Question: Is the 17.7% target for a sufficient supply of affordable rental housing appropriate?
No, this target is not appropriate.
Comments (optional):
To meet the target that 17.7% of all housing should be affordable to low income families would require the creation of 15,800 new county-subsidized Committed Affordable (CAF) housing units by 2040 (draft AHMP 5.0, page 18). This means that MORE THAN HALF of all the new housing units that will be built in Arlington between now and 2040 will be county-subsidized affordable housing.
The draft Master Plan contains no analysis of the costs of these 15,800 subsidized housing units, no analysis of the impact of the additional population on already overburdened county services—including schools, and no analysis of how the costs of housing and county services would be funded. See the report of the Arlington Civic Federation Revenue & Expenditures Committee (http://www.civfed.org/newContent/2015-06/ACCF%20RevExp%20Cmte%20AH%20Report%202015-05-15.pdf) for some sobering numbers.
The draft Master Plan ignores basic economics. Reserving more than one-sixth of the county’s housing supply for low-income households will greatly reduce the supply of housing available for middle-income households, thus increasing the price middle-income households have to pay for housing.
The Study Group’s predictions for new household creation appears to be based on predictions of job creation in Arlington and a judgment that people should live in the same political jurisdiction where they work. (Bad on all of you who live in Arlington and work in DC, Falls Church, Fairfax, etc.)
The Study Group’s determination that spending 30 percent or less of household income on housing is “affordable,” while spending more than 30 percent of household income on housing constitutes a “cost burden” is arbitrary. Other programs use 40% as the demarcation line, or a combined 48% cost for housing and transportation. The draft documents should, but do not, tell us how much affordable housing would be required if the 40% or 48% demarcation were used.
The draft Master Plan assumes that being “cost burdened” by any amount (even just 1%) requires a governmental intervention/solution and that the preferred solution is a system of county-subsidized housing.
Question: What are your thoughts regarding the approach to the geographic distribution of committed affordable housing?
I do not agree with the proposed policies.
Comments (optional):
Geographic distribution of affordable housing has been a county policy since 2000. It directly supports Arlington County’s Vision of being a “diverse and inclusive” community. There was a tremendous push-back from the public several weeks ago when version 3.0 of the draft Master Plan eliminated the geographic distribution policy. Geographic distribution appears to return in version 5.0 of the draft Master Plan’s Implementation Framework with the following new language:
In areas of the County designated by the U.S. Department of Housing and Urban Development HUD) as racially or ethnically concentrated areas of poverty (R/ECAP), AHIF or other County funds would only be used for the preservation or replacement of existing affordable rental units (MARK ’s or CAF ’s), or for ownership housing.
This language is deceptively attractive, but it would have little effect. This language would prohibit construction of new CAFs in only four of Arlington’s 59 census tracks. However, as noted in the county’s draft Consolidated Plan for housing and community development, low-income families are a majority of the population in 26 census tracts, not just four. There are significant concentrations of poverty in Buckingham and Rosslyn, and throughout South Arlington. However, these concentrations of poverty are not generally marked by racial or ethnic concentrations that meet the HUD definitions. The key factor is that poverty in Arlington racially and ethnically diverse. For the most part, Arlington's poor neighborhoods include a mix of hispanics, blacks, whites, and asians.
The new language would do nothing to prevent tax-money from being used to continue raising the number of poor households in the attendance zones of schools that are already overcrowded and that already have a high percentage of students living in poverty.
How effective is the "geographic distribution" criteria proposed in the AHMP draft 5.0?
It would allow additional CAFs to be built in the attendance zone of Carlin Springs Elementary where 81% of students are eligible for free or reduced-price lunch or Barcroft Elementary where 65% of students are eligible for free or reduced-price lunch.
It would prohibit additional CAFs from being constructed in the historically African-American Arlington View community where 16% of households earn less than twice the federal poverty level, but would allow additional CAFs to be constructed in Buckingham where more than 40% of households earn less than 200% of the federal poverty level.
Suggestion: More appropriate geographic distribution criteria might be:
AHIF or other County funds will be used only for the preservation or replacement of existing affordable rental units (MARK’s or CAF’s), or for ownership housing, and not for construction of net additional CAFs
within U.S. census tracks where more than 30% of individuals are in households with income of 200% or less than the federal poverty level within the attendance zone of an APS neighborhood elementary school where more than 30 percent of the students are eligible for free or reduced price meals, within the boundaries of an APS neighborhood elementary, middle, or high school that APS predicts will be at more than 105% of capacity within the next ten years.
The change in the Geographic distribution policy is predicated on the false assumption that affordable housing needs to be near major public transportation infrastructure. Locating CAF units near MetroRail is expensive and facilitates the occupants commuting to employment centers in other jurisdictions, such as Reston, Tysons Corner, and downtown DC. When this occurs, Arlington taxpayers subsidize the housing and education of the CAF residents, while Arlington employers obtain no additional workers. If the purpose of the county housing policy to provide affordable housing to low-wage employees of county businesses, CAFs should be located away from Metro stations but near ART bus routes that provide transportation inside Arlington County. Since the county controls ART, the county has the ability to provide public transport within a reasonably close distance of any location that is otherwise feasible for development as affordable housing.
Question: Should Arlington County residents and workers receive a preference for committed affordable housing?
No, I do not support giving preferences.
Comments (optional):
If there is utility to having school and county government employees live within the boundaries of Arlington County, it is much easier and much more efficient to realize that goal by giving school and county employees a cash subsidy or housing allowance that can be used towards ANY housing in Arlington, not just CAFs. This greatly increases the housing stock available to county employees (rather than restricting them to CAFs), keeps CAFs available for low-income families that really have no other alternative housing, and reduces the total number of CAFs that will be required, thus easing the pressure to increase density and to build housing on parks.
Private enterprises that want their employees to live within Arlington County have the same option: they can pay their employee better.
Question: Is it appropriate for this plan to address middle income ownership housing demands?
No, it is not appropriate.
Question: Should we be using public funds for higher-income households?
No, I do not agree.
Question: Would it be more appropriate to address this demand through land use provisions rather than financing?
No, that is not more appropriate.
Comments (optional)
No response.
Question: Should opportunities for creating greater flexibility of housing types beyond the urban corridors that support both rental and ownership options be further studied?
No, I do not agree they should be further studied.
Comments (optional):
No response.
Additional comments on the Draft Affordable Housing Master Plan & Implementation Framework (optional):
1. First Issue.
After a year of public discourse, on January 27, 2015, the County Board voted unanimously to “withdraw the Public Land for Public Good reports from further consideration.” However, the Public Land for Public Good (PLPG) policy, which targets parkland for development for affordable housing, makes a stealth reappearance in both the draft Master Plan and the draft Implementation Framework as Policy 3.5.2:
“3.5.2 Consider affordable housing needs and goals when planning for major capital investment in new or redeveloping existing major community facilities, taking into account the neighborhood context. The County Board does not support the placement of stand-alone affordable housing in officially designated parks or existing natural areas.”
The unnecessary inclusion of the modifier "stand-alone" reinforces that the county views parks as acceptable locations to site housing, as long as the housing is associated with something else, such as a community center. Indeed the “stand-alone” language originated in letter from then County Board Chairman Jay Fisette in which he suggested that affordable housing would be appropriate at Lubber Run if built “in a joint project with a new community center.”
Therefore: Please delete Policy 3.5.2 in its entirety. Arlington does not have sufficient public land to support the needs of its growing population. Community facilities are located on public property and are for the benefit of all county residents. In contrast, housing is a private use. Arlington should reserve its scarce public land for public services.
2. Second Issue: Arlington’s housing market is part of a regional market: Attempting to solve the region’s housing woes in isolation from the policies of the neighboring cities and counties cannot work and constitutes a threat to both quality of life in Arlington and to the county’s ability to achieve a strong and balanced economy.
3. Third Issue: Respect the Smart Growth Promise: Arlington’s land-use planning should respect the Smart Growth Promise that made Arlington famous: growth will be concentrated in dense developments along major transportation corridors, preserving and protecting open space and neighborhoods of single-family homes. The County should not change its land use plans and zoning to increase permissible densities for any reason unless there is sufficient infrastructure—including schools, parks, and emergency services—to support the additional density.
Open Arlington is not a certified voting system or ballot box. As with any public comment process, participation in Open Arlington is voluntary. The responses in this record are not necessarily representative of the whole population, nor do they reflect the opinions of any government agency or elected officials.
Question: Is the 17.7% target for a sufficient supply of affordable rental housing appropriate?
Comments (optional):
To meet the target that 17.7% of all housing should be affordable to low income families would require the creation of 15,800 new county-subsidized Committed Affordable (CAF) housing units by 2040 (draft AHMP 5.0, page 18). This means that MORE THAN HALF of all the new housing units that will be built in Arlington between now and 2040 will be county-subsidized affordable housing.
The draft Master Plan contains no analysis of the costs of these 15,800 subsidized housing units, no analysis of the impact of the additional population on already overburdened county services—including schools, and no analysis of how the costs of housing and county services would be funded. See the report of the Arlington Civic Federation Revenue & Expenditures Committee (http://www.civfed.org/newContent/2015-06/ACCF%20RevExp%20Cmte%20AH%20Report%202015-05-15.pdf) for some sobering numbers.
The draft Master Plan ignores basic economics. Reserving more than one-sixth of the county’s housing supply for low-income households will greatly reduce the supply of housing available for middle-income households, thus increasing the price middle-income households have to pay for housing.
The Study Group’s predictions for new household creation appears to be based on predictions of job creation in Arlington and a judgment that people should live in the same political jurisdiction where they work. (Bad on all of you who live in Arlington and work in DC, Falls Church, Fairfax, etc.)
The Study Group’s determination that spending 30 percent or less of household income on housing is “affordable,” while spending more than 30 percent of household income on housing constitutes a “cost burden” is arbitrary. Other programs use 40% as the demarcation line, or a combined 48% cost for housing and transportation. The draft documents should, but do not, tell us how much affordable housing would be required if the 40% or 48% demarcation were used.
The draft Master Plan assumes that being “cost burdened” by any amount (even just 1%) requires a governmental intervention/solution and that the preferred solution is a system of county-subsidized housing.
Question: What are your thoughts regarding the approach to the geographic distribution of committed affordable housing?
Comments (optional):
Geographic distribution of affordable housing has been a county policy since 2000. It directly supports Arlington County’s Vision of being a “diverse and inclusive” community. There was a tremendous push-back from the public several weeks ago when version 3.0 of the draft Master Plan eliminated the geographic distribution policy. Geographic distribution appears to return in version 5.0 of the draft Master Plan’s Implementation Framework with the following new language:
In areas of the County designated by the U.S. Department of Housing and Urban Development HUD) as racially or ethnically concentrated areas of poverty (R/ECAP), AHIF or other County funds would only be used for the preservation or replacement of existing affordable rental units (MARK ’s or CAF ’s), or for ownership housing.
This language is deceptively attractive, but it would have little effect. This language would prohibit construction of new CAFs in only four of Arlington’s 59 census tracks. However, as noted in the county’s draft Consolidated Plan for housing and community development, low-income families are a majority of the population in 26 census tracts, not just four. There are significant concentrations of poverty in Buckingham and Rosslyn, and throughout South Arlington. However, these concentrations of poverty are not generally marked by racial or ethnic concentrations that meet the HUD definitions. The key factor is that poverty in Arlington racially and ethnically diverse. For the most part, Arlington's poor neighborhoods include a mix of hispanics, blacks, whites, and asians.
The new language would do nothing to prevent tax-money from being used to continue raising the number of poor households in the attendance zones of schools that are already overcrowded and that already have a high percentage of students living in poverty.
How effective is the "geographic distribution" criteria proposed in the AHMP draft 5.0?
It would allow additional CAFs to be built in the attendance zone of Carlin Springs Elementary where 81% of students are eligible for free or reduced-price lunch or Barcroft Elementary where 65% of students are eligible for free or reduced-price lunch.
It would prohibit additional CAFs from being constructed in the historically African-American Arlington View community where 16% of households earn less than twice the federal poverty level, but would allow additional CAFs to be constructed in Buckingham where more than 40% of households earn less than 200% of the federal poverty level.
Suggestion: More appropriate geographic distribution criteria might be:
AHIF or other County funds will be used only for the preservation or replacement of existing affordable rental units (MARK’s or CAF’s), or for ownership housing, and not for construction of net additional CAFs
within U.S. census tracks where more than 30% of individuals are in households with income of 200% or less than the federal poverty level within the attendance zone of an APS neighborhood elementary school where more than 30 percent of the students are eligible for free or reduced price meals, within the boundaries of an APS neighborhood elementary, middle, or high school that APS predicts will be at more than 105% of capacity within the next ten years.
The change in the Geographic distribution policy is predicated on the false assumption that affordable housing needs to be near major public transportation infrastructure. Locating CAF units near MetroRail is expensive and facilitates the occupants commuting to employment centers in other jurisdictions, such as Reston, Tysons Corner, and downtown DC. When this occurs, Arlington taxpayers subsidize the housing and education of the CAF residents, while Arlington employers obtain no additional workers. If the purpose of the county housing policy to provide affordable housing to low-wage employees of county businesses, CAFs should be located away from Metro stations but near ART bus routes that provide transportation inside Arlington County. Since the county controls ART, the county has the ability to provide public transport within a reasonably close distance of any location that is otherwise feasible for development as affordable housing.
Question: Should Arlington County residents and workers receive a preference for committed affordable housing?
Comments (optional):
If there is utility to having school and county government employees live within the boundaries of Arlington County, it is much easier and much more efficient to realize that goal by giving school and county employees a cash subsidy or housing allowance that can be used towards ANY housing in Arlington, not just CAFs. This greatly increases the housing stock available to county employees (rather than restricting them to CAFs), keeps CAFs available for low-income families that really have no other alternative housing, and reduces the total number of CAFs that will be required, thus easing the pressure to increase density and to build housing on parks.
Private enterprises that want their employees to live within Arlington County have the same option: they can pay their employee better.
Question: Is it appropriate for this plan to address middle income ownership housing demands?
Question: Should we be using public funds for higher-income households?
Question: Would it be more appropriate to address this demand through land use provisions rather than financing?
Comments (optional)
No response.Question: Should opportunities for creating greater flexibility of housing types beyond the urban corridors that support both rental and ownership options be further studied?
Comments (optional):
No response.Additional comments on the Draft Affordable Housing Master Plan & Implementation Framework (optional):
1. First Issue.
After a year of public discourse, on January 27, 2015, the County Board voted unanimously to “withdraw the Public Land for Public Good reports from further consideration.” However, the Public Land for Public Good (PLPG) policy, which targets parkland for development for affordable housing, makes a stealth reappearance in both the draft Master Plan and the draft Implementation Framework as Policy 3.5.2:
“3.5.2 Consider affordable housing needs and goals when planning for major capital investment in new or redeveloping existing major community facilities, taking into account the neighborhood context. The County Board does not support the placement of stand-alone affordable housing in officially designated parks or existing natural areas.”
The unnecessary inclusion of the modifier "stand-alone" reinforces that the county views parks as acceptable locations to site housing, as long as the housing is associated with something else, such as a community center. Indeed the “stand-alone” language originated in letter from then County Board Chairman Jay Fisette in which he suggested that affordable housing would be appropriate at Lubber Run if built “in a joint project with a new community center.”
Therefore: Please delete Policy 3.5.2 in its entirety. Arlington does not have sufficient public land to support the needs of its growing population. Community facilities are located on public property and are for the benefit of all county residents. In contrast, housing is a private use. Arlington should reserve its scarce public land for public services.
2. Second Issue: Arlington’s housing market is part of a regional market: Attempting to solve the region’s housing woes in isolation from the policies of the neighboring cities and counties cannot work and constitutes a threat to both quality of life in Arlington and to the county’s ability to achieve a strong and balanced economy.
3. Third Issue: Respect the Smart Growth Promise: Arlington’s land-use planning should respect the Smart Growth Promise that made Arlington famous: growth will be concentrated in dense developments along major transportation corridors, preserving and protecting open space and neighborhoods of single-family homes. The County should not change its land use plans and zoning to increase permissible densities for any reason unless there is sufficient infrastructure—including schools, parks, and emergency services—to support the additional density.