DEPARTMENT HEAD: Verónica R. Soto, FAICP, Neighborhood and Housing Services Department Director
COUNCIL DISTRICTS IMPACTED: Citywide
SUMMARY: Briefing on the City’s Strategic Housing Implementation Plan progress including the draft recalibrated affordable housing goals, definition of affordability, and implementation strategies to include a Source of Income Discrimination Ordinance.
BACKGROUND INFORMATION:
San Antonio’s Housing Policy Framework is the city’s affordable housing policy document that was accepted by the City Council in 2018; the Framework is the final document produced by the Mayor’s Housing Policy Task Force (MHPTF). The Framework contained overarching policy areas with a list of potential strategies to address those areas and 10-year target goals. What was not included in the framework was a roadmap of which policies and programs should be prioritized and which organizations should play a role in their implementation. The creation of a roadmap of implementation strategies tied to overarching goals is the best next step in the process of implementing the framework plan and supports the Housing Policy Framework recommendation that an implementation plan, coupled with funding, will lead to successful housing policy. Because of this, staff has started the development of the Strategic Housing Implementation Plan (SHIP).
The foundation for the SHIP is the Housing Policy Framework and will serve to guide any future framework plan implementation. In addition, staff also underwent a process to recalibrate the 10-year affordable housing targets within the Framework as they were being exceeded in most areas in only a few years, building on the Framework’s recommendation that housing policy be data-driven. The SHIP will be developed in collaboration with community and housing stakeholders including but not limited to the San Antonio Housing Trust (SAHT), San Antonio Housing Authority (SAHA), South Alamo Regional Alliance for the Homeless (SARAH), Local Initiatives Support Corporation (LISC), VIA, Bexar County and applicable COSA departments. This collaboration also builds on another value of the MHPTF to promote public participation and value and balance both community members and technical expertise. In addition, the SHIP will include an outreach and input process to receive community input that will be overseen by the Housing Commission. Staff has created four stakeholders forums to provide feedback on the SHIP progress. The stakeholder forums include:
• Residents and Community Advocates
• Real Estate & Developers
• Affordable Housing Developers
• Housing Policy
Recommendations from the Housing Commission will go to the Planning and Land Development Committee before being recommended for consideration to city council, San Antonio Housing Trust board, and San Antonio Housing Authority board for review and adoption.
ISSUE:
The SHIP will be completed in two Phases, 1) Synthesis and Strategy and; 2) Management and Operations and is projected to be presented to City Council in FY 2021. Phase 1 was started in October and included the recalibration of the production goals included in the Framework Plan based on 2 years worth of housing data since the Framework was adopted. Economic and Planning Systems, the consulting firm that assisted in the creation of the Framework Report, is overseeing the recalibration. The second phase will identify the strategies required to reach those targets, including identifying lead organizations and timelines. In order to accomplish the housing goals and track their success, the roles of several organizations, including the City, SAHT, and SAHA must be identified.
The Planning and Land Development Committee will receive regular updates to provide feedback on the progress of the SHIP before formally recommending the plan for Council consideration. The Boards of the San Antonio Housing Trust and San Antonio Housing Authority will also receive updates and opportunities for feedback before adoption.
The original goals included in the Housing Policy Framework are on track to be exceeded much earlier than the projected 10-year timeframe. Because of this, staff has worked with Economic & Planning Systems to evaluate the need for housing in San Antonio by those most vulnerable to displacement and work to determine new housing targets for owner occupied and rental housing including rehabilitation and new construction. In addition, indexes are being created to identify key vulnerability factors by census tract and SA Tomorrow regional centers.
Critical to the SHIP is defining affordable housing. The current framework definition includes incomes up to 80% of the Area Median Income (AMI) for rental housing and 120% AMI for home ownership. Concerns have been raised by Council and the public over the Housing and Urban Development (HUD) AMI levels currently used as an industry standard. Because of the larger area the HUD AMI calculation includes beyond the City Limits of San Antonio, the concern is that using the HUD definition of affordability (80% or below of AMI) does not address the needs in San Antonio as the AMI levels within the City Limits are lower than for the metro area. Staff has recommended adjusting the level down to more closely align with the City of San Antonio population, using data from the Census while still utilizing HUD information on AMI as a yardstick. This adjustment has resulted in affordable housing income levels being adjusted to 60% AMI for rental housing and 100% AMI for homeownership. This topic is still being reviewed by the Housing Commission who are also considering the impact other household expenses, including utilities and transportation, have on housing needs.
As a starting point for implementation strategies, staff is working with our stakeholder forums to build off other housing related initiatives that have taken place over that last few years, mainly those identified those in the framework. Other documents that are being referenced include the SA Tomorrow Comprehensive Plan, ForEveryoneHome initiative, COVID-19 Community Action Working Groups, and Opportunity at Risk Report, among others. In addition to these reports and their strategies, there have been other issues raised through community groups, council offices, and city departments that have led to the consideration additional policy issues for consideration.
One of the draft implementation strategies for consideration is the creation of a Source of Income Discrimination Ordinance. Currently, property managers can use an applicant’s source of income as a reason to deny housing, specifically those receiving federal assistance to make rent payments in the form of Federal housing vouchers. While there are legal restrictions surrounding the creation of such an Ordinance in Texas, other cities including Dallas have been able to tie those protections to developments receiving incentives or funding from the City. The City does currently include language with those protections for most funding including CDBG, HOME, and the City’s affordable housing fund.
A possible city Ordinance would require that developments receiving any city funding or incentives not deny any applicant the ability to rent based solely on their income source, including federal vouchers. This Ordinance would have no impact on the unit qualifying for the federal program and would not require developments to accept vouchers if they are not eligible for other reasons. Staff would work with the City Attorneys Office to ensure any ordinance is legal and enforceable.
Staff will be returning to the SHIP taskforce group before reconvening the stakeholders forums during November and December. Staff will then return to Housing Commission and the Planning and Land Development in January to provide additional updates on the progress made.
ALTERNATIVES:
This item is for briefing only.
FISCAL IMPACT:
There is no fiscal impact at this time.
RECOMMENDATION:
This item is for briefing only.