Since my comments can only be brief, My approach will be to outline my concerns more than explain the specifics which I hope others have addressed.
I have been a practicing architect in New York City for the last 20 years. During this time, I have had a continual “love/hate” relationship with the zoning resolution. I have used it to analyze potential sites, design buildings, and in the recent years, to prove compliance and obtain approvals of projects. It has fascinated me for its complexity. When I finally understand a portion of it and it works, I am Love with it. When it prevents good design or sound economic development, or when a word or two prevents the realization of a project , I have hated it.
To be honest with you, practicing architecture in New York City, and having to use the zoning resolution has been like “playing with fire.” Thrilling, risky, dangerous, and you sometimes get burned.
The Unified Bulk Program is perhaps the most ambiguous set of zoning changes proposed since the 1961 Zoning Resolution was adapted.
The Unified Bulk Program is based upon noble goals. It seeks to simplify often contradictory regulations. It recognizes that the current zoning resolution as it has evolved is ambiguous, incomprehensible and often unpredictable.
As an architect, I want a simple set of regulations that allow me to practice my craft. I want to be able to explain to a client exactly what can be built on a site. I want predictability but I also design flexibility.
This program contains many of the text changes we have requested for so long. I feel these are good aspects of this proposal:
In general I support the program as one that will make it easier to design. I feel that along with the good, there is bad. I reject the following aspects of the proposal.
Almost immediately after the adoption of the 1961 Resolution, the favorably of Corbusian like Tower in the Park zoning has been questioned.
I wish to remind the City Planning Commission that at the same time Jane Jacob’s wrote, the Life and Death of American Cities, Robert Venturi wrote “Complexity and Contradiction in Architecture”. Although predictability and simplicity are good. The rigidity of height limitations contradict the character of New York City. New York City needs to be livable and have a human scale , but it is an extremely complex City that thrives of contradiction.
I cant help feeling that Zoning Policy has an element of fashion. IN 1961 Tall slender building surrounded by open space was desirable. In the year 2000, short fat Buildings are in style. I have no preference for either, I want the ability to design both when appropiate. I would hate to be part of the Zoning Revisions of 2040 and look back and say our decisions were just based again upon fashion.
It seems clear to me that the primary concern of the height limitation is to restrict unbalanced Zoning Lot Mergers. I say, if that is the case, simply find a more honest and direct was to place limits of zoning lot mergers. Do not do it In a defacto fashion using height limits as the tool.
In conclusion, I hope that the positive elements are addressed in a global text change, while responding the need to design flexibility.