Mayor de Blasio's housing plan

The Mayor’s Housing Progress Shows Why Relying on Market Isn’t Enough

But is the Mayor listening? (propublica)

But is the Mayor listening? (propublica)

As Mayor de Blasio gears up for his re-election campaign, he has been touting his progress on his signature policy initiative, affordable housing.  In an Op-Ed for The Daily News last week, he highlights how his $41 billion plan to create or preserve 200,000 affordable housing units over 10 years is on budget and on schedule.  In the last fiscal year, nearly 24,00 such units have been allotted, the most in a single year since 1989 (for a total of 78,000 since 2014). 

The administration’s focus on affordable housing has been commendable and real progress has been made, but the larger picture is less sanguine.  The affordability crisis and the homelessness crisis in NYC (which the Mayor appears to treat as a separate issue here) will not be solved by market-based solutions alone. We need much deeper federal government intervention on a number of fronts.

The Mayor’s affordable housing plan relies on several key premises (which mirrors the national focus of the LIHTC). First, it calls for attracting private development to drive construction.  Second, it requires those developers to include a certain percentage of affordable housing units with each project.  Third, it incentivizes that private development with tax breaks. The second and third premises have been highly controversial, while the first one has not been as much. 

Starting with the second premise, in 2016, the Mayor passed his Mandatory Inclusionary Housing and Zoning for Quality and Affordability laws which require developers to set aside a percentage of units for “affordable housing” and continues a general trend to upzone new neighborhoods in the city.  These were both met with heavy resistance from neighborhood groups worried about displacement and new development, but ultimately passed the City Council.  That it takes so much political capital to create a basic environment for more development is disheartening and, despite his plan’s flaws, the Mayor deserves credit for recognizing this and following through.  However, it’s not surprising that residents would be wary of private development based on other experiences in the city.

The third premise has also run into controversy, though of the political variety.  The Mayor’s plan relies on tax incentives, notably the toxic 421a program. Governor Cuomo stunned many people when he allowed the program to expire and used it as a political football to undermine the mayor’s plan. The Governor claimed he had a better plan himself (which never really materialized) and the program has been rebranded as Affordable New York.  A recent article estimates that the subsidy costs NY taxpayers $400-600k per unit  - while not producing nearly enough units (or in some cases any affordable units, due to lax oversight). Somehow this is "just how it works."

This brings us back to the first premise, which is the original sin of all of these policies.  Relying exclusively on the private market to create (and to a lesser extent preserve) housing units is an expensive, inefficient, and inequitable way to create affordable housing.

To state the obvious, it is incredibly expensive to build in NYC.  Land, labor, materials, planning, and design – all of these things are expensive and, for the most part, there are no secret shortcuts around them.  The lack of productivity gains in the construction industry in recent decades is a fascinating sideshow to this larger conversation, but the important point is that these costs are largely fixed for any type of developer.

Once you accept this, the only way to really build cheaper is to have the federal government involved.  First, it can borrow money for a lot less than the private sector, which keeps costs down (we’re missing a golden opportunity to improve our infrastructure as a result). And second, it doesn’t have to turn a profit.  This means it can build the housing that NYC needs rather than what the market rewards. All of the tax incentives in the world will not cover the difference between what is good for the bottom line of a private company and what is good for the public interest in the housing market. 

Relying on the private sector also crowds out alternative models of housing and ownership. The Mayor isn’t staffing people with this experience, isn’t listening to housers with this experience, and isn’t drawing political contributions from people with this experience. Large-scale co-living spaces, community land trusts, or (heaven forbid) more public housing all get ignored as policy tools or goals when a market-based approach runs through planning. This is a missed opportunity to consider new ways to use existing funds and assets under city control.

A truly transformative housing approach would include market-based and non-market based solutions because the goal would be simply to lower the cost of shelter.  The goal for the mayor’s housing plan includes this, but also includes keeping powerful real estate developers happy and at least keeping neighborhood groups and homeowners from openly revolting politically.  It also internalizes a hostile Albany and an indifferent Washington.

I don’t envy the Mayor’s need to balance these political realities, but clearly a bolder vision is not only necessary, but could be very popular with voters, and serve as a rallying point to change the nature of housing policy in the US. 

Mayor de Blasio was elected on a progressive platform not seen in the city for 20 years, which remains popular (perhaps even more so after 2016). He doesn’t appear to have any major rivals despite constant badgering from the press (not entirely undeserved). And yet 27,000 arguably affordable units is the best we can get? It is under a market mindset. 

We have been tinkering with neoliberalism for the better part of 40 years at the national and local levels and it demonstrably isn’t working for 80% of the country.  Voters want new ideas.  Many technocrats want those new ideas to come from local city governments given the paralysis at the national level.  So far the Mayor has passed on matching his progressive rhetoric with progressive reforms in housing.

It’s a shame because there are lots of good ideas - some old, some new, but hardly any that are radical - that the mayor should be willing to explore. Many of them can be tried without Albany or Washington.

But the truth is the Mayor de Blasio needs the state and particularly the federal government to take on a larger role in the affordable housing crisis. There are too many macro economic forces at play with the affordable housing crisis, which is why over 99% of US counties are suffering from it. Only a stronger federal commitment to housing, to wealth equality, and to tax policy can make a difference on that level.

The Mayor can be more helpful in forcing Albany and Washington to change the status quo on housing.  NYC is the biggest city, the most powerful real estate center, with the largest public housing population in the country.  If you want to change the conversation on housing, NYC is the place to do it. That change must include thinking about housing outside of the narrow, flawed lens of the market.  The Mayor needs to think bigger and I think he would be rewarded for doing so.

Governor Cuomo Wants You to Pay Developers' Labor Costs

You guys got it, right? (truthaboutguns)

You guys got it, right? (truthaboutguns)

Housing construction is complicated in New York City, but leave it to Governor Cuomo to make a bad thing worse.  The Governor had already single-handedly killed negotiations on 421a, the infamous tax subsidy to developers who agree to construct some affordable housing units, in the midst of Mayor de Blasio’s push to pass his ambitious housing plan.  As a result, hundreds of affordable units, and perhaps the Mayor’s entire housing plan, have remained in limbo. The Governor’s recently proposed solution makes matters worse.

Readers of this blog will be familiar with the problems that arose through the implementation of 421a since it was passed in 1971.  It was conceived while the NYC market was at its nadir, but quietly became a massive cash-transfer for developers when the market rebounded.  It has cost the city hundred of millions of dollars in lost tax revenue over the last decade’s hot market run, prompting many housing advocates to call for it to be abolished outright when it was set to expire last year. 

Mayor de Blasio took a different approach when putting his two major housing policy initiatives together last year.  The Mayor’s plan relied heavily on remodeling 421a with input from developers and construction union leaders.  He appears to have understood the political need for developers and construction unions to buy into his plan and the economic need for some type of tax benefit to spur development with his new requirements.  At the time that the law was up for renewal, the mayor was working with unions and developers on a compromised 421a version that would allow some non-union labor on certain housing projects that fell under the proposed guidelines.

It would be one thing if the Governor was against 421a from a policy standpoint but, in many circles, the governor’s last minute insistence on prevailing wage levels was seen as a direct attempt to kill the mayor’s plan for personal reasons.  The long-simmering tensions between the Governor and the Mayor, despite both being Democrats and broadly agreeing on policy, has been a major impediment to state and city policy-making on a number of issues.  Given the Governor’s track record, it’s hard not to look at his action as a petty lashing out.  The situation may be petty but the stakes are real - over the last eight months, a number of developments have been put on hold or out right cancelled over the 421a uncertainty.

To some degree, Governor Cuomo had political coverage at the time because he promised to announce his own detailed $2b housing plan.  The Governor created the impression that, if he was blocking Mayor de Blasio, it was because his plan was bigger and better. We’ll never know because he has never revealed his plan.  It, along with the $2b, quietly got pushed from the agenda until next year.

Instead, Governor Cuomo sent out a one-page outline to developers that suggested restoring 421a with prevailing wave requirements with the state directly subsidizing the differences for developers.  This type of direct wage intervention is virtually unprecedented. Taxpayers will literally be writing checks to construction workers to the tune of millions of dollars.

At least we think.  We don’t really know the true cost of this proposal because there aren’t many details about where the money would come from, what projects would get covered, who would administer and monitor the payments, and what if any restrictions or caps would be installed.  Although some numbers have been mentioned under some circumstances, the publicly available information is sparse.

To the extent that other parties are able to comment on the proposal as it stands, developers appear to be open to further consideration (as you would expect) and even Mayor de Blasio has offered support if the state holds to its obligation of paying those wages instead of the city.  We can expect a lot of closed-door talks to take place into the fall.

Governor Cuomo’s political antics against the Mayor and NYC in general have always appeared petty and vindictive to me.  It’s not the first time a governor has been nakedly jealous or resentful towards a mayor of NYC, but given the stakes of this particular issue – lest we forget this is about addressing the affordable housing crisis – the governor’s actions are a stunning failure of leadership.

Simply put, no taxpayer should support a vague plan to directly subsidize a developer’s construction costs.  Taxpayers should support the right to fair wages and safe working conditions for construction workers, but these are not, nor should the governor try to make them into, related issues.  This type of policy proposal is ill-conceived and potentially reckless.

If 421a is necessary for all parties to move forward right now, fine.  There will need to be complicated discussions and complicated agreements.  I certainly concede that there are no simple solutions to creating more housing under the existing framework. Though I argue that there are more options to consider and more ideas to explore to improve the creation of affordable housing in NYC, we must get the best possible agreement from all invested stakeholders.  If the Governor is secretly setting on a much better plan, I am all ears.

The Governor should be held accountable for holding up progress on affordable housing in the state.  He should be held accountable for promising then punting on a major $2b housing proposal.  And he should be held accountable for continuing to operate behind closed-doors and in vague terms.  Every stakeholder in the housing market, whether public or private, corporation or citizen, deserves better leadership.

The Mayor's Housing Plan Runs into First Major Test

The site would consist of two towers that span a small sliver facing both 17th and 18th street (morris adjmi via nytimes)

The site would consist of two towers that span a small sliver facing both 17th and 18th street (morris adjmi via nytimes)

Mayor de Blasio’s sweeping affordable housing plan passed in March has run into its first serious challenge in the form of a proposed development in the Ladies’ Mile historic district in Chelsea.  At its core, the issue comes down to at what scale should a development fall under the new housing policies.  As with any type of development in NYC, this is a maddeningly complicated question.  The answer, expected next week, will have a huge impact on how the mayor’s policy will play out.

Let’s review the housing plan quickly.  Back in March, the NYC City Council passed two major proposals to address the affordable housing crisis in the city.  The first was the Mandatory Inclusionary Zone plan, which requires every residential development to have a certain percentage of affordable units.  The second was the Zoning for Quality and Affordability plan, which sets out design and size requirements based on the location of a proposed development. 

Here’s where it gets a bit confusing.  Though a developer has several options for how many units (and at what level of ‘affordable’) to set aside for the mandatory inclusionary housing (MIH), the policy appears to allow some wiggle room because it doesn’t expressly state at what number of units a development falls under the policy.  The assumption could be that every residential development does, maybe every newly submitted development does, or maybe every large development does.  Whether the city allows for a certain amount of nuance and negotiation - or not - has a huge impact on future developments. 

(morris adjmi)

(morris adjmi)

Enter the current proposal by Acuity Capital for a 17-story building containing 62 condos on 6th Ave between 17th and 18th.  The site is currently a parking lot but would also encompass two surrounding buildings that are protected under historical preservation laws, though the Landmark Commission gave the development the go-ahead back in 2014 (obviously before the mayor's new zoning laws. It's unclear if there is an issue with it under the new ZQA requirements). The developer needs to build around those buildings rather than demolish them and also needs a special permit from the City Planning Commission to build a structure larger than 6 stories at that site. The air rights for the existing structures would transfer to the new development allowing them to add an additional number of stories on the existing square footage.

Because the new development would be larger than currently allowed, some leaders, including Manhattan Borough President Gale Brewer, argue that the development should be subject to the MIH requirements.  The concern here is that any nuance or exemption will create room for developers to get creative and avoid the MIH requirements in other ways.  If the goal of the policy is to require affordable housing units from every development, then it should do so.

(morris adjmi)

(morris adjmi)

The mayor’s office (and the developer) appear to think that the development is a ‘rejiggering’ of zoning rather than a full enlargement of the site that would trigger the requirements. The concern for the city is if the plan is deemed too onerous by developers, they might sue the city and threaten the laws (or just not develop more housing).  The courts have previously overturned housing requirements in other cases, so the city is eager to avoid that risk, particularly since the laws are still so new.

The City Planning Commission will decide on the issue on Monday.  According to several people interviewed for the NY Times article, even the Commission appears to be split about what to do.  There is some discussion of a compromise where the Commission would require a percentage of the additional units available through the air rights allowance to fall under MIH requirements. That would only create a handful of protected units, but might be enough to get through the Commission. They could also presumably make the argument that the development has been in the pipeline before the housing laws were passed and shouldn't be subjected, but I haven't seen that. (I also haven't seen if the development runs afoul of the new ZQA laws.)

The Commission and the Mayor seem wary of this case creating too large of a precedent going forward and that’s understandable. However, the reality is that the new housing plan is a major departure for the city and these edge cases must have even basic guidelines as quickly as possible.  It's also important, even though this specific case wasn't impacted, to clarify how the new housing laws will interact with other regulations, such as historical preservation.  If other policy tools can be used to prevent the housing requirements, affordable housing targets could be undermined.  Some level of nuance and negotiation are already accounted for in the city’s zoning laws and its ULURP process, so developers expect complexity in NYC; it’s the cost of doing business.  But for the mayor’s plan to take off and meet its goal of 200,000 affordable units, it needs to avoid costly legal battles with developers and, more importantly, get developers to buy-in.  It’s not pretty, but nothing in the built environment is.

The End of the Beginning: the Challenges Ahead for the Mayor's Housing Plan

Victory lap might be a short one for the Mayor (capitalnewyork via mayor's office)

Victory lap might be a short one for the Mayor (capitalnewyork via mayor's office)

Only a week has passed since the City Council approved Mayor de Blasio's ambitious housing plan, but already some observers have begun to discuss the many hurdles facing it that could spell trouble.  Though it will be years before anyone can assess the true scale and impact of these changes - and if they will deliver on the promise of more affordable housing - we can at least start to consider what this trouble could look like. Though there are a number of factors to consider, for this post, I will focus on three that seem particularly important to watch.

Governor Cuomo: Oh, yeah? (thewire.com)

Governor Cuomo: Oh, yeah? (thewire.com)

1.  Albany: 421a's & Heartbreak

The Mayor's plan has solidified political support in the city, but much of its success will depend on what transpires in Albany in the coming months and there are a lot of unknowns.  As I've outlined previously, Governor Cuomo has made his relationship with Mayor de Blasio something of a bloodsport; he has taken every chance to exert power over the city by withholding housing funds and creating excessive state oversight on projects wreaking havoc with city officials and developers alike.  It's not a stretch to see how much the governor would enjoy toying with the mayor over his signature policy achievement.

Perhaps no issue in Albany in the hands of the Governor could determine the fate of the housing plan more than the status of the expired 421a tax exemption.  I've gotten on my soapbox about 421a before, but the reality is that it was a major, if wildly flawed, tool for encouraging development of affordable housing.

Lawmakers, including officials from the de Blasio administration, had agreed on significant changes to the program when it came up for renewal in January, but the Governor surprised many and killed the talks by backing a call for developers to agree to new union contract stipulations to qualify.

As a result, 421a is off the books and many projects have been thrown into serious doubt while new projects will likely slow down as well.  There is no doubt that its previous form was a huge handout for high end developments that didn't come close to producing the needed affordable units, but simply killing it was political brinkmanship at its worst. Many people in real estate question if the mayor's plan can even work if 421a does not get extended.  Though the industry has a clear incentive to get 421a back as-is, the reality is tax policy is a major component of the mayor's plan and without buy-in from Albany, it's hard to see how the units get built.

Some of the Governor's political maneuvering might make more sense when he announces his own housing plan soon.  As I've speculated, if his plan greatly resembles the Mayor's but with more power and credit going to the Governor, it will be hard to defend.  If, on the other hand, it spells out a new direction in housing, and solves long lingering flaws in policy like 421a, then we might have something worthy of discussion. In either scenario, the Governor has made it clear that the Mayor's plan must go through Albany first and it remains hard to picture that being a pleasant journey.

CB15 (Sheepshead Bay) voting against the mayor's housing plan (sheepsheadbites)

CB15 (Sheepshead Bay) voting against the mayor's housing plan (sheepsheadbites)

2. Local Opposition: CB86'd

Though the City Council supported the plan by votes of 42-5 and 40-6 on the two major proposals, all but a handful of the city's 59 Community Boards rejected it.  CBs are made up of local residents and business owners and their votes are only recommendations, but their near-universal opposition was a chilling rebuttal to the Mayor and a potential sign of the pitched resistance these groups might undertake in the months and years ahead.

This opposition has practical implications because these same bodies review every development proposal in their districts under the city's ULURP land review process. Again, these votes are only recommendations and can be overcome through other city agency approval, but when time is money, opposition from a CB can delay and even derail projects.  If many residents have already opposed the plan overall, you can expect that this will continue with specific projects. For example, CB5, which includes East New York - singled out by the Mayor as a major focus of the plan- unanimously opposed the plan. It isn't likely that they will be open to the many projects already being discussed

The philosophical implications of local opposition are also important to consider. Though it is easy to dismiss some of these votes as naked NIMBYism, as the Mayor has unfortunately been close to doing, the issue is much more complicated.  No doubt, though, some of these positions are based on the more disappointing aspects of NIMBYism and resistance to the inevitability of a changing city.  

Preventing more density, more height, and more transit-focused development could have dire economic and environmental consequences for the city and the region, but it's hard for an individual to accept that when it means their trains or schools might get more crowded, their neighborhood might become a construction site and look very different at the end, and their parking could disappear. These are entirely understandable, if intractable, concerns.

However, it isn't just NIMBYism at play here, as many neighborhoods have built up mistrust towards the city over decades - whether it's from the scars of urban renewal projects, the slights of feeling overlooked by programs and services, or the perceptions of forced integration and change, community boards evolved from a resistance to top-down management and have long been wary of city-wide policies. New Yorkers have seen large scale, Big Idea type-plans before and are right to be wary of their true costs and benefits. 

It is up to the Mayor to outline these issues, outline the underlying causes, and explain why this plan is different and why it will be better for New York and for New Yorkers. There may well be many benefits in the housing plan for these communities, but there will also surely be trade-offs and negative consequences. The Mayor has obviously not done a good enough job of framing this discussion around those realities or to speak to the legitimate hopes and fears of New Yorkers regarding the plan.  For a Mayor who campaigned and won by recognizing the populist mood in the city, so far he has missed the opportunity to approach this plan through the same lens and vernacular.

The Mayor and his administration must do a better job of selling the tangible benefits of this plan while acknowledging the unavoidable pain of change.  Though the CBs are only advisory boards, their near-universal rejection of the plan could create havoc for his plan in the short term and greater consequences as the next election approaches in 2017. 

 

What (potentially) goes up, must (inevitably) come down (citylab)

What (potentially) goes up, must (inevitably) come down (citylab)

3. The Market: The Giveth and Taketh 

The real estate market is the easiest factor to overlook in all of these discussions, but ultimately it will have the final say in the future of the housing plan.  Many of the assumptions built into the plan, from the tax incentives available, to the expected population growth, are based on an ascendant market.  There are some early signs that the market may be headed for a correction or even something larger.  Given that the housing plan relies on the market to drive it, if the market tanks, it's unlikely that many units will be built, affordable or not.

Relying on the market has been a criticism voiced by many housing advocates as the Mayor's plan went under review, but given the power of the real estate industry and the construction unions in the city and the state, I don't think it would have been possible for the Mayor not to get their buy-in and still deliver a plan.  It might be incremental, but it is a necessary step in this political environment and the need demands that some action be taken right now.

The problem with a market-first approach, however, is relying on a market that is not healthy or functioning well to begin with.  Even what we talk about when we talk about 'the market' isn't terribly useful. It hides the fact that in reality, there are two markets in the city: the "asset" market and the "shelter" market.

The asset market has produced 432 Park on the high end and thousands of shiny doorman condos on the other end, many of which will sit empty for the majority of their ownership; this market has had severe ups and downs as would be expected when it is a function of the global economy, but it has created most of the new housing units in NYC over the last decade.  This operates more or less as a market should.

The shelter market is much larger but has not operated as a market should; it has had relentless pressure put on it without the necessary relief.  With the population of NYC expected to continue to rise, and the demand for all types of housing only increasing, a healthy market in theory should offer the incentive to produce a corresponding number of units.

The fact that this isn't happening owes to many complicated reasons, most of which we have discussed in this blog previously, but the main takeaway is that we're in a housing mess because the overall market is terribly distorted and there isn't much discussion about how to change it or even if it should be changed.  As a result, relying on said market, unaltered, to fix it is potentially a fool's errand. 

Much remains to be seen about the future of Mayor de Blasio's housing plan because so much of it falls outside of the Mayor's control, or anybody's for that matter.  The Mayor has much work to do in order to see the plan implemented and to see the types of benefits he, and many others, believes will result from it.  

SROs: The Wave of the Past

Hotel Chelsea, a classic SRO (vanityfair)

Hotel Chelsea, a classic SRO (vanityfair)

I wanted to continue the conversation on micro-living and shared-living and include an old idea that city officials should consider: the reintroduction of single room occupancy (SROs).  SRO buildings came in many shapes and forms, but generally consisted of small rooms with a single bed and a shared bathroom and kitchen for each floor (there is no single definition of SROs in New York housing law.)  Though Mayor de Blasio's housing plan, now backed by the City Council, does not contain any proposals about SROs, the successful if limited introduction of micro-units does open a door to discuss this type of affordable housing option.  

We forget, but for much of the late 19th and early-to-mid 20th century SROs, "rooming houses" and "lodging houses" provided a large portion of housing for workers flooding American cities from New York to San Francisco during the transition from an agricultural economy to an industrial one.  The diversity of housing allowed for single men and single women to find short term or long term housing that met their financial needs. I highly recommend reading this SRO report from CUNY Law Review by two lawyers from MFY Legal Services about the history of SROs in NYC and their current legal gray zone. 

The same factors that created the demand for SROs historically still exist with today's working population, perhaps more so given demographic changes. Just for some perspective, there were 185,000 single-person households in NYC in 1960; today, there are 1.8 million.

This blog has previously discussed some of these dramatic demographic changes. For younger workers, it speaks to lower marriage rates, higher debt levels, and social preferences; the numbers also speak to immigrants (many of them illegal) who live alone and send remittances home to support their families; it also accounts for the high level of seniors living on their own in the city.    (We will devote future blog posts to immigrant housing issues and senior housing issues.) Whatever the cause, NYC and other cities have been slow to recognize the dramatically shifting profile of renters and have not created more housing diversity to accommodate them. SROs would be an impactful and easy policy pool to include.

Why aren't they? Because most cities made SROs illegal (NYC banned new SRO construction in 1955) and severely cracked down on them in the following decades. This happened slowly over time as suburbanization and deindustrialization made SROs a highly-stigmatized form of living in the American consciousness - they became the last resort for the poor, the addicted, the disabled, or the marginalized.

By 1987, the city went further and made it illegal for an apartment to be smaller than 400 sq feet and not contain a bathroom or kitchen (Mayor Bloomberg created a waver for Carmel Place, the first micro-unit building in NYC, to have smaller units).  Though only about 30,000 SRO units are still registered in the city, according to multiple sources, potentially 100,000 exist illegally, which means many people live in substandard and dangerous conditions.  The fact that so many people would still take that chance shows the depths of the housing crisis and the need for more housing diversity.

It would be simple to reintroduce SROs legally, as far as it goes, by removing the law from 1987 that requires all units to be 400ft and contain a bathroom and kitchen.  But we should go further.  First, the city should offer amnesty for registering (and inspecting) the thousands of illegal SROs already in existence, many in private homes. Second, the city should offer incentives for developers to remodel existing buildings - whether tapping into the idle or underused warehouse stock in some of the boroughs or older Class B or C office buildings, particularly around transit. Finally, with new developments, allow developers to include SROs set to targeted AMI levels as an additional option for set-aside affordable units.  This would be a much lower cost option for developers and a higher output of affordable units.

The sum of banning SROs and other policy changes (such as height restrictions, historical districts, density limits, parking requirements) that have had local support and reasonable-enough intentions going back to the Bad Old Days, has stripped NYC of the housing diversity that it so desperately needs and used to have in abundance. It has warped the market to such an extent that developers are only building luxury high rises while 60,000 people are applying for a handful of units in a single micro-building.  Even Mayor de Blasio's compromised micro-housing plan reflects a disappointing resistance to a potentially transformative idea.

I am encouraged to see micro-apartments in NYC, even if the current models are on the top end of the market.  If they can create a framework to consider more housing diversity (and encourage a growing call for housing resiliency) that goes beyond even micro-apartments and SROs, then we should all welcome them.  Rather than trying to force a percentage of affordable units into every project, if we expand the types of projects at a developer's disposal, and expand the housing options for tenants across age and income groups, we can finally start adding a truly impactful amount of units to the market that will lower the costs for everyone.  We've seen this before in NYC and we can see it again.  Sometimes the most radical ideas are the old tried and true ones.