COMMENT: Drug and Alcohol Abuse Prevention and Reduction – please expand efforts to include not only youth but also the adults who are abusing substances. It is a key reason why people are not able to successfully hold onto steady jobs and that leads to low income and housing problems. It also leads to violence and crime. The data in your tables understates the growing crisis we have in our city because of substance abuse. One piece of data really stands out: 50% of BHS students know of an adult who has used an illegal substance recently! Ask any Fletcher Allen nurse or an EMT person how prevalent drug problems are in Burlington and they will tell you the problem is getting much worse. 60% of EMT calls are drug or substance abuse related. Fletcher Allen's emergency room is burdened with substance abuse issues. Implement some very straight-forward laws that very clearly tell youth and adults there is "no tolerance". What I would love to see you consider, but is probably seen as too harsh is: Sellers and users, if caught and found guilty, can no longer reside in Burlington (or better yet Vermont). Go find a home elsewhere because you are breaking our city (nation's) laws and we cannot afford to support your habit with entitlement programs and our city's economic health at risk. Any message of tolerance is going to signal to youth and adults that drug or alcohol abuse is okay. Clearly this is the wrong message.

RESPONSE: Substance abuse is indeed an issue that cuts across housing, economic opportunity and a suitable living environment; that affects residents’ lives in multiple ways; and that is calling out for new and/or increased counter efforts – including changed attitudes about substance use and abuse. Enforcement, however, is not the exclusive answer to substance abuse; prevention, intervention, treatment and recovery are equally important strategies. (And, banishment is not an appropriate or possible law enforcement strategy.) There are a variety of programs that currently exist in the city to address each part of this continuum (prevention, intervention, treatment, recovery and enforcement), as outlined in the city’s 2006 Substance Abuse Resource Guide. The Consolidated Plan’s stated priorities allow for funding of substance abuse activities through the city’s Community Development Block Grant funds. Substance abuse should remain a medium, rather than high, priority for funding under the CDBG program because there are other federal and state funding streams dedicated to addressing substance abuse.

COMMENT: Too large a percentage of children are not reading at grade level when they are tested in 2nd grade. This problem actually starts before they enter 1st grade. They are behind their peers who have parents that spend a lot of time teaching their pre-k and K at home. Please require 100% enrollment of all children in pre-school English Language Arts programs so they are at grade level when they enter first grade. Children can test out of the requirement each year if their parents don't want them to participate. Please require the school district to mandate pre-school and after-school phonics programs for all the children who are identified their pre-K through 5th grade teacher as needing extra help.

RESPONSE: Early education can indeed be key to the school success of at-risk children. The city has worked with the school district to implement the Early Learning Partnership program, has identified early education and care as a high priority for funding under the CDBG program, and is participating in the Regional Early Childhood Planning Group. The city does not have, and would not seek, the authority to impose mandates on the school district.

COMMENT: Do not mix neighborhoods by trying to force socio-economic integration through housing. You will lose your more affluent families and residents and you will be worse off. What is seen as socially desirable just isn't achievable because of human nature.

RESPONSE: A statutory purpose of the CDBG program is to reduce the isolation of income groups within areas through spatial deconcentration of housing opportunities for lower income persons. This is not only a federal program purpose, but also a city goal. The city can continue to be both a desirable place to live for all income classes and a community committed to social equity.

COMMENT: The goal of the city’s affordable housing policies should be to make sure that it is inclusionary, available throughout the city rather than isolated in particular areas, and part of a range of housing that does not isolate people.

RESPONSE: The city agrees, and hopes that its policies and programs promote that goal.

COMMENT: Has the city's goal of preserving affordable housing been reconciled with the "Excellence and Equity" goals of the Burlington School District? Currently, the Burlington School District is composed of almost 60% Free and Reduced Lunch (FRL) students. We know from recent studies the school district used, academic performance decreases as the percentage of FRL students increases, yet by working to preserve or increase affordable housing, we are ensuring that the FRL student percentage will increase. Do we have any target of FRL students at which the City of Burlington would say we have enough affordable housing?

RESPONSE: Affordable rental housing is located in all areas of Burlington and serves households with a wide range of incomes and household types. Hundreds of the units are dedicated for seniors and people with disabilities and households with no school-age children. Approximately half of the renter households in Burlington pay more than 30% of their income for rent plus utilities – affordable housing is one way to ensure that low-income households do not spend a disproportionate share of their income on housing. There is evidence that low-income households living in affordable housing are able to devote more resources to the essentials of living than their counterparts who live in market rate housing. Affordable housing provides household stability and the cushion to better withstand illness or job loss without creating havoc for their children. The city believes that most children living in affordable rental housing in Burlington enjoy greater stability and opportunities for enrichment than their low-income counterparts living in private sector rental housing.

COMMENT: It’s striking that Burlington has the census tract with highest poverty rate in the state. The inclusionary units at the Westlake project would have created affordable housing outside the high poverty area of the Old North End.

RESPONSE: The proposed inclusionary units at the Westlake project would have added new ownership units affordable to households earning at or below 75% of HUD median income. However, since households would realistically have to earn close to the income limit of $47,625 to be able to purchase these units, they would not have been available to people living at the poverty level (with less than $17,000 in annual income for the same household size) and would have no effect on the concentration of poverty in the Old North End.

Right now, there are 362 perpetually affordable units within three blocks of the Westlake project, all created with city support. Depending on the outcome of pending zoning permit appeals, there are an estimated 15 new inclusionary units that will be developed in the downtown/waterfront area in 2009 and another 30 to 40 additional affordable downtown units to be developed at Brown’s Court over the next three years.

It is true that the census tracts of the Old North End have high poverty rates, only mitigated in part by the high concentration of college students in some of those tracts that in some ways artificially inflate the poverty rates. However, there is more dispersion of non-special needs affordable housing throughout the city than is reflected in poverty rates. For example, the New North End census tracts have the highest number of property-based non-special needs affordable housing units (396) in the city, because of the affordable units at Northgate and Franklin Square. The city will continue to support the development of affordable housing throughout the city, as it creates the conditions conducive to a decent quality of life for low-income households.

COMMENT: The fact that there are over 400 housing units with expiring subsidies is troubling. It’s disconcerting to realize that the city needs to not only be addressing the need to produce new affordable units but also to preserve what we already have.

RESPONSE: It will indeed be a challenge, with shrinking resources, to both maintain and increase the city’s affordable housing inventory. However, preservation remains a top priority of both city and state housing policy, and the city will redouble its commitment to preserving every existing unit of affordable housing.

COMMENT: Does the Grand List decrease as the preservation initiative transfers property from the private sector to nonprofit ownership? If so, are the any plans to replace the lost property tax revenue or will services be reduced?

RESPONSE: There is no tax consequence involved when a nonprofit organization purchases affordable housing from the private sector – taxes for the nonprofit are based on the value of the real estate with the restrictions that were in effect under private ownership.

COMMENT: I question the fact that "workforce housing" is not mentioned anywhere. There is an evident need for affordable housing in Burlington but the lower middle class, I believe, also has a hard time with finding housing that is affordable to their means. Is there consideration of workforce housing anywhere in the plan or in your work?

RESPONSE: Workforce housing is a subset of affordable housing. Affordable housing includes both housing for people with special needs – the elderly and those with disabilities which may limit their work opportunities – and housing for those without special needs who are part of the workforce. The Consolidated Plan discusses those groups at length in the Housing Needs section of the Plan.

It’s not clear who is included in the “lower middle class,” but the “affordable” housing discussed in the Consolidated Plan includes households up to 80% of the area median (as defined by the federal statutes that establish the covered housing programs). This year, for a family of four, that means income up to $56,500. As discussed in the Housing Needs section of the Plan, the greatest need, for both renters and owners, is in fact found among those with income up to 80% of median. The Housing Needs section of the Plan does also look at the needs of those with income between 80 and 95% of median, although the need level is lower there, and the Housing Objectives laid out in Table 2A3 / 2C1 include all income levels.

COMMENT: The Consolidated Plan places too much emphasis on affordable housing and too little emphasis on affordable jobs. We can’t control housing prices, but we can control getting people into good paying jobs like those at Dealer.Com.

RESPONSE: Livable wage jobs are indeed a key part of any long-term strategy for economic mobility and have been a key part of the city’s strategy for the last twenty-five years. Economic development staff will continue to put time and effort into opportunities such as the Dealer.Com expansion. There is and will continue to be, however, a need for housing affordable for those who do not, and may never, earn livable wages – including the elderly, those whose disabilities limit their work opportunities, and those who do not yet have the skills necessary to get and retain high-paying jobs. And, the city does have the ability, in large part, to control the continued affordability of its affordable housing stock. Affordable units owned by nonprofits rarely lose their affordability. On the private sector side, the city has been quite successful in perpetuating the affordability of affordable units through inclusionary zoning, through project-basing of Section 8 vouchers and through transfer of ownership to the nonprofit sector. There is often more long-term control over the affordability of housing than over the availability of livable wage jobs.

COMMENT: Offer more continuing ed courses that are for a very specific job/career and focus these courses for people that are not working or are earning low wages. If someone is getting support from any non-profit or the city, then they should also be getting coaching with milestones on how to increase their work hours, their earnings, and their independence. We do not want to encourage a lifestyle where people are prone to collect benefits (subsidized housing) in lieu of getting a job and working. Too many people do not have a strong work ethic and are unwilling to work 40 hours a week. Teach these people the personal satisfaction and importance of a strong work ethic.

RESPONSE: There are, no doubt, some individuals – living in subsidized housing or not – who do not have a strong work ethic. There are, however, hundreds of elders living in subsidized housing for whom a work ethic is not relevant. The same is true for the hundreds of residents living in subsidized housing whose disabilities limit their work options. For the residents who live in subsidized housing and do work (often at multiple jobs), encouraging them to increase their earnings without addressing the benefits cliffs that penalize higher earnings is often not realistic. The city strongly supports continuing education and training that will lead to livable wage jobs, but also acknowledges the very real barriers that low-income workers face in continuing to work and raise their children while also attending classes. The city is committed to helping overcome stereotypes about poverty, and encourages its residents to become involved in programs such as Circles of Support which allow them to get to know their neighbors across economic and class lines and to offer support as those families work on financial, education and social goals.

COMMENT: Increase "green/clean" manufacturing jobs in the city so assembly line type jobs can be held by those that do not own a car and have limited education. Pine Street and the Old North End are good target zones for this economic development.

RESPONSE: Assembly line type jobs will continue to disappear and often do not pay a livable wage. As the livable wage chart for Production Jobs shows, there are very few production jobs which pay an average wage that would allow a family – with one parent or two working – to raise their families and meet basic needs. The city is, however, committed to supporting the industry clusters identified in the Consolidated Plan and to increasing the percent of residents who work in the city rather than commuting elsewhere. And, the Pine Street and North Street corridors are identified focus areas for economic development efforts.

COMMENT: Do not require employers to offer childcare benefits. Employers will leave Burlington. Have the city/ all taxpayers pay for it through the school district budget.

RESPONSE: There is no current or proposed requirement that employers offer childcare benefits. The city’s economic development staff do make information available to businesses on cafeteria plans and other ways to help make jobs “livable.” And, the school district is tapping into public education funds to support preschool programs.

COMMENT: In Chapter One (Introduction), the Community Vision adopted in 2000 as part of the Legacy Project contains this statement: "A sustainable economy requires a high degree of self-reliance and a diverse mix of businesses in a dynamic environment. The community has reiterated the need for increased local ownership of and support for local businesses. Burlington has a strong base and tradition of local ownership and self-reliance upon which to build, but policies and practices should be developed to encourage consumers, businesses and institutions to support and patronize locally owned and operated businesses. Residents also called for the city and its people to make maximum use of local resources for basic needs. This will anchor the local economy, which will need to successfully navigate the open waters of the global economy in years to come."

That vision was amazingly prescient at the time and is even more relevant in light of the past 8 years. Climate change, greenhouse gases, sweatshop labor in third-world countries, fossil fuel prices and other transportation costs, and worldwide food prices have all reinforced the need to reduce importation of goods into Vermont. We should be doing everything possible to encourage buying and selling Vermont products to Vermont businesses and consumers.

Burlington's Consolidated Plan should encourage Burlington businesses to buy their supplies from and sell their products to Vermonters ("Keep it in Vermont"). The city should encourage more innovations such as Vermont Food Network and Rural Vermont. Burlington School District serving locally grown and locally prepared food is a great example that should be emulated by other Burlington businesses. CEDO should direct staff expertise and grant funds to encourage Burlington businesses to increase the purchase of a variety of goods from other Vermont suppliers – not only food but also fabrics, furniture, raw materials etc. – instead of from beyond our borders. The Summary of Priorities and Use of Funds section of the Draft Consolidated Plan should give more focused attention to that vision.

RESPONSE: The Economic Opportunity strategic action portion of the Consolidated Plan (which begins on page 3-31) starts by laying out six guiding principles, the first of which is to “encourage economic self-sufficiency through local ownership and the maximum use of local resources.” The city does believe that supporting local purchasing is important. Specific past examples of support for local purchasing include the Community Outreach Partnership Center grant through which the city worked with the University of Vermont to increase local purchasing; the city’s contract with City Market, which required the sale of at least 1,000 Vermont products (with 1,700 Vermont products actually sold); the city’s contract with Frog Hollow, which required that at least 15 Burlington businesses be represented in the Church Street store; the city’s support of the Intervale Center and of ReCycle North’s reuse and resale programs; and the One World Market held in City Hall Park last summer. Economic development staff will continue to support local purchasing efforts.

The Resource Allocation Policy, Section X of the Consolidated Plan, establishes “programs that support economic development and other programs that capture local dollars and prevent them from ‘leaking out’ of the community” as a priority in the rating system used by the Advisory Board which reviews applications for funding. The city believes that including this issue as one of twelve rating priorities gives it sufficient emphasis in the Consolidated Plan, but will make a greater effort to explain and discuss this priority with Board members before they begin the allocation process.

COMMENT: In Chapter Three (the Strategic Plan), Section II, "Economic Development Tactics" lists several tactics that support locally owned and operated businesses and mention regional collaboration. Three of the applications submitted for 2008 grants could have been directly related to the vision of regional self-sufficiency (Intervale Community Food System, CEDO Business Financing & Technical Assistance, and CEDO Sustainable Economic Development). But a close review of their 2008 CDBG grant applications finds no reference to regional collaboration or buying from and selling to other Vermonters, and suggests that none of them are looking beyond Burlington's borders to a sustainable regional or statewide economy. CDBG grants should give them opportunities to look at the bigger picture.

RESPONSE: The city will look at broadening its discussion of the allocation priorities with applicants at the workshops held for them, so that they can prepare more comprehensive applications.

COMMENT: The city school district is wasting money by not allocating the school budget properly. Families with children are only 20% of the city, but look how much J. Collins spends. Increase the number of master degree teachers, and decrease class size to max 16 students per classroom. Offer more pre- and after- school remedial and advanced teaching. Decrease the number of administrators and benefits. The city needs to become more involved in managing this tax user. Otherwise you will lose families as we move to Charlotte and other communities where the education is better and the city problems are fewer. It's a reality that many other U.S. cities have experienced.

RESPONSE: Burlington is not in the position of those cities with failing schools where the city has taken over management of the public school system. Residents have the opportunity to give input on the school district budget and the administration of the schools directly to the school district and its elected governing Board – and to seek election to that Board – and the city encourages its residents to do so.

COMMENT: I think it would be helpful for the lay reader if you started by talking about Past Performance and then go into what you plan on doing for the next five years. It would help explain how you came up it the numbers/thresholds in your new targets, which I was wondering about until I read the rest of the summary.

RESPONSE: The Consolidated Plan is all about the next five years and the Executive Summary therefore focuses first on the future, on what the city hopes to achieve over those five years, to set the context for the rest of the Plan. The numbers/thresholds for the new five-year targets are based on the data analysis in the rest of the Plan, the anticipated funding levels over the next five years and the input from stakeholders – and not on prior year results. The city does prepare a document annually (the Consolidated Annual Performance and Evaluation Report) which focuses on looking backward at results achieved.

COMMENT: On page 1-3 of the Consolidated Plan, in the second paragraph, the last three sentences say that, “The city has recently experienced a loss of retail business and a significant slowing in its population growth as compared to the rest of Chittenden County. If we reserve this process and Burlington were to absorb a higher percentage of local growth – as a means of countering suburban sprawl – the population could reach as high as 65,000 in 30 years. Burlington must grow carefully but significantly if we are to guarantee everyone the benefits of a healthy economy.” 

Is this a direct quote from the Legacy Action Plan? Is this statement consistent with the city Council Resolution approving the Legacy Plan?

RESPONSE: The language is a direct quote from the Legacy Action Plan approved by City Council in 2000.

COMMENT: The Legacy Action Plan as posted online (and as quoted in the Consolidated Plan) isn’t consistent with a subsequent City Council Resolution, especially with respect to the reference to possible population growth to the specific figure of 65,000.

RESPONSE: In June 2001, City Council amended the Legacy Action Plan to change the Goal Statement on page 10 of the Plan from, “Goal: In 2030 Burlington has absorbed the greater portion of the region’s population growth, expanding to as much as 65,000,” to “In 2030 population grown in Burlington has diversified the city and improved its quality of life while reversing the trend toward low density development in Chittenden County.” This amendment left in place the subsequent discussion language, quoted in the Consolidated Plan, which set no number as a target or goal for growth but suggested that population could reach as high as 65,000 (emphasis added). However, the reference to a specific population number is not of particular importance to the Consolidated Plan, and that sentence will be deleted.

COMMENT: On page 3-27 of the Consolidated Plan and on page 54 of the Action Plan, there is a reference to on the record development review hearings as one step that could be taken to further reduce barriers to affordable housing. Specifically, both Plans say that, “In 2005, Burlington was recognized by HUD as a model for reducing regulatory barriers that drive up housing costs. There are, nonetheless, several actions which can be taken to further reduce barriers, which include the following steps. These are recommendations of both the Mayor’s Affordable Housing Task Force in 2002 and the City Council Housing Super Committee in 2005: . . . Conduct on the record development review hearings for projects that meet the requirements for Major Impact Review.”

Is this language consistent with the most recent City Council directive regarding on the record review?

RESPONSE: The language of the Consolidated Plan will be amended to reflect the language of the October 29, 2008 resolution relating to Creation of a Pilot Project Relating to “On the Record” Zoning Appeals. The resolution states that the “City Council hereby directs its Community Development Committee to develop the necessary and appropriate protocols to carry out a pilot project, of not more than two (2) years duration, involving on the record review of downtown area projects, commencing no later than May 1, 2008, with the understanding and stipulation that the precise protocols for implementation will be recommended to the full City Council for consideration and vote on implementation no later than the first City Council meeting in March, 2008.” Since the Council has not been presented with the precise protocols for implementation, the vote has not yet occurred as of the drafting of this Plan.

COMMENT: I’m concerned that the language on page 3-27 about on the record review is overly broad and makes it sound as if the concept has already been fully embraced.

RESPONSE: The language will be modified as stated above.

COMMENT: On page 2-93, in the discussion of transportation, there should be a mention of CATMA and other private TMA’s. They are important partners in the city’s transportation system.

RESPONSE: The city agrees, and will edit that section to be more inclusive.

COMMENT: I see that in the past year, the number of youth served in funded programs has dropped while the number of seniors served is rising. Are we adequately serving our youth?

RESPONSE: The drop in the number of youth served is due in part to the challenges that youth service providers are encountering in welcoming and integrating large numbers of refugee children (often with limited English proficiency and significant trauma histories) into their programs – straining capacity, with resulting staff turnover and some program cancellations. Youth agencies, like senior centers, often have no sustainable funding sources and rely principally on what they can raise in grants and private funding each year. Many agencies are stretched very thin at this point. Unfortunately, with declining CDBG funding, the city is not well-placed to help address these challenges.

COMMENT: There are twice as many college students now as in 1970, and half as many families. We see the effects of this in our school budgets and declining enrollment. It has important implications for housing and code enforcement policies.

RESPONSE: These trends do indeed have important implications, though it’s also important to note that the declining trends in homeownership, in the number of family households and in the number of children in the city did begin to bend in the opposite direction between 1990 and 2000. In June 2002, the City Council passed a Resolution requesting that the Community & Economic Development Office (CEDO) review and identify reasons leading to the decline in the number of families with children living in Burlington, submit a broad-based plan that the City Council could adopt to help reverse the trend, and identify specific recommendations to the City Council that could be implemented immediately to strengthen Burlington's commitment to families. The resulting Family Report is available on CEDO’s website. Some of the recommendations have been implemented and others may require further discussion.

COMMENT: The Community Vision is presented as a consensus, while there is in fact no consensus around increased density, infill and on-the-record review.

RESPONSE: The Community Vision presented in the Consolidated Plan is taken from the Legacy Action Plan and the Legacy Action Plan, as adopted by City Council, does talk about a common vision developed through the participatory process leading up to the Plan’s adoption. However, it would be unusual in any city, and perhaps more so in Burlington, to find consensus or unanimity of views among all residents about all of the means towards a vision or even about the vision itself. Burlington has a well-founded reputation for an active and engaged citizenry, and as the recent Zoning Rewrite demonstrates, there will be continuing opportunities for debate about the shape of the city’s future.

COMMENT: CEDO should find better ways to get the Plan out to residents for review and comment.

RESPONSE: In mid-March, CEDO sent notice about the online posting of the Plan to several thousand city residents through the Buzz and through all city Front Porch Forums, as well as to City Councilors, the hundred plus people and organizations on the CDBG mailing list, and the CDBG Advisory Board. The city did receive a number of comments from residents reached through this process, as well as a number of requests for hard copies of the Plan. However, it’s important to acknowledge that as people are increasingly bombarded with information, it becomes more difficult to filter that information and to decide what is worth paying attention to. And, there were without doubt people who did not receive notice about the Plan. CEDO looks forward to participating in the upcoming meetings of the Transparency Committee established by City Council and to working on better ways in which to effectively communicate with residents.

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