Over recent weeks, I have heard from parents, teachers, tenants and other activists who are concerned about two sets of redevelopment proposals that could have a significant and potentially harmful impact on our Upper West Side neighborhoods.

The NYC Department of Education (along with two related government agencies, the NYC School Construction Authority and the NYC Educational Construction Fund, NYC DOE) solicited and is now reviewing proposals to completely demolish P.S.191 on West 61st Street and P.S. 199 on West 70th Street, with an eye toward building residential towers with replacement public schools located in the base.

Similarly, the New York City Housing Authority (―NYCHA‖) has a plan to invite developers to build high-rise apartment towers within existing public housing projects. On the Upper West Side, the proposal is to construct four luxury high-rise towers at the Frederick Douglass Houses on Amsterdam Avenue.

The NYC DOE and NYCHA proposals have a great deal in common. Both agencies are under great financial strain – NYC DOE has lost critical funding to meet student needs, while NYCHA lacks the resources to complete routine repairs, let alone addressing critical infrastructure needs. Both agencies are seeking to address these financial strains by ―monetizing‖ the value of publicly-owned real estate assets through long-term agreements with private developers.

Unfortunately, NYC DOE and NYCHA have something else in common. Both agencies’ proposals are exempt from the Uniform Land Use Review Procedure (ULURP), which means that the voices of residents, neighbors, parents, teachers, students and others are discounted or disregarded.

The purpose of ULURP was to establish a standardized procedure for public review of applications affecting the land use of the city, especially development projects of some magnitude and projects which involve the sale or lease of public assets. However, neither NYC DOE nor NYCHA is legally required to submit these proposals to ULURP.

Both agencies are exploiting municipal ULURP exceptions that should not apply to these proposals. ULURP exceptions should apply only to projects that are within the normal scope of an agency’s activities, such as NYC DOE building a school, or NYCHA building more public housing. Our elected officials, including Manhattan Borough President Scott Stringer, Assemblywoman Linda B. Rosenthal and Council Member Gale Brewer, have expressed concerns about the lack of public review and input for the NYC DOE proposals.

I call upon both NYC DOE and NYCHA to submit these proposals through ULURP, to provide for a full analysis of the environmental impact of each proposal, and to abide by any ULURP determinations. These proposed developments are likely to increase traffic, create additional demand for seats in already-overcrowded local schools, and impact the character of the neighborhood. Both proposals will inevitably reduce open and green spaces. Some sites may require environmental remediation; the NYC DOE projects also require finding safe, convenient temporary school locations so that educational activities are not disturbed – which will be next to impossible to find!

Going forward, we must ensure that any future proposals of this type and magnitude are required to be subject to ULURP, so that the general public, community boards and elected officials can do their jobs by having a full and fair opportunity to review, comment upon and approve or disapprove of future proposals.