[BoulderCouncilHotline] Housing

[Wallach, Mark]

In connection with tomorrow’s conversation concerning middle-income housing, I do have a few comments.

1) Can we start by understanding what housing  must be priced at in order to be considered middle-income? And what level of AMI is associated with various price levels?

2) On page 4 of the staff memo: what is the data on the impact of the Construction Defect Law? Are condos not being built anywhere? Are no condos being built in Denver?

3) On page 5 of the memo, please clarify the distinction between mid-size and larger annexations.

4) on page 7 of the staff memo it says the following: “The city cannot influence the tenure (ownership/rental), location or any other characteristics of the IH required affordable housing in a new housing development.” Why not generally, and specifically why not when the developer is asking for relief from one or more requirements, such as height, open space requirements, etc.?

5) What aspect of the Telluride Decision forbids us from entering into a bargain with a developer who wants relief from city requirements in exchange for other limitations on rents? What if the rent relief were for a fixed period of time, say 20 or 25 years? Why is this not a contractual bargain relating to an individual project instead of the institution of a rent control system?

6) On page 11, the calculation of what is necessary to achieve 15% affordability is a bit misleading. The text implies that if we could simply double our existing affordable units we would achieve our goal. Where the calculation falls short is that as Boulder continues to grow, so will the required number of affordable units in order to hit the 15% threshold. If we continue building at a rate of 75/25 market rate to affordable units, we would need to build more than 10,000 units of housing to get to that 15% affordability level.

7) On page 12, proposed changes to IH requirements: CIL is a major source of funding for the creation of affordable housing in Boulder. What will be the revenue impact on the ability of BHP to provide affordable housing by moving towards middle-income housing. And, as affordable housing is highly leveraged through private equity, LIHTC credits, and federal funding, what is the true comparison of the number of units in each category that we will produce? Affordable housing has a leverage of 9 or 10 to 1. What will be the expected leverage for middle-income housing? Is this not a zero sum situation where we produce fewer affordable units through the diversion of resources to middle-income units? Have we fully analyzed the costs and benefits of doing so?

8) On page 12 it is stated that at 60% AMI families are fully able to access market rate housing. This may be the case in older market rate projects, but strikes me as unlikely in newer construction. Looking at the last 20 large projects completed in Boulder, in how many of those could a 3 BR unit be rented for $1,956/month? My instinct is that the market is not providing a great deal of housing at that price.

9) I am confused about the comment on page 13 that increases in IH can make some housing developments less attractive. At least with respect to large projects, isn’t this the goal, in order to incentivize the production of actual units, either on site or off site?

10) I think staff’s goals with respect to utilization of a consultant (page  13) are on point and appropriate.

11) What does the comment that BHP, Thistle and Habitat for Humanity are buffered from bankruptcy mean, and what is its relevance to this discussion? (page 14)

12) While this is not the moment to get into detail concerning the mechanics of deed-restricted housing, have we at least done any analysis as to the extent of the market for this type of housing? While there are undoubtedly individuals or families whose desire to live in Boulder is so great that they would forego market appreciation for the opportunity to do so, have we at least studied how deep that market would be? If not, should we not do so?

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