Why Food Justice Advocates Should Care About CRA Reform

The following is a guest post from Samantha Koches, demonstrating the vital opportunity Community Reinvestment Act reform presents for advocacy communities far beyond the housing, lending, and community development space.

Is the American Dream drying up?

She crosses a dry patch of lawn to unlock her squeaky front door, tosses one more overdue bill on the mounting pile, and eyes an empty fridge she can barely afford to keep on.

His brow furrows as the numbers tick higher at the pump. After his second shift, he drives past cushy homes with pristine, lush gardens to a concrete condo block facing an abandoned lot, wondering if one day his view might mimic his wealthier neighbors.

This is life for millions of Americans: working below a living wage, relying on federal assistance for shelter and food, and watching the American dream dry up as quickly as the forests and streams around them.

These are not new problems, and in fact, they’re getting worse

38 million Americans struggle with hunger despite a record $122 billion in food aid spending.

4.7 million households rely on rental assistance, yet 7 million more cannot access it because there are just 36 affordable homes for every 100 eligible households.

Millions of low- and moderate-income (LMI) families face daily tradeoffs between housing, utilities, medical care, education, and food. 

These families also bear the brunt of climate change: disproportionate health burdens from urban heat are worst in historically redlined communities for lack of green space and tree cover common in wealthier, Whiter communities.

Food security advocates have a tangible, simple, right-now moment for action: Submit comments to regulators on new rules that will shape our work for decades.

These worsening crises are no secret. Billboards remind us that 1 in 6 children go to sleep hungry. Record heat waves, water restrictions and droughts bring the foreboding effects of climate change into our everyday lives.

So what about new solutions? How do we impact real change together? 

Affordable housing policies get LMI communities shelter. Food banks protect them from hunger. Tree planting and organic agriculture are similarly straightforward solutions for cooling, re-greening, and reinvigorating our land.

But activism, advocacy and volunteer work in these three spaces is often siloed. If we instead think of them as complementary, intrinsically connected pieces – and make concrete efforts to coordinate and assist across these organizational spaces – our work can blossom in an integrated system: affordable living.

Affordable living means integrating regenerative, climate-friendly foodscaping into affordable housing developments. It means installing edible gardens on-site at affordable housing communities, providing residents a source of fresh, healthy produce just outside their doors.

Affordable for our wallets.

Nourishing for our bodies.

Regenerative for our planet.

That’s exactly what my organization, Nourish All, is bringing to life. We help property developers promote an affordable-living approach in diverse communities. For instance, on the Big Island of Hawai’i, we recently designed and built food gardens for a 50-unit community in close collaboration with Hawaii Affordable Properties. Residents now have no-cost access to sweet potatoes, pumpkins, leafy greens, ripe tomatoes and tropical fruit trees that will last for decades. We have also helped developers beyond Hawai’i plan agricultural spaces into projects starting in the initial design phase.

Ground-level organizations like Nourish All must also think about high-level policy. Projects like these require capital – and food security advocates therefore should engage at policy intersections that shape the flow of capital.

There is opportunity in this obligation – and not just an abstract one. Food security advocates have a tangible, simple, right-now moment for action: Submit comments to regulators on new rules that will shape our work for decades.

Federal agencies are overhauling Community Reinvestment Act (CRA) regulations this summer. Their decisions will reshape how institutional lenders approach community development financing – and whether they are rewarded for pursuing this affordable-living approach to change. That’s why we who see ourselves as primarily engaged in the food security issue space should file comment letters to the federal banking agencies on a policy that may seem adrift from our work: We should be urging CRA’s enforcers to include  food access and sustainability projects in the new rules. This would create clear incentives for developers and lenders to plan food security and sustainability into their work serving LMI communities. Your voice can have an immense impact nation-wide on investment directed to food security and affordable living. 

Comment letters must be submitted no later than August 5. Guidance on the process and sample templates to adapt for comment letters are available on NCRC’s #TreasureCRA page here. 

Have our gardens and eat them too

Like anything in life, edible gardening is not just a means to an end. There are abundant, diverse benefits of incorporating food gardens into housing to deliver affordable living.

LMI households stand to gain physical, mental, financial and social health benefits. Participating in community gardens increases fruit and vegetable intake, improves food choices and cuts food spending– effects that are disproportionately stronger for food-insecure households. Many studies on gardening show evidence of increased physical activity and lower BMI; reductions in stress, depression and anxiety; increased socialization and sense of community; and improved quality of life. Gardening increases children’s likelihood of eating fruits and vegetables, establishing healthy habits at an early age. For seniors, learning new skills has also been shown to maintain strong cognition and memory. 

Designing these opportunities into affordable housing sites brings them directly to those who need them most. Steady, on-site access to fresh removes time and financial burdens, reduces the challenges of managing monthly SNAP benefits and builds resilience to volatility in personal finances, grocery prices and strained supply chains. Locating green spaces in affordable housing properties can also mitigate the risk of green gentrification like that seen in Chicago’s Pilsen area. Rather than leaving LMI communities exposed to rising costs of living associated with new public greenways, they directly reap the benefits of green space without endangering affordable housing.

For owners and operators of affordable rental properties, gardens are a unique amenity that can attract tenants and improve retention. Edible gardens also build a sense of belonging, which can also raise tenant retention and even deter crime.

Green space increases property values – by anywhere from 3% to 20% in New York for example – and thus offsets initial costs to rental firms and promotes wealth-building for homeowners. 

Developers can already strengthen financing applications by building greenspace into projects in some places. Pushing federal regulators to include such incentives in CRA reform would make that true nationwide.

Root to rise: our call for action

To make affordable living a reality for the millions of Americans who not only need it, but deserve it, we call on you:

• Property developers, owners, and operators – Swap traditional landscaping for edible community gardens in your design plans. Identify existing properties that have unused space or lawns and take action to convert them. Build partnerships with landscape designers, community-based organizations, urban farmers, or food gardeners.
• Landscape-based professionals and organizations – Seek existing affordable housing properties with unused land and put it to work growing food. Offer design services to housing developers in the planning stages of greenfield projects. Share your knowledge and expertise with LMI communities. 
• Land banks & trusts – Consider affordable living in procurement of land by strategically seeking parcels fit for development of affordable housing and food gardens.
• Institutional lenders – Invest in or award grants to a variety of partners embracing affordable living, particularly organizations designing and creating edible gardens.
• Advocates for CRA reform – Submit comments regarding the CRA proposed reforms to denote food access and sustainability projects as eligible for reward. Introduce the concept of affordable living as an eligible activity: affordable housing coupled with regenerative food gardens that act as both a form of community development and climate remediation. 

Nobody should be going to bed hungry. Nobody should be choosing between keeping the power on, paying their medical bills, or having a nutritious meal. We can do better; we must do better.

By establishing affordable living, rather than simply affordable shelter, our neighbors can sleep with full bellies and happier minds. Vulnerable communities can build wealth and resiliency. Our lands can heal. Community partners can thrive. 

We can nourish all, together.

Photos courtesy of Samantha Koches, who is the founder of Nourish All.