Comment Log Display

Commissioners:

I write on behalf of Mercy Housing California, a statewide
affordable housing developer active in Southern California, the San
Francisco Bay Area and the Sacramento Valley.  We have developed
over 10,000 affordable homes in California, and currently have over
3,000 affordable homes in development.  We appreciate the
opportunity to comment on the design of the Affordable Housing and
Sustainable Communities Program (AHSCP) and in particular on the
key definitional issues related to Disadvantaged Communities.

While we have comments on the definition of Disadvantaged
Communities, our comments are focused on the critical issue of the
definition of benefit.   Mercy Housing provides affordable housing
and services to over 13,000 people with an average household income
of $15,000 per year.  As such we are all too familiar with the
challenges that lower income individuals face in terms of
environmental conditions, health care access, school quality, and
job access.   

Based on our experience, it would be a mistake to define the DAC
benefits of affordable housing in particular as simply based on
geographic location in a disadvantaged community.   
Rather, we would encourage the Air Resources Board to define
benefit in broad terms that account for the many ways that lower
income families choose to improve their lives and the lives of
their children.

We believe there are at least two critical ways to determine the
DAC benefits of affordable housing: 1) location in or within one
mile of a DAC; or 2) location in non-DAC communities that provide
low income populations with increased access to transit, quality
jobs, schools, and healthy environmental conditions.

We have worked in many disadvantaged communities in which lower
income residents advocated for environmental clean-up, better
schools or improved transit, only to be displaced by the lack of
permanent, affordable housing.   For those reasons, it’s critical
that some of these funds be used in part to create permanently
affordable housing in transit-rich locations that typically
gentrify when local conditions improve.

Conversely, we have worked with many families who would prefer to
have opportunities to move into affordable housing in other, less
impacted communities with less pollution, higher performing
schools, and/or more high-quality jobs.   We are currently leasing
up a family property in the Mission Bay neighborhood of San
Francisco (a former brownfield), and had over 3,000 applications
for 150 apartments.    Mission Bay is 70% market rate housing with
apartments renting for $3,000-$5,000 per month.  What makes Mission
Bay so desirable?  Quick transit access via Muni, CalTrain and BART
to over 1 million jobs in downtown San Francisco, Oakland, and
Silicon Valley. 

For that reason, we believe it is also critical to define benefit
in terms of transit-oriented affordable housing that serves
households earning less than 60% of median income.    Ideally the
Air Resources Board would count housing produced within 5 miles of
a DAC or within a key transit-served commute shed that ensures that
DAC residents have equal access to those housing and transit
opportunities.  

As it relates to infrastructure, we encourage the Air Resources
Board to maintain a link to affordable housing production when
considering funding through this program. As noted by many
commentators, expensive infrastructure improvements with no link to
equity goals like affordable housing are unlikely to benefit lower
income people in the medium to long term.

At the workshops, we heard that the AHSC should catalyze the
development of affordable housing and infrastructure at a district
or neighborhood scale, and generate significant environmental
benefits with that approach.  Mercy Housing California, in
partnership with Related California and the Cities of San Francisco
and Sacramento and their housing authorities, as well as other
partners, is working on redeveloping two large, severely distressed
public housing developments where the housing and infrastructure
have aged beyond repair and physical, social and economic isolation
of these sites have led to extreme poverty for its residents.   Los
Angeles, San Joaquin, Sacramento, San Francisco and Sutter Counties
are all just some of the areas in which there are large public
housing communities that are physically isolated and underserved by
transit, services and quality housing.  

We believe that these types of projects would be ideal for this
funding source as they address environmental contaminants like lead
paint and asbestos, and numerous conditions leading to asthma,
respiratory illnesses and other indicators of poor health.  These
public housing communities are also characterized by extreme
poverty, linguistic isolation and high unemployment.  Given the
unique histories of environmental harm and vulnerable populations
associated with public housing, we would respectfully request that
California Air Resources Board consider any public housing project
as a unique category that should be considered a DAC regardless of
census tract location.

Lastly, in terms of defining Disadvantaged Communities, we
encourage the Board to use a definition that blends population
characteristics and pollution characteristics.   While we do not
have a strong preference for which of the methodologies (#1, #4, or
#5) that could be used, we feel strongly that the Board should
define DAC in terms of the top 25% of communities in any of the
formulas.  We encourage more inclusiveness because it is nearly
impossible for any statistical sorting process to account for the
many local conditions and arbitrary boundaries that census tracts
may present as it relates to poverty and pollution.   Choosing a
more inclusive definition will increase the likelihood that
legislative intent will be met.
 
Thank you for giving us the opportunity to provide our comments and
suggestions. Please contact me at DShoemaker@mercyhousing.org or
(415) 355-7151 if you have any questions.