2021 Affordable Housing Appeals List

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2021 AFFORDABLEHOUSING APPEALS LISTANALYSIS & RECOMMENDATIONSMAY 18, 2022SEAN GHIOinfo@pschousing.org

ContentsIntroduction22021 Affordable Housing Appeals List Summary32021 Municipalities Exempt from Section 8-30g4Affordable Housing is Overconcentrated Even Among Exempt Municipalities42021 Affordable Housing by Category6Government Assisted Housing6Tenant Rental Assistance6CHFA Single-Family Mortgages7Deed Restricted Housing8Policy Considerations9One Plan Ten Local Actions to Grow Affordable Housing Supply11Conclusion15Partnership for Strong Communities pschousing.org1

IntroductionIn February 2022, Connecticut’s Department of Housing published the 2021 AffordableHousing Appeals List that provides an annual count of affordable housing (as defined by Section8-30g) in each municipality. 1For this list, government-assisted and deed-restricted housing is composed of:1. Housing receiving financial assistance under any governmental program for theconstruction or substantial rehabilitation of low- or moderate-income housing,2. Housing units with tenants who have federal Housing Choice (Section 8) vouchers orstate rental assistance certificates (RAP),3. Housing with Connecticut Housing Finance Authority (CHFA) and United StatesDepartment of Agriculture (USDA) single family mortgages, and4. Housing subject to deeds restricting its sale or rental to low- and moderate-income peopleat prices that will result in housing cost being no more than 30% of income.The Affordable Housing Appeals List is collected for purposes of determining municipalexemption from the provisions of Section 8-30g and is not an inventory of all housing in thestate that is “affordable” in the lay sense of the term. Instead, it is a tool for exempting from theact those towns in which a relatively high percentage of the housing units are governmentassisted or subject to long-term affordability deed restrictions. Municipalities with at least 10percent of housing stock that meets the Section 8-30g definition of affordable are exempt fromthe statute.Because the Affordable Housing Appeals List data have been collected annually in a similarfashion for some 30 years, the list offers us an opportunity to view how this type of long-termaffordable housing supply in Connecticut (as defined by Section 8-30g) has changed over time.This report builds on Partnership for Strong Communities’ previous analysis of nineteen years ofAffordable Housing Appeals Lists published in 2021. 2 It includes an analysis of the 2021 list,and a set of recommendations on actions that municipalities may take to grow the percentageof their housing supply that qualifies as affordable under Section ticutPartnership for Strong Communities pschousing.org2

2021 Affordable Housing Appeals List SummaryThere was only very minor net growth in the total supplyof affordable housing in Connecticut during 2021.According to the 2021 Affordable Housing AppealsList, Connecticut had 174,337 assisted housing unitsrepresenting 11.71% of total housing supply. This is anet gain of 129 units from 2020.A continuing drop in the number of CHFA single familymortgages masks gains in other affordable housingcategories. The net annual change in affordablehousing supply jumps to 2,998 units when CHFAmortgages are excluded.As in 2020, the same thirty-one municipalities are exempt from Section 8-30g. As discussed inlast year’s analysis of the Affordable Housing Appeals List, the state’s supply of assisted housingremains about as geographically concentrated as it was nearly 20 years ago. In 2002, 31municipalities had assisted housing supply equal to or greater than 10% of their total housingsupply. These municipalities are exempt from the provisions of Section 8-30g. The 31Partnership for Strong Communities pschousing.org3

municipalities had a total of 127,960 assisted housing units representing 78.2% of the totalsupply of affordable homes in the state in 2002.The group of municipalities with an assisted housing supply equal to or greater than 10% of itshousing stock has varied little over the last 20 years. Exempt municipalities have remainedunchanged except for the following substitutions. In 2002, Brooklyn, Colchester, andNaugatuck all were above 10%. In 2021, these three municipalities are no longer exempt butDerby, North Canaan, and Windsor Locks have taken their place.2021 Municipalities Exempt from Section dUnitsPercentAffordableHartfordNew HavenWindhamGrotonNew %23.22%22.52%BristolManchesterEast NorwichNew 2%19.34%18.60%Windsor niaEast 7078610.99%10.76%10.56%10.35%West Haven3,53815.76%North Canaan16210.21%Stamford7,94515.71%Affordable Housing is Overconcentrated Even Among Exempt MunicipalitiesAffordable housing remains incredibly concentrated in Connecticut in a few cities with majorityBIPOC (Black, Indigenous, people of color) populations. The affordable housing units locatedin the 31 exempt municipalities account for 133,929 (76.8%) of total assisted housing units in2021. Looking back again to 2002, 77.4% of all assisted housing was in exempt municipalitiesin that year. The degree of concentration of affordable housing in Connecticut remains largelyunchanged.Partnership for Strong Communities pschousing.org4

Even among the 31 exempt municipalities, the affordable housing supply is very concentrated.Hartford’s supply of affordable housing represented 40.32% of all housing in the city. This isthe highest percentage in the twenty-year period of 2002 – 2021. There is also a greatconcentration of affordable housing in New Haven, where 33% of all housing in the city isaffordable.Three Connecticut cities contain 29.4% of all assisted housing in the state – another indicationof the imbalanced distribution of assisted housing in the state. Hartford, New Haven, andBridgeport have 51,173 assisted housing units, equivalent to the total assisted housing in thebottom 150 Connecticut municipalities. 403,731 people live in these three cities, representingonly 11.2% of Connecticut’s population (3,605,944). 3 Hartford, Bridgeport, and New Havenalso have the highest proportion ofCitiesAssisted LowestRankedBIPOC residents in the state: 85.2%,UnitsMunicipalities79.9%, and 70.5% respectively. LikeNeeded to Equalthe disproportionate concentration ofHartford20,897 121affordable housing in these threeHartford & New 39,039 143cities, 26.5% of Connecticut’s BIPOCHavenresidents live in Hartford, New Haven,Hartford, New Haven 51,173 150and Bridgeport.& BridgeportThe number of assisted housing units inHartford alone (population 123,008) is equal to the assisted housing supply in 121municipalities with the lowest supply of assisted units – 71.6% of all Connecticut towns. Hartford,smaller in overall population than either Bridgeport or Stamford, dwarves the supply ofaffordable housing in those cities. The concentration of affordable housing is so great in Hartfordthat it can artificially elevate prevailing rents. 4U.S. Census Bureau, .pdf34Partnership for Strong Communities pschousing.org5

2021 Affordable Housing by Category20202021PercentageChangeGovernment92,075 93,840 1.92%AssistedTenant Rental 47,034 48,102 58 26,989 -9.6%5,2415,4063.2%From 2020 to 2021, affordable housingsupply grew by 2 – 3% in three of the fourcategories of assisted housing. This isremarkable given that fewer buildingpermits for new housing were issued in2021 than in any year since 2011. Deedrestricted housing saw the greatestpercentagepointgainwhileCHFA/USDA single-family mortgagescontinued a long-term decline.Government Assisted HousingFifty-four percent of Connecticut’s assisted housing supply (93,840 units) is housing receivingfinancial assistance from a governmental program for the construction or substantialrehabilitation of low- or moderateincome housing. 5 This includesGovernmentally Assisted Housinghousing created under a myriad 95,000of federal housing programs,including the Low Income 93,000Housing Tax Credit program91,000(LIHTC), and state investmentssuch as Connecticut’s Housing 89,000Trust Fund and Connecticut’s87,000Affordable Housing Program(FLEX). The continued growth in 85,0002011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021this category reflects the sustainedcommitment of state bonding foraffordable housing construction over this period. 6Tenant Rental AssistanceIn 2021, Connecticut residents had access to 5,574 state Rental Assistance Program housingvouchers as well as more than 40,000 federal housing vouchers. While Connecticut DOH/DOH/Programs/FLEXPartnership for Strong Communities pschousing.org6

invested more than 70 millionannually in recent years to supplythese RAP vouchers, there are notnearly enough available vouchers tomeet the need in Connecticut. Morethan 220,000 renter householdsspend more than 30% of their incomeon housing costs, and 114,000renter households spend more thanhalf of their income on housing costs.Tenant Rental , only 20-25% of voucher2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021eligible households receive one. InJanuary 2022, there were over 3,600 households on the waitlist for RAP in Connecticut. 7CHFA Single-Family MortgagesCHFA/USDA single-family mortgages declined sharply in 2021 from 29,858 mortgages in2020 to 26,989. Of the assisted housing categories collected in the Affordable HousingAppeals List, this category is the most volatile over the period between 2002 – 2021.The steep decline in CHFA single-family mortgages over the last year is reminiscent of a dramaticdrop in CHFA mortgages from 2002 – 2006. As with that decrease, it is likely due in part tohomeowners with CHFA mortgages either selling their homes, or more likely, refinancing out ofa CHFA mortgage because of lowinterest rates or to take advantage ofCHFA/USDA Mortgageslarge increases in home equity resulting38,000from the single-family price spikesConnecticut has experienced duringthe COVID-19 pandemic. 834,00030,00026,00022,0002002 2004 2006 2008 2010 2012 2014 2016 2018 2020In many ways CHFA single familymortgages compete with the privatemortgage market. As a result, CHFA’ssingle family program is subject tosimilar pressures as private markethome lending products. Borrowers willseek out lending products to best artnership for Strong Communities pschousing.org7

their financial and housing needs at a given time and with given market conditions. Currently,the Connecticut single-family real estate market appears to be in a position that does not favorCHFA single-family mortgages. This may change soon as mortgage rates are expected to risefrom the historic lows we have seen over the last decade.Deed Restricted HousingDeed restricted dwellings grew by 3.2% to 5,406 in 2021. This category includes propertieswith deeds containing covenants or restrictions that require the dwelling be sold or rented atprices assisted to low- and moderate-income households.9In Connecticut, assisted housingunits created through Section 8-30g7,000development proposals hatrequireapercentage of units in a housing4,000development be set-aside as3,000assisted contribute to this total.2,000Affordability restrictions on housing1,000are not typically permanent; theyexpire after a set number of yearsspecified in the deed. As a result,the supply of deed restricted units fluctuates as the supply 01320142015201620172018201920202021Deed Restricted UnitsSome Fairfield County municipalities have had several housing development proposals thatconform to Section 8-30g requirements for set-aside developments, especially Greenwich.Greenwich Time reported in March 2022 that “[o]ver the last 14 months, 13 proposals forhousing developments that include some units designated as affordable have gone before thetown, town officials said. That compares to eight proposals over the last 30 years.” 10Given the time required to gain permitting approvals, secure financing, and construct multifamily housing, we can expect some of these new proposals to contribute to the deed restrictedhousing supply in future Affordable Housing Appeals Lists.Households with incomes less than or equal to 80% of the area median 004714.php10Partnership for Strong Communities pschousing.org8

Policy ConsiderationsLooking back at the last twenty years of appeals lists can help us understand how the state’sassisted housing supply has changed and how it has stayed the same. What can be said withconfidence is that government subsidy, whether in the form of individual housing vouchers,mortgages, or underwriting affordable housing construction, continues to be the most impactfulmeans to create and maintain assisted housing in Connecticut, especially for Connecticut’slowest income households. This crucial affordable housing supply is at risk. More than 2,600public housing units are in immediate need of investment. More than 9,000 publicly supportedrental homes face an expiring affordabilityrestriction in the next 10 years. 11Public resources (state and federal) must beallocated at a level to preserve the existing assistedhousing supply while also expanding the supply ofassisted housing available to Connecticut’s lowestincome households.Deed restrictions requiring housing affordability,whether through Section 8-30g developments,inclusionary zoning ordinances, or other methods,remain a small, but important, part of the overallassisted housing supply. These units are distributedmore broadly across the state in 2021 than in2002, providing valuable affordable housingopportunities in many communities that areotherwise lacking in assisted housing.Chart from PAHRC Connecticut 2021 PreservationProfileHowever, our state’s assisted housing stock remains highly concentrated in a small number ofcommunities, primarily communities of color, with higher concentrations of poverty. If we areto truly break away from Connecticut’s intense levels of economic and racial segregation andfulfill the promise of affordable housing – opportunity, we will need to enact policies thatexplicitly serve to expand the supply of assisted housing in towns across the state.Zoning reforms adopted in 2021 to allow accessary apartments and set maximum for parkingrequirements have improved the land use environment for further development of lower costhousing in communities across the state. 12 These changes were a small step forward. Deeperreforms are still needed if we want to create an environment conducive to further content/uploads/2021/08/PD-Profile 2021 107-R010716-BA.PDFPartnership for Strong Communities pschousing.org9

housing development. Two worthwhile reforms were discussed during Connecticut StateLegislature’s 2022 session: creation of a fair share zoning system 13 and permitting moreintensive development near our transit stations. 14 While neither initiative became law this year,advocates will continue to pursue both reforms in the future. These changes must be coupledwith expanded public investment in affordable housing construction and mobile housingvouchers if we intend to significantly grow the supply of assisted housing in communities of allkinds in ps://www.desegregatect.org/tocPartnership for Strong Communities pschousing.org10

One Plan Ten Local Actions to Grow AffordableHousing SupplyThere are many activities residents and local officials canundertake to expand the supply of affordable homes in theircommunity that will also increase the number of assisted housingunits in their town for purposes of the Affordable HousingAppeals List. A precondition to expanding housing affordabilityequitably, must be drafting and adopting an actionableaffordable housing plan. It is state law, and Connecticut’sDepartment of Housing has a guidebook for municipalities tohelp. 15“Planning for Affordability in Connecticut” provides a frameworkfor municipalities to engage the community in the planningprocess and recommendations for creating specific elements ofplan. Municipalities can use the guide to apply best practices to implement an affordablehousing plan and drive actions that expand affordable housing.Ten such local actions are listed below.Each is followed by a key that identifies inwhich category/ies of the AffordableHousing Appeals List the action couldexpand assisted housing supply.Assisted Housing CategoryGovernment Assisted HousingCHFA/USDA Single-family MortgagesTenant Rental AssistanceDeed Restricted HousingKeyGASFTRADR1. Advocate for increased state funding for housing construction and mobile housing vouchers.State government has committed hundreds of millions of dollars toward affordable housingconstruction in recent years through bonding authorizations. Many affordable housingdevelopments in the state receive funding because of these authorizations. Local officials andresidents can advocate for the state to commit more resources to affordable housingdevelopment and to allocate the existing funding more quickly to proposed housingdevelopments. In 2022, the HOMEConnecticut campaign advocated for 150 million in bondfunding for affordable housing construction and 20 million to expand the number of housingvouchers available in the state. 16 (GA, SF, TRA, k RPA da%202022.03.14.pdf1516Partnership for Strong Communities pschousing.org11

2. Create a local housing trust that can support development by a local housing authority orother nonprofit affordable housing developers. Stamford created an Affordable Housing TrustFund in 2020. It is largely funded through a percentage of the building permit fees forcommercial development, and fee-in-Lieu payments as part of the City’s Below Market Rate(BMR) program.17 In February 2021, the fund made its first awards totaling 1.7 million fortwo housing projects. The funding was awarded to two local nonprofits: Housing DevelopmentFund and Pacific House. Housing Development Fund will build 25 two- and three-bedroomcondominiums for purchase. Pacific House will build 25 units of shared housing apartments inthree buildings for individuals and families at risk of homelessness.18 (GA, DR)3. Lower new housing costs by reducing minimum lot size requirements. A 2021 report fromDesegregate CT finds that “[l]arge minimum lot sizes make homes more expensive, bothbecause the amount of land itself drives up home prices and because large minimum lot sizesreduce the number of homes that can be built, artificially restricting supply.” 19 Homes built onsmall lots are an effective means of reducing housing costs. Land costs in Connecticut are asignificant driver of housing costs. Reducing minimum lot sizes has many additional benefits toa community including reducing vehicle miles traveled, reducing vehicle emissions, makingneighborhoods more walkable, and maximizing existing infrastructure. A 2015 study found thatsuch ‘gentle density’ reduces a municipality’s maintenance costs “reducing the per-resident costsof road building and maintenance, water and sewer mains, fire and emergency medicalprotection and school transportation.” 20 (SF)4. Lower housing costs by permitting lower cost housing types for homeownership and rental –condominiums, smaller single-family homes on small lots, expansion or conversion of singlefamily homes to duplexes or triplexes on small lots. In addition to decreasing minimum lot sizes,allowing more homes on a lot is a very effective method of reducing housing costs. The perhome cost of a duplex, triplex, or 4-plex is more affordable than the single detached house thatcould have been built in their place. These homes will be “naturally” less expensive, and theyalso serve as supply for potential CHFA first-time homebuyers and rental housing voucher holders– both categories of housing that increase a municipality’s supply of affordable housing. (SF)5. Support the expansion of Rental Assistance Program vouchers to reduce the number ofresidents spending unsustainable amounts of their income on housing costs. Every municipalityin Connecticut, including the wealthiest, has a significant number of residents that struggle 90fe9/1642726053008/Issue Brief - Minimum Lot he-power-of-urban-density/1718Partnership for Strong Communities pschousing.org12

affording a home. For example, New Canaan’s median household income of 197,200makes it one of the wealthiest towns in the state. Even so, 726 renter households (47.4% of allrenter households) are housing cost burdened, meaning they spend more than 30% of householdincome on housing costs. 21 Residents in every town in the state would benefit from expandedaccess to RAP housing vouchers. (TRA)6. Dedicate town owned land to affordable housing development, thereby lowering the cost ofaffordable housing development while at the same time maintaining control over the choice ofdeveloper and directing housing development where town infrastructure and services can bestsupport it. In 2020, Guilford donated a parcel of land adjacent to its train station to nonprofithousing developer NeighborWorks New Horizons to develop affordable housing. The propertywas selected several years earlier after the town commissioned a study for possible locationsfor affordable housing in Guilford. 22 (GA, DR)7. Ask the state to identify state owned land that can be used for affordable housingdevelopment. Like with town owned land, a donation of state land removes a significant driverof housing cost from an affordable housing development. This is already happening in Westportwhere the state Department of Transportation agreed to divide a piece of its land and is workingwith the state Department of Housing to determine how much of the property it will be willingto give to the town for affordable housing development. 23 (GA, DR)8. Implement an affordable housing density bonus program. Density bonuses allow an increasein dwellings/acre and/or height in specific zoning districts when a developer includesaffordable housing units in a proposal. There are many examples of successful density bonusprograms across the country, but this is not a tool that has been adopted widely in largelysuburban Connecticut yet. Bethel allows for a density bonus in its Designed Conservation Districtand requires a 20% set aside of affordable units in its transit-oriented district. Tying rezoningnear a municipality’s transit stations for higher density with density bonuses for developmentsthat include affordable housing is another great way to expand access to transit in yourcommunity while growing the supply of affordable housing. San Diego’s program has helpedcreate many affordable homes. 24 (DR)9. Target funds to rehabilitate and deed restrict existing housing. Rehabilitating and deedrestricting older homes is a great way to improve housing quality in a town while expandingthe supply of affordable housing without new construction. Community Development BlockGrants and a local housing trust are two frequent sources of funding a rehabilitation ip for Strong Communities pschousing.org13

Fairfield’s Residential Rehabilitation Program for Rental Property Owners provides financialassistance to eligible property owners to provide improvements and repairs to rental propertiesin exchange for a commitment to keep the rental units affordable. 25 (DR, SF)10. Create an incentive housing zone (IHZ) with affordable housing set-aside requirements thatmeet Section 8-30g conditions. 26 The IHZ program is a voluntary, incentive-based land useprogram created by the General Assembly in 2007. It provides towns with incentives if theychoose to create an IHZ in a smart growth location in their community. An Incentive HousingZone is an area which has a zoning overlay that allows developers to increase housing densityin exchange for creating mixed-income housing. The program provides municipalities withcontrol over the location, amount, type, and design of the homes created.The Incentive Housing Zone program includes incentive payments made to municipalities whenthe zone is approved and again when housing is built in an IHZ. Canaan/Falls Village adoptedan incentive housing zone on 66 acres. The Falls Village Housing Trust has proposed to build16 affordable homes in the IHZ. 27 (DR)Falls Village Housing Trust's proposed River Road tnership for Strong Communities pschousing.org14

ConclusionWhat often is lost in the rhetoric and vitriol against Section 8-30g are the numerical facts of theAffordable Housing Appeals List. The affordable housing supply in most Connecticut towns is,and always has been, largely made up of housing with direct government subsidy, whether forconstruction, rental support, or reduced mortgage rates for first-time homebuyers. Deed restrictedhousing, the source of conflict among many affordable housing advocates and their manyopponents, is a small, but important, part of our affordable housing supply. Deed restrictedhousing is important to Connecticut’s affordable housing supply because it often is built inmunicipalities that would otherwise have little or no affordable housing. It is, as the saying goes,necessary but not sufficient to expand the supply of deed restricted homes so that there is agreater choice of homes in every community in Connecticut.Section 8-30g is a necessary and valuable tool for affordable housing development in townsthat consistently reject housing development, but it isn’t the only tool available to grow our supplyof affordable homes. Expanding state investments in housing can grow the supply in every townin the state without developers making use of Section 8-30g. Revising local zoning to permitmultifamily homes and homes on smaller lots can lower the cost of housing and increase thesupply of homes available to first-time homebuyers with CHFA mortgages and housing voucherholders. Finally, rehabilitating or converting the housing already in a community can expandaffordable housing without new construction.Complaints of powerlessness at the local level concerning affordable housing couldn’t be furtherfrom the truth. Instead of eliciting a litany of reasons why an affordable housing proposal won’twork for a community, the conclusion of the often-heard statement of housing opponents, “weall support affordable housing, but ” now can be “we haven’t done enough to make it happenhere. Let’s get to work.”Partnership for Strong Communities pschousing.org15

Affordable Housing is Overconcentrated Even Among Exempt Municipalities Affordable housing remains incredibly concentrated in Connecticut in a few cities with majority BIPOC (Black, Indigenous, people of color)populations . The affordable housing units located 2021. Looking back again to 2002, 77.4% of all assisted housing was in exempt .

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