It’s NIMBY Time…Again

“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:


  1. I came across your article while searching the internet and find great offense in your failure to properly present the facts. I further find it insulting to the many and varied cultures of the people of our community to state that “Milwaukee 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).” This is absolutely false. The fact that you base these claims off of out-of-date information posted on the “Remapping Debate’s” website is most likely the cause of this. In fact, the maps that they use for this don’t even show Milwaukee Avenue being continuous from 34th street to the Marsha Sharp Freeway which has been in place for quite some time. Milwaukee Ridge is a completely new community that only started in 2005 and therefore their “statistics” are most likely not anywhere near accurate as they claim to show 2005-2009 data.
    We have an incredible mix of races and ethnicities in our neighborhood including Hispanics, Filipinos, and yes, even though you report otherwise, African-Americans; among others. There was absolutely no split in the decision to vote in opposition of the development among these different ethnic groups either. In fact, the Filipino members of the community even started their own petition so that that they could discuss the matter more comfortably and accurately among themselves and came to the same conclusion that this was not the proper location for the proposed development.
    As stated in the letter that we submitted, Milwaukee Ridge is a very unique community in the City of Lubbock and throughout the country in that we are one of, if not the only, registered sex-offender free communities in the nation and we take the protection of our children very seriously. There is absolutely nothing that we would not do to help protect our children and our community from negative outside influences; including doing everything that we can to keep criminals away from our doorstep. Again, as we stated in the submission letter, we do not assume that all individuals that are classified as “low-income” are criminals, but we are also not blind or ignorant to the facts and our own personal experiences and knowledge.
    We also cited and alluded to other specific reasons why we felt like this location was not “the appropriate location for it”, including proximity to major job contributors (hence the comment about it being a “commuting neighborhood”) and proximity to public transportation stops.
    Lastly, I will note that your focus on this letter in specific does nothing to support your position as our QCP submission was not accepted for scoring due to the fact that the proposed development was outside of our neighborhood association boundaries. Your use of this to exemplify how and why the LIHTC program scoring should be changed is ignorant and highlights a weakness in your research and debate. While we knew that our submission would not be accepted before we even sent it, we also understood that we had the right to speak up and make our voices heard to protect our community and our rights as hard-working Americans.
    Since when is it a wrong to try to protect your property, assets, and all that you have worked hard for your entire life. Many of our homeowners have their own stories of struggles and hardships along their path to getting where they are today and that does not change their stance on doing what they can to protect what they have worked so hard to achieve, attain, and earn. To portray us as some kind of “richy-rich”, snobby, all-white community that looks down on “low-income folks” is an absolute disgrace to your professionalism as a writer. Further, I find the manner in which you, on several occasions, misquoted our letter to be unethical. There was never a “statement” that “low-income folks need housing, just not in “nice commuting neighborhoods.””; you simply took two different references from our letter and stuck them together to help support your position and attempt to villainize our position.
    On this point, I can not speak on behalf of the entire community, however personally I will say that I am absolutely unapologetic about my stance and my rights to protect my property and my investments and the things that I have worked so hard for my entire life to provide for my family. I have quite a few friends, as well as family members, that would probably qualify for this type of housing development and I still do not think that this specific proposal was the right one that would benefit the community of Milwaukee Ridge, nor the Lubbock community at-large.

  2. Low income housing is just another form of welfare. It artificially closes the gap between those that have and those that have-not. In so doing, you reward those who have achieved little while punishing those that have achieved much.

    I applaud the residents of the Milwaukee Ridge community for their frank honesty regarding the proposed low-income housing development. They came together and decided they were opposed to the plan and voiced their opinion. If it is true that these communities are so desirable, why do they have to be foisted upon those who do not want them? Shouldn’t there be another neighborhood who will welcome the development and wouldn’t that be a better situation for everyone involved?

    Why don’t we change the focus from putting poor people in nice houses to fostering an environment where folks can work hard, make money and actually EARN the privilege of living in a nice house in a nice neighborhood. That way, they’ll appreciate what they have. They’ll take care of it and they’ll rightfully defend it when they feel it is coming under attack.

    As for the author of the main article…
    I don’t know if it’s a lack of integrity or lack of journalistic competence but fabricating a quote like that is just wrong.
    Also your statement, “At the original time of this post, the 2005-2009 ACS data was the most recent data available to researchers.” is simply not true. You could have done your homework and actually researched the topic (Perhaps by talking to those who live there?). Instead, you chose the most convenient data which was supportive of your position.

    As for the Milwaukee Ridge neighborhood…
    I hope you continue to do what you feel is right. Stick to your beliefs, be active in your community and make your voices heard.

    A man wiser than me once said:

    I am for doing good to the poor, but…I think the best way of doing good to the poor, is not making them easy in poverty, but leading or driving them out of it. I observed…that the more public provisions were made for the poor, the less they provided for themselves, and of course became poorer. And, on the contrary, the less was done for them, the more they did for themselves, and became richer.–Benjamin Franklin

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