This report reviews the current Below Market Rate (BMR) Housing Program, which is contained in Sunnyvale Municipal Code Chapter 19.66, titled "Affordable Housing and Single Room Occupancies." Several changes to the BMR Program are recommended to increase the supply of affordable housing and to more effectively meet the City’s Goals and Policies in the General Plan Housing and Community Revitalization Sub-element.

Recommended revisions include:

• Increasing the required percentage of BMR units from 10% to 15%;
• Lowering the exempt units from 9 or fewer to 6 or fewer;
• Adding condominium conversions to the types of residential development required to dedicate units;
• Extending the deed restriction for purchase units from 20 years to 55 years;
• Extending the deed restriction for rental units from 20 years to in perpetuity;
• Revising the priority categories for future program participants;
• Lowering the income limits that qualify for rental units from 80% of median income or less to 70% of median income or less and for purchase units from 80% - 130% to 70% - 120%;
• Instituting an indexing method to annually adjust the sales price of new purchase units and to maintain the resale affordability of purchase units already in the Program; and,
• Revising the rental increase method from the percentage increase in median income to the percentage increase in market rent or 5%, whichever is less.

Staff will also be revising the Program administrative procedures to improve the City’s ability to monitor and enforce program compliance. The revised ordinance and procedures will replace the requirements in Legislative Policies 2.3.3 and 2.3.7 (in Attachment 9). Staff recommends repeal of these policies.

In 1980, Sunnyvale adopted an Affordable Housing Ordinance, which can be found in Chapter 19.66 of the Sunnyvale Municipal Code. The Ordinance established the requirements of the BMR Housing Program. At the 2001 Study Issues workshop, City Council directed Staff to explore options for affordable housing for teachers and City employees including a comprehensive review of the BMR Housing Program. More specifically, City Council requested that the review cover the availability of housing units, eligibility and housing preferences and the types of housing development offered in the Program. This was to be a two-year study to be brought to City Council in two phases for the 2002 calendar year.

Since it was adopted in 1980, the Affordable Housing regulations have undergone five amendments. In 1982, they were amended to allow smaller interior units and to specify minimum room size standards. Following a study to evaluate the impacts of instituting an in-lieu fee option for smaller developments, the regulations were amended in 1989 to allow the fee for developments of less than twenty units with City Council approval. In 1991, the State Bonus Density Law was codified into the BMR regulations. In 1992, several changes were made as follows: a waiver was added for multi-family projects of fifty or more units that were not able to use the density bonus; BMR units were to be constructed concurrently with market-rate units, they were to be dispersed throughout the development and they were to have a similar number of bedrooms and exterior design; and, the sale and resale procedures were revised. Lastly, the BMR regulations were amended in 1994 to allow the Community Development Director authority to waive the requirement to provide BMR units in exchange for the in-lieu fee.

Following two study sessions each with the Planning Commission and the Housing and Human Services Commission, the report was presented on September 23, 2002 at the Planning Commission Hearing and on September 25, 2002 at the Housing and Human Services Commission Hearing. The Housing and Human Services Commission concurred with Staff recommendations. The Planning Commission recommended several modifications to Staff recommendations which are noted in the discussion of Recommended Revisions to the Ordinance, beginning on Page 7 of this report.

General Plan Goals, Policies and Actions related to this issue are listed below.

Goal C2: Ensure ownership and rental housing options in terms of style, size and density that are appropriate and contribute positively to the surrounding area.

Action C2.1.1 Ensure consistency with the City’s Housing and Community Revitalization Sub-element.

Policy C2.2 Encourage the development of ownership housing to maintain a majority of housing in the City for ownership choice.

Goal A: Foster the expansion of the housing supply to provide greater opportunities for current and future residents given environmental, social, fiscal and land use constraints.

Goal B: Move toward a local balance of jobs and housing.

Goal D: Maintain diversity in tenure, type, size, location and cost-of-housing to permit a range of individual choice for all current residents and those expected to become city residents.

Goal E: Maintain and increase housing units affordable to households of all income levels and ages.

Goal I: Ensure compatibility of Federal, State, regional and countywide housing programs with local policies and needs.

The Consolidated Plan, which is required by U.S. Department of Housing and Urban Development (HUD), establishes priorities, strategies and objectives designed to correspond with adopted goals from the Housing and Community Revitalization Sub-element. The following Consolidated Plan Objectives support the Housing Sub-element Goals and Policies listed above:

These Objectives are identified as high priority in the Consolidated Plan.

Existing BMR Regulations

In addition to the above goals and policies, applicable requirements in the existing BMR regulations are:

• 10% of units are dedicated to the BMR Program for residential developments of 10 or more units in all zones with the exception of R-0, R-1, R-1.5, R-1.7/PD;
• A deed restriction of 20 years for both purchase and rental units;
• Household income limits of low to moderate for purchase units;
• Use of the percentage change in median income to increase rents; and,
• Use of 100% of the Bay Area CPI as the index in the calculation for the resale price of purchase units.

As of the year 2000, the ratio of jobs to housing units in Sunnyvale was 2.37. There were 124,450 jobs (ABAG Projections 2002) and 72,756 employed residents (U.S. Census 2000), or 1.71 jobs per employed resident. Even if all employed residents living in Sunnyvale also worked in the City, nearly 42% of the people employed in Sunnyvale in 2000 would not live in the City. This large percentage and the high jobs-to-housing ratio are indicative of a housing shortage in Sunnyvale that has resulted in a dramatic increase in the cost of housing.

The 2002 median income for a family of four in Silicon Valley reported by HUD is $96,000. Attachment 4 contains a table showing average incomes in the Bay Area for a variety of occupations published in a June 2002 report by the Nonprofit Housing Association of Northern California. Of the occupations included in the table, childcare workers make the lowest annual salary at $20,000 and registered nurses make the highest annual salary at $63,800. These salaries range from 20.8% to 66.5% of Silicon Valley median income. According to HUD income-limit definitions, all of the salaries listed in the table are considered to be low income (80% or less of median income). Half of the salaries listed are considered to be very low-income (50% or less of median income).

The BMR Program is one of the primary programs in Sunnyvale to address affordable housing. Currently, there are 180 BMR purchase units and a total of 632 affordable rental units, some of which are part of the BMR Program and some that are part of other affordable housing programs. There are currently 279 people waiting to purchase a BMR unit. Please note that this figure does not include the number of people waiting for a BMR rental unit because the waiting lists for rental units are kept and managed by the apartment property managers. To meet today’s demand for BMR purchase units, Sunnyvale would need a 34.4% increase in the supply of units. When the BMR Program was first implemented, the development community expressed concerns of difficulty complying. A density bonus was added to the Program to address their concerns. Based on the level of development activity since the inception of the Program, it should be noted that the BMR requirements have not deterred residential development in the community.

The Housing and Community Revitalization Sub-element establishes affordable housing goals, which the City is required to meet by State law. These goals include reduction of the jobs/housing ratio and provision of a variety of housing types at a range of prices. As part of the housing element law, the State of California has adopted a process for determining each local jurisdiction’s fair share of regional housing needs. Each city’s regional fair share is projected based on job growth and household growth for that city. The Association for Bay Area Governments (ABAG) has determined Sunnyvale’s regional share through 2006 to be an annual average of 511 units, 146 of which are needed for low and very-low income households (Housing Sub-element, p. 36).

Staff considered several factors when developing recommended revisions to the BMR Program:

• The Housing Sub-element requirement for supply of affordable housing;
• The jobs/housing ratio in Sunnyvale;
• The potential impact on housing development given cost constraints and land availability;
• Appropriateness of the income levels for current qualifying households;
• Demand for BMR units and wait list backlog;
• Maintenance of the affordability of existing purchase and rental units;
• Prior experiences administering the program; and,
• How Sunnyvale’s program compares to programs in other comparable (in terms of location, population and/or economy) California jurisdictions.

Attachment 1 contains a complete listing of the recommended revisions alongside existing requirements. As previously noted, the revisions address the percentage of units required; the number of exempt units; the types of residential development included; term limits for deed restrictions; the in-lieu fee calculation; target household income levels; priority categories for households wishing to be assigned a BMR unit; purchase unit indexing for annual sales price adjustment and resale price; and, rent calculation and increase methods.

Please note that there are two items listed in Attachment 1 that are still under review. The first item considers adding penalty fees for program non-compliance. The additional fees would address issues such as administrative compliance and violation of deed restrictions. Staff is reviewing the possibility of imposing these fees. The second item considers the continuing study of the inclusion of single-family residential Zoning Districts to the types of residential development required in the BMR Program. This item is addressed in more depth as part of the discussion on the recommended revisions below.

The BMR Programs of the other comparable California jurisdictions surveyed served as the benchmark for some of the recommendations, particularly for specific numbers such as the percentage of required units. Attachment 2 shows a comparison of the BMR Programs of other jurisdictions surveyed. In addition to information gathered for development of Staff recommendations, suggestions made during the September 5^th Joint Study Session with the Planning Commission and the Housing and Human Services Commission have been considered and in some cases incorporated into the recommendations.

RECOMMENDED REVISIONS TO THE ORDINANCE

Staff is recommending that the percentage of units required to be dedicated as BMR units be increased from 10% to 15%. As shown in Attachment 2, 15% is comparable to the percentage requirements in several other surveyed jurisdictions. In addition, the potential benefit of the increased number of affordable units that could be added is illustrated in Attachment 3. For fiscal year 2000, for example, 13 new purchase units would have been added as compared to the 9 purchase units that were actually added with the existing requirement of 10%, and 62 rental units would have been added as compared to the 41 rental units that were actually added.

Planning Commission Recommendation: Increase the required percentage of BMR units to 12.5%.

Housing Commission Recommendation: Adopt Staff recommendation.

Staff is recommending that the number of exempt units be decreased from developments of less than 10 units to those of less than 7 units to complement the recommended 15% of required units. Staff previously evaluated an exemption of less than 5 units based on the size of many recent housing developments that have been proposed. There is a concern that the opportunity to increase the number of BMR units may be lost if the majority of new housing developments have less than 5 units. In addition, 15% x 5 units would still yield one BMR unit since the BMR code requires that any fraction of a unit equal to 0.5 or more be rounded up to one unit.

During the September 5^th Joint Study Session with the Planning Commission and the Housing and Human Services Commission, a suggestion was made to exempt development of less than 7 units since 15% x 7 units = 1. The recommendation of less than 7 units meets the intended goal of capturing units in smaller housing developments while avoiding potential administrative complications associated with having to round up or down for a fraction of a unit. With this recommendation, Staff recommends monitoring the size of future developments to assess whether a lower number of exempt units is appropriate.

Planning Commission Recommendation: Keep the existing requirement for exempt units at 9 units or fewer.

Housing Commission Recommendation: Adopt Staff recommendation.

The purpose of the in-lieu fee is to offer an alternative to housing developers of smaller projects (less than 20 units) to provide BMR units. The existing code requirements state that developments of not less than 10 and not more than 19 units or parcels may elect to pay an in-lieu fee. Staff is recommending that this be changed to "not less than 7 and not more than 19 units or parcels" for consistency with the recommended number of exempt units. Developments under seven (7) units would be exempt from all BMR requirements.

The in-lieu fee was also reviewed to determine whether the formula should be changed. The fee should provide ample incentive for developers of smaller projects to provide BMR units while offering them an alternative should they choose not to do so.

The existing formula for purchase units multiplies the number of BMR units that would have been provided by the difference between the Fair Market Value and the BMR Price of the unit (the formula is shown in Attachment 1). The existing formula for rental units capitalizes the difference between the Market Rent and the BMR Rent over the current 20-year deed restriction period, using 100% of the Bay Area CPI as the index. Staff is recommending that the existing in-lieu fee formulae for both purchase and rental units remain the same, with the exception that the fee calculation for rental units would be capitalized over 99 years rather than 20 years. This change would make the in-lieu fee calculation for rental units consistent with the recommended rental unit deed restriction of "in perpetuity."

Planning Commission Recommendation: Keep the existing requirement for the in-lieu fee to maintain consistency with exempt units of 9 or fewer, and allow capitalization of the rental in-lieu fee over 99 years.

Housing Commission Recommendation: Adopt Staff recommendation.

Staff is recommending that a preference system based on points be developed to establish the priority assigned to applicants of the BMR Program. The existing priority categories are broadly defined as: 1) persons who live or work in Sunnyvale, and 2) persons who do not live or work in Sunnyvale. A point system would more specifically establish priority to improve the administration of the wait list.

Staff is also recommending that the priority categories be defined in the code, but that the specifics of the point system be defined in the administrative policy guidelines for the program. The priority categories are as follows: school employees in the four school districts serving Sunnyvale, public employees in Sunnyvale, other employees in Sunnyvale and residents in Sunnyvale. Please note that these categories are not necessarily in priority order, as that will be established in the point system.

Planning Commission Recommendation: Allow development of a point system to establish the priority assignment of BMR units, and establish categories based on professions rather than employers.

Housing Commission Recommendation: Adopt Staff recommendation.

Staff is recommending that condominium conversions be added to the existing required residential developments subject to BMR dedication. Given the limited opportunity for high-density residential development in Sunnyvale, this change will offer another much needed opportunity to add more BMR units.

Inclusion of the single-family Zoning Districts, R-0, R-1, R-1.5 and R-1.7/PD, which are currently excluded in the existing regulations is still under review. Staff initially recommended inclusion of these Zoning Districts. However, it was determined during the Joint Study Session that further study is needed to evaluate the impact of issues such as higher land prices for the larger lot sizes in single-family Zoning Districts. Staff recommends that this item be addressed as a separate study issue so that a more thorough evaluation can be done. In addition, Staff will look at an incentive program to encourage BMR units in single family Zoning Districts.

Staff also evaluated Assisted Living Units and determined that the services provided with these units do not sufficiently fit the model for the BMR Program. These developments are subject to Use Permits, and a case by case analysis can be done to determine whether any of the units should be reserved for moderate or low-income persons.

In response to a suggestion made during the informational meeting held on August 22^nd, Staff is also proposing that possible modifications to the residential development standards be studied to better enable use of the density bonus currently offered in the BMR Program.

Please note that mobile homes are not exempt from the requirements; they are regarded as affordable housing. It is not likely that new mobile home parks would be developed. However, Staff recommends that the MH Zoning District be included in the review of the Single Family Zoning Districts.

Planning Commission Recommendation: Adopt Staff recommendation.

Housing Commission Recommendation: Adopt Staff recommendation.

The 20-year deed restrictions of 14 BMR purchase units and 295 affordable rental units will expire by the year 2006 (see Attachment 3). Staff is recommending that the term limit for purchase units be increased from 20 years to 55 years, and that the term limit for rental units be increased from 20 years to "in perpetuity." This modification would not affect existing BMR owner or rental properties. The new limit for rental units will ensure that BMR units remain in the program, thereby increasing the supply of affordable rental units over time. These term limits are similar to those adopted in several local cities with BMR programs.

In the Joint Study Session, it was suggested that purchase units remain in the BMR Program "in perpetuity." Staff has reviewed the suggestion, but has decided to recommend a term limit of 55 years so that future generations of families who remain in the unit for the term of the deed restriction have an opportunity to improve their economic status and benefit by the full appreciation in the value of their home. This fulfills one of the primary goals of affordable housing, which is to allow an opportunity for lower-income families to improve their economic status.

These revisions would apply to both new units and units that are resold prior to the expiration of the existing deed restrictions.

Planning Commission Recommendation: Adopt Staff recommendation.

Housing Commission Recommendation: Adopt Staff recommendation.

The current calculation of rent targets households at 77% of median income and uses 25% of gross income as the percentage of income dedicated for housing cost. Staff is recommending that 65% of median income be used to improve affordability for low-income households and that the HUD guideline of 30% of gross income be used as the percentage of income dedicated for housing cost. This change will better serve lower-income households by lowering the percentage of median income upon which the rent is based. A comparison of the resulting rent when the existing and recommended rent calculations are used is shown in Attachment 5.

Planning Commission Recommendation: Adopt Staff recommendation.

Housing Commission Recommendation: Adopt Staff recommendation.

Staff is recommending that the lesser of 5% or the percentage increase of the average market rent as published in the semi-annual Sunnyvale Vacancy and Rent Survey be used as the basis for rent increases. Percentage increase in median income has historically been used, but this has resulted in rent increases that have outpaced wage increases of the lower-income households that occupy BMR rental units. A comparison of the existing and recommended rent increase methods is shown in Attachment 5.

This revision would apply to all existing rental units as well as future BMR units.

Planning Commission Recommendation: Adopt Staff recommendation, but add a requirement to evaluate the rent when a tenant moves out of a unit.

Housing Commission Recommendation: Adopt Staff recommendation.

Staff initially recommended that the formula used to calculate the original sales price of a new BMR purchase unit remain the same, but that the qualifying household income range be lowered from 80% - 130% of median income to 70% - 100% of area median income. The current formula uses a multiplier of 1.78 (number of employed residents per household) and the household income range to establish the sales price.

The Planning Commission is recommending that the qualifying income limits for purchase units be 70% - 120% of area median income, and that the formula for sales price reflect the mortgage amounts that households at these income limits can afford. Staff concurs with these recommendations. Attachment 6 shows the modified sales price ranges based on the recommended income limits, and a total monthly housing cost equal to 28% of gross monthly income. Please note that other monthly housing costs, namely property taxes, property insurance, mortgage insurance and homeowners association dues, are estimated to be 11% of gross monthly income. To maintain the 28% housing cost limit, the mortgage payment must be limited to 17% of gross monthly income.

Once the sales price range has been established, a specific sales price within the range is determined by using the RSMeans Residential Cost Data index, which is published annually by the RSMeans Company, Inc. for the construction industry. This indexes construction costs for developments of varying sizes and for a wide variety of amenities. Applicable costs are used to adjust the sales price of a new BMR unit based on construction quality.

Planning Commission Recommendation: Set qualifying income limits for purchase units at 70% - 120% of area median income, and establish a sales price formula that reflects affordability at these income limits.

Housing Commission Recommendation: Adopt modified Staff recommendation.

The existing regulations have no provision for annually adjusting the sales price of BMR purchase units. City Council previously requested that this provision be included as part of the overall Ordinance revision. Staff is recommending that the sales price be indexed using 1/3 of the Bay Area Consumer Price Index (CPI) for housing. HUD has recommended using this index in the HOME Program for first-time homebuyers. The index is recommended for geographic regions that experience significant volatility in the real estate market, similar to Sunnyvale.

Other indices such as percentage change in median income and 50% of the Construction Industry Research Board Index (CIRB) were studied. The resulting percentage increases in the sales price of purchase units would not sufficiently control the long-term affordability of the units. Staff compared annual percentage increases from 1997 through 2002 for three indices: 1) median income; 2) 1/3 of the Bay Area CPI; and, 3) 50% of the CIRB (see Attachment 7). Application of 1/3 of the Bay Area CPI yields the least volatile results of the three indices, and will therefore better ensure that sale prices remain affordable to qualifying households.

With respect to resale price, Staff is recommending that the formula remain the same, but that 1/3 of the Bay Area CPI be used in place of 100% of the Bay Area CPI to maintain affordability. The resale price formula is shown in Attachment 1.

This revision would apply to new homes and resale homes with deed restrictions specifying these requirements.

Planning Commission Recommendation: Adopt Staff recommendation.

Housing Commission Recommendation: Adopt Staff recommendation.

This study issue is exempt from CEQA per Article 5, Section 15061(b)(3) where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment.

There is no fiscal impact to the General Fund.

Public contact for the Planning Commission, Housing and Human Services Commission and City Council hearings was made through an advertisement in The Sun, posting on the City’s official notice bulletin board and posting of the agenda and report on the City’s web page.

An initial presentation of the project and its status were presented to the Housing and Human Services Commission on June 26th. A subsequent informational meeting for interested parties (housing developers, apartment managers and the general public) was held on August 22^nd. Invitations were mailed to a list of 27 housing developers, and a meeting notice was published in the Sunnyvale newspaper, The Sun. 10 people attended the meeting.

Staff presented the proposed revisions to the current BMR Program. Members of the housing development community expressed a general concern regarding the impact on profitability. One member of the rental property management community expressed concern with increasing the deed restriction of rental units to "in perpetuity" due to the risk of having to support vacant units when qualified renters are not available. Participants made suggestions to modify the development standards to create incentives in addition to the density bonus, and to allow replacement BMR rental units when new tenants cannot be found for recently vacated designated units.

Following the informational meeting, a Joint Study Session with the Planning Commission and the Housing and Human Services Commission was held on September 5^th. One member of the public who had previously corresponded with Staff via e-mail (discussed below) attended this meeting to reiterate her concern with the percentage rent increase currently allowed for BMR units. Members of both Commissions commented on the proposed recommendations and offered several suggestions as follows:

• Require that the number of exempt units be 6 or fewer;
• Reconsider a prior proposal to require that a fee be paid for small developments of less than 75% density due to a concern that this would deter development;
• Further evaluate the practicality for the inclusion of single-family residential Zoning Districts due to a concern with the higher cost of land for larger lot sizes in single-family residential zones;
• Consider using an index other than 1/3 of the Bay Area CPI, such as 2/3 of the Bay Area CPI, in the resale price formula to avoid resale prices that are less than the sale price of new BMR units and to offer occupants of purchase units higher return on investment; and,
• Require that BMR purchase units remain in the Program in perpetuity rather than 55 years.

Staff incorporated the first three items into the recommendations that were later made at the September 23^rd Planning Commission Hearing and the September 25^th Housing and Human Services Commission Hearing. Following a Staff review of the fourth item, it was determined that it would not be beneficial to the Program to have the resale price of older units be equivalent to the sales price of new units. Having different priced units should allow a broader range of the benefit population to be served. In addition, using the national standard of 1/3 of the CPI established by HUD and used in other housing programs will facilitate the administrative processes associated with resale of purchase units. Staff also considered the fifth item, which was discussed in detail under "Term Limits of Deed Restrictions" in the "Recommended Revisions" section of this report.

As previously noted, on September 23, 2002, the Planning Commission considered this study issue and made recommendations to City Council. Those recommendations are listed in the Alternatives section of this report.

Following the Planning Commission Hearing, this study issue was presented at the September 25^th Housing and Human Services Commission Hearing. The Commission concurred with all Staff recommendations. A comparison of Staff, Planning Commission and Housing and Human Services Commission recommendations is shown in Attachment 13.

Two e-mails were received from citizens commenting on the proposed changes to the BMR Program. Both messages are included in Attachment 8. The first message is from a current occupant of a BMR rental unit expressing concern about the rent increase with her lease renewal, and asking for information on how the proposed changes will affect her current situation and future rent increases. The second message is from a member of the development community who attended the 8/22 informational meeting. The message questions the purpose of the BMR Program and expresses a concern regarding the restriction of rents and sales prices based on income rather than allowing market forces to determine prices.

Three letters that discuss the concerns of the development community were submitted to the Planning Commission prior to the September 23^rd hearing. These letters are also included in Attachment 8.

1. Continue to study the following:

1. The practicality of including single-family residential and mobile home Zoning Districts in the BMR Program; and,
2. Modification of residential development standards to support the density bonus currently offered in the BMR Program.

2. Approve the following revisions to the Below Market Rate Housing Program and adopt the changes in the Affordable Housing Ordinance (SMC Chapter 19.66):

1. Increase the required percentage of BMR units to 15%;
2. Lower the exempt units to 6 or fewer;
3. Add condominium conversions to the types of residential development required to dedicate units;
4. Revise the in-lieu fee to be consistent with exempt units of 6 or fewer and rental unit deed restriction of in perpetuity;
5. Extend the deed restriction for purchase units to 55 years;
6. Extend the deed restriction for rental units to in perpetuity;
7. List priority categories for program participants based on a point system;
8. Lower the income limits that qualify for rental units to 70% of area median income or less and for purchase units to 70% - 120%, and revise the new home sales price formula to reflect affordability;
9. Institute an indexing method to annually adjust the sales price of new units and resale units; and,
10. Revise rent increase method to the lesser of 5% or the percentage increase in market rent in Sunnyvale.

3. Repeal Legislative Policies 2.3.3 and 2.3.7.
   
4. Per Planning Commission recommendations, approve recommended revisions c, e, f, h and i in Alternative 2 above, and modify recommended revisions a, b, d, g and j as follows:

1. Increase the required percentage of BMR units to 12.5%;
2. Keep the existing requirement for exempt units at 9 or fewer;

4. Keep the in-lieu fee for purchase units the same to be consistent with 9 units or fewer exempt;

7. Allow development of a point system to establish the priority assignment of BMR units, and establish categories based on professions rather than employers;

10. Approve rent increases of 5% or the percentage increase in market rent in Sunnyvale, whichever is less; however, evaluate rent when tenants move out.

5. Approve the recommendations in Alternative 2 with modifications.
   
6. Approve the recommendations in Alternative 3 with modifications.
   
7. Do not approve revisions to the Below Market Rate Housing Program.

Staff recommends Alternative 1, the introduction of an ordinance for Alternative 2, and Alternative 3.

Prepared by: 
Christine Cannizzo
Project Planner

Reviewed by:
Trudi Ryan
Planning Officer 

Annabel Yurutucu
Housing Officer

Robert E. Paternoster
Director, Community Development Department

Approved by:
Robert S. LaSala
City Manager