[Note from Keith Howard: I have compiled the information in this post, which aims to present a factual account of developments so far. I was able to attend two meetings (on July 17th and 18th) with officials from the Denver Office of Economic Development (OED.) These meetings were held by OED for the purpose of discussing the Recommendations and hearing the comments,reactions and suggestions from members of the public and neighborhood organizations. The italicized explanations/clarifications in the Draft Recommendation document, at the end of this post, are mine. I am a member of the SUNI Board of Directors.]
Here is a timeline of recent events related to affordable housing issues and Sunnyside:
July 15th. Denver Office of Economic Development (OED) releases the draft summary of Recommendations from “Denver’s 5-Year Housing Plan.” OED also announces a series of public meetings aimed at soliciting comment on the recommendations. The six evening meetings run from the 17th through the 24th. OED says all comment should be submitted by the 25th, giving this explanation for the short time window: Between the 25th and the 30th of July OED plans to “write the 40-page plan.” OED did not email registered neighborhood organizations to announce the publication or the meetings. SUNI heard about all this indirectly. Here is a link to the full Recommendations document, which I’ll also paste at the end of this discussion: http://www.denvergov.org/Portals/690/documents/New/Denver Housing Plan – Draft Summary.pdf
July 21-23 . The SUNI Board of Directors meets and discusses the subject, agrees a statement.
July 25th. SUNI’s letter goes to the head of OED plus two other OED officials, the Mayor, all City Council members, and the executive director of the Denver Housing Authority.
July 26th. The Zoning & Planning Committee of Inter-Neighborhood Cooperation (the umbrella group of all Registered Neighborhood Organizations [RNO]) discusses the housing plan recommendations and agrees a resolution to send to the full INC Delegate meeting in August.
August 9th. The INC Delegate meeting votes to adopt the resolution and to send a letter with the resolution to OED and to the Mayor.
September 10th. In reply to a query about progress on the Housing Plan, Rick Padilla (Director of OED) replied as follows:
“Mr. Howard, my apologies for any the misunderstanding, but the close out for public comment was the end of July, since that time we have been drafting the full document and vetting through the appropriate departments. After the Mayor’s office adopts it and we go to print, we anticipate announcing a date for a public announcement.”
September 15th. Mayor Hancock’s announced his proposed budget for 2015. Among the bullet points of the press release is the following item:
“$3 million for affordable housing, bolstering an initial $3 million budgeted in 2014, to create rehabilitate or preserve significant numbers of housing units by leveraging public and private funding sources.”
Here is a link to the Mayor’s announcement letter and the detailed Budget proposal: http://www.denvergov.org/LinkClick.aspx?fileticket=cpm4OgorFsY=&tabid=442869&mid=517000
September 29th. SUNI received the following announcement/invitation:
Housing Denver Announcement Event
A Five-Year Plan: 2015-2019
Please join Denver Mayor Michael B. Hancock for the announcement of Housing Denver, a new comprehensive housing plan for the City and County of Denver. Housing Denver is a multipronged, collaborative five-year plan that will harness public- and private-sector resources to deliver accessible housing opportunities for individuals and families of all income levels throughout the City. Date:
Monday, October 6, 2014 10-10:30 a.m.
Location:
Aria Apartments 2791 W. 52nd Ave.
RSVP:
Please register by sending an email to OEDEventsRSVP@ denvergov.org, indicating your name and number of attendees. In case of inclement weather, this event will be moved to
an alternate location and registered attendees will be notified via email.
At this writing (9/30) the housing plan has not yet been published.
Background
Some time ago the Mayor appointed a Housing Advisory Group. This working group did not include any neighborhood representatives/advocates. The remit of the group was to formulate a plan for coping with the shortage of housing suitable for people who don’t make much money – from the chronically homeless all the way to people who earn as much as 120% of median income. The Recommendations document is like an executive summary of the Housing Plan. OED announced in its public meetings that “the Mayor has adopted these recommendations.” Note: OED describes this whole housing plan as a mayoral initiative which will not be presented to the City Council for approval. [The Denver Office of Economic Development is the conduit for federal money for housing; 96% of all the housing money OED parcels out comes from HUD in Washington. The amount Denver now receives for housing is down 15% in the last few years, and it is not likely regain lost ground any time soon.]
The Recommendation document is especially interested in creating and/or preserving affordable/subsidized housing of all kinds in “rapidly gentrifying neighborhoods” which will be served by new rail transit. Obviously Sunnyside is such a neighborhood. The SUNI Board thought some observations and proposals were in order. Here is the text of the letter SUNI sent to Rick Padilla, the Director of the Denver Office of Economic Development:
25 July 2014
Mr. Rick Padilla, Director
Denver Office of Economic Development
Dear Mr. Padilla,
On July 15th of this year your office published a Draft Summary of its Five-Year Housing Plan Recommendations. The Sunnyside United Neighbors, Inc. Board of Directors, having read this document and having had a report of what transpired at two meetings on this subject (6 PM on July 17 and 4 Pm on July 18), makes the following observations:
Taking as its basis the rising cost of housing in Denver, the Summary of Recommendations proposes various actions, with special emphasis on actions in “rapidly gentrifying neighborhoods” and in neighborhoods served by new rail transit infrastructure. Sunnyside (especially Sunnyside east of Pecos Street) is a conspicuous example of such a neighborhood.
But the Summary document ignores the fact that past actions by the Denver Housing Authority and other City agencies have created heavy concentrations of public and other non-market housing in Sunnyside, as well as in some other neighborhoods. We believe it is essential for the City administration to notice the obvious fact that not all of Denver’s neighborhoods are starting from the same place with reference to the distribution of affordable housing. Of course we recognize that Sunnyside will have a sizeable component of non-market housing for the foreseeable future. But some principle of equity must operate in the determination of new actions.
A very damaging and persistent consequence of the creation or intensification of areas of concentrated poverty is serious stress on the local schools. Sunnyside already has decades of experience with this sad consequence, the first victims of which are our neighborhood’s children. This is one of the main reasons why the assembly of dense clusters of public and subsidized housing is now recognized as bad policy. This view is not controversial. At the two meetings referenced (above) Mr. Lucero, Deputy Director of your Department, readily conceded the need to avoid “excessive” concentrations of non- market housing. We live in hope that the present natural evolution of the Sunnyside neighborhood will gradually alleviate the perverse side effects of past actions.
The Summary document roughly delineates a significant mapping project. Mr. Lucero told the assembled gatherings referenced above that these maps will contain all relevant [housing] information and will be fully transparent to the community, as well as interactive. We welcome this project, and we believe the data these maps aggregate will be important for the shaping of reasonable housing policy decisions.
In light of these observations we ask that the City administration commit to these actions:
1. From the data assembled by the mapping project, the City will calculate the ratio of non-market housing to all dwelling units for each census tract in the City. From this table of ratios a median ratio can be ascertained. This median ratio will provide an impartial benchmark, specific to the City of Denver, for the identification of existing or potential excessive concentrations of non- market housing.
2. The City will evaluate all future housing actions with reference to their potential effect on local schools, especially on schools that are already struggling or failing. The City will share these evaluations with the residents of the surrounding neighborhood(s).
3. The City will hold all non-market housing to the same standard of property maintenance as pertains to other housing. We refer here not only to public housing, but also to Section VIII properties, as well as subsidized, supportive, affordable, and workforce housing, and including group homes of all types.
Sunnyside United Neighbors, Inc. has had very little time to react to the Summary document so recently published by the Office of Economic Development. It is likely that we will have further observations and ideas, and we will be glad to collaborate on the development of programs that may affect Sunnyside. But we will need – and we will certainly appreciate – earlier consultation and a more liberal time window in which to respond.
Very sincerely yours,
Andrew Novick,
Acting SUNI President
[Copies of the above letter went to John Lucero (Deputy Director of OED,) Seneca Holmes (strategic analyst,) Mayor Hancock, all members of the City Council, and the executive director of the Denver Housing Authority. To date SUNI has not received even a single acknowledgement of the comment letter.]
Here is the text of the Inter-Neighborhood Cooperation resolution adopted on 8/9:
Inter-Neighborhood Cooperation strongly urges the Mayor, the Office of Economic Development, the Denver Housing Director, the Housing Advisory Council and the City Council that 1) Registered Neighborhood Organizations and other citizens must be meaningfully engaged in the development and implementation of the Housing Plan, including the location of affordable housing developments; 2) serious consideration must be given to not further encouraging over-concentration of lower-income housing units in any Denver neighborhoods and 3) OED must develop tools to measure the concentration of lower-income housing units in Denver neighborhoods.
Here (below) is the text of the Draft Summary of Recommendations. I attended two meetings with members of the OED staff. I have added a few bracketed interpolations in italics to explain, clarify, and expand on some issues from information that came out during the meetings.
DRAFT:
DENVER FIVE-YEAR HOUSING PLAN RECOMMENDATIONS
The Denver Five Year Housing Plan is a living document that will state the City’s principles, priorities, goals and initiatives as they concern Denver’s housing needs. The Housing Plan will be the primary guide informing the City’s housing policies and resource allocations for the next five years. Addressing Denver’s housing needs has, and will continue to, require numerous community collaborations and partnerships. To this end, this document hopes to create the context in which the City will work with community housing partners and stakeholders.
Listed below is a summary of the proposed priorities and action items to be included in the Denver Five Year Housing Plan. This summary is meant to help solicit feedback from our community stakeholders to inform the drafting of the final document.
[By “stakeholders” OED primarily means enterprises and individuals that are professionally involved in the business of organizing, building, financing, and managing affordable and other non-market housing.]
Priority 1: Increase Housing Resources
Five years ago, the Office of Economic Development’s annual allocation from the Department of Housing and Urban Development, the City’s primary source of housing funding, was $15.9M. That allocation has steadily decreased year over year. This year’s OED allocation is $10.4M, a decrease of 35%. Currently, the City has no other consistent funding sources to backfill the decrease in federal resources.
Action 1A- Develop a permanent funding stream, of considerable magnitude, for the express use of housing preservation and development.
Action 1B- Create a functioning revolving housing fund utilizing the $3M from the 2013 General Fund budget allocation. Ensure the existence of a comprehensive set of sound governance and accountability provisions guide the administration of this revolving housing fund.
Action 1C- Use innovative funding models, such as Social Impact Bonds, in conjunction with available housing resources to develop new supportive housing units and services for the most vulnerable and frequent users of City services. Continue to study and articulate the benefits and savings of providing supportive housing over the current system of paying for jail, detox, and other emergency services.
Action 1D- Dedicate revenues generated by the Metro Mortgage Assistance Plus Program to the revolving housing fund to grow resources available for housing programs. Make the fund self-sustaining.
Action 1E-Work with housing partners including the State Department of Housing (DOH), Colorado Housing and Finance Authority (CHFA), and the Denver Housing Authority (DHA) to target subsidies for 4% Low Income Housing Tax Credit (LIHTC) projects.
Action 1F- Continue to use the City’s lobbying influence at the State and Federal levels to educate decision makers and stakeholders to help preserve existing housing resources and, when possible, expand those resources.
- Pursue Choice Neighborhood Initiative Grant for Sun Valley Neighborhood
- Pursue Denver Promise Zone designation(s)
[OED stated that finding more funds for housing efforts is their first priority by a long way. The money Denver OED spends on housing comes almost entirely from the Federal Department of Housing & Urban Development. This money is a pass-through, not affecting the City budget. OED told the meetings I attended that they do not know where additional money will come from.]
Priority 2: Revise and Articulate City Funding Process
The City proposes to work openly with the housing community to revise its funding criteria and funding priorities to be transparent and appropriately consistent with our housing development partners.
Action 2A-Work with CHFA, the State DOH, DHA and local housing development community to align priorities for housing funding, define development preferences and establish consistent underwriting criteria for project applications.
Priority 3: Reduce Regulatory Burden of Subsidized Housing Development
Where cash funds are scarce, it becomes necessary to look at other options that can help facilitate the creation of affordable housing. Consequently, the City will continue to examine its regulatory process to provide relief and efficiencies that could help reduce the time and cost of development.
Action 3A-Work with Community Planning and Development and Public Works to review requirements for land planning, design and infrastructure requirements with the aim of reducing the burden on Workforce and Critical Needs housing projects.
Action 3B- Consider accelerated processing and fee waivers for housing projects that have City investment or are utilizing LIHTC.
Action 3C- Work with Denver Water to review the connection between System Development Charges and the City’s housing goals.
[Neighborhood representatives specifically asked whether provisions 3A and 3B mean that the City will ask for changes to zoning code rules, e.g. parking requirements, land area coverage, etc., in order to make it easier (cheaper) to build new below-market housing. OED officials replied that they do not intend to ask for any changes to zoning rules/requirements.]
Priority 4: Provide Additional Critical Needs and Homeless Housing
The Mayor’s “Safety Net” priority emphasizes Denver’s commitment to providing decent, safe and sanitary housing for our most vulnerable citizens, Denver remains committed to housing with wrap around services for our citizens that have special needs.
Action 4A- Prioritize available housing resources for Critical Needs and Homeless Housing and supportive services.
Action 4B- Establish a standardized access and assessment process with coordinated referral and housing placement to include appropriate supportive services.
Action 4C- Invest in a model Single Room Occupancy/micro-unit development designed for Workforce and Critical Needs housing, including those individuals experiencing homelessness.
Action 4D- Encourage housing advocates to work with neighborhood planning groups, property owners and property managers to help alleviate any negative perceptions concerning the placement of critical needs and homeless housing, and supportive services.
[At the 7/18 meeting with OED officials RNO representatives objected to the subtext of Action 4D, namely, that objections to placement of certain kinds of public functions are only the result of “negative perceptions” — in other words wrong thinking by neighborhoods, property owners, etc. This was found to be a tendentious and incomplete description of the situation.]
Priority 5: Increase Housing Diversity
Denver continues to strive for housing balance to promote the vitality and enhance the neighborhoods within its boundaries. In doing so, it recognizes that mixed income, mixed use developments provide the best opportunities for continued successful and livable communities.
Action 5A- Develop a dynamic mapping system that identifies priority areas for workforce and Critical Needs housing. Identify housing opportunities in rapidly gentrifying neighborhoods and for family housing opportunities that provide proximity and access to quality schools, child care, healthy foods, parks, playgrounds and green space. This analysis will then be used to define broad neighborhood affordability goals for new construction of Workforce and Critical Needs housing.
Action 5B- Establish a specific plan to create or preserve affordable housing in those areas where the City indirectly contributes to rising residential costs through infrastructure, transportation and business investment.
Action 5C- Create a continually updated database of government owned and distressed and/or underutilized property that could be utilized for housing.
Action 5D- Adopt a resolution that disposition of City land will be prioritized for affordable housing and community serving development.
[Concerning Action 5A: In two public input meetings (7/17 and 7/18) the Deputy Director of OED, John Lucero, was pointedly asked about the mapping project. Mr. Lucero stated that the maps will collect and present comprehensive data on all non-market housing (public housing, Section VIII, critical needs, supportive, group homes, affordable developments, etc.) showing their locations with sufficient precision to identify areas where “excessive concentration” already exists or where additional placement(s) would bring saturation. RNO participants in these meetings noted that such useful data will allow the development of objective measures for the definition of “excessive concentration” and “housing diversity.”]
Priority 6: Preserve Workforce and Critical Needs Housing
Preserving and rehabilitating existing low-income and workforce rental housing stock is the most cost effective strategy in addressing the need for affordable housing. Rehabilitating an existing affordable rental unit can cost 1/3 less than a newly constructed affordable apartment.
Action 6A- Activate the City and Urban Land Conservancy (ULC) low income/special needs and workforce housing preservation online mapping tool. Identify a dedicated funding stream to allow for website maintenance and data updating.
Action 6B- Officially adopt recommendations that came from the National Housing Trust and Mile High Connects’ “Preserving Affordable Housing in Denver” Study by amending the current preservation ordinance to include additional covenant restricted housing units, such as LIHTC housing, and increase the required amount of time for the notice of intent to sell an income restricted development.
Action 6C- Convene a stakeholder group to begin the formation of a permanent Preservation Collaborative that can be called upon to respond to approaching covenant expirations.
Priority 7: Provide Greater Home Ownership Opportunities
For those individuals who have found homeownership opportunities, it is essential they have access to housing counseling and services including pre-purchase education, down payment assistance, financing education, and in the worst case, foreclosure intervention and assistance.
Action 7A-Work assertively to promote condominium development by finding and endorsing a solution to the current construction defects barrier.
Action 7B- Continue to offer and expand the Metro Mortgage Assistance Program to include additional regional cities, counties and housing authorities.
Action 7C- Make housing counseling mandatory for all homebuyer assistance programs.
Action 7D- Encourage all home buyer and housing counseling assistance programs to refer buyers to financial literacy education services.
Priority 8: Encourage Sustainable Housing Development
Critical needs and workforce housing development will be expected to address the City’s community health and environmental sustainability priorities. These priorities include proximity to public transit (light rail stations and high frequency bus corridors), green building standards, and efficient energy and water infrastructure and appliances. Residents must also have access to fresh foods, as this is a critical element in supporting a physically healthy community. These priorities, while promoting environmental responsibility and healthy lifestyles, offer a substantial economic benefit to the residents
Action 8A- Support the regional expansion of the Denver Transit Oriented Development (TOD) Fund, with the City of Denver’s investment to be reserved for Denver specific projects.
Action 8B- Prioritize housing developments in proximity to TOD (1⁄2 mile from light rail station or 1⁄4 mile high frequency bus corridor).
Action 8C- Promote and support the development of a net-zero neighborhood development as a replicable demonstration project.
Action 8D – Critical needs and workforce housing developments receiving City subsidy must demonstrate that future residents will have reasonable access to fresh foods.
Action 8E- Work with Denver Water to strengthen the City’s commitment to water efficiency.