Affordable Housing in Transit-Oriented Development: Key Practices Could Enhance Recent Collaboration Efforts between DOT-FTA and HUD
Published: 2009-09-09T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The federal government has increasingly focused on linking affordable housing to transit-oriented developments--compact, walkable, mixed-use neighborhoods located near transit--through the Department of Housing and Urban Development's (HUD) housing programs and the Department of Transportation's (DOT) Federal Transit Administration's (FTA) transit programs. GAO was asked to review (1) what is known about how transit-oriented developments affect the availability of affordable housing; (2) how local, state, and federal agencies have worked to ensure that affordable housing is available in transit-oriented developments; and (3) the extent to which HUD and FTA have worked together to ensure that transportation and affordable housing objectives are integrated in transit-oriented developments. To address these issues, GAO reviewed relevant literature, conducted site visits, and interviewed agency officials.
section_title: What GAO Found
paragraphs: Characteristics of transit-oriented developments can increase nearby land and housing values, however determining transit-oriented development's effects on the availability of affordable housing in these developments are complicated by a lack of direct research and data. Specifically, the presence of transit stations, retail, and other desirable amenities such as schools and parks generally increases land and housing values nearby. However, the extent to which land and housing values increase--or in the rare case, decrease--near a transit station depends on a number of characteristics, some of which are commonly found in transit-oriented developments. According to transit and housing stakeholders GAO spoke with, higher land and housing values have the potential to limit the availability of affordable housing near transit, but other factors--such as transit routing decisions and local commitment to affordable housing--can also affect availability. Few local, state, and federal programs are targeted to assisting local housing and transit providers develop affordable housing in transit-oriented developments. The few targeted programs that exist primarily focus on financial incentives that state and local agencies provide to developers if affordable housing is included in residential developments in transit-oriented developments. However, GAO found that housing developers who develop affordable housing in transit-oriented developments generally rely on local and state programs and policies that have incentives for developing affordable housing in any location. HUD and FTA programs allow local and state agencies to promote affordable housing near transit, but rarely provide direct incentives to target affordable housing in transit-oriented developments. Since 2005, HUD and FTA, and more recently DOT, have collaborated on three interagency efforts to promote affordable housing in transit-oriented developments including (1) an interagency agreement, (2) a HUD-FTA action plan, and (3) a new DOT-HUD partnership. While these interagency efforts have produced numerous strategies, local housing and transit officials told GAO that these strategies had little impact, in part, because they have yet to be implemented. However, the agencies have not yet developed a comprehensive, integrated plan to implement all efforts, and without such a plan, the agencies risk losing momentum. GAO has previously identified key practices that could enhance and sustain collaboration among federal agencies; when compared to these practices, GAO found that HUD, FTA, and DOT have taken some actions consistent with some of these practices--such as defining a common outcome. However, weaknesses in agency housing data and analytical transportation planning methods will limit these agencies' ability to effectively monitor, evaluate, and report results--another key collaboration practice. GAO found that other collaboration practices, such as establishing compatible policies and procedures, could be taken to strengthen

section_title: Letter
paragraphs: Households seeking relief from high housing costs may move to areas with  less costly housing but then find themselves further away from their place  of employment and public transportation. Consequently, they can face  significant increases in transportation costs and commute times. Such  costs can particularly affect lower-income households, since these  households are more transit dependent and have fewer transportation  choices available. In addition, state and local governments, which build,  operate, and maintain each region’s transportation system, may need to  accommodate more people driving longer distances to work, and with an  increase in traffic congestion, will likely need to spend more money on  roads.
To combat increasing costs for both individual households and local  governments, numerous local communities believe there is a need to  expand housing opportunities and other amenities located near transit by  promoting transit-oriented developments. Transit-oriented developments  are commonly seen as compact, mixed-use (commercial and residential),  walkable neighborhoods located near transit facilities—such as fixed- guideway stations. The perceived benefits of transit-oriented  developments include reducing individual households’ transportation  costs by providing residents with walkable access to transit service and  shopping, and reducing the investment needed for local governments to  build and maintain roads. Officials in cities such as Denver and Seattle  believe that promoting transit-oriented development will realize these  benefits and can spur economic development.
Some policy makers and housing experts, however, have raised concerns  that lower-income households might not benefit from these developments.  Specifically, they are concerned that the high demand for housing at  transit-oriented developments will encourage developers, who typically  seek to maximize the return on their housing investments, to primarily  build market rate housing that may limit affordable housing opportunities  for lower-income households. Also, housing stakeholders have expressed  concern that existing affordable housing—whether subsidized or not— presently located near transit may no longer be financially feasible once a  transit-oriented development is built, thereby increasing the demand for  affordable housing.
The federal government has acknowledged the link between housing and  transportation. For example, the Department of Housing and Urban  Development (HUD) and the Federal Transit Administration (FTA) started  collaborating in 2005 by funding research on expanding housing near  transit. More recently, in separate testimonies presented in March 2009,  the Secretaries of HUD and the Department of Transportation (DOT)  discussed the relationship between housing and transportation. In  addition, there has been an increased focus on combining the cost of  housing and transportation as the “true” cost of housing affordability.  However, under the current structure, the federal government provides  significant funding to state and local governments to support both local  affordable housing and surface transportation programs through separate  housing and transportation departments. For example, HUD provides  rental housing assistance through three major programs—housing choice  vouchers, public housing, and project-based rental assistance; in fiscal  year 2008, these programs provided rental assistance to about 4.75 million  households and, according to HUD officials, paid about $31.25 billion in  rental subsidies. DOT, through a variety of FTA programs to include the  New Starts program, has provided more than $33 billion over the last  decade to help design, construct, rehabilitate, and modernize fixed- guideway transit projects throughout the country. Congress, among  others, has raised questions about how these departments could better  work together. In 2008, the Appropriations Committees directed HUD and  FTA to jointly address new and better ways for promoting affordable  housing near transit service.
You asked us to provide information on several key questions related to  the impact of transit-oriented development on affordable housing and how  HUD and FTA might better work together. More specifically, this report  addresses the following questions:  1.  What is known about how transit-oriented developments affect the  availability of affordable housing? 2.  How have local, state, and federal agencies worked to ensure that  affordable housing, including housing subsidized through HUD  programs, is available in transit-oriented developments? 3.  To what extent do FTA and HUD work together to ensure that  transportation and affordable housing objectives are integrated in  transit-oriented developments, and what opportunities exist to  enhance collaboration?
To address these questions, we conducted a review of relevant literature,  reports, studies, and our prior research. We also conducted 11 site visits in  Mesa, Phoenix, and Tempe, Arizona; Sacramento, California; Chicago,  Illinois; Cleveland, Ohio; Jersey City and Hoboken, New Jersey; Portland,  Oregon; Washington, D.C.; and Arlington, Virginia. During these site visits,  we interviewed federal, state, and local housing and transportation  officials; nonprofit housing organizations; and housing developers, and  toured transit-oriented developments. We selected this nongeneralizable  sample of metropolitan areas based on whether the metropolitan areas  reported having transit-oriented developments, if the area had received  New Starts federal funding for construction of a local fixed-guideway  transit system, and geographical diversity. We also interviewed  transportation, housing, and community development officials; housing  developers; and representatives from various transportation and housing  associations with experience in developing, implementing, or analyzing  these issues. In addition, we reviewed studies and documentation on how  government agencies and other housing and transportation stakeholder  groups in these and other metropolitan areas and states have promoted  transit-oriented developments. We conducted this performance audit from  August 2008 to September 2009 in accordance with generally accepted  government auditing standards. Those standards require that we plan and  perform the audit to obtain sufficient, appropriate evidence to provide a  reasonable basis for our findings and conclusions based on our audit  objectives. We believe that the evidence obtained provides a reasonable  basis for our findings and conclusions based on our audit objectives. See  appendix I for more information about our scope and methodology.
subsections: section_title: Background
paragraphs: There is no single definition of transit-oriented development; however,  research generally describes such a development as a compact, mixed-use,  walkable neighborhood located near transit facilities. Research has  highlighted that most transit-oriented developments are typically near a  fixed-guideway rail station, generally encompass multiple city blocks up to  a half-mile from a transit station, have pedestrian-friendly environments  and streetscapes, and include high-density and mixed-use developments.  In addition, these developments may have fewer parking spaces compared  to more traditional developments because residents have easy access to  transit, and thus less need for an automobile. Transit-oriented  developments can range in both size and scope, with some being in  suburban neighborhoods with streetcars or bus rapid transit systems and  community-related services while others are located in major urban  locations with light, heavy, or commuter rail. Transportation experts  believe that transit-oriented developments can increase accessibility to  employment, educational, cultural, and other opportunities by promoting  transportation options to households, thereby increasing transit ridership  and reducing road congestion. Figure 1 provides a graphic representation  of a transit-oriented development, and appendix II provides a description  of various types of such developments.
Planning and development of a transit-oriented development and  affordable housing are driven largely by state and local governments,  transit agencies, and private developers. For example, state and local  government agencies provide many of the necessary infrastructures of  transit-oriented developments, including transit stations, connections to  other transportation modes, sidewalks, utilities, and other public  amenities. Local governments also create the zoning environment, which  may, for example, allow developers to build a mix of uses at higher  densities. Some of the key agencies involved and their principal roles are  summarized below.
State and local departments of transportation and metropolitan  planning organizations develop transportation plans and improvement  programs; and build, maintain, and operate transportation infrastructure  and services.
Local transit agencies, such as transit authorities or transit operators,  are responsible for building, maintaining, and operating transit systems.  These transit systems can include fixed-guideway transit systems—such as  light or heavy rail, and bus rapid transit—ferry systems, paratransit  services, and local bus service.
Local county and city governments, and regional councils, through  agencies such as county or city planning departments, have control over  land use planning, which includes zoning policies and growth management  policies. Regional councils develop land use plans used by metropolitan  planning organizations for transportation planning.
In addition, state housing agencies, local governments, and private and  nonprofit housing developers are the main stakeholders in building  affordable housing. Some of the key agencies involved include:    State housing development and financing agencies provide funding  for affordable housing through the Low Income Housing Tax Credit  (LIHTC) program—an indirect federal subsidy used to finance the  development of affordable rental housing for low-income households— and other state programs for affordable housing.
City and county housing departments are responsible for planning,  developing, and funding affordable housing. In addition, local housing  departments or agencies are required by federal law to develop local area  housing plans.
Local public housing authorities (PHA), normally created by state law,  typically manage a local region’s public housing units and federally  sponsored housing voucher programs.
Private for-profit housing developers and nonprofit housing  developers, such as community development corporations, build and  manage housing units.
FTA provides financial and technical assistance to local and state public  transit agencies to build, maintain, and operate public transit systems.  FTA’s New Starts program, its major capital investment program for new  and extensions to existing fixed-guideway transit systems—a key element  of transit-oriented developments—awards funds to individual projects  through a competitive selection process. Only a few systems are  recommended by FTA for funding in each fiscal year. FTA also provides  transit funding to state and local governments through formula grants,  which are funded entirely from the Highway Trust Fund’s Mass Transit  Account. These grants provide capital and operating assistance to local  transit agencies and states through a combination of five relatively large  and five relatively smaller grant programs, which FTA distributes via  formula grants. In addition, two programs administered by the Federal  Highway Administration, the Surface Transportation Program and the  Congestion Mitigation and Air Quality Improvement Program—also  referred to here as flexible funding programs—routinely provide state and  local transportation agencies flexibility in using funding for transit  projects by permitting a portion of the program funding to be transferred  for these purposes. A portion of flexible funding is allocated to localities  and metropolitan planning organizations rather than states, allowing local  authorities, acting through the metropolitan planning organization, to  select projects reflecting their jurisdictions’ priorities. Table 1 provides  additional information on these programs.
HUD generally provides rental housing assistance through three major  affordable housing programs—housing choice vouchers, public housing,  and project-based rental assistance. These three programs generally serve  low-income households—that is, households with incomes less than or  equal to 80 percent of area median income (AMI). Some of these  programs include targets for households with extremely low incomes—30  percent or less of AMI. HUD-assisted households generally pay 30 percent  of their monthly income, after certain adjustments, toward their unit’s  rent.
The Housing Choice Voucher program, which supports over 2 million  housing units and is administered by local PHAs, provides vouchers that  eligible families can use to rent houses or apartments in the private  housing market. Voucher holders are responsible for finding suitable  housing that meets HUD’s housing quality standards. The subsidies in the  voucher program are provided to the household (that is, tenant-based), so  tenants can use the vouchers in new residences if they move. The housing  subsidy is paid to the property owner directly on behalf of the  participating households. The household then pays the difference between  the actual rent charged by the owner and the amount subsidized by the  program. PHAs have some flexibility to determine the maximum amount  of rental subsidy they can pay for assisted households within limits set by  HUD. For example, HUD establishes “fair market rents” for each  metropolitan area, based on actual market rents for standard-quality rental  units, but PHAs may choose a “payment standard” that is up to 10 percent  lower or higher than the fair market rent.
The public housing program, also managed by PHAs through operating  and capital grants, subsidizes the development, operation, and  modernization of government-owned properties and provides units for  eligible tenants in these properties. In contrast to the voucher program,  the subsidies in the public housing program are connected to specific  rental units, so tenants receive assistance only when they live in these  units. HUD pays an operating subsidy, which helps to cover the difference  between the PHA’s operating costs and the rents the PHA collects from  tenants.
Through a variety of project-based programs including project-based  Section 8, HUD provides rent subsidies in the form of multiyear housing  assistance payments to private property owners and managers on behalf of  eligible tenants. Tenants may apply for admission to these properties with  project-based rental assistance contracts. HUD pays the difference  between the household’s contribution and the unit’s rent.
HUD also administers formula grant programs, such as the Community  Development Block Grant (CDBG) program and the HOME program,  which help low-income households obtain access to affordable housing.  These programs divide billions of dollars across local jurisdictions and  numerous activities on an annual basis using funding formulas pursuant to  statutory guidance. Activities funded by the CDBG program can include  housing, economic development, neighborhood revitalization, and  community development. The HOME program provides federal assistance  to participating jurisdictions for housing rehabilitation, rental assistance,  homebuyer assistance, and new housing construction. Recipients of CDBG  and HOME funding have a great deal of flexibility in how they use these  grants, and must fulfill HUD’s planning requirements to receive funding.
section_title: Transit-Oriented Developments Can Affect the Availability of Affordable Housing but Conclusions Are Complicated by Limited Research and Data
subsections: section_title: Characteristics of Transit- Oriented Developments Can Increase Nearby Land and Housing Values
paragraphs: According to most of the literature we reviewed, plans for the existence of  transit stations and amenities commonly found in transit-oriented  developments generally increase nearby land and housing values, but the  magnitude of the increase varies greatly depending upon several other  characteristics. The studies generally conclude that increases occur  because residents place a premium on land and housing the closer each is  to a transit station. Although the presence of transit generally affects land  and housing values, increases in some cases are modest, and results can  vary throughout an entire transit system depending on several  characteristics which are summarized below.
Retail development is common to the type of mixed-use development  found in transit-oriented developments because it allows residents to  avoid car trips for everyday shopping. A few studies we looked at found  that retail presence near transit stations affected land and housing values  near transit positively. One particular study found that the stations with  the highest increases in nearby housing values had a retail presence.
Neighborhood characteristics surrounding a transit station is another  factor the studies we reviewed have shown to be valued by transit users  and nontransit users resulting in increased land and housing values. The  studies we reviewed showed a number of neighborhood characteristics  such as higher relative incomes, and proximity to parks, schools, or other  neighborhood amenities. One of the goals often cited in research of  transit-oriented development is to create quality, desirable neighborhoods  that include many of these amenities.
Other factors that have been found to increase land and housing values  include proximity to job centers, pedestrian amenities, and quality or  frequency of transit service. For example, a study of California transit  systems found that increases in property values are more likely along  reliable, frequent, and fast transit systems in the San Francisco-Oakland  Area and San Diego than near more limited light rail service in Sacramento  and San Jose.
Conversely, some characteristics of areas near transit can limit increases,  or even cause a transit station to be a negative influence on land or  housing values. These characteristic include:    Non-transit-oriented land uses and prevalence of crime: In the San  Francisco-Oakland Area, studies found that a transit station generally has  a positive influence on land and housing values, except near certain  stations in a largely industrial area in Oakland. In addition, the study of  the Atlanta rail system found that the presence of crime limited increases  and sometimes even decreased land and housing values, particularly near  rail stations with an adjacent surface parking lot.
Poor economic environments: A study of Buffalo transit stations found  a premium value for real estate near stations in high-income areas, but a  negative effect on land and housing values near stations in low-income  areas. The authors conclude that these negative effects may be the result  of a lengthy economic decline and population loss in Buffalo, delayed  development, and a lack of job centers on the transit system rather than  the presence of the transit station.
section_title: Availability of Affordable Housing in Transit- Oriented Developments Varies Depending on Land and Housing Values, Local Decision Making, and Other Factors
paragraphs: Higher land and housing values generally tend to limit housing units  affordable for lower-income households but many other factors can also  affect the availability of affordable housing near transit and in transit- oriented developments. According to local officials and transit and  housing stakeholders we spoke with, higher land and housing values have  the potential to limit the affordable housing units that are market rate,  government subsidized, or incentivized. Increased land and housing values  can raise the market price of sale and rental housing beyond an affordable  percentage for households at or below an area’s median household  income, thus reducing the availability of market rate affordable housing.  Subsidized or incentivized affordable housing units can also be affected by  higher land and housing values. For example, if rents for units near transit  stations increase above fair market rents, tenant-based rental vouchers— provided through HUD’s housing choice voucher program—may be  insufficient to cover the increased rents.
Moreover, a recent study conducted by Reconnecting America and the  National Housing Trust highlighted that HUD project-based Section 8  contracts for many properties near transit stations will expire in coming  years. Nearly two-thirds of those buildings near transit in the eight cities  the study examined have contracts expiring by 2012. As the study  indicates, if contract holders believe that the increasing land values could  allow them to charge higher rents than the subsidy they receive from HUD  for participating in the Section 8 contract, the property owners may decide  not to renew the Section 8 contracts.
Increased values and land speculation can also potentially stifle  development of affordable or mixed-income housing projects. In several  places we visited, local officials and developers told us that higher land  costs can make it difficult for projects to meet profit expectations,  resulting in a preference for developers to market projects in transit- oriented developments to higher income households.
In addition to land and housing values, local officials told us that several  other conditions and local decisions can affect the availability of  affordable housing near transit. For example:    Local economic conditions can suppress land and housing values  proportionately more than the local median household income, resulting  in an increased supply of affordable housing units at market rate. For  example, officials in Cleveland told us that the weak local economic  conditions have led to an abundant supply of market rate units that are  affordable to people with low incomes. Therefore they are less focused on  increasing the stock of affordable housing units near the recently  completed Euclid Corridor Bus Rapid Transit, and more focused on  stimulating economic development and revitalizing the general housing  market.
Local transit station location decisions can also affect the availability  of affordable housing near transit. For instance, although housing  advocates and local officials raised concerns that as land values increase,  low-income households may be displaced, several local officials we spoke  with told us that new transit station locations were planned in corridors  with limited housing prior to the construction of the transit line. These  station locations were specifically placed in blighted or industrial areas or  railyards with relatively inexpensive land and plentiful space available for  infill developments. For localities committed to providing affordable  housing, new development near these transit stations provides  opportunities for new affordable housing near transit. For example,  officials in Washington, D.C., told us that some stations of the rail transit  system were aligned to support housing and economic development on  vacant or underutilized properties (see fig. 2).
Other transit lines can be aligned to serve populated, low-income  neighborhoods. Local officials told us that one of the goals of the Hudson- Bergen Light Rail was to provide better transit access to low-income  residents of Jersey City and Hoboken, New Jersey. The introduction of  light rail in the past decade, paired with longer-term, focused investment  of HUD affordable housing and revitalization dollars, has helped improve  the availability of quality, affordable housing near transit. While transit  lines can provide better transit access to low-income residents in the short  term—a key role of transit—housing advocates have raised concerns that  rents will increase in the long term, placing pressure on existing low- income residents.
State and local commitment to preserving or developing affordable  housing near transit can help ensure the availability of affordable housing  despite potential increases in land value. Local officials told us that some  tools—which we will discuss in greater detail in the next section—are  available to subsidize affordable units or to encourage developers to  provide affordable units to help counter higher rents and property values  near transit. In addition, coordinated state and regional planning also can  influence local governments’ support of affordable housing in transit- oriented developments, according to recommendations from recent  reports. For example, to overcome issues associated with increasing land  values and speculation, nonprofit organizations and regional and local  governments can invest in land along transit alignments with the intent to  develop the land in the future with an affordable housing component.
section_title: Limited Research and Data Complicate Conclusions about the Effect of Transit- Oriented Developments on the Availability of Affordable Housing
paragraphs: A lack of direct research, incomplete data, and factors unique to each  transit station limit the conclusions that can be made about how transit- oriented developments affect the availability of affordable housing. To  date, there has been little research that specifically links transit-oriented  developments to affordable housing, hindering the ability of policy makers  and private investors to make informed decisions or evaluate results. For  example, most of the studies we reviewed focused on land or housing  values near transit but did not distinguish between stand-alone transit  stations and transit stations in transit-oriented developments. In addition,  most studies did not directly measure the number of affordable housing  units, or otherwise quantify the availability of affordable housing, whether  it was market rate or subsidized. Moreover, the research that does exist on  land and housing values is typically focused on specific geographic areas  and does not distinguish among the effects of state and local commitment  to affordable housing and other factors that affect the availability of  affordable housing. Finally, many communities with relatively new fixed- guideway transit systems have limited experience with transit-oriented  developments, and often development—and any potential long-term  effects on the availability of affordable housing—has yet to fully take  hold.
The scarcity of reliable housing data and limitations in analytical  transportation planning methods also limit thorough study and evaluation  of the direct effect that transit-oriented developments have on the  availability of affordable housing. For example, HUD-subsidized housing  data—the only nationwide data available for subsidized housing—do not  provide a full and accurate picture of the availability of subsidized housing  for research purposes. According to HUD, funding recipients self-report  data for the locations of subsidized housing programs to local PHAs,  limiting HUD’s ability to ensure completeness and accuracy. In addition,  the data that are collected are primarily intended for administrative  purposes and HUD officials told us they think the data are sufficiently  reliable for administrative purposes. However, our analysis of the data  revealed that several quality concerns—including inconsistencies in data  over time—limit using the data for research purposes which involve  reliable long-term data analysis. HUD officials told us that a variety of  potential explanations existed for these inconsistencies including  transitions between reporting requirements having potentially caused  missing records as well as some records with missing geographic data.  For example, 32 PHAs were not required to submit data for Housing  Choice vouchers or public housing units from 2000 to 2006 due to  participation in the Moving to Work program. Figure 3 shows examples  of three geographic areas in which the number of HUD-subsidized housing  unit records changes significantly over time and in some cases from one  year to the next. While HUD’s Performance and Accountability reports  indicate there has been some variation in the overall number of HUD- subsidized units over time, the extent of change in figure 3 is not explained  by this variation. The lack of reliable and complete data would limit  analysis on the impacts of HUD investments for affordable housing near  transit. Furthermore, state and local governments—which provide  significant amounts of housing subsides—vary in the extent to which data  are collected, available, and reliable. The affordability of market rate  housing can also be affected by increases in land value in transit-oriented  developments; however the market rate housing datasets that do exist,  such as the American Housing Survey, do not record housing costs with  the detail, scale, or frequency needed to capture trends that may result  from transit-oriented developments. Our past work has also cited the  difficulties of accurately predicting changes in traveler behavior and land  use resulting from a transit project, as well as concerns about the quality  of data inputs into local travel models.
section_title: Local, State, and Federal Affordable Housing Programs and Policies Support, but Generally Do Not Require, Affordable Housing in Transit- Oriented Developments
subsections: section_title: Few Local and State Programs Are Specifically Targeted to Affordable Housing in Transit- Oriented Developments, and Most Are Incentive Based
paragraphs: Few local and state programs are targeted to assist local housing and  transit providers develop affordable housing in transit-oriented  developments; the few targeted programs that do exist mainly provide  financial incentives to developers if they include affordable housing in  new residential developments in transit-oriented developments. In our site  visits, we found examples in which local housing providers used these  targeted programs to either build new or preserve existing affordable  housing in transit-oriented developments. For example, California  allocated $285 million over a period of 3 years to the Transit-Oriented  Development Housing Program, which uses loans and grants to encourage  the development of housing development projects within one-quarter mile  of transit stations. The loans and grants are made available on a  competitive basis to affordable housing developers and local government  housing agencies that commit to build at least 15 percent of the units they  develop as affordable housing units. According to California officials, in  2008, $145 million was committed or awarded to 16 applicants, and over  1,800 affordable housing units will be created as a result of these awards.  In Portland, Oregon, the Transit-Oriented Development Property Tax  Abatement supports affordable housing on vacant or underutilized sites in  transit-oriented developments by reducing operating costs for affordable  housing property owners and developers through a 10-year maximum  property tax exemption. For 2007-2008, Portland reported that the tax  abatement program assisted 971 housing units resulting in over $1.3  million in foregone tax revenues for the city and county. Of these units,  279 have rents restricted for residents with incomes between 30 percent to  80 percent median family income. Finally, in Denver, Colorado, the city is  developing a transit-oriented development fund that will provide funding  to local affordable housing developers to preserve and create at least 1,200  affordable units for sale and rental along Denver mass transit corridors  over a 10-year period.
Many states use federal tax credits as a financial incentive to encourage  development of affordable housing near transit as well as specifically in  transit-oriented developments. States administer federal LIHTCs and  provide them to developers in accordance with state Qualified Allocation  Plans (QAP)—plans that states are required to develop which outline the  competitive process used to award these funds. In QAPs, most states use a  competitive points system to award LIHTCs. There is no statutory  requirement that a state incorporate proximity to transit into its QAP.  States that have either required or provided incentive points for proximity  to transit have done so independent of federal requirements. In these  states, incentive points can be earned if developments are within a certain  radius of public transit or in transit-oriented developments as designated  by a state or local authority. For example, New Jersey’s QAP awards an  additional point for proposed developments that are one-half mile from  public transportation, as well as up to 10 points for proposed  developments in Transit Villages, a designation given by New Jersey’s  Department of Transportation to transit-oriented developments. New  Jersey officials commented that since tax credits are awarded only to a  fraction of those that apply for them, developers consider these points a  strong incentive to propose projects that will earn the additional points for  proximity to transit. Appendix III provides examples of LIHTC programs  that contain proximity to transit incentives. Additionally, states can award  additional tax credits in HUD-designated high-cost areas. While HUD  designates high-cost areas, which could include transit-oriented  developments, states have the authority to designate buildings as being  located in areas which they determine as high cost, independent of the  areas designated by HUD. Oregon has used this authority to designate  affordable housing buildings in transit-oriented developments as high-cost  areas which require additional funding to be financially feasible.  Therefore, Oregon provides additional tax credits to projects located in  transit-oriented developments.
State and local governments we visited generally did not use incentives in  their local land use regulations or building codes to promote affordable  housing in transit-oriented developments. Rather, incentives and  requirements provide broad support for state and local governments to  promote affordable housing without regard to location. These can help  support the economic feasibility of affordable housing development by  using nonfinancial incentives—such as land use regulations and building  codes—and financial incentives—such as direct funding or financing  options. In addition to incentives, we found that a few state and local  governments have implemented certain requirements to include affordable  housing in new developments, but like most state and local incentives,  these requirements are not specifically targeted at affordable housing in  transit-oriented developments. Determining if these nontargeted  incentives and requirements have ensured the availability of affordable  housing in and near transit-oriented developments is difficult due to a  number of reasons described earlier.
subsections: section_title: Incentives
paragraphs: Density bonus permits allow developers to build more than the  maximum number of allowable units permitted by local code if they agree  to designate a certain number of units as affordable housing.
Parking reductions allow local governments to reduce minimum parking  requirements set forth in local building codes for developers that build  near transit. This incentive allows developers to build fewer parking  spaces and use the money saved from the reduced parking construction  costs to support additional affordable units.
Tax increment financing is used by local governments to encourage  economic development by issuing municipal bonds to subsidize  development, which are repaid using the incremental future tax revenues.  Some localities dedicate a portion of tax increment financing for  affordable housing.
Affordable housing trust funds are distinct funds set aside by cities,  counties, and states that dedicate sources of revenue to support affordable  housing development.
section_title: Requirements
paragraphs: Inclusionary zoning: Some states or localities may require that all new  housing developments, regardless of location, include a portion of units as  affordable housing. Some inclusionary zoning ordinances allow developers  to pay the local government for each affordable unit they choose not to  build.
Affordability requirements on publicly financed residential  development: Some state and local governments include affordable  housing requirements when they sell land to housing developers or when  any government financing is involved in the project.
We found examples from our site visits and other research where each  type of nontargeted incentive and requirement discussed above was being  used to support affordable housing in transit-oriented developments (see  table 2). Because developers (both for profit and nonprofit) are not  required to do so, developers may or may not take advantage of the  various state and local government incentives to build or preserve  affordable housing in transit-oriented developments.
section_title: HUD and FTA Programs Allow Local and State Agencies to Promote Affordable Housing near Transit, but Rarely Provide Direct Incentives to Target Affordable Housing in Transit-Oriented Developments
paragraphs: Local housing providers have used HUD programs in a number of cases to  support affordable housing in transit-oriented developments, however,  these programs support affordable housing in any location. HUD  programs, such as the CDBG and HOME programs, generally provide local  and state agencies with flexibility to tailor their housing spending  decisions to meet local needs. According to HUD officials, CDBG and  HOME grant recipients have flexibility in applying funds to local  initiatives, and in some locations we visited, local officials told us they  used these funds, among others, to increase affordable housing near  transit as part of a transit-oriented development plan.
A community development corporation in Washington, D.C., used  approximately $7 million in CDBG funds to rehabilitate or develop  approximately 800 units of affordable housing and generate economic  development as part of its efforts to revitalize the neighborhood around a  transit station.
In Hoboken, New Jersey, a local housing agency official highlighted the  flexibility in the CDBG program as an opportunity for the city to target  funding to best meet the city’s need to revitalize the existing housing stock  around new transit stations.
In Seattle, Washington, local housing agency officials allocated over $4  million in HOME program funds to subsidize 200 new affordable units in  four rental housing developments located in transit-oriented  developments.
Similarly, numerous other HUD programs, including project-based Section  8 and the Housing Choice Voucher program, can be used to support  affordable housing in transit-oriented developments, but according to  HUD officials, these programs have not been targeted specifically for  developing or preserving affordable housing in transit-oriented  developments. While project-based Section 8 assists more than 1.3  million low- and very-low-income families, during our site visits, local and  federal housing agency officials told us they had not prioritized the  renewal of project-based Section 8 contract housing in transit-oriented  developments. As highlighted earlier, a study found that some project- based Section 8 housing is located near rail stations—defined as within  one-half mile of existing or proposed rail stations—and that many of the  contracts for the properties near rail stations are set to expire before the  end of 2012. Housing experts have identified this as a potential problem  since Section 8 contract holders may not renew these contracts if they  believe the rents they could earn without the contract would be higher  than the rental subsidy they receive from HUD, thereby, reducing the  number of affordable units in these areas. The Housing Choice Voucher  program is also a significant source of HUD-subsidized affordable housing  that individuals can use for housing in transit-oriented developments.  However, this requires that individuals find units where the owner accepts  the voucher, which is set at the region’s fair market rent. HUD allows for  exceptions to be made to the fair market rent valuations in high-cost areas,  but HUD officials did not know of any exceptions that had been made  specifically based on rents in transit-oriented developments exceeding  HUD’s fair market rent valuations.
It is unclear the extent to which increases in market rate rents that may  occur in transit-oriented developments have affected subsidized housing,  such as project-based Section 8 properties and rental vouchers. In transit- oriented developments, consideration of ways to ensure that project-based  Section 8 contract units remain affordable and rental vouchers remain  viable may be integral to ensuring the ongoing availability of affordable  housing in transit-oriented developments. However, as described earlier,  HUD’s data for its subsidized housing programs have limitations. These  limitations do not permit a comprehensive analysis of the HUD-subsidized  housing units located in transit-oriented developments. In addition, HUD  has not assessed the effects of its policies and programs in supporting the  availability of affordable housing in transit-oriented developments.  Without such analysis grounded in reliable data, it will be difficult for HUD  to assess how its programs might help to ensure the availability of  affordable housing in transit-oriented developments.
While most HUD programs do not consider a connection between housing  and transit in the program criteria, some HUD programs do provide  incentives for building affordable housing near transit, but not specifically  in transit-oriented developments. For example, the Neighborhood  Stabilization Program, funded by the American Recovery and  Reinvestment Act of 2009, provides competitive grants to states, local  governments, and nonprofits to address the damaging economic effects of  properties that have been foreclosed and abandoned. Of the funds to be  awarded to successful applicants of this program, 25 percent must be used  for the purchase and redevelopment of abandoned and foreclosed-upon  homes and residential properties to house individuals and families whose  incomes do not exceed 50 percent of AMI. Under the program’s  competitive scoring criteria, applications for projects that are transit  accessible will be awarded additional points. Also, Sections 202 and  811—multifamily programs for the elderly and people with disabilities,  respectively—consider proximity to transit in their selection criteria. HUD  officials from one region noted that the location of multifamily projects is  determined by many other factors, such as land prices, which have a  greater impact in the rating process than access to transit. HUD’s HOPE VI  program, which funds the redevelopment of obsolete public housing, also  has a formal link between public housing and transit. If public housing  locations that are selected as HOPE VI redevelopment sites lack sufficient  transportation to services and employment, then project plans for  revitalization must include increased access to transportation.
Since FTA’s core mission is to support locally planned and operated public  transportation systems, we found that FTA policies that allow local transit  agencies to support affordable housing in transit-oriented developments  are limited and still have a statutory requirement to support transit use.  Under FTA’s Joint Development Guidance, local transit agencies can use  land that was purchased with FTA funds to support transit-oriented  developments through joint development partnerships. With FTA  approval, local transit agencies can improve this property through  incorporation of private investment, including commercial or residential  development (to include affordable housing), as long as the transit agency  can demonstrate that the development supports transit. To receive FTA  approval, the local transit agency must demonstrate that the joint  development project provides an economic link, public transportation  benefits, revenue for public transportation, and reasonable share of costs  (if applicable). The current Joint Development Guidance seeks to allow  the maximum flexibility to transit agencies under the law when  undertaking joint development purposes. Of four FTA regions we  contacted regarding their approved joint development projects, FTA  officials identified a total of 11 approved projects, of which four were used  by a local transit agency to support the development of affordable housing  as part of a transit-oriented development. Portland, Oregon’s transit  agency had three of the approved projects, including a recent project  which included the development of 54 affordable housing units. In  Portland, the transit agency used land it had purchased for construction  staging areas as part of a New Starts-funded transit development for a joint  development project. When construction of the transit stop was  completed, the agency sold the land to a developer with the condition that  affordable housing be part of the development. In two of our site visit  locations, we heard from local transit agency officials that the guidelines  for the Joint Development Program policy are unclear and that further  clarification would assist them in supporting transit-oriented development  through joint development partnerships with the private sector. According  to FTA officials, an FTA task force is clarifying the eligible activities that  can be supported through the provisions and applications of this policy.
While FTA’s New Starts Program considers mobility improvements for  riders—which includes consideration of the lowest socioeconomic group  of transit dependent residents—and economic development benefits of  proposed New Starts projects, FTA currently does not weigh these criteria  in its overall project rating. In a number of our site visit locations, local  transit agencies planned to implement components of transit-oriented  development around one or more of the transit stations that were part of  the transit project funded by New Starts. Some local government transit  officials we interviewed and literature we reviewed described the benefits  of transit-oriented development—which includes components such as  higher-density and mixed-use projects of commercial and residential  activity—as potentially including economic development.
However, many of the local transit agencies we met with commented that  although they viewed the transit stations as anchors for economic  development, they did not believe the New Starts project evaluation  criteria fully assessed the project’s impact from economic development  activities. In a previous report, we also found transit stakeholders who  expressed concern about how economic development is considered in the  New Starts project evaluations. When we discussed this with FTA  officials as part of our current review, they discussed the challenges of  capturing economic development benefits and separating those benefits  from the measures included under the transit supportive land use  criterion. FTA officials acknowledged the limitations of its current  approach, but noted that FTA has been working with the transit industry  to develop a more robust methodology for measuring economic  development effects. FTA officials explained that the transit industry has  not yet reached consensus on the best way to measure economic  development effects that would be useful in meaningfully distinguishing  between projects and would not require extensive new data collection and  reporting by project sponsors. The FTA officials also said a quantitative  approach could require significant additional time and contractor  resources for both project sponsors and FTA.
Some HUD and FTA regional officials noted they support having  affordable housing in close proximity to transit but they emphasized that  local governments have jurisdiction over land use planning and determine  priorities for the development of affordable housing and transit.  Recipients of either certain HUD or DOT program funding must fulfill  planning requirements calling for them to focus on either community  development and affordable housing issues for HUD funding or  transportation issues for DOT funding. The requirement for local and  state agencies to integrate housing and transportation issues in these  planning activities, however, is minimal. Guidelines for the Consolidated  Plan required by HUD urge jurisdictions to coordinate with other local  plans, which may include metropolitan-wide plans that address issues  such as transportation. Some officials from HUD and local agencies  receiving HUD funding noted that guidance on the Consolidated Plan was  not significant in integrating affordable housing and access to transit. DOT  requires states and metropolitan areas, through their metropolitan  planning organizations, to develop long-range and short-term  transportation plans, which includes planning for transit. These  transportation plans are also limited in integrating housing into  transportation planning. In some regions, HUD officials told us they attend  local or regional planning meetings, but their role is limited to observing or  providing guidance on HUD programs. Similarly, DOT officials said that  FTA officials provide guidance to states, metropolitan planning  organizations, and transit agencies regarding FTA program and planning  requirements, but do not influence decision making related to  transportation plans and programs. HUD and DOT have recently  considered ways to strengthen integrated housing and transit planning, as  described in more detail later in this report.
section_title: Local Governments and Developers Encounter Challenges in Supporting Affordable Housing in Transit-Oriented Developments
paragraphs: According to transit and housing agency officials and stakeholders we  interviewed, infrastructure and economic conditions can present  challenges to supporting affordable housing in transit-oriented  developments. Some local housing agency officials told us that in some  areas where land values are higher (and irrespective of proximity to  transit) the high cost of land acquisition made it economically unfeasible  for a developer to build affordable housing units. As discussed earlier,  several studies we reviewed show that the presence of a transit station, as  well as factors associated with transit-oriented developments, generally  increase the value of land near the transit station. Based on their  experiences, some affordable housing providers we interviewed  commented that the value of land near a transit station rose quickly with  the announcement of the station’s opening. Therefore, affordable housing  providers told us they may require additional financial support from  government agencies to support affordable housing units in close  proximity to transit stations and in transit-oriented developments. Local  affordable housing providers often referred to land banking as another  tool to address the challenge of land acquisition in high-cost areas.  Affordable housing developers land bank when they purchase land at a  low cost in anticipation of future increases in land values, thereby  lowering land acquisition costs and using the additional funds on  affordable housing. Many officials told us, however, they had limited  opportunities to practice land banking for affordable housing development  due to limited resources and available land near transit.
According to local affordable housing providers and experts, the ongoing  economic slowdown has contributed to a slowdown in the construction of  new housing, including affordable housing. Specifically, they noted that  the ongoing economic slowdown has caused LIHTCs to be less valuable,  which may lead to less funding for affordable housing. Tax credits are  allocated to affordable housing developers, who typically sell the credits  to private investors, who then use the tax credits to offset taxes otherwise  owed on their tax returns. Generally, the money private investors pay for  the credits is paid into the projects as equity financing. This equity  financing is used to fill the difference between the development costs for a  project and the non-tax-credit financing sources available, such as  mortgages that could be expected to be repaid from rental income.  Financial institutions with limited resources have been buying fewer tax  credits, and as a result prices for tax credits have dropped and funding  available for affordable housing has declined.
Local housing officials we spoke to also described aspects of federal  policy and programs that may limit the programs’ use for supporting  affordable housing in transit-oriented developments. One source of  financial support, the LIHTC program, has some specific provisions that  limit its use in developing affordable housing in transit-oriented  developments. Specifically, the amount of tax credits for which a  development project is eligible is based in part on the amount of  development costs for the project. But, the development costs used to  calculate the amount of tax credits excludes the cost of acquiring land and  higher land costs may be associated with transit-oriented development.  This can potentially make LIHTCs less valuable for developers building  affordable housing in transit-oriented developments. Developers may  receive financial assistance through the CDBG and HOME programs to  acquire land as part of LIHTC projects. Also, as described earlier, states  may designate transit-oriented developments as high-cost areas, allowing  them to allocate additional tax credits to affordable housing developments  in such areas. Another aspect of the LIHTC program which may limit its  use in transit-oriented developments is that the maximum tax credit  allowed for each project is based on the development costs allocated to  only those units that are designated for low-income residents. Since tax  credits are applied only to those units in the housing development that  qualify as affordable, there is an incentive for developers to plan for as  many affordable units as possible, making mixed-income developments  relatively less competitive in this regard. However, some transit-oriented  development studies have cited the benefits of mixed-income housing in  transit-oriented developments. Some states appear to be addressing this by  prioritizing mixed-income housing for tax credits in their QAPs.
In some cases local transit agencies we contacted described the challenge  of selling surplus land—purchased using federal funds—for affordable  housing development near transit. Transit officials said they had explored  the possibility of selling the land at a low cost to affordable housing  developers to increase the availability of affordable housing in transit- oriented developments. However, they cited the requirement to sell this  land at fair market value as a potential barrier to selling the land at a low  cost in order to make it more feasible for the development of affordable  housing in high cost areas. According to FTA officials, transit agencies  may dispose of real property through sale, using competitive sale  procedures to the extent practical, which yield the highest possible value  return. In certain circumstances, transit agencies may transfer the  property for purposes such as affordable housing joint development.
section_title: DOT, HUD, and FTA Have Collaborated on Interagency Efforts to Promote Affordable Housing in Transit- Oriented Developments, However, Implementation Has Been Limited, and Additional Steps to Enhance Collaboration Could Be Taken
subsections: section_title: HUD and FTA, and More Recently DOT, Have Collaborated on Interagency Efforts to Promote Affordable Housing in Transit- Oriented Developments
paragraphs: Starting in 2005, HUD and FTA, and more recently DOT, have collaborated  to promote affordable housing in transit-oriented developments through  three interagency efforts, which are summarized below.
Interagency agreement: In 2005, HUD and FTA entered into an  interagency agreement to assist communities in understanding the  potential demand for housing in transit-oriented developments by  conducting a research study. The agreement identified five major research  objectives, including (1) increasing the understanding of the potential for  incorporating housing—including affordable or mixed-income housing— and homeownership in transit-oriented developments; (2) enhancing data  analyses and communities’ geographic information system capacity for  developing and building affordable housing adjacent to transit-oriented  developments; (3) identifying federal, state, and local policies and future  research that can influence linking affordable housing and transit-oriented  developments; (4) quantifying the factors that facilitate the development of  affordable housing in transit-oriented developments; and (5) identifying  regulatory barriers to building affordable housing in transit-oriented  developments. To address these research objectives, HUD and FTA funded  the Center for Transit-Oriented Development (CTOD) to conduct this  research study and publish a final report. The final report, which was  published in April 2007, recommended broad approaches to addressing  some key challenges in supporting affordable housing in transit-oriented  developments, including high land prices around transit stations, complex  financing structures of mixed-income and mixed-use developments, and  limited funding for building new affordable housing.
HUD-FTA action plan: In December 2007, the Appropriations  Committees indicated that HUD and FTA should jointly address new and  better ways for promoting affordable housing near transit service and  develop a best practice manual to assist communities that seek to  establish mixed-income transit-oriented developments. In response to  this request, HUD and FTA jointly developed an action plan to better  coordinate their respective programs to promote affordable housing in  transit-oriented developments, expand mixed-income and affordable  housing choices in the immediate proximity of new and existing transit  stations, develop a more comprehensive approach to address housing and  transportation expenditures, and preserve existing affordable housing  near transit. The HUD-FTA action plan outlines 11 strategies—including  the development of the best practices manual for local governments to  successfully promote mixed-income housing and transit-oriented  developments—that HUD and FTA say they will implement from fiscal  year 2008 through fiscal year 2010. Some strategies are focused on  increasing education for housing and transit stakeholders and reviewing  current housing and transit policies and regulations.
Partnership for Sustainable Communities: In March 2009, DOT and  HUD announced the Partnership for Sustainable Communities, which  seeks to help American families gain better access to affordable housing,  more transportation options, and lower transportation costs by  coordinating federal programs. Since the partnership’s original  announcement, the Environmental Protection Agency (EPA) has joined  the partnership. As part of this partnership, the agencies have highlighted  six livability principles that will serve as the partnership’s foundation.  While these six livability principles establish some broad goals, including  increasing transportation options to address climate change and  supporting existing communities, a major component of the partnership is  promoting affordable housing. To support this partnership, the  Secretaries of DOT and HUD and the EPA Administrator have created a  high-level interagency task force, led by DOT’s Deputy Assistant Secretary  for Transportation Policy, the Senior Advisor to the HUD Deputy  Secretary, and the EPA Director for the Development, Community and  Environment Division. For example, the high-level interagency task force  is charged with collaborating in developing a federal funding program,  called the Sustainable Communities Initiative, to encourage local  governments to integrate their regional housing, transportation, and land  use planning and investments by funding grants for local governments to  reform their current zoning, building codes, and land use codes. This  Sustainable Communities Initiative will be administered by HUD under the  proposed Office of Sustainable Development and in consultation with DOT  and EPA. The President’s fiscal year 2010 budget request for HUD includes  $100 million in Regional Planning Grants, $40 million for Community  Challenge Grants, and $10 million for joint DOT and HUD research efforts  in its fiscal year 2010 budget. The partnership will also fund joint DOT,  HUD, and EPA research and evaluation efforts and work to align the  respective agency programs. In addition, a joint HUD-FTA working group,  which was originally formed as part of the HUD-FTA action plan, will be  one of several individual working groups that will support the  DOT/HUD/EPA high-level interagency task force in implementing the  partnership. According to HUD officials, the partnership is intended to  supersede and incorporate the activities contemplated by the HUD-FTA  action plan.
Based on our review, the three interagency efforts outlined a number of  similar strategies and recommendations. For example, the CTOD report  recommended that HUD explore regulatory and policy approaches that  may increase the supply of affordable or mixed-income housing within  transit corridors—a strategy outlined in the HUD-FTA action plan. In  addition, all three interagency efforts have recommendations or strategies  that encourage local jurisdictions to better integrate and coordinate their  housing and transportation planning and to conduct research to better  measure affordability. Table 3 provides a summary of recommendations  and strategies made by the three interagency efforts.
section_title: HUD and FTA Collaboration Has Not Yet Affected Federal Support to Local Housing and Transit Agencies
paragraphs: Although HUD and FTA’s collaboration has produced numerous  recommendations and strategies to promote affordable housing in transit- oriented developments, local officials told us these efforts have had little  impact on local housing and transit agencies’ planning and decision  making. As we mentioned above, because housing and transportation  planning and decision making is done by state and local jurisdictions,  many of these recommendations and strategies could affect how local  housing and transit agencies use federal programs to support their  activities. However, since many of these strategies are relatively new and  have yet to be implemented, it may be too soon to evaluate their  effectiveness.
Furthermore, our review of the HUD-FTA action plan shows that while  some of the strategies identify specific products or other deliverables— such as publishing a best practices manual in fiscal year 2010 or  developing an outreach plan—many other strategies require additional  research and analysis before any actual change to current federal policy or  programs could be made. For example, both the CTOD report and the  HUD-FTA action plan recommend identifying regulatory barriers to  promote affordable housing in transit-oriented developments and  identifying a range of incentives that could be adopted to support efforts  to include affordable housing in such developments. And while HUD has  recently issued two competitive task order requests to implement some of  the strategies, including identifying regulatory barriers identified in the  HUD-FTA action plan, it will still take some time before these strategies  can potentially benefit housing and transit agencies. For example, under  the terms of the first contract, three policy reports assessing—(1) state,  federal, and local regulatory barriers to mixed-income housing in transit- oriented developments; (2) financing techniques available for mixed- income housing in transit-oriented developments; and (3) incentives  through HUD and FTA programs—are due to be completed and published  by July 1, 2010, almost 3 years after this assessment was first  recommended by the CTOD report. Once the agencies have identified the  regulatory barriers, they need to take additional steps—some of which,  such as public notice and comment periods, take time—to address those  barriers. Furthermore, HUD and FTA must identify which areas may  require congressional action to revise current statutory requirements. In  addition, the second contract solicits the development of a model  transportation and housing plan that can be utilized as a template by local  jurisdictions; however, this plan is not expected to be completed until  March 2011.
Because several strategies in both the HUD-FTA action plan and the  Partnership for Sustainable Communities have no detailed implementation  information available, it is unknown when and how these strategies could  impact local housing and transit agencies. In our prior work examining a  variety of federal programs, we have highlighted the importance of having  implementation plans to build momentum and show progress from the  outset. For the Partnership for Sustainable Communities, the President’s  fiscal year 2010 budget request for HUD includes $150 million for the  Sustainable Communities Initiative. As part of this initiative, $100 million  is allocated for the proposed Regional Integrated Planning Grants  program, which will award grants to local metropolitan areas or states that  integrate their regional transportation, housing, and land use planning and  investment. However, this budget has not been approved and therefore, no  detailed information is available regarding the components of this program  or how this program will be implemented. An example of the steps that  HUD, in consultation with DOT and EPA, may need to take to implement  this type of grant program can be seen with DOT’s recent implementation  of a similar type of grant program, the new Urban Partnership Agreement  initiative. This initiative—a competitive grant program intended to  demonstrate the feasibility and benefits of comprehensive, integrated, and  innovative approaches to relieving congestion—illustrates the many steps  required to implement a competitive grant program. DOT issued a Federal  Register notice soliciting proposals for the Urban Partnership Agreement  Initiative, set requirements for applications, created a multistep review  process, and established terms and conditions of the agreement.  However, because there is no detailed information available on the  proposed Regional Integrated Planning Grants program, it is unclear how  grants will be awarded or when the program will be finalized. In addition,  HUD and FTA officials stated they are still working to determine whether  there will be any link between these competitive grants under the  Sustainable Communities Initiative and the HUD-FTA development of a  transportation and housing planning model.
Finally, local housing and transit agencies with whom we met were  generally unaware of the collaboration between HUD and FTA. Many of  the local housing and transit agencies officials we interviewed stated they  were not aware of the HUD-FTA action plan or that HUD and FTA had  been working on this project. In addition, as part of our site visits, we  interviewed officials from HUD regional and field offices and FTA regional  offices. During these visits, we found that most of these regional officials  had not received official copies of the HUD-FTA action plan, were  unaware that the action plan was posted on the agencies’ Web sites, and  most were generally unaware of the plan’s strategies. In addition, HUD and  FTA headquarters officials noted that only headquarters staff were  involved in the development of the action plan and did not receive any  formal input from regional officials or local housing and transit agencies.  We have highlighted in prior GAO reports that other federal agencies reach  out to key stakeholders to collect input from stakeholders and gain  support for the program both during the development of the program and  during its implementation.
section_title: DOT, HUD, and FTA Have Started Using Some Key Practices for Enhancing and Sustaining Collaboration, but a More Formal Approach and Other Practices Could Encourage Further Collaboration
paragraphs: Key practices for enhancing and sustaining collaboration could be used to  help the agencies implement the HUD-FTA action plan and the recently  announced Partnership for Sustainable Communities. We have reported  before that federal agencies often face a range of barriers when they  attempt to collaborate with other agencies, including missions that are not  mutually reinforcing, concerns about protecting jurisdictions over  missions and controls over resources, and incompatible procedures,  processes, data, and computer systems.  In our October 2005 report, we  identified eight key practices federal agencies can undertake to overcome  these barriers and enhance and sustain their collaborative efforts. Table  4 summarizes the key practices and extent to which DOT, HUD, and FTA  are using these key practices. While these practices can facilitate greater  collaboration among federal agencies, we recognize that other practices  may also help to foster greater collaboration. In addition, while the  specific ways in which agencies implement these practices may differ in  light of the specific collaboration challenges each agency faces, we have  previously recommended that federal agencies adopt a formal approach— to include practices such as a memorandum of agreement or formal  incentives focused on collaboration signed by senior officials—to  encourage further collaboration.
In comparing the agencies’ collaboration—through the interagency  agreement, the HUD-FTA action plan and the Partnership for Sustainable  Communities—to these key practices, we found that the agencies have  taken some initial actions that are consistent with some of the key  practices; however, these actions have not been fully formalized. Even  though some of the interagency efforts are still in the early stages—such  as the HUD-FTA action plan and the Partnership for Sustainable  Communities—and implementation has only recently started,  collaboration between the agencies started back in 2005 with their  interagency agreement.
The agencies have started defining and articulating a common outcome,  through the three interagency efforts, to highlight a compelling rationale  for why the agencies have to collaborate, by establishing some goals for  their collaboration efforts. These goals include expanding mixed-income  and affordable housing choices near transit, developing a more  comprehensive approach on housing and transportation affordability, and  preserving existing affordable housing. However, the development of a  common outcome takes place over time and requires sustained resources  and commitment by both agencies staff. The agencies have only recently  begun allocating resources to implementing the strategies and  recommendations produced by the efforts and assigning staff to work on  the various interagency working groups to implement these strategies and  recommendations.
The agencies have identified and taken steps to establish mutually  reinforcing or joint strategies that were developed in both the HUD-FTA  action plan and the Partnership for Sustainable Communities. For  example, the HUD-FTA action plan calls for identifying opportunities for  joint research and development, improving coordination of local housing  and transportation planning through federal housing and transportation  programs, and identifying financial incentives to local communities  through both HUD and FTA funding programs. By establishing these  reinforcing strategies, the agencies can align core processes and resources  to accomplish the common outcome. However, while the agencies have  started implementing some of these reinforcing strategies, such as  awarding the contract to prepare an outreach plan, and have recently  adopted a shared set of principles, a number of these efforts require  additional research and analysis, and therefore, it is too soon to determine  how the agencies will integrate these reinforcing strategies into current  agency processes and resources.
HUD and FTA have identified and started leveraging resources needed to  initiate or sustain their collaboration efforts by allocating funding to start  implementing a number of the HUD-FTA action plan strategies and  proposing funds for the Partnership of Sustainable Communities, through  the proposed Sustainable Communities Initiative in the fiscal year 2010  HUD budget. In addition, the agencies have assigned staff to work on the  interagency task force and have established four interagency working  groups to work on a number of items, such as developing performance  measures and identifying barriers to coordinated housing and  transportation investments. However, the most significant resource  investment, $150 million for the Sustainable Communities Initiative, has  not yet been approved by Congress, and therefore, the initiative’s final  budget is unclear.
The agencies have started to define and agree on their respective roles  and responsibilities, and in doing so, are beginning to clarify who will do  what, identify how to organize their joint and individual efforts, and  facilitate their decision making. For example, under the Partnership for  Sustainable Communities, DOT and HUD have formed an interagency task  force to implement the specific programs and policies of the initiative and  plans to have HUD administer the Regional Integrated Planning Grants  program, in consultation with DOT, EPA, and other federal agencies.  However, while the DOT-HUD high-level interagency task force has  conducted numerous meetings, and has scheduled future meetings, to  discuss goals, objectives, implementation issues, and establish working  groups, the agencies have yet to formally determine and document how  specific roles and responsibilities will be divided.
There have been actions taken to reinforce agency accountability through  strategic and annual performance plans. For example, our review of both  agencies’ recent strategic and annual performance plans found that while  only HUD had included the collaboration efforts with FTA in its 2008  annual performance review, officials in both agencies noted they would be  updating their strategic plans and annual performance plans to include  their collaboration efforts.
Based on interviews with HUD and FTA officials, there are several other  key collaboration practices the agencies have not yet begun to implement.  These key practices include establishing compatible policies, procedures,  and other means to operate across agency boundaries; developing a  mechanism to monitor, evaluate, and report results; and reinforcing  individual accountability for collaborative efforts through performance  management systems. Adopting each of these key practices could enhance  the agencies’ collaboration, and the effectiveness of both the HUD-FTA  action plan and the Partnership for Sustainable Communities.
For example, in each of the interagency efforts, strategies and  recommendations call for increasing research and development between  the agencies. In the HUD-FTA action plan, the agencies have identified  eight specific topics for joint research to include development of tools,  techniques, and methods for addressing housing and transportation  expenditures, improving the use of geographical information systems, and  monitoring and assessing the effectiveness of policies and tools that have  been deployed to promote mixed-income housing in transit-oriented  developments. To facilitate this collaboration, the agencies need to  address the compatibility of standards, policies, procedures, and data  systems that will be used. However, according to HUD and FTA officials,  there has been no assessment on whether any compatibility exists or can  be established.
The HUD-FTA action plan calls for the joint HUD-FTA working group to  develop performance measures and an associated management  information system which, in part, would require that HUD and FTA  determine if there are reliable data available for assessing the  effectiveness of the results of joint actions taken by the two agencies. This  is in line with a key practice to develop a mechanism to monitor,  evaluate, and report results. In addition, we have previously reported that  the annual performance planning processes under the Government  Performance and Results Act (GPRA) allow agencies to foster greater  collaboration by ensuring that collaborating agencies’ individual program  goals are complementary and, as appropriate, common performance  measures are used. However, agency officials reported that there has  been no effort to establish a monitoring system or to determine whether  current data systems would be able to provide reliable data that would be  needed to identify areas for improvement. In addition, as we stated above,  the current scarcity of reliable housing data and limitations on transit  modeling would need to be addressed to make sure the agencies develop  an effective performance measurement system.
Agencies can strengthen collaboration by reinforcing individual  accountability through their performance management systems. HUD and  DOT officials stated they have not implemented any changes to their  performance management systems to reflect better coordination efforts  between their respective agencies’ staffs.
Inherent to each of these eight practices, factors such as leadership and  trust are key to establishing collaborative working relationships. These  factors can foster a collaborative culture and therefore help agencies  overcome the barriers they face when they attempt to collaborate. In  addition to these eight practices, there are other management tools  available that can foster greater collaboration among federal agencies. For  example, GPRA, with its focus on strategic planning, the development of  long-term goals, and accountability for results, provides a framework that  Congress, the Office of Management and Budget, and executive branch  agencies can use to consider the appropriate mix of long-term strategic  goals and strategies needed to identify and address federal goals that cut  across agency boundaries.
section_title: Conclusions
paragraphs: One way to assist lower-income households, which are generally more  transit dependent and thus more vulnerable to increased housing and  transportation costs, is to increase the availability of affordable housing in  transit-oriented developments. Since state and local governments are the  main providers of affordable housing and transit services, they are on the  front line of this issue. From our site visits and review of relevant studies,  we found that some communities have programs and policies that  specifically promote affordable housing in transit-oriented developments,  but most do not. Therefore, many communities that choose to build or  preserve affordable housing near transit-oriented developments rely on  broader affordable housing programs and other incentives that can be  used wherever the development is located.
With HUD and FTA focusing on their individual core missions and, until  recently, promoting affordable housing and transit separately, these  agencies have not generally attempted to link federal housing and  transportation programs. Furthermore, while there are federal  requirements for both housing and transportation planning, traditionally  these plans have not been integrated. In fact, some program requirements  (such as the LIHTC) may limit the development of affordable housing in  transit-oriented developments. Starting in 2005, HUD and FTA have  collaborated to develop strategies for better coordination of their  respective programs with the goal of helping to provide more affordable  housing in transit-oriented developments. The strategies that HUD and  FTA, and more recently DOT, have developed are in line with what  housing and transit stakeholders have stated can assist local communities,  and address some current weaknesses we found in the two agencies’  independent programs and policies. While these strategies have the  potential to assist local communities better link housing and  transportation programs, only a few strategies—such as the best practices  manual—have the potential to provide assistance in the near term. Many  strategies, such as identifying regulatory barriers and financial incentives,  still require additional research and analysis and others have only just  been announced. In particular, any areas that may require congressional  action to revise current statutory requirements may require the agencies to  take additional steps. Without an implementation plan for each strategy,  however, DOT and HUD run the risk of losing momentum. Given the  number of steps and time it may take to implement the various strategies,  including the proposed new regional planning grants, it will be important  to establish an implementation plan that encompasses the various  strategies in order for HUD and DOT to be better positioned to implement  each of their strategies as their interagency efforts progress. The scarcity  of reliable housing data and the limitations on transit modeling also limit  the ability of DOT, HUD, and FTA to determine whether current and future  efforts are ensuring the availability of affordable housing in transit- oriented developments. Therefore, without development of better data and  data systems, which are key elements of any performance measurement  system, the agencies will not have the information necessary to determine,  among other things, whether they need to increase coordination or adjust  existing strategies.
In addition, when comparing the agencies’ collaboration to the key  practices we have previously identified, we found that the agencies have  taken actions that are consistent with some of the practices. However, the  agencies had not taken actions on a number of practices—such as  reinforcing individual accountability for collaborative efforts or  developing mechanisms to monitor, evaluate, and report on results.  Furthermore, without a formal approach to collaboration for all of the key  practices, DOT, HUD, and FTA may miss opportunities to effectively  leverage each other’s unique strengths to promote affordable housing in  transit-oriented developments.
section_title: Recommendations for Executive Action
paragraphs: To strengthen formal collaboration efforts, we recommend that the  Secretary of Transportation should direct the Administrator of the Federal  Transit Administration, and the Secretary of Housing and Urban  Development should direct the appropriate program offices, to take the  following three actions:    Develop and publish an implementation plan for interagency efforts to  promote affordable housing in transit-oriented developments, to include  the HUD-FTA action plan and the Partnership for Sustainable  Communities. This plan should include, but not be limited to, a project  schedule, resource allocation, outreach measures, and a performance  measurement strategy.
Develop a plan to ensure that data collected on the various programs of  the agencies related to affordable housing and transit are sufficient to  measure the agencies’ performance toward goals and outcomes  established in the HUD-FTA action plan and the Partnership for  Sustainable Communities.
Adopt a formal approach to encourage further collaboration in promoting  affordable housing in transit-oriented developments. Such an approach  could include establishing and implementing a written agreement to  include defining and articulating a common outcome; establishing  mutually reinforcing or joint strategies; identifying and addressing needs  by leveraging resources; agreeing on agency roles and responsibilities;  establishing compatible policies, procedures, and other means to operate  across agency boundaries; reinforcing agency accountability for  collaborative efforts through agency plans and reports; and reinforcing  individual accountability for collaborative efforts through performance  management systems.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided draft copies of this report to the Secretary of Transportation  and the Secretary of Housing and Urban Development for their review and  comment. DOT generally agreed to consider the recommendations in this  report, and provided technical comments, which we incorporated, as  appropriate. We also received technical comments from HUD that we have  incorporated as appropriate. In written comments, HUD’s Director of the  Office of Departmental Operations and Coordination stated that HUD  would consider the findings and recommendations of the report carefully  as the agency continues its efforts to combine housing and transportation  funds and resources near transit. The Director’s letter is reprinted in  appendix IV. Discussed below are the additional comments HUD had with  certain aspects of the report and our response.
First, HUD stated that the definition of affordable housing used in the  report is overly narrow in that we focused on subsidized housing and that  affordable housing goes beyond subsidized housing for low- and moderate- income families. However, the definition of affordable housing used in the  draft report is not limited to subsidized housing.  Nor does the report  suggest that subsidized housing is the only source of affordable housing;  however, as we state in the report, national data on all affordable housing  in transit-oriented developments are limited and there has been little  research that specifically links transit-oriented developments to affordable  housing. HUD also noted that we did not sufficiently look at the combined  cost of housing and transportation, as a measure of affordability. We agree  that the combined costs of housing and transportation are an important  indicator of housing affordability and noted in our draft report that some  organizations have worked to establish a link between housing and  transportation costs by developing new measures of affordability.  However, determining transit-oriented developments’ effects on  affordability—as defined by combined housing and transportation costs— is complicated due to a lack of national data including reliable data on  subsidized housing.
Second, HUD commented that it has made significant progress on  coordinating housing and transportation under the Partnership on  Sustainable Communities. HUD cited some specific actions it has taken,  including developing the six livability principles announced in June and  creating four working groups to implement the partnership. While our  draft report did mention these efforts and recognized other actions the  agencies have taken consistent with some of the key practices for  collaboration, we have added some additional discussion of the six  livability principles and the four working groups. However, we believe that  we correctly assessed the level of progress made by the agencies and  maintain that to sustain their initial efforts, it will be important for the  agencies to meet the principles of interagency collaboration, which we  discuss in the report.
Lastly, HUD noted that we overstated the issues associated with accuracy  of HUD data on subsidized households. HUD stated in its comments that  the data collected on subsidized housing are primarily intended for  administrative purposes and may be sufficiently reliable for administrative  purposes. We acknowledge in our report that HUD officials told us that the  data are collected primarily for administrative purposes but we did not  evaluate the reliability for those purposes. Rather, we discuss the data’s  limitations for monitoring, evaluating, and reporting results related to  understanding the impact of transit-oriented development on the  availability of certain affordable housing. In the report, we provide  multiple reasons why we believe the data have gaps and inconsistencies  beyond those associated with the Moving to Work program that make their  use for geographic analysis limited. Reliable geographic information will  be important for the department to measure the impact of its programs  and make adjustments to those programs to ensure the availability of  certain affordable housing in transit-oriented developments.
As arranged with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 15 days after the  date of this letter. At that time, we will send copies of this report to  congressional committees with responsibilities for surface transportation  and housing programs; DOT officials, including the Secretary of  Transportation and the Administrator of FTA; and HUD officials, including  the Secretary of Housing and Urban Development. This report will also be  available on our home page at no charge at http://www.gao.gov.
If you have any question about this report, please contact us by e-mail at  wised@gao.gov or by telephone at (202) 512-2834 or by e-mail at  sciremj@gao.gov or by telephone at (202) 512-8678. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on the  last page of this report. GAO staff who made key contributions to this  report are listed in appendix IV.
section_title: Appendix I: Scope and Methodology
paragraphs: To identify how transit-oriented developments affect the availability of  affordable housing, we reviewed reports and studies issued by federal,  state, and local agencies; transportation research organizations; and  academia, as well as our past work in surface transportation and  affordable housing. A GAO economist reviewed relevant reports and  studies, which were identified by searching economics, housing, and  transportation literature, and found their methodology and economic  reasoning to be sound and sufficiently reliable for our purposes.
To identify how local, state, and federal agencies have worked to ensure  that affordable housing, including housing subsidized through Department  of Housing and Urban Development (HUD) programs, is available in and  near transit-oriented developments, we interviewed Department of  Transportation (DOT), Federal Transit Administration (FTA) officials, and  HUD officials. We also conducted 11 site visits or interviews with state and  local transportation and housing officials in Mesa, Phoenix, and Tempe,  Arizona; Sacramento, California; Chicago, Illinois; Cleveland, Ohio; Jersey  City and Hoboken, New Jersey; Portland, Oregon; Washington, D.C.; and  Arlington, Virginia. We selected this nongeneralizable sample of  metropolitan areas based on experience with transit-oriented development  and if the area had received New Starts federal funding for construction of  a local fixed-guideway transit system, and geographical diversity. During  these site visits, we interviewed federal, state, and local housing and  transportation officials and toured transit-oriented developments. In  addition, we reviewed studies and documentation on how these and other  metropolitan areas and states have promoted transit-oriented  developments.
To identify to what extent do HUD, DOT, and FTA work together to ensure  that transportation and affordable housing objectives are integrated in  transit-oriented development projects, we reviewed documentation  describing the collaborative efforts. We examined the mechanisms (e.g.  interagency agreements, task force agendas, etc.) the agencies used to  collaborate. Additionally, we interviewed agency officials on their  knowledge of any past or future collaborative effort.
To determine what opportunities exist to enhance collaboration between  HUD, DOT, and FTA, we reviewed our prior work on key practices that  can help enhance and sustain collaboration and address barriers to more  effective collaboration. We also obtained the views of agency officials,  local housing and transit providers, transportation organizations, and  nonprofit housing organizations with experience in developing,  implementing, or analyzing these issues. Finally, we compared the  agencies’ collaboration efforts with key practices that can help federal  agencies enhance and sustain their collaborative efforts.
We conducted this performance audit from August 2008 to September  2009, in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: Types of Locations that Could Have Transit-Oriented Developments
subsections: section_title: Regional centers are the primary centers of economic and cultural activity in any region. These are the regional downtowns, and are characterized by a dense mix of housing and employment types, retail, and entertainment that cater to the regional market. They are served by a rich mix of transit modes that support all this activity, including high-capacity regional rail and bus, and local-serving bus.
paragraphs: Urban centers contain a mix of residential, employment, retail, and entertainment uses, usually at slightly  lower densities and intensities than in regional centers. Destinations draw residents from surrounding  neighborhoods. These centers serve as commuter hubs for the larger region and are served by multiple  transit options, often including rail and high-frequency regional bus or bus rapid transit, as well as local- serving bus.
Suburban centers contain a mix of residential, employment, retail, and entertainment uses, usually at  intensities similar to that found in urban centers but lower than that in regional centers. Suburban centers  can serve as both origins and destinations for commuters. They are typically connected to the regional  transit network and include a mix of transit types—regional rail and bus, bus rapid transit, and local bus— with high-frequency service.
Transit town centers function more as local-serving centers of economic and community activity than either  urban or suburban centers, and they attract fewer residents from the rest of the region. A variety of transit  modes serve transit town centers, and there is a mix of origin and destination trips—primarily commuter  service to jobs in the region. There is less secondary transit service when compared to regional centers,  urban centers, or suburban centers. Secondary transit lines feed primary lines, often at intervals timed to  facilitate transfers at the primary transit stations.
Urban neighborhoods are primarily residential areas that are well-connected to regional centers and urban  centers. Densities are moderate to high, and housing is usually mixed with local-serving retail. Commercial  uses are limited to small businesses or some industry. Development is usually oriented along a well- connected street grid that is served by a secondary transit network. Transit is often less a focal point for  activity than in the “center” types of locations, and stations may be located at the edge of two distinct  neighborhoods.
Transit neighborhoods are primarily residential areas that are served by rail service or high frequency bus  lines that connect at one location. Densities are low to moderate and economic activity is not concentrated  around stations, which may be located at the edge of two distinct neighborhoods. Secondary transit service  is less frequent and less well connected. There is often not enough residential density to support much  local-serving retail, but there are often retail nodes.
Special-use or employment districts are often single use—either they are low to moderate density  employment centers, or are focused around a major institution such as a university, or an entertainment  venue such as a stadium. Transit stations are not a focus of economic activity. Secondary transit service is  infrequent and focused on stations; development tends to be more recent and the street grid may be less  connected than in older neighborhoods.
Mixed-used corridors are a focus of economic and community activity but have no distinct center. These  corridors are typically characterized by a mix of moderate-density buildings that house services, retail,  employment, and civic or cultural uses. Many were developed along streetcar lines or other transit service.  Mixed-use corridors are especially suitable for streetcars, bus rapid transit or other high-quality bus service  with closely spaced stops.
section_title: Appendix III: Examples of LIHTC Programs that Award Points for Proximity to Transit or Transit-Oriented Developments
subsections: section_title: Awards 10 points for projects located within the Phoenix or Tucson Metropolitan Statistical Areas that demonstrate indicators of sustainable development or transit-oriented development, including locating the project within 1 mile or less from a mass transit route or light rail line.
paragraphs: Awards 7 points for projects part of a transit-oriented development strategy where there is a transit station, rail  station, commuter rail station, or bus station, or bus stop within one-fourth mile from the site with service at least  every 30 minutes during the hours of 7 to 9 a.m. and 4 to 6 p.m., and the project’s density will exceed 25 units per  acre.
Awards 3 points for projects designated as a transit-oriented development by a rapid transit authority or projects  located within one-fourth mile walking distance of a rapid rail transit station along paved roads, sidewalks,  established pedestrian walkways, or bike trails.
Awards 1 point for projects that are part of a transit-oriented development strategy (located within four blocks) of a  regular bus route, or to a rapid transit system stop, etc.
Awards 5 points for projects that are part of a transit-oriented development—which is defined as having a density  that exceeds 25 units per acre, involves mixed-use or is part of a larger mixed-use undertaking, and involves good  nonmotorized transport design (walkability)—and are located within one-half mile of a mass or public transit or rail  station, or are located within one-fourth mile of a bus depot or bus stop with scheduled service at intervals at most  30 minutes between the hours of 6:30 a.m. and 7:00 p.m.
Awards 6 points for projects in which the buildings and the project site, including the nearby surroundings, provide  opportunities for recreation, education, convenient access to mass transit or rail systems, and community activities.
Awards 10 points for projects that are located within a transit village. “Transit village” refers to a designation given  by the New Jersey Department of Transportation to communities with a bus, train, light rail, or ferry station that has  developed a plan to achieve its goals of transit-oriented development. The transit village program is designed to  spur economic development, urban revitalization, and private-sector investment around passenger rail stations.
Awards 1 point for projects located within one-half mile of public transportation.
Awards 1 point for projects within one-fourth mile of local transit route.
Awards 4 points to projects located within one-fourth mile of public transportation that is accessible to all residents  including persons with disabilities and/or located within a community that has “on demand” transportation, special  transit service, or specialized elderly transportation for qualified elderly developments.
section_title: Appendix IV: Comments from the Department of Housing and Urban Development
section_title: Appendix V: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to the individuals named above, Raymond Sendejas, Assistant  Director; Paul Schmidt, Assistant Director; Lauren Calhoun; Melinda  Cordero; Delwen Jones; Anar Ladhani; Terence Lam; Matthew LaTour;  Sara Ann Moessbauer; Josh Ormond; Andrew Pauline; Linda Rego; and  Tim Schindler made key contributions to this report.