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Most QAPs establish a point system for
<br />scoring potential LIHTC projects, and due
<br />to the highly competitive nature of LIHTC
<br />awards, every point counts. Most states
<br />allocate anywhere from to to 20 percent of
<br />total points for satisfying measures of loca-
<br />tion efficiency (e.g., proximity to community
<br />assets and positive land uses). These points
<br />can mean the difference between a funded
<br />project and an unviable one. Furthermore,
<br />some states deduct points from applications
<br />that are in proximity to undesirable land
<br />uses. For example, in New Jersey, large fam-
<br />ily projects in transit -oriented developments
<br />earn five points, but projects within a mile of
<br />undesirable land uses (e.g., landfills, dumps,
<br />superfund sites, etc.) lose three points.
<br />Common Zoning Barriers to LIHTC Projects
<br />Despite increasing housing affordability
<br />and social inequity issues, many communi-
<br />ties have zoning codes that act as barriers
<br />to LIHTC projects. The largest, and per-
<br />haps most common, zoning barrier is the
<br />geographically extensive application of low -
<br />density residential zoning districts. That is,
<br />many communities only permit multifamily
<br />residential development in a small number of
<br />zoning districts, mapped to a small percent-
<br />age of the jurisdiction's total area. Given
<br />that most affordable housing development
<br />depends on economies of scale for viability,
<br />this practice severely constrains LIHTC proj-
<br />ect opportunities, even before considering
<br />any location -efficiency factors.
<br />Similarly, the dimensional standards
<br />and density limits in many zoning districts
<br />that permit multifamily development make
<br />LIHTC projects infeasible. Minimum set-
<br />backs, maximum heights, and maximum
<br />residential density standards all affect the
<br />per -unit cost of development. Holding all
<br />other factors equal, the lower the density,
<br />the higher the per -unit cost of development.
<br />The same idea applies to zoning codes
<br />that require the same amount of off-street
<br />parking per dwelling unit, regardless of com-
<br />munity context or project characteristics.
<br />The more required parking, the higher the
<br />per -unit cost of development. LIHTC projects
<br />often generate less parking demand than
<br />comparable market -rate projects. Accord-
<br />ing to the 2009 National Household Travel
<br />Survey, low-income households own fewer
<br />automobiles per capita than moderate -
<br />income households, and a higher percentage
<br />of low-income households rely on public
<br />transit for transportation (FHWA n.d.).
<br />Beyond this, zoning often poses addi-
<br />tional barriers to siting LIHTC projects in
<br />locations that satisfy location -efficiency
<br />measures. In most communities, high loca-
<br />tion -efficiency areas are typically downtowns
<br />and neighborhood centers. However, many
<br />zoning codes either prohibit residences in
<br />these predominantly commercial areas or
<br />require vertical mixed use development, with
<br />ground -floor commercial space, which com-
<br />plicates project financing and management.
<br />Additionally, many zoning codes have
<br />single -use zoning districts where land
<br />uses that help satisfy location -efficiency
<br />measures, such as supermarkets, pharma-
<br />cies, farmers markets, and libraries, are far
<br />removed from residential districts. Isolated
<br />shopping centers along major highways con-
<br />tain many "QAP points" that cannot be used.
<br />Many suburban communities have
<br />mapped exclusively single-family zoning
<br />districts in close proximity to highly ranked
<br />schools. This is in spite of the fact that
<br />many states, including California, Texas,
<br />and New Jersey, award extra QAP points to
<br />developments in catchment zones of high -
<br />performing schools. If not for limitations
<br />of very low -density zoning, many of these
<br />districts would be prime areas for LIHTC proj-
<br />ects. Communities concerned about LIHTC
<br />housing impacts to school districts should
<br />balance the impact on test scores with
<br />life -changing opportunities provided to low-
<br />income students. Communities concerned
<br />about LIHTC housing impacts to property
<br />values can review many recent studies
<br />(backed by empirical data) that show little to
<br />no negative impact —despite common mis-
<br />conceptions.
<br />LIHTC FRIENDLY ZONING
<br />While zoning barriers to LIHTC projects are
<br />prevalent, the good news is that there are
<br />several conceptually simple fixes. These
<br />include strategic upzoning, special-purpose
<br />zoning districts or overlays, and zoning
<br />incentives or flexible standards for LIHTC-
<br />eligible projects.
<br />StrategicUpzoning
<br />Given the strong correlation between per-
<br />missible residential density and the per -unit
<br />costs of residential development, perhaps
<br />the most meaningful fix that communities
<br />can enact is strategic upzoning of areas that
<br />are rich in assets. Review the location factors
<br />in your state's QAP, and look for opportuni-
<br />ties to increase the permissible residential
<br />density in zoning districts that permit or are
<br />proximate to land uses that contribute to
<br />location efficiency. These are typically down-
<br />towns, neighborhood centers, and major
<br />corridors. They may also be residential areas
<br />surrounding schools or near parks.
<br />ZONINGPRACTICE 9.17
<br />AMERICAN PLANNING ASSOCIATION I Page 5
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