A TERNER CENTER REPORT - MARCH 2020 The Costs Of Affordable Housing .

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A TERNER CENTER REPORT - MARCH 2020The Costs of AffordableHousing Production:Insights from California’s9% Low-Income HousingTax Credit ProgramAUTHOR:CAROLINA REIDRESEARCH TEAM:ADRIAN NAPOLITANOBEATRIZ STAMBUK-TORRESCopyright 2020 Terner Center for Housing InnovationFor more information on the Terner Center, see our website atwww.ternercenter.berkeley.edu

A TERNER CENTER REPORT - MARCH 2020IntroductionIn February of 2016, California’s LegislativeAnalyst’s Office (LAO) reported thatCalifornia’s shortfall of subsidized housingunits—affordable to those who earn 80 percentor less of the median income where they live—was about 1.7 million housing units.1 The LAOestimated that closing this shortfall throughnew construction would cost in excess of 250billion in public subsidies, though the reportalso noted: “There is a good chance the actualcost could be higher.”That caveat now seems prescient. Between2016 and 2019, the costs to develop a newaffordable unit under the Low-IncomeHousing Tax Credit (LIHTC) program haveincreased from 425,000 per unit to morethan 480,000 per unit, an increase of 13percent in just four years (after accountingfor inflation). Costs per square foot haveincreased by 30 percent over the same timeperiod, reaching 700 per square foot in 2019.A report by the federal Government Accountability Office (GAO) found that average development costs for new LIHTC projects in California were the highest in the nation, eclipsingthose in New York City.2These escalating costs represent a significantchallenge to a state struggling with an affordable housing crisis, and erode the impact ofthe increased public subsidies directed towardbuilding new housing. Understanding why itcosts so much to build new housing can helpto identify opportunities for the state andlocalities to bring down the price of development. In this brief, we analyze the factorsthat influenced total development costs fornew construction projects that were awarded9% tax credits through the LIHTC programbetween 2008 and 2019. We also intervieweddevelopers and general contractors to betterunderstand the mechanisms contributing tothese cost increases. While the 9% LIHTCprogram represents only one of the ways thatsubsidized housing is built in California, thedata collected through the application processprovide valuable insights into the factors thatinfluence development costs.The research shows that hard constructioncosts—specifically the costs of materialand labor—are the primary driver of risingdevelopment costs. The shortage in theconstruction labor market and higherprices for general contractors (as well asthe subcontractors they hire) is affectingaffordable housing development—just as thisshortage impacts market-rate development.The research also highlights the importanceof other costs, including local developmentfees, lengthy entitlement processes, parkingrequirements, prevailing wages or local hirerequirements, and state and local designThis report is part of the Terner Center’s The Cost of Building Housing Research Series,which examines the different cost factors that layer together to comprise the total coststo build housing in California. Accompanying this report, we have also released The HardCosts of Construction: Recent Trends in Labor and Material Costs for Apartment Buildingsin California, which looks specifically at the factors influencing hard construction costsin both market and affordable developments. Previous studies include Making It Pencil:The Math Behind Housing Development, in which we outline how land costs, constructioncosts, local fees, and financing costs all contribute to the total development cost for ahousing project. In our work on impact fees and development fees, we found that waningtax revenue and the loss of state and federal funding for infrastructure resulted in risinglocal exactions on new housing. And in Perspectives: Practitioners Weigh in on Driversof Rising Housing Construction Costs in San Francisco, we examined the ways in whichlengthy permitting processes as well as local regulations and requirements can increasethe cost of both market-rate and affordable housing projects.2

A TERNER CENTER REPORT - MARCH 2020regulations (including those that require moresustainable building techniques). In otherwords, affordable housing development is notimmune to the same cost drivers pushing upthe costs of market-rate developments, norto all the ways building in California is moreexpensive than in other states. However,the research also highlights that affordablehousing developers face a cost that market-ratedevelopers don’t: the increased complexity infinancing affordable projects and the need tomanage multiple funding sources that addrequirements and delays to every project.The report proceeds as follows. First, wedescribe the data and methodology used inthis report. Second, we present findings fromthe descriptive analysis, interweaving thequantitative and qualitative data to describethe factors that contribute to affordablehousing development costs. We then presenta multivariate regression model that allowsus to assess which factors have a significanteffect on costs, controlling for differencesin project type and location. Developmentcosts are influenced by what is being builtand where—for example, an infill projectwith 10 stories and underground parking inSan Francisco will face different costs than alow-rise building with surface parking in theCentral Valley. A regression model allows usto control for those differences and identifythe cost drivers more precisely. We concludewith policy recommendations as well as adiscussion of the limitations of the currentanalysis. The solutions are not straightforward,and ultimately require additional data andresearch on development costs as well asapproaches to cost containment that do notforgo the mission of providing high-qualityaffordable housing.MethodologyThis paper focuses on affordable housingbuilt with Low-Income Housing Tax Credit(LIHTC) financing. Since 1986, the LIHTCprogram has been the most important sourceof funding for the construction of affordablehousing. In California, more than 225,000new units have been funded under the LIHTCprogram; our research has shown that theprogram contributes significantly to thedevelopment of high-quality properties thatpromote housing stability and economic security for low-income families.3This paper focuses on new construction projects that were awarded 9% tax credits throughthe LIHTC program between 2008 and 2019.4The 9% LIHTC program represents only aslice of the affordable housing units builtin California: LIHTC also includes a 4% taxcredit program, and subsidized housing canalso be funded through federal or state grantsor through local inclusionary programs. Thismeans that the results presented here may notapply to all affordable housing developments.However, California’s Tax Credit AllocationCommittee (TCAC) makes data on 9% projectspublicly available, providing an opportunityto study what is influencing the costs of theseprojects. To collect the data, the Terner Centerfiltered through and entered data by hand for724 projects.5 The data primarily come fromsubmitted tax credit applications, includingthe information provided in the overviewsection of the application, the Sources andUses table—which provides detailed data onthe sources of funding and cost line items—andthe claimed Basis Boosts.6 We cross-checkedthese data against TCAC staff reports on eachindividual project. If there was a discrepancy3

A TERNER CENTER REPORT - MARCH 2020between the information presented in theapplication and in the staff report, we deferredto the data in the staff report. However, it isimportant to note that these data reflect thedeveloper’s estimates of project costs at timeof application, and not the final costs afterthe development is completed. As a result,the data in this report should be consideredconservative estimates of the total costs ofdevelopment.7The resulting dataset includes 678 newconstruction projects awarded 9% tax creditfunding between 2008 and 2019.8 Table1 presents general information about thesample. Approximately 60 percent of thesample constitutes projects designed forfamilies, and the majority (70 percent) arebetween 40 and 100 units. Approximately30 percent of the projects are located in LosAngeles, but the sample includes projectsacross all of California’s regions, as well asacross all of the years in the sample.Table 1 also shows the distribution ofproject characteristics that could influencedevelopment costs, including amenities likestructured parking9 or an elevator. Nearly 60percent of projects included a requirementthat contractors pay prevailing wage, 70percent were assessed local developmentfees, and almost half included some formof sustainable building techniques, such asenergy or water conservation measures orthe use of natural materials. More than threequarters of projects included at least fourseparate sources of funding.We also find that more than half (59 percent)of the projects in our sample are sited in either“High Segregation & Poverty” or “Low-Resource” neighborhoods. These designationsare based on the 2018 amendments to California’s Qualified Allocation Plan (QAP)—thepolicy document that guides state requirements and guidelines for tax credit projects—and are designed to encourage more development in higher-resource communities.10TCAC’s decision to incentivize building inhigher-resourced neighborhoods is alignedwith research that increasingly points to thenegative effects of living in neighborhoodscharacterized by high levels of segregation andpoverty, particularly for children.11In addition to the quantitative data analysis,we interviewed 13 affordable housingdevelopers and general contractors in orderto better understand the results of thequantitative analysis. Interviews includedquestions about a) the changing context foraffordable housing development in the state,b) the biggest contributors to costs from therespondents’ perspective, c) the factors thatthey felt put up the greatest barriers to costcontainment, and d) the approaches they and/or policymakers have taken to bring down thecosts of development. Each of the interviewswas transcribed and coded to identify commonthemes from across all 13 respondents.4

A TERNER CENTER REPORT - MARCH 2020Table 1: Descriptive Statistics, LIHTC 9% New Construction Projects, 2008 - 2019Project TypeProject CharacteristicsLarge Family412Prevailing Wage59.8%Senior126Development Fees69.5%Special Needs/SRO140Sustainable Construction41.8%Structured Parking32.1%39.2%Number of UnitsSmall (Less than 40 units)155ElevatorMedium (40-100 units)448Number of Funding SourcesLarge (More than 100 units)50Regional DistributionLess than 411.5%4 to 879.9%Capital North39More than 8Central Coast71Year of Project AwardCentral Valley93200829Inland Empire55200952191201061North and East Bay56201178Orange41201264Rural32201353San Diego54201465San Francisco12201561South and West Bay34201659201754Los AngelesNeighborhood Opportunity Ranking8.6%Highest Resource10.1%201855High Resource11.1%201947Moderate Resource19.4%Total ProjectsLow Resource31.2%High Segregation & Poverty27.9%6785

A TERNER CENTER REPORT - MARCH 2020General Trends inAffordable HousingDevelopment CostsIn this section, we present the results of thedescriptive analysis, discussing the major costdrivers that have led to significant increases inaverage LIHTC development costs over time.In all of these analyses, we adjust costs forinflation to 2019 dollars using the Bureau ofLabor Statistics’ national CPI index for urbanconsumers. We also present the costs adjustedby unit and by square feet, since these twometrics present slightly different results (asunits have generally gotten smaller over time).Total development costs have risendramatically since 2008.Several studies in recent years have pointedto the high and rising costs of LIHTCdevelopment in California; our analysis showsthat this trend continues unabated. Figure 1presents data on total development costs from2008 and 2019, adjusted for inflation andaveraged by the cost per unit and the cost persquare foot. Since 2008, the average cost perunit of 9% LIHTC new construction increasedfrom 411,000 to 480,000, an increase ofover 17 percent. The cost per square foot hasrisen even more dramatically, from 451 persquare foot in 2008 to 700 per square footin 2019, an increase of 55 percent. (In part,the difference in these two measures relate towhat is being developed: in recent years, thenumber of square feet per unit has gone down,as has the number of bedrooms per unit.)This increase in costs has material consequences for the supply of new affordablehousing—in broad terms, the same amountof public subsidy is now needed to build twounits at 1,000 square feet as was needed forthree units just 10 years ago.Figure 1: Total Development Costs, LIHTC 9% New Construction Projects, 2008 - 201983.2%600,000800Cost Per Unit ( ost Per Square Foot ( 2019)700500,0001002008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019Cost Per Unit0Cost Per Square FootSource: Terner Center Analysis of TCAC 9% LIHTC Project Applications. All figures adjusted for inflation.6

A TERNER CENTER REPORT - MARCH 2020Total development costs vary substantially by region, and are most expensivein California’s San Francisco Bay Area.The statewide average in developmentcosts obscures significant regional variation(Figure 2). Projects in San Francisco costsignificantly more than in any other part ofthe state, averaging 1,100 per square foot forall projects built between 2008 and 2019. Incontrast, projects in the Central Valley costapproximately 330 per square foot. However,even in the Central Valley, development costsare still higher than the national average—while comparable data are hard to comeby, between 2013 and 2017, multifamilydevelopments nationally cost between 148and 233 per square foot to build.12In Figure 3, we present broader regionaltrends over time, grouping project awards into3-year intervals that follow broader economictrends.13 All the regions experienced a declinein total development costs during the 20112013 time period, reflecting the economicrecession and housing market slowdown inCalifornia. Since then, however, costs haveonly escalated. Statewide, developmentcosts per unit have increased 12.6 percentfrom 2008-2010 to 2017-2019. Projects inthe greater San Francisco Bay Area—whichincludes Oakland and San Jose—increasedby 22.4 percent to an average of almost 600,000 per unit in the past three years.While lower than the rest of the state, inlandareas (including the Central Valley, InlandEmpire, and rural TCAC regions) experiencedthe greatest percent increase in developmentcosts since the recession. Projects in thesegeographies saw a 30 percent increase from2008-2010 to 2017-2019.Figure 2: Average 9% LIHTC Development Costs Per Square Foot by TCAC Region, 2008-20191,4001,2001,000800600400200-Source: Terner Center Analysis of TCAC 9% LIHTC Project Applications. All figures adjusted for inflation. Data are presented by square foot in partto account for differences in unit size across regions.7

A TERNER CENTER REPORT - MARCH 2020Figure 3: Regional Differences in Total Development Costs Per Unit Over TimeTotal Development Costs Per Unit ( atewideBay Area2008-20102011-2013Inland2014-2016Southern California2017-2019Source: Terner Center Analysis of TCAC 9% LIHTC Project Applications. All figures adjusted for inflation.The main driver of these increases ishard construction costs.Total development costs are made up of alot of different line items, including landor property acquisition costs, constructioncosts, architectural/engineering costs, localdevelopment fees, as well as fees associatedwith the “soft” costs of development (e.g., legalfees, appraisals, and insurance). In Figure 4,we compare the change in land costs with thechange in hard construction costs over time.Although reporting of land costs can varyacross LIHTC projects (since some projectsrely on donated land and don’t always includethe full amount of what that land would costat market valuation), in general, the reportedcosts of land acquisition has remained largelyflat since the end of the recession.In contrast, hard construction costs haveincreased by 40 percent since 2012. Interviewsfurther emphasized the role of construction indriving the upward trend in costs; developersconsistently pointed to the bids coming fromtheir general contractors as the key factorcontributing to cost increases. One affordablehousing developer who works largely in theBay Area shared that “when I look at all thelines of a pro forma, what has changed mostdramatically is the pricing that is coming fromthe general contractor. Prices have increasednearly 50 percent in terms of the dollars persquare foot in the past few years. I don’t thinkthat we are designing buildings that look oroperate much differently. It’s the materialsand labor costs coming from the contractingend that have changed.”As we discuss in more detail in the report TheHard Costs of Construction: Recent Trends inLabor and Material Costs for Apartment Buildings in California, it is hard to disentangle therelative contribution of labor versus materialson hard construction costs. For example, acontractor will generally provide a bid sheetwith just the total amount it will cost to installthe drywall or electrical work on a project.This bid sheet rarely itemizes the share ofthe costs that are going to labor. Interviews8

A TERNER CENTER REPORT - MARCH 2020Figure 4: Trends in Hard Construction and Land Acquisition Costs, California 9% LIHTC Projects, 2008 - 2019300,000Cost Per Unit ( 1020112012Construction Costswith general contractors suggested that bothfactors play a role– with tariff battles contributing to increased material costs for lumberand metal—but emphasized that the bulk ofthe rising costs was coming from labor. Figure5 displays trends in general contractor wagesbetween 2008 and 2018 for Los Angeles, SanFrancisco, and California—while increaseshave been most dramatic in San Francisco,wages overall have increased faster than thecost of inflation.The role of wages in driving cost increases isnot unique to affordable housing development.Since the recession, there has been asignificant mismatch between the number ofpermitted units—increasing more than 430percent between 2009 and 2018—and thegrowth in the construction sector, where thenumber of workers has only expanded by 32percent.14 General contractors noted thatanti-immigration rhetoric, as well as a tightlabor market overall, has made it hard to findconstruction workers, let alone workers withmore multifamily construction experienceand/or those trained in the specific n CostsPrevailing wage requirements areassociated with higher averagedevelopment costs.In addition to the general labor marketshortage driving up wage costs, affordablehousing developments are also often requiredto pay prevailing wages. Prevailing wages aredetermined by the California Department ofIndustrial Relations, and are usually basedon rates specified in collective bargainingagreements. Although the LIHTC programdoes not trigger prevailing wage requirements,LIHTC projects often layer other forms ofpublic funding that do require either federalor state prevailing wage, or they may besubject to local project labor agreements fortheir construction contracting.15Approximately 60 percent of LIHTC projectsawarded funds between 2008 and 2019 weresubject to either prevailing wage or localproject labor agreements, or both. Prevailingwages tend to be higher than the “openshop” or non-union wages in local markets,though it can depend on the county and the9

A TERNER CENTER REPORT - MARCH 2020Figure 5: Average Annual Wages for Residential Multi-Family General Contractors, 2008 - 2018 160,000 140,000Annual Wages ( 2018) 120,000 100,000 80,000 60,000 40,000 20,000 -2008200920102011Statewide20122013Los Angeles20142015201620172018San FranciscoSource: U.S. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, General Contractors, Multifamily Residential Construction,available online at https://www.bls.gov/cew/. Wages adjusted for inflation.Figure 6: Trends in Total Development Costs Per Unit in California, by Prevailing Wage, 2008 - 2019600,000Cost Per Unit ( 01020112012Prevailing Wage2013201420152016201720182019Not Prevailing Wage10

A TERNER CENTER REPORT - MARCH 2020specific trade classification. Because of thesehigher wage rates, the LIHTC program allowsdevelopers to claim a 20 percent increase ontheir development cost limits if the projectincludes prevailing wage requirements.Figure 6 shows that prevailing wage cost morethan non-prevailing wage projects, thoughthe difference between these two types ofprojects varies over time. For example, in2016 and 2017, the gap between prevailingand non-prevailing wage projects narrowed,in part because open shop construction wageshad risen substantially (in part due to theshortage of construction labor).The gap between market and prevailing wagesalso varies by region. In the Sacramentoregion, for example, prevailing wage projectsin our sample were 36.4% more expensivethan those without prevailing wage, and in theCentral Valley, the gap was 27.5%. In contrast,in cities like San Francisco, San Jose, and LosAngeles, which have a larger union presenceand higher open shop wages overall, the gapwas only around 10 percent.Prevailing wages increase the cost ofdevelopment for a number of reasons.Besides paying higher wage rates, prevailingwages trigger additional requirements suchas payroll certification that can add to costs.Interviews consistently highlighted that whilethe higher wages accounted for some of theincreased costs, the additional “paperworkand bureaucracy” associated with prevailingwage increases soft costs and may also preventcontractors from taking on a prevailing wageproject when demand for labor is strong. Forexample, contractors who want to take on astate prevailing wage job need to register withthe Department of Industrial Relations, whichexceeds the requirements under the federalrules set forward in the Davis-Bacon Act.Several developers noted that when “there isa shortage of workers with prevailing wage,you’re probably cutting your vendor pool in halfby having a prevailing wage project. Because iften guys would bid a project, you’re probablygoing to only get 5 that would bid a prevailingwage project.” Other developers similarlynoted that affordable housing developers areoften selecting from a “smaller pool of generaland subcontractors because of the prevailingwage or project labor agreement requirementsand all the ‘headache’ and paperwork thatcomes with that.”The challenges of finding constructionworkers in a tight labor market can beexacerbated when the project also includeslocal hiring requirements, such as recruitingfrom small or minority-owned businesses.These requirements are considered acondition of using public subsidy, but theyincrease developer costs. An affordablehousing developer that builds in multiplestates explained, “[Local hire] is what I meantwhen I said an affordable unit needs to satisfya lot of policy goals. And they are good goals.But on the implementation end, it does causethese unforeseen situations with limiting thelabor pool. Let’s say there’s 4 to 5 affordablehousing developers and we’ve all been fundedwith A1 measure funding,16 and we all breakground pretty much at the same time. So ifyou’re looking for framers, there are only somany small local framers, minority-owned it’s just very difficult to check all the boxes.”11

A TERNER CENTER REPORT - MARCH 2020General contractors also noted that they canalso run into difficulties on prevailing wageprojects when government agencies don’tapprove payments, which means that theyprefer to select non-prevailing wage jobs. Onesaid: “The city or county that is funding partof the project has labor compliance on staff,and they won’t approve the release of fundsfor that monthly pay application until all thelabor requirements are met. So what happensis that contractors end up going unpaid forweeks and weeks and weeks, while agencystaff are trying to sort out some problem withthe wage compliance or the labor compliancepaperwork, and so, often I just decide, I don’tneed this headache.”Rising construction costs alsocontributes to increased contingencyand construction financing costs,driving up total development costs.The rise in construction costs also leadsto higher costs related to the interest onconstruction loans (since the amount that thedeveloper needs to borrow goes up) as well asconstruction contingency costs. Contingencyfunds are a requirement of project funders,and refer to the capital a developer sets asidefor unexpected expenses during the development process. For example, contingency fundscan help to cover unexpected costs associatedwith land remediation or “a new fee imposedby the city that we hadn’t anticipated” as onedeveloper noted. However, rising constructioncosts are leading developers to turn to theircontingency funds more quickly. One developer who works in the LA region noted that:“In a different era, we wouldn’t have to dip intoour contingency funds and had funding leftover at the end of the development process.But in the last 3-4 years, we hardly have anycontingency left.” Across all the interviews,developers reported that they have neededto increase their contingencies because costescalations make it more difficult to accurately assess the final costs of development.Several developers also highlighted that utilitydelays have contributed to projects runningup against deadlines and eating into contingency costs. As one explained: “We run intoissues with the utilities. We had a project thatfinished not too long ago, and basically had a6-month delay based on PG&E not completingits work on time. So we are finding that a lotof our contingency costs are directly related toutilities.”Developers further noted that because of labormarket and general contractor shortages, theywere running into increased costs related tothe deadlines for occupancy imposed by theLIHTC program. The program requires thata project be completed in under two years.“That timing is rushed in a way that is not formarket-rate developers. We’re often gettingbids on plans that aren’t 100% finalized, whichleads to change orders that can increase costs.There’s a premium that you pay for bringingon a general contractor when it’s rushed.”Other developers noted that they will usecontingency funds to pay for overtime so theycan meet regulatory deadlines.Affordable projects face both politicaland funding constraints in achievingefficiencies of scale.On average, larger development projects canachieve efficiencies of scale, reducing per unitor per square foot costs. The relationship isn’texactly linear, because high-rise buildings(often referred to as Type I projects) requiremore steel and concrete than lower-risebuildings and therefore see higher materialcosts. However, in general, the more units andhigher density that is allowed on a parcel willreduce overall project costs for similar typesof buildings.12

A TERNER CENTER REPORT - MARCH 2020Figure 7: Examples of Average Density 9% LIHTC ProjectsThird Avenue Apartments,Walnut CreekPATH Villas Eucalyptus,InglewoodYet, with the exception of infill projects indowntown urban areas, LIHTC developmentsin California tend to be relatively low density.The average project size for a 9% LIHTC newconstruction project is less than 55 unitsand under 3 stories. Density is measured asthe number of units per acre of land; for theprojects for which these data were available,we found that the average density was 50 unitsper acre. However, nearly a third of projectswere less than 20 units per acre. Figure 7presents two photos of properties representingthe average density (50 units/acre) for LIHTCdevelopments to help visualize the relationshipbetween building density and land use.Developers pointed to two key reasons forwhy projects tend to be smaller and lowerdensity. The first factor is local city designrequirements and, in particular, ongoingresistance to larger, denser affordable housingdevelopments. As one developer aptly put it:“It is impossible to overstate the continuedresistance to new affordable development inmost cities in California.” Developers notedthat they often needed to make concessions todensity or design to get through the permittingprocess, and that this works to limit how manyunits they can build on the lot.The second reason has to do with the structureof tax credit financing. To ensure that creditsare broadly distributed across the state, TCACallocates a specific proportion of 9% credits todifferent regions (and establishes “set asides”for specific policy areas such as special needs13

A TERNER CENTER REPORT - MARCH 2020and supportive housing). TCAC also sets acap on the amount of funding that can beallocated to any one project. However, withdevelopment costs rising, the “cap” on fundingin the 9% credit program is often too low forlarger projects. Developers sometimes splitlarger projects into multiple phases, and/orpropose projects that are smaller than whatcould be built on the parcel. In Santa ClaraCounty, for example, one developer explainedthat “we have given up on doing a 9% projectthat is above 60 units. Because of the cap, wecan’t propose larger, more efficient projects.”Developers also shared that as a result, theyhave increasingly been turning to the 4%credit program for larger projects.Developers also noted that larger pro

affordable housing. Methodology This paper focuses on affordable housing built with Low-Income Housing Tax Credit (LIHTC) financing. Since 1986, the LIHTC program has been the most important source of funding for the construction of affordable housing. In California, more than 225,000 new units have been funded under the LIHTC

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