HomeMy WebLinkAbout2022-01-06 HRA Special Work Session PacketAg enda
H ousing and R edevelopment Authority Work Session Meeting
City of E dina, Minnesota
City Hall, Community Room
The H R A will be hosting a special work session in the Com m unity R oom from 7:30-
8:00 AM.
Thursday, January 6, 2022
7:30 AM
I.Call to Ord er
II.Roll Call
III.Am endm en t to New Multi-Fam ily Aord able Housing Policy
IV.Ad jou rn m ent
Th e E d ina Housing a n d Redevelop m ent Au thority wa n ts all pa rticip ants to be
com fortable b ein g pa rt of th e p u b lic p rocess. If y ou n ee d a ssista n ce in the w a y of
h ea ring am pli(ca tion, a n in terp reter, large-p rint docum en ts or som ethin g else,
p lease ca ll 952-927-8861 72 hou rs in advance of the m eeting.
Date: January 6, 2022 Agenda Item #: I I I.
To:C hair & C ommis s ioners of the Edina HR A Item Type:
R eport / R ecommendation
F rom:S tephanie Hawkinson, Affordable Housing
Development Manager Item Activity:
Subject:Amendment to New Multi-F amily Affordable Hous ing
P olicy
Disc ussion
Edina Housing and Redevelopment
Authority
Established 1974
C ITY O F E D IN A
HO US I NG & R EDEVELO P MENT
AUT HO R I T Y
4801 West 50th Street
Edina, MN 55424
www.edinamn.gov
A C TI O N R EQ U ES TED:
No action needed. For discussion only.
I N TR O D U C TI O N:
B ased on the ever changing housing market and after reviewing recent housing proposals, Staff proposes three
changes to the New M ulti-Family Affordable Housing P olicy:
· I ncrease the Buy-in from $125,000 per unit to $150,000 per unit.
· R equire the inclusion of affordable units if the top half of the density range is requested.
· R equire cooperation with the C ity designated compliance officer.
AT TAC HME N T S:
Description
Staff Report
Proposed New Multi-Family Affordable Hous ing Policy
Pres entation
January 6, 2022
Chair and Commissioners of the Edina Housing and Redevelopment Authority
Stephanie Hawkinson, Affordable Housing Development Manager
Proposed Amendments to the New Multi-Family Affordable Housing Policy
Information / Background:
In 2015 the Edina Housing Foundation proposed an Affordable Housing Policy (“Policy”) that requires new
residential development with greater than 20-units to include affordable housing units equaling 10% of the
combined units’ square footage. In subsequent years the Policy was amended to include a Buy-In option,
change the percentage based on the number of units verses square feet, a proportionality provision, and a
requirement for non-discrimination of Housing Choice vouchers among other things. The Policy is
periodically reviewed to determine if there are gaps in coverage, confusing elements, for ease in
understanding, and to make sure the goal of creating affordable housing opportunities is met.
Staff is now proposing three primary amendments:
Increase the Buy-in from $125,000 per unit to $150,000 per unit.
Require the inclusion of affordable units if the top half of the density range is requested.
Require cooperation with the City designated compliance officer.
Increasing the Buy-In
In March 2021 the Buy-in amount was increased from $100,000 to $125,000 to address the increasing
disparities between the cost of developing affordable housing and the cost to Buy-In. $125,000 was agreed
upon as it aligned with the policies in Cities similar in size and demographics. However, in the heels of
COVID the need for affordable housing has increased as have construction costs. The cost disparities
continue to grow. Electing to Buy-In versus including affordable units is becoming an increasingly easier
option, as indicated by the following:
1. Based on recent proposals, the cost of an affordable unit, including land, is roughly $330,000 per unit
where the cost to construct a Market Rate housing unit is over $500,000 per unit.
STAFF REPORT Page 2
2. For affordable housing, debt financing based on Net Operating Income account for between 30%
and 70% of the Total Development cost. Therefore between 30% and 70% of the financing comes
from tax credits and other public sources. Based on recent proposals the Buy-in amount of
$125,000 is 38% of the cost to construct a unit and therefore does not cover the gap financing
needed.
3. In looking at the rent levels of affordable units compared to market rate units over a 20-year period
(using recent proposals as examples), a developer makes more than $326,000 on the market rate
unit than on an affordable unit.
4. Since 2015, 90 affordable units were included in Market Rate developments compared to 117 units
that were not included in favor of paying the Buy-In fee.
Although the cost differential is roughly $326,000 per unit, Staff believes that that high amount would not
only be a disincentive to selecting the Buy-In option but could also be a disincentive to residential
development generally. Therefore, Staff proposes increasing the Buy-In to $150,000 per unit. This increase
was reviewed and is supported by the Edina Housing Foundation.
Inclusion Requirement
The Land Use Chapter of the Comprehensive Plan (“Plan”) provides density ranges for housing units that
can be built per acre. For example, in a High-Density Residential area between 12 and 60 housing units per
acre are allowed. In Greater Southdale District Residential between 50 to 100 housing units per acre are
allowed. Based on recently site plan applications, developers most frequently request maximizing the
number of units allowed.
The Comprehensive Plan does not indicate that the higher end of the range is deemed a “bonus” tied to
affordable housing. Rather the Plan states that denser land use categories allow for the creation of
affordable housing. Yet the Policy includes language that states that density bonuses can be used to make
including affordable housing units within a market rate development financially feasible. The inclusion of the
bonus language in the Policy reflects Staff’s intent that developments seeking the greatest density would
include the affordable units within the development. An amendment to the Policy provides clarity to that
intention.
Staff is proposing a two-tiered system:
Mixed Use Developments: Developments that are 50% or greater of the maximum within the
density range must include affordable units within the development. Conversely, developments that
are less than 50% the maximum density allowed in a range can choose to include the units or pay
the Buy-in fee.
All Residential Developments: Developments that are 75% or greater of the maximum density
within the range must include affordable units within the development. Conversely, developments
that are less than 75% the maximum density allowed can choose to include the units or pay the Buy-
in fee.
STAFF REPORT Page 3
Compliance Cooperation
It would seem self-evident that the developers who include affordable units within their development would
recognize that the City would need to confirm and verify the following:
1. Affordable units were included;
2. The rents on affordable units fall within the published affordable ranges; and
3. Tenants dwelling in affordable units are income qualified.
Nonetheless some owners have resisted cooperating with the City’s compliance consultant and we have
little recourse when no funding is involved. Staff believe it is important to make developers and owners
aware before the development is approved that the City will confirm and verify that the included affordable
units comply with the Policy.
Alignment with the 2040 Comprehensive Plan and Race & Equity Initiative
1. Comprehensive Plan
The New Multi-Family Affordable Housing Policy is the City’s primary mechanism for creating affordable
housing. Since its passage, the City has made great strides in creating more housing opportunities. The
passages below are sections of the 2040 Comprehensive Plan that support the proposed changes to the Policy.
Goal 1: Accommodate all planned residential growth in the city based on planned infrastructure investments
and other community goals and assets.
1. Seek to accommodate the total new households projected to locate in the city by the year 2040.
3. Recognize that successfully reaching affordable housing goals assists the city in achieving related
community goals, including:
f. Addressing climate change through higher density development patterns that help reduce
vehicle emissions (see Energy and Environment Chapter)
Goal 2: Encourage the development and maintenance of a range of housing options affordable to residents at
all income levels and life stages.
1. Encourage the production of additional affordable housing units and retention of existing affordable
housing units to meet the city’s housing needs and its Metropolitan Council affordable housing need
allocation of 1,804 units.
4. Revisit height and density zoning requirements if needed to make the development of affordable
housing financially feasible in areas guided for redevelopment.
Goal 4: Support the development of a wide range of housing options to meet the diverse needs and
preferences of the existing and future Edina community.
3. Promote affordable and workforce housing that includes a range of housing prices and options, based
on the principle that those who contribute to the community should have the opportunity to live
here.
7. Support the development of both mixed income and 100% affordable housing throughout Edina where
there is access to transit.
STAFF REPORT Page 4
Status on Achieving 2040 Affordable Housing Goal
Affordable Housing
Goal
Affordable Housing
Units Approved % Remaining
Total Units 1804 330 18.3% 1474
<30% AMI 751 22 2.9% 729
31-50% AMI 480 127 26.5% 353
51-80% AMI 573 181 31.6% 392
2. Race & Equity Initiative
Periodically reviewing an updating the Policy aligns with Goal 16 of the 2018 Race & Equity Initiative Final
Report and Recommendations. The report calls for the City to “Review policy with a race and equity lens
to include language relating housing to equity and disparities” (page 42). The recommendation goes further
by requesting the consideration of removing the Buy-In option. Staff does support collecting some Buy-in
funds as they make possible different types of affordable housing programs that are not financed through
traditional means. However, increasing the Buy-In amount addresses the concern raised by the Race &
Equity Task Force by incentivizing the inclusion of the affordable units.
☐City Council Approved: 11/1/2015
☒City-Wide Revised: 3/25/2021
☐Department
City of Edina Policy
NEW MULTI-FAMILY AFFORDABLE HOUSING
The City and Housing and Redevelopment Authority recognize the need to provide a range of affordable
housing choices for those who live or work in the City. Since the land appropriate for new multi-family
residential development is limited, it is essential that a reasonable proportion of such land be developed
into affordable housing units. As such, the City of Edina adopts the following New Multi-Family
Affordable Housing Policy.
FOR THE PURPOSES OF THIS POLICY:
1. “Unit” means either a for-sale dwelling or a rental dwelling in which a lease is signed prior to
occupancy.
2. “Financial Assistance” provided the City includes but is not limited to tax increment financing,
land write downs, pass-through funding for purposes other than environmental remediation and
other forms of direct subsidy.
3. Any specific projects requesting exemptions to the affordable housing requirements of this
policy must seek recommendation from the Edina HRA and approval from the Edina City
Council based on alternative public purpose.
4. All new multi-family developments of 20 units or more must adhere to this policy and must be
zoned PUD Planned Unit Development.
5. Affordable Rental Housing Income and Rents are defined as both gross incomes (adjusted for
family size) and gross rental rates (adjusted for bedroom count and include utility allowance and
any fees that are a requirement of occupancy as per Section 42 of the Internal Revenue Service
Code.) that are updated annually by the Minnesota Housing Finance Agency (MHFA) and
published at www.mnhousing.gov. 2020 income and rental limits can be found at the end of this
policy.
6. Affordable Ownership Housing Income and Sales Price are affordable to and initially sold to
persons whose income is at or below 80% of Area median Income.
THIS POLICY APPLIES TO ALL NEW MULTI-FAMILY DEVELOPMENTS THAT:
1. Include 20 units of more.
2. Require rezoning or a Comprehensive Plan Amendment.
3. Receive financial assistance from the City of Edina and/or the Edina Housing and Redevelopment
Authority.
4. Are developed on property purchased from the City of Edina even if no financial assistance is
being provided by the City unless the waiver is recommended by the Edina HRA and approved
by the Edina City Council.
Page | 2
THE POLICY
1. New rental multi-family developments subject to this policy shall provide a minimum of 10%
residential units at 50% affordable rental rates or 20% residential units at 60% affordable rental
rates as defined below. The units shall be occupied by households at or below 60% of the Multi-
Family Tax Subsidy Income Limits (MTSP).
2. New for-sale developments shall provide a minimum of 10% of residential units at affordable
sales prices as defined below.
3. The affordable unit mix must be approximately proportional to the market rate unit mix.
4. Rental and for-sale/owner occupied affordable units shall provide the following:
a. on-site parking (either surface or enclosed) for affordable units and the cost related to
parking must be included affordable sales price or affordable rental rate. At least one
enclosed parking space shall be included in the purchase price of a for-sale unit in the
same manner offered to buyers of market rate units.
b. Affordable and market rate residents will have equal access to all entries, lobbies,
elevators, parking and amenities. Examples of amenities include storage lockers,
balconies, roof decks, outdoor patios, pools, fitness facilities, and similar unit and project
features.
c. Exterior appearance of affordable units shall be visually comparable with market rate
units in the development.
5. New rental housing will remain affordable for a minimum of 20 years and this requirement will
be memorialized by a Land Use Restrictive Covenant.
6. New for-sale or owner-occupied developments will remain affordable for a minimum of 30
years and this requirement will be memorialized by a Land Use Restrictive Covenant. The Land
Use Restrictive Covenant will contain a provision providing the Housing and Redevelopment
Authority or Edina Housing Foundation the right of first refusal to purchase affordable units.
7. The developers and/or owners of multi-family rental housing projects subject to this Policy by
receiving financial assistance shall accept tenant-based rental housing assistance including but not
limited to Section 8 Housing Choice Vouchers, HOME tenant-based assistance and Housing
Support. Tenants with rental assistance may occupy an affordable dwelling unit with the rent
charged not exceeding the maximum allowed by Metro HRA or the assistance provider.
Furthermore, the rent charged may not exceed the maximum allowed by the most restrictive
funding sourced. This requirement will be enforced through a contract between the City of the
project owner pursuant to which the owner will be required to adopt business practices that
promote fair housing and provide documentation of compliance with these requirements to the
City. This requirement will be further enforced through the City’s monitoring policies and
procedures.
8. Owners of City-assisted housing projects shall affirmatively market affordable housing
opportunities. All multi-family housing providers subject to this policy must submit an
Affirmative Fair Housing Marketing Plan (AFHMP) at lease every 5 years and a Survey and
Certification regarding AFHMP outcomes annually. Owners must advertise housing
opportunities on HousingLink or another medium acceptable to the City concurrent with any
other public or private advertising.
9. Recognizing that affordable housing is created through a partnership between the City and
developers, the City and/or Housing and Redevelopment Authority will consider the following
incentives for developments that provide affordable housing:
a. Density bonuses
b. Parking requirement reductions
c. Tax increment financing for projects that exceed the minimum requirement
Page | 3
d. Deferred low interest loans from the Housing and Redevelopment Authority and/or
Edina Housing Foundation
e. Property Tax Abatement
10. It is the strong preference of the City that each new qualifying development provide its
proportionate share of affordable housing on site. However, the City recognizes that it may not
be economically feasible or practical in all circumstances to do so. As such, the City reserves the
right to waive this policy (only if circumstances so dictate, as determined by the City). In lieu of
providing affordable housing in each new qualifying development, the City may consider the
following:
a. Dedication of existing units in Edina to 110% of what would have been provided in a
proposed new development. These units would need to be of an equivalent quality
within the determination of the City.
b. Financial risk and participation in the construction of affordable dwelling units of an
equivalent quality by another developer on a different site within the City.
c. An alternative proposed by a developer that directly or indirectly provides or enables
provision of an equivalent amount of affordable housing within the city. An alternative
could be payment of a Total Buy In (TBI) fee, a cash payment to the City in lieu of
providing affordable housing units. The TBI shall be equal to $125150,000 per unit
rounding up to the next whole unit. The TBI would be due in cash or certified funds in
full to the City at the time of issuance of the building permit. A building permit will not
be issued unless the TBI is paid in full. The City Council may allow the housing
developer to pre-pay the TBI to satisfy a future Affordable Housing Opportunity on a
case-by-case basis. TBI will be deposited into the Affordable Housing Trust Fund to be
used for the development and preservation of affordable housing.
11. As allowing maximum density was intended to serve as a density bonus for the inclusion of
affordable units, for mixed use developments that have densities 50% or greater within the
density range, affordable units must be included in the development. For residential
developments with densities 75% or greater within the density range, affordable units must be
included in the development. For example:
a. If zoning allows between 50-100 units per acre, and the residential development is 50-87
units per acre, the developer/owner may elect to include the affordable units into the
development, pay the TBI fee, or an approved alternative.
b. If the proposed development is 88-100 units per acre, the development must include
affordable units within the building.
12. The owners and their agents of multi-family rental and ownership properties subject to this
policy must cooperate with the City’s compliance officer during the affordability period. Non-
compliance may be grounds for suspension of the rental license.
13. Guidelines for implementing this Affordable Housing Policy can be found in the Inclusionary
Housing Policy Program Guide.
202021 INCOME AND RENTAL LIMITS
Please refer to the income and rent tables published on www.mnhousing.gov.
201821 OWNERSHIP HOUSING INCOME AND SALES PRICE
GROSS INCOMES GROSS RENTS
60% 50% 60% 50%
1 Person
$43,440$44,100
$36,200
$36,750
Studio $1,086
$1,102
$905 $918
Page | 4
2 Persons $49,680
$50,400
$41,400
$42,000
1 Bedroom $1,164
$1,181
$970$984
3 Persons $55,860
$56,700
$46,550
$47,250
2 Bedroom $1,396
$1,417
$1,163$1,181
4 Person $62,040
$62,940
$51,700
$52,450
3 Bedroom $1,613
$1,636
$1,344$1,363
5 Persons $67,020
$67,980
$55,850
$56,650
4 Bedroom $1,800$1,825 $1,500$1,521
6 Persons $72,000
$73,020
$60,000
$60,850
Acquisition Limit in this policy definition: $293,500$316,000
20201 income limits as published on the Metropolitan Council website are as follows: 80% of AMI
($78,500$79,900)
Income limits and maximum sales prices are updated annually. See www.mnhousing.gov and
https://metrocouncil.org/Communities/Services/Livable-Communities-Grants/Ownership-and-Rent-
Affordability-Limits.aspx
Originally adopted: November 1, 2015
Income/Rent Limits Adjusted: April 13, 2016
As amended: February 7, 2018
As amended: April 3, 2018
As amended: October 2, 2018
As amended: March 5, 2019
Income/Rent Limits Adjusted: December 10, 2020
As amended: March 25, 2021
As Amended:
Proposed Revisions to
Affordable Housing Policy
December 9, 2021
Background Information
•2015 Policy initially approved
•2018 (winter) Buy-In option was
added
•2018 (Autumn) Affirmative Fair
Marketing and Non-
discrimination of Housing
Choice Vouchers added
•2019 Affordable Housing Trust
Fund Created
•Rents and incomes adjusted
annually
EdinaMN.gov 2
Proposed: $150,000
Construction costs have increased
Development costs range from
$300,000 to $515,000 per unit
(affordable to luxury).
Increase fee to incentivize
including units
Current: $125,000
Increased March 2021
Based on other Communities
Change #1: Buy-In Fee
EdinaMN.gov 3
It is much more Cost Efficient
for the Developer to Buy-In
rather than to include an
affordable unit:
Over a 20 -year period a
developer’s revenue is
significantly greater than
$125,000 per unit in a 100%
Market Rate Development.
Conclusion:
Over a 20-year period a100%
Market Rate development has
revenues $6,500,000 greater than
an inclusionary development. This
equates to $327,000 per unit that
was not affordable (10% or 20
units).
$125,000 is only 38% of the difference.
•200 unit building with a mix of 1
and 2 bedroom units
•Income escalator of 2%
•20-year affordability Period
•Comparing all market rate
apartments to one that includes
10% of units at 50% AMI rents.
•Market rate rents based on recent
proposals.
Basic Analysis
EdinaMN.gov 4
Inclusion:
•4917 Eden –20 units
•4977 77th Street –20 units
•Lorient –3 units
•Avidor –18 units
•Aria –8 units (4.3%)
•Millenium –11 units (4.8%)
•Nolan Mains –10 units
TOTAL: 90 units
Buy-In:
•Pentagon North –in lieu of 41
units
•Bower –in lieu of 19 units
•7001 France –In lieu 27 units
•Lorient –In lieu of 2 units
•4425 Valley View –In lieu of 3 units
•The Loden –in lieu of 25 units
TOTAL: In lieu of 117 units
Inclusion vs. Buy–in Comparison
EdinaMN.gov 5
Affordable Housing
Goal
Affordable Housing Units
Approved %Remaining
Total Units 1804 330 18.3%1474
<30% AMI 751 22 2.9%729
31-50% AMI 480 127 26.5%353
51-80% AMI 573 181 31.6%392
Affordable Housing Goals
EdinaMN.gov 6
•Edina has goal of creating 994 to
1804 new units of affordable
housing.
•Increases disincentive to Buy-In.
•Construction costs are increasing
--Buy-In fee does not go as far;
--Increasingly less expensive to
-Buy-In than to include units.
•In 2018 Race & Equity Task Force
proposed to Eliminate Buy-in
option
Keep Buy-In Option –But increase
EdinaMN.gov 7
Affordable Housing Trust Fund Estimated Balance Requests
Beginning Balance*$ 4,360,000
Market Street ($750,000)
4d Pilot Program -NO TAKERS ($160,000)
4d Pilot Program -2019 ($50,000)
VEAP Emergency Assistance*$0
Single Family Ownership Program (2020)($840,000)
Home Rehabilitation Program (Pilot)($250,000)
425 Jefferson ($150,000)
Single Family Ownership Program (2021)($1,500,000)
Home Rehabilitation Program Aug. 2021)($750,000)
Ending Balance $ 210,000
Importance of Buy-In: Flexibility
EdinaMN.gov 8
•Making loans at interest rates below or at market rates
•Guaranteeing of loans.
•Providing gap financing for affordable housing developments.
•Financing the acquisition, demolition, and disposition of property for
affordable housing projects.
•Financing the rehabilitation, remodeling, or new construction of affordable
housing.
•Funding to facilitate affordable homeownership opportunities including down
payment assistance, second mortgages, closing costs, etc.
•Interim financing of public costs for affordable housing projects in anticipation
of a permanent financing source (i.e. construction financing, bond sale, etc.)
•Other uses as permitted by law and approved by the city council.
Importance of Buy-In: Variety of Uses
EdinaMN.gov 9
Buy-In
Commitment
Timeline of Buy-In vs. Expenditure
EdinaMN.gov 10
2018 2020 20212019
SF Ownership
Homeowner
Rehab
SH Ownership
425 Jefferson
VEAP Assistance
Nolan Mains Gap
4d Revised
4d Program
$2M Loden $1.9M Bower $300K Valley
View$160K Lorient
Policy Language:
Recognizing that affordable housing is created
through a partnership between the City and
developers, the City and/or Housing and
Redevelopment Authority will consider the
following incentives for developments that
provide affordable housing:
•Density bonuses
•Parking requirement reductions
Etc.
Change #2: Regarding Density
“Bonuses”
EdinaMN.gov 11
Example 1:
•Density range 50-100 units per acre
•Proposal is 95 units/acre (90% of Max)
Requirement: Development must include
affordable units.
Example 2:
•Density range 50-100 units/acre
•Proposal is 70 units/acre (40% of max)
Requirement:Either Buy-In, inclusion or
blend.
Density Level May Require
Inclusion
EdinaMN.gov 12
Project Project Density Comp. Plan % of Density
Onyx –240 units (0 affordable)53 units/acre 75 units/acre 71%
Lorient –46 units (3 affordable)50 units/acre 60 units/acre 83%
Nolan Mains –100 units (10 aff.)74 units/acre 75 units/acre 99%
The Loden –246 units (0 affordable)10 units/acre 30 units/acre 33%
Pentagon Village–200 units (20 aff.)16 units/acre 75 units/acre 21%
70th and France –267 units 46 units/acre 150 units/acre 31%
Approved Density: Mixed Use
EdinaMN.gov 13
Project Project Density Comp. Plan % of Density
Aria –185 units (8 affordable)93 units/acre 100 units/acre 93%
Millennium –375 units (11 aff.)66 units/acre 105 units/acre 63%
Avidor –166 units (16 aff.)95 units/acre 100 units/acre 95%
Sound on 76th –70 units (all aff.)35 units/acre 40 units/acre 75%
Edina Flats–18 units (0 aff.)14 units/acre 30 units/acre 47%
Amundson Flats–62 units (all aff.)50 units/acre 50 units/acre 100%
Hazelton Road Apts. –186 units 149 units/acre 150 units/acre 99%
4040 70th Street –118 aff.75 units/acre 75 units/acre 100%
Perkins Site –196 units (20 aff.)94 units/acre 100 units/acre 94%
Approved Density: Residential
EdinaMN.gov 14
Type of Zoning Density Range Mixed Use Residential Only
High Density Residential 12-60 >= 36 units >= 48 units
Greater Southdale Residential 50-100 >= 75 units >= 88 units
Neighborhood Node 10-60 >= 35 units >= 48 units
Office Residential 20-75 >= 48 units >= 61 units
Mixed Use Center 12-100 >= 56 units >= 78 units
Community Activity Center 90-150 >= 120 units >= 135 units
Regional Medical Center 50-100 >=75 units >= 88 units
Inclusion Required
EdinaMN.gov 15
Add:
•The owners and their agents of multi-
family rental and ownership properties
subject to this policy must cooperate with
the City’s compliance officer during the
affordability period. Non-compliance may
be grounds for suspension of the rental
license.
•Amend rent, sales price, and income limits
Change #3: Cooperation
EdinaMN.gov 16
EdinaMN.gov 17
Location of
Affordable
Housing
EdinaMN.gov 18
Questions?