Testimony: Zoning Changes Should Not be Approved Without a Plan to Build Enough Schools

A copy of our Testimony for the City Planning Commission, a PDF of this testimony can be downloaded here.

Testimony before the City Planning Commission

December 16, 2015


Dear Chair Weisbrod and members of the Commission:

My name is Miho Watabe, and I am testifying on behalf of Class Size Matters, a citywide public interest organization that advocates for smaller classes in NYC and nationwide.

The proposals under consideration today, Mandatory Inclusionary Housing and Zoning for Quality and Affordability, would lead to increased rates of development and school enrollment growth at a time when our public schools are bursting at the seams.  According to the city’s own data, there are over 556,000 students in schools that are already overcrowded and our elementary schools are at an astonishing 104% capacity.  Yet there is nothing in these proposals that would address the need to build new schools along with residential development, and that is simply unacceptable.

Currently the DOE’s school capital plan only contains half of the seats necessary to alleviate overcrowding and address existing enrollment growth, no less the accelerated growth that these proposals are likely to create.

We need a far better planning process, including reforms to ensure that school capacity keeps up with development.  The CEQR formula that City Planning uses to estimate the impact of new construction on school enrollment is fundamentally inadequate and imprecise.  It is based upon data from 1990-2000, and relies on borough-wide data, with no differentiation for neighborhoods within boroughs, and doesn’t take into account significant changes in birth rate data and family out-migration rates.  Nor does the formula take into account differentiation in the size of the unit or number of bedrooms, as was previously the case.

The CEQR manual also sets unreasonable high thresholds for requiring mitigation.  For example, in Brooklyn, no residential development would be projected to have a “significant” impact on elementary schools unless it includes 121 units, and over one thousand units in the case of high schools.  It must also cause locally zoned schools to exceed 100 percent utilization, and even then no specific mitigation measures are required.  As a result, New York Lawyers for Public Interest and many Community Boards have called for reform of the CEQR formula review process, to ensure that development does not worsen school overcrowding. .

Last spring, the Public Advocate wrote a letter to the Chancellor and the Mayor, along with twenty two Councilmembers, many parent leaders and Community Education Council members, urging an immediate expansion of the school capital plan and a Commission to fix the broken school planning process.[1]  Fundamental reforms to the planning process are needed, including a revamping of the CEQR formula in light of more recent birth and census data, improvement in the DOE’s enrollment projections and utilization formula, a more transparent needs assessment, and a more responsive public process that better takes account of the need to build schools along with housing.

Impact fees should also be considered as exist in more than 83 percent of cities and counties, so that developers are obligated to pay into a fund for schools and other infrastructure improvements.  All these steps should occur before any zoning changes are instituted that would accelerate the rate of residential development, which has already far outpaced the capacity needs of our public schools.

City officials have often said that their goal is not merely to ensure more housing is built, but also to create better neighborhoods.  There cannot be better neighborhoods without a concurrent strategy to build schools along with housing, so that future generations of NYC children are not subjected to even more detrimental conditions.

[1] https://3zn338.a2cdn1.secureserver.net/wp-content/uploads/2015/06/061515-PA-Ltr-to-Chancellor-Farina-re-Capital-Plan-final.pdf


Categories Reports, Testimonies, Etc., Testimonies & Comments, Updates | Tags: | Posted on December 21, 2015

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