HomeMy WebLinkAboutSubmittal-Truly Burton-Letter RE Affordable Workforce HousingBASF
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City Je4rk
111 NW 183ra Street, Suite 111, Miami Gardens, FL 33169 H Telephone: 305-556-6300 Fax: 954-639-7107
January 9, 2019
Honorable Chairman Ken Russell
and City Commissioners
City of Miami
3500 Pan American Drive
Miami FL 33133
Via e-mail and hand delivered
Re: Affordable/Workforce Housing items on January 10, 2019 City Commission Agenda.
Dear Mr. Chairman and City Commissioners:
I write today on behalf of the Builders Association of South Florida's (BASF) City of Miami Working
Group, including builders and attorneys actively working in the City of Miami. They have expressed
concerns about four items on the January 10, 2019 Agenda which all relate to affordable and workforce
housing. They include:
1. DI.3 (Discussion Item 3) — regarding use of City vs. County Average Median Income (AMI) for
benchmark project rents.
2. FR.1 (File No. 5194) — regarding enforcement provisions in workforce housing covenants
3. FL.1 (File No. 5118) — regarding significant changes to Miami 21 Special Area Plan requirements,
commitments, and incentives
4. F. L. 5310 — proposing changes to Attainable / Mixed -Income Housing Program
While our members share the City's goal of building more workforce/attainable housing, their concerns relate
to the following:
There are several proposals under discussion simultaneously. And with very little backup information or
analysis. Thus, they are very unclear how all these proposals — while well-intentioned - could inter -relate and
impact one another. Even worse, adopting these proposals could potentially have the opposite result of the
intended purpose —resulting in less affordable and workforce housing units made available in the City of Miami.
BASF members seek more clarification to these provisions, including any technical and economic basis for
the proposed changes, to understand how they would work, as the Commission intends them to, from an
economic standpoint, so that financing these projects can continue uninterrupted.
Particularly, from internal discussion among BASF builder members, who have significant
experience building projects in the City of Miami, the use of City AMI would make future
affordable and workforce housing projects unfinanceable. City AMI is too low for any available
existing financing programs.
While well-intentioned, this provision, if adopted, would have the opposite affect the City is looking for: it
would reduce or stop future the construction of affordably priced housing developments, because it would
5115 Cbe no longer be hnancilallyfeasible to build them. I�
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Chairman Ken Russell record f ite (s) 1 F L • Z
And City Commissioners on City Clerk
Page Two
January 9, 2019
This is too important to rush forward with incremental proposals that lack appropriate analysis. The effect
of this uncertainty, and lack of understanding about the meaning and implications of the concepts included
in the four Agenda items, can be best resolved with a serious, in-depth discussion among all interested
groups and with the expertise of City staff, builders and consultants active in the industry. Members also
have identified some recommendations and possible solutions to this complex issue, which could include:
• Retaining key incentives and improving the existing process to continue the construction of more
units, with incentives which are grounded in practical application with tested, positive outcomes.
• A rational percentage range of housing, for various income levels
• Operational or marketing focus aimed toward City residents
• Facilitating supply-side innovations by removing artificial regulatory barriers and incentivizing
purpose-built housing
• Other ideas that may come about after having these conversations
To get to the right solutions for this complex issue, and to ensure that all programmatic provisions
work in unison, BASF is respectfully requesting a Commission Workshop with all interested
members of the public, to have the necessary, in-depth discussion about proposed solutions to
this issue.
On behalf of the BASF, thank you for the opportunity to present their views and look forward to
continuing their partnership with the City to meet our common goals.
Sin ely,
yB
Executive ice Preside t
And Government Affairs Director
cc: City Manager Gonzalez
BASF City of Miami Working Group
Carolina Herrera, President
Jose M. Gonzalez, Incoming President
Ben Solomon, Board Chairman.
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All opinions stated above are solely those of the Builders Association of South Florida and do not express or reflect any individual or
corporate positions of any individual BASF member.