Proposed IHO Changes--What Joining Forces Thinks

The Inclusionary Housing Ordinance (IHO) Sub-Committee in Evanston has nearly finished its work and is going to be presenting its proposed changes to City Council for a vote in October. For the most part, Joining Forces members have felt that the proposed changes are excellent and will make the ordinance much more impactful. However, we do have a couple of concerns--areas where we feel more should be done. 

What We Appreciate
The following changes are ones that we feel will have a positive impact by creating more affordability at different levels:

• Inclusion of options for developers to provide units for people with extremely low incomes (30% of AMI) instead of just moderate- and middle-income households.
• Increase in the length of the affordability period from 25 to 30 years for rental units (see below for a concern).
• Making the ordinance applicable to developments containing 5 or more units across the board (not just in Transit-Oriented Development (TOD) areas).
• Applying the same incentives and bonuses to developers of affordable housing as to other developers.
• Using a creative and flexible formula for determining income-based eligibility for for-rent units--and one that includes an option for including affordability for households at 30% of the Area Median Income (AMI).
• Requiring developments that receive variances or allowances to make at least 5% of the units on-site (instead of allowing cash payments in lieu for all 10% of the required units).
• Increasing the fee in lieu for from $100,000 to $175,000 for developments in TOD areas and from $75,000 to $150,000 for non-TOD areas, and to 1.5 those amounts for condo developments (see below for how we'd like to see this go even further).
• Including a clause to review the fees in lieu every year based on the Consumer Price Index.
• Making the fees in lieu due earlier in the development process.
• Elimination of the “Reduction of Requirements” article.
• Renewability of the 99-year affordability period for affordable owner-occupied dwellings upon sale.
• The clarity of the incentives for developers to include on-site units.

Where We'd Like the City to Go Further
In addition to the changes above, we would like to see the following:

• For units that are for-sale, as opposed to for-rent, the proposed ordinance would price the affordable units for people at 120% of the AMI. We feel that the units should be priced for people at 80% if the AMI.
• While we are glad that the committee is proposing an increase, we'd like to see the amount of fees in lieu per unit to be even higher. Given that the cost of development is at least $300,000 per unit, it seems that the fees in lieu of on-site units should be even higher than the proposed $175,000 per unit (in a TOD area).
• We appreciate the increase in the length of the affordability period from 25 to 30 years for rental units, we think this is the minimum increase that should be considered. In addition, we would like to see staggered periods of affordability, particularly for large developments with more than 5 affordable units--for example, so that some would expire after 30 years, some after 35 years, and some after 40 years.
• Some of our members are concerned that the affordable units can have different interior appearances and finishes than the market rate units and can be smaller than market rate units. They do not want the difference in appearance or size to stigmatize the lower income tenants and want the quality to be equal to that of the market rate units. In general, we would prefer to have the affordable units be identical to the market rate units.

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Here is a link to the proposed changes--the first part of the packet is a summary, and the second part is the ordinance itself, with changes underscored.