Chair Ung round 2: Mangin on fast track affordability and AMI requirements
Ung asks Mangin to commit that the BSA Fast Track only applies to 100% permanently affordable housing and to specify maximum AMI. Mangin explains the charter uses HDFC state law language, which doesn't require 100% affordable to accommodate limited equity co-ops with non-qualifying residents. He declines to set a maximum AMI, deferring to HPD's soft letter process.
I'm going to move on to the new BSA zoning permit that's in the Charter Commission proposal.
So given the express intent during the Charter revision process that this new BSA permit
was it for the facility 100% affordable housing project.
Will you commit to this council that BSU only grant this new permit to projects when they are in fact 100% permanently affordable income restricted housing?
Thank you for the question.
Very excited about the BSA Fast Track and its ability to facilitate publicly sponsored affordable housing.
The BSA Fast Track, the charter language, very intentionally picks up the state law language around HDFC.
The state law language around HDFC does not include a restriction for 100% affordable housing, in part, for instance, because over the years,
HDFCs, limited equity co-ops, or things like that, often include, you know, one or two tenants.
shareholders, residents who can't meet the income requirements that would therefore kick it out from the BSA Fast Track or HDFC eligibility entirely.
And it's just important in those types of situations to build in a little tiny bit of flexibility so that we're not excluding worthy projects from the pipeline.
But if you look back at the last however many HDFCs that have been used to create homeownership or rental affordable housing, virtually all of them are in fact 100% affordable.
And so I don't think that the concerns on that should be too pronounced.
Okay, so in absence of specified maximum AMI requirements in the charter, how can you assure this body that affordable housing meant to be generated by this new permit will be in fact affordable?
And what would be the maximum AMI you would consider is appropriate for the projects to apply for this permit?
Gotcha.
That's a great question.
Thank you.
So the BSA Fast Track, again, picks up the state law definition around HDFC, which does include income restrictions there as well.
In general,
I think the Charter Revision Commissioners did not want to overly constrain future leadership at HPD over what types of housing projects were
and were not appropriate.
I mean, if you look over the last few administrations in New York City, you go back to Bloomberg era and, you know, affordable housing was being produced at higher AMIs.
Since the de Blasio era through Adams and now in Mamdani, I think the focus has been on much lower incomes.
Would expect that to...
To maintain into the future, but we wouldn't want to overly constrain future HPDs around the city's affordable housing mandates through charter language, which, after all, require a referendum to change.
So would you today give us a maximum AMI that you would be considered to be appropriate for this project?
That's difficult.
For BSA Fast Track, HPD has to provide a soft letter of commitment for those projects.
And so I'm not sure that I would want to go way out of my lane and try to dictate to HPD what they thought was and wasn't an appropriate affordable housing projects in different neighborhoods around the city.
In talking to council members, I would say most council members want lower AMI affordable housing, but that is by no means the only thing that council members want.
I've also talked to members who want a full range of mixed incomes, including into middle income, and we wouldn't want to undercut that.
Okay.