How should housing funds from impact fee be targeted?

Housing Alliance provided the below comments to PHFA concerning their draft plan for how Marcellus Shale Impact Fee funds for housing will be targeted:

The Plan sets out to accomplish two goals: first, to make operational the PHARE Fund, also known as the Housing Trust Fund, and second, to address the housing needs in the Marcellus Shale region. Accordingly, our comments are divided into two sections: those addressing the workings of the Housing Trust Fund and those related to funding for the Marcellus Shale region.

PHARE/Housing Trust Fund Operations
While PHARE was established in late 2010, the funds to be received under the Impact Fee law (“Act 13”) will be the first moneys going into the Fund. As we move forward to utilize the Act 13 money, it is important to establish a process for administering the Fund which will accomplish not only the goals of Act 13, but also those of the Housing Trust Fund legislation, Act 105 of 2010. It is in the best interest of the Shale region and of the Fund to ensure the effective and efficient use of the funds, and to provide accountability to the General Assembly, the governor, and the public.

One of the requirements of Act 105 is an annual plan which includes a housing needs analysis. From the annual plan are set priorities for the coming year. In addition to the public comment called for in Act 105, we propose an advisory board. Initially, because the Act 13 funds are limited in their use to the Shale region, the advisory board should be made up of housing and human services professionals from the counties specified in Act 13. When other funds are directed into the Fund for other parts of the state, the advisory board should be expanded.

We also suggest that the planning process be as open and transparent as possible, so that public comment is not limited to a 30 day period after a draft plan is produced, but rather is encourage throughout the drafting process.

Act 105 also requires an annual report on the Fund. We suggest an evaluation process that collects data on the impact of the funds spent.
Regarding the application process, we suggest receipt of applications on an ongoing basis, rather than at selected times of the year. This will allow applicants to apply for funding as needs arise and as they are able to coordinate various funding sources. Particularly with regard to Act 13 funding, we propose prioritizing local applicants.

Act 13 Priorities
In many ways, the housing needs in the Marcellus Shale region are different from those we have faced before. Our first recommendation is to think creatively. While the development of new housing is part of the solution to the tight housing market, it is not the only solution. Programs such as rental assistance, rental rehab, and the rehab and adaptive reuse of existing structures should also be considered.

To address the needs in the Shale region we propose that PHFA:
1. Suggest a broad range of possible uses of the funds, but not limit applicants. Encourage creativity.

2. Encourage regional approaches and municipal cooperation. Housing markets are regional; not every borough or township needs a new housing development. Strategically placed projects can serve a large population while preserving the rural nature of the region.

3. Prioritize the use of existing structures and infrastructure. Funds can be used to address housing affordability and blight at the same time. Rehabbing vacant structures can create more homes and revitalize small towns. Creating a rental rehab program would provide an incentive to property owners to fix up their units in exchange for a commitment to rent to low or moderate-income families and individuals.

4. Encourage rental assistance programs, especially on a county-wide or multi-county level. PHFA could administer such a program across jurisdictional boundaries. Rental assistance supports private landlords and is much less expensive per family served than either new construction or substantial rehab.

5. Ensure that the homes created serve local families and individuals rather than workers coming into the area for Shale jobs.

6. Ensure an ample number of accessible homes. In an area of mostly older homes, accessibility is already an issue. With a dwindling supply of affordable homes, people with mobility impairments have an even harder time finding accessible homes.

7. Promote long term solutions. Discourage large developments of new homes which may become ghost towns after the Shale workers move on. At the same time, encourage permanent housing rather than temporary shelters. Emergency shelters may be a necessary response to the current crisis, but they are not long term solutions for people who were and can be self-sufficient as long as they have homes they can afford.