HomeMy WebLinkAbout08-20-24 Public Comment - N. Nakamura - AHO work sessionFrom:Natsuki Nakamura
To:Bozeman Public Comment
Subject:[EXTERNAL]AHO work session
Date:Monday, August 19, 2024 4:16:55 PM
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Dear Commission,
Regarding the Affordable Housing Ordinance work session, I ask you to consider:
1. Putting a pause on all new applications wishing to use any of the Shallow or DeepIncentives.Countless hours and energy of City staff, Commissioners, and residents went into
thinking about the Guthrie, and the result is 0 affordable units. It is important we avoid arepeat of a situation like the Guthrie. We should also seriously question the efficacy of
the shallow incentives. City Staff has cited a 10% vacancy rate in Bozeman, a hugejump from 1.5% vacancy in 2022. So we are either no longer in a housing crisis or we
are incentivizing the wrong kind of housing. (I would argue the latter.) More supply ofunaffordable housing will not get us closer to meeting our housing needs. Even when
we had the tool of inclusionary zoning, developers opted for the cash-in-lieu option overbuilding the housing needed in our community. Please do not let more projects wishing
to capitalize on the affordable housing incentives to enter the pipeline that are notbringing us affordable housing. The PDZ process still exists for applicants wishing to
request variances in exchange for a public benefit.
2. Repealing the Affordable Housing Deep Incentives immediately, entirely, andpermanently.
I appreciate the time and thought City Staff has put into drafting recommendations andthe discussion at the different advisory boards. However, tweaks to the incentives are
not sufficient. There is still an underlying assumption that less parking and more densitycan successfully incentivize for-profit developers to provide affordable housing. Fully
removing any parking requirement for developers shifts the cost of parking andtransportation completely to the residents, especially if we don’t have adequate funding
for the infrastructure needed for public transit and bikeability. Focusing only on theincentives of more density and less parking also does not acknowledge the implicit
forces currently present that the City has control over that incentivize developers to fullydemolish existing buildings and housing. The cost to demolish existing affordable
housing should be appropriately expensive, so that people are incentivized towards infillor adaptive reuse instead of putting existing housing in the dump.
3. Having a deep and thorough conversation about how to better get affordable housingin conjunction with the UDC update.A thoughtful update to the UDC can capture the variances between neighborhoods and
encourage beneficial density in areas that have the infrastructure to support it. A properUDC update will provide predictability to both residents and developers. Developers
have expressed time and time again that predictability reduces their development costs;promoting incentives for developers when the underlying UDC could change does not
promote predictability. Also, we must consider what we can successfully negotiate
through incentives. If the UDC update gifts density by-right across the board, we willhave less ability to use extra density to negotiate for affordable housing or even cash-in-
lieu of affordability. If parking requirements are reduced - ideally to successfully bettermatch the actual need for parking in different areas - we cannot hope to negotiate for
affordable housing with reduced parking requirements. Density, zoning, parking,incentives, etc all need to be considered together with the UDC update and in
structuring successful incentives. It would be a shame to spend so many hours craftingand improving incentives that will soon become ineffective.
Thank you for recognizing that the Affordable Housing Incentives need to be reevaluated and
for prioritizing this discussion. I hope you all will consider repealing the Affordable HousingIncentives until better and more effective ones can be developed alongside the UDC update.
Thank you for your time and consideration,
Natsuki Nakamura