HomeMy WebLinkAbout11-18-24 Public Comment - A. Hoitsma - Affordable Housing Ordinance requirements for Application 24-107_ Block 104_Bozeman YardsFrom:Amy Kelley Hoitsma
To:Bozeman Public Comment
Cc:Terry Cunningham; Joey Morrison; Jennifer Madgic; Douglas Fischer; Emma Bode
Subject:[EXTERNAL]Affordable Housing Ordinance requirements for Application 24-107: Block 104/Bozeman Yards
Date:Monday, November 18, 2024 7:38:28 PM
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I am directing these comments to the Economic Development Department, specifically BritFontenot and David Fine.
I am concerned that Application 24-107 (Block 104/Bozeman Yards) does not meet the
requirements of the Affordable Housing Ordinance (AHO). Specifically:
1. The ordinance states: “The number of affordable homes must meet or exceed theminimum standards needed to qualify for the applicable incentive.” This application does
meet the standard of offering greater than or equal to 5% of the units at affordable rates(defined by the AHO as a maximum of 120% AMI). It offers 4.76% of the units at exactly
120% AMI. I realize there is a clause in the AHO that states “if the calculation of the requirednumber of affordable homes results in a fraction of a home, fractions equal to or less than 0.5
shall be ignored.” However, I find that clause—and the predictable result of that loophole, asdemonstrated in this application—wholly against the spirit of the ordinance (i.e. “rounding
down” the standard in favor of the developer and not the home buyer needing affordability). Italso results in fewer affordable homes.
2. The ordinance has another requirement in order to qualify for incentives: “The mix ofbedrooms per unit in affordable homes must be as similar as possible to the mix ofbedrooms per unit of the market-rate homes in the development.” This application shows:
14 one-bedroom units (33%)
19 two-bedroom units (45%)7 three-bedroom units (17%)
2 four-bedroom units (5%)
The two affordable units being offered are both one-bedroom units (and both on the groundfloor of a five-story building that touts the views from the upper levels in the project
narrative). Clearly this is not a similar mix of bedrooms as is offered in the market-rate homes.Again, the applicant seeks to meet the absolute lowest standard required by the AHO, yet
actually fails to even meet that standard.
[As a side note: were the standard based on number of bedrooms rather than units, theapplicant would have to offer 4 bedrooms as affordable, and not 2. Perhaps that standard
should be considered in re-evaluating the AHO.]
To remedy this inadequacy, I think that the applicant should be offering (1) two-bedroom unit and (2) one-bedroom units at “affordable” rates. While I personally believe
the number of affordable units offered should be greater (and the % of AMI lower), I believethis remedy would at least meet the letter and spirit of the ordinance.
I need to add that I am aware that the applicant is not asking for the maximum of the “shallow
incentives” offered through the AHO (they seek 10’ of additional height and not the 30’ theycould claim). I am also aware that they could decide to reject the incentives altogether and
offer NO affordable units (although as far as I understand looking at the drawings they wouldhave to decrease the overall height of the building to meet the B2M zone requirements). All I
can say is that would be a shame and a lost opportunity to help make Bozeman a more livablecommunity.
With my best,
Amy Kelley Hoitsma
706 E. Peach Street, Bozeman
p.s. I will submit these comments as well to the Affordable Housing Ordinance discussion, as Ithink this project is a perfect example (though not as gross as others) of how the standards in
the ordinance need to be re-evaluated.
Amy Kelley Hoitsma
406-581-1513aok@mcn.net
aokworks.com