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patrick.russell

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 #1 

§11.9(c)(4), Opportunity Index

Guiding principle:

To identify neighborhoods with beneficial amenities and conditions that help residents to meet their daily needs and achieve their long-term goals.

Key questions for the 2019 QAP:

  1. Should any menu items be removed from the list of menu items?

  2. Should any menu items that speak to High Opportunity be added?

  3. Should any menu items be modified?

  4. How might the high opportunity scoring item be made more competitive (i.e., make the “max score” a score that not everyone can achieve)?

  5. The menu items for property crime rate and percentage of adults with an associate’s degree or higher are intended to align with conditions typically found in  a potentially safe and upwardly mobile neighborhood. Could there be other menu items that might align with those conditions found where certain neighborhoods are on the cusp of becoming considered a high opportunity area?

  6. What is the best way to differentiate between income Q1, Q2, and Q3 census tracts?

     

    Possible Modifications:

     

    As an entry point into generating feedback, staff proposes two possible modifications to the Opportunity Index. Both revisions maintain the intent and structure of the opportunity index.

     

    Option 1:

     

  • Collapse subparagraph (A) regarding income quartile and poverty rate into a single threshold item that an Application must pass before pursuing menu item points. This process is similar to meeting basic qualifications under §11.9(d)(7), Concerted Revitalization Plan, before pursing point-eligible items.  Staff anticipates that the current criteria for qualifying Q3 census tracts would continue.

  • Weight eligible menu items based on the Development’s proximity to that item. The closer the Development, the more the points. The farther away, the fewer the points.

  • Offer a small “bonus” for any eligible menu item whose distance is measured on an accessible route of a reasonable length, as opposed to being drawn “as the crow flies.”   What should be the maximum length of such a route, and how should it be documented?   

     

Urban Opportunity Index Scoring Matrix

 

Proximity

Accessible Route*

 

0.50 miles

1.0 miles

2.0 miles

 

Opportunity Item

    

Public Park w/ Playground

1.5

1

0.5

+ 0.5 points

Public Transit

1.5

1

0.5

+ 0.5 points

Grocery Store

1.5

1

0.5

+ 0.5 points

Pharmacy

1.5

1

0.5

+ 0.5 points

Health-related Facility

1.5

1

0.5

+ 0.5 points

Child Care Facility

1.5

1

0.5

+ 0.5 points

Public Library

1.5

1

0.5

+ 0.5 points

Postsecondary Institution

1.5

1

0.5

+ 0.5 points

Indoor Rec

1.5

1

0.5

+ 0.5 points

Outdoor Rec

1.5

1

0.5

+ 0.5 points

Civic Organization

1.5

1

0.5

+ 0.5 points

Meals on Wheels

n/a

n/a

n/a

n/a

Property Crime Rate

n/a

n/a

n/a

n/a

Associate's degree >= Rate

n/a

n/a

n/a

n/a

     

*By "Accessible Route" for Opportunity Index menu items, TDHCA means a route with sidewalks for pedestrians, the entirety of which consists of smooth hard surfaces, curb ramps, and marked pedestrian crossings when traversing a street. To qualify for these bonus points, the route itself--from property to property--cannot exceed the applicable distance requirement.

 

 

Option 2:

 

  • Continue to differentiate among income quartiles 1, 2, and 3, but in addition to treating them as “thresholds” for the Opportunity Index, treat them as multipliers for the menu items.

  • Developments in a Q1 census tract get a multiplier of 1; Q2 qualifies for a multiplier of 0.75; and Q3 qualifies for a multiplier of 0.50.

  • Like Option 1 above, an Application must qualify for the Opportunity Index “threshold” in order to pursue points, which are only available through the menu items.

     

Urban Opportunity Index Scoring Matrix

 

Income Quartile Multipliers

 

Q1

Q2

Q3

Opportunity Item

   

Public Park w/ Playground (1pt)

1

0.75

0.50

Public Transit (1pt)

1

0.75

0.50

Grocery Store (1pt)

1

0.75

0.50

Pharmacy (1pt)

1

0.75

0.50

Health-related Facility (1pt)

1

0.75

0.50

Child Care Facility (1pt)

1

0.75

0.50

Public Library (1pt)

1

0.75

0.50

Postsecondary Institution (1pt)

1

0.75

0.50

Indoor Rec (1pt)

1

0.75

0.50

Outdoor Rec (1pt)

1

0.75

0.50

Civic Organization (1pt)

1

0.75

0.50

Meals on Wheels (1pt)

1

0.75

0.50

Property Crime Rate (1pt)

1

0.75

0.50

Associate's degree >= Rate (1pt)

1

0.75

0.50

 

 

Staff Comments:

 

  • These preliminary proposals are ideas for soliciting feedback and are not set-in-stone changes. Please propose other ideas or modifications. Be as specific as possible, even offering rule language to be considered.

  • Few Applications qualified for Opportunity Index through income quartile 3 census tracts that border Q1 and Q2 tracts. The breakdown for all submitted 2017 Full Applications was as follows:

Tract Income Quartiles for HOA Applications, 2017

 

Q1

Q2

Q3

Q4

Urban

48%

49%

3%

0

Rural

56%

33%

11%

0

 

  • Once Full Applications are submitted for the 2018 competitive round, staff will perform the same analysis to see how many Applications qualify through income quartile 3 census tracts that border Q1 and Q2 tracts. Staff is also currently calculating how many census tracts are Q3 but border a Q1 or Q2 census tract (while remaining below poverty rate benchmarks) in the entire state of Texas. Staff will post this analysis to this forum.

  • Parts of both option 1 and option 2 above could feasibly be combined with each other.

RRHA

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Posts: 1
 #2 
The Rural Rental Housing Association of Texas, Inc. (“RRHA”) represents more than 700 rural properties consisting of over 24,000 units that house more than 34,500 residents, and has considered the staff proposed “options” to change the opportunity index in the 2019 Qualified Allocation Plan (“QAP”).  A significant focus of Chapter 2306, Texas Government Code, is the preservation of existing affordable multifamily housing. None of the proposed options will enhance the ability of the Agency, or applicants, to preserve affordable housing.  It is our understanding that if an option is chosen, it (or something similar) will also be applied to Rural Applicants.  The RRHA respectfully requests that no revisions be made to the opportunity index for rural. If any revisions are made to rural, then the revision should be consistent with the goal of enhancing the preservation of affordable rural housing and only if the revision provides a measurable (not speculative) improvements to rural life.   
 
Rural Communities do not have scheduled bus service, taxicabs, passenger light rail, or other sources of public transportation.  A rural town center is typically a square (if the county seat, a Courthouse), a block of store fronts, with chain stores, parks, schools and/or emergency care facilities away from the established center of town. While there may be a marginal benefit in narrow distinctions in the urban context based on distance to facilities, similar arbitrary distinctions are not advisable, practical or needed for rural areas.  Particularly, the issue of relative time and distance has little, if any, bearing on rural residents' quality of life.  As one mile may take quite some time to travel in any particular urban area, one mile is consistently the same amount of time to travel in rural areas—approximately two minutes.  A small distance between competing towns’ facilities is nothing more than an arbitrary difference between competitors with no real value-added for rural residents.  Practically speaking, a half mile in a Rural area might cause one more minute to travel in a vehicle, while a half-mile in urban areas can easily take 5 minutes or more.  Over four miles in a rural area could be traveled in the same amount of time.  Revisions to the existing QAP are an unnecessary scoring complication that does not enhance the mission of preserving affordable housing.   
 
A significant revision to the opportunity index shortly before the opening of the application period will negatively impact applicants, rural residents and their rural communities.  Preserving affordable housing is difficult and TDHCA should not create obstacles to preservation without significant public policy considerations mandated by statute. There have been frequent revisions to the opportunity index over the years – it is now time to leave the index alone for at least a couple of cycles and then determine whether it is necessary for a revision. Rural applicants, particularly in the At-Risk Set-Aside, need consistency and predictability with which to preserve existing properties.  The current opportunity index now represents a fair competitive scoring range for preserving USDA financed housing.  The current rural index is inherently fair, reflecting realities in travel distances of rural community life. 
 
In sum, the presence of opportunity items within the current distances provided in rural areas is a well-tested, thoroughly vetted system through years of rural practice. Shorter distance to facilities is not an indicator of the property’s viability or value for residents in rural communities, and the proposed options for weighting the score is unnecessary. During the initial QAP Planning meeting, the attendees’ general consensus was that there is no desire or need to revise the opportunity index again. In conclusion, we request that none of the options be adopted for the 2019 QAP.
SallieB

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Posts: 8
 #3 
Responses to key questions.

1. Yes, there are too many ways to get full HO points as evidenced by the number of tied applications on the pre-app log. Will the max number of HO points be raised with the proposed 1.5/1/.5 system? Civic organizations should go. They are not valued by survey respondents. Others too if the HO point max is not raised.
2. No, please don't add any HO menu items.
3. Yes, a grocery with a pharmacy should be valued higher than just a pharmacy. Additionally, I love sidewalks, but 2017 was a mess with them. Allowing a half point on 11 items that are on an accessible route sounds like a staff review/appeal nightmare.
4. Yes, weight the top 3 items from the survey: safety, grocery, and healthcare.
5. Yes, access to jobs via the objective Census on the Map Tool. Consider a ratio of existing and proposed HTC units to the the number of <$3,333/month jobs in the census tract plus a 1 mile buffer (urban) and 2 mile buffer (rural).
6. It is not necessary to differentiate between Q1, Q2, and Q3.

Option 1 is preferable because access to community amenities is prioritized over demographic data. 

If TDHCA modifies distance measurements, non-crow fly routes and accessible routes should be considered as 2 characteristics, not 1. Both have merit, but are unique. The first is the length to drive (or walk) to the amenity and should be measured driveway to driveway or sidewalk to sidewalk. As discussed in survey results, this is more sensible method to determine travel time and access. I recommend using driveway to driveway on public roads measured via google maps. The second attribute is an accessible route that should be bonus-ed separate from non-crow fly characteristic as it is only non-vehicular. Please consider that best practices use .25 miles for the preferred walking distance. An accessible route for something over .5 miles may not yield any real benefits for the residents.

Thank you for considering this input. We welcome your responses and guidance to these items in a round table, at a Board Meeting, QAP Committee meeting, or on this forum, please.
tcroxdale

Registered:
Posts: 2
 #4 

In general, we think that the scoring and opportunity index is working well and that 'good' projects are winning in Austin.

 

  1. Should any menu items be removed from the list of menu items? all are ok

 

  1. Should any menu items that speak to High Opportunity be added? Proximity to good schools and good jobs is an important indicator of high opportunity areas. Good schools could be added as an amenity rather than its own scoring criteria, making it more flexible for regions that have low performing schools. Good jobs critieria hasn’t been vetted yet, but would be interesting to dig into.

 

  1. Should any menu items be modified? We like the proposed idea of weighted points. But not sure it is worth the additional complexity. Areas that score, will still score. If weight is used, high scoring amenities from the tenant survey should be given more weight. (grocery store, pharmacy, clinic, low crime)

 

  1. How might the high opportunity scoring item be made more competitive (i.e., make the “max score” a score that not everyone can achieve)? We don’t think it needs to be more competitive. If you are in a Q1, Q2, Q3-adjacent census tract and close to 5 – 6 amenities from a list of 14 amenities we think you are in a ‘good’ area

 

  1. The menu items for property crime rate and percentage of adults with an associate’s degree or higher are intended to align with conditions typically found in  a potentially safe and upwardly mobile neighborhood. Could there be other menu items that might align with those conditions found where certain neighborhoods are on the cusp of becoming considered a high opportunity area? Same as #2

 

  1. What is the best way to differentiate between income Q1, Q2, and Q3 census tracts? Leave as is, or make Q1, Q2, and Q3 adjacent all count for 2 points and you have to get 5 points in amenities. No need to make it more complicated. The current scoring is working well.
ajcarpen

Registered:
Posts: 8
 #5 
I think the current 2018 high opportunity language worked fine. I do not see any reason to make it more complex with things like weighting or subjective accessible routes (like "smooth hard surface"....you are going to see a challenge if there is a slightly pebbly section of concrete sidewalk). If the point is that the development is in an area with several desirable amenities with a higher base score for a higher income census tract, then the 2018 language worked.

The bigger concern in my opinion is the significant increase in revitalization applications that do not need to meet as many amenity requirements as non-revitalization applications. I think the concerted revitalization plan rules need to be cleaned up, the language needs to revert to where a city can only designate 1 priority revitalization application in the entire city, and revitalization applications need to hit more than 4 high opportunity amenity items. 
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