CITY OF WAUWATOSA, HOUSING POLICY & ACTION PLAN DRAFTDRAFT October 30, 2017 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

TABLE OF CONTENTS

1 DRAFT HOUSING POLICY 3 HOUSING ACTION PLAN 5 Potential Implementation Strategies 5 Policy Priority A: Increase Availability and Improve Affordability of Housing for the Local Workforce, Lower Income Families, Seniors and People with Special Needs 5 Identify and Solicit Affordable Housing Developers through an RFP Process 6 Develop Incentive-Based Inclusionary Housing Policy 7 Identify or Prepare Affordable, Senior or Supportive Housing Development Sites 8 Develop a City-Administered Affordable Housing Fund 9 Target Use of Community Development Block Grant Funds for Housing Production 9 Create Down-Payment Assistance Program and/or Employer-Assisted Housing Program 10 Promote Use of HOME Funds 11 Develop/Enhance Partnerships with Affordable Housing Organizations 11 Policy Priority B: Preserve Existing Housing by Addressing Accessibility and Deferred Maintenance Issues Associated with an Aging Housing Stock 11 Develop a General Housing Fund 12 Create Modification Programs for Owner-Occupied and Rental Properties 13 Acquire and Make Available City-Owned Accessibility Improvements 14 Redevelop Select Properties 14 Policy Priority C: Enhance Ability of Current Residents to Age in Place within the Community 14 Develop New Senior Housing Options 15 Develop Financial Assistance Programs for Fixed-Income Seniors 15 Connect Seniors to Service Networks 16 Consider the Built Environment and its Impact on Seniors 16 Policy Priority D: Ensure a Mix of Housing Types is Available 16 Refine Regulatory Framework 18 Provide Financial Assistance 21 Toolkit 21 Tax Increment Financing 22 Community DevelopmentDRAFT Block Grant Funding 23 HOME Investment Partnership Program Funding 24 Regulatory Tools 24 City-Administered Housing Funds 25 Dedicated Housing Department or Staff 26 Strengthened Relationship with WHEDA 29 Administrative & Implementation Considerations 33 Appendices & Additional Information

SB FRIEDMAN DEVELOPMENT ADVISORS 221 N. LaSalle St. Suite 820 Chicago, IL 60601 Contact: Fran Lefor Rood, AICP T: 312.424.4253 E: [email protected]

TABLE OF CONTENTS CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

City of The City of Wauwatosa recognizes the need to ensure housing Wauwatosa options are available in the community for households of all ages, incomes and levels of physical ability; that the City’s housing stock is a significant asset that should be maintained Housing Policy over time; and that an array of housing options is necessary to accommodate a diverse population and attract and retain (DRAFT) businesses. As outlined in the 2016 Comprehensive Housing Study and Needs Analysis, the City’s existing housing supply and pipeline of private market development is not adequately For consideration on November 14, 2017 addressing the range of housing needs. The City therefore seeks to implement a comprehensive housing policy to ensure availability of a range of high-quality housing options today and in the future.

The City intends to use available tools and resources to proactively address existing and future housing issues. The policies outlined below will guide the City’s housing investment and regulatory programs, with a menu of specific strategies outlined in the attached Housing Action Plan.

Policy Priority A: Increase Availability and Improve Affordability of Housing for the Local Workforce, Lower Income Families, Seniors and People with Special Needs

Finding affordably-priced housing units in Wauwatosa can be challenging for households with low or fixed incomes DRAFTand residents with special needs, such as physical or mental disabilities or those at risk or with a history of homelessness. A lack of affordable units for these populations limits their ability to benefit from the high quality of life, employment and educational opportunities, and amenities that Wauwatosa offers. Furthermore, Wauwatosa is a major employment center that supports a workforce with a diversity of skill sets and incomes. The availability of affordable housing allows employees of Wauwatosa businesses to live nearby, decreasing commute times and increasing reliability.

Recognizing the importance of providing housing options to a range of income levels and physical abilities, the City will proactively increase the availability of housing units affordable to a wide range of households and segments of the population that often face housing challenges, especially as new development occurs.

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Policy Priority B: Preserve Existing Housing Therefore, the City will undertake efforts to enhance the ability Stock by Addressing Accessibility and Deferred of residents to remain in Wauwatosa as they age by addressing Maintenance Issues Associated with Aging Housing both the challenges of remaining in their current homes over the Stock long term, and ensuring sufficient alternatives exist for seniors of different incomes, ages and ability levels once they have Wauwatosa’s housing stock represents a significant local asset decided to move. which requires ongoing investment to maintain. Without proper maintenance, declining housing quality may over time reduce Policy Priority D: Ensure a Mix of Housing Types is property values and remove units from the stock entirely, Available in Wauwatosa requiring more substantial investment in new construction to simply maintain the current number of housing units in the Different types of households prefer and can afford different community. Investing in existing units prevents their loss and types of housing units. Anticipated population growth and permits new construction to expand housing options, allowing demographic shifts over the coming years are expected to the existing housing stock to serve as a more moderately-priced drive demand for a different mix of housing types than currently option relative to new construction. Investments in maintaining exists in Wauwatosa, including additional rental multifamily and updating the existing housing stock, specifically and for-sale attached housing, such as townhomes and through updates to major building systems and accessibility condominiums. Furthermore, a diversity of housing options is improvements, are critical to preserving Wauwatosa’s existing important to ensure the local workforce is attractive to current housing resources and ensuring safe, accessible living spaces. and potential businesses.

The City recognizes that financing home improvements can To ensure that Wauwatosa’s housing stock includes options be challenging, especially for lower- or moderate-income for households of all types, City policies and programs will be households, including senior households on fixed incomes, designed to ensure a variety of housing types in Wauwatosa. and private owners of small rental buildings. Therefore, as an investment in this community asset, its existing residents and overall housing affordability, the City will prioritize assisting property owners who may not otherwise have access to funds for home maintenance. DRAFT Policy Priority C: Enhance Ability of Current Residents to Age in Place within the Community

Growth in households headed by empty nesters and seniors are expected drive a significant share of Wauwatosa’s housing growth over the next five to 15 years. Therefore, special consideration should be given to the needs of this group to ensure that the housing stock accommodates a range of physical abilities and incomes. Furthermore, the City recognizes the importance to its senior residents of remaining in their homes as long as possible and that when relocating, either by choice or by need, appropriate housing options exist within the community.

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City of In 2015, the City of Wauwatosa (the “City”) engaged Wauwatosa SB Friedman Development Advisors (SB Friedman) to assess the City’s housing stock, evaluate its ability to meet the current and future needs of residents, and identify unmet housing needs and Housing other housing-related issues. The resulting 2016 Comprehensive Housing Study and Needs Analysis (the “Housing Study”) Action Plan identified several key housing issues, including: • Lack of available and/or affordable housing options for the local workforce, lower income families, seniors, and people with special needs; • Accessibility and deferred maintenance issues associated with an aging housing stock; • Challenges to the ability of current residents to age in place within the community; and • Limited availability of a mix of housing types.

The City’s Common Council then authorized City staff to work with SB Friedman in developing a Housing Policy and Action Plan to address the issues identified in the Housing Study.

PURPOSE

This Housing Policy and Action Plan outlines a draft City Housing Policy (see page 1-2) and presents a number of potential strategies to proactively implement the Policy and address unmet housing needs. Many of the strategies DRAFTrecommended within have been successful in peer communities in the Midwest in advancing similar housing objectives, while others reflect best practices nationwide. Peer communities (detailed in Appendices E and H) are either: demographically and geographically comparable to Wauwatosa, recognized for having model housing programs/policies and/or have experience with strategies currently under consideration.

STRUCTURE

Strategies are outlined in Section 1 (pages 5-19) and organized by the four policy priorities identified in the City Housing Policy. The Housing Action Plan is intended to provide the Common Council and City staff with a menu of potential options, rather than a prescriptive sequence of implementation steps. It is anticipated that the Common Council and City staff

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will work together to identify near- and long-term priorities and select relevant strategies for implementation.

Many of the strategies will require modifications and/or enhancements to existing City administrative processes, policies and programs. Potential additions to and modifications of City and Community Development Authority (CDA) financial and regulatory tools are presented in Section 2 (pages 21-26) with key administrative and implementation considerations outlined in Section 3 (pages 29-31).

DRAFT

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1. Housing Policy Priority A: Increase Availability and Action Plan: Improve Affordability of Housing for the Local Workforce, Lower Income Families, Potential Seniors and People with Special Needs

The Housing Study identified a need for additional housing Implementation units for residents and the local workforce with lower or fixed incomes, and for residents with special needs. Outlined below Strategies are strategies to incentivize the construction of new units targeted to these populations.

IDENTIFY AND SOLICIT AFFORDABLE HOUSING DEVELOPERS THROUGH AN RFP PROCESS

Pursue a request for proposal (RFP) process to alert developers to City or Community Development Authority (CDA)-identified priority redevelopment areas, assembled sites, and financial resources available to support construction of new affordable housing that meets identified specifications (i.e., serving specific low-income populations, providing particular accessibility features or creating supportive housing for people with special needs and those at risk or with a history of homelessness).

• Conduct developer solicitation. Before releasing an RFP, conduct outreach to active developers in the region with experience developing the City’s priority project types to DRAFTenhance publicity and encourage developer responses. • Streamline application process. Align the RFP process with applications for other forms of assistance such as Community Development Block Grants (CDBG) or City- administered housing funds. Streamlined application processes reduce administrative load on both the developer and City staff. Aligning the application with external financing sources such as the County HOME Consortium or Wisconsin Housing and Economic Development Authority (WHEDA) may encourage developer participation. Structure and time the City’s RFP process such that local funds are committed prior to the developer applying for funds from other public entities, in order to demonstrate required local support.

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• Provide coordination and developer support. Use the WHAT IS INCLUSIONARY HOUSING? RFP as a vehicle to source promising projects that meet Policies that require or incentivize developers to include units local priorities and are likely to receive public financial affordable to low-to-moderate income (LMI) households assistance, then “quarterback” the interface between when building new market-rate housing. In communities the developer, other City departments and other public experiencing growth in market-rate housing, IH policies financing sources. provide a way to maintain a range of housing affordability.

Immediate Action Steps IH policies are typically structured as either mandatory policies, which require the creation of affordable units in new • Identify timing of City, county and state assistance housing developments, or incentive-based, which require programs and time release of RFP and award decisions affordable units only in exchange for financial or regulatory before other funding applications are due. (zoning) assistance from the municipality, including waived • Identify developers active in the region with relevant requirements surrounding density and design, reduced experience. parking requirements, etc. It appears based on the legal • Conduct initial outreach to developers to gauge interest framework and local development considerations that and discuss City policy changes and priorities. an incentive-based inclusionary policy is feasible in • Identify and outline in an RFP/property offering document Wauwatosa. (Additional Information in Appendix H) the City resources to be made available, potential structure(s) of assistance, target population and/or location, and housing type sought. • Determine characteristics of projects covered by • Identify and list CDA priority development sites where policy. IH policies often apply regardless of the project’s development could be incentivized through the RFP. intended tenure (whether rental or ownership), though • Release RFP and conduct additional outreach to some communities target only rental or ownership units. developers to answer questions and ensure responses. Some communities have created spatial distinctions, only • Work with developers to identify other sources of public applying IH in certain areas or increasing requirements funding to leverage City support. near transit. There are often minimum project size requirements, with the policy only applying to projects DEVELOP INCENTIVE-BASED INCLUSIONARYDRAFT above a certain size (e.g., 15 units). HOUSING POLICY • Determine number of affordable units required. The Craft an inclusionary housing (IH) policy that requires developers number of required affordable units varies in communities receiving City financial assistance to include affordable units in that have instituted IH policies, ranging from 5% to 20% otherwise market-rate housing developments. Implementation of total units. Some policies require a set percentage of steps include: units be affordable, while others have tiered requirements based on characteristics of the project and affordability • Clearly define the forms of City assistance that trigger IH of the units. requirements. TIF is the most likely IH trigger, but others may include city loans or grants, reduced sale prices for • Set affordability targets. Affordability targets identify the publicly-owned land, flexibility in development standards incomes of households allowed to live in the units. Some (e.g., greater height or density or reduced parking communities set flat affordability targets (e.g., households requirements), reduced permit fees, or other City financial at 60% of area median income (AMI))[1], while others allow assistance to which a project would not otherwise be some units to serve higher income households in exchange entitled. for serving lower-income households as well (e.g., at least

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half of affordable units at 60% of AMI and the remaining [1] Area Median Income (AMI), as calculated by the U.S. Census, is a metric units at 80% AMI). The Housing Study identified units for used by the U.S. Department of Housing and Urban Development (HUD) and other entities, to determine eligibility for programs targeted for low-to-moderate households with incomes below $15,000 as a particular income households. For a family of four in the Milwaukee-Waukesha-West Allis need in Wauwatosa, therefore the City may consider Metropolitan Statistical Area, 2017 AMI thresholds were as follows: 30% of AMI the latter structure as a way to benefit a wider range of -- $21,700; 50% -- $36,200; and 80% -- $57,900. A table of AMI figures by households. household size is included in Appendix C.

• Determine required affordability period. There is wide Immediate Actions Steps variation in affordability periods which range from 10 years to perpetuity, regardless of tenure. • Prepare an outline of a draft inclusionary housing policy including the parameters outlined above and brief • Decide alternatives to on-site affordable units. To account Common Council members. for situations where providing affordable units on-site may • Incorporate feedback and revise policy appropriately to not be feasible or practical, IH policies often allow for develop a draft inclusionary housing policy. alternatives: creating affordable units elsewhere in the city • Conduct outreach regarding draft inclusionary housing (through new construction, dedication of existing units, or policy to impacted stakeholder groups (e.g., affordable dedication of land), payments into an affordable housing housing advocates, housing developers, other communities trust fund (commonly called a fee-in-lieu payment), with similar policies). participation in a third-party affordable housing • Revise policy based on feedback from stakeholder development elsewhere, or proposing an alternative outreach as necessary. which furthers other City affordable housing goals. • Prepare inclusionary housing ordinance.

While an IH policy may not create large numbers of affordable IDENTIFY OR PREPARE AFFORDABLE, SENIOR OR units at once, and is dependent on the pipeline of private- SUPPORTIVE HOUSING DEVELOPMENT SITES sector development, IH has the advantage of distributing affordable units throughout the City in buildings that would • Make City-owned land available. Make surplus City- not otherwise provide housing opportunities for residents with owned land available for developers at a discount, a range of incomes. Implementing an IHDRAFT policy may require provided that it is used for affordable, senior or supportive City staff to reach out to the development community to explain housing development. requirements, discuss alternatives and offer guidance on process and compliance. Where possible, aligning IH policy • Identify surplus land held by major landowners in requirements with policies in neighboring communities can Wauwatosa. Work with Milwaukee County and other make administration and compliance easier for developers major landowners in Wauwatosa to identify surplus sites and can enhance support for the policy. that could be made available for affordable, senior or supportive housing development. Appendix H analyzes the impacts of a sample IH policy on a hypothetical development project to illustrate the potential • Undertake site assembly in key areas. Given that impacts of IH on development in Wauwatosa. This appendix Wauwatosa is landlocked and has limited redevelopment also includes a matrix of inclusionary housing policies and sites available, consider undertaking site assembly profiles of Midwestern communities with incentive-based in areas identified as promising for future affordable policies. St. Louis Park, Minnesota’s, inclusionary policy, which housing development. Once site assembly is complete, has resulted in the development or approval of more than 280 make the land available either through sale or RFP for the affordable units since 2015, is profiled in Appendix E. development of affordable, senior or supportive housing.

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Immediate Actions Steps financing for private projects that would otherwise be financially infeasible. An AHF could also be used for • Inventory existing City-owned land to identify sites that City-led site acquisition, assembly and preparation, as could be made available for housing development well as a match for leveraging external funding sources. through either sale or RFP. For example, the Wisconsin Housing and Economic • Work with Milwaukee County and other major landowners Development Authority (WHEDA) has indicated that in Wauwatosa to identify surplus land. including local funds in a project reduces the amount of • Monitor listings and potential sales in areas targeted for LIHTC allocation needed and can improve a project’s future housing development and strategically purchase competitive LIHTC score. sites that could be used for affordable, senior or supportive housing. Place special emphasis on monitoring areas of • Determine mechanism to distribute funds. AHFs often use obsolete land uses and deteriorated or abandoned sites. a request for proposal (RFP) process (see pages 5-6) to • Make sites available through listing for sale or as an award grants or loans . Award terms could be variable incentive in an RFP. to incentivize certain priorities, such as providing more attractive terms for addressing pressing local priorities. DEVELOP A CITY-ADMINISTERED AFFORDABLE HOUSING FUND • Capitalize the fund. An AHF can be funded by amending/ extending existing Tax Increment Finance districts (TIDs) to Develop an Affordable Housing Fund (AHF) as a primary capture the one additional year of increment earmarked tool to achieve local affordable housing priorities (see pages for affordable housing. Other sources of capital to explore 24-25 for additional detail). To create an AHF, the Common include general City funds and outside grant funding. Council needs to: Immediate Actions Steps • Develop an administrative structure. Prepare a framework to guide operations, oversight and compliance (e.g., how • Craft a policy outlining AHF administration, form of priorities will be set, projects evaluated, funding distributed assistance, awards process and compliance requirements. and projects monitored over time). • Identify potential target uses, e.g. the populations to be DRAFTserved or the housing types to target. • Identify target populations and project types. Develop • Conduct outreach to solicit input from the stakeholder guidelines outlining the types of projects that the AHF will groups identified above. Consider aligning program support, including considerations for the built form (e.g., requirements with QAP requirements and deadlines to single or scattered site, single- or mixed-use, geographic award funds prior to WHEDA deadlines and leverage area) and the population to be served (e.g., household City funds into projects well-positioned to score highly on income levels, special needs populations, specific age LIHTC. cohorts). Determine programmatic requirements of • Prepare annual estimates of anticipated AHF requests funding sources the AHF may leverage (e.g., the State’s based on targeted uses and City housing goals. Qualified Action Plan (QAP) for Low-Income Housing • Identify potential one-time and ongoing sources of Tax Credit (LIHTC) awards). Consider the input of revenue and prepare five-year revenue projections. affordable housing advocacy groups, the development • Capitalize the AHF with funds from the affordable housing community, the public and other stakeholder groups. extension year from TID #5 closing in 2018. • Extend existing TIDs to capture the one additional year of • Identify appropriate uses of AHF assistance. Typically, increment earmarked for affordable housing. AHF for new housing development is used as “gap” • Identify additional sources of funding for the AHF.

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TARGET USE OF COMMUNITY DEVELOPMENT BLOCK households to be assisted (e.g., seniors, families, the GRANT FUNDS FOR HOUSING PRODUCTION homeless, people with disabilities). • Modify City CDBG policies and practices to achieve Enhance the City’s ability to support the development of new long-term housing goals, including spending goals and affordable and/or accessible housing units through targeting leverage targets. of community development block grants (CDBG) funds to the • Identify and solicit housing service providers that match development of housing units. City housing priorities to begin operations in Wauwatosa.

• Define housing priorities. The City’s current five-year CREATE DOWN-PAYMENT ASSISTANCE PROGRAM CDBG Consolidated Plan covers the 2014 to 2018 AND/OR EMPLOYER-ASSISTED HOUSING PROGRAM programming period. As City staff prepare its next five- year plan for the 2019 to 2023 period, establish concrete, Implement a down-payment assistance program, possibly in long-term, attainable housing goals (for an example of this, partnership with one or more large local employers, to increase see the goals matrix from La Crosse’s 2015 Consolidated the ability of lower-income employees to reside in Wauwatosa. Annual Performance and Evaluation Report (CAPER) in Appendix E). Encourage a more proactive pursuit of • Develop a down-payment assistance program. housing-focused programs by establishing a percentage Down-payment assistance programs reduce barriers of annual CDBG allocations to devote to housing, rather to homeownership for households that can afford the than responding to external partners requesting funding. monthly mortgage payments but face barriers in saving sufficient funds for a down payment. Down-payment • Expand operations of existing housing service providers assistance is typically offered as either a grant or a second and/or solicit additional providers. Work with existing mortgage. Second mortgages can be structured either partners to identify opportunities to expand current as an installment loan for moderate-income households programming and/or actively solicit housing service or a deferred loan due at a future date (e.g., upon sale providers whose services align with City’s housing priorities or transfer of the home) for lower-income households. and that have capacity to work regularly in Wauwatosa. The City of Madison, Wisconsin, has implemented a • Leverage CDBG funds for housing.DRAFT When allocating home-buyer assistance loan program, described further CDBG funds, prioritize investments that leverage funds in Appendix E. The Wisconsin Housing and Economic from other sources. Aligning the CDBG application Development Authority (WHEDA) also offers down- process with complementary programs from other units of payment assistance but limits participation by home government demonstrates local commitment to desirable purchase price, currently $253,809, which may limit projects. As part of program monitoring and goal-setting, applicability in Wauwatosa. Similarly, the Milwaukee track CDBG investments to monitor the leverage the City County HOME Consortium offers a limited amount is able to achieve in terms of additional resources brought of HOME funds for down-payment assistance in into a project and target a benchmark rate. Wauwatosa, West Allis and suburban Milwaukee County.

Immediate Action Steps Wauwatosa has provided CDBG funding to Housing Resources Inc. in the past for a down-payment assistance • Define long-term housing goals as part of U.S. Department program, but the program has faced challenges in of Housing and Urban Development (HUD) consolidated attracting households who could both afford to purchase planning process, including, for example, quantifiable in Wauwatosa and meet program income requirements. goals of units to be assisted or created or types of Therefore, funding for a new down-payment assistance

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program may be needed from sources without affordability expertise drafting EAH policies for employers, as requirements as strict as CDBG funds. A new program described in Appendix F. could evolve into a revolving loan fund over time as initial • Consider using a City-administered, down-payment loans are repaid. assistance program as a source of matching funds to induce employers to establish EAH programs. • Implement rental assistance program. To address rental • Based on employer feedback, define City role and affordability, offer assistance for renters by providing funds potential program structure for EAH program and needed when a lease is signed – either a security deposit implementation steps. and/or first/last month’s rent. A rental assistance program could be capitalized with federal entitlement program PROMOTE USE OF HOME FUNDS or City-administered funds. This program could develop into a revolving structure rather quickly as tenants move Become more engaged and proactive in the use of HOME in and out of units and the City recovers capital. Specific funds within Wauwatosa. eligibility criteria can be defined (e.g., income eligibility, renters who work in Wauwatosa). • Increase coordination with the Milwaukee County HOME Consortium (MCHC). Enhance contact and coordination • Initiate Employer-Assisted Housing (EAH) program with MCHC to increase awareness of MCHC priorities discussion. EAH describes efforts by employers to and resources and improve opportunities for Wauwatosa incentivize their employees to live nearby through a variety to obtain HOME Partnership program funds to achieve of means, including down-payment or rental assistance. its affordable housing goals. An improved relationship Depending on local employers’ interest in participation, with MCHC and understanding of HOME investments employer contributions may be used as a financing source may allow the City to proactively request and negotiate in a City-administered program. Alternatively, employers funding for local projects or programs. could operate funds independently as a benefit for employees. (See Appendix F for more information on case • Monitor and advocate for HOME funding in Wauwatosa. study EAH programs). Proactively track and monitor HOME funds used within Wauwatosa to gauge success in meeting housing goals. Immediate Actions Steps DRAFT • Target use of HOME funds for local priorities. Leverage • Coordinate with providers of existing down-payment the relationship with MCHC and understanding of local assistance programs to identify ways to make those funds HOME spending to better understand the HOME funds as widely available in Wauwatosa as possible. available and the local projects/programs best suited • Identify gaps in the provision of down-payment assistance to attract those funds. Given the regulatory compliance from existing funders and design Wauwatosa’s program associated with the HOME program and the common to supplement existing programs. preference to invest it in larger amounts across fewer • Create a program to provide deposit funds to renters who projects, the City may focus its efforts on providing funding meet City-defined eligibility terms. for new affordable housing developments (whether single- • Begin discussions with major local employers to gauge site rental housing or scattered-site single-family homes). interest in and encourage participation in an EAH program. Identify a preferred model – City-operated • Coach prospective projects and developers through fund, employer-operated program or another structure. process. Identify promising projects and work with • For an employer-based EAH model, offer financial developers to prepare their applications to MCHC to assistance to work with an outside organization with increase chances of receiving HOME funds.

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Immediate Actions Steps Immediate Actions Steps

• Conduct regular meetings (e.g., quarterly) between City • Identify and meet with affordable housing organizations and MCHC staff. active in southeast Wisconsin relevant to Wauwatosa’s • Develop stronger understanding of existing MCHC housing needs. funding availability and the opportunity to leverage funds • Produce a briefing document to inform these organizations to address Wauwatosa’s unmet housing needs. of Wauwatosa’s housing needs and available resources. • Annually track the use of HOME funds in Wauwatosa. Recommended Next Steps Recommended Next Steps • Maintain contact with relevant organizations over time. • Identify projects which meet City priorities that may be • Act as a point of coordination for affordable housing viable candidates for HOME funding. service providers. • Work with developers to prepare applications for MCHC funds. Policy Priority B: Preserve Existing Housing by Addressing Accessibility and Deferred DEVELOP/ENHANCE PARTNERSHIPS WITH AFFORDABLE HOUSING ORGANIZATIONS Maintenance Issues Associated with an Aging Housing Stock Build relationships with organizations dedicated to affordable housing creation and preservation to leverage the City’s The Housing Study found Wauwatosa’s existing housing stock investment into its affordable housing programs and capitalize to be of high quality but also aging, with seven in 10 housing on the expertise and financial resources of the outside units built before 1960. Proper maintenance and rehabilitation organizations. of these older housing units is critical in maintaining the quality of housing and ensuring safe and accessible living spaces. • Coordinate with affordable housing organizations. Ongoing maintenance for aging properties can be financially Reach out to organizations active in southeast Wisconsin challenging for some homeowners, particularly those with fixed focused on issues that align with Wauwatosa’sDRAFT housing incomes. The City currently provides Community Development goals, including affordable housing developers, service Block Grant (CDBG) funding to the non-profit Community providers (e.g. supportive housing groups), lenders (e.g. First in support of a program for emergency substantial home Wisconsin Housing and Economic Development Authority repairs. In addition, a Milwaukee County program provides (WHEDA) or the Federal Home Loan Bank of Chicago), no-interest loans using HOME funds for the rehabilitation of stakeholder groups representing prioritized populations owner-occupied units for income-eligible households. The (such as Movin’ Out, a provider of housing solutions City should leverage and expand these programs to aid more for people with disabilities and their families), and other residents in addressing deferred maintenance and making stakeholders. Connecting with these groups creates accessibility improvements. opportunities to connect Wauwatosa’s needs with each organization’s area of focus and available resources. DEVELOP A GENERAL HOUSING FUND

• “Quarterback” the process. Coordinate between Create a General Housing Fund (GHF) as a more flexible developers, funders, service providers, and groups companion tool to the Affordable Housing Fund (AHF) (see representing priority populations. (The City of Madison’s page 8). experience with this role is described in Appendix E).

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• Target populations and project types. Craft the GHF to modification program funds include CDBG, HOME, City- target priorities and populations not covered by the AHF administered AHF/GHF, and/or Tax Increment Financing (e.g., offering assistance to households with a wider range (TIF). To implement the program, leverage existing of incomes). relationships with non-profit organizations providing home rehabilitation services. A home modification program • Identify appropriate uses of GHF assistance, develop could be structured in one or more of the following ways, mechanism to distribute funds, and develop administrative depending upon City goals and funding sources: structure. Once the priorities for GHF funds have been identified, follow the same programmatic steps described • Funds for third-party service providers. Expand in the creation of the AHF. existing programming and provide additional funds directly to third-party organizations which work with Immediate Actions Steps homeowners to perform home modification work. New funding sources, such as the AHF and GHF, • Follow the same steps outlined for the AHF to establish a would expand existing programming to help improve GHF. Priorities will vary, but other steps are the same. aging housing stock.

CREATE MODIFICATION PROGRAMS FOR OWNER- • Grants or forgivable loans. Award grants or OCCUPIED AND RENTAL PROPERTIES forgivable loans – which are forgiven/converted to a grant once a homeowner satisfies certain • Create home modification program for owner-occupied conditions (such as length of residency) – to support properties. Financing for home improvements may be maintenance and improvement of aging housing difficult and/or costly to obtain from conventional lenders stock. Community First, a current Wauwatosa CDBG for certain residents who own their own homes. The beneficiary, employs a forgivable loan model in Wisconsin Housing and Economic Development Authority Milwaukee, with loans forgiven five years after (WHEDA) currently offers low-interest loans for home origination for single-family homeowners and after a improvement through private lenders but has indicated specified affordability period has elapsed for owner- that the program is not widely used. Existing City and occupied duplexes. St. Louis Park, Minnesota, uses Milwaukee County programs are relativelyDRAFT limited in scale a grant program to provide funds for emergency and availability. A new City program designed to serve repairs to necessary building systems for low-income residents who own their homes, but cannot access existing households (described further in Appendix E). programs (because of income limits, lending terms, or other reasons) would provide grant funding and/or • Revolving rehabilitation loan fund. Capitalize a financing with favorable terms for home repair (e.g., for revolving loan fund empowered to make new loans major systems like roofing, windows, plumbing, HVAC), only after outstanding loans are repaid. Provide loans weatherization and/or accessibility improvements. to homeowners meeting specified criteria related to home age, improvements and/or income. Because Uses of funds under a home modification program would such loans would require regular servicing to ensure be limited to the types of improvements the Common homeowners have completed the improvements and Council wishes to prioritize. Terms of assistance can be tied are making required payments, consider working with to income levels, with more favorable grant or loan terms a third-party entity to administer this program (e.g., available to lower-income homeowners who have less for loan distribution and servicing) or ensure City staff access to capital and potentially greater financial burdens has the capacity to disburse and service the loans. related to home maintenance. Potential sources for home

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• Reverse mortgage/deferred loan fund. Develop affordable housing” and may benefit from below-market a reverse mortgage and deferred loan program loan terms for rehabilitation. Rent limitations (e.g., to HUD- to provide either an upfront lump-sum payment or identified fair market rents) for a period of time could be stream of payments to the homeowner, to be repaid included as a term of this assistance. only when the property transfers ownership. Such funds can be used by homeowners with substantial • Clearly publish licensing requirements for home home equity but limited income to improve and/or improvement vendors. Provide a resource for residents maintain homes. A reverse mortgage or deferred seeking home improvement services by publishing a loan structure would have simplified compliance, with clear description of the licensing requirements for relevant a single lump sum repayment rather than the annual firms. Residents should be encouraged to verify firms are loan servicing responsibilities associated with a more appropriately credentialed, and residents using City funds traditional loan (as with a revolving rehabilitation should be required to do so. loan fund). A reverse mortgage/deferred loan fund could be structured as a revolving loan fund, though Immediate Actions Steps the longer term of such loans may make the revolving component somewhat limited. • Coordinate with providers of existing owner-occupied and/or rental property modification assistance programs • Create a rental housing modification program.Develop to identify ways to make those funds more widely a residential modification loan program for rental available. housing similar to that for owner-occupied units offering • Identify gaps in service among the existing modification below-market terms (e.g., lower interest rates, more programs available. flexible repayment features) relative to conventional • Publish licensing requirements for home improvement bank financing. Loans under a rental housing revolving vendors. fund would likely be structured as standard loans, not as deferred or potentially forgiven loans. Rental properties, Next Steps if maintained, should support a steady stream of income to property owners, allowing them to fully amortize • Craft a policy to address identified gaps in resources for the costs of apartment unit improvementsDRAFT over time. owner-occupied and/or rental property modifications. Outline program administration, funding, intended WHEDA’s commercial lending programs provide limited purpose (targeted uses, populations, housing types), form options for private market owners of existing buildings of assistance and compliance requirements for any new exploring rehabilitation of their properties. WHEDA’s programs. main tool for rehabilitation for existing owners is primarily • Determine if additional licensing requirements are to be available to non-profit property owners. Eligible owners required for home improvement vendors conducting work should be directed to WHEDA’s existing multifamily using City funds. If so, incorporate additional requirements rehabilitation lending programs. A new Wauwatosa into relevant program guidance. program funded with the GHF could then target private, generally market-rate multifamily properties ineligible for ACQUIRE AND MAKE AVAILABLE CITY-OWNED WHEDA funding. The City should determine parameters to ACCESSIBILITY IMPROVEMENTS limit the loan funds to properties that may have challenges in obtaining conventional financing (e.g., older single-site • Acquire and make available City-owned accessibility two- to eight-flat buildings). This segment of the market improvements. Purchase mobile/temporary ramps or has been recognized as providing “naturally-occurring chair lifts and loan them to homeowners with accessibility

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needs. Refurbish and reuse the improvements once they Policy Priority C: Enhance Ability of Current are no longer needed at a particular home. Fund the Residents to Age in Place within the program with CDBG or City-administered AHF or GHF. Community Immediate Actions Steps Aging in place often refers to two goals: 1) allowing residents to remain living independently in their homes as long as • Identify the types of accessibility improvements the City possible, and 2) ensuring alternative housing options exist in will offer. the community so that residents can move within the community • Outline process for purchasing and managing an inventory when they want or need to move out of their long-term of City-owned accessibility improvements. home. The City already provides support to service providers • Make improvements available to residents through long- and dedicated senior housing facilities with Community term leases. Development Block Grant (CDBG) funds. Strategies to enhance the ability of seniors to age in place in Wauwatosa are outlined REDEVELOP SELECT PROPERTIES below. • Redevelop select properties. In cases of extensive home or DEVELOP NEW SENIOR HOUSING OPTIONS rental property deterioration where rehabilitation may not be financially viable, implement a selective redevelopment • Develop new senior housing options. Apply programs program modeled on the program in La Crosse (described for the creation of new affordable units (see pages 5-11) further in Appendix E). Using Community Development to senior-targeted projects. For example, offer financial Block Grant (CDBG), HOME, City-administered assistance through a request for proposals (RFP) process Affordable Housing or General Housing Funds (AHF/ for the construction of new housing for seniors, with GHF), or Tax Increment Financing (TIF) funds, acquire and specific accessibility guidelines or supportive housing demolish dilapidated single-family properties, and then requirements. In a senior housing-focused RFP, emphasize use dedicated housing funds to support construction of new development of new units within existing neighborhoods single-family homes or small rental buildings for low-to- with a range of services, as opposed to outlying areas moderate income (LMI) households. This program would where mobility challenges may limit senior’s access not be intended to provide large-scale redevelopment DRAFTto community resources. Target the creation of a mix but would address locally-problematic properties and of housing types (e.g., townhomes, condominiums or provide an opportunity to develop high-quality, fully- accessory dwelling units (ADUs)) (see pages 16-19) to accessible, scattered-site affordable housing. enhance options for seniors, and, in the case of ADUs, generate potential income streams for homeowners. Next Steps Recommended Next Steps • Develop program of selective redevelopment of properties where rehabilitation is not financially viable • As the City releases RFPs for construction of new housing with scattered-site, affordable, accessible single family or units, consider adding preferences for new housing for small multifamily properties. seniors, with specific guidelines related to accessibility, supportive services and geographical locations within existing communities with nearby services.

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DEVELOP FINANCIAL ASSISTANCE PROGRAMS FOR Common Council to identify funding and implement FIXED-INCOME SENIORS proposed program.

• Develop financial assistance programs for home operating Next Steps costs. Reverse mortgages or deferred loan funds (see page 13) provide funds to homeowners that are repaid when a • Convert home operating cost assistance program into a property transfers ownership. For seniors with substantial revolving loan fund. home equity but fixed incomes, a similar structure could assist with substantial ongoing home operating costs CONNECT SENIORS TO SERVICE NETWORKS such as property taxes, special assessments (i.e., for sidewalk, curb or gutter improvements) and city-operated • Identify concentrations of senior citizens. To better utilities. Initial capital provided by the City or Affordable target the City’s and partner agencies’ senior services, Housing or General Housing Funds (AHF/GHF) could conduct detailed demographic research and work with be used to pay the borrowers’ taxes or utility bills. service providers to identify areas of the City with high concentrations of senior citizen residents. Reinforce Borrowers typically apply to such programs annually and service provision to these “naturally occurring retirement have a lien placed against their home for the borrowed communities” (NORC) and direct other programs there as amount to be repaid upon sale of the home. For borrowers well. who reapply annually, the lien is essentially refinanced with the balance increased to include the newly borrowed • Connect seniors, especially within identified NORCs, amount plus previous principal. This structure is used for a to service networks. Serve as a point of coordination, property tax assistance program in the City of Madison, connecting housing service providers/servicers with non- Wisconsin, and is described in more detail in Appendix E. profit organizations serving the senior population. Use Such a program could eventually evolve into a revolving the City’s relationship with Interfaith Older Adults as a fund, but would need several years of up-front financing building block to connect housing programming with the from other sources to sufficiently capitalize the fund, given senior-specific services provided by Interfaith, and vice the potentially lengthy terms of loans. As part of the intake versa. For example, the Milwaukee County Department of process for any real estate tax assistance,DRAFT ensure that Aging (MCDA) is the City’s Area Agency on Aging and homeowners are receiving all proper property tax credits uses federal funds to contract with senior-oriented service allowable under Wisconsin law. providers (including Interfaith). Convene a working group with representatives from MCDA, Interfaith and the City’s • Develop financial assistance for home maintenance costs. housing programs to develop a detailed operations Ensure that the full suite of programs to assist with expenses and outreach strategy to connect senior services, for home modification and accessibility improvements (see housing services, and the seniors who could use them. pages 11-14) are available and marketed to any low- Replicate the Interfaith model for other types of service income seniors meeting income requirements specified for providers (e.g., health services) to increase the range of each program. services assisting seniors to remain in their homes longer. Train any City staff with high levels of interaction with the Immediate Actions Steps senior citizen community on the suite of housing programs offered through the City and provide information to likely • Conduct outreach with senior citizens groups and elected beneficiaries. officials to develop a framework for a new program to assist seniors with home operating costs. Work with the

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Immediate Actions Steps Policy Priority D: Ensure a Mix of Housing Types is Available • Conduct demographic research and interviews with service providers to identify NORCs. The Housing Study found that anticipated population growth • Educate city workers in contact with the senior citizen as well as demographic shifts among Wauwatosa residents community about the housing assistance programs are likely to drive demand for a different mix of housing types available through the City. than what currently exists. In particular, this shift is expected • Identify and meet with senior citizen service providers to increase demand of for-sale attached housing in the active in Wauwatosa. Connect them to City and non-profit form of townhouses or condominiums. The Housing Study housing programs and services. also anticipated increased demand for market-rate rental • Explore replicating the Interfaith model with additional multifamily and higher-end single-family units. Diversifying service providers for other types of senior services (e.g., the City’s housing stock would address these trends. The health services). private market has recently responded to demographic and market changes, producing hundreds of units of multifamily Next Steps rental product. Higher-end detached single-family homes are typically provided by the private market as well. The City can • Conduct outreach to senior citizen service providers/ therefore direct its support to housing types that may not be senior citizen groups as part of any future outreach as easily produced by the private market, through mechanisms effort to improve relationships with affordable housing described below. organizations. The Housing Study identified starter homes as a missing CONSIDER THE BUILT ENVIRONMENT AND ITS IMPACT component of the local housing stock. Developing alternative ON SENIORS housing types in the community like attached single family and condominiums may help in this regard by providing this option • Consider the built environment and its impact on seniors. to first time home-buyers but also by providing alternatives The built environment plays an important role in whether to existing homeowners looking to move but remain in the seniors are able to comfortably age in place, especially community, thereby potentially making their units available to as options for mobility decrease. AsDRAFT the City develops first-time home-buyers. In this way, other strategies described and implements policies regarding its built form, consider in this document may indirectly aid in making starter homes impacts to seniors. This includes emphasizing accessibility available. requirements and universal design in changes to the building code; emphasizing walkability; implementing REFINE REGULATORY FRAMEWORK the City’s complete streets policy; improving transit connections (especially in NORCs); encouraging mixed- • Specify desired housing types in the City’s Tax Increment use development; and locating City services in locations Finance (TIF) Program Policy. Specify the missing housing accessible by walking or transit. types identified in the Housing Study as a new line item in the Public Purpose Objectives of the City’s TIF Program Next Steps Policy or as a specification of item B.6 to more explicitly incentivize such housing types. • As the City implements policies impacting the built form, consider effects on senior citizens and the City’s NORCs. • Expand multi-unit residential zoning options. Consider expanding the range of multi-unit residential zoning options to include:

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• At least one multi-unit “R” district that does not place C2’s current residential density restriction, which would an absolute cap on the number of dwelling units accommodate smaller residential dwelling units, larger allowed on a parcel (e.g., an “RM” district that limits residential buildings (in appropriate settings) and greater building scale and density without an absolute cap on housing choice. Along with an increase in density, consider the number of units that can be located on a lot); and imposing an overall maximum building height restriction in the C2 district in alignment with the new density regulation. • An expansion of the uses allowed in the “SP-MED” (Medical Center) zoning district to include multi- Under the City’s current zoning ordinance, all zoning unit residential or creation of a companion special districts that allow multi-unit residential and mixed-use purpose zoning district specifically intended for buildings limit the number of units allowed on the subject application near the medical center campus or in lot through the imposition of minimum-lot-area-per-unit other predominantly commercial or industrial areas (MLA) requirements. Applicable MLA regulations are as where multifamily development could be appropriate. described in the table below.

The City’s zoning ordinance currently includes two multi- With an allowed density of up to 27 units per acre and unit residential districts: R4 and R8. Both districts allow a maximum height of 35 feet, the R4 and R8 districts detached houses, semi-detached houses, duplexes appear to be roughly aligned. In other words, it is at least and multi-unit (apartment or condominium) residential theoretically possible to achieve the maximum allowed buildings. These districts are differentiated solely on the density while complying with the maximum allowed basis of the number of dwelling units allowed on a single building height. The same is generally true in the C1 district. lot, with the R4 district capped at four units and the R8 However, since the C2 district allows unlimited building district at eight units. Because of these dwelling unit height, the current MLA requirement imposes an artificial caps, any development project that includes more than constraint on residential density. eight dwelling units must either be located in a C1 or C2 district or be processed as a PUD, which are the only One alternative could be revising the C2 district’s MLA other zoning options for multi-unit residential buildings. requirement to 400-500 square feet per dwelling unit and imposing a maximum building height limit of 90-100 feet Changes to the zoning code would beDRAFT subject to the City’s (7-9 stories). Another option would be to establish multiple typical public input process. versions of the C2 district so that maximum height limits vary based on the area’s character and context. Under • Relax residential density limits. Align all of the regulations such an approach, the district could include multiple height (e.g. density, building height) within a given zoning district classifications, identified by a height designator appended so that buildings could be reasonably constructed and not to the district name (e.g., C2-45, C2-60, C2-90, C2-120). limited by any particular regulation. Consider relaxing

District Minimum Lot Area per Equivalent Density Maximum Height Dwelling Unit (sq. ft.) (units per acre) (feet) R4 1,600 27 35 R8 1,600 27 35 C1 1,000 43 40 C2 1,000 43 No maximum

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• Allow for construction of Accessory Dwelling Units. To materials outlining the process and guide developers facilitate a greater variety of housing types, adjust the through conversion. City zoning ordinance to allow accessory dwelling units (ADUs), which are small rental dwelling units on single- • Address other regulatory barriers to multifamily housing family home lots. ADUs can be contained within the development. Municipal regulatory structures can often principal dwelling unit (e.g., basement apartment) or unintentionally hinder development of certain land uses. within a separate structure entirely (e.g., carriage house To address this, implement regulatory changes that can or apartment above a detached garage). ADUs increase reduce the costs of producing multifamily housing including rental options, present potential new income streams for parking requirements, unit size/amenity requirements, homeowners and provide additional living arrangement rehabilitation requirements for existing buildings, and options (e.g., family members or caretakers living on- permissiveness of innovative building techniques. site) for the elderly or other residents with special needs. (A proposed zoning ordinance text amendment to allow Immediate Actions Steps ADUs is presented in Appendix G). • Specify desired housing types in the City’s TIF Program • Modify Planned Unit Developments (PUD) process for Policy. selected housing types. Explore use of an expedited • Work with Common Council to expand multifamily PUD approval process for projects providing certain City- residential zoning options and recalibration of zoning identified public benefits, such as inclusionary, senior or district density limits. supportive housing. If the City does not pursue expansion • Expedite the PUD process for projects providing certain of multi-unit residential zoning options or recalibration City-identified public benefits. of residential density limits, the primary mechanism for • Facilitate multifamily rental to condominium conversions. multifamily development will continue to be the PUD zoning Resolve any points of ambiguity in the process, prepare option. PUDs are intended to allow for a variety of housing document outlining process, and guide developers types and compact development patterns with mixed land through the process. uses by providing greater flexibility in land use, density • Work with consultants/Common Council to implement and site design requirements relative to underlying zoning. revisions to City zoning ordinance to allow ADUs. Due to the lack of multifamily residentialDRAFT zoning options, most recent multifamily projects in the City were built in PUD PROVIDE FINANCIAL ASSISTANCE overlay zones. The review and approval process for PUDs extends beyond that required for as-of-right development • Proactively solicit developers. Conduct outreach to and the outcomes of case-by-case project review can developers experienced in building the range of housing be highly unpredictable for developers and neighbors. types targeted by the City. This may be done as part of an RFP process but does not need to be restricted to that • Facilitate conversion of rental units to condos. Developers process. active in Wauwatosa have designed or have considered designing multifamily rental projects such that they could be • Provide financial assistance. The City has made financial converted to condominium units in the future. To facilitate assistance available in the form of Tax Increment such conversions, undertake a review of the relevant Financing (TIF) gap financing to support the construction regulatory process, including steps such as filing a plat of of multifamily rental buildings in the City. While this has subdivision and seeking approval through the Planning increased available housing choices, not all housing types Commission and Common Council, to identify points of identified in the Housing Study are being developed. ambiguity and take steps to clarify the process. Prepare Condo and attached single-family projects are currently

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difficult to finance due to the inability of sale prices to Next Steps support development costs and conventional lenders’ pre-sale requirements. To enable these projects to move • Review City zoning ordinance for areas where revisions forward, provide financial assistance to address at least may reduce the costs/barriers to the production of one of these issues: multifamily housing. • As the City releases RFPs for construction of new housing • Development Costs. Offer low-interest construction units, consider adding preferences for specified housing loans or private loan guarantees, short-term types in demand but generally unavailable in Wauwatosa. financing through project stabilization, or reduced- • Using information gained during developer outreach, price City-owned land. If the project meets other design financial assistance tools to overcome financial community development objectives, such as challenges to the production of desired housing types. including a mix of housing types or being located • Include a first-time home-buyer component to any in a target neighborhood, waive development- proposed Down-Payment Assistance Program. related fees or loosen other requirements (e.g., the hypothetical inclusionary policy). In addition to TIF, City-administered Affordable Housing or General Housing Funds (AHF/GHF) and HOME are possible funding sources.

• Pre-Sale Requirements. Work with local real estate agents and brokers to identify potential buyers and direct them to proposed projects. Provide or guarantee a portion of construction financing, which is typically limited by pre-sale requirements and often challenges the feasibility of condo development.

• Issue a Request for Proposals (RFP) for new housing types. Offer financial assistance throughDRAFT an RFP process (see pages 5-6) that prioritizes housing types the Common Council has identified as missing from its local housing mix. The Housing Study identified for-sale attached housing as one type of housing that is not generally available in Wauwatosa but which is desired by residents. An RFP for a particular housing typology could be combined with some of the other RFP strategies discussed in this document, such as for senior-focused, special needs/supportive, or affordable housing.

• Support first-time home-buyers. Offer a first-time home- buyer down-payment assistance program as a subset of the Down-Payment Assistance Program (see pages 9-10) with below-market terms targeted to prospective home- buyers who have not previously owned a home.

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DRAFT

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2. Housing Key to implementing the Housing Policy and Action Plan is Action Plan: identifying available resources that the City already uses and additional resources that could be available to supplement current resources. City financial and regulatory tools available Toolkit to address unmet housing needs include:

• Tax Increment Financing (TIF); • Community Development Block Grant (CDBG) funding; • HOME Investment Partnership Program funding; • Land use zoning; • Zoning ordinance and design standards; • City-administered housing funds; • Dedicated housing staff; and • Organizational relationships.

This section provides an introduction to each tool, outlines its historic use in the City, and presents case study research into best practices from Midwestern peer communities. Options to modify and/or supplement existing tools to more effectively address unmet housing needs are presented here, with specific programmatic options for the use of each tool outlined in the subsequent section.

TAX INCREMENT FINANCING

Tax increment financing (TIF) is an economic development tool that allocates future increases in property taxes from a DRAFTdesignated area, or TID, to pay for improvements within that area. TIF is often used to leverage other public and private financing sources in support of private development.

TIF-eligible costs in Wisconsin include capital costs, land assembly, and infrastructure, among others. TIF can be used to directly benefit affordable housing projects by providing “gap” financing that improves a project’s financial feasibility. Municipalities in Wisconsin may extend a TID for one additional year after TID project costs are fully paid to fund housing improvements, with 75% of the additional increment required to be used to benefit affordable housing within the municipality and 25% used to improve the municipality’s overall housing stock. This is a relatively new feature of Wisconsin’s TID law, enacted by the legislature in 2009.

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HOW DOES TAX INCREMENT FINANCING WORK? • Land assembly and site preparation; • Housing construction/rehabilitation; Real estate property is taxed by several different government • Financing of extraordinary site costs (e.g. remediation or entities, including cities, counties and school districts, which parking); and apply an annual tax rate against the total assessed value • Incentivizing developers to include community benefits in (AV) of the property. Taxes collected by these government their project (e.g. setting aside a portion of the units in their entities are then used to provide municipal services that project for affordable housing). benefit that property, such as police and fire protection, education, and public health. Currently, two TIDs contain language permitting the extension of the TID for one year to support affordable housing. City staff When a TID is formed, the AV of the real estate property, has indicated that this language will be included in all future upon which real estate taxes are levied, is frozen for a TID plans, and existing TID plans could be amended to provide specific period of time (as allowed under state statute). Local for the housing extension. Based on SB Friedman’s review of taxing bodies continue to collect taxes based on this frozen the TID feasibility studies and council minutes, doing so could base value, while taxes levied against any increases in AV produce approximately $10 million over the next 25 years to due to new development, rehabilitation/improvement, or support housing efforts. property appreciation are allocated to a special fund that is used to pay for improvements within the TID. More information on TID use in the City is presented in Appendix D. Upon expiration of the TID, the government entities are able to levy taxes against the full value of the property, including COMMUNITY DEVELOPMENT BLOCK GRANT any increase in AV. FUNDING

The community development block grant (CDBG) program Use of TIF in Wauwatosa is a federal entitlement program administered by the U.S. Department of Housing and Urban Development (HUD). TIF has been the primary economic development tool for The program provides grants to cities and counties to assisting and incentivizing redevelopmentDRAFT in Wauwatosa address locally-identified community development needs and the use of TIF has been successful in facilitating the including housing conditions and the availability of economic redevelopment of blighted and underutilized properties, opportunity, with an emphasis on benefitting low- and supporting job creation efforts, and assisting with mixed-use, moderate-income persons. Funds are awarded annually market-rate development that has increased taxable value. on a formula basis to entitled counties and cities, including Through the seven active TIDs, the City has supported over Wauwatosa. Grantee communities have the freedom to plan 1,000 units of housing, more than 80,000 square feet of retail, how best to achieve HUD-defined goals locally and program and associated parking facilities since 2014. Estimated taxable their funds accordingly; however, most funds (70%) must be value of these six projects totals more than $125.0 million. used to benefit low- and moderate-income (LMI) households, defined as those with incomes up to 80% of AMI. In Milwaukee TIF can also be leveraged to address housing-related challenges, County, 80% of AMI for a family of four is $57,900 (2017). as noted in the 2014 City TIF policy, which prioritizes using TIF funds for “creating a range of lifecycle housing opportunities” Typically, CDBG funds for housing are spent on the following: and “protecting and revitalizing neighborhood character by removing blight in, or adjacent to, residential areas.” Potential • Residential rehabilitation; uses of TIF in support of housing objectives include: • Homeownership assistance;

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• Public housing improvements; takes a different approach to connecting CDBG funding to • Energy efficiency improvements; service providers by setting internal policies mandating certain • Lead-based paint remediation; percentages of CDBG funds be spent on housing, discussed in • Code enforcement; Appendix E. An application of this more proactive strategy in • Historic preservation; and Wauwatosa is discussed further on page 9. • Operation and repair of foreclosed property. Best Practices for the Use of CDBG Housing practitioners interviewed by SB Friedman typically viewed CDBG funds as being easier to deploy in small- SB Friedman reviewed HUD best practices and conducted case scale projects, such as rehabilitation and home modification study research in peer communities to identify best practices programs, due to their less onerous oversight terms when in the use of CDBG funds, many of which the City is already compared to other HUD-administered programs like HOME. practicing.

Historic Use of CDBG in Wauwatosa Short descriptions of HUD-identified projects with effective uses of CDBG funds are available in Appendix E. Best practices for From 2013 to 2017, Wauwatosa received roughly $900,000 the use of CDBG funds are also presented in case studies of annually in CDBG funds, with an average of 15.3% of funds peer communities in Appendix E. being spent on housing activities, 65.2% on all other non- housing community development activities, and 19.5% on HOME INVESTMENT PARTNERSHIP PROGRAM planning and administration. FUNDING

Housing-related CDBG expenditures since 2013 have ranged The HOME program is administered by HUD, and consists from 6.2% to 26.9% of Wauwatosa’s annual allocation, and of block grants to states, counties, and municipalities to have been used to support: fund solutions to locally-identified, eligible housing needs. Communities are determined to be eligible via a formula which • Greek Manor. Upkeep of a 34-unit subsidized residential takes into account the local housing market and demographic facility for low-income seniors and residents with physical conditions. Eligible uses of HOME funds include: disabilities; DRAFT • Community First. Rehabilitation of homes occupied by • Tenant-based rental assistance; LMI households, prioritizing code violations, health/ • Housing rehabilitation; safety hazards, accessibility modifications, security • Assistance to home-buyers; improvements, and structural repairs; and • New construction; • Housing Resources Inc. Funding of a down-payment • Site acquisition; assistance program. • Site improvements; • Demolition; Most of the City’s CDBG funds are committed in response to • Relocation; and organizations’ requests for assistance, rather than through a • Other necessary and reasonable activities related to the process driven by City priorities. Historically, the City’s ability development of non-luxury housing. to direct CDBG dollars to housing uses has been limited by the organizational capacity of partner organizations to request Units developed with HOME funds must have rents that meet and deploy CDBG funds annually. Potential barriers to meeting HUD-published standards for their markets. Households housing objectives include: shortage of available land for new occupying HOME-funded units must also meet affordability construction, low vacancy rates and high land values. La Crosse standards – with incomes no greater than 80% of AMI and

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a majority with incomes at or below 60% AMI. Affordability overlay are to allow for a variety of housing types and to standards for Wauwatosa are outlined in Appendix C. create “compact, mixed-use development patterns” where land uses may be situated in close proximity to one another. In SB Friedman’s interviews with housing practitioners, HOME This zoning designation is an existing tool that the City can use funds were often considered as having the most onerous with developers to encourage the mixing of land uses and the compliance terms, making deployment in small-scale projects creation of housing types that may not otherwise be allowed. more difficult. Ongoing eligibility certification and inspection requirements, among others, can be challenging for small Zoning Ordinance and Standards (Design, Parking, projects. Therefore, HOME funding is often provided to a Density) smaller number of relatively larger projects. The City’s zoning ordinance establishes maximum allowable Historic Use of HOME in Wauwatosa densities as well as lot and building regulations governing setbacks, building coverage and building height. The Wauwatosa does not receive HOME funds directly from ordinance also includes off-street parking requirements and HUD, as the City is a member of the Milwaukee County landscaping regulations. All of these regulations work to affect HOME Consortium (MCHC), and funds are directed through a site’s overall development potential. However, in some cases Milwaukee County as the lead entity. MCHC receives funds regulations could be better aligned to allow for greater housing of approximately $1.2 million annually for use in suburban choice. For example, the City’s C2 zoning allows unlimited Milwaukee County, Wauwatosa and West Allis. MCHC building height but imposes fairly strict limits on density. administers First-Time Homebuyers, Rental Assistance (including Revising regulations such as this may allow development of vouchers), and Home Repair Programs. HOME funds greater intensity on existing parcels without necessitating use supported the construction of 11 affordable senior units at of a PUD overlay. In other cases, Wauwatosa may consider Cedar Glen in Wauwatosa. flexibility regarding these requirements for all developments which include affordable units or aid the City in achieving other REGULATORY TOOLS housing-related goals, as some other communities have done. Any flexibility or relief provided through the zoning ordinance Regulatory tools, such as zoning and design standards, are would need to be part of an overall policy available to projects also a key component of the City’s toolkitDRAFT for addressing meeting policy criteria and would not be provided on a case- housing issues. by-case basis.

Land Use Zoning CITY-ADMINISTERED HOUSING FUNDS

Wauwatosa has and enforces a zoning ordinance, and uses The City has options to more effectively coordinate available this authority to regulate land use and development through resources to address unmet housing needs, but many of zoning, impacting housing type, tenure and affordability. The these efforts will ultimately require a source of capital. A key City could consider adjusting its zoning ordinance to allow the implementation tool is the creation of one or more dedicated, creation of different housing typologies and a greater mix of city-administered housing funds. While the City could develop residential and nonresidential land uses. a single fund capitalized with all of its available funding sources devoted to housing, that fund would be limited by The zoning ordinance includes a PUD zoning classification, the programmatic requirements of the most restricted funding which allows for development that would not otherwise source. Segregating funding sources into separate funds be permitted or which would be difficult to produce under according to the programmatic requirements of each funding existing zoning regulations. Two of the objectives of the PUD source may allow for greater flexibility. A two fund structure

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that may be appropriate for Wauwatosa is outlined below. others. Potential capital sources for dedicated housing funds are presented in the table below. • Affordable Housing Fund (AHF). A fund established solely for the purpose of funding affordable housing projects. Frequently, AHFs and GHFs are initially supported by general Funds could be used to provide low-interest loans or municipal revenue, bond proceeds and/or outside grants grants to developers, provide down-payment assistance, from public or private sources, generally with the goal that or support other programs that improve affordability for the funds will become self-sustaining over time. Though LMI households. An AHF would likely be capitalized with larger in population, the Cities of Madison, Milwaukee funds that have affordability requirements and would and Minneapolis all use general revenue funds as one of therefore likely be required to meet the requirements of the the primary funding sources for their municipal affordable most stringent funding source in its funding mix. housing funds. Supporting these funds with City revenues allows maximum flexibility when deploying the funds. Funds • General Housing Fund (GHF). A fund established to generated by extending expiring TIDs for an additional year improve the condition of the overall housing stock. Funds provide a source of funding as 75% of such funds must be used could be used to address code violations/deferred for affordable housing, with the remaining 25% eligible for maintenance, assemble land for residential projects, or to more general housing programming, corresponding to uses of support other programs that more generally improve the the AHF and GHF respectively. overall housing stock. A GHF should be capitalized with funds that do not come with affordability requirements to Operationalizing these funds is described in more detail on preserve its flexibility. Keeping the GHF free from funding page 8 (AHF) and pages 11-12 (GHF). sources which include their own spending guidelines would allow Common Council to set the terms on how DEDICATED HOUSING DEPARTMENT OR STAFF GHF dollars are used. In addition to available financial and regulatory tools, a Both funds could be used to leverage and demonstrate local dedicated housing department or staff would also advance the support for projects seeking other funding sources, including City’s housing goals. Currently, housing issues are managed private equity and debt, TIF, LIHTC, CDBG,DRAFT HOME, and by the Development Department where staff work on housing Source of Capital Funding AHF GHF TIF, including collections from the extra year of increment collection X X 75% of final year funds 25% of final year funds Federal entitlement funds (CDBG, HOME) X Fees paid by developers, such as an inclusionary housing fee (see pages 6-7) X X [1] Private grants/donations [1] X X Repayments from other loan programs or other program income [1] X X Interest accrued from government accounts X X City general funds (e.g., real estate taxes) X X [1] May be used for GHF provided that program requirements do not stipulate that the identified capital source must be used for affordable housing purposes.

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issues part-time in addition to fulfilling a variety of other duties. project equity, thereby reducing project debt and allowing Significant staff time is required to implement and operate lower rents without impacting overall financial feasibility. programs that are complex and require cooperation with multiple stakeholder groups (e.g., government agencies, In addition to administering the state’s LIHTC allocation, affordable housing and market rate developers, seniors, WHEDA also operates several lending programs. WHEDA populations with special needs, etc.). Dedicated housing staff lends directly to affordable housing developers for a variety would have the time to devote to developing and operating of eligible uses including acquisition, new construction, programs, enhancing technical expertise and enriching rehabilitation, preservation of affordable housing, and relationships with stakeholder groups. accessibility improvements, among others. These products are generally designed to provide terms that are unavailable on the Peer communities analyzed by SB Friedman often have private market, increasing the financial feasibility of affordable specialized housing staff with expertise in: housing development. Features of WHEDA loans that are more favorable than private market loans include below-market • CDBG and HOME programming and requirements; interest rates, longer terms, or ease of combination with other • Conducting outreach to developers; WHEDA tax credit and financing tools for example. Commercial • Conducting outreach to media; lending programs are available on a rolling basis throughout • Construction management; the year. To access these loan products, projects must meet the • Local inclusionary housing policies; eligibility requirements of the program; they do not compete • Local market conditions; with other projects, as for LIHTC allocation. Generally, projects • Operating affordable housing funds; obtaining commercial loans through WHEDA include a mix of • Operating revolving loan funds; and affordable and market rate units. • Reverse mortgages. WHEDA’s personal lending products make mortgage credit STRENGTHENED RELATIONSHIP WITH WHEDA available to single-family homebuyers and homeowners as well. These lending programs are administered through private One component of WHEDA’s mission is to provide affordable banks and serviced by WHEDA. There is no volume cap on housing in Wisconsin, which it achieves through partnerships single-family lending products and borrowers must meet with local governments and affordable housingDRAFT stakeholders. requirements and work with a WHEDA-approved lender. Among its programs, WHEDA administers Wisconsin’s Low- Income Housing Tax Credit (LIHTC) allocation, conducts While WHEDA indicated that they most commonly work commercial lending with its own lending products, and makes with developers, they work directly with municipalities as personal mortgage loans through partner lending institutions. well. Affordable housing staff from other cities in Wisconsin indicated that WHEDA can play a role in implementing LIHTCs were created in the Federal tax code and are intended to affordable housing strategies. WHEDA was involved in La draw private equity into the development of housing affordable Crosse’s RFP process targeting affordable housing developers. to LMI populations, including individuals and families, the In Madison, RFP requirements were crafted as an addendum elderly, persons with disabilities, and the chronically homeless. to WHEDA’s QAP guidelines. To the extent the City can further Each state is awarded an allocation of tax credits by formula. develop relationships with WHEDA, it may be able to enhance WHEDA awards its annual LIHTC allocation on a competitive local access to WHEDA resources. For instance, WHEDA basis once a year according to criteria laid out in the state’s has indicated they are willing to review proposed municipal Qualified Allocation Plan (QAP). Typically the deadline to programs and provide feedback on how such a program apply for LIHTC awards is in early December with awards in could enhance the scoring of a LIHTC project, increasing the February/March. Developers use LIHTC allocations to raise opportunity for local projects to receive a LIHTC allocation.

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3. Housing Implementing the policies and programs outlined above would Action Plan: require significant changes to existing City housing policies, procedures and staffing. Key considerations are outlined Administrative & below. Implementation ADMINISTRATIVE CONSIDERATIONS • Adopt a City Housing Policy. Prior to significant changes to the City’s housing programming, staff should draft and Considerations Common Council adopt a housing policy for the City. This adopted policy would guide City staff and Council as new and existing programs are implemented by clearly identifying City housing priorities, the intentions behind City housing programs and desired outcomes. Solicit feedback during the drafting, approval and adoption process from stakeholder groups and City residents.

• Expand housing-dedicated staffing.Proactively addressing the City’s housing issues and implementing new housing policies will likely require the addition of City staff dedicated solely to housing. Currently, implementation of housing issues are handled by Development Department staff who also focus on economic development, planning and other areas. All three case study communities have specific staff dedicated to housing. The City of La Crosse, which is comparable to Wauwatosa in both population and annual federal entitlement allocation, maintains two DRAFTfull-time housing specialists and three staff members who work on housing issues as needed. These staff members have specialized skills required to implement La Crosse’s programs (e.g., construction management, affordable housing finance expertise). If Wauwatosa expands housing staff, the City should align staff capabilities with the housing priorities and strategies being pursued.

• Define internal goals and track outcomes. As housing programs are created, it is important to define goals with measurable results against which outcomes may be compared to ensure programs are achieving intended impacts. For instance, a reverse mortgage program intended to limit the burden of property taxes on fixed- income seniors could track numbers of households assisted, dollars committed, assistance per household,

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average household income of households assisted, or groups on market conditions, specifically occupancy, some other metric to quantify program performance. rents, land availability, financing, and other issues driving In doing so, performance can be analyzed to evaluate development decisions. This provides the City with an whether the program is functioning effectively. If not, the opportunity to learn about current development conditions program can be reformulated. as well as to communicate City housing priorities.

• Define one mechanism for applying for City funds. As • Inform residents and publicize achievements. Informing the City implements new housing programs, it is important residents and stakeholders regarding City programs, to minimize the application process and administrative including how funds are being spent in the community burden to the applicant by providing a single application and the resulting achievements and public benefits can for all City programs. maintain and enhance community support for housing programs and funding allocations. This can occur • Align City programs with Milwaukee County HOME through local media but may require specific outreach to Consortium, the Wisconsin Housing and Economic stakeholder groups. For example, La Crosse publicizes Development Authority (WHEDA), and/other relevant grand openings and coordinates with the media to tell program requirements. Ensure that projects receiving individual stories of the people benefiting from their any City funding are best positioned to leverage non-City housing programs. La Crosse also produces press releases resources by aligning application timing such that City with program updates and works with LIHTC development funds are awarded prior to deadlines for other sources. partners to publicize developments. To the extent City priorities align with those of other public entities (e.g., WHEDA), consider including those • Proactively deploy available funds through RFPs. organizations’ priorities into City requirements as a way Currently, the City awards financial assistance as projects to leverage City resources by investing in projects well- are proposed by developers. Going forward, a more positioned to receive funding from those public entities. proactive approach is needed to identify priority project types (e.g., affordable, senior, supportive), unit types • Continue to monitor local housing market. Ongoing (e.g., apartment rental, for-sale attached single family, monitoring of the housing market is important to understand condominium) and even locations (e.g., located in service- housing opportunities and challenges.DRAFT This process was rich areas or CDA-identified priority redevelopment sites) started in 2016 with completion of the Housing Study; that support City-identified goals and where City resources however, it is important to continue to monitor market are available to support development. conditions, assess the impact of existing housing programs, and explore areas which may need greater policy focus. Immediate Actions Steps Special emphasis should be placed on monitoring changes to the housing stock, including new development, • City staff prepare and Common Council adopt a City supply and demand trends (including vacancy), changing housing policy. demographics, housing prices and the local employment • Reallocate funding for housing specialist staff within the market. As part of this process, solicit feedback from Development Department. residents, building owners, developers and other key • Identify desired skill set and solicit applicants for housing stakeholders on Wauwatosa’s housing needs. Identify a specialist staff. regular schedule for updating the Housing Study (e.g., • Educate the public regarding benefits of existing housing every 5 years for a comprehensive update, with annual programs, community housing needs, and any new City market surveys between updates). Annually survey active policies/efforts. multifamily developers, building managers and housing • Develop single point applications for City housing

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assistance to be used as new programs are developed. Immediate Action Steps • Identify timing and requirements of complementary funding programs controlled by other public entities and • Following adoption of overall housing policy, focus align City funding award deadlines and requirements with City staff efforts on one achievable project to address those sources. a community need, generate positive publicity and • As changes in existing programs or funding sources are demonstrate the value of City housing programs. contemplated and implemented, provide transparent information to residents and stakeholders through greater outreach efforts and the local media as well as opportunity for community feedback. • Monitor and report on local housing market conditions, housing program performance and emerging housing issues. Provide opportunity for residents and stakeholder groups to provide feedback on community housing opportunities and concerns. Survey developers active in Wauwatosa and surrounding communities on perceived market challenges and opportunities. Establish a regular schedule for updates.

Next Steps

• As housing programs are rolled out with defined programmatic goals, conduct regular monitoring of performance. • Publicize community achievements and benefits to residents and stakeholders. • Conduct any RFP and developer solicitation process in a proactive, transparent manner designedDRAFT to achieve community-identified goals.

IMPLEMENTATION CONSIDERATIONS

• Importance of a single high-quality project. Multiple housing practitioners emphasized the impact a high- quality project that addresses relevant community needs can have in changing the narrative surrounding housing programs. Once the City has defined and adopted an overall housing policy, staff should pursue one or just a few high-impact projects that address an identified community priority, will demonstrate tangible results and thereby generate positive momentum toward achieving further housing goals.

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4. Housing Action Plan: LIST OF APPENDICES Appendix A: Limitations of Our Engagement Appendix B: List of Interviews, References & Sources Appendices Appendix C: HUD Income Limits Appendix D: Existing TIDs in Wauwatosa & Additional Appendix E: Case Studies • Exhibit E.1: CDBG Best Practices Information • Exhibit E.2: Case Study Communities • Exhibit E.3: Madison, Wisconsin • Exhibit E.4: La Crosse, Wisconsin • Exhibit E.5: La Crosse Goals Matrix from 2015 CAPER • Exhibit E.6: St. Louis Park, Minnesota Appendix F: Employer Assisted Housing • Exhibit F.1: Rochester Area First Homes Program • Exhibit F.2: REACH Illinois Appendix G: Accessory Dwelling Units • Exhibit G.1: Proposed Zoning Ordinance Text Amendment to Allow Accessory Dwelling Units Appendix H: Inclusionary Housing • Exhibit H.1: Case Study Communities • Exhibit H.2: Edina, Minnesota, IH Policy Summary • Exhibit H.3: St. Charles, Illinois, IH Policy Summary • Exhibit H.4: Typical Affordable Housing Plan Components DRAFT• Exhibit H.5: Impacts of Hypothetical Policy on Development • Exhibit H.6: Edina, Minnesota, Full IH Policy Text • Exhibit H.7: St. Charles, Illinois, Full IH Policy Text • Exhibit H.8: St. Louis Park, Minnesota, Full IH Policy Text Appendix I: Additional Documentation • Exhibit I.1: Madison, Wisconsin, 2016 Biennial Housing Report

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Appendix A: Limitations of Our Engagement

Our analysis and deliverable is based on analyses, assumptions and other information developed from research of the market, knowledge of the industry and meetings during which we were provided certain information. The sources of information and bases of the recommendations are stated in the deliverable. Some assumptions inevitably will not materialize, and unanticipated events and circumstances may occur; therefore, actual results achieved will necessarily vary from those described in our deliverable, and the variations may be material.

The terms of this engagement are such that we have no obligation to revise analyses, the deliverable or other documents to reflect events or conditions which occur subsequent to the date of the deliverable. These events or conditions include, without limitation, economic growth trends, governmental actions, additional competitive developments and other market factors. However, we will be available to discuss the necessity for revision in view of changes in the economic or market factors affecting the recommendations.

Our deliverable is intended solely for your information and that of the City Council and should not be relied upon by any other person, firm or corporation, or for any other purposes. Neither the deliverable nor its contents, nor any reference to our firm, may be included or quoted in any offering circular or registration statement, appraisal, sales brochure, prospectus, loan or other agreement or document intended for use in obtaining funds from individual investors without our prior written consent.

We acknowledge that upon submission to the City the documents may become public documents within the meaning of the Freedom of Information Act. Nothing in these limitations is intended to block the disclosure of the documents under such Act.

Appendix B: List of Interviews, References & Sources

Interviewees: • Chris Corley, Corley Real Estate • Alan Kesner, City of Wauwatosa, • Linette Rhodes, City of Madison, • David Ginger, WHEDA Wisconsin Wisconsin • Caroline Gregerson, City of La • Michael Martin, HUD • Matt Wachter, City of Madison, Crosse, Wisconsin • Marney Olson, City of St. Louis Wisconsin Park, Minnesota • Maria Watts, WHEDA References: • Ball, M. S. Aging in Place: A Toolkit for Local Governments. (http://www.aarp.org/content/dam/aarp/livable- communities/plan/planning/aging-in-place-a-toolkit-for-local-governments-aarp.pdf) • American Planning Association. (2006). APA Policy Guide on Housing. (https://www.planning.org/policy/guides/ adopted/housing.htm) • American Planning Association. (2014). Aging in Community Policy Guide. (https://planning-org-uploaded-media. s3.amazonaws.com/legacy_resources/policy/guides/pdf/agingincommunity.pdf) • Jakabovics, A., Ross, L. M., Simpson, DRAFTM., Spotts, M. (2014). Bending the Cost Curve: Solutions to Expand the Supply of Affordable Rentals. (http://uli.org/wp-content/uploads/ULI-Documents/BendingCostCurve-Solutions_2014_web.pdf) • Policy Link. (2001). Equitable Development Toolkit: Housing Trust Funds. (http://www.policylink.org/sites/default/files/ housing-trust-funds_0). • Shear, W. (2012). HUD Has Identified Performance Measures for Its Block Grant Programs, but Information on Impact Is Limited. (http://www.gao.gov/assets/600/590845.pdf)

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Sources: • American Planning Association • First Homes • Northwest Michigan Council of • Chicago Tribune • The Gazette (Iowa City, Iowa) Governments • City of Edina, Minnesota • Greater Minnesota Housing Fund • Novogradac • City of Evanston, Illinois • Illinois Housing Development • PolicyLink • City of Highland Park, IL Authority • Project Home • City of Iowa City, Iowa • Independent Living, Inc. • REACH Illinois • City of Lake Forest, Illinois • Iowa City Press‐Citizen • SB Friedman • City of Madison, Wisconsin • Kane County Chronicle • Southeastern Wisconsin Regional • City of St. Charles, Illinois • Metro Cities Planning Commission • City of St. Louis Park, Minnesota • Metropolitan Planning Council • State of Wisconsin • City of Traverse City, Michigan • Milwaukee County, Wisconsin • StarTribune (Minneapolis, • City of Wauwatosa, Wisconsin • Minnesota Housing Finance Agency Minnesota) • Department of Housing and Urban • Movin’ Out • Sun Current (Edina, Minnesota) Development • National Community Development • Urban Institute • Community First Association • Urban Land Institute • Corporation for Supportive Housing • National Housing Conference • Wisconsin Legislative Fiscal Bureau • Dane County, Wisconsin • National Low-Income Housing • Coalition

Appendix C: HUD Income Limits Appendix C: HUD Income Limits The following table outlines income limits as defined by HUD by family size as a share of area median income (AMI) for the The following table outlines income limits as defined by HUD by family size for the Milwaukee-Waukesha- Milwaukee-Waukesha-WestWest Allis, Wisconsin MSA for fiscal year Allis, 2017. Wisconsin, MSA for fiscal year 2017.

Table B.1: HUD Income Limits Table C.1: HUD Income Limits

Source: HUD U.S. Department of Housing and UrbanDRAFT Development

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Appendix D: Existing TIDs in Wauwatosa and Projected Final Year AppendixRevenues D: Existing TIDs in Wauwatosa and Projected Final Year Revenues

Table D .1:D.1: Wauwatosa Wauwatosa TID Summary TID Summary

[1][1] TID TID plan plan permits permits affordable affordable housing extension.housing extension. Source:Source: City City of Wauwatosa of Wauwatosa,, TID Feasibility TID Feasibility Studies and AmendmentsStudies and, SB Amendments; Friedman SB Friedman

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Appendix E: Case Studies

AppendixEXHIBIT E. 1:E: CDBGCase StudiesBEST PRACTICES

EXHIBITThe following E.1: areCDBG two BESTprojects PRACTICES cited as best practices by HUD for the use of CDBG:

The following• Sherwood are two Village projects Senior cited Apartment as bests practices (Salinas, California).by HUD for A the local use non of- profitCDBG: used $2.5 million in CDBG and HOME funds, along with $15.9 million in LIHTCs as part of a $22 million project to • Sherwoodconvert threeVillage obsolete Senior motel Apartments buildings (Salinas, into 124 unitsCalifornia). of housing A local for low non-profit-income seniors. used $2.5The nonmillion- in CDBG and HOME funds, alongprofit’s with history$15.9 millionand close in LIHTCs working as relationshippart of a $22 with million the Cityproject of toSalinas convert was three cited obsolete as a key motel buildings into 124 units of component to the successful outcome over the two-year development period. housing for low-income seniors. The non-profit’s history and close working relationship with the City of Salinas was cited as a

key component to the successful outcome over the two-year development period. • Thomas H. Wynn, Sr. Memorial Veterans Manor (Milwaukee, WI). Veterans Manor provides 52 permanently supportive housing units for low-income veterans. In addition to $6.8 million in • ThomasLIHTC H. funds, Wynn, the Sr. project Memorial received Veterans about Manor$969,000 (Milwaukee, in CDBG funds Wisconsin). from both Veteransthe City of Manor Milwaukee provides 52 permanently supportive housingand Milwaukee units for low-income County. On- siteveterans. services In are addition provided to by$6.8 the millionU.S. Departm in LIHTCent offunds, Veterans the projectAffairs received about $969,000 in CDBGor Center funds forfrom Veterans both the Issues, City of a longtimeMilwaukee supportive and Milwaukee housing provider. County. On-site services are provided by the U.S. Department of Veterans Affairs or Center for Veterans Issues, a longtime supportive housing provider. EXHIBIT E.2: CASE STUDY COMMUNITIES EXHIBIT E.2: CASE STUDY COMMUNITIES SB Friedman conducted research into housing practices of several peer communities across the Midwest, SBand Friedman selected threeconducted communities research based into on housing conversations practices with of the several City as peer being communities particularly relevantacross the to Midwest, and selected three communitiesWauwatosa: basedMadison, on WI;conversations La Crosse, withWI; andthe CitySt. Louis as being Park, particularlyMN. A brief relevant demographic to Wauwatosa: description Madison, of WI; La Crosse, WI; and Wauwatosa and each case study community is presented below, followed by more detailed profiles of St. Louis Park, MN. A brief demographic description of Wauwatosa and each case study community is presented below, followed each case study community. by more detailed profiles of each case study community. Table E.1: Characteristics of Case Study Communities Table E.2.1: Characteristics of Case Study Communities

DRAFT Source: Longitudinal Employer-Household Dynamics (LEHD) OnTheMap; U.S. Census Bureau, Source: U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates; LEHD OnTheMap 2011-2015 American Community Survey 5-Year Estimates

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EXHIBIT E.3: MADISON, WISCONSIN

Madison was selected as a case study community because of its proactive approach to addressing local housing issues and its robust local housing program. The City also implemented an inclusionary housing policy. However, that program has since ended.

Note: All references to the “City” in Exhibit E.3 refer to the City of Madison.

Primary housing challenges, as identified in the City of Madison 2016 Biennial Housing Report:

• Consistently strong demand for housing; • Rising housing prices with low vacancy rates; • Rental construction focused on high-income households; • Declining federal affordable and low-income housing assistance; • High construction and land costs limit low-income housing development, unless subsidies are provided; and • Homeownership inaccessible to low-income and first-time homebuyers due to tight lending and an overhang of student debt.

Strategies to address these issues, as recommended by the City’s Housing Strategy Committee:

• Increase the variety of housing types available at different income levels in amenity-rich neighborhoods; • Improve existing housing stock quality and increase availability of amenities in “lagging” neighborhoods; and • Expand the types of housing available to fill gaps left by the private market.

These strategies are intended to be implemented by increasing efficiency of existing City programs; leveraging existing resources to the greatest extent possible with City, State and federal resources; proactively soliciting developers to partner with to address housing priorities; and operationalizing Madison’s new AHF to address the City’s top housing priorities.

The City of Madison 2016 Biennial Housing Report’s Executive Summary is available in Appendix I. Key strategies currently (or previously) utilized in Madison that could be implemented in Wauwatosa are outlined below.

• Inclusionary housing. A mandatory inclusionary housing policy was implemented in 2006. The policy sunset in January 2009 after being challenged in court. Ultimately, the Wisconsin Court of Appeals ruled that Madison’s inclusionary housing policy was a form of rent control which is not allowed by state statute. The City has since pursued purely incentive-based policies which incent, but do not require developers to include affordable housing in market-rate projects.

• Housing Rehabilitation Services and Home Modification programs. Madison uses CDBG funds to support multiple housing rehabilitation or accessibility programs, two of which are the Housing Rehabilitation Services program and the Home Modification program. The Housing Rehabilitation Services program provides deferred and installment loans (depending on income) to households for owner-occupied housingDRAFT upgrades. The Home Modification program, administered through a local non-profit organization, provides grants for accessibility improvements for low-income elderly households or households with disabilities.

• Home-buyer assistance. The City originates second mortgages for eligible homebuyers acquiring and rehabilitating eligible, owner-occupied, one-to-eight-unit properties. Assistance is provided from HOME funds as either an installment loan or a deferred loan depending on borrower income. Loan size is limited to 30% of total development cost (purchase price, cost of rehabilitation, and closing costs) or to a dollar amount based on the size of property ($40,000 for a single-family home and up to $110,000 for an eight-unit building). In addition to this program, the City also maintains other home-buyer assistance programs (e.g. to assist first-time home-buyer with down payment and closing costs) funded by state sources (Housing Cost Reduction Initiative), local funds (including CDBG), and, in some cases, TIF.

• CDBG and HOME. Due to the compliance associated with HOME funds, Madison has generally invested its HOME funds into just a few projects. CDBG funds, which have less onerous compliance requirements, can more easily be deployed to smaller projects (e.g., non-profit-driven rehabilitation of 4-, 8-, or 16-unit buildings rather than large-scale rehabilitation or new construction projects).

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• Affordable Housing Fund. Madison provides assistance to affordable housing developers through its AHF, which is funded by funds generated through TIF affordable housing extension years, fees and approximately $4.5 million in City funds annually. Funds are provided as an incentive to developers (mainly of LIHTC projects). Madison’s AHF is intended to be used for a variety of housing programs but, due to market conditions, has been primarily utilized for the construction of new affordable and supportive housing units. Madison has structured its AHF awards process (as well as that for other forms of public assistance) to align with the LIHTC funding cycle. The City has a goal of 1,000 units created over a five-year period and is currently on track, having approved funding for 600 units in the last three years.

• RFP for affordable housing. Madison City staff emphasized the use of the RFP process (to distribute AHF funds) as a proactive way to encourage projects that meet City priorities (e.g., projects located in high opportunity areas with access to amenities like transit, parks, schools, and retail with fewer affordable housing opportunities). Furthermore, the City aligns the RFP’s priorities and schedule with WHEDA’s LIHTC awards priorities (QAP) and simply layers City priorities on top of that structure. Projects that score well for City programs would therefore be well-positioned to receive LIHTC allocation from WHEDA. This process is revised annually in response to market needs and as WHEDA releases its updated QAP. City staff indicated they may use a similar process to target the creation of senior units in the future.

• “Quarterbacking” the process. While the City may not have the resources to contribute financially in all scenarios, it serves as a point of contact for a variety of funding partners. City staff described this in the context of a project intended to move homeless individuals into permanent supportive housing. While the City was participating financially and contributing land, these were only two of seven sources of public assistance. However, the City was also able to contribute non-financially by recruiting the developer through the RFP process and as a leader/champion to see the project through.

• Reverse mortgage program. Madison operates a reverse mortgage program that allows eligible homeowners to access home equity to pay their real estate taxes. The loan is structured as a deferred payment loan with an interest rate set at the City’s borrowing rate plus 1% repaid at sale, transfer of ownership, or when it is no longer the borrower’s place of residence. At closing, the borrower must sign a land use restriction stating the property will remain owner-occupied. In practice, this can be difficult to enforce if a property stays within a family after an eligible borrower is no longer living in the home. Borrowers reapply each year with additional borrowed amounts added to existing principal and refinanced. The program has been in place for 20 years and for the first 10 years was funded from the City’s operating budget; however, in the last 10 years the program has become self-sustaining. The City opted to fund it locally (i.e. versus mixing in CDBG) to ease the compliance load. In its 20 years, the City has only had to write off one loan of this type.

A similar program is available for households to pay for special assessments and the City is considering expanding the program to allow seniors to pay City utilities using this structure (which would likely require additional City funds to implement). The City originates 20 to 25 property tax assistance loans per year as well as one to two special assessment loans. Staffing is mainly seasonal around periods when taxes are due. While the program is not advertised, outreach is conducted to the Senior Commission and senior centers and no one is turned away for lack of funds. City staff use the intake process for this program to identify issues homeowners may haveDRAFT with their homes and refer them to other City programs as appropriate. According to City staff, many of the beneficiaries take advantage of this program year after year and have expressed the importance it has played in allowing them to remain in their homes.

EXHIBIT E.4: LA CROSSE, WISCONSIN

La Crosse was identified as a potential case study community because of its effectiveness in applying CDBG and HOME funds to local housing programs. La Crosse is also comparable in population and federal entitlement allocation to Wauwatosa.

Note: All references to the “City” in Exhibit E.4 refer to the City of La Crosse, Wisconsin.

La Crosse’s City housing staff described their housing policy as comprising three main programs: multifamily development, housing replacement and housing rehabilitation. La Crosse’s staffing, outreach/education efforts and practices in setting housing goals may also be relevant to crafting an implementable affordable housing policy in Wauwatosa. These elements are described in greater detail below.

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• Multifamily development loans. La Crosse combines CDBG in a revolving loan fund with HOME funds to attract LIHTC affordable housing developers. Through an RFP process, the City offers $500,000 in CDBG funds as an interest-only loan. Contribution of City-owned land has also occurred. The process has successfully attracted three affordable housing projects to La Crosse in recent years. Prior to implementing the program, the City had not seen any new LIHTC development for multiple years.

• Housing replacement program. La Crosse also uses CDBG funds, in combination with HOME and TIF funds, to operate a program through which deteriorating housing is selectively acquired, demolished, and then replaced with new single-family housing for LMI households. CDBG funds are used for acquisition and demolition, with HOME or TIF funds used for construction. A partnership with the local technical college provides an opportunity to reduce construction costs while providing on-the-job training.

• Housing rehabilitation program. La Crosse funds a housing rehabilitation program with its CDBG allocation that offers 1% deferred loans of up to $25,000 to eligible homeowners to repair major building systems. Borrowers work with City staff to evaluate their home needs, bid the work, and manage the renovation. The program is also available to rental properties. The City opted for a deferred loan structure repaid only when the property is sold, transfers ownership, or is no longer the borrower’s place of residence, which lessens administrative burdens. With tepid interest initially, City staff conducted outreach and improved the loan terms – the program now originates 15 to 20 loans per year and has a waiting list. While not explicitly targeting seniors, City staff cited this program as a tool which helps residents to age in place.

• Dedicated housing staff. La Crosse has a staff of two full-time housing specialists as well as three other staff members who work on housing as needed. Personnel decisions have been important to implementing the City’s affordable housing strategy in two primary ways. First, the City emphasizes in-house management of its housing programs which has required strategic hiring to ensure needed skills are represented (e.g., staff with a background in housing construction are required for the City’s housing rehabilitation program). Second, staff emphasized the proactive nature of the work they undertake. For instance, solicitation of affordable housing developers as part of their RFP process, conducting outreach to attract borrowers for housing rehab loans, consistently publicizing program achievements/benefits, and proactively certifying local communities as neighborhood revitalization strategy areas (NRSA) to achieve greater flexibility in the use of CDBG funds.

• Publicize achievements, media outreach and popular support. La Crosse maintains a proactive relationship with local media as a tool to educate the public of program benefits. For example, the City publicizes grand openings of major projects, but also conducts follow-up outreach to connect local media with individuals benefiting from the program, publicizing personal stories to animate the impact of the City’s housing programs. Education helps to defuse public opposition to affordable housing projects. Educating the public regarding the quality of the product and populations served has defused some resistance and helped to build support. Similarly, La Crosse has found that affordable housing developers are good partners in education/publicity.

La Crosse identifies projects to be funded through its CDBG committee which includes the mayor, council members, and members of the public. This process for targeting projects, in which local elected officials play a crucial part, was identified as one way to ensure some level of political supportDRAFT for projects.

• Housing goal-setting. La Crosse uses the five-year planning process required by HUD as an opportunity to define goals for its housing programs. As part of the process, the City receives substantial public input and reviews available housing data. Goals are revisited annually and staff hold themselves accountable for achieving identified goals. The City also sets goals specific to CDBG spending, targeting certain percentages to different priorities (e.g., housing, economic development, public services). (See Exhibit E.5)

PAGE 40 Assess how the jurisdiction’s use of funds, particularly CDBG, addresses the priorities andCITY OF specific WAUWATOSA ojecties identified in the plan, iin special attention to the hihest priority actiities identified HOUSING POLICY & ACTION PLAN

This chart details the City's priorities for funds.

EXHIBIT E.5: LA CROSSE GOALS MATRIX FROM 2015 CAPER

riorities and Achieeents EXHIBIT E.6: ST. LOUIS PARK, MINNESOTA

SB Friedman identified St. Louis Park as a case study community because it isCAPER an inner-ring suburb (of Minneapolis/St. Paul) and is 6 demographically comparable to Wauwatosa. Population, households, median income and housing profile are very similar, though OMB Control No: 2506-0117 (exp. 07/31/2015) Wauwatosa has a more substantial employment base. St. Louis Park also proactively addresses housing challenges through several programs, including an inclusionary housing policy.

Note: All references to the “City” in Exhibit E.6 refer to the City of St. Louis Park.

SB Friedman interviewed City staff from DRAFTSt. Louis Park primarily to discuss their inclusionary housing program. However, other elements of their housing policy are also relevant, including a CDBG-funded emergency home repair program and an EAH program.

• Inclusionary housing policy. St. Louis Park’s inclusionary housing policy is the result of a City Council desire to more actively facilitate affordable housing. Following a City Council Housing Summit in 2005, St. Louis Park committed itself to promoting affordable housing; however, few tangible results were realized until an inclusionary housing ordinance was adopted in 2015. St. Louis Park’s incentive-based inclusionary housing policy requires that developers provide affordable units if they receive financial assistance from the City, which is primarily TIF, and the development includes at least 10 units. The adopted policy applies citywide.

St. Louis Park outlines tiered affordability requirements depending on the depth of affordability. Previously, if affordable rental units targeted households at 50% AMI, 8% of units were required to be affordable; if such units were affordable to households at 60% AMI, 10% of units were required to be affordable. That has since been increased to 10% and 18% respectively by the City Council as a way incentivize affordability at lower income levels. All affordable owner-occupied units are required to target households at 80% of AMI. Units must remain affordable for 25 years. Unlike many other communities, St. Louis Park does not offer density bonuses or waived/reduced permitting fees

PAGE 41 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

to developers impacted by the inclusionary housing policy. Nor does the City allow for fee-in-lieu payments as the policy preference of the City was to produce units on-site. Alternatives to producing on-site units include options for producing affordable units off-site or participating in an affordable development being built by another developer. Developers may also propose an alternate solution to provide affordable units. An affordable housing plan must be filed by any impacted developer. Compliance terms are written into a redevelopment agreement with the developer.

According to City staff, the ordinance has not limited development since it was enacted in 2015. In fact, the City recently increased affordability requirements because it felt more could be done to achieve affordable housing goals. More than 280 affordable units have been created across six projects to date (either created or approved to move forward), representing nearly 1,100 total units, with more currently in the development pipeline. Prior to the inclusionary housing policy, most affordable units were affordable purely because of age and condition of the units, with no new affordable projects developed.

St. Louis Park is currently working with neighboring municipalities to align compliance requirements to reduce the administrative load imposed on developers. Aligning compliance terms with existing programs like LIHTC also helps to reduce the compliance load.

• Single-Family Emergency Repair program. St. Louis Park deploys CDBG funds through an emergency repair program for low-income households, many of which are senior households. The program provides grants of up to $4,000 to households for repairs to major building systems such as furnaces, roofs, electrical systems, plumbing, or to address code violations. The program is administered by a third party non-profit organization. Other home improvement loan programs are available to residents through Hennepin County and the Minnesota Housing Finance Agency.

• Employer-assisted housing. St. Louis Park attempted to develop a matching fund program for employees working in the City. Under the program, the City would commit $2,500 in down-payment assistance for the purchase of a home in St. Louis Park to be matched by employers. However, major employers in St. Louis Park are more regionally focused and were reluctant to provide what amounted to a benefit to employees at only one of their locations. The program has therefore been underutilized.

• Importance of one high-profile project.City staff credited one large-scale project in changing the perception of affordable housing in St. Louis Park. The redevelopment of an existing affordable development in the City through a major investment by new ownership was credited with mobilizing pro-affordable housing groups. DRAFT

PAGE 42 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

Appendix F: Employer Assisted Housing (EAH)

SB Friedman researched EAH programs in communities throughout the Midwest. Details on two programs are provided below that offer lessons for a potential Wauwatosa EAH policy.

EXHIBIT F.1: ROCHESTER AREA FIRST HOMES PROGRAM (RAFHP)

The First Homes Program appears to be Minnesota’s largest EAH effort. First Homes was developed as a joint effort of the Greater Minnesota Housing Fund (GMHF) and the Rochester Area Foundation to build at least 500 single-family homes and 375 affordable rental units in Rochester and surrounding communities by 2004. Low vacancy rates and rising home prices had caused the local housing market to become unaffordable to many local workers. To support the project, the Rochester Area Foundation raised $14 million from local employers. The Mayo Clinic, which employs more than 18,000 people in the area, contributed $4 million and pledged an additional $3 million in matching funds. The local economy is strongly dependent upon the Mayo Clinic and the businesses that support it; the Mayo Clinic, in turn, is dependent on being located in a stable community and attracting top medical talent and support staff. The Mayo Clinic therefore developed a model through which the entire community would benefit. Homes developed through the project are available to any area low-income buyers and are not restricted to employees of the participating companies. As the affordability situation in Rochester has improved, RAFHP has evolved its program offerings to implement a greater focus on its community land trust.

HOW IT WORKS

• The program supports the development of affordable rental units. The employer, combined with state, local and GMHF resources, provides secondary financing for affordable rental projects. • It also provides homeowner assistance: When the program began homebuyers could receive $30,000 of assistance from the First Homes Community Land Trust or up to $15,000 of secondary financing for down-payment and closing cost assistance from First Homes. This has since changed with greater emphasis on the community land trust component to only $10,000 in secondary financing. • GMHF provides significant technical assistance and financial resources to the initiative including construction and permanent financing.

TAKEAWAYS FOR WAUWATOSA

• Wauwatosa’s EAH program as envisioned is narrower in scope than the program implemented in the RAFHP, currently limited to down-payment or rental assistance and without the multifamily financing or land trust component. However, EAH programs benefit from being used in conjunction with other affordability tools. Other components of Wauwatosa’s affordable housing strategy could substitute for other elements of the RAFHP, like multifamily financing, maintaining down-payment assistance in the same continuum of housing affordability strategies as implemented in Rochester. • RAFHP can provide a model to the CityDRAFT for a fund-based EAH, in which multiple funding partners pool resources into one central fund from which grants or loans are disbursed. • The RAFHP is not limited to employees of participating employers. There was a recognition that major employers like the Mayo Clinic are reliant on other industries (e.g., service and hospitality) in the surrounding economy. This may argue for opening EAH assistance availability to non-employees in a market where one or just a few major institutions are major economic engines.

PROGRAM HIGHLIGHTS

Administered by: First Homes Program, GMHF Funding provided by: Rochester Area Foundation, The Mayo Clinic, Employers Grant or Loan: Grant, secondary financing Employers: Any Rochester-area employer Program Boundary: City of Rochester, MN Source: GMHF

PAGE 43 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

EXHIBIT F.2: REACH ILLINOIS

The Regional Employer-Assisted Collaboration for Housing (REACH) program started in response to the combined housing shortage and the rising cost of housing in the State of Illinois. It was initially a pilot EAH program for one large employer, System Sensor, that brought together the Metropolitan Planning Council (MPC) for technical assistance and a non-profit housing developer (Joseph Corporation). The pilot program demonstrated the major savings for employers in terms of employee turnover, recruitment and training when employees live near their workplace.

The recent recession reduced employer participation in the REACH Illinois program and it is no longer active in this format. Components of the program continue however through both REACH partner organizations who continue to administer EAH programs and with entirely new organizations.

The State of Illinois has continued incentivizing EAH, providing a 50% tax credit for every dollar that an employer invests in an EAH program, and matching down-payment assistance provided to eligible employees. These incentives have made EAH a very attractive and cost-effective program.

PROGRAM DETAILS

• Down-payment assistance was usually structured as a five-year forgivable loan and secured by a lien on the new home. • The program was administered by a REACH Partner organization (non-profit housing expert). • REACH non-profit partners provided credit counseling, home-buyer education, and assistance throughout the process. • Illinois Housing Development Authority created two financial incentives—a state tax credit for EAH and a matching funds program—to encourage employer participation. • In an effort to reach more low-income employees, some programs offered monthly rental subsidies along with housing counseling or Individual Development Accounts which provided a vehicle for individuals to save for a down payment over two years to eventually be matched by funds from their employer.

RESULTS

Through REACH Illinois, more than 1,800 employees have bought homes since 2000. Over 60 employers participated in an EAH program. Employer contributions totaled more than $1.7 million.

TAKEAWAYS FOR WAUWATOSA

• In the REACH Illinois program, employers worked with a REACH Illinois partner organization to craft an EAH specific to the employer’s needs and budget, which was then administered by the employer’s REACH partner. Wauwatosa could act as coordinator, identifying an organization with this capacity, then connecting employers to this organization which would create and administer EAH programsDRAFT for them. To further incentivize this partnership, the City could subsidize the cost of the administrator organization. • Wauwatosa could play a similar role to the State of Illinois in the REACH Illinois program, providing funds to match those provided by participating employers (though not other components, e.g. tax credits). This could provide a model for how the City could financially participate in a program operated by employers themselves or by a third-party. • Providing down-payment assistance exclusively directs assistance to households able to purchase homes and may not serve lower-income households without the resources to consider a home purchase. REACH’s efforts to expand offerings to reach low- income households through rental subsidy or down payment savings may provide a roadmap for similar efforts as Wauwatosa structures its own program.

PROGRAM HIGHLIGHTS

Administered by: REACH Illinois Partners Partnership: MPC, Housing Action Illinois, Illinois Housing Development Authority, City of Chicago

PAGE 44 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

Funding provided by: Washington Mutual, Fannie Mae, MacArthur Foundation, Polk Bros., McCormick Tribune Foundation, and employers Grant or Loan: Either Employers: Over 60 employers statewide Program Boundary: State of Illinois Source: REACH Illinois, MPC, American Planning Association

DRAFT

PAGE 45 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

Appendix G: Accessory Dwelling Units (ADUs)

EXHIBIT G.1:

PROPOSED ZONING ORDINANCE TEXT AMENDMENT TO ALLOW ACCESSORY DWELLING UNITS

Proposed Definition of “Accessory Dwelling Unit” (addition to Sec. 24.18.020) A separate dwelling unit within a detached house, semi-detached house or attached house or a separate dwelling unit that occupies an accessory building that shares a lot with a detached house, semi-detached house or attached house. As the name implies, accessory dwelling units are an accessory use to the principal use of the property (i.e., the principal dwelling unit). (See also the accessory dwelling unit regulations of Sec. 24.10.075) 24.10.075 - Accessory Dwelling Units (ADUs)

A. Purpose 1. The accessory dwelling unit regulations of this section are intended to help promote the benefits of accessory dwelling units, while also preserving neighborhood character and promoting predictability and certainty for established neighborhoods. 2. Accessory dwelling units (ADUs) help advance the city’s housing and land use goals and policies by: a. Accommodating additional housing units while preserving the character of existing neighborhoods; b. Allowing efficient use of the city’s existing housing stock and infrastructure; c. Providing housing options and choices that respond to varying income levels, changing household sizes and lifestyle needs; d. Providing a means for older residents to remain in their homes and neighborhoods, and obtain extra income, security, companionship and assistance; and e. Promoting a broader range of accessible and more affordable housing. B. General Regulations for all ADUs All accessory dwelling units must comply with the regulations of this subsection. 1. Zoning District Regulations Accessory dwelling units are subject to all applicable regulations of the zoning district in which they are located, DRAFTunless otherwise expressly stated in this section 2. Where Allowed Accessory dwelling units are allowed only on lots occupied by a detached house, semi- detached house or attached house. 3. Number No more than one accessory dwelling unit is allowed per lot. 4. Methods of Creation An accessory dwelling unit may be created through any of the following methods: a. Converting existing area within the interior of a principal dwelling unit (e.g., attic or basement) to an ADU; b. Adding floor area to an existing dwelling unit to accommodate an ADU; c. Constructing a detached accessory dwelling unit on a parcel with an existing principal dwelling unit;

Wauwatosa Zoning Ordinance Text Amendment Accessory Dwelling Units (09.13.2017 DRAFT) Page 1 PAGE 46 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

d. Converting space within a detached accessory building; or e. Constructing a new principal dwelling unit with an internal or detached accessory dwelling unit. 5. Rental No more than one of the dwelling units on a lot occupied by an ADU may be a rental dwelling unit. Accessory dwelling units may not be rented for periods of less than 30 consecutive days. 6. Deed Restriction Prior to issuance of a permit establishing an accessory dwelling unit, the owner must file with the register of deeds a deed restriction stating that the owners of the subject property agree to the restriction that no more than one of the dwelling units on a lot occupied by an ADU may be a rental dwelling unit and to notify all prospective purchasers of those requirements. The deed restriction shall run with the land and be binding upon the property owner, their heirs and assigns, and upon any parties subsequently acquiring any right, title, or interest in the property. The deed restriction must be in a form prescribed by the zoning administrator. Proof of recording must be provided to the zoning administrator before the building permit for the accessory dwelling unit is issued. 7. Number of Residents The total number of residents that reside in the accessory dwelling unit and the principal dwelling unit, combined, may not exceed the number permitted for a household. 8. Location of Entrances Only one entrance to a principal dwelling unit containing an accessory dwelling unit may be located on a façade that facesDRAFT a street, unless the principal dwelling unit contained an additional street-facing entrance before the accessory dwelling unit was created. Detached ADUs are exempt from this regulation. 9. Size The floor area of an ADU may not exceed 49% of the gross floor area of the principal dwelling unit on the subject lot (excluding any attached garage), or 650 square feet, whichever is less. For purposes of this provision, the following are excluded from the definition of “gross floor area”: a. Garage areas; b. Basement areas where the ceiling height measured from the floor is less than 7 feet; and c. Any other areas of the building where the floor-to-ceiling height is either less than 5 feet or not accessible by a stairway. 10. Parking

Wauwatosa Zoning Ordinance Text Amendment Accessory Dwelling Units (09.13.2017 DRAFT) Page 2 PAGE 47 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

No additional parking is required for an accessory dwelling unit. Existing required parking for the principal dwelling unit must be maintained or replaced on-site. 11. Building Permit Approval Before the issuance of a building permit for the construction of any new accessory dwelling unit, plans must be reviewed and approved by the chief building official to determine compliance with all applicable building and life safety codes. C. Regulations for New Detached ADUs and Building Additions The regulations of this subsection apply to all detached buildings and building additions proposed to be occupied by ADUs. These provisions apply only to detached buildings and building additions constructed after INSERT EFFECTIVE DATE OF ADU AMENDMENT. 1. Exterior Finish Materials The exterior finish material must be the same or visually match in type, size and placement, the exterior finish material of the principal dwelling unit. 2. Roof Pitch The roof pitch must be the same as the predominant roof pitch of the principal dwelling unit. 3. Trim Trim on edges of elements on the building addition to the principal dwelling unit or the accessory structure occupied by the ADU must be the same in type, size and location as the trim used on the principal dwelling. 4. Entrances Entrances to ADUs occupying detached accessory structures may not face the nearest side or rear property line unless there is an alley abutting that property line. 5. Setbacks A detached accessory dwelling unit must be located at least 10 feet behind the principal dwelling. This required 10-foot separation distance must be free of structures except that it may include walkways, patios, decks and similar structures that do not exceed 30 inches in height above finished grade. 6. Height The maximum allowed height of a detached accessory dwelling unit is 20 feet or the height of the principal dwelling building, whichever is less.1 DRAFT

1 This provision may necessitate a revision to the text of footnote “[7]” in Sec. 24.02.030 (residential districts lot and building regulations table. One option would be to delete the prohibition on creation of habitable floor area, as follows: “[7] Accessory building heights of up to 20 feet may be approved by the zoning administrator if the administrator determines that the additional height is necessary to accommodate a roof pitch consistent with the architectural style of the principal building. ”

Wauwatosa Zoning Ordinance Text Amendment Accessory Dwelling Units (09.13.2017 DRAFT) Page 3 PAGE 48 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

Appendix F: Inclusionary Housing

Appendix H: Inclusionary Housing SB Friedman reiewed inclsionary hosing policies in seeral idwestern conities hree case stdy conities with incentieased inclsionary hosing policies as identified in Exhibit E.1 were selected forEXHIBIT closer H.1: reiew CASE dina STUDY COMMUNITIES St Charles and St ois ark Exhibits E.2 and E.3 descrie the policies for the first two conities the St ois ark policy is descried in Appendix D Exhibit D.5 ExhibitSB Friedman E.4 incldes reviewed typical inclusionary coponents housing o policiesf ffordale in several osing Midwestern lans communities.which are at Three ties case reired study communitiesof with incentive- deelopbased inclusionaryers y conities housing policies, Exhibit as Eidentified.5 illstrates in Table the ipactsH.1.2, were of selecteda hypothetical for closer incentie review: Edina,ased MN; St. Charles, IL; and inclsionarySt. Louis Park, hosing MN. Exhibits policy onH.2 a andtypical H.3 thogh describe hypothetical the policies newfor the constrction first two communities; arketrate theltifa St. Louisily Park policy is described deelopentin Appendix E, proect Exhibit E.6. Exhibit H.4 includes typical components of Affordable Housing Plans, which are at times required of developers by communities. Exhibit H.5 illustrates the impacts of a hypothetical incentive-based inclusionary housing policy on a typical, rief coparison though hypothetical, of case stdy new conityconstruction characteristicsmarket-rate multifamily is presented development elow eleant project. portions of city code ordinances or policies that gide the inclsionary hosing policy in case stdy conities are presentedA brief comparison in Appendix of case X study community characteristics is presented below. Relevant portions of city code, ordinances or policies that guide the inclusionary housing policy in case study communities are presented in Exhibits H.6 though H.8. Table F.1: Characteristics of Case Study Communities with Inclusionary Housing Policies Table H.1.1: Characteristics of Case Study Communities with Inclusionary Housing Policies

Source: LEHD OnTheMap; U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates Sorce S Censs rea erican Conity Srey ear stiates nheap

DRAFT

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PAGE 49 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

TableINCLUSIONARY H.1.2: Inclusionary HOUSING ‐ MATRIX Housing OF SURVEYED Matrix POLICIES 10/19/2017 WHO DOES THIS POLICY APPLY TO? WHAT DO THEY NEED TO PROVIDE? WHAT INCENTIVES ARE AVAILABLE? ALTERNATIVE MECHANISMS

Depth of Affordability Required Affordability Period Off‐site Participation in AFFORDABLE Affordable Units Waived Relief from Other, YEAR Minimum Owner‐Occupied Renter‐Occupied Property Tax Affordable Construction of HOUSING Public Action that Triggers Geographic Required ‐ Permitting Parking Expedited Financial including ADOPTED Number Density Bonus Exemption/ Others? Fee In‐Lieu Units (incl. Affordable Units PLAN Requirement Scope Reason for Variable Owner‐Occupied Renter‐Occupied or Impact Require‐ Permitting Assistance Alternative of Units Household Income Level ‐ Household Income Level ‐ Abatement new, existing, by Other REQUIRED? Requirements (in years) (in years) Fees ments Proposals Units by Income Level Units by Income Level land) Developer

10/20 10/20 X 10%/20% ‐ Presence of (Depending on (Depending on (Depending on Select public financing per 110% of AMI ‐ 60% of AMI ‐ presence of public presence of public presence of public Iowa City, IA 2016 10 zoning X XX existing City Economic 100% 100% financing per existing financing per existing financing per existing district only Development Policy City Economic City Economic City Economic Development Policy) Development Policy) Development Policy)

80%/120% of AMI ‐ 60%/80% of AMI ‐ At least 50% low‐income, At least 50% low‐income, Lake Forest, IL 2005 5 Citywide 15% Perpetuity Perpetuity X X XX X remainder for moderate‐ remainder for moderate‐ income income

Originally Citywide 80%/100% of AMI (in 50%/60% of AMI (in TOD); adopted 5 in TOD, Evanston, IL (2015 (varying in 10%/20% ‐ Presence of TOD); 80%/120% of AMI 60%/80% of AMI (out Mandatory 2007, 10 out of Perpetuity (99?) 25 X XXX X X X X Revised) relation to public financing (out TOD) ‐ TOD) ‐ Inclusionary revised TOD transit) 50% at each income level 50% at each income level Policies 2015

50%/80%/120% of AMI ‐ 65%/100% of AMI ‐ At least 33% lowest‐ At least 50% low‐income, Highland Park, IL 2003 5 Citywide 20% income, at least 33% low‐ Perpetuity 25 X X XX X remainder for moderate‐ income, remainder income moderate income

Rental units: Zoning map 2006, amendment, subdivision, or Offsets may 80% of AMI ‐ 60% of AMI ‐ Madison, WI sunsetted other land division. 10 Citywide 15% Unspecified 50 X XXX X be XX XX 100% 100% 2009 Owner‐occupied units: requested Mandatory inclusionary.

Development approved via subdivision, PUD, or other new lot, or following 5%/10% ‐ 80% of AMI ‐ 60% of AMI ‐ St. Charles, IL 2008 1 Citywide 15 Perpetuity X X XX XX issuance of a building Total number of units 100% 100% permit in select circumstances Minnesota Housing 50%/60% ‐ Incentive‐ 10%/20% (of livable Finance Agency's 'Startup 100% (depth of Based Rezoning or Comprehensive Edina, MN 2015 20 Citywide area) ‐ Depth of Program' guidelines apply affordability based on Initial sale 15 X X X X X X X Inclusionary Plan Amendment Policies affordability / tenure ‐ number of affordable 100% units provided)

50%/60% of AMI ‐ 10% to 18% ‐ 100% (depth of 80% of AMI ‐ St. Louis Park, MN 2015 Financial Assistance 10 Citywide Depth of affordability affordability based on 25 25 X XX XXXX 100% and tenure number of affordable units provided)

Development receiving Voluntary density bonus or 80% of AMI ‐ 60% of AMI ‐ Inclusionary Traverse City, MI 2009 1 Citywide 30 30 X X dimensional modification 100% 100% Policies DRAFT incentive

SB FRIEDMAN | development advisors Sources: American Planning Association; Chicago Tribune; Edina, MN; Evanston, IL; The Gazette; Highland Park, IL; Iowa City, IA; Iowa City Press‐Citizen; Kane County Chronicle; Lake Forest, IL; Madison, WI; Metro Cities; Minnesota Housing Finance Agency; National Housing Conference; Northwest Michigan Council of Governments; SB Friedman; St. Charles, IL; St. Louis Park, MN; StarTribune; Sun Sources: American Planning Association; Chicago Tribune; Edina, MN; Evanston, IL; The Gazette; Highland Park, IL; Iowa City, IA; Iowa City Press- www.sbfriedman.com Current; Traverse City, MI Citizen; Kane County Chronicle; Lake Forest, IL; Madison, WI; Metro Cities; Minnesota Housing Finance Agency; National Housing Conference; Northwest Michigan Council of Governments; St. Charles, IL; St. Louis Park, MN; SB Friedman; StarTribune; Sun Current; Traverse City, MI

PAGE 50 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

INCLUSIONARY HOUSING ‐ MATRIX OF SURVEYED POLICIES TableINCLUSIONARY H.1.2: Inclusionary HOUSING ‐ MATRIX Housing OF SURVEYED Matrix POLICIES 10/19/2017 10/19/2017 WHO DOES THIS POLICY APPLY TO? WHAT DO THEY NEED TO PROVIDE? WHO DOES THISWHAT POLICY INCENTIVES APPLY TO?ARE AVAILABLE? WHAT DO ALTERNATIVETHEY NEED TO MECHANISMS PROVIDE? WHAT INCENTIVES ARE AVAILABLE? ALTERNATIVE MECHANISMS Depth of Affordability Required Affordability Period Depth of AffordabilityOff‐site Participation in Required AffordabilityAFFORDABLE Period Off‐site Participation in AFFORDABLE Affordable Units Waived Relief from Affordable Units Other, Waived Relief from Other, YEAR Minimum Owner‐Occupied Renter‐Occupied YEAR Minimum Property Tax Owner‐OccupiedAffordable Renter‐ OccupiedConstruction of HOUSING Property Tax Affordable Construction of HOUSING Public Action that Triggers Geographic Required ‐ Public ActionPermitting that Triggers Parking ExpeditedGeographic RequiredFinancial ‐ including Permitting Parking Expedited Financial including ADOPTED Number ADOPTEDDensity Bonus Number Exemption/ Others? Fee In‐Lieu Units (incl. Affordable Units PLAN Density Bonus Exemption/ Others? Fee In‐Lieu Units (incl. Affordable Units PLAN Requirement Scope Reason for Variable Owner‐Occupied Renter‐Occupied Requirementor Impact Require‐ PermittingScope Reason forAssistance Variable OwnerAlternative‐Occupied Renter‐Occupied or Impact Require‐ Permitting Assistance Alternative of Units Household Income Level ‐ Household Income Level ‐ of Units Abatement Household Income Level ‐ new,Household existing, Income Levelby Other ‐ REQUIRED? Abatement new, existing, by Other REQUIRED? Requirements (in years) (in years) Fees ments Requirements (inProposals years) (in years) Fees ments Proposals Units by Income Level Units by Income Level Units by Income Level Unitsland) by Income LevelDeveloper land) Developer

10/20 10/20 X 10/20 10/20 X 10%/20% ‐ Presence of (Depending on (Depending on (Depending on 10%/20% ‐ Presence of (Depending on (Depending on (Depending on Select Select public financing per 110% of AMI ‐ 60% of AMI ‐ presence of public presence of public presence of public public financing per 110% of AMI ‐ 60% of AMI ‐ presence of public presence of public presence of public Iowa City, IA 2016 10 zoning Iowa City, IA 2016 X10 zoning XX X XX existing City Economic 100% 100% financing per existing financing per existing financing per existing existing City Economic 100% 100% financing per existing financing per existing financing per existing district only district only Development Policy City Economic City Economic City Economic Development Policy City Economic City Economic City Economic Development Policy) Development Policy) Development Policy) Development Policy) Development Policy) Development Policy)

80%/120% of AMI ‐ 60%/80% of AMI ‐ 80%/120% of AMI ‐ 60%/80% of AMI ‐ At least 50% low‐income, At least 50% low‐income, At least 50% low‐income, At least 50% low‐income, Lake Forest, IL 2005 5 Citywide 15% Perpetuity LakePerpetuity Forest, IL 2005 X X 5 Citywide 15% XX Perpetuity XPerpetuity X X XX X remainder for moderate‐ remainder for moderate‐ remainder for moderate‐ remainder for moderate‐ income income income income

Originally Originally Citywide 80%/100% of AMI (in 50%/60% of AMI (in TOD); Citywide 80%/100% of AMI (in 50%/60% of AMI (in TOD); adopted 5 in TOD, adopted 5 in TOD, Evanston, IL (2015 (varying in 10%/20% ‐ Presence of TOD); 80%/120% of AMI 60%/80% of AMI (out Evanston, IL (2015 (varying in 10%/20% ‐ Presence of TOD); 80%/120% of AMI 60%/80% of AMI (out Mandatory 2007, 10 out of Perpetuity Mandatory(99?) 25 2007, X XXX10 out of X X PerpetuityX (99?) X 25 X XXX X X X X Revised) relation to public financing (out TOD) ‐ TOD) ‐ Revised) relation to public financing (out TOD) ‐ TOD) ‐ Inclusionary revised TOD Inclusionary revised TOD Policies transit) 50% at each income level 50% at each income level transit) 50% at each income level 50% at each income level 2015 Policies 2015

50%/80%/120% of AMI ‐ 50%/80%/120% of AMI ‐ 65%/100% of AMI ‐ 65%/100% of AMI ‐ At least 33% lowest‐ At least 33% lowest‐ At least 50% low‐income, At least 50% low‐income, Highland Park, IL 2003 5 Citywide 20% income, at least 33% low‐ Perpetuity Highland25 Park, IL 2003 X X 5 Citywide 20% XXincome, at least 33% low‐ Perpetuity X25 X X XX X remainder for moderate‐ remainder for moderate‐ income, remainder income, remainder income income moderate income moderate income

Rental units: Zoning map Rental units: Zoning map 2006, amendment, subdivision, or 2006, amendment, subdivision, or Offsets may Offsets may 80% of AMI ‐ 60% of AMI ‐ 80% of AMI ‐ 60% of AMI ‐ Madison, WI sunsetted other land division. 10 Citywide 15% Unspecified Madison,50 WI sunsettedX other land division.XXX 10 Citywide 15% X be XX UnspecifiedXX50 X XXX X be XX XX 100% 100% 100% 100% 2009 Owner‐occupied units: 2009 Owner‐occupied units: requested requested Mandatory inclusionary. Mandatory inclusionary.

Development approved via Development approved via subdivision, PUD, or other subdivision, PUD, or other new lot, or following 5%/10% ‐ 80% of AMI ‐ 60% of AMI ‐ new lot, or following 5%/10% ‐ 80% of AMI ‐ 60% of AMI ‐ St. Charles, IL 2008 1 Citywide 15 St.Perpetuity Charles, IL 2008 X X 1 Citywide XX 15 XXPerpetuity X X XX XX issuance of a building Total number of units 100% 100% issuance of a building Total number of units 100% 100% permit in select permit in select circumstances circumstances Minnesota Housing 50%/60% ‐ Minnesota Housing 50%/60% ‐ Incentive‐ Incentive‐ 10%/20% (of livable Finance Agency's 'Startup 100% (depth of 10%/20% (of livable Finance Agency's 'Startup 100% (depth of Based Rezoning or Comprehensive Based Rezoning or Comprehensive Edina, MN 2015 20 Citywide area) ‐ Depth of Program' guidelines apply affordability based on Initial sale Edina, 15MN 2015 X X 20 Citywide Xarea) ‐ DepthX of Program' guidelines apply affordabilityX based onX Initial saleX 15 X X X X X X X Inclusionary Plan Amendment Inclusionary Plan Amendment Policies affordability / tenure ‐ number of affordable Policies affordability / tenure ‐ number of affordable 100% units provided) 100% units provided)

50%/60% of AMI ‐ 50%/60% of AMI ‐ 10% to 18% ‐ 100% (depth of 10% to 18% ‐ 100% (depth of 80% of AMI ‐ 80% of AMI ‐ St. Louis Park, MN 2015 Financial Assistance 10 Citywide Depth of affordability affordability based on 25 St. Louis25 Park, MN 2015 Financial Assistance 10 Citywide DepthX of affordability XX affordabilityXXXX based on 25 25 X XX XXXX 100% 100% and tenure number of affordable and tenure number of affordable units provided) units provided)

Development receiving Development receiving Voluntary Voluntary density bonus or 80% of AMI ‐ 60% of AMI ‐ density bonus or 80% of AMI ‐ 60% of AMI ‐ Inclusionary Traverse City, MI 2009 1 Citywide 30 Inclusionary Traverse30 City, MI 2009 X 1 Citywide X 30 30 X X dimensional modification 100% 100% dimensional modification 100% 100% Policies Policies DRAFT incentive incentive

SB FRIEDMAN | development advisors SB FRIEDMAN | development advisors Sources: American Planning Association; Chicago Tribune; Edina, MN; Evanston, IL; The Gazette; Highland Park, IL; Iowa City, IA; Iowa City Press‐Citizen; Kane County Chronicle; Lake Forest, IL; Madison, WI; Metro Cities;Sources: Minnesota American Housing Planning Finance Association; Agency; ChicagoNational Tribune; Housing Edina,Conference; MN; Evanston, Northwest IL; MichiganThe Gazette; Council Highland of Governments; Park, IL; Iowa SB City, Friedman; IA; Iowa St. City Charles, Press ‐IL;Citizen; St. Louis Kane Park, County MN; Chronicle;StarTribune; Lake Sun Forest, IL; Madison, WI; Metro Cities; Minnesota Housing Finance Agency; National Housing Conference; Northwest Michigan Council of Governments; SB Friedman; St. Charles, IL; St. Louis Park, MN; StarTribune; Sun Sources: American Planning Association; Chicago Tribune; Edina, MN; Evanston, IL; The Gazette; Highland Park, IL; Iowa City, IA;www.sbfriedman.com Iowa City Press- www.sbfriedman.com Current; Traverse City, MI Current; Traverse City, MI Citizen; Kane County Chronicle; Lake Forest, IL; Madison, WI; Metro Cities; Minnesota Housing Finance Agency; National Housing Conference; Northwest Michigan Council of Governments; St. Charles, IL; St. Louis Park, MN; SB Friedman; StarTribune; Sun Current; Traverse City, MI

PAGE 51 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

EXHIBIT H.2: EDINA, MINNESOTA, IH POLICY SUMMARY Source: City of Edina, MN; Sun Current; Star Tribune; Minnesota Housing Finance Agency

Note: All references to the “City” in Exhibit H.2 refer to the City of Edina, MN.

Edina’s incentive-based inclusionary housing policy requires that developers provide affordable units if their development obtains a rezoning or comprehensive plan amendment and the development includes at least 20 units. The policy applies citywide.

For rental projects, the number of affordable units varies based on the affordability of the units provided. If units are affordable to households at 50% of AMI, a project must set aside 10% of its rentable area for low-income households. If units are affordable to households at 60% AMI, a project must set aside 20% of its rentable area. Owner-occupied projects must set aside 10% of livable area and use income thresholds defined by an existing program of the Minnesota Housing Finance Agency (MHFA). Rental units must remain affordable for at least 15 years while owner-occupied units must just be initially sold to a household that meets affordability requirements.

As an incentive for developers to participate in the policy, the City will consider density bonuses, parking reductions, TIF, deferred low-interest loans from the Edina Housing Foundation and tax abatements.

Edina reserves the right to waive the requirements of the policy if it is deemed to be economically infeasible or impractical in a particular situation and will consider certain alternatives to developing units on-site. However, notably, Edina does not offer developers the option to pay a fee-in-lieu to avoid participation. Developers may dedicate existing units as affordable but must dedicate more than if they built new units (110% of built requirement). Developers also may produce new units on a different site, participate in a different affordable housing development in Edina, or propose an alternative that produces an equivalent number of affordable units.

According to the development pipeline currently under review by the City, the ordinance does not appear to have limited development since it was enacted in 2015.

Multiple outreach attempts to the City of Edina to discuss their affordable housing policy and project pipeline were not successful.

EXHIBIT H.3: ST. CHARLES, ILLINOIS, IH POLICY SUMMARY Source: City of St. Charles, IL; Kane County Chronicles

Note: All references to the “City” in Exhibit H.3 refer to the City of St. Charles, IL.

St. Charles’ incentive-based inclusionary housing ordinance has been in place since 2008 and requires affordable units if a project is approved via a subdivision, PUD, or, in some cases, after receiving a building permit. The ordinance applies to relevant projects citywide, regardless of the number of units.DRAFT

St. Charles applies different unit requirements based on the size of the project. For projects with 15 units or less, 5% of units must be affordable; for projects with more than 15 units, 10% of units must be affordable. For rental units, the affordability threshold is 60% of AMI, which must be maintained in perpetuity. For owner-occupied units, the affordability threshold is 80%, which must be maintained for at least 15 years. If, after the 15-year affordability period, an owner sells at market rate, a portion of the sale price must be paid to the City to be used for other affordable housing programs. Density bonuses and waivers of development or municipal impact fees charged for the affordable units constructed on-site are available.

St. Charles allows developers to either construct units or pay an in-lieu fee by right. However, if these options are not feasible for economic or other reasons listed in the ordinance, developers may submit an Alternative Affordable Housing Plan outlining the infeasibility of the requirements for the project and detailing how they will provide required affordable units. Alternative options include making efforts throughout the construction period to acquire additional funding to make the affordable units possible, purchasing units off-site and dedicating them for affordable housing, or providing some affordable units on-site and paying the in- lieu fee to make up the affordable unit requirement.

PAGE 52 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

The ordinance was suspended in 2013 when the City determined it had a sufficient stock of affordable housing citywide but was reinstated in 2016 as affordability declined. The fee-in-lieu of providing affordable units has also been reduced multiple times. Originally $140,000 per unit, it was lowered to $104,500 in 2010, suspended from 2013 to 2016, reinstated in 2016 at $72,819, and lowered in 2017 (for multifamily only) to $5,000.

EXHIBIT H.4: TYPICAL AFFORDABLE HOUSING PLAN COMPONENTS

Six of the communities reviewed by SB Friedman required an affordable housing plan as part of the development application process for projects impacted by the inclusionary housing policy. In each of these cases, a development agreement outlining the requirements and restrictions placed on the development to achieve affordable housing goals was also required.

Required contents for the affordable housing plan are laid out in the ordinance or policy in each community. Two requirements were standard across all communities:

• Proof that documents necessary to ensure ongoing affordability have been executed/recorded; and • Documentation of any alternatives to on-site construction of affordable units that are to be used in the project.

Additional typical requirements include:

• A general description of the project; • Tenure of units to be created, either owner-occupied or rental; • Count of units by market-rate or affordable; • Physical specifications for each unit including bedroom count, square footage and interior/ exterior finishes; • Site plans or floor plans documenting the distribution of affordable units throughout the development; • Pricing by unit; • Phasing and construction schedule by unit; and • Marketing plan to sell or rent the affordable units.

In most cases, either the affordable housing plan itself or specific components of the plan (project description, unit count by affordability, physical specifications, distribution of affordable units throughout development, pricing, and timeline) are identified as required components to be included in the development agreement as well.

There were several other items required by some communities that were less standard but may still provide some value in an affordable housing plan or development agreement:

• Specific outreach to low-income or priority populations; • Targeted income levels; • Documentation of incentives sought/toDRAFT be used; • Maintenance or management agreements for the affordable units; and • Documentation that any alternatives being used would provide equal or greater affordability benefits to construction of on-site units.

EXHIBIT H.5: IMPACTS OF SAMPLE INCLUSIONARY HOUSING POLICY ON DEVELOPMENT

SB Friedman conducted a financial analysis to evaluate the impact of sample inclusionary housing policies, particularly in regards to developer returns and the need for financial assistance, on a hypothetical 185-unit new construction apartment project. Sample inclusionary housing scenarios evaluated include:

• Scenario A: 85% of units are market rate and generating an average rent of $1.85 per square foot, with 15% of units (28 units) affordable to households earning 60% and 80% of area median income (income and rent limit assumptions are presented in Table H.5.1). Affordable units are split evenly between the two affordability levels, as presented in Table H.5.2.

PAGE 53 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

• Scenario B: 85% of units are market rate and generating an average rent of $1.85 per square foot, with 15% of units affordable to households earning 30%, 60% and 80% of area median income. Affordable units are split evenly between the three affordability levels.

The results of the analysis are presented in Table H.5.4. Key conclusions are outlined below:

• Developer returns. Returns are projected to decrease from a benchmark of 6.0% yield-on-cost to 5.5% (Scenario A) and 5.4% (Scenario B) with the hypothetical inclusionary programs. Both returns are below current typical market return expectations of 6.0-7.0% yield on cost.

• Financial assistance. The base case scenario assumes that 10.0% of total development costs, or approximately $3.9 million, are funded through Tax Increment Financing (TIF), primarily to support structured parking. To improve developer returns and ensure the projects are financially feasible (i.e. meet typical market return thresholds), with the hypothetical inclusionary program, it is anticipated that developers would request additional City financial assistance. To achieve a 6.0% yield on cost, approximately $2.7 million in additional assistance would be required for Scenario A and approximately $3.6 million for Scenario B.

Inclusionary housing is projected to impact the financial feasibility of new projects, many of which already receive City financial assistance, primarily to cover extraordinary costs such as structured parking. Additional assistance will likely be required to support affordable units, through either TIF or another financing source, such as an Affordable Housing Fund (see page 8). The amount of overall TIF or other assistance should be carefully calibrated to ensure the projects are financially feasible but developers are not generating above-market returns.

Table H.5.1. F.5.1. Income Income and and Rent Rent Limit Limit Assumptions Assumptions for Affordable Units Income Limits for 2017 (Based on 2017 AMI Income Limits) 30% 40% 50% 60% 70% 80% 1 Person 2 Person 3 Person 4 Person 5 Person 6 Person 7 Person 8 Person 9 Person 10 Person 11 Person 12 Person Rent Limits for 2017 (Based on 2017 AMI Income Limits) DRAFT Bedrooms (People) 30% 40% 50% 60% 70% 80% FMR Efficiency (1.0) 1 Bedroom (2.0) 2 Bedrooms (3.0) 3 Bedrooms (4.0) 4 Bedrooms (5.0) 5 Bedrooms (6.0) Sorce oogradac ent ncoe iit Calclator ther ederal State or Source: Novogradac Rent & Income Limit Calculator; Other Federal, State, or ocal rogra nonC person per edroo pls ilwakee Conty Local Program (non-LIHTC), 1 person per bedroom plus 1, Milwaukee County, WI, 2017

Table F.5.2. Hypothetical Project Affordability Assumptions

SCENARIO A SCENARIO B INCLUSIONARY HOUSING ASSUMPTIONS INCLUSIONARY HOUSING ASSUMPTIONS MARKET RATE & AFFORDABLE UNITS MARKET RATE & AFFORDABLE UNITS nits arketate ffordale nits arketate ffordale nits reakdown nits reakdown Stdio Stdio ed ed PAGEed 54 ed ed ed AFFORDABLE UNIT BREAKDOWN AFFORDABLE UNIT BREAKDOWN reakdown reakdown Stdio Stdio ed ed ed ed ed ed AFFORDABLE UNIT RENTS AFFORDABLE UNIT RENTS Stdio Stdio ed ed ed ed ed ed AFFORDABLE RENT GENERATION $351,408 AFFORDABLE RENT GENERATION $294,504 Sorce SB Friedman

49

Table F.5.1. Income and Rent Limit Assumptions Income Limits for 2017 (Based on 2017 AMI Income Limits) 30% 40% 50% 60% 70% 80% 1 Person 2 Person 3 Person 4 Person 5 Person 6 Person 7 Person 8 Person 9 Person 10 Person 11 Person 12 Person Rent Limits for 2017 (Based on 2017 AMI Income Limits) Bedrooms (People) 30% 40% 50% 60% 70% 80% FMR Efficiency (1.0) 1 Bedroom (2.0) 2 Bedrooms (3.0) CITY OF WAUWATOSA 3 Bedrooms (4.0) HOUSING POLICY & ACTION PLAN 4 Bedrooms (5.0) 5 Bedrooms (6.0) Sorce oogradac ent ncoe iit Calclator ther ederal State or ocal rogra nonC person per edroo pls ilwakee Conty

Table F.5.2. Hypothetical Project Affordability Assumptions Table H.5.2. Hypothetical Project Affordability Assumptions SCENARIO A SCENARIO B INCLUSIONARY HOUSING ASSUMPTIONS INCLUSIONARY HOUSING ASSUMPTIONS MARKET RATE & AFFORDABLE UNITS MARKET RATE & AFFORDABLE UNITS nits arketate ffordale nits arketate ffordale nits reakdown nits reakdown Stdio Stdio ed ed ed ed ed ed AFFORDABLE UNIT BREAKDOWN AFFORDABLE UNIT BREAKDOWN reakdown reakdown Stdio Stdio ed ed ed ed ed ed AFFORDABLE UNIT RENTS AFFORDABLE UNIT RENTS Stdio Stdio ed ed ed ed ed ed AFFORDABLE RENT GENERATION $351,408 AFFORDABLE RENT GENERATION $294,504 SorceSource: SB SB Friedman Friedman

49 DRAFT

PAGE 55 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

Table F.5.2.H.5.3. Hy Hypotheticalpothetical Project Project Assumptions Assumptions Base Scenario Scenario A Scenario B AFFORDABILITY ASSUMPTIONS esidential nits ercent arketate nits er of arketate nits ercent ffordale nits er of ffordale nits of of of DEVELOPMENT PROGRAM entale S per nit ilding fficiency ross ilding S S per nit entale S S ross ilding S S Strctred arking Spaces per nit S Strctred arking Spaces CASH FLOW ASSUMPTIONS onthly ross enteenes per S nnal ross enteenes per S acancy oss perating Costs ecl property ta of eene roperty aes per S onthly arking eenes per space nnal arking eene per Space arking perating Costs of eene CONSTRUCTION COST ASSUMPTIONS cisition Costs per S ard Costs per S or nit ard Costs per Strctred arking Space Soft Costs as a of ard Costs inancing Costs as a of ard Costs eeloper ee as a of C e and City ssistance as a of C Source:Sorce SB SB Friedman Friedman

DRAFT

50

PAGE 56 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

Table H.5.4. Hypothetical Project Pro Forma with Inclusionary Housing Policies Base Scenario Scenario A Scenario B OPERATIONS Gross Market Rate Rents/Revenues $3,490,950 $2,967,308 $2,967,308 Gross Affordable Rents/Revenues $351,408 $294,504 ‐ Vacancy Loss ‐$174,548 ‐$165,936 ‐$163,091 ‐ Operating Costs ‐$837,828 ‐$837,828 ‐$837,828 ‐ Property Taxes ‐$555,000 ‐$555,000 ‐$555,000 + Parking Revenues $233,520 $233,520 $233,520 ‐ Parking Vacancy Loss ‐$11,676 ‐$11,676 ‐$11,676 ‐ Parking Operating Costs ‐$56,045 ‐$56,045 ‐$56,045 = Net Operating Income $2,089,374 $1,925,751 $1,871,692 DEVELOPMENT COSTS Acquisition Costs $2,405,000 $2,405,000 $2,405,000 + Hard Costs (Building) $25,900,000 $25,900,000 $25,900,000 + Parking Construction Costs $4,448,000 $4,448,000 $4,448,000 + Soft Costs $3,034,800 $3,034,800 $3,034,800 + Financing Costs $1,517,400 $1,517,400 $1,517,400 + Developer Fee $1,396,008 $1,396,008 $1,396,008 = Total Development Costs $38,701,208 $38,701,208 $38,701,208 Total Development Costs per SF $209 $209 $209 ‐ TIF Assistance (base level ‐ 10% of TDC) ‐$3,870,121 ‐$3,870,121 ‐$3,870,121 = Total Development Cost, net of TIF Assistance $34,831,087 $34,831,087 $34,831,087 DEVELOPER RETURNS Yield on Cost 6.0% 5.5% 5.4% Additional Assistance Required to Achieve 6.0% YoC $2,727,688 $3,628,880 Additional Assistance per Affordable Unit $98,295 $130,770 Source: SB Friedman

DRAFT

PAGE 57 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

Exhibit H.6: Edina, Minnesota, Full IH Policy Text

Affordable Housing Policy | Edina, MN

Affordable Housing Policy

The Affordable Housing Policy took effect November 1, 2015.

Background The City recognizes the need to provide affordable housing in order to maintain a diverse population and to provide housing for those who live or work in the City. Since the remaining land appropriate for new residential development is limited, it is essential that a reasonable proportion of such land be developed into affordable housing units. As such, the City of Edina adopts the following Affordable Housing Policy.

The Policy 1. This policy applies to all new multi-family developments of 20 or more units that require a re-zoning or a Comprehensive Plan amendment. All new multi-family developments requiring a rezoning shall be required to be re-zoned to PUD, Planned Unit Development. 2. New rental developments will provide a minimum of 10% of all rentable area at 50% affordable rental rates or 20% of all rentable area at 60% affordable rental rates as defined below. 3. New for sale developments will provide a minimum of 10% of all livable area at affordable sales prices as defined below. 4. New rental housing will remainDRAFT affordable for a minimum of 15 years, and this requirement will be memorialized by a land use restrictive covenant. 5. Recognizing that affordable housing is created through a partnership between the City and developers, the city will consider the following incentives for developments that provide affordable housing: a. Density bonuses b. Parking reductions c. Tax increment financing d. Deferred low interest loans from the Edina Housing Foundation e. Tax Abatement

6. It is the strong preference of the City that each new qualifying development provide its proportionate share of affordable housing, however, the City recognizes that it may not be economically feasible or practical in all circumstances to do so. As such, the City reserves the right to waive this policy (only if circumstances so dictate, as determined by the City). In lieu of providing affordable housing in each new qualifying development, the City may consider the following: Enable Google Translate https://www.edinamn.gov/624/Affordable-Housing-Policy 8/28/2017 PAGE 58 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

Affordable Housing Policy | Edina, MN a. Dedication of existing units in Edina equal to 110% of what would have been provided in a proposed new development. These units would need to be of an equivalent quality, within the determination of the City. b. New construction of units of an equivalent quality within the City at a different site, at the discretion of the City. c. Participation in the construction of affordable dwelling units of an equivalent quality by another developer on a different site within the City. d. An alternative proposed by a developer that directly or indirectly provides or enables provision of an equivalent amount of affordable housing within the City.

Definitions Rental Housing Either 10% of all rentable area is both rent restricted and occupied by persons whose income is 50% or less of area median gross income, Or 20% of all rentable area is both rent restricted and occupied by persons whose income is 60% or less of area median gross income.

Both incomes (adjusted for family size) and rental rates (adjusted for bedroom count and including utilities) are updated annually by the Minnesota Housing Finance Agency (MHFA) and published at Minnesota Housing Finance Agency. View 2017 income and rental limits.

Ownership Housing 10% or more of all livable area is affordable to and initially sold to persons whose income is at or below the levels set in the MHFA’s “Startup Program” (first time homebuyer). This program has a sales price limit of $306,000. The Edina Housing Foundation has set this limit at $350,000 in consideration of the high prices in Edina. The Foundation would recommend the following sales prices be used as the acquisition limit in this definition.

Number of Bedrooms Sales Price

1 Bedroom $250,000

2 Bedroom $300,000 3 or more Bedroom DRAFT$350,000

The 2017 Income Limits as Published on the MHFA Website

Number of People Price

1 to 2 Person Household $90,400

3 or more Person Household $103,900

Income limits and maximum sales prices are updated annually, see Minnesota Housing Fiance Agency.

Effective: November 1, 2015

Income/Rent Limits Adjusted: April 14, 2017 Enable Google Translate https://www.edinamn.gov/624/Affordable-Housing-Policy 8/28/2017 PAGE 59 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

19.02 – Inclusionary Housing Ordinance Exhibit H.7: St. Charles, Illinois, Full IH Policy Text

19.02 – Inclusionary Housing Ordinance

Sections

19.02.010 – Purpose and Intent

19.02.020 – Implementation

19.02.030 – Enforcement

19.02.040 – Definitions

19.02.050 – Applicability

19.02.060 – Affordable Units and Fee In-Lieu Required

19.02.070 – Alternative Affordable Housing Plan

19.02.080 – Density Bonus

19.02.090 – Development Cost Offsets

19.02.100 – Location, Phasing and Design.

19.02.110 – Maximum Price of Affordable Units

19.02.120 – Ownership and Occupancy of Affordable Units. 19.02.130 – DevelopmentDRAFT Applications that Include Affordable Units. 19.02.140 – Affordable Housing Agreement and Documents

19.02.010 – Purpose and Intent [1]

To provide opportunities within the City for affordable housing, either within new residential developments by requiring Developers to provide a proportionate share of affordable housing, or fees in lieu thereof, to ensure that an adequate stock of affordable housing is, and remains, available in the City of St. Charles.

(2016-M-7 [2]: § 2)

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19.02 – Inclusionary Housing Ordinance

19.02.020 – Implementation [3]

The Director of Community and Economic Development or Director’s designee shall promulgate regulations and forms as may be necessary for the implementation of this Chapter. Said regulations shall be reported to the Housing Commission and City Council.

(2016-M-7 [2]: § 2)

19.02.030 – Enforcement [4]

1. The provisions of this Chapter shall apply to all agents, successors and assignees of an Applicant. 2. The City of St. Charles may institute injunction, mandamus, or any other appropriate legal actions or proceedings for the enforcement of this Chapter. In addition, any person, firm, or entity, whether as principal, agent, employee or otherwise, violating or causing the violation of any of the provisions of this Chapter, shall be guilty of a misdemeanor, and upon conviction thereof shall be punishable for each offense by the payment of a fine of not more than $750.00 dollars per day. Such person, firm, or entity shall be deemed to be guilty of a separate offense for each and every day during any portion of which any violation of this Chapter is commenced, continued, or permitted by such person, firm, or entity, and shall be punishable as herein provided.

(2016-M-7 [2]: § 2)

19.02.040 – Definitions [5]DRAFT

The following words and phrases shall have the meanings set forth in this Section. Words and phrases not defined in this Section, but defined elsewhere in the St. Charles Municipal Code, shall have the meanings set forth therein. In the event that a word or phrase is not defined, it shall have the common and ordinary meaning ascribed thereto. In interpreting the provisions of this Chapter, in the event there is a conflict between a definition in this Section and one found elsewhere, the definition in this Section shall apply.

1. Affordable Housing: Housing that has a sales price or rental amount that is within the means of an “Eligible Household” as defined herein. In the case of Dwelling Units for sale, housing that is affordable means housing in which mortgage, amortization, taxes, insurance, and condominium or association fees, if any, constitute no more than 30% of the gross annual household income for a household of the size that may occupy the unit. In the case of Dwelling Units for rent, housing that is affordable means housing for which the rent and utilities constitute no more than 30% of the gross annual household income for a household of the size that may occupy

Page 2 of 12

PAGE 61 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

19.02 – Inclusionary Housing Ordinance

the unit. 2. Affordable Unit: A Dwelling Unit of Affordable Housing that satisfies the requirements of this Chapter. 3. Affordable Housing Agreement: Any agreement between the City and an Applicant as required by Section 19.02.140 of this Chapter. 4. Applicant: Any Developer who applies to the City to receive approval of a Residential Development pursuant to this Chapter. 5. Area Median Income (AMI): The median income level for the Chicago Primary Metropolitan Statistical area, as established and defined in the annual schedule published by the Secretary of the U.S. Department of Housing and Urban Development, and adjusted for household size. 6. Base Density: The number of Dwelling Units permitted to be constructed on a parcel in conformance with the requirements of the Zoning District in which it is located, prior to applying any applicable density bonus. 7. Developer: Any person, firm, corporation, partnership, limited liability company, association, joint venture, or any entity or combination of entities that develops a dwelling or units, not including any governmental entity or a Housing Provider as defined herein. 8. Director: The Director of the Community and Economic Development Department, or his or her designee. 9. Dwelling Unit: A Dwelling Unit as defined in Chapter 17.30, “Definitions”, of Title 17 “Zoning”. For purposes of this Chapter, the term Dwelling Unit includes Affordable Units and Market Rate Units. 10. Eligible Household: A household with an income at or below eighty percent (80%) of the Area Median Income (AMI) for for-sale units and at or below sixty percent (60%) of the AMI for rental units, based on the size of the household. 11. Housing Provider: An entity approved by the City of St. Charles to develop, manage or own Affordable Dwelling Units. 12. Market Rate Units: All Dwelling Units in a Residential Development that are not Affordable Units as defined herein. 13. Residential Development: The establishment of one or more Dwelling Units in any of the following instances: 1. Construction of one or more Dwelling Units pursuant to a Final Plat of Subdivision, where the Preliminary Plat is approved by the City Council after February 15, 2008. 2. Construction of one or more Dwelling Units within a Planned Unit Development, where the Preliminary PUD Plan is approved by the City Council after February 15, 2008. 3. Construction of one or more Dwelling Units on a lot created after February 15, 2008 by means other than a Plat of Subdivision or Planned Unit Development, including but not limited to a division conforming to the Statutory Plat Act Exemptions. 4. Issuance of a building permit for a new Dwelling Unit following demolition of a Dwelling Unit on the lot, when the last sale price prior to demolition of the Dwelling Unit was at or below the price of an Affordable Unit with theDRAFT same number of bedrooms; if the last sale occurred more than two years prior to demolition, then the equalized market value assigned by the Township Assessor as of the date of demolition shall be used. 5. Issuance of a building permit for alteration of an existing building, in whole or in part, that increases the number of Dwelling Units from the number that existed prior to its alteration.

(2016-M-7 [2]: § 2)

19.02.050 – Applicability [6]

1. The provisions of this Chapter shall apply to any Residential Development, as defined herein. Residential

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19.02 – Inclusionary Housing Ordinance

Developments undertaken in phases, stages, or otherwise constructed in distinct parts by one or more developers, but which are located within the same Planned Unit Development or Subdivision, or which are otherwise approved as a whole, shall be considered a single Residential Development. 2. The requirements of this Chapter shall not apply in the following instances: 1. Moving a building containing one or more Dwelling Units from one location to another within the City. 2. Construction of a single Dwelling Unit on a lot that was of record prior to February 15, 2008 and upon which no Dwelling Unit or part thereof has existed for a period of ten years or more prior to issuance of a building permit. 3. Upon issuance of a building permit for a new Dwelling Unit following demolition of a Dwelling Unit on the lot, when the new Dwelling Unit is intended to be occupied by the same household or individual that occupied the Dwelling Unit that was demolished, and the demolition occurred more than one (1) year after the date of purchase by said household or individual. 4. When a Dwelling Unit is destroyed by fire or other casualty or act of God, by any means not within the control of the property owner or tenant. 5. When an application for Special Use for Planned Unit Development, Preliminary Plat of Subdivision, and/or Final Plat of Subdivision in relation to a Residential Development was filed with the City on or before February 16, 2016. 6. When an application for building permit for a Residential Development was filed with the City on or before February 16, 2016.

(2016-M-7 [2]: § 2)

19.02.060 – Affordable Units and Fee In-Lieu Required [7]

1. General requirement. Affordable Units, and/or a fee in lieu thereof, shall be required for every Residential Development. The City Council may permit the Applicant to provide Affordable Units or pay a fee in lieu of constructing some or all of the required Affordable Units within a Residential Development. 2. Number of Affordable Units Required: 1. Calculation. The number of Affordable Units required for a Residential Development shall be a percentage of the total numberDRAFT of Dwelling Units to be constructed within the Residential Development, but not including any bonus Market Rate Units permitted by Section 19.02.080. The minimum requirement shall be calculated as follows: 1 to 15 Dwelling Units: 5 percent More than 15 Dwelling Units: 10 percent 2. Fractions. In the event that the calculation of the number of required Affordable Units results in a fraction, the following rules shall apply: For that portion of the requirement that is to be satisfied by the construction of Affordable Units, the fraction shall be rounded to the nearest whole number; a fraction of exactly ½ shall not be counted as a required Affordable Unit. For that portion of the requirement that is to be satisfied by payment of a fee in-lieu, any fraction shall be used in calculating the total fee in lieu to be paid by the Developer. 3. Amount of Fee In-Lieu Per Unit. The amount of the per-unit fee in-lieu of Affordable Units shall be determined annually by the City Council. If no fee has been determined by the City Council for the current year, the fee most recently determined by the City Council shall apply. 4. Calculation of Total Fee In-Lieu. For purposes of determining the total fee in-lieu payment amount, the per unit fee in-lieu shall be multiplied by the required number of Affordable Units, including any fractional units.

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5. Payment of Fee In-Lieu. Unless otherwise approved by the City Council in the Affordable Housing Agreement, for Residential Developments constructed in multiple phases the fee in-lieu payments due under the provisions of this Chapter shall be paid for the entire phase to be developed prior to issuance of the first building permit for the applicable phase. For Residential Developments constructed in a single phase the fee in- lieu payment shall be paid for the entire Residential Development prior to issuance of the first building permit.

(2016-M-7 [2]: § 2)

19.02.070 – Alternative Affordable Housing Plan [8]

A. Alternative Affordable Housing Plan Criteria

As an alternative to compliance with the provisions of Section 19.02.060, the Developer may request the City Council to approve, concurrent with the approval of the overall development and after receiving a recommendation from the Housing Commission, one or more of the alternatives listed in this Section. The City Council shall not approve an Alternative Affordable Housing Plan unless the Developer demonstrates and the City Council finds in the affirmative that the Alternate Affordable Housing Plan is justified based on one or more of the following criteria:

1. A demonstrated financial hardship exists that is not of the developer’s own making. Items to be considered shall include but shall not be limited to:

a. The financial hardship must be equal to or greater than 10% of the total project cost and purchase price, but cannot include any costs incurred as part of the normal and orderly development of the property.

b. Environmentally sensitive or natural areas to be protected are equal to or greater than 20% of the total development site area (not including stormwater retention/detention facilities or park sites related to the construction of the project).

2. The development site does not allow for the density bonus as stated in Section 19.02.080 due to limitations on development capacity. Items to beDRAFT considered shall include but shall not be limited to: a. Insufficient water or sewer utility capacities.

b. Unique parcel configurations, which shall include but shall not be limited to steep slopes above an 8% grade or irregular shaped parcels that create unbuildable areas equal to or greater than 20% of the development site.

3. The development will fulfill an alternative City Policy or goal such as redevelopment of a vacant, underutilized, or blighted parcel that cannot otherwise be readily redeveloped and comply with all other applicable requirements.

4. The creation of the Alternative Affordable Housing Plan represents an equal or greater opportunity to create Affordable Housing in the City. Examples of these greater opportunities shall include but shall not be limited to:

a. Providing units below the maximum affordability thresholds established by Illinois Housing Development Authority for rental or owner-occupied units. (Example: Pricing rental units at or below 50% of area median income)

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b. Providing offsite affordable units in vacant or foreclosed homes.

c. Providing affordable units for a period of time longer than the fifteen year minimum affordable period stated in Section 19.02.110 Maximum Price of Affordable Units.

B. Alternative Affordable Housing Plan

For instances in which the Developer is requesting to utilize an Alternative Affordable Housing Plan, the Developer shall submit the proposed Alternative Affordable Housing Plan. This plan shall detail the Developer’s course of action chosen to create Affordable Housing opportunities in St. Charles. This plan is required to be submitted in writing and must detail how the Alternative Affordable Housing Plan fulfills the criteria listed in Section 19.02.070.A.

One or more of the following options shall be utilized by the Developer:

1. External Funding Sources – The Developer will apply for grants, tax credits, and/or any other applicable funding mechanism each year that the project is under construction. These funds will be used to subsidize the costs associated with the construction of onsite or offsite Affordable Housing Units.

2. Purchase Offsite Units – The Developer shall purchase for-sale or foreclosure properties and then sell or rent them at the established Affordable Housing price.

3. Construction of a portion of the required Affordable Units onsite and/or payment of a portion of the required fee in-lieu, and any combination of the two options listed above.

(2016-M-7 [2]: § 2; 2013-Z-3 [9]: § 4)

19.02.080 – Density Bonus [10]

A. A density bonus shall be permittedDRAFT when Affordable Units are constructed within the Residential Development in accordance with Section 19.02.060 (B). One bonus Dwelling Unit shall be permitted for each Affordable Unit constructed within the Residential Development; however, in no event shall the total number of Dwelling Units constructed within the Residential Development exceed one hundred twenty percent (120%) of the Base Density.

B. In implementing this density bonus, the following requirements of Title 17 of the St. Charles Municipal Code, the St. Charles Zoning Ordinance, may be varied without additional justification:

1. Lot area.

2. Lot width.

3.

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Building coverage.

(2016-M-7 [2]: § 2)

19.02.090 – Development Cost Offsets [11]

An Applicant that fully complies with the requirements of this Chapter, including any rules or regulations promulgated thereunder, shall, upon written request to the City, receive a waiver of all building permit, demolition, and plan review fees required by Title 15 of the St. Charles Municipal Code, sewer and water connection fees required by Title 13 of the St. Charles Municipal Code, and cash contributions (when required in lieu of park and school land dedications) as required by Title 16 of the St. Charles Municipal Code, but only relative to the required Affordable Units constructed within the Residential Development.

(2016-M-7 [2]: § 2)

19.02.100 – Location, Phasing and Design. [12]

Affordable Units shall be integrated into the Residential Development by location, construction phasing, and design as described below. Waivers or variances as to the location, construction phasing, or appearance of Affordable Units may be granted by the City Council following a review and recommendation by the Housing Commission, based on supporting evidence that demonstrates that said waiver(s) or variance(s) will further affordable housing opportunities to an equal or greater extent than compliance with otherwise applicable requirements, or that integrating the Affordable Units will create a hardship.

A. Location of Affordable Units. Affordable Units shall be dispersed among the Market-Rate Dwelling Units throughout the Residential DevelopmentDRAFT B. Phasing of Permits. The Affordable Units shall be constructed concurrently with the Market-Rate Units within the Residential Development. Building and occupancy permits for Market-Rate Units shall be issued only if building and occupancy permits, respectively, for the required Affordable Units have been issued in accordance with the following schedule:

Market-Rate Units (%) Affordable Units (%)

Up to 50% At least 30%

Up to 75% At least 60%

100% 100%

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C. Exterior Appearance. The exterior appearance of the Affordable Units in any Residential Development shall be visually compatible with the Market-Rate Units in the development. External building materials and finishes shall be substantially the same in type and quality for Affordable Units as for Market-Rate Units.

D. Interior Appearance and Finishes. Affordable Units may differ from Market-Rate Units with regard to interior finishes and gross floor area, provided that:

1. Bedroom Mix. The number of bedrooms per Dwelling Unit in the Affordable Units within the Residential Development shall be in equal proportion to the number of bedrooms per Dwelling Unit in the Market-Rate Units within the Residential Development. This provision is not intended to require the same floor area in Affordable Units as compared to Market-Rate Units.

2. Energy Efficient Improvements. Affordable Units and Market-Rate Units shall have the same type and quality of improvements related to energy efficiency, including plumbing, insulation, windows, and heating and cooling systems.

(2016-M-7 [2]: § 2)

19.02.110 – Maximum Price of Affordable Units [13]

A. Affordability Controls; Waivers. All Affordable Units developed in accordance with this Chapter shall be subject to restrictions as provided in this section.DRAFT B. For-Sale Affordable Units. Affordable Units shall be offered for sale in conformance with the following principles:

1. The sale of Affordable Units to the first purchaser shall be governed by the following:

a. Affordable Units shall be offered for sale at no more than the maximum price that is affordable to an Eligible Household based on household size in accordance with paragraph D of this Section, using the limits established annually by the Illinois Housing Development Authority (IHDA).

b. The property shall be subject to a deed restriction or other suitable instrument limiting the maximum sale price of the property for a period of fifteen years, and specifying the conditions under which title to the property may be transferred to an entity other than an Eligible Household, including but not limited to transfer of title to heirs. c. The purchaser shall execute a promissory note in favor of the City in an amount equal to the difference between the purchase price for the Affordable Unit and its fair market value as determined by a licensed appraiser. Said

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promissory note shall be non-interest bearing and shall be secured by a Mortgage on the property. The City shall subordinate the Mortgage to that of the primary lender. (Said promissory note shall be due upon sale of the Affordable Unit after the initial fifteen-year period if the property is sold at market value in accordance with Section 19.02.110.B.3.b.)

2. Subsequent sales of Affordable Units during the first fifteen years following the initial sale shall be governed by following, unless the property owner is granted a waiver by the City Council based upon supporting market-related evidence of undue hardship on the owner of the Affordable Unit:

a. The maximum sale price shall be the initial sale price plus 1) appreciation in the property’s value, but not to exceed any increases in the IHDA affordability limit since the last sale of the property; 2) an allowance for the cost of repair and/or replacement of heating, electrical, plumbing, roofs, and structural elements necessary to address safety of the occupants or integrity of the structure.

b. The seller shall receive any of the Affordable Unit’s appreciation in value based on the sale price as determined in Section 19.02.110.B.2.a.

c. The purchaser shall execute a promissory note in favor of the City in an amount equal to the difference between the purchase price for the Affordable Unit and its fair market value as determined by a licensed appraiser. Said promissory note shall be non-interest bearing and shall be secured by a Mortgage on the property. The City shall subordinate the Mortgage to that of the primary lender. (Said promissory note shall be due upon sale of the Affordable Unit after the initial fifteen-year period if the property is sold at market value in accordance with Section 19.02.110.B.3.b.)

3. Subsequent sales of Affordable Units after the initial fifteen-year period shall be governed by either (a) or (b) as follows:

a. Resale as an Affordable Unit. If the sale price does not exceed the initial sale price plus 1) appreciation in the property’s value, but not to exceed any increase in the IHDA affordability limit since the last sale of the property; and 2) an allowance for the cost of repair and/or replacement of heating, electrical, plumbing, roofs, and structural elements necessary to address safety of the occupants or integrity of the structure, then the property shall be sold as an Affordable Unit in accordance with Section 19.02.110.B.2.

b. Resale at market value. The full amount of the promissory note shall be payable to the City and shall be deposited into the Housing Trust DRAFTFund or other fund devoted to providing affordable housing. In the event the amount of the promissory note is in excess of the difference between market value and the purchase price paid by the seller, with allowances granted to the seller for any increase in the IHDA affordability limit since the last sale of the property and for the cost of repair and/or replacement of heating, electrical, plumbing, roofs and structural elements necessary to address safety of the occupants or integrity of the structure, then the excess amount shall be forgiven by the City. Once the promissory note is paid and/or forgiven in accordance with this Section, all restrictions of this Chapter applicable to the Affordable Unit, including its designation as such, shall cease.

C. For-Rent Affordable Units. The maximum gross rent (including a utility allowance for utilities not provided with the rent) for Affordable Units offered for rent shall be calculated using the gross rent limits established annually by the Illinois Housing Development Authority on the basis of thirty percent (30%) of gross monthly income at fifty percent (50%) to sixty percent (60%) of AMI, based on household size in accordance with paragraph D of this Section. The net rent charged by the owner shall not exceed the maximum gross rent minus a utility allowance for any utilities to be paid separately by the tenant. All Affordable Units shall be offered at not more than the maximum rent calculated in accordance with this paragraph in perpetuity or as long as permissible by law.

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D. Household Size. In calculating the maximum sale and rental prices of Affordable Units, the following relationship between the number of bedrooms per unit and household size shall apply:

Size of units: Affordable for:

Efficiency units: 1-person household

One-bedroom units: 2-person household

Two-bedroom units: 3-person household

Three-bedroom units: 4-person household

Four-bedroom and larger units: 5-person households and larger

E. Sale or Rental to Housing Providers. Every Affordable Unit required by this Chapter shall be offered for sale or rental to an Eligible Household as a primary resident, except for units purchased by Housing Providers. Housing Providers designated by the City of St. Charles shall have the right, but not the obligation, to purchase any for-sale Affordable Units, but only for the purpose of reselling to an Eligible Household.

(2016-M-7 [2]: § 2)

19.02.120 – Ownership and Occupancy of Affordable Units. [14]

Owner-occupied Affordable Units shallDRAFT only be sold to and occupied by Eligible Households. Affordable Units that are rented shall only be rented to and occupied by Eligible Households. Subletting of Affordable Units shall not be permitted. Priority will be given to Eligible Households where one or more members live or work in St. Charles, and to employees of the City of St. Charles, the St. Charles Park District, and Community Unit School District No. 303, regardless of their initial place of residence, to the extent permitted by law.

1. Increase in Annual Income for Owner-Occupied Affordable Units. If a Household’s gross income increases above the maximum Eligible Household income level for a household of its size, the Household may continue to own and occupy the Affordable Unit, and the Affordable Unit shall otherwise remain subject to the limitations set forth in Section 19.02.110.

2. Increase in Annual Income for Renter-Occupied Affordable Units. If a Household’s gross income increases above the maximum Eligible Household income level for a household of its size, the Household may continue to lease and occupy the Affordable Unit, and renew said lease, and the Affordable Unit shall otherwise remain subject to the limitations set forth in Section 19.02.110.

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(2016-M-7 [2]: § 2)

19.02.130 – Development Applications that Include Affordable Units. [15]

As part of the application for approval of a Residential Development, the Applicant shall submit information describing how the Residential Development will comply with the requirements of this Chapter. The Director of Community and Economic Development may require any or all of the following to be submitted for review:

1. The number and rental/for sale status of Market-Rate Units and Affordable Units to be constructed including type of dwelling, number of bedrooms per unit, proposed pricing, and construction schedule, including anticipated timing of issuance of building permits and occupancy certificates.

2. Documentation and plans regarding locations of Affordable Units and Market-Rate Units, and their exterior appearance, materials, and finishes.

3. A description of the marketing plan that the Applicant proposes to utilize and implement to promote the sale or rental of the Affordable Units within the development; and,

4. Any proposal to pay fees in lieu of providing the required Affordable Unit, per Section 19.02.060.

5. Alternative Affordable Housing Plan Submittal Requirements

a. The Applicant shall submit a financial statement or pro-forma including the following:

i. Purchase price of the property.

ii. Identification of the financial hardship and cost estimates associated with absorbing and/or remediating the identified hardship. iii. All non-hardshipDRAFT development costs and expected profits. b. Where the Applicant will apply for external funding sources, the following is required:

i. An action plan clearly identifying the external funding sources that will be applied for during the construction phase and frequency of application to each funding source. The Action Plan shall clearly demonstrate that the project is eligible for the funding source that will be utilized.

ii. Commitment to providing a copy of all grant applications at the same time the application is submitted to the funding authority.

iii. Statement of the number of Affordable Units targeted to be affordable.

iv. Documentation and plans regarding locations of Affordable Units and Market-Rate Units onsite or offsite, and their exterior appearance, materials, and finishes should external funding be awarded.

c. Where the Applicant will purchase offsite units, the following is required:

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i. An action plan or market study identifying the number of offsite units planned for purchase, the location of available offsite units, and purchase price of these units.

ii. Any supplemental information necessary to support the proposed plan such as, anticipated cost of renovations for offsite properties.

iii. The expected timing for the purchase of offsite units.

iv. Commitment to submitting a copy of the home inspection report to the City for review. This report shall include the following:

- Identification of the age and condition of all major systems (plumbing, HVAC, electrical, and structural)

- Identification and condition of all major appliances

- A list of all necessary repairs that the Developer proposes to perform before the offsite unit is resold to an Eligible Household.

The Developer shall provide a copy of this inspection report to the affordable household who has signed a contract to purchase the unit.

(2016-M-7 [2]: § 2; 2013-Z-3 [9]: § 5)

19.02.140 – Affordable Housing Agreement and Documents [16]

Prior to issuance of a building permit for any Residential Development in which Affordable Units are to be provided, the Applicant shall have entered into an Affordable Housing Agreement with the City. Said agreement shall set forth the commitments and obligations of the Applicant, including but not limited to the number, timing and location of the required Affordable Units, and/or theDRAFT amount and payment schedule for any fee in lieu thereof, to ensure that the provisions of this Chapter are met. The Applicant shall execute any and all documents deemed necessary by the City, including without limitation, restrictive covenants and other related instruments, to ensure the continued affordability of the Affordable Units in accordance with this Chapter.

(2016-M-7 [2]: § 5)

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Exhibit H.8: St. Louis Park, Minnesota, Full IH Policy Text

Inclusionary Housing Policy

This Policy promotes high quality housing located in the community for households with a variety of income levels, ages and sizes in order to meet the City's goal of preserving and promoting economically diverse housing options in our community.

The City recognizes the need to provide affordable housing to households of a broad range of income levels in order to maintain a diverse population and to provide housing for those who live or work in the City. Without intervention, the trend toward rising housing prices in new developments will continue to increase. As a result, this Policy is being adopted to ensure that a reasonable proportion of each new development receiving City financial assistance include units affordable to low and moderate income households and working families.

The requirements set forth in this Policy further the City’s Housing Goals and the City’s Comprehensive Plan to create and preserve affordable housing opportunities. These requirements are intended to provide a structure for participation by both the public and private sectors in the production of affordable housing.

I. Applicability and Minimum Project Size

Market Rate Multi-Unit Development Receiving City Financial Assistance This Policy applies to market rate multi-unit residential developments that receive financial assistance from the City and includes:

(1) new developments that create at least 10 multi-family dwelling units; or

(2) any mixed use building that creates at least 10 multi-family dwelling units; or

(3) renovation or reconstruction of an existing building that contains multi- family dwelling unitsDRAFT that includes at least 10 dwelling; or (4) any change in use of all or part of an existing building from a non- residential use to a residential use that includes at least 10 dwelling units.

II. Affordable Dwelling Units

General requirement A development that is subject to this Policy shall provide a number of affordable dwelling units equal to at least ten (10%) to eighteen percent (18%) of the total number of dwelling units in the development. The units designated as affordable will be subject to the requirements listed below.

Calculation of units required. (1) For development of multi-family dwelling units:

PAGE 72 CITY OF WAUWATOSA HOUSING POLICY & ACTION PLAN

A. The required number of Affordable Dwelling Units is based on the total number of dwelling units that are approved by the City.

B. To calculate the number of Affordable Dwelling Units required in a development the total number of approved Dwelling Units shall be multiplied by ten percent (10%) or ten percent (18%) depending on the affordability standard. If the final calculation includes a fraction, the fraction of a unit shall be rounded to the nearest whole number.

C. If an occupied property with existing dwelling units is remodeled and/or expanded, the number of affordable Dwelling Units shall be based on the total number of units following completion of renovation/expansion. At least ten percent (10%) or eighteen percent (18%) shall be affordable, depending on the affordability standard.

Affordability Level The required affordable dwelling units within a residential project subject to this policy shall meet an income eligibility and rent affordability standard for the term of the restriction as follows: (1) Rental Projects: A. At least eighteen percent (18%) of the units shall be affordable for households at sixty percent (60%) Area Median Income (AMI), or B. At least ten percent (10%) of the units shall be at available affordable for households at fifty percent (50%) Area Median Income.

(2) For-Sale Projects: A. At least fifteen percent (15%) of the units shall be affordable for households at eighty percent (80%) Area Median Income (AMI).

Rent and Sale Price Level Rental Unit: The monthly rental price for affordable dwelling units shall include rent and utility costs and shall be based on fifty percent (50%) and/or sixty percent (60%) for the metropolitan area that includes St. Louis Park adjusted for bedroom size and calculated annually by Minnesota Housing for establishing rent limits for the Housing Tax Credit Program.

For-Sale Projects: The qualifying sale price for an owner-occupied affordable dwelling unit shall include property taxes, homeowner’s insurance, principal payment and interest, private mortgage insurance, monthly ground DRAFTlease, and shall be based on eighty percent (80%) AMI for the metropolitan area that includes St. Louis Park adjusted for bedroom size and calculated annually by the Department of Housing and Urban Development.

Period of Affordability In developments subject to this Policy, the period of affordability for the affordable dwelling units shall be at least twenty-five (25) years.

Location of Affordable Dwelling Units Except as otherwise specifically authorized by this Policy, the Affordable Dwelling Units shall be located within the development.

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III. Standards for Inclusionary Rental Units Size and Design of Affordable Units The size and design of the affordable dwelling units should be consistent and comparable with the market rate units in the rest of the project and is subject to the approval of the City. The interior of affordable dwelling units do not need to be identical to the market rate units but if units are smaller than the other units with the same number of bedrooms in the development, City approval must be obtained.

Exterior/Interior appearance. The exterior materials and design of the affordable dwelling units in any development subject to these regulations shall be indistinguishable in style and quality with the market rate units in the development. The interior finish and quality of construction of the affordable dwelling units shall at a minimum be comparable to entry level rental or ownership housing in the City. Construction of the affordable dwelling units shall be concurrent with construction of marketrate dwelling units

IV. Integration of Affordable Dwelling Units

Distribution of affordable housing units. The affordable dwelling units shall be incorporated into the overall project unless expressly allowed to be located in a separate building or a different location approved by the City Council. Affordable dwelling units shall be distributed throughout the building.

Number of bedrooms in the affordable units. The affordable dwelling units shall have a number of bedrooms in the approximate proportion as the market rate units. The mix of unit types, both bedroom and accessible units, of the affordable dwelling units shall be approved by the City.

Tenants Rental affordable dwelling units shall be rented only to income eligible families during the period of affordability. An income eligible family may remain in the affordable dwelling unit for additional rental periods as long as the income of the family does not exceed one-hundred twenty percent (120%) of the applicable AMI.

V. Alternatives to On-Site Development of Affordable Dwelling Units This section provides alternativesDRAFT to the construction of affordable dwelling units onsite as a way to comply with this Policy. The alternatives are listed in subsection (3), below.

(1) The alternatives must be:

A. Approved by the City Council, and

B. Agreed to by the applicant in an Affordable Housing Performance Agreement.

C. Applicant must show evidence acceptable to the City that a formal commitment to the proposed alternative is in place.

(2) This Section does not apply unless the applicant demonstrates:

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A. The alternative provides an equivalent or greater amount of Affordable Dwelling Units in a way that the City determines better achieves the goals, objectives and policies of the city’s Housing Goals and Comprehensive Plan than providing them onsite; and

B. Will not cause the City to incur any net cost as a result of the alternative compliance mechanism.

(3) If the conditions in (2) are met, the City may approve one or more of the following options to providing Affordable Dwelling Units that are required by this Policy.

A. Dedication of Existing Units: Restricting existing dwelling units which are approved by the City as suitable affordable housing dwelling units through covenants, contractual arrangements, or resale restrictions. The City shall determine whether the form and content of the restrictions comply with this Policy. Off-site units shall be located within the City of St. Louis Park. The restriction of such existing units must result in the creation of units that are of equivalent quality, and size of the permanently Affordable Dwelling Units which would have been constructed on-site if this alternative had not been utilized.

B. Offsite construction of affordable dwelling units within the City. Offsite construction of units should be located in proximity to public transit service at a site approved by the City.

C. Participation in the construction of affordable dwelling units by another developer on a different site within the City. D. An alternative proposed by the applicant that directly provides or enables the provision of affordable housing units within the City. The alternative must be approved by the City and made a condition of approval of the Affordable Housing Performance Agreement.

VI. NON-DISCRIMINATION BASED ON RENT SUBSIDIES: Developments covered by the policy must not discriminate against tenants who would pay their rent with federal, state or local public assistance, including tenant based federal, state or local subsidies, including, but not limited to rental assistance, rent supplements, and Housing Choice Vouchers.DRAFT VII. Affordable Housing Plan

(1) Applicability

Developments that are subject to this Policy shall include an Affordable Housing Plan as described below. An Affordable Housing Plan describes how the developer complies with each of the applicable requirements of this Policy.

(2) Approval

A. The Affordable Housing Plan shall be approved by the City.

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B. Minor modifications to the plan are subject to approval by the City Manager. Major modifications are subject to approval by the City Council. Items that are considered major and minor will be designated in the Affordable Housing Plan.

(3) Contents.

The Affordable Housing Plan shall include at least the following:

A. General information about the nature and scope of the development subject to these regulations.

B. For requests to an alternative to on-site provision of affordable housing, evidence that the proposed alternative will further affordable housing opportunities in the City to an equivalent or greater extent than compliance with the otherwise applicable on-site requirements of this Policy.

C. The total number of market rate units and affordable dwelling units in the development.

D. The floor plans for the affordable dwelling units showing the number of bedrooms and bathrooms in each Unit.

E. The approximate square footage of each affordable dwelling unit and average square foot of market rate unit by types.

F. Building floor plans and site plans showing the location of each affordable dwelling unit.

G. The pricing for each affordable ownership dwelling unit. The pricing of each unit shall be determined at time of approval. At time of sale this price may be adjusted if there has been a change in the median income or a change in the formulas used in this ordinance. H. The orderDRAFT of completion of market rate and affordable dwelling units. I. Documentation and specifications regarding the exterior appearance, materials and finishes of the development for each of the affordable dwelling units illustrating that the appearance of affordable units are comparable to the appearance of the market-rate units.

J. An Affordable Dwelling Unit Management Plan documenting policies and procedures for administering the affordable dwelling units in accordance with the Affordable Housing Performance Agreement.

K. Any and all other information that the City Manager may require that is needed to achieve the Council’s affordable housing goals.

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VIII. Recorded Agreements, Conditions and Restrictions

(1) An Affordable Housing Performance Agreement shall be executed between the City and a Developer, in a form approved by the City Attorney, based on the Affordable Housing Plan described in Section VII, which formally sets forth development approval and requirements to achieve Affordable Housing in accordance with this policy and location criteria. The Agreement shall identify: a. the location, number, type, and size of affordable housing units to be constructed; b. sales and/or rental terms; occupancy requirements; c. a timetable for completion of the units; and d. restrictions to be placed on the units to ensure their affordability and any terms contained in the approval resolution by the City as applicable.

(2) The applicant or owner shall execute any and all documents deemed necessary by the City Manager, including, without limitation, restrictive covenants and other related instruments, to ensure the affordability of the affordable housing units in accordance with this Policy.

(3) The applicant or owner must prepare and record all documents, restrictions, easements, covenants, and/or agreements that are specified by the City as conditions of approval of the application prior to issuance of a Zoning Compliance Permit for any development subject to this Policy.

(4) Documents described above shall be recorded in the Hennepin County Registry of Deeds as appropriate.

IX. Definitions

1. Affordable Dwelling Unit: The required affordable dwelling units within a residential project subject to this policy shall meet an income eligibility and rent affordability standard for the term of the restriction as follows:

(1) Rental Projects: A. At least eighteen percent (18%) of the units shall be affordable for householdsDRAFT at sixty percent (60%) Area Median Income (AMI), or B. At least ten percent (10%) of the units shall be at available affordable for households at fifty percent (50%) Area Median Income.

(2) For-Sale Projects: A. At least fifteen percent (15%) of the units shall be affordable for households at eighty percent (80%) Area Median Income (AMI).

2. Financial Assistance: The Inclusionary Affordable Housing Policy applies to all new and renovated multifamily residential buildings receiving City financial assistance.

Financial Assistance is defined as funds derived from the City and includes but is not limited to the following:

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A. City of St. Louis Park B. Community Development Block Grant (CDBG) C. Housing Rehabilitation Fund D. Reinvestment Assistance Program E. Revenue Bonds (private activity bonds are negotiable) F. Tax Increment Financing (TIF) & Tax Abatement G. Housing Authority (HA) Funds H. Land Writedowns

3. Affordable Housing Plan: A plan that documents policies and procedures for administering the affordable dwelling units in accordance with the Affordable Housing Performance Agreement.

4. Affordable Housing Performance Agreement: Agreement between the City and the developer which formally sets forth development approval and requirements to achieve Affordable Housing in accordance with this policy.

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Appendix I: Additional Documentation

EXHIBIT I.1. Madison, Wisconsin, 2016 Biennial Housing Report

2016 CITY OF MADISON BIENNIAL HOUSING REPORT

DRAFT

PREPARED FOR THE CITY OF MADISON HOUSING STRATEGY COMMITTEE

AUTHOR: MATT WACHTER - HOUSING INITIATIVES SPECIALIST

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EXECUTIVE SUMMARY

The City of Madison Housing Strategy Committee is tasked with creating the Biennial Housing Report, an analysis of the city’s entire housing market with a particular emphasis on the affordability of housing and breadth of housing options. The report was written as a series of chapters that deal with individual segments of the housing market and each of these chapters attempt to:

• Clearly articulate how supply and demand functions in the market segment • Identify the primary challenges impacting the market segment • Highlight ongoing local initiatives and national best practices to address challenges in the market segment • Develop specific recommendations to guide City of Madison housing related programs and policy to address these challenges

Madison’s housing market is defined by long-term steady household growth powered by two engines: a high quality of life and a strong job market. These engines deliver durable but not explosive demand that is tempered by supply constraints ranging from physical limitation (lakes, surrounding municipalities) to self imposed limits (zoning, height limits). The result has been steady 1% per year growth in households for over 30 years, which is impressive for a mid-sized Midwest city but does not approach the booms seen by Austin, Denver, or Raleigh who have seen annual growth rates in the 3% range in recent years or suburbs in the Southwest that have grown at 5-8% a year.

Within that growth are significant shifts in who the city is adding as well as how they want to live. The first major trend that is affecting our housing market is income inequality. This is a national if not global trend, which appears in housing data in three ways. First, is on a macro scale most household growth after the 2007 recession came from the bottom of the income spectrum and the top, with very little growth in medium income tiers. Only in the last two years has the middle class begun to rebound. Second is geographic, with wealth and poverty concentrated in different pockets of the city. This is mirrored by rising or stagnating property values. Third is the split in housing tenure, with homeownership becoming out of reach for lower and middle class households.

The second major trend is that housing choices are being made based on lifestyle preference as much as economics. Households, particularly younger households, are basing their housing decisions on a desire for flexibility rather than commitment as well as convenient access to work, entertainment, and shopping. This has manifested as a market wide shift towards rental housing with nearly all net new households choosing to rent rather than own as well as a flurry of development and rising property values in areas of the city that are rich with amenities and transportation options. This trend is reinforced and complicated by tightened federal mortgage rules, stricter tenant-landlord rules, and historically low vacancy rates, which make it harder to enter the rental market or move up to ownership. The challenges that these trends present canDRAFT be summarized as: • Solid demand for housing that keeps housing prices relatively high • Accelerated household growth of nearly 2% (~2,100 net new households/year) since 2007 O For most of this period, household growth was split between higher-income households (>$100,000) and very low- income households (<$25,000) with a stagnant middle • New construction of housing dropped below the rate of household growth from 2007-2012 • This has resulted in historically low vacancy and rising rental prices, pushing low-income renters out of the market and preventing households from moving up • New rental construction has been focused on meeting the demand from high-income households and federal funding to subsidize housing for homeless, low-income rental, and low-income ownership has been steadily declining o Construction and land costs in our market make the creation of new units too expensive for low-income households without subsidy to developers • Tightened lending standards and high levels of student debt have made homeownership less accessible for low-income households and first time homebuyers

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To address these challenges, the Housing Strategy Committee recommends a multipronged strategy focused on the ideas of:

• Increasing the variety of housing options and price points in our most amenity and transit rich neighborhoods • Improving the quality of the housing stock and increasing access to transit and amenities in neighborhoods that are lagging • Expanding the types of housing available to fill in gaps that the housing market doesn’t currently serve

The tactics that the Housing Strategy Committee recommends rely on the themes of:

• Streamlining City programs that fund housing to be more efficient • Coordinating and leveraging all available funding sources across all City agencies, State, and federal programs to have the greatest impact • Proactively seeking partnerships with private developers to address housing challenges • Utilizing a variety of funding sources to support a new Affordable Housing Fund to fund housing projects and programs to meet our most pressing housing challenges

This report is divided into chapters covering:

• Homelessness • Low-Income Rental • Market Rate Rental • Low-Income Ownership • Market Rate Ownership • Student Housing • Senior Housing

Each chapter has been designed to stand on its own, with its own submarket analysis and recommendations. Each chapter has been individually referred to relevant City of Madison committees for acceptance and approved by the Common Council. DRAFT

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RECOMMENDATIONS

HOMELESSNESS

The top priority for this segment of the housing market has been and should continue to be moving people into permanent housing as quickly as possible and ensuring that no person in our community is unsheltered. To that end, supply should be increased using models that stretch the limited amount of federal funding as far as possible while delivering a broader range of options to meet the diverse needs of the population.

1. For individuals with alcohol and drug as well co-occurring mental health issues (who also have high levels of chronic homelessness), harm reduction, and wet housing options that do not require sobriety should be investigated, particularly in medium scale multiunit buildings with integrated case management. This population is a large user of detox programs, emergency rooms, police, services, and shelter facilities that are extremely expensive. Creating housing options for these individuals with particularly high barriers to housing could provide relief for the overall system of services. a. Fund Phase 2 of “Permanent Supportive Housing for Chronically Homeless Adults” as part of the Affordable Housing Fund* b. Prioritize funding non-profits expansion of harm reduction and “wet” housing programs* c. Pursue partnerships with healthcare providers to make an economic case for cost savings through reduced use of services 2. For families and single adults with low to moderate need for services, capacity should be increased through Rapid Rehousing into existing housing units and the creation of units integrated into mixed income developments through partnerships with for-profit real estate developers. By combining federal HOME and CDBG dollars and project based and VASH vouchers awarded to non-profits with Section 42 tax credits obtained by for-profits real estate developers, our limited federal resource allocation can be stretched farther. a. Continue/increase support for existing Rapid Rehousing programs and encourage their expansion to include single men* b. Prioritize funding and voucher allocations to non-profits pursuing projects in partnership with for-profits on Section 42 tax credit applications* c. Coordinate City and County funding and voucher allocation process, timelines, and priorities to maximize impacts and reduce administrative burden for each project* d. Actively work to develop non-profit/for-profit collaboration by hosting education and training events in conjunction with WHEDA* e. Actively lobby WHEDA to develop Section 42 tax credit award criteria to support projects in the City of Madison and in integrated settings* 3. As shelter facilities approach theDRAFT end of their usable life, new shelters should be constructed as purpose built shelters (rather than retrofitting churches and gymnasiums) with designated space for service providers, abundant showers and laundry, and bedbug machines. Options should be expanded to include “pay to stay” sections to serve as a transitional housing option. a. Local government should actively participate in land acquisition for new shelter construction to control siting and ensure adequate space and amenities* b. Work with shelter providers to develop long-term facilities plans to guide development*

*Completed or in-process

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LOW-INCOME RENTAL The overarching goal for the low-income rental market is to ensure that non-student households are not paying more than 50% of their income in rent, preferably not even paying 30%. The first priority in achieving this goal is to ensure that there is a sufficient supply of rental housing in the market to allow the market to properly function through moderate vacancy. The priority must then be to substantially increase the number of units in the market that are affordable to households making less than $50,000 per year (80% of median household income).

1. For all new multifamily rental buildings proposed in the City of Madison that are well sited for low-income populations (access to transportation, schools, grocery, walkability, not in a concentration of poverty), integration of some affordable units should be encouraged. As market rate projects begin the approval process, developers should be encouraged to include units affordable to low-income populations as part of their unit mix. This can be facilitated by: a. Dedicate a larger portion of City of Madison funds to subsidize low-income rental units i. Further enhance TIF policy to subsidize the development of low-income rental units ii. Subsidize affordable units as part of the Affordable Housing Fund* b. Explore ways to give a preference in the development approval process to rental developments that include affordable units. i. Discount or exempt affordable units from density limits ii. Identify areas and zoning districts in which to encourage low-income rental development iii. Waive or reduce City fees on affordable units* 2. Existing affordable subsidized rental units should be preserved and additional units should be converted to affordable housing by purchasing land use restrictions. Converting existing units is the fastest way to add affordable units to the market. a. Explore programs to subsidize landlords to designate existing units as affordable i. Place a land use restriction on units ii. Commit to affordable rents for 15 years iii. List units for rent on WIHousingSearch.org iv. Subsidize affordable units as part of the Affordable Housing Fund 3. For new multifamily developments pursuing Section 42 tax credits, City funding programs should be aligned to maximize the likelihood of tax credits being awarded. Coordinating these programs leverages City subsidy, making subsidy go further or reach deeper down the income spectrum. a. Coordinate HOME, CDBG, TIF, Affordable Housing Fund, and Project-based Voucher award timelines to ensure that projects have awards in place in time to apply for Section 42 tax credits in January* b. Coordinate HOME, CDBG, TIF, Affordable Housing Fund, and Project-based Voucher award criteria and processes so that projects that meet a common set of criteria in line with City and WHEDA priorities (access to transportation, schools,DRAFT grocery, walkability, not in a concentration of poverty) get funded by the City and therefore score higher on their tax credit applications* c. Annually release coordinated RFPs to drive development that achieves the priorities* d. Actively recruit developers to apply for Section 42 tax credits in the City of Madison* 4. Pursue demonstration projects to test the viability of alternative housing forms (Accessory Dwelling Units, Micro housing, Cottage Housing, Cooperative and Co-housing) a. Allow exceptions to existing funding programs and zoning rules to allow for demonstration projects b. Recruit and fund developers with experience constructing alternate forms of housing c. Recruit financial institutions to create portfolio loan products that would allow for housing types that might not conform with current lending rules

*Completed or in-process

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MARKET RATE RENTAL For market rate rental housing, the primary goal is to ensure that there is sufficient quantity and diversity of supply to meet the needs of a growing market. When possible, this housing should strive to meet broader goals of mixing incomes and uses to strengthen neighborhoods. To achieve these goals, this report identifies two main priorities:

1. As housing preferences change and rental housing becomes a larger portion of our housing market, it is more important than ever that there is open communication and information sharing between rental housing providers and municipal government. a. Create a quarterly Housing Data Report combining data on key market trends* i. Work with MG&E to improve their rental vacancy data (ex. reporting by Census tract) ii. Provide up-to-date City information on permits, development pipeline, year over year trends iii. Targeted towards policy makers, neighborhoods, developers to provide a common set of impartial data to inform decisions b. Increase representation by rental housing providers on city committees to foster greater communication and ensure that City policy is well informed of trends and concerns in the rental market i. Create dedicated seats in housing related committees (Community Development Authority, CDBG, Economic Development, Housing Strategy, and Tenant-Landlord) for rental housing providers 2. To meet the increased demand for rental housing and ensure that new supply serves a variety of incomes and household types, the City should create a Development Zone Initiative (Appendix A) to proactively encourage rental housing development in locations throughout the City that are suitably zoned, are well served by transportation infrastructure, and are in close proximity to amenities that renters demand. a. Identify areas throughout the City that are suitably zoned, are well served by transportation infrastructure, are in close proximity to amenities that renters demand, and are identified in other City plans as development priorities to designate as Development Zones* b. Create a TIF Strategy to target the creation of TIDs and use of TIF to Development Zones as well as identify priorities and opportunities c. Direct Affordable Housing Fund spending to Development Zones to support the creation of affordable housing and its integration into the broader redevelopment area d. Prioritize neighborhood planning and the creation of zoning overlay and urban design districts in Development Zones e. Create a Land Banking Fund to finance land banking and pre-development costs to prepare sites and reduce barriers to rental housing development (Appendix B) i. Structured as a joint City/private equity fund with commitments from lenders for low-interest loans ii. Administered by the City, Community Development Authority, or a non-profit iii. Set clear parametersDRAFT for acquisition targets and outcomes (Ex Require a portion of units be affordable, mixed-use, etc)

*Completed or in-process

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LOW-INCOME OWNERSHIP The overarching goal for the low-income ownership market is to increase the rate of success for low-income households that pursue homeownership. The first priority in achieving this goal is to ensure that these low-income homebuyers are ready for homeownership through enhanced homebuyer education. For low-income households that then choose to become homeowners, the goal must be to make ownership more affordable by reducing the size of their mortgage and giving them access to funds to maintain their home to make it safe and energy efficient.

1. For households interested in homeownership focus first on homebuyer education. The best way to increase a household’s chance of successful homeownership is to prepare them to budget for the unexpected costs and work that homeownership requires and to correct problems in their credit history to improve their financial standing. a. Fund and pair Individual Development Accounts with City matching funds to comprehensive homebuyer education i. Incentivizes households to participate in long-term education programs ii. Helps build a nest egg for downpayment or future home repairs b. Enhance partnerships with the Homebuyer Roundtable, Neighborhood Resource Teams, and hold homebuyer resource fairs in underserved neighborhoods to push homebuyer education to populations of color. 2. Simplify the City’s ownership program structure to three tracks with a single intake stream a. Use downpayment assistance programs as a tool to reduce mortgage size to increase affordability i. Consolidate existing downpayment programs (ADDI, Home-Buy) * 1. The goal of these programs is to provide stable housing for individual households 2. Reduce future housing cost burden and risk of foreclosure 3. Target low-income households with high likelihood of successful homeownership or particular housing need (disability, large family size) b. Use acquisition/rehab programs as a tool to stabilize and revitalize neighborhoods i. Consolidate existing acquisition rehab programs (HBA, Small-Cap TIF) * 1. Should be geographically targeted to neighborhoods with aging/blighted housing stock or land use issues (single-family homes used as multifamily rental, high turnover) 2. Allow moderate income households to participate (80-120% of AMI) to mix area incomes c. Use rehab programs as a tool to stabilize existing low-income homeowners in their housing i. Consolidate existing rehab programs (DPL, Installment, Green Madison) * 1. Target projects that makes houses safer and less expensive to operate 2. Goal of reducing housing cost burden and risk of foreclosure for existing owners 3. Allow condo associations to jointly apply for rehab funds DRAFTDownpayment New Low-income Assistance Program Owners

Geographically Targeted Acquisition/Rehab Homeowner Education New Low-Moderate Program Income Owners

Existing Low-income Rehab Program Owners

3. Expand revamped ownership programs a. Rebrand and market programs through advertising and outreach * b. Educate alders on programs to serve as a toolkit for improving their districts c. Dedicate a larger portion of City of Madison funds to subsidize low-income ownership programs *Completed or in-process

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MARKET RATE OWNERSHIP For market rate ownership housing, the primary goal is to ensure that there is sufficient quantity and diversity of supply to meet the demands of a growing population and allow a new generation of homebuyers to enter our market who have demonstrated a strong desire for housing in a location proximate to amenities and convenient transportation. When possible, efforts to provide this housing should strive to meet broader goals of strengthening neighborhoods by mixing incomes, improving aging housing stock, and adding neighborhood amenities. To achieve these goals, this report identifies two main priorities:

1. Create programs to make our existing reasonably priced neighborhoods more attractive to first-time and middle income homebuyers a. Identify and create a designation for Opportunity Neighborhoods that are based on factors such as:* i. Aging housing stock ii. Average property value below the City average iii. Flat or declining property values iv. Located outside of the city center v. Longer than average days on market b. Encourage the development of mixed-use nodes along transit corridors in Opportunity Neighborhoods to bring amenities (restaurants, retail, civic uses) to the neighborhood to increase its desirability i. Create new TIF districts to support development ii. May require rezoning and demolition of existing single family homes iii. Create a pilot neighborhood program to test strategies c. Create a “Residential Facade Grant Program” targeting houses on high traffic residential streets in Opportunity Neighborhoods based on the City’s successful Business Façade Grant Program i. Identify high priority corridors ii. Fund small matching grants or loans repaid by special assessment (~$5,000) to support exterior upgrades iii. Potentially funded by TIF d. Modify existing homeownership loan programs to drive first-time and middle income homebuyers into Opportunity Neighborhoods* i. Increase loan limits and/or reduce interest rates for homes located within Opportunity Neighborhoods ii. Raise income requirements to 120% of AMI within Opportunity Neighborhoods iii. Rebrand and market programs through advertising and outreach 2. Support the creation of new owner occupied housing developments in urban, walkable, and amenity rich neighborhoods through middle scale/density development priced between $200,000 and $300,000 a. Remove regulatory barriers in zoning, demolition, and subdivision rules restricting middle scale/density housing types (condominiums, town houses, small lots)* i. Create staff team toDRAFT identify code and process challenges ii. Research national models and best practices iii. Create a set of recommended code and process solutions b. Identify appropriate areas for middle scale development i. Target Neighborhoods ii. Target Sites c. Facilitate the development of new entry level owner occupied middle scale/density housing i. Recruit developers familiar with these product types ii. Encourage developers to create middle scale housing on parcels too small to support larger multifamily development or to transition from commercial development to single family neighborhoods iii. Support developments through TIF *Completed or in-process

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SENIOR HOUSING The overarching goal for the senior housing market is to provide an affordable housing option with the appropriate level of service for every stage of a senior’s life that is integrated into our community. Because the vast majority of seniors prefer to age in place, the first priority must be to provide the services and financing tools to allow seniors to stay in their homes as long as possible or to transition to dedicated senior housing development in their neighborhood. The priority must then be to attract and retain senior households by ensuring that future senior housing developments are located in areas with a strong connection to transportation and services as well as offering options for low and moderate-income seniors.

1. Increase the ability of senior households to age in place by making it affordable to stay in their homes and bringing services to them a. Identify existing concentrations of seniors (Naturally Occurring Retirement Communities) and direct relevant services to them i. Facilitate neighborhood association/non-profit/Madison Senior Center coalitions to deliver services ii. Reorient public transportation to enhance services to these areas iii. Improve infrastructure to meet accessibility needs (ex improved sidewalks) iv. Create youth employment/after-school programming to support aging place by matching youth with seniors in need of assistance with basic tasks related to homeownership (yard work, snow removal, etc) b. Consolidate and expand existing City financing programs for seniors to retrofit their homes for accessibility and afford the ongoing operating costs of homeownership i. Expand the City Reverse Mortgage Program to finance gas, electricity, and municipal services bills in addition to property taxes ii. Expand the City Reverse Mortgage Program to finance accessibility retrofit work iii. Create or contract with an independent advisory service to help homeowners select remodelers, draw up contracts, and check quality of work before making payments 2. For seniors that can no longer stay in their homes due to affordability, work to ensure the creation of affordable senior housing throughout the City to allow them to continue to age in place a. Create a parallel “senior housing track” in the Affordable Housing Fund RFP i. In the “Senior Track” replace a preference for 3-bedroom units with a preference for senior housing with a connection to healthcare and services ii. Geographic preference for neighborhoods without senior apartments b. Work with WHEDA to guide future Section 42 tax credit Qualified Allocation Plans to support the creation of affordable senior housing developments* 3. Position Madison as a destination for senior living to attract and retain senior households by addressing their demand for small, urban, walkable development. Encourage new senior housing development in transit and service rich locations in preparation of aging Baby-boomersDRAFT rather than on the City edge or isolated areas a. Identify preferred development areas in future comprehensive and neighborhood plans, and other funding processes to encourage development in superior locations b. Implement the Demographic Change Working Group recommendation to create a city-led pilot project combining senior housing, mixed-income housing, transit oriented development with a strong connection to services and healthcare on an infill site* i. Would likely require a City RFP process and possibly site acquisition ii. City participation through subsidy for the low-income component, onsite services, and transit

*Completed or in-process

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STUDENT HOUSING For the student housing market it is clear that for a variety of reasons, proximity to campus is a top demand driver for students and increasing the opportunities for students to live close to campus should be a primary goal. To achieve this goal, this report identifies two main priorities:

1. Provide options for all students who want to live near campus to have access to well maintained housing at a variety of price points a. Allow for the development of student focused rental housing at greater density to increase affordability and the number of units in prime locations close to campus i. Allow for the creation of smaller units (sub 200 sqft micro units) and greater density in areas around campus through modifications to the building code (minimum unit size) and zoning (lot area and open space requirements) ii. Remove regulatory barriers in zoning rules restricting the creation/redevelopment of buildings that utilize a shared common space/cooperative model b. Actively encourage the development of affordable rental housing for students from low-income households through the creation of public-private partnerships i. Partner with the University of Wisconsin Student Financial Aid Office to create screening criteria to identify students from low income households for referral to affordable units ii. Modify TIF policy to allow for use in student housing developments that reserve units for referred students from low-income households iii. Develop public–private partnerships that leverage City, University of Wisconsin, and UW Alumni Association resources to create affordable housing for students from low-income households

2. For neighborhoods located further from campus where the student rental market is softening, facilitate a transition of the housing to serve a wider variety of household types and incomes. Because of the deteriorated condition of the housing stock and difficult economics of converting rental housing to ownership, greater density, or subsidy are needed to bridge the gap. a. Identify areas that have a large number of buildings originally constructed as single family homes that have been converted to multi-unit and/or student rental housing and have a high incidence of Building Inspection violations b. Remove regulatory barriers in zoning, demolition, and subdivision rules restricting middle scale/density housing types (condominiums, town houses, small lots) i. Create staff team to identify code and process challenges ii. Research national models and best practices iii. Create a set of recommended code and process solutions iv. Allow project specificDRAFT rezoning for middle scale/density housing in the identified areas c. Create/amend TIF districts to support housing conversion and redevelopment in these areas i. Create new TIF districts to capture increment from new hi-rise student housing developments ii. Modify Small Cap TIF programs to allow for new construction of medium scale developments iii. Expand Small Cap TIF to encompass more of the identified areas

*Completed or in-process

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CITY OF WAUWATOSA, WISCONSIN HOUSING POLICY & ACTION PLAN