New York City Comptroller Alan G. Hevesi yesterday repeated his position that Mayor Rudolph Giuliani may need to make an additional $400 million in cuts to balance the city's fiscal 1995 budget.

The announcement came as part of the comptroller's review of the city's October budget modification, in which Giuliani said he closed a $1.1 billion gap in the city's fiscal 1995 budget through workforce reductions, an expanded severance program, and a reduction in health spending for city workers.

In the review, Hevesi said the modification "is an important step toward a balanced budget," and said the mayor's plan to close the gap is "generally realistic and achievable."

But Hevesi repeated concerns that the Giuliani Administration may be underestimating the severity of the city's budget problems.

Specifically, Hevesi said the city faces "substantial risks" that may add another $400 million to the gap from this fiscal year, which began July 1. These risks range from revenues that may never materialize to an undercounting of such expenses as overtime costs.

The review also said the city faces a projected growth in budget gaps from $2 billion in fiscal 1996 to $3.9 billion in fiscal 1998. "A major contributor to those gaps is a potentially large increase in the city's pension costs beginning in fiscal year 1996," Hevesi said.

Abraham Lackman, Giuliani's budget director, did not return a telephone call. Forrest Taylor, a budget spokesman for the mayor, also did not return a telephone call.

The risks cited by Hevesi include Giuliani's reliance on $100 million from the refund of Social Security overpayments, $65 million from the sale of the UN Plaza Hotel, $24 million from lower-than-expected tax revenues, and $30 million from renegotiating the city's airport leases.

New York City is rated Baa1 by Moody's Investors Service; A-minus Fitch Investors Service; and A-minus by Standard & Poor's Corp.

Municipal market analysts are closely watching the city's dealings with Standard & Poor's because the firm has placed a negative outlook on the city's A-minus rating.

David Hitchcock, a director at Standard & Poor's, said he wants to review Hevesi's analysis before commenting on its impact on the city's bond rating. "Risks are different than an actual gap," Hitchcock said. "Maybe he's identified something here, but I have to look at it first."

In the coming weeks, state Comptroller H. Carl McCall and the state's Financial Control Board will also release reports showing that the city faces budget risks similar to those cited by Hevesi.

Dennis Tompkins, a spokesman for the comptroller's office, said, "Hevesi's numbers come pretty close" to those McCall will release next week. "We still believe there is a substantial problem that needs to be addressed," Tompkins said. "But we do believe the mayor has made some moves toward a more realistic approach to the budget."

Jeffery Sommer, the control board's acting executive director, said the board will release its budget report in December, also showing gap numbers "in the neighborhood" of what Hevesi revealed yesterday.

"There are risks like the sale of the UN hotel," Sommer said, adding that the city has often cited asset sales as one-shot revenue raisers, only to find that the sales never materialize. "They haven't done it before," Sommer added.

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