June 6, 2016

Re: Proposed “Streamlining Affordable Housing Approvals” Trailer Bill

Dear Governor Jerry Brown,

The Alliance for Community Transit – Los Angeles (ACT-LA) writes to express our opposition to the proposed “Streamlining Affordable Housing Approvals” Trailer Bill.

ACT-LA is a coalition of thirty-one organizations in the City of Los Angeles. We work towards just, equitable, sustainable transit systems and neighborhoods for all people in Los Angeles, placing the interests of low-income communities and communities of color at the forefront of our journey towards a more sustainable city.

We support, and seek to advance equitable development and inclusive planning. We believe in a transit-rich Los Angeles where all people have access to quality jobs, affordable housing, necessary social services, ample transportation options, and a voice in decision-making.

While we appreciate the recognition of the severe affordable housing crisis that has gripped our neighborhoods, we strongly believe that this proposal misses the mark and may actually impede our state’s ability to achieve sustainable community growth and accountable investment without displacement. Our communities need development and planning policies that reflect the principles of inclusion, opportunity, community empowerment and equity. This proposal falls short.

The proposal undercuts community input and further disempowers low-income communities.

This proposal runs counter to important values of community input and informed decision-making. In fact, it would allow projects to bypass most local processes for community input and environmental review, and would undermine the discretion of local elected policymakers to respond to community concerns. In Los Angeles and other areas across the State, we have a long and unfortunate history of planning done to, not with, low-income communities and communities of color. This proposal takes us in the wrong direction. While efficiency and predictability in planning are important, we do not believe these values should trump the opportunity for residents to participate in decisions affecting their lives and neighborhoods.

The proposal threatens to undermine state and local affordable housing programs.

Addressing our affordable housing crisis requires a comprehensive and coordinated approach. New legislation should strengthen existing frameworks and solidify a foundation of equity and inclusion. Unfortunately, the piecemeal and uncoordinated nature of this proposal threatens to weaken important affordable housing tools and destabilize existing programs. Among other things, the proposal is inconsistent with State Density Bonus Law, our State’s first smart growth planning tool.

Generally, this proposal takes away communities’ ability to provide their input on development projects in exchange for extremely low amounts of affordable housing. Requiring less affordable housing than the state density bonus law and existing or proposed local “value capture” policies require may in fact undermine these key tools for attaining critically needed affordable housing. Inconsistent replacement housing policies and affordability durations may weaken vital neighborhood stabilization tools.

The proposal runs counter to well-established state environmental and transportation policy objectives.

Los Angeles is currently undergoing the largest public transit build out in the country and our local city government is prioritizing new development near transit. A recent study concluded that low-income residents of neighborhoods near transit have the lowest VMT rates in the state, and the legislature has affirmed that lower income households are more likely to use transit when living near a major transit station than higher income households.[1] It is critical that low-income transit-dependent riders – the vast majority of Los Angeles’ regular transit users – are able to afford to live near transit.

Inexplicably, this proposal would accelerate by right development with lower affordability requirements near transit than projects not located near transit. This is fundamentally inconsistent with sound policy principles and is diametrically opposed to the vision of SB 375 and other state programs that prioritize affordable and inclusive development near transit. As a transit equity coalition we are deeply disturbed by this bizarre framework.

The proposal fails to advance the creation of quality, local jobs

Our current housing crisis is not only a consequence of rising rents, it is also one of stagnating wages and lack of quality, local job programs. Investments in our cities must lead to sustaining work for local residents. The Governor’s proposal does nothing to ensure that residential construction will lead to better employment opportunities for California residents, particularly those who face barriers to employment.


We are extremely concerned with the last minute, fast-tracked nature of this proposal, which would have consequences around the state on the most important issues we face: housing, economic development, transit access and our environment. Many key stakeholders are unaware of the details of this proposal, and there is woefully inadequate time to respond.

We join labor unions, environmental organizations, and many other housing and economic justice advocates across the state in opposing this proposal. We remain committed to working toward comprehensive and informed policy strategies to create and preserve affordable housing and promote sustainable and inclusive development.


Alliance for Community Transit – Los Angeles (ACT – LA)



cc: Senator Kevin de León

Senator Mark Leno

Assemblyman Phil Ting


[1] AB 2135 (2014).

Posted by act_la