In December of 2017, the Florida Housing Finance Corporation received 27 applications for competitive 9% tax credits in Miami-Dade County. The locations of the associated development sites are mapped below.

Comparing the Sites to the Average Miami-Dade Neighborhood

Let's take a closer look at the communities where theses sites are located.

In the census tracts containing sites for which developers submitted applications for competetive tax-credit funding:

  • The average poverty rate is 31.3% (with a range of 11.5% to 54.0%);
  • The average rate of households receiving food assistance benefits is 43.2% (with a range of 14.3% to 55.7%);
  • The average adult labor force participation rate is 58.9% (with a range of 42.8% to 74.1%); and
  • The average unemployment rate (among individuals over 16 years of age) is 13.6%.

Let’s put that all in context. For all populated census tracts in Miami-Dade County:

  • The average poverty rate is 20.0%;
  • The average rate of households receiving food assistance benefits is 25.0%;
  • The average adult labor force particiaption rate is 62.2%; and
  • The average unemployment rate (among individuals over 16 years of age) is 8.6%.

That means that on average, applications for tax credits are originating from census tracts where the incidence of poverty is 56.5% greater than the typical Miami-Dade County census tract; dependence on food assistance is 72.8% greater. Applications are originating from tracts where labor force participation is meaningfully less; and among those in the work force, unemployment is 58% greater than in the typical Miami-Dade County census tract.

Comparing Sites to Each Other

Among the 17 applications indicating that the development will serve the family demographic (i.e occupancy will not be limited to older persons), 3 are in census tracts where the rate of poverty is less than the average Miami-Dade County census tract. Another 8 are located in census tracts with rates of poverty less than a full standard deviation above the mean.

There are 20 applications which supposedly include participation by not-for-profit organizations (including one in which the true principal is a for-profit developer subject to a deferred prosecution agreement for lying to the Corporation about construction costs in order to enrich himself). Of these, 11 indicate that the property will serve the family demographic. In all likelihood, the funded deals will be among these applications.

All of these applications come from competent developers who can make it through underwriting, complete construction, and place the buildings in service on time. The buildings will all be physically indistinguishable from market rate housing.  All of the proposals are for concrete new construction. The most significant difference between these sites is social geography. Simply put, most are located in neighborhoods where poverty and dependence on public assistance are normative. A few are located in neighborhoods where poverty is not normative and upward mobility is more likely. To put this all in perspective, the peak unemployment rate in Florida during the Great Recession was 11.2%. That means that employment prospects in the neighborhoods producing tax credit applications during normal – even good times – are worse than most people experienced during the bleakest economic period in living memory.

Looking Ahead - Fair Housing Implications

The Corporation is in the process of updating the rules which guide the allocation of competitive resources, as well as the Qualified Allocation Plan. These guidelines will be operationalized in future RFAs. If Florida is committed to fair housing, it must recognize that where a person lives, especially during childhood, has a a significant impact on her opportunities for upward mobility. Our housing production programs should not be focused on warehousing the poor and keeping them in a position of dependence. Instead, we should expand the options available to low-income households and use the tax credit program to create housing opportunities in otherwise inaccessible neighborhoods.



Florida Housing Finance Corporation RFA 2017-112; RFA 2017-112 Applications Submitted Report

American Community Survey 2016 5-yr Average tables: S2301; S2201; S1501; S1701