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Why Does This Building by the Subway Need 193 Parking Spots? (Yes, Exactly 193.)

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Why Does This Building by the Subway Need 193 Parking Spots? (Yes, Exactly 193.)

A rendering of the new apartment building at 975 Nostrand Ave. in Brooklyn. Underground parking spaces not shown.

Lemons Bucket

The apartment building under construction at 975 Nostrand Avenue in Brooklyn is the kind of project that city officials and economists say New York needs to solve the city’s severe housing shortage.

It will have 328 new homes at rents targeting young professionals, from studios up to three-bedrooms, with a grocery store on the ground floor.

But the ability to construct these homes, at this location, turns on a peculiar problem: How do you also find a place to park 193 cars on this lot?

The site is about one block from the subway.

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To fit ample parking here, the builders had to excavate 14 feet underground. And some of this cellar space is needed for utilities and storage.

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The remaining space is irregular. These are the structural columns supporting the apartments above.

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And here’s where you fit the cars.

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Actually, that’s only 146 of them. To accommodate the remaining cars, each spot here holds a two-car mechanical stacker.

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(This is the actual diagram submitted to the New York Department of Buildings for review.)

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This Brooklyn building is subject to a powerful but obscure force operating in communities all over the country: the parking minimum. Every one of its 193 parking spaces is prescribed by the city’s zoning code, in dizzying detail.

The project must provide, at minimum, half a parking spot for each housing unit; one parking spot for every 400 square feet of retail and art gallery inside; and one spot for every 300 square feet of space in part of the planned grocery store (the other part of the grocery store is exempt from parking, and we’re sorry but only a land use lawyer can explain this).

New York is now proposing to radically simplify requirements like this by ending parking mandates on all new housing citywide. The move could make it cheaper and faster to construct new homes amid a housing affordability crisis, and it would make New York the latest American city to toss out decades-old parking rules. But as a movement to end parking minimums gains traction across the country, what happens in New York will be revealing: In the least car-dependent big city in America, the instinct to accommodate cars may still prove stronger than fears about the shortage of homes.

“These rules were written at a time when cars defined everything,” said Dan Garodnick, the head of New York’s Planning Commission.

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It was a moment when cities were first racing to adapt to cars and compete with suburbs full of plentiful parking. “We are in a different era today,” he said.

That assessment will be put to the test in the coming weeks, as the City Council is set to vote on the change as part of a broader package of housing measures.

Mr. Garodnick is quick to clarify that the administration is not proposing to end parking in residential buildings — just the required minimums. Developers will still build parking, he reasons, where there’s demand for it (and in fact, today some build more than the minimum). But they’ll also have the option to build none.

Those opposed to the change are skeptical of its benefits: “I don’t see where less parking means there’s greater affordability,” said Fred Baptiste, the chair of Community Board 9, where 975 Nostrand sits. “It just means there’s less parking.”

Six Parking Spots Per Bowling Lane

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Cities and towns nationwide have had parking minimums sitting unquestioned in their zoning codes for half a century. But in recent years, dozens of cities have removed them. Buffalo was among the first in 2017. Austin, Texas, last year became the largest U.S. city to do so.

As housing has grown more expensive across the country, cities have increasingly realized that parking can make the problem worse, raising the cost and complexity of development, even discouraging the construction of homes.

Construction costs run from $10,000 per parking space in a surface lot to $70,000 per space in an underground garage. That gets baked into what developers must recoup from tenants and buyers, whether they own a car or not. The rules drive up the per-unit cost to build affordable housing (in New York, affordable units near transit are exempt from parking minimums, but the rules still apply elsewhere). And they often require more parking than people actually use.

The mandates began in the 1950s and ’60s as mass car ownership expanded beyond the capacity of on-street parking. Minimums in New York were introduced in 1950 for new residential buildings. The city’s 1961 zoning code (the one still in place today) raised the requirements and added them for offices, retail and other building types. In New York and elsewhere, the rules typically take the form of ratios that have been copied from one city to another, handed from one generation of engineers to the next without much study or skepticism.

A Sample of Minimum Parking Rules

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0.5 parking spots per unit plus 1 parking spot per employee

Senior Housing in Vallejo, Calif.

2 parking spots per dwelling unit

Manufactured Home in Knoxville, Tenn.

1 parking spot per 2 beds

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Monastery/Convent in Savannah, Ga.

1.25 parking spots per dwelling unit

Efficiency Apartment in Fargo, N.D.

1 parking spot per 4 rooms

Rooming House in New Orleans

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1 parking spot per 2 beds

Fraternity/Sorority in Baltimore

2 parking spots per dwelling unit plus garage

Single-Family Home in Oklahoma City

1 parking spot per million gallons of capacity

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Sewage Treatment Plant in Dallas

1 parking spot per 100 sq. ft.

Haunted House in Gilbert, Ariz.

1 parking spot per 8 occupants plus 1 spot per 2 employees

Cemetery in Carver, Mass.

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1 parking spot per 10 migrants at max capacity

Migrant Labor Camp in Queen Anne’s County, Md.

10 parking spots per 1 mile of trail

Nature/Bike Trail in Jefferson Hills, Pa.

1 parking spot per 250 sq. ft. of office/retail area

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Butterfly/Moth Breeding in SeaTac, Wash.

6 parking spots per lane

Bowling Center in Folsom, Calif.

1 parking spot per 50 sq. ft. of floor area

Night Club in Port Angeles, Wash.

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8 parking spots per green

1 parking spot per 10 children plus 1 per employee

Child Care Center in Charlotte, N.C.

1.2 parking spots per bed

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3 parking spots per court

Tennis Club in Rochester, N.Y.

1 parking spot per 100 sq. ft. of sanctuary seating area

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1 parking spot per 60 sq. ft. of batting area

1 parking spot per 50 sq. ft. water surface plus 1 spot per 2 employees

Swimming Pool in Allentown, Pa.

“People just assume these numbers are right because they’re in the zoning code,” said Tony Jordan, who runs the Parking Reform Network, which advocates ending minimums. “No, they’re just made up.”

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Beyond increasing construction costs, the rules have squeezed out of existence many common prewar urban housing forms, like four-unit apartment buildings on lots too small for parking. Mandates have meanwhile produced their own specific kinds of places: stores surrounded by surface lots, strip malls wrapped around parking, apartment complexes that have no ground-floor retail because the ground floor is full of cars.

And because the rules apply broadly, they can require parking in subsidized housing for low-income households least likely to own a car. They can force builders to construct 350 square feet of garage space for a 400-square-foot studio.

Given that cities have only recently begun to change these rules, there’s limited evidence of what happens after they’re gone. In the first years after Buffalo ended parking minimums, about half of new developments built fewer parking spaces than they were previously required to, supporting the idea that the standards are too high for some properties, too low for others.

Proponents also hope that by ditching parking mandates, cities communicate another message: “If you require a place to park a car, you’re automatically saying a car is welcome,” said Felicity Maxwell, a planning commissioner in Austin who voted to end minimums there last year. And many of the prewar buildings and neighborhoods cherished today are places that have long thrived without welcoming cars.

Compared with Austin and Buffalo, New York is proposing a half-measure: to end mandates only for housing (at 975 Nostrand, for example, the retail space would still require some parking). Mr. Garodnick demurred on whether ending all minimums would be a logical future step for the city.

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An Expensive Hole in the Ground

New York is also a particularly tough place to create parking. Land is so scarce and valuable that it seldom makes sense to use it just to park cars. 975 Nostrand was originally a single-story grocery store with a large parking lot. Now it will become home to 500 to 600 people, with a grocery store on the ground floor.

But making the best use of that limited space means developers frequently turn to the hardest possible parking solution: putting it underground.

“When you go below grade in New York City, you are talking about the most expensive and the most risky part of a project,” said Sam Charney, principal of the developer Charney Companies. His worst construction horror story involved a mixed-use building that required two levels of underground parking in a corner of bustling Williamsburg in Brooklyn. He thought the parking actually necessary was none.

Before Charney Companies built The Dime in Williamsburg, it first dug this 30-foot-deep hole (while propping up the neighboring properties) for a two-story underground garage.

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Charney Companies LLC

Excavation is costly and onerous. Neighboring buildings must be underpinned. Buried oil tanks and boulders get in the way. Below the water table, everything must be waterproofed. And all of this adds months to construction, during which time developers are carrying large loans.

Parking stackers help save space by lifting cars up so others can park underneath. But then garages require parking attendants to operate them — and that’s another cost someone has to pay.

All of this is further complicated by the fact that the exact quantity of parking required depends on how the land at a given site is zoned.

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Here are just the few blocks around 975 Nostrand:

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Buildings across the street from each other are often zoned differently.

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And each zone has its own minimum parking ratios for housing.

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Source: New York City Zoning & Land Use Map

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Certain zones also exempt parking on the first five or 15 housing units, incentivizing builders to stay below that cutoff — or to carve lots up into several smaller buildings with fewer total housing units.

“You really don’t want to build a bigger building than you can provide parking for,” said David West, an architect.

These trade-offs for developers don’t garner a lot of sympathy with New Yorkers who have a more prosaic concern: where to park after a long work day or when there’s a hungry child in the back seat. The community board that encompasses the Nostrand development opposes getting rid of the minimums, as do politicians representing parts of the city that don’t have good transit access.

“For Staten Islanders, it’s almost impossible to not have at least one car per household,” said Joseph Borelli, who represents southern Staten Island as minority leader of the City Council.

Source: New York Times survey; New York City Zoning Application Portal

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The City Planning Commission expects that the greatest change to come from ending parking mandates would be in the “inner outer” boroughs — not in the lowest-density neighborhoods that have opposed it the most, but in places like Nostrand Avenue in Crown Heights. That’s where the gap is widest today between the quantity of parking required and the demand for it around public transit. In the densest parts of the city — much of Manhattan, and Long Island City in Queens — parking minimums are already waived (Manhattan, in fact, has had parking maximums since 1982, in a bid to reduce car travel and improve air quality).

Some suggest the city should more narrowly tailor its proposal rather than sweep away requirements citywide. But that would be an extension of what New York has done for years — carving out piecemeal exemptions for certain geographies, lot sizes, affordability levels and building amenities, until it has arrived at an intricate web of parking rules.

To proponents of ending minimums, the citywide simplicity is part of the point: The requirements aren’t just arbitrary near the subway; they are arbitrary everywhere because a prescribed ratio can never be just right for every lot. And even on Staten Island, lifting the minimums might allow someone to build an accessory dwelling unit — without extra parking — in the backyard. That would serve the city’s housing goals too.

At 975 Nostrand, where the developer Hudson Companies is about a year away from completing the building, the managing director of development, Marlee Busching-Truscott, struggled to estimate exactly how much parking would have been built if that number weren’t dictated by a zoning table. This is one of the other distortions of parking mandates. Developers typically try to study the market for nearly every facet of a project — the mix of apartment sizes, the targeted rents, the building amenities, the outdoor spaces, the kitchen finishes. But they don’t do that basic exercise for something as costly and sizable as a parking garage, because they have little choice in the matter.

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Though Ms. Busching-Truscott couldn’t say exactly how the building would have taken shape without parking minimums, “I don’t think we would have gotten to 193 spaces that would have required having a fully excavated cellar and a chaotic layout.”

That result speaks to the building’s essential paradox: “This is transit-oriented development,” she said, “that you’re still building around the car.”

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Map: 2.3-Magnitude Earthquake Strikes Connecticut

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Map: 2.3-Magnitude Earthquake Strikes Connecticut

Note: Map shows the area with a shake intensity of 3 or greater, which U.S.G.S. defines as “weak,” though the earthquake may be felt outside the areas shown. The New York Times

A minor, 2.3-magnitude earthquake struck in Connecticut on Wednesday, according to the United States Geological Survey.

The temblor happened at 7:33 p.m. Eastern about 1 mile northwest of Moodus, Conn., data from the agency shows.

As seismologists review available data, they may revise the earthquake’s reported magnitude. Additional information collected about the earthquake may also prompt U.S.G.S. scientists to update the shake-severity map.

Aftershocks in the region

An aftershock is usually a smaller earthquake that follows a larger one in the same general area. Aftershocks are typically minor adjustments along the portion of a fault that slipped at the time of the initial earthquake.

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Quakes and aftershocks within 100 miles

Aftershocks can occur days, weeks or even years after the first earthquake. These events can be of equal or larger magnitude to the initial earthquake, and they can continue to affect already damaged locations.

Source: United States Geological Survey | Notes: Shaking categories are based on the Modified Mercalli Intensity scale. When aftershock data is available, the corresponding maps and charts include earthquakes within 100 miles and seven days of the initial quake. All times above are Eastern. Shake data is as of Wednesday, Nov. 20 at 7:41 p.m. Eastern. Aftershocks data is as of Wednesday, Nov. 20 at 11:34 p.m. Eastern.

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Two Affordable Housing Buildings Were Planned. Only One Went Up. What Happened?

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Two Affordable Housing Buildings Were Planned. Only One Went Up. What Happened?

It is an idea that many point to as a solution for New York City’s worst housing shortage in over 50 years: Build more homes.

More people keep deciding they want to live in the city — and the number of new homes hasn’t kept pace. Residents compete over the limited number of apartments, which pushes rents up to stratospheric levels. Many people then choose to leave instead of pay those prices.

So why is it so hard to build more housing?

The answer involves a tangled set of financial challenges and bitter political fights.

We looked at two developments that provided a unique window into the crisis across the city, and the United States, where there aren’t enough homes people can actually afford.

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Both developments — 962 Pacific Street in Crown Heights in Brooklyn, and 145 West 108th Street on the Upper West Side in Manhattan — might have appeared similar. Both were more than eight stories, with plans for dozens of units of affordable housing. And each had a viable chance of being built.

But only one was.

Here’s how their fates diverged, from the zoning to the money and the politics.

The Neighborhood

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The lack of housing options across the region makes high-demand areas particularly expensive.

Homes are built in Westchester County and the Long Island suburbs, for example, at some of the slowest rates in the country. In New York City, only 1.4 percent of apartments were available to rent in 2023, according to a key city survey.

And median rent in the city has risen significantly over the past few decades.

Source: U.S. Census Bureau

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That leaves neighborhoods like the Upper West Side and Crown Heights sought after by people of all income levels. Both neighborhoods have good access to parks, subways and job centers in Brooklyn and Manhattan.

The pressures are immense, even as each neighborhood has added some new housing to try to match the demand, though at different rates.

Crown Heights has become one of the most striking emblems of gentrification in the city, with new residents, who tend to be white and wealthy, pushing out people who can no longer afford to live there. Low-rise rowhouses line many streets, just blocks from Prospect Park. But there are also shiny new high-rises.

There were more than 50,000 housing units in the Crown Heights area, according to a 2022 U.S. Census Bureau estimate, a roughly 13 percent jump over the past decade.

The Upper West Side has long been one of the city’s more exclusive enclaves with many brownstone homes. Next to Central Park and Riverside Park, with easy access to downtown, the neighborhood is home to many of the city’s affluent residents.

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There were 129,000 housing units on the Upper West Side according to the 2022 Census Bureau data, an increase of roughly 5 percent over the same time period.

The Lot

There isn’t as much empty land left in New York City compared with places like Phoenix or Atlanta, which can expand outward. City developers have to look hard to find properties with potential, and then they have to acquire the money to buy them.

The empty lot in May 2021.

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Google Street View

Between the two proposals, the Crown Heights site seemed to be more promising at first glance. Until 2018, it was just vacant land that local businesses sometimes used as a parking lot. The developer, Nadine Oelsner, already owned it, removing a potential roadblock that can often tie up projects or make them financially unworkable.

One of three aging parking garages in September 2015.

Google Street View

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On the Upper West Side, though, the site was already occupied by three aging parking garages with a shelter and a playground in between. The garages would need to be demolished if the developer, a nonprofit known as the West Side Federation for Senior and Supportive Housing that operated the shelter, succeeded in its plan to build apartments on either side of the playground.

The new development, which was floated to the community in 2015, would also include a renovated and expanded shelter. And the nonprofit did not own the garages or the land — the city did.

One thing working in the group’s favor, though, was that the city had wanted to build housing on the site since at least the mid-2000s, according to planning documents.

Source: West Side Federation for Senior and Supportive Housing

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The Zoning

But something invisible can matter more than a plot’s physical characteristics: zoning.

That governs how every piece of land in New York City can be used. Zoning determines, for example, whether homes or warehouses are allowed in a particular area, how much parking is needed and how tall a building can be.

It also aims to prevent growth in haphazard ways, with schools next to factories next to office buildings.

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The city’s modern zoning code does not leave much room for growth, which means that a bigger building often requires a zoning change. One 2020 study by the nonprofit Citizens Budget Commission found that only about one residentially zoned plot in five would allow for that kind of additional housing. A zoning change triggers a lengthy, unpredictable bureaucratic process.

The site Ms. Oelsner owned was zoned for industrial, not residential use, a throwback to a time when that part of Brooklyn was dominated by businesses supported by the nearby railroad line.

Community leaders were frustrated by one-off changes to individual lots — there had been at least five zoning changes within a two-block radius of Ms. Oelsner’s site in recent years. To counter the trend, the community decided to come up with a bigger rezoning plan for the area. Ms. Oelsner saw an opportunity for her lot in that idea.

But she would need a zoning change, too.

Sources: OpenStreetMap, New York City Department of City Planning

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The site on the Upper West Side had a slight edge: It was zoned for residential use.

As the project began to move forward, the city also sought a slight zoning change to allow for a bigger structure with more homes.

Sources: OpenStreetMap, New York City Department of City Planning

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The Proposal

U.S. housing is mostly built and run by the private sector. If developers and owners can’t cover their costs with income from rents and sales — and make a profit — they most likely won’t build.

This can make it hard to keep rents affordable to potential tenants without big subsidies from the government, such as money a developer receives directly or tax breaks in exchange for making some units affordable for people at specified income levels.

Here are more details of what the two developers planned.

The proposal for the Crown Heights lot was by Ms. Oelsner and her company, HSN Realty, who were private developers working without city support.

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Ms. Oelsner also made the case that her family had been part of the community for years, operating a Pontiac dealership.

Most of the apartments she proposed would rent at market rates, meaning the rents could be set as high as the landlord thought tenants could pay. This was similar to other new buildings in the area.

In Ms. Oelsner’s case, a government subsidy would likely come in the form of a decades-long property tax exemption.

In exchange, several apartments would be made “affordable” — in this case, rents would be capped at a certain percentage of gross household income for particular groups.

Under one plan, for example, 38 units would be restricted in this way. Of those, 15 might rent for around $1,165 for a one-bedroom apartment, or $1,398 for a two-bedroom.

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Source: West Side Federation for Senior and Supportive Housing

The proposal from the West Side Federation had a much stronger case because of the city’s support. The group wanted to construct a building where all the apartments would rent below market rates and be targeted to some of the city’s poorest residents.

Most units would rent to people who were formerly homeless, often referred from shelters and typically relying on government-funded voucher programs to pay almost all of their rent. The remaining apartments would rent for between $865 and $1,321.

The West Side Federation said it had slowly built trust in the community over decades, in part because of the shelter it already operated on the street and was now expanding, as well as two dozen other area buildings it ran.

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Because of that track record, and the need for affordable housing, the city decided to do several things. It essentially gave the developer the land — appraised at about $55 million — for free, a typical government practice in such a scenario.

It also chipped in $9 million to help pay for construction and another $33 million through a federal tax credit program. The West Side Federation would not have to pay property taxes on the development.

The Politics

Both projects met immediate opposition as they began to wade through a bureaucratic city process in which housing proposals often run into challenges from community members and politicians. It’s not unusual for this process to be costly and time-consuming, often taking more than two years.

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In fact, this is where Ms. Oelsner’s project in Crown Heights met its end.



Informal project discussions

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These discussions between the developer, the community and the government about the project can determine its fate early. They helped shape both the Crown Heights and the Upper West Side proposals.

Application filed with the city

An application is filed with the City Planning Department and is considered certified if it properly describes the proposal and any zoning change.

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Over 60 days, the community board holds a public hearing. The Upper West Side project was recommended for approval while the Crown Heights project wasn’t. This isn’t binding so the Crown Heights proposal still moved ahead.

Over 30 days, the borough president’s office might hold another public hearing and issue its own recommendation. Both projects were recommended for approval.

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City Planning Commission review

Over 60 days, the commission may hold another public hearing and vote on whether to allow the project to move forward. Both projects were approved.

Here’s where things ended for the Crown Heights project, which was rejected by the council member from the area. The Upper West Side project was approved.

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The mayor has the option to veto a project, and the City Council can override that veto. In this case, the Upper West Side project was not vetoed.

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Informal project discussions

These discussions between the developer, the community and the government about the project can determine its fate early. They helped shape both the Crown Heights and the Upper West Side proposals.

Application filed with the city

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An application is filed with the City Planning Department and is considered certified if it properly describes the proposal and any zoning change.

Over 60 days, the community board holds a public hearing. The Upper West Side project was recommended for approval while the Crown Heights project wasn’t. This isn’t binding so the Crown Heights proposal still moved ahead.

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Over 30 days, the borough president’s office might hold another public hearing and issue its own recommendation. Both projects were recommended for approval.

City Planning Commission review

Over 60 days, the commission may hold another public hearing and vote on whether to allow the project to move forward. Both projects were approved.

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Here’s where things ended for the Crown Heights project, which was rejected by the council member from the area. The Upper West Side project was approved.

The mayor has the option to veto a project, and the City Council can override that veto. In this case, the Upper West Side project was not vetoed.

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Informal project discussions

These discussions between the developer, the community and the government about the project can determine its fate early. They helped shape both the Crown Heights and the Upper West Side proposals.

Advertisement

Application filed with the city

An application is filed with the City Planning Department and is considered certified if it properly describes the proposal and any zoning change.

Advertisement

Over 60 days, the community board holds a public hearing. The Upper West Side project was recommended for approval while the Crown Heights project wasn’t. This isn’t binding so the Crown Heights proposal still moved ahead.

Over 30 days, the borough president’s office might hold another public hearing and issue its own recommendation. Both projects were recommended for approval.

City Planning Commission review

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Over 60 days, the commission may hold another public hearing and

vote on whether to allow the project to move forward. Both projects

were approved.

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Here’s where things ended for the Crown Heights project, which was rejected by the council member from the area. The Upper West Side project was approved.

The mayor has the option to veto a project, and the City Council can override that veto. In this case, the Upper West Side project was not vetoed.

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In Crown Heights, neighbors wanted more apartments to be available at lower rents and were concerned about parking. Ms. Oelsner worried the bigger rezoning plan of the area would take too long and, if she waited, would run up the costs of her project, which she said she had designed to be consistent with the broader efforts.

In the end, Crystal Hudson, who held the power to approve or reject the development as the local council member, voted against Ms. Oelsner’s proposal last year, effectively killing the project. Ms. Hudson said she would not back individual developments until the bigger neighborhood rezoning was finished.

On the Upper West Side, a vocal resident group had several complaints: that the loss of the parking garages could lead to an uptick in traffic, greenhouse gas emissions and accidents; that the development could disturb students at a nearby middle school; and that it could reduce the amount of sunlight in nearby parks.

The councilman who represented the neighborhood at the time, Mark Levine, initially said he would hold off on supporting the plan until he better understood the effects of more cars on the street.

Eventually, though, the project gave the community enough of what it wanted, the group behind the project said, and government officials came around. The project was split into two phases, keeping one garage running for a few years after the first two were demolished.

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The Results

One key to successful development is buy-in from the government and local politicians. The Upper West Side plan had that, despite the opposition it faced, while the Crown Heights project did not.

That’s in part because the Upper West Side lots were owned by the city, which was ready and willing to chip in lots of money to create a deeply needed housing project in the area that would most likely not have been built otherwise. The Crown Heights lot, on the other hand, is privately owned and mostly out of the city’s control — which made the project potentially very lucrative for the owners, even if it added some benefit to the community.

Hiroko Masuike/The New York Times

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The dirt lot in Crown Heights remains a dirt lot. The broader plan Ms. Hudson pushed is underway, set to be completed next year.

Ms. Oelsner, however, has said that she’s not sure whether it still makes financial sense to build her project, so its fate remains uncertain.

Hiroko Masuike/The New York Times

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The Upper West Side building has been open for about two years. It is full and has a long waiting list.

And the amount tenants pay in rent remains low. That’s because the government sends the West Side Federation about $1 million annually to help cover the rent.

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Read the Trump Assassination Plot Criminal Complaint

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Read the Trump Assassination Plot Criminal Complaint

and committed out of the jurisdiction of any particular State or district of the United States,
FARHAD SHAKERI, CARLISLE RIVERA, a/k/a “Pop,” and JONATHAN LOADHOLT, the
defendants, and others known and unknown, at least one of whom is expected to be first brought
to and arrested in the Southern District of New York, knowingly and willfully did combine,
conspire, confederate, and agree together and with each other to commit murder-for-hire, in
violation of Title 18, United States Code, Section 1958.
6. It was a part and an object of the conspiracy that FARHAD SHAKERI,
CARLISLE RIVERA, a/k/a “Pop,” and JONATHAN LOADHOLT, and others known and
unknown, would and did knowingly travel in and cause others to travel in interstate and foreign
commerce, and would and did use and cause another to use a facility of interstate and foreign
commerce, with intent that a murder be committed in violation of the laws of the State of New
York or the United States as consideration for the receipt of and as consideration for a promise or
agreement to pay anything of pecuniary value, to wit, SHAKERI, RIVERA, and LOADHOLT
participated in an agreement whereby RIVERA and LOADHOLT would kill Victim-1 in exchange
for payment, and used cellphones and electronic messaging applications to communicate in
furtherance of the scheme.
(Title 18, United States Code, Sections 1958 and 3238.)
COUNT FIVE
(MONEY LAUNDERING CONSPIRACY)
7. From at least in or about December 2023, up to and including the date of
this Complaint, in Iran, the Southern District of New York, and elsewhere, and in an offense begun
and committed out of the jurisdiction of any particular State or district of the United States,
FARHAD SHAKERI, CARLISLE RIVERA, a/k/a “Pop,” and JONATHAN LOADHOLT, the
defendants, and others known and unknown, at least one of whom is expected to be first brought
to and arrested in the Southern District of New York, knowingly and willfully did combine,
conspire, confederate, and agree together and with each other to commit money laundering, in
violation of Title 18, United States Code, Section 1956.
8. It was further a part and an object of the conspiracy that FARHAD
SHAKERI, CARLISLE RIVERA, a/k/a “Pop,” and JONATHAN LOADHOLT, the defendants,
and others known and unknown, in an offense involving and affecting interstate and foreign
commerce, knowing that the property involved in certain financial transactions represented the
proceeds of some form of unlawful activity, would and did conduct and attempt to conduct such
financial transactions which in fact involved the proceeds of specified unlawful activity, to wit,
the proceeds of the murder-for-hire offenses charged in Counts Three and Four of this Complaint,
knowing that the transactions were designed in whole and in part to conceal and disguise the
nature, location, source, ownership, and control of the proceeds of said specified unlawful activity,
in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i).
9. It was further a part and an object of the conspiracy that FARHAD
SHAKERI, CARLISLE RIVERA, a/k/a “Pop,” and JONATHAN LOADHOLT, the defendants,
and others known and unknown, would and did transport, transmit, and transfer, and attempt to
transport, transmit, and transfer, monetary instruments and funds to a place in the United States
3

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