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[quote="Jersey Dad"]Public comments on COAH's Rules changes are due by August 15th. As food for thought, my comments are below...

To the Council on Affordable Housing,
I grew up a poor kid in what some people would call a "rich" town (Haddonfield). My father was a state employee and my mother a teacher in a poor urban area. We didn't have affordable housing; we had a house we could barely afford. My parents worked hard to fulfill the American Dream. Their work ethic set a good example for me. I worked hard so I could live in a nice town with good schools and a commitment to open space and historic preservation (Cranbury). Accordingly, I believe it is a worthy mission to help hard-working people who are trying to provide the American Dream for their families. The underlying goals of affordable housing policy seem consistent with my beliefs. However, I do have practical concerns and recommendations with regards to the changes in affordable housing rules. They are:

Stranded in the Suburbs
The new rules are likely to leave the residents of affordable housing stranded in the suburbs.For instance, the number of jobs assigned to warehouses appears to be grossly over-estimated, causing inflated obligations in many suburban towns. This will result in a glut of affordable housing in towns with insufficient local employment opportunities to support the new residents. Furthermore, low-income workers are particularly vulnerable to layoffs. Therefore, affordable access to a multitude of employment opportunities is critical in our economy. In addition, increasing commuting costs make access to mass transit a necessity for low and moderate income families. For example, commuting by car from Cranbury to Newark costs twice as much as commuting by train from West Windsor; a difference of more than $3,000 per year. It is counter-productive to leave low-income workers stranded in the suburbs with limited employment opportunities and limited access to mass transit.

COAH should re-consider the obligations based on more accurate employment data. COAH should also reduce the obligations in towns without access to mass transit, or at least encourage towns to work regionally to ensure that affordable housing is built near mass transit.

Planning Retroactively
The growth share methodology should enable towns to manage affordable housing obligations through smart planning. However, retroactively imposing new rules is a contradiction of this logic. Towns like Cranbury will need new schools, more police and expanded infrastructure, in addition to construction costs that cannot be recouped retro-actively from builders. In addition, the new rules seem at odds with Cranbury’s intense commitment to historic and farmland preservation.

COAH rules changes should not be retroactive. Appropriate plans submitted prior to the rules changes should be granted substantive certification according to the rules in place at the time of submission. COAH should honor the plan submitted by Cranbury in 2005 that fully addressed Cranbury’s anticipated affordable housing obligation, including an RCA with Perth Amboy .

Rules & Priorities
A top objective of fair housing is to give workers a reasonable opportunity to live near their jobs. However, local workers, such as police, firefighters and teachers, don’t receive priority housing in their local communities. Additionally, despite their service, returning Veterans don’t receive priority for affordable housing, either. Furthermore, despite an increasing senior population, COAH rules changes reduce the opportunity to address the specific needs of seniors. Ironically, affordable housing policy and COAH rules changes will substantially increase property taxes for many workers, veterans and seniors who are already struggling to keep their heads above water. COAH rules also favor rental communities in contrast to the American Dream of home-ownership.

COAH should set up a priority system for local workers such as police, teachers and others who are an integral part of the community. In addition, offering priority to returning veterans and to the seniors who built our communities is the right thing to do. Finally, encouraging “rent-to-own” communities will foster a commitment to the community and enable affordable housing residents to build equity toward the American Dream.

Thank you for your consideration[/quote]

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