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Cascade: No. 55, Summer/Fall 2004

Do the New COAH Rules Meet the Needs of New Jersey Residents?

Yes: They Encourage Affordable Housing and Smart Growth

Last summer, the Council on Affordable Housing (COAH) proposed a sweeping overhaul of the state's existing affordable housing system. In keeping with Governor McGreevey's bold plan to stop sprawl and improve our quality of life, this new system-the third-round methodology-encourages sound local planning, promotes smart growth, and creates affordable housing opportunities for all of our state's citizens.

Through the proposed COAH rules issued in August 2003, the state encourages municipalities to plan in a comprehensive way that meets the needs and concerns of our communities. The new methodology uses actual residential and employment growth to determine a community's affordable housing obligation. This sensible, long-overdue approach is known as a growth-share model. The growth-share model has three main advantages over previous methods.

First, this growth-share methodology encourages municipalities to plan for growth while providing affordable housing opportunities. In the past, COAH assigned each municipality an affordable housing obligation using speculative population, employment, and economic growth projections. Actual growth often varied widely from these projections. As a result, affordable housing wasn't always provided in areas that experienced significant growth, creating much less affordable housing than would have been produced under a growth-share approach. The growth-share methodology allows a municipality to plan for future growth and include the need for affordable housing in that planning. Under this plan, as a municipality grows and attracts jobs over time, it will provide affordable housing in proportion to that growth.

Second, a growth-share approach promotes smart-growth principles by encouraging strategic, sensible growth in the right places. By planning for the long term with smart-growth principles, we can work to reverse the years of damage that unplanned growth has had in our communities-damage such as pollution, loss of open space, deterioration of our drinking water, and traffic congestion.

For instance, we want to make sure the third-round rules are consistent with the New Jersey State Development and Redevelopment Plan and that affordable housing sites are located in environmentally suitable areas. This will further protect our state's wetlands, historic sites, and environmentally sensitive areas such as the Pinelands, the Highlands, and the Meadowlands, while increasing the quality of life that all New Jerseyans want, need, and deserve.

The inherent weakness of the new rules, however, is compounded by the following two provisions, each of which would have the effect of reducing the amount of affordable housing that will be built:

The third major advantage to the COAH rules is that we have streamlined the way COAH works to ensure efficiency and reduce bureaucratic delays by shortening mediation times, ensuring quick turnaround time, and setting firm deadlines for all participants in the COAH process. In the past, municipalities sometimes participated in the COAH process for years. By expediting reviews, more affordable housing will be built more quickly.

Creating quality affordable housing for all New Jerseyans is crucial when planning for long-term growth throughout our communities. That is why the McGreevey administration has made the provision of affordable housing one of its highest priorities.

For instance, we understand the need to provide rental and homeownership opportunities for low- and moderate-income families, people with disabilities, and seniors throughout New Jersey and are discussing ways to make sure the rules provide a variety of affordable housing choices for all of these constituencies. We also recognize the needs of very low-income households-those who earn below 30 percent of regional median income-and are looking for ways to assist them using financial resources generated through the COAH process. That is why we are looking at ways to provide incentives to municipalities to create more affordable rental and homeownership opportunities for low-income residents.

The COAH overhaul is just one way that the Department of Community Affairs (DCA) seeks to fulfill its commitment to affordable housing. In addition to the affordable units produced throughout the COAH process, DCA-in partnership with the New Jersey Housing and Mortgage Finance Agency-has provided more than $2 billion in funding to help finance 17,526 affordable housing units in 499 municipalities throughout New Jersey since January 2002. Clearly, we are well on our way to meeting-and exceeding-Governor McGreevey's commitment to provide 20,000 affordable housing units by 2006.

Since the proposed third-round rules were announced in the summer of 2003, we have received feedback and suggestions from constituents, advocates, organizations, and individuals. A COAH task force has been reviewing these comments in order to make the rules work best for New Jersey's families and seniors. Their recommendations, based on the public comments we have received, will assist COAH in its goal of creating quality affordable housing opportunities for all of New Jersey's hard-working residents.

I hope that together we can move forward to realize our goals for New Jersey: to provide more affordable housing, to provide smart planning in our communities, and to work toward improving the quality of life for all of New Jersey's citizens.

For information, contact the New Jersey Department of Community Affairs at (609) 292-6055 or dca.feedback@dca.state.nj.us; www.state.nj.us/dca/coah.