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October 29, 2018

City Planning Commission
120 Broadway, 31st Floor
New York, NY 10271

Marisa Lago, Chair
Kenneth J. Knuckles, Vice Chairman
Allen P. Cappelli, Commissioner
Alfred C. Cerullo III, Commissioner
Larisa Ortiz, Commissioner
Hope Knight, Commissioner
Cheryl Cohen Effron, Commissioner
Richard W. Eaddy, Commissioner`
Orlando Marin, Commissioner
Joseph Douek, Commissioner
Anna Hayes Levin, Commissioner
Michelle de la Uz, Commissioner

Re: Public Comment on Two Bridges LSRD Draft Environmental Impact Statement
(CEQR No. 17DCP148M)

Dear Chair Lago and City Planning Commissioners,

On behalf of Asian Americans for Equality (AAFE), a nearly 45-year-old nonprofit organization,
we are writing in regards to the Draft Environmental Impact Statement for three large-scale
projects in the Two Bridges neighborhood. We are unable to support the projects as currently
configured, and urge the City Planning Commission to vote against adding these out-of-scale,
primarily market-rate residential towers to the Two Bridges LSRD Site Plan.

AAFE is dedicated to improving the lives of Asian Americans and all of those in need by offering
social services, affordable housing, small business loans and advocacy services throughout
New York City. While we are committed to building equitable communities citywide, our roots
are in Manhattan’s Chinatown and on the Lower East Side. The organization was founded in
1974 to fight for civil rights at the Confucius Plaza construction site. Today, AAFE continues to
provide safe, affordable housing in Chinatown, to stand up for tenants facing harassment and to
advocate for the most vulnerable in our community - immigrants and low-income people - to
participate in and benefit from community development.

The towers, rising as high as 80 stories and ​spanning four blocks​, would fundamentally change
the socioeconomic character of the neighborhood. Yet the city concluded that they were not
subject to the Uniform Land Use Review Procedure (ULURP). We believe any development on
this scale can only go forward with a full land use review in which the community has the
opportunity to shape the future of their neighborhood. This is why the commission must vote no,
and the city must commit to a true community-driven planning process.

The Two Bridges area has for decades been a bastion of affordable housing. These proposed
projects would add more than 2,700 new apartments, 75% of them market rate units. We cannot
forget that the median household annual income in this neighborhood is less than $30,000 and
that nearly 30% of the families in the area are living below the poverty line.

While there is an opportunity to address New York’s housing crisis in the Two Bridges
neighborhood, we firmly believe any new project must protect the character and affordability of
this community. As currently envisioned, 25% of the apartments would be designated as
affordable. This number should rise to at least 50%. Setting aside, at minimum, half of the
apartments for low-and middle-income families would not only address the critical shortage of
affordable housing in the community, but would also help ensure that Two Bridges retains its
essential, economically diverse character.

We also feel strongly that the Area Median Income (AMI) for these projects must be in line with
neighborhood income levels. The New York City AMI for a 3-person family is $93,900, far above
the median household income of $42,014 in Chinatown/Lower East Side. It is critical that any
new apartments in the neighborhood are affordable to the people who live in and helped build
the Two Bridges community.

Since 2007, approximately 950 units of housing have left rent stabilization in this area.
According to Association for Neighborhood Housing and Development (ANHD), 300 eviction
cases were filed just in a two-year time period (2013-2015). Over the years, AAFE staff have
seen first-hand how rising rents imperil the neighborhood’s existing stock of rent stabilized
housing. From Hester Street to Essex Street to Madison Street, we have advocated for tenants
facing the pressures of a neighborhood undergoing unprecedented change. We have seen
hundreds of tenants facing eviction by harassment and building neglect from unscrupulous
landlords. We expect this disturbing trend will only accelerate with a new development of this

Whether or not there is substantial new development, we urge the city to provide robust funding
to support city enforcement within landlord-neglected buildings and families facing harassment.
If and when any large-scale development is approved, we believe the city should establish a
Lower Manhattan Task Force to respond in real time to problems in rent stabilized buildings.

We are prepared to continue working with the city in support of affordable housing in the Two
Bridges area, but development must happen the right way, through a true
community-government partnership and a commitment to building on Two Bridges’ legacy as a
vibrant low- and middle-income community.

Thomas Yu
Co-Executive Director
Asian Americans for Equality

Jennifer Sun
Co-Executive Director
Asian Americans for Equality