via email: [email protected] PLANNING ARCHITECTURE INTERIOR DESIGN May 12, 2010 Nancy Muller Florida Housing Finance Corporation 227 North Bronough Street, Suite 5000 Tallahassee, Florida 32301 RE: FORUM’S COMMENTS ON “FLORIDA HOUSING DISCUSSION POINTS FOR CONSIDERATION FOR THE 2011 UNIVERSAL APPLICATION CYCLE” Dear Nancy, I attended the First Rule Development Workshop as well as a CAHP sub-committee meeting on April 29th in Orlando, both of which I found to be very informative and interesting. The meetings certainly gave us a much better feel for the Universal Application process and the difficulties FHFC faces moving forward. FORUM is an established industry leader in multifamily housing design, and we have been actively designing multi-family projects for 24 years throughout the country, although we are primarily focused in Florida. More than half of our 320+ multifamily developments are affordable projects. We work closely with many of Florida’s affordable housing developers, contractors and local housing authorities and we can provide constructive comments to some of the Discussion Points from this position of experience that we hope you will find valuable and insightful. Please find the attached comments gathered from the experienced staff at FORUM presented, per your request, for your consideration in establishing criteria for the revised 2011 Universal Application and beyond. Should you have any questions about our comments, or should you like any additional input, we are happy to assist you in any way that we can. Please feel free to contact me and thank you for the opportunity to be a part of this process. Sincerely, FORUM ARCHITECTURE & INTERIOR DESIGN, INC. Karen V McIntyre Architect / Project Manager [email protected] cc James B. Black Andrew Roark C:\DOCUMENTS AND SETTINGS\KAREN\MY DOCUMENTS\FLORIDAHOUSINGDISCUSSIONPOINTS-050710-FORUMSCOMMENTS (4).DOCX FORUM ARCHITECTURE & INTERIOR DESIGN, INC. 745 Orienta Avenue, Suite 1121, Altamonte Springs, FL 32701 P(407) 830-1400, F(407) 830-4143, AA0002731 www.forumarchitecture.com Discussion Points for Consideration for the 2011 Universal Application Cycle Comment [F1]: We are concerned with the ramifications of mandating certain materials over As we prepare to consider changes to the state’s Qualified Allocation Plan, Consolidated Plan, Annual others without substantiation. Implementing construction standards separate from code Action Plan, applicable Rule Chapters and Universal Application Cycle documents, Florida Housing is requirements and market forces will result in a per working to develop a vision of what type of housing we should be financing in the current climate and project increase in construction costs. These coming years. This document provides a preliminary overview of our initial thoughts for public negative impacts vary regionally throughout the discussion. The public discussion of our vision and priorities will in turn provide guidance for state, for example: CMU exterior construction represents approximately 8-15% greater cost in the implementation details, to be discussed as the rule development process continues. Some discussion Orlando area compared to equivalent wood points may not be fully implemented in 2011, but are here to lay grounds for future consideration. construction, but the increase is smaller in South Florida and greater in North Florida. Traditional wood frame construction, built to Vision current codes and with a well designed exterior envelope, complies with the most stringent • requirements and offers superior impact resistance Florida Housing envisions that new construction developments that we finance should be located to concrete masonry. Current model energy codes in areas that have a high level need for affordable rental housing at the income levels being also favor wood-frame construction and have served by Florida Housing properties, particularly as specified by investor interest. shown diminished preference for mass walls. Wood frame apartments comprise 95% of the 144 • Florida Housing believes that the ideal new construction development is one that: affordable housing communities designed by Forum o Is built with strong construction materials, such as concrete, that enable the building to be in Florida over the past 15 years. Wood viable for many years; construction allows infinite opportunity for expression of aesthetics and local vernacular design. o Is certified as green and energy efficient to ensure that all green and energy aspects of the Efficiencies in concrete and masonry structures, in property are working synergistically to provide a higher quality, sustainable development comparison, are only achieved by strict adherence (both in terms of materials and operating costs) over time; to limiting modules and structural requirements. o Provides units that can be easily visited by persons with disabilities by incorporating Comment [F2]: We agree that construction features that allow these persons to come and go more easily; should continue trending towards green and energy efficient, but the standards should continue to o Is located near to mass transit, particularly rail transit that is and will be developed into emerge and be applied consistently to all the future; construction. We do not understand why FHFC o Is near services and jobs, promoting walkability when possible; would seek to push affordable housing into a o Provides some ELI units for persons with special needs who are receiving supportive completely separate realm of requirements than the Florida Building Code otherwise requires. Would it services and referred by a partnering supportive services agency; and not be more beneficial to lobby for such o Is developed and maintained by strong developers and management companies. improvements in the statewide codes and allow affordable housing to track along with them? • Florida Housing believes that additional financing should be targeted to preserve existing Certification requires substantial increases in the affordable rental properties that are at risk because of: design/soft costs of the development budget, but o Loss due to affordability restrictions ending; provides minimal benefit. The construction process currently includes a system of checks and balances o Loss as a result of deterioration (causing, for example, HUD to pull the project based that ensures the design plans and specifications are rental assistance and ‘decommission’ the property); or reviewed for conformance with applicable o Deterioration resulting in poor living conditions for tenants. requirements and that the construction adheres to the approved design plans. The design also includes energy code calculations. Certification is primarily a • In addition to the targets above, Florida Housing’s preservation priorities continue to be focused benefit to the third party entity, both for liability on ensuring that federal subsidies to support extremely low income residents (for instance, and as a revenue stream. through project based rental assistance) are saved and maintained over the long term. Comment [F3]: Focus on point scoring for systems and products that reduce tenant energy costs to allow developers to initially raise rents to help offset the expense of the upgrades discussed in Discussion Points for 2011 UAC Page 2 this document, with phased-in reduction in effective April 29, 2010 rents (via lower energy costs) for future tenants. Comment [F4]: All multifamily projects are • Additional preservation priorities include the following: currently required to comply with the Fair Housing Design Guidelines, which already set forth project accessibility requirements specifically targeting visitability by disabled persons in units designated as “covered” by the guidelines. o Properties financed are part of a local government’s broader priorities for such things as community revitalization or maintenance of affordable housing in a high income/service/job/amenity area; o The property currently serves tenants with special needs and/or those with extremely low incomes who have rents commensurate with their ability to pay (and will continue to do so after refinancing/rehab). • Florida Housing believes that, in addition to meeting one or more of the priorities above, the ideal preservation development is one that: o Was built with strong construction materials, such as concrete, that will enable the Comment [F5]: We feel it is inappropriate to building to be viable for many years; afford preferential status to concrete structures over wood frame. Many well-constructed wood o Is retrofit to include green/energy efficient systems/features appropriate for the particular projects are well-positioned for rehabilitation property to ensure that as many green and energy aspects of the property are working and/or renovation and are more feasibly upgraded synergistically to provide a higher quality, sustainable development (both in terms of with many green, energy efficient systems and materials and operating costs) over time; features. Concrete buildings are very costly to renovate, which weighs on the argument of long- o Provides units that can be easily visited by persons with disabilities by incorporating term sustainability. features that allow these persons to come and go more easily; o Is located near to mass transit, particularly rail transit that is and will be developed in the future; o Is near services and jobs, promoting walkability when possible; o Provides some ELI units for persons with special needs who