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              Retort to Housing Commission's Response
                         
                by Fred Schnaubelt

     
May 9. 2003


Ms. Elizabeth Morris
San Diego Housing Commission
1625 Newton Avenue
San Diego, California 92113

Dear Betsy:                                                RE: Letters to Mayor & City Council

What a joy to hear from you.  You defend the indefensible with such panache! This is why I tell people you are
my favorite bureaucrat of all time. You spent a lot of time addressing the concerns I expressed to the Mayor and Council, which I genuinely appreciate. Sot it's only fair that I thoughtfully respond to your points.

To begin with, I wasn't aware that the Housing Commission was charged with the responsibility of neighborhood revitalization in addition to helping people find decent housing. I take your word for it that Metro Villas are more than just housing and that's why they are more expensive than 99% of the privately built, non-subsidized, for-profit rental units in San Diego. You also say that Metro Villas are an example of smart growth. Thank you for confirming that smart growth is far more expensive than traditional development, just as critics have claimed. I agree with what you have made obvious--smart growth makes new housing much more expensive, not less.

In paragraph 4 of your response, you state my, "cost comparisons of Metro Villas (a new construction project) to apartments of various ages, bedroom sizes, locations, etc. are not comparing like properties. Also, complexes like Metro Villas will cost more per unit ($199,278) because "this development provides three and four bedroom apartments and housing types the market is unable to serve". It appears that you are saying that the housing in which 99% of non-subsidized renters now live isn't good enough for poor people.
      
I refer you, however, to the sale of four apartment projects that were built in 2001 and 2002 (the newest I could find) for a closer comparison. I believe they qualify as new construction for our purposes. The 284 unit project at 4705 Frazee, Oceanside, sold for $117,000 per unit, consisting of 78 one-bedrooms, 166 two-bedrooms, and 40 three-bedrooms. The 183 unit project at 7077 Navajo Rd., San Diego sold for $185,000 per unit, consisting of 98 one-bedroom units, and 85 two-bedroom/two bath units. The 251-unit project at 8465 Regents Rd., San Diego, sold for $197,211 per unit, consisting of 149 one-bedrooms, 98 two-bedroom /two baths, and 4 three-bedroom/three bath units.  The most expensive new apartments, 139 units at 10902 Evening Creek Dr., Sabre Springs/RB, sold for $199,280 per unit, consisting of 97 two-bedroom/two baths, and 42 three-bedroom/two baths.  The land cost is substantially higher at all the above locations compared to 39th and Polk. I stress that all of these new apartment buildings are among the most expensive apartments in San Diego, Luxury Apartments for the most affluent renters.  (As you know, one-bedroom and two-bedroom units are more expensive per square foot than three and four bedroom units because the kitchens and baths  are the most expensive part of the construction and larger units afford more square footage over which to amortize these costs.)

It is irrelevant that the parties you listed, who are each making money off the project, found the cost of Metro
Villas acceptable. What else would they say, "You're paying me too much?"

You mention Knox Glen, a previous record price setting Housing Commission project, one of several government projects over the past 25 years for which I requested a GAO investigation. Your recollection is partially correct. The GAO said Knox Glen construction costs were reasonable compared to other similarly funded Tax Credit projects and that a $781,000 developer fee (on 54 units) "was allowed". However, I remind you that the new larger 3 and 4 bedroom homes across the street were advertised for up to $20,000 less per unit. The GAO agreed with my allegation that Glen Knox was more expensive than brand new condos just completed at the same time next to Hazard Center in Mission Valley and in Scripps Ranch on Scripps Creek Dr. -- both upscale locations by comparison. The GAO found no evidence of any illegal acts or violations of HUD regulations.  The GAO said I was unaware of any commission of fraud, which I stipulated from the outset in requesting the investigation; and I have never contended there was any fraud on the part of the Housing Commission.  Fraud or possible fraud is the major concern of the Inspector General. My concern is the astronomical cost of public housing, however the responsible politicians may rationalize it.

I have not been alone in my concerns over the years. In 1994 the U.S. House of Representatives' Committee on Government Operations published a report on Section 8 Housing. It found that in some HUD projects,
"the rent for a two-bedroom apartment was more than $800, compared to similar private sector apartments available nearby for just a little more than $400."  In another example, it reported, "Section 8 two-bedroom apartments renting for $1,100, while rents for a two-bedroom unit in a well-maintained unsubsidized property in the same general area ranged between $600 and $750 a month."  Furthermore, the Inspector General found in a project that was part of the investigation that "Section 8 rents were 170% of the Fair Market Rents."

In a Report to Congress, The Comptroller General stated: "The cost of much of the housing the program provides is equal to or exceeds the income of many of the families being served. For a family receiving housing assistance equal to its income, a quadrupling of income would be required before the family could pay its rent with no more than 25% of its income.  "We are concerned about this captivating effect of the program." (Pg 13) Although gross rents are not supposed to exceed fair market rents, they were found to be higher in 68% of the projects GAO sampled." (Pg 32) 

It was the Comptroller General, not me, who first said,  "Many Section 8 projects were so expensive that only the poor could afford to live in them." (Pg 76)

When he was Secretary of HUD, James T. Lynn testified before the U. S.  Court of Appeals that "the construction costs of Section 236 units are on average 20% higher than those of comparable unsubsidized units, and that rents are at least 10% higher." (Federal Reporter, Pg 866)  When George Romney was Secretary of HUD, he said, "It appears Government will never be able to provide housing without it costing 20% to 40% more than the private market."

While the above did not specifically point to San Diego, I am suggesting the Housing Commission is simply following a long tradition of inefficiently providing extremely expensive housing under the auspices of the government.  The same money invested by the private sector would produce 20% to 40% more housing.  I admit it's virtually impossible for the government to provide any housing at the same, much less a lower cost, than private developers.  This is because at the minimum you have all the costs of a private developer plus the Housing Commission's oversight, the City Council's oversight, state and federal government overhead costs, and the inherent inefficiencies of government. These are only a few of the reasons why even non-profit housing is also more expensive than private development. The Housing Commission simply cannot build affordable housing anymore than can private developers.

On page 2, paragraph 1 of your letter concerning City owned homes in high priced areas (La Jolla), you asseverate that I do not take into account the limited number of such units and you refer to the City's Balanced Communities Policy. This is what I love about you Betsy.  Whereas I, and nearly 100% of the people in the U.S. believe that even one poor family living in a million-dollar-home at taxpayer expense is one too many, you boldly and forthrightly justify the absurdity as not wanting to segregate lower-income from upper-income families.  Statements like this bring a chuckle from my cheeks and a smile to my lips.

In paragraph 3, you state, "this flexible inclusionary housing program would have a modest impact, if any, on (all other) housing costs...." Furthermore, "Any cost impact would be absorbed by land sellers, developers and, to some extent, by homebuyers."   You've got to be kidding.  However, if you truly believe this then please explain why the tens of thousands of dollars in fees assessed by the city have been added to the cost  of each new home rather than being deducted from land prices and the profits of developers and their subcontractors?  Under your premise there should have been a wash, and land prices should be falling.

By the way, it was the Federal Home Loan Bank of San Francisco that brought to my attention the impact of government adding to the cost of new housing, a cost that then percolates throughout the entire inventory of housing in a region.  A survey by the bank found an almost dollar for dollar increase, after a lag time, between new and used housing.  You can confirm this by looking at how the average price of resale homes and apartments rise in tandem each year with the rise in costs of new homes and apartments.  Why do prices  keep increasing beyond the CPI?  When the opportunity cost of new housing is beyond reach, buyers go to the nearest substitute and bid up the price to the point where, in their subjective opinion, they get the most for their money.  This is why homes in North Park have risen from $18,000 when I started in real estate to $400,000 today. Rising in tandem each year with the price of new housing.  Inflation accounts for less than $100,000 of the increase. Before "Growth Controls" were implemented, the median priced home in San Diego was less than the national median. Now, San Diego far exceeds the national median of $163,100, and isranked among the least affordable markets in the U.S.

In paragraph 4 you say, "All three of your letters decry housing subsidies for lower income families. Yet, we could find no record of any protests by you against the largest housing subsidy in the United States -- the $90 billion income tax deduction for mortgage interest that benefits homeowners." First of all, Betsy, a subsidy is a grant of money from the government to someone else. When this occurs, money is usually taken from people who earned it and then given to people who did not. "All political power derives from what you can do to, or for someone."  Second, unless you're prepared to argue that 100% of all money earned belongs to the government, allowing people to keep their own money (even through an income tax deduction) is not a subsidy, but what we call freedom.   The people of the United States are citizens, not serfs. (I know it is silly and condescending to remind you of this, but it sounds so good.)

In paragraph 5 you say that the City needs to act in order to supply housing at varying price points that families of different incomes can afford.  Betsy, no one "needs" a brand new condo, home or apartment any more than they need a brand new car.  Brand new housing is a luxury not a necessity.  People who can only afford used cars can also live in used housing.  And please, don't even think about making car manufacturers sell 10% of their "new" vehicles to the poor.

We agree, as always, on the advantages of living and working in a city where ordinary people can afford to rent or own a home of their own, and the benefits to business and the local economy. You seem, however, to believe that the very government that's causing the problems can correct them by continuing to do the same things that created the problems in the first place. Respectfully, I disagree.  I recognize that the current situation is not of your doing.  Politicians, trapped between their environmental rhetoric and their professed social concerns, try to reconcile the shortage of land (MSCP, down zonings) and higher home prices they've created -- with inclusionary zoning. Builders are their scapegoats and they pray to you for their salvation.

Affectionately,
Fred
 
Fred Schnaubelt
2728 Adams Avenue
San Diego, CA. 92116

 


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