Our reading of the law, the record, and the argument.
Every page in this section is NYHOA analysis — interpretation and argument built from primary documents, not the documents themselves. For the underlying record, see the Research Library.
📝 NYHOA AnalysisPolicy Argument Brief · condensed
Why Local Law 18 fails on its own terms.
Ten arguments — each one a separate line of failure. Click any argument to expand the full reasoning.
The record behind Local Law 18 — hearings, sponsor memos, contemporaneous press — is overwhelmingly about commercial operators warehousing apartments and converting multiple dwellings into de facto hotels. Owner-occupied one- and two-family homes were rarely named as a target and were never the harm the law was sold to address. Enforcement has nevertheless swept in exactly those homes, which is the definition of a law being applied against its stated purpose.