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Home My WebLink About10/10/2018 Item 2, Hopkins-Tucker Goodwin, Heather From:Davidson, Doug Sent:Tuesday, October 2, 2018 4:48 PM To:Christian, Kevin; Goodwin, Heather; Purrington, Teresa; Sheffield, Alexis Subject:FW: Affordable Housing Parking Requirements Attachments:10-02-18 Zoning Regulation Update_Affordable Housing Parking Requirements.pdf th Please forward as agenda correspondence for the Planning Commission on October 10. Thanks From: Michael Hopkins-Tucker \[ ] Sent: Tuesday, October 02, 2018 1:15 PM To: Davidson, Doug <ddavidson@slocity.org> Cc: John Fowler <johnf@pshhc.org>; Scott Smith (ssmith@haslo.org) <ssmith@haslo.org>; Bell, Kyle <KBell@slocity.org> Subject: Affordable Housing Parking Requirements Hello David, I hope this email finds you well. I am reaching out to you on behalf of PSHH and HASLO to communicate our concerns about the changes to the affordable housing parking requirements. If you have any questions or concerns regarding the attached letter, please let me know and I would be happy to answer them for you. Best, Michael Hopkins-Tucker Policy Analyst 3533 Empleo St San Luis Obispo, CA 93401 Office (805) 548-2341 1 October 1, 2018 Doug Davidson, AICP Deputy Director Community Development City of San Luis Obispo 919 Palm Street San Luis Obispo, CA 93401 RE: Final Adoption of the City of San Luis Obispo's Revised Zoning Regulations Dear Doug: We are writing because we believe that the unintended consequences of proposed parking requirement changes may reduce the number of affordable units built in San Luis Obispo, while simultaneously increasing the greenhouse gas emissions (GHGs) and the harmful effects of climate change. The Housing Authority of the City of San Luis Obispo and Peoples' Self -Help Housing are the City's only community- based nonprofit developers of truly affordable deed -restricted housing. As such, we feel that it is important to not only advocate for our own residents, but also for policy decisions that affect all low-income households in San Luis Obispo. We are particularly concerned about the elimination of Section K of the City's Parking Section 17.16.060, which outlines the parking restrictions for low-income units. Without this section, which requires a 1:1 unit to space ratio, affordable housing developers must defer to City and State requirements for multi -family projects that require more parking spaces overall. While such requirements might be sensible for a market -rate apartment complex, this change contradicts compelling academic research and industry standards, which indicate that residents of low-income housing use less vehicles per household on average. In other jurisdictions around the country, cities and counties are reducing or even eliminating parking for deed -restricted units; this change would move our city backwards from best policy practices (UC Berkeley Terner Center for Housing Innovation). The example outlined in RRM's letter dated September 21, 2018 for a 30 -unit building with a mix of one and two- bedroom units clearly articulates our concerns about this policy change: Current Requirement Calculation 30 units x 1.0 spaces per unit = 30 required spaces Proposed Requirement Calculation (15 one -bedroom units x 1.0 spaces per unit) + (15 two-bedroom units x 2.0 spaces per unit) = 45 required spaces Such a dramatic increase in parking — 50% more than the previous requirements — would be enough to make us reconsider the scope, scale, and feasibility of a given project. The developer's options would be as follows: 1) Reduce bedrooms per unit. This option is difficult for both logistical and mission -oriented reasons. First, to receive federal 9% tax credits, the most robust resource for affordable housing finance, we must set aside 25% of all apartments as three-bedroom units. Increasing a developer's parking requirements to two spaces per three-bedroom unit could make it very difficult to pursue 9% tax credits, which might make an entire project infeasible. Additionally, one of the most profound impacts of our mission -driven work is the time -tested ability of affordable housing to transform the lives of children and young adults. This parking burden may incentivize the creation of more studio and one -bedroom units, which would be a de facto selection against families, and therefore, our ability to provide this live -changing service. Zoning Regulations Update October 1, 2018 Page 2 of 2 2) Increase height. To accommodate for the higher parking standards while retaining the same number of units, we may be forced to build higher. This would unnecessarily expose the project, staff, and the Council to greater scrutiny from community interests that oppose taller buildings. 3) Eliminate units. Although this would be a last resort, if a project's feasibility was put into question due to these parking requirements, we may be forced to reduce project scope for the sake of saving an entire project. This reduces our capacity to serve more people and would not only undermine our own organizational mission, but also a desperate community need for more affordable housing. If a project could remain feasible throughout predevelopment despite these parking requirements, the spaces built as the result of the new requirement would either: 1) undermine the City's Climate Action Plan; or, 2) become underutilized — neither of which is a desirable outcome. 1) Undermine the City's Climate Action Plan goals. More parking spaces may encourage more vehicle usage, and therefore the production of more GHGs. On the contrary, reducing parking requirements is one of the first major steps to causing substantive behavioral shifts that support alternative transportation. On a related note, the proposed parking requirements may cut off the City's ability to access millions of dollars of funding through the cap -and -trade program, Affordable Housing and Sustainable Communities (AHSC). This program provides robust funding for affordable housing and sustainable transportation infrastructure with the overall goal of reducing vehicle miles traveled and GHGs. One of the easiest ways for a project to become competitive for this program is to demonstrate 1:1 housing unit to parking ratio. The city's previous parking requirement gave projects located in San Luis Obispo a greater chance of gaining access to these funds. However, if the proposed parking standards were to go into effect, it would make it very difficult for city -based projects to compete. 2) Alternatively, these spaces could become underutilized. As previously mentioned, on average, residents of affordable housing own less vehicles per household and are more likely to utilize public transportation. The Assembly Committee on Housing and Community Development issued an analysis citing that market rate parking requirements "may not reflect the demand from tenants [of affordable housing] for parking." Both federal and state funding resources for affordable housing often encourage transit -oriented development by giving a competitive advantage to projects located within X mile of major transit infrastructure, which ensure that low-income residents have easy access to environmentally friendly public transportation. We hope that you will consider bringing back Section K to allow qualified low-income housing properties a 1:1 unit to parking space ratio. Thank you for your consideration of these comments and we look forward to working with you regarding affordable housing issues in the future. Sincerely, 6 Scott Sm .Executive Director, HASLO y4 4 wlerCPA President & CEO, PSHH cc: Kyle Bell / WilLO t,4v1'�N6 AVfxONT. SA111�•�5 G&3:h'� Nousiv Qm Comm WW ��• Peoples' Self -Help Housing