To Council Members and City Staff;
First and foremost, we extend our deep appreciation to the City of Austin, and specifically Neighborhood Housing & Community Development, for creating the draft of a formalized and well-considered affordable Housing Plan. This effort aligns with key recommendations we provided in our 2011 CHDO Roundtable Position Paper (see attached).
Nevertheless, it is our considered position, as the consortium of affordable housing providers in the City of Austin, that the Housing Plan needs considerable work to achieve its full potential as a robust, goal-setting framework with clearly defined strategies to successfully address Austin’s burgeoning housing affordability crisis.
IDENTIFYING THE NEED + SETTING THE GOALS
On pg. 6, the 2014 Comprehensive Housing Market Study is rightly referenced as one measure of need – a housing shortage of 48,000 units at or below 30% MFI. However, there is a massive and growing shortage of housing for families 30-120% MFI as well. To be clear, these numbers are present day. In ten years, these needs will only increase.
- INCREASE AFFORDABLE UNIT GOAL: The Austin Housing Coalition’s position is that the Housing Plan’s Goals & Targets (pg. 11) are not sufficiently ambitious. The goals should directly aim at current conditions plus projected 10-year increases. The Housing Plan’s 35,000-unit goal (80% MFI and below) is dramatically low and fails to account for almost certain significant loss of unsubsidized affordable units.
We recommend NHCD work with the City Demographer, or other departments, to identify a rigorous methodology for developing a comprehensive affordable unit goal. We would not be surprised if the result doubled or tripled the currently identified goal.
- GOALS BY INCOME LEVEL: The Housing Plan needs defined sub-goals targeted by income level. The deeper analysis of need, as described above, should inform these goals.
- HOME OWNER SUPPORT: The Housing Plan needs to set well-defined goals for affordable home ownership units and home repair (also by income level).
- ACTIONABLE STRATEGIES: The Housing Plan needs to identify an overall, integrated strategy for success that goes well beyond the diagram on pg. 12. The City needs a complete roadmap with actionable strategies and a timeline organized by 1-year goals, 2-3 year goals, 3-5 year goals, etc.
- 20% MFI UNITS: There is a deep need for units at or below 20% MFI for renters without access to housing vouchers. We commend the included Target to address this need, but it should be considerably higher.
- AFFORDABLE, ACCESSIBLE, INTEGRATED: The Austin Housing Coalition supports the model of affordable, accessible, integrated housing for people with disabilities. 100% of all new-construction affordable housing units should be adaptable.
- INCLUDE PUBLIC HOUSING: Neither the City of Austin’s nor Travis County’s public housing authorities’ goals are included in the Housing Plan. HACA and HATC are key players and they need to be included.
- REGIONAL PLANNING: Though the City cannot set regional goals alone, the Housing Plan needs to stress the importance of regional affordable housing planning efforts.
- REMOVE MARKET UNIT TARGET: Since NHCD has no agency in the production of market units, we believe it is neither necessary nor useful for NHCD to specify a market-unit goal.
KEY POLICIES + PROGRAMS
Starting on pg. 13, the Housing Plan describes a laudable list of potential policies. However, the language used and description of said policies does not rise to the necessary level of clearly defined strategies with timelines and prioritized action steps structured to achieve success.
- PRIORITIZE MOST IMPACTFUL: The policies and programs need to be re-organized to prioritize and highlight those with the most potential impact.
Example: “Revise S.M.A.R.T. Housing Program” on pg. 20 has enormous potential impact on affordable unit production by market rate developers (if revised quickly and well). This program should be prioritized accordingly.
- WHAT AND BY WHEN: Each program or policy needs to written with actionable language with explicit guidance to City Council on what steps need to be taken and by when.
Example: Under “Prevent Displacement of Low-Income Homeowners” on pg. 13, the City cannot merely explore ways to help stabilize, instead, actionable steps need to be clearly identified.
MONITORING + WELCOME CENTER
- CENTRALIZED MONITORING STRUCTURE: To achieve the affordability goals, a large percentage of projected affordable units will have to be developed by market rate developers (SMART Housing, density bonus programs, etc.) There is currently no centralized mechanism for the City, for developers or for potential income-qualified tenants to track units, know where they are located or identify vacancies. With the dramatic increases in such units required, NHCD needs the budget and staff to implement such a centralized structure.
- WELCOME CENTER: If we are going to have any hope for success, market rate developers must be welcomed with direct support and assistance in building affordable units under SMART Housing or density bonus programs. With care and a customer service-oriented approach, a welcome center can transform what currently occurs as another hurdle put up by the City into a catalyst for market rate participation. This welcome center needs to be one of the first priorities in the Housing Plan.
With the current vacancy of the NHCD Directorship, City Council and the City Manager have the opportunity to hire a visionary leader that can guide NHCD and invigorate the implementation of the Housing Plan over the next 10 years. Please carefully review the Director’s job description with an eye to leadership with a powerful voice for advocacy and implementation.
However, please do not postpone the adoption of the Austin Housing Plan until a new Director is hired. We need an updated Housing Plan now.
As NHCD suggests on pg. 10, without sufficient and dispersed housing for Austinites at a range of incomes, Austin will become a city accessible only to the affluent and privileged with paradigmatic consequences for Austin’s quality of life, transportation network, job retention, fair housing legalities, and environmental condition.
The Austin Housing Plan needs to be just that, a Plan with explicit strategies and correlated implementation timeline. Please give NHCD the staff the support they need to revise the plan to become the most actionably ambitious Housing Plan in the country.