City of Yes–Zoning for Economic Opportunity

On Wednesday, January 24, the City Planning Commission will have the Mayor’s City of Yes (COY) Zoning for Economic Opportunity (ZEO) on its agenda for review. This meeting is open to the public and we will be testifying. We encourage any businesses that are interested to do so as well. 

The full agenda is available here. Page 2 has instructions for how to attend in person, virtually, or by phone. The virtual option will have instructions for testimony here one hour prior to the meeting. 

We wanted to share the general overview of Evergreen’s testimony and thinking on this proposal. The COY ZEO effort is much-needed, as our zoning code hasn’t been comprehensively updated in decades and often creates obstacles that stand in the way of business and job growth. The Department of City Planning (DCP) has been presenting the material as a series of 18 proposals (you can find a detailed breakdown of them in the second half of this document), and we believe that many of them would have a positive effect on making things easier and more conducive for economic growth. We are also quite pleased that there is no plan to add residential uses to the Industrial Business Zones (IBZs), which are the heart of our manufacturing communities throughout the city. However, we also have recommendations for changes to parts of the plan that likely would have negative impacts on M-zones, particularly IBZs, and the manufacturing businesses within them. 

The most significant changes to the M-zones are found in Proposal 18, “Create new kinds of zoning districts for future job hubs” of the COY ZEO framework, which will establish three new districts: M3A “Core” districts, M2A “Transition” districts, and M1A “Growth” districts. The undeniable benefit is that in all of these new districts, manufacturing uses will gain density in the form of increased Floor Area Ratio (FAR, defined here).

In M3A Core, we would like the non-industrial uses that are not compatible in a Core Manufacturing District to be limited to 10,000 square feet rather than 1.0 FAR. The Core should be a protected area for manufacturing businesses, which have so few as-of-right options on where to locate. The infringement of non-compatible uses has an effect of driving up land costs and making it more difficult to conduct business operations. 

In M2A Transition, we would like to see the density bonus applied with retention/creation of at least 1.0 FAR of manufacturing use, making it more of a requirement than an option to have manufacturing in these areas.

In M1A Growth, we would like to see a stronger incentive applied to be at least 1.0 of manufacturing added to any project seeking bonus density.

In all three of these areas, we strongly recommend the establishment of oversight mechanisms to ensure the uses are what they are supposed to be, and that whenever they are industrial they are actually feasible for industrial activity – meaning they have proper ceiling height, floor loads, and so forth.

It is important to note that none of these districts would be mapped as part of this effort if COY ZEO is passed by City Council at the end of this ULURP process. That would be done through neighborhood planning initiatives and private rezoning applications.

Additionally, we are supportive of the following other proposals in COY ZEO:

  • Proposal 3 to allow more opportunities for small-scale production, 
  • Proposal 4 to update loading requirements, 
  • Proposal 6 to update the zoning code and its use categories and parking regulations, and 
  • Proposal 17 to allow more waivers on bulking requirements to increase in-place growth. 

We believe that the following proposals have the potential to relieve pressure on M-zones and support them in concept: 

  • Proposal 5 on expanded commercial activity on upper floors,
  • Proposal 8 on updated rules for life science facilities,  
  • Proposal 9 on updated rules for nightlife,
  • Proposal 10 on updated rules for amusements, and 
  • Proposal 14 on more opportunities for micro-distribution

We have been advocating for our recommendations over the past several months in frequent conversations with DCP and City Council, at meetings of Community Board 1, Community Board 4, and the Brooklyn Borough President, and in conjunction with our partners in office and on the Industrial Jobs Coalition. We will continue to advocate for our community and strive to make sure the best version of this plan possible gets passed.

If you would like to learn more or have any questions, please contact Stephen Fabian at

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