Photo: RPA

Complex rules exclude too many residents from the process and make it too difficult to advance worthy projects

Each of the region’s 782 cities, towns, and villages has its own process for approving development projects, zoning changes, and other land-use actions. Each state also has its own requirements for environmental review, municipal master planning, and other approvals.

And yet all of these processes have the same three problems in common: community residents feel shut out of the process until it is too late to affect decisions; developers complain that approvals take far too long and the process is so unpredictable that only the most well-resourced and patient capital can see projects to completion; and municipal officials often lack the resources to adequately evaluate proposals and efficiently move them through the approvals process.

At a regional level, this inefficiency results in too few beneficial projects reaching completion, impacting housing supply and contributing to the affordability crisis. For projects that do get finished, benefits are unevenly distributed and adverse impacts are overlooked, affecting community health and well-being.

All cities, towns, and villages should have up-to-date comprehensive plans that reflect the input and needs of residents

Up-to-date comprehensive plans, developed with robust resident participation early in the process, both require communities to think proactively about their future and help them set out a policy framework that informs, rather than reacts to, development projects as they are proposed. These plans help communities better negotiate with developers, and give developers a clearer sense of what projects are likely to be approved.

Although New Jersey and Connecticut require municipalities to prepare and adopt a comprehensive plan every ten years in order to maintain eligibility for certain funding, they do not provide specific guidelines or requirements for incorporating community input into the planning process. Instead, municipalities typically gain input through public meetings. However, such public meetings tend to attract only a small and often unrepresentative share of the population, as many stakeholders are either unengaged or unable to attend because of work schedules, child care issues, and other conflicts. Much more needs to be done to expand the scope of engagement formats, including the use of online and social media tools. Municipalities need more guidance and training on how to effectively communicate and engage with local communities early in the process.

In New York, comprehensive planning is encouraged, but not required. Instead, the state relies on mandated environmental review to guide planning and development decisions. This means community engagement is limited to providing input into scoping of environmental impacts, and participating in public hearings, as proactive engagement with local communities in shaping proposals and/or development scenarios early in the process is not included within the scope of the current state and city environmental review processes.

All three states need a meaningful, comprehensive planning process that evaluates potential impacts and provides clear direction for future planning and development decisions. Updates should be required every ten years, with environmental review folded into the planning process. In New York City, comprehensive plans should be developed for each community board.

All projects should have a fixed timeline for community input and government approvals

Clear and predictable timelines are essential for transparent and effective community input and reliable government approvals. Without predictability and transparency, the development process can become mired in political dealings and/or the appearance of such dealings, which can result in a drawn-out, frustrating, and expensive process.

Unfortunately, outside New York City, there are often no statutory timelines, so even small projects can take years to complete—if they happen at all. Community members waste valuable time in public meetings without a clear sense of how their input is being incorporated. For developers, redundant meetings increase legal and professional consulting costs, potentially reducing the budget left over for quality design and materials. Delays can also impact developers’ ability to obtain public funding and/or private financing for a project.

New York City’s Uniform Land Use Review Process (ULURP) provides a good example of a clear and predictable approvals timeline, once a proposal is certified as ready for review. Once certified, ULURP guarantees that a proposed project will move through the review process with specified timelines for different agencies, community boards, and the mayor. Despite this predictability, however, meaningful community engagement does not occur early enough in the ULURP process. There is no clear process or timeline for public input before a proposal is certified as ready for review; and after certification, it is difficult to change a project in response to community feedback.

In order to be inclusive, equitable, and predictable, ULURP and other planning processes in the region need to include robust and transparent public engagement early in the planning process as alternatives are being considered and evaluated, before proposals become solidified and difficult to change. Set timelines should be specified, and a suite of engagement tools employed, to ensure meaningful contributions from a diverse group of stakeholders. The states should provide technical assistance and/or funding for municipalities to implement such engagement, with municipalities engaging with organizations within their local communities as partners to solicit community input into the process.

Projects should be evaluated for their impact on health, the environment, and local communities through a process that links environmental permitting and comprehensive planning

Although environmental review processes differ in each state, as well as in New York City, they typically require proposed projects to be evaluated on a similar set of impacts: natural habitats, air quality, water quality, traffic, noise, viewsheds, and other environmental conditions. But development projects also have important repercussions on other conditions, like health, displacement, transit accessibility, workforce development, and fiscal balance sheets. These types of impacts are rarely included in the environmental review process. Effective analyses must capture both impacts on the natural environment and on local communities. Environmental review methodologies should take advantage of new technology, data, and research to include metrics such as formulas for calculating displacement, employing health impact assessments, and taking into consideration the social determinants of health.

Today, the environmental review process suffers from two distinct, but related flaws. First, the process is structured, by design, to identify the negative impacts of a proposed project, and not its positive benefits. For example, community services required to support a new development project can often be a flashpoint of contention, while positive impacts of a project on areas such as housing affordability may receive little attention. Second, the environmental review evaluates impacts in a very narrow geographic context that fails to include neighboring communities or the region at large—either of which may benefit or be affected negatively. Dense multi-family housing, for example, may cause more traffic or noise at one intersection, but on the whole, may generate fewer car trips than the same number of units built across a broader geography. Operating with this narrow lens, the environmental review process is very often used as a tool to delay and stop developments that may, in fact, be seen as beneficial to communities when viewed from a more holistic perspective.

Data is critical to effectively evaluating the impacts of proposed projects—and new technologies can make more data available and easier to analyze. States and/or counties must collect, maintain, and make available the information local communities need throughout the planning process. They should also provide the technical and planning assistance necessary for municipal officials, staff, and citizens to learn how to utilize the data in ways that produce better, more equitable outcomes, with greater speed and efficiency. At the municipal level, all permitting and environmental review and approvals for development projects should be coordinated by a designated municipal office or point person. At the state level, an online dashboard should be created to track local development project review and permitting. This dashboard should be accessible to the public and provide transparency and information-sharing across municipalities.

The project evaluation process should be accessible and transparent, and include the views of a wide range of stakeholders

At first glance, there seems to be an inherent tension between expanding stakeholder engagement and making the planning process faster and more predictable. Experience has shown, however, that not taking stakeholder input into account—especially early in the process—can slow down projects, or even stall them entirely. Early and inclusive participation in project planning can reduce opposition and litigation, and when combined with clear timelines and evaluation criteria, can provide greater predictability overall. Several actions by municipalities and states can help create this more virtuous cycle.

The first is to solicit the help of community-based organizations in reaching out to people who are typically underrepresented in the planning process, particularly communities of color, as well as immigrant and low-income communities. Getting their views incorporated into the project is important not only to ensure everyone has a voice in the future of where they live, but to give the municipality a better understanding of how the project will affect its residents and businesses.

Other organizations, like health clinics, senior centers, and other community groups can also help reach out to diverse stakeholders. By serving as mediators and organizers, these organizations can coordinate community needs assessments, identify community priorities, and articulate trade-offs related to planning and development decisions.

The participatory budgeting model, which allows local community members to vote directly on how a portion of capital funds are spent in their neighborhood, could be adapted to allow local stakeholders to vote on trade-offs related to planning and development decisions (e.g., housing affordability, visual impacts, mobility, etc.).

Successful community engagement in the planning process is difficult, so states should make sure communities have the technical support and resources necessary to effectively undertake these efforts.

Planning and zoning boards and commissions should be diverse with respect to race, age, gender, and socioeconomic background

A substantial portion of development-application decisions are made at planning and zoning boards and commissions across the region. In many cases, these entities do not represent diverse demographic and socioeconomic backgrounds, areas of expertise, or perspectives. And with the exception of New York City’s community boards, non-resident workers who often have important ties to, and care deeply about, the communities in which they work are completely excluded from community planning and decision-making, despite being important contributors to the local economy. Even in New York City, where there is more diversity on boards and commissions than in other parts of the region, community planning boards are not necessarily representative of the residents and workers in their communities.

In order for planning and development decisions to become more inclusive, predictable, and economically efficient, the boards and commissions who have the ultimate say in voting on development proposals must become more diverse and reflective of a wider range of community perspectives. Municipalities should actively work to diversify boards and commissions and create mechanisms for including the voices of non-resident workers critical to the local economy, particularly with selection of individuals for appointed and volunteer positions over which they have direct control.


Planning and development approval processes that are more predictable, inclusive, and efficient will result in projects that better reflect the needs and aspirations of local communities, and better address potential development impacts. They will also reduce project timelines, and therefore municipal and developer costs, which can translate into higher quality developments. Open-source, community-driven data tools will enable municipalities to more easily integrate planning with assessment of community and regional costs and benefits.

Paying for It

Developing comprehensive municipal and neighborhood plans with full community engagement requires significant resources for staff, outreach, and technical studies. Centralizing data sources and creating replicable tools can help reduce costs, but the commitments are still substantial, especially for small municipalities. Technical assistance for planning and data gathering and distribution are two areas where the states can play an active role in providing resources to local municipalities, either through grant funds or direct staff assistance. Some municipalities could also benefit from multi-jurisdictional planning and shared resources, a collaboration states could incentivize.

1. State Environmental Quality Review (SEQR for jurisdictions outside NYC) and City Environmental Quality Review (CEQR) for development applications within the five boroughs.
2. Environmental impact assessment is mandated by law in New York State through the State Environmental Quality Review Act (SEQR). New York City has its own specific requirements for environmental review through CEQR. In Connecticut and New Jersey, environmental impacts are evaluated through environmental permitting processes and by individual municipalities through local land use regulations.