The Regional Plan Association (RPA) — an independent, not-for-profit civic group that develops ideas to improve the economy, environment, and quality of life in the New York metropolitan area — is calling upon the City to repeal its Floor Area Ratio (FAR) cap. This limit, which currently restricts residential buildings to a total square footage of 12 times the size of the lot on which the structure is located, was enacted in 1961, in an effort to prevent developers from creating, “large vertical slums that would be health hazards and overwhelm the urban infrastructure,” according to the RPA’s new report, “Creating More Affordable Housing in New York City’s High-Rise Areas: The Case for Lifting the FAR Cap.”
If such a policy were adopted, Lower Manhattan would be among the areas where its impact would be most dramatic, according to the report, which predicts more development of affordable units — under the City’s Mandatory Inclusionary Housing (MIH) law — as designs for new residential buildings were permitted to become taller and bulkier.
“This cap is blocking the way to better urban design, more needed homes, and more mixed-income neighborhoods” says Moses Gates, the RPA’s director of Community Planning and Design, who oversaw the report’s creation.
“Removing this cap will create more affordable housing opportunities in neighborhoods which are out of reach to most New Yorkers” says Rachel Fee, executive director of the New York Housing Conference.
“Without the ability to build more housing,” the report argues, “the Manhattan and other inner core areas will continue to become more and more expensive, increasing already enormous pressures on existing affordable and rent-stabilized housing, pressure that has a ripple effect on the rest of New York City and the region as a whole.”
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The skyline of Lower Manhattan as it appeared in 2013, when only a handful of ‘super-tall’ buildings dotted the landscape.
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Removing the FAR cap of 12 is also a cherished goal of the real estate industry, which regularly lobbies State legislators to rescind it. This report marks a rare alignment of the RPA and development industry groups, which often clash.
Conversely, the RPA is usually in accord with another civic group, the Municipal Art Society (MAS) — a highly regarded non-profit urban planning group that advocates for a more livable city. But not in this instance: The MAS (which helped to create the City’s first zoning codes) responded to a 2016 effort to repeal the FAR cap of 12 by predicting that the measure would, “allow for significant new bulk in New York City’s high-density residential neighborhoods, especially Midtown and Lower Manhattan…. These neighborhoods are zoned for the maximum residential density currently permitted. If the residential FAR cap is removed, the City will look to upzone many of these areas to increase density, facilitating the production of more affordable housing under MIH. Adding new levels of density to what are some of the country’s most populated districts could overburden the City’s stressed infrastructure network and crowd out light and air for neighboring properties and public spaces.”
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Lower Manhattan as it will appear in 2025, when 13 new ‘super-tall’ will be added to the current total of six.
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In October of last year, the MAS issued its own report about the proliferation the large skyscrapers in New York, with a particular focus on Lower Manhattan. Noting that a total of seven structures meeting the criteria for “super-tall” status (656 feet, or higher) were finished in America in 2016, it observed that five were located in New York, and three of these were Lower Manhattan apartment buildings — meaning that just under half of all the “super-talls” in America completed that year were located in the square mile below Canal Street.
But that density of development now appears poised to become even more lopsided. In “The Accidental Skyline-2017,” the MAS noted that while there are currently six “super-tall” buildings in Lower Manhattan, there are another 13 currently either under construction or in the planning stages. MAS cited a spectrum of worries associated with such buildings, including the need to protect public assets like light, air, open space, and the character of the City’s neighborhoods, as well as the prospect that local civic infrastructure (in the form of schools, transportation systems, healthcare resources, water and sewage networks, and trash collection services) may be overwhelmed by the large populations that such buildings draw, whether they are residential or commercial. The MAS report concluded with a recommendation that flatly contradicts the RPA proposal, instead suggesting that the City “strengthen regulations that control height and bulk.”
The RPA report counters that other metropolitan areas have much looser FAR caps, citing the example of Jersey City, which, “allows residential development up to 25 FAR in its Journal Square redevelopment area, despite it having less mass transit, parks, and jobs per capita than Manhattan.”
The RPA report also notes that high-rise districts comprise less than five percent of land in New York City, but are home to nine percent of the population, and, “have access to a disproportionate share of employment opportunities, urban infrastructure and amenities.” Indeed, the report documents that areas such as Midtown and Lower Manhattan contain more than half of all the jobs in New York City, and are within a half-mile of more than one-third of all the subway stops in the five boroughs.