CRA loan request not driven by land use regulation, permitting process

Samuel Staley, in his Feb. 26th Your Turn, “Workforce housing subsidy should be a wake-up call,” fails to provide evidence to support his implied assumption that the Global City project developers needed a subsidized loan from the Community Redevelopment Agency because of excessive costs of local land use regulation and permitting.

While regulation and permitting add to development costs, today’s high development costs are not primarily due to regulation and permitting. Staley points out that more stringent rules affecting development began to be adopted in the 1940s. But the housing of that time was vastly different. In 1940, 45% of housing in the U.S. lacked hot water, a toilet, and bathtub; by 1970 that figure was below 7%; in 2000 it was less than 1%.

Through zoning and building codes, including plumbing, electric, accessibility, and hurricane protection standards, the U.S. has established a minimum standard of housing quality and safety. While this increase in living standards is a remarkable achievement, it means that the minimum cost to produce housing is much greater. Housing built today also tends to be bigger and thus more expensive.

The trade-off is that most people in the U.S. today live in far superior housing than their 1940 predecessors. But these changes in standards exceed the cost of what some people can pay for housing. Many renters living in poverty in 2023 still live in deplorable housing conditions, paying unaffordable rents and unable to do better because they cannot find better options at prices they can afford.


In his call for local regulatory reform, Staley fails to acknowledge the multiple policies and programs the city has in place to reduce permitting time and costs for affordable housing projects including expedited permitting, complementary site planning and environmental reviews, reduced land use regulation, and waivers of water and sewer fees. It seems unlikely that excessive regulatory and permitting costs explain why the Global City developers sought a subsidized loan of $7 million from the CRA.

The principal reason affordable rental projects require financial subsidies is the lower rental income developers receive to offset capital and operating costs. For this development, which will serve families earning 80 to 140 %  of the area median income (about $55,000 - $100,000 per year), it is debatable whether such a subsidy is justified. What is not debatable is that the CRA could have leveraged that $7 million loan to help address Tallahassee’s most critical affordable housing shortage: the more than 13,500 households in the city with extremely low and very-low incomes (about $15,000 - $35,000) who are paying more than half their income for rental housing.

These residents of our city also are members of “the work force,” many of whom are one mishap away from becoming homeless: maids, waiters, and cooks; custodians and maintenance workers; nursing assistants, school bus drivers, and crossing guards; reserve police officers and fire dispatchers.

Robert Deyle
Robert Deyle

Robert Deyle is emeritus professor of Urban and Regional Planning at Florida State University and a former member of the Tallahassee Affordable Housing Advisory Committee.

Nancy Muller
Nancy Muller

Nancy Muller has 30 years of experience in the affordable housing policy, finance, and growth management arena working statewide in Florida. She currently consults on permanent supportive housing solutions in local communities.


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This article originally appeared on Tallahassee Democrat: CRA loan request not driven by land use regulation, permitting process