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Solimar Research

Proposed Final AHSC Guidelines Would Broaden Possible TOD Funding Sites

Martha Bridegam on
Jan 12, 2015

A late-added change in proposed final guidelines for California's new cap-and-trade grant program might broaden transit-oriented development sites.

The Strategic Growth Council (SGC), which heads the interagency project to design and run the Affordable Housing and Sustainable Communities (AHSC) program, posted the proposed texts January 9 in the form of attachments to its January 20 agenda. On January 20 the council will be invited to adopt guidelines for both the main AHSC program and its $5 million offshoot, the Sustainable Agricultural Lands Conservation Program (SALC).

New as of January in the draft guidelines was a definition of "Qualifying High Quality Transit" that would allow transit-oriented development projects to be located one mile away from a transit stop as opposed to the half-mile previous proposed. An "affordable housing development" (possibly funded by other means) would still need to be within half a mile of the transit stop. The half-mile definition is common in state law.

The new definition looks to a looks requirement for peak-hour headways of 15 minutes or less and seven-day-per-week service, but otherwise requires relatively flexible "dedicated right-of-way" or Bus Rapid Transit (BRT) characteristics. The prior September 2014 draft had emphasized specific transit modes: rail, BRT or "express bus".

These criteria will help determine eligible projects in the transit-oriented development (TOD) grant category, which is to receive at least 40%, and as much as 70%, of total AHSC grant funds.

The change might be a concession to housing and equity advocates, who argued that the program as originally conceived would favor transit-oriented development (TOD) in areas that were already well served by major transit systems, to the disadvantage not only of less dense areas but also of less transit-favored (likely poorer) parts of large cities.

Also new are promises of technical assistance, both immediately for 2014-15 applicants and in a less defined longer-term effort. Technical assistance had been an issue in workshops and comment letters; advocates had argued that without it, success would beget success for well-budgeted big-city nonprofits, edging others out.

The new draft reweights the competitive criteria to give greenhouse gas (GHG) "emissions reductions per... dollar requested" the greatest significance, contributing 55% of the total score. Otherwise "project readiness and feasibility" would contribute 15% of the total and all other criteria, grouped under "policy considerations," would contribute 30%.

The prior full version of proposed guidelines, as circulated in September, would have weighted scores 35-40% for "feasibility and readiness", 40-45% for "connectivity and improved access" and 15-20% for "community orientation".

The SALC program grant applications would be scored primarily based on need (40%), "integration of entities and existing resources" (25%) and "community involvement and participation (20%). Lesser scores would go to organizational capacity (10%) and "disadvantaged community impacts" (5%).

The AHSC program was allocated $130 million for the 2014-15 fiscal year (for the main program and SALC together). It has been promised 20% of the cap-and-trade proceeds placed into the Greenhouse Gas Reduction Fund in each future year. Governor Jerry Brown's new budget proposal, also released January 9, assumes the AHSC program will have $200 million for the following 2015-16 fiscal year.

The posted materials include 82 pages of public comment letters on the SALC guidelines and a five-page table of contents for the much larger volume of AHSC comments, which were not posted as of this writing. Comments from organizations in the agricultural easement field included recommendations to connect the AHSC and SALC programs more closely together and objections that the proposed 50% matching requirement on easement acquisition grants would be too high for some organizations. The proposed final guidelines provide for consideration of "compelling applications which include a lesser match".

A number of changes that SGC first circulated for informal review in December appear in the January 9 proposed final version. Notably, the new draft removes minimum criteria for project size and reduces minimum unit densities to a range of 15 to 30 units per acre, as proposed in December. It drops a requirement for a public agency to be a co-applicant unless the agency has a direct "interest or stake" in the project; allows award size limits by place or developer to be lifted "if needed to meet statutory affordable housing or disadvantaged community set-asides," and allows up to 30% or $500,000 of an award to be spent on "program uses". On the other hand, planning costs are limited to 15% of the requested amount or $250,000.

As proposed in December, "Anti-Displacement Strategies" would be part of all scoring criteria. However, scoring in that area would affect only one point out of 100. That one point would be part of the 30% of scoring given to "policy considerations." Others would include 6.5% for service to lower and moderate-income households and 3% for promotion of bicycling.

The new draft makes a rule more prominent that also appeared in the September proposal: making projects with "Qualifying High Quality Transit" eligible only for TOD grants and ineligible for ICP grants. The distribution of grants between the two categories retains the originally proposed leeway: 40% must go to TOD projects and 30% to ICP projects; the rest can go to either.

An "affordable housing development" is still defined as one with 20% of the units "affordable".

As initially proposed in December, the guidelines call for quantification of GHG reductions using the California Emissions Estimator Module (CalEEMod) for most projects and the Congestion Mitigation and Air Quality Improvement (CMAQ) guidelines projects serving a large area or otherwise falling outside the expectations of the CalEEMod approach.

As also proposed in December, metropolitan planning organizations (MPOs) would have rights to review proposals and make recommendations, but in a role firmly defined as advisory.

Having more time to public review than was originally calendared, the AHSC and SALC programs are now jammed against the part of their timetable that calls for the SGC to review and select grant applications by the end of the 2014-15 fiscal year in June.

The SALC timetable would circulate the solicitation for grant applications on the very next day after the scheduled January 20 approval meeting, and the AHSC program the following week.

The January 20 meeting will be available by webcast with free registration.