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City of Whitefish DRAFT Pathways to Removing Obstacles to Housing Grant Application October 10, 2023 ---PAGE BREAK--- 2 of 30 Table of Contents Exhibit A: Executive Summary 4 Exhibit B: Threshold Requirements and Other Submission Requirements 6 Exhibit C: Need 7 Previous and Current Efforts 7 Acute Demand and Remaining Needs 9 Key Barriers 11 Exhibit D: Soundness of Approach 13 Vision 13 Geographic Scope 17 Stakeholder 17 Furthering Fair Housing 18 Budget and Timeline 20 Exhibit E: Capacity 22 22 Exhibit F: Leverage 24 Exhibit G: Long-term Effect 25 Long-term effects and outcomes 25 Attachment A: Summary of Comments 30 ---PAGE BREAK--- 3 of 30 ---PAGE BREAK--- 4 of 30 Exhibit A: Executive Summary The City of Whitefish is excited about the opportunity to apply for the HUD Pathways to Removing Obstacles to Housing Grant. The grant proposal stands to greatly benefit the community through activities that will promote the preservation of affordable housing, the production of affordable housing, and ensure that housing is available for all members of the Whitefish community. This application is one of many ongoing efforts by the City of Whitefish and its partners to promote affordable housing. The proposed activities are based on the goals identified in the 2022 Whitefish Area Community Housing Needs Assessment Update, 2022 Whitefish Community Housing Roadmap and the overall mission of the City to be a welcoming community that is diverse, livable, and vibrant. The City proposes to utilize this PRO Housing Grant to further efforts to remove barriers to affordable housing by completing a citywide Growth Policy/Vision Plan, a "Zoning for Affordability" analysis of current zoning regulations, and a Community Housing Development Plan that will identify areas or properties best suited for the creation of affordable housing, development partnership opportunities, and financing options which will be used to guide future investment. The City is a small resort community in northwestern Montana known as a home to Whitefish Mountain Resort, a multitude of water sports on Whitefish and Flathead lakes and is a vibrant gateway to nearby Glacier National Park. Approximately 8,900 residents call Whitefish home with another 100,000 in the remainder of Flathead County. Large portions of the nearly 3 million yearly visitors of Glacier National Park and 460,000 visitors of Whitefish Mountain Resort interact with the City in some way whether it be staying in visitor accommodations, dining in downtown Whitefish or one of the hundreds of other recreation opportunities in the area. ---PAGE BREAK--- 5 of 30 Increased tourism has been a huge advantage to Whitefish but has also brought several challenges. The City of Whitefish is experiencing an extreme affordable housing crisis. A range of factors including, but not limited to, increased construction cost, limited land area, greater interest from out-of-state buyers, and job growth has brought the crisis to the forefront of the community. Many of these factors are compounded by the effects of the COVID-19 epidemic. Nearly 37% of owner households and 43% of renter households fall below 100% AMI according to the 2022 Whitefish Area Community Housing Needs Assessment Update. At the same time units typically affordable to lower incomes are being redeveloped, rental price growth continues to outpace income growth, and demand from migration reduces housing availability. ---PAGE BREAK--- 6 of 30 Exhibit B: Threshold Requirements and Other Submission Requirements N/A A copy of the current code of conduct for the City of Whitefish is included as an attachment to this application. ---PAGE BREAK--- 7 of 30 Exhibit C: Need Previous and Current Efforts Over the last decade, the City of Whitefish has worked to identify, address, mitigate, and remove barriers to affordable housing production and preservation. The City has also worked closely with several partners including the Whitefish Housing Authority. The 2003 Whitefish Housing Authority Community Housing Needs Assessment and 2007 Growth Policy are early examples of identifying housing needs within the Whitefish area. In 2015, business owners and the Whitefish Chamber of Commerce hosted a housing summit due to an increasing concern about employee shortages, and in 2016, the City partnered with the Chamber on a new Housing Needs Assessment which projected that 980 new housing units would needed by the year 2020 and 62% of those units should be below market rate to meet the needs of permanent residents and the local workforce. In addition, a Strategic Housing Plan was completed in late 2017, which recommended a three-tiered approach consisting of 40 separate housing strategies. Tier 1 strategies included a development partnership on the "Snow Lot", a property owned by the City of Whitefish, an inclusionary zoning (IZ) program, and a "Zoning for Affordability" zoning code audit and revisions. Those plans were created with significant community input and engagement including a wide range of non-profit, business, and agency support. That support, combined with city staff and council efforts resulted in several successes including; • The City created an inclusionary zoning program that required new multi-family developments and subdivisions to set aside 20% of the units or lots for long-term affordability to medium-income residents. After the State Legislature enacted a law prohibiting mandatory affordable housing statewide, the City amended the Legacy Homes ---PAGE BREAK--- 8 of 30 Program into a voluntary program with heavy incentives such as increased density, reduced parking, increased building height and lot coverage, etc. The program also allows a fee-in- lieu to be paid which is reinvested into other affordable housing projects. • The City amended the zoning for two commercial zones (WB-1 and WB-2) to permit multi- family housing where residential uses were not previously allowed. • Accessory dwelling units (ADUs) regulations were revised to make ADUs easier, quicker, and less costly to get permitted. The City did away with owner-occupancy requirements and made them a use-by-right rather than being subject to a conditional use permit. Incentives including more square footage, no parking, and impact and building permit fee reimbursement will be made available to the owner for agreeing to rent for 12-month leases for five years to a local person. In addition, 38 units serving <60% AMI have been constructed, a non-profit community land trust known as Housing Whitefish was formed, the Housing Steering Committee was created to advise City Council on housing issues, a 4-mill levy on property taxes was specifically to establish an affordable housing fund within the City was passed and the process of proposing a reallocation of an existing Resort Tax was started to increase funding for future affordable housing programs. The Housing Steering Committee is now known as the Whitefish Community Housing Committee and continues to address affordable housing issues by bringing together community members with various areas of expertise and experience in housing-related subjects. Current work includes drafting deed restrictions which can be utilized to maintain housing units for residents and the local workforce. ---PAGE BREAK--- 9 of 30 The Needs Assessment and Housing Roadmap documents were updated in 2022 to reflect the increased pressures on the housing market and the latest data on construction and population statistics. Newly added strategies since the 2016/7 documents include hiring a full-time housing planner within the City, the first full-time position dedicated to community housing, the formation of a Community Housing Financing Plan, and the creation of a rental assistance program. The planner position has been filled, the Financing Plan is in progress and the rental assistance program developed by Housing Whitefish, a partner organization, with funding from the City, is expected to begin aiding rental cost-burdened households in January 2024. These efforts demonstrate the City's commitment to serving the housing needs of the community and an evolution from a solely regulatory role to actively serving as a development partner, thus the need for a holistic Community Housing Development Plan. The City continues to support affordable housing developments including a $2 million contribution to the Snow Lot Townhomes project, a for-sale product serving the 80%-120% AMI population expected to begin construction in late 2023/early 2024. The City continues to take action to identify, address, mitigate, or remove barriers to affordable housing production or preservation and will continue to do so in the long term. Acute Demand and Remaining Needs The City of Whitefish is experiencing an acute demand for housing. The 2022 Whitefish Area Community Housing Needs Assessment Update estimated that 1,310 housing units are needed (market rate and below market rate units) through 2030 to address housing shortages for residents and employees. The Housing Bridge (below) illustrates the extent and variety of these needs by housing type and price point. The Housing Bridge also shows where the market is providing ---PAGE BREAK--- 10 of 30 housing and where it is not, as well as how much additional housing is needed to address current shortfalls and keep up with future job growth. The 2022 Whitefish Needs Assessment indicated: • The rental market is both expensive and scarce. A three-person household earning up to $75,000 per year in Whitefish will struggle to find rental housing defined as affordable in the Whitefish Area. • Buying a home is out of reach for most local employees. Households making their living locally are often priced out of the homeownership market – it has simply gotten too expensive. This includes condominiums, townhomes, and single-family homes. Homes priced under $500,000 are scarce not only in the Whitefish Area but in neighboring communities as well. ---PAGE BREAK--- 11 of 30 • To address the current housing shortfall and keep up with future job growth, at least 75% of the 1,310 housing units needed by 2030 need to be priced below market to support residents and employees. Addressing housing needs will require local policies, subsidies, and creative partnerships, building upon the existing achievements of the City, local organizations, employers, developers, and community in this regard. Home sale prices continue to rise limiting options for community members in need of affordable housing options. The 2022 Whitefish Area Community Housing Needs Assessment Update measured a 197% increase in median residential sale prices in the City of Whitefish between 2016 and 2022 while the overall AMI for Flathead County increased just 30%. Although the City is not identified as a priority geography, Flathead County is identified as a priority geography under the Housing Affordability Factor criteria. Nonetheless, the City continues to face similar issues and may not be present on the priority geography list due to successes in previous affordable housing efforts outlined in the above sections. Key Barriers Preservation of affordable housing is becoming increasingly difficult due to market pressures resulting in higher demand for short-term rentals, redevelopment, and conversion of community housing to market rate. The 2022 Whitefish Community Housing Needs Assessment Update found a 160% increase in short-term rentals in the Whitefish area since 2016. This growth of short-term rentals not only limits units available for the workforce but increases the number of visitors in the City at any given time increasing demand on local businesses for dining, shopping, and recreation. These local businesses are increasingly struggling to hire and retain an adequate number of ---PAGE BREAK--- 12 of 30 employees in a manner that is economical for their businesses. Increased enforcement does limit the spread of short-term rentals, but more can be done. Redevelopment places additional pressure on the real estate market. Recently proposed projects are redeveloping housing units into hotels and businesses while others are removing housing units in favor of larger, more expensive homes. The City has identified the need to implement a "No- Net Loss Policy" for redevelopment projects but lack of staff time has hindered progress. A well- written policy to preserve housing units in the face of redevelopment is proposed in the "Zoning for Affordability" activity proposed as part of this application. While tourism represents a significant portion of the Whitefish economy it has created an artificial market demand with buyers that can outbid local and inflate house values while reducing available units for the workforce. Zoning control continues to be a barrier to affordable housing in the City. Land values continue to rise however only moderate changes have been made to the zoning code to increase density, offsetting the higher land costs over a greater number of units. Single-family housing makes up nearly 60% of developable land in the City of Whitefish. Recent changes in state law have mandated the allowance of duplex units on all single-family properties but greater opportunities exist for housing unit infill without hindering the community character of Whitefish or significantly impacting infrastructure demands. An analysis of the current land use regulations, approval procedures, and land use needs is necessary to encourage more affordable housing types. The Zoning for Affordability activity proposed as part of this grant application is directly targeted at identifying how the existing zoning code and approval procedures are limiting affordable housing development. ---PAGE BREAK--- 13 of 30 Exhibit D: Soundness of Approach Vision The City of Whitefish is developing a wide range of responses to the urgent need for affordable housing in the community. As a resort community of just over 6,500 residents, the demands from outside real estate investors, rising construction costs, and limited land availability are limiting housing options for the local workforce, families, and protected class groups. Many of these issues were compounded by the COVID-19 epidemic as paradigm shifts in the real estate market, working habits, and vacation destinations decimated any remaining affordable housing options in Whitefish and surrounding communities in the Flathead Valley. The City is seeking grant funding through the PRO Housing Grant to achieve its vision and recognition that having diverse and secure housing opportunities, at prices residents making their living in the area can afford, is essential for maintaining the livability, diversity, and character of the Whitefish community and to ensure a strong and vibrant economy and quality of services. The proposed activities are summarized below and although defined separately are extremely interrelated. Concurrent development of these plans/analysis activities is highly beneficial to the community due to the efficiency in data gathering and alignment of goals, priorities, and objectives to guide efforts in affordable housing production and preservation for the coming decades. 1. Growth Policy Buildout Analysis – this activity consists of completing an analysis of existing conditions and a plan that guides the growth of the City for the next 20 years. 2. Community Housing Development Plan – develop a plan that identifies properties best suited for affordable housing in the near term considering utility availability, transportation, land costs, construction limitations, equity, and relation to other affordable housing properties. ---PAGE BREAK--- 14 of 30 3. Zoning for Affordability analysis – develop recommendations for zoning and land use reform which allows more affordable dwelling types to be permitted by right. The Growth Policy, also known as a Land Use Plan, Comprehensive Plan, or Vision Plan, will analyze the existing conditions of the City, anticipate changes and trends, and then serve as a guide for making decisions about the future, particularly about land use. Elements that must be analyzed and projected include population, housing, local facilities and services, economic development, and natural resources. The Growth Policy will provide clear documentation of barriers to housing production and preservation from the infrastructure and land use perspective and does so in an economical and equitable method that includes all areas of the City instead of limiting analysis activities to a single parcel or neighborhood for project-specific work. Ensuring that city services including water, sewer, fire protection, and education are available to all residents today and in the future is a foundation for more specific activities targeted at housing affordability. Goals for the Growth Policy include: • Learn from recently built, approved, and denied community housing projects to understand how to align Growth Policy with desired design/locations and improve project outcomes/successes. • Ensure policy permits/incentivizes community housing where most desired. Make community housing by-right in such zones purely market development may still require conditional use permit (CUP) process in some zones, for example). • Utilize density bonus/incentives, not upzone, in prime community housing locations. Upzoning simply allows more market priced units to be built; density bonus incentives ---PAGE BREAK--- 15 of 30 ensure a portion of the new development will be occupied by and affordable for residents/employees as deed restricted community housing. • Attached product by-right in all zones – duplex/triplex in single family zones, larger scale multi-family where appropriate. • Integrate engineering and building standards with community housing priorities to ensure all polices are aligned. If zoning allows small lots for tiny homes, building standards must also allow tiny homes, for example. The specific studies proposed to serve as the foundation of the Growth Policy include: • Overlay of all environmental constraints including rivers, lakes, wetlands, streams, steep slopes, protected land and areas affected by high groundwater. • Vacant land analysis identifying parcels with no structure, underperforming parcels in terms of highest and best use and large lots that could be further developed or subdivided. • Water system plan – where to extend, identify projects, costs • Sewer system plan – where to extend, identify projects, costs • Stormwater plan – overall plan that identifies problem areas or areas where the City could invest in a large stormwater system. Stormwater is typically handled on site, increasing costs and lower land available for a structure, for most projects. Affordable housing specifically stands to benefit if it does not have to provide storage because of a city facility, there could be increased density and, hopefully, more affordable housing. • Overall traffic capacity analysis for the roads which forecasts a full build out scenario. Identify the impact of additional density vs. additional commuting demands and where investments should be prioritized to support residents. This is intended to include ---PAGE BREAK--- 16 of 30 recommendations on forming a public transportation system to serve present and future affordable housing development. The Community Housing Development plan is based on the guidance of the Growth Policy analysis to identify parcels where affordable housing is most appropriate. Considerations will include, but are not limited to, construction feasibility, proximity to education and employment, environmental risks, utility availability, and transportation infrastructure, including potential for integration into a future public transportation system. Properties identified here are generally going to be subsidized projects targeted to serve the 30%-100% AMI for rental properties and 70% AMI- 250% AMI for ownership housing. The 2022 Whitefish Affordable Housing Roadmap identified a combined need for 1,310 homes within these categories. The plan will serve as a guide for allocating future investments including tax revenue, subsequent grant awards, private funding, and partnerships. The Zoning for Affordability analysis will be a complete review of the current zoning and land use code, entitlement process, and policies to identify barriers to affordable housing production. Recent zoning code changes to reduce limitations on the construction of Accessory Dwelling Units (ADUs) and duplex housing are beneficial but do not fully address the extreme need for housing. A shift to form-based code is likely to be included in core development areas. In addition, the proposal should increase by-right uses and building types as well as reduce the time and capital needed to permit smaller, more efficient dwelling units throughout the City. These recommendations would result in the option for more creative solutions to affordable housing production including allowing small lots for modest/tiny houses, live/work opportunities, dorms/seasonal options, or hotel conversion. ---PAGE BREAK--- 17 of 30 Geographic Scope The activities proposed will encompass the entirety of Whitefish city limits; an area of approximately 8,022.46 acres within Flathead County, Montana. Parcels currently outside of city limits but expected to be annexed in the next 20 years may also be included in the analysis but City regulatory control is limited to the city limits and therefore will not be subject to zoning code reforms or Growth Policy recommendations. Stakeholder Engagement The proposal has been developed from a continuing effort of community outreach, engagement, and input regarding community affordable housing efforts in Whitefish. The activities proposed here were identified in the 2022 Whitefish Community Housing Roadmap document which was created under the guidance of a Housing Refresh Team consisting of various community members and stakeholders including numerous local banks, Logan Health, Whitefish Chamber of Commerce, Whitefish Community Foundation, Whitefish Housing Authority, Whitefish Convention & Visitors Bureau Board, Whitefish Public Schools, Explore Whitefish as well as at- large members with property management and development experience. The public was offered multiple opportunities throughout the plan development period to provide comments. Some members of the Refresh Team continue to serve on the Whitefish Community Housing Committee which meets and serves as an advisory board to City Council. The community will continue to be engaged throughout the process through regular updates and public meetings to provide input on the various elements of the Growth Policy. The process and consultant scope of work for the Zoning for Affordability study and Community Housing ---PAGE BREAK--- 18 of 30 Development Plan will both include several public engagement exercises which may include charettes, listening sessions, information sessions, brainstorming, or visioning. Additionally, formal approval of each plan by the City Council will occur as a public hearing, advertised according to City of Whitefish standard practices, where the public will be allowed to comment. Ensuring broad community engagement is extremely important throughout the grant process. The City will continue to foster relationships with the Whitefish Housing Authority, Housing Whitefish, and Shelter WF, an advocacy group, as these organizations represent many underserved and under-housed populations. This grant application will be made available to the public for the required 15-day comment period and advertised in the Whitefish Pilot, the local newspaper. In addition, a notification and full grant application will be available on the homepage of the City of Whitefish website for the duration of the comment period. A public hearing with the City of Whitefish City Council is scheduled for October 16, 2023. A summary of comments received will be included as Attachment A per the requirements of this grant application. Furthering Fair Housing The City of Whitefish created the 2022 Whitefish Community Housing Roadmap to identify strategies that promote the construction of affordable housing and reduce the housing cost burden. Without action, members of our community are increasingly becoming economically disadvantaged and often experiencing housing cost burdens that force them out of the community. This hinders the livability of the community for members in all income ranges. The Zoning for Affordability study is a step in an ongoing effort to encourage more affordable housing types to be constructed within the City and the Community Housing Development Plan will serve as a ---PAGE BREAK--- 19 of 30 guide for future investment in affordable housing whether that comes through additional federal grant dollars, local resort tax, mil levy or private donors. Having this plan in place will speed up the process with which the City can ensure housing is provided to the community from the time funding becomes available. The changes proposed through the Zoning for Affordability project will respond clearly to the goal of improving the availability of affordable housing in all neighborhoods and areas of the community. In addition, the Community Housing Development Plan will identify land throughout the City which is suitable for affordable housing. This housing in addition to the units already provided in an affordable housing program will ensure that protected classes, often the most vulnerable to housing instability, can remain living in their community. The activities proposed within this grant application directly respond to needs contained within the 2022 Whitefish Community Housing Roadmap. Section 3 of that plan, Implement Policies to Support Community Housing, contains Priority Action 1. Update Growth Policy and Priority Action 5. Zoning for Affordability. Section 1 Activate Public Private Development also lists, Priority Action 1: Create Community Housing Development Plan, and Priority Action 3: Create pipelines of land partnership opportunities/next-tier projects. These four goals of the housing roadmap document make up the activities for which this application is addressing. This application does not propose any activities which can reasonably be considered as increasing the risk of displacement. Promoting additional affordable housing in the community will lessen the extreme risk of displacement already faced by members of the community due to market pressures on housing costs. Any property identified as suitable for affordable housing in the Community Housing Development Plan document which also has existing housing will include ---PAGE BREAK--- 20 of 30 an anti-displacement strategy such as replacement of units. No activity proposed in this application will in any way directly reduce the number of affordable housing units available to the community. All activities will be completed following the Fair Housing Act, HUD guidelines, and the City of Whitefish's affordable housing goals. Budget and Timeline The bulk of proposed activities will be carried out through one or more consulting agencies engaged by the City of Whitefish. The timeframe is inclusive of all three proposed activities but may vary to a degree depending on the number of firms engaged. The schedule represents the expectation of having all activities finalized by January 2026 which includes all necessary community engagement, feedback, and data collection. Event Timeframe Grant Award January 2024 Consultant Engagement and RFP February 2024-May 2024 Consultant Selection June 2024 Data Collection July 2024-July 2025 Community Outreach and Report Preparation August 2025-May 2026 Final Report June 2026 The provided budget is an estimation for consultant services based on the scope of work and compared to previous consultant work performed. The bid process will follow all City standards for Request for Proposals (RFP). Should a partial amount be awarded the City is prepared to ---PAGE BREAK--- 21 of 30 reduce the scope of work proposed. The activities are ordered by priority in the budget table below. An award of 50% would still allow for a strong Buildout and Infrastructure analysis but would likely forfeit additional detail or time allotted to community engagement which are critical elements to achieving a final product that is useful and responsive to community needs. Activity Budget Buildout and Infrastructure Analysis • Environmental constraints • Vacant land/highest and best use analysis • Water system capacity • Sewer system capacity • Stormwater system capacity • Traffic system capacity $700,000 Zoning for Affordability Study • No Net Loss/Preservation Policy $150,000 Community Housing Development Plan $150,000 ---PAGE BREAK--- 22 of 30 Exhibit E: Capacity Capacity The City of Whitefish will be the recipient of funding and act as the lead agency in the completion and implementation of the proposed activities. Consulting firms engaged to complete the activities proposed will be communicating directly with city staff members and may include presentations to the City Council, Planning Board, and other groups as needed to engage community members. As a local government, the City of Whitefish is well equipped to not only serve the project management role for this proposal but also has the ability and legal authority to enact the proposed plans and reforms. Staff, including the Planning and Building Department, City Manager, and City Attorney are responsible for bringing forward policy changes and adoption of regulatory documents to the City Council for formal adoption. The City Council is prepared to support recommendations and reforms proposed through this process. A formal resolution of support from the City Council is attached. Staff capacity will be minimally impacted at the City level. The Housing Planner, Luke Sponable, will be the primary grant manager supported by David Taylor, Planning and Building Department Director, and Dana Smith, City Manager. The City of Whitefish will be responsible for all reporting as required by HUD and is committed to the responsible use of funds. The systems, policies, and procedures are already in place to accurately allocate and report on the use of funding to fully comply with the grant requirements. The bulk of the work including data collection, analysis, community outreach, and report preparation will be conducted by one or more outside consulting agencies to be hired by the City of Whitefish using the award funding. The City will ensure that the selected consulting agency is adequately prepared to complete the proposed work within the proposed timeline, in a manner that ---PAGE BREAK--- 23 of 30 complies with all relevant HUD guidelines and whose vision is consistent with that of the City of Whitefish and HUD. The City of Whitefish has been the recipient of numerous other federal grants and has completed similar activities to that proposed here including engagement of community stakeholders, management of contractors, public engagement, and reporting procedures. Major projects and grants managed include the 2022 Whitefish Transportation Plan, the 2022 Whitefish Community Housing Roadmap, and a grant award under the Safe Streets and Roads for All Discretionary Grant Program in the amount of $200,000. This application was written by Luke Sponable, Housing Planner for the City of Whitefish, with support from Dana Smith, City Manager; Angela Jacobs, City Attorney; and David Taylor, Planning and Building Department Director. ---PAGE BREAK--- 24 of 30 Exhibit F: Leverage No leveraged funding is proposed. ---PAGE BREAK--- 25 of 30 Exhibit G: Long-term Effect Long-term effects and outcomes The activities proposed in this grant application are intended to reduce barriers to housing production and preservation in three aspects: 1. Reduce zoning and land use code restrictions to permit more flexibility, creativity, and unique infill development projects within existing neighborhoods to accommodate an increased number of housing units. 2. Introduce a "no net loss" policy to ensure maximum protection of existing housing units as redevelopment occurs. 3. Develop a Community Housing Development Plan (affordable housing master plan) specifically responding to affordable housing needs which will direct future investment as it is received to increase the affordable housing stock. Plan elements may include subsidies, land acquisition, redevelopment, or construction of housing to serve lower- income populations. 4. Facilitate completion of a Growth Policy/Land Use Plan which will serve as a guide for development over the next 20 years. The plan will identify how and where development will need to occur to support the projected population growth. Elements such as utility capacity, transportation, open space, parks, and emergency services will be evaluated against anticipated growth and relevant use trends. It is intended that these efforts will increase the number and variety of affordable housing units within the City of Whitefish, minimize the housing cost burden for residents, and reduce the time and capital investment required during the entitlement process. Long-term success is dependent ultimately on adoption by the City Council and community support. The possibility of denial or ---PAGE BREAK--- 26 of 30 heavy modification by the City Council is a threat to a successful outcome. However, affordable housing has been identified as a Council priority and therefore it is reasonably assumed that there is general support for these activities and an understanding of the dire need to support multiple solutions to address the affordable housing crisis. Additionally, a failure to engage one or more consulting firms to complete the specified work is a threat to the implementation of the proposed activities. Given the number of firms that are generally qualified to complete the work identified the issue does not appear to be significant but may more likely result in a longer timeline than originally proposed to accommodate consultant availability. However, the City remains fully committed to completing all activities in advance of the deadline at the end of FY2029. Many aspects of affordable housing construction and implementation should be considered during the planning process. The location of the proposed housing is extremely important. While no aspect of this proposal involves construction, location will be considered during activities proposed in the Community Housing Development Plan, along with transportation, utilities, open space, education, employment, recreation, and more. A priority of the plan is to ensure that proposals would not increase other costs for residents. Infill proposed under the "Zoning for Affordability Activity" is extremely beneficial to the community as it would increase affordable housing in already developed neighborhoods complete with education, employment, amenities, and more. This minimizes costs to the City and developer for additional infrastructure and services that may be required for the same development in a non- developed location. ---PAGE BREAK--- 27 of 30 Other communities can benefit greatly from the outcomes of the "Zoning for Affordability" study proposed in this grant application. The recommendations made will be directly applicable to several communities with similar zoning regulations. Other activities proposed in this grant application are very location-specific but will serve as a good example for the process, procedures, and content of a growth policy that meets the standards of the State of Montana and an Affordable Housing Plan that includes a wide range of context-specific solutions to address the affordable housing crisis. Communities of any size will be able to replicate these activities within their context and scale to achieve a similar result. The City of Whitefish is a desirable community in many ways due to its proximity to both mountains and water. Both elements also pose a risk to the City from wildfire and flooding and will be included in all analysis activities for the proposed activities. Wildfire risk will be fully analyzed as part of the Growth Policy since little work has been done previously to quantify risk and recommend firewise development practices to reduce risk to the entire community. Being so closely integrated into the natural landscape also brings a heightened responsibility to protect natural resources. The Growth Policy will take into consideration the impact of population growth on transportation, energy use, and related climate impacts to minimize the City's contribution to climate change. The activities proposed in this grant application will continue the efforts of the 2022 Whitefish Community Housing Roadmap, therefore, these activities will continue to target the outcomes that have already been identified. 1. Objective 1: Own/Rent Mix ---PAGE BREAK--- 28 of 30 a. Stabilize the owner/renter relationship to preserve the community’s character as influenced by its mix of owners and renters. Specific targets to maintain: i. 35% rental and 65% ownership 2. Objective 2: Income Targeting a. Serve and ensure housing is available that meets the wide range of housing needs (income level and rental/ownership) of the City population: i. For rental housing, focus efforts on serving households with annual incomes between 30% to 100% AMI. ii. For ownership housing, focus efforts on serving households with annual incomes between 70% to 250% AMI. 3. Objective 3: Primary Home/Second Home Relationship a. Maintain and, if possible, increase the percentage of homes occupied by residents of the community as their primary residence. i. 70% full-time occupancy rate of homes. 4. Objective 4: Jobs/Housing Relationship a. Keep up with job growth and provide more opportunities for in-commuting employees to reside in Whitefish near their jobs. i. Additional 1,310 homes needed through 2030, at least 900 of which need to be priced below market. In addition to the metrics above the activities proposed will reduce barriers to housing production and promote preservation of existing units to ensure affordable housing is available for all members of the Whitefish community. ---PAGE BREAK--- 29 of 30 ---PAGE BREAK--- 30 of 30 Attachment A: Summary of Comments Comment Summary to be completed upon completion of Public Comment period