APA New York Metro Chapter Statement on Proposed SEQRA Reforms

The American Planning Association – New York Metropolitan Chapter (APA-NYM) represents the professional planning community across the New York metropolitan region — from the five boroughs to Long Island, the lower Hudson Valley, and the Catskills. Our members serve in city, town, village, and county government; in state and federal agencies; in private practice; in academia; and in mission-driven nonprofits. We are the practitioners who, every day, do the work that the State Environmental Quality Review Act (SEQRA) was designed to inform.

At our Executive Committee retreat at Hunter College on May 9, 2026, our chapter leadership convened a sustained discussion of the Governor's "Let Them Build" agenda and the SEQRA reform package now moving through the FY27 budget. This statement reflects the consensus that emerged from that conversation.

APA-NYM supports, in spirit, responsible reform of SEQRA.

We recognize what a growing chorus of New Yorkers — including Regional Plan Association, Open New York, the New York State Association of Counties, the New York State Association for Affordable Housing, New York City, and a broad coalition of village, town and county executives — have made plain: SEQRA, as currently administered, can serve as an obstacle to housing and infrastructure that communities want and need. We agree that the original intent of SEQRA was to integrate environmental considerations alongside social and economic factors in planning decisions, not to elevate procedural review into an end in itself. Responsibly recalibrating the law to that original intent is appropriate, and we welcome the opportunity to participate in it.

Housing production and environmental conservation are not mutually exclusive goals. They are complementary obligations, and our chapter's members work at the intersection of both. We believe there is room for both in every village, every town, every county, and every city across our region — and we are committed to helping make that room.

At the same time, the depth and breadth of changes contemplated would be difficult to fully resolve in the compressed timeframe of a single budget cycle. As the Legislature finalizes statutory language and as the Department of Environmental Conservation (DEC) moves toward implementation, regulation, and the development of new Generic Environmental Impact Statements (GEIS), we offer the following principles to guide the work ahead.

1. Regional diversity demands tailored approaches.

New York is a large and diverse state. The implications of SEQRA reform are very different across our chapter’s varied landscapes. A reform package that works well for an infill site in a transit-served NYC neighborhood may not translate cleanly to a previously disturbed parcel in a small Hudson Valley village or to a coastal community on Long Island navigating climate risk.

This concern is not ours alone. Environmental Advocates NY noted in its FY27 budget testimony that "any reform amendment should, where appropriate, differentiate between how the state works to meet the needs of Upstate or Long Island communities and those of New York City. The needs between different areas of the state vary widely and any revisions should be tailored to meet a region's needs." 

We agree, and we urge the State to develop region-specific implementation guidance — co-developed with regional planning councils, county planning departments, and municipal planners — to accompany statutory enactment.

2. Communities that have invested in their own streamlining tools deserve continuity.

A number of municipalities, anticipating or working within the current system, have already pursued Generic Environmental Impact Statements (GEIS) and similar instruments as a means to fast-track local housing and infrastructure approvals. These communities have invested time, professional capacity, and public processes into these tools. In New York City, a new “Green Fast Track” for affordable housing has reduced the scope of environmental review for projects committing to green infrastructure and inclusionary housing by expanding the local Type II list for unlisted actions. We hope these successful local approaches to streamlining the SEQRA process will be considered and, where feasible, incorporated into the State's approach to SEQRA reform.

As the State pursues categorical SEQRA exemptions and new state-level GEISs, we ask the Legislature and DEC to clarify how these reforms will interact with locally adopted GEISs already in place. Will municipalities be expected to amend existing GEISs to reflect the new framework? Are previously approved findings still operative? Without clear answers, communities risk being forced to revisit settled work — undermining the very predictability the reform is intended to create.

3. SEQRA's value as a shield, and not only a sword, must be preserved.

While SEQRA is, in some communities, an impediment to development, in others it serves as a structured opportunity for community discourse about the kind of growth a place wants and the impacts a project may bring. The "hard look" doctrine has produced real mitigation, real design changes, and real community benefit in places across our region. Where SEQRA review remains required, it should remain rigorous.

This is particularly important in historically marginalized communities. The Environmental Justice Siting Law, the State's ongoing implementation of cumulative impact analysis through DEC's January 2025 proposed regulatory amendments, and the Climate Leadership and Community Protection Act’s (CLCPA) commitments to disadvantaged communities all establish a framework that SEQRA reform must not inadvertently weaken. Riverkeeper and a coalition of seventy state and local elected officials raised analogous concerns in their letter to the Governor; we share the view that exemptions must be drafted with care to protect floodplains, drinking water sources, and disadvantaged communities, and to ensure that the "previously disturbed" definition is not so broad as to invite litigation that ultimately slows the very projects the reform seeks to accelerate.

4. Reform should be paired with technical assistance and local capacity building.

Many of the planning boards that administer SEQRA at the local level are staffed by volunteers, supported by part-time clerks, and advised by attorneys and consultants retained on limited budgets. As the reform package adds new tools — categorical exemptions, statewide GEISs, tracking systems, and tighter EIS timelines — local administration will need to keep pace. SEQRA is just one tool, and is not a substitute for good proactive planning that achieves the community's goals along with updated zoning and other local regulations. Local governments should also be better supported and empowered to plan comprehensively for future housing needs, including undertaking environmental review at the policy and planning level so that individual project review can be more predictable, efficient, and consistent with long-term community goals.

The land-use bar has explicitly called for "enhanced support and education to local governments to help them better understand the SEQRA process," and we second that call emphatically. APA-NYM and our state chapter stand ready to partner with DEC, the Department of State, Homes and Community Renewal (HCR), and regional planning councils to deliver this technical assistance — including training, model documents, peer learning networks, and direct support for municipalities pursuing local GEISs to streamline housing approvals on their own terms. Local capacity is what will determine whether this reform delivers housing, or merely delivers paperwork in a new format.

5. The greatest efficiency gains lie in eliminating true duplication.

For substantive housing developments, the current sequence — SEQRA review, then zoning approval, then site plan approval, then building permit approval, with associated public hearings often layered atop one another — can produce a daisy chain of months or years  of duplicative public conversation. The goal of reform should be to measure once and cut twice: a coordinated, rigorous, transparent local process that produces one robust public record on which all subsequent approvals can rely.

We urge the State, as part of agency end-to-end review processes already directed under the budget, to commission a clear-eyed analysis of where SEQRA review genuinely duplicates local zoning, site plan, and public participation processes — and where it provides distinct, non-duplicative value. This analysis should inform any further legislative or regulatory action, and should be conducted in partnership with municipal planners who navigate these sequences in practice.

6. Establishing SEQRA Methodology that supports climate goals and people-centered designs. 

Many of the technical analysis used to perform SEQRA review are inconsistent with the stated goals of state and local government. This is particularly true of transportation analysis where “Level of Service” or an intersection’s throughput is the metric used to assess potential impacts. In other words, minimizing driver delay is the definition of environmental success. A wider road, “performs better” and shorter, safer pedestrian crossings may “worsen intersection throughput”. The negative repercussions of this analytical framework have been widely studied and alternatives, focused on increasing safety and minimizing greenhouse gas emissions associated with travel, have been adopted by other states. CITE

SEQRA reform should seek not only to exclude more projects from review, but to amend the nature of the review itself to better reflect the stated goals and values of the planning community at large.     

7. The reform process itself must sustain public trust.

SEQRA's most durable accomplishment over fifty years has been the public expectation that the government will take a hard look before it acts. If reforms are perceived as rushed, opaque, or driven primarily by development interests, that public trust — in the law, in the reform, and in the institutions implementing both — will erode. The consequence, ironically, is more litigation, more delay, and more community opposition to the housing the reform is intended to deliver. Any meaningful SEQRA reform should also consider ways to reduce unnecessary or frivolous litigation, such as specialized review bodies, additional judicial training, or clearer standards regarding standing and appeals, while still preserving appropriate oversight.

We therefore encourage the State, even as the budget framework moves forward, to continue and deepen its engagement with planners, environmental advocates, environmental justice leaders, municipal officials, and the affected public on implementation. The State of the State and budget process has begun this conversation. Implementation must continue it.

Looking ahead

APA-NYM stands ready to be a constructive partner in this work. Our members include planners on both sides of every relevant table — public agencies and private applicants, environmental advocates and housing advocates, NYC and the suburbs, urban and rural. We are well positioned to help translate the reform package into practice across the diversity of our region.

We look forward to working with the Governor's Office, DEC, HCR, the Department of State, the Legislature, our sister chapters within APA New York Upstate, and our colleagues across the planning and environmental communities to ensure that SEQRA reform delivers what New York needs: more housing, faster, in the places it belongs, without sacrificing the conservation, equity, and public-trust commitments on which our region's long-term resilience depends.

Conservation and responsible housing growth in every village, every town, every county, and every city — that is the goal. We are committed to helping the State achieve it.