Análisis del entorno

2005 Forecasted Population from 2000

Housing Need Allocations: Existing Affordable Housing

The way that the proposed methods adjust for existing affordable housing stocks is also seriously flawed. The targets are given in absolute numbers of housing units, and surpluses or shortfalls in affordable housing are also calculated in numbers of housing units.³⁸ However, under the current method, adjustments to the base share for the existing affordable housing factor are proportional, not absolute.³⁹ In other words, a community with a 20 percent oversupply of housing has its base share adjusted downwards by 20 percent. This is mathematically nonsensical, especially since the adjustment is applied to the growth share, not the community’s overall housing. There is simply no reason to expect that an area that has over- or under-provided affordable housing by a certain proportion in the past can be restored to its fair share by over- or under-providing that same proportion of new affordable housing growth. Proportional adjustments – increasing or decreasing a fair share target by a percentage – also guarantee that all places will be required to add affordable housing even if they already have much greater affordable housing shares than other parts of the region – indeed, even if their existing housing stock is already 100 percent affordable. This directly contradicts MLUPA’s description of local fair share obligations, which explicitly allows for communities to meet their obligation by

“providing sufficient existing or new housing.”⁴⁰

For instance, using the Met Council’s estimate of the percentage of current housing (inside the MUSA) affordable at 80 percent or less of regional median income (53 percent according to Council data used to support the Subgroup), Minneapolis had 15,296 more affordable units in 2010 than its “fair share” of 53 percent. Using the current methodology, however, Minneapolis’s affordable need allocation is still approximately 10,700 units from 2020 to 2030 – or 82 percent of total projected growth. What sense would it make to require Minneapolis to build more affordable housing in future years, given that the model already acknowledges that the city’s current share of affordable housing exceeds the regional average by an even larger number of units? St. Paul and many inner suburbs are in similar situations.

This flaw is particularly egregious because a fairer and more intuitive method is easily available. Instead of using a proportional approach, the Plan should use absolute figures. Surpluses (or shortages) of affordable units should simply be subtracted from (or added to) fair share targets.⁴¹

Maps 3 and 4 demonstrate the enormous practical implications of this flaw. They show how fair share obligations would be distributed around the region using a

proportional affordable housing adjustment (Map 3) versus an adjustment that adds or subtracts units (Map 4). A city’s fair share obligation was capped at 65 percent of

38 See Metropolitan Council, Allocation of Housing Needs 2010-2020.

39 Id.

40 Minn. Stat. 473.859 subd. 4 (emphasis added).

41 Low-wage jobs and workers and transit access are measured in fundamentally different units than housing counts, so it is reasonable to use proportional adjustments in those cases.

projected growth in both simulations, an adjustment suggested in materials submitted to the Needs Allocation Subgroup.

Both of the calculations underlying the maps make proportional adjustments for low-wage workers and jobs and transit access like those used in the past (and outlined in materials distributed by Met Council staff to the Subgroup).⁴² Map 3 shows each city’s fair share as a percentage of projected growth, if fair shares were increased or decreased by the percentage that the place’s current affordable housing rate differs from the regional average. For instance, in this case the number of additional affordable units required of Minneapolis would be reduced by 9.2 percent because its current affordable housing share is estimated to be 62.2 percent and the regional average is 53 percent.

Map 4 shows each city’s fair share as a percentage of projected growth, if current shortages or surpluses are added or subtracted to need allocations in absolute numbers, after adjusting for low wage jobs/workers and transit.

The differences between the two methods are dramatic. Fair share obligations are concentrated in the central cities, inner suburbs and a few middle suburbs west of

Minneapolis using the proportional adjustment (Map 3). Using this method, Minneapolis and almost all inner suburbs would be at the maximum percentage fair share (65 percent of projected growth in housing units) while most middle and outer suburbs would have much lower obligations. In this scenario, Minneapolis would be expected to add 8,515 new affordable units during the decade out of total growth of 13,100 units – the 65 percent maximum. Many inner ring suburbs that already have greater than average affordable housing shares – such as Richfield, Hopkins, and West St. Paul – are also at the cap. At the same time, many relatively affluent middle and outer suburbs get relatively low fair shares – like Apple Valley where the fair share would be only 26 percent of projected growth (whether capped or not).

Map 4 shows the results of the alternative affordable housing adjustment. A band of areas along the I-94 corridor with large current surpluses of affordable housing, from Oakdale to Anoka, show much lower obligations, while higher-income middle and outer suburbs with little affordable housing show larger fair share targets.

Overall, the fair share targets in Map 4 correlate much more strongly (negatively) with current affordable housing distributions.⁴³ In other words, the proportional method used in the first simulation (Map 3) would further concentrate poverty in the central cities and some inner suburbs while the additive method (Map 4) would help to spread low-income households more evenly across the region.

42 Each method produces a regional total of fair share obligations reasonably close to the estimated need of 54,600. The proportional adjustment runs produces regional totals of about 65,500 units (uncapped) and 57,000 units while the additive adjustment models give totals of about 62,000 and 45,100. The formulas could be easily fine-tuned to produce the exact amount needed.

43 The correlation between the fair share percentages in Map 3 and current affordable housing percentages is -.34 while it is -.84 for the percentages in Map 4.

The Map 4 distributions would also be much more likely to direct new affordable housing to areas near higher-performing schools. The percentages in Map 4 are strongly positively correlated with local school performance while those in Map 3 are weakly negatively correlated.⁴⁴

44 The correlation coefficients are +.55 for the Map 4 percentages and -.01 for the Map 3 percentages. Local school performance scores were drawn from the data in Metropolitan Council, Choice, Place and

Opportunity: An Equity Assessment of the Twin Cities Region (2014).

May

LE SUEUR RICE GOODHUE

AIRPORT

-Map 3: Fair Share Affordable Housing Targets as a