By Jennifer O’Donnell, Hone Strategic LLC
New York is currently at a high-stakes crossroads in urban and environmental policy. Whether we are discussing the Expedited Land Use Review Procedure (ELURP) in New York City or the proposed State Environmental Quality Review Act (SEQRA) revisions in Albany, the mandate is clear: we must ‘build at the speed of need’ to solve our housing crisis. I see a recurring structural risk in these ‘fast-track’ models. Speed is a necessary objective, but it cannot be achieved by dismantling the very review processes that ensure development is compatible with our physical, historical, and climate limits. True efficiency in land use isn’t about bypassing scrutiny; it’s about refining it to incentivize growth where it is most sustainable. My analysis suggests a deeper structural risk.
Moving at the Speed of Need
Last week, NYC’s new Expedited Land Use Review Procedure (ELURP) underwent its first real-world tests (see Shelterforce story). With the Mamdani Administration and the Department of City Planning aiming to reduce review times from seven months to just 90 days, the “Manhattan Plan” is officially in motion.
I view this as a fascinating yet precarious crossroads, similar to the one we face with SEQRA in New York State.
There is consensus that the status quo is broken. We need at least 100,000 new homes in New York City and have a shortage of more than 800,000 in New York State, according to figures being used in Albany. However, the “Fast Track” approach requires more than just speed—it requires adaptation, resilience, and agency.
The new measures emphasize the 12 community districts with the lowest affordable housing production. While increasing density is a mechanical solution to the supply crisis, we must be cautious not to lose the character that defines our 19th-century commercial streetscapes.
I believe this new era calls for three key pillars:
- Adaptive Integrity: Speed should facilitate the adaptive reuse of historic structures. “The greenest building is the one already built” (i.e., embodied energy is more environmentally sound than new construction) is a longstanding motto of the National Trust for Historic Preservation.
- Climate-Resilient Infrastructure: The ELURP includes “climate-resilient infrastructure.” This must be a priority, ensuring regenerative land management is integral to every new urban site plan.
- Community Agency: Streamlining should not equate to silencing.
True success in expediting occurs when developers engage early and authentically, rather than waiting for a 90-day clock to start.
The objective is not merely to construct “units,” but to develop neighborhoods. To my fellow planners and developers: How are you preparing for the January 2027 rollout of the full “City of Yes” framework? Are we ready to build at the speed of need while preserving the quality our unique city demands?
Let’s Go Further: Focusing Reforms on Sustainable, Environmentally Just Housing
As Albany nears a final budget agreement, a critical debate is unfolding over SEQRA. While the goal is to accelerate housing, the current legislative language contains technical gaps that could undermine local planning.
“….focusing growth precisely where it is most sustainable: in areas already served by robust infrastructure, transit access, and walkable neighborhood centers. Rather than allowing sprawl to hide behind vague definitions, these changes ensure that ‘fast-tracked’ housing is built in the locations best equipped to support it”
In my work as an environmental strategist and urban planner, I’ve raised these issues with state leadership. Here’s what matters most:
- The “Disturbed” Definition: Current proposals broadly define “disturbed land” to include maintained lawns. This risks bypassing reviews for subsurface archaeological resources and critical pervious landscapes.
- The Sprawl Loophole: We must ensure that a minor existing road or structure isn’t used to classify a massive greenfield site as “previously disturbed,” allowing large-scale sprawl to skip traditional environmental scrutiny.
- Infrastructure Reality: Fast-tracking cannot ignore physical limits. Without mandatory water and sewer capacity analysis, we risk overwhelming local systems and degrading environmental health.
Critically, adopting these technical refinements will not hinder the delivery of new housing. On the contrary, by narrowing the ‘previously disturbed’ and ‘mixed-use’ definitions, the State provides a clearer, more predictable roadmap for the development community. These revisions act as a strategic incentive, focusing growth precisely where it is most sustainable: in areas already served by robust infrastructure, transit access, and walkable neighborhood centers. Rather than allowing sprawl to hide behind vague definitions, these changes ensure that ‘fast-tracked’ housing is built in the locations best equipped to support it, thereby reducing the likelihood of the very infrastructure failures and legal challenges that currently stall production.
While many advocates, including Ulster County Executive Jen Metzger, suggest that “tweaking” the bill to include affordability and sustainability standards is enough, my analysis suggests a deeper structural risk. While I support those goals, adding “criteria” to an exemption is an honor-system approach. The review process itself is the only way to verify infrastructure capacity and prevent industrial-scale energy users from hiding behind residential facades and honor the intent of CLCPA’s climate and environmental justice goals.
SEQRA is not a substitute for local planning and zoning, but it is the essential “hard look” that ensures development is compatible with a community’s physical limits. Efficiency must not come at the cost of evidence-based decision-making.
Ultimately, the goal of these recommendations—whether tightening the definition of ‘previously disturbed land’ upstate or ensuring community agency within the ‘City of Yes’ framework —is to move from a culture of delay to one of strategic acceleration.
By ensuring our environmental reviews are precise rather than permissive, we provide a clearer, more predictable roadmap for developers while protecting our aging infrastructure and the character of our neighborhoods. We do not have to choose between housing production and environmental integrity; in fact, the most resilient housing is that which respects the ‘hard look’ required by our state and city laws. As we move toward full implementation of these new frameworks, let’s ensure we are not just constructing ‘units,’ but developing the sustainable, equitable neighborhoods that the next generation of New Yorkers deserves.
Jennifer O’Donnell is the founder of Hone Strategic. She has lived in the Hudson Valley since 2004, where she has worked with numerous communities and organizations to plan and implement projects in historic sites and neighborhoods. Prior to this, she was a cultural heritage specialist and planner at the World Bank, where she was involved with World Heritage sites and cities in over 30 places abroad. Jennifer was also a design and construction project manager for many historic buildings and cultural institutions in her native New York City. She has Masters’ degrees from Columbia University in Urban Planning and Real Estate Development, a BA in Art History from SUNY Stony Brook, and studied conservation at UNESCO’s ICCROM program in Rome, Italy.