RPA on affordability: add density, tax vacancy, reform subsidies (plus, as with The Nation, implicit Atlantic Yards criticism)
The Fourth Regional Plan from the Regional Plan Association has a lot to say about adding affordability, thanks to increased supply and new protections, and in my previous coverage for this blog and for The Bridge I’ve addressed part of it.
But it deserves a broader look, including for its advice on how to change the philosophy behind and implementation of housing subsidies.
Here’s their summary, which involves both increasing supply and increasing subsidies, as well as enhancing legal protections:
The solutions include (plus some commentary):
The region should reform housing subsidies, the RPA says, toward “the greatest housing needs, such as very low-income rental housing, first-time homeownership, and affordable homes in high-opportunity neighborhoods.”
The RPA suggests that “a bidding process should be created to prioritize subsidizing developments that create the most high-need housing for the least amount of subsidy.” That’s an implicit dis of projects like Atlantic Yards--which it's hard to say represented/represents the best use of subsidies.
“Subsidies should target housing that cannot be produced by the private market,” the RPA says, counting “all types of subsidy, whether it comes from tax exemptions, capital dollars, or other sources.” That means “low-income rental subsidies, housing-court help, senior and supportive housing, and permanently affordable housing for people who have the least amount of market choice."
“Construction overall should be stimulated by loosening the zoning envelope and allowing for more development opportunities, not by using government subsidy to attempt to outbid the private market for a constrained amount of housing construction opportunities,” the RPA says, an argument that might work if government action on housing policy was seen as broadly fair.
“Target middle-income housing programs to home ownership, not rental housing,” since the “lack of supply at middle-income ranges” is for owner-occupied units, not rentals. Moreover, the constraint on for-sale units puts middle-income households in the rental market, where they bid up available units. (This is an implicit criticism of "affordable" buildings like 535 Carlton with empty middle-income units and a policy long discussed by Moses Gates of the RPA.)
“Consolidate marketing and make tenanting fairer,” says the RPA, suggesting a single application system for all subsidized housing overseen by a single agency with a “comprehensive inventory of social housing.” That, obviously, would change the lottery process.
What The Nation says
The RPA is a rather mainstream, centrist group, with the ability to propose relatively liberal or conservative policies with a long-view perspective. So it's interesting to see the overlap with recommendations from the decidedly liberal Nation magazine, which 1/1/18 published Mayor De Blasio Should Seize His Second Term to Make New York the ‘Fairest Big City in America’.
The magazine praised "critical initiatives" like "right-to-counsel legislation for low-income New Yorkers facing eviction and a two-year rent freeze," but criticized an affordable housing plan that might gentrify rather than help poor New Yorkers. Its proposal, like that of the RPA, implicitly criticizes middle-income affordable projects like 535 Carlton, and adds criticism of private developers:
Note that Gov. Andrew Cuomo didn't address it either, in his recent State of the State, though New York City Public Advocate Letitia James raised the issue, in her critique of his address, according to Gotham Gazette:
But it deserves a broader look, including for its advice on how to change the philosophy behind and implementation of housing subsidies.
Here’s their summary, which involves both increasing supply and increasing subsidies, as well as enhancing legal protections:
The tri-state region suffers from a severe and growing housing crisis, due in part to stagnant earnings and rising housing costs. This has squeezed out middle-income families, while those with low incomes can face overcrowding, displacement, and homelessness. The region’s legacy of discrimination and segregation has limited housing opportunities, especially for communities of color.Proposed solutions
At the regional level, demand for housing far exceeds supply. The region needs more multifamily, affordable housing in every community, particularly near transit. A stable and rational housing market will require reforming zoning and financing rules to facilitate more transit-oriented and mixed-use development; allowing more two-family houses and accessory dwellings, and providing incentives for primary residences over secondary ones.
We must invest in public housing and increase subsidies to low-income people who cannot find homes in the private market. And we need to maintain diverse and mixed-income neighborhoods in all communities by requiring inclusionary zoning in every community, expanding and enforcing fair housing laws, and protecting people from unaffordable rent increases and displacement.
The solutions include (plus some commentary):
- “Protect low-income residents from displacement,” using government-owned land in community land trusts and limited-equity cooperatives
- “Invest in public housing,” thanks to government support and new development on housing-authoirty property (which is not simple)
- “Enable rent regulation to prevent sudden, sharp rent increases” (though they don’t address means-testing rent regulation, or the politics of taking back control from Albany)
- “Remove barriers to transit-oriented and mixed-use development,” including allowing development near train stations in the region (a big lift)
- “Allow for more homes to be built in the region’s core by lifting the arbitrary state cap on residential development,” in other words a Floor Area Ratio of more than 12. (This surely will stir debate, though the RPA notes that housing is being converted in far larger office buildings)
- Tax vacant land and empty apartments (seems logical but hasn't been tried)
- Increase supply by allowing accessory units in private homes (will be opposed in some homeowner neighborhoods)
- Regulate short-term rentals, such as AirBnB, with one apartment allowed per host (surely not supported by AirBnB)
- Proactively monitor and remediate health hazards in rental housing (good idea, but costly, though RPA argues it's a bargain in the long run)
The region should reform housing subsidies, the RPA says, toward “the greatest housing needs, such as very low-income rental housing, first-time homeownership, and affordable homes in high-opportunity neighborhoods.”
The RPA suggests that “a bidding process should be created to prioritize subsidizing developments that create the most high-need housing for the least amount of subsidy.” That’s an implicit dis of projects like Atlantic Yards--which it's hard to say represented/represents the best use of subsidies.
“Subsidies should target housing that cannot be produced by the private market,” the RPA says, counting “all types of subsidy, whether it comes from tax exemptions, capital dollars, or other sources.” That means “low-income rental subsidies, housing-court help, senior and supportive housing, and permanently affordable housing for people who have the least amount of market choice."
“Construction overall should be stimulated by loosening the zoning envelope and allowing for more development opportunities, not by using government subsidy to attempt to outbid the private market for a constrained amount of housing construction opportunities,” the RPA says, an argument that might work if government action on housing policy was seen as broadly fair.
“Target middle-income housing programs to home ownership, not rental housing,” since the “lack of supply at middle-income ranges” is for owner-occupied units, not rentals. Moreover, the constraint on for-sale units puts middle-income households in the rental market, where they bid up available units. (This is an implicit criticism of "affordable" buildings like 535 Carlton with empty middle-income units and a policy long discussed by Moses Gates of the RPA.)
“Consolidate marketing and make tenanting fairer,” says the RPA, suggesting a single application system for all subsidized housing overseen by a single agency with a “comprehensive inventory of social housing.” That, obviously, would change the lottery process.
What The Nation says
The RPA is a rather mainstream, centrist group, with the ability to propose relatively liberal or conservative policies with a long-view perspective. So it's interesting to see the overlap with recommendations from the decidedly liberal Nation magazine, which 1/1/18 published Mayor De Blasio Should Seize His Second Term to Make New York the ‘Fairest Big City in America’.
The magazine praised "critical initiatives" like "right-to-counsel legislation for low-income New Yorkers facing eviction and a two-year rent freeze," but criticized an affordable housing plan that might gentrify rather than help poor New Yorkers. Its proposal, like that of the RPA, implicitly criticizes middle-income affordable projects like 535 Carlton, and adds criticism of private developers:
As a first crucial corrective, the administration must rework this housing plan, funneling the majority of resources toward building deeply affordable housing—the kind that’s available to extremely low-income households—which is where the need and numbers are greatest. This may well require scaling back the overall scope of the plan and dipping deeper into the city’s capital budget; it may also require revamping its development model to rely even more on mission-driven developers than for-profit ones; and it will certainly require instituting an across-the-board policy that reserves all public land for affordable housing—but in an age when a third of the city’s renters spend more than half their income on rent and utilities, these steps are not only justified but necessary.Going beyond the RPA to address the politics of rent regulation, the Nation suggests:
Similarly necessary: the mayor must continue to lobby Albany to tighten rent regulations—specifically, to remove (or, at the very least, dramatically increase) the $2700 rent-stabilization cap as well as to dump the “vacancy bonus” (known by its critics as an “eviction bonus) and the preferential rent system. New York is a city of renters—a town where two-thirds of all dwellings are occupied by people who pay by the month—which means that progressive changes to the rent-regulation regime can have sprawling, positive effects. It also makes it all the more outrageous that the mayor must head to Albany, hand extended, to beg the governor and state legislature to do what’s best for his constituents. But he should keep doing it, keep pushing for better rent laws and for a mansion tax to fund affordable senior housing. New Yorkers will cheer him as he does.What Cuomo said, and didn't
Note that Gov. Andrew Cuomo didn't address it either, in his recent State of the State, though New York City Public Advocate Letitia James raised the issue, in her critique of his address, according to Gotham Gazette:
In her statement reacting to Cuomo’s speech, Public Advocate James praised Cuomo on several fronts, but pointed to a need for Cuomo to improve his commitment to creating and preserving affordable housing. “I urge the Governor to push Albany legislators to adopt vacancy decontrol, make preferential rent permanent and repeal the twenty percent vacancy bonus and introduce a housing bond act to create more affordable housing,” she said. “In order to truly protect New Yorkers, we must ensure that everyone has access to safe and decent housing. It is the most critical step to creating a New York that is just and inclusive for all.”
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