April 19, 2022
Mr. Rudolph Marconi, Chairman
Western Connecticut Council of Governments
1 Riverside Road
Sandy Hook, CT 06482

Dear Mr. Marconi:

I am writing in response to Western Connecticut Council of Governments’ (WestCOG) request for public comments regarding the March 17, 2022 draft of the Western Connecticut Regional Affordable Housing Plan. Thank you for this opportunity to provide input on the draft plan.

Regional Plan Association is an independent non-profit research, planning and advocacy organization that develops and promotes ideas to improve economic health, environmental resiliency and quality of life in the New York-New Jersey-Connecticut region. Over the course of our 100- year history working together with partners in Connecticut we have developed four, once in a generation, long-range plans, each addressing the major issues of its time. Our Fourth Regional Plan, published in 2017, identified housing affordability as one of the central challenges facing our region today, and it is an issue that we are passionately committed to addressing in Connecticut and across the tri-state region.

RPA strongly supports WestCOG’s decision to create a regional affordable housing plan and to provide regional context and guidance to municipalities to create meaningful action steps that will create the housing necessary to address the affordable housing crisis in the WestCOG region. Unfortunately, the draft regional affordable housing plan as written is a missed opportunity to truly serve as an impactful, regional guide. This current draft instead serves to support the status quo, and misses a very real and important opportunity to lead on promoting meaningful, actionable steps that member towns can and must take in order to create the homes necessary to address the affordable housing crisis in the WestCOG region.

In December 2020, in partnership with RPA, the CT Department of Housing published Planning for Affordability in Connecticut, which is intended to serve as a best practices guide to assist towns in the preparation of their affordable housing plans, as required by Section 8 – 30j. The guidebook is a step-by-step ​“how to” that details both the process for developing meaningful, impactful plans and the elements that should be included in the affordable housing plan document, including-

• Community values statement

• History of affordable housing in your town

• Housing needs assessment

• Land use and zoning assessment

• Housing market considerations

• Plan principles, goals and actions

As you know, building support for affordable housing in local communities is challenging. As we’ve heard throughout this legislative session in heated debates on the state’s role with respect to zoning reform, there is a strong desire in Fairfield County for towns to tackle this challenge independently at the local level. Therefore, taking the opportunity to build support through the plan development process is crucial, as detailed in Section 3 of the guidebook: Building Support for an Affordable Housing Plan. If this is not done in a meaningful way, then we cannot expect to see any tangible progress towards actually creating the homes that we need to address the glaring affordable housing needs facing WestCOG towns.

It is clear from the current draft WestCOG regional affordable housing plan that meaningful community engagement at the local level was not part of the planning process that led to the creation of this draft plan. And therefore, it is not surprising that the recommendations of the draft plan say very little with respect to tangible, actionable steps that must be taken to actually create more affordable homes in WestCOG towns. The plan’s recommendations call for ​‘investigating,’ ​‘evaluating’ and ​‘considering,’ in lieu of acting. There is no shortage of recent studies identifying and quantifying the need for more affordable homes in towns in the WestCOG region, including Housing Connecticut’s Future published by the Urban Institute in partnership with CT Department of Housing and Fairfield County’s Center for Housing Opportunity and the Fairfield County Housing Needs Assessment published by RPA, both in 2021.

If WestCOG is serious about taking meaningful action at the local level to address the affordable housing that we so clearly need, then this plan must demonstrate that commitment and recognize that the obstacle to creating the homes is strong local opposition, not a lack of understanding of the underlying problem. As the regional entity that has taken on the responsibility of guiding its towns through the affordable housing plan process, it is incumbent upon WestCOG to create a process that encourages and assists towns in moving from consideration to action. WestCOG must create a regional affordable housing plan that calls on municipalities to take concrete steps at the local level that will actually result in the creation of more affordable homes with meaningful reforms to zoning and identification of specific sites for affordable housing development. But the draft plan does not do that.

Instead, in a glaring and appalling recommendation, it suggests ​“to allow municipalities with an affordable housing shortfall to pay a neighboring municipality with an affordable housing surplus for the right to apply designated housing units to their Section 8 – 30g quota” (pg. 89). This demonstrates a fundamental misunderstanding of state housing law and calls into question WestCOG’s ability and commitment to advancing affordability in the region. The idea that towns without sufficient affordable housing should be able to buy their way out of creating the affordable homes that are needed in every community is wildly inappropriate and is a policy that endorses, perpetuates, and exacerbates the glaring residential segregation in the WestCOG region.

This is exactly the opposite of what the plan should do. Instead, it ought to recognize that every town in the WestCOG region relies on people of all incomes to thrive — including home healthcare workers, landscapers, teachers, police, firefighters, grocery store workers and many others lower income community members — and that every town must provide homes that meet their housing needs. The goal should be to create more affordable homes in all towns that provide opportunities for a more diverse population, rather than reinforcing the status quo of residential segregation.

Further, The draft plan incorrectly defines the ten percent affordable housing level that exempts municipalities from Section 8 – 30g as a quota to be met at the municipal level. Meeting the housing needs of the region should be a priority independent of achieving a moratorium or exemption from Section 8 – 30g, and should be based on an affordable housing needs assessment, which has already been completed by both CT Department of Housing and Regional Plan Association in 2021, as noted above. In other words, regional affordable housing goals and policies should be developed around the goal of meeting the need for more affordable homes, and not around begrudgingly achieving a moratorium on new development. The draft plan characterizes the affordable housing units in Danbury, Norwalk and Stamford that exceed the ten percent affordable housing threshold set for Section 8 – 30g exemption as ​“surplus” for the region. It is difficult to understand how the plan can consider affordable housing in a few cities as ​“surplus” in a region where there is overwhelming housing cost burdens and where the price of housing in suburban towns categorically excludes lower income residents.

More affordable homes in all communities that meet the needs of people of all incomes and ages is critical to the sustainability and prosperity of the WestCOG region. We very much hope that you will incorporate our feedback as your work to edit and finalize the WestCOG regional housing plan and, as always, are happy to participate and contribute as you work together with your towns on this challenging issue. Thank you for the opportunity to submit these comments.