Introduction: The Affordable Housing Crisis

New York City is the most populous city in the United States by a significant margin. With such a substantial population and continuous growth, the expansion of affordable housing in the city has been a critical policy area for the past few decades. In 2013, NYC’s Department of Housing Preservation and Development declared an affordable housing crisis. The root of this crisis has been attributed to median rent prices increasing at a faster rate than average renter’s income, as well as a growing discrepancy between housing supply and demand. In fact, the city’s planning department has found that over the past 40 years, job growth has exceeded that of housing growth (Fig. 1). This shortage has led to a significant increase in NYC’s rent burdened households, or households that must contribute over one third of their gross income to rent. 

Fig 1: NYC Planning COY Story Maps

The City of Yes 

In an effort to address the housing crisis in tandem with other key issues, New York’s municipal government introduced a 3-part plan titled “The City of Yes” in June 2022 to update NYC’s zoning code. The three main components of the plan are carbon neutrality, economic opportunity, and housing opportunity. Each component of “The City of Yes” has operated on its own timeline and faced several rounds of revision to gain approval from the city council. The first initiative, “The City of Yes for Carbon Neutrality,” promotes decarbonization efforts through a streamlined clean energy transition and building modernization. The initiative supports NYC’s effort to reach net-zero emissions by 2050 and was adopted on December 6, 2023. Following this, the city focused on “The City of Yes for Economic Opportunity” which was passed by the council on June 6, 2024. The general goal of this initiative is to lift zoning barriers that prevent businesses from finding physical spaces and to support growing industries. Last, “The City of Yes for Housing Opportunity” (COYHO), was most recently passed on December 5, 2024. COYHO amends NYC’s zoning code to increase housing availability by a small amount in each neighborhood. With these focus areas combined into a holistic zoning plan, “The City of Yes” attempts to modernize NYC’s zoning code to sustainably address the housing crisis while bolstering the economy.

Key Provisions of the COYHO

Focused specifically on housing access, the final COYHO zoning amendments have authorized the creation of 82,000 new housing units within the next 2 decades accompanied by a $5 billion investment in infrastructure. The city largely sorts residence districts into two categories: low or moderate and high-density. Low-density districts (zoned R1-R5) are characterized by lower building heights, yards, and far distances from central business districts. Moderate and high density districts (zoned R6-R10) typically have bulky, dense buildings and residences are located in close proximity to central business districts. The COYHO contains separate provisions for low-density housing, medium- and high-density housing, and parking areas, along with other actions to support housing conversions. 

• Low-density districts:
  • Transit-oriented development: In an effort to increase the amount of housing close to public transit stations, low-density residential sites located within a half mile of transit can develop three- to five-story apartment buildings.
  • Town center zoning: Reauthorizes the development of housing above businesses in all low-density areas. Under this provision, two to four stories of apartments can be built above a commercial ground floor.
  • Accessory dwellings: Accessory dwelling units, such as garage conversions or basement apartments, are now permitted in one and two-family homes with some case-by-case restrictions. 
  • Affordability incentive: Housing projects with 50 units or more can take advantage of the transit-oriented development provision if at least 20% of the units are permanently affordable at 80% of the area’s median income.
• Medium- and high-density districts:
  • Universal affordability preference: Permits buildings to add 20% more units if the added units are permanently affordable to households that earn 60% of the area’s average median income. Replaces a previous policy known as voluntary inclusionary housing that only applied to a small portion of medium and high-density districts. 
• Parking areas:
  • Parking zone system: Establishes a three-zone system to reduce previous rules that required new housing developments to include parking areas. In zone 1 areas, largely Manhattan and Long Island City, parking mandates are nearly eliminated. In outer transit zones, or zone 2 areas, parking mandates are reduced in areas near public transit stations. Zone 3 areas, or areas beyond outer transit zones that have a greater dependence on cars, have largely retained their parking mandates with a few exceptions. (Fig. 2)

Fig 2: NYC Planning COYHO

• Other:
  • Housing conversions: Other provisions allow certain non-residential buildings like offices to be converted into housing, reduce restrictions on converting underused university campus structures to housing, and permit more buildings to contain small and shared apartment units. 

As such a large plan, COYHO will also alter living conditions for many residents. As a result, the policy has been met with considerable debate 

Arguments in Favor of the COYHO

The most prominent argument in support of the COYHO is that it will expand affordable housing in NYC, countering the ongoing housing crisis. Proponents of the COYHO point to the fact that NYC’s vacancy rate of 1.4% is significantly lower than the recommended percentage and historically low for NYC itself, representing a lack of housing supply and growing demand. They point to provisions of the COYHO that directly incentivize affordable housing supply such as the universal affordability preference in middle and high-density areas. In a written testimony, New York University’s Furman Center for Real Estate and Urban Policy argues that the COYHO’s provisions to incentivize mixed-income housing developments will not only meet the growing demand, but also reduce rent growth in surrounding areas. Other supporters echo this idea, citing similar rezoning policies in Portland and Minneapolis that increased supply and in turn led to lower rent costs for existing housing units. 

Supporters of the COYHO also applaud the policy’s expansion of housing across the city rather than in concentrated areas. They argue that in order to significantly increase housing stock, housing reform must be holistic and cannot be focused on only a few communities. With its broad scope from low to high-density housing units, proponents believe the COYHO meets these demands. Supporters contend the policy’s wide scope will increase geographic mobility and “relief for New Yorkers across the income spectrum”.  

Beyond housing, many supporters cite the COYHO’s potential for economic growth. They highlight that by incentivizing different types of housing developments – from mixed commercial-residential buildings to small houses – the policy will generate jobs for a variety of contractors. A study conducted by the Regional Planning Association estimated that when fully implemented, the policy could create 15,000 to 30,000 new jobs with $1.1 to 2.1 billion in annual earnings. Others add that the COYHO will help retain low- and middle-class households in NYC and revitalize small businesses. 

Enhanced environmental sustainability is another commonly-cited perk of the COYHO. Transit-oriented development is a major component of the plan that seeks to reduce car usage and promote public transportation. The transportation sector is the second highest emitter of greenhouse gases in NYC, with the majority of the emissions coming from passenger vehicles. Opting for public transportation over passenger vehicles can reduce emissions by up to 2/3rds per passenger. With more housing near public transportation and reduced parking mandates under the COYHO, supporters argue the plan can incentivize public transportation use and thus promote sustainability. 

Opponents to the COYHO

Critics assert that the COYHO does not adequately address the affordability component of NYC’s housing crisis. While many agree that the plan incentives the production of housing, they contend that increased housing alone does not fully address affordability. The universal affordability preference, the COYHO’s central affordability incentive, is criticized for being unlikely to increase affordable units in areas with increased demand for luxury housing. COYHO has also been criticized for its definition of affordable housing. When asked about COYHO, Bertha Lewis, president of the Black Institute, responded, “Any time you call affordable a $3,000 studio then what are we really doing?” 

Opponents also dispute the claim that NYC lacks housing capacity for its residents. They cite census figures demonstrating since 2010, the number of housing units in Manhattan has increased past the number of households by over 10%. This contributes to their argument that an overstated emphasis on increased housing supply as prescribed by the COYHO is not the best course of action for addressing the housing crisis. They argue that the crisis must be framed as a shortage of affordable housing, not housing in general, and that stronger affordability incentives are necessary to achieve the policy’s intended effect. 

Outer-borough residents living in more residential areas such as Queens and the Bronx also have concerns that the plan may impact their lifestyle. Many outer-borough residents live in low-density areas, where the COYHO intends to lift restrictions that keep housing density low. Paul Graziano, a prominent opponent of the COYHO and urban planner from Queens, is concerned that the policy will drastically change the makeup of neighborhoods and overwhelm outer-borough communities. Many residents who choose to live in low-density areas have done so because they enjoy the reduced crowding and space that come with single-family neighborhoods. With the potential introduction of apartments in areas such as Queens, the Bronx, and Staten Island, residents are concerned that family homes and quiet neighborhoods will be disrupted. In fact, following the adoption of the revised COYHO plan, city planner Graziano and community members raised over $70,000 to sue the city in an attempt to block or delay the plan. 

Conclusion

With housing shortages across five boroughs and over eight million constituents at play, finding solutions to the housing crisis has proven challenging for NYC policymakers. The COYHO, a policy years in the making, aims to address the affordable housing crisis by shifting zoning laws, incentivizing affordability, and reducing parking mandates. While proponents highlight the policy’s potential to create economic relief and housing mobility, many outer-borough, lower-density district residents find it difficult to support a plan that may lead to increased housing congestion in their neighborhoods. As the COYHO goes into effect, many are waiting to see whether the provisions achieve their goal of increasing housing affordability in the nation’s largest city.