New York City Comptroller Scott Stringer issued an analysis of Mandatory Inclusionary Housing and the East New York Rezoning. It opens,

In an effort to address the City’s ongoing affordable housing crisis, the New York City Planning Commission is currently proposing a series of zoning changes, including Mandatory Inclusionary Housing (MIH) and Zoning for Quality  and Affordability (ZQA), for potential application in communities across the city. One neighborhood targeted for significant redevelopment is the East New York/Cypress Hill area of Brooklyn. While many Community Boards have already expressed a variety of concerns about the proposed rezonings, the ultimate question comes down to this: does the proposal help or hurt the existing affordability crisis — in East New York and across the five boroughs? (1)

The analysis concludes that “the City’s own data shows that the current plan could inadvertently displace tens of thousands of families in East New York, the vast majority of whom will be unable to afford the relatively small number of new units that will be built.” (1)

In place of the Mayor’s plan, the Comptroller proposes the following principles, among others:

• target density to sites primed for affordable housing
• ensure affordability for existing, low-income residents

While the Comptroller is right to highlight the impact of zoning changes on existing residents, his principles do not seem to lead to a better result for a city starved of new housing. Targeting density to sites primed for affordable housing will result in many fewer housing units because it applies to far fewer parcels. Ensuring affordability for existing, low-income residents will mean that subsidy dollars will have to be concentrated on fewer units of affordable housing.

This debate between the Mayor and the Comptroller highlights two key issues. First, every plan to increase affordable housing has winners and losers. Second, affordable housing policies almost always have to choose between providing moderate subsidies to many units or deep subsidies to fewer units. While the Comptroller’s analysis highlights those tensions in the Mayor’s plan, it does not acknowledge them within its own. There are no easy answers here and those who are truly committed to increasing the supply of affordable housing in NYC must make sure not to let the perfect become the enemy of the good.