Building a more equitable, healthy, and sustainable District food system

East End Grocery and Retail Incentive Program Tax Abatement Act: is under review by DC Council now. This SAMPLE LETTER has been drafted by by the DC Food Policy Council’s Working Group on Equity, Access, Health, and Nutrition Education, please use whatever elements of it are most relevant to you in your testimony or outreach to Councilmembers. 

 SAMPLE LETTER

 

Dear Councilmember [insert your Councilmember’s name here],

 

As the DC Food Policy Council, we applaud the intention behind the East End Health Care Desert, Retail Desert, and Food Desert Elimination Act of 2017. We believe expanding access to healthy food in our city, and specifically in Wards 7 and 8, is essential to improving public health, reducing racial disparities in health and economic outcomes, and building more a vibrant, prosperous communities for all our residents.

 

The Act seeks to allocate District government funds toward the construction of a hospital in Ward 7 and a series of incentives aimed at bringing large anchor grocery stores to Wards 7 and 8. While the hospital question is beyond the scope and expertise of the Food Policy Council, the bill proposes a number of measures aimed at changing the calculus that large, for-profit, grocers and retailers apply when considering new store locations – a calculus that has consistently deemed Wards 7 and 8 as unfavorable destinations and reinforced the status of these communities as ‘food deserts.’ In its current form, the Act:

• Designates funding to establish incentives for affordable grocers and retailers to locate in specific commercial areas of Wards 7 and 8. This is meant to apply specifically to large, anchor stores that sell both groceries and retail goods.
• All but eliminates the cost of leasing District-owned land for grocers and retailers and fully pays for store construction costs, which are forgiven by the District over a thirty-year period.
• Establishes the East End Medical Center Fund, comprised of 50% of the District’s unassigned end-of-year surplus funding in excess of 60 days’ cash on hand, to be applied to the construction of the hospital and to fund the East End Grocery Retail Incentive Program. This bill assigns 50% of that additional, one-time, yearly funding to pay for construction of the hospital and, at the discretion of the Director of Health Care Finance, to be transferred to the Office of the Deputy Mayor for Planning and Economic Development (DMPED) to fund the construction of grocery and retail anchor stores.
• Exempts participating anchor retail stores from real property, deed recordation and transfer, personal property, and sales taxes so long as 50% of full-time employees are District residents. These tax exemptions improve store profitability and could, contingent on their implementation, lower the price of goods paid by consumers at those locations.

 

Our Analysis

The DC Food Policy Council has reviewed this bill and supports its overriding goal of expanding healthy food access in Wards 7 and 8. In some ways, these are generous benefits to offer national and businesses, but given the tight margins of the grocery store industry, there is a chance they still may not be enough to attract these retailers, or attract them in the near-term. We recommend that you use the opportunity to testify to talk both about your larger vision for healthy food access in DC as well as the provisions of these specific bills. Our city needs to take decisive action to expand healthy food access, and we believe this encouraging first step can become even stronger by adjusting some of the bill’s provisions in the following ways:

 

• Increase the number of specific sites in Wards 7 and 8 where these anchor facilities can be built and still receive the subsidy. We propose adding Parkside/the DC Promise Neighborhood to the list of sites along with language that states “Sites in Wards 7 and 8 deemed to meet the purposes of this Act” by DMPED. We also recommend updating the language so DMPED has the flexibility to add additional locations as opportunities arise.
• Shorten the timeframe an anchor store must stay on its site from thirty years to fifteen. Our industry research shows that a thirty-year timeline is unlikely to attract any willing grocery stores, while fifteen years may be sufficient. While we share the concern about excessive “giveaways” to well-resourced, non-local entities, we do not believe this incentive program will work under the current thirty-year timeline.
• Ensure that eligible projects have sufficient grocery store components, as opposed to other retail focus areas (e.g. household goods, clothing) that, under the current language, could conceivably secure these funds without positively impacting public health. We would suggest stipulating a minimum percentage of annual sales or dedicated square footage (i.e. 30%) at each incentivized site to consist of foodstuffs.
• Require that a certain percent of the funding be required to go specifically towards grocery uses. Funding for retail and grocery is at the determination of the Director of Healthcare Finance and not guaranteed through the current language. We would suggest setting aside a minimum of 30% of the funding for grocery purposes, as hospital costs may balloon and could use up all the available funding before a grocery store goes in.
• Expand the definition of eligible projects from exclusively new construction to include “substantial modernization” of existing grocery retailers in Wards 7 and 8 to support improved offerings of healthy, fresh, affordable food at these sites and help retain food businesses that are dramatically needed in these communities.
• Provide additional construction support through expedited permitting. Delays with construction often add extra costs to projects. Expedited permit review was provided for buildings under the DC Green Building Act, a similar speedy permitting process could be established to help these sites built for communities in need faster than the usual development process.
• Require the grocery to work with community members about their needs. Healthy Food Financing programs in other cities require that grocers work with the community about their needs (nutrition education, hiring local, tours by dieticians, etc.) in exchange for assistance with construction or renovation costs. We recommend that a similar requirement is included here.
• Expand the definition of eligible projects from “large anchor stores that sell affordably priced groceries and/or retail goods” to include “operations related to processing, procurement, storage, or production of food, meals, or nutrition services” that also provide substantial retail grocery options in Wards 7 and 8. Ensure that the definition is broad enough for modern grocer y business models to be sustainable. Eligible projects under this definition could include food hubs or community kitchens offering jobs and job training to District residents while operating adjoining mid-size grocery storefronts offering affordable, healthy food products. This change will allow more local DC businesses and organizations to potentially access these benefits, as well as larger nationwide grocers and retailers. Our community of homegrown food-focused businesses, social enterprises, and nonprofit organizations is eager and well-suited to help address our city’s healthy food access needs, and they should have the opportunity to submit their ideas and solutions for the best uses of these local incentives as well.

 

About the DC Food Policy Council

Created by the DC Food Policy Council and Director Establishment Act of 2014, we are an official board and commission of the District of Columbia government. Our members were appointed by Mayor Bowser and confirmed by the District Council. Supported by the Sustainable DC Plan and based on successful models from around the United States, the DC Food Policy Council is a collection of diverse community leaders and stakeholders with special expertise on how food is, and should be, a tool for improving public health, racial equity, and economic opportunity in the District. Our goal is to bring all relevant parties with a stake in food policy and practice – from District government agencies and entrepreneurs to community-based organizations and individual residents – together to identify regulatory gaps, create effective solutions, and promote informed policy in the District.

 

For more information about the DC Food Policy Council’s perspective on the East End Health Care Desert, Retail Desert, and Food Desert Elimination Act of 2017, our proposed amendments to the language of the Act, or the Food Policy Council itself, please contact dcfoodpolicy@dc.gov.

 

What can I do if I can’t testify on May 19th at 11am ?

You can still submit written testimony to Cherita Whiting, Committee Legislative Clerk Assistant at cwhiting@dccouncil.us email or notify the Councilmembers on the Health Committee about your support of the bill through the contact information listed here: http://dccouncil.us/events/committee-of-the-whole-business-and-economic-development-health-joint-publi .