Comment Log Display

September 12, 2014
 
The Honorable Mary Nichols
California Air Resources Board

Re: Comments on Draft Interim Guidance on Investments to Benefit
Disadvantaged Communities

Dear Chair Nichols and Members of the Air Resources Board:

Thank you for the opportunity to provide comments and to
participate in the stakeholder process for development of the
definition of benefit to disadvantaged communities particularly
with regard to the Affordable Housing and Sustainable Communities
(AHSC) program.

The Non-Profit Housing Association of Northern California (NPH) is
the collective voice of those who support, build, and finance
affordable housing. We promote the proven methods of the nonprofit
sector and focus government policy on housing solutions for lower
income people who suffer disproportionately from the housing
crisis.

While we appreciate the work that the Office of Environmental
Health Hazard Assessment (OEHHA) did in creating the
CalEnviroScreen 2.0 tool, we are very alarmed that although “rent
burden” is explicitly called out as a factor to be considered in
the language of SB 535, it is not included as an indicator to
determine disadvantaged communities.

In fact, as the San Francisco Bay Area’s four regional agencies
have noted, the income thresholds used in the poverty indicator in
CalEnviroScreen 2.0 are uniform throughout the state even though
large regional differences in the cost of living exist in
California.

This flaw in CalEnviroScreen 2.0 must be addressed if this tool is
to be used to direct affordable housing investments in an equitable
way that truly targets need and avoids further concentrating
poverty.

We concur with and support the comments submitted to you by the 535
Coalition that the ARB Guidance must avoid using location/geography
or census tract as the sole criterion for assessing whether
affordable housing provides a benefit to disadvantaged
communities.

Investments in affordable housing that offer low-income and
minority populations access to what the U.S. Department of Housing
and Urban Development (HUD) calls “communities of opportunity” are
essential to “affirmatively furthering fair housing” and providing
equal opportunity for lower income people to access affluent
communities with high quality transit, good schools, parks and job
centers.

The fact is homes affordable to lower income households benefit
disadvantaged communities wherever they are built, as they increase
choices, mobility, and access to opportunities for disadvantaged
communities and low-income households in more affluent communities
while reducing segregation and the concentration of poverty.
Affordable homes also improve health outcomes for lower income
families and improve children’s academic performance. This is
already explicitly noted in the list of needs identified by
community advocates (see item 8 on p. 17 of draft guidance), but
inexplicably is not included in the draft criteria for evaluating
affordable housing projects (see page 1-2 in Appendix 1).

We urge ARB to refine its definition of what it means to “provide a
benefit to a disadvantaged community” to include benefits to
disadvantaged households and populations as this is both the intent
and explicit language of AB 1532 and SB 535.

The language on page 15 addressing all agencies receiving GGRF
funds should be changed to read: “Target funding, to the extent
feasible, for projects that benefit disadvantaged communities and
households, whether or not these investments are within communities
in the top tier of disadvantaged communities that qualify for SB
535 funding.” We recommend that ARB’s GGRF Guidance include
prioritization for investments that benefit:
·      Census tracts with overall CES scores in the top 40%;
·      Census tracts with an indicator in the top 40%, if the
project will address that indicator; and
·      Low-, very low-, or extremely low-income households, as
determined by Area Median Income (AMI).

The construction of affordable homes in all locations across our
state helps avoid gentrification and displacement especially in
high cost areas, promotes racial and socioeconomic integration,
improves the quality of life for low-income individuals and
families and directly benefits disadvantaged households and
populations. Acknowledgement and recognition of these many benefits
of affordable housing to disadvantaged households and populations
should not be limited to particular census tracts.

Thank you for the opportunity to comment.

Sincerely,
Michael Lane, Policy Director
Non-Profit Housing Association of Northern California (NPH)