A Letter to AG James (October 2021)

Attorney General James,

We understand that your office will play an important role in deciding how the opioid settlement money should be spent.  As residents of Harlem (124th between Adam Clayton Powell and Lenox), we have experienced an intense degradation in the quality of life in the neighborhood.  The increased draw of vulnerable people to the high-density methadone clinics has created a massive pool of vulnerable people for drug dealers to prey upon.  In addition to the vulnerable population, the dealers attract addicts who are not seeking help, and the problem is exacerbated.  Drug deals are done in the open, drug use is in the open, and the resulting loitering has led to a level of filth from trash, urination, defecation, and rat infestations that we have only ever witnessed in the most desperate parts of 3rd world countries.  Given the over-saturation of methadone clinics in Harlem (19% of the city’s methadone clinics are located in Harlem; 75% of the patients commute in from as far away as Staten Island), we would like to see several things happen with the settlement money.  

First, new smaller facilities should be opened elsewhere in the city to allow patients the support they need closer to home.  Simultaneously, the concentration of methadone clinics should be reduced by at least two thirds in order to more appropriately align with the actual local need.  Moreover, the capacity of individual clinics should be cut way down so that no one location provides a rich pool of targets for drug dealers.

Second, rather than offering methadone, the remaining clinics should offer treatments like naltrexone or buprenorphine that don’t require patients to travel to clinics on a daily basis for treatment.  Taking it a step further, methadone should be offered only as a last resort to avoid building up a concentration of vulnerable people upon whom drug dealers prey.

Third, there should be money invested in a professional support team for and daily cleaning of the 125th St & Lenox corridor.  Lenox between 123rd and 126th is a safety and hygiene hazard.  The local community has essentially been abandoned to deal with a density of mental health and addiction patients who pose a threat at all hours of the day and who leave trash everywhere.

Thank you for your consideration,

Kate and Dustin Rubenstein

Letter to AG James on Use of Opioid Settlement Funds (October 2021)

Dear Attorney General James.

I am writing to add my voice to the many you have heard asking you to use funds from the opioid settlement to address the problem of disproportionate distribution of drug treatment centers that is so negatively affecting the already vulnerable neighborhood of Harlem. 

As you know, over 75% of the people being treated in Harlem commute (6 days a week) from other areas that do not provide access to treatment. This is detrimental to health outcomes for the patients and to the quality of life in our neighborhood. And the problem keeps getting worse, with providers continuing to expand facilities and establish new ones, all in this same area. I have lived here only 10 years, but even in that short time, there has been a significant deterioration in the quality of life.

The funds could be used to redestribute drug treatment facilities more appropriately and constructively. An independent committee that evaluates density of service vs. density of LOCAL need could be established to pinpoint which areas are underserved (Staten Island, for example), and suggest capacities for those. These numbers could then be used to determine whether a provider is granted permission to expand or establish new facilities in any given area, and to move facilities out of places where they are excessive. Financial incentives could be offered to offset the additional cost to providers of moving facilities into new and, likely, more expensive areas, including legal fees to respond to NIMBY lawsuits.

Funds could also be used to help patients afford less burdensome alternatives to methadone.

Finally, as we wait for the density to decrease through these measures, funds could be used to increase sanitation, including more trash cans and more frequent pick-up, and to create a team of mobile social workers and drug counselors, who could walk the areas around the treatment centers to offer follow-up help to patients, as well as to the un-treated addicts who flock here to buy the drugs that are so readily available on the street  —  dealers know where the facilities are and come here to prey on this concentration of the vulnerable population of patients who are trying to get clean.

Thank you for all you do!


Kate Neuman


Letter to NY Attorney General James – October 2021

Dear Attorney James,

I would like to start by saying that you are a hero at a time when heroes are so desperately needed.  I support you making citizens responsible for paying their fair share of taxes, even when these powerful individuals try to hide behind organizations.  Thank you for pursuing accountability for what is fair and just.  I really appreciate and admire having the buck stop here.

The reason I am writing you today is that my neighborhood, Harlem, needs your support.  I have been living in Harlem for 16 years and am raising my two children 14 and 11 here.  For the last 5 years or so things have been getting worse.  Stepping around people under scaffolding while they’re ‘waiting for their man’ on our way to the morning school bus.  Being careful of certain corners, deli’s where dealers are hanging out.  Planning paths to and from my house that feel safe.  When I was enlightened a few years ago to the fact that Harlem contains an overabundance of rehabilitation clinics it was like an epiphany.  Suddenly this pressure and fear I was experiencing at almost every corner of my neighborhood had a reason.  I know that these clinics support much more rehabilitation than just Harlem residents.  Approximately 3 out of every 4 people seeking support from these clinics commutes to my neighborhood for these services.  That brings a lot of strangers and a lot of struggling strangers to my community.  Along with individuals seeking treatment, this also brings much more drug dealing commerce to my local community.   Rehabilitation is a difficult business, but Harlem is being set up to fail.  Rehabilitation needs community effort and accountability.  Local people need to support their own neighbors and help lift them up.  That’s what makes a community.  Westchester needs to support their own population of struggling users and so does Park Avenue.  The people who call Park Slope home need to have a place to treat their local population struggling with drugs.  One needs local, community support and LOCAL ACCOUNTABILITY to help rehabilitate local people, your neighbors.  Harlem cannot and should not be expected to support the drugs struggles of this entire city and beyond.

Between Wednesday, October 6th and Thursday, October 14th at least five children were shot within blocks from my house.  Children.  All of them under 18.  I have heard it is probably gang, probably drug related.  I guess that means targeted.  I guess that means I can take a deep breath and hope my children don’t get caught in the crossfire as I walk through this war zone.  These children need opportunities outside of the drug trade.  Please help us help Harlem be the vibrant, colorful, diverse and SAFE community for all of its taxpaying residents.
Please let me know how I can support these efforts.

Sally Brackett

Letter Sent to The Commissioner of OASAS (April 27, 2021)

Testimony to NYC Racial Justice Commission (October 2021)

Testimony to NYC Racial Justice Commission

  1. Unfair displacement of local residents in gentrifying neighborhoods


Due to the high real estate prices in New York City, residents from neighborhoods of color, such as Harlem, are often exposed to risk of displacement and homelessness. To protect these residents and to help preserve their culture, the government must offer incentives and implement governance that will ensure residents’ access to quality affordable housing in their neighborhood. 


  1. To prevent displacement of residents or homelessness, city charter must mandate a greater proportion of affordable housing must be set aside for local residents of districts at risk of gentrification. For example, buildings in these gentrifying districts can increase the required percentage of affordable units reserved for local residents from 40% to 80% 
  1. Too often “affordable housing” is not really affordable to the local residents. City charter must require that building height associated with zoning and tax incentives associated with Mandatory Inclusionary Housing (MIH) ensure adequate supply of deeply affordable housing units for residents with low AMI (Average median income), if there is such a need. To enable this, for example, the city can develop its own AMI scale tailored to specific neighborhoods and their various AMIs.
  1. Overall, the city does not have sufficient deeply affordable housing units and since the majority of the residents who need such housing are residents of color, they are exposed to the risk of homelessness. Every few years, the city charter should require a holistic review if current Mandatory Inclusionary Housing (MIH) and zoning regulations are (1) providing sufficient incentives to build adequate housing units in all districts (2) helping to reduce reduce racial segregation of New York City’s population
  1. The majority of residents in NYCHA housing are people of color. The severe deterioration of the living conditions in NYCHA housing over the last decade means children of color are disadvantaged relative to their wealthier counterparts. Too often they are exposed to lead paint, coaches, rats, contaminated water, polluted air, leading to poor health. For example, the rate of asthma of children in NYCHA housing is significantly higher than their counterparts. So NYC charter must mandate a sustainable maintenance plan for NYCHA housing. 
  1. Irreversible over-concentration of social services and supportive housing


Social justice means fairly distributing social burden as well as social goods, so that no one district is over-burdened with the less desirable elements of maintaining the health of our society, such as garbage trucks, waste treatment plants, homeless shelters, and drug treatment facilities. While all these services are critical, concentration of them in one district would unfairly disadvantage that district’s residents. It is the government’s role, then,  to counter such oversaturation and to address any tendency toward it.

Over the past decades, inadequate government oversight and/or attempts to provide services at a lower cost have led to an excessive concentration of adult-only homeless shelters and drug treatment clinics in East Harlem and Central Harlem. As of 2019, East and Central Harlem host 14% of NYC’s  adult-only homeless shelter population and 18% of its methadone patients. East Harlem is the most impacted; East Harlem has 1.5% of NYC’s population but hosts 14% of NYC’s methadone patients and 10% of NYC’s adult-only homeless shelters. Even if homelessness and drug use were more prevalent in East Harlem than in other neighborhoods, such disproportionate allocation would be multiple times beyond what East Harlem needs, not a mere 20-30% more. East Harlem also has the highest concentration of NYCHA housing in NYC’s 59 districts.


To reverse decades of systemic racism, the NYC government must redistribute these services to other districts by making these requirements in city charter:. 

  1. All placements and, importantly, expansion of individual homeless shelters should go through community board approval, and data should be presented to demonstrate that the specific district’s residents, rather than the whole of New York City, have such a need. Prior to such approval, the government and the district must assess whether similar funds can be used to offer homeless individuals better options, such as rent vouchers. 
  2. Similarly, all placements and, importantly, expansion of individual drug treatment centers should go through community board approval, and data should be presented to demonstrate that the specific district’s residents, rather than the whole of New York City, have such a need. Prior to such approval, the government and the district must also assess whether similar funds over multiple years can be used to pay for better forms of treatment, such as buprenorphine. Related to drug treatment centers, City charter must require:
    1. Siting and expansion of drug treatment centers must also undergo a public Need Assessment Review conducted by experts. This is the practice in other states but not in New York (see Tennessee, South Carolina, Connecticut, Virginia). This assessment would counter private interest’s  tendency to oversaturate neighborhoods of color that offer lower real estate costs.
    2. Providers must implement Neighborhood Engagement Plans to ensure regular and transparent processes and governance in addressing neighborhood residents’ concerns about the facilities’ impact on the neighborhood’s quality of life.  The effectiveness of the provider in addressing neighborhood concerns must factor into the granting of any contract renewal  (see Arizona, Virginia)
  3. Zoning reform is required:
    1. A specific zone should be set aside for out-patient opioid dispensing facilities due to the high risk of diversion of opioid into the neighborhood, which can attract drug dealers. In contrast, liquor stores and night clubs are regulated by such zoning restrictions
    2. Zoning law in NYC focuses on height and form of building and insufficiently on the specific use of land. Holistic city plans with specification of land usage can be leveraged to distribute social services fairly.
  4. At least once in a decade, the city needs to conduct a holistic and transparent review of social services needed by each district and determine whether certain districts have an excessive concentration of one type of social services or a combination of social services. This assessment should use a data driven approach which should include the original residence districts of currently homeless people and incarcerated individuals.
  5. New York City must commit to processes that will not only reverse the existing conditions that are the result of decades of systemic racism, but also offset the great damage that has been done. For example, such districts should receive a disproportionate amount of funding for education, needle pick-up, and sanitation.

Redlining and Opioid Treatment Programs in New York City

The New York State addiction agency – OASAS – has licensed decades of opioid treatment programs (OTPs) throughout New York.

Examining the locations of the 69 OTPs in New York City, shows a non-random spatial pattern that can be compared to neighborhoods that were racially redlined in 1938. When the two geographies (separated by over 80 years) are overlaid, a shocking correspondence is immediately seen. 96% of OASAS licensed OTPs in New York City, are located in residential areas that had been redlined as “Definitely Declining” or “Hazardous”.

[The map, above, shows 1938 redlined New York City with dots indicating the location of 21st century opioid treatment programs]

This classic example of conscious and unconscious structural racism – locating OTPs under the guise of care while actually mirroring an 80 year-old map’s racist community designations – has had tremendously negative consequences for Harlem and East Harlem. The intense density of large methadone mega centers attracts a daily influx of drug dealers who feed and profit on the concentration of methadone patients. The dealers in turn attract (non-patient) users, who commute into Harlem and East Harlem in order to purchase. The inevitable outcome is that dealing increases, using increases, and overdoses increase – all of which are then used by OASAS to justify increasing the capacity of programs in fragile communities.

To see the full presentation of this cycle, see the video below – a presentation at Rockefeller Institute of Government at the Developing Evidence-Based Drug Policy Conference 2021.


Gale Brewer Says “Enough is Enough”

‘The money is there’: Manhattan borough president shares plan to tackle crime, homelessness on PIX11:

She said she has requested some money from the $150 million settlement Attorney General Letitia James received from an opioid settlement. 

She also said she wants to make sure there are well-trained police at the precincts and officers who go out should go with mental health counselors.

“The resources are there, but they have to get the kind of inter-agency coordination,” Brewer said, “and they need the funding.”

“We don’t want any more methadone centers [in Harlem and East Harlem]”

Gale Brewer’s Press Conference and GHC

Nck Garber from Patch.com covered the Times Square press conference held by Borough President Gale Brewer to address the distribution of opioid settlement funds by AG James.

GHC was at the press conference, standing with Gale Brewer, and hope that AG James will not simply pack programs in Harlem and East Harlem.

Also in attendance Sunday were leaders of the Greater Harlem Coalition, a neighborhood group pushing to reduce the number of opioid treatment centers in the neighborhood.

Shawn Hill, one of the coalition’s founders, said the group “wholeheartedly” supports Brewer’s proposals. Another leader, Joshua Clennon, told Patch that the group wants the city to expand the use of the addiction drug buprenorphine to lower-income patients and create a redistribution plan for methadone clinics to reduce Harlem’s “over-saturation.”

Below is the Borough President’s letter:

Patch.com Reports on Harlem Oversaturation Pushback

Nick Garber posted: Drug Clinics Face Scrutiny In Harlem As Residents Push Back on Patch.com on March 24, 2021 and examined the “tax revolt” and a new community board resolution aim to stop the placement of drug treatment clinics in Harlem, citing safety concerns.

The influx of clients into Harlem each day has given rise to open drug use, discarded needles and filthy sidewalks, according to neighborhood advocates.

The piece examined Maria Granville’s Tax Revolt project and the work in CB11 to implement a moratorium on new substance use programs in East Harlem.

To read the full article, please see:


Harlem Battles an Increasing Rate of Opioid Injections

“I was born and raised in Harlem,” says Maria Granville, “and I have never seen anything this bad.” begins an article by Karina Tsui on medium: https://medium.com/labor-new-york/a-community-battles-with-increasing-rates-of-open-opioid-injections-9cea139c963c

Granville, a board member at Harlem’s Mount Morris Park Community Improvement Association, which is dedicated to revitalizing and preserving the neighborhood, is referring to a spike in open drug injections in the neighborhood. “Heroin use was pervasive, but we did not see hypodermic needles on the streets,” she recalls. “We did not see human feces on the streets.”

Earlier this month, the 64-year-old joined over 200 Harlem residents and local business workers to protest what they say is an oversaturation of opioid treatment facilities in the area, which has given rise to open drug use and exchange on the streets. Residents held up signs reading “Harlem Is Not A Dumping Ground!” and “Needle-Free Streets!” as they paraded across 125th Street.