Comments on Housing Finance Authority's Allocation Plan

September 17, 2009
Ms. Delbe Speth, Manager
Tax Credit Programs, Connecticut Housing Finance Authority
999 West Street
Rocky Hill, CT 06067

Dear Ms. Speth:

1000 FRIENDS of Connecticut is the state’s preeminent smart growth education and advocacy organization. Affordable housing is a lynchpin of smart growth, and we are pleased to submit the following comments regarding the Connecticut Housing Finance Authority’s draft Qualified Allocation Plan.

We commend CHFA’s staff, executive leadership and board for expressing a commitment to responsible growth in the policy discussion of the QAP. We suggest that the Connecticut Housing Finance Authority be proactive and adopt the definition and principles of smart growth in the policy guidance. Public Act 09-230 requires the definition and principles become an integral part of the next iteration of the state’s Comprehensive Plan of Conservation and Development and the QAP maintains consistency with that plan.

The definition of smart growth and smart growth principles are as follows:

(1) "Smart growth" means economic, social and environmental development that (A) promotes, through financial and other incentives, economic competitiveness in the state while preserving natural resources, and (B) utilizes a collaborative approach to planning, decision-making and evaluation between and among all levels of government and the communities and the constituents they serve; and

(2) "Principles of smart growth" means standards and objectives that support and encourage smart growth when used to guide actions and decisions, including, but not limited to, standards and criteria for (A)integrated planning or investment that coordinates tax, transportation, housing, environmental and economic development policies at the state, regional and local level, (B) the reduction of reliance on the property tax by municipalities by creating efficiencies and coordination of services on the regional level while reducing interlocal competition for grand list growth, (C) the redevelopment of existing infrastructure and resources, including, but not limited to brownfields and historic places, (D) transportation choices that provide alternatives to automobiles, including rail, public transit, bikeways and walking, while reducing energy consumption, (E) the development or preservation of housing affordable to households of varying income in locations proximate to transportation or employment centers or locations compatible with smart growth, (F) concentrated, mixed-use, mixed income development proximate to transit nodes and civic, employment or cultural centers, and (G) the conservation and protection of natural resources by (i) preserving open space, water resources, farmland, environmentally sensitive areas and historic properties, and (ii) furthering energy efficiency.

On close analysis of the eligible points an applicant might earn, a discrepancy appears between what is articulated as a policy goal and how points accumulate. 1000 FRIENDS of Connecticut suggests the following modifications to incent affordable housing creation that better comports with smart, sustainable, responsible growth.
There are three areas in which 1000 FRIENDS of Connecticut suggests changes: first, transportation costs are second only to housing costs generally and, for many households, transportation costs actually exceed housing costs. The cost of transportation as a percentage of household income is highest among the lowest-income households. Transportation costs of people with access to transit are 25percent lower than for people who have no choice but to drive. Housing built in the wrong locations means driving is not a convenient alternative, but an expensive necessity. As the world in which we live becomes increasingly more carbon-constrained, there will be new costs associated with living in nontransit-accessible areas in the form of vehicle miles travelled taxes or carbon off-sets, etc. Creating incentives for affordable housing near transit saves low-income households money now and will save even more in the future. We suggest that applications that are within ½ mile of fixed route transit (bus rapid transit and passenger/commuter rail) be awarded General Class I priority status.

A key concept behind smart or responsible growth is creating balance between housing and jobs, yet the draft allocation plan gives no special consideration to housing built within walkable distances to employment centers. We recommend that D.2. be edited to add housing units within ½ mile of a major employer.

There is logical inconsistency in the point allocation of the Responsible Growth section. A site located within a 5-minute walk of a downtown area with a bank and a full-service grocery store should be assigned significantly more points than units within one mile of a rural community center which is likely to mean a now-empty post office, a Congregational Church and a former Grange Hall converted into a town office building. We recommend that D.9. be eliminated and D.2. be assigned 4 points.

One final general concern is the point allocation gives preference for low per-unit costs. This skews toward applications in places where the land values, site preparation and site security costs are low, and where there are no neighbors to request community benefits, etc. Point allocations for infill, brownfield remediation, historic preservation, building reuse, and community participation should be higher to clearly off-set the perceived preference for greenfield development.

1000 FRIENDS of Connecticut thanks you for your good work to house our low-income friends and stabilize our communities. We also thank you for the opportunity to comment and hope that you will make these changes to reinforce smart, sustainable, responsible growth in Connecticut.

Sincerely,

The Board and Staff of 1000 FRIENDS of Connecticut


Heidi Green, President