AIANY Planning & Urban Design Committee and the AIANY Transportation & Infrastructure Committee formed a taskforce to hold workshops examining many of the same proposals and information provided to the Mayor’s panel. These workshops culminated into a complimentary report finalized in July 2019.

    February 02, 2018 | Aging in Place Guidelines
    樓宇業主之在地安養指南 - Aging in Place Guide for Building Owners - Mandarin
    長者友善住宅更新建議
    此指南提出住宅樓宇更新建議,以適合年長住戶居住。透過做出這些改進,樓宇業主將幫助居民在步入老年時仍能夠安全、舒適且獨立地在家生活。

    In collaboration with the NYC Department for the Aging, the AIANY Design for Aging Committee released the Aging in Place Guide for Building Owners in July, 2016. A 21-member advisory panel of city agencies, design professionals, nonprofit organizations, community partners, and businesses assisted with the creation of the guide.

    October 25, 2017
    Design Guidelines: Rehabilitation of NYCHA Residential Buildings

    Read the Design Guidelines: Rehabilitation of NYCHA Residential Buildings

    October 17, 2017 | Aging in Place Guidelines
    Guía para propietarios de edificios sobre el envejecimiento en el hogar - Aging in Place Guide for Building Owners - Spanish
    MEJORAS AMIGABLES PARA LA TERCERA EDAD EN EDIFICIOS RESIDENCIALES
    Esta guía recomienda mejoras en los edi cios residenciales para alojar a inquilinos de la tercera edad. Al hacer estas mejoras, los propietarios de edificios pueden ayudar a los residentes a permanecer en sus hogares a medida que envejecen de manera segura, cómoda e independiente.

    In collaboration with the NYC Department for the Aging, the AIANY Design for Aging Committee released the Aging in Place Guide for Building Owners in July, 2016. A 21-member advisory panel of city agencies, design professionals, nonprofit organizations, community partners, and businesses assisted with the creation of the guide.

    October 25, 2016 | Aging in Place Guidelines
    Aging in Place Guide for Building Owners - English
    RECOMMENDED AGE-FRIENDLY RESIDENTIAL BUILDING UPGRADES
    This guide recommends residential building upgrades to accommodate older tenants. By making these improvements, building owners can help residents remain in their homes as they age—safely, comfortably, and independently.
    October 25, 2013
    A Platform for the Future of the City

    Read “A Platform for the Future of the City”

    August 12, 2011
    Update to the 2011 New York Energy Conservation Code

    Update to the 2011 New York Energy Conservation Code

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