TESTIMONY


New York City Planning Commission / The Unified Bulk Program
(#NOOO244ZRY)
April 25, 2000
City Hall

STATEMENT By Paul Graziano

The Queens Civic Congress

Thank you for this opportunity to discuss the Unified Bulk Program. The Queens Civic Congress is a coalition of almost 100 community and neighborhood civic organizations representing condo and co-op owners, homeowners and tenants living in neighborhoods across Queens. As civic associations that organized around land use issues, we recognize that a progressive, accessible and fair land use policy is essential toneighborhood stability and our quality of life.

So, when we learned of the Commission's intention to undertake a comprehensive reform and revision of the Zoning Resolution, we looked forward to a new Resolution that would serve every New York City neighborhood.

We were disappointed.

LOW AND MEDIUM DENSITY DISTRICTS
The Proposal mostly ignores the low and medium density districts that prevail outside Manhattan and in all but the most densely built up neighborhoods Brooklyn, the Bronx and in rare pockets of Queens. Low and medium density neighborhoods in Queens, Brooklyn,
Staten Island and the Bronx are at risk of inappropriate development as a result of the absence of low and medium density zoning districts that reflect their character. The 1989 Low-density Zoning Text Amendments saved sound, stable neighborhoods from being razed. There is a need for new zoning districts to reflect the character and fabric of housing configurations overlooked in 1989. Many neighborhoods across the city continue to be at risk of unplanned and unheeding development. Surely, the Unified Bulk Program could include additional low-density zoning text amendments.

Most certainly, they should be added to satisfy fundamental concepts for appropriate neighborhood development.

R-l AND R-2 DISTRICTS:
In one of the only mentions of low-density districts, the program contains a proposed change in R-1 and R-2 districts to permit taller houses on lots in excess of 9,500 square feet. This would encourage consolidation of smaller lots to create larger parcels to qualify for the new bonus. In built up neighborhoods where vacant lots are scarce, creating a large lot to qualify for the "bonus" would inevitably require razing older, often architecturally significant homes to be replaced by "McMansions" or "snout houses" that are aesthetically and contextually incompatible with their neighbors. This proposal would encourage lot mergers in our lowest density neighborhoods that you seek to discourage in higher density neighborhoods. Residents of these low-density districts consider this proposal detrimental to their communities. Just a few months ago, the Commission recognized the value of low-density neighborhoods by rezoning an inappropriately zoned Forest Hills neighborhood from R-6 to the more contextually appropriate R-2. Should residents of the Kew Forest neighborhood and other similarly zoned communities now ready themselves for the destruction of their neighborhoods contexts by way of lot mergers and overly tall houses?

We see aspects of the proposal that have citywide implications: the creation of new Special Permits and the omission of a comprehensive reform of community facilities.

SPECIAL PERMIT/DESIGN PANEL
A provision for a new Special Permit to allow bigger and taller buildings if a development is deemed to be of higher quality or superior design would create a panel of architects and planners (and a Commission appointee) to advise the Commission if an applicant qualifies. Such a panel would, by its nature, apply non-specific, subjective evaluations in determining if a project should be exempt from objective and specific bulk and height requirements applicable to the zoning district. We see such subjective evaluations leading to divisiveness within the Commission when the panel presents its recommendations as that of the "professional community." Moreover, nowhere in the proposal for a panel are there details of how or when the panel would enter the public review process or how the public would contribute to the panel's recommendations.

A provision for a new Special Permit (for community facilities) by Commission authorization without providing the community the opportunity to review and comment is a further dilution of ULURP. Exemptions, even when minor, should be conferred only after the public, community boards, and the Borough Presidents exercise their opportunity to comment and if they wish, object.

COMMUNITY FACILITIES
The Unified Bulk program fails to address the changing impacts of community facilities, particularly in low-density residential neighborhoods. Community facilities, and what they are, their role in the community, their relationship to the neighborhoods in which they are sited, are as intrinsic to the city's fabric as the "tower in the park."

The Unified Bulk Program exacerbates burdens community facilities present higher density districts and largely ignores the problems experienced in lower and medium density districts. Issues ranging from the definition of community facilities, bulk bonuses, post- construction changes in use, parking to impacts on the infrastructure should be addressed in the Unified Bulk Program.

In conclusion, we feel that planning should be a democratic process. We appreciate the amount of work that the City Planning Commission has put into this proposal. Planning for future needs of New York City as a whole must be balanced by immediate planning for the people who reside in an individual neighborhood. This includes a commitment by the City Planning Commission to create more low- and medium-density zoning text amendments; make sure that any new rules put into effect are without loopholes in order to eliminate any potential of abuse by developers; and the creation of fair and equitable regulations. instead of current bonuses, for community facilities.

Sincerely,



Paul Graziano
Zoning Chairman
Queens Civic Congress



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