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The Inwood Rezoning – What Ever Happened to “First Do No Harm”?
There’s an old medical maxim, “first do no harm,” or, make sure your response to a problem doesn’t in fact make it worse. It’s a tenet the City would be wise to heed, and one that unfortunately seems to be missing from too many of its current land use actions. The proposed Inwood rezoning is a case in point: a neighborhood where the City is using the wrong approach for a very real problem, and one that’s only likely to exacerbate it further.
So what’s ailing Inwood? In a few words: speculation and displacement. Community District 12 has the highest concentration of rent stabilized housing in New York City, making up some two thirds of the neighborhood’s total housing stock. With a median household income of around $46,000 and a third of households making below 30% AMI (about $28,000 a year for a family of three), this is a neighborhood that can ill afford to lose this stabilized housing stock. Yet Inwood is losing stabilized apartments at an alarming rate, the third highest rate of any Community District in New York. ANHD’s Displacement Alert Project District Reports – a monthly update of harassment and displacement risk in stabilized buildings – shows that Manhattan Community District 12 has the highest number of buildings at high risk of displacement in the entire city: 183 at high risk buildings containing 10,435 units just last month. HPD issued 390 severe violations in those buildings in June alone.
If the problem is the loss of affordable apartments due to tenant harassment and speculation, the response should be clear – focus on the preservation of those existing units and work to slow speculative pressure. If ever there were a neighborhood to focus heavily on preservation, Inwood would be it.
Unfortunately, the City is taking a different approach. The City’s framing of the problem is that displacement pressure happens because of a lack of new housing development, both market rate and affordable. This may be a reasonable argument to make at a citywide level; as our city’s population grows, adding more housing units to meet the rising demand makes sense, and using rezonings to encourage the creation of more units can be part of the overall approach. But, where that rezoning takes place is not just a question, it is the question since rezoning a neighborhood that is not vulnerable to displacement pressure makes sense, but rezoning a neighborhood that is especially vulnerable to displacement pressure does not.
That’s where Inwood comes in. The City’s proposal is to upzone large sections of the neighborhood to allow more new housing construction – primarily market rate, with a portion set aside as affordable through Mandatory Inclusionary Housing (MIH). But this is an approach more likely to exacerbate than alleviate the displacement pressures Inwood already faces. By providing the opportunity for far more new market rate development than affordable, in one concentrated shot, this rezoning will only increase the speculative forces already at work. While the City also says they will work to preserve existing affordable units, it won’t be enough to counterbalance the accelerated displacement pressures that the rezoning will bring, especially to the 35 rent stabilized buildings, with close to 1,500 apartments, directly in the path of the proposed upzoning. And preserving existing units is something the City can and should focus on in this neighborhood regardless of any zoning change – the proposed upzoning will simply make that task even more difficult.
The City may say that MIH represents the floor, not the ceiling, in terms of the affordable housing that will get built in Inwood. But absent specific guarantees of additional affordable units, MIH is likely to be it. This is borne out in the commitments made in other rezoning neighborhoods, where the City has been hesitant to make specific promises about the number of affordable units that will be created outside of MIH and on public land. That’s because the City doesn’t want to make promises about things outside their control, and the City simply can’t require developers on private land to take City subsidy in exchange for additional affordability. In Inwood, the market is strong enough (and speculation is already rampant enough) that it’s likely that most developers will simply build market rate, rather than use subsidy – especially after they’ve just been granted the ability to build at higher density as of right.
If the goal is to increase the total amount of housing units in Inwood, regardless of the consequences, then the proposed rezoning is a fine approach. But if the goal is to increase the amount of affordable housing in Inwood, then the rezoning stands to do more harm than good. It’s a crucial distinction and one the City seems unwilling to acknowledge. But finding the right balance of new market rate and affordable housing is essential, not just in Inwood but for the city as a whole.
The City has acknowledged the importance of preserving existing affordable housing in neighborhoods like Inwood, and has recently taken the lead with the passage of important legislation including Right to Council, Certificate of No Harassment (CONH), and the Stand for Tenant Safety laws, all of which create important new city-backed protections for tenants.
This makes it all the more unfortunate when the City gets it wrong. By encouraging speculative forces and displacement pressure, the Inwood rezoning is likely to lead to the loss of more rent regulated units than are gained. Or, to put it another way, it will do harm. That’s not healthy, for Inwood, or New York City.
Christopher Walters, ANHD’s Rezoning Technical Assistance Coordinator