SR 03-26-2019 7B
City Council
Report
City Council Meeting: March 26, 2019
Agenda Item: 7.B
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To: Mayor and City Council
From: David Martin, Director, City Planning
Subject: Introduction and First Reading of an Ordinance for Proposed Amendments to
the Affordable Housing Production Program
Recommended Action
Staff recommends that the City Council:
1) Review and discuss the information contained in this report regarding the City’s
regulatory and policy framework to support housing production, as well as
affordable housing production trends, including units in the Extremely Low
Income (ELI) category.
2) Authorize the City Manager to negotiate and execute an agreement with HR&A
Advisors, Inc., a California-based company, for financial feasibility analysis of
potential affordable housing requirements and minimum density requirements for
the Planning and Community Development and Housing and Economic
Development Departments. This recommended award is for a total amount not to
exceed $150,000 with future year funding contingent on Council budget approval.
3) Consider introduction and first reading of an ordinance amending the text of the
Municipal Code to temporarily remove the option for providing ELI units to satisfy
a project’s Affordable Housing Production Program obligation pursuant to SMMC
Chapter 9.64 and specify that 100% Affordable Housing Projects that are owned
and operated by non-profit housing providers and financed with tax credits may
be exempt from certain provisions of the Affordable Housing Production Program
(SMMC Chapter 9.64), subject to certain conditions (Attachment “A”)
Executive Summary
Affordable housing is the City’s highest housing priority, and is the focus of City
programs, subsidies and other efforts to minimize the affordability gap in Santa Monica.
This report presents information on the use of the Affordable Housing Production
Program (AHPP) to support the long-term housing needs in Santa Monica, and to
maintain economic diversity within the city. It focuses on two aspects of the AHPP:
1) The use of the Extremely Low Income inclusionary option to satisfy a
development’s affordable housing obligation, and
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2) Development of 100% affordable housing projects owned and operated by non -
profit housing providers outside of the requirements of the City’s AHPP using
financial assistance through the California Tax Credit Allocation Committee.
Extremely Low Income Option
Most of this report focuses on the production of units targeted to lower income
households earning no more than 30 percent of the area median income (“AMI”),
commonly referred to as “extremely low-income” (ELI). Based on evidence of local
housing needs, this income category was added to the AHPP in 2013 as an option for a
development to satisfy its onsite affordable housing obligation by restricting five percent
of the total units built for ELI households for Tier 1 projects, and seven and a half
percent for a Tier 2 housing project.
In the past ten years, nearly 160 units at the ELI income category have been approved,
including several projects that predate the formal introduction of this income category
into the AHPP. While the creation of units deed-restricted to the ELI level helps to
realize SCAG’s Regional Housing Needs Allocation and the City’s own Quantified
Objectives, there is a concern that the recent methodology for creating the units (i.e.,
through the existing AHPP “menu of options”) is counterproductive to meeting the
overall Proposition R mandate for 30 percent of all housing to be affordable. This report
contains data on the use of the 5 percent option since its adoption in 2013, as well as a
preliminary evaluation of its impact on the City meeting its Proposition R targets.
The information presented in this report is intended to support the City Council’s
direction to prepare amendments to the AHPP to temporarily remove the 5 percent
option by providing background on the past half-decade of housing policy, as well as
information about affordable housing production trends, including units in the ELI
category. Should the Council decide to temporarily remove the 5 percent option,
Attachment A presents the ordinance language to effect this change to SMMC Section
9.64.050.
California Tax Credit Allocation Committee Financial Assistance
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Also included in this report is a brief discussion of a financial tool that supports 100%
affordable housing development. The California Tax Credit Allocation Committee
(TCAC) provides financial assistance to housing developers and presents additional
affordable housing opportunities distinct from the City’s AHPP through TCAC’s own
regulations that include affordability levels, maximum rents, minimum unit sizes and
other amenities. TCAC-funded projects that are also funded by the City are currently not
required to use the City’s housing waiting lists.
An ordinance to modify SMMC Section 9.64.030 is included in Attachment A that would
allow affordable housing developments by nonprofit TCAC recipients that are not City-
funded to be exempt from AHPP requirements provided they select households from
the City-developed list of income-qualified households and do not compete with City-
funded projects also seeking TCAC financial assistance.
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PART 1: EXTREMELY LOW INCOME OPTION
Background
Santa Monica has an extensive history that prioritizes affordable housing to preserve
and promote a diverse and sustainable community. Residents have affirmed this p riority
in local voter-approved initiatives, such as Proposition R (1990), requiring that 30
percent of all new multifamily housing be affordable, and Proposition I (1998),
authorizing the City to participate financially in creating affordable housing equa l to one-
half of one percent of the housing stock annually (approximately 250 residences). City
Council has further facilitated affordable housing through adoption of land use
incentives and administrative funding guidelines to streamline affordable housing
production and preservation, based on a policy foundation supporting affordable
housing in the General Plan Land Use and Housing Elements. The Land Use Element
also identifies affordable housing as a primary community benefit in new development.
The Affordable Housing Production Program (AHPP) requires developers of multi-family
housing to contribute to affordable housing production through a flexible framework to
help the City meet its affordable housing goals. Finally, City Council has approved a
local preference policy that prioritizes affordable housing opportunities for Santa Monica
residents and workers.
Changes to the Zoning Ordinance and AHPP (2013)
In recent years, California’s ongoing housing crisis has underlined the need for local
jurisdictions to revisit their regulatory frameworks governing housing production. In
Santa Monica, the discussion has been particularly dynamic, as the community and
decision-makers have wrestled with a variety of local, regional and State -level factors
that contribute to production, affordability, and equity. From time to time, changes to the
rules and regulations related to housing are effected in response to these factors.
With the dissolution of the Redevelopment Agency in 2012, the City lost its primary
funding source for affordable housing. In 2012-2013, Council led a host of public
discussions on the ability for the City to continue to meet the needs of Santa Monica
residents. Out of those discussions arose a focus on providing for those whose
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household income levels were below the traditional very-low income threshold
established by HUD.
On February 28, 2012 (Attachment G), Council held a study session to consider
a variety of issues related to housing in Santa Monica. At the study session, staff
presented data from the City’s affordable housing waiting list showing that the
vast majority (95%) of Santa Monica residents and workers on the list were at
extremely low- or very low-income levels.
On December 11, 2012 (Attachment H), Council directed staff to amend the
AHPP to include opportunities for extremely low-income households to address
the approximately 3,000 ELI households who lived or worked in Santa Monica at
that time.
On February 26, 2013 (Attachment I), Council directed staff to consult with the
Legal Aid Foundation of Los Angeles (LAFLA) and return with a draft ordinance
amending the AHPP rent limit standards to achieve greater affordability.
On June 25, 2013 (Attachment J), Council introduced for first reading Ordinance
No. 2429 (CCS) to revise household income eligibility levels and rent limits for
the AHPP, and to add an option for developers to provide affordable housing to
households earning no more than 30 percent AMI to satisfy AHPP obligations.
The subsequent amendments to the AHPP approve d by Council in 2013 revised the
City’s household income eligibility levels to match income levels published annually by
HUD and/or HCD, and added the 30 percent of AMI category referred to as “extremely
low-income1” to the menu of options that satisfy a development’s inclusionary affordable
housing requirement. This significant addition to the AHPP was designed to create a
financial incentive to stimulate the development of such units. Henceforth, outside of the
1 30% Income Household means a household whose gross income does not exceed the
30% income limits applicable to the Los Angeles-Long Beach Primary Metropolitan
Statistical Area, adjusted for household size, as published and periodically updated by
Housing and Urban Development (HUD)
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areas governed by the Downtown Community Plan, applicants undertaking Tier 1 and
Tier 2 projects currently may select from a menu of options to develop at least:
Option Tier 1 Tier 2 (Requires 50% more than Tier 1)
1
5% of the total units of the project for
30% income households at
affordable rent2; or
7.5% of the total units of the project
for 30% income households at
affordable rent;
2
10% of the total units of the project for
50% income households at affordable
rent; or
15% of the total units of the project
for 50% income households at
affordable rent; or
3
20% of the total units of the project for
80% income households at affordable
rent; or
30% of the total units of the project
for 80% income households at
affordable rent;
4
100% of the total units of a project for
moderate income households at
affordable rent.
Not Applicable
Proposition R Compliance (1994-Present)
The production of multifamily affordable housing in Santa Monica is regulated by the
voter-approved Proposition R, which requires that:
Thirty percent of all multifamily housing completed in each fiscal year be
affordable for and occupied by low- and moderate-income households; and
At least one-half of the total affordable housing completed be affordable for and
occupied by low-income households.
The most recently published Annual Report (FY 16/17) discussing the City’s compliance
with Proposition R illustrates a downward trend in affordable housing production, citing
just 13 percent of multifamily housing completed during that time is affordable to low-
and moderate-income households. This is consistent with the low production numbers
from the previous two fiscal years (FY 14/15, and FY 15/16) when 19 percent of new
multifamily housing was affordable to low- and moderate-income households.
2 The 5% option was added to Chapter 9.64 in 2013 by Ordinance 2429 (CCS)
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Cumulative Proposition R Achievements3
Affordable New Multifamily Residences Completed Annually
FY 94/95 through FY 16/17
One of the main factors affecting the number and percentage of affordable residences
being constructed is the loss of funding from the Redevelopment Agency. Historically, a
3 Annual Affordable Housing Report on Propositions R and I, April 2018
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significant portion of the Proposition R affordable housing mandate has been fulfilled by
nonprofit developers who use City-subsidized loans to create affordable housing. The
largest funding source for such loans was the Redevelopment Agency. Since the
demise of the Redevelopment Agency in 2012, Santa Monica voters approved
measures GS and GSH in 2016, which provides approximately half of the amount of
funding that was available through the former Redevelopment Agency. In addition,
Council has directed that all repayment of loans from the former Redevelopment
Agency to the City be dedicated to affordable housing.
Despite a failure to achieve Proposition R requirements annually over the past three
fiscal years, the City continues to exceed the minimum Proposition R requirement
cumulatively, adding up the developments that have been completed over the past 23
years.
Subsequent Shifts in Housing Policy (2017)
Since the most recent changes were made to the AHPP, local, regional and national
economic factors have shifted once again, leading to a widely-recognized state-wide
housing crisis and a renewed discussion on local housing production policy, both
market-rate and affordable. The City has been proactive in its efforts to use adopted
policy as a lever for incentivizing new housing production in targeted areas, such as
Downtown, and for increasing the supply of affordable housing. These measures have
been implemented at the same time that the City has witnessed a decrease in the
overall amount of affordable housing produced on an annual basis, as previously
mentioned.
Downtown Community Plan
The adoption of the Downtown Community Plan (DCP) in 2017 established a new
methodology for housing production that includes permit streamlining, and floor area
and height incentives for qualified housing projects. Downtown development is also
subject to higher affordable housing requirements than citywide, and must provide a set
percentage of units (on-site or off-site) that are deed-restricted to each income level
identified in the AHPP.
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This approach differs from the Zoning Ordinance in three important ways:
1. The affordable housing methodology in the DCP removes developer selection of
income categories at the Tier 2 level, and instead establishes a 20 percent base
requirement for a project’s total affordable housing contribution based on the
project’s height.
2. The DCP does not provide the developer a financial incentive to profit from a
higher market-to-affordable ratio based on developer selection of income levels.
For example, a Tier 2 mixed-use housing project of 100 units that has selected
the Zoning Ordinance’s ELI option will generate only 8 deed-restricted units, and
92 market-rate units. In the DCP, that same project would provide a minimum of
20 deed-restricted units, and 80 market-rate units.
3. The required affordable housing units produced in a project by the DCP must be
distributed across the four income levels recognized by the AHPP based on the
following percentages:
a. 20% Extremely Low-Income
b. 20% Very Low-Income
c. 30% Low-Income
d. 30% Moderate-Income
The increased affordability requirements in the DCP are expected to play a critical role
in helping the City meet the requirements of Proposition R. Amending the AHPP to
require a broader array of affordability levels could also assist in Proposition R
compliance. A forthcoming Council Information Item on the impact of DCP housing
policy on production will be issued in March 2019.
Suggested Changes to the AHPP (2018)
Based on the DCP’s new approach to creating equity among income levels, new
conversations have sprung up to evaluate the existing Zoning Ordinance methodology
in order to identify potential improvements that balance supply with demand, and aid in
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reversing the downward trend in affordable housing produc tion identified in the past
several Proposition R compliance reports. These discussions have been fueled by the
perception that the financial incentive to allow a development to deed -restrict a low
number of units for extremely-low income households has perhaps been too successful,
and has ultimately impacted the City’s ability to meet annual Proposition R targets. This,
coupled with the loss of Redevelopment, has placed an even heavier burden on the City
to make up the production of remaining affordable units using limited financial and
regulatory resources.
In light of this concern, the Housing Commission discussed on November 15, 2018
modifying affordable housing requirements outside of the Downtown Community Plan
area, and opined on the possibility of suspending the extremely low-income option until
a full review of the AHPP could be conducted through an updated economic feasibility
study. The feasibility study is a work effort currently in the scoping phase being led in
partnership by the Planning and Community Development and Housing and Economic
Development departments, which will provide analysis on the potential to modify the
AHPP so that it addresses a broader range of needs, including supporting Prop. R and
Regional Housing Needs Assessment compliance. The scope and timeframe for the
upcoming feasibility study is discussed later in this report.
As an interim measure, Council directed staff on December 18, 2018 to prepare
amendments to the Affordable Housing Production Plan disallowing the current option
for developers to provide fewer extremely low-income units until the feasibility study can
be completed.
Discussion
Santa Monica is a desirable place to live and work, making the demand for housing far
greater than the existing supply. Based on significantly higher than average rent and
home ownership values, as well as the housing policy described earlier in this report,
the City continues to receive proposals to create new housing. Because of these
conditions, the City has been fortunate to routinely meet the Regional Housing Needs
Assessment (RHNA) housing production targets established by the Southern California
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Association of Governments (SCAG) as well as the City’s own “Quantified Objectives”
for housing production outlined in the adopted 2014 -2021 Housing Element. The City’s
mixed-use higher-density commercial districts provide a wide range of housing
opportunities, and current pipeline projects indicate that the City will continue to attract
new market-rate housing development that is capable of contributing to the creation of
new affordable units at a variety of income levels.
Affordable Housing Production (2014-Present)
Since 2014, the cumulative amount of affordable residences completed (final building
permits) has met the City’s minimum requirement of 30 percent. Multifamily
developments completed between 2014 and 2018 produced 1,001 residences, of which
402 (40 percent) were affordable to low-and moderate-income households. Of those
affordable units, 95 percent were affordable to low-income households. The City has
met both Proposition R requirements that 30 percent of all multifamily housing be
affordable to low- and moderate-income households and that at least one-half of the
total affordable housing be affordable for and occupied by lo w-income households.
However, pipeline projects indicate that future production will fall short of this mark.
Multifamily developments currently in construction will produce just 13 percent
affordable units (95 of 759 total), and multifamily developments with planning approval
will produce just 10 percent affordable units (133 of 1,384 total). For projects in
construction and with planning approval, over 90 percent of all affordable units will be
affordable to low-income households.
Pending projects are those that have been submitted but have not received planning
approval yet. Affordable residences represent 22 percent of all pending projects (366 of
1,651 total), which includes five large 100 percent affordable housing developments.
The following table summarizes this information.
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2014-2018 Affordable Housing Production Program Summary
Development
Stage
Total Residences Affordable
Residences
Percent
Affordable
Completed 1,001 402 40%
In Construction 759 95 13%
Planning Approval 1,384 133 10%
Pending 1,651 366 22%
TOTAL: 4,795 996 21%
Developments Completed
Attachment B indicates that 46 developments totaling 1,001 residences were completed
between 2014 and 2018. A total of 402 of these residences (40 percent) were affordable
to low- and moderate-income households. These projects received planning approvals
between 2000 and 2015 and include six 100 percent affordable housing developments.
Developments in Construction
Attachment C lists active building permits to illustrate the number of multifamily
residences in construction as of January 2019. There are active building permits for 759
residences in 21 new multifamily developments. These developments will provide 95
residences affordable to low- and moderate-income households representing 13
percent of multifamily residences in construction. These active building permits received
planning approvals between 2006 and 2018 and do not include any 100 percent
affordable housing development.
Developments with Planning Approval (not in construction)
Attachment D identifies 38 multifamily developments containing 1,384 residences that
have received planning approval but have not been issued building permits yet. A total
of 133 of these residences will be affordable to low- and moderate-income households,
representing just 10 percent of all residences at the planning approval stage. These
projects received planning approvals between 2008 and 2018 and two of these
developments are 100 percent affordable housing developments.
Looking at just the 14 multifamily developments that received planning approval in
2018, 16 percent of the residences (98 of 604 units) were affordable to low- and
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moderate-income households. Seven of these 14 developments provided only
extremely low-income units (and market rate), representing eight to nine percent of the
units in each development.
Multifamily Residences (Units) with Planning Approvals in 20184
Developments Submitted Since 2013 (Approved, In Construction, Completed)
Considering all multifamily developments that were submitted and received planning
approvals since the changes to the AHPP policy in 2013, which also includes completed
projects and projects in construction, residences affordable to low- and moderate-
income households make up 16 percent of all residences (199 of 1,283). More than
one-third of all affordable units approved since 2013 have been in the extremely low-
income category (74 of 199). Excluding the three large 100 percent affordable housing
developments developed by Community Corps of Santa Mon ica (CCSM), the remaining
multifamily market developments include just 8 percent of residences that are affordable
to low- and moderate-income households.
4 Source: Planning and Community Development Permit Tracking
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Affordable Units in Approved Multifamily Developments Submitted Since 20135
Pending Developments
Attachment E shows the 27 pending multifamily developments containing 1,651
residences that have been submitted but have not yet received planning approvals. A
total of 366 of these residences are proposed to be affordable to low- and moderate-
income households, representing 22 percent of all proposed residences. Five of these
developments are 100 percent affordable housing developments (three of which are off -
site affordable units from market-rate developments), which represent 231 units, or 63
percent of all the proposed affordable residences.
Planning Commission Comments
The Planning Commission held a study session on this topic on February 20, 2019.
During that meeting, staff presented information described in this report and
attachments, as well as a snapshot of the City’s progress in realizing the housing
production targets established by the following:
SCAG Regional Housing Needs Allocation (2013-2021) (Attachment E)
5 Source: Planning and Community Development Permit Tracking
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Housing Element Quantified Objectives (2014-2021) (Attachment E)
City of Santa Monica Proposition R (1990)
As demonstrated by the housing production data, the City is on track to meet both the
RHNA and Quantified Objective targets for ELI, VLI and Above Moderate; however,
production has fallen short in the categories of Low Income and Moderate Income.
Approved and pending housing projects are not anticipated to contribute enough units in
these income categories to realize the targets.
Similarly, preliminary data indicates that annual Proposition R compliance will be difficult
to achieve during FY18/19, but some recovery is anticipated in future years based on
the success of the City’s effort to support affordable housing production through its
Housing Trust Fund program, which is successfully generating a range of affordable
units through non-profit development 100% affordable housing projects.
Based on this information, as well as an appreciation of other housing-related work
efforts scheduled for 2019, such as the AHPP Feasibility Study, the DCP Housing
Report, Housing Incentives for the Boulevards and Bergamot, and solutions to
Corporate or “Medium Term” Housing, the 6 person Planning Commission was evenly
split over the issue of temporarily removing the 5 percent ELI option from the AHPP.
Commissioners in Support of Removing the 5 Percent ELI Option
Those in favor of temporarily removing the 5 percent option cited data demonstrating
that ELI needs have been met and already exceeded, and that more attention should be
focused on the production of low- and moderate-income units during the time remaining
in both the RHNA and Housing Element cycles.
Commissioners in Opposition to Removing the 5 Percent ELI Option
Those in opposition to removing the 5 percent ELI option argued for the continued
production of housing under the current regulatory framework, and viewed changes to
the AHPP as premature pending a more comprehensive assessment of the entire
affordable housing production program. This will commence in spring, pending Council
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budget authorization. Some commissioners made a case for expediting the upcoming
feasibility study, as well as the effort to bring forward information regarding possible
incentives for the Boulevards and Bergamot.
Agreement on Pipeline Project Exemption
Despite the split vote on removal of the 5 percent ELI option, the Planning Commission
unanimously passed a separate motion to recommend that pipeline projects be
categorically exempt from any regulatory action taken by Council on this subject. The
Planning Commission did not clarify what defines a “pipeline” project.
Housing Commission Comments
The Housing Commission held a public meeting on February 21, 2019 to discuss,
among other items, use of the ELI option in development. Mirroring the
recommendations of several Planning Commissioners, the Housing Commission
majority voted to 1) temporarily remove the 5 percent option until a financial feasibility
study can be completed to evaluate potential modifications to the AHPP; 2) defer final
consideration of other amendments to the AHPP (regarding exempting nonprofit-
developed affordable housing) until after the financial feasibility is completed and
reviewed, and 3) to expedite the financial feasibility study.
Ordinance to Implement Proposed Temporary Elimination of ELI Option from
AHPP
The proposed ordinance in Attachment A provides for a temporary elimination of the ELI
option to allow the feasibility study to be completed and reviewed. The elimination would
apply to projects with an application that has been determined complete on or after
March 26, 2019. Those projects would not be allowed to select Extremely Low Income
from the AHPP’s “menu of options”, but would otherwise be permitted to choose from
any other income level currently available.
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Future Analysis and Efforts on Housing Production
Downtown Community Plan Housing Report Information Item (March 2019)
Staff recently issued a monitoring report for the DCP that evaluates the influence of
DCP housing policy and requirements on housing production. This review of data from
the past one and a half years since DCP adoption provides information that may be
informative to the related analytical efforts mentioned below, specifically regarding how
the unique project requirements for affordable housing production Downtown are
working, or are producing unintended consequences such as the emergence of six new
Tier 1 SRO projects that avoid entirely the DCP’s affordability requirements. This report
also provides an insight into the urban design implications of the affordable housing
requirements Downtown, as well the fulfillment of desired community benefits that are
associated with Tier 2 and Tier 3 projects.
Feasibility Study to Evaluate Citywide AHPP Program (Spring-Summer 2019)
The upcoming financial feasibility study is intended to inform decision-makers with the
results of empirical testing of prototypical private developments to establish the
financially-feasible limits of modified affordable housing requirements, in addition to
testing a minimum density concept for R2 multi-family lots to help increase the City’s
supply of affordable housing. More specifically, the feasibility study will evaluate
whether affordable housing requirements associated with broader affordability levels,
unit mixes, and percentage requirements can be supported financially by p rivate
developers of future Tier 2 developments outside of the Downtown area. A similar
feasibility analysis was completed for the inclusionary requirements in the DCP. Staff
estimates that this work will take between 6-8 months to complete and review with the
Planning Commission, Housing Commission and City Council.
Housing Incentives: Boulevards and Bergamot Plan Area (Spring-Summer 2019)
During the same timeframe as the AHPP Feasibility Study, staff will work to identify
means to stimulate more housing production on the city’s Boulevards and in the
Bergamot Plan area, where housing development has been relatively anemic over the
past half decade. This process will consider a variety of tools including project
streamlining, floor area and height incentives, and other features to direct multifamily
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housing production away from the residential neighborhoods to areas identified by the
Land Use and Circulation Element.
PART 2: CALIFORNIA TAX CREDIT ALLOCATION COMMITTEE (TCAC)
FINANCING
Background
SMMC Section 9.64.030 defines the applicability of the AHPP to certain project types.
The ordinance currently provides that a multi-family rental housing project that will be
developed by a nonprofit housing provider receiving financial assistance through one of
the City’s housing trust fund programs and secured by a regulatory agreement with the
City for a minimum period of 55 years shall be exempt from the City’s Affordable
Housing Production Program (AHPP). This standard is intended to differentiate
nonprofit affordable housing developments from inclusionary housing obligations
resulting from market-rate developments. This standard is also intended to help ensure
that City funds invested in affordable housing can be maximized, including leveraging
non-city funds.
Nonprofit housing providers have identified an opportunity to increase the total amount
of affordable housing that can be produced through the AHPP by partnering with market
rate developers to leverage tax credits for offsite inclusionary housing. Howe ver, under
the existing AHPP ordinance, only projects that will be developed with “financial
assistance through one of the City’s housing trust fund programs” can be exempt from
the AHPP requirements. Community Corporation of Santa Monica (“CCSM”), a non -
profit housing provider who has developed affordable housing throughout Santa
Monica, has therefore proposed an amendment to the AHPP ordinance that would
extend certain provisions of the AHPP exemption to 100% affordable housing projects
owned and operated by nonprofit housing providers that finance the development of
these projects with tax credits. The proposed exemption to the AHPP requirements
would be subject to the following conditions:
(i) compliance with Section 9.64.110 of the AHPP (which would require the
developer to select tenant applicants from the City developed waiting list);
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(ii) compliance with the then-current California Tax Credit Allocation
Committee Regulations (“TCAC Regulations”), including the minimum unit
size requirements in Cal. Code Regs. tit. 4, § 10325(g)(1)(B);
(iii) ensuring that the project’s affordability obligations will be secured by a
regulatory agreement, memorandum of agreement, or recorded covenant
in form approved by the City Attorney, for a minimum period of fifty-five
years; and
(iv) ensuring that the project does not compete with a City-funded Tax Credit
project in the same category and round of competition, as reasonably
determined by the City Manager.
If approved, this exemption would allow these 100% affordable housing projects to
comply with TCAC Regulations, instead of AHPP requirements, except that tenant
applicants would be selected from the City-developed list. TCAC regulations apply
different affordability levels, maximum rents, minimum unit sizes, and amenities from
AHPP standards. For example, the TCAC maximum rent levels are higher than AHPP
maximum rents, which enhances the underwriting of these projects for tax credit equity
investors and commercial lenders, and facilitates layered financing for larger affordable
housing projects than would otherwise be feasible in the absence of tax credit financing.
A comparison of TCAC and AHPP rents are set forth in the table, below:
AHPP vs TCAC Rent Limits (2018)
Unit Type Extremely Low Very Low Low Moderate
AHPP 0-Bdrm $364 $606 $728 $1,334
TCAC $509 $848 $1,018 n/a
AHPP 1-Bdrm $416 $693 $832 $1,525
TCAC $545 $909 $1,091 n/a
AHPP 2-Bdrm $468 $780 $936 $1,715
TCAC $654 $1,091 $1,309 n/a
AHPP 3-Bdrm $520 $866 $1,040 $1,906
TCAC $756 $1,260 $1,512 n/a
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AHPP vs TCAC Minimum Unit Sizes
AHPP in Blue
Unit Type
Minimum
Square
Footage
0-Bdrm 500
200
1-Bdrm 600
450
2-Bdrm 850
700
3-Bdrm 1,080
900
Discussion
Attachment A presents a clarified description of the applicability of the AHPP for certain
project types. The attached ordinance accomplishes the following:
Adds to the current exemption for projects developed with financial assistance
through one of the City’s housing trust fund programs from the AHPP
requirements by further exempting multi-family rental housing projects developed
by a nonprofit housing provider receiving financial assistance through the
California Tax Credit Allocation Committee from the AHPP requirements so long
as the project is a 100% Affordable Housing Project as defined by the Santa
Monica Municipal Code.
Multi-family project applicants would be required to select households from the
City-developed list of income-qualified households or equivalent priority list
approved by the City.
Applicants would be required to comply with then-current California Tax Credit
Allocation Committee Regulations, including the minimum unit size requirements.
The project’s affordability obligations would be secured by a regulatory
agreement, memorandum of agreement, or recorded covenant in form approved
by the City Attorney, for a minimum period of fifty-five years.
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Planning Commission Comments
This issue was first raised as part of the latest round of Zoning Ordinance updates. On
February 20, the Planning Commission recommended that the City Council approve an
amendment consistent with the language presented to the Commission, which did not
require to use the City’s housing waiting list and did not prohibit the projects from
competing with City-funded projects for financial assistance from TCAC.
Housing Commission Comments
The City’s Housing Commission, upon reviewing the proposed modification to this
language, made the following recommendations:
1) Recommends against adopting the text amendment permanently until an
economic analysis is completed to ensure that the off -site inclusionary
requirements reflect the additional opportunity associated with tax-credit
leveraging.
2) Supports adopting the text amendment on an interim basis to enable a currently
proposed inclusionary / market-rate arrangement if the developer can
demonstrate to Council that the proposed developments are beneficial in terms
of the number of inclusionary apartments that will be created.
3) If the proposed text amendment is adopted, it should make explicit that
prospective residents of tax-credit funded inclusionary housing will come from the
City list, as they do for other inclusionary housing.
Next Steps on Financial Feasibility Study
Vendor Selection for AHPP Feasibility Study
Staff recommends HR&A Advisors, Inc. to provide financial feasibility analysis of
potential affordable housing requirements and minimum density. This recommended
award is made as an exception to the competitive bidding process pursuant to Section
2.24.80(d). Competition does not exist because HR&A has completed extensive
feasibility analysis related to the AHPP, including the recent Downtown Community
Plan, and therefore has the unique ability or capability to complete the study.
Completing a competitive procurement process is highly unlikely to produce cost-
23 of 24
competitive proposals from other sources, given HR&A’s experience and knowledge
with preparing modeling for the AHPP.
Financial Impacts and Budget Actions
Staff seeks authority to award an agreement with HR&A Advisors, Inc. for financial
feasibility analysis of potential affordable housing requirements and minimum density
requirements. Staff will seek grant funding from the California Department of Housing
and Community Development’s to fund the agreement in whole or in part. To ensure
that the study can commence immediately, the Housing and Economic Development
Department will advance the funds from an existing account.
Agreement
Request Amount FY 2019-19 Budget
Housing and Economic
Development Department
Account #
Total Agreement Amount
$150,000 01160001.552010 $150,000
Future funding is contingent on Council budget approval.
Prepared By: Peter James, Principal Planner
Approved
Forwarded to Council
Attachments:
A. Ordinance to Temporarily Remove ELI Option
B. Developments Completed
C. Developments in Construction
D. Developments with Planning Approval
24 of 24
E. Pending Developments
F. RHNA and Quantified Objectives Progress
G. February 28, 2012 Council Study Session on Housing (Web Link)
H. December 11, 2012 Direction to Staff to Add ELI Option (Web Link)
I. February 26, 2013 Direction to Staff to Amend Rent Limit Standards (Web Link)
J. June 25, 2013 Ordinance Adopted to Include ELI Option (Web Link)
K. Written Comments
L. Powerpoint presentation
1
City Council Meeting; March 26, 2019 Santa Monica, California
ORDINANCE NUMBER _________ (CCS)
(City Council Series)
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
SANTA MONICA AMENDING SANTA MONICA MUNICIPAL CODE CHAPTER 9.64
TO EXEMPT CERTAIN 100 PERCENT AFFORDABLE HOUSING PROJECTS
OWNED AND OPERATED BY NONPROFIT HOUSING PROVIDERS THAT ARE
SUBJECT TO CALIFORNIA TAX CREDIT ALLOCATION COMMITTEE
REGULATIONS AND TO REMOVE THE EXTREMELY-LOW INCOME AFFORDABLE
HOUSING CATEGORY
WHEREAS, the City has a long history of prioritizing preservation and production
of affordable housing in order to promote and maintain affordability and diversity within
the community; and
WHEREAS, the City’s residents have affirmed this priority in voter-approved
initiatives, such as Proposition R, which was adopted by the voters in 1990 and
mandated that 30 percent of all new multi-family housing units constructed each year be
affordable, and Proposition I, which was adopted by the voters in 1998 and authorized
the City to participate financially in creating affordable housing equal to one -half of one
percent of the housing stock annually; and
WHEREAS, the City Council has further facilitated preservation and production of
affordable housing by adopting land use incentives and administrative funding
guidelines to streamline affordable housing production and preservation and through the
policy foundation of supporting affordable housing articulated in the General Plan’s
Land Use and Housing Elements; and
2
WHEREAS, the City’s Affordable Housing Production Program, codified at
Chapter 9.64 of the Santa Monica Mun icipal Code (the “AHPP”), requires developers of
multi-family housing projects to contribute to affordable housing production and thereby
enhances the City’s efforts to meet its affordable housing production goals; and
WHEREAS, the requirements of the AHPP are based on a number of factors
including, but not limited to, the City’s longstanding commitment to economic diversity;
the serious need for affordable housing as reflected in local, state, and federal housing
regulations and policies; the demand for affordable housing created by market rate
development; the depletion of potential affordable housing sites due to market-rate
development; and the impact that the shortage of affordable housing has on the health,
safety, and welfare of the City’s residents, including local and regional traffic, transit,
transportation and air quality impacts; and
WHEREAS, on June 25, 2013, the City Council adopted Ordinance Number
2429 (CCS) to amend Chapter 9.64 by revising affordable housing categories, income-
eligibility limits, and rent limits to be consistent with federal and state affordable housing
programs (“Ordinance 2429”); and
WHEREAS, Ordinance 2429 also expanded AHPP income categories to include
households at the lowest end of the income scale, whose gross income does not
exceed 30 percent of the area median income, sometimes referred to as the extremely
low-income category; and
WHEREAS, Ordinance 2429 further provided that a developer may meet its
AHPP requirements by developing 5 percent of the total units of the project to be made
available at affordable rent to households in the extremely low-income category; and
3
WHEREAS, the extremely low-income category was added to the AHPP to
stimulate the development of such units; and
WHEREAS, since the adoption of Ordinance 2429, more than one-third of all
affordable units approved have been in the extremely-low income category, and, in
2018, 84 percent of all affordable units approved were in the extremely-low income
category; and
WHEREAS, although the City has met its overall affordable housing production
requirements as mandated by Proposition R since adoption of Proposition R and,
collectively, since 2014, the City has seen an overall decline in affordable housing
production since 2014 and has not met its annual targets for affordable housing
production under Proposition R in fiscal years 2014/2015, 2015/2016, or 2016/2017;
and
WHEREAS, the production of such a large number of affordable units in the
extremely low-income category has resulted in fewer affordable units being produced in
the very low-, low- and moderate-income categories and fewer affordable units being
produced overall; and
WHEREAS, on July 25, 2017, after conducting a feasibility study, the City
adopted AHPP obligation requirements specific to the Downtown as part of the
Downtown Community Plan (“DCP”); and
WHEREAS, the DCP established a 20 percent base requirement for a project’s
total affordable housing contribution, with a required distribution across all affordable
income levels; and
4
WHEREAS, the DCP AHPP requirements are designed to ensure the
development of affordable units to be made available across all income levels and to
assist the City in meeting its affordable housing production goals overall; and
WHEREAS, the City now desires to conduct a feasibility study to determine
whether adjustments to the AHPP obligations are appropriate for areas outside of the
City’s Downtown; and
WHEREAS, until that study is completed, the City desires to remove the
extremely low-income category as an option for satisfying affordable housing production
obligations in order to ensure production of affordable housing units at a variety of
affordable income levels and to encourage the overall production of affordable housing
within the City; and
WHEREAS, a significant portion of affordable housing units developed in the City
have historically been constructed by affordable housing providers that have received
financial assistance from the City to develop 100% affordable housing projects; and
W HEREAS, Santa Monica Municipal Code Section 9.64.030 exempts from the
AHPP those 100% affordable housing projects that are developed by nonprofit
affordable housing providers receiving financial assistance through the City’s housing
trust fund programs; and
WHEREAS, as a result of the loss of redevelopment funding in 2012, the City
has been unable to provide the same level of financial assistance to affordable housing
developers to construct 100% affordable housing projects in the City; and
WHEREAS, in order to encourage the development of more 100% affordable
housing projects within the City, the City desires to exempt 100% affordable housing
5
projects that will be owned and operated by affordable housing providers receiving
financial assistance through the California Tax Credit Allocation Committee from the
requirements of the AHPP, subject to certain conditions; and
WHEREAS, the proposed exemption would allow 100% affordable housing
projects to comply with regulations adopted by the California Tax Credit Allocation
Committee, rather than AHPP requirements, except that tenant applications would be
selected from the City’s list of eligible tenants; and
WHEREAS, the proposed amendments to the AHPP are intended to achieve
greater affordability and maintain Santa Monica’s economic diversity; and
WHEREAS, the proposed changes to the AHPP would result in lower rents and
greater accessibility of affordable housing to lower income households; and
WHEREAS, the proposed amendments to the AHPP are consistent with
Proposition R.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA MONICA
DOES HEREBY ORDAIN AS FOLLOWS:
SECTION 1. Santa Monica Municipal Code Section 9.64.030 is hereby amended
to read as follows:
9.64.030 Applicability of chapter.
A. The obligations established by this Chapter shall apply to each
multi-family project involving the construction of two or more multi-family units.
Multi-family projects that, which project has not have received its ministerial or
discretionary planning approvals on or prior to July 26, 2013 shall be subject to
the provisions of Santa Monica Municipal Code Section 9.56.010 et seq., as
6
they existed on the date of their approvals, except that pricing requirements for
affordable housing units shall be published by the City on an annual basis
instead of adoption by resolution of the City Council. For purposes of this
Chapter, ministerial or discretionary planning approvals include, but are not
limited to: plan checks, variances, conditional use permits, administrative
approvals, development review permits, and development agreement
ordinances which have not yet become effective (collectively, "Approvals") on or
before July 26, 2013.
B. No building permit shall be issue d for any multi-family project
unless such project construction has been approved in accordance with the
standards and procedures set forth in provided for by this Chapter.
C. Notwithstanding the above, a multi-family rental housing project
shall be subject to Section 9.64.110 of this Chapter but shall not be subject to
the other requirements of this Chapter if the project is secured by a regulatory
agreement, memorandum of agreement, or recorded covenant with the City
valid for a minimum period of fifty-five years and the project is:
1. A 100% affordable housing project, as defined by Santa
Monica Municipal Code Section 9.52.020.0050, that a multi-family rental
housing project that will be developed by a nonprofit housing provider
receiving financial assistance through one of the City’s housing trust fund
programs shall not be subject to the requirements of this Chapter so long
as the project is an affordable housing project meeting the requirements
of Santa Monica Municipal Code Section 9.52.020 or any successor
7
thereto and the project’s affordability obligations will be secured by a
regulatory agreement, memorandum of agreement, or recorded covenant
with the City for a minimum period of fifty-five years.
2. Additionally, a A multi-family rental housing 100%
affordable housing project, as defined by Santa Monica Municipal Code
Section 9.52.020.0050 that (a) will be developed by a nonprofit housing
provider receiving financial assistance through the California Tax Credit
Allocation Committee; (b) will comply with California Tax Credit Allocation
Committee Regulations as set forth in California Code of Regulations,
Title 4, Sections 10300 and following, including minimum unit size
requirements set forth in Section 4, § 10325(g)(1)(B); and (c) does not
compete in the same category and round of competition to receive
financial assistance through the California Tax Credit Allocation
Committee as a project receiving financial assistance from the City, as
reasonably determined by the City Manager.
B. Multi-family projects which have received Approvals prior to the
effective date of this ordinance shall be subject to the provisions of Santa
Monica Municipal Code Section 9.64.010 et seq., as they existed on the date of
their approvals, except that pricing requirements for affordable housing units
shall be published by the City on an annual basis instead of adoption by
resolution of the City Council.
DC. A designated landmark building or contributing structure to an
adopted Historic District that is retained and preserved on-site as part of a multi-
8
family project shall not be considered or included in assessing any of the
requirements under this Chapter.
SECTION 2. Santa Monica Municipal Code Section 9.64.050 is hereby
amended to read as follows:
9.64.050 On-site option.
The following requirements must be met to satisfy the on -site provisions of
this Chapter:
A. For ownership projects of at least four units but not more than
fifteen units in multi-family residential districts, the multi-family project applicant
agrees to construct at least: (1) twenty percent of the total units as ownership
units for moderate-income households at an Affordable Ownership Hosing Cost,
or as an alternative; (2) twenty percent of the total units as rental units for 80%
income households at affordable rent if these rental units are provided by the
applicant in accordance with Civil Code Sections 1954.52(b) and 1954.53(a)(2);
(3) ten percent of the total units as rental units for 50% income households at
affordable rent if these rental units are provided by the applicant in accordance
with Civil Code Sections 1954.52(b) and 1954.53(a)(2); or (4) for projects with an
application for a ministerial or discretionary planning approval that is determined
complete on or before March 26, 2019, five percent of the total units as rental
units for 30% income households at affordable rent if these rental units are
provided by the applicant in accordance with Civil Code Sections 1954.52(b) and
1954.53(a)(2).
9
B. For ownership projects of sixteen units or more in multi-family
residential districts, the multi-family project applicant agrees to construct at least:
(1) twenty-five percent of the total units as ownership units for moderate -income
households at an Affordable Ownership Housing Cost, or as an alternative; (2)
twenty-five percent of the total units as rental units for 80% income households at
affordable rent if these rental units are provided by the applicant in accordance
with Civil Code Sections 1954.52(b) and 1954.53(a)(2); fifteen perc ent of the total
units as rental units for 50% income households at affordable rent if these rental
units are provided by the applicant in accordance with Civil Code Sections
1954.52(b) and 1954.53(a)(2); or (4) for projects with an application for a
ministerial or discretionary planning approval that is determined complete on or
before March 26, 2019, ten percent of the total units as rental units for 30%
income households at affordable rent if these rental units are provided by the
applicant in accordance with Civil Code Sections 1954.52(b) and 1954.53(a)(2).
C. For all other multi-family applicants, the multi-family project
applicant agrees to construct at least:
1. five percent of the total units of the project for 30% income
households at affordable rent for projects with an application for a
ministerial or discretionary planning approval that is determined complete
on or before March 26, 2019;
2. ten percent of the total units of the project for 50% income
households at affordable rent;
10
3. twenty percent of the total units of the project fo r 80%
income households at affordable rent; or
4. one hundred percent of the total units of a project for
moderate income households at affordable rent.
D. Except as provided in 9.23.030(A), any fractional affordable
housing unit that results from the formulas of this Section that is 0.75 or more
shall be treated as a whole affordable housing unit (i.e., any resulting fraction
shall be rounded up to the next larger integer) and that unit shall also be built
pursuant to the provisions of this Section. Any fractional affordable housing unit
that is less than 0.75 can be satisfied by the payment of an affordable housing
fee for that fractional unit only pursuant to Section 9.64.070(A)(2) or by
constructing all the mandatory on-site affordable units with three or more
bedrooms. The City shall make available a list of income levels for 30% income
households, 50% income households, 80% income households, and moderate
income households, adjusted for household size, the corresponding maximum
affordable rents adjusted by household size appropriate for the unit, and the
minimum number of units required for 30% income households, 50% income
households, or 80% income households required for typical sizes of multi-family
projects, which list shall be updated periodically.
E. The multi-family project applicant may reduce either the size or
interior amenities of the affordable housing units as long as there are not
significant identifiable differences between affordable housing units and market
rate units visible from the exterior of the dwelling units; provided, that all dwelling
11
units conform to the requirements of the applicable Building and Housing Codes.
However, except as provided in Section 9.23.030(A), each affordable housing
unit provided shall have at least two bedrooms unless:
1. The proposed project comprises at least ninety-five percent
one bedroom units, excluding the manager’s unit, in which case the
affordable housing units may be one bedroom;
2. The proposed project comprises at least ninety-five percent
zero bedroom units, excluding the manager’s unit, in which case the
affordable housing units may be zero bedroom units;
3. The proposed project comprises zero and one bedroom
units, excluding the manager’s unit, in which case the affordable housing
units must be at least one bedroom units; or
4. The multi-family project applicant has elected not to pay the
affordable housing fee pursuant to Section 9.64.070(A)(2), in which case
the affordable housing units must be at least three bedroom units. The
design of the affordable housing units shall be reasonably consistent with
the market rate units in the project. An affordable housing unit shall have a
minimum total floor area, depending upon the number of bedrooms
provided, no less than the following:
12
0 bedrooms 500 square feet 1 occupant
1 bedroom 600 square feet 1 occupant
2 bedroom 850 square feet 2 occupants
3 bedrooms 1,800 square feet 3 occupants
4 bedrooms 1,200 square feet 5 occupants
Affordable housing units in multi-family projects of one hundred units or
more must be evenly disbursed throughout the multi-family project to prevent
undue concentrations of affordable housing units.
F. All affordable housing units in a multi-family project or a phase of a
multi-family project shall be constructed concurrently with the construction of
market rate units in the multi-family project or phase of that project.
G. On-site affordable housing units must be rental units in rental
projects. In ownership projects, these affordable housing units may be either
rental units or ownership units.
H. Each multi-family project applicant, or his or her successor, shall
submit an annual report to the City identifying wh ich units are affordable units,
the monthly rent (or total housing cost if an ownership unit), vacancy information
for each affordable unit for the prior year, verification of income of the household
occupying each affordable unit throughout the prior year, and such other
information as may be required by City staff.
I. A multi-family project applicant in a residential district who meets
the requirements of this Section shall be entitled to the density bonuses and
13
incentives provided by Sections 9.22.030 or any successor thereto and the
waiver/modification of development standards provided by Section 9.22.040 or
any successor thereto. A multi-family project applicant in a commercial or
industrial district shall be entitled to the development bonuses and incentives
provided in the Land Use and Circulation Element and implementing ordinances.
J. All residential developments providing affordable housing on -site
pursuant to the provisions of this Section shall receive priority building
department plan check processing by which housing developments shall have
plan check review in advance of other pending developments to the extent
authorized by law.
K. The City Council may by resolution establish compliance monitoring
fees which reflect the reasonable regulatory cost to the City of ensuring
compliance with this Section when affordable housing units are being initially
rented or sold, when the required annual reports are submitted to the City, and
when the units are being re-sold or re-leased.
SECTION 3. Any provision of the Municipal Code or appendices thereto
inconsistent with the provisions of this Ordinance, to the extent of such
inconsistencies and no further, is hereby repealed or modified to that extent
necessary to effect the provisions of this Ordinance.
SECTION 4. If any section, subsection, sentence, clause or phrase of this
Ordinance is for any reason held to be invalid or unconstitutional by a decision of any
court of competent jurisdiction, such decision shall not aff ect the validity of the
remaining portions of this Ordinance. The City Council hereby declares that it would
14
have passed this Ordinance and each and every section, subsection, sentence, clause,
or phrase not declared invalid or unconstitutional without reg ard to whether any portion
of the ordinance would be subsequently declared invalid or unconstitutional.
SECTION 5. The Mayor shall sign and the City Clerk shall attest to the passage
of this Ordinance. The City Clerk shall cause the same to be published on ce in the
official newspaper within 15 days after its adoption. This Ordinance shall become
effective 30 days from its adoption.
APPROVED AS TO FORM:
_______________________
LANE DILG
City Attorney
14
ATTACHMENT B: DEVELOPMENTS COMPLETED
Address Total Ex-Low
- 30
V-Low
- 50
Low -
80
Mod -
120 Market Completed
Year
914 5th St 4 4 2014
947 4th St 5 5 2014
2640 Lincoln Blvd. 2 2 2014
214 Santa Monica Blvd. 38 4 34 2014
1127 Princeton St 3 3 2014
1959 High Place [HPE] [2401 44 5 39 2014
1754 19th St 49 5 42 2 2014
612 Lincoln Blvd 4 4 2014
1317 7th St 57 6 51 2014
1755 Ocean Avenue 93 93 2014
1725 Ocean Avenue 160 58 47 53 2 2014
1705 Ocean Avenue 65 65 2014
829 Broadway [Phase II] 19 3 16 0 2014
1548 6th St 4 1 3 2014
1253 17th St 4 4 2014
713 Ashland 2 2 2015
1837 12th Street 8 8 2015
908 5th St 3 3 2015
702 Arizona Ave 49 5 44 2015
1919 4th St 3 3 2015
2438 Ocean Park Blvd 2 2 2015
1959 20th Street 2 2 2015
943 16th St 5 1 4 2015
1834 Euclid Street 2 2 2015
520 Colorado 34 12 20 2 2015
1319 Yale St 6 1 5 2016
1171 Franklin St 6 1 5 2016
525 Broadway 122 122 2016
1012 2nd St 4 4 2016
1318 2nd St 53 5 5 43 2016
2316 3rd St 3 3 2016
1347 19th St 3 3 2016
1236 25th St 3 3 2017
1433 18th St 6 1 5 2017
1433 14th St 19 19 2017
3214 Highland 6 1 5 2017
1455 4th St 2 2 2017
1750 10th St 7 1 6 2018
1211 9th St 5 1 4 2018
1803-1807 16th St 10 10 2018
1038 Bay St 2 2 2018
2919 Lincoln Blvd 10 1 9 2018
954 5th St 3 3 2018
1626 Lincoln Blvd. 64 7 39 18 0 2018
1329 California Ave 3 3 2018
1136 18th St 3 3 2018
Total: 46 Projects 1001 87 170 125 20 599
15
ATTACHMENT C: DEVELOPMENTS IN CONSTRUCTION
Address Total
Ex-
Low -
30
V-
Low -
50
Low
- 80
Mod -
120 Market Planning
Approval
Bldg
Permit
1621 Franklin St 4 1 3 2011 2013
2930 Colorado (VTP) 356 3 35 318 2013 2015
2913 10th St 3 3 2013 2016
2300 Wilshire Blvd 30 30 2014 2016
1423 Franklin St. 3 3 2016 2016
3008 Santa Monica Blvd. 24 2 22 2018 2016
1807 17th St 6 1 5 2007 2017
1444 11th St 8 2 6 2008 2017
2323 28th St 8 1 7 2009 2017
1533 11th St 5 1 4 2012 2017
1112 Pico Blvd 32 4 28 2014 2017
1541 Franklin 5 1 4 2014 2017
723 Pier Ave 2 2 2015 2017
1927 18th St 3 3 2015 2017
1025 Euclid St. 5 5 2006 2018
1601 Lincoln Blvd 90 14 4 1 71 2015 2018
1560 Lincoln Blvd 100 15 5 80 2015 2018
1014 Bay St 3 3 2016 2018
1641 Lincoln Blvd. 66 5 61 2016 2018
212 Bay St. 3 3 2016 2018
436 Pier Ave 3 3 2017 2018
Total: 21 Projects 759 10 68 10 7 664
16
ATTACHMENT D: DEVELOPMENTS WITH PLANNING APPROVAL
Address Total
Ex-
Low
- 30
V-
Low
- 50
Low
- 80
Mod
- 120 Market Planning
Approval
1041 17th St 8 8 2008
1703 Ocean Front Walk 6 1 5 2009
1518 11th St 6 1 5 2011
919 Broadway 2 2 2014
1211 12th St 13 4 9 2016
1840 17th St. 5 1 4 2016
1927 19th St 3 3 2016
1949 17th St 5 1 4 2016
2102 5th St. 3 3 2016
500 Broadway (offsite 1626 Lincoln) 249 249 2016
2512 7th St 3 3 2016
1035 21st St 3 3 2017
1121 22nd St 3 3 2017
1216 Arizona Ave 2 2 2017
122 Strand St 3 3 2017
1325 6th St 64 64 2017
1430 Lincoln Blvd 100 100 2017
1613-37 Lincoln Blvd. 191 15 176 2017
1754 10th St 3 3 2017
2219 Virginia Ave 3 3 2017
2901 Santa Monica Blvd 51 5 46 2017
423 Ocean Ave. [aka 429] 12 2 10 2017
601 Wilshire Blvd 40 5 35 2017
2215 5th St 2 2 2017
1437 Lincoln Blvd 40 6 34 2018
2903 Lincoln Blvd. 47 4 43 2018
2225 Broadway 16 2 14 2018
1450 Cloverfield Blvd. 34 3 31 2018
1318 Lincoln Blvd. 43 4 39 2018
1650 Lincoln Blvd 100 8 92 2018
401 Ocean Ave 5 5 2018
1342 Berkeley St 8 8 0 2018
1443 18th St 12 12 2018
1824 14th St 39 4 20 15 0 2018
234 Pico Blvd 105 8 97 2018
2822 Santa Monica Blvd 50 4 46 2018
1828 Ocean Ave 83 12 71 2018
1921 Ocean Front Walk 22 22 2018
Total: 38 Projects 1384 60 52 19 2 1251
17
ATTACHMENT E: PENDING DEVELOPMENTS
Address Total Market Affordable % Affordable
1514 7th St 50 0 50 100%
711 Colorado 56 0 56 100%
1235 5th St 23 18 5 22%
1543 7th St 100 100 0 0%
601 Colorado Ave 140 140 0 0%
1425 5th St 92 92 0 0%
1323 5th St 41 39 2 5%
1437 7th St 65 52 13 20%
501 Broadway 94 60 34 36%
525 Colorado Ave 40 28 12 30%
1338 5th St 96 91 5 5%
1427 Lincoln Blvd 15 12 3 20%
1557 7th St 40 38 2 5%
1437 6th St 41 39 2 5%
1238 7th St 37 0 37 100%
2906 Santa Monica Blvd 44 40 4 9%
3223 Wilshire Blvd 53 49 4 8%
1618 Stanford 50 46 4 8%
1445‐1453 10th St 40 0 40 100%
1301 4th St 48 0 48 100%
101 Santa Monica Blvd 79 61 18 23%
1437 5th St 41 39 2 5%
1415 5th St 102 97 5 5%
2020 Virginia Ave 21 19 2 10%
18
1665 Appian Way 3 3 0 0%
3030 Nebraska Ave 177 164 13 7%
1707 Cloverfield Blvd 63 58 5 8%
Total: 27 Projects 1,651 1,285 366 22%
14
ATTACHMENT B: DEVELOPMENTS COMPLETED
Address Total Ex-Low
- 30
V-Low
- 50
Low -
80
Mod -
120 Market Completed
Year
914 5th St 4 4 2014
947 4th St 5 5 2014
2640 Lincoln Blvd. 2 2 2014
214 Santa Monica Blvd. 38 4 34 2014
1127 Princeton St 3 3 2014
1959 High Place [HPE] [2401 44 5 39 2014
1754 19th St 49 5 42 2 2014
612 Lincoln Blvd 4 4 2014
1317 7th St 57 6 51 2014
1755 Ocean Avenue 93 93 2014
1725 Ocean Avenue 160 58 47 53 2 2014
1705 Ocean Avenue 65 65 2014
829 Broadway [Phase II] 19 3 16 0 2014
1548 6th St 4 1 3 2014
1253 17th St 4 4 2014
713 Ashland 2 2 2015
1837 12th Street 8 8 2015
908 5th St 3 3 2015
702 Arizona Ave 49 5 44 2015
1919 4th St 3 3 2015
2438 Ocean Park Blvd 2 2 2015
1959 20th Street 2 2 2015
943 16th St 5 1 4 2015
1834 Euclid Street 2 2 2015
520 Colorado 34 12 20 2 2015
1319 Yale St 6 1 5 2016
1171 Franklin St 6 1 5 2016
525 Broadway 122 122 2016
1012 2nd St 4 4 2016
1318 2nd St 53 5 5 43 2016
2316 3rd St 3 3 2016
1347 19th St 3 3 2016
1236 25th St 3 3 2017
1433 18th St 6 1 5 2017
1433 14th St 19 19 2017
3214 Highland 6 1 5 2017
1455 4th St 2 2 2017
1750 10th St 7 1 6 2018
1211 9th St 5 1 4 2018
1803-1807 16th St 10 10 2018
1038 Bay St 2 2 2018
2919 Lincoln Blvd 10 1 9 2018
954 5th St 3 3 2018
1626 Lincoln Blvd. 64 7 39 18 0 2018
1329 California Ave 3 3 2018
1136 18th St 3 3 2018
Total: 46 Projects 1001 87 170 125 20 599
15
ATTACHMENT C: DEVELOPMENTS IN CONSTRUCTION
Address Total
Ex-
Low -
30
V-
Low -
50
Low
- 80
Mod -
120 Market Planning
Approval
Bldg
Permit
1621 Franklin St 4 1 3 2011 2013
2930 Colorado (VTP) 356 3 35 318 2013 2015
2913 10th St 3 3 2013 2016
2300 Wilshire Blvd 30 30 2014 2016
1423 Franklin St. 3 3 2016 2016
3008 Santa Monica Blvd. 24 2 22 2018 2016
1807 17th St 6 1 5 2007 2017
1444 11th St 8 2 6 2008 2017
2323 28th St 8 1 7 2009 2017
1533 11th St 5 1 4 2012 2017
1112 Pico Blvd 32 4 28 2014 2017
1541 Franklin 5 1 4 2014 2017
723 Pier Ave 2 2 2015 2017
1927 18th St 3 3 2015 2017
1025 Euclid St. 5 5 2006 2018
1601 Lincoln Blvd 90 14 4 1 71 2015 2018
1560 Lincoln Blvd 100 15 5 80 2015 2018
1014 Bay St 3 3 2016 2018
1641 Lincoln Blvd. 66 5 61 2016 2018
212 Bay St. 3 3 2016 2018
436 Pier Ave 3 3 2017 2018
Total: 21 Projects 759 10 68 10 7 664
16
ATTACHMENT D: DEVELOPMENTS WITH PLANNING APPROVAL
Address Total
Ex-
Low
- 30
V-
Low
- 50
Low
- 80
Mod
- 120 Market Planning
Approval
1041 17th St 8 8 2008
1703 Ocean Front Walk 6 1 5 2009
1518 11th St 6 1 5 2011
919 Broadway 2 2 2014
1211 12th St 13 4 9 2016
1840 17th St. 5 1 4 2016
1927 19th St 3 3 2016
1949 17th St 5 1 4 2016
2102 5th St. 3 3 2016
500 Broadway (offsite 1626 Lincoln) 249 249 2016
2512 7th St 3 3 2016
1035 21st St 3 3 2017
1121 22nd St 3 3 2017
1216 Arizona Ave 2 2 2017
122 Strand St 3 3 2017
1325 6th St 64 64 2017
1430 Lincoln Blvd 100 100 2017
1613-37 Lincoln Blvd. 191 15 176 2017
1754 10th St 3 3 2017
2219 Virginia Ave 3 3 2017
2901 Santa Monica Blvd 51 5 46 2017
423 Ocean Ave. [aka 429] 12 2 10 2017
601 Wilshire Blvd 40 5 35 2017
2215 5th St 2 2 2017
1437 Lincoln Blvd 40 6 34 2018
2903 Lincoln Blvd. 47 4 43 2018
2225 Broadway 16 2 14 2018
1450 Cloverfield Blvd. 34 3 31 2018
1318 Lincoln Blvd. 43 4 39 2018
1650 Lincoln Blvd 100 8 92 2018
401 Ocean Ave 5 5 2018
1342 Berkeley St 8 8 0 2018
1443 18th St 12 12 2018
1824 14th St 39 4 20 15 0 2018
234 Pico Blvd 105 8 97 2018
2822 Santa Monica Blvd 50 4 46 2018
1828 Ocean Ave 83 12 71 2018
1921 Ocean Front Walk 22 22 2018
Total: 38 Projects 1384 60 52 19 2 1251
17
ATTACHMENT E: PENDING DEVELOPMENTS
Address Total Market Affordable % Affordable
1514 7th St 50 0 50 100%
711 Colorado 56 0 56 100%
1235 5th St 23 18 5 22%
1543 7th St 100 100 0 0%
601 Colorado Ave 140 140 0 0%
1425 5th St 92 92 0 0%
1323 5th St 41 39 2 5%
1437 7th St 65 52 13 20%
501 Broadway 94 60 34 36%
525 Colorado Ave 40 28 12 30%
1338 5th St 96 91 5 5%
1427 Lincoln Blvd 15 12 3 20%
1557 7th St 40 38 2 5%
1437 6th St 41 39 2 5%
1238 7th St 37 0 37 100%
2906 Santa Monica Blvd 44 40 4 9%
3223 Wilshire Blvd 53 49 4 8%
1618 Stanford 50 46 4 8%
1445‐1453 10th St 40 0 40 100%
1301 4th St 48 0 48 100%
101 Santa Monica Blvd 79 61 18 23%
1437 5th St 41 39 2 5%
1415 5th St 102 97 5 5%
2020 Virginia Ave 21 19 2 10%
18
1665 Appian Way 3 3 0 0%
3030 Nebraska Ave 177 164 13 7%
1707 Cloverfield Blvd 63 58 5 8%
Total: 27 Projects 1,651 1,285 366 22%
19
ATTACHMENT F: SCAG REGIONAL HOUSING NEEDS ASSESSMENT PROGRESS
RHNA
Quantified
Objective
Completed
and In
Construction
Needed
for
RHNA
Needed
for
Quantified
Objective
Approved
(not In
Construction)
Extremely Low
(0-30% AMI)
428
83 97
93
(14) 60
Very Low (31-
50% AMI) 214 238 (24) 52
Low (51-80%
AMI) 263 263 135 128 128 19
Moderate (81-
120% AMI) 283 111 27 256 84 2
Above
Moderate
(>120% AMI)
700 700 1,263 (563) (563) 1,251
Totals 1,674 1,371 1,760
1
Vernice Hankins
From:Fred Alexander <riverfred1@gmail.com>
Sent:Saturday, March 23, 2019 9:09 AM
To:councilmtgitems
Subject:Community
Dear Council,
In regards to affordable housing, you do not get much bang for your buck in SM, that is why people commute. With the
train system leading to SM people can live outside of SM and easily commute with low fares. Please use the funds for
affordable housing for more practical purposes.
In regards to the homeless, I suggest the council study other beach cities that do not have the problem SM has such as:
Dana Point, Redondo Beach, Manhattan Beach, Seal Beach, Hermosa Beach, Huntington Beach, Newport Beach, etc.
Obviously these beach communities are not attracting the homeless and destroying the quality of life of their residents.
Fred Alexander
Long time concerned resident
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Vernice Hankins
From:Hank Koning <hkoning@kearch.com>
Sent:Monday, March 25, 2019 10:00 AM
To:councilmtgitems
Subject:Agenda Item 7B: Zoning Code change - an opportunity to create more affordable
housing
Mayor, City Council Members,
I am writing to support the proposed revisions to the Zoning Code as supported by CCSM and Amy Anderson
towards creating more options for the production of affordable housing in Santa Monica.
As a resident of and business owner in Santa Monica for 38 years I appreciate the need for more housing, and
particularly affordable housing, in this fine City. And as an Architect involved in both market rate and
affordable housing I understand the need to have flexibility in how this is produce.
Kind Regards
Hank Koning
Hank Koning FAIA FRAIA LEED A.P. Founding Principal
KoningEizenberg | 1454 25th Street, Santa Monica, CA 90404
310 828 6131 x111 www.kearch.com
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March 26, 2019
Santa Monica City Council
1685 Main Street
Santa Monica, CA 90405
RE: ITEM 7B: ELIMINATION OF THE EXTREMELY LOW INCOME HOUSING OPTION
FROM THE AHPP
Dear Mayor Davis and Councilmembers:
I would first like to thank you for referring the proposed Interim Zoning Ordinance calling for the
elimination of the Extremely Low Income (ELI) option from the Affordable Housing Production
Program (AHPP) to the Planning Commission for discussion. I would also like to acknowledge City
staff, who prepared an excellent staff report and presentation for us. We had a robust discussion
of this issue at our February 20, 2019 meeting and deadlocked, 3 to 3, on whether to support or
reject this proposal.
The Planning Commission discussed what we were told was to be an Interim Ordinance, which
would be in place until the final adoption of AHPP changes, if any, which may be based on the
findings of the feasibility study. However, the draft Ordinance before you on March 26 seems to
be a permanent one with no reference to “Interim” or a sunset date. I would appreciate
clarification of this.
Although I am writing this as an individual, not as a representative of Planning Commission, I
would like to share with you the discussion points which were raised at the meeting. Those
opposing elimination of the ELI option did so after pointing out the following reasons for
supporting their objections. (The language in italics has been added by me and was not brought
up at the Planning Commission meeting.)
The ELI option provides housing opportunities for the very lowest income among us and is
therefore a safety net for preventing homelessness. Given the City’s strong commitment to
addressing the needs of the homeless, eliminating the ELI makes no sense. The definition of
extremely low income for a family of four is an annual income that does not exceed $29,050. For
an individual, the annual income limit is set at $20,050.
Eliminating the ELI option has no impact on the City’s meeting its Regional Housing Needs
Allocation (RHNA) goals since the RHNA does not include an Extremely Low Income housing
goal. Instead, the RHNA prescribes a housing goal for Very Low Income units, which includes the
ELI units produced. The City Housing Element does include a goal for ELI households, but
achievement of this goal is not considered by the State when evaluating our compliance with the
RHNA. The State bunches our ELI units with Very Low Income units when assessing the City’s
assessing its performance.
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The major vehicle for compliance with the production requirements of Measure R was never
thought to be inclusionary units produced under the AHPP. Instead, the 100% affordable
housing projects developed and owned by CCSM and other nonprofits were always considered
to be the vehicle for compliance. Historically, more than 60% of the units produced in compliance
with Measure R have been in 100% affordable projects. With the death of redevelopment and
the loss of those housing funds, the City has experienced a slowdown in the production of 100%
affordable projects. However, that is changing with investment in the Housing Trust Fund and
the development of AHPP off-site projects. We therefore expect to see an increase in the
percentage of nonprofits’ contribution to Measure R compliance. (According to its Executive
Director, CCSM has two projects that will begin construction in 2019 and five more projects in the
predevelopment pipeline. This point was overlooked, I believe, in staff’s recommendation to
eliminate the ELI option. Before reacting to the apparent over reliance on the ELI option, the
Council should ask for an income level breakdown of these CCSM projects. The alarm over
Measure R compliance may be an overreaction.)
Revising the AHPP on a piecemeal basis is not prudent policy making. Instead, the Council
should await the findings of the feasibility study and revise the AHPP based on those findings and
public input.
There is no current analysis proving the feasibility of AHPP requirements other than ELI units
for Tier 2 projects. If a developer chooses an option other than ELI units for a Tier 2 mixed income
project, that project must include 15% of the units for Very Low Income households, or 30% of
the units for Low Income households. We do not know if these requirements work. The only
feasibility test ever done was in 2014, and it only looked at Very Low Income inclusionary units.
The analysis was limited to one Tier 2 prototype project in downtown using the Very Low Income
option. One cannot consider this limited 5-year old analysis to be applicable Citywide. It is also
no longer valid since construction costs have risen 30-40% since then.
The Commissioners in favor of removal of the ELI option were of the belief that developers are
opting for the ELI choice because it means more profit for them. They may be right, but no one
knows for sure. We are all frustrated with mixed income projects coming before us with the
minimum number of inclusionary units allowable. The point is that no one knows whether the
inclusion of units other than ELI units is feasible. And, until we do, we should not be tinkering
with the AHPP requirements.
Thank you for your consideration and for your commitment to affordable housing in Santa
Monica.
Respectfully,
Leslie Lambert, Sunset Park Resident
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Vernice Hankins
From:Soloff, Michael <Mike.Soloff@mto.com>
Sent:Monday, March 25, 2019 5:28 PM
To:councilmtgitems
Cc:Gleam Davis; Terry O’Day; Councilmember Kevin McKeown; Ted Winterer; Sue
Himmelrich; Greg Morena; Ana Maria Jara
Subject:Agenda Item 7B (Mar. 26, 2019) -- Temporary Removal from AHPP of Extremely Low
income Option
Attachments:Chair Soloff Report to SMHC re Extremely Low income Option.pdf; PERSONAL VIEW OF
MICHAEL SOLOFF REGARDING INITIAL HTF PLAN (ITEM 8.D).pdf
To the Honorable Members of the Santa Monica City Council:
One topic covered under your Agenda item 7B is whether to amend the Affordable Housing Production
Program to temporarily eliminate the extremely low income option. I write first to provide additional
information regarding the Housing Commission’s deliberations regarding this issue, and then to share
some additional personal views.
Housing Commission Deliberations
I attach for your reference the Report that I presented to the Housing Commission at its November 15,
2018 meeting when we first discussed the issue (as well as my prior report referenced therein). In that
Report I demonstrate that (1) the City will not achieve compliance with Proposition R during the 2013-
2021 Housing Element, (2) the existing extremely low income option—which requires just half the
number of affordable units as the next lowest income option—incentives for-profit developers to select
this option when it is available (i.e., a Tier 1 or Tier 2 project outside the current Downtown
Community Plan), (3) selection of this option—which provides at most 8% affordable units in a
project—imposes a large burden on the City to use its own limited funds to create enough affordable
units to meet Proposition R, and (4) no plan yet existed to conduct the feasibility study needed to revise
the AHPP outside of the Downtown as directed by City Council as part of the Housing Trust Fund Plan
adopted in July 2018. This is the same Report you received (among other items) in connection with
Item 13.G on your December 18, 2018 agenda.
Prior to its February 21, 2019 meeting, the Santa Monica Housing Commission also received the staff
report on this issue provided to the Planning Commission. After further discussion, the Housing
Commission passed the following resolution by a vote of 6 ayes, 0 noes, and 1 abstain:
Motion by Chair Soloff, seconded by Commissioner Katz to recommend that City Council (1) adopt an
interim zoning ordinance temporarily suspending the extremely low income option in the Affordable
Housing Production Program outside of the Downtown, (2) direct the expedited preparation of an
economic feasibility study of the Affordable Housing Production Program outside of the Downtown,
and (3) direct that the results of that study be brought before the Planning Commission and the Housing
Commission for their deliberations and recommendations about permanent solutions.
Additional Personal Views
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Voter approved Proposition R provides that “The City Council by ordinance shall at all times
require that not less than thirty percent (30%) of all multifamily-residential housing newly constructed
in the City on an annual basis is permanently affordable to and occupied by low and moderate income
households.” The City will not comply with Proposition R over the eight years of the current Housing
Element. .
The AHPP is a critical component of the Council’s efforts to comply with Proposition R In July 2017
the Council—using data from an HR&A feasibility analysis, and recommendations from staff, the
Planning Commission, and the Housing Commission—developed and adopted a new approach to the
AHPP for the Downtown that is designed to better serve the requirements of Proposition R and the
City’s other affordable housing goals. Both at that time, and a year later, the Housing Commission
recommended that Council direct a similar feasibility analysis outside of the Downtown so that that
portion of the AHPP likewise could be changed to better align with Proposition R and the City’s other
affordable housing goals. The Council adopted that recommendation in July of 2018 as a part of the
initial Housing Trust Fund Plan for the 2013-2021 Housing element period. Only now is there an
effort to contract for that feasibility study.
In the meantime, every additional project that utilizes the extremely low income option makes it that
much more difficult for the City to catch up, and/or will make it more difficult to meet Proposition R’s
requirements over course of the next eight year Housing Element. As the old adage states, the best way
out of a hole is to stop digging. I therefore join my fellow Housing Commissioners in urging the
temporary suspension of the extremely low income option outside the Downtown, an expedited
feasibility study, and deliberation by staff, the Planning Commission, the Housing Commission and
ultimately the Council on an improved design for the AHPP outside of the Downtown.
In that regard, I object to the apparent recommendation of staff (not presented to the Housing
Commission) that any project with a completed application as of March 26, 2019, be permitted to
continue to use the extremely low income option. Given that the existing text of the AHPP provides
that only projects with “Approvals” prior to the effective date of a prior revision to the AHPP do not
have to comply with the new requirements, there does not appear to be any legal requirement to adopt
staff’s proposal (although I claim no expertise on that legal issue). Nor is there an equitable
requirement to do so. For-profit developers earn large returns precisely because they take risk,
including entitlement risk. Moreover, since July of 2018, developers have had notice that City Council
had directed a new AHPP feasibility study outside of the Downtown, with an eye toward revising the
AHPP. And as of December 18, 2018, developers knew that Council had directed preparation of an
ordinance to suspend the extremely low income option. Given all of these circumstances, the voters
who passed Proposition R, and the taxpayers and residents who money goes to fund affordable
housing, properly will want to know why staff—and if adopted, why the City Council—believes it is
necessary or proper to make Proposition R’s mandate harder and more expensive to reach by
grandfathering any project with an application completed as of March 26, 2019.
Michael E. Soloff | Munger, Tolles & Olson LLP
350 South Grand Avenue | Los Angeles, CA 90071
Tel: 213.683.9159 | Fax: 213.683.5159 | mike.soloff@mto.com | www.mto.com
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To: Santa Monica Housing Commission
From: Chair Michael Soloff
Re: Item 4C on Agenda for November 15, 2018 Meeting
I. EXECUTIVE SUMMARY
While it is projected that the City will meet or exceed all of its other housing production goals
during the 2013-2021 Housing Element cycle, it is projected that only 25% of all new housing
completed during that time period will be affordable housing, rather than 30% as mandated by
Proposition R. While the lack of an HTF funding source for the first half of that time period
undoubtedly played a role, so too did the over-incentivization in the Affordable Housing
Production Program for developers to choose to provide a very small number of extremely low
income units in complete satisfaction of their inclusionary housing obligations.
The City Council remedied this issue in the Downtown Community Plan in July of 2017 based
on the HRA feasibility analysis. The Housing Commission recommended in 2017 that a review
take place of the AHPP outside the Downtown Community Plan, and the Housing Commission
recommended in 2018 that the City Council put into the initial HTF plan a direction to Staff to
do so as soon as possible. While the City Council adopted this recommendation, Staff advises
that Planning Staff is necessary to the process of obtaining the feasibility study essential to any
such review, and that Planning Staff reports it is fully engaged on other matters that City Council
prioritized over the AHPP review outside of the downtown.
The 105 unit Tier 2 project on Pico Boulevard considered for a Development Review Permit by
the Planning Commission at its November 7, 2018 meeting illustrates that the AHPP
requirements outside of the Downtown Community Plan continue to undermine City efforts to
meet Proposition R’s Charter mandate. By providing only 8 extremely low income affordable
units, that project imposes on the City the obligation to produce 34 new affordable housing units
just to meet the Proposition R mandate created by this one project.
The Housing Commission should discuss what, if anything, can and should be done in light of
these realities. Possibilities include (1) asking Council to preclude the extremely low income
option outside the downtown until a feasibility study can be conducted and/or (2) urging the City
Council to direct that a higher priority be placed on obtaining and acting upon such a feasibility
study.
II. BACKGROUND
A. The City’s Affordable Housing Production Program
1. The AHPP In Areas Outside The Areas Governed By The Downtown
Community Plan
In 1990 the voters of Santa Monica passed Proposition R, which amended the City Charter to
add the following provision:
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The City Council by ordinance shall at all times require that not less than thirty
percent (30%) of all multifamily-residential housing newly constructed in the City
on an annual basis is permanently affordable to and occupied by low and
moderate income households. For purposes of this Section, “low income
household” means a household with an income not exceeding sixty percent (60%)
of the Los Angeles County median income, adjusted by family size, as published
from time to time by the United States Department of Housing and Urban
Development, and “moderate income household” means a household with an
income not exceeding one hundred percent (100%) of the Los Angeles County
median income, adjusted by family size, as published from time to time by the
United States Department of Housing and Urban Development. At least fifty
percent (50%) of the newly constructed units required to be permanently
affordable by this Section shall be affordable to and occupied by low income
households.
Santa Monica City Charter Section 630.
Pursuant to this voter mandate, the City Council subsequently adopted an Affordable Housing
Production Program (“the AHPP”). As relevant to this Agenda Item, the AHPP currently
provides for Tier 2 projects located outside the boundaries of the area governed by the
Downtown Community Plan:
All Tier 2 projects must meet the following requirements:
1. Affordable Housing. Applicants proposing residential and mixed-use
projects shall incorporate the following:
a. At least 50 percent more affordable housing units than would be
required pursuant to Section 9.64.050.1 Any fractional affordable
1 Section 9.64.050(C) provides (bolding added):
C. For all other multi-family applicants, the multi-family project applicant
agrees to construct at least:
1. five percent of the total units of the project for 30% income
households at affordable rent;
2. ten percent of the total units of the project for 50% income
households at affordable rent;
3. twenty percent of the total units of the project for 80% income
households at affordable rent; or
4. one hundred percent of the total units of a project for moderate
income households at affordable rent.
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housing unit that results from this formula shall be provided as a whole
affordable housing unit (i.e., any resulting fraction shall be rounded up to
the next larger integer).
b. On-site affordable housing units shall be affordable to 30%, 50%,
or 80% income households depending on the percentage of affordable
units being provided and shall not include any Moderate Income units,
as defined by Section 9.64.020. Subject to the modifications contained in
this Subsection (A), all of the affordable units shall comply with the
provisions of Chapter 9.64.
c. Affordable housing units required by this Subsection (A) may be
provided offsite, pursuant to Section 9.64.060 2, if the affordable
housing units are owned in whole or part and operated by a non-
profit housing provider for the life of the project, and the Final
Construction Permit Sign Off or Certificate of Occupancy for the
affordable units is issued prior to or concurrently with the Tier 2
project.
2. Unit Mix. Applicants proposing residential and mixed-use projects shall
incorporate the following:
a. For market rate units:
i. At least 15% of the units shall be three-bedroom units;
ii. At least 20% of the units shall be two-bedroom units;
iii. No more than 15% of the units shall be studio units;
iv. The average number of bedrooms for all of the market rate
units combined shall be 1.2 or greater; and
v. Notwithstanding Subsections (A)(2)(a)(i-ii) above, any
fractional housing unit less than 0.5 that results from this unit mix
shall be rounded down to the next lower integer. Any fractional
housing unit of 0.5 or more that results from this unit mix shall be
rounded up to the next larger integer.
b. For affordable housing units:
2 Section 9.64.060(B) provides (bolding added):
B. For all other multi-family project applicants, the applicant shall agree to
construct the same number of affordable housing units as specified in Section
9.64.050(C).
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i. The average number of bedrooms for all of the affordable
housing units combined shall be equal to or greater than the
average number of bedrooms provided for all of the market rate
units pursuant to Subsection (A)(2)(a) of this Section.
c. The Director may grant a waiver from this unit mix requirement
pursuant to the requirements and procedures for Waivers in Chapter 9.43.
d. The requirements of Subsection (A)(2) of this Section shall not apply
to project applications filed prior to the effective date of this Ordinance.
Santa Monica Municipal Code §§ 9.23.030(C)(1)-(2) (bolding added).
2. AHPP Requirements In The Downtown Community Plan
With the adoption of the Downtown Community Plan in the summer of 2017, AHPP
requirements for projects in the areas governed by that plan are as follows (emphases in
original):
Housing and Mixed-Use Residential Projects Qualifying Benefits. An applicant
seeking approval for a housing or mixed-use residential project that exceeds the base floor
area ratio or height allowed in the district where the project is located shall provide
community benefits in each of the following categories.
1. Housing. All Tier 2 projects and Tier 3 projects less than 75,000 square feet must
meet the following requirements:
a. Affordable Housing. Subject to the modifications contained in this Section,
all of the affordable units shall comply with the provisions of Chapter 9.64. As set
forth in Table 9.10.070.A, applicants proposing residential and mixed-use projects
shall incorporate the following:
i. A percentage of the total number of units in the project, corresponding
with the height or FAR of the project, shall be deed-restricted as on-site
affordable housing units. Any fractional affordable housing unit that results
from this formula shall be provided as a whole affordable housing unit (i.e.,
any resulting fraction shall be rounded up to be the next larger integer).
Table 9.10.070.A: On-Site and Off-Site Affordable Housing Requirements
Height
(Feet)
On-Site
Affordable
Housing
%
Off-Site Affordable
Housing %
On-Site Affordable
Housing % for
Development
Agreements and
Planning
Applications
Complete on or
before 11/11/16
Off-Site Affordable
Housing % for
Development
Agreements and
Planning
Applications
Complete on or
before 11/11/16
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40-50 20% 25% 20% 25%
52 21% 26% 20% 25%
54 22% 27% 20% 25%
56 23% 28% 20% 25%
58 24% 29% 20% 25%
60 25% 30% 20% 25%
62 26% 31% 20% 25%
64 27% 32% 20% 25%
66 28% 33% 20% 25%
68 29% 34% 20% 25%
70-84 30% 35% 20% 25%
ii. Affordable housing units may be provided off site pursuant to
Section 9.64.060 except that the total number of affordable housing units
shall be increased to the percentage of the total number of units in the project
as set forth in Table 9.10.070.A,. The off-site affordable housing units shall
meet the following conditions:
(1) The affordable housing units are owned in whole or part and
operated by a non-profit housing provider for the life of the project;
(2) The final construction permit sign off or certificate of occupancy
for the affordable units is issued prior to or concurrently with the Tier 2
or qualifying Tier 3 project; and
(3) The location of the off-site location shall be within the boundaries
of the Downtown or within a one-quarter mile radius of the market rate
units.
iii. The total number of affordable housing units shall incorporate the
affordability mix specified in Table 9.10.070.B. Any fractional affordable
housing units that result from the percentage mix of total affordable housing
units shall be aggregated into whole affordable housing units (i.e., any
resulting fraction shall be added to other resulting fractions). The resulting
whole units may be provided at 30%, 50%, 80%, or moderate-income
household affordability levels.
Table 9.10.070.B. Affordability
Affordability Level Affordability Mix of Total Number of
Affordable Housing Units
30% Income Household 20%
50% Income Household 20%
80% Income Household 30%
Moderate Income 30%
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b. Unit Mix. Applicants proposing residential and mixed-use projects shall
incorporate the following:
i. For market rate units:
(1) At least 15% of the units shall be three-bedroom units;
(2) At least 20% of the units shall be two-bedroom units:
(3) No more than 15% of the units shall be studio units;
(4) The average number of bedrooms for all of the market rate units
combined shall be 1.2 or greater; and
(5) Notwithstanding subsections (C)(2)(a)(i) through (iii) above, any
fractional housing unit less than 0.5 that results from this unit mix shall
be rounded down to the next lower integer. Any fractional housing unit
of 0.5 or more that results from this unit mix shall be rounded up to the
next larger integer.
ii. For affordable housing units the average number of bedrooms for all of
the affordable housing units combined shall be equal to or greater than the
average number of bedrooms provided for all of the market rate units
pursuant to subsection (C)(2)(a) of this Section.
iii. The Director may grant a waiver from this unit mix requirement
pursuant to the requirements and procedures for Waivers in SMMC
Chapter 9.43.
B. Prior Housing Commission Recommendations To City Council Regarding
The AHPP
At several meetings in June 2017, the Housing Commission considered the then draft Downtown
Community Plan, and made a number of recommendations to the City Council (including
recommendations to increase the percentage of affordable units required for project approval in
light of the results of the HRA feasibility study performed in connection with the preparation of
the draft plan). Of relevance to this agenda item, the Housing Commission recommended
(bolding added):
Review the entire Affordable Housing Production Program now for consistency
with Proposition R mandated income targeting and rent limits, and to assure that
the affordability requirements of the AHPP outside of the downtown area
are based on an economic analysis similar to that conducted for the
DOWNTOWN COMMUNITY PLAN.
One year later, in connection with review of the draft initial Housing Trust Fund Plan for the
2013-2021 Housing Element, the Housing Commission recommended that this Plan include the
following:
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City staff is directed to develop as soon as possible, in consultation with the
Planning and Housing Commissions, a proposal to adjust the AHPP program that
applies outside of the Downtown Community Plan. The proposal shall be based
on a feasibility study, and shall take into account past and projected future
production of housing through inclusionary zoning and HTF funded projects, as
well as the quantified objectives in the Housing Element and the requirements of
Proposition R.
The Staff Report to City Council recommended that the initial HTF Plan include this provision,
and City Council did include it.
C. Current Status Of Updated AHHP Feasibility Study For Areas Outside Of
The Areas Governed By The Downtown Community Plan
Based on communications with Staff, it appears that no steps have yet been taken to obtain an
updated feasibility study for areas outside of the areas governed by the Downtown Community
Plan. Nor is there any projected date for when such a study will be undertaken. Staff advises
that work by the Planning Department is necessary to proceed with arranging for such a
feasibility study, and that Planning Department Staff advises that it is presently fully engaged on
other planning issues given a higher priority by the City Council.
D. Impact Of Existing AHPP Requirements Outside The Downtown On
Acheivement Of Proposition R Mandates
1. Evidence That The Existing AHPP Requirements Outside Of
Downtown Continue To Incentivize Developers To Provide Only A
Small Number Of Extremely Low Income Units In Tier 2 Projects
The AHPP requirements outside of downtown create an enormous economic incentive for
developers to meet their AHPP requirement by providing a small number of extremely low
income units. This is because (1) the developer of a Tier 2 project outside of the downtown need
only make 7.5% of the units in the building deed-restricted for extremely low income residents in
order to satisfy the AHPP, but needs to make 15% of the units deed-restricted for very low
income residents or 20% of the units deed-restricted for low income residents in order satisfy the
AHPP. The small amount of revenue the developer loses by making units extremely low income
(rather than very low income or low income) is tiny compared to the additional revenue the
developer receives from charging market rate on those additional units it otherwise would have
to make either very low income or low income deed-restricted units.
This fact is illustrated by the very small differences in the percentage of affordable extremely
low, very low and low income units HRA found feasible in its study of downtown prototypes:
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This reality is also illustrated in the most recent Tier 2 project to come before the Planning
Commission (at its 11/7/18 meeting) for a Development Review Permit—216-234 Pico
Boulevard. This mixed-use project will create 105 new residential units, only eight of which will
be deed-restricted affordable units for extremely low income residents.
2. The Current Status Of The City’s Efforts To Comply With
Proposition R During The 2013-2021 Housing Element Period
Based on the data and projections provided by Staff in connection with the Housing
Commission’s recent review of the draft Initial HTF Plan, the following is the best information
currently available:
a. Without doing anything more, Santa Monica is projected to produce (i.e.,
complete or issue building permits for) more than three times the number of market-rate units
called for by the current Housing Element. See Part II.B.1 of Personal and Individual Views of
Housing Commission Chair Michael E. Soloff regarding Initial Housing Trust Fund Plan
(submitted to City Council in connection with Item 8D on the Council’s July 24, 2018 Agenda
(provided herewith).
b. Without doing anything more, Santa Monica is projected to produce (i.e.,
complete or issue building permits for) more than the overall number of deed-restricted
affordable housing units called for by the current Housing Element. However, the unit mix will
deviate from the mix called for by the current Housing Element in that it will include many more
extremely-low (30% AMI) and very-low income (50% AMI) units, but considerably fewer low-
income (80% AMI) units. See id . Part II.B.2.
c. Without doing anything more, Santa Monica is projected to fall short of
Proposition R’s requirements by approximately 130 affordable housing units. Proposition R
requires 30% of all new housing completed each year be affordable housing, with at least half of
that 30% (i.e., at least 15% of all new housing) affordable to those earning 60% or less of the Los
Angeles County median income. It is projected that more than 15% of the new housing that will
be completed during the 2013-2021 Housing Element will be affordable to those earning 60% or
less of the Los Angeles County median income, thus meeting one of Proposition R’s two
requirements. But only 25% of the new housing overall will be some form of affordable
housing, rather than the required 30%. See id. Part II.C below.
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III. DISCUSSION
The existing AHPP requirements outside of the areas governed by the Downtown Community
Plan incentivize developers to provide a very small number of extremely low income units in
their Tier 2 projects. This fact is among the factors that has contributed to the projected failure
of the City to meet its Proposition R Charter mandate during the 2013-2021 Housing Element. It
also is exacerbating that projected failure.
The recent mixed use project at 216-234 Pico Boulevard illustrates the problem. That project
adds 105 new residential units. In order to meet Proposition R’s 30% mandate, 32 of those units
would have to be deed-restricted affordable units. As only eight will be deed-restricted
affordable units, the City will have to spend its own funds to generate 35 additional affordable
housing units just to meet Proposition R’s Charter mandate created by this project (105 private
units plus 34 City financed units is 139 total units; 30% of 139 units is 41.7 units; 8 inclusionary
units and 34 City financed units is 42 affordable units). Even if the City financed units only
require $275,000 per unit in HTF funds because they will be part of a tax credit project, the 34
units will cost the City just under $9.4 million.
By contrast, if the same project had provided 15% very low income units (an alternative under
the AHPP). 16 of the 105 units would be deed restricted affordable units. Under that scenario,
the City would only need to finance 22 additional affordable housing units to meet Proposition
R’s Charter mandate (105 private units plus 22 City financed units is 127 total units; 30% of 127
units is 38.1 units; 16 inclusionary units and 22 City financed units is 38 affordable units).
Assuming again that the City financed units only require $275,000 per unit in HTF funds
because they will be part of a tax credit project, the 22 units will cost the City just over $6
million.
In the Downtown Community Plan, the City decided to require a mix of affordability levels
among any inclusionary units in a project. In order to implement that approach—and to set the
inclusionary requirement at the maximum economically justified level—a new feasibility study
is required for projects outside the downtown. But no such study is currently on the horizon.
The Housing Commission should discuss what, if anything, can and should be done in light of
these realities. Possibilities include (1) asking Council to preclude the extremely low income
option outside the downtown until a feasibility study can be conducted and/or (2) urging the City
Council to direct that a higher priority be placed on obtaining and acting upon such a feasibility
study.
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1
Vernice Hankins
From:Council Mailbox
Sent:Tuesday, March 26, 2019 3:22 PM
To:City Council Distribution Group
Cc:councilmtgitems
Subject:FW: Santa Monica Forward letter re 7B on Council agenda tonight
Attachments:SMF Letter to Council.docx
Council‐
Please see the email below regarding the Affordable Housing Production Program.
Thanks,
Stephanie
From: Judy Abdo [mailto:judyabdo@gmail.com]
Sent: Tuesday, March 26, 2019 2:59 PM
To: Council Mailbox <Council.Mailbox@SMGOV.NET>
Subject: Santa Monica Forward letter re 7B on Council agenda tonight
March 26, 2019
Santa Monica City Council
1685 Main Street
Santa Monica, CA
RE: ITEM 7B ON MARCH 26 COUNCIL AGENDA
Dear Mayor Davis and Councilmembers:
A Guiding Principle of Santa Monica Forward (SMF) is to support the development of new housing that is
affordable to all income levels as a means to do our part in meeting the Statewide housing crisis, to protect the
economic diversity of our residents, and to prevent homelessness among our lowest income citizens.
Santa Monica Forward, therefore, opposes the language, as amended by City staff, in the proposed Zoning
Ordinance amendment being considered under Item 7B at your meeting tonight.
Specifically, Section 9.64.030 C.2 will render infeasible the development of off‐site 100% affordable housing
projects as an option for compliance with the Affordable Housing Production Program (AHPP). SMF strongly
believes that this off‐site option is a highly desirable approach for producing affordable housing at no cost to
the City. Since more affordable units are required if the off‐site option is used, it contributes to Measure R
compliance more than on‐site affordable units would do. Further, as the 1626 Lincoln Boulevard project has
proven, off‐site 100% affordable housing projects produce more and larger units, suitable for family occupancy,
support services and community spaces, and open space that is designed with children in mind.
SMF supports substitution of the language submitted by Tara Barauskas, CCSM Executive Director, in her March
25, 2019 to the Council, for that language being proposed by City staff.
2
Santa Monica Forward also opposes the elimination of the Extremely Low Income category from the AHPP
options as set forth in Section 9.64.0505 C.1. The very poorest among us and those most in danger of
homelessness will suffer the most if the City Council approves staff’s recommendation. This is contrary to SMF’s
Guiding Principles and the Strategic Goals of the City.
Of grave concern to SMF is the fact that no one can say with any certainty that eliminating the Extremely Low
Income category will result in more production of Very Low and Low Income units. No one can say because no
current, meaningful feasibility study has been performed demonstrating whether these income categories will
work in a new project. Housing applications may grind to a halt.
Rather than eliminating the Extremely Low Income category, we urge you to expedite the AHPP feasibility study
and, upon its completion and if necessary, to revise the AHPP holistically rather than piecemeal and in the dark.
Sincerely,
Judy Abdo and Juan Matute, Co‐Chairs, Santa Monica Forward Steering Committee
CITY OF SANTA M ONICA
Affordable Housing Policy
CITY COUNCIL
Item #7B
March 26, 2019
Authorize
AHPP
Feasibility
Study
2
Purpose of Tonight’s #7B Discussion
Potential
Removal of
ELI Option
from AHPP
1
Ta x Credit
Allocation
Committee
Te xt
Changes to
AHPP
3
HOUSING
IN SANTA
MONICA
Remove ELI
5% from
AHPP
Prop. R
SB50
Rent
Control
RHNA
Housing
Element
AHPP
Study
SRO and
Ensuite
Tr end
Corporate
Housing
Analysis
Displacement
and
Gentrification
DCP
Monitoring
Report
Context for Housing Discussion
Policy and
Requirements
Adjustments
and Analysis
Background
•Changes to Zoning Ordinance and AHPP
•Council Direction
Potential
Removal of
ELI Option
from AHPP
1
2013
5% ELI Option
Introduced to
AHPP
Background on Housing Policy
2015
New ZO Adopted
Tier 2 Rules
Established to
Require 7.5% for
ELI
2017
DCP Adopted
New Methodology
for AHPP
DCP AHPP Methodology
Height (Feet)
On-Site
Affordable
Housing %
Off-Site
Affordable
Housing %
40-50 20%25%
52 21%26%
54 22%27%
56 23%28%
58 24%29%
60 25%30%
62 26%31%
64 27%32%
66 28%33%
68 29%34%
70-84 30%35%
AHPP Income Category Required % of Units
Extremely Low 20%
Ve ry Low 20%
Low 30%
Moderate 30%
More height = more required affordable units
Affordable Units are
Distributed Across AHPP
Income Categories
Housing Commission
November 2018
Preclude the extremely low-income
option until a full review of citywide
AHPP through updated economic
feasibility study based on the DCP
Model.
Direction from Council
City Council
December 2018
Prepare amendments to the AHPP
disallowing the current option for
developers to provide fewer extremely
low-income units until the feasibility
study can be completed.
Housing Demand and
Production
Housing Needs/Demand
Affordable Housing Waiting List
(Applicants Who Live or Work in Santa Monica)
Income Category Count Percentage
Extremely Low (0-30% AMI)405 21%
Ve ry Low (31-50% AMI)176 9%
Low (51-80% AMI)855 44%
Post 2013 Moderate 11 7 6%
Pre 2013 Moderate 380 20%
Above Moderate (>120% AMI)8 0%
To tals 1941 100%
* Compared with 2013, there is increased demand at all levels of affordability
Needed for
RHNA
Needed for
Quantified
Objective
93
(14)
(24)
128 128
256 84
(563)(563)
Completed and In
Construction
97
238
135
27
1,263
1,760
Housing Production
RHNA
Quantified
Objective
Extremely Low
(0-30% AMI)
428
83
Ve ry Low (31-50% AMI)214
Low (51-80% AMI)263 263
Moderate (81-120% AMI)283 111
Ab ove Moderate
(>120% AMI)700 700
To tals 1,674 1,371
Progress Tow ards RHNA and Housing Element Quantified Objectives
Approved
(Not In
Construction)
60
52
19
2
1,251
üSATISFIED HOUSING ELEMENT
ü SATISFIED HOUSING ELEMENT
Housing Production 2014-Present
402
40%
599
60%
95
13%
664
87%
In Construction
133
10%
1,251
90%
Planning Approval
(not in construction)Completed
Affordable Market Rate
366
22%
1,285
78%
Pending
(no approval)
39.3% Affordable 16.4% Affordable
Factors Affecting Affordable Housing Production:
•Loss of Redevelopment Agency (2012)
•Use of in-lieu fee
•Popularity of ELI option
Housing Production 2018
7%6%
3%
0%
84%market rate
2018 Planning Approvals
Ex-Low - 30 V-Low - 50 Low - 80 Mod - 120 Market
•14 Total Projects
•604 To tal Units Approved
•16% of Total Units are Affordable
•46% of Affordable Units are
Extremely-Low Income
•0% Moderate-Income Units
DCP Regulated Housing Production
Downtown Pending New Projects (DCP Regulations and Zoning Ordinance)
Address TYPE HEIGHT PA RKING #UNITS % AFFORDABLE PROVIDED
1427 Lincoln AA-Tier 2 50 15 15 20%
1437 6th Street AA-Tier 1 39 0 41 5%
1557 7th Street AA-Tier 1 39 0 40 5%
1437 5th Street AA-Tier 1 39 0 41 5%
1338 5th Street AA-Tier 1 39 0 96 5%
1415 5th Street AA-Tier 1 39 0 102 5%
Proposition R Performance
Proposition R (1990)
•30% of all multifamily housing
completed each fiscal year
must be affordable and
occupied by low-and
moderate-income households;
and
•At least one-half of the total
affordable housing completed
be affordable for an occupied
by low-income households.
Removal of ELI Option
Commission Comments
PLANNING COMMISSION
2.20.19
Remove ELI Option
•3 yes
•3 no
AHPP Feasibility Study
•Unanimous
•Expedite
HOUSING COMMISSION
2.21.19
Remove ELI Option
•6 yes
•1 no
AHPP Feasibility Study
•Unanimous
•Expedite
Public Comment
Public Comment Received
Leslie Lambert
•Seeks clarification on temporary vs. permanent ordinance
•Opposes removal of ELI option until AFTER AHPP feasibility study
Michael Soloff
•Supports temporary removal of ELI option
•Suggests exempting only approved projects
Discussion
Question for City Council to Consider
•In light of presented data, should the ELI option be temporarily
removed?
•Attachment A could effect changes to Section 9.64.050
•ELI option removed for any application not complete as of
March 26, 2019
•Financial Feasibility Analysis of
Modified AHPP Citywide Program
–Pro forma development analysis
•Enhanced affordable housing requirements
•Housing production incentives
•TCAC Guidelines
–Construction cost estimator, Developer
–Expedited timeline
AHPP
Feasibility
Study
2
•Staff Recommendation
–Authorize City Manager to execute agreement
with HR&A Advisors, Inc. not to exceed
$150,000.
•New language added to AHPP
(Attachment A)
–Exempts TCAC-financed housing from AHPP
requirements
–Maintains requirement to use City’s list
–Requires coordination with staff in applying for
competitive tax creditsUse of Tax
Credit
Allocation
Committee
Financing
3
•Staff Recommendation
–Introduce for 1st reading
Public Comment Received
CCSM
•Supports recommendation to remove the City funding requirement for 100%
affordable Housing Projects to use TCAC guidelines.
•Concern that limitations on applying for tax credits would cause market-rate
developers to forgo partnering with non-profits.
TCAC Financing and AHPP
Authorize
AHPP
Feasibility
Study
2
Purpose of Tonight’s #7B Discussion
Discuss
Potential
Removal of
ELI Option
from AHPP
1
Introduce for
1st Reading:
TCAC Text
to AHPP
3
Extra Information
Housing Production 2014-Present
65
11
22
14 11 9
0
10
20
30
40
50
60
70
2 to 10 11 to 25 26 to 49 50 to 74 75 to 100 Over 100
Pending, Planning Approval, In Construction, and Completed
Multi-Family Projects (Since 2014)
Housing Production 2018-Present
0
1
7
5
4
2
0
1
2
3
4
5
6
7
8
2 to 10 11 to 25 26 to 49 50 to 74 75 to 100 Over 100
P r o j e c t s
Number of Units in Project
Pending Multi-Family Projects, 2018-2019
Background on Housing Policy
Option Tier 1 Tier 2 (Requires 50% more than Tier 1)
1 ELI:5% for 30% income 7.5% for 30% income
2 VLI:10% for 50% income 15% for 50% income
3 LI:20% for 80% income 30% for 80%income
4 M:100% for moderate income Not Applicable
REFERENCE:
Agreement No. 10830 (CCS)