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HomeMy WebLinkAboutFinal Recommendations MEMORANDUM TO: FROM: DATE: RE: Iowa City City Council Matthew J. Hayek October 11, 2005 Scattered Site Housing Taskforce Final Recommendations Dear Council Members: The Scattered Site Housing Taskforce has now completed the investigation for which it was formed in April 2004. I am pleased to report that the complexity of the issues examined was matched by the energy and dedication of all eight Taskforce members. Attached are the following: · Final Recommendations for City Council · Chart summarizing free-reduced lunch numbers at ICCSD schools (Table 1) · Fair Share Matrix (Table 2) · Map showing census block groups in Iowa City where opportunities exist for future assisted housing The above-referenced final recommendations and materials collectively were adopted by an almost-unanimous vote ofthe Taskforce. Seven members voted for their adoption, and one member (Jerry Anthony) voted against. I and others from the Taskforce look forward to discussing these materials with you at the October 17,2005, Council work session. -~~ Iowa City Scattered Site Housing Taskforce Final Recommendations for City Council 11 October 2005 INTRODUCTION The Scattered Site Housing Taskforce ("Taskforce") was created by the Iowa City City Council by unanimous vote on April 6, 2004. The Council's instructions to the Taskforce were to "study the existing distribution, location and types of assisted housing in Iowa City" and "recommend policies or actions, as appropriate, regarding the disbursement, location, and type of future assisted housing." The Taskforce consisted of eight individuals from the community who volunteered their time and talents to the inquiry: · Don Anciaux - Chair, Iowa City Planning & Zoning Commission · Jerry Anthony - Vice Chair, Housing and Community Development Commission · Darlene Clausen - Representative, Iowa City Neighborhood Council · Matthew Hayek - Chair, Housing and Community Development Commission · Jan Leff - President, ICCSD Board of Directors · Jan Peterson - Executive, United Way of Johnson County · Sally Stutsman - County Supervisor, Johnson County Board of Supervisors · Joan VandenBerg - At-Risk/Youth and Family Coordinator, ICCSD Between April 2004 and October 2005, the Taskforce toured much ofthe community's assisted housing infrastructure, conducted 24 open session meetings, and held two public hearings. Numerous individuals and organizations were invited to present data and opinions. Of the 17 organizations that presented, 11 were providers of assisted housing. Others presenters included housing-related departments at the City, University of Iowa experts, residents, developers, and so on. The Taskforce reviewed over a thousand pages of written material submitted by these organizations and individuals. Following this exhaustive review, the Taskforce began a process of deliberating the issues at hand. This report (1) summarizes some of the trends identified by the Taskforce and (2) offers a number of policy recommendations for consideration by the Council. Page 1 of8 Iowa City Scattered Site Housing Taskforce Final Recommendations for City Council II October 2005 TRENDS The Taskforce identified numerous trends that need community attention. The more salient trends include the following: (1) Demand for housing assistance is on the rise. In 2000, the waiting list delay for Housing Choice Voucher Program (formerly known as Section 8) vouchers through the Iowa City Housing Authority was zero. An individual or family could apply for housing assistance and, if qualified, receive a voucher immediately. By 2005, the waiting list has grown to more than 2,650 names. An individual or family applying now for housing assistance faces an approximately two-year wait for a voucher. It should be noted that Iowa City is by no means unique in this regard; other metropolitan areas and even smaller communities within the state have witnessed this very trend in recent years. The influx oflow-moderate income populations likely stems from housing policy shifts in major metropolitan areas as well as demographic and economic changes. Iowa City is a particularly attractive place to live due to job opportunities and a broad array of services such as health care, human and social services, education, and public safety. (2) Local housing costs are among the highest in the state. Whether renters or owners, Johnson County households face among the highest housing costs in Iowa. In fact, Johnson County has the highest proportion of cost-burdened households statewide. While the cost of housing within Iowa City drives the countywide average, this dynamic is changing as Coralville now has a higher median price for single-family units. The Taskforce found that numerous members of the community whose incomes are modest are unable to pay market rates to rent or purchase housing. Land prices continue to rise. (3) Assisted housing tends to be concentrated. The Taskforce found that certain census block groups contain a disproportionately high number of assisted housing units, while other block groups contain few (and often no) assisted housing units. Census block groups are the smallest geographic measurement for which reliable statistical data are available. This fact makes it very difficult to gauge the concentration of assisted housing within, for example, a single square block or a portion of a single street. Without a doubt, large multi-unit assisted housing complexes result in an even higher concentration in the immediate vicinity. (4) Emergency and transitional housing is even more concentrated. Within the spectrum of assisted housing, emergency and transitional housing (i.e. housing for the homeless or nearly-homeless) is especially concentrated. One area in particular stands out in this regard. Block group 18-2 presently contains 41 percent of all transitional housing and 69 percent of all emergency housing. If the local homeless shelter is relocated pursuant to current plans, block group 18-2 could end up with 100 percent of all emergency housing. The Taskforce believes this situation merits special attention. (5) Poverty and mobility pose a challenge to our schools. The school district has witnessed marked changes in its student population. Poverty levels at certain schools, measured by Page 2 of8 Iowa City Scattered Site Housing Taskforce Final Recommendations for City Council II October 2005 the percentage of students receiving a free or reduced price lunch, are on the rise. By way of example, 26 percent of Mark Twain Elementary students received a free or reduced price school lunch in 1995; by 2004, the figure was 61 percent. This contrasts sharply with other schools in the district, where rates were as low as 2 percent. The district wide average was 21 percent. A chart summarizing the 2004 free/reduced lunch numbers of all ICCSD elementary schools is attached as Table 1. Other data are likewise alarming. Rates of student mobility (the likelihood that a student will not start and finish an academic year at the same school) are on the rise. At Twain, the mobility rate exceeded 60 percent by 2003, while elsewhere in the district the mobility rates were as low as 8 percent (Lincoln Elementary). Teachers who addressed the Taskforce noted the difficulty of providing quality educational outcomes to high- poverty, highly-mobile student populations. The district targets higher-poverty schools with considerably more resources (up to ten times the amount targeted to lower-poverty schools) in the areas of guidance, reading, class-size reduction, ESL, special education, before-and-after school programs, family resource centers, and the like. Despite this, however, educators from the classroom to the central administration office shared what they described as a growing crisis for education within the community. Notwithstanding the commitment of additional resources, Twain and Grant Wood are the two ICCSD elementary schools at risk of being placed on the federal watch list. The Taskforce is concerned with what it regards to be increasingly disparate school environments within the same public school system. Due to confidentiality restrictions on school data, the Taskforce was unable to examine links between poverty and mobility on the one hand and assisted housing on the other. However, it believes the City, the school district, and other relevant organizations should research this issue further and explore appropriate responses. (6) Local service providers face increasing demand. The Taskforce heard from numerous agencies and non-profits that provide housing and/or services to low-moderate income populations. The message from these entities is that their workloads continue to increase and that many of them face barriers to meeting demands for housing, social and human services, and the like. As budgets for these services are reduced by the federal and state governments, additional burdens are placed on local government, the agencies themselves, and private donors. (7) The University of Iowa impacts local housing. The Taskforce found that rental units of all kinds (both assisted and unassisted) are found mostly within a third of Iowa City's residential census block groups, and mostly near the University of Iowa. This is due to zoning as well as market demands. The total current enrollment at the University of Iowa is 29,745. Only 20 percent of University ofIowa students live on campus. The remaining 80 percent live in private market rental units. Of the total enrollment, 15,765 (53 percent) live in private market rental units in Iowa City; 1,785 (6 percent) live in private market rental units in Coralville. As a result, individuals and families compete with college students for rental housing. The college students can often pay higher rental rates and/or find roommates to share rent expenses, placing low-moderate income individuals and families at a disadvantage. Page 3 of8 Iowa City Scattered Site Housing Taskforce Final Recommendations for City Council II October 2005 (8) Federal funding for housing programs is decreasing. City staff and the presenters discussed the declining levels of support for housing, jobs and services for low-moderate income persons. Drops in CDBG, HOME and Housing Choice Voucher Program (formerly known as Section 8) funding have diminished the federal resources available for local housing needs. RECOMMENDATIONS The Taskforce urges the Council to consider two sets of objectives: General policy obiectives: (1) Iowa City should strengthen its commitment to assisted housing and increase opportunities for affordable housing generally. (2) Iowa City should adopt a scattered site policy to ensure a fair share distribution of assisted housing throughout the community. Specific policy obiectives: (3) The City should launch a campaign to educate the community about the importance of affordable housing, the impact of allowing the status quo to continue, and the degree to which housing and development decisions must involve all segments of the community. (4) The City should enlist other municipalities, as well as the county and area school districts, for purposes of collective action to address affordable housing and services. The issues of housing and poverty cannot be solved by the City alone. (5) The City should make land available for emergency and/or transitional housing throughout the community. The City should neither encourage nor support additional transitional or emergency housing within census block group 18-2. At present, 41 percent of all transitional housing, and 69 percent of all emergency housing, is located within census block group 18-2. The new Shelter House facility will result in the location of 100 percent of all emergency housing within census block group 18-2. (This recommendation is not intended to impact plans for the new Shelter House facility. The Taskforce recognizes the difficulty to date associated with finding a location for the new shelter.) (6) The City should commit resources to encourage future assisted housing to be placed in underrepresented census block groups identified by the fair share matrix provided with these recommendations. This means committing additional funding (i.e. beyond current expenditures and beyond the CDBG/HOME funding stream from HUD) to providers of assisted housing to offset the increased cost of developing housing in such areas. Page 4 of8 Iowa City Scattered Site Housing Taskforce Final Recommendations for City Council II October 2005 (7) If the City commits sufficient resources to scatter assisted housing without causing a reduction in current rates of supply, it should not support additional assisted housing in census block groups identified as significantly overrepresented. (8) The City should encourage affordable housing within the private market. This may involve changes in zoning and code regulations; permitting smaller lot sizes, row housing, and the like; and exploring creative approaches to housing and development policy. (9) The City should ensure that the needs of our assisted housing population are adequately met by the community's service providers. The City should avoid imbalances between the level of need and the ability to meet that need through human and social services. The City should collaborate with public and private partners on comprehensive services to those in poverty. Assistance in the areas of transportation, child care, counseling, education, and employment can help individuals and families become and remain self sufficient. (10) The City should encourage low- and medium-density rental housing (such as duplexes, town houses and the like) to be developed in currently-underrepresented areas of the community. At present, most rental housing is confined to only 10 of 31 census block groups. Such a policy would disperse rental housing away from the University of Iowa student areas and make it easier for families to compete with students for such housing. (11) The City should take additional steps to increase sustainable home ownership among its population earning less than 80 percent of area median income. (12) The City should develop a mandatory inclusionary zoning policy with incentives for new housing developments. An inclusionary zoning policy holds great promise for affordable housing at minimal cost to taxpayers. [Adopted 6-1.. Hayek voted against; Anciaux abstained.] (13) The City should expect owners and managers of all rental housing to manage their facilities adequately. The Taskforce encourages vigorous enforcement of existing policies. Much public opposition to assisted housing results from deficient maintenance and management of unassisted tenant populations. As a mere 1,150 of the approximately 15,000 rental units in Iowa City are assisted, it is important to monitor all rental facilities. (14) In conjunction with its review ofthe Consolidated Plan (CITY STEPS), the City should provide for a yearly review of fair share data so that the matrix provided with these recommendations is updated as conditions within block groups change. The Taskforce recommends that City staff and HCDC coordinate this annual task. (15) The City should conduct a comprehensive review of any scattered site policies at five- year intervals. The City should consider a sunset provision to ensure that such policies are closely monitored. Page 5 of8 Iowa City Scattered Site Housing Taskforce Final Recommendations for City Council (I October 2005 [Recommendation nos. 1-11 and 13-15 were adopted 7-1; Anthony voted against them. Recommendation no. 12 was voted on separately (see above).] FAIR SHARE MATRIX As described above, the Taskforce concluded that concentrations of assisted housing are a growing problem for the community and should be addressed as a matter of policy. At the same time, the growing need for both affordable and assisted housing requires a continued commitment. How best to address concentration and housing demand is the challenge we face. After considerable analysis and deliberation, the Taskforce decided to establish a "fair share" matrix (Table 2) (see also the attached map showing census block groups within the community that lack assisted housing). For this, each of the 31 applicable census block groups was assigned two numbers. The first number is the present amount of housing units (both assisted and unassisted) within a given block group as a percentage of all housing units in the community. The second number is the present amount of assisted housing units within that block group as a percentage of all assisted housing units in the community. This approach demonstrates how a given block group compares to other block groups in terms of its share of assisted housing. Additionally, the task force wanted the matrix to be easy to understand, employ readily available and reliable data, and permit efficient updating as new building occurs within the community. The fair share matrix demonstrates that the total current number of housing units within a given block group may be as low as four and as high as 2,945. Similarly, the fair share matrix demonstrates that the total current number of assisted housing units within a given block group may be as low as zero and as high as 392. The basic premise ofthe fair share matrix is this: for a block group to contain its "fair share" of assisted housing relative to other block groups, its percentage of all assisted housing should approximate its percentage of all housing. The Taskforce believes this approach provides the most equitable means of improving the distribution of assisted housing. It should be noted that the fair share matrix does not - and cannot - answer all questions or account for all variables. For example, zoning constraints within certain block groups preclude medium- or higher-density apartments and condominiums, discouraging the even distribution of such housing. However, after considering various different approaches and data sources, the Taskforce concluded that the fair share matrix represents a fair, logical way to measure the assisted housing landscape. While the fair share matrix was selected as the primary means by which concentration or lack of affordable housing opportunities should be gauged, other data were considered and are worth mentioning. The Taskforce reviewed the following data and discussed their merits and faults at great length. Consensus was not reached regarding the use of these data, and as such they were not included as criteria in the fair share matrix. However, the Taskforce believes these and other factors should be considered in any scattered site policy. Page 6 of8 Iowa City Scattered Site Housing Taskforce Final Recommendations for City Council 11 October 2005 · Data regarding the Housing Choice Voucher Program (formerly known as the Section 8 program) · Data regarding assisted housing by type (elderly viz. disabled viz. individuals/families) and by block group · Data regarding assisted rental housing as a percentage of all rental housing per/within each block group · ICCSD free/reduced lunch data · ICCSD mobility data · ICCSD test scores data · Poverty, median housing price data · Location of hum ani social services data · University of Iowa - Field Problems Project List of Presenters Habitat for Humanity Shelter House Domestic Violence Intervention Program City of Iowa City Housing Authority City of Iowa City Community and Economic Development Office City of Iowa City Urban Planning Office Greater Iowa City Housing Fellowship Successful Living, Inc. Hawkeye Area Community Action Program Bums & Burns, L.C. Mid-Eastern Council on Chemical Abuse Neighborhood Centers of Johnson County Iowa City Neighborhood Council Wells Fargo Bank (private lender representative) University of Iowa - Residential Services University of Iowa - Urban and Regional Planning Home Builders Association of Iowa City Iowa City Area Association of Realtors (invited but declined to present) Iowa City Community School District Page 7 of8 Iowa City Scattered Site Housing Taskforce Final Recommendations for City Council II October 2005 S.S.H.T. Meeting Dates April 29, 2004 May 12,2004 Bus Tour May 17,2004 June 7, 2004 June 21,2004 July 12, 2004 July 19, 2004 August 2, 2004 August 16, 2004 August 30, 2004 September 20, 2004 October 4, 2004 Public Hearing at Twain Elementary School October 18, 2004 November 8,2004 November 22,2004 December 6, 2004 December 13, 2004 January 3, 2005 January 24, 2005 January 31, 2005 February 14,2005 February 28,2005 March 28, 2005 April 4, 2005 Public Hearing at the Senior Center April 25, 2005 May 26, 2005 (cancelled) October 3,2005 Page 8 of8 Table 1 Table 1: Percentage of K-6 grade students in F&R programs by school Year 1995 2004 26% 61% 30% 54% 19% 45% 37% 44% 35% 41 % 16% 32% 13% 29% 15% 27% 18% 23% 19% 21 % 7% 18% 20% 15% 7% 11 % 5% 8% n.a. 5% 5% 4% 7% 2% 7% 15% 8% 14% 14% 21 % 13% 22% 44% n.a. 14% 21 % School Twain Hills Wood Mann Roosevelt Kirkwood Lucas Coralville Central Penn Longfellow Lemme Weber Hoover Horn Wickham Lincoln Shimek City High West High Northwest junior high Southeast junior high CEC Total for ICCSD Source: ICCSD data presented to the Taskforce TABLE 2 Fair Share Assisted Housing Units Based on Percentage of All Housing In Each CnBG All Assisted Units (Owner and Renter) Column 9* Over\Under Fair Share Under Under Over Under Under Under Over Under Over Under Under Under Over Over Under Under Over Under Over Over Under Over Under Over Under Over Under Under Under Under Over Column 8 of Assisted in CnSG 2.66% 1.41% 2.76% 0.90% 5.89% 4.61% 0.86% 2.34% 4.61% Percent Unit:§. 0.39% 3.43% 13.94% 0.00% 2.14% 12.18% 10.71% 0.00% 13.85% 0.22% 0.71% 0.49% 3.57% 1.48% 3.50% 0.79% 1.76% 1.71% 0.00% 0.00% 0.00% 8.16% 4.44% Column 7 Number of Assisted Units 4 38 392 o 21 9 30 14 14 4 13 9 6 90 28 10 16 15 81 21 3 13 102 162 o 104 1 o o o 76 1276 Column 6 Percent of All Housing Units in CnSG 3.56% 3.85% 9.79% 0.01% 10.25% 6.33% 2.93% 3.29% 1.39% 1.75% 2.57% 1.83% 0.98% 2.57% 3.66% 2.47% 2.02% 5.83% 4.78% 1.59% 1.21% 1.93% 7.70% 5.26% 0.05% 2.61% 1.60% 2.73% 0.02% 2.18% Column 5 Total of Housinq Units 1023 1108 2813 4 2945 1819 841 947 400 504 740 526 281 739 1053 711 580 1675 1375 456 348 556 2214 1512 14 751 460 786 5 627 Number Column 4 90 486 o 293 7 8 18 2 5 59 3 o 26 144 2 8 73 3 1 2 11 420 123 o 139 30 2 o o 618 2661 Permits Column 3 2000 Census All Housin Units 935 1018 2327 4 2652 1812 833 929 398 499 681 523 281 713 909 709 572 1602 1372 455 346 545 1794 1389 14 612 430 784 5 627 Column 2 Slack Group 1 2 1 1 2 1 1 2 1 2 1 2 1 2 3 1 2 1 2 1 2 3 1 2 1 2 1 2 3 4 1 Column 1 Census Tract 1 1 4 5 5 6 11 11 12 12 13 13 14 14 14 15 15 16 16 17 17 17 18 18 21 21 23 23 23 104 105 3.24% 100.00% 931 28744 313 26083 Iowa City Totals (a.k.a. Section 8) units. Share in column 9 is determined by the data in columns 6 and 8. If the percentage in column 8 is greater than the percentage in column ß then the census block group fthe percentage in column 8 is less than the percentage in column 6 the census block group is 'Under' its Fair Share and is lacking assisted housing opportunities. This does not include Housing Choice Voucher Program "Assisted" units include rental and owner-occupied housing units that received public funds. The 'Over\Under' Fair 'Over' its Fair Share and Note: is ~"';>,-., ""~",,-. ""'. "'~'" ""~~~ ''''',<~'' " , o \ " , , ''',- , \"- \ r , " -'" , , , , \\ P I , , ! (2) \ \ \-- , 1 , :'\ -'\, '~ '0 '\'0 \ Scattered Site Housing Task Force\::,p/ October 3, 2005 eJI/ . -,' 1, U ". ¡ , ',,:~. l...# n !i u , " ï .,J \V7 ,0 ! ': ,'" " '-'<-"\ r':"; ."Aj >~, ':' '0" ,.<~';-.. " 'è, ,~ <~, "'>. ," '>, ".. ,.-., '.C! -,,-' , , I I :1: ,¡ ,- o ,<::' I"'" <:::7 . >,~, -0c~ -';~. ~- , (]) , , , ~-^- Z\' ":' 's:- ".' , "'>~" "..'-. ",", " \s" :":" ~\, , , , , , , I i , , I , I i , , ! ¡:; ~ ::¡ [:; Ù ~ :;; ," '~-. ,-,. -',., , ''\, ", ''';., '\: / I I , , I I , \ , Areas thai are underserved with affordable housing opportunities 10 October 2005 Dear Council Members: The following are some supplemental thoughts concerning the recommendations of the Scattered Site Housing Taskforce. 1. The recommendations before you were the product of deliberation and negotiation between eight citizens who lent their time and energy to the task, as well as certain agencies and individuals who advocated a number of policy outcomes. The recommendations reflect a compromise of opinion. 2. The specific method of scattering assisted housing chosen by the Taskforce is, from my perspective, less critical than the need per se to avoid such concentrations. In other words, the fair share matrix offered with the recommendations mayor may not be the best approach. The City's own planners are well-equipped to advise Council in this regard. 3. If housing in Iowa City is to become more affordable for more people, the private market is essential. Even if additional public funds are dedicated to assisted housing programs, the net increase in assisted housing units throughout the community will pale in comparison to the amount of housing generated by the private market. In realistic terms, I would estimate the ratio of future assisted housing to future private market housing to be no greater than 1 :20. This fact underscores the importance of working with the private market to encourage and incent affordable housing. Density of housing (lot sizes, row housing, etc.) is, in my opinion, a good place to start. 4. Greater promotion of home ownership among low-moderate income individuals and families is important. Home ownership carries financial and other benefits that most of us take for granted. It offers more options for consumers and can scatter housing more effectively. It merits as much support as this community can provide. 5. I do not support mandatory inclusionary housing for two reasons. First, I believe the City should experiment with voluntary, incentive-based inclusionary zoning before taking the more drastic step of requiring it. Second, I believe the specifics of any inclusionary zoning policy (regardless of type) should be crafted by City planners after careful study. Ideally, any such policy would cover most or all of Johnson County to avoid imbalances or unanticipated impacts to Iowa City. 6. Regional planning will become more important - and hopefully more viable - with time. Affordable housing, concentrations of poverty, and increasing demands on social services are issues that Iowa City's neighbors are starting to face. I believe area municipalities and school districts will be more likely to conclude that they, too, have a role to play in these issues. Collective, well- planned action promises to benefit all communities in Johnson County. Sincerely, ~~J Matthew J. Hayek Scattered Site Housing Taskforce OCT10. !t) Supplementary Note and CritiQue- Jerry Anthonv. member Housin2 and Community Development Commission of the City of Iowa City The recommendations of the Scattered Site Housing Taskforce have several features and some shortcomings that if overlooked in any scattered site policy adopted by the City may lead to serious legal challenges. 1. Problems because of the lack of evidence The Iowa City Community School District's letter to the Council (dated November 11, 2003) implied that students living in assisted housing are the prime cause of low school test scores. As explained in paragraphs a), b) and c) below, there is no evidence to support this contention. a) The Taskforce asked Iowa City Community School District (ICSSD) to provide test scores of students based on where they lived (assisted housing versus non-assisted housing). Citing data confidentiality reasons, ICSSD did not disclose this information. Thus, no evidence to back ICCSD's claim was presented to the Taskforce. b) Students living in assisted housing are often assumed to be more likely enrolled in free and reduced price lunch programs than students living in non-assisted housing. Yet if ICCSD data on students enrolled in free and reduced price lunch (F&R) programs is examined one does not find clear support for this assumption. As the Table 1 (on the next page) shows, the percentage of F&R students in Wood and Twain (two schools that are often presumed to draw many students from assisted housing developments) are not dramatically different from those of Hills, Mann and Roosevelt (that are commonly presumed to have far fewer proportions of students living in assisted housing). c) Students enrolled in F&R programs are often assumed to have lower scores on standardized tests than other students. Yet data from ICCSD schools presented to the Taskforce do not support this assumption. In ICCSD elementary schools in 2003 there were 826 students in grades 3-6 who were below proficiency levels on standardized tests: of these, the majority (454) were not enrolled in F&R programs. Assisted housing comprises a mere 4% of the total rental housing stock in Iowa City. Since children living in non-assisted rental housing are likely to be as mobile as those living in assisted rental housing, ascribing all problems from mobility (if any) in the ICCSD to those children living in assisted rental housing is incorrect. In summary then, there is no evidence at all linking students scores with living in assisted housing, there is no indication that there is a greater percentage of students on F&R programs in areas that have more assisted housing units, and no definitive trend linking enrollment in F&R programs or high mobility with low test scores in ICCSD. Therefore, to blame students living in assisted housing for poor school test scores without any evidence to that effect is clearly wrong. And if poor test scores is used as an argument to support a scattered site housing policy, such a policy may be easily overturned upon legal challenge. 1 Table 1: Percentage of K-6 grade students in F &R programs by school School Year 1995 2004 Twain 26% 61% Hills 30% 54% Wood 19% 45% Mann 37% 44% Roosevelt 35% 41% Kirkwood 16% 32% Lucas 13% 29% Coralville Central 15% 27% Penn 18% 23% Longfellow 19% 21% Lemme 7% 18% Weber 20% 15% Hoover 7% 11% Horn 5% 8% Wickham n.a. 5% Lincoln 5% 4% Shimek 7% 2% City High 7% 15% West High 8% 14% Northwest junior high 14% 21% Southeast junior high 13% 22% CEC 44% n.a. Total for ICCSD 14% 21% Source: ICCSD data presented to the Taskforce 2. The danger of inappropriate policy intervention The issue as framed in the ICSSD's letter to the City Council (noted above) tends to pit the school district's interests against those ofIowa City families wanting to pay affordable rents and prices for housing. Based on overall test scores, the ICCSD is one of the best performing school districts in the nation and perhaps the best in the state. On the other hand, Johnson County has the absolute worst affordable housing situation in the state. Since new policy interventions should enhance community welfare, it is imperative that new policies not exacerbate current problems. Therefore, attempting to address the school district's concerns about low-test scores (a worthy goal) by exacerbating the affordable housing crisis, regardless of whether scattering could actually improve test scores, may not be a wise, legally-defensible strategy. If the City considers implementing a scattered site housing policy, hopefully this point will be kept at the forefront of all deliberations. Parenthetically, one wonders whether the ICCSD has explored other options for improving school test scores within the school system, such as busing some students from enrollment areas of school with low-test scores to schools with higher scores. 2 3. The Fair share matrix has significant shortcomings The Fair share matrix is based on the notion that every part of the city should have its fair share of the assisted housing units. While the concept is simple, it has a significant shortcoming: zoning disallows location of assisted or affordable housing in many parts of the city (for example, multi-unit apartments and high density single-family units can only be built in a select few areas of the city). Therefore, it is absolutely impossible for all parts of the city to have a fair share of the city's assisted housing. The matrix itself has three major shortcomings: a) One, it disallows construction of assisted housing for elders (who do not have any children in schools) in certain areas of the city. b) Two, it disallows construction of new assisted housing in areas that have developable land while encouraging construction in areas that do not. c) And finally, it uses a definition of concentration that is vastly different from the one the City has always used without providing any reason for the change in definition. Use of the matrix to implement a scattered site policy will likely lead to multiple legal challenges about its appropriateness. 4. Problems in process Deliberations of the Taskforce were seriously compromised by several lapses of due process that could invite legal challenges. For the sake of brevity, only one example is provided here: the Taskforce did not include any member who either built assisted housing or lived in it--- thus excluding an important group from the deliberations-while including two members of the organization that leveled charges against assisted housing. Guidelines for policy intervention. Given the plethora of legal challenges possible, should a scattered site policy be implemented and if so how? If the City chooses to implement a scattered site housing policy, committing additional funds (from new sources, rather than from CDBGIHOME and other existing sources) will help ensure that the current supply of affordable housing is not adversely affected by a desire to scatter. Implementing a scattered site policy after the new sources have been identified will further reduce legal challenges. That said the Fair Share matrix in its current form, may still expose the City to some legal challenge. The City should consider using the definition of concentration that it has always used in the past or prepare a less flawed Fair Share matrix. Ideally, the City should adopt a mandatory inclusionary zoning policy as recommended by the Taskforce. This would provide a steady supply of affordable housing units, in scattered locations and at no-cost to the City. Ultimately, as Taskforce members concluded, a mandatory inclusionary zoning policy is the only financially feasible and sustainable solution to offset the location of assisted housing units in only some areas of the city. 3