24 - Laserfiche WebLink

can be used to account for a portion of the lower-income capacity; however, this does not result in the net reduction of the RHNA, since an equivalent number of market-rate units would be added to the above-moderate RHNA. Legislative efforts were made in 2021, with proposed AB 787, to allow for the sorts of moderate-income deed-restricted units facilitated by programs such as CSCDA to be counted in the City's Housing Element sites inventory. Although AB 787 was adopted and appears to allow for these types of conversions to be annually reported (and counted) in the Annual Progress Report (APR) for the City's production of moderate-income units, it would not allow for them to be included in the initial inventory being developed in conjunction with the 6th Cycle Housing Element. With respect to the APR, AB 787 sets limitations on the number of such units that may be counted (only allowing up to 25 percent of the moderate-income RHNA to be so reported). The language of the adopted legislation also has a number of stipulations with respect to the pre-conversion rental rate and other limitations that may ultimately further restrict the number of units that may be counted in the APR. CONCLUSION AND RECOMMENDATION Based on the above analysis, it is clear that there would be significant questions and implications associated with a potential project acquisition funded through a program such as the CSCDA Workforce Housing Program. While CSCDA has issued over $65 billion in bonds across its range of programs, the Workforce Housing Program is relatively new, having existed only since 2020. Therefore, a much smaller number of properties have been acquired which has produced a correspondingly limited track record to report in terms of long-term benefits and risks. Nonetheless, the program represents a unique and creative approach to securing deed-restricted moderate-income housing, which very few existing affordable housing funding and programs address today, representing an important need in the community. Staff reiterates the request at this time, from the program proponent, is for the City to join the affiliate JPA (CSCDA-CIA), an action that does not commit the City to participating in future transactions or pose any financial risk. However, it is clear that the specific costs, benefits, and risks of a program are difficult to evaluate outside of a specific project proposal, and staff would strongly advise that any proposed transaction be carefully reviewed by a firm expert in the necessary analysis before any commitment is made on the part of the City to participate. Given this uncertainty, staff does not recommend the City Council take any action on joining the affiliate JPA at this time, and only consider doing so in conjunction with an actual project. CSCDA staff has indicated that not being a member of the JPA would not obstruct, delay or limit the City's ability to participate in a future project acquisition, and that the two actions could be considered concurrently (i.e., approval to join the affiliate JPA could occur at the same time as an approval to participate in a property acquisition). Page 8 of 9