Recommendation Concerning Local Government Verification of Contribution-Loan Form for Florida Housing Finance Corporation RFA 2017-108 - Tonya Gant, Neighborhood & Human Services Department Director
That the Board take the following action concerning the Application for Local Government Verification of Contribution-Loan Form for Florida Housing Finance Corporation (FHFC) RFA 2017-108:
A. Accept the Application submitted for Avery Commons, to be located at 6080 Hilburn Road;
B. Accept the ranking committee recommendations, noted in Exhibit IV; and
C. Authorize the County Administrator to sign the Local Government Verification of Contribution Loan Form, committing $37,500, for Avery Commons for FHFC RFA 2017-108 State Apartment Incentive Loan (SAIL) Financing of Affordable Multifamily Housing Developments to be used in conjunction with tax exempt bonds and non-competitive housing credits;
OR
D. Reject the Application submitted for Avery Commons.
[Funding: Fund 120/SHIP and/or Fund 124/Affordable Housing] |
On August 31, 2017, Florida Housing Finance Corporation (FHFC) opened its competitive Request For Applications (RFA) 2017-108 State Apartment Incentive Loan (SAIL) Financing of Affordable Multifamily Housing Developments to be Used in Conjunction with Tax Exempt Bonds and Non-Competitive Housing Credits. The development must set aside 20% of the units to tenants at or below 50% area median income (AMI) ($21,700 for a one person household) or 40% of the units to tenants at or below 60% AMI ($26,040 for a one person household), per IRS code. Additionally, the FHFC application requires elderly non-assisted living facility applications to set aside at least 80% of the development to households at or below 60% AMI.
As part of the tax credit application process, developers must secure a “Local Government Certification of Contribution Form” (Exhibit I) from each local government which secures a minimum contribution of $37,500 in order to receive maximum points during the scoring process. The BCC directed staff to come up with a process to review any multifamily applications applying for FHFC funding that would require the local Government Contribution form, which was approved by the BCC on May 4, 2017 (See Exhibit II for minutes). Escambia County made its application for the FHFC RFAs requiring a Local Government Contribution form available on its website on August 15, 2017 (before the FHFC RFAs were released) (Click Here)
Under this new process, one application was received by Escambia County for RFA 2017-108 as follows:
| DEVELOPMENT NAME |
LOCATION |
DEVELOPER |
# OF UNITS |
TYPE |
DISTRICT |
| Avery Commons |
6080 Hilburn Rd. |
Blue Hillburn, Ltd. |
96 |
Elderly |
3 |
The scoring committee had concerns regarding the development meeting the "Community Outreach" threshold. The developer was provided with contact information for all owners within 2500 feet of the proposed development on August 17, but the only community outreach evidence provided at initial application was multiple advertisements in the Pensacola News Journal regarding a community meeting, which was held on September 1 and attended by the developer and County staff (See . However, since the application called for developers to "provide evidence of notification via flyers, emails, mailouts, and/or advertising to property owners within 2500 feet of the proposed development," the committee determined that the development did meet minimum threshold requirements and proceeded to scoring the development.
A complete copy of the development application is attached as Exhibit III. The application scored an average of 80.5 points from committee members, which exceeds the 80 points minimum requirement as approved by the Board. A summary of the scoring and ranking for the Board's consideration is attached as Exhibit IV, with ranking committee score sheets. A printout of the property description as provided by the Escambia County Property Appraiser's site is included as Exhibit V.
This recommendation was brought to the Board for consideration at the September 21, 2017 meeting. Due to the Board's concern regarding community outreach, the Board voted to pull the item at that meeting and reconsider for the October 5, 2017 BCC meeting (Exhibit VI). For consideration at the October 5 meeting, the developer was instructed to hold a community meeting with direct mailing notification to all property owners within 2500 feet of the proposed project as was original BCC direction for these applications. An email was sent from the Neighborhood Enterprise Division (NED) to the developer on September 22, 2017 confirming this request (Exhibit VII). Due to the timing of submission of this recommendation in order to be placed on the October 5, 2017 BCC agenda, backup regarding the new community outreach will be submitted under separate cover. Additionally, due to the timing, the review committee will not rescore the application since the minimum scoring requirement has already been met.
If the Board authorizes the County Administrator to sign the form committing $37,500 for a proposed development, there is no guarantee of a development being selected for financing in Escambia County since the FHFC application process utilizes a lottery system to determine awards. Given the amount of funding available from FHFC, it is anticipated that only two or three projects will be selected in the Medium County Category statewide. The applications were originally due to FHFC by October 5, 2017, but FHFC extended the deadline to October 12. FHFC awards selection should be known by early spring 2018.
FHFC mandates income set asides, green and energy saving features, at least four resident program offerings for elderly developments (24 hour support to assist residents with urgent issues plus 3 other programs such as literacy training, computer training, daily activities, resident assurance check in or assistance with light housekeeping) and proximity to transit and community services. Each development has had to secure a verification of the presence of infrastructure (roads, water, sewer, electricity) for each site as well as a verification that the property is zoned for the proposed use. A copy of the complete RFA and related documents is available online (Click Here)
Each development will undergo a rigorous underwriting process through FHFC. None of the developers are on the FHFC's non-compliance list for projects that have received funding from FHFC in the past. These developments are monitored regularly (typically annually) by FHFC's contracted monitoring agents for physical condition of the property, verification of tenant occupancy, income eligibility and rent restrictions, and documentation of availability of amenities and services as stipulated in the FHFC Land Use Restrictions. Developments failing to provide the amenities or meet the income or rent set asides would jeopardize their tax credit standing, which could result in a recapture of the tax credit benefit. |