WHAT
IS PROPOSED
CLICK HERE
to download a
Word file containing a copy of the proposed Workforce Housing Ordinance
- On November 15, 2005 the
Miami-Dade County Commission adopted on first
reading a proposed ordinance. Final adoption will occur upon
approval after a second reading. As of mid-December 2005 it was not clear when that second
vote
will be taken.
- The proposed Ordinance would require developers of larger residential projects to make some of
their units "affordable" as a precondition to getting a building
permit.
- It would apply only to
unincorporated portions of the County.
- The term "affordable" is defined
to mean housing affordable for persons
earning less than approximately $63,000 per year.
- Various
incentives are offered to developers such as density bonuses.
- Developers would have
the option of "buying out" by paying a fee into a new County managed
"workforce housing trust fund".
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OUR SUGGESTIONS FOR IMPROVEMENT
The proposed Workforce Housing Ordinance is long
overdue.
Having said that, there are 4 areas that the Coalition would like the Commissioners to be aware of
that could improve the proposal:
1. THE
INCLUSIONARY HOUSING
POLICY NEEDS TO BE VIEWED AS A REGIONAL ISSUE AND SHOULD APPLY TOWARDS
ALL OF MIAMI-DADE, INCLUDING INCORPORATED
COMMUNITIES.
Having the policy apply only to unincorporated Miami-Dade will defeat
the regional goal of the Inclusionary Housing proposal. A
principle objective of the proposed policy is to promote the market
rate production of affordable, integrated housing and serve as a
vehicle for economic integration and poverty deconcentration.
Absent this, the Commission should consider engaging the League of
Cities and incorporated cities to assist in crafting corresponding
legislation.
2. THE TARGETED
INCOME GROUPS ARE TOO HIGH AND A SET-ASIDE FOR LOWER-INCOME GROUPS IS
NEEDED.
The proposal targets between 65% to 140% of AMI.
This seems
high and could actually be beyond the target group that it's designed
to help (starting salaries for teachers and police range between 35K to
40K). Targeting between 45% and 120% of AMI would serve a
better
population group that is truly housing burdened. Also, the
program requires that a between 20 and 30% of new units be earmarked as
affordable in new developments. To reach the population lower
than 65% of AMI, we should allow MDHA to be allowed to purchase a
certain percent of the affordable units.
For example,
Miami Dade Housing Agency (or MDHA approved non-profits) should, as is
the case in Montgomery County, MD., have first right of refusal for
purchasing say one-third of affordable set aside units with the
understanding they be rented or sold to low to very-low income
households. We should strive to have a policy that helps not
only
police officers and teachers, but also hospital orderlies, nursing home
workers, school janitors, and store clerks. This will have the effect
of "reaching" those at the lower income levels.
3. MAINTENANCE
OF AFFORDABILITY
To ensure that units are maintained as affordable and to lessen the
administrative burden, the County should consider mortgage restrictions
as well as deed restrictions to ensure maintenance of
affordability. Also see next bullet regarding resell
restrictions.
4. ADMINISTRATIVE
BURDEN
Finally, the proposal is extremely ambitious and with 37 pages of
rules, regulations and policies. We are concerned whether it would be
difficult for MDHA to administer this program easily and developers to
clearly understand it as well as abide by it. As a general
philosophy, we believe simple and direct policies work best in
practice. Also, there are areas of the proposal that seem
contradictory or are unclear.
- For instance on page 30; on
section D, 1-b
(Shared Equity Agreement Build-up. Does this mean that if
there
is no subsidy, there is no equity agreement?)
- On page 26, Workforce Housing Unit
sales price calculation was unclear.
These comments were drafted for
the Coalition by John Ise
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MIAMI-DADE COUNTY