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Item D1 BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: Bulk Item: Yes February 22, 200 1 No X Division: Growth Management Department: Plannin~ D~partment AGENDA ITEM WORDING: Public hearing to consider adoption of an ordinance amending sections 9.5- 122.3. (6),9.5-266 (a)(3), 9.5-266 (a)(4), and 9.5-266 (a)(4) a.; deletion of sections 9.5-266 (a)(4) b., 9.5- 266 (a)(4) d., 9.5-266 (a)(4) g., and 9.5-266 (a)(4) h.; renumbering of and amendment to sections 9.5-266 (a)(4) e., 9.5-266 (a)(4) d.; and creation of new sections 9.5-266 (a)(4) b., 9.5-266 (a)(5), and 9.5-266 (a)(6). ITEM BACKGROUND: In accordance with the Monroe County Year 2010 Comprehensive Plan and at the direction of the Board of County Commissioners, the Planning Department is proposing these amendments to the Monroe County Code to expand the eligibility criteria for qualifying for affordable housing ROGO allocations. In response to the increasing need of assisting all our retiring elderly and disabled population, the amendments include very low to median income households who do not meet the requirement of receiving at least "70" percent of their annual household earnings from employment in Monroe County. PREVIOUS RELEVANT BOARD ACTION: None STAFF RECOMMENDATION: Approval TOTAL COST: N/A BUDGETED: N/A COST TO COUNTY: N/A APPROVED BY: County Attorney X OMB/Purchasing N/A Risk Management N/ A / DEPARTMENT DIRECTOR APPROVAL: -:: -'" <. ~ DIVISION DIRECTOR APPROVAL DOCUMENTATION: Included X Not required t),~ Agenda Item#: ~ DISPOSITION: PROPOSED TEXT AMENDMENT SECTIONS 122.3. (6), 9.5-266 (a)(3), 9.5-266 (a)(4), AND 9.5-266 (a)(4) a.; DELETION OF SECTIONS 9.5-266 (a)(4) b., 9.5-266 (a)(4) d., 9.5-266 (a)(4) g., AND 9.5-266 (a)(4) h.; RENUMBERING OF AND AMENDMENT TO SECTIONS 9.5-266 (a)(4) e., 9.5- 266 (a)(4) d.; AND CREATION OF NEW SECTIONS 9.5-266 (a)(4) b., 9.5-266 (a)(5), AND 9.5-266 (a)(6) MONROE COUNTY CODE The Soard of County Commissioners has directed the Planning Department staff to prepare amendments to the current Land Development Regulations to expand the eligibility for qualifying for affordable housing ROGO allocations to include very-low to median income households who do not meet the requirement for at least 70 percent of their annual household earnings to come from employment in Monroe County. SOCC Staff PC Staff Public Hearing APPROVAL APPROVAL APPROVAL February 22, 2001 February 22, 2001 December 27,2000 November 28, 2000 Draft Ordinance SOCC Staff Report PC Resolution # P80-00 PC Staff Report Ordinance No. -2001 AN ORDINANCE BY THE MONROE COUNTY BOARD OF COUNTY COMMISSIONERS APPROVING THE REQUEST FILED BY THE PLANNING DEPARTMENT TO AMEND THE AFFORDABLE HOUSING CRITERIA IN MONROE COUNTY LAND DEVELOPMENT REGULATIONS SECTIONS 122.3. (6), 9.5-266 (a)(3), 9.5-266 (a)(4), and 9.5-266 (a)(4) a.; DELETION OF SECTIONS 9.5-266 (a)(4) b., 9.5-266 (a)(4) d., 9.5-266 (a)(4) g., AND 9.5-266 (a)(4) h.; RENUMBERING OF AND AMENDMENT TO SECTIONS 9.5-266 (a)(4) e., 9.5-266 (a)(4) d.; AND CREATION OF NEW SECTIONS 9.5-266 (a)(4) b., 9.5-266 (a)(5), AND 9.5-266 (a)(6) TO EXPAND THE ELIGIBILITY FOR QUALIFYING FOR AFFORDABLE HOUSING ROGO ALLOCATIONS TO INCLUDE VERY-LOW TO MEDIAN INCOME HOUSEHOLDS WHO DO NOT MEET THE REQUIREMENT OF AT LEAST SEVENTY PERCENT (70%) OF THEIR ANNUAL HOUSEHOLD EARNINGS FROM EMPLOYMENT IN MONROE COUNTY. WHEREAS, the Development Review Committee met on November 21, 2000 and conducted a public meeting and recommended approval to the Planning Commission of the proposed amendments; and WHEREAS, the Monroe County Planning Commission at the public hearing on December 11, 2000 in Marathon conducted a review and consideration of the request of the Planning Department to amend Monroe County Land Development Regulations, sections 122.3. (6), 9.5-266 (a)(3), 9.5-266 (a)(4), and 9.5-266 (a)(4) a.; deletion of sections 9.5-266 (a)(4) b., 9.5-266 (a)(4) d., 9.5-266 (a)(4) g., and 9.5-266 (a)(4) h.; renumbering of and amendment to sections 9.5-266 (a)(4) e., 9.5-266 (a)(4) d.; and creation of new sections 9.5-266 (a)(4) b., 9.5-266 (a)(5), and 9.5-266 (a)(6) to expand the eligibility criteria for qualifying for affordable housing ROGO allocations; and WHEREAS, the Planning Commission made the following Finding of Facts and Conclusions of Law: "1. Based on Section 9.5-511 of the Monroe County Code (MCC), the planning Commission finds that the Board of County Commissioners may consider a text amendment to the Land Development Regulations if at least one of the six criteria is met. ... The Board of County Commissioners and the Planning Department are concerned that the current affordable housing criteria in LDR does not provide opportunities for our elderly and disabled population who meet the income criteria for affordable housing. Therefore, the Planning Commission conclude that the proposed text amendment to eliminate the "70" percent earnings requirement from the affordable housing criteria, and to establish "70" percent earning of household income from employment in Monroe County for commercial apartments and employee housing, is consistent with Affordable Housing Monroe County Code Ordinance Page 1 of 8 the requirement enumerated in section 9.5-511 (5)(d)b. (iv) (New Issues) of the Monroe County Code. 2. Based on Goal 601 of the Monroe Countv Year 2010 Comorehensive Plan, we find that the County shall improve access to affordable housing for all current and future residents. In addition, based on POlicy 601.4.3 of the Monroe Countv Year 2010 Comorehensive Plan, we find that the county shall expand affordable housing opportunities for the elderly. Therefore, the Planning Commission concludes that the proposed text amendment is consistent with and furthers the goals of the Monroe Countv Year 2010 Comorehensive Plan." NOW THEREFORE, BE IT ORDAINED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA, THAT: Section 1. Section 9.5-122.3 (6) of the Land Development Regulations shall be amended to read as follows (the strike-through and underline format is used to indicate additions and deletions to this section): Section 9.5-122.3 Evaluation criteria. (6) Affordable housing The following points are intended to increase the supply of affordable housing. Point Assignment Criteria An application which proposes a dwelling unit which meets the definition of affordable housing and restricts the dwelling unit to a household wAieA with a aross annual income limit as defined in Section 9.5-4 (A-5J. · Dorivos at 10aGt sovonty (70) poroont of its inoomo from gainful omploymont in Monroo County; and . Earns an inoomo no groator than one hundrod (100) poroont of tho modian adjustod groGs annual inoomo for housoholds within Monroo County for a poriod of at loast twonty (20) yoars. Section 2. Section 9.5-266 (a)(3) of the Land Development Regulations shall be amended to read as follows (the strike-through and underline format is used to indicate additions and deletions to this section): +5 Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: Affordable Housing Monroe County Code Ordinance Page 2 of 8 (3) Before any certificate of occupancy may be issued for any structure, portion or phase of a projects subject to this section, restrictive covenant(s), limiting the required number of dwelling units to households meeting the income criteria described in paragraph (4) a. or (4) b. ~ of this subsection W running in favor of Monroe County and enforceable by the county, shall be filed in the official records of Monroe County. The covenant(s) shall be effective for twenty (20) years but shall not commence running until a certificate of occupancy has been issued by the building official for the dwelling unit or units to which the covenant or covenants apply. Section 3. Section 9.5-266 (a)(4) of the Land Development Regulations shall be amended to read as follows (the strike-through and underline format is used to indicate additions and deletions to this section): Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article m, IV, the owner must ensure that: Section 4. Section 9.5-266 (a)(4) a. of the Land Development Regulations shall be amended to read as follows (the strike-through and underline format is used to indicate additions and deletions to this section): Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: a. The use of the affordable housina dwelling unit is restricted to households that dorivo at loast seventy (70) poroont of thoir housohold inoomo from gainful omploymont in Monroo County meet the adiusted aross annual income limits for median-income as defined in subsection 9.5-4 (A-5): and. Section 5. Sections 9.5-266 (a)(4) b. of the Land Development Regulations shall be deleted as follows (the strike-through and underline format is used to indicate additions and deletions to this section): Section 9.5-266. Affordable housing; employee housing. Affordable Housing Monroe County Code Ordinance Page 3 of 8 (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: "b. Tho panml propoGod for dovolopmont iG of Gufficiont aroa and dimonGioRG to moot tho bull< rogulationG Got out in di'JiGion 4 of thiG articlo [Goation 9.6 281 ot Goq.]; and Section 6 Sections 9.5-266 (a)(4) c. of the Land Development Regulations shall be deleted as follows (the strike-through and underline format is used to indicate additions and deletions to this section): Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: c. The parcol propoGod for dovolopmont iG of Gufficiont aroa and dimoRGion to moot tho roquiromontG of ahaptor 100 8, Florida AdminiGtrativo Codo, for tho inGtallation of an on Gito waGtowator troatmont GYGtom; and Section 7 Sections 9.5-266 (a)(4) d. of the Land Development Regulations shall be deleted as follows (the strike-through and underline format is used to indicate additions and deletions to this section): Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: d. Tho parcol propoGod for dovolopmont iG Gorvod by adoquato public facilitioG in accordance with Geotion 9.6 292; and" Section 8. New Section 9.5-266 (a)(4) b. of the Land Development Regulations shall be created and read as follows (the strike-through and underline format is used to indicate additions and deletions to this section): Section 9.5-266. Affordable housing; employee housing. Affordable Housing Monroe County Code Ordinance Page 4 of 8 (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: b. If the affordable housina dwellina unit is desiQnated for emolovee housina or commercial aoartments. the use of the dwellina is restricted to households that derive at least seventy (70) percent of their household income from aainful emolovment in Monroe County: and meet the adiusted aross annual income limits for median-income as defined in subsection 9.5-4 (A-5l: and Section 9. Section 9.5-266 (a)(4) e. of the Land Development Regulations shall be amended and renumbered to read as follows (the strike-through and underline format is used to indicate additions and deletions to this section): Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: e Q. The use of the affordable housing dwelling unit is restricted for a period of at least twenty (20) years to households '....ith an inoomo no greater than ene hundred (100) per.oent of the adjusted gFOGS annual inoome fer houGehelds '....ithin Monroe Ceunty; that meet the reauirements of oaraaraoh (4) a. or b. above: and, Section 10. Sections 9.5-266 (a)(4) d. of the Land Development Regulations shall be amended and renumbered to read as follows (the strike-through and underline format is used to indicate additions and deletions to this section) : Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: H:l. The size of an affordable residential housina dwellina unit shall be limited by a condition to be placed on the development permit which restricts the habitable space of the unit to a maximum of Affordable Housing Monroe County Code Ordinance Page 5 of 8 one thousand three hundred (1,300) square feet for a period of at least twenty (20) years.-afl9; Section 10. Section 9.5-266 (a)(4) g. shall be deleted as follows (the strike-through and underline format is used to indicate additions and deletions to this section): Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: g. Tho oligibility of a potential ewner eooupier of an affordable housing residential dwelling unit shall be determined by the planning department at tho time a potential owner either applies for an afferdable heusing residential ROGO alleoatien, or applies to purohase a unit that utilized an afferdable heusing ROGO alleGation unit to detormine if the applioant meets the affordability oriteria as defined by (sub] seotien 9.6 4(/\ 6). Section 11. Section 9.5-266 (a)(4) h. shall be deleted as follows (the strike-through and underline format is used to indicate additions and deletions to this section): Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: h. The eligibility of a potential renter of an affordable Reusing residential dwelling unit shall be determined by the planning department at the time the petential renter applies to oooupy a residential dwelling unit that utilized an affordable housing residential ROGO alleoatien pursuant to [sub]seotion 9.6 4(/\ 6). The planning department will review the lease agreement fer the unit en an annual basis to ensure that the rent for the unit dees net oxoeed the affordable rent standard for tho unit pursuant te [sub) seotion[s) 9.6 4(.^. 6) and 9.6 266. Section 12. New Section 9.5-266 (a)(5) (including subsections a. and b.) of the Land Development Regulations shall be created and read as follows (the strike- Affordable Housing Monroe County Code Ordinance Page 6 of 8 through and underline format is used to indicate additions and deletions to this section): Section 9.5-266. Affordable housing; employee housing. Affordable housing: (5) The eliaibilitv of a ootential owner-occuoier or renter of an affordable housina dwellina unit or an affordable housina dwellina unit desianated as a commercial aoartment or emolovee housina. shall be determined bv the olannina deoartment as follows: a. At the time the ootential owner either aDo lies for affordable housina RaGa allocation. or aoolies to ourchase a unit that utilized an affordable housina RaGa allocation: or b. At the time the ootential renter aoolies to occuov a residential unit that utilized an affordable housina RaGa allocation. Section 13. New Section 9.5-266 (a)(6) (including subsections a., b., and c.) shall be created and read as follows (the strike-through and underline format is used to indicate additions and deletions to this section): Section 9.5-266. Affordable housing; employee housing. Affordable housing: (6) The olanning deoartment shall: a. Review the lease aareement for an affordable housina unit on an annual basis to ensure that the rent for the unit does not exceed the affordable rent standard for the unit oursuant to subsection 9.5-4(A-5): and. b. Review the lease aareement and letter of emolovment and/or occuoation license of an occuoant of a commercial aoartment or emolovee housina on an annual basis to ensure that the occuoant is aainfullv emoloved in Monroe County. c. Review annual verification statement from business certifvina that emolovee housing is occuoied bv emolovees meetina income criteria in subsection 9.5-266(a)(4) b. Section 14. If any section, subsection, sentence, clause, item, change or provision of this ordinance is held invalid, the remainder of this ordinance shall not be affected by such invalidity. Section 15. All ordinances or parts of ordinances in conflict with this ordinance are hereby repealed to the extent of the said conflict. Affordable Housing Monroe County Code Ordinance Page 7 of 8 Section 16. This ordinance shall be filed in the Office of the Secretary of State, of the State of Florida, but shall not become effective until a notice is issued by the Department of Community Affairs or Administrative Commission approving this ordinance. PASSED AND ADOPTED by the Board of County Commissioners Monroe County, Florida, at a regular meeting held on the day of , A.D., 2001. Mayor George Neugent Mayor Pro Tem Nora Williams Commissioner Charles "Sonny" McCoy Commissioner Murray Nelson Commissioner Dixie Spehar BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA BY Mayor/Chairperson (SEAL) DEPUTY CLERK ATTEST: DANNY K. KOLHAGE, CLERK Affordable Housing Monroe County Code Ordinance Page 8 of 8 . MEMORANDUM TO: The Board of County Commissioners FROM: The Planning and Environmental Resources Departments RE: Proposed Amendments to: The Affordable Housing Criteria in the Land Development Regulations section 9.5-122.3 (6), sections 9.5-266 (a)(3), 9.5-266 (a)(4), and 9.5-266 (a)(4) a.; deletion of sections 9.5-266 (a)(4) b., 9.5-266 (a)(4) d., 9.5-266 (a)(4) g. and 9.5-266 (a)(4) h.; creation of new sections 9.5-266 (a)(4) b., 9.5-266 (a)(5), and 9.5-266 (a)(6); and renumbering of and amendment to section 9.5-266 (a)(4) e. and section 9.5-266 (a)(4) d. DA TE: February 22, 2001 I. OVERVIEW The Planning Department, at the direction of the Board of County Commissioners, is proposing amendments to the current Land Development Regulations (LDR) to expand the eligibility criteria for qualifying for affordable housing ROGO allocations. The amendments include very low to median income households who do not meet the requirement of receiving at least 70 percent of their annual household earnings from employment in Monroe County. The Board of County Commissioners and the Planning Department are concerned that current affordable housing criteria do not provide opportunities for all our elderly and disabled population. II. BACKGROUND Section 9.5-4 (A-5) ofLDR establishes the income criterion for affordable housing. This criterion, which was amended last year, requires that affordable housing be only for occupancy by households that earn no more than the median household income for all households in Monroe County. This definition however, has no limitations on the derivation of this income. Section 9.5-122.3(6) [ROGO scoring criteria] and Section 9.5-122 (b)( 1) explicitly require that 70 percent of this earned income must be derived from employment in Monroe County. Commercial apartments, as defined by Section 9.5-4 (C-ll) and employee housing defined by Section 9.5-4 (E-l) are required to house only residents employed in Monroe County that meet the 70 percent rule. In addition, Section 9.5-266 requires that in order for a development to be recipient of incentives ("free" Transferable Development Rights (TDRs), ROGO points, 25 unit/acre density bonus in UR, and waiver of impact fees), it must be affordable housing for households that meet the 70 percent rule. It is fairly clear that the current regulations with the 70 percent rule, was based on a deliberate policy decision of the Board and the Planning Commission. When the affordable housing regulations were originally adopted, the intent was to limit their application to only residents employed in Monroe County. Affordable Housing Staff Report -soee Page 1 of3 This legislative intent, which was affirmed during last year's amendment process, reflected the policy that affordable housing should not be available to attract people to retire to the Keys, but to address the critical housing shortage for working households and service workers in the tourism industry. III. POLICY ANALYSIS The Board of County Commissioners, the Planning Commission, and the Planning Department are still concerned about the potential for affordable housing to attract people to retire here. However, they are even more concerned about the increasing need to assist our retiring elderly and disabled population. Any residency requirements to limit eligibility would also be legally suspect. The optimum solution to this pressing issue should balance both policy concerns about not providing incentives through the availability of affordable housing to encourage non-working residents to move to the Keys, with the need to make such housing available for disabled and retired elderly residents. This solution must be done in a manner that is both legally defensive and easy to administer and enforce. IV. PROPOSED APPROACH The Planning Department proposes a short and a longer-term approach: 1. Short Term. In the short-term, the existing regulations need to be amended to eliminate the "70" percent earnings requirement from the affordable housing criteria. However, the requirement for earning 70 percent of household income from employment in Monroe County, should still be retained for commercial apartments and employee housing. Although the 70 percent requirement can be supported for affordable housing designated for employees and commercial apartments, it can not be applied universally to all households that meet the income eligibility. Some of these households, particularly the disabled and retired elderly, may not be gainfully employed or make insufficient earnings within the County to meet this income requirement. To help limit the potential for attracting non-residents and promote affordable housing opportunities, the staff recommends the County entering into a Memorandum of Understanding with the Monroe County Housing Authority, as provided for under Section 9.5-122, to assign a specific number of affordable housing allocations to the Authority for its varied programs. This assignment to the Housing Authority will reduce the number of affordable housing allocations available for the general public, but will ensure these allocations are used primarily by County residents due to the backlog in demand for obtaining assistance under the Authority's programs. 2. Longer Term. As part of its current efforts to comprehensively revise LDR, the Planning Department intends to explore the option of further breaking down the affordable ROGO allocations into two categories: general and employee. This option would further reduce the possibility of affordable housing being used by non-residents and provide additional opportunities for employers to secure housing for their workers. In response to direction from the County Commission and in conjunction with the creation of a separate allocation category for employee housing, the staff intends to prepare amendments to LDR, and if necessary to the Comprehensive Plan. The amendments require new Affordable Housing Staff Report -BOCC Page 2 of3 commercial and transient residential development to provide housing for their employees. The linkage between employee housing and new commercial development is a significant one, especially with severe lack of affordable housing for the existing workforce. With the current moratoria on new commercial and transient residential development, it would be beneficial and prudent to prepare and enact such regulations prior to further resumption of any permitting of significant new commercial development. v. PLANNING COMMISSION RECOMMENDATION The Monroe County Planning Commission reviewed the request and based on the above discussions and the facts presented by Staff, recommended the approval of the proposed amendments to the Land Development Regulations. In addition, the Planning Commission supported the proposal that the Planning Department should: . work with Monroe County Housing Authority in preparing a Memorandum of Understanding for assignment of ROGO affordable housing allocations and; · prepare appropriate amendments to the Comprehensive Plan and the Land Development Regulations to establish two separate affordable ROGO housing categories (general and employee) and affordable housing linkage requirements for commercial development. Affordable Housing Staff Report -BOCC Page 3 of3 FINAL LDR TEXT AMENDMENTS AS THEY SHALL READ ORDINANCE NO. MONROE COUNTY CODE AMENDED SECTIONS AS THEY SHALL APPEAR AND READ 1. Section 9.5-122.3 (6) of the Land Development Regulations shall read as follows: Section 9.5-122.3 Evaluation criteria. (6) Affordable housing The following points are intended to increase the supply of affordable housing. Point Assignment Criteria +5 An application which proposes a dwelling unit which meets the definition of affordable housing and restricts the dwelling unit to a household with a gross annual income limit as defined in Section 9.5-4 (A-5). 2. Section 9.5-266 (a)(3) of the Land Development Regulations shall read as follows: Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (3) Before any certificate of occupancy may be issued for any structure, portion or phase of a projects subject to this section, restrictive covenant(s), limiting the required number of dwelling units to households meeting the income criteria described in paragraph (4) a. or (4) b. of this subsection running in favor of Monroe County and enforceable by the county, shall be filed in the official records of Monroe County. The covenant(s) shall be effective for twenty (20) years but shall not commence running until a certificate of occupancy has been issued by the building official for the dwelling unit or units to which the covenant or covenants apply. 3. Section 9.5-266 (a)(4) of the Land Development Regulations read as follows: Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: Affordable Housing Monroe County LOR Amendments Page 1 of 4 (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article, IV, the owner must ensure that: 4. Section 9.5-266 (a)(4) a. of the Land Development Regulations shall read as follows: Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: a. The use of the affordable housing dwelling unit is restricted to households that meet the adjusted gross annual income limits for median-income as defined in subsection 9.5-4 (A-5); and, 5. Section 9.5-266 (a)(4) b. of the Land Development Regulations shall be deleted. 6. Section 9.5-266 (a)(4) c. of the Land Development Regulations shall be deleted. 7. Section 9.5-266 (a)(4) d. of the Land Development Regulations shall be deleted. 8. New Section 9.5-266 (a)(4) b. of the Land Development Regulations shall be created and read as follows: b. If the affordable housing dwelling unit is designated for employee housing or commercial apartments, the use of the dwelling is restricted to households that derive at least seventy (70) percent of their household income from gainful employment in Monroe County; and meet the adjusted gross annual income limits for median-income as defined in subsection 9.5-4 (A-5); and 9. Section 9.5-266 (a)(4) c shall replace section 9.5(a) (4) e. of the Land Development Regulations and shall read as follows: Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: Affordable Housing Monroe County LDR Amendments Page 2 of 4 c. The use of the affordable housing dwelling unit is restricted for a period of at least twenty (20) years to households that meet the requirements of paragraph (4) a. or b. above; and, 10. New Sections 9.5-266 (a)(4) d. shall replace Section 9.5-266 (a)(4) 1. of the Land Development Regulations shall read as follows: Section 9.5-266. Affordable housing; employee housing. (a) Affordable housing: (4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article IV, the owner must ensure that: d. The size of an affordable housing dwelling unit shall be limited by a condition to be placed on the development permit which restricts the habitable space of the unit to a maximum of one thousand three hundred (1,300) square feet for a period of at least twenty (20) years. 11. Section 9.5-266 (a)(4) g. shall be deleted. 12. Section 9.5-266 (a)(4) h. shall be deleted. 13. New Section 9.5-266 (a)(5) of the Land Development Regulations shall read as follows: Section 9.5-266. Affordable housing; employee housing. Affordable housing: (5) The eligibility of a potential owner-occupier or renter of an affordable housing dwelling unit or an affordable housing dwelling unit designated as a commercial apartment or employee housing, shall be determined by the planning department as follows: a. At the time the potential owner either applies for affordable housing ROGO allocation, or applies to purchase a unit that utilized an affordable housing ROGO allocation; or b. At the time the potential renter applies to occupy a residential unit that utilized an affordable housing ROGO allocation. 14. Section 9.5-266 (a)(6) shall read as follows: Section 9.5-266. Affordable housing; employee housing. Affordable Housing Monroe County LOR Amendments Page 3 of 4 Affordable housing: (6) The planning department shall: a. Review the lease agreement for an affordable housing unit on an annual basis to ensure that the rent for the unit does not exceed the affordable rent standard for the unit pursuant to subsection 9.5-4(A-5); and, b. Review the lease agreement and letter of employment and/or occupation license of an occupant of a commercial apartment or employee housing on an annual basis to ensure that the occupant is gainfully employed in Monroe County. c. Review annual verification statement from business certifying that employee housing is occupied by employees meeting income criteria in subsection 9.5-266(a)(4) b. . Affordable Housing Monroe County LOR Amendments Page 4 of 4 . MEMORANDUM TO: The Planning Commission Hearing on December 11, 2000 FROM: The Planning and Environmental Resources Departments RE: Proposed Amendments to: The Affordable Housing Criteria in the Land Development Regulations section 9.5-122.3 (6), subsections 9.5-266 (a)(3), 9.5- 266 (a)(4), and 9.5-266 (a)(4) a.; removal of subsections 9.5-266 (a)(4) b. and d., and subsections 9.5-266 (a)(4) g. and h.; creation of new subsections 9.5-266 (a)(4) b., 9.5-266 (a)(5), and 9.5-266 (a)(6); and renumbering of and amendment to subsection 9.5-266 (a)(4) e. and d. DATE: November 28, 2000 I. OVERVIEW The Planning Department, at the direction of the Board of County Commissioners, is proposing amendments to the current Land Development Regulations (LDR) to expand the eligibility criteria for qualifying for affordable housing ROGO allocations. The amendments include very low to median income households who do not meet the requirement of receiving at least 70 percent of their annual household earnings from employment in Monroe County. The Board's intent is to not discriminate against the elderly and disabled. II. BACKGROUND Section 9.5-4 (A-5) ofLDR establishes the income criterion for affordable housing. This criterion, which was amended last year, requires that affordable housing be only for occupancy by households that earn no more than the median household income for all households in Monroe County. This definition however, has no limitations on the derivation of this income. Section 9.5-122.3(6) [ROGO scoring criteria] and Section 9.5-122 (b)(l) explicitly require that 70 percent of this earned income must be derived from employment in Monroe County. Commercial apartments, as defined by Section 9.5-4 (C-11) and employee housing defined by Section 9.5-4 (E-1) are required to house only residents employed in Monroe County that meet the 70 percent rule. In addition, Section 9.5-266 requires that in order for a development to be recipient of incentives ("free" Transferable Development Rights (TORs), ROGO points, 25 unit/acre density bonus in UR, and waiver of impact fees) that it must be affordable housing for households that meet the 70 percent rule. T A99054AffHsg Page 1 of7 It is fairly clear that the current regulations with the 70 percent rule, was based on a deliberate policy decision of the Board and the Planning Commission. When the affordable housing regulations were originally adopted, the intent was to limit their application to only residents employed in Monroe County. This legislative intent, which was affirmed during last year's amendment process, reflected the policy that affordable housing should not be available to attract people to retire to the Keys, but to address the critical housing shortage for working households and service workers in the tourism industry. In. POLICY ANALYSIS Although the County Commission still expresses concerns about the potential for affordable housing to attract people to retire here, it is even more concerned about the increasing need to assist our retiring elderly and disabled population. Legal issues have also been raised about the discriminatory effect of the requirement for being employed in Monroe County. Any residency requirements to limit eligibility would also be legally suspect. The optimum solution to this pressing issue should balance both policy concerns about not providing incentives through the availability of affordable housing to encourage non-working residents to move to the Keys, with the need to make such housing available for disabled and retired elderly residents. This solution must be done in a manner that is both legally defensive and easy to administer and enforce. IV. PROPOSED APPROACH The Planning Department proposes a short and a longer-term approach: 1. Short Term. In the short-term, the existing regulations need to be amended to eliminate the "70" percent earnings requirement from the affordable housing criteria. However, the requirement for earning 70 percent of household income from employment in Monroe County, should still be retained for commercial apartments and employee housing. Although the 70 percent requirement can be supported for affordable housing designated for employees and commercial apartments, it can not be applied universally to all households that meet the income eligibility. Some of these households, particularly the disabled and retired elderly, may not be gainfully employed or make insufficient earnings within the County to meet this income requirement. To help limit the potential for attracting non-residents and promote affordable housing opportunities, the staff recommends the County entering into a Memorandum of Understanding with the Monroe County Housing Authority, as provided for under Section 9.5-122, to assign a specific number of affordable housing allocations to the Authority for its varied programs. This assignment to the Housing Authority will reduce the number of affordable housing allocations available for the general public, but will ensure these allocations are used primarily by County residents due to the backlog in demand for obtaining assistance under the Authority's programs. 2. Longer Term. As part of its current efforts to comprehensively revise LDR, the Planning Department intends to explore the option of further breaking down the affordable ROGO allocations into two categories: general and employee. This option would further reduce the TA99054AffHsg Page 2 of7 possibility of affordable housing being used by non-residents and provide additional opportunities for employers to secure housing for their workers. In response to direction from the County Commission and in conjunction with the creation of a separate allocation category for employee housing, the staff intends to prepare amendments to LDR, and if necessary to the Comprehensive Plan. The amendments require new commercial and transient residential development to provide housing for their employees. The linkage between employee housing and new commercial development is a significant one, especially with severe lack of affordable housing for the existing workforce. With the current moratoria on new commercial and transient residential development, it would be beneficial and prudent to prepare and enact such regulations prior to further resumption of any permitting of significant new commercial development. v. ANALYSIS A. Proposed Amendments The following amendments to LDR are proposed in the short term: . Amend Section 9.5-122.3 (6) as follows: "(6) Affordable housing: The following points are intended to increase the supply of affordable housing. Point Assignment Criteria +5 An application which proposes a dwelling unit which meets the definition of affordable housing and restricts the dwelling unit to a household "'Ai_A with a gross annual income limit as defined in Section 9.5-4 (A-5). · Dari"ag at laagt ga"aRty (70) p~r_aRt 9f itg iR_Qma frsm gaiRfwl ampI9~'maRt iR MSRr9~ CSWR~'; 3RQ · EarRg aR iR_Qmi RS graatar tAaR SRa AWRQraQ (1 QO) par_aRt sf tAa maQiaR 3QjW[taQ grsgg aRRwal iR_sma fur AswgiAsIQg "'itRiR HSRrsa C9wRty fsr Ii pari9Q sf at laagt 1N'iR~' (20) ~" . Amend subsection 9.5-266 (a)(3) to read as follows: I "(3) Before any certificate of occupancy may be issued for any structure, portion or phase of a projects subject to this section, restrictive covenant(s), limiting the required number of dwelling units to households meeting the income criteria described in paragraph (4) a. or (4) b. - t:.... of this subsection W running in I Amendment clarifies existing language and makes its consistent with revisions made in paragraph (4). T A99054AffHsg Page 3 of7 favor of Monroe County and enforceable by the county, shall be filed in the official records of Monroe County. The covenant(s) shall be effective for twenty (20) years but shall not commence running until a certificate of occupancy has been issued by the building official for the dwelling unit or units to which the covenant or covenants apply." . Amend subsection 9.5-266 (a)(4) to read as follows:2 "(4) In order for the owner of a parcel of land to be entitled to the incentives outlined in this section, and division 1.5, article.m:, IV, the owner must ensure that"3 . Amend subsection 9.5-266 (a)(4) a. to read as follows: "a. The use of the affordable housing dwelling unit is restricted to households that QiriFi at lia~t ~i\'iAt:,' (70) pirQWAt ef tAwir A9w~wA9IQ iAQ9Hli fr9Hl gaiAfwl liHlpl9YHlliAt iA M9AI:9W CQWA!:3' meet the adjusted gross annual income limits for median-income as defined in subsection 9.5-4 (A-5); and" . Remove subsections 9.5-266 (a)(4) b., C., and d.4 "g. TAi paI:Qwl pI:9p9SliQ fer Qi'.'ilepmiRt 1~ gf EwffiQi'iRt aria aAQ QiHliA~i9AS t9 HlWit tAW gwlk I:igwlati9A~ ~wt gwt iA Qh'i!:i9A 4 9f tAi~ artiQli [siQtieA 9.S 2Kl it ~i'i.]; aAQ Q. TAli paI:Qil pI:9p9SiQ fer Qi\'ilepHliAt is gf ~wffiQiiRt aI:ia aRQ QiHliA~i9A tg HlWWt tAi rW'iwiriHliAts gf ~Aaptir 10J;) (i, Fl9riQa '\QHliAistrati\'i C9Qi, fer tAw iA[tallati9R gf aA 9R ~iti '.va~ti'J(atwr traatHliAt S)'~tiHl; aAQ Q. TAw pat:liJlil pt:9p9SiQ fQr Qli'.'ilepmiAt i~ ~wn'wQ by aQi'iwati pwgliQ faQiliti'is iA aQQ9I:QaRQi "'itA ~wQtigA 9 S 292; aAQ " . Create new subsection 9.5-266 (a)(4) b. that reads as follows: "b. If the affordable housing dwelling unit is designated for employee housing or commercial apartments, the use of the dwelling is restricted to households that derive at least seventy (70) percent of their household income from gainful employment in Monroe County; and meet the adjusted gross annual income limits for median-income as defined in subsection 9.5-4 (A-5); and" . Renumber and amend subsections 9.5-266 (a)(4) e. and d. to read as follows: 2 Corrects scrivener's error. 3 Corrects scrivener's error. 4 Superfluous language; provision is required for all permitted development. T A99054A ffHsg Page 4 of7 "8C. The use of the affordable housing dwelling unit is restricted for a period of at least twenty (20) years to households V'itl:l aR iRQQHla RQ graat~r tl:laR QRa l:lwRQriQ (100) pirQiRt ef tl:li aQjwliitiQ grQliig aRRwal iRQQ~i fer l:lQwgil:lelQg "'itl:liR MQRrQi CQWR~'; that meet the requirements of paragraph (4) a. or b. above; and ;:.d. The size of an affordable rilEisiRtial housing dwelling unit shall be limited by a condition to be placed on the development permit which restricts the habitable space of the unit to a maximum of one thousand three hundred (1,300) square feet for a period of at least twenty (20) year~" . Remove subsections 9.5-266 (a)(4) g. and h. "g. Tl:lil iligibili~' ef a PQtiRtial g"'Rir QQ~wpiir Qf aR aff9rQabl~ l:lQwgiRg riEisiRtial Q"'illiRg WRit dull bi QitinRiRiQ by tAil plaRRiRg sipart~~Rt at tl:li ti~i a PQtiRtial Q"'Ailr iitl:l~r appliiE fur aR aff9rQabli l:lQwgiRg rilEiQiRtial ROGO allQQatiQR, Qr appliiE tQ pWrQl:laE~ a WRit tl:lat WtiliZiQ aR affursabli I:tQWliiiRg ROGO alh~QatieR WRit tQ sitiFJRiRi if tAi appliQaRt ~iitE tl:li afferQabili~' QritiriaaE SiHRiQ b~' [Eyb]EiQtiQR 9.$ 4(.^. $). h. Tl:li iligibility Qf a PQtiRtial riRtir ef aR aff9rsabli l:lewEiRg riEiQiRtial sn'illiRg wRit El:lall ba sat~FJRiRis by tl:li plaRRiRg sipart~aRt at tl:la ti~e tl:ti petiRtial raRtir appliiE tg eQQWpy a riEisiRtial sn'~lliRg WRit tl:lat wtiliziQ aR affeTQabla l:leuEiRg riliiiQiRtial R aGO alleQatieR pwrliiwaRt tg [Ewb]Iii~QtieR 9.$ 4(.^. $). Tl:li plaRRiRg Sipar-t~iRt will ra"ii'" tl:li liagj agri~~iRt fQr tl:li WRit eR aR aRRwal baliiig te iREwri tAat tl:li riRt f9r tl:li WRit QeiE Ret iXQiiQ tl:l~ aff9rsabli riRt EtaRQaFQ f9r tl:l~ WRit pWFEwaRt tQ [Ewb]EiQtiQR[g] 95 4(.^. $) aRQ 9.$ 2(;(;. " . Create new subsection 9.5-266 (a)(5) that reads as follows: "(5) The eligibility of a potential owner-occupier or renter of an affordable housing dwelling unit or an affordable housing dwelling unit designated as a commercial apartment or employee housing, shall be determined by the planning department as follows: a. At the time the potential owner either applies for affordable housing ROGO allocation, or applies to purchase a unit that utilized an affordable housing ROGO allocation; or b. At the time the potential renter applies to occupy a residential unit that utilized an affordable housing ROGO allocation." . Create new subsection 9.5-266 (a)(6) that reads as follows:5 5 This new subsection incorporates original language from subsection 9.5-266 (a)(4) h. T A99054AffHsg Page 5 of7 "(6) The planning departmentwiU shall: a. Review the lease agreement for ~ an affordable housing unit on an annual basis to ensure that the rent for the unit does not exceed the affordable rent standard for the unit pursuant to subsection 9.5-4(A-5); and, b. Review the lease agreement and letter of employment and/or occupation license of an occupant of a commercial apartment or employee housing on an annual basis to ensure that the occupant is gainfully employed in Monroe County. c. B. Consistency with Chapter 380 The Planning Department staff finds that the proposed amendments are consistent with the "Principles for Guiding Development" of Section 380.0552, Florida Statutes, in that they make "available adequate affordable housing for all sectors of the population of the Florida Keys" by reducing the barriers for affordable housing eligibility to the elderly and disabled. C. Consistency with the 2010 Comprehensive Plan The Planning Department staff finds that the proposed amendments are consistent with the objectives and policies of the Monroe County Comprehensive Plan in that they: . Implement the intent of Goal 601 by improving access to affordable housing for all future and current residents. . Further Policy 601.4.3 by expanding affordable housing opportunities for the elderly. VI. RECOMMENDATION Based on the above discussions and the facts presented, the Planning Department recommends the approval of the proposed amendments to sections 9.5-122.3 (6) and 9.5-266 of the Land Development Regulations. In addition, the Planning Department proposes that the Development Review Committee recommend the Planning Commission to request the staffto: . work with Monroe County Housing Authority in preparing a Memorandum of Understanding for assignment of ROGO affordable housing allocations and; 6 This amendment reflects that employee housing is for persons employed by the business located on the property in question unlike commercial apartments, which may contain persons employed off property. Therefore, the amount of documentation to certify its use for affordable housing should not be as rigorous. T A99054AffHsg Page 6 of7 . work on preparing appropriate amendments to the Comprehensive Plan and the Land Development Regulations to establish two separate affordable ROGO housing categories (general and employee) and affordable housing linkage requirements for commercial development. TA99054AffHsg Page 7 of7 PLANNING COMMISSION RESOLUTION ". "' PLANNING COMMISSION RESOLtmON NO. P8O-OO A RESOLUTION BY THE MONROE COUNTY PLANNING COMMISSION RECOMMENDING APPROVAL TO THE MONROE COUNTY BOARD OF COUNTY COMMISSIONERS OF THE REQUEST BY THE MONROE COUNTY PLANNING DEPARTMENT FOR AN AMENDMENT TO: THE AFFORDABLE HOUSING CRITERIA IN THE LAND DEVELOPMENT REGULATIONS SECI10N 9.5-122.3 (6), SUBSECI10NS 9.5-266 (a)(3), 9.5-266 (a)(4), AND 9.5-266 (a)(4) a.; REMOVAL OF SUBSEcrIONS 9.5-266 (a)(4) b. AND d., AND SUBSEcrIONS 9.5- 266 (a)(4) g. AND h.; CREATION OF NEW SUBSEcrIONS 9.5-266 (a)(4) b., 9.5-266 (a)(5), AND 9.5-266 (a)(6); AND RENUMBERING OF AND AMENDMENT TO SUBSECfION 9.5-266 (a)(4) e. AND d. WHEREAS, the Monroe County Planning Commission, during a regular meeting held on December 11,2000. conducted a review and consideration of an amendment to Section 9.5-122.3 (6), subsections 9.5-266 (a)(3), 9.5-266 (a)(4), and 9.5-266 (a)(4) a.; removal of subsections 9.5-266 (a)(4) b. and d., and subsections 9.5-266 (a)(4) g. and h.; creation of new subsections 9.5-266 (a)(4) b., 9.5-266 (a)(5), and 9.5-266 (a)(6); and renumbering of and amendment to subsection 9.5-266 (a)(4) e. and d. of the Monroe County Land Development Regulations to expand the eligibility criteria for qualifying for affordable housing ROGO allocations; and WHEREAS, the Planning Commission examined the following information: 1. The staff repon prepared by Aref 10ulani, Planner, dated November 28, 2000; and 2. Comments made by the Planning Commission; and 3. Comments made by the members of public; and ''''~EREAS, the Planning Commission made the following Finding of Facts and Conclusions of Law: 1. Based on Section 9.5-511 of the Monroe County Code (MCC), we find that the Board of County Commissioners may consider a text amendment to the Land Development Regulations if at least one of the six criteria is met. Section 9.5-4 (A-5) of LOR establishes the income criterion for affordable housing. It requires that affordable housing be only for occupancy by households that earn no more than the median household income for all households in Monroe County. Section 9.5-122.3(6) [ROGO scoring criteria] and Section 9.5-122 (b)( 1) explicitly require that 70 percent of this earned income must be derived from employment in Monroe County. The Board of County Commissioners and the Planning Oepanment are concerned that current affordable housing criteria in LOR does not provide opponunities for our elderly and disabled population who meet the income criteria for affordable housing. Therefore, we conclude that the proposed text amendment to eliminate the "70" percent earnings requIrement irom the affordable housmg cmena, anci to e -. tisn Page 10f2 P80AffHsgCrit Init' "70" percent earning of household income from employment in Monroe County for commercial apartments and employee housing, is consistent with the requirement enumerated in section 9.5-5 11 {5Xd)b. (iv) (New Issues) of the Monroe County Code. 2. Based on Goal 601 of the Monroe County Year 2010 ComDrehensive Plan, we find that the County shall improve access to affordable housing for all current and future residents. In addition. based on Policy 601.4.3 of the Monroe County Year 2010 Conmrehensive Plan. we find that the county shall expand affordable housing opponunities for the elderly. Therefore. we conclude that the proposed text amendment is consistent with and funhers the goals of the Monroe County Year 20 I 0 Comprehensive Plan. NOW THEREFORE, BE IT RESOLVED ,BY THE PLANNING COMMISSION OF MONROE COUNTY, FLORIDA, that the preceding Findings of Facts and Conclusions of Law. suppon their decision to RECOMMEND APPROV AL to the Board of County Commissioners of the request filed by the Monroe County Planning Dcpanment for amendments to Sections 9.S-122.3 (6) and 9.5-266 of the Monroe County Land Development Regulations concerning the eligibility criteria for qualifying for affordable. commercial. and employee housing. PASSED AND ADOPTED by the Planning Commission of Monroe County. Florida at a regular meeting held on the 11111 day of Decemoer .Woo. Chair Mapes Commissioner Werling Commissioner Marr Commissioner Hill ~ ~ YES YES By nfh Signed thi~ day 0 ( n Mapes. Chair (\ ~'0 . 2000. APPROVED AS TO FORM I AND LEG BY P80AftHsgCrit Page 2 0(2 Initials