March 12, 2010

Thank you for the opportunity to provide comments on the Sustainable Communities Planning Grant Program (Program). The Council of Large Public Housing Authorities (CLPHA) is a non-profit organization representing 60 large public housing authorities (PHAs) that own and manage 40 percent of the nation’s public housing program; administer 26 percent of the Housing Choice Voucher program; and operate a wide array of other housing programs. We offer the following comments on behalf of our members.

The Obama administration has set as a priority a Sustainable Communities Initiative to foster “development patterns that achieve improved economic prosperity, environmental sustainability, and social equity…” The Administration believes this goal is best achieved by interagency collaboration, and has formed the Partnership for Sustainable Communities – collaboration between the Departments of Housing and Urban Development, Transportation, and the Environmental Protection Agency. The Partnership will focus on six “Livability Principles” that support the overall goals of the Sustainable Communities Initiative. Each agency will be tasked with preparing local, state, and regional agencies for “integrative regional planning for sustainable development.” The initial step is the creation and preparation of planning grants through the Program. 

The Program, as described in the advance notice for comment, would provide planning grants “to support multi-jurisdictional regional planning efforts…that empower jurisdictions to consider the interdependent challenges of economic growth, social equity and environmental impact simultaneously.” Specifically, the grants would be provided to planning efforts that “integrate housing, economic development, and transportation decision-making.” Grants will be provided for 1) preparation of regional plans where plans currently do not exist; 2) preparation of more detailed execution plans where such regional plans currently exist; and, 3) implementation of sustainable development plans and implementation strategies.

CLPHA supports the concept of using interagency collaboration to foster whole community approaches. In fact, many CLPHA members have already revitalized distressed public housing, replacing it with viable sustainable communities.

For example:

• The Rainier Vista HOPE VI project allowed the Seattle Housing Authority to work collaboratively with several local and state transportation agencies, various private developers, and numerous other stakeholders to locate affordable housing around Seattle’s new light rail system.
• The Denver Housing Authority plans to create a mixed-income transit-oriented community using HOPE VI funds to revitalize the South Lincoln public housing development.

In both cases, the housing authorities faced obstacles just to begin a dialogue with the interested parties, and then to successfully integrate local housing, transportation planning, and development. Specifically, these agencies had to deal with program and agency silos that prevented them from coordinating local public investment strategies. The Sustainable Planning grants should help incentivize metropolitan areas to bring together various stakeholders to better harmonize future development.

Housing Authorities Should Be Included in Any Regional Planning Efforts

As described in categories one and two of the proposed Program description, and consistent with the livability principles, each regional plan should include how a metropolitan area will address location and supply of low-income housing. Large housing authorities are often the largest owner and manager of low-income housing, and the primary coordinator of services for low-income needs in any given metropolitan area. As such, their housing stock and tenants would likely be most affected by any plan that addresses low-income housing.  Even in cities where the majority of low-income housing opportunities are tenant-based vouchers, housing authorities -- as administrators of that program -- would be the logical entity to provide input on planning for private low-income rental units as well. CLPHA recommends that each regional planning process include the local public housing authority(s) as a primary party.

Housing Authorities Should Be Eligible to be the Lead Agency for Funding Purposes

Housing authorities should be eligible to be the lead agency for funding purposes. In a number cities, housing authorities have a proven record of revitalizing communities, spurring economic growth and creating additional low-income housing using programs like HOPE VI. Furthermore, these agencies already have relationships with local transit agencies, service providers, and jobs programs – all elements of a sustainable community. In such cases where the housing authority has a proven record of collaborating with other local agencies, the housing authority should be an eligible lead agency.

HOPE VI and other Public Housing Activities Should be Pre-Certified Programs

Over the past 15 years public housing has a proven track record of redevelopment and rehabilitation through the use of mixed finance, the HOPE VI program, and other programs like Energy Performance Contracts. Many of these projects are transit-oriented, green, sustainable communities that provide broader access to jobs in and around the metropolitan area. The neighborhood benefits, and resulting community improvements, have been directly attributed to the redevelopment project. In fact, a 2008 study funded by the MacArthur Foundation, Assessing the Economic Spillover of Major Public Housing Redevelopment: An Economic Cost-Benefit Analysis of HOPE VI Developments, demonstrated the positive impact of HOPE VI redevelopments on property values, crime rates, and local and state government revenue. The study also highlighted newly formed partnerships to better connect residents to education, employment, and supportive services – opportunities that did not exist without the HOPE VI grant. Given this track record, some public housing activities should be considered “regionally significant” and should qualify for implementation funding.

$5 Million is Not Sufficient Funding to Cover Capital Costs of a Regionally Significant Development

According to the notice, category three will “support pre-development costs, capital costs for a regionally significant development or infrastructure investment, or land acquisition investments.” This appears to mean that funding in category three would provide actual capital funding to support a capital project. If this is not the department’s intent, then it would be useful for HUD to define what activities would be considered eligible under this program.

If the department plans to provide capital funding for projects that qualify under category three, then CLPHA is concerned with the size of the grants available to large metropolitan areas. It seems from the notice that the maximum grant available for large metropolitan areas is $5 million. Furthermore, the grant size does not vary by category (new plan, adaptation of an existing plan, and implementation). It has been our members’ experiences that funding at this level is not adequate to leverage additional funding and fully implement a large-scale capital project. In order for a proposed activity to be a catalyst for future investment and planned activities, it must first be fully funded. Too often, development plans are stymied by funders that back out, changes in financing terms, and other unforeseen circumstances. Large-scale public housing revitalization is no different. The most recent HOPE VI NOFA provided a maximum grant of $22 million, and most applicants leverage additional financing equal to or exceeding the grant. CLPHA believes that grants for implementation activities should be sufficient enough to adequately leverage additional funding. This could be accomplished by increasing the maximum grant for the implementation category.  

Thank you for the opportunity to comment on the proposed program, and we stand ready to work with the department to further improve the Sustainable Communities.