HomeMy WebLinkAbout09-23-25 Public Comment - L. Jay - Comments on City Commission Meeting Today 9_23_2025 Consultant Presentation on WARDFrom:Lorre Jay
To:Bozeman Public Comment
Subject:[EXTERNAL]Comments on City Commission Meeting Today 9_23_2025 Consultant Presentation on WARD
Date:Tuesday, September 23, 2025 8:54:59 AM
Attachments:Public Comment 09_23_2025.pdf
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Please see my comments in the attached.
Lorre Jay
To: Mayor Cunningham, Deputy Mayor Morrison, City Commissioners Magic, Bode, and
Fischer
From: Lorre Jay, Bozeman resident
Date: 9/23/2025
Re: Economic and Planning Systems Analysis Presentation of the Feasibility of the
A:ordability Requirements of the Water Adequacy for Residential Development
(WARD) Ballot Initiative, 9/23/2025
The following are my comments on the presentation prepared by Economic and Planning
Systems Analysis (the “Consultant”) of the Feasibility of WARD. There appear to be several
flaws and faulty assumptions that make the conclusions invalid.
Incorrect Assumptions or Statements that Contradict City Information
On Slide 2, bullet 2, the Consultant states that one of the eVects of the WARD ballot initiative
is that development needs to purchase water rights if they do not meet aVordability
requirements. Development is a choice based on many factors. According to the City, 99%
of development purchases water rights through the City. By using this entry point, the City
gets to direct housing that is needed to meet the needs of the community, rather than
housing that is not aVordable. If 99% of development purchases water from the City, then
this is not a salient point.
On Slide 2, bullet 4, the Consultant states that the supply of housing in Bozeman will likely
not keep up with the demand. This is a misstatement. The unaVordable housing surplus in
Bozeman is oVered at price points that are not aVordable based on Bozeman incomes.
There is a surplus of market-rate/luxury housing in Bozeman, as reflected in the 22%
vacancy rate for housing built after 2020 (Sterling CRE Advisors, Q1 2025 Market Update)
with average rents of $2300. This is evidence of a very unhealthy market for investors. This
may result in a building moratorium as investors tend to flee when vacancies get to this level.
Bozeman’s first-time home buyers decreased to 24% this year from 32% last year. This is
the lowest it has been since 1981, when NAR started collecting the data. 55% of Bozeman
rents and 45% of renters are in the 60% of AMI category or less. “Given that Hotels &
Restaurants is the fastest-growing job sector in Gallatin County, it is expected that the first
wage quartile (the lowest 25 percent of earners) would see substantial growth… with annual
wages at or below approximately $52,000, equivalent to $25 per hour.” (Bozeman 2024 Q2
Economic and Market Update, p. 11, latest available).
However, even with that potential surplus of unaVordable housing, there is insuVicient
housing at price points that are aVordable to the majority of the renters in Bozeman. A recent
23-year national study, including Bozeman, indicates that there is a housing surplus but that
price points are too high to meet the needs of the community, creating a mismatch between
housing supply and Bozeman incomes and aVordability.
The City stated earlier this year that there is a shortage of about 6,000 homes for households
earning at or below the 60% of AMI level. To satisfy this demand over a 10-year horizon, the
City would need to allocate 50% to 60% of development to aVordable housing. This is not
something the City has proven they are able to do under the current aVordable housing
strategy.
There is a disconnect between what is being built and what is required to meet the needs of
the Bozeman Community. Therefore, it is not that supply will not keep up with demand, but
that the supply is too expensive for the Bozeman Community to aVord. Therefore, increasing
the supply of market-rate housing will never satisfy the demand for aVordable housing as the
gap between the two is too great.
On slide 2, bullet 5, the Consultant states that due to the laws of supply and demand, the
cost of existing housing may also increase, reducing aVordability for everyone. This is not
true. The costs of housing have increased due to the upzoning strategy that the city has
undertaken. Upzoning increases land costs as more income can be earned on an upzoned
property that holds more units.
Bozeman development is producing housing price points for rent that are so high that the
prices will never decline to aVordable levels. Although the Bozeman Chronicle recently
stated that rent concessions were deepening for development to get vacant apartments
rented, these rents will return to their normal levels next year as investors won’t tolerate
reduced cash flows for very long.
Problems with the assumptions used in the Pro Forma Analysis
Conflation of Sales Price and Costs:
On slide 4, the Consultant states that the Cost to build a SFD (Single Family Detached home)
is $783,815. However, on slide 6, the Consultant states that the sales price is $783,815 per
SFD. It seems that the Consultant has conflated costs with sales price.
Land Cost Assumption is Well in Excess of Existing and New Development
In the SFD analysis, the Consultant indicates that land costs are $150,000/per SFD home.
This results in a net loss for the 33% set aside example of -$747,975 versus a $2,351,445
profit in the baseline case. For 30 homes assumed in the analysis, the land cost would $4.5
million. However, recent transactions for land annexed into the City and developed into
housing sold for much lower costs.
For example, BuValo Run, a 20-acre parcel, sold for $2.25 million. If you assume a small lot
size of 5,000 square feet per SFD home (similar to Blackwood Groves), then you could put a
total of 174 SFD on this property, which would be $2.25 mln /174 = $12,931 land cost per
SFD home. This is a 91% reduction in land cost as compared to the $150,000 per SFD in the
Consultant’s analysis.
Another more current example of land costs is the property for sale on 19th Street across from
Graf Street. This is a 6.8-acre lot with an asking price of $6.155 mln. If we assume that 10%
of the lot is not buildable, then that would mean a land cost of 8.7 SFD per acre or 53 SFD
total (8.7 SFD per acre x 6.1 acres = 53 SFD, which would be $6.155 mln / 53 = $116,000 land
cost per SFD, a reduction of 23% as compared to the Consultant’s assumption. I note that
this property has been on the market 139 days, so it may overpriced.
The listing for this property on Realtor.com:
https://www.realtor.com/realestateandhomes-detail/19th-Ave-S_Bozeman_MT_59718_M97710-93862?from=srp-list-card
In reality, to address the land cost issue, many developers build a mix of housing, which may
include SFD and multi-unit buildings similar to Gran Cielo or BuValo Run. That would reduce
the land cost per unit even more.
The Multifamily Analysis is Flawed and Does Not Reflect the Bozeman Market.
The multifamily pro forma analysis starting on page 7 shows a net loss for the Baseline case
(without the WARD initiative) of -$6,133,846. If that were truly reflective of the Bozeman
market, then no development would occur here, as no developer is going to build if losses
are guaranteed. Bozeman has at least 3,200 units in review or under construction as of July
2025 in Bozeman, according to various realtor reports. It is unlikely that such a pipeline
would exist if these projects were producing losses, as developers are quick to respond to
negative changes in market economics.