HomeMy WebLinkAbout11-18-24 Public Comment - A. Hoitsma - Re-Evaluation of Affordable Housing OrdinanceFrom:Amy Kelley Hoitsma
To:Bozeman Public Comment
Subject:[EXTERNAL]Re-Evaluation of Affordable Housing Ordinance
Date:Monday, November 18, 2024 7:44:11 PM
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I submitted these comments to the Economic Development Department regarding Application 24-107 (Block
104/Bozeman Yards) but I feel they are absolutely relevant to the conversation regarding how the Affordable
Housing Ordinance should be rescinded or re-written.
[I originally directed these comments to Brit Fontenot 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 the minimum 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 required number 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, as demonstrated 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). It also results in fewer affordable homes.
2. The ordinance has another requirement in order to qualify for incentives: “The mix of bedrooms per unit in
affordable homes must be as similar as possible to the mix of bedrooms 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 ground floor 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, the applicant 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 believe this 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’ they could 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 would have 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 livable
community.
With my best,
Amy Kelley Hoitsma
706 E. Peach Street, Bozeman