If adopted, the proposed tiebreaker will increase the production of low-income units.

It will leverage California’s scarce resources.

It will help the industry raise additional resources for housing Californians.

It will shift competitive responsibility from local agencies to developers.


If adopted, the 9% competition will hone the industry’s skill set.

Developers will find ways to increase units, reduce costs, and maximize debt and equity.

The proposed tiebreaker clearly communicates the goal, “Provide more homes!”

It affords developers many tools to achieve this goal: zoning, design, financing, etc.

It emboldens developers to solicit efficiency from investors, contractors, local agencies, etc.

It motivates all project participants to make prudent decisions “at the margin.”

It will foster innovation that will produce more units in both the 9% and 4% programs.


The proposal creates a competitive environment with a level playing field.

It requires no changes to set-asides, housing type goals, or points.

It requires less policing and is therefore harder for bad actors to circumvent.

It is easily adjustable as individual modules can be tweaked to incent behavior.

It is easily expanded or contracted to address emerging policy issues.

It produces an honest starting point, wherefrom returning credits could be incentivized.


The proposed methodology is intuitive, logical, explainable, and defensible.

It results in a meaningful expression of return on investment: “units produced per million credits.”

It shows the media, the public, and legislators that our industry is willing to sharpen its pencil.