Creating a Plan Introduction
In theory, a community can have a comprehensive and effective housing strategy without a written plan that explains it. But that is unusual. Developing a formal document that sets out the community’s overall housing strategy can help to ensure that all bases are covered and facilitate an evaluation and monitoring process that increases the likelihood of successful implementation. The process of developing a plan is also critical for bringing diverse agencies and stakeholders on board to maximize support for the plan’s adoption and implementation.
Some of the components of the plan development process are discussed elsewhere in the Building a Strategy section of HousingPolicy.org. We include links to those sections when discussing the process of creating a plan below.
Assembling a housing taskforce
Many of the most effective housing strategies are developed through a broad and inclusive taskforce. One reason is that a taskforce allows for input from individuals with a wide range of experience. Another is that an inclusive taskforce facilitates the critical process of getting buy-in from the diverse range of stakeholders needed to support the plan’s adoption and implementation.
In considering who to include within a housing taskforce, you may wish to consider these three points: (a) process matters; (b) inclusive is generally better; (c) participation by a diverse range of government agencies is important.
As many policymakers and advocates know, it is often easier to stop a policy from being adopted than to enact one. By bringing a diverse range of stakeholders together to develop a shared package of policy interventions that everyone can support, the chances of adoption are greatly increased. The plan development process can also be helpful for educating each other on the nature of the community’s housing challenges and the roles that many well-intentioned policies may be playing in inadvertently contributing to these challenges. While a taskforce process can often take much longer than a more unilateral one, a comprehensive housing strategy developed by a broad-based taskforce will have much more momentum and support, and thus a greater likelihood of adoption and implementation by the range of agencies and other actors whose backing is needed.
Inclusive is generally better
For these reasons, it is important to involve a diverse array of stakeholders in the development of a comprehensive housing strategy by including representatives of the various practitioner and other stakeholder groups on the taskforce and by scheduling frequent opportunities for meaningful citizen input from the outset of the planning process. Among other key groups that should be represented on a housing taskforce are: both nonprofit and for-profit developers and builders, lenders, community development corporations, housing counseling entities, employers, and representatives from a diverse range of government agencies (more on this below). Other groups that may be interested in being involved in one way or another are civil rights groups, labor unions, and organizations – whether faith-based or secular – with a strong social justice mission.
Involvement by residents is also important, especially for plans that focus on particular neighborhoods or include a neighborhood component. Studies have shown that public involvement results in a greater likelihood that plans will be implemented, by building ownership of plan initiatives and interest in seeing projects through.  Resident participation and input also allows authors of the plan to benefit from “insider” information on local conditions and concerns, and can provide early warning of proposed strategies that are likely to meet with opposition on the basis of NIMBY concerns and other grounds. As stated in Stamford, Connecticut’s affordable housing strategy, “input should not come in a reactive mode. Public hearings are, frankly, too late. The lack of consultation would inherently promote tension and opposition.” To build trust and support for the planning process, residents and other stakeholders should be given early notification of meetings and community forums, and efforts should be made to hold events at varying times and in accessible locations.
Involve multiple government agencies
By necessity, a comprehensive plan to meet the community’s housing will require the participation – and ideally, the collaboration – of multiple governmental agencies. The following are some of the key government actors whose involvement will be necessary for the successful implementation of a comprehensive housing strategy:
- Taxing entities to facilitate the reuse of tax-delinquent property, and implement tax abatements and tax increment financing
- Zoning and planning boards, building departments and other agencies involved in the zoning, planning or permitting processes to reduce regulatory barriers to development
- City and state housing finance agencies and community development departments to provide project financing, implement efficient practices and oversee projects
- State and local legislatures to pass necessary legislation
Depending on the community, state and local housing authorities also may have a prominent role to play in implementing some of these policies. In any event, they should be included on the core implementation team as they bring a number of key complementary tools to the table, including the ability to attach Section 8 housing vouchers or public housing subsidies to rental developments to increase the range of incomes that can be served.
Other government agencies also may need to be involved, especially if a community is searching for publicly owned land that could be made available for the development of affordable homes. In New York City, where finding new land for affordable housing is a long-standing challenge, the Department of Housing Preservation and Development (HPD) has identified a wide range of City and State agencies to work with on land use collaborations. Among other agencies that own or oversee land that could be developed as affordable housing in New York City are: the City’s Housing Authority and Economic Development Corporation, as well as the Departments of Transportation and Education, Health and Hospitals Corporation, and the Human Resources Administration. HPD projects these partnerships will result in 20,000 units of new housing by 2013.
Beyond acquisition of vacant or underutilized land, collaboration between government agencies can yield positive outcomes related to the integration of housing and other related goals. In its most recent five-year plan for affordable housing, Chicago’s Department of Housing continued its partnership with the Chicago Public Schools to offer the Teacher Homebuyer Assistance Program, which creates housing incentives to help in the recruitment and retention of Chicago public schoolteachers. The Department offers a similar program for police officers, paramedics, and firefighters, providing downpayment assistance to those who purchase homes in the City, and additional financial incentives to buy homes in designated Chicago Housing Authority redevelopment areas.
Gathering and analyzing information
Many of the best housing strategies start with a clear understanding of the housing challenges facing the community. The standard “needs assessment,” which looks at the extent to which different population segments are facing housing affordability and quality challenges is a core component of this analysis, but it is important not to stop there. Other components include: an analysis of expected demographic trends and future demand for housing; an investigation of the root causes of the housing challenges faced by the community, including any obstacles preventing the market from responding to demand; and an inventory of the assets and programs currently available to help the community address these challenges.
Click here for more information on the info gathering process.
There are three different types of targets that need to be defined as part of a housing taskforce process:
The first is the overall mission or charge for the taskforce process. Is the taskforce developing a comprehensive housing strategy for the community, or addressing a more specific need – such as promoting homeownership or a workforce housing strategy?
The second are the policy objectives needed to meet the challenges identified through the information gathering and analysis process. For example, if an analysis of the root causes of the community’s housing challenges indicates that affordable housing developers find it difficult to find land on which to build, the corresponding policy objective may be to “Expand the availability of land for affordable housing.” Similarly, if your analysis indicates that decisions by owners to exit federal subsidy programs are reducing the availability of affordable rental homes, the corresponding policy objective will be to “Preserve affordable rental housing.”
The third type of goal is a numerical goal that helps the community track progress toward successful implementation of the plan. Examples include: “Build 10,000 new homes in the next five years,” “Increase the homeownership rate to 50 percent by 2012,” etc.
Click here for more information on setting these different types of goals.
Evaluating existing policies and programs
Once communities have identified the root causes of their housing challenges and the corresponding policy objectives needed to address these challenges, the next natural question to examine is whether the community’s existing policies and programs fully address those concerns. The hardest thing about this review may be to set aside both personal and political considerations and take an objective and honest look at whether the policies are effective. For this and other reasons, it is essential that this process be constructive and forward-looking, rather than critical or judgmental. The goal is not to pass judgment on the current or prior administration and its policies, but rather to determine whether modifications are needed to more effectively meet the community’s housing challenges.
In most communities, the range of problems identified as root causes of their housing challenges will require an examination of a fairly broad set of policies administered by different agencies. For example, in addition to considering programs set up specifically to provide funding for affordable housing, many communities will want to consider their zoning and planning policies – could they be revised to expand opportunities for new development?; their tax incentives for development – could policies be put into place to incentivize or capitalize on market activity?; and their building code inspection and enforcement process – could the policies be streamlined to reduce red tape and other barriers to development?
In examining the policies of the city, county or state housing department, it will be useful to go beyond the question of whether the department is fair and thoughtful in how it distributes HOME and Community Development Block Grant (CDBG) funds – two large HUD block grants – and consider more broadly whether the policies meet the most pressing affordable housing challenges. If there is a need for predevelopment and acquisition funding, for example, are policies in place to meet this need? To the extent that a community seeks to help working families move closer to their places of employment or to public transit, are there existing programs set up to help make this happen?
In the course of this evaluation, many communities may determine that certain desired activities are not permissible expenditures under the main federal funding sources for developing affordable homes: HOME, CDBG, and the Low-Income Housing Tax Credit. This is one reason
why it is important to look beyond federal programs and consider all the various resources of the city, county or state. Just because the federal government has limited the use of its funds for a particular activity does not mean that states and localities need to adopt the same limitations for locally generated funds from trust funds, tax increment districts, etc. Certain financing needs can also be met effectively through the private sector, or through public-private partnerships. Finally, as noted throughout HousingPolicy.org, there are many strategies community can adopt that carry little or no out-of-pocket costs.
One key question to consider in evaluating existing programs is the extent to which the review will focus on the public housing and housing voucher programs. While these programs are generally funded almost entirely with federal funds, there are a number of discretionary policy decisions that state and local housing authorities can make to tailor these programs to meet local needs. Moreover, these resources are absolutely essential for meeting the housing needs of the poor and near-poor who require very large subsidies to afford the costs of renting a home. By attaching housing vouchers or public housing subsidies to new or rehabilitated rental properties developed through the Low Income Housing Tax Credit or HOME programs, for example, communities can incorporate a wider range of incomes within a mixed-income property than might be possible only with locally controlled resources. Similarly, by using Section 8 vouchers for homeownership, communities can bring sustainable homeownership opportunities within reach of poor and near-poor families.
Developing recommendations for new and improved policies and programs
Developing a set of recommendations for how to improve the community’s policies and programs is clearly one of the principal responsibilities of a housing policy task force. While this is not an easy assignment, a taskforce that has progressed through the earlier steps of information gathering and analysis, goal setting, and evaluation of existing policies and programs, should have a pretty good sense of the policy gaps that need to be addressed by the time they get to this point of the process.
Many members of the taskforce and other stakeholders will have specific ideas about how to strengthen existing policies and programs to respond to the gaps that have been identified. Staff members of the various government departments that touch on these issues (housing department, planning department, zoning commission, building inspections division, housing authority, housing finance agency, etc.) will also have ideas. An open and honest conversation among stakeholders and agency staff can go a long way to identifying ways to improve the existing procedures. Remember that in some cases, it is the policy itself that needs revision – say, the policies regarding allowable densities. In other cases, however, the problem is with how the policy is being implemented – for example, a building inspections process that looks good on paper but is slow and unpredictable in practice, driving up development costs.
In many cases, existing policies can be improved by allowing for greater flexibility. For example, authors of the Arizona housing plan recognized that regulatory barriers limited developers’ ability to combine resources from two key state agencies on a single project. A recommendation to better coordinate administration of these finance programs allows funds to be jointly leveraged, offering greater resources and flexibility to developers.
To identify new policies that may be helpful in rounding out a comprehensive housing strategy, communities may wish to consider what is working in other similarly situated communities. The Toolbox section of this site provides a good place to start. It identifies more than 20 high-impact state and local housing policies in a broad range of policy domains, including planning, zoning, tax, finance, and counseling. The Toolbox is organized into six sections corresponding to six key roles for state and local governments to play in expanding the availability of homes for working families and others. Visit the Toolbox to explore these six roles in more detail or jump directly to one of the following sections:
- Expand Development Opportunities – Increase the supply of sites for the development of affordable homes
- Reduce Red Tape – Remove regulatory barriers that constrict the supply of homes available to working families
- Capitalize on Market Activity — Use the momentum of the marketplace to increase the supply of affordable homes
- Generate Capital – Leverage additional financial resources to bring homes within reach of working families
- Preserve and Recycle Resources – Preserve affordable homes as community resources now and into the future
- Help Residents Succeed – Help residents become homeowners, make informed decisions and stay stably housed
To learn how specific communities have put these and other pieces together to form a comprehensive housing strategy, visit the Housing Plan Profiles section.
Targeting state and local funding
Once a decision is made to generate revenue for affordable homes – for example, through a housing trust fund, a housing bond issue, a dedicated share of tax increment financing, etc. – the question arises as to how those funds will be distributed. Similar questions arise in determining how to spend HOME or CDBG funds at the state or local level.
These decisions can be controversial. Many affordable housing advocates will argue that all or nearly all of the funding should go to families with the lowest incomes – often known in housing parlance as “extremely low-income” or “very low-income” families – because these families are the most likely to be spending half or more of their incomes on housing. Some employers may argue for assistance for moderate-income families to help them find affordable homes closer to work, to boost retention rates. Some groups may want housing activities to be concentrated in particular neighborhoods, in order to stimulate community revitalization; others may argue for spreading affordable homes throughout the broader community to minimize concentrations and promote a mix of incomes.
Before examining the specific questions that need to be addressed in targeting state and local housing funds, it may be helpful to consider some cross-cutting observations on how to reach common ground:
- Funding allocation decisions are easier when you are expanding the pie rather than changing how existing resources are allocated. By bringing new money on the table – through a new or expanded trust fund, bond issue, or other source – one can change the dynamic among stakeholders and advocates to be more open to new ideas.
- One way to generate political momentum to expand the pie is to bring in a greater range of stakeholders than those who have traditionally focused on affordable housing. The employer community in particular represents a promising ally. Labor unions, lending institutions, civil rights organizations, and private and non-profit developers may also consider joining a coalition in support of stronger affordable housing policies.
- The conversation shouldn’t be about funding alone. As illustrated in the Toolbox section of this site, there are many things that states and localities can do to expand the availability of homes for working families without spending public funds. Some communities may decide to implement low- or no-cost strategies to help working families – for example, inclusionary zoning requirements or incentives; expedited permitting; etc. – while concentrating the bulk of direct funding on affordable homes serving very low-income families.
The Qualified Allocation Plan (QAP)
As federal funding for the production of new construction has waned, the Low-Income Housing Tax Credit (LIHTC) has become increasingly important to the developers of affordable homes. Each state develops a federally-mandated qualified allocation plan (QAP) that explains the standards and priorities against which LIHTC applicants will be ranked each year. As the importance of the LIHTC as a revenue source has grown, so has the influence of the QAP as a targeting statement.
Targeting by Location
In most cases, states use the QAP to establish preferences for development in specific areas, such as targeted improvement zones or rural communities. Recently, the Sacaramento Housing and Redevelopment Agency issued a proposal to increase the competitiveness of LIHTC applicants developing homes in new, master-planned communities, primarily by re-assessing criteria that require site amenities such as public transit and schools to be in place when the project is placed in service. Click here to read the proposal.
Targeting by Population
In other states, the QAP has been used to prioritize housing for particular types of residents, such as large families, elderly households, or people who have experienced homelessness. In its QAP, the North Carolina Housing Finance Agency established a threshold requirement that all LIHTC applicants reserve 10 percent of units for extremely low-income persons with disabilities. Click here to read a case study about North Carolina’s QAP from the Corporation for Supportive Housing [PDF].
- Consider how to expand the pie by leveraging additional federal and private-market funds. When public funds are used to make a 4 percent or 9 percent low-income housing tax credit work, the community obtains leverages additional federal funds. Similarly, a tax credit or direct matching program can be used to leverage employer contributions for affordable homes for their workers, magnifying the impact of public funds.
Click here to learn more about some of the key decisions that communities will need to make in determining how to target state and local resources.
Central to any strong housing policy is the continual monitoring of results and the corresponding refinement of strategies. Numerical goals set out in a comprehensive housing strategy – for example, build 1,000 new homes affordable to working families in the next five years – can give both agency staff and the public an opportunity to track progress toward implementation of a housing strategy. Specific targets also can provide the impetus for periodically reviewing the strategy to ensure it is on track, and to resolving the obstacles that will inevitably emerge as implementation proceeds.
Ideally, evaluation will also become a core value and operating principle of the agencies that administer housing programs and policies. Among other data, communities may wish to keep track of the numbers of families served by each program, the costs and the amount of unspent funds within each program, and the extent of unmet needs. When funds are not being spent as quickly as assumed, why not? Are changes in program rules needed?
If programs are costing more than expected, what is the source of extra costs? What additional changes do practitioners recommend to make programs easier to use and thus more effective?
As communities consider updates to program rules, it is important to bear in mind that frequent rule changes may be counterproductive, unsettling existing expectations and forcing beneficiaries to change their business plans midstream. Ideally, programs should be well-designed from the start, reflecting feedback from practitioners before the programs are implemented, and thus minimizing the need for subsequent change. When data or other feedback demonstrate a need for program changes, by all means, make the changes; but again, it’s best to solicit input on the specific changes before they are implemented.
In Portland Oregon, changes to the River District Urban Renewal Area housing strategy reflect the importance of flexibility as implementation progresses and local conditions evolve. Initially adopted in 1994, the housing strategy is one element of a larger 20-year redevelopment plan for the area. Due to public concerns about increasing rents and the perceived displacement of low-income people, in 1999 the Portland City Council requested a comprehensive survey of all housing in the area. Based on data collected on the cost of owning or renting a home, findings indicated that the River District, once home to primarily extremely low-income households, had doubled its housing supply and become a mixed-income community, reaching its goal of achieving an income distribution similar to the City’s overall income distribution. Recognizing this shift, the 1999 update to the housing strategy refines the income categories used to set housing targets, to ensure the maintenance of this balance and preservation of units affordable to low- and extremely low-income families.
 Raymond J. Burby. 2003. Making Plans that Matter: Citizen Involvement and Government Action. APA Journal 69(1): pp. 33-49.