November 3, 2026
Dear Town Councilors and County Commissioners,
Thank you for taking the time to review the Housing Rules and Regulations. We recognize the importance of updating these rules regularly to reflect both the changing needs of community members and dynamic conditions of our region. We support the hard work from the Housing Department staff and Housing Authority board to provide recommendations regarding potential updates. Please consider our comments below.
- Should first responders receive first preference in weighted drawings?
We support the original staff recommendation to keep the current system in place and continue to provide extra lottery entries for first responders.
ShelterJH supports ensuring that first responders can access affordable housing, and believes that the current method of providing extra lottery entries for weighted drawings is sufficient to recognize the importance of their professions. First responders are essential members of our community, and so are teachers, childcare providers, snow plow drivers, restaurant workers, nonprofit employees, and the many other workers who keep Teton County functioning. We do not support giving additional preferential housing access based solely on first responders’ occupations or volunteer history.
The lottery system that governs the allocation of publicly-subsidized homes should reflect the housing needs of all folks who are facing long commutes, rising rents, and other unstable housing situations. We agree with the editorial published in the Jackson Hole News and Guide on October 14: “Emergency responders are vital, but many other occupations also provide essential services that support the health, safety and daily functioning of the community. We shouldn’t be reducing housing opportunities for one group to boost another.”
The Town and County may want to consider additional preferential treatment for first responders in the homes they provide for their own staff. We also remind elected officials that one of the most direct ways you can help locals stay local and provide opportunities for the many folks who call this community home is by increasing supply, i.e. building hundreds of homes on the Virginian parcel as soon as possible.
- How should the 60-day vacancy requirement for new restricted rental units be enforced?
Overall, we support the staff and Housing Authority Board’s recommendation to require a 20% decrease in rent after 60 days of vacancy, plus an additional 10% reduction after each 30-day period, combined with a $100 fee for each subsequent week the home is empty.
ShelterJH supports codifying rent reductions for vacant deed-restricted homes because we believe this added enforcement will enable homes to be available at affordable rents to locals sooner. In many cases, developers of deed-restricted homes have already received a public benefit by the time certificates of occupancy are issued. Codifying rent reductions will ensure that the public receives their benefit in return: affordable homes for locals.
Furthermore, we have heard reports of developers offering concessions to attract renters, such as free rent for a limited period, appliances, or other amenities. Codifying rent reductions would help prevent developers substituting these temporarily beneficial offerings for what the community really needs: meaningful rent reductions. We recognize that a uniform reduction may not be appropriate for every project. For example, if hundreds of units become available in one complex at the same time, electeds may want to consider a variance to allow the units to be absorbed into the market; however, any flexibility should be based on evidence and should not undermine the goal of providing housing that local residents can afford.
Codifying this policy would establish clear expectations for developers, provide greater accountability for ensuring that developer incentives result in their intended purpose, and build credibility for the housing program by avoiding the existence of empty deed-restricted homes.
- Should owners of restricted homes pay an administration fee to the Housing Department?
We support the staff recommendation from August 3 to impose a $50 annual compliance fee, with a 2% annual increase, for future deed-restricted homeowners.
Part of keeping locals local is ensuring that the entities that provide and manage deed-restricted housing stock are adequately funded. Funding is needed to support staff, compliance monitoring, and pursue new housing opportunities. Annual administration fees are an established practice among housing organizations, including the Wyoming Community Development Authority and the Jackson Hole Community Housing Trust.
Because property owners benefit from deed restrictions through reduced sales prices, long-term stability, and appreciation associated with homeownership, a modest fee is a reasonable way to help support the ongoing monitoring and administration necessary to protect our community’s investment in deed-restricted housing.
- Should restricted homes have maximum occupancy requirements?
We support the Housing Authority Board’s recommendation to impose HUD-defined occupancy limits to homes specifically naming one-bedroom units as able to hold 2 adults plus one minor. ShelterJH wants deed-restricted homes to provide safety and stability while recognizing that regulations should not unnecessarily prevent different kinds of families from accessing housing.
- Should income ranges be changed to narrow the ranges?
We support the Housing Authority Board and staff recommendation to narrow income ranges.
ShelterJH supports narrowing the income ranges for deed-restricted housing to better align rents and sale prices with households’ ability to pay. We agree with staff and the Housing Authority Board that creating narrower income ranges would allow housing opportunities to be targeted more precisely and result in a more precise allocation of homes. We believe that the initial investment in updating this administrative change will have a quick and vital return for the housing program overall.
In conclusion, ShelterJH appreciates the attention staff, the Housing Authority Board, and elected officials have dedicated to these updates. We encourage the Town Council and Board of County Commissioners to adopt these update rules to ensure that deed-restricted homes are allocated equitably while sustaining the vital work of the Jackson/Teton County Housing Department.
Thank you for your consideration and for your continued work to address our community’s housing challenges.
Best,
Clare Stumpf
On behalf of ShelterJH board members and membership
