Affordable Housing in Transit-Oriented Development
Key Practices Could Enhance Recent Collaboration Efforts between DOT-FTA and HUD Gao ID: GAO-09-871 September 9, 2009The 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.
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
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Report to the Chairman, Subcommittee on Transportation, Housing and
Urban Development, and Related Agencies, Committee on Appropriations,
U.S. House of Representatives:
United States Government Accountability Office:
GAO:
September 2009:
Affordable Housing in Transit-Oriented Development:
Key Practices Could Enhance Recent Collaboration Efforts between DOT-
FTA and HUD:
GAO-09-871:
GAO Highlights:
Highlights of GAO-09-871, a report to the Chairman, Subcommittee on
Transportation, Housing and Urban Development, and Related Agencies,
Committee on Appropriations, U.S. House of Representatives.
Why GAO Did This Study:
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.
What GAO Found:
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 collaboration. Finally, without a more
formalized approach to collaboration, including establishment of
memorandum of agreements, these agencies may not effectively leverage
their unique strengths.
What GAO Recommends:
GAO is recommending that DOT and HUD develop a plan for implementing
interagency efforts to promote affordable housing in transit-oriented
developments, ensure they collect sufficient data to assess the results
of these efforts, and formalize key collaboration practices. DOT and
HUD agreed to consider the report‘s recommendations.
View GAO-09-871 or key components. For more information, contact Dave
Wise, (202) 512-2834 or wised@gao.gov, or Mathew J. Scirè at (202) 512-
8678 or sciremj@gao.gov.
[End of section]
Contents:
Letter:
Background:
Transit-Oriented Developments Can Affect the Availability of Affordable
Housing but Conclusions Are Complicated by Limited Research and Data:
Local, State, and Federal Affordable Housing Programs and Policies
Support, but Generally Do Not Require, Affordable Housing in Transit-
Oriented Developments:
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:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Types of Locations that Could Have Transit-Oriented
Developments:
Appendix III: Examples of LIHTC Programs that Award Points for
Proximity to Transit or Transit-Oriented Developments:
Appendix IV: Comments from the Department of Housing and Urban
Development:
Appendix V: GAO Contacts and Staff Acknowledgments:
Tables:
Table 1: Examples of Federal Programs that Fund Transit Projects:
Table 2: Examples of State and Local Affordable Housing Incentives and
Requirements that Have Been Used in Transit-Oriented Developments but
Are Not Specifically Designed for Use in Transit-Oriented Developments:
Table 3: Summary of Strategies and Recommendations Made by the Three
Interagency Efforts:
Table 4: Eight Key Practices Federal Agencies Can Undertake to Enhance
and Sustain Collaborative Efforts and the Extent to which DOT's, HUD's,
and FTA's Collaboration Efforts Are Consistent with These Key
Practices:
Figures:
Figure 1: Representation of a Transit-Oriented Development and Key
Components:
Figure 2: Infill Development, Including Some Affordable Housing Units,
Has Replaced Vacant or Underutilized Land near the Columbia Heights
Station in Washington, D.C.
Figure 3: Examples of Inconsistencies in Number of HUD-Subsidized
Housing Unit Records, 2000-2008:
Abbreviations:
AMI: area median income:
CDBG: Community Development Block Grant:
CTOD: Center for Transit-Oriented Development:
DOT: Department of Transportation:
EPA: Environmental Protection Agency:
FTA: Federal Transit Administration:
GPRA: Government Performance and Results Act:
HUD: Department of Housing and Urban Development:
LIHTC: Low Income Housing Tax Credit:
PHA: public housing authority:
QAP: Qualified Allocation Plan:
SAFETEA-LU: Safe, Accountable, Flexible, Efficient, Transportation
Equity Act: A Legacy for Users:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
September 9, 2009:
The Honorable John Olver:
Chairman:
Subcommittee on Transportation, Housing and Urban Development, and
Related Agencies:
Committee on Appropriations:
House of Representatives:
Dear Mr. Chairman:
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),[Footnote 1] walkable neighborhoods located near transit
facilities--such as fixed-guideway stations.[Footnote 2] 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.[Footnote 3] 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.[Footnote 4]
The federal government has acknowledged the link between housing and
transportation.[Footnote 5] 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.[Footnote
6] 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,[Footnote
7] has provided more than $33 billion over the last decade to help
design, construct, rehabilitate, and modernize fixed-guideway transit
projects throughout the country.[Footnote 8] 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.[Footnote 9]
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.
Background:
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.[Footnote 10] 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.
Figure 1: Representation of a Transit-Oriented Development and Key
Components:
[Refer to PDF for image: illustration]
Features (generally encompasses multiple city blocks up to a half-mile
from a transit station):
Transit station, such as a light rail station, that is part of a
transportation network allows residents to access the region‘s
neighborhoods, destinations, and centers, thereby promoting transit
use;
Open spaces to include transit-plazas, small parks or regional open
spaces;
High-quality walking environments and streetscape that allow people to
take care of some of their daily needs by walking or biking;
Includes moderate-to-high-density mix of residential, commercial,
employment, and civic/cultural developments;
Includes residential buildings that can vary from small-lot single
family/duplex/townhome units to high-rise multifamily units;
Offers mixed use and employment developments that can vary from mid- to
high-rise residential over commercial to low-to-high-rise
office/commercial.
Source: GAO.
[End of figure]
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[Footnote 11] develop transportation plans and
improvement programs; and build, maintain, and operate transportation
infrastructure and services.[Footnote 12]
* 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.[Footnote 13]
* 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.[Footnote 14]
* 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.[Footnote
15] 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.[Footnote 16] 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.
Table 1: Examples of Federal Programs that Fund Transit Projects:
New Starts and Small Starts (FTA):
Selects new fixed-guideway and fixed-guideway extensions, fixed
guideway modernization, and certain bus-related projects for funding in
accordance with 49 U.S.C. § 5309. Projects can include heavy, light,
and commuter rail, and certain bus rapid transit projects. To be
eligible for funding under New Starts, projects must, among other
things, be justified based on a comprehensive review of mobility
improvements, environmental benefits, economic development effects land
use, cost effectiveness, and operating efficiencies, and supported by
an acceptable degree of local financial commitment. Small Starts are
evaluated against a subset of these measures including cost
effectiveness, land use, other factors (including economic development
impacts), and local financial commitment.
Transit Capital Assistance (FTA):
Provides grants to local transit agencies through a formula for
projects that can include capital projects and associated capital
maintenance items, planning, transit enhancements, and operating costs
of equipment and facilities. Funding is apportioned to urbanized and
nonurbanized areas on the basis of legislative formulas, which include
such items as population and population density, bus revenue vehicle
miles, bus passenger miles, fixed guideway revenue vehicle miles, and
fixed guideway route miles.
Congestion Mitigation and Air Quality Improvement Program (joint
Federal Highway Administration and FTA):
Partially funds transportation projects and programs in order to reduce
transportation-related emissions in areas with poor air quality. To be
eligible for funding, projects must be transportation related, in
nonattainment or maintenance areas,[A] and reduce transportation-
related emissions.
Surface Transportation Program (joint Federal Highway Administration
and FTA):
Provides funding to states and localities for projects on any federal-
aid highway--including transit capital projects and local and intercity
bus terminals and facilities.
Source: GAO analysis of DOT information.
[A] Federal air quality standards, established by the Environmental
Protection Agency, exist for certain air pollutants (knows as criteria
pollutants). Geographic areas that have levels of a criteria pollutant
above those allowed by the standards are called nonattainment areas.
Areas that were previously nonattainment areas but now meet the
standards (i.e., have reached attainment) are known as maintenance
areas.
[End of table]
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).[Footnote 17] 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.[Footnote 18]
* 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.
Transit-Oriented Developments Can Affect the Availability of Affordable
Housing but Conclusions Are Complicated by Limited Research and Data:
Characteristics of Transit-Oriented Developments Can Increase Nearby
Land and Housing Values:
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.[Footnote 19] 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.[Footnote 20]
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.[Footnote 21]
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.[Footnote 22]
* 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.[Footnote 23] 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.
Availability of Affordable Housing in Transit-Oriented Developments
Varies Depending on Land and Housing Values, Local Decision Making, and
Other Factors:
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.[Footnote 24] 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.[Footnote 25] 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.[Footnote 26]
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.[Footnote
27] 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 figure 2).
Figure 2: Infill Development, Including Some Affordable Housing Units,
Has Replaced Vacant or Underutilized Land near the Columbia Heights
Station in Washington, D.C.
[Refer to PDF for image: illustration]
The illustration depicts the following:
Infill development on previously vacant or underutilized property since
2000:
Transit station;
1/2-mile radius from transit station;
100% affordable housing;
Mixed-income housing;
Market rate residential or non-residential development.
Source: GAO analysis of District of Columbia planning data.
[End of figure]
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.
Limited Research and Data Complicate Conclusions about the Effect of
Transit-Oriented Developments on the Availability of Affordable
Housing:
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.[Footnote 28]
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.[Footnote 29] 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.[Footnote 30] 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.[Footnote 31]
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.[Footnote 32]
Figure 3: Examples of Inconsistencies in Number of HUD-Subsidized
Housing Unit Records, 2000-2008:
[Refer to PDF for image: multiple line graph]
Fiscal year: 2000;
State of New Jersey-Multifamily[C]: 39,496 units;
Washington DC Metropolitan area - Section 8 Housing Choice
Vouchers[A,B]: 18,072 units;
Cleveland Metropolitan area - Public Housing: 9,383 units.
Fiscal year: 2001;
State of New Jersey-Multifamily[C]: 38,584 units;
Washington DC Metropolitan area - Section 8 Housing Choice
Vouchers[A,B]: 20,190 units;
Cleveland Metropolitan area - Public Housing: 7,908 units.
Fiscal year: 2002;
State of New Jersey-Multifamily[C]: 37,877 units;
Washington DC Metropolitan area - Section 8 Housing Choice
Vouchers[A,B]: 17,654 units;
Cleveland Metropolitan area - Public Housing: 1,465 units.
Fiscal year: 2003;
State of New Jersey-Multifamily[C]: 37,103 units;
Washington DC Metropolitan area - Section 8 Housing Choice
Vouchers[A,B]: 26,912 units;
Cleveland Metropolitan area - Public Housing: 2,052 units.
Fiscal year: 2004;
State of New Jersey-Multifamily[C]: 47,229 units;
Washington DC Metropolitan area - Section 8 Housing Choice
Vouchers[A,B]: 27,641 units;
Cleveland Metropolitan area - Public Housing: 9,503 units.
Fiscal year: 2005;
State of New Jersey-Multifamily[C]: 48,701 units;
Washington DC Metropolitan area - Section 8 Housing Choice
Vouchers[A,B]: 28,934 units;
Cleveland Metropolitan area - Public Housing: 9,091 units.
Fiscal year: 2006;
State of New Jersey-Multifamily[C]: 48,577 units;
Washington DC Metropolitan area - Section 8 Housing Choice
Vouchers[A,B]: 22,167 units;
Cleveland Metropolitan area - Public Housing: 10,667 units.
Fiscal year: 2007;
State of New Jersey-Multifamily[C]: 49,776 units;
Washington DC Metropolitan area - Section 8 Housing Choice
Vouchers[A,B]: 23,125 units;
Cleveland Metropolitan area - Public Housing: 12,992 units.
Fiscal year: 2008;
State of New Jersey-Multifamily[C]: 49,791 units;
Washington DC Metropolitan area - Section 8 Housing Choice
Vouchers[A,B]: 26,178 units;
Cleveland Metropolitan area - Public Housing: 13,057 units.
Source: GAO analysis of HUD Data.
Note: The graphic demonstrates several examples of significant and
unexpected changes in the number of subsidies in each of these
designated areas over time.
[A] Washington, D.C., includes subsidies within the Metropolitan
Washington Area. New Jersey includes subsidies located in the State of
New Jersey. Cleveland includes subsidies located in Metropolitan
Statistical Area 1680.
[B] The District of Columbia Housing Authority is a participant in the
HUD Moving to Work Program.
[C] Multifamily programs include Section 8 Project Based/Section 202 -
Project rental assistance contracts/Section 811 - Project rental
assistance contracts/Section 236/Section 221(d3)/Rental Assistance
Program/Rent Supplement.
[End of figure]
Local, State, and Federal Affordable Housing Programs and Policies
Support, but Generally Do Not Require, Affordable Housing in Transit-
Oriented Developments:
Few Local and State Programs Are Specifically Targeted to Affordable
Housing in Transit-Oriented Developments, and Most Are Incentive Based:
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.[Footnote 33] 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.[Footnote 34] 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.[Footnote 35] 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.[Footnote 36] 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.[Footnote
37] 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.[Footnote 38] 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.
Selected examples of state and local affordable housing incentives and
requirements that have been used in transit-oriented developments but
are not specifically designed for use in transit-oriented developments
include the following:
Incentives:
* 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.
Requirements:
* 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.
Table 2: Examples of State and Local Affordable Housing Incentives and
Requirements that Have Been Used in Transit-Oriented Developments but
Are Not Specifically Designed for Use in Transit-Oriented Developments:
Category: Nonfinancial incentives;
Type: Density bonus;
Location: Arlington County, Virginia;
Example: Arlington County permits a 25% density bonus to developers who
provide affordable units. The density bonus allows both market rate and
affordable units, with the income from the market-rate units designed
to offset the cost of the affordable units;
Result: Quincy Plaza, a residential development in the transit-oriented
development around the Ballston Metro station, used the full 25% bonus
to add 25 affordable units.
Category: Financial incentives;
Type: Tax increment financing;
Location: Sacramento, California;
Example: All local redevelopment agencies in California are required to
set aside 20% of tax increment financing resources for a separate
affordable housing fund;
Result: Sacramento's redevelopment agency supported 114 low-income
senior apartments in a transit-oriented development through $6 million
in tax increment financing.
Category: Financial incentives;
Type: Affordable housing trust funds;
Location: Los Angeles, California;
Example: The City of Los Angeles's Affordable Housing Trust Fund
provides funding to create affordable housing, as well as revitalize
neighborhoods and remove blight;
Result: In 2008, 225 affordable housing units in three developments
located in transit-oriented developments in Los Angeles received over
$21 million from the Affordable Housing Trust Fund.
Category: Requirements;
Type: Inclusionary zoning;
Location: Montgomery County, Maryland;
Example: Montgomery County's Moderately Priced Dwelling Unit program
requires that at least 12.5 percent of the units in new subdivisions of
20 or more units be set aside as affordable units;
Result: King Farm, a mixed-use transit-oriented development adjacent to
the Shady Grove Metro Station in Rockville, Montgomery County, includes
3,200 units, of which 353 units are affordable as part of the County's
inclusionary policy.
Category: Requirements;
Type: Affordability requirements on publicly financed residential
development;
Location: New Jersey;
Example: Statutory requirement that any new housing development for
which the land was purchased from a state or local government agency,
or which received any kind of state funding, must set aside at least
20% of the residential units for low-and moderate-income individuals;
Result: Legislation enacted in July 2008 and results are not yet
available.
Source: GAO.
[End of table]
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:
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.[Footnote 39] 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.[Footnote 40] 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.[Footnote 41] 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.
[Footnote 42] 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.[Footnote 43] 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.[Footnote 44] 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.[Footnote 45] 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.[Footnote 46] 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.[Footnote 47] 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.[Footnote 48] 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.
Local Governments and Developers Encounter Challenges in Supporting
Affordable Housing in Transit-Oriented Developments:
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.[Footnote 49] 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.[Footnote 50]
In certain circumstances, transit agencies may transfer the property
for purposes such as affordable housing joint development.[Footnote 51]
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:
HUD and FTA, and More Recently DOT, Have Collaborated on Interagency
Efforts to Promote Affordable Housing in Transit-Oriented Developments:
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.[Footnote 52]
* 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.[Footnote 53] 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.[Footnote 54] 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.[Footnote 55] 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.[Footnote
56] 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.
Table 3: Summary of Strategies and Recommendations Made by the Three
Interagency Efforts:
Category: Establishment of interagency working groups;
Center for Transit-Oriented Development Report (specific federal
recommendations): April 2007: Coordinate federal housing and
transportation programs by establishing a HUD and FTA interagency
working group;
HUD-FTA action plan: August 2008: Implement Joint HUD-FTA Working
Group;
Partnership for Sustainable Communities: June 2009: Establish a high
level DOT/HUD/EPA task force.
Category: Coordination of federal programs, policies, and requirements;
Center for Transit-Oriented Development Report (specific federal
recommendations): April 2007: Use transportation and housing policies
and funding to encourage mixed-income housing near transit;
HUD-FTA action plan: August 2008: Improve coordination of housing and
transportation planning through HUD's Consolidated Plan, DOT's
Transportation Planning requirements, and other mechanisms; Identify
regulatory barriers to affordable housing near transit;
Partnership for Sustainable Communities: June 2009: Harmonize DOT, HUD,
and EPA programs to identify opportunities to better coordinate their
programs; Coordinate federally mandated housing and transportation
planning requirements.
Category: Opportunities for education and outreach;
Center for Transit-Oriented Development Report (specific federal
recommendations): April 2007: [Empty];
HUD-FTA action plan: August 2008: Identify opportunities for joint
outreach to housing and transit providers and stakeholders; Conduct
briefings and workshops for HUD and FTA staff; Enhance capacity-
building program(s) by providing technical assistance to transit
providers, public officials, and other stakeholders;
Partnership for Sustainable Communities: June 2009: [Empty].
Category: Changes in statutory requirements;
Center for Transit-Oriented Development Report (specific federal
recommendations): April 2007: [Empty];
HUD-FTA action plan: August 2008: Address affordable housing and mixed-
income housing needs in new legislative initiatives;
Partnership for Sustainable Communities: June 2009: [Empty].
Category: Funding and financial incentives;
Center for Transit-Oriented Development Report (specific federal
recommendations): April 2007: Accelerate federal efforts to preserve
existing affordable and market rate rental housing near transit; Target
HUD funding sources to build housing near transit facilities;
HUD-FTA action plan: August 2008: Identify financial incentives for
funding affordable housing near transit;
Partnership for Sustainable Communities: June 2009: Establish a
competitive grant program for metropolitan areas to enhance integrated
regional housing, transportation, and land use planning and investment.
Category: Performance measurement;
Center for Transit-Oriented Development Report (specific federal
recommendations): April 2007: [Empty];
HUD-FTA action plan: August 2008: Assess the effectiveness of the HUD-
FTA action plan;
Partnership for Sustainable Communities: June 2009: Establish standards
and performance measures.
Category: Research and development;
Center for Transit-Oriented Development Report (specific federal
recommendations): April 2007: Continue to study the causal
relationships between housing markets and transit investments;
HUD-FTA action plan: August 2008: Identify opportunities for joint
research and development policy analysis;
Partnership for Sustainable Communities: June 2009: Research, evaluate,
and recommend measures that indicate the livability of communities,
neighborhoods, and metropolitan areas.
Category: Research and development;
Center for Transit-Oriented Development Report (specific federal
recommendations): April 2007: Consider implementing a federal
affordability measurement that reports on the combined costs of housing
and transportation;
HUD-FTA action plan: August 2008: Develop a best practices manual for
mixed-income housing near transit;
Partnership for Sustainable Communities: June 2009: Develop a federal
housing affordability measure that includes housing and transportation
costs.
Source: GAO.
[End of table]
HUD and FTA Collaboration Has Not Yet Affected Federal Support to Local
Housing and Transit Agencies:
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.[Footnote 57] 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.[Footnote 58] 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.[Footnote 59] 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[Footnote 60]. 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.[Footnote 61] 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.[Footnote 62]
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:
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.[Footnote 63] 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.
[Footnote 64] 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.[Footnote 65] Table 4
summarizes the key practices and extent to which DOT, HUD, and FTA are
using these key practices.[Footnote 66] 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.[Footnote 67]
Table 4: Eight Key Practices Federal Agencies Can Undertake to Enhance
and Sustain Collaborative Efforts and the Extent to which DOT's, HUD's,
and FTA's Collaboration Efforts Are Consistent with These Key
Practices:
Key practice: Define and articulate a common outcome: To overcome
significant differences in agency cultures and established ways of
doing business, collaborating agencies must have a clear and compelling
rationale to work together;
The agencies have not taken any action consistent with the key
practice: [Empty];
The agencies have identified and initiated one or more actions that are
consistent with the key practice: [Check];
The agencies have implemented actions consistent with the key practice
by adopting a formal approach such as a memorandum of agreement or
formal incentives: [Empty].
Key practice: Establish mutually reinforcing or joint strategies: To
achieve a common outcome, collaborating agencies need to establish
strategies that work in concert with those of their partners or are
joint in nature;
The agencies have not taken any action consistent with the key
practice: [Empty];
The agencies have identified and initiated one or more actions that are
consistent with the key practice: [Check];
The agencies have implemented actions consistent with the key practice
by adopting a formal approach such as a memorandum of agreement or
formal incentives: [Empty].
Key practice: Identify and address needs by leveraging resources:
Collaborating agencies should identify the human, information
technology, physical, and financial resources needed to initiate or
sustain their collaborative effort. By assessing their relative
strengths and limitations, agencies can look for opportunities to
address resources needs by leveraging each other's resources;
The agencies have not taken any action consistent with the key
practice: [Empty];
The agencies have identified and initiated one or more actions that are
consistent with the key practice: [Check];
The agencies have implemented actions consistent with the key practice
by adopting a formal approach such as a memorandum of agreement or
formal incentives: [Empty].
Key practice: Agree on agency roles and responsibilities: Collaborating
agencies should work together to define and agree on their respective
roles and responsibilities, including how the collaborative effort will
be led;
The agencies have not taken any action consistent with the key
practice: [Empty];
The agencies have identified and initiated one or more actions that are
consistent with the key practice: [Check];
The agencies have implemented actions consistent with the key practice
by adopting a formal approach such as a memorandum of agreement or
formal incentives: [Empty].
Key practice: Establish compatible policies, procedures, and other
means to operate across agency boundaries: To facilitate collaboration,
agencies need to address the compatibility of standards, policies,
procedures, and data systems that will be used in the collaborative
efforts;
The agencies have not taken any action consistent with the key
practice: [Check];
The agencies have identified and initiated one or more actions that are
consistent with the key practice: [Empty];
The agencies have implemented actions consistent with the key practice
by adopting a formal approach such as a memorandum of agreement or
formal incentives: [Empty].
Key practice: Develop mechanisms to monitor, evaluate, and report on
results: Agencies involved in collaborative efforts need to create the
means to monitor and evaluate their efforts to enable them to identify
areas for improvement;
The agencies have not taken any action consistent with the key
practice: [Check];
The agencies have identified and initiated one or more actions that are
consistent with the key practice: [Empty];
The agencies have implemented actions consistent with the key practice
by adopting a formal approach such as a memorandum of agreement or
formal incentives: [Empty].
Key practice: Reinforce agency accountability for collaborative efforts
through agency plans and reports: Collaborating agencies should ensure
that goals are consistent and, as appropriate, program efforts are
mutually reinforced through tools such as strategic and annual
performance plans;
The agencies have not taken any action consistent with the key
practice: [Empty];
The agencies have identified and initiated one or more actions that are
consistent with the key practice: [Check];
The agencies have implemented actions consistent with the key practice
by adopting a formal approach such as a memorandum of agreement or
formal incentives: [Empty].
Key practice: Reinforce individual accountability for collaborative
efforts through performance management systems: Collaborating agencies
should use their performance management systems to strengthen
accountability for results, specifically by placing greater emphasis on
fostering the necessary collaboration both within and across
organizational boundaries to achieve results;
The agencies have not taken any action consistent with the key
practice: [Check];
The agencies have identified and initiated one or more actions that are
consistent with the key practice: [Empty];
The agencies have implemented actions consistent with the key practice
by adopting a formal approach such as a memorandum of agreement or
formal incentives: [Empty].
Source: GAO analysis.
[End of table]
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.[Footnote 68] 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.
Conclusions:
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.
Recommendations for Executive Action:
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.
Agency Comments and Our Evaluation:
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
[hyperlink, 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.
Sincerely yours,
Signed by:
David Wise:
Director, Physical Infrastructure Issues:
Signed by:
Mathew J. Scirè:
Director, Financial Markets and Community Investment Issues:
[End of section]
Appendix I: Scope and Methodology:
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.
[End of section]
Appendix II: Types of Locations that Could Have Transit-Oriented
Developments:
Type: Regional center;
Definition: 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.
Type: Urban center;
Definition: 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.
Type: Suburban center;
Definition: 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.
Type: Transit town center;
Definition: 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.
Type: Urban neighborhood;
Definition: 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.
Type: Transit neighborhood;
Definition: 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.
Type: Special use or employment district;
Definition: 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.
Type: Mixed-use corridor;
Definition: 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.
Source: GAO summary of information from Reconnecting America and the
Center for Transit-Oriented Development report on transit-oriented
development.
[End of table]
[End of section]
Appendix III: Examples of LIHTC Programs that Award Points for
Proximity to Transit or Transit-Oriented Developments:
Arizona:
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.
California:
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.
Georgia:
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.
Illinois:
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.
Maryland:
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.
New Jersey:
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.
Nevada:
Awards 1 point for projects within one-fourth mile of local transit
route.
Texas:
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.
Source: GAO analysis of selected state Qualified Allocation Plans.
[End of table]
[End of section]
Appendix IV: Comments from the Department of Housing and Urban
Development:
U.S. Department Of Housing And Urban Development:
Washington, DC 20410:
[hyperlink: http://www.hud.gov]
August 28, 2009:
Mr. Mathew Scire:
Director, Financial Markets and Community Investment:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Mr. Scire:
Thank you for the opportunity to comment on the Government
Accountability Office (GAO) draft report GAO-09-871, "Affordable
Housing in Transit Oriented Development. Key Practices Could Enhance
Recent Collaborations among DOT, PTA and HUD."
The topic of this report, expanding the availability of affordable
housing near transit, is a top priority for this administration. In
March of this year, HUD initiated a significant new partnership with
DOT, and requested $150 million for a new Sustainable Communities
Initiative in our FY 2010 budget. In a short amount of time since
taking office we have made extraordinary progress through the work of
our Partnership for Sustainable Communities on expanding coordination
between HUD, DOT, and, more recently, the Environmental Protection
Agency.
We are pleased with the response so far of the House and Senate
Appropriations Committees to our FY 2010 budget request, as well as the
significant progress we have made since the start of the new
Administration on aligning HUD and DOT programs. We have established a
high-level Interagency Task Force, which has created four working
groups to address the issues raised in the GAO report, have agreed on
core Livability Principles that will provide a framework for our work,
and are in the process of finalizing a Work Plan to implement the
partnership's programs. We expect to finalize the Work Plan within the
next thirty days.
GAO Findings:
GAO's findings were inconclusive on the issue of whether transit
oriented development adds to the cost of housing near transit. GAO
found that due to a lack of direct research and data, determining the
effects of TOD on housing is" complicated" and that in some cases (e.g.
lowincome areas in Buffalo) housing values actually declined near
transit.
GAO also found few federal, state and local programs that are
specifically targeted to developing affordable housing near transit,
and that while HUD and FTA programs allow affordable housing near
transit, there are few direct incentives housing in transit rich
locations.
GAO also assessed the progress of three partnerships that have been
established between HUD and DOT since 2005, most recently the
Sustainable Communities Partnership that HUD established with DOT in
March of this year (and expanded to include EPA in June, 2009). GAO
acknowledges progress in 5 of 8 "key practices" to enhance and
sustainable collaborative efforts, but recommends that these should be
formalized in a variety of ways. GAO also was concerned that HUD's data
on subsidized housing were not sufficiently accurate to "provide a full
and accurate picture of the availability of subsidized housing" near
transit.
HUD Comments:
In addition to the technical comments submitted separately we have the
following comments on areas of the report where GAO did not accurately
address the issues:
* GAO's definition of affordable housing is overly narrow. The issue of
housing affordability near transit goes beyond subsidized housing for
low and moderate income families. However, the only measure of
affordability that GAO focused on was that of subsidized housing. GAO
did not sufficiently look at the availability of market rate affordable
housing to working families, and the extent to which its availability
is impacted by transit or transit oriented development.
More importantly, GAO failed to look at the combined cost of housing
and transportation, as a measure of affordability (beyond a footnote on
p. 2). The combined cost of housing and transportation may provide a
better indication of the "true" cost of housing, in that the cost of
housing near transit may be higher locations without access to transit,
but this must be balanced against the relatively lower costs of
transportation. These broader market trends are an important indicator
of housing affordability, not just for low-income households but for
moderate or middle income households who may not be able to afford to
live near transit if housing costs are too high. We believe that in
order to fully understand affordability trends, it will be critical to
look at the combination of housing and transportation expenses for all
income groups.
* Significant progress has been made on coordinating housing and
transportation under the new Administration's Partnership on
Sustainable Communities. As noted above, coordination of housing and
transportation has been one of the highest HUD priorities since this
Administration took office in January. We included this topic as a
significant new element in our FY 2010 budget, and are pleased with
Congress' response so far to this request. HUD Secretary Donovan and
DOT Secretary LaHood testified twice before Congress on this issue, on
March 18 before the House Appropriations Subcommittee on Transportation
and Housing and Urban Development, and again on June 16 before the
Senate Banking Committee when they were joined by EPA Administrator
Jackson.
GAO only briefly references the six livability principles announced in
June, which provides a new template for HUD, DOT and EPA to jointly
address environmental, transportation and housing issues-the first such
effort for federal agencies to establish a shared framework for future
action and collaboration. GAO also does not describe the four Working
Groups that have been created to implement the partnership, the
progress that has been made in identifying barriers to coordinated
housing and transportation investments, and the work that has begun on
developing detailed performance measures that will provide metrics for
measuring the success of the initiative in local communities. In
addition, a Work Plan has been drafted, and is close to being finalized.
GAO overstates the issues associated with accuracy of HUD data on
subsidized households for this study. While additional improvements can
be made in improving the geocoding of the data reported by public
housing authorities to HUD - and we are committed to making these
improvements - we believe that HUD generally has current and good
information on the location of HUD-subsidized units for the
administrative purpose for which the data is being collected. Data
collected is primarily intended to he used for administrative purposes
and several issues prevent reliable long-term data analysis. However,
there were gaps that GAO encountered for certain communities for the
period of this study: 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. All housing authorities
are currently required to report, so that those gaps no longer exist.
GAO Recommendations:
GAO recommended three actions to "strengthen formal collaboration"
between HUD and DOT: (1) publishing an implementation plan for both the
HUD-FTA action plan and the Partnership for Sustainable Communities;
(2) developing a plan to improve data quality to enhance performance
measurement; and (3) adopting a "formal approach" to promoting
affordable housing in transit oriented developments.
Please note that we are already in the process of implementing these
recommendations, in that, as noted above, a detailed three-agency
implementation plan is close to being finalized, and we are continuing
to formalize the partnership with DOT and EPA through a variety of
other means, using the two partnership agreements announced in March 18
and June 16 as the starting point. Table 4 in the report - which
includes eight practices recommended by GAO for sustainable interagency
collaboration - provides an excellent framework for formalizing these
efforts. Our FY 2010 budget also includes a request for significant
enhancements of HUD's data systems.
Accordingly, we will consider your findings and recommendations
carefully as we continue our efforts to combine housing and
transportation funds and resources near transit, and more broadly to
address the interest of Congress and the affordable housing industry in
sustainable community development.
Sincerely,
Signed by:
Inez Banks-DuBose, Director:
Office of Departmental Operations and Coordination:
[End of section]
Appendix V: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
David Wise (202) 512-2834 or wised@gao.gov Mathew Scirè (202) 512-8678
or sciremj@gao.gov:
Staff Acknowledgments:
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.
[End of section]
Footnotes:
[1] Mixed-use development mixes residential, commercial, cultural, or
institutional uses on the same site which can allow for greater housing
density; encourage more compact development; and promote pedestrian-
friendly environments.
[2] Fixed-guideway systems are permanent transit facilities that may
use and occupy a separate right-of-way for the exclusive use of public
transportation services. These fixed-guideway systems include rail
(light, heavy, commuter, and streetcar) and may include busways (such
as bus rapid transit).
[3] For purposes of this report, affordable housing refers to housing,
either for purchase or for rent, which is affordable to people with low
to moderate incomes. HUD and others define affordability in terms of
the proportion of a households income that goes toward housing. HUD
defines low and moderate income as a certain percentage of the area's
median income.
[4] We are defining subsidized housing as housing in which financial
assistance is provided to property owners or to tenants so as to make
housing affordable for people with low to moderate incomes. The
financial assistance may be provided by entities such as a federal or
state agency.
[5] Other organizations have worked to establish the link between
housing and transportation by developing new measures of affordability.
For example, an affordability index was developed by the Center for
Transit-Oriented Development (which is funded by FTA), the Center for
Neighborhood Technology, and the Brookings Institution's Urban Market
Initiatives program. The affordability index calculates the true
affordability of a home based on its market value and the
transportation costs incurred by its location.
[6] Livable Communities, Transit-Oriented Development, and
Incorporating Green Building Practices into Federal Housing and
Transportation Policy: Hearing before the Subcomm. on Transportation,
Housing and Urban Development, and Related Agencies, House of
Representatives Comm. on Appropriations, 111th Congress (Mar. 18, 2009)
(statements of Shaun Donovan, Secretary, Department of Housing and
Urban Development and Ray LaHood, Secretary, Department of
Transportation).
[7] For purposes of this report, we refer to New Starts as new fixed-
guideway and fixed-guideway extensions, fixed guideway modernization,
and certain bus-related programs in accordance with 49 U.S.C. §
5309(b).
[8] FTA formula programs, such as the Transit Capital Assistance
program, are also eligible to fund rehabilitation and modernization of
fixed-guideway systems.
[9] Specifically, in an explanatory statement accompanying the 2008
Consolidated Appropriations Act published by the Chairman of the
Committee on Appropriations of the House of Representatives, the
Appropriations Committees directed FTA and HUD to develop a best
practices manual to help communities establish mixed-income transit-
oriented developments. Further, the statement indicated that FTA and
HUD should jointly report to the Committees on Appropriations of the
House of Representatives and the Senate on new and better ways they
could coordinate transportation and housing programs to promote
affordable housing near transit. 153 Cong. Rec. H15741, H16497, and
H16562 (Dec. 17, 2007).
[10] Light rail transit is defined as a metropolitan-electric railway
system characterized by its ability to operate in a variety of
environments such as streets, subways, or elevated structures. Light
rail systems typically use an overhead source for electrical power, can
operate on streets with other traffic, and boarding takes place from
the street or platforms. Heavy rail transit systems operate on a
totally separated right-of-way, use a third rail on the ground to power
the trains, require platform boarding, and typically have longer
distances between stations and have greater capacity than light rail
systems.
[11] Metropolitan planning organizations are federally mandated
regional organizations responsible for comprehensive transportation
planning and programming in urbanized areas with a population of 50,000
or more and are required by federal law to develop regional
transportation plans.
[12] The current framework for federal participation in surface
transportation is set forth in authorizing legislation, most recently
amended by the Safe, Accountable, Flexible, Efficient, Transportation
Equity Act: A Legacy for Users (SAFETEA-LU). These pieces of
legislation have established an overall approach for surface
transportation planning and decision making that generally gives local
and state governments significant responsibilities for these activities
in their own regions. For example, 23 U.S.C. § 134 establishes specific
planning task requirements that metropolitan planning organizations, in
conjunction with states, public transportation operators, and other
stakeholders, must perform, which include (1) developing long-and short-
range transportation plans and transportation improvement programs, (2)
specifying financing for the transportation plan, and (3) involving a
wide range of stakeholders in the process that emphasizes consultation
and coordination.
[13] LIHTC is administered by the Internal Revenue Service based on
section 42 of the Internal Revenue Code, which was enacted by Congress
in 1986 to provide the private market with an incentive to invest in
affordable rental housing.
[14] HUD generally requires states, cities, and counties to prepare a 5-
year Consolidated Plan and a 1-year Action Plan that together identify
long-range housing needs, as well as short-term funding priorities for
HUD's formula grant programs. 24 C.F.R. pt. 91
[15] Under the New Starts program, the Secretary has the authority to
provide funding for new and extensions to existing fixed guideway
systems--done through a competitive process--as well as fixed guideway
modernization and bus-related projects. In addition to New Starts,
SAFETEA-LU established the Small Starts program for lower-cost fixed-
guideway capital projects, which may include a corridor-based bus
capital project. Small Starts projects are defined as those projects
that request less than $75 million in New Starts funding and have a
total estimated net capital cost of less than $250 million. FTA also
subsequently introduced a subset of the Small Starts program called the
Very Small Starts program for projects that have a total capital cost
of less than $50 million.
[16] The Highway Trust Fund is divided into two major accounts: the
Highway Account and the Mass Transit Account. A portion of federal fuel
taxes (2.86 cents of the 18.4 cents federal gas tax) is deposited into
the Mass Transit Account.
[17] Area median income--sometimes also referred to as median family
income--limits are published annually by HUD and are used to determine
eligibility of applicants in federal and local affordable housing
programs.
[18] A tenant's rent is based on a household's anticipated gross annual
income--that is, income from all sources received by the family head,
spouse, and each additional family member who is 18 years of age or
older, less applicable exclusions and deductions.
[19] Our literature review included eight studies, four of which
included extensive reviews of previously published literature. These
eight studies are representative of the general research findings that
the value of property is positively correlated with the presence of a
transit station. These studies, conducted between 1978 and 2008,
examined primarily residential property using sales data on single-
family homes, condominiums, or apartment rents in varying areas and, as
a result, estimates of land or housing values with respect to transit
development vary. A 2008 report from the Center for Transit-Oriented
Development said that increased asking prices for property along
planned light rail corridors have been observed in several areas,
including the Twin Cities, Houston, Denver, and Charlotte. See
Reconnecting America's Center for Transit-Oriented Development,
Capturing the Value of Transit, November 2008.
[20] Landis, John, Robert Cervero, Subhrajit Guhathukurta, David
Loutzenheiser, and Ming Zhang. Rail Transit Investments, Real Estate
Values, and Land Use Change: A Comparative Analysis of Five California
Rail Transit Systems. Monograph 48, Institute of Urban and Regional
Studies, University of California at Berkeley (1995).
[21] Pollution can also potentially negatively affect land and housing
values. See for example, Kenneth Chay and Michael Greenstone. "Does Air
Quality Matter? Evidence from the Housing Market," Journal of Political
Economy, vol. 113, no. 2 (2005).
[22] Bowes, D. R. and K.R. Ihlanfeldt. "Identifying the Impacts of Rail
Transit Stations on Residential Property Values,î Journal of Urban
Economics, vol. 50 (2001): pp. 1-25.
[23] Daniel Baldwin Hess and Tangerine Maria Almeida. "Impact of
Proximity to Light Rail Rapid Transit on Station-area Property Values
in Buffalo, New York," Urban Studies, vol. 44 (2007): p. 1041.
[24] Affordability is often defined as housing cost as a percentage of
household income, therefore higher land values can affect affordability
if income remains constant.
[25] Reconnecting America and the National Housing Trust, Preserving
Opportunities: Saving Affordable Homes Near Transit, 2007.
[26] HUD's project-based Section 8 program subsidizes the rent of low-
income individuals through contracts between HUD and multifamily
property owners. The subsidies keep rents in Section 8 properties
affordable to households earning at or below 80 percent of AMI.
[27] Infill refers to redevelopment of vacant or underutilized property
in urbanized areas.
[28] According to some research, transit-oriented developments often
take years, if not decades, to fully develop. The effect land and
housing values might have on affordable housing may not be fully
realized until years after the transit station opens.
[29] Local travel models are used to forecast travel demand for transit
projects, which is then used in calculating transportation system user
benefits for New Starts projects.
[30] HUD officials told us that this is in part because changes were
made to the reporting form for the Moving to Work program and there was
initial confusion among PHAs about the requirement. In addition, HUD
officials told us that missing geographic data were not random
throughout the database, and that the reasons for the differences
varied. Moreover, HUD told us that the accuracy of the geographic data
is of significantly less quality prior to 2000.
[31] Moving to Work is a HUD demonstration program that allows PHAs to
design and test ways to promote self-sufficiency among assisted
families, achieve programmatic efficiency and reduce costs, and
increase housing choice for low-income households.
[32] GAO, Highway and Transit Investments: Options for Improving
Information on Projects' Benefits and Costs and Increasing
Accountability for Results, [hyperlink,
http://www.gao.gov/products/GAO-05-172] (Washington, D.C.: July 25,
2008).
[33] In 2006, voters in the State of California passed the Housing and
Emergency Shelter Trust Fund Act of 2006 which allocated $2.85 billion
for housing and development programs, including affordable housing in
transit-oriented developments. Cal. Health & Safety Code §§ 53560 et
seq. (2009).
[34] Affordable housing units must be affordable to persons of very low
and low income for a period of at least 55 years.
[35] See Or. Rev. Stat. § 307.600 (2009).
[36] The total points which applicants can earn vary across QAPs. For
example, applicants can earn up to 63 points in New Jersey and up to
146 points in California. We did not examine the extent to which
applicants or state housing finance agencies believed a certain number
of points for proximity to transit would make a difference in
applicants' prospects for success in receiving LIHTCs.
[37] The New Jersey Transit Village Initiative is a coordinated effort
by the state's various agencies including housing and transit to
establish transit-oriented developments throughout the state.
[38] If the development is located in a HUD-designated high cost area
(HCA), the state allocating agency may award up to 30 percent
additional LIHTCs. These areas include both Qualified Census Tracts
(QCT) and Difficult Development Areas (DDA). In a QCT, 50 percent or
more of the households have incomes of less than 60 percent of AMI.
DDAs are designated according to a HUD comparison of housing costs with
incomes for each area. Section 3003(a) of the Housing and Economic
Recovery Act of 2008 amended section 42(d)(5) of the Internal Revenue
Code and allowed certain state-designated buildings to be treated as
being located in a DDA and qualify for additional LIHTCs. 26 U.S.C. §
42(d)(5)(B)(v). To quality for this special treatment, the building
must be designated by the state as requiring the enhanced credit in
order to be financially feasible as part of the low-income housing
project.
[39] Other programs include mortgage insurance programs that provide
federal loan guarantees to support the construction of new apartment
projects and the refinancing of the rehabilitation of older ones.
[40] Fair market rents are determined annually by HUD.
[41] Notice of Funding Availability for fiscal year 2009 for the
Neighborhood Stabilization Program 2 under the American Recovery and
Reinvestment Act, 2009, No. FR 5321-C-01, 28 (May 4, 2009) (the
Notice); Pub. L. No. 111-5, 123 Stat. 115.
[42] According to the Notice, transit accessible is defined as being in
a census tract with convenient bus service (local bus service every 20
minutes during rush hour or an express commuter bus) or being or
bordering a census tract with a passenger rail stop or station
(including, for example, commuter rail, subway, light rail, and
streetcars).
[43] Local transit agencies can use all types of federal transit funds
for the Joint Development Program including New Starts funding, formula
grants, and flexible funding programs.
[44] In addition, according to FTA officials, transportation and
transit planning studies that include transit-oriented development and
joint development are eligible for funding under FTA formula programs.
FTA's Metropolitan Planning Program (49 U.S.C. § 5305(d)) and the State
Planning and Research Program (49 U.S.C. § 5305(e)).
[45] According to FTA officials, FTA does not maintain a national
database of approved joint development projects.
[46] FTA has previously stated that the mobility improvements criterion
is used as a tiebreaker. Additionally FTA has taken steps to address
the consideration of economic development and the weight to be accorded
to it and other statutory New Starts criteria. In a Federal Register
notice published on January 26, 2009, FTA issued and sought comments on
a discussion paper on new ways of evaluating economic development
effects. See 74 Fed. Reg. 4502 (Jan. 26, 2009). FTA is now reviewing
those comments. Also, in May 2009, FTA took steps to address concerns
about the exclusion of some project justification criteria from the
evaluation process. In a Notice of Availability for New Starts and
Small Starts Policies and Procedures and Requests for Comments in the
Federal Register, FTA proposed changing the weights assigned for the
project justification criteria for New Starts projects. See 74 Fed.
Reg. 23776 (May 20, 2009). According to FTA, these changes reflect
statutory direction that project justification criteria should be given
"comparable, but not necessarily equal, numerical weight" in
calculating the overall project rating. See SAFETEA-LU Technical
Corrections Act of 2008, Pub. L. No. 110-244, § 201(d), 122 Stat. 1610.
FTA is currently soliciting public comments on these proposed changes.
[47] GAO, Public Transportation: Improvements Are Needed to More Fully
Assess Predicted Impacts of New Starts Projects, [hyperlink,
http://www.gao.gov/products/GAO-08-844] (Washington, D.C.: July 25,
2008).
[48] DOT program funding includes funding for transit activities
administered by FTA.
[49] The development costs which are included in determining the amount
of eligible tax credits include "hard" costs, such as construction
costs, and most "soft" costs, such as architectural and engineering
costs, soil tests, and utility connection fees.
[50] See 49 C.F.R. § 18.31.
[51] 49 U.S.C. § 5334(h).
[52] Reconnecting America's Center for Transit-Oriented Development,
Realizing the Potential: Expanding Housing Opportunities Near Transit,
April 2007.
[53] 153 Cong. Rec. H15741, H16497 and H16562 (Dec. 17, 2007).
[54] FTA has taken the lead in developing a best practices guidebook on
mixed-income housing and transit-oriented development and FTA has
partnered with Center for Transit-Oriented Development to develop the
guidebook, FTA providing the $60,000 and the Center matching this
funding amount.
[55] On June 16, 2009, it was announced that EPA joined DOT and HUD in
the Partnership for Sustainable Communities.
[56] Additional livability principles include valuing communities and
neighborhoods, coordinating federal policies and leveraging federal
investments, and enhancing economic competitiveness.
[57] Both competitive task orders were issued on June 1, 2009, and must
be awarded by September 30, 2009.
[58] The first policy report is due to be delivered 3 months after the
contract is awarded, the second policy report is due to be delivered 6
months after the contract is awarded, and the third policy report is
due to be delivered 9 months after the contract is awarded.
[59] GAO, Results-Oriented Cultures: Implementation Steps to Assist
Mergers and Organizational Transformations, [hyperlink,
http://www.gao.gov/products/GAO-03-669] (Washington, D.C.: July 2,
2003); Intercity Passenger Rail: Issues Associated with the Recent
Settlement between Amtrak and the Consortium of Bombardier and Alstom,
[hyperlink, http://www.gao.gov/products/GAO-05-152] (Washington, D.C.:
Dec. 1, 2004); United States Coast Guard: Improvements Needed in
Management and Oversight of Rescue System Acquisition, [hyperlink,
http://www.gao.gov/products/GAO-06-623] (Washington, D.C.: May 31,
2006); Telecommunications: Full Adoption of Sound Transition Planning
Practices by GSA and Selected Agencies Could Improve Planning Efforts,
[hyperlink, http://www.gao.gov/products/GAO-06-476] (Washington, D.C.:
June 6, 2006); 2010 Census: Costs and Risks Must be Closely Monitored
and Evaluated with Mitigation Plans in Place, [hyperlink,
http://www.gao.gov/products/GAO-06-822T] (Washington, D.C.: June 6,
2006); FAA Airspace Redesign: An Analysis of the New York/New
Jersey/Philadelphia Project, [hyperlink,
http://www.gao.gov/products/GAO-08-786] (Washington, D.C.: July 31,
2008).
[60] 71 Fed. Reg. 71231 (Dec. 8, 2006).
[61] On June 11, 2009, FTA Regional Administrators were briefed on the
HUD-FTA action plan and notified that the HUD-FTA action plan was
posted on FTA's Web site.
[62] GAO, Urban Partnership Agreements: Congestion Relief Initiative
Holds Promise; Some Improvements Needed in Selection Process,
[hyperlink, http://www.gao.gov/products/GAO-09-154] (Washington D.C.:
Mar. 25, 2009) and Privacy and Security: Food and Drug Administration
Faces Challenges in Establishing Protections for Its Postmarket Risk
Analysis System, [hyperlink, http://www.gao.gov/products/GAO-09-355]
(Washington, D.C.: June 1, 2009).
[63] For the purpose of this report we use the term "collaboration"
broadly to include interagency activities that others have variously
defined as "cooperation," "coordination," "integration," or
"networking." We have done so since there are no commonly accepted
definitions for these terms and we are unable to make definitive
distinctions between these different types of interagency activities.
[64] GAO, Managing for Results: Barriers to Interagency Coordination,
[hyperlink, http://www.gao.gov/products/GAO/GGD-00-106] (Washington,
D.C.: Mar. 29, 2000).
[65] See GAO, Results-Oriented Government: Practices That Can Help
Enhance and Sustain Collaboration among Federal Agencies, [hyperlink,
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21,
2005).
[66] Even though FTA is one of the four DOT surface transportation
operating administrations, we have decided to separate DOT and FTA in
our discussions of agency collaboration since FTA and HUD have
initiated collaboration efforts individually prior to the Partnership
for Sustainable Communities.
[67] GAO, Rural Economic Development: Collaboration between SBA and
USDA Could Be Improved, [hyperlink,
http://www.gao.gov/products/GAO-08-1123] (Washington, D.C.: Sept. 18,
2009).
[68] GAO, Results-Oriented Government: GPRA Has Established a Solid
Foundation for Achieving Greater Results, [hyperlink,
http://www.gao.gov/products/GAO-04-38] (Washington, D.C.: Mar. 10,
2004).
[End of section]
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