Affordable Housing Rules and Regulations

Affordable Housing Rules and Regulations

April 11, 2018

The town and county invited for further public comment on some of the details of their most recent drafting of rules and regulations for affordable housing in our community. Below are some of our thoughts and opinions on the staff’s recommendations and the general discussion of housing in our community! We are stronger together, not divided.


Dear Mayor Muldoon, Town Councilors, and County Commissioners:

Thank you for the opportunity to comment on your joint housing rules and regulations, and thank you and your staff for a tremendous amount of hard work on these important subjects.  

ShelterJH is a membership organization that works to ensure all who work in Jackson can have a home here. When people move out or commute, we lose critical service providers on-site, and we lose volunteers and active members of our community. Therefore, as we consider changes to housing rules, regulations, and zoning, we should always ask what the changes will do for our workers and community – especially our community members in the most vulnerable situations.

We have one high-level comment, and then comments on a few topics that we understand are still being discussed.

Overall, we believe the whole discussion of housing rules & regulations has been framed in a very limited way: Currently, affordable homes are viewed as a gift from our community to a few deserving individuals who have earned the homes through their merit, hard work, and type of work – and therefore our regulations should be very strict to make sure that only the most deserving people get and keep affordable housing. This whole frame misses the point. It’s not about the individuals at all – it’s about what kind of community we want to be. We believe a diverse community is a better community – and that we all benefit when our workers can live here. We aren’t “giving” homes to people – we’re creating opportunities that don’t otherwise exist for a diverse community that benefits all of us. If we don’t create affordable homeownership and rental opportunities, we’ll end up an empty husk of a resort town – and none of us want that. Seen in this light, the purpose of these rules and regulations should be to set up simple and streamlined opportunities to ensure a diverse community of local workers. Overall, we believe the current proposal is overly regulated, overly punitive, and overly expensive to administer.  Please use our tax dollars on building community rather than surveillance of affordable homeowners and tenants.

Occupancy requirements

Your current draft regulations add more restrictions to the size and types of households that can apply for different sizes of units. We ask that you base occupancy on number of persons in the household and not distinguish between adults and dependents. Based on discussions with two Fair Housing experts, we believe that restricting applications based on familial status (i.e. whether children are in the household or not) violates Fair Housing rules. Just as one example: a household of 2 should be able to apply for a 2-bedroom unit, regardless of what kind of family that is (a couple or a single parent with a child). Adding more rules makes this more restrictive and complicated. Please do not discriminate based on family / household make-up.

Lottery / drawing process

We are glad to see the new lottery process has been streamlined to only one “bucket,” so everyone who applies actually has a chance to win. This is a notable improvement over the old system. The goal should be creating a simple and equitable system that can retain local employees. Putting in more applications is irrelevant to our goal of retaining a diverse local workforce and is unnecessary. Increasing entries based on the amount of time you’ve lived here adequately provides priority for longevity in the community. Please do not add “number of past applications” to the drawing process.

Renting rooms in an affordable/employment home

When it comes to renting rooms, our goal should be to fill all available rooms with qualified employees, and to simplify the rules – not to generate revenue for the housing program. There are currently empty bedrooms, often the result of changing family status – why not let homeowners rent them to qualified renters? It is a cost-effective and environmentally sensitive way to get some of our employees in a safe and healthy living situation.  To your staff report questions:

  1. Yes, please allow rentals. Especially in employment-based homes without income restrictions, there is no reason to prohibit roommates. And in both employment-based and affordable homes, allowing roommates who also work here further helps house our workforce – which is our goal.
  2. The annual fee should be a simple and low flat fee of $100. Again, the goal isn’t to fund our housing program – it is to get more people in affordable housing. Yes, that takes staff time – but that’s why we fund the Housing Department with existing funds. Staff should not be involved in collecting rent – keep it simple.
  3. Maximum rents should be very affordable, and linked to maximum rents in public rental units. We suggest that all rented rooms (regardless of the category of the home) have a maximum rent that is affordable to 1 person at 50% AMI. (Option 3 at $460 seems most appropriate.) We do not support splitting rent with the housing department. Again, the goal isn’t to raise money, it’s to house more people. If a homeowner only gets half the rent, there’s much less incentive to rent your room to someone who needs it – and it’s more costly to administer.

Overall, please choose the policy options that are the simplest and do the best job at housing our local workers – especially those in most need (people earning below 50-60% of area median income).

Thank you for your consideration,

Mary Erickson