“We realize that not all residents of an affordable housing development will, by default, be criminals. However, we are also not ignorant to the fact, which is supported by real statistics, that many criminals (especially violent criminals, drug-related criminals, and sex-offenders) tend to come from a lower socio-economic class. […] We feel that in this area, based on the types of newer developments we have seen being built, if another developer were to build on this land it would be apartments carrying a higher rental rate and would attract young professionals and business persons looking for a nice commuting neighborhood. […]
We think we can all agree that affordable housing solutions can and should be made for those individuals needing the assistance, we simply do not feel like this is the appropriate location for it.“– Milwaukee Ridge Homeowners Association President Grant Koertner.
Last year we highlighted how the scoring algorithm for the Low Income Housing Tax Credit (LIHTC) program resulted in neighborhood associations in high-income, low poverty areas sinking applications to the program by giving developments in their area the “cold shoulder.” The Austin American Statesman then ran a story detailing how some LIHTC investors game the neighborhood letter system. The Texas Sunset Commission followed up by advising that the rules be tweaked to insure that the bulk of the scoring for community support be related to a formal vote by the local city council or county commissioners court. The Texas Legislature has not yet adopted those recommendations.
This year’s Neighborhood Letter’s have been released. TDHCA received letters for 114 of 220 pre-applications to the program, 8 of which were in opposition. The Milwaukee Ridge letter, quoted above, is unique in its unapologetic “Not in My Backyard” statement that low-income folks need housing, just not in “nice commuting neighborhoods.” [The full MR-HOA letter is embedded below the jump.]
Milawaukee Ridge is a predominately white, non-Hispanic neighborhood on the western edge of Lubbock. (According to Remapping Debate’s analysis of ACS data, no African Americans live in this block group). The elementary school serving this neighborhood has been rated “Exemplary” by TEA. The median income of the Census tract is 25% higher than the median income for Lubbock County as a whole.
These, in fact, are exactly the type of neighborhoods where affordable housing is needed in this state. The nearest existing LIHTC property is 2.2 miles away, and has zero vacancies.
This letter exemplifies why the current Community Participation format for the LIHTC program is broken. The state should consider many factors when deciding where to fund LIHTC properties in the state, but “Low-income folks shouldn’t live in ‘nice commuting neighborhoods'” is not one of them.
Update June 2011:
As noted by Mr. Koertner in the comment below, TDHCA’s final evaluation disqualified Milawaukee Ridge’s letter from being scored, with staff ruling “During the review of the documentation, staff verified that the proposed development is not located within the boundaries of the organization. Therefore, in accordance with §49.9(a)(2)(A)(iv) of the Qualified Allocation Plan, the organization does not qualify to provide comment QCP and the letter in ineligible for the purposes of scoring.”
We also appreciate Mr. Koertner’s updated information on local area demographics. At the original time of this post, the 2005-2009 ACS data was the most recent data available to researchers.
TxLIHIS’s comments on during the adoption of the 2011 LIHTC Scoring Algorithm:
“The State has a duty to consider the extent to which QCP [i.e. Neighborhood Letters] is an impediment to fair housing and to discount those comments that have the effect of acting as an impediment. For example, a claim of school overcrowding is directed against families with children (a protected class under fair housing). The instructions for commenters should include a statement that the state is under an obligation to Affirmatively Further Fair Housing and that QCP letters that urge or demonstrate an act that would amount to a prohibited act under the fair housing act cannot be considered. The stats should provide examples of such statements to commenters. The State should also limit the scoring of negative points to letters which address specific concerns regarding the specific proposed development at that location, and not concerns regarding the LIHTC program in general.”
Milwaukee Ridge Homeowner’s Associations Comments on the 2011 “Grove at Elm Park” LIHTC application: