Other Concerns

To Be Addressed

Below you will find a list of concerns stakeholders have raised but I have not had time to fully address.

  1. Permanent supportive housing projects forego conventional debt by providing supportive services, thereby increasing their need for credits, putting them at a disadvantage. (Consider a denominator decrease based on the net present value of committed services)
  2. Prevailing wages increase costs, thereby disadvantaging projects with these requirements. (While statistically significant, a policy decision needs to be made about whether the added cost should be borne by tax credits or the source imposing the requirement)
  3. High resource areas increase the impact for families, warranting an advantage. (Consider a numerator multiplier for projects with more than 2 bedrooms per unit)
  4. Local agencies will no longer be able to "vote with their dollars." (Take note that public funds can be added and credits removed to increase a project's score)
  5. Non-At-Risk rehab projects have lower costs, need less credits, and get an advantage. (Consider a numerator multiplier between 60% and 100% based on comparative rent benefit to new construction projects)
  6. Sustainability improvements are good for the environment but bad for one’s score. (Consider not doing them unless they can be offset with supportable debt)
  7. Financial support from local agencies indicates the project provides added public benefit. (Consider providing a small multiplier in the numerator if a sizeable investment is made, but this could exacerbate the disadvantage for jurisdiction with less funds)
  8. Financial support from other state agencies indicates the project provides added public benefit. (Consider a multiplier in the numerator for sizeable investments)
  9. Some local agencies don't have the resources to help finance affordable housing in their jurisdiction and remain at a disadvantage. (Consider an adjuster or set-aside for jurisdictions that haven't had a deal in a long time)
  10. Developers will cut costs to the bare bones causing a race to the bottom. (Set state standards if you fear local building standards aren't adequate)
  11. Developers will propose projects that are not financially feasible or are overly risky. (Make it clear that TCAC will issue negative points for not producing as promised)
  12. Developments in Los Angeles and San Francisco won't be motivated by the tiebreaker. (Ask these Cities to adopt similar methodologies in their selection processes)
  13. Developers will chose to develop in cities with lower design standards or cities that provide more concessions. (Agreed, cities will be able to incentivize development in their jurisdiction by offering concessions liked higher density, waived fees, or reduced requirements; money won't be the only way to support a project)
  14. Measuring return on investment will heighten competition. (Competition is good for the consumer and good for business in the long run)
  15. Designing a system with multiple adjusters will involve a dozen tough policy decisions. (Agreed, we better get started)
  16. Organizations like mine cannot be as competitive because of XYZ. (Propose an adjuster or ask for a set-aside)