PACDC’s Policy Director Beth McConnell testified before the Philadelphia Land Bank  Board of Directors on its Draft 2019 Strategic Plan and Performance Report.  PACDC called on the Land Bank and the Kenney Administration to make revised disposition and acquisition policies available for public comment, to consolidate the entire public inventory of vacant surplus property into the Land Bank, adequately fund the agency’s budget and reduce its costs, and to boost its focus on re-activating vacant properties on commercial corridors.  You can read Beth’s full testimony below, and view the Land Bank draft Strategic Plan here.

Testimony of Beth McConnell
Policy Director, Philadelphia Association of Community Development Corporations
On the Philadelphia Land Bank Strategic Plan, June 2019
June 19, 2019

Good afternoon and thank you for the opportunity to testify. My name is Beth McConnell, and I’m the Policy Director for the Philadelphia Association of Community Development Corporations (PACDC).

PACDC applauds the Land Bank and its consultant, Interface Studio, for producing a very high-quality strategic plan. The plan uses valuable data, which is well visualized, to help stakeholders understand everything from the state of the public property inventory, potential targets for acquisition, changing real estate markets, past performance of the Land Bank, and more. The maps are useful to see how activity overlaps other key data points, but would be particularly valuable if they were available as interactive, on-line tools so that stakeholders can zoom in to the neighborhoods, blocks, or parcels they are interested in. We hope you’ll add these interactive maps to the Land Bank website.

There are also a number of common sense recommendations made in the plan that PACDC supports, such as beginning the process of acquiring and disposing of vacant structures over the long term, hiring an outreach staffer to improve partnership with stakeholders around the city, developing a strategy to acquire vacant properties still encumbered by the 1997 tax lien securitization, modifying the reporting formats, and strengthening communication processes and tools.

PACDC has a few recommendations:

First, we strongly urge that the Land Bank make a draft of revised acquisition and disposition policies available to the public, and provide at least 30 days for public comment on those revised policies before they are sent to City Council for approval. These governing policies are the most important part of the Strategic Plan, yet they were not contained in the draft we are commenting on today. If the Land Bank only allows the public to review the revised policies once they reach Council, stakeholders that do not have strong relationships with Council offices, who are not familiar with the Council process, or are unable to respond to the often fast-moving Council schedule, may not have their perspectives heard.

Second, PACDC recommends that Council and the Administration reconsider maintaining a sizable inventory of public property in the Department of Public Property (DPP), and the Philadelphia Redevelopment Authority (PRA). As the plan acknowledges, advocates like PACDC and our allies spent years pushing for the creation of the Land Bank for two reasons: 1) to streamline the process for acquisition of private, vacant, tax delinquent properties, and 2) to consolidate the entire public inventory owned by the City of Philadelphia. Yet this plan proposes to keep nearly 3,000 properties at DPP and another 1,000 at PRA.

The point of the Land Bank was to create one owner, one system, one set of policies and procedures, and one entity making strategic decisions about the surplus public property inventory. While aligning the disposition processes between DPP and the Land Bank will alleviate some challenges, it is a band-aid, not a substitute, for a unified owner and process for surplus public property.

Third, we urge the Administration to provide adequate funding for the Land Bank’s core operations. The plan notes that the Land Bank is under pressure to sell property at market value in order to raise revenue necessary to fund its core operations. PACDC is unaware of any other city agency that must generate revenue to cover its basic operations. Agencies like the Department of Licenses and Inspections, the Streets Department, Parks and Recreation all generate revenue from fees and fines, but are not expected to fill operational budgetary gaps by assessing more fees or fines. This is for good reason, as government agencies should focus on making decisions in the best interest of the public, not for the agency’s economic survival.

Adequate funding for the Land Bank is particularly important in its early years when the inventory it has for disposition is predominantly in weak market neighborhoods. The Kenney Administration has also articulated as a priority advancing equitable development and preventing displacement of residents and small businesses. Disposition of valuable property at nominal or discounted value for those purposes is necessary to achieve that vision of a more equitable city, but results in less revenue for the Land Bank.

Furthermore, we urge the Administration to reconsider the Memorandum of Understanding (MOU) with the Land Bank that results in the General Fund subsidizing the Land Bank so that it can re-pay the General Fund for real estate or water liens on acquired properties. If the prime objective is to make the School District whole on back taxes owed, then the maximum paid should be 55 cents on the dollar for municipal liens. If the Administration discounted the acquisition cost for its own liens, the Land Bank would need fewer upfront public dollars. Short of such changes, the City needs to substantial increase funding for both acquisition and core operations of the Land Bank, are we won’t significantly move the needle on repurposing vacant properties.

Fourth, we urge the Land Bank to work more closely with the Philadelphia Department of Commerce to boost the acquisition and disposition of vacant property on our neighborhood commercial corridors. Commerce invests millions of dollars into commercial corridor management, cleaning, and property improvements. Vacant properties on our corridors stymie efforts to attract new investment, shoppers, and stores. The Land Bank can be a valuable partner in identifying potential targets for acquisition on priority commercial corridors, and the Strategic Plan is the right place to include and map that data. The Land Bank could partner with Commerce, the neighborhood CDC, Business Improvement District (BID), or merchant associations in developing a plan for disposition and renovation of key properties. There are new resources available for small businesses or non-profits that want to acquire and rehab commercial spaces on corridors that could be put to good use if the right properties are identified.

Finally, PACDC questions recommendation 21 (p. 53) to “shift” the role of the Vacant Property Review Committee (VPRC) to a working group “charged with guiding the citywide conversation about issues related to surplus property.” The Land Bank is where the citywide conversation about vacant property should occur. Further bifurcating discussions and development of strategy to yet another body outside of the Land Bank distances Philadelphia from promise of the Land Bank as a unifying, effective, transparent and efficient steward of the vacant property inventory. PACDC has also long advocated that the VPRC be abolished, and all of its functions absorbed by the Land Bank.

It has been a long road to getting the Land Bank to a fully operational state. PACDC applauds the Kenney Administration, the Land Bank staff, and members of City Council that have invested significant energy in getting the Land Bank to this point. We remain committed to working with you to ensure that the Land Bank lives up to its promise of using its powers to create a more vibrant, and more equitable, Philadelphia.