New York City Housing Preservation and Development (HPD) Deputy Commissioner Enderlins obfuscating response to my recent article

defends the Bloombergian trickle-down approach to neighborhood planning and stands in stark contrast to the efficient and equitable plan for City-sponsored community development called for by Mayor de Blasio. The rejoinder quibbles about the semantics of exactly how the Garvey and the Bradford relate to each other in the Citys broken inclusionary housing program, and misleads readers to imply that these projects were developed under a fixed master plan. In fact, the description of the 2008 acquisition loan to Goldman Sachs/BRP states that all affordable units will serve tenants earning less than 130% of HPDs Area Median Income, yet all 83 of the Bradfords high-rent units have income limits 27-50% higher. It is bad policy to think that building one affordable housing building with public land, $10.7 million in City subsidies, and $7+ million Federal LIHTC subsidy investment (the 73 unit Garvey) automatically grants Goldman Sachs/BRP the privilege to build a separately financed high-rent and over-subsidized building (the 105 unit Bradford) on nearby public land. Mr. Enderlin claims that my concerns about affordability in the Bradford amount to support of segregation by income. Arguing that a building constructed predominantly on free public land, using tens of millions of dollars in City subsidies, should reflect the needs of Bedford Stuyvesants diverse residents is the opposite of a call for segregation; in fact, it is a rallying cry for inclusion. The higher-rent units in the Bradford (comprising 83 out of 105 total apartments) were subsidized in part through the Citys New HOP Middle Income Program, yet the minimum income required to apply to the cheapest of the Bradfords middle income two bedroom units is 60 percent higher than the median (the middle) household income for New York City. Having high-rent units in an affordable building is good public policy, yet they should not compromise 80 percent of all units. In 2010, almost three-quarters of Bedford Stuyvesant residents earned less than $63,400, and in 2011 over half of all households in the entire city earned less than $50,400. 75 percent of neighborhood residents, and indeed the majority of residents citywide, would need to pay over 40 and 50 percent of their pre-tax income, respectively, to afford one of the Bradfords $2,300/mo apartments. This is not inclusive community development. Mayor de Blasios unifying agenda is One New York: Rising Together. The question still stands - how can the overwhelming majority of Bedford Stuyvesant residents rise together when they are priced out of new private developments and earn too little to even apply for a majority of the units in a City subsidized building like the Bradford? Enderlins claims distort the mechanics of New Yorks housing crisis and ignore the rise in inequality that plagues New York City. The affordable housing crisis in NYC is not about a lack of $2,000/month one bedroom apartments in Bedford Stuyvesant these apartments already exist in the neighborhood. The crisis is the story of working families unable to find housing, households facing eviction, overcrowding and displacement, 50,000 homeless individuals (21,000 of them children), closed waitlists for rental assistance, Federal retrenchment in housing programs, and a local real estate community that lobbies incessantly (and successfully) to unwind rent protections for millions of New Yorkers. It is the crisis being faced by Bedford Stuyvesant residents who, after helping transform the neighborhood from a symbol of urban decay to a flourishing community, are now struggling to stay in the community they fought to rebuild. De Blasio campaigned to hold developers feet to the fire, bargain harder, demand more, because [developers are] getting extraordinary value. He must have had over-subsidized and out-of-reach projects like the Bradford in mind. Unfortunately, HPD and its sister agency, the Housing Development Corporation (HDC), the public agencies entrusted to implement a multi-billion dollar housing plan, remain plagued by insufficient oversight and a culture of closed-door negotiations. As a result, buildings like the Bradford are over-subsidized despite agency neighborhood assessments showing significantly lower market rents and despite concerns raised by public servants about project costs. While recent efforts to increase transparency at HPD such as Local Law 44 are a step in the right direction, the law falls short of promoting true accountability. Full development budgets should be easily accessible online, not only to stimulate competition among the developers and contractors, but to ensure that public officials operate under the assumption that good-government watchdog groups and housing advocates are monitoring exactly what the City is spending taxpayer dollars on. With greater transparency would come greater efficiency; and HPD will need to operate more efficiently if Mayor de Blasio hopes to maximize the Citys limited resources to produce truly equitable community development. Mayor Bloombergs New Housing Marketplace Plan made impressive gains subsidizing housing for wealthier New Yorkers to move into relatively lower-income neighborhoods such as Harlem and Bedford Stuyvesant, yet fell short when it came to requiring significant permanently affordable housing in wealthier communities across the city. Mr. Enderlins rebuttal implies there is no alternative to this type of planning model. Actually, a more equitable alternative path is possible, and it involves creating and mandating economically integrated affordable housing in all of the Citys diverse neighborhoods, accessible to a broad spectrum of New Yorkers. This is exactly the sort of bold progressive change that the public expects from the de Blasio administration.