Eagles Lot RFP public comment from Cassidy Kipp with CAPNWMTAimee Brunckhorst
From: Cassidy Kipp <ckipp@capnwmt.org>
Sent: Tuesday, July 12, 2022 11:59 AM
To: Kalispell Meetings Public Comment
Subject: EXTERNAL Eagles Lot RFP public comment
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Good Morning,
I wish to submit input on the proposed inclusion of workforce housing in the mixed use structure slated for the Eagles
Parking Lot in Kalispell. It is with great regret that our agency will be unable to provide a response to the request for
proposals on the private development of the city owned Eagles lot. Given the short timeframe allotted for these
proposals we find it exceedingly difficult, if not impossible, to develop a salient and responsible business proposal as
required by the RFP. The initial request for proposal for the development of the Valley Bank parking lot was open for
over 7 months in order to gather the required elements of the RFP. Having only 16 working days to develop a plan for
this project makes it impossible to procure and generate the required information.
Therefore, our comments shall be centered on the proposed use of TIF funds to supplement rent in 'workforce housing'.
Our concerns are as follows:
1.) The RFP is light on housing requirements, number of units for a set -aside and ongoing responsibilities, yet
inclusion of housing is being marketed heavily right now in the press. Critical details that are typically
called for with mixed use development and deed -restricted housing proposals are not included. This is
potentially problematic for the long-term goals of the project.
2.) 80-120% AMI: This range is too high for a rental program. CDBG, HOME programs cap income eligibility at
80% AMI and Housing Trust Fund caps income at 30% AMI in Montana. Low-income Housing Tax Credit
program caps the income limit at 60% AMI. The Emergency Solutions Grant caps homeless prevention funds
for those under 30% AMI. Most, if not all, deed restricted affordable rental housing in the Flathead has
income limits much lower than those that are being proposed. Section 8 participants must be at or below
80% AMI; it is very unlikely that anyone would be able to use traditional rental assistance or Veteran rental
assistance at this property. The article in the Interlake today cites the Junegrass market study, but fails to
call attention to the fact that the income restricted units for that development are capped at 60% AMI,
which is presumably where the need was identified and what is required for funding.
3.) Period of Affordability: Projects of this nature enter into an agreement on the length of affordability .... how
long will the developer need to rent to people who are 80- 120% AMI? With Low Income Housing Tax
Credits have an initial period of 15 years PLUS a required 35 years for a total of 50 years of tracking
household income to ensure compliance with targeted AMIs. Rural Development also has a period of
affordability that extends decades. What assurances that this will be tracked are provided by the City/
Developer?
4.) Accountability: Who will be responsible for reviewing the housing files for tenants during the life of the
project? What would be the teeth if errors were found to occur? Models for how to handle these types of
infractions exist and need to be adhered to in order for the developer to have some accountability. For
example, should the City move forward, there should be incorporation of Section 42 LIHTC operating
parameters or the Qualified Allocation Plan as published by the Montana Board of Housing to keep things
consistent and to make sure that a developer is accountable for following through with their commitments.
As the recipient of TIF funds they must demonstrate compliance.
5.) Why now?: The City should question if changing the plan on the Eagles lot is being done in order to work
within the parameters of what an identified developer wishes, or if the intent is truly to move the needle on
housing needs. If housing is the goal, please evaluate who the target population is, who benefits the most,
and if there may be a more impactful use of TIF funds.
Thank you,
Cassidy Kipp
Please take a few minutes to complete the 2022 CAPNM Community Needs Assessment:
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Cassidy Hipp, Deputy Dire ctorr
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