November 16, 2022
This letter comes to you from the Community Advocacy Committee of the Austin Housing Coalition, and is representative of feedback from affordable housing developers, consultants, and lenders. Over the past few years this group has worked with the new HPD team to add more affordable units than at any time in Austin’s history. Coinciding with this increased productivity, we have also seen a policy shift within HPD to implement payback structures and to have greater oversight and involvement in the development process. As a community of housers, we are in support of policy goals that may open the door to recycling of public dollars in the right situations; however, we are seeking an opportunity to provide feedback on recent shifts to help improve the transparency and effective implementation of these policies.
We would like to schedule a meeting with HPD’s HDA staff to share our thoughts and collaboratively discuss constructive solutions. Below are some key topics we would like to discuss.
- Establish a recurring format for public engagement on AHFC Guidelines and policy priorities and open the Guidelines for public comment.
- Honor the terms of loans that have previously closed under older guidelines and begin enacting changes that are clearly specified under the published guidelines in effect at the time of application.
- Discuss the delicate balance of repayment goals with goals to fund high-quality and well-maintained affordable housing.
- Establish and define high-level underwriting parameters, such as subsidy caps, rates, and loan types, in the Guidelines or a NOFA that align with the level of affordability and other City initiatives and priorities being considered, so applicants know what to expect at the application stage.
- Consider different terms for different types of housing and/or units, such as supportive housing developments and deeply affordable units, which are not able to support much, if any, traditional debt.
- Discuss ways to improve flexibility and access to HPD’s acquisition and pre-development loans, while managing the risk to HPD.
- Provide a clear and realistic timeline from award to closing, and establish a transparent policy to ensure affordable developments are not saddled with unforeseen legal fees.
- Minimize the changes in loan terms between HDA application, which happens very early in the process, and closing.
We believe the above suggestions will strengthen HPD’s housing policies by creating clarity and certainty in the process, and will in turn produce more, high-quality affordable housing units across the City of Austin. We look forward to meeting with you to discuss collaboratively addressing Austin’s affordable housing crisis.
Austin Housing Coalition, including:
Austin Revitalization Authority
Accessible Housing Austin
Capital A Housing
Chestnut Neighborhood Revitalization Corporation
DMA Development Company, LLC
Guadalupe Neighborhood Development Corporation
True Casa Consulting