April 30, 2021
Connecticut General Assembly
Planning and Development Committee
HB 6611 - AN ACT CONCERNING A NEEDS ASSESSMENT AND OTHER POLICIES REGARDING AFFORDABLE HOUSING AND DEVELOPMENT.
Dear Planning and Development Committee Chairs and Committee Members:
Thank you for the opportunity to submit the following testimony on behalf of the Ridgefield Planning and Zoning Commission (PZC) on HB 6611. The Commission has been actively engaged in following the multiple efforts to reform the state’s zoning regulations, particularly as they pertain to advancing affordable housing.
Ridgefield is a strong advocate for affordable housing. Over the past 30 years, the PZC has received and approved 38 affordable housing applications submitted under 8-30g. Our zoning regulations have been modified during the same period to advance housing diversity. Accessory dwelling units (ADUs) up to 1200 square feet and two (2) bedrooms are permitted in residential zones by right. Middle housing is incorporated within our zoning regulations through Multi-Family Development Districts (MFDD), Age-Restricted Housing Districts (ARHD), and Main Street Design Districts (MSDD).
All provide for density of six (6) to eight (8) units per acre within the sewer districts. The Neighborhood Business Zone (NBZ) provides for apartments above commercial use. The Mixed-Use Overlay Zone was established to promote socioeconomic diversity with up to 16 units per acre of affordable housing above commercial use in the Business zones. The Central Busines District (CBD) allows and does not limit residential density. Ridgefield has provided for, and supports, middle and multi-family housing through the MFDD, ARHD, MSDD, NBZ, MU Overlay Zone, and CBD. Each project furthers the state’s, and the town’s, objective to increase housing diversity.
The advances Ridgefield has made toward addressing the state and town needs for affordable housing have been through public and private initiatives with decisions made by the town’s PZC, and input from the community through the public hearing process. Virtually all of the projects have been improved through the public hearing process and often result in an initially reluctant public supporting the resulting project.
HB 6611 seeks to remove affordable housing decisions from those who know the needs of their communities best – the local PZC and the citizens of the towns. Instead, the bill would delegate authority over municipal housing projects to a state agency with no knowledge of local needs - and compel towns to build affordable housing whether the demand is there or not. The bill disregards local needs and subjects the towns to demand brought by housing advocates, developers, aggrieved individuals, or special interest groups, and then mandates that the towns must pay the legal costs, and damages, for the litigation brought against them. HB 6611 would force the towns to build through litigation, regardless of demand.
The bill proposes to assess affordable housing quotas for Connecticut towns based on their level of poverty. The lower the poverty rate, the higher the quota. According to the HB 6611 calculations, Ridgefield’s “fair share” of affordable housing could be as high as 20 percent. After 30 years of diligent effort, approximately 3.1 percent of Ridgefield housing built since 1990 is deed-restricted affordable. Were the town allowed to count housing built prior to 1990 that is naturally affordable but not deed-restricted, the number would be considerably higher. However, Ridgefield is nowhere near the state mandated 8-30g threshold of 10 percent, and the PZC believes the threshold is unattainable without changing our town into a city.
The state’s interest to address the need for affordable housing is shared by Ridgefield’s PZC. We have found the approach the state advances through 8-30g to be a challenge, but the original intent was to create a remedy to address market needs when towns did not provide it. HB 6611 disregards market need, and, instead, would require towns to build affordable housing whether the demand is there or not. The resulting cost of forced compliance through litigation would surely take precious municipal resources away from schools, roads, social services, and public safety, or, worse, subject towns to crippling debt.
Perhaps a more constructive approach to create affordable housing would be to correct the flaws within 8-30g and allow the towns to identify their housing needs through the submission of their state-mandated 8-30j Affordable Housing Plans. A review of the Plans, once submitted, would provide the state with a better understanding of where the needs are and the best way to approach them – in collaboration with the towns.
The bill proposes unachievable goals to relieve some of the housing pressures from the cities at the expense of the small towns. We ask that you consider the consequence of the reforms that are proposed in HB 6611 and if the devasting impact they would have on towns like Ridgefield is the best way to address the housing needs of the state.
Chair, Ridgefield Planning and Zoning Commission
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