Inclusionary housing and cash-in-lieu

Would that uh trigger an inclusionary housing fee? No, not rebuilding the existing dwelling.

Motion to modify the inclusion the inclusionary housing benefit so that it will be determined

I am going to propose an amendment to one of the two motions regarding the inclusionary housing ordinance

So they would pay the inclusionary housing per square foot fee

inclusionary housing potentially the inclusionary housing um benefit but what I want to remind us of

the community benefit requirement for inclusionary housing that is so minimal compared to the benefit that the applicant is getting

they have to pay the additional inclusionary housing fee for any floor area on a fourth or fifth story

they would be affordable housing units to meet inclusionary housing, in which case they would need to meet all of our other inclusionary housing standards

so wait so right now what the projects that are the non-affordable and the affordable units have to be the same

I was wondering I also heard that that Frasier Meadows was paying $8 million into the inclusionary as inclusionary housing

when it's getting into things like paying for inclusionary housing fees and that sort of thing

One, I'm a great supporter of our current, inclusionary housing ordinance

there's going to be cash in lieu, there's going to be additional tax revenue

in the very beginning with inclusionary housing, the agreement was, we can't do for sale housing here

the manner in which uh inclusionary housing obligations will be met

with inclusionary housing where the middle income conversation was the main conversation

our inclusionary housing program requires this 25% of new residential development to be permanently affordable.

I would think that if the cash-in-lieu rate was at an equilibrium.

Local funds are from our cash in lieu, our inclusionary housing.

Has the city ever been sued over the inclusionary housing program, and has it been successfully attended in court?

maintaining support for inclusionary housing, like spoken before, inclusionary housing is a very powerful tool we have in the city

our program, Inclusionary Housing Program, requires that 25% of new residential development to be permanently affordable.

under our inclusionary zoning standards uh that could be market rate or mixed

a developer could pay the cash andlue and then uh develop market rate homes

can require um inclusionary zoning ordinances, deed restrictions, and affordable housing agreements

in addition to always providing for the inclusionary housing benefit

so that they would not have to pay the normal inclusionary housing benefit.

exemption from our normal community benefit cash in lieu, an extremely flexible interpretation

Boulder has made real progress through inclusionary housing and infill development, particularly for renters

New dwelling units are subject to inclusionary housing requirements

infill development is governed by our, inclusionary housing ordinance, and so there are affordability requirements

diverting funding from our current inclusionary housing program and using it to subsidize the building of middle housing

community benefit isn't just employee housing and cash in lieu

I'm not going to bring up how much cash in lieu this building is included

You modernized occupancy limits, updated the use table, strengthened inclusionary housing, and simplified the review process.

And I assume this this project is subject to inclusionary housing.

Cash in lieu is about half a mil. Seems like it doesn't cover a lot of need compared to the amount of luxury housing that's been created

affordable development impact fee, which is often called the inclusionary fee

reusing and revisiting the completed nexus study of our inclusion inclusionary housing fees

there's a nexus study that justifies the inclusionary housing fee which is separate from the development

Um so three years ago um this council um updated the inclusionary housing ordinance

create affordable middle housing at scale uh through the current tools that we have um around our inclusionary housing program

We need a knot of five to move forward with direction. about whether to investigate inclusionary or affordable housing as an

inclusionary housing ordinance applying to single-family residents is that there would be

The project will be required to meet the inclusionary housing increase of 11% for bonus units

Do we know how many bonus affordable units this height measure would provide?

to pay cash in lieu, a percentage of the cash in lieu, on each market unit

We did have a consultant do a study that looked at the 25% inclusionary housing requirement

So, you can't charge, a 25% IH requirement on less than 4 units, right?

and we already have an inclusionary… a pretty extensive inclusionary housing spreadsheet.

I'm sorry, wouldn't that fall under the existing inclusionary housing ordinance and not this one?

This inclusionary housing, you get either inclusionary housing, or you get impact fees.

I thought the inclusionary housing, it was exempt if it was under 4 units, or do I have that wrong?

inclusionary housing regulations, similar to the cash-in-lieu that we have in Boulder

a study which was done a couple years ago that was used to update our inclusionary housing ordinance

the second we reclassify these as residential, the city applies the full inclusionary housing fees, the same as if we were breaking ground

well, there's some additional requirements for the high bonus, beyond just the cash in lieu.

providing community benefit that's a cash-in lieu that goes into affordable housing fees

And it lists the affordable housing requirements. That's essentially what's being modified if that makes sense.

The Annexation agreement specifies that the implementation of the affordable housing requirement will be consistent with the city's inclusionary housing program

in inclusionary housing, so in this case they were allowed essentially a credit for existing units on the property.

so setting 15% affordable housing and using cash in lieu to create those units

So in this case we are planning to contribute to the affordable fee in lieu

I know that with the inclusionary housing program the rates that we charge for cash in lieu are meant to be the equivalent

And then subsequently, they changed their mind, as was their right And they paid cash in lieu.

They may choose to fulfill their inclusionary housing requirement with cash in lieu.

the basis for an impact study is different than that of inclusionary housing

their inclusionary housing only applies to 10 or more units

the inclusionary housing program requires developers of new residential development to set aside 25% of new units to low or moderate income households

who administers our inclusionary housing funds?

So it's really more the relationship between the cash in lieu dollars and where that's going.

You know the money that goes into the inclusionary housing program. How's it being spent?

to pay the cash in lieu, and to provide the community benefit of this, the 4th floor.

They basically don't have to make the call as to whether they're going to provide on-site affordable housing or pay cash in lieu

Piggybacking off of that Was there any? Is there inclusionary housing in in this project?

So we do charge essentially extra inclusionary housing fees for any bonus floor area above the 3rd floor.

this partnership may help inform concepts of afford ility uh beyond our current program uh that research uh anticipates examining our current inclusionary

for inclusionary housing purposes, that we sort of examine this as part of calculating cash in lieu on a square foot basis

So just to provide some more background on inclusionary housing, this is a requirement that all new developments contribute

it's not subject to inclusionary housing, and it's not required to contribute to affordable housing

the research includes examining our current inclusionary housing Pro program zoning regulations affordable housing financing structure

so just to cover inclusionary housing, it's a requirement that all new developments contribute.

Some background on inclusionary housing, and how these types of projects fall outside that tool.

what percent of developments are cash in lieu as opposed to the other methods of inclusionary housing

then pay inclusionary housing on the residential portion, which is part of current policy

ultimately that and our affordable housing cash in lieu requirement. Became the downfall of that particular project

that this project would pay towards the city's inclusionary Housing Fund.

They have to either have 25% on site or pay into the inclusionary Housing Fund.

that's more money that's going to go into the Inclusionary Housing fund with every unit that gets added.

It's for projects where there might be a site review project that fulfills its housing. It's inclusionary housing requirements by doing offsite

adding more housing allows for more cash. In lieu. Going into the affordable Housing Fund

we ask for Community benefit in the form of that inclusionary housing uh bonus square footage

through an annexation um annexation is an agreement between parties um in inclusionary housing ordinance um can work as a base

I will note that the program is called in inclusionary housing um but who would like to um open up our discussion

doesn't someone in this room know if it's inclusionary or exclusionary housing

It has an inclusionary housing policy, and it's legislative, you know.

the formula that we have for customary inclusionary housing fees I would say we stick with what we've got

in the form of customary inclusionary housing fees rather than the alternative Community benefit

we could require them to pay the um inclusionary housing fees instead if that is our choice

we talked about um an inclusionary housing fee for additional square footage

and the inclusionary housing, ordinance and community benefit all those things

That meeting the inclusion. Inclusionary housing requirement means you've met the inclusionary housing requirement.

they can change their option and meeting Ih at any point

In the applicant statement it says that for the inclusionary housing requirement that there will be 4 affordable for sale housing units

Satisfy your inclusionary housing requirement. And you're building market rate units and affordable units.

the fee she would pay under the cash andl option under the um inclusionary housing ordinance

in ways that we could a private project paying into our the Inclusionary Housing Fund

And you know the comment I made earlier about inclusionary housing money is this.

for we know that there's now a stream for middle income housing.

we did an update to the inclusionary housing requirements last year, and as part of that

So cash in lieu is not an option for meeting this requirement.

But the current inclusionary housing ordinance requires the developer to donate and then pay a differential

The changes to the inclusionary housing standards that basically didn't penalize someone for having multiple units.

our big pitch is cash in lieu allows us to leverage 2, 3, sometimes $4 in State and Federal funds.

The challenge. With that we just changed the whole inclusionary housing program.

So this is a hundred percent affordable because of the city's inclusionary housing.

our inclusionary housing funds have been put to good use

how much money comes to develop this project from the city's inclusionary housing ordinance.

we have it in our land use code under inclusionary housing a certain percentage of projects has to be deed restricted

Have the developers of this or longbow negotiated a cash in lieu agreement to meet affordability requirements.

It's separate from inclusionary housing. Because it is a an impact fee.

I believe this is about imprison inclusionary housing, cash and new fees for renovations.

As we talked about on our last council, assessing inclusionary housing fees for all types of structures, including single family.

which allowed local communities to initiate inclusionary housing ordinances.

turning it into housing, providing additional funds for our inclusionary housing.

over 1500 permanently affordable housing units since inclusionary housing was established in 2013

so the fourth and fifth stories would have to provide an additional 44% above

I did just ask um inclusionary housing staff about this today and the numbers

We need to get a reasonable 140%. Or more inclusionary housing.

with inclusionary housing and not meeting the jobs, housing, imbalance and or having ex, you know, having impact fees on the developers

What we can do is through our inclusionary housing program, say either.

I understand the rationale of cash in lieu, leveraging collected money with additional grants, etc.

They have said in their proposal that they're going to pay cash in lieu, which is a stupid position

Yeah, they just they can't do it with the the inclusionary housing program that they have now because that it's not supported by the logic behind that program

You don't have to pay the inclusionary housing. Cache and whatever you want.

it does talk about how we have the authority to. Review HOAs if there is permanently affordable housing in the development.

states that the project must be consistent with, Chapter 9 13 inclusionary housing and also the associated regulations for inclusionary housing.

at least increase the inclusionary housing percentage to 33% the the equivalent square footage

a modification to the cash and lose structure and methodology is necessary

tonight's item is a public hearing on ordinance 8601 to update the city's inclusionary housing regulations

do you think in the end this is gonna result in more cash in lieu more units like sort of big picture

Then, let's move on to agenda item number 5 matters from the board. First up is the inclusionary housing update

the inclusionary housing update, which involves a great presentation and lots of questions

On site is, is an inclusionary housing. And while inclusionary housing, is what we call the workforce that affordable housing

A developer can not do that if they pay a significantly more cash in loop.

adjusting the rents that would be required of any on-site affordable rentals that are put on site because of inclusionary housing

we're working with housing on updating the inclusionary housing standards

you also would get more deed restricted inclusionary housing units with projects since there's still a percentage that's required

about 10% of the units subject to inclusionary housing so it's actually a pretty small percentage

Boulder was one of the first 10 cities in the country um to adopt inclusionary housing now

that is 6a the inclusion Area Housing update

So we're gonna get a piece of land, but no money to develop it.

we could actually reduce or even wave the cash in lieu if you made that choice

So that's been an option in the inclusionary housing program since day one.

we're gonna get inclusionary housing out of the market, adding more units one way or the other.

we got inclusionary housing, basically on site or adjacent to the site.

I'm in Hhs, and I'm the inclusionary House of program manager.

The report included an assessment of financial feasibility for a range of development types tested the program alternatives

the purpose of this item tonight is to present options for updates to the city's inclusionary Housing program

the inclusionary housing ordinance will be the the primary mechanism to get affordable housing

are there any opportunities to try to spend some of our inclusionary housing money in this area

it would be tied to inclusionary housing requirements

it isn't a good deal that we got 8 million instead of 3 on inclusionary housing

in lieu of the eight units that they had committed to provide on-site they will be paying a total of 1.7 million dollars

so it reverted back to um the inclusionary housing requirements of 20 percent

to recall at that time our inclusionary housing requirement was 20 percent it's currently 25 percent

The work on the inclusionary housing ordinance that I know is coming up in September. I don't know if it would be appropriate

Any affordable housing, any inclusionary housing they might be responsible for Those could be increased if there are any

we also have the inclusionary housing fee, which states that for each new market rate or non formal unit constructed

that obligation to the inclusionary housing program to either build it on site or pay the cash in Loo

inclusionary housing updates. So August is going to be a very busy meeting.

the museum being in lieu of our inclusionary housing

if they're not providing permanently affordable units on site they'd be subject to the same inclusionary housing requirements as any other development

inclusionary housing is an administrative process that happens after you decide whether or not

inclusionary housing through that process as an administrative thing before the building department process

one of the criteria for residential uses is inclusionary housing

in light of the rough numbers we have for the inclusionary housing program

we have 25% inclusionary housing for the first 3 floors and 36 for the fourth floor

The total amount of fees that would be provided for inclusionary housing by this project would be about 18.9 million based on our current fees.

enforce the inclusionary housing percentage requirements for new residential developments these currently remain at 25 percent

increasing linkage fees and increasing the percentage of inclusionary housing both of which are a fraction of what

supporting a fund very similar to our inclusionary Housing fund that would support the addition of rip top solar

so the bonus floor area would be used to determine the required number of bonus units above the 25 inclusionary housing requirement

providing the low income affordable housing through our inclusionary housing program.

Just go back and really look at more stuff of inclusionary zoning, whatever you you have to there

the exact number of affordable units that we could produce with the inclusionary housing, cash, and new fees

that's something that inclusionary housing staff would determine during site, review

It doesn't matter if you get inclusionary housing. You know what the inclusionary housing needs to be for boulder citizens

As part of the inclusionary housing program would help us to meet that 3% goal.

So when we apply the the required 25 for inclusionary housing that has to be deed restricted, you would get 30 ih units out of a project there.

which then yielded 70 units that would be deed restricted or cash in lieu

through the inclusionary housing program 25 of any number of housing units in a project

that is administered through our inclusionary housing program sometimes we get on-site affordable

the more housing units that would be subject to the inclusionary housing program.

It's it's monitored and administered by our housing department through the inclusionary housing program

would not take care of the applicants inclusionary housing fees for the residential portion

is the applicant proposing to pay into the inclusionary housing fund

if you're talking about fixing it to something like inclusionary housing or or mandated low cost

Inclusionary housing. That's our for housing program and zoning for a middle income housing.

has to do with inclusionary housing updates and so you will be considering an ordinance to revise the existing

the inclusionary housing update that will be coming to you late summer early fall

it could be potentially folded into the inclusionary housing discussion which would allow for both market rate and the restricted

those units the affordable ones were intended to satisfy the applicants the inclusionary housing obligations for a companion project

the requirement of 70 permanently affordable housing made the development unfeasible over the last three years

allowing adus co-ops duplexes commercial linkage fees and a long-standing inclusion inclusionary housing program

in this case inclusionary housing fees, so paying 2 times the applicable cash and low amount required

I'm not sure that inclusionary housing, in my opinion, is the right tool to focus on middle income

No matter how well we do with our inclusionary housing program and push and stretch it

even in just this conversation around inclusionary housing

A preview of next week's joint meeting with a funding board on inclusionary Housing.

Inclusionary Zone. No, it's in front of you how it works.

Housing and restructuring how we charge cash and loo, so that we're not incentivizing modestly size.

Update the inclusionary housing policy update or ordinance update zoning for affordable housing

whereas the cash in lieu is um only eight dollars per square foot in this scaled version

even if the me3 on the on the far left with zero affordable on site and just spending cash in lieu

in the inclusionary housing ordinance that's where there's a connection because of the use type of the unit

So we get a credit for those 48. So we have to pay inclusionary zoning on the remaining beyond 48 units

Is it in the code if it's in the code, then we don't have to debate it

Pay the inclusionary fee, because we get credit for the 48 units on site

That loophole exists in our inclusionary housing ordinance.

This is in our inclusionary housing ordinance in chapter 13 of the code

isn't what you said, but it's limited to the inclusionary housing

the city's community benefit standards require an increase in inclusionary housing requirements

What city did she say where she was talking about the inclusionary? So many fees she'd mentioned

mandatory inclusionary zoning programs that require developers to set aside a certain percentage of units

Are they not? To our inclusionary housing ordinance?

we kind of take inclusionary housing as a starting point

the Inclusionary Housing Staff feel like anything we can do

I have many discussions with the City's Inclusionary Housing Staff

You can do um the um inclusionary housing of um the a regular percentage twenty-five

paying permitting developers to pay cash in lieu actually produces more units for a given amount of money

there is an agreement that states future owners are not sovereign and must meet City inclusionary housing requirements

when we were doing arter inclusionary housing discussion really probably best fit within that um a work plan item

it also spoke to the inclusionary housing fees a little bit I also did want to see us look at

when they propose units on site they can still default to cash and loo later in the process

So the the code has incentives for putting half of the requirement on site.

We went to council, first study session to kick off an update to the inclusionary housing program

some of these seem like they're IH related even though they might involve kind of planning code changes

revise the existing inclusionary housing program to focus on middle-income housing and next we will have

our discussion on a council priority to revise the existing inclusionary housing program to focus on increasing middle income housing

how we implement inclusionary housing so that you guys have sort of a better understanding, for when we start talking about making changes

Item B. Council, study, session, and inclusionary housing update. Yeah.

and the inclusionary zoning that needs to take place to be fair It would probably be not 25%

you're never going to catch up with the demand for inclusionary stuff

I know you're involved with inclusionary things and uh

is going to be a presentation from our staff colleagues on the inclusionary housing policy

future owners of the property that are not the school district will be required to meet the city's inclusionary housing requirements

And then the other one is an update to our inclusionary housing program

affordable housing is dealt with through the inclusionary housing program

the size restriction on the home is intended to make sure that very very large homes are not built on the market

say cash in lieu just because they decide to they feel like it that is unacceptable

how do we make changes to our existing inclusionary housing program to encourage more ownership units

they have started to adopt their own inclusionary housing programs but the challenge is

i think so if i look at 35 000 times 14 units for you know basically half a million dollars in cash in lieu

setting the cash in lieu as a fixed fee based on what we think the possible development potential is

for us to pay cash in lieu and um then that would relieve the units of and then we could sell the units at a market rate

this value is codified in the inclusionary housing provisions providing that inclusionary housing is necessary to preserve

the inclusionary housing update we did a community engagement around that

the next one um uh where it talks about uh decreasing the average size of um Market units um looking at inclusionary housing

the next one is a a review of inclusionary Housing and um the inclusion or housing ordinance

i would like to suggest that we change the way our inclusionary housing fees are

currently how it's um documented in our uh inclusionary housing ordinance

especially if it were contingent on meeting inclusionary zoning with on-site units

why are we charging significantly more cash in lieu for a single family home as opposed to you know smaller units

he promised that what happened nothing he backed out of it now they are doing cash in lieu this is unacceptable

the ordinance ensures that inclusionary housing requirements will be met through a covenant prior to any residential building permits

there's actually no requirement for anything to be provided on site

under inclusionary zoning we would normally expect 25 affordable units

inclusionary zoning alone will not provide all the housing we need

using the city of boulder that's that's really that cash in lieu

maybe the first one is around between the cash in lieu versus the

And that cash in lieu in the commercial linkage fees this just gives you a sense of how variable

in addition to their inclusionary housing low-income housing that would be really really swell

your inclusionary housing program programming you have in place where you require affordable units on site

the inclusionary housing requirements are imposed on residential developments and this would be imposed on a commercial development

this ordinance would divert the inclusionary housing portion of linkage fees for bonus commercial space

those that are a tax credit deal that predates the city's inclusionary housing ordinance

we did not participate are my pre-date kind of inclusionary housing

the homes and town homes and the single family homes that are built there will also be subject to our inclusionary zoning requirements

I think they were relying on the code of were how they were going to meet inclusionary housing

when you build market rate apartments or housing in boulder you have an affordable housing requirement as we all know

in our inclusionary housing um measure um this bill has not yet been introduced

under things to consider tiny homes are subject to inclusionary housing ordinance

we also have an overall inclusionary housing an affordable housing landscape that we have to deal with

we have the chance of affordability with the triplex or paying into our inclusionary zoning fund

first as an inclusionary project on the site with a combination of market rate and affordable units

want permanently affordable rental to be concluded in inclusionary zoning

the fifth priority would be to allow us to use our inclusionary zoning authority to require a permanently affordable rentals

position 21 would allow us to uh use the inclusionary zoning to include rental Housing Development

establishment of the first inclusionary housing goal in 2000 which is since increased a 15 percent affordable to low and moderate income earners

we also did the inclusionary housing update project in 2018 and that and we included incentives

we're really good at expensive homes and we're really good at inclusionary zoning

A PROJECT WOULD GO TO RENTAL THERE WOULD HAVE TO BE A CASH IN LIEU OPTION

THAT WOULD BE BASED UPON THAT TWENTY FIVE PERCENT REQUIREMENT

IN LIEU FEE OF ABOUT SEVEN HUNDRED THOUSAND CASH IN LIEU SINCE THERE IS HALF ON THE SITE

how does land value factor in to all of this when you're talking about cash in lieu and what you're really able to get from an inclusionary housing perspective

if you go to a bonus project with 50 percent of the IH units on the site you get four additional affordable units

there will be obviously there will be either you know the inclusionary housing or or the cash in lieu or whatever it is

with either cash in lieu or whether the particular private developer is putting on site an affordable

to twenty-five percent on-site or through the cash in lieu and so next steps as I mentioned

through the inclusionary housing program either by twenty percent twenty

affordability will likely be addressed through the cities include inclusionary housing program in the in the form of cash in lieu

probably lytec first cash in lieu second consistently probably chap which is primarily property tax revenue

it's beyond just inclusionary zoning for sure it's any new or interesting ideas about how to fund affordable housing

the housing would likely be market rate only with inclusionary housing met through cash and loot

for the market rate to contribute by cash and lieu affordable housing outcomes are best supported

for private development in the area affordability will likely be addressed through the city's incl inclusionary housing program

that we made on our inclusionary housing where if somebody wants to build deed restricted middle-income housing

expansion of inclusionary housing to 25 percent of all new development

one of the most important things and one of the tentpole strategies that we had was to pass local requirements called inclusionary housing

I know we have inclusionary housing we have all these regulation

cash in lieu as the market rate developments happen and they have to if they want

IF WE WERE TO REQUIRE THAT HERE IF WE COULD RECORD HERE WHO WOULD BEGIN AT SIX PERCENT

WE ARE ALSO VERY DISAPPOINTED THAT THIS IS GOING TO BE A CASH IN LIEU SITUATION

THERE WERE SOME SUGGESTIONS BY PLANNING BOARD MEMBERS TO LOOK AT ON SITE AFFORDABLE HOUSING

the amount of affordable housing will just be dictated by you know the linkage fees in the inclusionary zoning

evaluating potential increase to inclusionary housing percentage in the opportunity zones

FOR THAT TWO TIMES THE CASH IN LIEU OR DWELLING UNIT

AFFORDABLE HOUSING WITHIN THE OPPORTUNITY ZONE CARE AS OPPOSED TO PAYMENT OF CASH IN LIEU FUNDS

SO FINAL NOTE YOU'LL NOTICE THAT THERE IS NO INCLUSION OR HOUSING REQUIREMENTS THAT ARE IN THE AGREEMENT

UNINTENDED CONSEQUENCES OF THE CASH IN LIEU PROGRAM SOUNDS GREAT.

grant funds come from cash in lieu payments via the affordable housing fund

we need to work out some of the inclusionary housing

I think we need to do some work on inclusionary housing not revamp the whole thing

cash in lieu was more attractive that was the sort of path of least resistance that the market took

there was a cash in lieu option that was almost always available cash in lieu of which would go to affordable housing

there have been two challenges to inclusionary housing ordinances that I'm aware of one San Jose and the other one Seattle

WE'RE NOT PROPOSING CASH IN LIEU IN ANY WAY

inclusionary housing is the requirement that when a residential development is built a certain percentage of that be permanently affordable

the inclusionary housing requirement aside the direct unit provision as opposed to cash in lieu with that for example be included in that 300 number now

so I guess the question about that sir when you're talking about funds currently available or needed down the road this includes cash in lieu but it

WITH REGARD TO AFFORDABLE HOUSING PROJECT AS A REQUIREMENT OF ABOUT NINETEEN TWO BEDROOM AFFORDABLE UNITS

OR WRITING A CHECK FOR CASH IN LIEU

they govern the affordable housing fund which is cash in lieu and other sources

they're not having to pay any cash in lieu or you know they're putting all that money into the site

we just voted recently on the inclusionary housing you know changes and we talked about how

and inclusionary housing and we already had a public hearing on an inclusionary housing

the fees for affordable projects because right now we're just taking money from one pot and pin it to the other

three inclusionary housing and post inclusionary housing such that when the condo conversion occurred

we're expecting I think 9 million to be paid in cash in lieu

if they pay cash in lieu it comes in somewhere into the city

the inclusion amendments to the inclusionary housing regulations and that's well along and you'll be seeing that

that's something that we're now trying to undo with the inclusionary housing

we have learned repeatedly that getting cash in lieu gives us more units and disperses them more

we asked him why his inclusionary requirement is not building on their own

We also have our own inclusionary policy uh resolution.