Last week, the state released draft guidelines for the much anticipated Affordable Housing and Sustainable Communities (AHSC) program. With California now collecting revenue from the new Cap and Trade program, there is now dedicated funding for infill projects that demonstrate the ability to reduce greenhouse gas emissions and create sustainable and equitable communities. Unfortunately, the first draft of the AHSC guidelines are misguided, ignoring where greenhouse gas emissions are the worst and sustainable community investment is needed the most: the Central Valley.
While I fully support the allocation of cap and trade funding to help create sustainable development, there is a strong disconnect between AHSC program goals and the realities of where the most polluted areas of California are. The AHSC draft guidelines are indicative of the state’s habit of directing money to already wealthy areas while giving short shrift to less politically connected regions. If we want real walkable communities in Stockton and other Central Valley cities, we have to make sure state program officials know we are not happy with the AHSC program guidelines in their current form.
AHSC guidelines cite greenhouse gas reduction as a principal program objective. Given that, it stands to reason that the majority of funding should be awarded to the most polluted communities in order to promote compact development in existing urban areas. If this were the case, the Central Valley—home to the nation’s poorest air quality and most sprawling land use patterns—should be the focal point of such a program. Instead, current AHSC scoring criteria is clearly tilted toward big cities that already support dense development patterns where driving is an option, not a necessity. Moreover, the Central Valley is set to grow at a much faster rate than the already dense coastal regions, so one would think that funds should be earmarked in greater quantities to build communities in the Central Valley that can mitigate the environmental effects of a booming population. Without funding to kick start infill development, the Central Valley will continue to sprawl, exacerbating an already dangerous pollution problem stemming from too much driving.
The AHSC program puts certain communities at a disadvantage by assigning higher point values to projects that are in close proximity to subways and light rails—transportation options that are nonexistent in Central Valley cities. Case in point, despite having popular Bus Rapid Transit (SJRTD Metro Express) and commuter lines (ACE Rail) in close proximity, a Downtown Stockton project cannot score maximum points. The only projects that can receive maximum points are those that enjoy existing subway or light rail services (such as BART in the Bay Area or the Red Line in Los Angeles). As a result, Central Valley developers with projects promoting walkability are penalized– even if they have tie ins to transportation networks that make perfect sense for their community– simply because they do not have the luxury of a big-city rail transportation system.
AHSC projects also get scored higher for amenities you won’t find in any Central Valley downtown area. Bike share kiosks, car sharing programs, grocery stores and electric vehicle charging stations are all staples of more affluent city cores, but not in Central Valley downtown areas. The presence of these amenities brings higher scores for infill projects, making it even more difficult for cities like Modesto, Fresno, and Bakersfield to compete for AHSC funds. It would be nice to have these things in Downtown Stockton, and hopefully one day we can get there, but it seems counterproductive to the emission reduction goals of the AHSC to penalize a Central Valley city such as Stockton for not yet having these amenities.
While it’s easy to pick apart why this program appears to be inequitable, I do understand how this scoring criteria came to be. On the one hand, program administrators need to make sure they’re awarding funding to projects that will actually decrease driving and reduce emissions. But California is a big state and it’s difficult to develop a formula that can score every community evenly. Because of this reality, special steps should be taken to ensure that strict scoring criteria does not inadvertently exclude smaller cities with bigger pollution problems.
In order to have the greatest impact on greenhouse gas emissions, the AHSC must set aside a significant portion of funds for Central Valley communities where seemingly limitless amounts of land make it very difficult for infill projects to take hold. Similar programs in the past have included such set asides for the Central Valley, but they were too small to make a significant impact. For example, the state’s previous Transit Oriented Development and Infill Infrastructure Grant programs only set aside 10% of funding for the Central Valley. The AHSC cannot make this same mistake and must include a much higher set aside if state officials hope to actually make meaningful progress on reducing emissions and creating sustainable communities.
Fortunately, the AHSC guidelines released last week are in draft form, so there is time to make changes. The state is accepting feedback on these guidelines, specifically noting that it needs input on the geographic distribution of these funds. The comment period for the draft guidelines are open until October 31st, so if you care about making walkable, sustainable and equitable development in the Central Valley a reality, send in comments to email@example.com. The state is also hosting feedback workshops this month, with one slated for Sacramento on October 28th.