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Public Testimony

Michael Palumbo (Local 3) on 485X 99-unit loophole

New York City Council · Sep 9, 2026 · starts 3:50:14 · 1 min 32 sec

Palumbo describes the incentive to build 99-unit buildings to avoid construction wage requirements under 485X, arguing this hurts the middle class and that the housing crisis should not be solved by pitting workers against housing.

Member of the Public - Michael Palumbo

Good afternoon.

Member of the Public - Michael Palumbo

Chair Sanchez, Michael Palumbo from Local 3, Residential Division.

Member of the Public - Michael Palumbo

I'm here today, I believe, in the goal of 485X.

Member of the Public - Michael Palumbo

New York City needs more housing, and we need more affordable housing.

Member of the Public - Michael Palumbo

But I believe there's a problem with the way the program is structured.

Member of the Public - Michael Palumbo

Under the 485X, there's a major difference between a project with 99 homes and a project with 100 units.

Member of the Public - Michael Palumbo

Projects with 100 or more units are subject to construction wage requirements, while 6 to 99 unit category are different requirements.

Member of the Public - Michael Palumbo

This creates a very strong incentive to stop at 99, and that's what I believe we need to fix.

Member of the Public - Michael Palumbo

We need to build more housing, but we need to make sure that incentives actually encourage developers to build more rather than encourage them to stop just below the threshold.

Member of the Public - Michael Palumbo

As an electrician, I see firsthand what goes into construction of these buildings.

Member of the Public - Michael Palumbo

The men and women who build New York housing deserve to earn a wage that allows them to support their families.

Member of the Public - Michael Palumbo

We should be creating opportunities for people to enter the skilled trades, build careers, and become part of the middle class.

Member of the Public - Michael Palumbo

So my request is simple, to stop the 99-unit loophole, which lowers labor costs and overall hurts the middle class.

Member of the Public - Michael Palumbo

At the end of the day, New York's housing crisis shouldn't be solved by putting workers and housing against each other.

Member of the Public - Michael Palumbo

We should be able to have more housing, more affordability, and more middle-class construction jobs.

Member of the Public - Michael Palumbo

And that's what I believe 45X should and can accomplish.

Member of the Public - Michael Palumbo

Thank you for your time today.