To: Members of the Workforce Housing Task Force

 Subj: Housing ideas

Below, I have compiled the thoughts of many concerned, informed and involved Keys’ citizens. The generic term “affordable housing” is used here without intending to convey any of the eligibility requirements. Our goal is viable solutions. I and the other contributors to this submission share with you a sincere desire to solve our real housing problems.

1. With the emphasis on increasing height, increasing density, claiming the need for thousands of new allocations with misleading data, reducing hurricane evacuation public safety and confronting those citizens who—just like you—have taken many of their personal hours to participate in the process, you’ve focused on issues that represent an assault on widely- and deeply-felt community values. Hiring a public-relations expert won’t help.

2. By focusing the bulk of your energy and resources on new construction, you have turned your eye from the bleeding that constitutes the loss of existing affordable housing. *We are losing affordable housing faster than we could ever build it. Put another way, you can retain housing faster than you can build it, and with much less public opposition.*

3. First, stop the bleeding. You must demonstrate sincere housing-retention efforts first, in order to gain public support.

 4. We believe the solution to our housing needs must be solved primarily within our existing housing stock, and that large numbers of new dwelling unit allocations are not likely to be forthcoming.

 5. A Countywide focus on retention of existing affordable housing would be widely accepted.

 6. You’ve expended substantial resources promoting the pro-development side of the issue (higher, denser, more allocations), risking lengthy legal battles in the process. Why not put some legal resources on the other side of the issue as well, like Islamorada, which will establish an Inclusionary housing requirement, requirements to maintain affordable housing within the redevelopment of mobile home parks, an affordable housing mitigation fee and an affordable housing trust fund?

7. Without meaning to offend, it appears that your committee consists predominantly of pro-development interests. You claim to be in search of all possible means, but that bias keeps you from giving equal consideration to other potential tools.

8. Increase the percentage of allocations in the “affordable” category. If the crisis is upon us, then 80% of the allocations should be for affordable housing. Require that Transferable Development Rights for Mobile homes be used only for Low and Very Low income housing only.

 9. When you listed the stakeholders, you omitted the most critical member: Your Customer. Without knowing your customer, you will likely run afoul of involved citizens again, many of whom are the folks you purport to “serve.” One of the many issues that affronted the community regarding the Carlisle Group Community Workforce Housing Innovative Pilot program (CWHIP) project was the “one size fits all” approach that would have placed 78 of the densest and tallest housing units in all of Monroe County on the island of Key Largo – where they are needed least. Residents of the Upper Keys have access (for better or worse) to housing options on the mainland. With that option available, the dense units proposed at Burton Drive in Key Largo could easily have remained vacant.

10. We have _not_ defined the need, particularly with respect to geography. The need and “Customer” of the Upper Keys is likely to be very different than the need and customer of Key West. Regarding housing needs, to treat the entire county as homogeneous is fatally simplistic and counterproductive. If the committee’s perception of “need” is limited to the false claim that “we have an unmet need of 7,317 affordable housing units”, as stated in many of your documents, then you /do/ need more information. As was stated at the December 13 meeting, that number represents the number of households paying more than 30% of their combined income for housing. Those folks already have a home.

11. Have you asked current landlords what it would take to keep their many, dispersed rental units in the “affordable” category? Loss of these “invisible” units occurs daily without the fanfare of large developments like mobile home parks, as landlords make rational business decisions to sell because they cannot charge enough rent to cover their rising costs.

12. It may require legislation, but nevertheless we need to consider the sort of incentives that would entice landlords to keep the rental units they /have/ and for other non-participating landlords to be willing to join. Perhaps we need to look at the balance sheets of landlords and subsidize those costs over which government has purview. One of those growing costs is wastewater. Perhaps bona fide affordable housing should be granted “Homestead” rights if a long-term lease is held by a resident that would qualify for the exemption if they were the owners.

13. Representative Saunders is on target with his pursuit of the Sadowski funds and the reduction of tax and insurance costs.

14. A job generation schedule could be created that requires a certain number of “employee” units be provided with any new development or expansion.

15. Is the Keys’ business model right for this housing market? While it is recognized that considerable money for affordable housing comes from the bed tax that is “delivered” by the tourist industry, perhaps we need to rethink our tourist-dependent economy with its labor-intensive workforce. Why not develop incentives that would attract no-impact, high-tech businesses whose employees would be more likely to be able to afford market-rate housing?

16. That’s another way of saying instead of single-mindedly focusing on increasing the /supply/ of new housing, dedicate some energy to reducing the /demand/.

17. To what degree is the taxpayer obligated to subsidize housing for businesses that cannot or do not pay their employees enough to live here? That’s not a flippant question. We recognize the need and obligation to provide housing for many of the “Essential Service” personnel that constitute the heart and lungs of the community, but where does that obligation end?

18. If the income level requirement for Monroe County’s Workforce Housing is defined as anything under 150% of Area Median Income (CWHIP RFP), who /doesn’t/ qualify? It does not appear that you are working for the “Essential Services” customers if anyone with an income under $87,000 can qualify for subsidized housing. Put another way, what percentage of the County makes /over/ $87,000?

19. Speaking of Essential Services, each County is supposed to define their “Essential Services” personnel. Have we done so? That would go a long way toward identifying the Customer.

20. An ideal solution would involve having an honest, accurate and dynamic measure of the demand for affordable housing, and a flexible set of tools that could be applied to balance the demand with the supply. Thus, government could adjust the incentives to provide the required housing supply by type and location. This would not only allow government to open the “spigot” when needed, but to shut it off if the incentives prove excessive.

21. The Real Estate market is stagnant, which may represent an opportunity. What would it take to attract owners to convert their languishing condominiums to affordable housing stock? Attracting housing units into the affordable category from the existing market-rate category should be one of the tools. Similarly, many second homes are unoccupied that might make terrific shelter for a caretaker/renter.

22. There are many advantages to preserving existing housing stock: They are here…today! You can’t provide housing any faster They do not require building allocations They would not become blights on neighborhoods They have already survived the test of the marketplace They enable the “workforce” to blend into the community where they belong They don’t involve displacement of vulnerable citizens They would probably be cheaper, delivering more bang for tax buck.

23. Why is it that there are other Affordable Housing projects in Monroe County that did not need to increase building height and density? Your committee’s insistence of the “need” for both is belied by the fact that there are other successful projects that did not.

24. To use the argument that increased density and height are essential to “more effectively use land” is to embark down a _very_ slippery slope. That argument is still being used in Manhattan, and continued widespread opposition should be expected.

25. The Theme and top priority for Florida’s 2006 Affordable Housing Study Commission is “Preservation of Existing Affordable Housing”. While their Final Report for 2006 consists largely of legislative goals, Chapter Two is an “Overview of Existing Preservation Efforts & Programs”, which seems to this lay reader to be very comprehensive.

26. The CWHIP Request for Proposal included significant incentives for rehabilitation of existing affordable housing. The 2006 version can be expected to similarly encourage rehabilitation of existing affordable housing.

27. Although it is true that there were CWHIP points granted for innovations like increasing density, such community-inflaming provisions were not a /requirement/. There was a long list of ways an applicant could gather “innovation” points without assaulting the Comprehensive Plan.

28. There will be a gold mine of information among the winning CWHIP proposals. It is hoped that we will make full use of that resource.

29. Fractional ROGOs. It insults the intellect for advocates to argue that twice as many dwelling units (using the .5 ROGO concept) would /not/ increase density and precipitate commensurate impacts. If there are _not_ more families that would be accommodated by the increased number of units, what is the purpose of doubling the dwelling units? There would be twice as many electric meters, twice as many water meters, twice as many vehicles on the road daily and for hurricane evacuation, etc. As you are no doubt aware, all of the hurricane evacuation models count dwelling units, and derive a number of vehicles from that measure. More dwelling units means more evacuating vehicles.

30. Regarding the hurricane evacuation issue: It is deeply dishonest to claim that instantaneously reducing the “Clearance Time” from 24 hours to 18 hours improved safety when the only thing that was changed was the definition of “Clearance Time.” Everyone on this end of the state knows that the sole purpose of the recent Comprehensive Plan Policy 216.1.8 amendment was to increase dwelling unit allocations. Furthermore, the purpose of the Comprehensive Plan requirement to “reduce clearance time to under 24 hours” is to increase safety. To manipulate evacuation for the sole purpose of increasing development is a violation of public trust, particularly since the additional development /degrades/ safety.

Thank you for considering our thoughts on this important subject.

Sincerely, John Hammerstrom