Testimony before the New York City Council Committee on Land Use on Int. No. 1661: Legislation to Create a Comprehensive Urban Agriculture Plan
Nevin Cohen, Ph.D., Associate Professor, CUNY Graduate School of Public Health and Health Policy, Research Director, CUNY Urban Food Policy Institute
Dear Chairman Greenfield, Council Member Espinal, and Committee Members. My name is Nevin Cohen, and I am an Associate Professor of Health Policy at the CUNY Graduate School of Public Health and Research Director of the CUNY Urban Food Policy Institute. The CUNY Urban Food Policy Institute advances urban food equity by engaging with students, government officials, and advocates to produce evidence-based research, innovate new collaborative solutions, and provide policy guidance.
I have studied and written about NYC’s urban agriculture system for the past ten years. As the Policy Fellow of the Design Trust for Public Space I co-authored the report Five Borough Farm, the first comprehensive assessment of urban agriculture in New York City. I also co-authored the book Beyond the Kale: Urban agriculture and social justice activism in New York City, a study of the potential for urban agriculture to address racial, gender, and class disparities. I am currently leading a three-year evaluation of the Farms at NYCHA, an innovative public-private partnership that trains NYCHA youth while growing fresh produce for its residents.
I would like to express my strong support for Int. No. 1661. The need for an urban agriculture plan is detailed in the policy section of the Five Borough Farm report, which is appended to my testimony. Since 2012, when the report was published, new developments have only increased the importance of a plan:
New initiatives have been launched to make New York City healthier, just, and more resilient: Building Healthy Communities; Next Generation NYCHA; Housing New York; Age Friendly NYC; Zero Waste; Green Infrastructure; and others. Urban agriculture can contribute to achieving the goals of these programs, but only if it is fully integrated into program design. An urban agriculture plan would require conformity with these and other city plans, giving stakeholders the opportunity to identify how to integrate food production in programs that might otherwise not be viewed as relevant to urban agriculture.
Continuing conflicts between urban agriculture and competing land uses, most recently around HPD’s affordable housing initiative, highlight the need for a public process to decide how much urban agriculture is appropriate for NYC, where new urban farms and gardens should be located, methods to protect existing gardens and farms, and a process for supporting current and new farming and gardening activities.
As Beyond the Kale shows, the benefits people usually attribute to urban agriculture -- fresh food, green space, job training -- can mask and even exacerbate structural inequities. A planning process would involve the public in identifying and addressing disparities within the urban agriculture system, particularly disparate access to financial resources and land.
New forms of commercial urban agriculture – practiced indoors, in shipping containers, on rooftops – require reassessing zoning and related codes and regulations to ensure that these innovations are supported while also protecting community health, safety, and quality of life, with fair wages and working conditions for farmworkers. Council Member Espinal and Borough President Adams have committed substantial resources to agro-entrepreneurship, and a plan will identify and address obstacles to this emerging business sector.
Efforts to sustain regional agriculture, particularly in the Hudson Valley, have created opportunities for innovative links between peri-urban and urban farms. Incorporating regional agriculture in the urban agriculture plan would identify common needs and opportunities for shared infrastructure and supportive policy.
The following specific revisions would strengthen the legislation and resulting urban agriculture plan:
Identifying relevant agencies in Section 1(a) (e.g., HPD, EDC, DOB, DEP, DOH, and DOS) that have significant effects on gardens and farms, yet often are considered peripheral to urban agriculture, would ensure that the plan is developed with all agencies that influence land, infrastructure, public health, and organic waste. Agencies that address regional agriculture, like NYS Agriculture and Markets, should be involved as well.
The catalog of existing and potential urban agriculture spaces required in Section 1 (a) (i) should include public and private spaces, and should be easily accessible online.
In Section 1 (a) (ii), the classification and prioritization of urban agriculture uses should be based not only on food production potential but also on community needs and objectives (e.g., for open space) and the potential for agriculture to contribute to non-food municipal goals (e.g., physical activity, environmental management, job development, age-friendly spaces).
Existing and potential land use policies are required by Section 1 (a) (iii) to be evaluated for their ability to expand urban agriculture, but the term “land use policies” should include not only zoning but also related policies such as the uniform land use review process (ULURP) and the City Environmental Quality Review process (CEQR).
Section 1 (a) (iv) should be clarified to require DCP to consider the impacts of all relevant codes on urban agriculture, including but not limited to the three listed. Sanitation, water, transportation, vector control (e.g., the use of rodenticides) and other codes are potential hindrances to urban agriculture that should be reviewed.
Urban agriculture’s role in expanding access to healthy food, required in Section 1 (a) (v), should not be construed as limited to the production of healthy food, but also to the potential for urban agriculture sites to serve as healthy food spaces, e.g., distribution points for farmers markets, CSAs or box schemes, and hosts for activities such as nutrition counseling or cooking instruction.
As noted above, Section 1 (a) (vi) should require the integration of urban agriculture into all relevant plans, including but not limited to conservation and resiliency plans.
The urban agriculture plan should link urban agriculture to the regional food system, parts of the food supply chain often regarded as separate, and requiring DCP to convene stakeholders to recommend opportunities for the plan to support regional food production and distribution along with urban agriculture.
DCP should formally adopt the urban agriculture plan, and not simply write a planning report that lacks the authority of formal plan. One procedure for doing so is Section 197-a of the City Charter. Though commonly used to plan specific neighborhoods, the 197-a process can address broad topics and geographic areas. Plans are more complex because they require more extensive public reviews, but the review processes will ensure wide participation and broader support.
The bill requires the plan by July 2018, yet does not include a provision for review and revision. Urban agriculture is changing so rapidly that regular updates are essential and should be required.
Finally, urban agriculture is so diverse that the legislation should establish a community advisory board to provide input to the planning process, and to review and recommend changes to ensure that the plan continues to address the needs of different stakeholders over time.
These modifications will ensure that the plan is well-crafted, has an impact, and remains relevant for years to come. My colleagues at the CUNY Urban Food Policy Institute and I welcome the opportunity to provide further input as the bill is considered by the Committee and the Council, and as the plan is developed.