Testimony at DHCD Hearing on Draft LIHTC QAP
Ward 3 Housing Justice (W3HJ)
August 25, 2021
Thank you for the opportunity to testify on the LIHTC Qualified Allocation Plan (QAP).
I am Margaret Dwyer, Convener of Ward 3 Housing Justice, a grassroots organization affiliated with the DC Grassroots Planning Coalition dedicated to significantly increasing truly affordable housing through bold, visionary action and community advocacy in Ward 3.
We find much to support in the Plan.
In particular, we strongly support the shift to two rounds of awards, thus providing more opportunity for a variety of players, including non-profit community organizations, to qualify.
Likewise, we applaud that the 2021 Priority Classification #1 includes Rock Creek West and Near Northwest Planning Areas. It is time to lay to rest the tired narrative that RCW is racist and exclusive. The Mayor has called for 1990 new affordable housing units in RCW by 2025. It is time for the city to invest in this worthy goal, and W3HJ wants to be part of making that happen.
At the same time, we are deeply opposed to the single definition of mixed income housing found on page 32 of the QAP, which places a premium on inclusion of market rate housing for 20 to 80% of the proposed units. Earlier, it says that the QAP “…is intended to ensure the selection of only those Projects that comply with federal law and address, on a priority basis, the District’s housing needs” (p.4, italics added).
What priority housing needs does the inclusion of up to 80% market rate housing address in a city with thousands of vacant market-rate units? And what is the result of a requirement like this in a plan designed to respond to the urgent need for affordable housing?
Consider how this mindset has played out in the Wardman Hotel redevelopment proposal.
Last January, W3HJ and the Wardman Hotel Strategy Team proposed a redevelopment project of the Wardman Hotel that meets many of the criteria set forth in the QAP. The hotel is located in Woodley Park, an area with a deficit of affordable housing, but a wealth of amenities including access to schools, libraries, recreation centers, parks, and Metro. We proposed a green redevelopment which is more environmentally sound than demolition and new construction. Our architectural concept study includes 500 units, many family-sized, in a mix of housing types for people living on 0-80% MFI to allow residents to move up economically without having to move out. The study also includes opportunities for job and business development, supplemental classrooms for Oyster School and community recreation facilities. Our proposal accommodates renters from the DCHA Section 8 voucher waiting list as well as limited-equity coop owners. Although the parcel is not city land, the previous owner, Pacific Life, has a social bonds program that the city could avail itself of, reducing the purchase to a manageable, long-term mortgage-type arrangement.
So why has the city refused to consider the project seriously? We believe that the single most significant obstacle was the commitment to a definition of mixed income housing that requires large amounts of market rate housing, one that still is embedded in the QAP, and one which we urge be stricken.
Many city officials, elected and appointed, have greeted our Wardman proposal with concerns about ‘concentration of poverty’, a phrase that has been rejected by leaders in the field of urban planning as part of a conservative ‘discourse of disaster’ that undermines confidence in our public institutions such as public schools and public housing. This myth is outmoded and based on the belief that there is something inherently problematic about striving households living together. Our proposal would have provided affordable housing and other opportunities for retail and hospitality workers, social security recipients, veterans living on pensions, barbers, teaching assistants, lab technicians, fire dispatchers, school dietitians, clergy, speech pathologists and others-- all of whom make less than 80% AMI.
The problems that have beset other models of 100% affordable housing have been the result of planned, strategic neglect, something that is not accidental, irremediable or attributable to the resident families. In fact, this entire manufactured stigma is undeniably part of the '...systematically racist housing policy of the past…’ (p. 31) that the QAP is supposed to remedy.
Visionary housing sponsors are moving beyond this limited thinking. The Urban Institute has reported, “Although tax credits can be used for mixed-income projects, most projects are 100 percent affordable to maximize the equity raised for the project” (2018). In our region, Amazon has announced the donation of land to enable Arlington County to build a 550-unit 100% affordable housing project for people living on up to 80% of the MFI. Fairfax County is exploring acquiring land near a Metro Station, providing gap financing and tax credits, to create an all- affordable housing project for people making no more than 60% of the MFI.
Why not DC? We urge that the use of LIHTCs be limited to projects, like our Wardman proposal, that provide mixed income housing for households living at 0-80% of the MFI.
In closing, I would leave you with three key ideas:
1. We support aspects of the QAP draft such as the second round for proposals and the focus on areas such as RCW that have not had significant investment in affordable housing.
2. We strongly oppose the narrowness of the definition of ‘mixed income housing’ and maintain that no market rate housing needs to be included to have a community with a wide range of mixed incomes.
3. We have been using the present tense in this testimony to describe our Wardman conversion proposal because we believe it is still viable. Our new partner, the NW Opportunity Partners CDC, will be meeting with the Deputy Mayor in September to pursue this proposal and to explore others.