January 11, 2008

Ms. Lynn Jacobs, Director Mr. Chris Westlake, Deputy Director California Department of Housing and Community Development 1800 Third Street, Suite 400 Sacramento, CA 95814

Re: Infill Incentive Grant Program Draft Guidelines

Dear Ms. Jacobs and Mr. Westlake:

On behalf of Greenbelt Alliance, I am writing to provide comments on the draft guidelines for the Infill Incentive Grant Program. This cover letter provides a brief summary of our comments. As requested, our detailed comments are included on the accompanying comment form provided by the Department.

Since 1958, Greenbelt Alliance has worked to protect the San Francisco Bay Area’s open space and promote livable communities. Greenbelt Alliance supported Proposition 1C and have followed and commented on the draft guidelines for the various Prop 1C HCD programs.

Thank you for your efforts in developing these guidelines and for the opportunity to provide input. We have comments on several areas of the draft infill guidelines:

Affordability

Given that the intention of voters was to provide funding for affordable housing, we believe that both scoring and award amounts should take into account affordability. The infill incentive funding is most needed for infill projects that have significant infrastructure challenges and face obstacles to feasibility. In the Bay Area and across the State, most of these major projects include a diverse range of proposed housing types, including affordable rental and ownership units. In most cases, well over 15% of the units in these developments are already planned as affordable, and we believe it is both feasible and desirable to reward projects that include more affordable housing at deeper affordability targets. In this context, we support the emphasis in the draft program guidelines on assigning more competitive points to infill projects and areas that include higher percentages of affordable homes at deeper affordability levels.

MAIN OFFICE • 631 Howard Street, Suite 510, San Francisco, CA 94105 • (415) 543-6771 • Fax (415) 543-6781 SOLANO/NAPA OFFICE • 1652 West Texas Street, Suite 163 Fairfield, CA 94533 • (707) 427-2308 • Fax (707) 427-2315 SOUTH BAY OFFICE • 1922 The Alameda, Suite 213, San Jose, CA 95126 • (408) 983-0856 • Fax (408) 983-1001 EAST BAY OFFICE • 1601 North Main Street, Suite 105, Walnut Creek, CA 94596 • (925) 932-7776 • Fax (925) 932-1970 SONOMA/MARIN OFFICE • 555 5th Street, Suite 300B, Santa Rosa, CA 95401 • (707) 575-3661 • Fax (707) 575-4275 [email protected] • www.greenbelt.org

Consistency with regional blueprints

In general, Greenbelt Alliance strongly supports including criteria in HCD and other state planning and capital grants programs which reward projects that are consistent with regional blueprint plans. In addition, as the Bay Area has not formally adopted a regional blueprint plan, we would like to clarify that an appropriate regional entity could certify that a proposed project is consistent with regional smart growth visioning efforts and the ongoing FOCUS process jointly administered by the Association of Bay Area Governments (ABAG) and the Metropolitan Transportation Commission (MTC).

Thank you for considering our comments. We look forward to continuing to actively participate in the Prop 1C implementation process. Sincerely,

Stephanie Reyes Senior Policy Advocate

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