San Diego s Voice for Affordable Housing

Transcription

1 July 15, 2015 SANDAG Board of Directors, Chair Jack Dale Transportation Committee, Chair Todd Gloria Regional Planning Committee, Chair Lesa Heebner 401 B Street, Suite 800 RE: Draft San Diego Forward: The Regional Plan Honorable SANDAG Board and Committee members: On behalf of the San Diego Housing Federation, I am writing the San Diego Association of Governments (SANDAG) to submit our comments and feedback for the draft of San Diego Forward: The Regional Plan. Founded in 1990, the San Diego Housing Federation (SDHF) serves as the collective voice of those who support, build, and finance affordable housing in the San Diego region. As an interested stakeholder in SANDAG s work, SDHF staff have participated in several of the San Diego Forward workshops and we appreciate the opportunity to provide this feedback on the draft plan. While we are pleased to see housing identified as important in Chapter One of the Regional Plan, we are disappointed to see little in the plan that will actually address our region s housing needs. With housing so largely overlooked, the Regional Plan will do little to help improve regional transit into the future. This is troubling for many reasons, especially because, as is noted in SANDAG s 2008 Regional Prosperity Study, if today s housing trends continue, what will look like a transportation problem in 2030 will have actually been caused by a housing problem that could have been prevented by acting today. 1 We also share the concerns of our colleagues at Circulate San Diego, Climate Action Campaign, and the Environmental Health Coalition that this plan falls short in working to achieve greenhouse gas (GHG) emissions reduction targets for 2030 and 2050 through early and increased investment in transit and active transportation options. Such investment is particularly important to residents in affordable communities, which includes seniors, those living with disabilities, and other lower-income San Diegans who are less reliant on cars and more reliant on public transportation options than the average residents. However, in order to meet these GHG emission reduction goals, the proposed Regional Plan must go much further in not only making the right transit and active transportation investments, but ensuring that affordable housing is a component of development around these investments. Housing is the missing leg of the stool in the Regional Plan and is a critical part of achieving regional sustainability, 1 SANDAG San Diego Regional Economic Prosperity Study, 2008, p. 14

2 reaching the goals of SB 375 and Executive Orders S-3-05 and B-30-15, and meeting regional vehicle miles traveled (VMT) and GHG reduction goals. We recognize that SANDAG faces inherent challenges in promoting affordable housing as part of its Regional Plan: namely, the agency s lack of direct land-use authority as well as the current limitation on funding for affordable homes within the agency s charter. That said, there are many steps SANDAG can take that can play a critical role in helping ensure the creation and preservation of affordable homes throughout San Diego County to meet GHG emission reduction and other agency goals. In order for the Regional Plan to take greater strides in reducing GHG emissions and addressing affordable housing needs as a part of solution to make such reductions, we offer the following comments and recommendations: Explore ways SANDAG can provide direct funding for housing In order to better connect transit to riders, we urge SANDAG to look for ways to provide direct funding for affordable housing. This could be accomplished through state legislation, similar to SB 1685 (Kehoe), a SANDAG-sponsored bill that expanded purposes for which revenue can be used to allow for funding of environmental mitigation measures. A similar bill could be introduced that would provide SANDAG with flexibility to fund housing to spur investment in affordable housing near transit as part of GHG reduction strategies. If this is done promptly, SANDAG could and should include affordable housing as a component of the proposed Quality of Life ballot measure. As we mentioned in our January 2015 letter to the SANDAG Board of Directors, lack of affordable housing has forced more San Diegans to drive to qualify in order to find an affordable place to live. This is unsustainable and must be addressed as a part of a regional Quality of Life initiative. Work with transit agencies to identify land for transit-oriented affordable housing SANDAG should also work with the San Diego Metropolitan Transit System and North County Transit District to identify land owned by these agencies that could be set aside for affordable housing. Earlier this year, the Los Angeles Metropolitan Transit Agency voted to set aside 35 percent of its own land for development of apartments near transit for low-income residents. Recognizing that a majority of their riders are low-income and struggling to pay rent, LA Metro s land dedication is a step in the right direction to keep ridership up rather than forcing riders to abandon transit and begin to drive as they are forced to move further away from transit hubs in search of a place to live that they can afford. Providing land set-asides near transit also makes affordable housing development at these sites more feasible by eliminating competition from market-rate developers that drives up the cost of land at these sites. Incentivize strong local-level housing programs

3 As noted in Appendix U-13, one strategy SANDAG could implement to encourage affordable housing development is to provide incentives for local jurisdictions to meet their affordable housing needs. This could be accomplished by dramatically increasing funding for the Smart Growth Incentive Program and putting in place measures that ensure funds are allocated to jurisdictions with strong affordable housing and anti-displacement programs and policies. Rewarding cities that have strong housing programs, such as inclusionary housing policies, housing impact fees and other tools that promote affordable housing as a part of residential growth furthers smart growth principles by providing adequate opportunity for affordable housing in proximity to transit and other services. SDHF would be pleased to work with SANDAG to identify how to create such guidelines for the Smart Growth Incentive Program. Even if SANDAG does not pursue our first recommendation to pursue avenues to allow the agency to directly fund affordable housing programs, the agency can put in place requirements associated with any Quality of Life initiative that will direct funds only to those cities with strong affordable housing policies and programs. This could help generate hundreds of millions of dollars for affordable communities throughout the region. Help make San Diego competitive for other funding sources The Draft Regional Plan continues to prioritize freeway expansion and other auto-centric investment over public transportation and active transit. By not prioritizing transit, the Regional Plan not only falls short in meeting GHG reduction goals, but leaves San Diego continuing to fall behind in competition for transit-related funding programs that reward robust transit infrastructure. Programs such as the state s Transit Oriented Development (TOD) Housing Program and the newly created Affordable Housing and Sustainable Communities (AHSC) Program that provide funding for affordable homes near transit rely on availability of adequate sites for development. The Regional Plan can help increase the potential to tap into these resources by investing in public transit and active transportation rather than highway expansion. Strengthen SANDAG s Regional Transit Oriented-Development Strategy In its current form, the Regional Transit Oriented Development (TOD) Strategy does not go far enough to implement the recommendations made in the strategy document. Once again, this is an area where SANDAG has opportunity to flex its power of the purse strings and incentivize cities that have policies and land uses in place that reflect the best practices identified in the Regional TOD Strategy document. This rewards jurisdictions that are TOD ready. SANDAG should be a regional leader on housing issues We reiterate the points made in our January 2015 letter to SANDAG s Board of Directors SANDAG must take steps to clearly identify ways housing fits into its work and this could begin by reconvening the Regional Housing Working Group. This action is recommended as a best practice in SANDAG s

4 housing affordability white paper on Regional Transit-Oriented Development Strategy 2 and makes sense for working to meet GHG reduction goals. According to a recent study published by the Center for Neighborhood Technology, housing affordability, availability, and location near transit particularly for households with lower-incomes plays a critical role in our ability to reduce vehicle miles traveled and increase transit ridership. This report 3, released on July 14, concluded, In short, due to the residential selection, household composition, receptivity to higher density housing, and income levels, allocating land and funding to enable development of location-efficient areas in a way that is affordable to lower-income households is expected to yield greater VMT benefits per parcel and per person than allocating the same land to higher-income people. If SANDAG is truly dedicated to its GHG reduction goals, it must take more of a leadership role to address regional housing issues. Additionally, in other regions, we have seen Metropolitan Planning Organizations (MPOs) and other transportation agencies demonstrate significant leadership on affordable housing issues. Both the Southern California Association of Governments (SCAG) and LA County MTA have convened housing developers to cross-educate on opportunities such as the Affordable Housing and Sustainable Communities program. While SANDAG staff have made efforts in this area, most recently at the Complete Communities Marketplace convening in 2013, such leadership has not been forthcoming from the SANDAG board, and instead seems to be going in the opposite direction as evidenced by the agency doing away with its housing working group. Closing In San Diego Forward: The Regional Plan, SANDAG has the opportunity to lay a framework that will have impacts for many years to come. The San Diego Housing Federation urges SANDAG to adopt a plan that will significantly increase resources to create housing opportunities for low-income residents, spur early and ongoing investment in transit and active transportation, and maximize environmental and social equity outcomes. We are looking to you to be the leader in shaping a better future for all residents in our region, especially for those most impacted by pollution. Thank you for the opportunity to provide these comments. We look forward to continuing to work with SANDAG to preserve and increase the region s supply of affordable homes. Sincerely, Bruce Reznik Executive Director 2 SANDAG Working Paper Housing Choices and Affordability, April 2015, p.8 3 Newmark, G. & Hass, P. (2015) Income, Location Efficiency, and VMT: Affordable Housing as a Climate Strategy. Center for Neighborhood Technology

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