Make sure you read Exhibit 10, which puts all of this in perspective. Note reference to letters from protagonists Mayor Gallagher and Alderman Quail who wrote in favor of project, which was ultimately rejected. The original project requested a PILOT for 30 years. It was reduced to 15 years after heavy opposition. A PILOT is "payment in lieu of taxes." In the end, the Conifer project was denied by common council. It is worth a second look. See more about this project at Mayor Susan Feiszli's Facebook page: www.facebook.com/pages/Mayor-Susan-Feiszli/215502941817168
April 8, 2008
To: Commissioner Deborah Van Amerongen
DHCR
Hampton Plaza
38-40 State Street
Albany, NY 12207
RE: Specific Objections to Conifer (Cortland Family Housing LLC - Cortland Apartments) Proposal for Subsidized Housing; SHARS ID 20086020
Correction of Misleading or False information and claims regarding Community/Housing Needs and evidence of local Support
This summary addresses specific claims within the Cortland Apartments application for 2008 DHCR funding that are false and/ or misleading. It is requested that the application be reviewed on the basis of the correct data as here in explained:
DHCR App Exhibit 2 - Community Impact/ Revitalization
A. Documentation of Community/Housing Needs
2a Existing Documentation of Local Need
A - Document - Local Needs Document - Local Consolidated Plan
Name: Cortland County Consolidated Plan, Cortland County, Published 10/2002
B- Needs identified:
1. Type of Project: The type of project is for NEW or Additional affordable housing units. The application correctly identifies needs for community revitalization but page 47 indicates only housing rehabilitation and home ownership as needs (see exhibit 1 pg 47) Pg 56 (exhibit 2) again references rehabilitation of existing units as Activity 2 of Objective 3. However, the preceding page 55 that begins Objective 3 specifically states “The high vacancy rates suggest that new subsidized housing may not be appropriate,...” ( see Exhibit 3) The italicized emphasis was by the plans authors.
3 Item 3 Specifically mentions need for proposed project. This is false. In fact, the type of project , building new units, is specifically mentioned as inappropriate. As noted above (See Exhibit 3). The entire emphasis of the Consolidated Plan is on rehabilitation of existing units and replacement.
2a Existing Documentation of Local Need
A - Document Local Needs Document - Community Revitalization Plan
Name: South End Neighborhood Strategic Plan, City of Cortland, Published 6/19/2007
1. Identifies this type of project. The answer is incorrect. As in the Consolidated Plan, the South End Strategic Plan stresses a need for “rehabilitation” not additional units. Pgs 16, 22-23 , 38 reference only poor condition of housing in general. Pg 45 stresses Rehabilitation. The only time new units are discussed is in the context of replacing existing units that are not suitable for rehabilitation and must to removed and replaced. - See below Exhibit 5 which summarizes the five (5) actions recommended within the South End Plan. All address rehabilitation only. “New” is only listed on page 67 which is the summary matrix of the actions listed in the report. Read Exhibit 5 which lists all five recommended housing projects and/or pages 45 through 51 of the Plan which detail the specifics of the recommended actions. None refer to the type of project intended by Cortland Family Housing - which is for new additional units outside of the blighted South End area.
3. See above - need for project type is NOT mentioned in Plan.
In addition, it should be noted that the project is NOT is the South End geographical area. See Exhibit 6 map of the South End Plan. ( It should be noted a small City map in the lower left corner indicates that the actual study area was the general areas from Owego to Main Street from the City line to downtown. The eastern portion included on the Plan map is actually the City Noss industrial park and the former Rosen Superfund clean up site - now vacant and promoted by the City for industrial development. See South End Plan page 17) The Cortland Family Housing site is actually one of the few vacant General Industrial zoned sites in the City of Cortland outside of Noss Park and the Rosen site. Although multi family housing units are not prohibited in Industrial zones, single and two family homes are. The zoning ordinance states that the zone is “created to provide for industrial activities which could have significant adverse impacts upon neighbors ..” (See Exhibit 7 for zoning map and zone)
DHCR App Exhibit 2, B Evidence of Local Support
The following addresses the community supporting documentation of Mayor Gallagher and Dan Quail as listed in Attachment C1:
Gallagher letter - January 31, 2008:
Paragraph 2: states “ the development site is located in the south end of our city..”. This statement is incorrect. The South End Strategic Development Plan does NOT include this site. See exhibit 6.
Paragraph 4 states : “on behalf of Cortland Family Housing, LLC, the City of Cortland, ... give this application your utmost consideration,” . On February 19, 2008 the Common Council voted 5 to 3 to deny Cortland Family Housing, LLC a community development loan. Much discussion occurred , the Council as the governing body of the City of Cortland determined that the support for this specific project through use of Community Development funding was NOT in the best interests of the City of Cortland. ( See Exhibit 8 Common Council meeting minutes)
In addition, 5 of the Common Council members wrote to the Cortland IDA recommending that the Project NOT receive consideration for a PILOT program - See Exhibit 9)
Gallagher letter of February 21, 2008
Paragraph 1 states “The Cortland Family Housing apartments will be within the City’s South End Neighborhood “ . This is false - see attached Exhibit 6 mapping the South End and the Conifer (Cortland family Housing )Project
The third sentence states that the project “specifically addresses the South End Plan by providing “ ‘ energy saving, safety , and special needs housing features so the living units remain affordable and can be enjoyed by all”“ . The quoted line paraphrases sentence 5 of paragraph 2 from page 45 in Section VI - Action Agenda of the Strategic Plan - Problem/Opportunity 1 - Housing. It also is the title of Project 1.4 However, the quote specifically neglects to mention the preceding paragraph on page 45 (see Exhibit 4) and sentences which state the problem is due to deterioration of home ownership and conversion to rental units and that “To reverse this trend, the City should embark on a course of rehabilitation the existing owner- occupied housing market segment and encouraging home ownership programs to increase the level of owner-occupied housing. Tenants also deserve to live in standard affordable housing units, and the City should promote the rehabilitation of the rental market, particularly those units occupied by lower income households. Rehabilitation efforts should preserve and enhance the rich architectural detailiing that give the Neighborhood character. Financial incentives should be developed to assist tenants to become home owners. This action would make the dream of home ownership a reality and help reverse the lack of pride which is evident on some of the neighborhoods streets. New housing programs should..”
All housing recommendations for the South End Plan stress - rehabilitation. See Exhibit 5 and full report pages 45 - 50.
Paragraph 2 again erroneously states that the project is in the South End - see map Exhibit 6
The 3rd sentence indicates the City “has already made plans to spend approximately $175,000 ..” This is erroneous. The City has made an application for Safe to School grant funds to modify sidewalks and provide improvements along Pendleton Street as it serves an existing low income housing project to the south of the Cortland Family Housing LLC site to have better access to the High School and Randall School. No expenditure of City funds is anticipated without the grant.
Paragraph 3 states “on behalf of the City of Cortland ... I welcome this proposed project to the South End neighborhood”. As noted above Exhibit 6 - the site is NOT in the South End Neighborhood. As per Exhibits 8 and 9, the majority of the governing body of the City of Cortland, the Common Council, rejected the use of City Community Development funds for the project at its meeting of February 19, two (2) days prior to the letter.
Dan Quail letter of February 22, 2008
Paragraph 1 - second sentence states “ the project is critical to the continuation of re-developing the City of Cortland’s South End Neighborhood”. As noted in exhibit 6, the project is NOT located in the South End Neighborhood.
Per pages 45 - 50 of the South End Plan - the type of project proposed is NOT recommended as part of the South End Plan - Only rehabilitation of existing units and replacement of or removal of existing units to reduce densities, and promotion of home ownership are recommended. No part of the plan recommends construction of additional units.
DHCR App Exhibit 2 D - Community Needs Narrative:
1 Paragraph 12 conclusion states that “ substantial current need and an identified pressure in the near future to provide additional quality affordable family units.” This is a false statement. As per the Consolidated Plan pg 55 (see Exhibit 3) additional units are specifically noted as being undesirable.
The general discussion of Item 1 of D is correct in that affordable housing is needed. However, all plans quoted also specifically note that there is a high vacancy rate within the City and that additional units will only exacerbate the problem. The Consolidated Plan and the South End Plan both stress removal of existing units and rehabilitation. Additional units will degrade housing quality in general in the long run.
3 Paragraph 2 state the project is part of “..the South End Strategic Plan” . This is false see map Exhibit 6
Also that it is part of “Cortland County Consolidated Plan 2002" This false as per pg 55 of Plan - See Exhibit 3
Paragraph 3 same - see exhibit 3 and 5
Paragraph 4 . This again makes the false statement that the project is in the South End Strategic Neighborhood - See Exhibit 6
Paragraph 5 state there is a “..great need for the Project in the Neighborhood “ This is again a false statement as it is NOT in the Neighborhood. (Exhibit 6) and the Plan indicates per pages 45-50 (see Exhibit 5) that rehabilitation is needed and reduction is concentration and density of units is needed.
Paragraph 6 references Mayor Gallagher and Councilman Quails letters - See above comments on these letters - claims of public support are false.
Paragraph 7 references “ .. The City has committed to infrastructure improvements at the project site” The City has made a grant application for Safe to School funds in the area and not specifically for the project. No commitment of City funds has been made and noted improvements are contingent upon receiving grant funds. Sewer improvements are City wide due to excessive infiltration/inflow problems that have plagued the system for decades.
Paragraph 8 falsely states the project is part of the south end plan (see exhibit 6) and indicates “implementation” of significant measures by the City. Only the sewer project is ongoing.
DHCR App Exhibit 8 - Site and Building Information
Item 7 a. Site is free of hazardous materials and incompatible adjacent uses. This was answered yes. In fact the site may have some residual hazardous materials as evidenced by Pat Snyder letter of ( see exhibit 11). It is also in an industrial zone with the following surrounding uses :
East - rail road line and scrap yard - demolition company processing faciltiy
North - industrial facility
South and East - County Recycling facility
All of the above would be considered incompatible uses.
In conclusion, there is no disagreement that there is a need for affordable housing. However the application fails to mention, and the Project address, the high existing vacancy rates. Projects recently undertaken in the City by Housing Visions where rehabilitation or replacement in kind are the type of government subsidized housing that is needed and acceptable within the guidelines of the Consolidated Plan and the South End Plan. Also needed and stressed to a greater extent, is the need to promote home ownership programs for middle and lower income individuals and to reduce high density rates.
Very truly yours,
EXHIBIT 5 - SUMMARY OF HOUSING PROJECTS RECOMMENDED IN SOUTH END STRATEGIC PLAN
The South End Strategic Plan suggests 5 specific projects to meet the Housing needs identified. They are :
1.1 - Housing rehabilitation program in the South End for Owner occupied and Income property page 46
1.2 - limit conversion of owner occupied housing to income and encourage converting income property to owner occupied - page 48
1.3 - demolish properties not fit for rehabilitation and reduce density - specifically lots with 2 structure and insufficient parking page 49
1.4 - “promote energy saving, safety and special need housing features so the living units remain affordable and can be enjoyed by all” The sentence next states that in order to be affordable for households, “housing rehabilitation must consider energy saving features ” and “Rehabilitation must take into account the needs of individual household members such as features that allow the elderly to age in place ..” and “address lead base paint, asbestos, and smoke and CO detectors ..” pg 49
1.5 - Encourage development of more middle income housing - to diversify the neighborhood. Pg 50
As can be seen ALL recommendations associated with the South End Strategic Plan specifically target “Rehabilitation” and reduction in densities. No NEW multifamily developments are suggested
.EXHIBIT 10 - PORTIONS OF CONSOLIDATED PLAN.
Attached below are excerpts from the COrtland County Consolidated Plan and pages from the South End Strategic Plan. Even though the project is NOT in the South End - both documents clearly stress the need for affordable housing through “rehabilitation” and specifically state that NEW or Addition housing units are NOT desirable.
Excerpts from the Consolidated Plan are attached. The full plan can be found on the Cortland County web site http://www.cortland‑co.org/Planning/ConsolidatedPlan.pdf
OBJECTIVE 1 was to:
“ Improve the condition of the existing housing stock in the community, especially housing which is owned, occupied, or available to low to moderate income residents” The following activities were listed as priorities in order:
Activity 1: Renovate existing rental properties thru rehabilitation programs
Activity 2: Renovate owner-occupied housing through rehabilitation programs
Activity 3: More aggressive code enforcement to maintain rental and owner-occupied housing units as “standard”.
Activity 4: Coordinate inspection of student housing and enforcement of housing code to ensure that student housing meets housing code standards, at a minimum
Activity 5: Review local codes, and revise as needed to enable “proactive” code enforcement
Objective 2 was: “Increase the level of home ownership”
Activity 1: Encourage and promote home ownership through programs that provide assistance to low- and moderate-income first-time home buyers
Activity 2: Limit the conversion of single-family homes to rental properties.
OBJECTIVE #3: Increase access to affordable, quality rental properties
Need: While rental vacancy rates remain high in the City and villages, waiting lists for quality subsidized housing and Section 8 Housing Choice Vouchers remain long. The high vacancy rates suggest that new subsidized housing may not be appropriate, however, the long waiting list for subsidy programs suggest that the supply of affordable quality rental properties is an issue in Cortland County.
Activity # 1: Income property rehabilitation incentive programs should be conditioned on rent subsidy programs and/or affordable rents. Rental property rehabilitation programs (as discussed in Objective #1) if successful, will increase the amount of available quality rental properties. Linking rent subsidy/assistance programs and/or affordable rents as a prerequisite for participation in the rehabilitation programs will ensure that these rental units, once brought into compliance with housing quality standards, will remain affordable to low to moderate income persons and families.
Activity #2: Identify and pursue funding opportunities for additional rental assistance programs, as they become available. Cortland County community housing agencies should seek to provide additional subsidies, including additional Housing Choice Vouchers, to low and moderate income families and individuals, for existing rental housing which meets housing quality standards, as funding become available. As detailed more fully under the “Homeless and Supportive Housing Needs” section below, there is a significant need to provide affordable housing that is accessible to disabled individuals. Funding should be sought to provide rental subsidies specifically for this population.
Proposed Accomplishments: A stronger supply of affordable rental housing that meets housing quality standards will ensure that even those in the community with limited financial resources will have access to decent, affordable housing options.
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