This is a slightly different version of a letter that was sent to Department of City Planning, who is the “lead agency” on the rezoning application. It is in reference to the environmental consequences of the proposed development that allows comments and suggestions to be given to the city. It can also be the basis for a lawsuit if the City fails to consider and explore the negative consequences of a development.

It is our belief that the City can not simply ignore or even state that because a developer is building “affordable“‘ units that they will not have adverse effects upon the community, especially since the developer has such a range of options that he can choose from, as this paper will explore. In fact some of these options could actually help gentrification and displacement as the “affordable” income bands can be way above market rent.

Misrepresenting Affordable Units

It is common for the news media and other communications to make the claim that when the word “Affordable” housing is stated that it means “below market value“. However, this is so untrue that “Affordable” can actually mean luxury apartments depending upon where they are being built and who they are for (targeting).

This is the case with the 960 Franklin Ave Development where 100% of the “affordable” units which is 50% of the total amount of the entire development being built in Crown Height South, will be rent burden and severe rent burden (above market value/luxury apartments).

What the Developer Plans on Building

Bruce Enicher, the developer has stated on his application that he plans on applying for the Mandatory Inclusionary Housing (MIH) program – Option 2 and **HPD/HUD funding . He wants to build almost 1600 residential units where currently he can build only 500. He states half will be built under the “affordable” of the two programs sited above.

Affordable Income Bands
MIH Option 2 Parameters/Requirements
One and Two Income Band Scenarios
Three Income Band Scenarios
Lawful Double Dipping HUD/HPD and Mandatory Inclusionary Housing
Developer’s Current Statements Are Not Legally Binding

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