NYCLT letter on rule hearings

Dear Ms. Alexander:
Dear Mr. LiMandri:

Please distribute this letter to the Loft Board.

NYCLT was concerned to hear at the last Loft Board meeting that once again, rule publication has been delayed, this time because the Board is concerned that loft tenants will be confused by individual rules being published out of context.

While we appreciate the complexity of the Loft Board rules and the need to understand the connections between them, we are afraid that the continued delay is going to affect our ability to comment on the rules more than our comprehension of them. Without sufficient tenant testimony, the Board risks passing ill-considered rules.

We hope that the Loft Board is still interested in the on-the-ground experience and knowledge of tenants affected by the new law. The remaining 12 rules will have a huge impact on tenants and we hope that we will have proper time to read them and provide our perspective during public hearings. Each hearing should address one rule so that we can reasonably prepare testimony.

Most loft tenants work days and do not have time to come to Loft Board meetings every other week, and if the hearings are scheduled back-to-back, there is no way that we will be able to testify about how the rules affect us. We also doubt that Board members will have any chance to respond to our concerns if the hearings are too close together.

We call on the Loft Board to
release the draft rules now so that we can start learning how they affect us
schedule the hearings at a reasonable pace so that working people can attend
schedule one rule per hearing so that we can testify on each one
allow the Board to ask questions of people giving testimony
schedule time between hearings for the Board to adjust rules based on public comment

Thank you,
NYCLT

cc: Council Member Erik Dilan, Council Member Stephen Levin,
Brooklyn Borough President Marty Markowitz,
State Assemblyman Vito Lopez, State Assemblyman Joseph Lentol,
State Senator Daniel Squadron

Letter to LB on landlord incentives

To: NYC Loft Board
From: New York City Loft Tenants [NYCLT]

Dear Chairman LiMandri –
Dear Ms. Alexander –

NYCLT members were heartened at Thursday’s decision by the Loft Board to draft two sets for 2-06 Interim Rent Guidelines – one with a 0% increase and one with a single-year RGB increase, lesser for tenants who pay their for utilities. To reiterate we feel strongly that there should be no Interim Rent Increase before the statutory “compliance milestone” increases of 6-8-6%.

We agree with Mr. DeLaney that awarding landlords a rent increase before they reach any milestone in the compliance process is counter-productive and actually acts as a disincentive to start the work.

There were however some misconceptions that came up in discussion by the Board that we would like to comment on to add clarity.

It was insinuated that the first 6% statutory rent increase was a difficult and expensive first step for building owners. This is simply not true. The 6% increase is awarded to landlords upon submitting a provisional first draft of architect’s plans. Not only is the work solely architectural, but the plans don’t need to be complete or viable. The 8% increase does require negotiation with tenants in the Narrative Statement Process, and architectural and legal costs, but it is still before any material work is completed. Both of these milestones are achieved through paperwork and are awarded before an owner must spend any money on actual construction, materials or building labor. The implication that a landlord will be compelled to spend huge sums of money before getting any rent increases is inaccurate – owners will actually get a 14% rent increase before beginning any physical work or making any substantial cash outlay.

In making decisions about rent increases, the Loft Board should not underestimate its responsibility to foster sustainable neighborhoods. Making buildings safe from fire and collapse is an essential endeavor. Keeping entire communities with their history and culture safe from those who seek to uproot us is a valiant effort and something we hope the Loft Board can be truly proud of for years to come.

NYCLT

cc: Council Member Stephen Levin, Council Member Erik Dilan, Brooklyn Borough President Marty Markowitz, State Assemblyman Vito Lopez, State Assemblyman Joseph Lentol, State Senator Daniel Squadron