In September, CFDC board members took several steps to ensure Tribeca has a voice in New York City’s developing Fair Housing Growth Strategy.

The City’s draft Strategy lays out a framework for addressing housing needs across New York City, including expectations for high-growth, limited-affordability areas like Community District 1. CFDC board members participated in the City’s public briefing on the draft report, then held a separate Q&A session with the Fair Housing Growth Strategy team to dig more deeply into what the proposed framework could mean for Tribeca.

During that discussion, we asked how preservation of existing affordable housing will be tracked and considered; how the plan will account for the type of market-rate housing being built, not simply the number of units; and how it will address neighborhoods like Tribeca that are already unaffordable and are hot spots for ultra-luxury development.

City representatives were very supportive of our questions and indicated that CFDC will be well positioned to participate when the City begins pursuing neighborhood plans.

Following those conversations, CFDC submitted a formal response to the City by its public-comment deadline, outlining six recommendations for strengthening the final Fair Housing Growth Strategy. We’ll continue tracking this work and digging further into the data needed to understand and preserve Tribeca’s existing affordable housing. More to come.

Read the City’s draft Fair Housing Growth Strategy report here.

CFDC’s Formal Response to the Fair Housing Growth Strategy

Community First Development Coalition (CFDC) supports the Fair Housing Growth Strategy’s central premise that every part of New York City—including Tribeca and Community District 1—must contribute to addressing the housing crisis. We support ambitious housing goals and agree that Tribeca, as a high-growth area with limited affordability, should be a focus for meaningful affordable-housing production and preservation.

For the Strategy to succeed, growth must be measured by whether it creates and preserves homes that New Yorkers can actually afford. Additional ultra-luxury housing should not be treated as a substitute for deeply affordable and income-restricted housing. In neighborhoods like Tribeca that are already unaffordable and are hot spots for ultra-luxury development, the City should consider not only how many market-rate units are produced, but also what is being built—including unit size and bedroom distribution, rental versus condominium tenure, and whether the resulting housing serves a range of household needs.

The City should establish a credible baseline for existing affordable housing and explain how preservation will be tracked and incorporated into the plan. During the public process, CFDC raised the difficulty of identifying all affordable units in Tribeca, particularly units supported through vouchers, regulatory agreements, tax benefits, or arrangements that may not appear in a single public dataset. Without a reliable baseline and continued tracking of expirations, demolitions, conversions, unit combinations, and other losses, the City cannot determine whether a community is making genuine progress toward its affordability targets.

Accordingly, CFDC recommends that the final Strategy:

1. Measure and publish the net change in affordable housing, not only new production.
2. Explain how preservation of existing affordable homes will be tracked, valued, and incorporated into district and neighborhood targets.
3. Count the demolition, conversion, or expiration of affordable units as losses against those targets and require meaningful replacement of those homes.
4. Track the composition of new market-rate housing—including unit size, bedroom distribution, and rental versus condominium tenure—so that raw production totals do not obscure whether new housing responds to community needs.
5. Match production and preservation targets with realistic capital resources, subsidy programs, implementation tools, and timelines, while ensuring that essential infrastructure and neighborhood services—including sewer capacity, schools, and open space—are maintained or improved as housing grows.
6. Create a neighborhood-planning process for Tribeca that recognizes its existing unaffordability and concentration of ultra-luxury development while translating Community District 1’s targets into locally appropriate land-use and preservation strategies with sustained community participation.

CFDC is prepared to participate constructively in that neighborhood-planning process. We believe Tribeca can help the City meet its housing goals, but success should be judged by durable gains in genuinely affordable housing, protection of the affordable homes that already exist, and a housing mix that responds to the needs of New Yorkers.

Community First Development Coalition