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APR j 7 ]990
C/ED:HD:JM
City Council Meeting: April 17, 1990
Santa Monica, California
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TO: Mayor and city council
FROM: city staff
SUBJECT: Ordinance Amending Inclusionary Housing Program
INTRODUCTION
This report transmits information requested by Councilmembers
pertaining to the proposed ordinance amending the city's inclu-
sionary housing program.
Application of Ordinance 1448
The City's existing inclusionary housing program is implemented
by Ordinance 1448.
As currently administered, ordinance 1448
applies to residential projects containing five (5) or more
units, and requires that a minimum of 15% of the total number of
uni ts in a proj ect be rental uni ts affordable to households
earning no more than 100% of the County median income adjusted by
household size. Alternatively, developers may develop units
off-site or pay an in-lieu fee based on project square footage.
In-lieu fees must be used by the City to develop low and moderate
income housing. The City has established the citywide Housing
Trust Fund as the mechanism for expending the funds for
affordable housing development.
ADIJ >> j)-A-
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APt; 1 7 i990
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Inclusionary unit production by year
30 projects have been
28 projects are under
providing inclusionary
are rental proj ects .
of building permit is
To date, 52 inclusionary units in
completed. An additional 45 units in
construction. Five of the 48 projects
units are condominium proj ects ; 43
detailed below:
1984
1985
1986
1987
1988
1989
1990
* OF PROJECTS t INCLUSIONARY UNITS
3 7
2 2
11 19
8 15
17 41
7 13
0 0
48 97
YEAR OF PERMIT
TOTAL
The City has received approximately $1.65 million in Program 12
in-lieu fees paid by 46 projects. 11 projects paying fees were
rental projects; 35 were condominium projects. Fees received by
year of payment are detailed below:
YEAR OF PAYMENT * OF PROJECTS FEES PAID
1986 1 $17,169.00
1987 9 $173,505.72
1988 17 $734,876.21
1989 17 $671,825.25
1990 2 $58,919.62
TOTAL 46 $1,656,295.80
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The City has established the citywide Housing Trust Fund to
utilize funds paid pursuant to Ordinance 1448 as well as funds
paid pursuant to Ordinance 1367 (Office Housing and Parks
Mi tigation Program) and Ordinance 1448. To date approximately
$3.2 million in office mitigation fees for housing, and $1.65
million in inclusionary housing fees have been paid to the City
for expenditure through this trust fund.
Like the City's two other housing trust fund programs, this trust
fund will provide loans secured by deeds of trust and regulatory
agreements which restrict rents and occupancy. Under this
program, however, borrowers will be required to repay principal
and interest through project residual receipts. $2.34 million
from the Citywide Housing Trust Fund has been committed for the
development of a 45-unit affordable housing project being
developed by Community Corporation of Santa Monica in Sunset
Park, and $1.1 million has been committed toward the development
of 72 units of affordable senior housing being developed by
Retirement Housing Foundation.
Roundinq of Fractional Units
The proposed ordinance presented to city council on March 27,
1990 would alter the method by which the number of inclusionary
units is calculated. ordinance 1448 currently requires that
fractional units of less than .5 be rounded down to the nearest
whole number. This methodology differs from that now required by
State law regarding density bonuses. Under the State program,
any fractional units are rounded up to the nearest whole number
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to determine the number of units to be set aside and the number
of density bonus units provided. In order to simplify
calculations under the two programs, the proposed ordinance would
adopt the state's methodology for all calculations. This
rounding approach results in one additional unit being required
in projects of four, seven, and eight units.
An al ternati ve approach could be to round to the nearest whole
number from .5 in calculating the total number of inclusionary
units required, but to retain the requirement that at least 20%
of the units be set aside for low income households. This
approach would reduce by one unit the total inclusionary
requirement for four, seven, and eight unit proj ects , but it
would not change the number of low income units required. This
approach would reduce the total inc1usionary burden on these
projects by reducing the number of moderate income units
required. This approach would also ensure that projects meeting
the City's 20% inc1usionary requirement for low income households
would also meet the state requirements for a 25% density bonus.
A revised schedule detailing this approach is attached as Table
1. Whether using this approach, or the current approach to
rounding to calculate the low-income unit requirement, the
in-lieu fees charged would be the same.
Consideration of Tax Credit Equity in Calculatinq In-Lieu Fees
The proposed ordinance would calculate the required in-lieu fee
by subtracting from total development costs the maximum
affordable mortgage, based upon the inclusionary rent stream and
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standard operating expenses. The proposed ordinance has not
presumed the availability of owner equity or other non-City
sources of subsidy which would reduce the required city subsidy.
Because Citywide Housing Trust Fund loans are available only to
non-profit borrowers, the only type of equity which is likely to
be available in City funded projects utilizing inclusionary
housing in-lieu fees would be equity generated through sale of
Low Income Housing Tax Credits.
When a non-profit borrower enters into a limited partnership with
investors seeking to utilize the Low Income Housing Tax Credit,
the amount of equity which the limited partners will contribute
is a function of eligible project costs and the percentage of low
income units in the project. Low income units must be occupied by
and have rents affordable to households earning less than 60% of
the County median income.
Typically, the amount of equity contributed by investors buying
tax credits will equal 50% of the total development costs, not
including land costs, for the low income units. Because of the
income targeting requirements of the program, only those units
affordable to low income households can be presumed to generate
tax-credit equity. Therefore, where only two-thirds of all
incl usionary units are required to be low income units, the
amount of per unit tax credit equity which can be presumed will
equal two-thirds of 50%, or 33% times total development costs,
not including land. This is equal to approximately 20% of total
development costs including land.
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By including tax credit generated equity in the in-lieu fee
calculations, the required City subsidy would be reduced by an
average of $15,580 to $40,047 per inclusionary unit, depending on
unit size. The required in-lieu fee would be reduced from $22
per square foot to $15 per square foot. These calculations are
detailed in Tables 2, 3, and 4.
Per unit vs. Square Footaqe Assessment
The proposed ordinance would assess in-lieu fees against the
gross square footage of the market rate units in a project, as
has been the practice under Ordinance 1448. An assessment which
is based upon a square footage calculation ensures that the fee
charged to each developer is related to the size, and presumably
the value of the market-rate project. The city is assured that
overall, sufficient fees will be generated to allow the city to
develop the desired mix of low and moderate income housing. The
square footage assessment would has the disadvantage of requiring
an individual calculation for each project. In addition, it does
not ensure, on a project by project basis, that the fee charged
would be related to the number of inclusionary units which would
have been developed in a particular project.
An alternate approach would be to assess the fee for each
development according to the number of inclusionary units
required but not provided by a developer. Table 5 compares the
in-lieu fee schedules for both approaches, presuming tax credit
equity in the calculations. utilizing a per unit assessment, ln
lieu fees would range from $34,000 for zero bedroom units, to
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$85,000 for four or more bedroom units. This approach would have
the advantage of administrative simplicity in that, for example,
all projects consisting of two-bedroom units would have the same
in-lieu fee obligation.
However, this approach would have the more signi f icant
disadvantage of being more likely to skew development decisions
toward certain kinds of developments. In particular, a per unit
assessment would encourage developers to build projects with
fewer units, and with fewer bedrooms per unit to avoid larger
fees.
For example, with a per unit assessment, the fees for a four unit
development consisting of two-bedroom units would be $55,000 less
per market rate unit than the fees for a comparable five unit
development. Wi th a square footage assessment the fee
differential between a four and five uni t project is
approximately $17,625 per market rate unit~ The per unit
assessment is therefore much more likely to discourage the
development of five unit projects than would a square footage
assessment. Further, with a per unit assessment, the developer
would have an additional financial incentive to build large units
containing fewer bedrooms. As indicated in Table 5 the in-lieu
fee for a project containing two bedroom units would be $18,000
less per inclusionary unit than the same sized project containing
three bedroom units.
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Considering the relative advantages and disadvantages of both
approaches, the square footage assessment is the more workable
and equitable method.
Comparison to Proqram 10 Fees
On April 25, 1989, the City Council approved in concept an
ordinance implementing Program 10 of the City's Housing Element.
The purpose of the proposed Program 10 implementing ordinance was
to ensure adequate replacement of the existing housing stock. In
contrast, Ordinance 1448 and the proposed interim inclusionary
housing ordinance are designed to ensure that the new housing
stock is at least partially affordable to low and moderate income
households.
The proposed Program 10 implementing ordinance included a
schedule of in-lieu fees ranging from $27,000 to $63,000 per unit
removed and not replaced. These fees were calculated so as to
allow the city to replace rental units removed from the housing
stock. The fees were designed to facilitate the development of
units comprised of 85% market rate units, and 15% affordable
units, per the current requirements of Ordinance 1448. In
contrast, the fee schedule in the proposed inclusionary housing
ordinance is designed to facilitate the development of affordable
uni ts only, of which two-thirds are to be affordable to low
income households, and one-third are to be affordable to moderate
income households. For this reason, the proposed inclusionary
housing fees are higher than the previously proposed Program 10
fees.
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The firm of Kotin, Regan, and Mouchly has been retained to
analyze the cumulative economic impacts of Program 10 and
inclusionary housing fees on those projects with both replacement
and inclusionary housing obligations. Staff will return with
recommendations regarding both Program 10 fees and a permanent
inclusionary fee schedule when Program 10 analyses are completed
in the fall. Staff's analysis and recommendations regarding fee
levels for each program will take into account the cumulative
impacts of both programs.
All of the development cost assumptions utilized in calculating
the proposed inclusionary housing in-lieu fees are based upon
those used in calculating Program 10 fees. These development
cost assumptions were analyzed and verified by Economics Research
Associates in December 1989. To the extent that there were small
differences between staff's earlier assumptions and the ERA
verified figures, the ERA figures have been utilized.
Economic Impact on Small Projects
The impact of changes to the city's inclusionary housing program
will differ according to individual project circumstances.
Higher inclusionary fees will variously be passed on in the form
of higher prices to market rate housing consumers, lower ultimate
sales prices for land, and lower developer profits. In a
typical proj ect of four two-bedroom uni ts, the proposed
ordinance's in-lieu fee requirement of $22 per square foot would
result in a total in-lieu fee obligation of $103,400, equivalent
to $25,850 per market rate unit. At $15 per square foot the fee
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obligation would be $70,500, or $17,625 per market rate unit.
Depending on individual circumstance, these additional costs
would be paid by consumers, land-owners, and developers. A fee
equivalent to $17,625 per market rate unit would represent five
percent of the sales price of a typical $350,000 condominium.
As noted above, modifying the rounding calculation will impact
projects of four, seven, and eight units. A change in the
rounding
calculation
would
not
change
the
in-lieu
fee
requirements for projects unless the fees are assessed on a per
uni t, rather than on a square footage bas is.
Presuming tax
credit equity in the fee calculation, the fees for a four unit
proj ect would be $27,500 per market rate unit if fees were
assessed on a per unit basis using the rounding calculation in
the proposed ordinance. In contrast, the fees would be $13,750
per market rate unit if the rounding scheme were modified as
described above.
Prepared by: Jeff MUdrick, Senior Development Analyst
Nancy West, Housing Program Manager
Department of community and Economic Development
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April 17, 1990
PROGRAM 12 (INCLUSIONARY HOUSING PROGRAM) IN-LIEU FEE CALCULATION
I. INCLUSIONARY REQUIREMENTS:
Category
% of Units
Required
% of Area
Median Income
50%
60%
100%
120%
130%+
Very Low
Low
Median
Moderate
Market
0%
20%
10%
0%
0%
II. DEVELOPMENT COST ASSUMPTIONS:
DEBT SERVICE PAYABLE
$11,500jSpace*
$57.97jsquare foot* + parking cost
15.45% of hard cost*
$42jsquare foot*
Vacancy at 2%;
Taxes at 1.25% x total
development cost divided by 12;
Other expenses at (5.25% x rent)
plus ($1.10 x square footage divided
by 12)
Net income divided by 1.10 debt
coverage
9% interest, 30 year amortization
PARKING COST
HARD CONSTRUCTION COST
SOFT COST
LAND COST
OPERATING EXPENSES
MAXIMUM LOAN TERMS
III. UNIT SIZE ASSUMPTIONS:
Affordable Market-Rate
Type of unit unit
unit Size** Size*
0 BR 500 732
1 BR 600 1,006
2 BR 850 1,175
3 BR 1,080 1,450
4 BR 1,200 1,630
NOTES:
*Source: Evaluation of proqram 10 Proposed Fees. Economics Research
Associates, December 1989.
**Source: Ordinance of the city council of the city of Santa Monica
Relating to the Inclusionary Housing program, section 9423 Cd).
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