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    Anthony Gill

    Housing and Homelessness Policy

    Dr. Elsa Chen

    10 June 2014

    Implications of Land-Use Planning Strategies on Affordable and Mixed-Income Housing

    INTRODUCTION: An Unfortunate ConflictBut Need There Be?

    On March 10, 2013, residents of the Winchester Ranch Mobile Home Community in San

    Jose, California received one-day notice of a Planning Commission meeting which would

    include a discussion of the so-called Santana Row/Valley Fair Urban Village Plan (Save the

    Winchester Ranch). The plan was originally intended to unify urban planning efforts in the

    vicinity of the popular Santana Row and Valley Fair upscale shopping centers. Instead, due to the

    inclusion of the mobile home park, it has become a touchstone of sorts for the ongoing battle

    over affordable housing and gentrification in the high-tech, high-income Silicon Valley region.

    Understandably, residents, mostly low-income or disabled seniors, were livid. By

    including the park in the urban village plan, the City of San Jos dramatically increased the value

    of the property, virtually guaranteeing that it would be redeveloped. By July, the owner, Cali-

    Arioto Properties, was in talks to sell to market-rate developer Pulte Homes, with the expectation

    that the seniors would be evicted with little to no assistance in relocation (Bigler). Residents and

    affordable housing advocates exerted more pressure, and by April of 2014, the city was

    considering a moratorium on mobile home conversions to allow time to, according to Vice

    Mayor Madison Nguyen, ensure thatexisting laws governing conversions are clear, up-to-

    date, and adequate given the changing state of the economy (Wadsworth).

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    It was a small victory for residents of the park, but the battle illustrates a crucial real or

    perceived conflict between new development and affordable housing. In other areas of the

    country, similar controversies are playing out over mixed-income housing, inclusionary zoning,

    and other land use issues. Residents and elected officials alike often lack sufficient knowledge

    about urban planning best practices and ways to mitigate the negative impacts of development.

    Even mixed-use urban village projects can be planned in such a way as to benefit low-income

    and lower-income residents. But while land use regulation and mixed-use infill development do

    pose significant opportunities for ameliorating the affordable housing dilemma currently facing

    many cities, they come with their own set of of unique challenges that can make or break entire

    projectsnamely, uncoordinated local policies, community and neighborhood support, and

    simple economics.

    SECTION 1: The Problem with Sprawl

    With the mass production of the automobile and the advent of freeways in the 1940s and

    1950s, the urban areas of the United States underwent a massive expansion that resulted in the

    modern American suburb. Unlike more traditional urban areas, these often far-flung bedroom

    communities strictly distinguished between residential, commercial, and industrial areas.

    Automobile use thus became a virtual prerequisite, necessitating wide freeways, multi-lane city

    streets, and expansive surface parking lots for commercial centers. As regions grew, public

    services, like water, sewer, police, and fire, were extended to newly-incorporated or -annexed

    areas, increasing the burden on local governments and taxpayers, Before long, the suburbs had

    become almost cripplingly expensive. Still, they proved quite popular with families, the middle-

    class, and the wealthy.

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    Over the past several decades, however, dense urban cities became increasingly popular

    as younger college-educated professionals returned in droves for their wide array of

    entertainment options and job opportunities. Cities could offer a tightly-packed living

    environment with a lower per-capita cost, opportunities to walk, bike, and use transit to

    commute, and enriching arts and culture activities. Moreover, thanks to their smart urban

    planning and effective density balances, they could support a wider array of housing choices. In

    response to these changing cultural attitudes, urban planners developed new zoning types, in

    both cities and suburbs, to spur redevelopment and increase housing affordability.

    Mixed-use or urban village designs became by far the most popular. According to the

    American Planning Association, which represents the professional urban planning community,

    mixed-use development blends residential, commercial, cultural, institutional, and sometimes

    even industrial uses. These types of projects allow for greater housing variety and density,

    strengthen neighborhood character, and promote pedestrian and bicycle-friendly

    environments (Mixed Use Development). By favoring denser, more tightly-packed

    developments with large numbers of small units, urban planners argue that affordable housing

    can become a more profitable enterprise. Planners envision these zones as becoming mini-

    downtowns for neighborhoods, with community retail, housing, and often, city services, such as

    libraries and public squares. In some cities, urban villages have been organized around university

    campuses, medical districts, and office parks.

    With prominent examples of mixed-use developments, such as Santana Row, catering to

    the wealthy, it would be easy to dismiss the strategy as a non-solution. Surprisingly, however,

    these concepts hold great promise for affordable housing advocates. With a large number of

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    units, low-income and lower- to middle-income housing can indeed become more affordable

    (Quigley 69). And with easy access, often by foot or transit, to jobs, healthcare, and other

    essential services, dense, mixed-use urban villages might also provide an increased level of

    upward mobility (Chetty, et al.). More innovative mixed-income housing models have utilized

    mixed-use practices with an eye toward social mixing, in hopes of providing further benefit to

    lower-income residents. As such, mixed-use and urban village development forms, as

    incentivized by inclusionary zoning requirements, can offer unique and tangible benefits to even

    the lowest-income residents. Of course, the primary challenge lies in the promotion of policies to

    prioritize these types of equitable developments.

    SECTION TWO: Promising Policy Prescriptions

    Introduction

    In late 2013, protests erupted in San Francisco over the use of public transit stops by the

    employee shuttles of Silicon Valley technology companies. The Google bus protests received

    widespread national and international press attention as anti-gentrification activists and

    affordable housing advocates engaged in mostly peaceful demonstrations against a perception of

    growing income inequality in the city. Essentially, the protesters argued that the Google buses

    compound the problem by making San Francisco a more desirable home for tech workers than

    cities like Palo Alto, Mountain View, and San Jose, which lie closer to their jobs but also lack the

    urban amenities craved by young professionals.

    Indeed, its a powerful argument. Transporting workers to the suburbs instead of

    developing housing opportunities and amenities in the suburbs creates a host of new land use

    issuesin both cities and suburbs. But perhaps policymakers and activists can strike a middle

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    ground. With the advent of new development practices and policy prescriptions, such asinfill

    development, mixed-income housing, and inclusionary zoning, the cause of redevelopment need

    not conflict with efforts to improve housing variety.

    Infill Development

    In many urban areas, surface parking lots and old, dilapidated buildings limit housing

    growth and decrease economic and civic vitality. By infilling these underutilized properties

    with denser, mixed-use development, urban planners argue, affordable housing will blend with

    market-rate units until the two become nearly indistinguishable. (Note that community advocates

    and politicians often use such terms as infill, mixed-use development, urban village, and

    smart growth somewhat interchangeably.) For their part, city politicians see infill

    development as a way to expand their tax base, attract more middle-class residents to the city,

    and build more affordable housing (Steinacker 492).

    Similarly, in a brilliant piece in the civic affairs journal Urban Studies , researcher Andrew

    Aurund notes that smart growth proponents often argue that greater density, a greater variety of

    housing types, and mixed land use can alleviate the upward pressure on housing prices because

    dwelling units in locations pursuing these three goals aresmaller and consume less

    land (1016). Indeed, while advocacy groups like Smart Growth America often tread carefully

    around mention of affordable housingperhaps for fear of increased oppositionthe

    coalitions website notes that the diverse mix of housing options in smart growth

    neighborhoodsmeans people with different housing needs can all live in the same

    neighborhood (Housing). But does mixed-use development really work as well as proponents

    advertise?

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    As it turns out, at least some of the claims of smart urban growth proponents may stand

    up to quantitative research. In his study, Aurund finds that in two Northwestern cities, Portland

    and Seattle, which both adopted strong density guidelines and urban growth areas in the 1990s,

    the percentage of rentals available for very low-income citizens increased after the policies were

    enacted and density levels increased (1029). Indeed, he notes that the research suggests that a

    neighborhood with greater density and with a greater variety of housing types is likely to have a

    greater quantity of affordable rental units than a low-density neighborhood consisting of single-

    family homes (Aurund 1032).

    On the other hand, in a broader, more national study of fifty of the largest metropolitan

    areas, researcher Annette Steinacker finds that while infill development can benefit cities tax

    bases, revitalize neighborhoods, and slow urban expansion, it also results in higher market-rate

    housing costs, especially for the multifamily units typically more likely to be developed in

    combination with affordable units (504-505). Perhaps more concerning, her research finds that

    the regions most likely to attract infill are already more expensive than others.

    As such, affordable housing and density can still be considered somewhat contradictory

    goals that must be carefully balanced. While major benefits for cities can be realized when

    smartly-implemented policies mitigate upward pricing pressures on market-rate units, developers

    and policymakers must still work together to ensure a strong mix of housing options, increased

    density, and a mix of land uses.

    Inclusionary Zoning

    Since the landmark United States Supreme Court ruling in Village of Euclid v. Ambler

    Realty Company (1926), cities have been assured of the broader constitutionality of traditional

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    zoning regulation practices. Typically, zoning in cities is used to regulate uses and provide

    spacial requirements; however, land use planning should also consider the communitys need for

    affordable housing (Lerman 385). Inclusionary zoning offers local governments a method to

    ensure that developers create affordable residential units as a part of any new

    development (Lerman 385). In other words, these regulations require that new housing

    developers contribute a certain amount of funds to the development of affordable units. This can

    be done through fees paid to the city of through directly-developed units. Often, in return for

    complying with the regulations, cities grant so-called density bonuses to developers, which

    allow a greater number of units on a site than otherwise would be allowed.

    New York City, for example, has adopted a inclusionary zoning program under which

    developers are allowed 33% more square footage in a development as long as they set aside 20%

    of the units for affordable housing (Barro). While the developers of massive projects with

    hundreds of units have taken advantage of the rules, the response to the voluntary program

    among small- and medium-scale developers, somewhat understandably, has been quite tepid.

    Only 3,000 affordable units are estimated to have been created between 2005 and mid-2013

    (Barro). Some developers argue that because market-rate units essentially subsidize the

    affordable units, the use of inclusionary zoning incentives will cause housing prices for

    moderate-income families will increase. Still, Bill de Blasio and other city officials argue that the

    program should be made mandatory in certain areas.

    Legal analyst Brian Lerman argues in no uncertain terms that mandatory inclusionary

    zoning could be the answer to the affordable housing problem. In his analysis published in the

    Boston College Environmental Affairs Law Review , Lerman notes that mandatory programs have

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    in the past created more affordable units than have voluntary programs (390). They also do a

    better job of alleviating social problems and decentralizing poverty by mandating

    integration of the community (Lerman 390). The success of voluntary programs, by contrast,

    lies at the mercy of the strength of their attached development incentives. But what of

    constitutionality? Zoning itself may be legal, but unlike inclusionary programs, typical zoning

    regulations do not specify the types (low-income, luxury, etc.) of development allowed.

    Lerman argues that as long as the city can establish a compelling interest for the

    development of affordable housing and as long as a mandatory inclusionary zoning program does

    not inhibit a developers ability to turn a profit, the constitutionality of the statute can be assured

    (394). In the Emory Law Journal , Jennifer Morgan concurs, adding that the development of

    policies at both the local and the state level can be important to ensuring the success of these

    programs (383). Indeed, she notes, many states, such as Oregon and Washington, have adopted

    strong growth management legislation with inclusionary zoning and affordable housing

    components (373), with varying degrees of success.

    For example, in recent decades, Washington State passed a strict growth management

    legislation, which required cities and counties to develop Comprehensive Plansessentially, a

    roadmap of development over the next twenty years (Growth Management Act). The plans

    take into account a variety of issues, including land use, transit, and affordable housing.

    Typically, the affordable housing section mandates that a certain number of units be developed

    by the end of the plan horizon, according to expected population increases and urban growth area

    expansion. Specific plans for implementation are then left up to cities and counties, who can

    develop unique inclusionary zoning policies to suit their unique needs.

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    Indeed, a variety of factors contribute to the success of inclusionary zoning. The support

    of state government and legislatures, the creation of comprehensive plans for urban areas, and

    mandatory requirements all work to improve outcomes in the program. While detractors argue

    that mandatory inclusionary zoning can increase costs, effective use of inclusionary zoning

    would include density bonuses large enough to offset the decrease in a developers expected

    profit.

    Mixed-Income Housing

    Over the past fifty years, the urban poor in many major American cities have become

    increasingly segregated from the wealthy. In cities like San Antonio and Washington, D.C., the

    two economic groups have become so separated geographically that comparisons have been

    drawn to racial segregation (Badger). But while economic segregation may allow the wealthy to

    live more comfortably, reaping the benefits of the best schools, public services, and facilities, the

    urban poor must endure higher crime, lower graduation rates, and lower-quality public services

    and facilities. By decreasing economic segregation and prioritizing development in which the

    low-income can afford to live alongside middle- and upper-income families, perhaps the long-

    term cycle of poverty may be reduced.

    Fortunately, both mixed-use infill development and mandatory inclusionary zoning

    practices result in a unique new focus on this innovative type of mixed-income housing. With

    multiple different income levels living alongside each other in dense apartment complexes and

    mixed-use developments, cities and counties realize a number of benefits. Researchers Paul

    Brophy and Rhonda Smith note in urban affairs journal Cityscape that mixed-income housing

    advocates anticipate among the lower-income residents a higher level of upward mobility, higher

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    rates of employment, and lower levels of crime (6). Low-income households, he states, will

    have the benefit of better schools, access to jobs, and enhanced safety, enabling them to move

    themselves and their children beyond their current economic condition (Brophy and Smith 6).

    Over the past several decades, the U.S. Department of Housing and Urban Development

    has experimented with funding mixed-income housing projects in hopes of realizing some of

    these benefits. According to Lynn Cunningham, the departments HOPE IV program is intended

    to revitalize depressed neighborhoods by replacing selected large, severely depressed public

    housing properties with modern, mixed-incomecommunities (353). Through the use of

    several HOPE IV grants, the District of Columbia Housing Authority (DCHA) partnered with a

    number of private developers to replace low-income housing projects with mixed-income

    development. While many of the projects favored lower-density single-family and two-unit

    townhouses, designs incorporated many smart growth elements and increased density near transit

    stops.

    Unfortunately, in Washington, D.C. the HOPE IV grants did not succeed in substantially

    increasing the number of affordable units. Because land in the area remains in short supply, the

    lower densities of the redeveloped properties resulted in net losses in units that could not be

    made up elsewhere in the system. New units were less affordable for lower-income residents,

    who in most cases could not utilize Section 8 vouchers for rent at the properties. Moreover,

    Cunningham argues that the basic premise behind HOPE IV, namely increased economic mixing,

    was applied unequally in that poor neighborhoods were deconcentrated while wealthy

    neighborhoods remained intact (361-2). There are even questions as to whether the grants

    contribute to gentrification. Most concerningly, however, the projects low-density designs

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    ultimately may have doomed them to failure. Without a strong mixed-use anchor development,

    HOPE IV did not produce increased levels of affordable housing in Washington, D.C. Other

    cities have had differing levels of success.

    Questions abound as well over the effects of mixed-income housing. Because analysis of

    the effects of mixed-income housing on the behavior of residents must take into account the

    subtleties of human behavior, measuring the true effects of mixed-income housing can be

    difficult (Brophy and Smith 6). In their research, Brophy and Smith analyze several mixed-

    income developments and communities in order to find common threads that lead to success. The

    pair find that the most important factor in the viability of mixed-income housing, perhaps

    unsurprisingly, lies in the development and management of the property. Location, design

    quality, maintenance, and profitability all contribute to success. Moreover, additional programs

    designed to spur social mixing must be developed in order to succeed in increasing upward

    mobility (Brophy and Smith 6). A sufficient quantity of market-rate units must be developed to

    make the affordable units more viable. Finally, in order to realize the largest benefits, mixed-

    income housing must not distinguish between the upper-income and lower-income units, and

    must not emphasize that element in marketing. These factors lead to a better, more successful

    mixed-income housing project.

    SECTION THREE: We Should Implement That!

    Introduction

    Of course, despite the major long-term benefits of infill, inclusionary zoning, and mixed-

    income housing in alleviating a lack of affordable housing, many areas have been quite slow to

    adopt these proven reforms. Sometimes projects and policy implementation have stalled as a

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    result of local politics and NIMBYism. Other times, simple economics has stalled specific

    projects. Finally, sometimes city policies toward new housing are so piecemeal and fragmented

    that they cannot make a dent in the affordable housing problem.

    NIMBY/YIMBY

    In November of 2013, residents of Palo Alto, California overturned their City Councils

    unanimous approval of a 72-unit mixed-use affordable housing infill project called 562 Maybell

    Avenue (Smith). The development, which would have included sixty apartments for low-income

    seniors and twelve market-rate townhouses, was designed to help alleviate a dearth of units in

    Palo Alto for low-income residents. Opponents cited the potential for increased traffic as a major

    concern, despite the projects traffic mitigation efforts and location near a major transit corridor

    (Smith). With a major housing crunch in the Silicon Valley, the voters denial quickly became a

    national example of the not in my backyard phenomenon, or NIMBYism, in action.

    These neighbors of proposed projects object on often shaky grounds, although it is

    important to note that some of the concerns of so-called NIMBYs (neighbors in opposition to a

    nearby project) may have a certain level of validity. For example, dense projects can increase the

    number of vehicle trips on surrounding roads. Many projects violate zoning or development

    agreements set forth for specific sites. Sometimes developers propose buildings with ugly

    architecture or poor site plans. Frequently a project will have an unmitigated environmental

    impact.

    But because such opposition is often driven more by emotion than rational thinking,

    NIMBYism often arises out of no single discernible issue. (Although one Vancouver, B.C.

    famously wrote that the NIMBY phenomenon itself might better be described as FRUITfear

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    of revitalization, urban infill, and towers.) Property values, traffic, and zoning violations are

    common citations, but location might be the single sticking point.

    Affordable housing projects may be particularly vulnerable to NIMBYism. The residents

    of a wealthy town like Palo Alto, for example, may not want to live alongside lower-income

    neighbors. They may worry that an influx of lower-income people will decrease property values

    and increase crime. Residents in traditionally lower-income cities, like Spokane, Washington,

    may oppose projects like halfway-houses that can aid in getting former criminals off of the street

    and preventing recidivism (CITE).

    Fortunately, NIMBYism can be at least somewhat mitigated. Affordable housing

    developers should consider potential neighborhood opposition from the very start, planning the

    projects size, type, density, appearance, and other factors around the areas existing zoning plans

    and development patterns. Jaimie Ross of the National Low-Income Housing Coalition argues

    that developers should educate elected officials and investigate potential legitimate legal

    problems so as to ensure approval (10-11). Meanwhile, special care should be taken to gather

    allies from a broad range of interests and to address all legitimate neighborhood and

    community opposition (Ross 11). The best projects blend the best of residents desires with the

    needs of the developer in order to create a project with broad support.

    Of course, this reads almost like Pressman and Wildavskys suggestions for ensuring

    public policy success in Implementation . By addressing NIMBYism from the very start,

    developers would essentially be designing a policy with a special eye toward its implementation.

    In Oakland, local Economic Development Agency head Eugene Foley turned his nose at meeting

    with community groups and neighborhoods, ultimately dooming public support for his projects.

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    As such, strong communication and interaction with potential opposing community groups

    throughout the project development phase would ensure at the very least that NIMBYism does

    not arise suddenly and without warning.

    To be sure, NIMBYism can cause headaches for affordable housing developers. As

    neighbors of a project argue, whether justifiably or unfairly, about property values, traffic, and

    crime, support for a project may erode in the wider community. In order to avoid the fate of Palo

    Altos 562 Maybell Avenue, developers should plan from the start for opposition, incorporating a

    plan for project changes at the request of the community. In addition, project managers should

    engage with the community from the very start of a project to limit the number of surprises

    which arise at the last minute and diminish the likelihood of approval. Through smart planning,

    developers typically can find a path around NIMBYism and through to construction.

    Economics

    Sometimes, affordable housing projects can run into problems before their creation, due

    to unfavorable economics. In areas like the Silicon Valley and San Francisco, for example, where

    the cost of land has reached exorbitant levels and a strong demand for housing compounds the

    struggle for low-income units, the opportunity cost of producing affordable units over market-

    rate units becomes so high that developers simply refuse to develop affordable units.

    Mandatory inclusionary zoning attempts to solve this problem, but in areas with an

    already-strong housing market, fund contributions may not be enough for housing authorities to

    build a sufficient number of affordable units. And because market-rate units subsidize the lower-

    income units, direct development of affordable housing can indeed result in a higher cost of

    market-rate housing, further squeezing middle-income buyers out of the market (Quigley 69-70).

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    Cities can mitigate these economic issues by ensuring that density bonuses for

    inclusionary housing projects balance with the cost of construction. Building a larger number of

    market-rate units would theoretically decrease the amount that each family essentially

    contributes to subsidize the low-income component of the project. In addition, economic

    carrots, like tax subsidies, benefits, or even public financing can sweeten the deal for

    developers. Of course, cities must be careful to ensure long-term viability, but if short-term

    efforts result in additional units, then those options should be explored.

    Poor City Policies

    While most cities at least nominally endorse affordable housing and low-income housing

    construction, their municipal codes and comprehensive development plans may not offer the type

    of far-reaching, universal policy strategy that would actually solve the problem. Instead, local

    development laws often consist of a complex, difficult-to-navigate patchwork of often-

    conflicting policies and zoning regulations. Considerable confusion results for well-intentioned

    developers, low-income housing advocates, and policymakers

    For example, a citys comprehensive plan may prioritize infill development with a mixed-

    use focus, but fail to include relevant enforcement mechanisms that ensure code compliance.

    Local governments may pass a mandatory inclusionary zoning component, but apply it only to a

    certain area of the city or to certain types of projects. Inclusionary zoning may live alongside

    exclusionary zoning (which mandates certain heights, parking lots, and setback requirments)

    despite evidence that the strongest mandatory exclusionary zoning policies blanket the city

    without discrimination (Lerman 392). And though mixed-income housing may be promoted on

    paper, many cities, such as New York City, have not yet thrown their weight entirely behind the

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    proposal, opting to continue to support the types of public housing projects which segregate low-

    income residents from wealthier citizens.

    Unfortunately, simplifying and streamlining these conflicting policies can prove difficult.

    In some states, any change to development laws involves a comprehensive plan update, which

    can require the approval of a state hearings board. Local governments may find powerful

    political interests standing in opposition, depending on the policy, including homebuilders

    associations and neighborhood advocates. Finally, despite the attention given in the Bay Area to

    income inequality and affordable housing, partially as a result of the Google bus protests, in most

    cities, residents possess little appetite for changes in development laws to make affordable

    housing easier and more profitable to develop. As such, city policies encourage affordable

    housing at a mere fraction of their potential.

    CONCLUSION: Long-Term Prognosis

    Land-use and urban development strategies often tread a fine line between supporting

    affordable housing and working against it. Through the use of mixed-use, high density infill

    development, inclusionary zoning practices, and mixed-income housing prioritization, many

    regions attempt to make more units available for low-income residents. But NIMBYism, simple

    economics, and uncoordinated city policies can create problems in implementation. And without

    a major focusing event, in most areas of the country the issue remains more of a background

    concern than one at the forefront of the publics attention.

    In the case of Winchester Ranch, the mobile home park for the elderly across the street

    from Santana Row, the City of San Jos has a number of policies in place to ensure that any

    potential developer would contribute a significant amount to affordable development in the area.

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    But even if Pulte Homes purchases the property, demolishes the mobile homes, and constructs

    500 low-income units, the seniors will still be out of a home, the developers will miss out on

    millions of dollars in profit, and the areas low-income housing situation would not be

    substantially affected. Perhaps the the clearest signal yet that in the complex realm of land use

    planning, affordable housing remains caught in a high-stakes balancing act.

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    Works Cited/Consulted

    Barro, Josh. "Affordable Housing Thats Very Costly." The New York Times . The New York

    Times, 07 June 2014. Web. 8 June 2014.

    Bigler, Matt. "San Jose Mobile Home Park Residents Face Eviction For Condo Development."

    CBS San Francisco . KCBS, 23 Oct. 2013. Web. 08 June 2014.

    Brophy, Paul C. "Mixed-Income Housing: Factors for Success." Cityscape 3.2, Mixed-Income

    Housing (1997): 3-31. JSTOR . Web. 23 Apr. 2014.

    Chetty, Raj, Nathaniel Hendren, Patrick Kline, and Emmanuel Saez. Where Is the Land of

    Opportunity? The Geography of Intergenerational Mobility in the United States . N.p.:

    n.p., n.d. The Equality of Opportunity Project . Web. 6 June 2014.

    Cunningham, Lynn E. "Islands of Affordability in a Sea of Gentrification: Lessons Learned from

    the D.C. Housing Authority's HOPE VI Projects." Journal of Affordable Housing and

    Community Development Law 10.4 (2001): 353-71. JSTOR . Web. 23 Apr. 2014.

    "Growth Management Act." APA Washington . American Planning Association: Washington

    Chapter, n.d. Web. 9 June 2014.

    "Housing." Smart Growth America . Smart Growth America, n.d. Web. 10 June 2014.

    Lerman, Brian R. "Mandatory Inclusionary Zoning: The Answer to the Affordable Housing

    Problem." Boston College Environmental Affairs Law Review 33.2 (2006): 383-416.

    Digital Commons at Boston College Law School . Web. 7 May 2014.

    "Mixed Use Development." Planning.org . American Planning Association, n.d. Web. 08 June

    2014.

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