Housing for the Disabled Homeless-CPA recommendation-WF10-4-21.pdf
October 4, 2021
Community Preservation Committee
c/o Planning & Sustainability
210 Main St
Northampton, MA 01060
RE: Housing for the Disabled Homeless
Dear Community Preservation Committee,
As director of the City office charged with affordable housing, I would like to add my comments to
the Housing the Disabled Homeless CPA application.
Support: This project serves a desperate need among our population experiencing houselessness
and the concept has the whole-hearted support of Planning & Sustainability. Likewise, the location
of the site, under a mile from downtown, makes it walkable (albeit a long walk), which is important
for the population being served.
I cannot comment on whether the proposed support services are adequate, but clearly the applicant
has thought about that and has included some focus in their work.
Cautions: While we have no reservations about the project, we have three concerns:
First, the CPA cost per affordable unit provided is extremely high, probably the highest CPA match
per unit ever requested. Traditionally, we think of both CPA and CDBG as being used for gap
financing, financing that leverages as much money from other sources as possible. It is not clear
from this application that the applicant is searching for and finding as much other funding as
potentially is out there, which would tax CPA support more than needed.
Second, the application does not discuss either affordability restrictions or energy performance.
CPA requires that such housing does provide an affordability restriction. We would urge that the
restriction be a minimum of 99 years, which has become practice for most CPA and CDBG
funded projects. Such a restriction must be senior to all other private financing (although it
could be junior to any state contribution).
We would urge that in return for this large investment, the building get an extreme energy
conservation makeover and a commitment to no new investments in fossil fuel heating. This is
consistent with our recent Climate Resilience and Regeneration Plan and with our recent
CPA and CDBG practices.
Finally, the proposed matching funds for the project are in the form of a private investment and
private shareholders. It is not clear if those investors understand that their investment would be
junior to the affordability restriction, which would dramatically reduce the value of the property and,
perhaps, make investors less like to make this investment. One approach, if that is a concern, is that
the affordability restriction could be, in part, in the form of a first mortgage that could be released if
the CPA funds were paid back (principal and simple interest, such as 2.5%)
None of our concerns undercut our support for the project, but they could require a significant
reworking of the project parameters and financing.
Thank you for your consideration.
Sincerely,
Wayne Feiden, FAICP
Director of Planning and Sustainability
Cc: Keith Benoit and the Northampton Housing Partnership