Question: Is the 17.7% target for a sufficient supply of affordable rental housing appropriate?
No, this target is not appropriate.
Comments (optional):
Because the market is not/will not producing any affordable housing in Arlington, meeting the 17.7% target will require that more than half of all new housing units built between now and 2040 would have to be a CAF. This is neither feasible nor desirable.
The assumption that Arlington will increase the total housing supply by 30,500 units (over 30%) in the next 25 years also is not desirable. Arlington is full and county services, including schools, are already overburdened. Arlington does not need more population. Housing demand is a regional phenomena driven overwhelmingly by regional forces. Arlington CANNOT resolve regional demand for affordable housing problems in isolation from other jurisdictions.
The assumption that every person with AMI below 60% needs to LIVE in Arlington in order to WORK in Arlington is false. It is perfectly possible to live in Fairfax, Falls Church, Alexandria, or DC and be close/easy commute to an Arlington workplace.
The draft Master Plan should be revised to include a detailed fiscal impact analysis that includes the costs and sources of revenue to construct the 15,800 additional CAFs, the annual costs of rent subsidies for families that cannot afford CAF rents, and the costs of county services for the additional population (including the cost of education and the capital costs--including land--of constructing new schools).
There is no basis to use predictions of employment growth in Arlington as a proxy for housing demand.
The assumption that every household spending more than 30% of income on housing is “cost burdened” by has a problem requiring county government intervention should be revisited. Many households willingly make choice to spend more money to live in a higher cost areas because of what they view as a better quality of life or better educational opportunities. For truly low-income families, the real problem is the low income. Rather than an expensive county housing program, a more efficient solution would be a direct remedy such as raising the minimum wage (even if it requires legislative action in Richmond) or providing cash subsidies/housing allowances.
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. If the county aims for its affordable housing policy to help create social diversity in Arlington, it must keep and enforce the goal of geographic distribution of affordable housing throughout the county.
The language about geographic distribution in version 5.0 of the draft Master Plan’s Implementation Framework is deceptively attractive, but it would have little effect. It says, "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 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. These high-poverty census tracts 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.
For example the "geographic distribution" criteria proposed in the AHMP draft 5.0
- 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.
-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 and there is only a single affordable housing complex with 77 CAFs, but would allow additional CAFs to be constructed in Buckingham where there are eleven complexes with 1647 CAFs and 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 historical 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?
I support preference for Arlington residents, but not for workers.
Comments (optional):
Current Arlington County residents should receive preference for the limited supply of county-subsidized affordable housing.
There is some utility to having employees of Arlington County and APS live within the boundaries of Arlington County. That goal is best realized by giving school and county employees a cash subsidy or housing allowance that can be used towards ANY housing in Arlington, not just CAFs.
Private enterprises that want their employees to live within Arlington County should do the same thing: offer to pay them better.
Question: Is it appropriate for this plan to address middle income ownership housing demands?
I am not sure.
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)
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. Within that constraint, land-use planning, not financing, should be used to address the needs for middle-income family housing. That does not mean that we need to assume a significant growth in the number of middle-income housing units.
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):
There should be great flexibility for accessory dwelling units.
Multi-family housing should not be introduced into Arlington's single-family existing neighborhoods.
Additional comments on the Draft Affordable Housing Master Plan & Implementation Framework (optional):
Policy 3.5.2 is a reprise of the ill-named "Public Land for Public Good" attempt to place housing on parks that caused so much discord in 2014. In particular, the sentence "The County Board does not support the placement of STAND-ALONE affordable housing in officially designated parks or existing natural areas" is deliberately deceptive. If 3.5.2. is not deleted in its entirety, then the modifier “stand-alone" should be deleted from the above sentence in all three places where it appears in the draft Master Plan and Implementation Framework. Housing should never be built in parks, or on land purchased with money raised from the sale of park bonds.
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 constitute a threat to both quality of life in Arlington and to the county’s ability to achieve a strong and balanced economy.
The County should not change its land use plans and zoning to increase permissible densities for any reason related to income of the future residents. Density increases should only be based on proximity to new transit services, and only when there is sufficient infrastructure—including schools and parks—to support the additional density.
The draft Affordable Housing Principles, enumerated in Chapter 1, are in the wrong order. The most important principles should be moved from the bottom of the list to the top:
4 > 1. No one should be homeless.
5 > 2. Housing discrimination should not exist in Arlington.
6 > 3. All housing should be safe and decent
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.
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Question: Is the 17.7% target for a sufficient supply of affordable rental housing appropriate?
Comments (optional):
Because the market is not/will not producing any affordable housing in Arlington, meeting the 17.7% target will require that more than half of all new housing units built between now and 2040 would have to be a CAF. This is neither feasible nor desirable.
The assumption that Arlington will increase the total housing supply by 30,500 units (over 30%) in the next 25 years also is not desirable. Arlington is full and county services, including schools, are already overburdened. Arlington does not need more population. Housing demand is a regional phenomena driven overwhelmingly by regional forces. Arlington CANNOT resolve regional demand for affordable housing problems in isolation from other jurisdictions.
The assumption that every person with AMI below 60% needs to LIVE in Arlington in order to WORK in Arlington is false. It is perfectly possible to live in Fairfax, Falls Church, Alexandria, or DC and be close/easy commute to an Arlington workplace.
The draft Master Plan should be revised to include a detailed fiscal impact analysis that includes the costs and sources of revenue to construct the 15,800 additional CAFs, the annual costs of rent subsidies for families that cannot afford CAF rents, and the costs of county services for the additional population (including the cost of education and the capital costs--including land--of constructing new schools).
There is no basis to use predictions of employment growth in Arlington as a proxy for housing demand.
The assumption that every household spending more than 30% of income on housing is “cost burdened” by has a problem requiring county government intervention should be revisited. Many households willingly make choice to spend more money to live in a higher cost areas because of what they view as a better quality of life or better educational opportunities. For truly low-income families, the real problem is the low income. Rather than an expensive county housing program, a more efficient solution would be a direct remedy such as raising the minimum wage (even if it requires legislative action in Richmond) or providing cash subsidies/housing allowances.
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. If the county aims for its affordable housing policy to help create social diversity in Arlington, it must keep and enforce the goal of geographic distribution of affordable housing throughout the county.
The language about geographic distribution in version 5.0 of the draft Master Plan’s Implementation Framework is deceptively attractive, but it would have little effect. It says, "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 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. These high-poverty census tracts 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.
For example the "geographic distribution" criteria proposed in the AHMP draft 5.0
- 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.
-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 and there is only a single affordable housing complex with 77 CAFs, but would allow additional CAFs to be constructed in Buckingham where there are eleven complexes with 1647 CAFs and 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 historical 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):
Current Arlington County residents should receive preference for the limited supply of county-subsidized affordable housing.
There is some utility to having employees of Arlington County and APS live within the boundaries of Arlington County. That goal is best realized by giving school and county employees a cash subsidy or housing allowance that can be used towards ANY housing in Arlington, not just CAFs.
Private enterprises that want their employees to live within Arlington County should do the same thing: offer to pay them 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)
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. Within that constraint, land-use planning, not financing, should be used to address the needs for middle-income family housing. That does not mean that we need to assume a significant growth in the number of middle-income housing units.
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):
There should be great flexibility for accessory dwelling units.
Multi-family housing should not be introduced into Arlington's single-family existing neighborhoods.
Additional comments on the Draft Affordable Housing Master Plan & Implementation Framework (optional):
Policy 3.5.2 is a reprise of the ill-named "Public Land for Public Good" attempt to place housing on parks that caused so much discord in 2014. In particular, the sentence "The County Board does not support the placement of STAND-ALONE affordable housing in officially designated parks or existing natural areas" is deliberately deceptive. If 3.5.2. is not deleted in its entirety, then the modifier “stand-alone" should be deleted from the above sentence in all three places where it appears in the draft Master Plan and Implementation Framework. Housing should never be built in parks, or on land purchased with money raised from the sale of park bonds.
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 constitute a threat to both quality of life in Arlington and to the county’s ability to achieve a strong and balanced economy.
The County should not change its land use plans and zoning to increase permissible densities for any reason related to income of the future residents. Density increases should only be based on proximity to new transit services, and only when there is sufficient infrastructure—including schools and parks—to support the additional density.
The draft Affordable Housing Principles, enumerated in Chapter 1, are in the wrong order. The most important principles should be moved from the bottom of the list to the top:
4 > 1. No one should be homeless.
5 > 2. Housing discrimination should not exist in Arlington.
6 > 3. All housing should be safe and decent