This summer we spent several sunny days indoors with state agencies figuring out how to best spend California’s cap-and-trade funds. With the workshops over, the guidelines for the Affordable Housing and Sustainable Communities (AHSC) program are now coming into the final stretch.
We’ve worked tirelessly with our fabulous allies in the Sustainable Communities for All Coalition to develop detailed comments. Here’s a summary of what TransForm thinks is going well, and what can still improve. Ultimately, we want to ensure the funding catalyzes model projects that can lead the way towards a healthy, affordable, climate-friendly California.
The Strategic Growth Council shows it cares about equity and geography
The draft guidelines are an impressive first step in this process. They reflect the Strategic Growth Council’s (SGC) strong interest in a comprehensive program. It also shows they take the public input process very seriously, truly trying to account for different geographic realities
We are particularly pleased that the program is set up to distinguish between Transit-Oriented Development (TOD) Project Areas – places with high quality transit – and Integrated Connectivity Projects (ICPs) for places in need of more transportation choices. This division is an important and welcome strategy to ensure that rural, suburban, and urban areas all receive meaningful investments that will provide affordable housing and transportation choices.
We are also pleased to see a clearly defined eligibility for transit subsidy programs, such as transit passes. These programs can significantly increase ridership.
We are committed and look forward to working with the council to achieve these goals and ensure that each of these programs is set up to have a maximum impact.
But the housing program should be designed to benefit those who need it most
In order to meet the state’s goals of reducing GHG’s while investing in disadvantaged communities, the program should require at least 10% of the new homes in each housing development to be affordable to extremely low income (ELI) households. These Californians are most likely to ride public transportation and drive less if they live in areas with a higher concentration of jobs, services, and transit. Half of the people who would be impacted are seniors or people with disabilities who would benefit from the increased mobility gained by living near great public transportation options.
What’s more, it’s essential to make sure that people who already live in neighborhoods with great transit are able to stay there. We are pleased the draft guidelines include anti-displacement language to protect local residents where AHSC program investments may induce displacement.
Still, SC4A is recommending clearer, stronger language to ensure those who are physically displaced get nearby, comparable sized units, a first right of return and other best practices. We are further urging the SGC to apply protection for economic displacement, i.e. where rents may rise even outside of the geographic footprint of the proposed project. While we are recommending that for this year, projects that have such policies in place earn more points than those that don't, we believe by the next round of grants we can turn these policies into a “threshold” criteria that would be required of all relevant projects.
The promising success of free or discounted transit passes is there, but too limited
We are pleased to see the eligibility of free or discounted transit passes in the draft guidelines. Studies show that these transit passes can successfully increase ridership and decrease vehicle trips.
However, as currently written, the guidelines seem to limit the inclusion of free or discounted transit passes, only allowing them for residents of specific housing developments. There are opportunities to offer these transit passes more broadly – such as to residents in one of the defined Project Areas rather than just a particular housing development itself – that can make a greater impact on transit ridership and GHG reduction. We strongly support allowing the programs to target K-12, community college, and university students, among other groups.
Bicycling and pedestrian safety is not an “and/or” issue
The guidelines should create separate categories for biking/walking projects and public transportation projects. The SGC should encourage all projects to consider both types to maximize the benefits – not pit one against the other.
The future will be good – and green
SC4A has some additional concerns and strongly urges language within the guidelines that will ensure that no project results in conversion of agricultural land or open space for unrelated purposes.
We also believe non-profits can, and should, play a larger role and be considered as co-applicants on Capital Use projects.
Finally, scoring should assign additional points to proposed projects that also help lessen the impacts of climate change in addition to their primary benefits (For example, a project that incorporates urban forestry that sequesters carbon and avoids heat islands should be ranked higher than a project without these positive environmental impacts. )
As you can tell, there are many conversations still to be had, but the main point is this: California is well on its way to implementing one of the first and most important cap-and-trade programs in the world.
We expect the final draft guidelines for the AHSC Program in December, and the SGC hopes to select projects by June. In the meantime, other programs receiving cap-and-trade funds are also in development, including the Transit and Intercity Rail Capital and the Low Carbon Transit Operations programs. We expect to see draft guidelines or updates from the Administration on these programs very soon.
TransForm and our allies will be there every step of the way to make sure their benefits are felt by all Californians, no matter where you live, where you’re going, or how you get there. To see SC4A’s full comments click here, or contact me to get involved.