October 10th, 2019
Dear Chief Housing Officer Britta Fisher,
Thank you for opening public comment on Denver's Draft Housing Action Plan 2020. We appreciate the progression of many of the strategies in the plan, especially the increase in funding for affordable housing. Although we approve of much of the plan, we have provided some additional comments that we believe should be taken into deeper consideration and included in the final version of the plan.
Below, we have included fifteen comments that came as a result of organizing with more than 200 neighbors in Elyria-Swansea and Globeville who participated in more than 60 community meetings during 2019. A summary of community comments are provided below:
1. Anti-displacement strategies should explicitly center the stability of the most vulnerable residents who reside in the community, and should have a direct impact on housing stabilization of vulnerable households. Collaboration with community-based organizations with a proven-track record should be emphasized in order to identify families and individuals at the highest-risk of displacement, or who have previously been displaced.
2. Clearly defined and measurable “Equity impacts” should be central to policy debate about development and neighborhood change.
3. Investments by the City of Denver and their partners should proportionately mitigate displacement in relationship to the amount of public-private spending for large-scale economic development that is driving the threat of displacement in Denver’s neighborhoods most vulnerable to displacement. There is no language or acknowledgement in the Action Plan 2020 about the history of the City of Denver's public investment that is contributing to wide-spread displacement.
4. For new development in neighborhoods vulnerable to displacement, require a “”Displacement-Impact Fee”” that are collected from the developer for every unit developed at the site. These fees should be allocated for new and existing programs that stabilize neighbors who are at a high-risk of involuntary displacement. An example program that could be funded by “Displacement-Impact Fees” is a Community Legal Fund made available for neighbors facing legal issues with their housing (ie: costs for early or forced lease-termination, legal costs to address common issues like the illegal withholding of security deposit, etc). The programs funded by the (per unit) “Displacement Impact Fee” should directly address the prevention and mitigation of displacement of neighbors within 1.5 miles of site development.
5. The Housing Action Plan should do more to support community organizing, and involve residents in making actual decisions that impact the residents.
6. Require developers to promote and measure positive human development and health outcomes (ie. neighborhood stabilization programs, prevention and mitigation of displacement), in addition to economic indicators.
7. Do more to acknowledge the long (and ongoing) history of systemic racial and economic discrimination that have created the inequity that make communities of color most vulnerable to displacement.
8. Do more to acknowledge and support the importance of racial equity, community, and culture as parts of a healthy community.
9. Affordable housing policies and programs should be tied to people in the same neighborhood most impacted by development and displacement pressures (within the bounds of Fair Housing Laws)
10. Because low-earning families who are at the highest-risk of displacement have the least amount of affordable housing units to choose from, include and initiate policy and programs that increase funding for 30% AMI for two, three, and four bedroom units, and make these units available through a scoring system that favors families at high-risk of displacement (similar to the Portland Preference Policy).
11. Include scoring of displacement pressures to qualify families most at-risk of displacement, for prevention and mitigation of displacement programs and resources, including emergency services, short-term vouchers, etc.
12. Tax rebate programs should be expanded to include all families earning at or below 50% AMI.
13. Community stewardship should be a core component of the City and its partners exploration of the community land trust model in Denver. There is no mention of community in the “Land Trust” section, and there is no mention of the community stewardship component.
14. Search for and promote opportunities to partner with grassroots, neighborhood-based organizations with a proven-track record of community stewardship, including partnerships and public land sale/donations for new and existing development with Community Land Trusts.
15. Despite that the 3rd goal of the Action Plan is to “Promote equitable and accessible housing,” the Action Plan includes no definitions, measurements, programs or strategies that specifically address how “equity” and “equitable housing” will be accomplished.
Thank you for your time to consider this feedback for the final version of Denver's Housing Action Plan 2020.