City of Gainesville Commissioner Mail Archive

Dear Mayor and City Commissioners,

Please accept this letter on behalf of the North Central Florida Apartment Association (NCFAA) regarding Agenda Items #O.1, the City’s proposed inclusionary zoning ordinance. While we acknowledge the well-intentioned nature of this policy, NCFAA continues to have serious concerns regarding the City’s ability to meet the threshold statutorily mandated by HB 7103.

HB 7103 requires the City of Gainesville to “fully offset all costs to the developer…” when inclusionary zoning is mandated. This letter aims to highlight potential unintended consequences that could adversely affect the development of apartment homes and the broader housing market in Gainesville.

Rising Costs of Housing Construction
In today’s economy, development projects face the escalating costs of construction materials, financing, and insurance. Every project is unique in terms of supply costs, labor, design, etc. It is not uncommon for developers to experience significant cost overruns during the construction process. That is because many of these costs are moving targets while developers navigate an economy with high inflation and the uncertainty of the development process.

Given these challenges, it is crucial that the City establishes a mechanism allowing developers to demonstrate when incentives provided under this ordinance fail to cover their expenses for constructing, managing, and maintaining the mandated inclusionary zoning units. Will the City provide an appeals process if developers can substantiate that the incentives do not adequately offset their costs?

Does This Ordinance Meet HB 7103 Threshold?
The City proposes a 30% density bonus as its primary incentive, intended to enhance the feasibility of certain developments. However, the current draft of the ordinance mandates 10% of all units, including those within the 30% density bonus, to be allocated to inclusionary zoning. The City’s own study originally intended the density bonus to be solely for market-rate units unaffected by set aside requirements. This approach risks rendering projects financially unviable and widens the gap the City must bridge to meet HB 7103’s cost-offset requirement.
The City has proposed additional incentives such as expedited application processing, increased building heights, and flexibility in design standards. However, developers may be unable to proceed with plans for increased density if the additional density is not feasible for the project, the site cannot physically accommodate additional units, or if there is considerable community resistance.

It is crucial that this policy does not deter development from the City, exacerbating the housing supply gap. The North Central Florida Apartment Association strongly recommends that the proposed incentives become standard for new developments under this ordinance. Additionally, we urge the inclusion of other incentives such as impact fee waivers and utility fee reductions. These measures are essential for ensuring the City meets HB 7103’s requirement to “fully offset all costs to the developer”.

Thank you for your thoughtful consideration of the apartment industry’s concerns. For these reasons, NCFAA opposes ordinance 2022-677, and respectfully requests that the City Commission address these concerns at the final hearing and adoption.

Warm Regards,

Devante Funderburk

Multifamily Property Manager

Pinnacle is now Cushman & Wakefield

4117 SW 20th Ave

Gainesville, FL 32607

352-375-1519

addisonlaneliving.com

AddisonlaneMGR@cushwake.com

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Date Received:	9/19/2024 1:27:32 PM
To:	wardh@cityofgainesville.org; Chestnut, Cynthia M; Walker, Desmon N; Eastman, Bryan M; Book, Edwin A
Cc:
From:	Addison Lane-Mgr
Subject:	[EXTERNAL] Inclusionary Zoning Ordinance
Attachments:	Outlook-jf4t33ut.png
Message:	Dear Mayor and City Commissioners, Please accept this letter on behalf of the North Central Florida Apartment Association (NCFAA) regarding Agenda Items #O.1, the City’s proposed inclusionary zoning ordinance. While we acknowledge the well-intentioned nature of this policy, NCFAA continues to have serious concerns regarding the City’s ability to meet the threshold statutorily mandated by HB 7103. HB 7103 requires the City of Gainesville to “fully offset all costs to the developer…” when inclusionary zoning is mandated. This letter aims to highlight potential unintended consequences that could adversely affect the development of apartment homes and the broader housing market in Gainesville. Rising Costs of Housing Construction In today’s economy, development projects face the escalating costs of construction materials, financing, and insurance. Every project is unique in terms of supply costs, labor, design, etc. It is not uncommon for developers to experience significant cost overruns during the construction process. That is because many of these costs are moving targets while developers navigate an economy with high inflation and the uncertainty of the development process. Given these challenges, it is crucial that the City establishes a mechanism allowing developers to demonstrate when incentives provided under this ordinance fail to cover their expenses for constructing, managing, and maintaining the mandated inclusionary zoning units. Will the City provide an appeals process if developers can substantiate that the incentives do not adequately offset their costs? Does This Ordinance Meet HB 7103 Threshold? The City proposes a 30% density bonus as its primary incentive, intended to enhance the feasibility of certain developments. However, the current draft of the ordinance mandates 10% of all units, including those within the 30% density bonus, to be allocated to inclusionary zoning. The City’s own study originally intended the density bonus to be solely for market-rate units unaffected by set aside requirements. This approach risks rendering projects financially unviable and widens the gap the City must bridge to meet HB 7103’s cost-offset requirement. The City has proposed additional incentives such as expedited application processing, increased building heights, and flexibility in design standards. However, developers may be unable to proceed with plans for increased density if the additional density is not feasible for the project, the site cannot physically accommodate additional units, or if there is considerable community resistance. It is crucial that this policy does not deter development from the City, exacerbating the housing supply gap. The North Central Florida Apartment Association strongly recommends that the proposed incentives become standard for new developments under this ordinance. Additionally, we urge the inclusion of other incentives such as impact fee waivers and utility fee reductions. These measures are essential for ensuring the City meets HB 7103’s requirement to “fully offset all costs to the developer”. Thank you for your thoughtful consideration of the apartment industry’s concerns. For these reasons, NCFAA opposes ordinance 2022-677, and respectfully requests that the City Commission address these concerns at the final hearing and adoption. Warm Regards, Devante Funderburk Multifamily Property Manager *Pinnacle is now Cushman & Wakefield* 4117 SW 20th Ave Gainesville, FL 32607 352-375-1519 addisonlaneliving.com AddisonlaneMGR@cushwake.com The information contained in this email (including any attachments) is confidential, may be subject to legal or other professional privilege and contain copyright material, and is intended for use by the named recipient(s) only. Access to or use of this email or its attachments by anyone else is strictly prohibited and may be unlawful. If you are not the intended recipient(s), you may not use, disclose, copy or distribute this email or its attachments (or any part thereof), nor take or omit to take any action in reliance on it. If you have received this email in error, please notify the sender immediately by telephone or email and delete it, and all copies thereof, including all attachments, from your system. Any confidentiality or privilege is not waived or lost because this email has been sent to you by mistake. Although we have taken reasonable precautions to reduce the risk of transmitting software viruses, we accept no liability for any loss or damage caused by this email or its attachments due to viruses, interference, interception, corruption or unapproved access. For information on how your personal information is processed, including information on how to exercise state or country specific Privacy Rights please view our privacy notice here: https://www.cushmanwakefield.com/en/privacy-and-cookies

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