City Staff Promoting On-Site Units through IHO

Based on information in the packets for the following two developments, City of Evanston staff is consistently advocating that developers include the full number of on-site units in new buildings. It looks like there may be one or two areas where we want to advocate for stricter adherence, but overall, they are moving in a very good direction!

3233-3249 Central St.

Reviewed at the Zoning Board of Appeals meeting on Tuesday, 2/20--will include write-up once available

The following is from the packet for the meeting:

Because the development proposes 10 or more dwelling units (14 dwelling units are proposed), the Inclusionary Housing Ordinance applies and the development must either provide one on-site affordable unit with rental rates affordable to a tenant at 60% of the area median income, or pay a one-time $75,000 fee-in-lieu of the on-site unit. If the affordable unit is provided on-site, development bonuses apply that increase the as-of-right total number of dwelling units to 11 and also reduce the parking requirement from 21 required spaces to 15 required spaces. The applicant currently proposes to pay the fee-in-lieu rather than provide one affordable unit on-site, and therefore is not eligible for the development bonuses. City staff and the DAPR Committee recommend approval of the development only if the affordable unit is provided on-site.

1727 Oak Ave.

Reviewed at the Design & Project Review meeting on Wednesday, 2/21--will include write-up once available

The following is from the packet for the meeting:

The proposal appears to be an alternative equivalent IHO proposal for the 169-unit project. In order to be in compliance with the IHO, it would need to provide 10% of the units as affordable onsite (17 units), or pay a fee in lieu of those units. However, the project is proposing to provide only six units onsite, four one bedroom units and two 2- bedroom units, and pay a fee in lieu of the remaining 11 required units. The Applicant met with the housing division on January 18, 2018 to discuss alternative equivalent proposals that provide all 17 units on-site to meet the IHO requirement rather than a mix of on-site units and fees in lieu. Given that the majority of the demand for affordable senior apartment units (age-restricted) is single occupancy, coupled with the current unit mix geared towards smaller units (approximately 70% 1-beds or smaller), the housing division suggested proposing the 17 affordable units as a mix of studio and 1-bed units. In order to make this financially feasible, the Applicant needs to set the AMI as follows: 1/4 at 50% AMI, 1/4 at 60% AMI, 1/4 at 80% AMI and 1/4 at 100% AMI. The Applicant is open to other options and previously offered 6 units on-site at 50% AMI and 60% AMI and fee-in-lieu for the remaining requirement, which strictly complies with the IHO. However, given feedback received, the Applicant believes that this proposal developed through discussion with the housing division better addresses the City's affordable housing desires and the intent of the IHO. 59.

The project is located in a TOD area, which means half of the affordable units have to be at 50% AMI and half have to be at 60% AMI. The developer proposes two one bedroom units and one two-bedroom unit at 50% AMI, and then two one bedroom, one two bedroom at 60% AMI. The developer also proposes to pay a fee-in-lieu of the remaining 11 units. Because this project is located in a TOD area, the fee per unit is $100,000. The developer is proposing to pay a $1.1 million fee. What is the reasoning why all required affordable units cannot be on- site rather than paying the fee-in-lieu? Staff has a strong preference for on-site affordable units. Since City Council must approve IHO alternative  equivalent proposals, the developer must demonstrate that it is financially infeasible to provide all 17 units onsite. Section 5-7-8 of the IHO allows for payment of a fee in lieu of building affordable units “as of right”. However, acknowledging the preference for on-site units, the Applicant has crafted a proposal that can accommodate onsite units rather than pay the fee in lieu.

Our Position: We would advocate that the 17 affordable units be split evenly between 50% AMI and 60% AMI.