Chair Murphy explained that Commissioner Scott previously emailed his comments to the Commissioners about the Affordable Housing Plan (AHP) document (A copy is available at Ivins City office), and she acknowledged her thanks for the thorough job that he did.
Commissioner Scott read each comment and explained his reasoning for each change. Overall it's a good plan for what the document is. The mission of the preparer of the plan is to help the poor and underprivileged. It is a great goal but when someone is preparing a plan it's a good idea to keep in mind what their inherent bias is and that it is not an independent consultant preparing a plan. Although this was prepared for Ivins to help us, his understanding is it's Ivins' plan so we need to be careful. Some of the comments and recommendations are:
1. Front Cover: Change date from 2012-2013
2. Page 3 - Executive Summary - Paragraph 4:
AHP states: "households earning less than a moderate income do not have sufficient opportunity to purchase or rent affordable housing to...."
Recommendation: using "may not" instead of "do not"
AHP states: "Providing housing choice and opportunities to serve all segments of the population is important for the welfare of the entire community."
Recommends modified General Plan statement: "Encourage a variety of housing types in attractive, functional neighborhoods, to meet the needs of all income levels is important." Using the terminology "provide" puts more responsibility on Ivins to ensure that below moderate income housing is provided, etc. It was suggested to use language such as "encourage" or "allow" which does not bind Ivins financially, etc.
AHP states: "taking action to expand housing opportunities for this segment of the population is suggested."
Recommendation: "continuing to zone sufficient land zoned for both for-sale and rental housing, a variety of lot sizes, a variety of residential building types, reasonable Land Use ordinances, and a reasonable level of bureaucracy (cost and time) are important elements in maximizing housing affordability."
3. Page 3 - Executive Summary - Paragraph 5:
There was some concern that the AHP statements would obligate Ivins financially but felt Ivins should embrace other programs to help provide housing.
Bullet 1: Change to read: "Continue to zone sufficient land zoned for both for-sale and rental housing, a variety of lot sizes, a variety of residential building types, reasonable Land Use ordinances, and a reasonable level of bureaucracy (time and cost) are important elements in maximizing housing affordability."
Bullet 2: Change to read: "Embrace programs such as: USDA Rural Development loan and Mutual self Help programs."
4. Page 4 - Introduction - Paragraph 2:
It was felt that para 2 was impossible to commit to and wasn't sure the City could make that happen.
Recommendation: "The intent of this affordable housing plan is to ensure that we continue to zone sufficient land zoned for both for-sale and rental housing, a variety of lot sizes, a variety of residential building types, reasonable Land Use ordinances, and reasonable level of bureaucracy (time and cost). These actions will help to meet the needs of both current and future households, including moderate income households."
5. Analysis of population and growth:
Paragraph 1: The revised population projection seems to be close to the growth the City is currently experiencing. The projection is 107. 4 for new households each year. In 2012 there were 90+ permits issued.
Paragraph 2: AHP states: "In addition, the existing housing stock will have to be maintained and in some cases rehabilitated, in order for the units to be safe, decent places to live."
Recommendation: Eliminate the statement. It's obvious that people need to maintain their homes and Ivins continues to address any property that has deteriorated. A statement will be written in place of Paragraph 2.
Para 3: AHP states: "that 52% of the current population is at/below moderate income and therefore 52% of future growth will be the same."
Moderate Income according to HUD makes between 81% and 95% of the area's median income. AHP states that moderate income is 81% of median income. There may be a definitional problem with the AHP statement. AHP state that 52% of the population is at or below moderate income which implies that Ivins has a large number of people within this group. We have just the number we expect when doing the calculations and he would like to clarify it because it's just normal. There could be people at or below the moderate income level but that doesn't guarantee that they cannot afford housing because they may have some other assets such as retirees on a pension or 401K and their housing cost maybe minimal. When we look at Ivins' total housing stock, AHP is asking if there i enough housing units affordable at different income levels.
Recommendation: "Households that earn a moderate income or less currently make up 52% of the Ivins population, which is close to the approximate 50% that would normally be expected. If 52% of the new households projected for the next ten years are also moderate income or less, that would indicate an increase of 559 moderate/low income households over ten years, or 56 housing units a year. Based on the Housing Estimating Software, 10 of those units each year would be rental units. Depending on their finances, some of these households may require housing priced below median costs. Some of these units may be provided by the movement and changes in the existing housing stock over time. Other units may come from the wide variety of housing types and lot sizes Ivins has created. And other units may come from organizations utilizing tax credits, vouchers, and other federal government programs."
Paragraph 4: eliminate the paragraph and merge the data into the paragraph above.
Commissioner Loris noted that the document states the majority of the housing stock is younger than 1990. Will the homes built in 1990 depreciate enough to become affordable housing?
Commissioner Scott explained that it would not happen by itself and "depreciate" is not the correct term. All housing in the long run will appreciate because of inflation and will appreciate at a slower rate than new construction. That's sort of a continuum down the age scale. Housing built in the 60's, 70's, and 80's will all appreciate at a similar rate. Properties in the last ten years appreciate faster. He gave some examples. The concept by itself is not a solution to creating housing that's affordable to low income households. It's to help low income households.
Commissioner Loris stated that we are suggesting and encouraging not solving the problem but allowing a way for them to plan to come in, create affordable housing over time or build new to get the affordable housing.
Commissioner Scott gave an example such as Seattle that Ivins could create an office of housing, staffed with employees, have a bond levy every 5-7 years to collect funds to create affordable housing. He didn't think that is the immediate direction for Ivins. Ivins cannot make it happen but we can encourage it by making the development process fast, simple and predictable. It takes some risk from the developer if there is a variety of land available. If all Ivins had is large homes on large lots, we would not be encouraging affordability. Ivins has several building lot sizes, etc.
6. Page 6 - Analysis of income
AHP states: "moderate income is 80% of paragraph median income"
Recommendation: the HUD definition of "81-95%"
AHP states: "households that earn just 30% of the area median income find it very difficult to live within the affordable housing guidelines since they cannot afford average market rentals rates."
Recommendation: "Households that earn 30% or less of area median income cannot typically find affordable housing opportunities within the private market and need to rely on organizations that take advantage of federal programs like tax credits, housing vouchers, etc."
AHP states: "It is vital to the well-being of the community that households of all income levels have housing options."
Recommend as per General Plan: "Allowing for a variety of housing types in attractive, functional neighborhoods, to encourage the needs of all income levels is important."
Commissioner Benson asked if people take advantage of federal programs, vouchers etc.
Dale Coulam advised that Color Country Community Housing has and they just recently submitted an application for a tax credit. They were denied but they can try again. They have received some grants, etc. through their self-help programs.
7. Page 6 - Housing stock - housing occupancy and vacancy
AHS references the American Community Survey (ACS) to determine housing occupancy rates.
Commissioner Scott advised that this is a mail survey that surveys only about 2% of all housing units which may distort results in Ivins because of the higher number of seasonal residents here than in many other parts of the country.
Recommendation: "The American Community Survey collects information mostly by mail and for only approximately 2% of the households nationwide." These two factors make it less than ideal for use in a community like ours so we use this information sparingly.
Commissioner Scott explained that there are better sources available but they are using the best source they can based on the cost. Ivins is not willing or able to pay for a lot more. We are too small of a community to go into that depth.
Chair Murphy advised that the AHP numbers are not that far off from Washington County but there are 2,500 primary and 500 non-primary homes. However, they are not vacant as stated in the document. Vacant refers to homes for sale and these homes are not.
Recommendation: using "secondary homes"
Recommendation: under "Multi-family Housing" strike "However, Color Country Community Housing is currently working with Ivins City to construct a 36-unit low income multi-family housing project."
Chair Murphy commented that realtor.com is not a good or complete source. The Multiple Listing Service (MLS) is a better source. As per MLS there are 67 active listings from $98,000 - $2.7 million. Utah is a non disclosure state for the sell price but listing prices can be researched. Currently, the sale price is approximately 95% of the listing price. She will work on an analysis.
8. Page 7-8- age of housing stock
Chair Murphy will research the numbers on this table since we don't know where the source came from.
9. Page 8 condition of housing stock
AHP states: "6 homes are either severely deteriorated or dilapidated...."
Recommendation: delete the second paragraph and add language on how Ivins handles deteriorating homes
AHP states: "6 homes (0.24%) are either severely deteriorated or dilapidated, which is a slightly lower percentage than other cities in Washington County."
Recommendation: Delete "a slightly"
10. Page 10 - Analysis of housing affordability of home ownership
AHP states: "fifty two percent of all households in Ivins City are moderate income households or below, a significant portion of the population."
Recommendation: "Fifty-two percent of all households in Ivins City are moderate income households or below. According to the Washington County Assessor, 47% of the housing stock is affordable for moderate income earning households. There are also rental units in Ivins that are likely affordable to moderate income households.
New paragraph: "Of the homes currently for sale, 40% are affordable to moderate income households or lower (29% are affordable for moderate income households, 10% are affordable for households earning 50% of median income, and 1% are affordable for those earning 30% of median income.)"
11. Page 11 - Affordability of rent
Par 1 line 4: AHP states: "Households earning a moderate income (80% of AMI) are able to afford median rental rates in Ivins City, however, those households earning 50% of AMI and less cannot."
Recommends changing the paragraph starting on Line 2 to: "It is reasonable to look at overall rental affordability by comparing median rents to incomes at 80% of median. In Ivins households earning 80% of median incomes are able to afford the median cost to rent a two-bedroom apartment is $786. The median cost of apartments in Ivins is likely less than $786 due to the inclusion of studios and one-bedroom units. As a result, overall rental affordability in Ivins appears to be reasonable. However, households earning 50% or less of median income generally have fewer rental housing opportunities."
Paragraph 2 Line 2: AHP states: "Median rent rates should not be expected to be affordable for households at/below 50% of median.
Recommendation: delete sentence 2
Recommendation: Change sentence 3 to "There are few rental housing options in Ivins for households at or below 50% of area median income.
Paragraph 3: AHP states "......that they cannot afford."
Recommends changing sentence 1 to: "The chart indicates that many renter households are paying more than 30% of their income for housing. Although this does not mean they are all suffering any hardship as a result, it suggests we pay attention to this trend.
Paragraph 4:
Sentence 1: Add: "As would be expected, rental options......."
Sentence 2: Change "they cannot afford" to "some may not be able to afford."
Sentence 3: AHP says ".....the demand is much higher..."
Recommendation: Eliminate Sentence 3.
12. Page 12 Special needs housing
Paragraph 2: Add to the last sentence: "and the attraction Ivins has for retirees."
Paragraph 3: AHP states: "Many of the elderly who own their homes are living on fixed incomes..."
Commissioner Scott asked if Ivins provides any assistance to low income seniors or are we willing to provide any of these services?
Dale Coulam explained that low income seniors are referred to Five Counties. They have a process on how to winterize the homes etc. but the city does not have any of those programs. The City has some reduction of utilities for active military.
Chair Murphy advised that the county has Circuit Breaker and Indigent for Taxes that lowers the property taxes.
Recommendation: "Some options are available through other state and county agencies.
13. Page 13 - survey of residential zoning
Line 6: Delete: "However, the deficiency in affordable housing options for households earning less than 50% AMI and the high percentage of (67%) of individuals that are paying more than 30% of their income to rent indicate that some zoning regulations may be creating a barrier to develop sufficient affordable housing for this segment of the population."
Line 10: Is it is our goal to increase the amount of multi-family land beyond what we have already identified?
Dale Coulam did not think it is because we have had the opportunity to make changes to the Zoning Map and we wait for development to come in and request changes beyond that. In regards to the last two sentences, he was not concerned about the first sentence that "Multi-family dwellings of 3 or more units are listed as a conditional use within multiple residential (R-M) zones and prohibited in all other areas of the city." That's a fair statement but suggested striking the last sentence.
14. Page 14 - Gaps and Needs
Rewrite the title and the first paragraph and delete the paragraphs referring to "Need."
Gap 1: AHP states: "Many of the very low and extremely low income earning households do not have sufficient opportunity to purchase affordable housing."
Recommendation: "Very low and extremely low income earning households typically do not have the opportunity to purchase affordable housing."
Gap 2: AHP states: "Many of the very low and extremely low income earning households do not have sufficient opportunity to rent affordable housing."
Recommendation: "Many low income households in Ivins are paying more than 30% of their income for rent. This is expected, due to the general inability of the private market to produce such housing without federal assistance. Ivins has been, and will continue to be responsive to developers and organizations that can find additional resources to make such housing opportunities available."
15. Page 15 - Benchmarks
AHP states: "The goals, objectives, and strategies should be evaluated on an annual basis to determine if the goals have been met. If the strategies are not achieving the listed goals, the strategies should be amended."
Commissioner Scott indicated that this statement potentially boxes Ivins into a corner. He was concerned about this statement and it would reflect how he looks at the goals.
Dale Coulam indicated he would check the statute but we may be required to evaluate and review it on an annual basis but not necessarily have to go through, redo and update the document.
6. Page 14 & 15 - Goals
Chair Murphy stated that Goal 1 should be rewritten.
Commissioner Anderson asked why are we making this the City's goal?
Dale Coulam explained that the City is required to have a moderate income housing plan. The state scores the City's plan. The City's current plan is vague and receives a lower score. Higher scores may help get grants and protects us legally since a plan is required in the General Plan. The goal may not be as stated here but we've talked about encouraging, embracing and allowing these types of activities to occur and that we view them favorably without committing us to actually changing the zone. We are actively and embracing the programs such as Color Country and we have participated in their tax credit attempt and with people on attempts to get grants with Color Country on a CDBG grant. He suggested using language such as "continue" to support such program, but to say the City will actually increase the number of units or specific number is beyond our control.
Commissioners Anderson referred to Goal 1 that states, "Increase Opportunities to Purchase Affordable Housing......." Ivins cannot increase opportunities to purchase affordable housing. Some cities have a housing authority and hire people but Ivins City does not do that. We don't want to discourage it but we can encourage and allow it. However, we can't tell people what to do.
Dale Coulam suggested having a goal to increase the amount of affordable housing in the City by continuing to embrace the programs. If there was one more Color Country project, it would increase the affordable housing in the community. Goal 2 is to rent. Those goals could be combined by saying the City will increase the opportunities for affordable housing whether it be purchase or rent. Depending on how the market goes, it maybe to purchase or to rent.
Commissioner Anderson felt that the City has to be careful. If affordable housing is not done right and in the right situation and area, it decreases other people's values. People agree to build in the area based on the Land Use Plan and zoning, if there's a change it decreases the value. He agrees there is a need but we need to be careful.
Goal 1 - Objective: Change from "Actively encourage" to "Continue to encourage"
Strategy 1: Change from "Promote programs" to "Embrace programs"
Goal 2 - Objective: Change from "Actively encourage" to "Continue to encourage"
Commissioners Scott will clarify and submit the recommended changes at the next meeting.