My Comments on Metro Community Investment Strategy.

Metro has published their Community Investment Strategy for public comments until October 1st. 

Comments should be sent to arrive NLT October 1 ( I recommend you send EARLIER) by e-mail to 2040@oregonmetro.gov, or snail mail to:

Metro

Community Investment Strategy comments

600 NE Grand Ave.

Portland, OR 97232

The summary of the Investment Strategy and COO recommendations are in a 24 page document HERE.

The details are found in supporting documents HERE. (One of those documents,  Draft Capacity Ordinance and Exhibits includes proposed changes in the Framework plan and the Functional plan). 

While comments on the COO recommendations and other sections of the strategy may be useful, my view is that comments on the Framework and Functional plan language are the most critical, and especially the draft Functional Plan language.  Here's why:

• The only portion of the strategy that can be enforced at the LOCAL level are requirements that are included in the Functional Plan. 
• Changes in the Framework Plan may set Metro policy but they are NOT enforceable at the local jurisdictional level. 

This distinction is important because the only NEW affordable housing requirement of note, tracking the percentage of renter households spending 50% or more of their income for housing and transportation, is ONLY found in the Framework Plan, and is thus a region wide goal, and NOT a local goal.  

The draft plan has NO new affordable requirement that I can see for local government in the Metro functional plan, and changes in compliance reporting in Title 8 of the Functional Plan ALSO give the Metro Chief Operating Officer the authority to waive ANY functional plan reporting requirement, including local progress toward voluntary affordable housing targets, and reporting on changes in affordable housing supply. 

All of my comments can be found HERE; my recommendations for changes in the Metro draft amendments to the Framework and Functional plan are bold faced in "Corrective Actions" 9 and 10.
(NOTE: My comments are in MS Word 2007-2010 format. Do NOT try to open the file in your browser. To OPEN the file right click the link above and SAVE /download the file to your PC; once it has downloaded THEN double click the file and it will open). 

In particular I recommend that a ONE word change be made to Title 6 Functional plan language related to planning in "Centers, Corridors, Station Communities, and Main Streets ".  The current draft only "recommends" that "needed housing" (as defined by ORS) be included by local government in their planning; and I suggest that "recommend" be changed to "require" that local government consider ORS defined "needed housing" in their planning for Centers/Corridors. 

Even without a specific set aside existing Metro Functional plan language [Title 7 (307.740 B.3.] already requires reporting on changes in affordable housing in Centers/Corridors. However, Metro has waived existing required local semi annual reporting on changes in affordable housing supply due in both 2007 and 2009, but if that data were available it likely would should little affordable housing activity and/or a lack of equitable distribution. 

Metro projects some $3.8 billion of residential incentives will be made in Centers and urban renewal areas, so the failure to require that "needed housing"  be included in local planning for Centers, etc would allow spending of those incentives exclusively for multifamily home ownership units and high end rental units.

Originally created and posted on the Oregon Housing Blog.

Metro Local Infrastructure "Residential Incentives"/Subsidies: $3.8 Billion Projected, but ZERO Require Income Targeting; City of Portland to Produce 71% of Units, Supply 84% of $$.

Metro is accepting comments on their Community Investment Strategy/ Infrastructure report through October 1, 2010. (My prior post HERE).

I hope to get a complete set of my comments posted by the early part of next week in time for others to review and make their own comments. [I will provide more details on where to comment in a future post, I would NOT use the on line questionnaire].

In the interim, this post contains one of the most important conclusions I reached after reading through most of this long report and its appendices.

Problem 1: Metro Says 97,290 Units will Receive Residential Infrastructure "Incentives"/Subsidies, But Does Not Show 
A. Total Costs. 
B. That Any Subsidies Will be Required to be Targeted to Low Income Renter Households with the Highest Cost Burden Rates. 
C. The Heavy Concentration of Units and Subsidies Within the City of Portland.

After reading through the report and appendices it is apparent to me that Metro clearly understands that:

1. Rising housing costs, NOT rising transportation costs are the reason that H+T cost burdens are projected to increase significantly.
2. The rate of cost burdens are the highest among low income renter households. 

With this knowledge the policy responses from Metro to deal with growing cost burdens can only be viewed as disappointing and ineffective.

The principle tool that Metro apparently sees to address the affordability problem is the use by local government of residential "incentives" /subsidies. These are primarily urban renewal funds and incentives in "centers".

Appendix 1 includes a  residential "incentives"/subsidy table by sub area HERE. I added the numbers in that table and conclude that Metro projects that a total of 97,920 units will receive these subsidies by 2030, but there are three problems:

1. NONE of the subsidies are REQUIRED to be targeted to low income renters who have the highest cost burdens and there is no apparent ongoing local reporting requirement for these incentives. 
2. There is no calculation that shows the projected COST of these subsidies. 
3. No where does Metro shows residential incentive totals by city, which would have revealed that the region is HEAVILY dependent on the City of Portland to deliver housing units and subsidies in centers and urban renewal districts for the entire region. 

To help address the second and third problems above I have created a table HERE that shows my projections (using Metro data) that:

1. Costs for these residential infrastructure "incentives"/ subsidies will total $3.8 billion through 2030. 
2. Residential "incentives"/subsidies in the City of Portland are projected to account for 71% of the units and supply 84% of the regions cost of these residential incentives. 

REQUIRED METRO ACTIONS:
With projecting rising rates of cost burdens (Metro's updated table is HERE) and a projected $3.8 billion local expenditure for residential "incentives" /subsidies through 2030:

1. SOME of those "incentives"/ subsidies must be targeted for exclusive use by low income renter households.
2. Future reporting on the actual deployment/use of these subsidies must include reporting by subarea and City on the income levels of the housing built with these subsidies.  
3. Metro's  Appendix 1 table must breakout residential infrastructure "incentives" by units and costs for each city and explicitly acknowledge that Metro's stated  "housing choice/ share the burdens and benefits of growth" policy is HEAVILY dependent on residential infrastructure incentives within the City of Portland, which is projected to produce 71% of the total regionwide units in center and urban renewal areas and supply 84% of the dollars through 2030.
4. Metro must help create/support an effective REGION WIDE strategy to leverage additional FEDERAL dollars for housing, as federal dollars have been and continue to be the primary source of funding for affordable housing, especially outside the City of Portland. This unified housing approach should be similar to the existing region wide approach that provides unified support for annual and long range federal transportation funding.

Originally created and posted on the Oregon Housing Blog.

Metro Transporation Policy Group Agenda Includes TIGER II Grant Application Endorsements.

TPAC meeting is on Friday July 30th.

Agenda package HERE includes recommended endorsement of 6 TIGER II grant applications (see pages 13-19 for details--I failed to see ANY housing related activity in the endorsement letters): 

1. Sunrise Corridor – Hwy 212: Hwy 224 to 162nd Ave., Sunrise Corridor Multiuse Path: Lawnfield to Hwy 212 and I-205 Multiuse Path to Hwy 212
2. Electric Vehicle Corridor Connectivity
3. NW Graham Road Reconstruction and NW Swigert Way Extension
4. I-5 Corridor Transit
5. Sellwood Bridge Replacement
6. Southeast Corridor Project: Connecting Communities

Agenda includes HUD sustainability grant Coop Agreement that is also on the July 28th MPAC agenda.  (see prior post HERE).

Originally created and posted on the Oregon Housing Blog.

Housing/Transportation Index Bill Introduced by Blumenauer.

Via NLIHC:

Representative Earl Blumenauer (D-OR) introduced H.R. 5824, the Transportation and Housing Affordability Transparency Act, or “THAT Act,” on July 22. The act would require the HUD Secretary to create a transportation affordability index designed to provide information about the transportation costs associated with housing in various communities. The index would offer families more complete information on what costs are likely to be associated with a particular home choice, while providing policymakers with additional factors to use in setting local policy. NLIHC supports this bill.
The bill, which has eight cosponsors, was referred to the Committee on Financial Services.

Originally created and posted on the Oregon Housing Blog.

Regional Planning Grant Data, Select Portland Metro Areas: Only the City of Portland is BELOW the National Housing Transportation Affordability Target.

In the HUD Regional Planning Grant NOFA, Factor 1.2 measures the "Portion of Regional Population Paying More than 45% of Income to Combined Housing and Transportation Costs".

Using the H+T index that is used to establish values for this factor I have pasted below a table showing the Housing AND Housing +Transportation values for select areas in the Portland Metro area. (I also added a column to the right, which is the Transportation value when the Housing value is subtracted from the H+T value).

Notes:

1. EXCEPT for the City of Portland, ALL of these select areas have values that EXCEED the national affordability standard of 45% of income.
2. Within these select areas, Lake Oswego is the LEAST affordable, with average H+T costs of 62% of income.
3. Among the three counties, Clackamas is the least affordable, with an average H+T index value of 55.8%.

Area	Housing	H +T	T?
Portland--Vancouver, OR--WA	28.6%	50.1%	21.5%
Beaverton	27.6%	47.9%	20.3%
Clackamas County	32.7%	55.8%	23.1%
Gresham	25.1%	46.4%	21.3%
Hillsboro	27.0%	48.2%	21.2%
Lake Oswego	40.6%	62.0%	21.4%
Multnomah County	26.0%	45.6%	19.6%
Portland	25.4%	44.4%	19.0%
Washington County	29.7%	51.2%	21.5%

Originally created and posted on the Oregon Housing Blog.

HUD $40 Million Community Planning Challenge Grant and DOT Tiger II NOFA is Out.

HUD NOFA web page for these grants is HERE.; direct URL to the NOFA on DOT website is HERE, with rating factors starting on PDF page 16. (Likely this NOFA will also appear shortly in the Federal Register in final format).

NOTE, this is NOT the HUD $100 Million Regional Planning Grant; hopefully this will also be out shortly.

HUD PR is HERE. 

NOFA application deadline is August 23, 2010.

Originally created and posted on the Oregon Housing Blog.

Test Map: Metro H+T Index Map/Data for Metro Portland, Multnomah County, City of Portland. (and you can select your fav block group).

As a trial I am embedding below a H+T Index map for the Portland Metro area that shows cost burdens for renter households.  Data shows that 41.2% of renter households in Metro area spent more than 45% of income for housing and transportation, vs 37.4% in City of Portland, and 43.5% in Multnomah County (Click within map in City of Portland and pop up will show with these numbers)

IMPORTANT NOTE :These %'s are of Median Household in Region [$47,077]; if focused on lower income renters the % of cost burdened households would be significantly HIGHER; my prior post HERE shows results at 80% of median household income [$37,662].

(Data sources for H+T index are explained in detail HERE, and HERE is a direct link in case the embed doesn't work). 

Also HERE is the H+T index PDF profile for the Portland Metro area.

H+T Affordability Index: Portland--Vancouver, OR--WA: Comparing Housing Costs, % Income for Renters to Housing + Transportation Costs, % Income for Renters The Housing + Transportation Affordability Index is an innovative tool that measures the true affordability of housing based on its location.

© Copyright 2003-10 Center for Neighborhood Technology
2125 W North Ave, Chicago, IL 60647 · Tel: (773) 278-4800 · Fax: (773) 278-3840

Originally created and posted on the Oregon Housing Blog.

MPAC Wednesday Transportation Plan Recommendation: Metro Staff Rejects My Comments, Continue to Obscure Housing/Trans Affordability Goal.

Despite my best efforts to identify the problems associated with Metro's use of a locally developed transportation/housing affordability index , instead of the national H+T index, Metro staff continues to reject use of the H+T index now available for 330 metro areas.

I have extracted from the Metro staff summary of comments on the Transportation plan the staff reaction to my suggestions into a single document HERE (similar comments were also made by Cathy Briggs from Oregon ON).

Metro : 2005 Benchmark Portland Metro Median Spending on Housing /Transportation Was 45%; Lets Adopt a New Standard of 50% That is 13%+ Higher than the Actual 2005 Level.

Metro also insists on using an acceptable housing/ transportation affordability level of 50% of income EVEN though the benchmark level for the region was 44% in 2005, and even though the H+T index uses a 45% of income standard. WHY Metro would use a future standard that would permit a HIGHER share of income to be spent on housing and transportation is beyond me. Their explanation:

Metro chose 50% of income because the 2007 national median share of household income spent on housing and transportation was 45%, and it seemed to be more meaningful to choose a threshold that was higher than the median.

IMPORTANT NOTE: Use of a 50% housing/transportation measure for affordability would represent a 13.6% INCREASE in income that households could spend on housing/transportation compared to the ACTUAL Metro Portland median expenditure in 2005 and still be consider "affordable" according to Metro's definition.(50%/44%-1=13.6%)

After reading Metro staff comments 
1. It seems clear that there will NOT be any LOCAL targets for affordability,only a single regional goal.
2. Is is STILL not clear what the REGIONAL Goal IS . The current target shown in Table 2.3 of the RTP says "By 2035, reduce the average household combined cost of housing and transportation by 25 percent compared to 2000" and there is nothing I see in the Metro staff comments that CHANGES this other than including a benchmark showing the actual percentage in 2005 was 44%. (see my comment 205 HERE to see the two contradictory Metro affordability goals in the RTP).

Metro's meeting is Wednesday May 26th at 5 PM, and the agenda packet for this meeting is HERE. 


Because I plan to be in Salem for some meetings tomorrow I likely will not be able to attend the MPAC meeting. IF anyone attends the key questions are:

1. WHAT IS the the regional housing/transportation affordability goal that is being recommended?
2. Why should the region adopt a 50% of income definition of housing/transportation affordability that is 13.6% HIGHER than the 2005 regional benchmark expenditure of 44%?
3. Why can't Metro use the H+T index?

Originally created and posted on the Oregon Housing Blog.