Open Letters to Public Officials

In the interest of getting as much information out for review as possible, I encourage you to email me or copy me on your letters to public officials and I will publish them here. I will also try to document any responses we receive.

Open Letter to the Washington State Housing Finance Commission:

From: Delridge Neighbor <delridgeneighbor@gmail.com>
Date: Mon, Mar 19, 2012 at 9:17 PM
Subject: An open letter to the WSHFC about the DESC Delridge project — includes even more information about the financial stress of the surrounding neighborhood
To: steve.walker@wshfc.org
Cc: jean.godden@seattle.gov, bruce.harrell@seattle.gov, tom.rasmussen@seattle.gov, tim.burgess@seattle.gov, sally.clark@seattle.gov, richard.conlin@seattle.gov, sally.bagshaw@seattle.gov, nick.licata@seattle.gov, mike.obrien@seattle.gov, kcexec@kingcounty.gov, joe.mcdermott@kingcounty.gov, janet.masella@commerce.wa.gov, rick.hooper@seattle.gov, cheryl.markham@kingcounty.gov, delridgeforum@gmail.com, “Tracy Record, WSB Editor” <editor@westseattleblog.com>

Dear Mr. Walker,

The WSHFC has a difficult job – to assess the needs for affordable housing statewide and to make allocations of limited public funding through the low-income housing tax credits. I realize that this is a very competitive process, based primarily on the use of a point-based ranking system. Thank you for your hard work in administering this program.

I am writing as a Delridge neighbor to express my concern about the DESC project proposed for our neighborhood. I am a supporter of affordable housing and recognize the desperate need for housing for the most vulnerable of our homeless citizens. However, I feel that this project is not a great use of taxpayer dollars – it uses a significant portion of the available federal funding for affordable housing projects throughout the entire state – and the project is hastily conceived, economically inefficient, and changed in last-minute last-ditch efforts.

Catching a train that has left the station

If DESC and their team of architects and developers had known that the unit count would be restricted to 66, would they still have pursued the project in this location? Probably not, since they explained that reducing the unit count from 75 would be impossible because of economic restraints (when neighbors asked for fewer units).

While I am sympathetic to the fact that there was some unknown information when DESC began to pursue this project, that does not mean that we should not question the advisability of the siting of this project, particularly as it becomes even less economically efficient. If further site exploration discovered a huge sinkhole on the property that made building impossible, the project would be abandoned. It is not the best use of scarce public funds to push forward an ill-conceived project just because DESC has already spent money pursuing it. It is a risk that they chose to take – spending money on developing a project that has not received the vast majority of its funding.

A dysfunctional process

As a strong supporter of affordable housing, I have very serious concerns about the process of developing projects like this. Because of DESC’s “slash and burn” approach to community interaction, they didn’t take the time to get to know the neighborhood. In fact it doesn’t really matter to them what the neighborhood is like, as long as they can make a project work financially. Perhaps if they listened carefully they would realize that there are legitimate concerns about this site.  But their approach is to steamroll over any questions, insisting that “all neighborhoods have the same questions” and that all questions about the project must be due to underlying fear and prejudice.

A policy that concentrates poverty

Doesn’t the presence of a very large percentage of extremely low-income households also count as a reason to question the siting of the project? There is a fundamental policy disconnect when this project can get a basis boost (i.e. extra tax credit funds) for being in a qualified census tract, while the future population will be drawn from throughout the city rather than being Delridge-specific. This is an affordable housing project that actually increases economic inequality for the neighborhood by bringing more extremely low-income residents into the neighborhood.

When I attended a public meeting about the project in October, I was a supporter of the project. However, I heard my neighbors describing the economic stress of the neighborhood and I decided to check the census data. I expected to find that their concerns were misguided, but the census data was actually quite alarming. This portion of Delridge is in even more economic distress than I realized.  Thirty percent of the households earn less than $20,000 and 17% earn less than $10,000. Data also suggests that the majority of those households are not in subsidized housing because they are paying more than 35% of their income for rent. That means that they aren’t even included in the siting policy administered by the Seattle Office of Housing.

You can read about my research at AConcernedDelridgeNeighbor.wordpress.com – if you have not yet had a chance to look at it. I am gratified that scrutiny by this blog and by other Delridge neighbors caused the Seattle Office of Housing to revisit their initial unit count determination. I hope that it will cause affordable housing professionals and public officials at all levels to rethink the policy behind siting these projects.

Further evidence of extreme financial distress

In addition to the existing extremely low-income households that do not appear to be in subsidized housing, there is another group of extremely low-income households that is not included in the Office of Housing siting policy – portable Section 8 vouchers. While it can be argued that these households may move, it is entirely possible to track how many are within one census tract when a project is developed. A neighbor has done the research and discovered that currently of the 1,977 households in this census tract, 302 have tenant based vouchers – that is 15% of the total households in the tract who are extremely low income and not counted in the siting policy. (Note that the zip code 98106 has the 4th highest percentage of portable vouchers in the city.) These Section 8 households, in combination with the existing extremely low income households who do not appear to be receiving subsidy, present a potentially stunning number of households in extreme financial distress – and this is all in addition to the (up to 20%) subsidized housing units that the Office of Housing tracks in administering the siting policy. Adding 66 more extremely low income households to this mix does not seem like a good idea. At what point are there simply too many extremely low-income households concentrated in one area? At what point is this type of project actually contributing to economic instability? See the latest blog post for more information.

An appeal for careful oversight

I recognize that there is tremendous political pressure to develop this type of project and that it is desperately needed. However, it is disheartening to see this magnitude of public resources being devoted to a less-than-excellent project in a marginal location. I call on you to raise questions as the stewards of our public dollars. With this level of investment, there should be more oversight. Neighbors shouldn’t be the ones finding the mistakes – the affordable housing providers and funders are the experts and should be doing the necessary research. The project is proceeding at break-neck speed and it is simply too hard to make good decisions this quickly.

Thank you for your hard work. I hope that you will consider these and other Delridge neighbors’ insights into the proposed project.

Sincerely,

A Concerned Delridge Neighbor

Letter from A Concerned Delridge Neighbor:

From: Delridge Neighbor [mailto:delridgeneighbor@gmail.com]
Sent: Wednesday, November 02, 2011 10:36 AM
To: Hooper, Rick; janet.masella@commerce.wa.gov; cheryl.markham@kingcounty.gov; Godden, Jean; Harrell, Bruce; Rasmussen, Tom; Burgess, Tim; Clark, Sally; Conlin, Richard; Bagshaw, Sally; O’Brien, Mike; John.dechadenedes@kingcounty.gov; Maria.ramirez@kingcounty.gov; joe.mcdermott@kingcounty.gov; delridgeforum@gmail.com; editor@westseattleblog.com
Subject: Is it okay with all of the funding agencies and policitical leaders that the DESC Delridge project concentrates extreme poverty in one area of Delridge?

New information in the funding applications shows that the project DOES NOT currently meet the siting policy. Census data shows that the area appears to have significant numbers of extremely low-income people who are not in subsidized housing and thus not even considered in the calculation of capacity for this project. More detail about these facts is at: http://aconcerneddelridgeneighbor.wordpress.com/ — sustained web traffic indicates that I am not the only concerned citizen.

Not only has the Office of Housing not responded to this information, but it turns out that they have granted a waiver based on possible future houses to be built. This project is on an extremely fast track, but I call on our leaders to spend the time to make sure we don’t make a big mistake. The site is due to be purchased by December 1, 2011.

Is this really the best place to spend $14.5 million of precious public money? I think it is a good question. A project of this size is a tremendous stress on a neighborhood, and this neighborhood does not have the economic strength to support it. Even if the City of Seattle considers it to be an acceptable solution to concentrate extreme poverty in one small area of an otherwise wealthy city, I call on the county, regional, and state funders to consider that the future residents of this project will not be well served by being in such a stressed location. I know every project like this faces opposition so it is hard to tell NIMBYism from truth, but I respectfully request that you spend the time to ensure that you are being the best possible stewards of our public money.

Here are the questions that I would like the Office of Housing to answer:

  1. Can you provide further demographic information to disprove the apparent concentration of extreme poverty in this one area of Delridge?
  2. Why have you provided “up to $4.45 million” for this project, when only $1.3 million was requested?
  3. How common is it to waive the requirements of the siting policy? Has it been done before, and if so, how many times? Has it been done for other DESC projects?
  4. It appears that the Office of Housing has also approved a bridge loan of $769,000 for purchase of the site by December 1, 2011. Can the Office of Housing provide a copy of the bridge loan documents that are currently being prepared?

Thank you for your consideration,
A Concerned Delridge Neighbor

Reponses to A Concerned Delridge Neighbor letter: Tom Rasmussen has requested that the Office of Housing provide a copy of their answers to him as well. The West Seattle Blog has included a link to this website in a story about this project.

November 7 Janet Masella of the State Housing Trust Fund replied to the letter. Although only a form letter, it was more reply than I have received from any other funder, and certainly more than from the Office of Housing.

Answers as provided by Rick Hooper of the Office of Housing on November 9:

Dear Delridge Neighbor, last week you sent an email listing 4 questions that you wanted the Seattle Office of Housing to answer.  Here are our responses—please let us know if you have additional questions:

  1. Can you provide further demographic information to disprove the apparent concentration of extreme poverty in this one area of Delridge?

When the Office of Housing evaluates proposed housing sites, we examine the concentration of subsidized housing for extremely low-income people, rather than the demographic information for all the residents in the area. This evaluation is required by the Council-adopted siting policy in the City’s Consolidated Plan, which has been in place since the early 1990s. The intent of the policy is to ensure that subsidized rental housing for extremely low-income people is not over-concentrated in areas outside of Downtown. It requires that we consider the number of subsidized units serving extremely low-income households (defined as earning less than 30% area median income, or $18,250 for a single person in 2011) and the total number of housing units in the Census block group. The policy limits the number of subsidized housing units serving extremely low-income households to no more than 20% of the total number of housing units in a Census block group, unless the proposed housing is eligible for a waiver under certain defined circumstances. The OH Director may grant a waiver of the siting policy if one or more of the following criteria are met:

  • The proposed project is a neighborhood‐supported project. To be considered a neighborhood‐supported project, OH must determine that the proposed project is supported by a reasonable number of immediate neighbors and/or affected neighborhood organizations. Such determination will be based on review of results of the community notification process as described in the Neighborhood Notification and Community Relations Policy section (see below) including notification of immediate neighbors, consultation with established community groups, public meetings, and/or other means of community notification as OH deems appropriate. In accordance with national, state and local fair housing laws, OH disregards, in evaluating neighborhood support for the project, any opposition that appears to be based on characteristics of future residents of a project if discrimination based on such characteristics is prohibited.
  • Additional market‐rate housing development is planned in the Census block group, and OH determines that the proposed project would not result in more than 20% of total housing units in the block group being subsidized rental housing for extremely low‐income households, based on an adjusted estimate of total housing units that includes units for which building permits have been issued (based on the Department of Planning & Development’s latest annual report of building permit data) or other such documentation as deemed appropriate by OH.
  • OH determines that natural or manmade barriers (e.g. a bluff, waterway, or freeway) physically separate the proposed project from existing concentrations of subsidized rental housing for extremely low‐income households.

The Analysis of Impediments to Fair Housing prepared for the City of Seattle, which is available on OH’s Consolidated Plan webpage, includes a thorough overview of federal, state and local fair housing law. OH’s Siting Policy is a tool for addressing barriers to fair housing. One goal is to ensure that housing for Seattle’s lowest‐income and most vulnerable populations is available throughout the City.

Consistent with local, State and Federal law, housing may not be excluded from a neighborhood based on any of the following characteristics of the persons who will live there: age, ancestry, color, creed, disability, gender identity, marital status, military status or veteran, national origin, parental status, political ideology, race, religion, sex, sexual orientation, possession or use of a Section 8 voucher, or use of a service animal.

  1. Why have you provided “up to $4.45 million” for this project, when only $1.3 million was requested?

The Office of Housing reviews project proposals in conjunction with other public funders of affordable housing to make collective decisions that maximize the quantity and quality of affordable housing development in our community. Actual funding awards may depart from what applicants propose, depending on the availability of other sources of funds for any given project. It is not unusual for the City to provide more or less than what an applicant requests once all funding sources have been determined.

In the case of the DESC Delridge application, the non-City sources of financing were ultimately lower than the application estimated, leaving a larger funding gap. The City chose to fill this gap because this project fulfills City goals of providing affordable housing with supportive services for homeless and special needs individuals.

All City awards are “up to” amounts that maybe reduced if other sources of financing are higher than projected, or if project costs are lower than projected.

  1. How common is it to waive the requirements of the siting policy? Has it been done before, and if so, how many times? Has it been done for other DESC projects?

OH has granted waivers in the past, but none for DESC projects. Waivers granted since 2003 (project, agency, year) include:

Holden Street Campus Extension, Common Ground, 2003
Rainier Family Court, SEED, 2003
West Seattle Community Resource Center, DNDA, 2004
Alder Crest, Seattle Housing Authority (SHA), 2004
Rainier Vista Phase II, SHA, 2009
Lake City Village, SHA, 2009
Rainier Vista Phase II North, SHA, 2009
Yesler Neighborhood, SHA, 2010
Sand Point, Solid Ground, 2010
 
  1. It appears that the Office of Housing has also approved a bridge loan of $769,000 for purchase of the site by December 1, 2011. Can the Office of Housing provide a copy of the bridge loan documents that are currently being prepared?

At the time of your request, the process for drafting the loan documents had not yet begun, so no records existed. That process has now started and we anticipate the documents will be completed by no later than the last week of November. We will be happy to provide those records in their entirety, except any information that may be exempt from disclosure, once they are finalized.

———————————–

One response to “Open Letters to Public Officials

  1. Here is a reply I received yesterday in response to a letter I drafted voicing my concerns…sounds like more ignoring the people!

    “Thank you for your e-mail regarding your concerns with the proposed DESC Delridge Supportive Housing project in Seattle. As you know, DESC has submitted an application to the Washington Department of Commerce for funding from the Housing Trust Fund (HTF).

    I understand you have concerns about whether the development of housing for very low-income people is an appropriate use of scarce public resources, particularly in the proposed location. Since 1989, the Washington State Legislature has appropriated funds within the Housing Trust Fund for the specific purpose of providing affordable housing for low-income and special needs populations. As a public agency, it’s our responsibility to ensure that those resources are invested for their intended purpose and that the investment will provide a long-term benefit to the community.

    Applicants to the HTF must complete a rigorous application process. HTF staff reviews each application carefully to ensure that the design and location of the proposed project is appropriate to the needs of the target population and is consistent with local priorities and plans. Applicants must also demonstrate that they are taking appropriate steps to comply with all applicable state and local permitting processes, including compliance with neighborhood notification requirements. Projects are also evaluated based on a number of other criteria, as described in the attached document.

    Based on our review, the Delridge Supportive Housing project appears to have met all of the necessary criteria for funding. We have made an award of $500,000 to the project, conditioned on DESC’s ability to secure all necessary funds and required permits for the project. It is our hope that DESC will continue to work with local officials and residents to address any concerns and ultimately achieve a successful outcome for this project.

    Thank you again for taking the time to bring your concerns to our attention.”

    Janet

    Janet Masella

    Associate Managing Director

    Housing Trust Fund

    360.725.4134

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