In 1985, three Manhattan housing projects were in litigation to convert the units from rental to condominiums or cooperative ownership. However, each project's redevelopment agreement, consistent with Title I of the 1949 Federal Housing Act, required that "no change" be made without consent of the City Planning Commission and the Board of Estimates of the City. This Note analyzes whether the conversion of rental units built under Title I to ownership units constitutes a "change" as interpreted by the New York courts. The interpretation of the term "change" under the Title I redevelopment agreements will be analyzed from both the City of New York's and the private developer's views. In addition, the legislative purposes behind Title I's enactment will be examined from the perspectives of both the City of New York and the private developer. Finally, the current status of Title I will be discussed. This Note concludes that a "change," for purposes of New York City redevelopment agreements drafted pursuant to Title I, refers only to land use and density and does not relate to the form of ownership. Therefore, city approval should not be required for a Title I building to convert to condominium or cooperative status.

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