Question: Is the 17.7% target for a sufficient supply of affordable rental housing appropriate?
No, this target is not appropriate.
Comments (optional):
The numerical targets for affordable housing should be based on providing safe and decent housing for Arlington’s CURRENT residents.
The county projects that 30,500 new housing units will be built between now and 2040. In order to meet the target of 22,800 affordable units in 2040, 15,800 new CAFs would be required (DRAFT-AHMP-3.0, page 18). This means that MORE THAN HALF of all the new housing units that will be built between now and 2040 will be CAFs. That is simply not realistic. Nor is it desirable.
The draft documents should tell us how many affordable units would be required if 40% was used as the demarcation line between "affordable" and "cost burdened", or if a combined 48% cost for housing and transportation.
The Master Plan should not assume that households that are only moderately “cost burdened” by housing (ie., housing costs are only a few percent higher than the demarcation line) require a governmental intervention/solution or that the preferred solution a system of county-subsidized housing household.
The 17.7% target is based on multiple false assumptions:
I. 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 to an Arlington workplace.
II. The target is based on the assumption that Arlington will/should increase the number of low-wage jobs and will concomitantly increase the number of households earning less than 60% of AMI from 20,200 in 2010 to 27,600 in 2040. This would make households earning less than 60% of AMI the single fastest growing segment of the Arlington population, growing 50% faster than households with incomes at 80-100% AMI. I do not believe that significantly increasing the number of low-wage jobs/residents should be the aim of the county’s economic development and housing policies.
III. The target is based on the assumption that every household that is “cost burdened” by spending more than 30% of income on housing has a problem requiring county government intervention. 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.
The draft affordable housing plan program ignores the economic reality that restricting supply of housing (by making 17.7% of the total housing supply CAFs restricted to households earning less than 60% of AMI) would significantly increase housing costs for households earning 60-100% AMI.
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 for many years. It directly supports Arlington County’s Vision of being a “diverse and inclusive” community. The proposed change in the Geographic distribution policy would continue the trend in recent years of concentrating affordable housing in neighborhoods where the elementary schools already have poverty rates of 50-80% as measured by the number of students receiving free and reduced meals. This is bad educational policy, bad social policy, and bad economic policy.
The new language in version 5.0 of the draft Implementation Framework about restricting net additional CAFs in HUD-designated racially or ethnically concentrated areas of poverty is deceptively attractive, but would have little effect. As demonstrated by the map on page 6 of the Implementation Framework V 5.0, 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 R/ECAP language?
• 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 proposed 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.
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.
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 county-subsidized affordable housing.
There is utility to having school and county government employees 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. The subsidy should be higher for emergency responders than for office workers.
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):
Yes, There should be great flexibility for accessory dwelling units.
No, 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 discredited Public Land for Public Good which was withdrawn by a unanimous vote of the County Board on January 27, 2015. Policy 3.5.2 section should be deleted from all three sections where it appears. 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 be for public services.
If 3.5.2. is not deleted in its entirety, then the modifier “stand-alone" should be deleted from policy 3.5.2 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. No one should be homeless.
5. Housing discrimination should not exist in Arlington.
6. 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.
Translate
Question: Is the 17.7% target for a sufficient supply of affordable rental housing appropriate?
Comments (optional):
The numerical targets for affordable housing should be based on providing safe and decent housing for Arlington’s CURRENT residents.
The county projects that 30,500 new housing units will be built between now and 2040. In order to meet the target of 22,800 affordable units in 2040, 15,800 new CAFs would be required (DRAFT-AHMP-3.0, page 18). This means that MORE THAN HALF of all the new housing units that will be built between now and 2040 will be CAFs. That is simply not realistic. Nor is it desirable.
The draft documents should tell us how many affordable units would be required if 40% was used as the demarcation line between "affordable" and "cost burdened", or if a combined 48% cost for housing and transportation.
The Master Plan should not assume that households that are only moderately “cost burdened” by housing (ie., housing costs are only a few percent higher than the demarcation line) require a governmental intervention/solution or that the preferred solution a system of county-subsidized housing household.
The 17.7% target is based on multiple false assumptions:
I. 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 to an Arlington workplace.
II. The target is based on the assumption that Arlington will/should increase the number of low-wage jobs and will concomitantly increase the number of households earning less than 60% of AMI from 20,200 in 2010 to 27,600 in 2040. This would make households earning less than 60% of AMI the single fastest growing segment of the Arlington population, growing 50% faster than households with incomes at 80-100% AMI. I do not believe that significantly increasing the number of low-wage jobs/residents should be the aim of the county’s economic development and housing policies.
III. The target is based on the assumption that every household that is “cost burdened” by spending more than 30% of income on housing has a problem requiring county government intervention. 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.
The draft affordable housing plan program ignores the economic reality that restricting supply of housing (by making 17.7% of the total housing supply CAFs restricted to households earning less than 60% of AMI) would significantly increase housing costs for households earning 60-100% AMI.
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 for many years. It directly supports Arlington County’s Vision of being a “diverse and inclusive” community. The proposed change in the Geographic distribution policy would continue the trend in recent years of concentrating affordable housing in neighborhoods where the elementary schools already have poverty rates of 50-80% as measured by the number of students receiving free and reduced meals. This is bad educational policy, bad social policy, and bad economic policy.
The new language in version 5.0 of the draft Implementation Framework about restricting net additional CAFs in HUD-designated racially or ethnically concentrated areas of poverty is deceptively attractive, but would have little effect. As demonstrated by the map on page 6 of the Implementation Framework V 5.0, 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 R/ECAP language?
• 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 proposed 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.
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.
Question: Should Arlington County residents and workers receive a preference for committed affordable housing?
Comments (optional):
Current Arlington County residents should receive preference for county-subsidized affordable housing.
There is utility to having school and county government employees 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. The subsidy should be higher for emergency responders than for office workers.
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):
Yes, There should be great flexibility for accessory dwelling units.
No, 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 discredited Public Land for Public Good which was withdrawn by a unanimous vote of the County Board on January 27, 2015. Policy 3.5.2 section should be deleted from all three sections where it appears. 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 be for public services.
If 3.5.2. is not deleted in its entirety, then the modifier “stand-alone" should be deleted from policy 3.5.2 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. No one should be homeless.
5. Housing discrimination should not exist in Arlington.
6. All housing should be safe and decent.