What NYC Real Estate Developers Need to Know About the 2025 CEQR Technical Manual Update

The CEQR Technical Manual establishes the standards and methodologies used to prepare City Environmental Quality Review (CEQR) documentation for projects seeking discretionary approvals, including variances, special permits, zoning map amendments, large-scale developments, and projects involving public actions or financing. For developers and land use practitioners, changes to the Manual directly affect project screening, scope, timelines, and the level of environmental analysis required to advance approvals.

In December 2025, New York City released an updated CEQR Technical Manual. While many technical chapters remain unchanged, the update introduces substantive procedural changes, new environmental justice requirements, and targeted revisions to screening thresholds, methodologies, and appendices that meaningfully affect how projects are screened, scoped, and documented under CEQR. 

Below is a summary of the most consequential changes and what they mean for NYC development projects.

Environmental Justice Siting Law (EJSL) IS NOW EXPLICITY EMBEDDED IN CEQR

The most significant change in the 2025 CEQR Technical Manual is the formal integration of the Environmental Justice Siting Law (EJSL) into CEQR and SEQRA review.

The updated Procedures and Documentation chapters now state that, pursuant to Environmental Conservation Law § 8-0113, lead agencies must consider whether a proposed action may cause or increase a disproportionate pollution burden on a Disadvantaged Community (DAC) when making determinations of significance and when preparing an Environmental Impact Statement. 

To support this requirement, the 2025 Manual adds Chapter 23, “Effects on Disadvantaged Communities,” a new technical chapter that defines DACs, establishes a standard study area, and directs applicants and agencies to State mapping tools and DEC guidance. While the chapter does not yet prescribe finalized quantitative methodologies, it represents a clear procedural shift from the 2021 Manual, where environmental justice was addressed only briefly and largely in a federal NEPA context.

What are the key updates to CEQR procedures and the analysis framework?

Several early chapters of the Manual were revised in ways that affect how CEQR documentation is prepared and reviewed:

• A new section on Type II Actions that Facilitate Housing clarifies when certain housing-related actions may be treated as Type II and requires documentation through a Type II memorandum, with explicit agency cross-references.
• SEQRA regulatory history has been updated to reflect amendments adopted in 2018 and the ongoing EJSL rulemaking process.
• Project description guidance now explicitly recommends visual materials, such as massing diagrams and No-Action versus With-Action comparisons, for projects involving zoning or bulk changes.

These changes clarify expectations and place greater emphasis on early-stage documentation and coordination.

Updated screening thresholds and technical triggers Across Various Chapters

The 2025 update includes substantial revisions to both the EAS Short Form and Long Form, changing when technical analyses are triggered.

• Socioeconomic Conditions: The residential screening threshold for socioeconomic analysis has been updated to 250 units. In addition, a new question now addresses potential retail concentration even when there is no direct displacement. The logic for indirect displacement screening has also been reorganized, placing more emphasis on key businesses and services.
• Community Facilities: The threshold for detailed public school analysis increased to 100 or more elementary and middle school students (previously 50), while the 150-student high school threshold remains unchanged.
• Open Space: Residential screening is now based on unit-based thresholds rather than population counts, while the core open space methodologies, study areas, and ratio thresholds remain unchanged.
• Shadows: The 2025 Manual introduces explicit height-based screening criteria and new guidance clarifies when a shadows analysis is not required, reducing unnecessary studies for de minimis changes.
• Urban Design and Visual Resources:  Preliminary analysis thresholds are now clearly defined, including projects that:
  
  • Result in buildings over 250 feet tall,
  • Occupy sites greater than 1.5 acres,
  • Are classified as general large-scale developments,
  • Require special permits to modify bulk or yard requirements, or
  • Introduce or relocate streets or public open spaces.

targeted technical updates and appendix revisions

• Air Quality
  
  • Chapter 17 now reflects the updated federal annual PM₂.₅ standard of 9 µg/m³, finalized in February 2024.
  • The CEQR air quality analytical framework itself remains unchanged; the update is regulatory rather than methodological.
• Transportation
  
  • Appendix tables were updated to reflect revised directional splits for multiple land uses, borough- and zone-specific modal split tables, and new 24-hour trip distribution profiles.
  • One notable chapter-level change is the increase in the Senior Center weekday PM peak share, while daily trip rates remain unchanged.
• Solid Waste
  
  • Chapter 14 was updated to reflect the current status of DSNY programs, including Commercial Waste Zones and citywide organics collection.
  • The Solid Waste Management Plan timeline was updated to reflect preparation of a new plan anticipated for State approval in 2026.

What Does This Mean for NYC Real Estate Projects?

The 2025 CEQR Technical Manual does not overhaul every technical chapter, but it materially affects how projects are screened, scoped, and documented, particularly for projects involving discretionary zoning actions or located in or near Disadvantaged Communities.

Developers are likely to encounter:

• More structured and precise early-stage CEQR screening,
• Earlier consideration of environmental justice and community context,
• Greater emphasis on documentation quality and clarity, and
• Increased front-end coordination with reviewing agencies.

GZA’s Commitment to Keeping Clients Ahead of Regulatory Change

At GZA, we understand how quickly the regulatory environment evolves—and how critical it is for owners, investors, and project teams to anticipate requirements before they affect budgets, timelines, or approvals.

Our environmental, planning, and regulatory specialists are already integrating the 2025 CEQR updates, including EJSL compliance considerations, new methodological standards and screening thresholds, and evolving City and State policies into project evaluations to inform issue identification, scope development, documentation strategy and efficient agency and stakeholder coordination. 

We continuously monitor CEQR updates, SEQR rulemakings, federal EJ policy shifts, and emerging technical standards so our clients stay informed and prepared—not surprised.

Want to understand how the 2025 CEQR Manual affects your upcoming NYC project?

GZA can provide a tailored compliance roadmap, early‑stage CEQR screening, and strategic guidance to help you navigate the new regulatory landscape with confidence.