HomeMy WebLinkAboutAffordable Housing Component AB 1290 Implementation Plan Jan tS_ ��
Council/Agency Meeting Held: 0
Deferred/Continued to:
Appro ed ❑ Conditionally Approved ❑ Denied City erk' Sign u e
Council Meeting Date: 12/17/2007 Department ID Number: ED 07-51
CITY OF HUNTINGTON BEACH
REQUEST FOR REDEVELOPMENT AGENCY ACTION
SUBMITTED TO: HONORABLE CHAIR AND RED�V4DA,
OPMENT AGENCY MEMBERS
SUBMITTED BY: PENELO/ CUL RETH-GRAFT, EXECUTIVE DIRECTOR
PREPARED BY: STANLEY SMALEWITZ, DEPUTY EXECUTIVE DIRECTORr �
SUBJECT: APPROVE THE AFFORDABLE HOUSING COMPONENT AB 1290
IMPLEMENTATION PLAN JANUARY 2005 - DECEMBER 2009 MID-
TERM UPDATE
Statement ofissue,Funding Source,Recommended Action,Alternative Action(s),Analysis,Environmental Status,Attachment(s)
Statement of Issue: The California Redevelopment Law requires Redevelopment
Agencies to prepare and adopt Five-Year Implementation Plans and Mid-Term Updates. On
November 15, 2004, the Agency adopted the Five-Year Implementation Plan for the
Huntington Beach Merged Project Area and, in 2002, the Agency adopted the Five-Year
Implementation Plan for the Southeast Coastal Redevelopment Project Area. In 2004, the
Agency also adopted a Ten-Year Housing Compliance Plan to supplement the
Implementation Plan materials. In December, 2007, pursuant to California Redevelopment
Law, the Agency will be asked to review and adopt a mid-term update for the Huntington
Beach Merged Project Area and a new Five-Year Implementation Plan for the Southeast
Coastal Redevelopment Project Area. The attached Affordable Housing Component
Implementation Plan (2005-2009) satisfies all the applicable affordable housing reporting
obligations.
Funding Source: None required
Recommended Action: Motion to:
1. Adopt the Affordable Housing Component AB 1290 Implementation Plan January
2005 — December 2009 Mid-Term Update Report
Alternative Action(s): Do not approve the Affordable Housing Component Implementation
Plan and direct staff regarding modifications to the mid-term housing component.
r
In the early 1990's the City initiated a policy requiring affordable housing units to be
integrated into new market rate housing developments. The City formalized the policy
into an Inclusionary Housing Ordinance in 2004 that imposes income and affordability
requirements on new residential development with three or more units.
The Ordinance allows projects with three to nine units to pay a fee in-lieu of producing
the units; these funds will be deposited in the Affordable Housing Trust Fund. The
Ordinance also provides the City Council with the latitude to allow developers, in limited
circumstances, to transfer the responsibility for producing the units to the Agency in
return for making a contribution to the "Housing Development Fund". Both the
Affordable Housing Trust Fund and the Housing Development Fund are administered by
the Economic Development Department.
The bulk of the Agency assistance to affordable housing projects and programs is
derived from Set-Aside funds. However, the City also receives HOME Program and
Community Development Block Grant (CDBG) funds from the United States Department
of Housing and Urban Development (HUD); these funds are transferred to the Agency to
supplement the Set-Aside.
Agency Activities
Since the late 1980's, the Agency has assisted over 1,000 affordable housing units.
These projects are named and described in the appendices to this report. These
projects can be summarized as follows:
1. In 1986, the Agency developed the 164-unit Emerald Cove project. Fifty percent
(50%) of the units are set-aside for very-low income households and 50% of the
units are allocated to low income households. The income and affordability
covenants are imposed on this project in perpetuity.
2. Between 1988 and 1993, the Agency assisted the 40-unit Huntington Village
Senior Apartment Project, the 44-unit Brisas del Mar Project and the 48-unit Five
Points Senior Apartment Project. These projects include a mix of very-low, low
and moderate income units. However, these projects are all located outside of
the Huntington Beach Project (Merged), and prior to 1994 only projects located
within redevelopment project areas could be used to fulfill the Section 33413(b)
inclusionary housing production requirements.
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3. Between 1994 and 2004, the first two Implementation Plan cycles, the Agency
assisted in the creation of 588 affordable housing units. The projects' names and
characteristics are identified in Table H-4, and the project types can be
summarized as follows:
a. 93 apartment units were developed or substantially rehabilitated within
the Huntington Beach Project (Merged);
b. 195 apartment units were developed or substantially rehabilitated outside
the Huntington Beach Project (Merged).
C. Six very-low income home ownership units were constructed outside the
Huntington Beach Project(Merged) by Habitat for Humanity with Agency
assistance.
d. The Agency purchased long-term income and affordability covenants on
294 apartment units located outside the Huntington Beach Project
(Merged).
4. During the current Implementation Plan period, several affordable housing
projects have come on-line. These projects can be described as follows:
a. Completed projects outside the Project Areas:
i. A 106-unit SRO was completed by a for-profit developer.
ii. Two substantial rehabilitation projects, totaling eight units, have
been completed by the Collette's Children's Home Crisis Shelters.
iii. One Habitat for Humanity ownership unit was completed.
b. Two substantial rehabilitation projects are currently being undertaken by
the Jamboree Housing Corporation in the Oakview neighborhood. These
projects include nine very-low income units and one low income unit
City Activities
The City's Inclusionary Housing Ordinance requires that at least 10% of the residential
units be subject to long-term income and affordability covenants. Nearly 500 income
restricted units have been developed since the City began implementing an inclusionary
housing policy in 1993; these units are all being counted toward the fulfillment of the
City's RHNA goals.
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The affordable housing covenants required by City's Inclusionary Housing Ordinance are
intended to comport with the inclusionary housing production requirements imposed on
the Agency by Section 33413(b). However, given the timing, location and covenant
monitoring in place on the existing units developed under the Inclusionary Housing
Ordinance requirements, the Agency is currently limited to receiving Section 33413(b)
inclusionary housing production credit for approximately 161 units.
C. PROPOSED AFFORDABLE HOUSING ACTIVITIES
Activities Funded with Set-Aside and HOME Funds
The array of affordable housing development being considered in this Affordable
Housing Component includes:
Oakview Acquisition and Rehabilitation Projects
In 1994 the Agency began a revitalization program for the Oakview neighborhood.
Between 1994 and 2004, the Agency assisted in the acquisition and substantial
rehabilitation of 81 units in 10 projects. During 2006 and 2007 the Agency approved 10
additional units in two projects. The Agency is also currently considering providing
assistance to a third project that includes four units.
The ultimate objective is to create a vibrant neighborhood that continues to be occupied
by a diverse mix of residents. Recognizing that local serving retail uses are needed by
the residents, KMA evaluated the opportunity for including retail in the development mix.
However, based on an analysis of the site selection criteria imposed by typical retailers,
it was the KMA conclusion that there is an insufficient number of residents in the primary
trade area; and the streets do not generate sufficient traffic to attract typical retail
tenants. To kick-start retail opportunities, the City is working with the Oakview
Revitalization Partnership to attract a local farmers market to the neighborhood and will
continue to pursue efforts to attract business opportunities in the future.
Given the development constraints, KMA focused the strategic planning process on
mixed-income residential development, the creation of a pleasant environment for the
residents throughout the neighborhood, and the need to create a uniform operating
standard for the various projects that have or will receive Agency assistance. To
maximize the impact on the neighborhood, and to create the ability to leverage outside
funding sources to defray the Agency's Affordable Housing Fund expenditures, this
Affordable Housing Component is based on the following assumptions:
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1. The Agency will work closely with Oakview Task Force to ensure that proposed
development and activities meet the needs of the existing community.
2. The Agency will work with nonprofit developers designated as Community
Housing Development Organizations (CHDO) to undertake these projects. The
selected developers will currently be involved in the neighborhood, or will come
to the Agency with site control for the proposed project.
3. The selected developer(s) will focus on assembling contiguous parcels.
4. To the extent it is financially feasible within the assistance parameters identified
by the Agency, the projects will be required to include sustainable design
features such as:
a. Energy and water reduction strategies;
b. Building design that maximizes sunlight for heat and light, and maximizes
air flow for natural cooling;
C. Solid waste reduction technologies;
d. Storm water mitigation; and
e. Gray water recycling.
5. The Agency will assist a CHDO in undertaking community organizing activities.
Specifically, the CHDO will create programming to benefit the residents within the
community, including the residents in the affordable housing projects undertaken
by other developers.
This strategy will provide the Agency with the opportunity to group the rehabilitation
projects together to maximize the effect; and/or to replace the existing projects with
efficiently designed new development projects geared to the needs exhibited within the
community. This will assist the Agency in fulfilling Section 33413(b) inclusionary housing
production requirements, and will assist the City in fulfilling outstanding RHNA goals.
The range of strategies to be considered by the Agency include:
1. The use of the existing fund balance to assist 40 units over the next two years,
followed by the use of approximately $1 million in Set-Aside funds and 100% of
the available HOME funds to assist five additional units per year throughout this
strategy period.
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a. This strategy would generate 80 units by fiscal year 2014/15.
b. The average subsidy, in 2007 dollars, is estimated at $300,000 per unit.
2. The issuance of a +/- $10 million taxable bond secured by Set-Aside funds,
which would be used in combination with the $13 million in currently available
funds to provide the opportunity to obtain outside leveraging such as Low Income
Housing Tax Credits (Tax Credits), Multi-family Housing Program (MHP) funds,
and other sources available at the state and federal levels. Development under
this scenario could take one of the following forms:
a. Acquisition and substantial rehabilitation of existing projects:
i. This strategy is projected to generate approximately 100 units, for
which implementation would commence over the next two years.
ii. The average Agency subsidy is estimated at $200,000 per unit.
b. The assemblage of contiguous parcels, combined with initial rehabilitation
work limited to bringing the properties to a decent, safe and sanitary
quality level. The ultimate plan would be to replace the existing projects
with mixed-income new construction projects:
i. The total development would include 50 to 75 units.
ii. The units would be designed to accommodate families.
iii. It would be possible to create open spaces and support services
that would be available to residents throughout the neighborhood.
iv. The project would be structured to allow Tax Credits and Tax-
Exempt Bonds to be obtained to defray the Agency assistance
costs.
V. The average assistance is estimated at $250,000 to $300,000 per
unit in 2007 dollars.
The Oakview neighborhood is located within the Huntington Beach Project (Merged).
Any substantial rehabilitation projects undertaken with Agency assistance, and any new
development undertaken with or without assistance, will trigger Section 33413(b)
inclusionary housing production obligations. However, it is assumed that the Agency
assisted development will provide a sufficient number of units to fulfill the obligations.
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Huntington Gardens
This Affordable Housing Component includes the 180 unit Huntington Gardens project,
which is located outside the Project Areas. This project is a HUD sponsored senior
citizen apartment project known as Wycliffe Gardens. The HUD assistance package
and covenants recently expired, which places the project"at risk" of conversion to
market rates. The property owner has expressed interest in selling the project, and this
Affordable Housing Component assumes that the Agency will assist a nonprofit
developer in the acquisition and rehabilitation, in return for the imposition of long-term
income and affordability covenants.
The assistance costs associated with this project are estimated at approximately $14
million, or $75,000 per unit. This project is located outside of a redevelopment project
area, so it will not trigger Section 33413(b) inclusionary housing production obligations.
The project can be used to fulfill the Agency's production requirements on a two-for-one
basis. Given the fact that this project is considered an "at risk" project, it can also be
used to fulfill the City's RHNA's goals.
Mixed-Use Projects on Commercial Corridors
Transportation corridors in Huntington Beach provide opportunities for mixed-use
commercial and residential development. Those projects located within the Project
Areas will create Section 33413(b) inclusionary housing production obligations for the
Agency to fulfill. However, all the mixed-use projects will be subject to the requirements
imposed by the City's Inclusionary Housing Ordinance. Thus, these developments can
potentially fulfill a portion of the Agency's Section 33413(b) inclusionary housing
production requirements.
It is assumed that mixed-use development will be proposed by private developers on
available infill sites, and that no Agency assistance should be required. Some
developers may agree to comply with the income and affordability requirements imposed
by the State of California density bonus (SB1818) to achieve greater development
intensity, and to enhance the project economics. As such, mixed-use zoning should only
be applied to sites that are appropriate for urban style development.
An example of a mixed-use project on a transportation corridor is the proposed Bella
Terra Phase II project. This project is currently proposed to include 503 residential units
as part of the overall development mix. The site is located within the Huntington Beach
Project (Merged), so residential development will create a Section 33413(b) inclusionary
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REQUEST FOR REDEVELOPMENT AGENCY ACTION
MEETING DATE: 12/17/2007 DEPARTMENT ID NUMBER: ED 07-51
Analysis: California Redevelopment Law (CRL) as portrayed in California Health and
Safety Code, §33490 requires Redevelopment Agencies to prepare and adopt Five-Year
Implementation Plans, Mid-Term Updates. The purpose of the Implementation Plans and
Mid-Term Updates is to identify the specific goals and objectives for the Redevelopment
Project areas, to describe the specific programs, including potential projects and estimated
expenditures that would be made during the five years, and explain how these activities will
eliminate blight and improve and increase the supply of affordable housing for the very-low,
low-, and moderate-income households. The Affordable Housing Component is a part of the
Implementation Plan and Mid-Term Updates.
The Affordable Housing Component Implementation Plan (Plan) provides the opportunity to
review what the Agency has accomplished and to review the Agency's affordable housing
goals, objectives, and specific program to meet its affordable housing obligations over the
time-frame of the Plan (2009). In brief, the Agency has currently met all of its replacement
and production obligations. The Affordable Housing Component Mid-term report will also
ensure that the Agency's goals are consistent with the City's draft Housing Element's goals
to provide affordable housing. In addition, the projects undertaken by the Agency are
counted toward the City's Regional Housing Needs Allocation (RHNA).
CRL sets forth the fundamental purpose of the Housing set aside (20%) which is to expand
the supply of very low-, low-, and moderate-income housing. The three primary
responsibilities of the Redevelopment Agency are: (1) production and/or replacement of low-
and moderate-income housing; (2) set-aside and expenditure of specified amounts of
property tax increment revenue (20%) for the express and exclusive purpose of increasing,
improving, and preserving a community's supply of low and moderate-income housing; and
(3) preparing reports on how the Agency has met, or preparing plans on how the Agency will
meet its responsibilities with regard to the first two items. The Affordable Housing
Component falls under the third requirement.
The Agency and the City have implemented a broad-based affordable housing program over
the past 20 years. It includes new development of rental and ownership housing; substantial
rehabilitation of rental housing; purchases of long-term income and affordability covenants on
existing apartment projects; and grants and loans for minor rehabilitation projects.
The financing of the Agency assistance is derived from the Property Tax Increment Housing
Set-Aside, federal HOME Program, and federal Community Development Block Grant
Program funds. Additionally, there may be Inclusionary Housing In-Lieu funds available in
the future.
Since the 1980's, the Agency has assisted over 1,000 affordable units. Currently, during this
Implementation Plan period, the Agency has assisted in three substantial rehabilitation
projects, totaling 14 units and one Habitat for Humanity ownership unit.
The attached Implementation Plan sets forth the following goals:
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REQUEST FOR REDEVELOPMENT AGENCY ACTION
MEETING DATE: 12/17/2007 DEPARTMENT ID NUMBER: ED 07-51
Workforce Housing — The Agency has established an objective to provide home ownership
opportunities to households that cannot afford to purchase a home in Huntington Beach,
and do not qualify for assistance under the statutory definitions of low- and moderate-
income households. The Agency would like to focus this program on providing home
ownership opportunities for City employees. In addition, the Agency would work with major
employers within Huntington Beach that are interested in providing housing assistance to
their employees. However, to maximize the benefits to the City, the program's marketing
effort would be focused on City employees.
Oakview Acquisition and Rehabilitation Projects — Between 1994 and 2007, the Agency
assisted in the acquisition and substantial rehabilitation of 95 units in 13 projects. In the
near-term, the Agency will assist in the creation of a weekly farmer's market, create a
community revitalization plan, require all projects to include sustainable design features, and
assemble contiguous parcels to attract new development of mixed-income units. This
strategy will allow new construction of rental developments by removing underutilized and
dilapidated properties.
Wycliffe/Huntington Gardens — As identified in the Housing Element, this project is currently
"at-risk" of conversion to market rates. This is a 180-unit senior complex. The Agency will
work with a non-profit to purchase the property and extend the long-term income and
affordability covenants.
Rehabilitation Loan Program — The Rehabilitation Loan Program is currently available for
single-family residential units, mobile homes, and multi-family homes. The program is
currently limited to $25,000 for single-family homes, $15,000 for mobile homes, and $15,000
per unit for the multi-family program. It is recommended that the Rehabilitation Loan
Program be changed to increase the cap to $75,000 for single-family home and to eliminate
the multi-family home component. Single-family homes are defined as developments that
include between one and four units. The loans are subject to 3% interest. The Agency
averages 25 rehabilitation loans per year.
Student Housing — The City/Agency is working to assist Goldenwest College in the
development of 150 to 175 units for 300 students.
Inclusionary Housing/Mixed-Use Projects on Commercial Corridors — All new development
within the City is obligated to meet the City's Inclusionary Housing Ordinance to set-aside
10% of the housing being built for sale or as rental units to very-low, low and median income
households. The City Council recently approved an in-lieu fee for residential projects
between four and nine units. Agency Housing Division staff administer the program, and the
units are counted toward the fulfillment of City and Agency affordable housing obligations.
Strategic Plan Goal: This project will help meet the City of Huntington Beach Strategic
Plan Goal L-3, "Preserve the quality of our neighborhoods,..." by enhancing and preserving
the quality of existing housing and providing additional affordable housing within the City
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REQUEST FOR REDEVELOPMENT AGENCY ACT0ON
MEETING DATE: 12/17/2007 DEPARTMENT ID NUMBER: ED 07-51
and Goal L-1 "Establish the vision and create a land use plan for reuse of critical parcels so
that the next phase of the community investment and improvement can begin".
Environmental Status: Not applicable.
Attachment(s):
below
City Clork?$
Pas - • • ! o •
1. Affordable Housing Component AB 1290 Implementation Plan January
2005-December 2009 Mid-Term Update
-4- 12/3/2007 9:58 AM
ATTACHMENT # 1
MD
THE HUNTINGTON BEACH REDEVELOPMENT AGENCY
NOVEMBER 26, 2007
I. AFFORDABLE HOUSING COMPONENT
A. IMPLEMENTATION PLAN REQUIREMENTS
Keyser Marston Associates, Inc. (KMA), the Huntington Beach Redevelopment Agency's
(Agency) financial consultant prepared the following Affordable Housing Component of
the Agency's Implementation Plan. This Affordable Housing Component aggregates the
requirements imposed on the Huntington Beach Project (Merged) and the Southeast
Coastal Redevelopment Project Area.
The Affordable Housing Component identifies a funding plan and activities related to the
production of affordable housing for persons and families of low and moderate income.
The Implementation Plan covers the period between January 2005 and December 2009.
However, various California Redevelopment Law (CRL) restrictions also require the
Agency to create plans for affordable housing activities through December 2014, and
then again through the end of the Project Areas' life.
The CRL provides that a fundamental purpose of redevelopment is to expand the supply
of low and moderate income housing (Section 33071).' To accomplish this purpose, the
CRL contains numerous provisions to guide redevelopment agency activities with regard
to low and moderate income housing. These provisions divide a redevelopment
agency's housing responsibilities into the following three major categories:
1. The production and/or replacement of low and moderate income housing;
2. The set-aside and expenditure of specified amounts of property tax increment
revenue for the express and exclusive purpose of increasing, improving and
preserving a community's supply of low and moderate income housing; and
3. Preparing reports on how the Agency has met, or preparing plans on how the
Agency will meet, its responsibilities with regard to the first two items.
This Affordable Housing Component of the Implementation Plan is one of the Agency's
responsibilities under the third major category. Its contents address how the Agency's
plans for the Project Areas will achieve the affordable housing requirements imposed by
the CRL. The Affordable Housing Component must address the following items.
The CRL income definitions are found in the following Sections: moderate Section 50093, low 50079.5
and very-low 50105.
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1. Production of Affordable Housing Based on Activities in the Project Areas:
a. At least 30% of all new and substantially rehabilitated dwelling units
developed by a redevelopment agency shall be provided at affordable
housing cost to low and moderate income households (Section
33413(b)(1)).
b. At least 15% of all new residential units developed in a redevelopment
project area, by public or private entities other than the redevelopment
agency, shall be provided at affordable housing cost to low and moderate
income households. This requirement also includes all substantially
rehabilitated units that have received agency assistance (Section
33413(b)(2)).
C. If a project identified in the Implementation Plan results in the removal of
units occupied by low or moderate income households, the
Implementation Plan must identify suitable locations for replacement
housing units to be developed or substantially rehabilitated (Section
33490(a)(3) and Section 33413(a)).
2. Set-Aside and Expenditure of Property Tax Increment for Housing Purposes:
a. Twenty-percent (20%) of the gross property tax increment (Set-Aside
funds) must be placed in a separate Affordable Housing Fund to be used
solely to increase, improve and preserve the community's supply of low
and moderate income housing (Section 33334.2).
b. Set-Aside funds must be spent on very-low, low and moderate income -
housing in proportion to the unmet need for housing as defined in Section
65584 of the Government Code. The unmet need for housing is identified
in the Regional Housing Needs Assessment (RHNA) for the City of
Huntington Beach (City) which is prepared by the Southern California
Association of Governments (SCAG) (Section 33334.4).
C. A cap is applied to the amount of Set-Aside funds that can be spent on
housing that is subject to age restrictions. The limit is equal to the
percentage that very-low and low income households over the age of 65
represent of the total very-low and low income population in Huntington
Beach, based on United States Census data (Section 33334.4).
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d. Set-Aside funds can only be used to construct infrastructure and public
improvements if the improvements are an integral part of the new
construction or rehabilitation of housing units that are subject to long-term
income and affordability covenants, and are directly benefited by the
improvements (Section 33334.2).
e. Set-Aside funds can only be used to fill the gap between the amount of
external financing that can be supported by a project, and the total project
costs. If more than 50% of the project costs are funded by the
redevelopment agency, a finding must be made that no other commercial
funding sources could be reasonably obtained (Section 33334.3)
The Implementation Plan must also include the following information:
1. Estimates of the balances and deposits into the "Affordable Housing Fund"
created to hold the Set-Aside funds;
2. A housing program identifying expenditures from the Affordable Housing Fund;
3. A description of the housing activity that has occurred in the Project Areas, and;
4. Estimates of housing units that will be produced in the Project Areas for each of
the various income categories.
All of this information is provided in the following sections of the Affordable Housing
Component of this Implementation Plan.
B. HISTORICAL AFFORDABLE HOUSING ACTIVITIES
The first area within the Project Area now known as the Huntington Beach Project
(Merged) was adopted in 1982. The Southeast Coastal Project was not adopted until
2002, and no residential development has occurred within this Project Area. As such, all
the Agency's historical affordable housing activities have taken place in the Huntington
Beach Project (Merged) or in portions of the city not located in a Project Area.
The Agency and the City have implemented a broad based affordable housing program
over the past 20 years. These projects and programs include new development of rental
and ownership housing; substantial rehabilitation of rental housing; purchases of long-
term income and affordability covenants on existing apartment projects; and grants and
loans for minor rehabilitation projects.
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housing obligation for the Agency. The City's Inclusionary Housing Ordinance requires
the development to set-aside 10% of"for sale" units for median income households.
However, the City may ultimately impose the full Section 33413(b) inclusionary housing
requirement on the project as part of the rezoning process.
Projects Assisted with Revolving Loan Funds
The rehabilitation loan program is funded with loan repayment proceeds received by the
City from existing rehabilitation loans. These loans were originally funded with CDBG
funds, and to comply with the CDBG requirements the participants are limited to very-
low and low income households. At the beginning of fiscal year 2006/7, the program
had an available fund balance of$1.4 million and outstanding loans totaling $3 million.
It is proposed that the rehabilitation loan program continue to be funded solely with
revolving loan repayment proceeds. It is further proposed that the program be
restructured to enhance the marketability and to simplify the implementation process.
The key modifications being proposed are:
1. The multi-family home component would be eliminated; only single-family home
ownership units would be included in the program. For the purposes of this
program, single-family homes are defined as developments that include between
one and four units.
2. The loan cap would be set at $75,000 per unit, with the potential to increase the
amount to $90,000 administratively. This limit was chosen because recent
applicants have been required to incur costs ranging from $60,000 to $90,000
per unit to comply with City Building Code standards.
3. Participants would be allowed to use the funds to include features designed to
improve the home's energy efficiency.
4. No repayment of principal or interest would be required until the home is resold
or refinanced to draw down cash.
5. The loans would bear 3% simple interest.
This City has been actively marketing the rehabilitation program since early in 2007. As
a result, 100% of the $1.4 million fund balance has been committed to loans. Going
forward it is projected that five loans will be funded per year. However, the number of
loans will ultimately be tied to the amount of debt service payments received, and the
actual amounts committed to each loan.
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The CRL imposes Section 33413(b) inclusionary housing production obligations on units
that receive redevelopment agency assistance to undertake substantial rehabilitation.
The rehabilitation loan program is not intended to trigger Section 33413(b) requirements,
nor are the units intended to fulfill production obligations, for the following reasons:
1. The loan program is not funded with Agency monies; and
2. The loan program is not intended to be used for projects that meet the
substantial rehabilitation test defined by the CRL. For reference purposes,
substantial rehabilitation is defined as 25% or more of the after-rehabilitation
value of the home.
Activities Funded with Affordable Housing Trust Funds and Housing Development
Funds
Funding Sources
The Affordable Housing Plan for the Pacific City Project requires Makallon Atlanta
Huntington Beach, LLC (Makallon) to contribute $20 million to the Housing Development
Fund. In return for receiving this payment, the Agency must fulfill a defined portion of
the Pacific City Project's affordable housing obligations.
The Inclusionary Housing Ordinance allows developers of projects with three to nine
units to pay a fee in lieu of producing the affordable housing units on site within a market
rate project. The in-lieu fee revenues will be contributed to the Affordable Housing Trust
Fund. The use of the monies in the Affordable Housing Trust Fund are guided by the
Inclusionary Housing Ordinance.
Pacific City Affordable Housing Obligations
The Affordable Housing Plan for the Pacific City Project requires the Agency to cause
117 very-low, low and median income units to be constructed or otherwise created within
the Merged Project Area.2 The Agency will use some or all of the Makallon payment to
fulfill the requirements identified in the Affordable Housing Plan.
2 The specific requirement is for 39 very-low, 39 low and 39 median income units distributed among
studio to three-bedroom units.
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Student Housing
The Agency has established an objective to assist in the development of 150 to 175
student dormitory rooms at Goldenwest College. It is proposed that the assistance costs
associated with producing these units be funded with Housing Development Fund and/or
Affordable Housing Trust Fund revenues.
In accordance with the Affordable Housing Trust Fund guidelines, 20% of the proposed
student housing units have been set aside for very-low income households, 30% of the
units are allocated to low income households, and the remaining units are proposed to
be provided to moderate income households.
For the purposes of this Affordable Housing Component, the student housing
development has been set at 150 units, and the public assistance cost is estimated at
$13 million. This equates to an average subsidy of$87,000 per unit.
Workforce Housing Program
The Agency has established an objective to provide home ownership opportunities to
households that cannot afford to purchase a home in Huntington Beach, but that do not
qualify for assistance under the statutory definitions of low and moderate income
households. To that end, the Agency would like to create a "Workforce Housing"
program.
The proposed Workforce Housing program will focus on providing home ownership
opportunities for City employees, school teachers in the local school districts, and major
employers with Huntington Beach that are interested in working with the Agency to
provide housing through a matching grant program. This program would provide down
payment assistance funds to the purchasers of existing homes within Huntington Beach.
Based on this structure, the proposed program will neither trigger nor fulfill Section
33413(b) inclusionary housing production requirements.
D. APPLICABLE AFFORDABLE HOUSING REQUIREMENTS
Applicable Housing Production Requirements
The affordable housing production requirements imposed on the Project Areas are
discussed in the following sections of this report.
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Replacement Housing Obligation
The Agency must fulfill the replacement housing obligations imposed by Section
33413(a). The Agency must replace, on a one-for-one basis, all units removed from the
low and moderate income housing stock as a result of Agency actions.
If an implementation plan includes projects that could result in the removal of low and
moderate housing units, the implementation plan must identify locations suitable for the
replacement of such housing. This Implementation Plan does not include any projects
or programs that would result in the removal of housing units from the low and moderate
income housing stock; therefore, no replacement housing obligations are considered in
this Implementation Plan.
Inclusionary Housing Production Obligation
The Agency is required to comply with the affordable housing production requirements
imposed by Section 33413(b). The requirements can be summarized as follows:
1. Subparagraph (1) requires at least 30% of all housing units developed by the
Agency to be low and moderate income housing subject to long-term income and
affordability covenants. Of this total, at least 50% of the units must be set-aside
for very-low income households. Units provided in Agency developed projects, in
excess of these requirements, cannot be used to fulfill the obligations identified in
Subparagraph (2).
2. Subparagraph (2) of Section 33413(b) imposes the following requirements:
a. At least 15% of all housing developed in the Project Areas, by parties
other than the Agency, must be low and moderate income units subject to
long-term income and affordability covenants. This requirement also
applies to Agency assisted substantial rehabilitation projects.3
b. At least 40% of the required low and moderate income units must be
affordable to persons and families of very-low income. The covenants for
the remaining units can be set at the low or the moderate income level.
C. These requirements are applied on a cumulative basis over time, rather
than on a project-by-project basis.
3 This includes private development, and development that receives Agency assistance but is not
developed by the Agency.
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The following sections of the Affordable Housing Component review past and anticipated
housing development activity in the Project Areas to quantify the Section 33413(b)
inclusionary housing production obligations. These sections also identify how the
Agency plans to fulfill the obligations during the Implementation Plan period and
throughout the remaining life of the Project Areas.
Housing Development in the Project Areas
The first component of the Huntington Beach Project (Merged) was adopted in 1982 and
the land use controls terminate for the entire area in 2024. The Southeast Coastal
Project was adopted in 2002 and the land use controls terminate in 2032. To assist in
identifying the Section 33413(b) inclusionary housing production obligations, the
residential development within the Project Areas must be identified for the period
between the Area's inception and the termination of the land use controls.
As shown in Table H-1, it is estimated that 2,634 residential units were developed within
the Huntington Beach Project (Merged) between 1982 and 2004. It is anticipated that
1,777 units will be developed between 2005 and 2024 (Table H-2). No residential
development has occurred in the Southeast Coastal Project since its inception in 2002,
and none is currently anticipated to occur through the end of the Project Areas' life.
Existing and Anticipated Inclusionary Housing Obligation
Based on the historical and projected residential development within the Project Areas,
the Section 33413(b) inclusionary housing production obligations are estimated in Table
H-3. The projected total obligations through the end of the Project Areas' life are:
1. Agency Developed Housing: The total obligation equals 50 units. Of this total, at
least 25 units must be allocated to very-low income households, and the balance
of the units must be set aside for low or moderate income households.
2. Other Residential: The total obligation equals 638 units. Of this total, at least
256 units must be set aside for very-low income households. The remaining
income restricted units can be provided to low or moderate income households.
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Existing and Projected Inclusionary Housing Production Units
Table H-4 lists the affordable housing projects that have already been developed, and
projects the future activity based on the projects recommended for implementation in this
Affordable Housing Component. Table H-4 only includes affordable housing unit
development that qualifies for Section 33413(b) inclusionary housing production credit.
The categories of units considered in Table H-4 are:
1. Agency Developed Housing
2. Agency Assisted Housing within Huntington Beach Project (Merged) (Completed)
3. City Inclusionary Units within Huntington Beach Project(Merged) (Completed)
4. Agency Assisted Housing Outside Huntington Beach Project(Merged)
(Completed)
5. City Inclusionary Units Outside Huntington Beach Project (Merged) (Completed)
6. Agency Covenant Purchase Outside Huntington Beach Project (Merged)
(Completed)
7. Agency Assisted Housing within Huntington Beach Project (Merged) (Executed
Agreements)
8. Agency Assisted Housing within Huntington Beach Project (Merged) (Proposed
in Plan)
9. Agency Assisted Housing Outside Huntington Beach Project(Merged) (Executed
Agreements)
10. Agency Assisted Housing Outside Huntington Beach Project(Merged) (Proposed
in Plan)
The inclusionary housing production units that have been produced to date, and those
projected to be produced in the future, are summarized in the following table:
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Very-Low Low/Mod
Timing Income Income Total
Agency Developed Units 82.0 82.0 164.0
Other Units
Projects Already Completed 133.5 284.5 418.0
Projects with Executed Agreements 42.0 31.5 73.5
Projects Proposed in this Plan 155.5 199.0 354.5
Total Other Units 331.0 515.0 846.0
Net Inclusionary Housing Production Surplus/ (Deficit)
The Agency is required to measure inclusionary housing production as of December 31,
2004, December 31, 2014, the end of the Huntington Beach Project (Merged) life in
2024 and the end of the Southeast Coastal Redevelopment Project in 2032. The results
of this analysis are detailed in Table H-5, and can be summarized as follows:
1. The Agency currently has a 114 unit surplus in Agency developed units (Section
33413(b)(1)). During this Implementation Plan period the Agency will be
exploring the opportunity for selling this project to a nonprofit developer. It is
possible that the conveyance, the imposition of new long-term income and
affordability covenants, and the substantial rehabilitation of the project may allow
the Agency to count these surplus units towards the fulfillment of the Section
33413(b)(2) production requirement for privately developed residential projects.
2. The Agency currently has a 47 surplus in the production of Section 33413(b)(2)
units. The Agency is anticipated to generate a production surplus through the
end of the Project Areas' life.
E. APPLICABLE DEPOSIT AND EXPENDITURE PROVISIONS
Set-Aside of Gross Property Tax Increment
The Project Areas are subject to the Section 33334.2 requirement to allocate 20% of the
gross property tax increment to affordable housing activities. The projections of the
required deposits into the Affordable Housing Fund are discussed in the following
sections of the Affordable Housing Component.
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Proportional Expenditures of Affordable Housing Fund Monies
The Project Areas is subject to the Section 33334.4 requirement that the Agency expend
Set-Aside funds in accordance with an income proportionality test and an age restriction
proportionality test. Section 33334.4 also provides redevelopment agencies with the
discretion to include other locally controlled public revenue sources in the proportionality
tests. These proportionality tests must be met between January 1, 2002 and December
31, 2014, and in 10-year increments through the termination of the Project Areas' life.
The results of the proportionality tests are presented in Table H-6, and described in the
following sections of the Affordable Housing Component.
Income Proportionality Test
The income proportionality test requires the Agency to expend Set-Aside funds in
proportion to the unmet housing needs that have been identified for the community
pursuant to Government Code Section 65584. The proportionality test used in this
Affordable Housing Plan is based on the 2006 RHNA figures prepared by SCAG. The
RHNA established the following unmet need for affordable housing in Huntington Beach:
Category Total Units % of Total
Very-Low Income: 454 37%
Low Income: 369 30%
Moderate Income: 414 33%
Total 1,237 100%
To comply with the Section 33334.4 requirements, the Agency must spend at least 37%
of its Set-Aside funds on projects and programs dedicated to very-low income
households, and no more than 33% of the funds on projects and programs dedicated to
moderate income households.4 Section 33334.4 provides the Agency with the flexibility
to allocate Set-Aside funds in any way that complies with the defined minimum for very-
low income expenditures and the defined cap for moderate income expenditures.
As shown in Table H-6, this Affordable Housing Component allocates 73% of the Set-
Aside and HOME Program funds to project and program expenditures earmarked for
very-low income households, 26% of the funds for low income households and 1% of the
funds for moderate income households. These expenditures comply with the income
targeting standards imposed by Section 33334.4.
4 Section 33334.3 provides redevelopment agencies with the discretion to include HOME funds revenues
in the proportionality testing.
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Age Restricted Housing Proportionality Test
Section 33334.4 also requires that the Agency cap assistance to age restricted housing
based on the percentage that very-low and low income households over the age of 65
represent of the total very-low and low income population in Huntington Beach. Based
on 2000 United States Census data, the very-low and low income senior citizen
population represents 30% of the very-low and low income population in Huntington
Beach.
The Affordable Housing Component allocates 30% of the Set-Aside and HOME Program
funds to senior citizen housing projects. Thus, the Agency is anticipated to fulfill the age
restricted housing expenditures test imposed by Section 33334.4.
Excess Surplus Calculation
The Project Areas are subject to the "excess surplus" requirements imposed by Section
33334.12. Excess surplus is defined as any unexpended and unencumbered funds in
the Affordable Housing Fund that exceeds the aggregate amount of Set-Aside funds
generated during the Project Areas' preceding four fiscal years. Based on the Section
33334.12 requirements, the Agency has three years to encumber any excess surplus
funds.
As illustrated in Table H-6, the Agency is not projected to incur an excess surplus
balance at any time during the current Implementation Plan cycle. It is not anticipated
that the Agency will experience an excess surplus balance throughout the Project Areas'
remaining life.
F. GOALS AND OBJECTIVES
The CRL requires that certain housing requirements be fulfilled during five- and 10-year
increments; and over the remaining Project Areas' life. Specifically, the inclusionary
housing production requirement must be met every ten years, and over the life of the
Project Areas. Comparatively, the proportionality tests must be achieved between
January 1, 2002 and December 31, 2014, and then again in 10-year increments
throughout the Project Areas' life.
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The Agency's primary goal is to comply with the affordable housing requirements
imposed by the CRL in a responsible manner. The affordable housing activities
identified in the Implementation Plan will be undertaken over the duration of the Project
Areas, and will explicitly assist in accomplishing the intent of the CRL in regards to the
provision of low and moderate income housing.
Affordable Housing Fund Resources and the Housing Program
This section of the Affordable Housing Component discusses the Agency's affordable
housing activities planned for the Implementation Plan period. Table H-7 projects the
Affordable Housing Fund deposits and expenditures anticipated to occur during each
year of the Implementation Plan period. These expenditures are then tied to estimates
of the number of affordable housing units projected to be assisted by the Agency.
Affordable Housing Fund Revenues
Table H-7 presents the estimated beginning balance in the Affordable Housing Fund,
and the projected future deposits into the Fund. The Affordable Housing Fund revenues
shown on Table H-7 include the following:
1. Twenty percent (20%) of the estimated gross property tax increment generated
within the Project Areas - the property tax increment projection was prepared by
the City's Finance Department.
2. HOME Program revenues—the fiscal years 2006/7 and 2007/8 are based on the
actual allocation received by the City. The allocation amount is held constant
thereafter.
3. Revolving loan fund payments—the amount of repayment funds varies from
year-to-year. this Affordable Housing Component is premised on the assumption
that the loan commitments in each year will be directly tied to the amount of the
debt service payments received by the Agency in that year.
4. Housing Development Fund revenues—The Agency has received $840,000 in
revenues to date. During the Implementation Plan period, the Agency is also
anticipated to receive $20 million in revenues from Makallon Atlanta Huntington
Beach, LLC in accordance with the timeline identified in the Affordable Housing
Agreement for the Pacific City Project.
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5. In-lieu fee revenues will be generated by three to nine unit residential projects
that choose to pay a fee in lieu of producing the affordable housing units required
by the Inclusionary Housing Ordinance. The amount of fee revenue that will be
generated is too speculative to predict at this time.
6. CDBG revenues— it is assumed that the City will continue to allocate $160,000 in
CDBG funds per year to the Agency to fund the costs associated with
administering the rehabilitation loan program.
7. Other revenues—this category includes miscellaneous loan payments,
administrative fees related to bonds issued by the Agency, ERAF repayment
from the unrestricted property tax increment fund and the Main-Pier loan
repayment. These amounts were all provided by the City's Finance Department.
8. Investment earnings, which are estimated based on a 4% interest rate, on the
average balance in the Affordable Housing fund during the previous year.
The Housing Program and Affordable Housing Fund Expenditures
Table H-7 also illustrates the costs anticipated to be incurred by the Agency from the
Affordable Housing Fund. These costs can be described as follows:
1. Operating costs include planning and administration; general operating
expenses; and rehabilitation loan program administration costs. These
projections were provided by the Agency staff.
2. The future program and project cost projections are based on the estimates
detailed previously in this Affordable Housing Component.
This Affordable Housing Component provides an illustrative example of how the
Affordable Housing Program could be financed over time. However, the timing and
specific amounts of the expenditures may be adjusted over time. Specific decisions on
each of these items will be made as part of the Agency's annual budget process.
Summary of Planned Affordable Housing Activity
Given the successful implementation of the proposed housing program, the Agency will
have accomplished the following:
1. The Agency will fulfill the Section 33413(b) inclusionary housing production
requirements for the 10-year period between fiscal years 2004/05 and 2013/14.
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2. By the end of fiscal year 2013/14, the Agency will have fulfilled all the Section
33413(b) inclusionary housing production requirements anticipated to be incurred
throughout the entire life of the Project Areas.
3. The Agency's expenditures of Set-Aside funds will comply with the proportionality
tests imposed by Section 33334.4.
4. The Agency will not experience excess surplus in any fiscal year throughout the
remaining Project Areas' life.
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TABLE H-1
RESIDENTIAL DEVELOPMENT WITHIN REDEVELOPMENT PROJECT AREAS(PREVIOUS PLAN PERIODS)'
IMPLEMENTATION PLAN-MID-TERM UPDATE
HUNTINGTON BEACH,CALIFORNIA
Units Built in
I. Project Construction Type Project Area Completion Year
Emerald Cove Agency Developed 164 1986
Private Housing Production New Construction 1,090 1984-1994
OCCHC Keelson Sub Rehab with Assistance 4 1994
Shelter for the Homeless-Barton#1 Sub Rehab with Assistance 4 1994
Shelter for the Homeless-Keelson Sub Rehab with Assistance 10 1994
OCCHC Koledo#1 Sub Rehab with Assistance 25 1996
Pacific Park Villas New Construction 38 1996
OCCHC Koledo#2 Sub Rehab with Assistance 8 1997
OCCHC Queens Sub Rehab with Assistance 10 1997
OCCHC Koledo#3 Sub Rehab with Assistance 10 2000
OCCHC Koledo#4 Sub Rehab with Assistance 6 2000
Plaza Almeria New Construction 42 2000
Interval House Sub Rehab with Assistance 6 2001
OCCHC Koledo#5 Sub Rehab with Assistance 5 2001
Ash Street Condos New Construction 6 2002
Bowen Court Senior Apartments New Construction 20 2002
Shelter for the Homeless-Barton#2 Sub Rehab with Assistance 4 2002
Private Housing Production New Construction 1,182 1994-2004
Total Housing Development 2,634
Agency Developed Other Total
II. Completion Year Units Units Units
Pre-1994 164 1,090 1,254
1994 18 18
1995 0 0
1996 63 63
1997 18 18
1998 0 0
1999 0 0
2000 58 58
2001 11 11
2002 30 30
2003 0 0
2004 1,182 1,182
Total Units Developed 164 2,470 2,634
1
Includes all units built by private entities, substantially rehabilitated units with Agency assistance, Agency assisted new
development and Agency developed units.
Prepared by: Keyser Marston Associates, Inc.
File name:HB Strategy_11_26_07:H-1
TABLE H-2
PROJECTED RESIDENTIAL DEVELOPMENT WITHIN THE REDEVELOPMENT PROJECT AREAS 1
HUNTINGTON BEACH PROJECT(MERGED): 2005-2024
SOUTHEAST COASTAL REDEVELOPMENT PROJECT: 2005-2032
IMPLEMENTATION PLAN-MID-TERM UPDATE
HUNTINGTON BEACH,CALIFORNIA
Construction Units Built in Completion
I. Project Type Project Area Year
Jamboree-Oakview#1 Sub Rehab with Assistance 5 2008
Jamboree-Oakview#2 Sub Rehab with Assistance 5 2008
Jamboree-Oakview#3 Sub Rehab with Assistance 4 2008
Oak View Acquisition/Rehab Projects Sub Rehab with Assistance 60 2007-2014
Bella Terra Residential New Construction 503 2007-2014
Pacific City Residential New Construction 516 2007-2014
Private Housing Production New Construction 500 2007-2014
Sea Colony(Hyatt Residential) New Construction 78 2007-2014
Sea Cove(Hyatt Residential) New Construction 106 2007-2014
Total Housing Production Units 1,777
Agency Developed Other Total
II. Estimated Completion Year Units Units Units
2005-2014 1,777 1,777
2015-2024 0 0
Southeast Coastal Redevelopment Project:
2025-2032 0 0
Total Units 1,777 1,777
1
Includes all units built by private entities, substantially rehabilitated units with Agency assistance,Agency assisted new
development and Agency developed units.
Prepared by: Keyser Marston Associates, Inc.
File name:HB Strategy_11_26_07:H-2
TABLE H-3
INCLUSIONARY HOUSING OBLIGATION
IMPLEMENTATION PLAN-MID-TERM UPDATE
HUNTINGTON BEACH,CALIFORNIA
Very-Low Income Low/Mod Income
Total Obligation Obligation Obligation
Agency Agency Agency
Developed Other Developed Other Developed Other
I. Year Units' Units 2 Units Units 2 Units ' Units 2
1982-1993 50 164 25 66 25 98
1994-2004 0 207 0 83 0 124
2005-2014 0 267 0 107 0 160
2015-2024 0 0 0 0 0 0
2025-2032 3 0 0 0 0 0 0
11. JTotals 50 638 25 256 25 382
1
See TABLE H-1 &TABLE H-2:At least 30%of the Agency owned units must be restricted as affordable units with at
least 50%of the units restricted to very-low income units, and the balance restricted to low and moderate income
units.
2
See TABLE H-1 &TABLE H-2: At least 15%of the units developed by public or private entities other than the
Agency must be restricted as affordable units with at least 40%of the units restricted to very-low income units, and
the balance restricted to low and moderate income units.
3 Only applies to the Southeast Coastal Project.
Prepared by: Keyser Marston Associates,Inc.
File name:HB Strategy_11_26_07:H-3
TABLE H-4
INCLUSIONARY HOUSING FULFILLMENT ANALYSIS
IMPLEMENTATION PLAN-MID-TERM UPDATE
HUNTINGTON BEACH,CALIFORNIA
Total Income Total Very-Low LIM
Covenant Restricted Units Countable Income Income
Project Term ' Produced Units 2 Units Units
I. Agency Developed(Completed)
Emerald Cove Perpetuity 164 164.0 82.0 82.0
II. Agency Assisted Within Project Area(Completed)
OCCHC Keelson 1994-2024 4 4.0 4.0 0.0
Shelter for the Homeless-Barton#1 1994-2024 4 4.0 4.0 0.0
Shelter for the Homeless-Keelson 1994-2024 4 4.0 4.0 0.0
OCCHC Koledo#1 1996-2026 10 10.0 10.0 0.0
OCCHC Koledo#2 1997-2027 8 8.0 8.0 0.0
OCCHC Queens 1997-2027 8 8.0 8.0 0.0
OCCHC Koledo#3 2000-2060 10 10.0 10.0 0.0
OCCHC Koledo#4 2000-2060 10 10.0 10.0 0.0
Interval House 2001-2029 6 6.0 0.0 6.0
OCCHC Koledo#5 2001-2060 5 5.0 5.0 0.0
Bowen Court Senior Apartments 2002-2062 20 20.0 0.0 20.0
Shelter for the Homeless-Barton#2 2002-2030 4 4.0 4.0 0.0
Total 93 93.0 67.0 26.0
III. City Inclusionary Units Within Project Area(Completed)
Pacific Park Villas 1996-2026 25 25.0 0.0 25.0
Ash Street Condos 2002-2062 6 6.0 0.0 6.0
Total 31 31.0 0.0 31.0
IV. Agency Assisted Outside Project Area(Completed)
OCCHC PSS 1994-2024 9 4.5 4.5 0.0
Bridges Apartments-Nichols 1997-2027 80 40.0 0.0 40.0
Habitat for Humanity-Ronald Road 1997-2027 3 1.5 1.5 0.0
Habitat for Humanity-Yorktown 2001-2060 3 1.5 1.5 0.0
Fountains Senior Apartments 2003-2062 80 40.0 27.5 12.5
Main Place Apartments 2004-2033 26 13.0 0.0 13.0
Total 201 100.5 35.0 65.5
V. City Inclusionary Units Outside Project Area(Completed)
Greystone Keys 1993-2023 23 11.5 0.0 11.5
Cape Ann 2000-2030 146 73.0 0.0 73.0
The Promenade 2000-2030 80 40.0 0.0 40.0
The Tides 2004-2034 12 6.0 0.0 6.0
Total 261 130.5 0.0 130.5
Prepared by: Keyser Marston Associates, Inc.
File name:HB Strategy_11_26_07:H-4 Page 1 of 3
TABLE H-4
INCLUSIONARY HOUSING FULFILLMENT ANALYSIS
IMPLEMENTATION PLAN-MID-TERM UPDATE
HUNTINGTON BEACH,CALIFORNIA
Total Income Total Very-Low L/M
Covenant Restricted Units Countable Income Income
Project Term Produced Units 2 Units Units
VI. Agency Covenant Purchase Outside Project Area(Completed)
Sea Aire Apartments 1996-2026 36 18.0 0.0 18.0
Sher Lane Apartments 2003-2028 66 33.0 8.0 25.0
Huntington Pointe Apartments 2003-2061 104 52.0 10.5 41.5
Hermosa Vista Apartments 2004-2063 88 44.0 13.0 31.0
Total Potential Units 294 147.0 31.5 115.5
Actual Countable Units 3 63.0 31.5 31.5
Total Units Prior to 1211104 880 418.0 133.5 284.5
Vll. Agency Assisted Within Project Area(Executed Agreements)
Jamboree-Oakview#1 60 Years 5 5.0 4.0 1.0
Jamboree-Oakview#2 60 Years 5 5.0 5.0 0.0
Jamboree-Oakview#3 60 Years 4 4.0 4.0 0.0
Total 14 14.0 13.0 1.0
Vill. Agency Assisted&City Inclusionary Units Within Project Area(Proposed in Plan)
Oak View Acquisition/Rehab Projects 60 Years 60 60.0 33.0 27.0
Bella Terra Residential 60 Years 51 51.0 0.0 51.0
Student Housing 60 Years 150 150.0 30.0 120.0
Total 261 261.0 63.0 198.0
Vlll. Agency Assisted Outside Project Area(Executed Agreements)
Beachview Villas SRO 5 2006-2066 106 53.0 23.5 29.5
Collette's-Cypress 60 Years 4 2.0 2.0 0.0
Collette's-Glencoe 60 Years 4 2.0 2.0 0.0
Habitat-Delaware 60 Years 1 0.5 0.5 0.0
7912 Newman Street 60 Years 2 1.0 0.0 1.0
Ellis/Patterson 60 Years 2 1.0 1.0 0.0
Total 119 59.5 29.0 30.5
IX. Agency Assisted Outside Project Area(Proposed in Plan)
Huntington Gardens 60 Years 185 92.5 92.5 0.0
Habitat-Ellis& Beach 60 Years 2 1.0 0.0 1.0
Total 187 93.5 92.5 1.0
X. Total Units Anticipated to be Produced 581 428.0 197.5 230.5
Prepared by: Keyser Marston Associates, Inc.
File name:HB Strategy_11_26_07:H-4 Page 2 of 3
TABLE H-4
INCLUSIONARY HOUSING FULFILLMENT ANALYSIS
IMPLEMENTATION PLAN-MID-TERM UPDATE
HUNTINGTON BEACH,CALIFORNIA
Total Income Total Very-Low LIM
Covenant Restricted Units Countable Income Income
Project Term Produced Units 2 Units Units
1
Projects subject to agreements executed prior to January 1, 2002 must have covenants that run at least as long as the land use
controls imposed by the Redevelopment Plan (2024). The covenants for projects from 2002 forward must run for at least 55 years
for rental projects and 45 years for ownership projects.
2
Units located within the Merged Project Area can be counted on a 1:1 basis; 50%credit is applied to units located outside the
Merged Project Area. Prior to 1994, units outside the Merged Project Area could not be used to fulfill the inclusionary housing
production requirements.
,3 At least 50%of units for which covenants are purchased, but substantial rehabilitation is not performed, must be set-aside for very-
low income households.
4 The total excludes the Agency Developed units. Those units must be tracked separately.
5 The project received density bonus benefits, but did not receive Agency financial assistance.
Prepared by: Keyser Marston Associates, Inc.
File name:HB Strategy_11_26_07:H-4 Page 3 of 3
TABLE H-5
INCLUSIONARY HOUSING FULFILLMENT ANALYSIS SUMMARY
IMPLEMENTATION PLAN-MID-TERM UPDATE
HUNTINGTON BEACH,CALIFORNIA
Total Countable Very-Low Income LOW/Mod Income
I. Agency Developed Inclusionary Housing Surplus Units Units Units
Total Inclusionary Housing Fulfillment 1 164 82 82
(Less) Inclusionary Housing Obligation 2 50 25 25
Inclusionary Housing Surplus/(Deficit) 114 57 57
Total Countable Very-Low Income Low/Mod Income
II. Current Inclusionary Housing Surplus/(Deficit) Units Units Units
Total Inclusionary Housing Fulfillment t 418.0 133.5 284.5
(Less) Inclusionary Housing Obligation(1982-2004) 2 371.0 149.0 222.0
Inclusionary Housing Surplus/(Deficit) 47.0 (15.5) 62.5
Total Countable Very-Low Income Low/Mod Income
III. 10 Years Inclusionary Housing Surplus/(Deficit) Units Units Units
Total Inclusionary Housing Fulfillment ' 846.0 331.0 515.0
(Less) Inclusionary Housing Obligation(1982-2014) 2 638.0 256.0 382.0
Inclusionary Housing Surplus I(Deficit) 208.0 75.0 133.0
Total Countable Very-Low Income Low/Mod Income
IV. Life of Plan Inclusionary Housing Surplus/(Deficit) Units Units Units
Total Inclusionary Housing Fulfillment ' 846.0 331.0 515.0
(Less) Inclusionary Housing Obligation (1982-2032) 2 638.0 256.0 382.0
Inclusionary Housing Surplus/(Deficit) 208.0 75.0 133.0
See TABLE H-4.
2 See TABLE H-3.
Prepared by: Keyser Marston Associates, Inc.
File name:HB Strategy_11_26_07:H-5
TABLE H-6
EXCESS SURPLUS&PROPORTIONALITY TESTS
IMPLEMENTATION PLAN-MID-TERM UPDATE
HUNTINGTON BEACH,CALIFORNIA
1/1/02-
6/30/06 FY 2006/7 FY 200718 FY 200819 FY 2009/10 FY 2010/11 FY 2011/12 FY 2012/13 FY 2013/14 FY 2014/15
I. Excess Surplus Analysis
Beginning Balance-Set-Aside Funds $8,236,353 $10,559,869 $7,716,929 $9,803,975 $2,989,923 $5,077,269 $6,963,860 $8,779,560 $10,610,269
Revenues
Housing Set-Aside Funds $3,360,000 $3,217,000 $3,281,340 $3,346,967 $3,414,906 $3,482,185 $3,551,828 $3,622,864 $3,695,321
Total Miscellaneous Revenues 70,000 801,000 1,363,000
Interest Earnings 450,000 502,530 417,048 343,047 286,466 133,892 114,590 185,855 256,003
Total Revenues $3,880,000 $4,520,530 $5,061,388 $3,690,014 $3,701,372 $3,616,077 $3,666,418 $3,808,719 $3,951,324
Expenditures-Set-Aside Funds
Planning and Administration $177,273 $321,253 $337,316 $354,181 $371,891 $390,485 $410,009 $430,510 $452,035
Operating Expenses 114,211 173,500 182,175 191,284 200,848 210,890 221,435 232,507 244,132
Project/Program Expenditures 1,265,000 6,868,717 2,454,851 9,958,601 1,041,289 1,128,110 1,219,273 1,314,994 1,415,502
Total Expenditures-Set-Aside Funds $1,556,484 $7,363,470 $2,974,342 $10,504,066 $1,614,027 $1,729,486 $1,850,717 $1,978,011 $2,111,669
Ending Balance $10,559,869 $7,716,929 $9,803,975 $2,989,923 $5,077,269 $6,963,860 $8,779,560 $10,610,269 $12,449,924
Maximum Allowable Balance $10,349,679 $11,657,443 $12,637,775 $13,205,307 $13,260,213 $13,525,398 $13,795,886 $14,071,783 $14,352,198
Excess Surplus $210,190 $0 $0 $0 $0 $0 $0 $0 $0
Prepared by:Keyser Marston Associates,Inc.
File name: HB Strategy_11_26_07; H-6 Page 1 of 2
TABLE H-6
EXCESS SURPLUS&PROPORTIONALITY TESTS
IMPLEMENTATION PLAN-MID-TERM UPDATE
HUNTINGTON BEACH,CALIFORNIA
1/1/02-
6/30/06 FY 2006/7 FY 2007/8 FY 2008/9 FY 2009/10 FY 2010/11 FY 2011/12 FY 2012/13 FY 2013/14 FY 2014/15
II. Set-Aside&HOME Program Expenditures(Proportionality Tests)
Completed Projects
Very-Low Income $4,859,248
Low Income $1,479,086
Moderate Income $342,466
Future Projects
Very-Low Income $3,892,448 $3,272,727 $1,718,182 $10,063,125 $1,116,281 $1,172,095 $1,230,700 $1,292,235 $1,356,847
Low Income 221,552 3,557,273 1,431,818 590,625 620,156 651,164 683,722 717,908 753,804
Moderate Income 0 0 0 0 0 0 0 0 0
Total Expenditures $6,680,800 $4,114,000 $6,830,000 $3,150,000 $10,653,750 $1,736,438 $1,823,259 $1,914,422 $2,010,143 $2,110,651
Income Proportionality Test Threshold Actual Age Restricted Housing Test Threshold Actual
Very-Low Income 37% 73.1% Maximum Exps-Age Restricted Housing 30.0% 29.0%
Low Income 30% 26.1% Minimum Exps-No Age Restrictions 70.0% 71.0%
Moderate Income 33% 0.8%
Prepared by:Keyser Marston Associates,Inc.
File name:HB Strategy_11_26_07; H-6 Page 2 of 2
TABLE H-7
CASH FLOW PROJECTION-AFFORDABLE HOUSING FUNDS
IMPLEMENTATION PLAN-MID-TERM UPDATE
HUNTINGTON BEACH,CALIFORNIA
FY 2006/7 FY 2007/8 FY 2008/9 FY 2009/10 FY 2010/11 FY 2011/12 FY 2012/13 FY 2013/14 FY 2014/15
I. Beginning Balance $11,841,487 $13,285,003 $7,567,414 $9,584,946 $4,738,379 $1,956,209 $3,773,286 $5,519,471 $7,280,665
II. Revenues
Housing Set-Aside Revenue 2 $3,360,000 $3,217,000 $3,281,340 $3,346,967 $3,414,906 $3,482,185 $3,551,828 $3,622,864 $3,695,321
HOME Funds 3 800,000 695,149 695,149 695,149 695,149 695,149 695,149 695,149 695,149
Revolving Loan Repayments 4 0 100,000 400,000 420,000 441,000 463,050 486,203 510,513 536,038
Housing Development Fund 5 0 0 0 15,000,000 5,000,000 0 0 0 0
CDBG 6 160,000 160,000 160,000 160,000 160,000 .160,000 160,000 160,000 160,000
Other Revnue7 70,000 801,000 1,363,000 0 0 0 0 0 0
Interest on Available Balances 450,000 502,530 417,048 343,047 286,466 133,892 114,590 185,855 256,003
Total Revenues $4,840,000 $5,475,679 $6,316,537 $19,965,163 $9,997,521 $4,934,276 $5,007,769 $5,174,381 $5,342,511
III. Operating Expenses
Planning&Administration 9 $257,273 $390,768 $406,831 $423,696 $441,405 $460,000 $479,524 $500,025 $521,550
General Operating Expenses 114,211 173,500 182,175 191,284 200,848 210,890 221,435 232,507 244,132
Rehab Loan Program Administration Costs 160,000 160,000 160,000 160,000 160,000 160,000 160,000 160,000 160,000
Bond Debt Service
Total Operating Expenses $531,484 $724,268 $749,006 $774,980 $802,253 $830,890 $860,959 $892,531 $925,682
IV. Funds Available for Projects/Programs $16,150,003 $18,036,414 $13,134,946 $28,775,129 $13,933,647 $6,059,595 $7,920,096 $9,801,321 $11,697,494
V. Proposed Protects/Programs
Jamboree-Oakview#1 $1,285,000
Jamboree-Oakview#2 1,580,000
Jamboree-Oakview#3 1,249,000
Oakview Community Organizing(CHDO) 50,000
Habitat-Ellis&Beach 830,000 0 0 0 0 0 0 0
Oak View Projects'() 6,000,000 3,150,000 1,653,750 1,736,438 1,823,259 1,914,422 2,010,143 2,110,651
Huntington Gardens(VL Income-Senior)" 0 0 9,000,000 4,800,000 0 0 0 0
Single-Family Rehabilitation Loan Program 12 1,400,000 300,000 315,000 330,750 347,288 364,652 382,884 402,029
Single-Family Emergency Grant Program" 100,000 100,000 105,000 110,250 115,763 121,551 127,628 134,010
Workforce Housing 14 840,000 0 0 5,000,000 0 0 0 0
Student Housing 15 0 0 12,963,000 0 0 0 0 0
Total Proposed Projects/Programs $2,865,000 $10,469,000 $3,550,000 $24,036,750 $11,977,438 $2,286,309 $2,400,625 $2,520,656 $2,646,689
VI. Ending Balance $13,285,003 $7,567,414 $9,584,946 $4,738,379 $1,956,209 $3,773,286 $5,519,471 $7,280,665 $9,050,805
Prepared by: Keyser Marston Associates, Inc.
File name:HB Strategy_11_26_07;H-7 Page 1 of 2
TABLE H-7(CONTINUED)
CASH FLOW PROJECTION-AFFORDABLE HOUSING FUNDS
IMPLEMENTATION PLAN-MID-TERM UPDATE
HUNTINGTON BEACH,CALIFORNIA
Footnotes:
1 Comprised of the following Fund Balances:Set-Aside-$8.2 million;HOME Funds-$1.4 million;Revolving Loan Payments-$1.4 million;and Housing Development Fund-$840,000.
2 Actual revenues for FY 2006/7. The projections for FY 2007/8 through FY 2013/14 amount are based on Agency projections. The FY 2014/15 amount represents a 2%increase.
3 Actual revenues for FY 2006/7. The amount is increased by 0.0%annually thereafter.
4
The loan portfolio has an outstanding balance of$3.0 million. The loans provided in the first year are based on the Fund Balance. The loans funded each year thereafter will not exceed the
repayment revenues received by the Agency.
5 This revenue source is developer payments made to the Agency in return for the Agency fulfilling the developer's inclusiona housing obligations.
P p Y 9 Y� 9 Y 9 p rY 9 9
6 Limited to the revenues that will be allocated to Rehabilitation Loan Program administration. Actual revenues for FY 2006/7. The amount is increased by 0.0%annually thereafter.
Includes:Loan Payments;Administrative Cost Bonds;Miscellaneous;ERAF Repayment from 80%Funds;and Main-Pier Loan Repayment.
6 Interest earnings estimated based on a 4%on the average of the Beginning and Ending Balance in each year.
9 Actual costs for FY 2006/7. The projections for FY 2007/8 through FY 2013/14 amount are based on Agency projections. The FY 2014/15 amount represents a 5.0%increase.
10 The projections are based on a subsidy cost of$300,000/unit in FY 2007/8 escalated at 5%annually thereafter. The assistance is funded with Set-Aside and HOME funds
11 The projections are based on a subsidy cost of$75,000/unit. The assistance is allocated as follows:$9.0 million in Set-Aside funds and$4.8 million in Housing Development Funds.
12 The projections are based on an average subsidy cost of$60,000/unit in FY 2006/7 escalated at 5%annually thereafter.
13 The projections are based on an average subsidy cost of$10,000/unit in FY 2006/7 escalated at 5%annually thereafter.
14
Comprised of existing homes sold to households at incomes above 120%of the County Median Income. The funding source is the City's Housing Development Fund and the average assistance
is set at$100,000/unit.
15 Average subsidy estimated at$127,600/unit for very-low income units;$106,333/low income unit;and$58,000/moderate income unit.
Prepared by:Keyser Marston Associates,Inc.
File name:HB Strategy_11_26_07;H-7 Page 2 of 2
RCA ROUTING SHEET
INITIATING DEPARTMENT: Economic Development
SUBJECT: Approval of the Mid-Term Update Report for the
Affordable Housing Component (2005-2009)
COUNCIL MEETING DATE: December 17, 2007
.._. _ _.
RCA ATTACHMENTS STATUS
Ordinance (w/exhibits & legislative draft if applicable) Attached ❑
Not Applicable
Resolution (w/exhibits & legislative draft if applicable) Attached ❑
Not Applicable
Tract Map, Location Map and/or other Exhibits Attached ❑
Not Applicable
Contract/Agreement (w/exhibits if applicable) Attached ❑
(Signed in full by the City Attorney) Not Applicable
Subleases, Third Party Agreements, etc. Attached ❑
(Approved as to form by City Attorney) Not Applicable
Certificates of Insurance (Approved by the City Attorney) Attached ❑
Not Applicable
Fiscal Impact Statement (Unbudgeted, over $5,000) Attached ❑
Not Applicable
Bonds (If applicable) Attached ❑
Not Applicable
Staff Report (if applicable) Notached
t Applicable ®❑
Commission, Board or Committee Report (If applicable) Attached ❑
Not Applicable
Findings/Conditions for Approval and/or Denial Attached ❑
Not Applicable
EXPLANATION FOR MISSING ATTACHMENTS''
REVIEWED RETURNED FORWARDED.;
Administrative Staff ( ) ( )
Deputy City Administrator Initial
City Administrator Initial
City Clerk ( )
EXPLANATION FOR RETURN OF ITEM:
(Below Spaoe For City Clerk's Use QtW
RCA Author: Fritzal 1519
AB m ,leentation an
Affarae� ®using Strtey
Huntington Beach City Council
December 17, 2007
:a Affordable Housing
Accomplishments
----
® The Agency has assisted over 1,000
affordable housing units since the late 1980's
Nearly 500 affordable units have been
developed under the City's Inclusionary
Housing Policy
December 17,2007 Keyser Marston Associates Page 2
h -
Affordable Housing
Requirements
® Production and replacement of low and moderate
income housing.
® Set-aside and expenditure of 20% of gross tax
increment to increase, improve and preserve low
and moderate income housing.
♦ Preparing reports on how the responsibilities will be
met.
December 17,2007 Keyser Marston Associates Page 3
Replacement Housing
Requirements
® The Agency must identify units proposed to be
removed by Agency action and prepare a plan to
replace the units.
_- ® The Agency has fulfilled all the replacement
housing obligations for all units removed in the
past.
® No units are currently anticipated to be removed
by Agency action.
December 17,2007 Keyser Marston Associates Page 4
2
Inclusi®nary Housing
Production Requirements
The Agency must identify all residential
development in the Project Areas.
® In 10-year intervals, income restricted units
subject to covenants must be developed or
substantially rehabilitated.
® The Agency and/or the City must be
beneficiaries to the income restriction covenants.
December 17,2007 Keyser Marston Associates Page 5
Inclusionary Housing
Production Obligations
Agency Developed Housing
Development to Date 164
Production Obligation:
Very-Low Income 25
Low/Moderate Income 25
Total Production Obligation 50
December 17,2007 Keyser Marston Associates Page 6
3
{ ° Inclusi®nary Housing Units
�4 Production
Agency Developed Housing
Very-Low Low/Moderate 'Total
Income Income
Obligation 25 25 50
Fulfillment 164 0 164
Surplus 139 (25) 114
December 17,2007 Keyser Marston Associates Page 7
Inclusionary Housing
Production Obligations
Private /Agency Assisted Development
Development to Date 2,470
Production Obligation:
Very-Low Income 1.49
Low/Moderate Income 222
Total Production Obligation 371
December 17,2007 Keyser Marston Associates Page 8
4
Inclusionary Housing Units
Production
Private /Agency Assisted Development
Very-Low Low/Moderate Total
Income Income
Obligation 149.0 222.0 371.0
Fulfillment 133.5 284.5 418.0
Surplus (15.5) 62.5 47.0
December 17,2007 Keyser Marston Associates Page 9
M --
Proportionality Tests
January 2002 — December 2014
® Income At least 37% of funds must be
spent on very-low and no more than 3 3% on
moderate income.
-_-- Plan calls for 73% of Set-Aside and HOME
funds to be spent on very-low income; 26%
for low income and 1% for moderate income.
December 17,2007 Keyser Marston Associates Page 10
5
Proportionality Tests
January 2002 — December 2014
-- ® Age Restrictions — No more than 30% of Set-
Aside funds may be spent on age restricted
housing.
® Plan calls for 30% of Set-Aside funds to be
spent on age restricted housing.
December 17,2007 Keyscr Marston Associates Page I
Excess Surplus Calculations
® Excess Surplus calculations — No more than
than the sum of four years of Set-Aside funds
deposits can be unencumbered.
® The Agency is not projected to incur an
excess surplus balance at any time during the
Implementation Plan cycle.
December 17,2007 Keyser Marston Associates Page 12
6
Covenant Requirements
4, Redevelopment law requires covenants of at
least 45 years for ownership units and 55
years for rental units
® The Agency and the City's Inclusionary
Housing Ordinance currently impose 60-year
covenants
December 17,2007 Keyser Marston Associates Page 13
Energy Efficiency
All Agency sponsored projects should include
sustainable design features — options include:
® Energy and water reduction strategies
® Building design that maximizes sunlight for heat and
light; and maximizes air flow for natural cooling
® Solid waste reduction technologies
-- ® Storm water mitigation
w Gray water recycling
December 17,2007 Keyser Marston Associates Page 14
7
Available Funding Sources
® Set-Aside Funds
® HOME Funds
® Inclusionary Housing In-Lieu Fees
* Revolving Loan Funds
® Community Development Block Grants
December 17,2007 Keyser Marston Associates Page 15
Set-Aside Funds
® Beginning fund balance in 2007/8 was $10.6
million
-= ® Deposits equal approximately $3.2 million
per year
® Future growth projected at 2% per year
® Can be used to assist very-low, low and
moderate income households
December 17,2007 Keyser Marston Associates Page 16
g
HOME Funds
v • The City receives approximately $700,000
per year from HUD
• Funds can be used to assist very-low and low
- - income households
"=-_= • 15% of funds must be provided to
Community Housing Development
Organizations (CHDO's)
December 17,2007 Keyser Marston Associates Page 17
Inclusionary Housing Fees
t
® The Agency will receive $20 million in
- Housing Development Fund Revenues
during the Implementation Plan period.
• Inclusionary housing in-lieu fees can be paid
for three to nine unit projects. Revenues are
- uncertain at this time.
December 17,2007 Keyser Marston Associates Page 18
9
Other Funding Sources
® Revolving loan proceeds — $3.0 million in
--- outstanding loans are used to fund the
- ongoing rehabilitation loan program
CDBG - approximately $160,000 per year is
allocated to rehabilitation loan administration
December 17,2007 Keyser Marston Associates Page 19
Affordable Housing Activities
1 Implementation Plan Period
�r- m ==
° ® Acquisition and rehabilitation projects
® Mixed-use development on commercial
corridors
® Rehabilitation loans
® Workforce housing
December 17,2007 Keyser Marston Associates Page 20
10
1
Oakview Neighborhood
® Work with the Oakview Task force to
-- -. coordinate activities.
Work with Oakview Revitalization
_ Partnership to attract local farmers market.
® Work to attract business opportunities to the
neighborhood.
December 17,2007 Keyser Marston Associates Page 21
Oakview Neighborhood
j
e Focus acquisitions on contiguous parcels.
= A Work with CHDO's to maximize use of HOME
funds.
• Rehabilitate to decent, safe & sanitary conditions.
® Consider creating a development site for future
mixed-income development with sustainable design
features.
December 17,2007 Keyser Marston Associates Page 22
11
Huntington Gardens
180 unit HUD sponsored senior citizen
-- project.
The project is "at risk" of converting to
market rents.
Work with a nonprofit developer to acquire
and rehabilitate the project, and extend the
income and affordability covenants.
December 17,2007 Keyser Marston Associates Page 23
Mixed-Use Development on
_r
Commercial Corridors
o New development anticipated to be
undertaken by private developers.
o Opportunities for higher intensity
development may be available with the SB
181.8 density bonus. This requires an
affordable housing component.
® Agency may require Section 33413
inclusionary requirements for rezoning.
December 17,2007 Keyser Marston Associates Page 24
12
t Rehabilitation Loan Program
® Limit program to single-family homes —
which are defined as one to four units.
® Set the loan cap at $75,000 per unit with
administrative ability to increase to $90,000.
== ® Allow funds to be used to include features
designed to improve energy efficiency.
December 17,2007 Keyser Marston Associates Page 25
.f
Emergency Grant Program
x___t
s Increase limit to $10,000 — Goal to provide
10 grants per year
® Allow use for paint/fix-up projects
Continue funding with revolving loan
repayment proceeds.
_-_ December 17,2007 Keyser Marston Associates Page 26
13
Pacific City Affordable
Housing Requirements
® The Agency is required to fulfill the Pacific
City Project requirements to provide 117
_- very-low, low and median income units.
® Provide assistance to create 150 to 175 units
-- adjacent to Goldenwest College.
• 20% of the units must be provided to very-
low income households and 30% of the units
are allocated to low income households.
December 17,2007 Keyser Marston Associates Pap 27
Workforce Housing
• The Agency will create a program for households
that cannot afford a home in Huntington Beach, but
-_= are above moderate income.
• The program will focus on City employees, school.
teachers in the local school districts and major
employers in Huntington Beach.
• The program will provide down payment assistance
to home buyers.
December 17,2007 Keyser Marston Associates Page 28
14
Summary — Implementation flan
Requirements 2004/5 — 2013/14
• The Agency will fulfill all the Section 33413
inclusionary housing production
requirements.
=- • The Agency's expenditures will comply with
the proportionality tests imposed by Section
33334.4.
• The Agency will not experience excess
surplus.
December 17,2007 Keyser Marston Associates Page 29
15