Fairfield County's Center for Housing Opportunity Comments on WestCOG’s 2020-2030 Draft Regional Plan of Conservation and Development

Dear Chairman Stevenson and Members of the Western Connecticut Council of Governments,

My name is Christie Stewart and I am Executive Director of Fairfield County’s Center for Housing Opportunity (FCCHO).  I had hoped to present this testimony to you in person today, yet was unable to re-arrange my schedule in order to do so after receiving this hearing announcement.  Thank you for your consideration of this written submission.  As you will see below, I have included my email address and would be pleased to continue this conversation with any members of WestCOG after today’s hearing.

FCCHO is a collaborative, regional initiative comprised of four partner organizations- Fairfield County’s Community Foundation, Partnership for Strong Communities, Regional Plan Association and Supportive Housing Works - dedicated to addressing the affordable housing crisis that continues to grow in Fairfield County.   

The purpose of this testimony is to strongly urge WestCOG to address the housing-related comments on the Draft 2020-2030 Regional Plan of Conservation and Development that we submitted on January 2, 2020 during the public comment period, prior to adoption of the Plan.

As a guiding document for member municipalities, the Plan is a critically important framework for regional and local decision making. As such, FCCHO feels it is critically important that the Plan accurately describe the region’s housing challenges in ways that underscore the centrality of those challenges to the future of the region’s economic and community health.

After careful review of the draft Plan, FCCHO has serious concerns about the Plan’s narrative as it relates to housing issues. As currently drafted, the Plan suggests that the region is meeting the housing needs of its residents, which is dangerously misleading. Existing data from respected sources shows that there are significant affordable housing needs within virtually every town within the WestCOG area, and across the entire region. The next decade of planning will be critical as we grapple with undeniable shifts in the demographic and economic landscape of our region.  Municipalities will be looking to the WestCOG POCD to provide a common frame for regional planning.  Indeed, as a tool for prioritization and allocation of state resources, and as a guide for local planning and land use decision-making, WestCOG’s POCD represents an important opportunity to meaningfully address the affordable housing crisis in our region, which is critical to securing our economic future.

We strongly urge WestCOG to address the following prior to adopting the Regional POCD:

1.  Inclusion of a Housing Needs Analysis

The draft POCD does not include a housing needs assessment, which is a necessary data-based foundation for accurately assessing existing housing needs and recommending housing policies that will guide decision making in the region over the course of the next decade. Without this fundamental assessment, the Plan’s pronouncements on housing need and solutions for meeting those needs are problematic.

For example, on page 9 the Plan states that, “Seniors are expected to become an increasing share of the region’s population over the next thirty years as the baby boom generation retire and chooses to stay living in their current dwelling units.” Regional and national data trends point to the desire for seniors to downsize from single family homes to apartment and townhouse units that are less difficult and costly to maintain. These same trends point to the desire of seniors to move into smaller, more affordable and easy to maintain units in the communities in which they currently live.

On page 15, the plan states, “…cities can expect to see increasing demands for housing reflecting their role in providing services and employment opportunities for the entire region.” This statement mischaracterizes housing as primarily the responsibility of the cities and does not address the suburbs, which can also expect to see increasing demands for housing as older residents look to downsize and residents of all ages seek homes in areas of opportunity.

Statements such as these fail to include critically important information, and in doing so implicitly contradict current findings from relevant local data sources, including the United Way of Connecticut’s ALICE Report and The Fairfield County Community Wellbeing Index.  We urge you to include the relevant housing data and findings from these respected reports in the Plan.

2.  Incorporation of the Implementation Plan for Sustainable Development in the NY-CT Metropolitan Region, 2014

As written, WestCOG’s draft Regional POCD does not reference or contain recommendations from the Implementation Plan for Sustainable Development in the New York – Connecticut Metropolitan Region, 2014 created by the NY-CT Sustainable Communities Consortium. This plan, signed onto by the communities in the WestCOG region, includes a Fair Housing and Equity Assessment (FHEA), which describes the context, data, and evidence for equity and opportunity in the region, and includes recommended strategies to inform decision- making in the region.

We ask that WestCOG reference the Implementation Plan to inform the housing section of the Regional POCD on pages 60-69 to ensure that issues of equity and opportunity, already agreed to by many WestCOG member communities, are included in the regional plan’s recommendations.

Some key recommendations that should be included are:

  • Adoption and enforcement of local mandatory inclusionary housing ordinances;
  • Preservation of affordable housing by local jurisdictions when affordability requirements are expiring;
  • Investment in redevelopment of public housing to replace existing units with new housing in mixed-income settings while preserving or expanding the number of extremely low-income units;
  • Increased access to job centers through strategic transportation investments by MPOs; and
  • Development of and commitment to community engagement best practices.

3.  Recognition of existing requirements for municipal housing plans

WestCOG’s draft POCD does not include any reference to the state requirement found in CGS Sec. 8-30j that “at least once every five years each municipality shall prepare or amend and adopt an affordable housing plan for the municipality. Such plan shall specify how the municipality intends to increase the number of affordable housing developments in the municipality.”

We feel strongly that it is imperative that the WestCOG regional POCD provide context for and guidance on preparation of mandated local affordable housing plans to assist member towns in meeting the affordable housing plan requirement as well as the required 10% affordability threshold, which is also mandated by State statute. As the housing market is regional and not confined to local municipal boundaries, a regional understanding of housing need, as noted above, is critical to addressing these State requirements.   

Again, we appreciate the opportunity to comment on WestCOG’s Draft 2020-2030 Regional Plan of Conservation and Development (POCD) and thank you and your staff for your efforts on behalf of the region and for your consideration of our concerns.