via email: [email protected] PLANNING ARCHITECTURE INTERIOR DESIGN May 12, 2010
Nancy Muller Florida Housing Finance Corporation 227 North Bronough Street, Suite 5000 Tallahassee, Florida 32301
RE: FORUM’S COMMENTS ON “FLORIDA HOUSING DISCUSSION POINTS FOR CONSIDERATION FOR THE 2011 UNIVERSAL APPLICATION CYCLE”
Dear Nancy,
I attended the First Rule Development Workshop as well as a CAHP sub-committee meeting on April 29th in Orlando, both of which I found to be very informative and interesting. The meetings certainly gave us a much better feel for the Universal Application process and the difficulties FHFC faces moving forward.
FORUM is an established industry leader in multifamily housing design, and we have been actively designing multi-family projects for 24 years throughout the country, although we are primarily focused in Florida. More than half of our 320+ multifamily developments are affordable projects. We work closely with many of Florida’s affordable housing developers, contractors and local housing authorities and we can provide constructive comments to some of the Discussion Points from this position of experience that we hope you will find valuable and insightful.
Please find the attached comments gathered from the experienced staff at FORUM presented, per your request, for your consideration in establishing criteria for the revised 2011 Universal Application and beyond. Should you have any questions about our comments, or should you like any additional input, we are happy to assist you in any way that we can. Please feel free to contact me and thank you for the opportunity to be a part of this process.
Sincerely, FORUM ARCHITECTURE & INTERIOR DESIGN, INC.
Karen V McIntyre Architect / Project Manager [email protected] cc James B. Black Andrew Roark
C:\DOCUMENTS AND SETTINGS\KAREN\MY DOCUMENTS\FLORIDAHOUSINGDISCUSSIONPOINTS-050710-FORUMSCOMMENTS (4).DOCX
FORUM ARCHITECTURE & INTERIOR DESIGN, INC.
745 Orienta Avenue, Suite 1121, Altamonte Springs, FL 32701 P(407) 830-1400, F(407) 830-4143, AA0002731 www.forumarchitecture.com Discussion Points for Consideration for the 2011 Universal Application Cycle Comment [F1]: We are concerned with the ramifications of mandating certain materials over As we prepare to consider changes to the state’s Qualified Allocation Plan, Consolidated Plan, Annual others without substantiation. Implementing construction standards separate from code Action Plan, applicable Rule Chapters and Universal Application Cycle documents, Florida Housing is requirements and market forces will result in a per working to develop a vision of what type of housing we should be financing in the current climate and project increase in construction costs. These coming years. This document provides a preliminary overview of our initial thoughts for public negative impacts vary regionally throughout the discussion. The public discussion of our vision and priorities will in turn provide guidance for state, for example: CMU exterior construction represents approximately 8-15% greater cost in the implementation details, to be discussed as the rule development process continues. Some discussion Orlando area compared to equivalent wood points may not be fully implemented in 2011, but are here to lay grounds for future consideration. construction, but the increase is smaller in South Florida and greater in North Florida.
Traditional wood frame construction, built to Vision current codes and with a well designed exterior envelope, complies with the most stringent • requirements and offers superior impact resistance Florida Housing envisions that new construction developments that we finance should be located to concrete masonry. Current model energy codes in areas that have a high level need for affordable rental housing at the income levels being also favor wood-frame construction and have served by Florida Housing properties, particularly as specified by investor interest. shown diminished preference for mass walls.
Wood frame apartments comprise 95% of the 144 • Florida Housing believes that the ideal new construction development is one that: affordable housing communities designed by Forum o Is built with strong construction materials, such as concrete, that enable the building to be in Florida over the past 15 years. Wood viable for many years; construction allows infinite opportunity for expression of aesthetics and local vernacular design. o Is certified as green and energy efficient to ensure that all green and energy aspects of the Efficiencies in concrete and masonry structures, in property are working synergistically to provide a higher quality, sustainable development comparison, are only achieved by strict adherence (both in terms of materials and operating costs) over time; to limiting modules and structural requirements. o Provides units that can be easily visited by persons with disabilities by incorporating Comment [F2]: We agree that construction features that allow these persons to come and go more easily; should continue trending towards green and energy efficient, but the standards should continue to o Is located near to mass transit, particularly rail transit that is and will be developed into emerge and be applied consistently to all the future; construction. We do not understand why FHFC o Is near services and jobs, promoting walkability when possible; would seek to push affordable housing into a o Provides some ELI units for persons with special needs who are receiving supportive completely separate realm of requirements than the Florida Building Code otherwise requires. Would it services and referred by a partnering supportive services agency; and not be more beneficial to lobby for such o Is developed and maintained by strong developers and management companies. improvements in the statewide codes and allow affordable housing to track along with them? • Florida Housing believes that additional financing should be targeted to preserve existing Certification requires substantial increases in the affordable rental properties that are at risk because of: design/soft costs of the development budget, but o Loss due to affordability restrictions ending; provides minimal benefit. The construction process currently includes a system of checks and balances o Loss as a result of deterioration (causing, for example, HUD to pull the project based that ensures the design plans and specifications are rental assistance and ‘decommission’ the property); or reviewed for conformance with applicable o Deterioration resulting in poor living conditions for tenants. requirements and that the construction adheres to the approved design plans. The design also includes energy code calculations. Certification is primarily a • In addition to the targets above, Florida Housing’s preservation priorities continue to be focused benefit to the third party entity, both for liability on ensuring that federal subsidies to support extremely low income residents (for instance, and as a revenue stream. through project based rental assistance) are saved and maintained over the long term. Comment [F3]: Focus on point scoring for systems and products that reduce tenant energy costs to allow developers to initially raise rents to help offset the expense of the upgrades discussed in Discussion Points for 2011 UAC Page 2 this document, with phased-in reduction in effective April 29, 2010 rents (via lower energy costs) for future tenants. Comment [F4]: All multifamily projects are • Additional preservation priorities include the following: currently required to comply with the Fair Housing Design Guidelines, which already set forth project accessibility requirements specifically targeting visitability by disabled persons in units designated as “covered” by the guidelines. o Properties financed are part of a local government’s broader priorities for such things as community revitalization or maintenance of affordable housing in a high income/service/job/amenity area; o The property currently serves tenants with special needs and/or those with extremely low incomes who have rents commensurate with their ability to pay (and will continue to do so after refinancing/rehab).
• Florida Housing believes that, in addition to meeting one or more of the priorities above, the ideal preservation development is one that: o Was built with strong construction materials, such as concrete, that will enable the Comment [F5]: We feel it is inappropriate to building to be viable for many years; afford preferential status to concrete structures o over wood frame. Many well-constructed wood Is retrofit to include green/energy efficient systems/features appropriate for the particular projects are well-positioned for rehabilitation property to ensure that as many green and energy aspects of the property are working and/or renovation and are more feasibly upgraded synergistically to provide a higher quality, sustainable development (both in terms of with many green, energy efficient systems and materials and operating costs) over time; features. Concrete buildings are very costly to renovate, which weighs on the argument of long- o Provides units that can be easily visited by persons with disabilities by incorporating term sustainability. features that allow these persons to come and go more easily; o Is located near to mass transit, particularly rail transit that is and will be developed in the future; o Is near services and jobs, promoting walkability when possible; o Provides some ELI units for persons with special needs who are receiving supportive services and referred by a partnering supportive services agency; and o Is developed and maintained by strong developers and management companies.
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I. Location
A. How should we target financing in light of low occupancy levels in many submarkets throughout the state?
B. How should we consider investor interest in markets/developers?
C. Location restrictions
1. Location A
a) No new construction would be financed due to market softness or proximity Comment [F6]: Establish clear metrics to avoid to Guarantee Fund properties as evidenced by vacant Florida Housing arbitrary application of subjective criteria. financed units. b) Preservation – only deals involving existing PBRA contracts, regardless of their relative positions to Guarantee Fund deals.
2. Develop market tests for credit underwriting that include:
Discussion Points for 2011 UAC Page 3 April 29, 2010
a) Areas where the physical occupancy rate for like-kind developments is at least 92% and the average market rental rate, based on unit mix and inclusive of rent concessions, is at least 110% of maximum Housing Credit rental rates.
b) Developer should be hesitant to enter any market that may be marginal or worse.
D. Prioritize properties located near transit centers Comment [F7]: Current site selection criteria reward proximity to various levels/concentrations of mass transit and services. The concept of living near 1. Promote Transit Oriented Development (TOD) by giving points to developments in a transit station is highly desirable, thereby driving local government designated TODs. See Attachment 1 for an overview of TOD the cost of real estate beyond of the range conducive to affordable housing in many cases. a) TODs are moderate to high density, mixed-use, and walkable developments Beyond this cost infeasibility, a disproportionately designed to maximize access to transit. TODs encompass a radius of ¼ to ½ small number of such properties are available and mile around a transit station, a distance most pedestrians are willing to walk. suited to residential development. They incorporate street-oriented design features that encourage comfortable Comment [F8]: These types of projects are more and convenient access to properties within the transit station area. [From expensive to design and construct than traditional Florida state guidelines, developed by DCA/DOT low-rise multifamily typologies, and are therefore more difficult to develop as affordable housing under the current system. 2. If not in a TOD, award points for proximity to commuter rail stations, bus stations and bus stops to within ¼ mile from a proposed property.
3. Should local government location priorities for preservation (above) take precedence over transit and other proximity concepts? Comment [F9]: Community is local, so local governments should certainly be encouraged to actively target their housing, infrastructure and E. Prioritize properties located near services transportation priorities, and they are certainly in a better position to assess them. 1. To promote property locations that are convenient to community amenities, Florida Housing is considering calculating proximity scores by measuring actual walking/driving distances to community amenities rather than the current approach— the straight line, or “as the crow flies” distance. Whereas a straight line measurement Comment [F10]: Adopting this methodology may cut through obstacles such as major highways and buildings, a walking/driving with the ¼ mile distance that appears to be preferred will result in very few developments distance would be measured as a definitive route that a person could actually travel to qualifying for these points. We recommend get to the amenity. maintaining the “radius” approach and increasing (1) Street Atlas has this capability. We could use the shorter of the the distance to 1/2 mile, which is still within distance derived from Street Atlas using the walking and driving walkable parameters.
functions of the software. Alternate suggestion is to adopt methodology similar to LEED for Home’s “Community 2. To promote walkable communities, decrease distances to achieve maximum Resources/Transit” Category, which allows for less services in a tighter radius as a substitute for more proximity points to be within ¼ mile of the development. services in a greater radius. This would also help define community amenity types and therefore 3. Consider adding services that can receive proximity points, including: assist in streamlining the certification process. a) Public park/public community center;
Discussion Points for 2011 UAC Page 4 April 29, 2010
b) Public library;
c) VA medical facility; and
d) Senior Center (elderly developments only).
F. Difficult Development Areas
1. GO Zone DDA designation. For developments in a GO Zone DDA that have not met the placed-in-service requirements by 12/31/2010, the development will not have DDA designation at time of execution of 8609s, unless the subject area is designated a DDA in the traditional manner or FHFC so designates it as such.
2. 2008 HERA Requirements for DDA Designation. Through 12/31/2013 FHFC has the ability (if approved in QAP) to designate a non-DDA to be a DDA for housing credit purposes. FHFC will need to adopt the parameters of how it decides the designation in the QAP prior to 12/31/2010.
3. How should Florida Housing use its discretion to designate DDAs?
II. Local Government Support
A. Local Government Contributions
1. Currently Applicants that receive contribution with a net present value equal to or greater than the minimal amounts outlined in the chart found on page 65 of the 2009 Application Instructions receive five (5) points.
2. Florida Housing is considering prioritizing applications within each local government jurisdiction that have received higher per unit local government contributions as a way to allow local governments that choose this option to set their priorities for which developments should be awarded financing. Comment [F11]: Sound in theory, but likely open to increased political manipulation. B. How can Florida Housing incorporate local government location priorities for preservation developments, including these possible location types?
1. An area that the local government has designated for community revitalization (as specified by an adopted plan, ongoing projects and financing going to the area, etc).
2. An area that is growing and/or gentrifying where services and jobs exist or are being created and where affordable housing is at risk of disappearing.
3. Others?
Discussion Points for 2011 UAC Page 5 April 29, 2010
III. Preservation Priorities A. Florida Housing continues to target properties with federal funding in place to maintain subsidies that support ELI residents.
B. As stated in II.B. above, Florida Housing believes local governments should play a critical role in setting preservation priorities within broad parameters (location, etc).
C. What about the following types of priorities?
1. At risk of loss due to affordability restrictions expiring – i.e., because the property is in a strong market?
2. Substandard property condition (but with a physical plant that is functionally strong if rehab is carried out)?
3. Properties that are 20 or more years of age?
D. Set-Aside Commitment for PBRA deals. Florida Housing is considering requiring developers with PBRA properties to set aside 40% of the property’s units for ELI residents. The rule could be modified to indicate that, should the PBRA contract be lost as a result of loss of congressional funding, affordability restrictions would revert to the traditional restrictions in place for Housing Credit (or other financing) at the time of award (including for 2011, a 10% ELI set-aside) unless Florida Housing at its discretion provided financing to keep the additional ELI units in place.
E. The required affordability period for preservation deals would be 30 years or the remaining useful life of the property as designated by a capital needs assessment (CNA). If the CNA indicates that the remaining useful life is less than 30 years, then the Development would no longer be eligible for funding and the funding would be offered to the next highest ranked development or it would be added to the next cycle’s available resources.
IV. Construction Type
A. Sticks and bricks
1. Prioritize new construction and preservation developments that are built with sustainable materials such as concrete and concrete block. Comment [F12]: “Sustainable” is defined in many ways, but typically addresses long-term net impact in a “cradle-to-grave” context of 2. Preservation construction features/amenities construction and use. Wood is a rapidly renewable resource and is relatively lighter and less expensive a) Should there be required or optional features/amenities? than all other materials.
See comments on page 1 for additional feedback. b) Rehab needs – require a capital needs assessment to be carried out in credit underwriting that will be used to determine rehab needs and replacement Compact developments and smaller dwelling unit reserves, and ensure that the property is eligible for funding. sizes are ultimately the best path to sustainability. Incentivizing such compactness would result in smaller A/C cooling loads, less construction materials, smaller site impact, etc. Discussion Points for 2011 UAC Page 6 April 29, 2010
c) Less than 50% of the proposed construction work must consist of new construction.
d) Applicants would be required to meet a minimum rehabilitation expenditure requirement of $20,000 per unit. In the event that the capital needs assessment didn’t substantiate the need for the level of expenditures required, the Development would no longer be eligible for funding and the funding would be offered to the next highest ranked development or it would be added to the next cycle’s available resources.
B. Green Features (See Attachment 2 for further information) Comment [F13]: Our comments are located on the attachment 1. New Construction Applicants may choose from a list of green building options to get points. Options will be weighted based on their cost and value as a feature. In the application applicants will commit to selecting options at credit underwriting.
2. New Construction Applicants may commit to become green certified to get more points.
3. Rehabilitation for Acquisition/Rehab and Preservation developments would be required to be carried out according to a green retrofit evaluation carried out as part of the capital needs assessment in credit underwriting.
C. Universal Design (See Attachment 3 for proposed features and overview) Comment [F14]: Our comments are located on the attachment 1. Required universal design features are proposed for all New Construction developments for all units. For additional points, New Construction Developments would choose to include the Optional Universal Design Features package in 20% of the total units. A commitment to include the Optional Universal Design Features package would be in addition to the federal requirement that 5% of the units be handicapped-accessible.
2. All Acquisition/Rehab and Preservation Developments would be required to include the Required Universal Design Features that are feasible, depending on the rehabilitation activities and improvements being made to a development's units.
V. Financial Structure
A. General measures
1. Replacement Reserves (to follow stimulus RFP, plus a tweak)
2. Operating Deficits Reserve can be approved as a separate line item cost up to six (6) months before being classified as a sub-set of developer fee.
Discussion Points for 2011 UAC Page 7 April 29, 2010
B. How should Florida Housing utilize our HOME funds?
VI. Sponsor Strength
A. How can Florida Housing determine, for the purpose of scoring, which developers will be best positioned to attract equity investment?
B. For scoring of developer experience, what components of experience should Florida Housing consider?
C. Florida Housing would like to develop ‘past experience’ parameters to keep out owners of properties eligible for preservation who have not maintained properties well. Such properties could be encouraged for preservation when current owners will not be any part of a new ownership structure. What past experience parameters could be used to score such an item?
D. Florida Housing expects to further codify credit underwriting considerations to mitigate lending risk. In doing so, how should we consider foreclosures?
1. What percentage of a General Partner’s portfolio, in terms of number of overall transactions, should be allowable in the current environment before more stringent underwriting parameters should be required for that party on a future transaction?
2. What percentage of a Limited Partner’s portfolio, in terms of number of overall transactions, should be allowable in the current environment before more stringent underwriting parameters should be required for that party on a future transaction?
3. What mitigating factors should be considered when evaluating a foreclosure (General Partner cash contributions, foregone Developer Fee, etc.)?
VII. Other Items
A. Developer / General Contractor Preference
1. Based on the current statutory requirement, Florida Housing will need to consider the following:
a) Domicile of the Developer and the General Contractor
(1) Whether the developer’s or general contractor’s principal office islocated in Florida; and
Discussion Points for 2011 UAC Page 8 April 29, 2010
(2) Whether a majority of the developer’s or general contractor’s principals and financial beneficiaries reside in Florida. Or
b) Substantial Experience of the developer or the general contractor (regardless of domicile)
(1) Whether the developer or general contractor has completed at least five (5) developments using funds either provided by or administered by Florida Housing.
2. The proposed statutory change would require Florida Housing to consider the developer’s and general contractor’s rate of Florida job creation in the development and construction of affordable housing as a final tie-breaker.
Attachment 3 Page 1 of 4 Proposal to Establish Required/Optional UD Features in Multi‐Family Units
Proposal to Establish Required and Optional Universal Design Features in all New Construction Multi‐Family Units
This proposal was developed to enhance Florida Housing’s ability to meet the housing needs of households with members who are frail, physically disabled or experience decreased levels of functioning at any time over their lives.
• Required: Visitability and other minimal Universal Design (UD) features in all units; o Estimated cost impact for 2 bedroom/2 bath unit - $500; o Provide funding to support the inclusion of required features of $500 per unit; and • Optional (for points): Additional UD features in 20% of a development’s units for additional points; o Estimated cost impact for 2 bedroom/2 bath unit - $750; o Estimated cost impact for providing, on an as needed basis, wired smoke alarms with visual features for hearing impaired persons – $350 (2 bedroom/2 bath unit).
In order to receive extra points, Applicants will commit to incorporate the set list of UD features established by Florida Housing. Applicants will not be able to choose individual items from the list.
Purpose of Required/Optional Visitability and Minimal UD Features
Visitability provides specific UD features that allow mobility impaired or wheelchair-bound persons to Comment [F15]: Clarify definition of safely and easily enter a dwelling unit, access and use one bathroom and visit the common spaces of the “Visitability”. dwelling unit. Visitability/UD requirements would pertain to units in which at least one of the exterior All multifamily projects are required to comply with entrances is accessible to mobility impaired persons, generally on the first level of a building or those the Fair Housing Design Guidelines, which set forth accessed via an elevator. The optional UD features address challenges faced by persons with limited detailed, clear and specific requirements addressing site accessibility and visitability to units on the physical functioning related to a dwelling units’ access, design of space, lighting, flooring, storage and accessible route. Most of the requirements in the fixtures. following table are already included in the FHDG. We recommend better support of the existing requirements and not another set of “similar but Current Accessibility Requirements different” regulations. Florida Housing-funded developments must adhere to federal and state new construction requirements regarding accessibility. Federal Fair Housing Act accessibility requirements cover entrances, common and public use areas (such as rental offices, clubhouses, laundry areas, mail rooms and mail boxes), routes into and through dwelling units, environmental controls (such as lighting and thermostats), reinforcements for bathroom grab bars and usable kitchens and bathrooms.
In addition, Florida Housing-funded developments must meet the federal Section 504 law. This law Comment [F16]: To our knowledge, this requires five percent of a development’s residential units to be fully accessible by a handicapped person statement is false. Section 504 applies only to projects which receive at least partial funding and another two percent must meet the 504 standards established for persons who are visually and/or directly from a federal government agency. FHFC affordable projects that do not apply for supplemental HUD, USDA or other federal funds are not required to comply with Section 504 (UFAS).
Attachment 3 Page 2 of 4 Proposal to Establish Required/Optional UD Features in Multi‐Family Units hearing impaired. Florida Housing’s proposal requires that the optional features be in addition to the five percent/two percent federal requirements. Florida Housing requires a significant number of UD features in newly constructed or substantially rehabbed Elderly developments. This proposal will create units that will benefit all household members, especially those with physical disabilities and limited physical capacity, to Comment [F17]: This is an arbitrary and ambulate and/or perform activities of daily living. unfounded statement. History has shown that multifamily units with “increased accessibility features” rent more slowly than standard units, even among residents with disabilities. The more accessible features/fixtures installed or provided initially, the more likely they will remain vacant.
For this reason, adaptability is a superior approach to accessibility simply because of the flexibility. This is not the forum for an “adaptable vs. accessible” argument, but logic dictates in a rental environment that universal adaptability is more beneficial than partial accessibility.
Attachment 3 Page 3 of 4 Proposal to Establish Required/Optional UD Features in Multi‐Family Units
2011 UAC Required Visitability and Universal Design Features for All Units in New Construction Developments Comment [F18]: As previously commented, Doors “visitability” should be clearly defined in this context. The Fair Housing Design Guidelines At least one unit entrance with a 36-inch wide exterior door (Primary entrance Door) (FHDG), which apply to all multifamily projects, 32” minimum clear door openings for all interior doorways. already sets forth the industry-accepted standard for “Visitability” and applicability of the term to Threshold with less than a 1/2-inch rise. various types of units, building configurations, and Entrance door must have two peepholes, one at standing eye level and one at seated eye level, not more than 43” from bottom of door. site arrangements. Lever-action handles on all exterior and interior doors. Comment [F19]: Depending on your ultimate definition of “visitable”, this blanket requirement General Interior will render many staple economical affordable All hallways at least 36” wide. unit/building designs non-compliant and drive developers to more costly designs. Examples: units Clear floor space of 18” minimum beside door to provide space to move out of the way of the door’s swing when pulling it open. such as townhome units with no ground-level Flush thresholds at all interior doorways. bathrooms, and buildings such as flat-over-flat Carpeting and/or non-skid flooring all living areas, including entrance foyer. walkups (without elevators). Carpeting shall be low pile or tight-napped and tile, hardwood, or laminate flooring shall be non-skid and non-glossy. Comment [F20]: Already indirectly required by FHDG (32” min. clear, 36” is smallest to comply).
Comment [F21]: Already required by FHDG Comment [F22]: FHDG already limits thresholds to ½” in height, but we strongly disagree with providing thresholds of less than ½” in our climate due to the combination of heavy rains & high winds.
Comment [F23]: This item would be easy to add and should remain an “adaptable” item.
Comment [F24]: Already required by FHDG at all “covered” dwelling units. Does not apply to multistory units or non-visitable units (upstairs). Comment [F25]: Already required by FHDG
Comment [F26]: This single item can have a dramatic impact on unit design, since it will displace a huge amount of usable space into circulation area. Comment [F27]: Addressed by FHDG in “changes to level” section
Bathroom and Kitchen There shall be at least one bathroom on an accessible level of the unit that allows maneuvering space to permit a person using a mobility device, Comment [F28]: FHDG is clear which unit types including a wheelchair to enter the room, close and reopen the door and exit, approach the toilet seat, and make a safe transfer onto the toilet. are “covered”. Townhouse units in buildings w/o elevators are not because they are inherently not Reinforced walls for future installation of horizontal grab bars around toilets, tub/shower units, and showers. adaptable for use by disabled persons. Likewise, Removable shower head in all tub/shower units and showers. upstairs units in buildings w/o elevators are not Lever-handles on all faucets. All faucets must have anti-scald feature. Kitchen faucet must have removable spout or separate sprayer with at least covered because they are not visitable. a 9” hose. Comment [F29]: Already required by FHDG at all “covered” dwelling units. Utility Features Comment [F30]: We have not encountered non- Mid-point on light, fan switch plates and thermostats should be not more than 48” above finished floor level. removable shower heads in multifamily projects. Toggle type or rocker style switches for lights and fans. - Comment [F31]: Already required by FHDG at all Mid-point on electrical outlets, phone jacks, and data ports should be located no less than 18” above finished floor level with exception of those “covered” dwelling units. electrical outlets, phone jacks and data points around cabinetry and electrical outlets for major appliances such as stoves, refrigerators, washers Comment [F32]: This is a maintenance concern And dryers. for developers and property managers. If someone with disabilities can operate the faucet, we see no There shall be at least two four-plex electrical outlets in all bedrooms for electrical equipment such as computers, printers, radios and reason that a sprayer should be “required”. medical/personal care equipment. Comment [F33]: Already required by FHDG at all Wired door bell accessible to a seated person at the entrance of unit (not more than 48” from floor of primary entry door). “covered” dwelling units and industry practice. Lighting inside and outside of entrance door. (comment applies to following two items as well) All living spaces shall be equipped with overhead lighting. Comment [F34]: Four-plex receptacles are very uncommon in residential/multifamily because they increase the total number of outlets, thereby increasing electrical loads of the unit, building and project. In conjunction with new code requirements for arc-fault circuits and tamper-proof receptacles, this is a cost concern and an unreasonable alternative to tenant-supplied power strips.
Comment [F35]: Current code already requires a switched light or switched outlet in living spaces.
Attachment 3 Page 4 of 4 Proposal to Establish Required/Optional UD Features in Multi‐Family Units
List of Universal Design Optional Features (Maximum _X_Points) Note: To be eligible for points, all items on this list must be included in at least 20 Percent of Units in New Construction Developments. Applicants Comment [F36]: We feel this percentage is too will not be allowed to choose individual items. The features on this list are in addition to the Required Universal Design and Visibility Features. high, since most accessible units are not occupied by tenants requiring those features. Also, as stated General Interior previously, these installed features reduce overall Hallways shall be at least 42” wide desirability among potential residents and therefore Turning space in living areas and bedrooms of at least 5’ diameter render these units less rentable. Bathroom and Kitchen Comment [F37]: There is no precedent for this width in any accessibility standard. At least one accessible bathroom with a 30”X 48” clear floor space at each bathroom fixture so a person using a wheelchair and other mobility device can get close enough to use the fixtures Comment [F38]: A 60” x 60” T-turn (per ADAAG & ANSI) should be allowed as an alternate to the Wall-mounted sink in the accessible bathroom with knee clearance of at least 27”; may include a removable base cabinet turning circle. Horizontal grab bars in place around each tub and/or shower, the installation of which meets or exceeds the Universal Federal Accessibility Comment [F39]: Already required by FHDG at all Standards “covered” dwelling units. Height of toilet in the accessible bathroom toilet must be 17” to 19” Comment [F40]: Revise to indicate “lavatory to Minimum 30”x48” approach to front of all kitchen appliances (T-turn is minimal, 5’ turning circle is preferred) accommodate a forward approach”. Does not need to be “wall-hung”. Stretches of continual kitchen countertop, especially between refrigerator, sink, and stove top Comment [F41]: Already required by FHDG at all Wall-mounted sink in the kitchen with knee clearance of at least 27” with plumbing on rear wall; may include a removable base cabinet “covered” dwelling units. In at least one of the kitchen’s bottom or base cabinets there must be a large drawer that has full extension guides. Comment [F42]: Unclear. All cabinet drawer and door handles in kitchen and bathroom must be loop or D-Shaped type Comment [F43]: Revise to indicate “sink to Utility Features accommodate a forward approach”. There is no Hard-wired smoke alarms, with battery back-up, that have a visual warning feature for hearing impaired persons * multifamily precedent for a wall-hung kitchen sink.
* NOTE: Florida Residential Code requires that smoke alarms be installed in each sleeping room and outside each separate sleeping area in the Comment [F44]: The FRC does not apply to immediate vicinity of the bedrooms and shall be interconnected. In new construction, the required smoke alarms shall receive their primary multifamily projects. power from the building wiring when such wiring is served from a commercial source, and when primary power is interrupted, shall receive power from a battery. The visual alarms can simply replace the standard wired smoke alarm, and could be available simply on request by a hearing impaired tenant, keeping down the cost of requiring these alarms in each unit. Therefore, it is doubtful that additional costs in wired visual alarms would be incurred for 20% of units in a property, because it is unlikely that all 20% of the units would be inhabited by hearing impaired tenants at one time.
Attachment 2 Page 1
2011 UAC: Proposed Green Building Section
This proposal gives applicants the option of either choosing green building features from a list to reach a maximum of X points, or choosing a green certification program for a higher number of points.
Some of the construction features that were previously in the Energy Conservation and Green Building Options sections of the Universal Application have been moved to Construction Features and Amenities, Required for New Construction. They are: • Comment [F45]: Requiring compliance with Energy Star New Homes certification for new construction, qualifying developments—based on Energy Star for New Homes as a non-optional item number of stories and central/individual HVAC and water heating. Equivalent standard will be provided will have significant cost impact to affordable for developments that are not eligible for Energy Star (i.e., over 5 stories or over 3 stories when using developments: third party fees, upgraded material costs, and time for the additional layer of review/ central HVAC and water heating). Equivalent standard is being developed. approvals. If you elect to stay with this proposal, • Low-VOC paint for all interior walls (50 grams per liter or less for flat paint; 150 grams per liter or please specify which Energy Star spec, preferably less for non-flat paint) the Florida Builder Option Package. • Water Sense certified showerheads, faucets, and toilets in all bathrooms (for new construction; Comment [F46]: See first page for commentary. and for rehabilitation, if replacing) Comment [F47]: Making this a requirement will • have significant cost impact but makes little sense Air conditioning with a minimum SEER rating of 14 (excluding buildings with central AC; excluding considering units are repainted every 1-2 years, with SRO units) no such restrictions on repaints. If you elect to stay with your proposal, require compliance with Green Seal GS-11, which is the standard referenced by most green codes and is the industry standard. Section III.B.3 Green Building Comment [F48]: Products complying with desired gallon-per-minute performance should be Applicant commits to choosing options from the following list that add up to X points (items would be chosen allowed, whether they have obtained Water Sense in credit underwriting). [Point values in parentheses are not final, but are meant to show the relative weight of approval or not. We are concerned with the growing trend to push “labeled” products as each option based on its cost to implement and value to overall sustainability.] opposed to specifying performance levels.
Comment [F49]: This should state “for split- • Energy Star rating for all windows (3) system air conditioners” and provide an alternate • Install daylight sensors, timers, or motion detectors on all outdoor lighting attached to buildings (1) specification for vertical PTAC-type units that are not evaluated the same per Department of Energy. • Programmable thermostats in each unit (1) • Comment [F50]: These exclusions are unclear. Rainwater harvesting system (reuse for irrigation and/or toilets) (4) “Central AC” historically means a split-system as • Water Sense certified dual flush toilets in all bathrooms (1) opposed to a window unit. Why are SRO’s • Florida Yards and Neighborhoods certification on all landscaping (1) excluded, do they not require AC? You may mean central chiller systems and SRO’s with PTAC units, but this should be clarified. Further, efficient and economical PTAC’s should be allowed in all multifamily units small enough to be served by them, and the requirements should specify a minimum EER for them since SEER is N/A. Comment [F51]: Please include the Green Item Checklist in the Universal Application itself, NOT in the Instructions as it is currently. This is confusing. Comment [F52]: The items on the “Green” list should be evaluated for true life cycle cost analysis, per line item, to provide an objective comparative basis for selection and provide incentives for the developer to appropriately select features for maximum long-term benefit. Comment [F53]: If Energy Star for New Homes is required, then this will already be provided.
Comment [F54]: As requirements continue to incentivize efficient building envelopes, we are observing an increase in interior humidity levels due to reduced heat gain, which in turn leads to mold- prone environments. We recommend offering a point for a combination thermostat/humidistat in lieu of programmable thermostats. • Light colored concrete pavement instead of or on top of asphalt to reduce the heat island effect (1) Comment [F55]: This is only one of two options • Energy Star certified roof coating (1) OR included in LEED for Homes, and it is the more expensive and less green of the two options. The • Energy Star certified roofing materials (metal, shingles, tiles) (2)¹ other option (and preferable one): Locate trees and other plantings to provide shading for at least 50% of sidewalks, patios and driveways (including ¹ Applicant may only choose one option related to Energy Star roofing parking aisles) within 50’ of the building.
Comment [F56]: In Florida, given the stringent state product approvals process and high design wind speeds, roof tiles are approximately twice the Attachment 2 Page 2 cost of shingles and metal roofing is almost three times the cost of shingles. Many manufacturers do not offer an Energy Star shingle, and those that do • Solar hot water heater (with at least 70% solar fraction) (4) only offer 1 to 2 color options at most. Developers • Eco-friendly cabinets—formaldehyde free, material certified by the Forest Stewardship Council (2) will likely opt for this point and install 1 of the 2 approved roof colors to avoid the requirements of • Eco-friendly flooring for entire unit—Carpet and Rug Institute Green Label certified carpet and pad, other points, so the net effect of this options is that bamboo, cork, 100% recycled content tile, and/or natural linoleum (3) most of the new projects under these rules would have the same color roof. --OR-- Comment [F57]: In multifamily high-density projects that you have stated a preference for, there Applicant commits to achieve green building certification from one of the following programs for a will not likely be enough roof surface area to higher number of points: provide this. This is especially true in areas with significant shade trees or north-facing roof surfaces. • U.S. Green Building Council’s LEED Comment [F58]: Should be reworded to clarify • “no formaldehyde added” and “any tropical woods Florida Green Building Coalition* must be certified by the FSC” • National Association of Home Builder’s National Green Building Standard* Comment [F59]: If building types occur more than once, is certification only required per type? *FHFC will require Energy Star certification in conjunction with FGBC and NAHB, since it is not a Comment [F60]: LEED and FGBC have multiple requirement of those programs. rating systems and tiers, please clarify applicability. Does participation in these programs supersede any contradictory requirement in these requirements?
Attachment 2 Page 3 Participation in any of these programs carries hidden costs by virtue of the presence of another working part in the machine, further complicating Background Information on Green Building Certification the development process and increasing the time and resources that development of such projects Background information on green building certification includes an overview of the green building certification requires. programs, plus WaterSense; a summary of the processes Florida Housing proposes to implement; and some information of the soft and hard costs of green building.
Summary of Green Building Certification Programs
Energy Star Comment [F61]: Our comments on Energy Star included in previous sections of this document. Energy Star is a joint program of the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Energy. Entire homes can be certified as Energy Star Qualified Homes if they follow specific requirements for efficiency, including a maximum HERS (Home Energy Rating System) index of 77 (for Florida), a successful thermal bypass inspection, properly sealed ducts, and Energy Star rated products and appliances. The HERS index of a home is a measure of its efficiency, ranging from 0-100; homes with greater efficiency earn a lower HERS index.
There are five key features necessary to qualify for Energy Star:
• Effective insulation; • High-performance windows; • Tight construction and ducts; • Efficient heating and cooling equipment; and • Efficient products (lighting fixtures, appliances).
Performance testing is done by a third party rater during construction and once construction is completed to ensure that the home meets Energy Star standards.
Florida Green Building Coalition
Florida Green Building Coalition (FGBC) is a membership based nonprofit with the mission to provide a statewide Green Building certification program with environmental and economic benefits. FGBC has a tiered rating system based on the number of points a building achieves. There are four certification tiers: bronze, silver, gold, and platinum. Points are earned in the following categories:
• Energy; • Water; • Lot choice; • Site; • Health; • Materials; • Disaster mitigation; and • General.
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A third-party verifier, called the FGBC Certifying Agent, may advise the builder in the design phase, but at a minimum must conduct an on-site mid-point inspection and a final inspection.
National Green Building Standard
The National Green Building Standard was developed by the National Association of Home Builders (NAHB) as a green building rating system for single family and multifamily housing. There is not a separate rating system for multifamily; however, there are notes specifically for multifamily units, specifying different requirements in some areas. There is no story limit for multifamily housing.
The NAHB Standard has four different certification levels: bronze, silver, gold, and emerald, and is divided into six categories:
• Lot design, preparation, and development; • Resource efficiency; • Energy efficiency; • Water efficiency; • Indoor environmental quality; and • Operation, maintenance, and building owner education.
The verification process begins before construction, with the builder using NAHB’s online Green Scoring Tool to score the project. The tool evaluates the building plans and creates the “Final Designer’s Report.” The builder selects a third-party verifier, to review the report and conduct a midpoint and final inspection.
Leadership in Energy and Environmental Design (LEED)
LEED is a third-party certification program developed by the nonprofit U.S. Green Building Council (USGBC).
LEED has four levels of certification: certified, silver, gold, and platinum. The rating system uses eight different resource categories to measure the performance of a development:
• Innovation and design; • Location and linkages; • Sustainable sites; • Water efficiency; • Energy and atmosphere; • Materials and resources; • Indoor environmental quality; and • Awareness and education.
A developer’s first point of contact with LEED is a LEED for Home Provider. The provider and the development team work together to give a preliminary rating of the project before it is built based on the design. The provider then designates a third-party verifier (called a Green Rater by LEED) to be onsite at specific phases of construction to conduct interim inspections. Once construction is complete, Comment [F62]: This assumes the developer opts for the LEED for Homes system instead of LEED for New Construction. Developer should have option to select the LEED rating system that is most Attachment 2 Page 4 appropriate for the project. the Green Rater must conduct an on-site inspection of each of the green measures originally selected, as well as the performance testing required for certification.
Water Sense
Water Sense is a program sponsored by the U.S. Environmental Protection Agency that certifies and labels water-efficient products. For showerheads and faucets, Water Sense has standards for gallons per minute that are more efficient than standard fixtures. The standards also include criteria for water coverage and spray intensity. Water Sense toilets meet a standard of 1.28 gallons per flush or less, as well as performance standards.
Green Certification – FHFC Processes
A key element of any green building certification program is third party verification. Third-party verifiers from each of the green certification programs work with developers during the design phase to discuss what construction features they should include in order to become certified. Each program has built-in processes designed to test the building at two or more key points of the construction process to ensure that certification will be achieved. The following checkpoints are proposed to make sure that the developer is going through the correct steps to achieve certification.
Notice of Commencement: With the Notice of Commencement, FHFC will require a certification form signed by the third-party verifier who has reviewed the applicable green certification program checklist with the developer and reviewed and approved architectural plans related to the green building measures being taken. For developers who choose NAHB and FGBC, a second certification form will be required for the Energy Star third party verifier. (Some NAHB and FGBC verifiers are also Energy Star raters, and some are not. Two forms will be required, but the same person will be allowed to sign them if they are qualified for both.)
During construction: FHFC will require a copy of the certified thermal bypass checklist for all units, provided upon completion of the thermal bypass inspection conducted by the third party verifier. This inspection must be completed before drywall is put up.
On or Before Place in Service Deadline: FHFC will require a copy of the official certification documentation from the chosen program(s) on or before the Placed in Service deadline. Depending on the green program(s) selected, the following documentation will be required:
• Final LEED for Homes Certification; or • FGBC Green Home Designation Certification and Energy Star Certificate; or • NAHB Certified Green Home Certificate and Energy Star Certificate.
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Soft and Hard Costs of Green Building
Soft Costs Comment [F63]: These are strictly third party Getting green certified involves the soft costs of paying a third party verifier to ensure that a developer has costs, and do not include the increase in design/engineering fees corresponding to the completed the requirements of certification, as well as registration and certification costs paid to the certifying additional scope to design to the selected green organization (except Energy Star, which only has fees to the verifier). standard and integrate the features. • Third party verifier fees are market-based. Estimates listed below are from talking with a few In our experience, these design/engineering fees are different verifiers about what they charge. Some third party verifiers may offer discounts for inspecting well in excess of the fees in the table below by a multiple units, but this is market-based. factor of 3 or higher. These requirements affect the • Registration and certification costs are fixed based on the number of units, number of buildings, and scope and therefore the fees of the architect, the civil engineer, the interior designer, the landscape building square footage. architect, the mechanical engineer, the plumbing engineer and the general contractor. The following chart summarizes soft costs for the different certification programs using a median cost of third party verification to estimate the cost for a 100-unit development.
Green Building Verification and Certification Costs for a 100-unit Development
3rd Party Total For Verification Registration Certification* 100 Units Total Per Unit For 100 Non- Non- Non- Non- Per Unit Units Members members Members members Members members Members members LEED** $650 $65,000 $1,800 $2,400 $3,000 $4,000 $69,800 $71,400 $698 $714 FGBC*** $550 $55,000 $7,500 $10,000 n/a n/a $62,500 $65,000 $625 $650 NAHB $800 $80,000 $2,800 $4,000 n/a n/a $82,800 $84,000 $828 $840 EnergyStar $400 $40,000 n/a n/a n/a n/a $40,000 $40,000 $400 $400 *LEED is the only program that has separate registration and certification costs. This calculation assumes 100 units at 1,000 square feet each. **LEED registration costs are based on the number of buildings; this calculation assumes 4 buildings w/ 25 units each. ***This registration cost is for the home standard, which is based on the number of units. Energy Star certification is incorporated into LEED, but not FGBC and NAHB. Thus, FHFC proposes that developers obtain Energy Star certification in addition to either FGBC or NAHB. A verifier for FGBC and NAHB may or may not be certified to do the energy inspections necessary to achieve Energy Star. If they are not, the developer will have to pay a separate verifier to conduct the Energy Star inspections.
Hard Costs The additional construction costs of green building versus conventional building range from 2-5% of the total development cost. In a study by New Ecology Inc. of 11 affordable housing projects, the average total cost per unit was approximately $178,000. The average additional cost of building green, or the “green premium,” was $5,653, or 3.91%. In a similar study by Enterprise of 27 projects, the average green premium was 3.52%.
For developments funded in 2009 by Florida Housing, the average estimated total development cost per unit was $149,195. Florida Housing already requires that developers incorporate some energy conservation and green building measures, so it is difficult to determine how much extra they will have to spend on construction costs to achieve certification. Based on this reasoning, the additional cost for achieving certification would be lower than the 2-5% typical green premium, because our developers are part way there with the current requirements. That being said, 2% of $149,195 is $2,984; 5% of $149,195 is $7,460 (hard costs only).
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Transit Oriented Development and Affordable Housing Policies
Florida’s Work toward Transit Oriented Development (TOD) Guidelines
In Florida, the Department of Transportation and the Department of Community Affairs have worked together to create a framework for TOD, and are working on guidelines for local governments that want to create transit-oriented communities. There are no specific state standards for an area to be considered as TOD; it is defined at the local level. At this point, DCA and DOT have developed a guide of best practices for TOD, based on the type of setting (urban, suburban, and rural). Their findings include the following national best practices for TOD:
• ¼ to ½ mile radius around a transit station, the distance most pedestrians are willing to walk; • Optimize transit, walking and biking; reducing “vehicle miles traveled”; • High density, 24-hour live, work and recreate centers (connecting housing and jobs); and • Reduced parking requirements.
Most state level planning recognizes the importance of affordable housing in TOD. The Florida draft guidelines acknowledge that TOD is conducive to affordable or workforce housing options, but that “land values increase around station areas, therefore if left to market conditions alone, maintaining the affordability of housing near TODs can be problematic over time¹.” At the federal level, HUD and the Federal Transit Administration are collaborating to address this issue. The Government Accountability Office report on TOD and affordable housing notes that state housing finance agencies have an important role in encouraging the development of affordable housing near transit, including TODs.
The final section of this paper includes information on specific TODs in Florida. The earliest TODs are centered on commuter rails; however TODs centered on bus rapid transit are also being planned around the state. TOD with bus rapid transit is a relatively new concept, but it is included in the state guidelines for TOD, and some local governments are planning for it.
¹ A Guidebook for Implementing Transit Oriented Development in Florida, Florida Department of Community Affairs and Florida Department of Transportation – DRAFT, February 26, 2010.
Common Elements of State Transit Oriented Development Policies
• Proximity to bus or rail stations • Proximity to bus stops • Frequency of transportation (e.g. length of time between service at a bus stop) • Proximity to employment centers • Proximity to resources, such as shopping, post-secondary institutions, and local government offices • Bicycle and pedestrian friendly design
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• Involvement in some type of district already designated by a body such as the state Department of Transportation (New Jersey and California have this)
The following states include transit related incentives in their Qualified Allocation Plans.
Arizona Department of Housing
In Arizona’s 2010 QAP, the TOD standard has been revised to reflect nationally recognized best practices. Applicants can receive up to 20 points, out of a total of 280 points for the following TOD features:
1. Quality bus transit – 5 points. There must be a bus stop within ¼ mile of the proposed site and it must meet the following specifications for frequency: a. At least every 15 minutes on weekdays from 6am to 6pm; b. At least every 30 minutes on weekends from 6am to 6pm; and c. Minimum 18 hours of service on weekdays, minimum 15 hours of service on weekend days.
2. Mixed Use – 5 points. The proposed site is located within 1/2 mile of a mixed use center represented by at least three of the following elements: a. At least 25,000 SF of convenience retail or grocery; b. At least 25,000 SF of other retail; c. At least 25,000 SF of commercial office or other employment other than retail; d. At least 25,000 SF of institutional and civic uses; and e. At least 25,000 SF of restaurant, café, or coffee shop uses.
3. High capacity transit – 10 points. The proposed site is within 1/2 mile of light rail transit, commuter rail, intercity rail, or streetcar.
In the 2009 QAP, projects received points if they met qualifications for proximity to employment centers, community amenities, post-secondary institutions, or mass transit. Employment centers were defined as downtown areas with commercial offices. There were three subsections, the first of which only applies to development within the Phoenix or Tucson MSAs, and the second for areas outside those MSAs. The third applied to any development. No more than 15 points were available under this section.
1. 10 points for projects within Phoenix or Tucson MSAs that demonstrate at least three of the following indicators of sustainable development: a. Project located within a three-mile radius of a major employment center, concentration of employment centers, or community amenities, such as medical facilities, educational institutions, and shopping; b. Project located within one mile of a mass transit route or light rail line; c. Project located within a three-mile radius of city center or some other readily identifiable concentration of local government offices; d. Project served by existing roads, utilities, and communications interfaces.
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2. 10 points for projects located in areas other than the Phoenix or Tucson MSAs that are within 1/2 mile of a U.S., state, or county highway or other arterial and no more than 5 miles from a major employment center, concentration of employment centers, city center, or other readily identifiable concentration of local government offices.
3. An additional 5 points for projects (inside OR outside Phoenix or Tucson MSAs) demonstrating four of the following TOD characteristics. A claim for points under this subparagraph must be supported by an appropriate map. a. Project located within a 1/2 mile radius of a major employment center; b. Project located within a 1/2 mile radius of a post-secondary educational institutions; c. Project located within a 1/2 mile radius of an identifiable concentration of retail commercial enterprises d. Project located within a 1/2 mile radius or a readily identifiable concentration of local government offices; e. Project located within 1/2 mile of a mass transit route or light rail line
California Tax Credit Allocation Committee
California awards points based on a graduated scale, depending on the distance to, or type of, transit, as well as the frequency and hours of service. The following are the requirements and points awarded:
• The project is part of a TOD strategy where there is a transit station, rail station, commuter rail station, bus station, or public bus stop within 1/4 mile from the site with service at least every 30 minutes during the hours of 7-9am and 4-6pm, and the project’s density will exceed 25 units per acre – 7 points • The site is within 1/4 mile of a transit station, rail station, commuter rail station, bus station, or public bus stop with service at least every 30 minutes during the hours of 7-9am and 4-6pm – 6 points • The site is within 1/3 mile of a public bus stop with service at least every 30 minutes during the hours of 7-9am and 4-6pm – 5 points • The site is located within 500 feet of a regular public bus stop, or rapid transit system stop. (For Rural set-aside projects, full points may be awarded where van or dial-a-ride service is provided to tenants, if costs of obtaining and maintaining the van and its service are included in the budget and the operating schedule is either on demand by tenants or a regular schedule is provided) – 4 points • The site is located within 1,500 feet of a regular public bus stop or rapid transit system stop – 3 points
A private bus or transit system providing service to residents may be substituted for a public system if: (a) it meets the relevant headway and distance criteria, and (b) service is provided free to the residents. Such private systems must receive approval from the California Tax Credit Allocation Committee (CTCAC) Executive Director prior to the application deadline. Multiple bus lines may be aggregated for the above points, only if multiple lines from the designated stop travel to an employment center. Such
Attachment 1 Page 4 aggregation must be demonstrated to, and receive prior approval from, the CTCAC Executive Director in order to receive competitive points.
New Jersey Mortgage and Housing Finance Agency
New Jersey awards 8 or 10 points for projects located within a transit village (8 points if in a QCT, 10 points if not in a QCT). Transit villages must be designated by the Transit Village Task Force (coordinated by NJ DOT) by the tax credit application deadline. Municipalities must take the following steps in order to receive Transit Village designation:
• Attend a pre-application meeting with the Transit Village Coordinator • Identify existing transit (rail, light rail, bus, or ferry) • Demonstrate municipal willingness to grow • Adopt a TOD redevelopment plan or TOD zoning ordinance o Include transit-supportive site design guidelines o Include transit-supportive architecture design guidelines o Include transit-supportive parking regulation • Identify specific TOD sites and projects o Document ready-to-go projects o Include affordable housing in the transit village district (any project being financed in whole or in part with State funds must reserve at least 20% of the residential units for low or moderate income households) • Identify bicycle and pedestrian improvements • Identify “place making” efforts near transit station, establish a management organization o Identify annual community events and celebrations o Identify arts, entertainment and cultural events
The area that makes up the Transit Village district is a 1/2 mile radius around the transit station. In order to be designated a Transit Village, the municipality must document that there are multiple TOD projects planned for the area within the district.
Maryland Department of Housing and Community Development
Maryland awards 5 points to developments that meet the criteria for one of the following: TOD; green certification²; brownfields; OR high development quality.³ TOD is defined as a development having a density that exceeds 25 units per acre, involves mixed use or is part or a larger mixed use undertaking, involves good non-motorized transport design (walkability), and: 2 To get the 5 points for green certification, developers can choose LEED, NAHB, or Earthcraft. 3 Points are given for high development quality if the development achieves at least 23 out of 28 points in the Development Quality Subcategory II, which includes consideration of project design, material selection, energy efficiency, healthy indoor environment, and site considerations. This is a section that all applicants complete; a high score gives “bonus points.”
• Is located within 1/2 mile of a mass or public transit rail station; OR
² To get the 5 points for green certification, developers can choose LEED, NAHB or Earthcraft. ³ Points are given for high development quality if the development achieves at least 23 out of 28 points in the Development Quality Subcategory II, which includes consideration of project design, material selection, energy efficiency, healthy indoor environment, and site considerations. This is a section that all applicants complete; a high score gives “bonus points.”
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• Is located within 1/4 miles of a bus depot or bus stop with service scheduled at least every 30 minutes (or more frequently) between the hours of 6:30am and 7:00pm.
Oregon Housing and Community Development
Oregon specifies projects in “Transit-Oriented Districts” as DDA (providing a 130% basis boost). Projects must be an area specified by a city or county government initiative as a TOD or an area that encourages the development and use of public transportation.
Illinois Housing Development Authority
Illinois has as one of their priorities serving “low and moderate income persons unable to afford housing near work or transportation. To address this priority, IHDA awards proximity points for developments near transit. 6 points will be awarded if the proposed Project is located in close proximity to fixed-route public transportation, excluding inter-city transportation. “Close proximity” for this category will vary by setaside and will be defined in the following manner: Chicago (6 blocks); Chicago Metro (1 mile); Other Metro (1.5 miles); Non-Metro (2 miles). Transportation routes and distance to Project site must be identified in the market study submitted with the Application.
Georgia Department of Community Affairs
To qualify for 3 Community Transportation points in Georgia’s QAP, the proposed site must be located within 1/2 mile walking distance of a rapid rail transit station along paved roads, sidewalks, established pedestrian walkways or bike trails.
Nevada Housing Division
Nevada includes proximity to transit routes and services in its green building section. The maximum for this section is 3 points.
• 1 point if the site is within 1/4 mile of local transit route; • 1 point for every 3 services within 1/4 miles of site (for a maximum of 2 points); services include grocery store, pharmacy, bank, park, school, day care, medical service, and library.
Texas Department of Housing and Community Affairs
Developments Sites located within a one mile radius (two-mile radius for Developments competing for a Rural Regional Allocation) of at least three services appropriate to the target population will receive 4 points. A site located within 1/4 mile of public transportation that is accessible to all residents including Persons With Disabilities and/or located within a community that has "on demand" transportation, special transit service, or specialized elderly transportation for Qualified Elderly Developments, will
Attachment 1 Page 6 receive full points regardless of the proximity to amenities, as long as the Applicant provides appropriate evidence of the transportation services used to satisfy this requirement. There are 14 types of eligible services for proximity, which are listed in the application:
• Full service grocery store or supermarket • Pharmacy • Convenience store/Mini-market • Department or retail merchandise store • Bank/credit union • Restaurant (including fast food) • Indoor public recreation facilities, such as civic centers, community centers, and libraries • Outdoor public recreation facilities, such as parks, golf courses, and swimming pools • Hospital/medical clinic • Medical offices (physician, dentistry, optometry) • Public schools (only eligible for developments that are not Qualified Elderly Developments) • Senior Center • Dry cleaners • Family video rental
TODs in Florida
The Miami-Dade county government has joint development programs with Miami-Dade Transit (MDT) to support residential and mixed-use projects, including retail, hotels, office space, and affordable housing near transit stations. There are currently 14 joint development projects. Seven include either affordable or workforce housing:
• Allapattah Metrorail Station; • Brownsville Metrorail Station; • Coconut Grove Metrorail Station; • Gran Via Housing/Park& Ride; • Northside Metrorail Station; • Okeechobee Metrorail Station; and • Senator Villa Housing/Park & Ride.
Jacksonville Transportation Authority is currently planning four TOD projects. One of these projects is centered on the Kings Avenue Skyway has broken ground and includes two hotels, a residential component, restaurants, and retail. The other three plans do not contain any information about housing at this point. They are:
• 200 Riverside; • Bay Street Station; and
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• Laura Street.
Broward County has the following TODs included in their county land use plan:
• Deerfield Beach Station TOD; • Hollywood TOD; and • Sunrise TOD.
Broward County is also planning for TODs around a major bus rapid transit corridor on State Road 7/US 441. There are currently five projects being planned along that corridor; however some of the development is on hold due to the economic climate.
Alachua County has four TODs in the planning stage that are centered on bus rapid transit.
Treasure Coast Regional Planning Council (TCRPC) has worked with many cities in the southeastern Florida on TOD design charrettes. TCRPC worked with the City of West Palm Beach to plan a TOD around the downtown Tri-Rail station that addresses the need for workforce housing, and increases transit ridership and pedestrian circulation. TCRPC relies on national best practices for TOD, as well as public input. The West Palm Beach plan includes the following elements:
• New federal courthouse • 100-room hotel • Palm-Tran bus transfer station • Florida Department of Health expansion • New north/south street • “Anchor” retail • Mixed-use housing • Expansion of the American Red Cross • New elementary school • Workforce housing
4-22-10, Web Proposed Rule Time Line Multifamily Rental Programs MMRB, SAIL, HC and HOME Rental 2011 Universal Application Cycle
Tentative Dates – Subject to Change
2-26-2010 Public meeting to solicit comments following Board meeting (Tallahassee)
4-29-2010 First Rule Development Workshop to solicit comments (Orlando)
6-17-2010 Second Rule Development Workshop to solicit comments (Tallahassee)
7-29 or 7-30-2010 Third Rule Development Workshop to solicit comments (Location TBD)
9-10-2010 Fourth Rule Development Workshop to solicit comments following Board meeting (Tallahassee)
11-30-2010 Rule Hearing (Tallahassee)
12-16-2010 Open Cycle
Early January 2011 Application Workshops (Tallahassee)
1-18-2011 Cycle Closes
2-23-2011 Issue Preliminary Scores
3-3-2011 NOPSEs due
3-30-2011 Issue NOPSE Scores
4-11-2011 Cures due
4-19-2011 NOADs due
5-18-2011 Issue Final Scores and Notice of Rights
Late June 2011 Informal Appeal Hearings
Late July/Early August 2011 Board approves final ranking