We must balance this commitment with our responsibilities to the quality of life of the adjacent neighborhoods and, with this balance in mind, we present the following three issues:
(1) The underlying zoning issue must be addressed.
Cliff Manor is located on Fort Worth Avenue in PD 714, Subdistrict 4. In this zoning, convalescent, nursing and related uses and community service uses are permitted by SUP only. Please see SEC 51(p)-714.111(a)(4). The property currently has an MF CO with SUP (SUP 537) for operating a residential facility for the disabled and elderly. The FWADG has taken the position that the proposed PSH use is a new use and therefore requires a use analysis leading to one of three outcomes:
(A) the proposed PSH use falls within the MF CO & SUP 537 - therefore, DHA may continue by right;
(B) the proposed PSH use is a non-conforming extension of the existing SUP 537 - therefore, there must be a new SUP hearing involving public input and a decision made by the full Council; or
(C) the proposed PSH use is a new use and under PD 714 this use requires a new SUP - therefore, there must be a new SUP hearing involving public input and a decision made by the full Council.
The FWADG believes (C) is the correct outcome. DHA believes (A). We believe that the physical co-location, as a programmatic requirement, of medical, mental and social services with a residential use defines a new use; namely, under PD 714, Sub 4 either (i) convalescent and other institutional use or (ii) community service center, both of which require an SUP. Simply put, PSH as proposed at Cliff Manor, is not an apartment complex.
We understand that DHA has not been forthcoming or transparent in answering the City's questions regarding the new use. With the task force meetings beginning, we expect DHA to be open and cooperative with the City so that this fundamental zoning issue may be decided.
(2) There needs to be a policy endorsing City-wide implementation of PSH.
On January 28, 2009, the Council unanimously passed Resolution 09-0344 (Consent Addendum Item No. 8 to January 28, 2009 Agenda, page 16):
[A]pproval of a Permanent Supportive Housing Program Statement and five-year plan endorsing
city-wide implementation for the creation of 700 Permanent Supportive Housing units for chronically homeless individuals. Emphasis Added.
As of today, there is no PSH plan or policy endorsing
city-wide implementation. In memoranda dated April 2, 2010 and June 18, 2010, the City spells out in detail the planned locations for the PSH units. Per the June 18, 2010 memorandum,
77% of the 327 location-determined PSH units will be in the Southern Sector. Please see the attached charts and memoranda.
We also invite you to review the following map showing the proposed locations of all PSH units in Dallas, according to the memoranda:
Link: <
http://maps.google.com/maps/ms?hl=en&ie=UTF8&msa=0&msid=113256691954244865729.00048c37a1c8e4f0cf19f&ll=32.824211,-96.799164&spn=0.578163,1.234589&z=10>
This is unacceptable and contrary to Resolution 09-0344. We are urging the City Council and Mayor to work with DHA and MDHA to develop a policy that will ensure
(1) equitable distribution of PSH units throughout our city;
(2) appropriate site concentration guidelines with considerations for schools, high-crime areas, and other contexts; and
(3) an assimilation plan for the formerly homeless.
We strongly advocate for a moratorium on PSH in Dallas until such a policy is put into place. Ad hoc neighborhood-by-neighborhood negotiations, as we are seeing in Lake Highlands and North Oak Cliff, are not the answer. A city of Dallas problem requires a city-wide solution.
(3) Funding.
The City of Dallas directly - and therefore the tax payers - are funding a large portion of this plan to establish 700 units of PSH over the next five-years. According to page 16 of the following Housing presentation, which was wholly incorporated as background material into the January 28, 2009 City Council Agenda binder, and the on-record discussion of January 28, 2009 when the resolution passed, DHA/MDHA need the following funds from the City of Dallas:
http://dallascityhall.com/committee_briefings/briefings0109/HOU_PermanentHousingSolution_01052009.pdf
2009 -
$3 Million from the City of Dallas General Obligation Bonds and Certificates of Obligation
2010 -
$1.5 Million from the City of Dallas General Obligation Bonds
2011 -
$2 Million from future City of Dallas Bonds
2012 -
$2 Million from future City of Dallas Bonds
2013 -
$2 Million from future City of Dallas Bonds
And these numbers are not maximums. Per the on-record discussion between Councilmember Mitchell Rasansky and Assistant Manager AC Gonzalez (approximately recording 2, minute 60 -
http://www.ci.dallas.tx.us/cso/mp3/City_Council_2009_01-28_Part-2.mp3), the actual City of Dallas expenditure may be closer to $18 Million over this five-year period.
Of these funds, $2.5 Million is from the 2006 City of Dallas Bond Package, Proposition 8. Proposition 8, which is funding the PSH reads: "Economic development in Southern Area of the City, and in Other Areas of the City in Connection with Transit-Oriented Development, by Providing Public Infrastructure and Funding the City's Economic Development Programs for Such Areas." Please see page 92 of 100 at the following link:
http://www.dallascityhall.com/pdf/Bond/2006BondProgramPropositionFinal.pdf
We are enacting a program disproportionately placing more than 70% of the planned PSH in the Southern Sector and we, the City of Dallas, are paying for this program, in part, with bond funds earmarked for "Economic Development in the Southern Area of the City."
Please let me know if you have any questions. For a matrix of PSH in Dallas and the June 21, 2010 Briefing to the Housing Committee,
click here.
Thanks for your support.