NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Antioch hereby:
1. A
ccepts the award of $2,000,000 in California Violence Intervention and Prevention (CalVIP) Cohort 5 grant funding from the Board of State and Community Corrections.
2. Authorizes the City Manager or designee to execute the grant agreement and any amendments, certifications, or related documents necessary to implement the program and administer the grant.
3. Amends the Fiscal Year 2025–26 budget to appropriate $112,000 of the awarded grant funds for expenditure in the current fiscal year. * * * * * * * * * * *
I
HEREBY CERTIFY that the foregoing resolution was passed and adopted by the City Council of the City of Antioch at a regular meeting thereof, held on the 10th day of March 2026, by the following vote:
A
YES:
A
BSENT:
A
BSTAIN:
NO
ES:
______
______________________________
MICHAEL J. MANDY
CITY CLERK OF THE CITY OF ANTIOCH
____M___
Agenda Item #
STAFF REPORT TO THE CITY COUNCIL
DATE: Regular Meeting of March 10, 2026
TO: Honorable Mayor and Members of the City Council
SUBMITTED BY: Lori Asuncion, City Attorney LA
SUBJECT: Resolution of the City Council Authorizing Execution of an Amendment to the Joint Exercise of Powers Agreement with the Municipal Pooling Authority
RECOMMENDED ACTION
It is recommended that the City Council adopt the resolution authorizing execution of an Amendment to the Joint Exercise of Powers Agreement with the Municipal Pooling Authority.
FISCAL IMPACT
There is no fiscal impact associated with the approval of this amended and restated agreement.
DISCUSSION
On February 27, 2025, the MPA Coverage and Governance Committee recommended JPA amendments to ensure alignment with other relevant documents and laws. The MPA Executive Committee approved these with revisions on March 26, 2025, and the Board of Directors gave final approval on April 10, 2025. Board- approved amendments were sent to all members for feedback, after which MPA Staff and Legal Counsel made further revisions based on input received. The MPA Board of Directors approved the final Amended/Restated JPA on January 13, 2026. The Amended/Restated JPA must now be approved by each member by resolution of the member’s governing body and signed by each member’s designee.
MPA was approved by the state as of July 1, 1977. It currently comprises 21 member municipalities, primarily located in Contra Costa County, with some in Santa Clara, San Joaquin, and San Mateo counties. MPA was formed primarily to reduce the rising costs of private insurance for liability and workers’ compensation. The founding members agreed to pool fiscal resources and share the cost of administering and litigating claims.
This pooling of funds is allowed under the Joint Exercise of Powers Act, Government Code, Sections 6500-6536.
Antioch City Council Report
March 10, 2026 Agenda Item #M 2
There are over 1800 JPAs in California providing agencies with pooled coverage for benefits, liability, workers' compensation, and other services. By pooling funds, MPA members share the risk and cost of claims, which helps stabilize individual members' exposure. The cost of claims is spread among all members. Pooling also brings economies of scale, providing members with access to additional insurance options that are only available through the pool. This includes employers' liability, property, cyber, crime, and deadly weapons coverage. MPA provides valuable resources for training and education, including a comprehensive wellness program, ergonomics program, dental and vision plans, life insurance, and online training modules. Risk mitigation support includes mandatory safety training, inspection support to ensure regulatory compliance, and required employee certifications.
Participation in a JPA is invaluable for reducing claims exposure and cost. Members receive dividends in years when reserved funds have exceeded actual costs. These dividends aided members during the COVID-19 revenue decline. MPA has also provided members with grants to meet safety needs within their cities.
MPA has a Board of Directors. Each member in the pool has a seat on the Board. The Board decides how claims are managed and what is covered by the pool. Through the Coverage and Governance Committee, the Board reviews the bylaws, the JPA agreement, and program coverage details annually to determine coverage terms. The Joint Powers Authority Agreement is the required document that members’ governing bodies must approve to join any MPA program.
Below are the list of current members and their inception date as a member of MPA:
Member Date Joined
Antioch 5/2/1977
Brentwood 5/2/1977
Clayton 5/2/1977
Danville 2/1/1983
Gilroy 7/1/2015
El Cerrito 5/2/1977
Hercules 5/2/1977
Lafayette 5/2/1977
Manteca 1/1/1998
Martinez 5/2/1977
Moraga 5/2/1977
Mountain House 7/1/2024
Oakley 7/1/2002
Orinda 7/1/1986
Pacifica 7/1/2006
Pinole 5/2/1977
Pittsburg 5/2/1977
Pleasant Hill 5/2/1977
San Pablo 5/2/1977
Antioch City Council Report
March 10, 2026 Agenda Item #M 3
San Ramon 7/1/1986
Walnut Creek 5/2/1977
The changes proposed to the JPA agreement are not major and are mostly technical. A redline version of the proposed amendment showing the changes is attached to this Staff Report.
ATTACHMENT
A. Resolution Authorizing Execution of Amended and Restated Agreement B. Amended and Restated Agreement (redline/track-change version)
ATTACHMENT A
RE
SOLUTION NO. 2026/___
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ANTIOCH APPROVING
THE AMENDED AND RESTATED MUNICIPAL POOLING AUTHORITY JOINT
EXERCISE OF POWERS AGREEMENT FOR PROVIDING ADMINISTRATION AND SELF-INSURED COVERAGE FOR LIABILITY, WORKERS’ COMPENSATION,
AND PROPERTY DAMAGE CLAIMS
WHEREAS, The Municipal Pooling Authority (MPA) was formed in 1977 by a Joint Exercise of Powers Agreement.
WHEREAS, the City of Antioch is a Member Agency of MPA; and WHEREAS, there have been amendments to the MPA Joint Exercise of Powers Agreement; and
WHEREAS, the Municipal Pooling Authority Amended and Restated Joint Exercise of Powers Agreement, a copy of which is attached, has been amended to reflect these amendments; and
WHEREAS, the City Council is familiar with the contents thereof.
NOW, THEREFORE, BE IT RESOLVED that the adoption of the Municipal Pooling Authority Amended and Restated Joint Exercise of Powers Agreement for providing administration and self-insured coverage for liability, workers’ compensation, and property damage claims is hereby approved, and the designated primary or alternate MPA Board member is hereby authorized and directed to execute the same on behalf of the City.
* * * * * * * I
HEREBY CERTIFY that the foregoing resolution was passed and adopted by the City Council of the City of Antioch at a regular meeting thereof, held on the 10th day of March, 2026 by the following vote:
A
YES:
N
OES:
ABS
TAIN:
ABS
ENT:
___
________________________________
MICHAEL J. MANDY
CITY CLERK OF THE CITY OF ANTIOCH
MUNICIPAL POOLING AUTHORITY
AMENDED AND RESTATED JOINT EXERCISE OF POWERS AGREEMENT This A
mended and Restated Joint Exercise of Powers Agreement (hereafter “Agreement”) is entered into by and among the p ublic e ntities listed in Appendix A ( hereafter referred to as "Members").
RECI
TALS
1. The Members are public entities organized and operating under the laws of the State of California;
2. The following State l aws, among others, authorize the Members to enter into this Agreement:
a. Labor Code Section 3700, allowing a public entity to fund its own workers' compensation claims;
b. Government Code Sections 989 and 990, permitting a local public entity to insure itself against liability and other losses;
c. Government Code Section 990.4, permitting a public entity to provide insurance and self-insurance in any desired combination;
d. Government Code Section 990.6, providing that the cost of insurance authorized under the related sections is a proper charge against the local public entity; e. Government Code Section 990.8, permitting two or more local public entities to enter into an agreement to jointly fund such expenditures under the authority of Government Code Sections 6500, et seq.; and
f. Government Code Sections 6500, et seq., permitting two or more local public entities to jo intly exercise under an agreement any power which is common to each of them.
3. Each of the Members desires to enter into an agreement with each of the others for the purpose of insuring against various risks jointly, rather than individually.
4. Pursuant to Government Code Section 6508.1, the debts, liabilities and obligations of MPA shall not constitute debts, liabilities, or obligations of the Members.
5. MPA was originally formed by a Joint Powers Agreement in 1977. Since that time the Agreement has been amended several times and Members have withdrawn from and new Members have been added to MPA.
ATTACHMENT B
NOW, THEREFORE, for and in consideration of the mutual benefits, covenants and agreements set forth herein, the Members agree as follows:
SECTION 1
Authority and Purpose
This Agreement is made under the authority of California Government Code Sections 6500, et seq. between the Members. The purpose of this Agreement is to exercise jointly powers common to each Member by managing risks and pooling or purchasing coverage for losses.
SECTION 2
Definitions
Unless the context otherwise requires:
1. "MPA" shall mean the public entity known as the Municipal Pooling Authority created by this Agreement.
2. "Board" shall mean the governing body of MPA.
3. "Chief Administrative Officer" shall mean the person appointed by the Board as the Chief Administrative Officer of MPA.
4. "Claim" shall mean a claim or demand made against a Member arising out of an occurrence that is covered or alleged to be covered by any Memoranda of Coverage issued by MPA or by a purchased policy of insurance.
5. "Member" shall mean any public entity listed in Appendix A to this Agreement.
6. "Memoranda of Coverage" shall mean documents issued by MPA specifying the type, terms, conditions, and limitations of coverage provided by MPA to each Member that participates in the program .
SECTION 3
Creation of MPA
Pursuant to Article 1, Chapter 5, Division 7, Title 1 of the California Government Code (commencing with Section 6500), the parties hereto create a A public entity, separate and apart from the parties hereto and , to be known as the Municipal Pooling Authority, was previously created and is continued .pursuant to Article 1, Chapter 5, Division 7, Title 1 of the California Government Code (commencing with Section 6500).
SECTION 4
Terms of Agreement
This Agreement is effective as of __________________ and continues until terminated as hereafter provided. The prior Joint Exercise of Powers Agreement is terminated upon the effective date hereof.
SECTION 5
Governing Board
MPA shall be governed by a Board composed of one individual representative from each Member, each serving in an individual capacity as a member of the Board. Each Member's governing body shall appoint to the Board either its Manager or Director, or the department head or staff person, responsible for its risk management function. Each Board member shall have one vote. Each Member shall appoint one Alternate to the Board. The Alternate shall have the same qualifications as the Board member. The Alternate may vote at any meeting of the Board at which the regular Board member is absent.
SECTION 6
Meetings and Committees
(a)
Committees. The Board may establish an Executive Committee comprised of members of the Board and delegate to it any powers or functions not reserved to the entire Board or otherwise nondelegable. Other regular committees may be created by, or in accordance with, the procedures set forth in Bylaws adopted by the Board. Ad hoc committees may from time to time be established by the President of the Board to serve as temporary committees for a limited purpose.
(b) Meetings. The Board shall hold at least one regular meeting each year. The Board shall fix the date upon which, and the hour and place at which, each regular meeting is to be held, and the Chief Administrative Officer shall notify each Member of that action.
Other meetings of the Board and meetings of any duly established committees may be held in accordance with applicable law. All meetings of the Board and regular committees shall be held in a manner consistent with the Bylaws and in compliance with the Ralph M. Brown Act (California Government Sections 54950, et seq.).
(c) Bvlaws and Regulations . The Board may adopt Bylaws and regulations that are not inconsistent either with applicable law or with this Agreement. In the event the Bylaws or regulations are inconsistent with this Agreement, this Agreement shall control. The Chief Administrative Officer shall send to each Member all such Bylaws and regulations, and any amendments thereto, promptly after adoption by the Board.
SECTION 7
Officers
(a) The Board shall elect a President and Vice-President from among its members to perform the duties set forth in the Bylaws.
(b) The Chief Administrative Officer shall be the Secretary of MPA and shall be responsible for maintaining all records of MPA.
(c) The Board shall elect a Treasurer with the qualifications and to perform the duties set forth in the Bylaws.
(d) The Board may appoint such other officers, employ individuals, and contract with consultants and other professional persons or firms as it considers necessary to carry out the purposes of this Agreement.
SECTION 8
Powers of MPA
MPA shall have the powers and authority to exercise any powers common to its Members and is hereby authorized, in its own name, to do all acts necessary for the exercise of those such common powers, referred to in the Recitals including, but not limited to, each of the following:
(1) Make and enter into contracts;
(2) Incur debts, liabilities and obligations but no debt, liability or obligation of MPA is a debt, liability or obligation of any Member, pursuant to Government Code Section 6508.1;
(3) Acquire, hold or dispose of real and personal property;
(4) Receive contributions and donations of property, funds, services and other forms of assistance from any source;
(5) Sue and be sued in its own name;
(6) Employ agents and employees;
(7) Acquire, construct, manage and maintain buildings;
(8) Lease real or personal property including that of a Member;
(9)
Receive, collect, invest, and disburse monies; and
(10) Carry out other duties as required to accomplish other responsibilities as set forth in this Agreement.
These powers shall be exercised in the manner provided by law and as expressly set forth in this Agreement. Pursuant to Section 6509 of the California Government Code, the exercise of such powers shall be , subject only to those restrictions upon the manner of exercising the powers which are imposed upon Members such as the City of Pleasant Hill, in the exercise of similar powers.
SECTION 9
Fiscal Year
The "fiscal year" of MPA is the period from the first day of July of each year to and including the 30th day of June of the following year.
SECTION 10
Coverage Provided by MPA
Pursuant to the payment of contributions by each Member, MPA shall provide coverage pursuant to one or more Memoranda of Coverage and/or purchased policies of insurance under the programs selected by the Member.
SECTION 11
Establishment and Administration of Funds
The Board shall establish such funds as it deems necessary to conduct the business of MPA.
SECTION 12
Budget
MPA shall adopt an annual budget no later than the first day of its fiscal year.
SECTION 13
Member Contributions
The Chief Administrative Officer shall be responsible for calculating annually the amount of contributions to be charged for coverage selected by Members. The Board shall approve each charge before it takes effect. Each Member by the act of paying its contribution accepts the coverage provided by MPA.
SECTION 14
Accounts and Records
The Chief Administrative Officer shall be responsible for establish ing and maintaining the funds and accounts in accordance with acceptable accounting practices and maintain ing such other records as the Board requires pursuant to the procedures set forth in the Bylaws.
The Chief Aministrative Officer shall have the custody of and be responsible for the disbursement of MPA funds as provided by accounting procedures developed in accordance with this Agreement and the Bylaws.
SECTION 15
Reserves
Separate reserves shall be maintained in the funds for each type of coverage.
SECTION 16
MPA Functions and Responsibilities
MPA shall provide comprehensive risk management services to its Members.
Formatted: Normal, Tab stops: Not at 0"
SECTION 17
Member Responsibilities
Each Member has responsibilities, including the following:
(1) Appoint its representative and alternate to the MPA Board in accordance with the procedures set forth in the Bylawsapplicable practices and procedures;
(2) Cooperate fully with MPA in the investigation, defense, and settlement of Claims, including compliance with any applicable Memoranda of Coverage;
(3) Comply with risk management recommendations, guidelines, and requirements established by MPA;
(4) Pay contributions and assessments approved by the Board when due;
(5) Provide MPA with statistical and loss experience, data and other information requested; and
(6) Cooperate with and assist MPA and any insurer, adjuster, or legal counsel retained by MPA in matters related to this Agreement, any Bylaws adopted by the Board, and any other governing documents, policies, or procedures adopted by the Board.
SECTION 18
New Members
Upon the vote of two-thirds of all members of the Board, any other public entity in Contra Costa County or in the general geographic area reasonably serviceable from Contra Costa County may become a party to this Agreement upon execution of this Agreement, and shall forthwith pay to MPA its current contribution payment as determined in accordance herewith, as well as any fees and expenses set by the Board.
SECTION 19
Cancellation of Coverage i n a Program or Programs
lf a Member fails to comply with this Agreement, any Bylaws adopted by the Board, or any procedures or policies established by the Board, the Board may, by a two- thirds vote of all members of the Board, refuse to provide coverage or may cancel any coverage being provided to that Member in any program(s).
SECTION 20
Termination of Agreement and Disposition of
Assets Upon Termination of Agreement
This Agreement may be terminated upon the unanimous consent of all parties to it. Upon complete termination of this Agreement by all Members and the settlement of all liabilities and claims, including incurred but not reported claims, all property of MPA shall be divided among the Members in a ratio equal to that of the total amounts paid by the Members for the five (5) fiscal years preceding the year in which the Agreement is terminated.
SECTION 21
Withdrawal of a Member
A Member may withdraw as a Member and party to the Agreement, effective at the end of any fiscal year upon giving MPA six (6) months prior written notice of its intent to withdraw.
SECTION 22
Expulsion
The Board, by a three-fourths vote of all members of the Board, may expel any member for the
reasons and under the procedures set forth in the Bylaws.
SECTION 23
Effect of Withdrawal or Expulsion
The withdrawal or expulsion of any Member shall not terminate its responsibilities and obligations as set forth in MPA’s governing documents.
Upon withdrawal of a Member, that Member is entitled only to its pro rata share of the balance of the amount paid by it for the fiscal year in which withdrawal takes place. That Member shall not participate in or be entitled to any other funds, property, or other assets of MPA. Coverages under all pool coverage programs for the coverage periods in which that Member participated will remain in effect and continue until the conclusion of their respective program years.
SECTION 24
Liability and Indemnification
MPA shall defend and indemnify its Board members, officers, and employees to the same extent as any other public entity of the State of California is obliged to defend and indemnify its public employees pursuant to California Government Code Section 825, et seq ., or other applicable provisions of law.
MPA may insure or self-insure itself to the extent deemed necessary by the Board against loss, liability and claims arising out of or connected to the conduct of MPA's activities.
SECTION 25
Assessment
Upon a two-thirds vote of all members of the Board, the Board shall have the authority to levy a cash assessment for any pooled coverage program if the Board finds that there are insufficient funds available to MPA to meet its legal obligations.
Any cost, including attorneys' fees, incurred by MPA in collecting any cash assessment shall be reimbursed by the Member against which such collection action has been taken.
Section 26
Dividends and Premium Rebates
Upon a two- thirds vote of all members of the Board, the Board shall have the authority to declare a dividend, rebate of excess contributions, and/or reduction of future contributions for any pooled coverage program if the Board finds there are excess reserves in the retention fund.
SECTION 27
Severability
lf any portion, term, condition or provision of this Agreement is determined by a court to be illegal or in conflict with a law of the State of California, or is other wise rendered unenforceable or ineffectual, the validity of the remaining portions, terms, conditions, and provisions is not affected.
SECTION 28
Prohibition Against Assignment
No Member may assign a right, claim, or interest it may have under this Agreement . No creditor, assignee, or third party beneficiary of a Member has a right, claim, or title to any part, share, interest, fund, premium or asset of MPA.
SECTION 29
Amendment
This Agreement may be amended by Resolution of the governing bodies of two- thirds of the then-participating Members. Appendix A to this Agreement may be amended to correctly list current Members without separate action by the governing bodies of the Members or the Board, and provided any additional members execute the Agreement.
SECTION 30
Notices
Notices to Members under this Agreement shall be sufficient if delivered to the office of the Member. Notices to MPA shall be sufficient if delivered to the office of the Chief Administrative Officer.
IN WITNESS WHEREOF, the parties hereto have executed this Joint Exercise of Powers Agreement as of the day and year first above written.
City of Antioch
City of Mountain House
City of Brentwood
City of Oakley
City of Clayton
City of Orinda
Town of Danville
City of Pacifica
City of El Cerrito
City of Pinole
City of Gilroy
City of Pittsburg
City of Hercules
City of Pleasant Hill
City of Lafayette
City of San Pablo
City of Manteca
City of San Ramon
City of Martinez
City of Walnut Creek
Town of Moraga
Municipal Pooling
Authority
1 City of Antioch
March 10, 2026
Chief Administrator Officer, Linda M. Cox
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
History
-
Fun Facts
• MPA was formally formed as of July 1, 1977
• The City of Antioch joined on May 2, 1977
• The pool was formed to offset the rising cost of private insurance for General Liability and later added Workers ' Compensation, Property, Vehicle Physical Damage, Employment Practices, Risk Control, Employee Benefits, Employee Wellness Programs, and more. • MPA has 21 members
• MPA is one of the last pools in California that is self-administered with in-house claims administrators.
• It is the only pool in California that provides an on-site wellness program.
MPA Governance
• MPA is governed by a Board of Directors; each of the 21 members designates a primary and alternate Board member to sit on the Board.
• The Board delegates authority of claims matters to the elected officers that make up the 7-member Executive Committee. • The Coverage and Governance Committee reviews all governing documents of the pool.
• Governing documents include the Joint Exercise of Powers Authority Agreement, Bylaws, and Memorandums of Coverage Services
• Workers’ Compensation Claims Administration and litigation • Liability Claims Administration and Litigation
• Vehicle Physical Damage Coverage
• Property Brokerage and Coverages
• Benefits ~Dental, Vision, Short Term Disability, Long Term Disability, Life Insurance
• Wellness Program
• Safety and Risk Training and Support
• Police Risk Committee
• Public Works and Safety Risk Committee
• Employee Ergonomics Evaluations and Trainings
Layers of Coverage
• Workers’ Compensation
• MPA provides first-dollar
coverage up to $500,000.
• Public Risk Innovation, Solutions, and
Management (PRISM) Provides
coverage excess of $500,000 to
statutory limits.
General Liability Coverage
• MPA provides for coverage up to
$1,000,000 above individual self-insured
retention limits of:
• $5,000, $10,000, $25,000, $50,000,
$100,000
Excess Coverage
Excess Coverage
• California Risk Management Authority
(CARMA)
• Provides $ 9,000,000 of coverage excess of
$1,000,000.
• CARMA retains excess liability insurance
above $10,000,000 to $24,500,000.
Member’s Investment at Work
• Workers’ Compensation
• FY17 Program funded at 85%
confidence level
• FY26 Program funded at 90%
confidence level
General Liability Coverage
• FY17 Program funded at 80% confidence
level
• FY26 Program funded at 90% confidence
level
Municipal Pooling Authority Captive (MPAC)
July 1, 2025, marked the start of an alternative insurance investment entity for the workers’ compensation program that acts as a formal, regulated, and risk-financing program, allowing MPA to manage unique risks, control premium costs, and retain improved underwriting profits for members. It is a long-term investment strategy.
Member Program Participation
Thank you
6 Agenda Item #
STAF
F REPORT TO THE CITY COUNCIL
DATE: R
egular Meeting of March 10, 2026
TO: Honor
able Mayor and Members of the City Council
David A. Storer, Interim Community and Economic Development Director
SUBMITTED BY:
SUBJECT: Appeal Of Conditions Of Approval Requiring The Lakeview Center CIH Project To Annex Into CFD 2018-01 (Public Services) And CFD 2018-02 (Police Services)
RECOMMENDED ACTION
It is recommended that the City Council continue the Public Hearing off calendar.
DISCUSSION
Staff is requesting that this item be continued off-calendar to allow staff and the appellant time to come to an agreed resolution of the matter.
_7____
Agenda Item #
ST
AFF REPORT TO THE CITY COUNCIL
DATE
: Regular Meeting of March 10, 2026
TO: H
onorable Mayor and Members of the City Council
David A. Storer, Interim Community and Economic Development Director
SUBMITTED BY:
SUBJECT: Appeal Of Conditions Of Approval Requiring The Buchanan Crossings CIH Project To Annex Into CFD2018-01 (Public Services) And CFD 2018-02 (Police Services)
RECOMMENDED ACTION
It is recommended that the City Council continue the Public Hearing off-calendar.
DISCUSSION
Staff is requesting that this item be continued off-calendar to allow staff and the appellant time to come to an agreed resolution of the matter.
8 A genda Item #
S
TAFF REPORT TO THE CITY COUNCIL
DAT
E: Regular Meeting of March 10, 2026
T
O: Honorable Mayor and Members of the City Council
S
UBMITTED BY: Greg Goodfellow, Associate Principal, PlaceWorks Zoe Merideth, Planning Manager
APPROVED BY:
David A. Storer, Interim Community and Economic Development Director
Adoption of an Inclusionary Housing Ordinance (IHO) Co nsistent with City’s 6th Cycle Housing Element Implementation
Program 2.1.10
RE
COMMENDED ACTION
It is recommended that the City Council:
1. Introduce by title only and waive the first reading of an ordinance of the City Council amending the City of Antioch Municipal Code Title 9: Planning and Zoning to add Article 43: Inclusionary Housing;
2. A
dopt the resolution establishing an a ffordable Inclusionary Housing Trust Fund (IHTF); and
3. A
dopt the resolution amending the Master Fee Schedule to add an in-lieu fee and an affordable housing compliance monitoring fee.
F
ISCAL IMPACT
The adoption of an Inclusionary Housing Ordinance (IHO) would lead to an indirect cost of staff time to administer the program. Many costs would be recoverable from the program, as staff time for the processing of housing projects is billed directly to developers. Additionally, the proposed compliance monitoring fees would cover staff’s time to monitor rental units annual ly, and process sale documents. Should a developer pay the in-lieu fee, which is proposed at $202,500 per unit, the City would collect these fees and be deposited into a fund to be used for affordable housing purposes (the newly created Inclusionary Housing Trust Fund – “IHTF”).
S
UMMARY
Staff and the Planning Commission have studied the feasibility of adopting an IHO and an appropriate optional developer in-lieu fee. An IHO, often referred to as “ inclusionary zoning”, is a zoning tool that requires developers to allocate a percentage of housing units SUBJECT:
Antioch City Council Report
March 10, 2026 Item # 8 2
in market-rate developments as “ affordable”, or below -market rate (BMR) units. Many IHOs include the option of paying a fee ( “in-lieu” fee) rather than building the required affordable units onsite. The IHO study is consistent with Program 2.1.10 of the City’s state-certified 6th Cycle (2023-2031) Housing Element.
Staff completed an IHO feasibility study, outreach, and fee calculation processes. Staff also drafted the IHO and determined an appropriate in-lieu fee amount based on current market conditions. For reference, the materials presented in this staff report include the in-lieu fee calculation and information regarding the IHTF.
The IHO process was previously reviewed in the following study sessions:
April 16, 2025: Planning Commission Study Session
May 27, 2025: City Council Study Session
August 26, 2025: City Council Study Session
September 16, 2025: City Council Study Session
On February 4, 2026, t he Planning Commission voted 4 -0, with two members absent recommending that the City Council adopt the IHO (discussed in detail below).
BACKGROUND
Inclusionary Housing in California
Inclusionary housing regulation, or inclusionary zoning , has been used for the past few decades in California to produce affordable housing. Inclusionary ordinances require that a specific percentage of units in market -rate development projects be offered at below - market rates, typically to Very Low-Income (VLI), Low-Income (LI), and Moderate Income (MI) households (see below for definitions). These percentages are known as inclusionary requirements. Nearly 200 cities and counties in California have adopted IHOs, including Contra Costa County and multiple jurisdictions in Contra Costa County . Examples of select IHOs in Contra Costa County are summarized in Attachment D.
Antioch has considered adopting an IHO since approximately 2009. Past City leadership concluded that market rate housing in Antioch was already adequately affordable. In 2016, the Contra Costa Grand Jury released a report titled Where Will We Live: The Affordable Housing Waiting List Is Closed. The report recommended that Antioch should consider adopting an IHO. The City responded to this recommendation on August 9, 2016, stating that the City, assuming 2000 -2009 home values, “already provides a diversity of housing options and is accessible to households of all income levels …” Therefore, an IHO was “not warranted and is not reasonable.”
The inclusion of Program 2.1.10 i n the current 6
th Cycle Antioch Housing Element is
indicative of current statewide and local housing challenges and new housing priorities.
Technical analyses and community outreach performed as part of the Housing Element demonstrate the need for housing-forward policies and the potential value of an IHO.
Antioch City Council Report
March 10, 2026 Item # 8 3
Income and Affordability in Contra Costa County
IHOs accommodate State-designated levels of housing affordability. California categorizes housing based on how affordable it is to households with different income levels, which are the same as income levels used in the City’s RHNA. The three categories of affordable housing typically accommodated in IHOs are:
Very Low-Income (VLI) Housing. Units affordable to households earning 0-50% of the Area Median Income (AMI).
Low-Income (LI) Housing. Units affordable to households earning 51-80% of AMI.
Moderate Income (MI) Housing. Units affordable to households earning 80-120% of AMI.
The State also recognizes Above-Moderate Income Housing, which are units affordable to households earning more than 120% of Area Median Income (AMI) . However, this affordability level is not provided for in IHOs but is included in RHNA’s.
The AMI in Contra Costa County i s $159,800. The following table shows incomes of households of various sizes, within each affordable income level. These figures were released by the California Department of Housing and Community Development, effective April 25, 2025. The figures are updated annually for each county.
The following table includes maximum rents by bedroom size affordable to households of each income category, in Contra Costa County. The figures are effective April 23, 2025.
Antioch City Council Report
March 10, 2026 Item # 8 4
INCLUSIONARY HOUSING PROCESS IN ANTIOCH
The State of California requires each jurisdiction to update its General Plan Housing Element on a regular cycle. The primary function of the Housing Element is to establish a State- certified land use and policy plan to accommodate the jurisdiction ’s Regional Housing Needs Allocation (RHNA). RHNA
is mandated by California law and requires
local jurisdictions to plan for their ‘fair share’ of housing units for all four affordability levels, as mentioned above.
The City of Antioch’s 6
th Cycle (2023-2031) Housing Element was certified by HCD on October 12, 2023. It responds to the following Antioch RHNA allocation for affordable housing units:
Very Low-Income: 792 units
Low-Income: 456 units
Moderate Income: 493 units
Above Moderate Income: 1,275 units
The Antioch Housing Element includes multiple programs to fulfill the City’s RHNA. One of these is Program 2.1.10:
2.1.10. Inclusionary Housing. Initiate a feasibility study for an inclusionary housing ordinance for City Council consideration. The ordinance would generally require that the development of new market -rate housing units include a percentage of units that are affordable at specific i ncome levels or that in-lieu payment be made. The revenue generated from in-lieu fees would be used to generate funding for the development of affordable housing in the city. Funds collected from in- lieu fees could be used for the following purposes:
New construction of affordable housing.
Acquisition/rehabilitation of housing and addition of affordability covenants.
Permanent supportive housing/transitional and emergency shelters. Down payment assistance program
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The City entered into an agreement with PlaceWorks, Inc. on May 1, 2024, to prepare the Antioch Inclusionary Housing Ordinance P roject (IHO Project), consistent with Program
2.1.10. Per Program 2.1.10, the IHO Project does not assume that Antioch will adopt an IHO.
Rather, all components of an IHO would be studied, and an IHO presented to the Planning Commission and City Council.
ANTIOCH IHO PROJECT COMPONENTS TO DATE
The f ollowing components of the IHO Project have been completed and previously reviewed by the Planning Commission and City Council.
Feasibility Study
As noted, j urisdictions are not legally required to study the impacts of inclusionary requirements on the financial feasibility of local housing projects. However, these studies provide evidence that IHOs do not “unduly constrain the production of housing” and will allow property owners to have a “fair and reasonable rate of return.” They can also demonstrate that inclusionary requirements can be increased without constraining housing production.
PlaceWorks completed a Financial Feasibility Analysis (FFA) (Attachment E) for the City of Antioch, dated May 6 , 2025. Feasibility impacts were ascertained by comparing the difference between the financial performance of a fully market -rate version of a housing project and one that includes a required number of affordable units, while also receiving any available density bonus under State law. The FFA process is summarized as follows:
1. Antioch Market Survey. In July and August of 2024, PlaceWorks used real estate industry software to complete a survey of Antioch housing costs, including single family, multifamily and townhome prices and rents.
2. Housing Project Prototypes. PlaceWorks developed five housing project prototypes in coordination with City staff. The prototypes reflect current hou sing trends, pipeline projects and regulation in Antioch. The FFA includes three for-sale housing prototypes and two for-rent housing prototypes.
3. Pro Forma Analyses . PlaceWorks prepared pro forma analyses of the fully market-rate housing prototypes to identify whether, and how, various affordability requirements could be supported by each. The pro formas rely on multi-year cash flow projections to achieve the most accurate evaluation of project feasibility. The pro formas assess the impacts of multiple affordability requirements, including:
15 percent requirements for VLI, LI and MI housing.
10 percent requirements for VLI, LI and MI housing.
Five percent requirement for VLI housing.
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The FFA relies on the following industry-accepted metrics to determine project feasibility:
Internal Rate of Return (IRR) is used for the for-sale projects. An IRR of 15 percent is generally considered the minimum threshold of financial feasibility. Cash-on-Cash Yield (CoC) is used for the rental projects. A CoC of six percent is generally considered the minimum threshold of financial feasibility.
The following are summary results of the draft FFA. These results may shift slightly with the introduction of new inputs such as updated City of Antioch Community Facilities District (CFD) property tax payments. The FFA conclusions are not expected to change.
FFA Results Summary: For-Sale Prototypes
The following table summarizes the results of the pro forma analysis for the three for-sale development protypes, which include:
Prototype 1: Large-lot single family subdivision
Prototype 2: Small-lot single family subdivision
Prototype 3: 70-unit townhome development
FINANCIAL FEASIBILITY SUMMARY, FOR-SALE PROTOTYPES
Prototype 1: Large Lot SFD Prototype 2 Small Lot SFD
Prototype 3: Townhome
Development
Fully Market Rate Scenario
No Inclusionary Housing 18.3% 21.0% 20.6%
15% Inclusionary Requirements
15% Very Low-Income -1.6% 26.5% 15.5%
15% Low-Income -7.1% 19.9% 12.8%
15% Moderate Income -14.3% 11.1% 19.9%
10% Inclusionary Requirements
10% Very Low-Income -2.6% 24.6% 16.3%
10% Low-Income -5.3% 21.8% 12.6%
10% Moderate Income -12.1% 13.4% 19.8%
5% Inclusionary Requirement
5% Very Low-Income -1.3% 24.4% 18.2%
As shown in the table, the Fully Market -Rate Scenarios of all three prototypes are financially feasible, assuming an IRR threshold of 15 percent. However, under various inclusionary scenarios, multiple for -sale prototypes saw a significant drop in IRR, such that they would not be financially feasible without additional densities. Prototype 1 would be extremely sensitive to inclusionary requirements . It would not achieve a 15 percent IRR under any of the inclusionary requirement scenarios, even with State density bonus maximized.
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Prototype 2 would remain financially feasible under most of the inclusionary requirement scenarios. It would not achieve a 15 percent IRR under the 15 percent Moderate Income requirement or 10 percent Moderate Income requirement. This is not surprising, as these scenarios offer the lowest density increases under State density bonus law.
Prototype 3 would also remain financially feasible under most inclusionary scenarios. It would not achieve 15 percent IRR under the 15 percent Low-Income requirement and 10 percent Moderate Income requirement.
FFA Result Summary: Rental Prototypes
The following table summarizes the results of the pro forma analysis for the two rental protypes, which include:
Prototype 4: Medium/High Density Multifamily Apartments Prototype 5: High Density Multifamily Apartments
FINANCIAL FEASIBILITY SUMMARY, RENTAL PROTOTYPES
Prototype 4: Medium/High Density
Multifamily
Prototype 5: High Density
Multifamily
Fully Market Rate Scenario
No Inclusionary Housing 6.1% 6.6%
15% Inclusionary Requirements
15% Very Low-Income 6.2% 6.3%
15% Low-Income 4.9% 6.4%
15% Moderate Income 5.2% 6.8%
10% Inclusionary Requirements
10% Very Low-Income 6.1% 6.3%
10% Low-Income 4.8% 6.4%
10% Moderate Income 5.0% 6.6%
5% Inclusionary Requirement
5% Very Low-Income 6.1% 6.3%
As shown in the table, the Fully Market-Rate Scenarios of both prototypes are financially feasible, assuming a CoC threshold of six percent. However, the financial impacts of the inclusionary requirements differ between the two prototypes:
Prototype 4 would maintain feasibility only under requirements for V ery Low - Income units. This is primarily because construction of VLI units allows for the greatest density increase under State Density Bonus law.
Protype 5 would maintain feasibility under all seven inclusionary scenarios.
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It should be noted that the density increases required to make rental projects feasible would also require additional building heights and potential parking regulation exemptions, both of which are potential challenges to project development.
The full FFA includes detailed analyses of density, physical form, costs, revenues, and feasibility of each prototype.
Project Outreach
In addition to technical analysis, input from residents, stakeholders and developers was collected to inform the IHO. The IHO project includes the following outreach efforts, each dated separately:
Community Survey. The IHO Project team released an online survey on October 15, 2024, to assess community awareness and support of inclusionary housing.
Over 50 community members responded to the survey. The following trends emerged:
o Need for ongoing education and outreach. Over 60% of responders were either “Unfamiliar” or “Somewhat familiar” with IHOs.
o General support for inclusionary housing. Over 80% of responders either “Fully” or “Somewhat” supported an IHO in Antioch.
o Need for diverse housing . Over 60% of responders felt an IHO should apply to both rental and for-sale development, citywide. o Mixed opinion regarding alternatives. The survey lists a series of potential alternative compliance options and asked responders to rate their value. No clear trends in local support for IHO alternatives have emerged. o Focus on in-lieu fees. In-lieu fees were a topic of community concern. Many responders provided specific feedback regarding the benefits, liabilities, calculation, management and allocation of said fees.
Developer Focus Group. The IHO Project team conducted a virtual Focus Group with local housing developers on December 5, 2024. Attendees were shown the results of preliminary feasibility analyses for a 15 percent inclusionary requirement.
A guided discussion was conducted. Key feedback from developers included:
o Concern over reliance on density bonus . Developers stressed that maintaining feasibility under inclusionary regulation is often based on maximizing State density bonus provisions. However, the costs associated with constructing denser, taller projects may outweigh financial returns.
Developers described Antioch as a “secondary market” that cannot support multifamily projects over three stories tall , which could limit additional density.
o Necessity of in-lieu fees. Developers stated that if the City were to adopt an IHO, it should include the option to pay in-lieu fees. Participants stressed that real estate is unpredictable, and that these fees offer “stability and clarity” in the IHO process. Because of this certainty, most developers will likely choose the in-lieu fee option.
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o Value of in-lieu fees. Developers stated that in -lieu fees should be transferred to affordable housing developers who specialize in maximizing funds and partnerships for affordable housing projects. Developers stressed that partnering with affordable housing developers in mixed- income developments often provides the greatest number of affordable units at the lowest income levels.
o Barriers to f or-sale affordable housing. Developers stressed that the difficulty of qualifying for home loans may impede the function of an IHO.
Per participants, lower income households in Contra Costa typically face severe economic barriers to mortgage qualification, including an adequate down payment. As such, requiring the construction of for-sale units for very low-income or low-income households may be an unproductive path toward privately subsidized affordable housing.
Community Workshop. Staff and PlaceWorks conducted a bilingual, interactive virtual Community Workshop on February 4, 2025. Participants were introduced to the IHO project and responded to a series of Zoom-based polls regarding various IHO topics. The polls included the following questions:
1. What household affordability levels do you want to see accommodated in Antioch?
o 64% of responders selected Very Low -Income households as the most needed.
2. What bedroom counts are most needed in affordable units in Antioch? o 67% of responders selected 2-3 bedroom units.
3. What type of affordable housing units does Antioch need? o “For-rent apartments” was identified as the most needed housing type, and “for-sale single family homes” was identified as the least needed.
4. Should the default requirement in Antioch's IHO be “constructing affordable units with the option to pay a fee,” or “paying a fee with the option to construct affordable units?”
o 67% of responders selected “constructing affordable units with the option to pay a fee.”
5. Select areas of Antioch where new affordable housing will provide extra benefit to future residents.
o The two answers that received the most selections were “In and near downtown” and “Around the BART Station.”
6. What are the most important aspects of affordable units created by the IHO? Antioch City Council Report
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o The two answers that received the most selections were “They are evenly distributed across the development site ” and “Their exterior design and construction quality matches the market rate units.”
7. Participants were asked whether 1) T hey support adopting an IHO and to identify issues the City Council should consider to ensure the IHO is effective, or 2) T hey do not support adopting an IHO and to identify alternative approaches to increasing affordable housing.
o 78 percent of participants stated they support adopting an IHO. Comments included:
The need to place upper limits on IHO requirements.
The value of collaborating with developers on a 15% IHO requirement near transit.
Lack of support for in- lieu fees, which require significant staff resources to administer.
o 22 percent of participants stated they do support adopting an IHO.
Comments included:
The City should purchase land for 100% affordable housing. This is the only way to build the minimum of more than 1 new affordable home for every market rate home.
Antioch is already largely affordable; the City should focus on fully staffing the police force and bringing anchor businesses to downtown and the shopping mall.
IHOs benefit only a few who can secure the units , while driving up costs for everyone else. Antioch should look for alternative sources of funding that do not drive up housing costs.
IHO Staffing Plan. PlaceWorks completed an IHO Staffing Plan on April 20, 2025 as part of its agreement with the City (https://antioch-iho.com/wp- content/uploads/2026/01/DRAFT_Antioch_IHO_Staffing_4.20.25-002.pdf). To understand the staff resources required to administer and manage an IHO, PlaceWorks released an online survey for staff of local jurisdictions that participate in IHO administration. Staff from Concord, Contra Costa County, Richmond, Pittsburg and El Cerrito participated. The following is a summary of feedback:
o 75% of responders answered that 1 -3 staff members work on IHO administration at any given time. 25% answered 4-6 staff members. o 75% of responders answered that IHO -related work “fluctuates ,” making long-term staff planning difficult.
o Nearly all r esponders indicated that staff from the Planning/Building department and the local Housing Authority work on IHO administration. It should be noted that Antioch does not have a Housing Authority. o Responders estimated the number of staff hours d edicated to IHO administration each week to be 4-8 hours.
o Responders identified the following skills as required for IHO implementation:
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Resale restrictions oversight & compliance.
Preparation of the deed restriction Agreement along with other legal document templates.
Calculation of the maximum sales prices.
Ongoing monitoring and property tracking.
Staffing over the period of affordability because deed restrictions can be 55 years and that is a long-term staff commitment.
The initial sale of homeownership units, especially through a lottery process.
Study Sessions
Planning Commission Study Session – April 16, 2025. Staff and PlaceWorks conducted an IHO Study Session with the Antioch Planning Commission on April 16, 2025. PlaceWorks made a background presentation and solicited Planning Commission feedback using a series of prepared questions. o Public comment. Four members of the public spoke at the Study Session.
Three commenters representing the East Bay Housing Organizations (EBHO), Hope Solutions, and Contra Costa County Multi -Faith ACTION Coalition, spoke in support of the potential IHO. One public speaker representing North Cal Carpenters Local Union 152 asked if the IHO would include labor standards.
City Council Study Session – May 27, 2025. Staff and PlaceWorks conducted an IHO Study Session with the Antioch City Council on May 27, 2025. PlaceWorks made a background presentation and solicited City Council feedback using a series of prepared questions.
o Public comment. Three members of the public spoke at the Study Session, all in support of an IHO.
City Council Study Session - August 26, 2025. Staff conducted a second IHO Study Session with the Antioch City Council on August 26, 2025 and solicited City Council feedback.
o Public Comment. Twelve members of the public spoke. Nine commenters represented a coalition of housing advocates and supported the project.
One speaker spoke on potential legal challengers to IHOs. One speaker encouraged more discussion on the matter. A final speaker spoke in support of the IHO an in opposition to in-lieu fees.
City Council Study Session - September 16, 2025. Staff conducted a third IHO Study Session with the Antioch City Council on September 16, 2025 and solicited City Council feedback. The feedback that staff received was incorporated into the IHO presented tonight.
o Public Comment. One speaker representing a coalition of housing advocates spoke in support of the IHO.
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ANTIOCH IHO PROJECT COMPONENTS
In-Lieu Fee Analysis
Staff and PlaceWorks completed an In -Lieu Fee Analysis and Recommendation (Attachment F) to determine the amount of the fee that developers would need to pay in- lieu of constructing each required affordable unit onsite. For reference, the in- lieu fees charged by other Contra Costa jurisdictions is included in Attachment G.
Multiple approaches are commonly used to determine IHO in-lieu fees. Antioch used the “Affordability Housing Financing Gap” approach. This approach involves identifying the difference between the total cost of developing a single affordable unit in Antioch and the sum of the two types of permanent financing that affordable housing developers reliably access. The in-lieu fee is intended to cover this gap.
The two permanent financing sources are:
1. Low-Income Housing Tax Credits (LIHTC) . These are tax credits that the federal government annually provides to states to distribute to affordable housing development projects.
2. Bank financing. Affordable housing projects rely on conventional bank financing for permanent funding, as market rate developers do.
Data Sources. The in-lieu fee analysis relies on two primary data sources:
1. Affordable housing projects from the California State Treasurer, California Ta x Credit Allocation Committee. The analysis uses detailed project and cost data from five recent affordable housing projects throughout Contra Costa County that were awarded LIHTC from the State of California.
2. Affordable Housing Developers. PlaceWorks shared initial estimates of the cost of developing an affordable housing unit in Antioch and the IHO in-lieu fee with local affordable housing developers, including Eden Housing and Cypress Equity. The final analyses and in-lieu fee recommendation reflect developer input.
Contra Costa County Affordability Gap
The analysis first identified the affordable housing financing gap for Contra Costa County as a whole. The analysis used data from five recent affordable housing projects throughout Contra Costa County that were awarded LIHTC from the State.
As shown in the table below, the cost of constructing a single affordable unit in Contra Costa County is approximately $882,000, while total tax credits and bank financing available to the projects was shown to be $476,000. As such, the financing gap per unit is about $406,000, or 46.02% of the average cost per unit.
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Construction Cost per Unit $882,000
Less Bank Financing -$134,400
Less Federal 4% Tax Credit Equity -$342,000
Financing Gap per Unit $406,000
- Percentage of Average Cost per Unit 46.02%
Source: PlaceWorks 2025, using cost and funding data from the CA Tax Credit Allocation Committee.
Antioch Affordability Gap and In-lieu Fee
The table below summarizes estimated costs for a conceptual affordability housing development in Antioch. The table reflects input from local developers, who stressed that current soft costs, including design and entitlement, are equal to 25 -30% of hard costs , including construction costs and site work, a significant increase from PlaceWorks’ initial estimates.
As shown in the table, the current average development cost of a single affordable unit in Antioch is $440,000.
Land Acquisition Cost $2,130,000
Hard Costs
Site Work $3,570,000
Construction 17,840,000
Hard Cost Subtotal $21,400,000
Soft Costs
Design, entitlement, and other soft costs @25.0% $5,350,000 Contingency @10.0% $2,140,000
Impact Fees $1,639,000
Soft costs subtotal $9,130,000
Development cost (before financing) $32,700,000
Financing cost $3,410,000
Total development cost $36,100,000
- per affordable housing unit $440,000
Source: PlaceWorks, 2025.
Next, the affordable housing financing gap, defined above as 46.02% of development cost for recent projects, was applied to the estimated cost for new affordable housing construction in Antioch. With an estimated development cost of $440,000 per affordable dwelling unit and an expected financing gap of 46.02%, the City would need to collect $202,500 through an in -lieu fee for each affordable inclusionary unit that a market rate developer opts to forego building onsite.
As such, the current recommended IHO in-lieu fee is $202,500 per unit.
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On July 1 of each calendar year, the amount of the in- lieu fee is recommended to be increased based on the increase in the United States Bureau of Labor Statistics’ Consumer Price Index (CPI) and to be incorporated into the City’s Master Fee Schedule.
The establishment of the in-lieu fee is included in the resolution in Attachment C.
Inclusionary Housing Ordinance
The proposed City of Antioch Inclusionary Housing Ordinance ( Attachment A) has been completed by City staff. The ordinance is composed of the following basic regulations:
Applicable Geography. The proposed IHO requirements apply to Residential Development Projects citywide.
Affordability Term. The proposed IHO requires all BMR units to be affordable in perpetuity.
Threshold Project Size. The proposed IHO requirements apply to all Residential Development Projects consisting of 5 or more units. Note: This number is tied to the processes in State Subdivision Map Act for Tentative Parcel Maps (four lots or less) and Tentative Subdivision Maps (5 or more lots) for ease of administration. Income and Affordability Requirements. As proposed, 15 percent of all new Residential Development Projects shall be affordable to VLI and LI incomes .
Specifically:
o Ten percent of the BMR units shall be affordable to VLI households. o Five percent of the BMR units shall be affordable to LI households. o The first BMR unit shall be affordable to VLI households, the second unit shall be affordable to LI households, and so forth for all the BMR units in the project.
In-Lieu Fee Regulation. The proposed IHO includes the option to pay a per -unit fee as an alternative to constructing on-site inclusionary units. The recommended fee is $202,500 per unit,
due at the issuance of building permits. The fee is
proposed to be updated annually.
o As an option, the City could add an additional percentage factor to the proposed fee to work as a disincentive, thereby making on-site development more financially feasible.
Alternative Compliance Options. The proposed IHO does not include alternatives for complying with inclusionary requirements, other than payment of in-lieu fees.
Developer Incentives. The proposed IHO does not include incentives , such as fee waivers, smaller lot and unit sizes for BMR units, for developers to comply with Antioch City Council Report
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requirements. Developers would be able to take advantage of State Density Bonus Law when building on-site affordable projects, including waivers and concessions.
Affordable Housing Plan. The proposed IHO requires applicants to submit an Affordable Housing Plan (AHP) and Inclusionary Housing Agreement (IHA) as part of their development application. These documents must specify calculations used to determine the number of inclusionary units; plans depicting inclusionary unit locations; the process by which households will be reviewed and selected to purchase or rent inclusionary units; the terms of affordability; annual reporting requirements and other components of the required inclusionary housing program.
Affordable Unit Standards. The proposed IHO includes standards to ensure that affordable units are of the same quality as Market Rate Units. Per the IHO, all affordable units shall:
Be built in the same proportion as the Market Rate Units.
Have an average square footage of at least 90 percent of Market Rate Units with the same bedroom count.
Be developed with the same bedroom count ratio as the Market Rate Units.
Have the same quality of exterior design and overall quality of construction as the Market Rate Units.
Have the same quality and type of interior finishes and features as the Market Rate Units.
Meet all site, design, and construction standards included in Title 8 (Building Regulations) and Title 9 (Planning and Zoning) of the Antioch Municipal Code.
Inclusionary Housing Trust Fund (IHTF)
The City’s adopted and State certified 6th Cycle Housing Element (2023- 2031) of the General Plan contains provisions to meet the existing and projected housing needs of all economic segments of the City. Specifically, it contains strategies and implementation programs that focus on:
Maintaining and Preserving an Affordable Stock
Expanding Affordable Housing Ownership
Reducing Household energy Costs to Increase Housing Affordability Infrastructure to Support Housing for Extremely Low, Very Low, Low and Large Households
Supporting Non-Profit Housing Sponsors
ADU/JADU loans/Promoting ADU’s as Affordable Housing
Senior Housing
Incentives for Special Needs Housing
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Rental Assistance
Housing and Services for those with Disabilities
Incentivizing Accessible Units
Home Repairs
Economic Development in Environmental Justice (EJ) Neighborhoods Specific Policies within the Housing Element encourage the funding of affordable housing projects/programs through regulatory incentives, concessions and available financial assistance. Further, the Element also provides policies that encourage fee waivers and collaborative partnerships in order to provide greater access to available housing funds.
The establishment and creation of a IHTF will further the goals of the Housing Element/General Plan. A IHTF is a dedicated fund for the purpose of promoting housing for low and moderate household incomes. The in-lieu fees that are collected from the IHO will be deposited into the IHTF.
In addition to establishing and creating the I HTF, “Administrative Guidelines” are established by the attached City Council resolution (Attachment B) that describe projects eligible for consideration of funding under the IHTF, which are described below:
Creation of new affordable units;
Preservation of existing affordable housing;
Assistance with multi-family rehabilitation programs; Conversion of market rate units to affordable housing units Support of the construction of accessory dwelling units; Acquisition and rehabilitation of potential limited equity housing co-operatives; First time homebuyer loans or other forms of assistance; Predevelopment loans/grants to assist non- profit and for -profit developers with project feasibility studies, site acquisition and preliminary design studies for potential affordable housing projects;
Administrative costs for affordable housing programs and projects; Program development, research or community engagement efforts focusing on housing matters;
Purchase of land for the development of affordable housing projects; and Rent, mortgage and utility payment assistance to Very Low-, Low-, and Moderate- income families during the time of a declared emergency by the City Manager.
The above-mentioned list of projects eligible for consideration of funding under the I HTF is a baseline list that can be amended over time at the discretion of the City Council by future resolution.
Compliance Monitoring Fees
As detailed in the IHO Staffing Plan section of the staff report, above, ongoing annual monitoring the affordable units involves staff time. Included in the resolution (Attachment C) amending the Master Fee Schedule is a compliance monitoring fee for both annual rental inspections ($50 per unit annually) and an ownership change fee for a change of Antioch City Council Report
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ownership of a for -sale unit ($500 per change of ownership). The recommended fee amounts are based on staff time estimates and the cost of other cities’ fees. On July 1 of each calendar year, the amount of the in-lieu fee is recommended to be increased based on the increase in the United States Bureau of Labor Statistics’ CPI.
PLANNING COMMISSION PUBLIC HEARING
On February 4, 2026, the Planning Commission held a public hearing regarding the proposed IHO. At the meeting, PlaceWorks provided a background presentation on the IHO and contents of the ordinance and the related IHTF and possible in- lieu fee. Draft meeting minutes are included as Attachment I.
Public Comment. One member of the public opposed the IHO with six members of the public representing coalitions of housing advocates spoke in favor.
The Planning Commission voted 4-0, with two members absent, recommending that the City Council adopt the IHO . The Planning Commission also provided recommendations and requested that the City Attorney review them prior to the City Council reviewing the IHO. The Planning Commission recommended:
That the housing units created with the I HTF shall be prioritized for residents of Antioch;
That the IHO and IHTF gives preference to local unions; That the IHTF document shall be reviewed in detail to ensure that t he Administrative Guidelines ensure funds are prioritized for housing development projects;
That the IHTF shall prioritize “extremely” low-income households (ELI); That a review of the IHO and IHTF be conducted during the first quarter of the first year and every two years thereafter.
The review process shall include a review of the percentage of projects utilizing the in- lieu fee in order to determine if the in- lieu fee shall be increased if a significant percentage of developers choose the in-lieu fee option.
Review of the Planning Commission’s Recommendations
The City Attorney’s Office reviewed the recommendations and determined that firstly, the City cannot implement a policy giving priority to Antioch residents over non- residents for housing assistance funded by inclusionary in- lieu fees, and secondly, the Ci ty cannot require private developers to prioritize local union labor over non- union contractors for construction work on inclusionary housing projects.
1) Priority to Antioch residents
To the question of prioritizing Antioch residents for housing assistance, the City of Antioch generally cannot lawfully adopt a broad resident-priority rule for assistance funded by inclusionary in-lieu fees, particularly for homebuyer subsidies. California law strongly protects statewide housing objectives and fair housing principles, and such a preference would likely conflict with those goals.
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Government Code § 65583 requires each city’s H ousing Element to include programs that affirmatively further fair housing (AFFH). The Court of Appeal in Martinez v. City of Clovis (2023) 90 Cal.App.5th 193, 236–237, confirmed that local actions creating a disparate impact on lower -income housing violate this enforceable duty. A rule giving priority to Antioch residents would limit regional access to assistance, undermining the Regional Housing Needs Allocation (RHNA) process outlined in § 65584 and conflicting with the broader state objective of addressing housing shortages across jurisdictions.
Government Code § 7061 (the Local Tenant Preferences to Prevent Displacement Act, enacted through SB 649) permits limited local preferences, its scope is narrow. It applies only to tenants in affordable rental housing financed through low- income housing tax credits (LIHTCs) or tax -exempt bonds, with the specific goal of preventing displacement in gentrifying areas. The statute provides no authority for preferences in for-sale (ownership) units or homebuyer subsidy programs, and any preference must st ill comply with AFFH obligations under § 8899.50 et seq. and other fair housing laws.
As a result, preferences in inclusionary housing programs are typically restricted to rental units to remain consistent with § 7061. There is no broad legal authority for resident preferences in for -sale units, because state policy prioritizes regional access over local favoritism. While a small number of jurisdictions have adopted community preferences for both rental and ownership units—often justified by anti- displacement or community stability goals—such measures are uncommon, must be narrowly tailored, and carry substantial legal risk of violating fair housing laws or preemption principles.
2) Union Labor
To the second question regarding union labor, the City of Antioch cannot lawfully require private developers to give priority to union labor over non-union contractors on inclusionary housing projects.
Such a requirement would first be preempted by federal law under the National Labor Relations Act (NLRA), which governs private- sector labor relations and occupies the field to the exclusion of most local regulation.
Beyond federal preemption, the requirement would impose a governmental constraint on housing development in violation of the Housing Element Law.
Government Code § 65583 directs cities to identify and remove constraints — including locally adopted ordinances—that increase the cost or reduce the supply of residential development, particularly for lower -income households. Mandating union labor would limit competition among contractors, raise construction costs, and potentially deter private developers fr om pursuing inclusionary projects, directly frustrating the city’s ability to meet its regional housing needs.
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The mandate would also undermine the city’s duty to affirmatively further fair housing under Government Code § 65583(c)(5), which requires cities to promote housing opportunities without discrimination and to advance fair housing for all persons. By increasing costs and constraining production, a union- labor preference could disproportionately affect lower -income households who depend on inclusionary units, creating a disparate impact that violates AFFH obligations.
Finally, the requirement may constitute an improper exercise of zoning authority.
Cities derive their zoning power from the police power under Article XI, Section 7 of the California Constitution, but Government Code § 65008 prohibits discriminatory application of that power. Favoring union contractors over non- union ones lacks a reasonable relationship to legitimate land- use objectives and could be challenged as an unjustified restriction that impedes housing production without adequate justification.
Based on the above information, staff ha s determined not to recommend that the City Council include the two above recommendations. With respect to other four recommendations, staff provides the following:
1. That the I HTF document shall be reviewed in detail to ensure that the Administrative Guidelines ensure funds are prioritized for housing development projects;
Staff response: The Administrative Guidelines provide options for the City Council to determine how fund are spent from the account and allows funds to be spent strategically on a variety of needs.
2. That the IHTF shall prioritize “extremely” low-income households (ELI); Staff response: This household income level is not included within the RHNA and is incorporated/included within the VLI range.
3. That a review of the IHO and IHTF be conducted during the first quarter of the first year and every two years thereafter.
Staff response: The City Council could include this recommendation in the draft ordinance and Administrative Guidelines which will provide direction to staff.
4. The review process shall include a review of the percentage of projects utilizing the in- lieu fee in order to determine if the in -lieu fee shall be increased if a significant percentage of developers choose the in-lieu fee option.
Staff response: The City Council could require this review to be conducted in the first annual review of the ordinance and Administrative Guidelines as referenced above.
ENVIRONMENTAL REVIEW
Staff has determined that the proposed IHO is exempt from CEQA pursuant to CEQA Guidelines section 15061(b)(3) because the ordinance will impose a regulatory requirement and not affect the environment. The proposed IHO and in- lieu fee will not allow for or encourage new development or otherwise allow for or promote physical change in the environment. Residential development projects that include inclusionary Antioch City Council Report
March 10, 2026 Item # 8 20
housing will be reviewed pursuant to CEQA on a case-by-case basis upon application to the City. This determination reflects the City’s independent judgment and analysis.
ATTACHMENTS
A. Inclusionary Housing Ordinance
B. Resolution Establishing an Inclusionary Housing Trust Fund C. Resolution Modifying the Master Fee Schedule
D. Summary of Existing IHOs in Contra Costa County
E. Inclusionary Housing Ordinance Financial Feasibility Analysis F. In-Lieu Fee Analysis and Recommendation Memo
G. In-Lieu Fees in Contra Costa County
H. Public Comments Received for the February 4, 2026, Planning Commission Meeting
I. Draft Meeting Minutes from February 4, 2026, Planning Commission Meeting
Ordinance No. XXXX-C-S Page 1 of 12 Adoption Date
ORDINANCE NO. XXXX-C-S
AN ORDI
NANCE OF THE CITY COUNCIL OF THE CITY OF ANTIOCH
ADDING TITLE 9, CHAPTER 5, ARTICLE 43 TO THE ANTIOCH MUNICIPAL CODE,
INCLUSIONARY HOUSING
WHE
REAS, the Legislature of the State of California has found that the availability of housing is of vital statewide importance. The Legislature has further found that local governments have a responsibility to use the powers vested in them to make adequate provisions for the housing needs of all economic segments of the community; WHE
REAS, the Legislature requires that City encourage the development of a variety of types of housing for all income levels to help meet the City’s assigned share of the regional housing need;
WHE
REAS, inclusionary housing ordinances typically require the development or payment of in-lieu fees for affordable housing;
WHE
REAS, the City of Antioch’s Housing Element Program 2.1.10 requires the City to initiate a feasibility study for an inclusionary housing ordinance for City Council consideration;
WHE
REAS, the City of Antioch completed a feasibility study for an inclusionary housing ordinance and the City Council directed that an ordinance be prepared; WHE
REAS, Title 9, Chapter 5, Article 43 of the Antioch Municipal Code will require that the development of new market-rate housing units include a percentage of units that are affordable to very low- and low-income households and be built on-site or that an in- lieu payment be made, as required by Program 2.1.10;
WHE
REAS, on February 4, 2026, the Planning Commission held a duly noticed public hearing to consider the proposed Ordinance related to affordable housing, received the staff report and staff presentation, received comments from the public and interested parties, and discussed the matter. Following the public hearing, the Planning Commission adopted Resolution N o. 2026-02 recommending the City Council adopt the proposed Ordinance;
WHE
REAS, on March 10, 2026, the City Council held a duly noticed public hearing to consider the proposed Ordinance related to affordable housing, received the staff report and staff presentation, received comments from the public and interested parties, considered the recommendation of the Planning Commission and discussed the matter; and
WHE
REAS, all legal prerequisites to the adoption of the Ordinance have occurred.
The C
ity Council of the City of Antioch does ordain as follows:
ATTACHMENT "A"
A1
Ordinance No. XXXX-C-S Page 2 of 12 Adoption Date
SECTION 1: Recitals
The recitals above are true and correct and are hereby adopted as findings as if fully set forth herein.
SE
CTION 2: Findings
The City Council finds that the Ordinance is necessary to further the public necessity, convenience, and general welfare in that this amendment to the Antioch Municipal Code implementing the City’s Housing Element Program 2.1.10, in the furtherment of developing a variety of types of housing for all household income levels.
SE
CTION 3: City Council Review
The City Council has reviewed, considered, and evaluated all of the information prior to acting upon Ordinance.
SE
CTION 4: Record of Proceedings
The documents and other materials that constitute the record of proceedings upon which the City Council has based its recommendation are located in and may be obtained from the City of Antioch’s Clerk’s Office, 200 H Street, Antioch, CA 94509 SE
CTION 5: Amendment
The Antioch Municipal Code is hereby amended as follows:
Ti
tle 9, Chapter 5, Article 43: Inclusionary Housing Ordinance § 9-5.
4301 Citation.
Thi
s Article may be known and cited as the "Inclusionary Housing Ordinance" of the City of Antioch. (Ord. xxx, passed xx-xx-xxx)
§ 9-5.
4302 Purpose
The p
urpose of the following Inclusionary Housing requirements are to:
A. Enha
nce the public welfare by facilitating the construction of housing affordable to households of Very Low and Low Incomes in all areas of the city.
B. Ens
ure that future residential development is consistent with housing policies of the State of California and the City of Antioch.
C. Ens
ure that each Residential Development Project complies with the requirements of this Article and is consistent with the city's housing goals of developing affordable housing, creating diverse housing opportunities for existing and future residents, and maintaining economic diversity and geographically dispersed affordable housing.
A2
Ordinance No. XXXX-C-S Page 3 of 12 Adoption Date
§ 9-5.4303 Definitions.
A. Ac
cessory Dwelling Unit (ADU) shall have the same meaning as defined under Section 66313 (a) of the Government Code and shall mean an attached or detached residential dwelling unit that provides complete independent living facilities for one or more persons and is located on a lot with a proposed or existing primary residence. It shall include permanent provisions for living, sleeping, eating, cooking, and sanitation on the same parcel as the single-family dwelling. An ADU also includes an efficiency unit and a manufactured home, provided it is built on a permanent foundation. An ADU may be located within an existing attached or detached garage, shed, barn or other accessory structure.
B. Af
fordable Dwelling Unit shall mean, for the purposes of this Article, a dwelling unit affordable to households earning at or below 120 percent of the county median income, including units that are affordable to Very Low and Low Income Households.
C. Af
fordable Housing Plan shall mean a plan on a form provided by the city that shall be submitted by the applicant or developer, containing all the information specified in and in conformance with Section 9-5.4305.F of this Article specifying the manner in which Inclusionary Units will be provided in conformance with this Article.
D. At
tached Single-Family Dwelling Unit shall mean a dwelling unit that is designed for occupancy by one household located on a separate lot from any other unit (except an accessory dwelling unit, where permitted), and attached through common vertical walls to one or more dwellings on abutting lots. Two attached single-unit dwellings may be configured as townhouses or row houses.
E. Com
mon Ownership and Control shall mean property owned or controlled by the same person, persons, or entity, or by separate entities in which any shareholder, partner, member, or family member of an investor of the entity owns ten percent or more of the interest in the property.
F. Dens
ity Bonus shall mean a density increase over the otherwise maximum allowable density on a site pursuant to California Government Code Section 65915 and Article 35 of the Antioch Zoning Code, or for any other reason.
G. Det
ached Single-Family Dwelling Unit shall mean a dwelling unit that is designed for occupancy by one household, located on a separate lot from any other dwelling unit (except an accessory dwelling unit, where permitted), and not attached to another dwelling unit on an abutting lot. This classification includes individual manufactured housing units installed on a foundation system pursuant to Cal.
Health and Safety Code § 18551.
H. For-S
ale Residential Development Project shall mean a Residential Development Project that includes the creation of one or more new dwelling units that may be sold individually. A For -Sale Residential Development Project also includes the A3
Ordinance No. XXXX-C-S Page 4 of 12 Adoption Date
conversion of a residential rental development to a residential ownership development.
I. Inc
lusionary Unit shall mean a dwelling unit intended for sale or rent that is required by Section 9-5.4304 to be affordable to Very Low or Low Income Households.
J. Inc
lusionary Housing Agreement shall mean an agreement in conformance with Section 9-5.4305.F of this Article between the city and an applicant, governing how the applicant shall comply with this Article.
K. Juni
or Accessory Development Unit (JADU) shall have the same meaning as defined under Section 66313 (d) of the Government Code and shall mean a unit that is no more than 500 square feet in size and contained entirely within a single- family residence.
L. Low I
ncome Household shall mean a household whose income does not exceed the low income limits applicable to Contra Costa County as defined in California Health and Safety Code Section 50079.5 and published annually pursuant to Title 25 of the California Code of Regulations, Section 6932 by the California Department of Housing and Community Development.
M. Mar
ket Rate Unit shall mean a new dwelling unit in a Residential Development Project that is not an Affordable Dwelling Unit.
N. Mul
ti-Family Unit shall mean one of three or more residential units contained within a single building or within two or more buildings on a site or lot. Types of multiple- unit dwellings include garden apartments, senior housing developments, multi - story apartment buildings, and condominiums. They may include side-by-side units separated by common vertical walls that are configured as townhouses or row houses.
O. Rent
al Residential Development Project shall mean a Residential Development Project that creates one or more dwelling units that cannot be lawfully sold individually.
P. Res
idential Development Project shall mean a development for which a building permit is required for a residential development that includes the creation of one or more new dwelling units, conversion of nonresidential uses to dwelling units, or the conversion of a use from a Rental Residential Development Project to a For - Sale Residential Development Project. Residential Development Projects include projects with a combination of dwelling units and commercial or other non- residential land uses.
Q. Unit
Type shall mean the type of dwelling unit, either Attached Single- Family Dwelling Unit, Detached Single-Family Dwelling Unit, or Multi-Family Unit.
R. Ver
y Low Income Household shall mean a household whose income does not exceed the very low income limits applicable to Contra Costa County as defined in A4
Ordinance No. XXXX-C-S Page 5 of 12 Adoption Date
California Health and Safety Code Section 50079.5 and published annually pursuant to Title 25 of the California Code of Regulations, Section 6932 by the California Department of Housing and Community Development.
S. Ves
ting Tentative Subdivision Map or Vesting Tentative Parcel Map shall mean a map which confers certain vested rights to proceed with development. § 9-5.
4304. Effective Date and Inclusionary Housing Requirement Applicability A. Ap
plicability. All For -Sale and Rental Residential Development Projects that consist of 5 or more units built in the City of Antioch shall comply with the requirements of this Article.
B. Ex
emptions. The provisions of this Article shall not apply to the following projects:
1. Ac
cessory Dwelling Units and Junior Accessory Dwelling Units.
2. Res
idential Development Projects on property with vested rights in effect on the effective date of this Article, including:
a. Pr
operty that is part of a Vesting Tentative Subdivision Map or Vesting Tentative Parcel Map.
b. Dev
elopment that is part of an existing Development Agreement with the city.
c. Dev
elopment applications vested pursuant to preliminary application requirements of Government Code section 65589.5 (o).
3. Res
idential Development Projects that have submitted a complete planning or building permit application along with the full payment of required application fees to the city prior to the effective date of this ordinance.
4. Res
idential Development Projects exempted by California Government Code Section 66474.2 or 66498.1, provided that such Residential Development Projects shall comply with any predecessor ordinance, resolution, or policy in effect on the date the application for the development was determined to be complete.
5. Res
idential Development Projects exempted by another state law or by final judgement of a court of competent jurisdiction.
6. Ex
isting residences that are altered, improved, restored, repaired, expanded, or extended; provided that the number of dwelling units is not increased and the existing floor area of the dwelling unit is not increased by 850 square feet or more. These units will be subject to a fee per square foot for any increase in square footage greater than 850 square feet.
A5
Ordinance No. XXXX-C-S Page 6 of 12 Adoption Date
§ 9-5.4305. Inclusionary Housing Requirements
Al
l new Residential Development Projects not exempted per Section 9- 5.4304.B shall include Inclusionary Units. Calculations of the number of Inclusionary Units shall be based on the number of dwelling units in the Residential Development Project, without regard to any density bonus units provided pursuant to State Density Bonus provisions. All required Inclusionary Units shall be built on the same site as the Residential Development Project.
A. Inc
lusionary Requirement . Fifteen percent of all new Residential Development Projects shall be Inclusionary Units. The fifteen percent total shall be achieved using the following affordability requirements:
1. Ten
percent of the dwelling units shall be affordable to Very Low Income Households.
2. Fi
ve percent of the dwelling units shall be affordable to Low Income Households.
3. The f
irst required unit shall be provided at the VLI household category, the second shall be at the LI household category and so forth repeated.
B. Fr
actional Units. When the application of the percentages specified in Section 9-
5.4305.A results in a number that includes a fraction equal to one- half (0.5) or more, the fraction shall be rounded to the next higher whole number. In that event an additional Inclusionary Unit shall be provided. If the result includes a fraction less than one- half (0.5), the fraction shall be rounded down. In that event no additional Inclusionary Unit shall be required.
C. St
ate Density Program. Any Inclusionary Units provided on site in compliance with this Article may be used to qualify for a density bonus under California Government Code Section 65915, or any ordinance implementing Government Code Section 65915.
D. Bas
e for Inclusionary Requirement. The number of Inclusionary Units required for a project shall be based on the total number of dwelling units in the Residential Development Project prior to the addition of units under the State Density Bonus provisions.
E. Cont
iguous Property under Common Ownership and Control . An applicant for a Residential Development Project shall not avoid the requirements of this Article by submitting piecemeal planning permit applications. At the time of the application for first approval for the Residential Development Project, the applicant shall identify all contiguous property under common ownership and control. The applicant shall not be required to construct dwelling units upon the contiguous property at the time of the application for first approval; however, the applicant shall be required to include the contiguous property under common ownership or control in its Affordable Housing Plan. The Inclusionary Housing Agreement shall be recorded against the Residential Development Project and all contiguous property A6
Ordinance No. XXXX-C-S Page 7 of 12 Adoption Date
under common ownership or control and shall require compliance with this Article upon development of each contiguous property at such time as there are planning permit applications that would authorize a total of five or more dwelling units for the residential development and the contiguous property under common ownership or control.
F. Af
fordable Housing Plan and Inclusionary Housing Agreement.
1. An A
ffordable Housing Plan shall be submitted as part of the application for first approval of any Residential Development Project whether paying the in-lieu fee in conformance with Section 9-5.4306 of this Article or providing inclusionary units on-site. No application for a first approval for a Residential Development Project may be determined to be complete unless an Affordable Housing Plan is submitted and approved by the city in conformance with the provisions of this Article.
2. For
each construction phase, the Affordable Housing Plan shall specify:
a. The c
alculations used to determine the number of inclusionary units; b. A floor plan or site plan depicting the location of the inclusionary units;
c. The tenure and affordability level for each inclusionary unit; d. The term of affordability;
e. A phasing plan for phased developments;
f. A description and details of any requested incentives, waivers, or exemptions;
g. The process by which eligibility of qualified households will be reviewed and selected to purchase or rent inclusionary units; h. Rent
al/ownership regulatory provisions;
i. An annual reporting schedule and requirements;
j. A statement signed by the applicant and property owner, if different, that the Inclusionary Housing Agreement required by this Article shall include a provision that authorizes the city to recover reasonable attorneys' fees, investigation and litigation ex penses, and related staff costs associated with enforcing the Inclusionary Housing Agreement; and
A7
Ordinance No. XXXX-C-S Page 8 of 12 Adoption Date
k. Any
other information that is reasonably necessary to evaluate the compliance of the Affordable Housing Plan with the requirements of this Article and any regulations adopted to implement this Article.
3. Upon s
ubmittal, the Community and Economic Development Director shall determine if the Affordable Housing Plan is complete and conforms to the provisions of this Article. The decision of the Community and Economic Development Director may be appealed to the Planning Commission by filing a written appeal in the manner outlined by the AMC. The appeal shall identify the decision being appealed and shall clearly and concisely state the reasons for the appeal.
4. The A
ffordable Housing Plan shall be reviewed as part of the first approval of any Residential Development Project. The Affordable Housing Plan shall be approved if it conforms to the provisions of this Article. A condition shall be attached to the first approval of any Residential Development Project to require recordation of the Inclusionary Housing Agreement described in this Article prior to the approval of any Final or Parcel Map or building permit for the Residential Development Project.
5. A r
equest for a minor modification of an approved Affordable Housing Plan may be granted by the Community and Economic Development Director if the modification is substantially in compliance with the original Affordable Housing Plan and conditions of approval. Other modifications to the Affordable Housing Plan shall be processed in the same manner as the original plan.
6. Fol
lowing the first approval of a Residential Development Project, the city shall prepare an Inclusionary Housing Agreement providing for implementation of the Affordable Housing Plan and consistent with any regulations adopted to implement this Article. Prior to the approval of any Final or Parcel Map or issuance of any building permit for a residential development subject to this Article, the Inclusionary Housing Agreement shall be executed by the city and the applicant and recorded against the entire Residential Development Project property and any other property used for the purposes of providing inclusionary housing pursuant to this Article to ensure that the affordable housing agreement will be enforceable upon any successor in interest. The Inclusionary Housing Agreement shall not be amended without the approval of the City Council and shall also not be amended prior to any necessary amendments to applicable planning permits.
§ 9-5.
4306 – Inclusionary Requirement In-Lieu Fees
A devel
oper of an applicable Residential Development Project may pay an in- lieu fee rather than providing Inclusionary Units.
A8
Ordinance No. XXXX-C-S Page 9 of 12 Adoption Date
A. Purpose. An in-lieu fee is an option that may serve as an alternative to the provision of on-site inclusionary units.
B. Am
ount. In-lieu fee amounts in the fee schedule shall be set by resolution of the city council.
C. Annu
al Adjustment. On July 1 of each calendar year, the amount of the in-lieu fee shall be increased based on the increase year over year in the US Department of Labor, Bureau of Labor Statistics’ Consumer Price Index for urban consumers (CPI-U). All items in U.S. city ave rage, all urban consumers, chained, not seasonally adjusted (C-CPI-U), unless changed by resolution of the City Council.
D. Ti
ming of Payment. Payment of in-lieu fees shall be due at the issuance of building permits, unless otherwise required for law, for Residential Development Projects.
For Residential Development Projects constructed in phases, in-lieu fees shall be paid prior to issuance of each building permit in the proportion that the phase bears to the overall Rental Residential Development Project.
E. Use
. The City shall use in -lieu fees paid under this Article to support affordable housing. In-lieu fees shall be deposited into an Inclusionary Housing Trust Fund. § 9-5.
4307 - Inclusionary Unit Standards
The
following standards shall apply to all Inclusionary Units built to satisfy the requirements of this Article.
A. Uni
t Type and Physical Quality. The Unit Types of the Inclusionary Units within a Residential Development Project shall:
1. Be b
uilt in the same proportion as the Market Rate Unit Types.
2. Hav
e an average square footage of at least 90 percent of Market Rate Units with the same bedroom count.
3. Be dev
eloped with the same bedroom count ratio as the Market Rate Units.
4. Hav
e the same quality of exterior design and overall quality of construction as the Market Rate Units.
5. Hav
e the same quality and type of interior finishes and features as the Market Rate Units.
6. Meet
all site, design, and construction standards included in Title 8 (Building Regulations) and Title 9 (Planning and Zoning) of the Antioch Municipal Code.
B. At
tached Single -Family Inclusionary Units . For -Sale Single- Family Residential Development Projects may include affordable Attached Single- Family Dwelling A9
Ordinance No. XXXX-C-S Page 10 of 12 Adoption Date
Units in a proportion that constitutes more than the proportion of Attached Single- Family Dwelling Units in the overall project.
C. Pa
rcel Size . The parcel size upon which an Inclusionary Unit that is alienable separate from the title to any other Dwelling Unit is located, shall be no less than ninety percent (90%) of the median square footage of the parcels on which market rate units with the same number of bedrooms are located, provided that all lot sizes are consistent with the lot size requirements of Title 9 (Planning and Zoning) of the Antioch Municipal Code.
D. Dist
ribution. The Inclusionary Units shall be integrated into the Market Rate Units so as not to be situated in a single area of a development or located in one building of a development that contains multiple buildings. Without limiting the foregoing, in no event shall an Inclusionary Unit be adjacent to more than one other Inclusionary Unit unless the adjacent Inclusionary Unit is located on a different floor in a multi - floor building.
§ 9-5.
4308 – Ongoing Affordability and Occupancy
A. Ongoi
ng Affordability of For-Sale Units. In order to maintain the availability of For- Sale Inclusionary Units constructed pursuant to this Article, the affordable sales prices of for-sale Inclusionary Units shall be restricted in perpetuity, and reset upon resale of the unit(s), as documented through an Inclusionary Housing Agreement, as prescribed in Section 9-5.4305.F, recorded against the property.
B. Ongoi
ng Affordability of Rental Units. In order to maintain the availability of Inclusionary Units constructed pursuant to this Article, rental Inclusionary Units shall remain affordable in perpetuity, as documented through an Inclusionary Housing Agreement, as prescribed in Section 9- 5.4305.F, recorded against the property.
C. Occu
pancy. Any household that occupies an Inclusionary Unit must occupy that unit as its principal residence at all times, unless the Community and Economic Development Director approves rental to a third party for a limited period of time due to household hardship.
D. Af
fordability Agreement Documentation. The developer shall be required to execute standard documents, in a form approved by the city attorney, to ensure the continued affordability of the Inclusionary Units approved for each Residential Development Project. The documents may include, but are n ot limited to, Inclusionary Housing agreements, regulatory agreements, promissory notes, deeds of trust, resale restrictions, rights of first refusal, options to purchase, and/or other documents. The affordability documents shall be recorded against the Residential Development Project, all Inclusionary Units, and any site subject to the provisions of this Article.
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Ordinance No. XXXX-C-S Page 11 of 12 Adoption Date
§ 9-5.4309 – Implementation and Enforcement
A. Es
tablishment of Administration Fees by Resolution. The city council, by resolution, may establish fees for the ongoing administration and monitoring of the affordable units, which fees may be updated periodically, as required. The administration and monitoring fees shall be included in the Inclusionary Housing Agreement for both rental and for-sale units.
B. Enf
orcement. The city attorney is authorized to enforce the provisions of this Article and all Inclusionary Housing Agreements, regulatory agreements, covenants, resale restrictions, promissory notes, deeds of trust and other requirements placed on Inclusionary Units by civil action and any other method permitted by law. The city may take such enforcement action as is authorized under this code and/or any other action authorized by law or by any regulatory document, restriction, or agreement executed under this Article.
C. Pr
oject Approval Restrictions. No permit, license, map, or other approval or entitlement for a Residential Development Project shall be issued, including without limitation a final inspection or certificate of occupancy, until all applicable requirements of this Article have been satisfied.
D. Annu
al Monitoring. Affordable housing homeowners will receive an annual monitoring notice from the city to confirm the owner occupancy requirement and prohibitions against rental of the dwelling. The review will provide owners with an opportunity to become familiar with the guidelines of the Inclusionary Housing requirements and any changes in adopted policies and procedures. For affordable rental units, an annual monitoring notice from the city will be sent to all management agencies and/or property owners to confirm residents are eligible to live in and occupy affordable units.
SE
CTION 6: CEQA
The City Council finds that adoption of this Ordinance is exempt from the California Environmental Quality Act (Pub. Resources Code §21008 et seq.) (CEQA) and the State CEQA Guidelines (Cal. Code Regs., Title 14, §15000 et seq.) pursuant to CEQA Guidelines 15061(b)(3) – General Rule.
SE
CTION 7: Severability
Should any provision of this Ordinance, or its application to any person or circumstance, be determined by a court of competent jurisdiction to be unlawful, unreasonable, or otherwise void, that determination shall have no effect on any other provision of this Ordinance or the application of this Ordinance to any other person or circumstance and, to that end, the provisions hereof are severable.
SECT
ION 8: Publication; Effective Date
This Ordinance shall take effect and be enforced within thirty (30) days from and after the date of its adoption by the City Council at a second reading and shall be posted and published in accordance with the California Government Code.
A11
Ordinance No. XXXX-C-S Page 12 of 12 Adoption Date
* * * * * * * I HERE
BY CERTIFY that the foregoing ordinance was introduced at a regular meeting of the City Council of the City of Antioch, held on the 10th day of March 2026, and passed and adopted at a regular meeting thereof, held on the ___ day of ___ 202 6, by the following vote:
AYES:
NOES:
ABSTAI
N:
ABSENT
:
_________
________________________
ROWLAND BERNAL JR.
MAYOR OF THE CITY OF ANTIOCH
ATTEST:
_________
_________________________
MICHAEL J. MANDY
CITY CLERK OF THE CITY OF ANTIOCH
A12
RESOLUTION NO. 2026/xxx
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ANTIOCH
ESTABLISHING THE CITY’S INCLUSIONARY HOUSING TRUST FUND AND
ADMINISTRATIVE GUIDELINES
WHEREAS, the Legislature of the State of California has found that the availability of housing is of vital statewide importance. The Legislature has further found that local governments have a responsibility to use the powers vested in them to make adequate provisions for the housing needs of all economic segments of the community; WHE
REAS, the Legislature requires that City encourage the development of a variety of types of housing for all income levels to help meet the City’s assigned share of the regional housing need;
WHE
REAS, inclusionary housing ordinances typically require the development or payment of in-lieu fees for affordable housing;
WHE
REAS, on March 10, 2026 the City Council introduced an ordinance adding Title 9, Chapter 5, Article 43 to the Antioch Municipal Code, Inclusionary Housing; WHE
REAS, the ordinance includes the provision for housing developers to pay an in-lieu fee;
WHE
REAS, the City currently lacks an Inclusionary Housing Trust Fund to deposit in-lieu fees collected;
WHERE
AS, the City Council is establishing a n Inclusionary Housing Trust Fund as a source of revenue to assist in the development of housing to meet the housing needs of the City's Very Low, Low and Moderate Income Households; WHE
REAS, the Inclusionary Housing Trust Fund is to be funded by impact fees on non-residential development, in-lieu fees, and other sources; WHE
REAS, it is further the intent of the City Council to utilize the Inclusionary Housing Trust Fund to foster a mix of household incomes in residential projects assisted by the Inclusionary Housing Trust Fund and to disperse affordable housing projects throughout the City to achieve a balance of housing in all neighborhoods and communities.
NOW
, THEREFORE, BE IT RESOLVED that the City Council of the City of Antioch, hereby:
1. Es
tablishes the Inclusionary Housing Trust Fund.
2. Adop
ts the Administrative Guidelines of the Inclusionary Housing Trust Fund as shown in Exhibit A.
ATTACHMENT "B"
B1
RESOLUTION NO. 2026/***
March 10, 2026
3. The Ci
ty Manager or designee is authorized to expend funds from the Inclusionary Housing Trust Fund after first creating administrative procedures to accept and review applications and that first payments from the Inclusionary Housing Trust Fund be made no sooner than May 1, 2026.
* * * * * * * I HERE
BY CERTIFY that the foregoing resolution was passed and adopted by the City Council of the City of Antioch at a regular meeting thereof, held on the 1 0th day of March 2026 by the following vote:
AYES:
NOES:
ABSTAI
N:
ABSENT
:
_________
_________________________
MICHAEL J. MANDY
CITY CLERK OF THE CITY OF ANTIOCH
B2
CITY OF ANTIOCH
INCLUSIONARY HOUSING TRUST FUND
Ad
ministrative Guidelines
Adopted by the Antioch City Council on March 10, 2026 via Resolution 2026/**
EXHIBIT A
B3
2 City of Antioch
Inclusionary Housing Trust Fund
Cha
pter 1: Statement of Purpose
The purpose of the City of Antioch Inclusionary Housing Trust Fund, (hereinafter referred to as the IHTF), is to assist in the creation and preservation of affordable housing in the City of Antioch for the benefit of extremely low, very low, low and moderate- income households.
Chapter 2: Definitions
1. “Area median income” or “AMI” is established for metropolitan areas or non - m
etropolitan counties by the U.S. Department of Housing and Urban Development (HUD), pursuant to 42 U. S. C. Chapter 1437 et seq., to establish local income classification levels. These classifications are also used in California housing law with respect to income eligibility limits.
2. “Affordable Housing” for purposes of these Guidelines shall mean rental housing that is affordable to low and/or very-low income households and for sale housing that is affordable to moderate, low and/or very-low income households.
3. “Extremely low income household” shall mean a household having an income not exceeding thirty (30) percent of AMI adjusted for household size.
4. “Very low income household” shall mean a household having an income not exceeding fifty (50) percent of AMI adjusted for household size.
5. “Low income household” shall mean a household having an income not exceeding eighty (80) percent of the AMI adjusted for household size.
6. “Moderate income household” shall mean a household having an income not exceeding one hundred twenty (120) percent of the AMI adjusted for household size.
7. “Impact Fees” are fees paid by market rate developers for either residential or non-residential projects consistent with a nexus study and the Mitigation Fee Act.
Chapter 3: Inclusionary Housing Trust Fund Established
B4
3 1. By adoption of Resolution No. 2026/** on March 10, 2026 , the City Council established a trust fund for a special revenue account under the name of the “Inclusionary Housing Trust Fund”.
2. Future Moderate, Low or Very-Low Income Housing Fund In-Lieu Fee dedications under Title 9, Chapter 5, Article 43: Inclusionary Housing of the Antioch Municipal Code shall become IHTF property and shall be deposited directly into the IHTF.
3. The IHTF may accept donations from individuals or organizations other than the City of Antioch. Such donations may not be designated for a specific project or purpose and may be used for purposes as determined by the City Council either in the City of Antioch or Contra Costa County.
4. All moneys remaining in the I HTF at the end of any fiscal year, whether or not expended by the City, remain within the IHTF.
Chapter 4: Management
1. The Public Safety and Community Resources Director , or designee, shall serve as the Manager of the IHTF. The responsibilities of the Manager, subject to direction of the City Council, shall include:
a. Maintaining all records of the IHTF.
b. Assisting prospective applicants requesting IHTF support in the preparation and presentation of their applications;
c
. Monitoring the use of monies distributed to successful applicants for I HTF support to assure ongoing compliance with the purposes of the I HTF and the conditions under which these monies were granted or loaned; and d. Reporting annually to the City Council regarding the operation and activity of the IHTF with assistance from the City’s Finance staff/City Manager.
2. The Finance Director, or designee, in coordination with the Manager of the Inclusionary Housing Trust Fund shall be responsible for the following:
a. Disbursing and collecting IHTF monies.
b. Maintaining and managing a separate account or accounts for IHTF monies.
c. Maintaining financial records for the IHTF.
B5
4 Chapter 5: Distribution & Use of Housing Trust Fund Assets
1. Distributions may be made to individuals and/or private or public, profit or non-for- profit entities.
2. The types of investments the fund may make include: gifts, grants, loan guarantees, letters of credit or other forms of credit enhancement, or other disbursements deemed necessary and appropriate to fulfill the purposes of the IHTF.
3. Types of projects in which the IHTF may invest include:
a. Creation of new affordable units;
b. Preservation of existing affordable housing;
c. Assistance with multi-family rehabilitation programs; d. Conversion of market rate units to affordable housing units; e. Support of the construction of accessory dwelling units; f. Acquisition and rehabilitation of potential limited equity housing cooperatives;
g. First time homebuyer loans or other forms of assistance; h. Predevelopment loans/grants to assist non- profit and for -profit developers with project feasibility studies, site acquisition and preliminary design studies for potential affordable housing projects;
i. Administrative costs for affordable housing programs and projects; j. Program development, research or community engagement efforts focusing on housing matters;
k. Purchase of land for the development of affordable housing projects; and l. Rent, mortgage and utility payment assistance to Extremely Low, Very Low, Low, and Moderate- income families during the time of a declared emergency by the City Manager.
B6
RESOLUTION NO. 2026/xxx
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ANTIOCH
AMENDING THE MASTER FEE SCHEDULE TO ADD AN IN-LIEU FEE AND AN
AFFORDABLE HOUSING COMPLIANCE MONITORING FEE
WHEREAS, the Legislature of the State of California has found that the availability of housing is of vital statewide importance. The Legislature has further found that local governments have a responsibility to use the powers vested in them to make adequate provisions for the housing needs of all economic segments of the community; WHE
REAS, the Legislature requires that City encourage the development of a variety of types of housing for all income levels to help meet the City’s assigned share of the regional housing need;
WHE
REAS, inclusionary housing ordinances typically require the development or payment of in-lieu fees for affordable housing;
WHE
REAS, on March 10, 2026 the City Council introduced an ordinance adding Title 9, Chapter 5, Article 43 to the Antioch Municipal Code, Inclusionary Housing; WHE
REAS, the ordinance includes the provision for housing developers to pay an in-lieu fee;
WHE
REAS, an In-Lieu Fee analysis and recommendation report was completed to determine the amount of the fee that housing developers would need to pay in- lieu of constructing each required affordable unit onsite;
WHE
REAS, the affordable units created under the Inclusionary Housing program, State Density Bonus Law, and through other means require monitoring to ensure compliance with the affordability terms;
WHE
REAS, annual monitoring of affordable rental units and the sale of affordable for-sale units requires staff time; and
WHE
REAS, in order for the City to be compensated for the time, an affordable housing compliance monitoring fee is being established.
NOW
, THEREFORE, BE IT RESOLVED that the City Council of the City of Antioch, hereby:
1. Am
ends the Master Fee Schedule to add an inclusionary housing in-lieu fee of $202,500 per unit;
2. Amends the Master Fee Schedule to add a $50 per unit annual affordable rental inspection fee;
ATTACHMENT "C"
C1
RESOLUTION NO. 2026/***
March 10, 2026
3. Amends the Master Fee Schedule to add a $500 per change of ownership fee for each change of ownership for an affordable for-sale unit; and FURT
HERMORE, BE IT RESOLVED that:
1. On J
uly 1 of each calendar year, the amount of the three above fees shall each be increased based on the increase in the United States Bureau of Labor Statistics’ Consumer Price Index.
2. Inclusionary housing in-lieu fees collected shall be deposited into the Inclusionary Housing Trust Fund to support affordable housing.
* * * * * * * I HE
REBY CERTIFY that the foregoing resolution was passed and adopted by the City Council of the City of Antioch at a regular meeting thereof, held on the 1 0th day of March 2026 by the following vote:
AYES:
NO
ES:
ABST
AIN:
ABSE
NT:
______
____________________________
MICHAEL J. MANDY
CITY CLERK OF THE CITY OF ANTIOCH
C2
Antioch IHO
�
Summary: Existing IHOs In Contra Costa County
Rental For-Sale In-Lieu Alternative
Jurisdiction Housing Housing Compliance
Requirements Requirements Fee Option Options
15% total with specific 15% total with specific Off-site development; land Contra Costa County allocations to income levels allocations to income levels Yes conveyance; combination Pittsburg 6% ELI to 10% VLI 9% LI and 6% VLI; 20% LI Per City approval Off-site construction; payment of public subsidies
Richmond 12. 5% VLI to 17% Ml 10% VLI to 17% Ml Yes Land Donation Walnut Creek 6% VLI to 10% LI 6% VLI to 10% Ml Yes Off-site construction; land dedication
Concord 6% total 15% total Yes Off-site development; non- profit partnerships
Pleasant Hill 5% VU; 10% LI or 20% LI 5% VLI; 10% LI or 20% LI Per City approval Off-site development ADUs ADUs El Cerrito 5 units to Ml; 5% LI 12% Ml Yes N/A
15% Ml (downtown single Off-site development;
Lafayette 9% LI or Ml; 6% VLI family); 9% LI or Ml and 6% Yes provision of for-rent units VLI (downtown multifamily) rather than for-sale or fee
Developer
Incentives
Density bonus; fee waivers;
modifications to zoning
standards
Smaller lot and unit sizes,
different interior finishes for
IH units; reduced parking
requirements
N/A
Reduced size and different
interior finishes for IH units
Density bonus; FAR increase
N/A
N/A
Reduced size and different
interior finishes for IH units;
provision of ADUs as IH units
ATTACHMENT "D"
May 6, 2025
Inclusionary Housing Ordinance
Financial Feasibility Analysis
Prepare
d for:
City of Antioch
Prepare
d by:
PLACEWORKS
2040 BANCROFT, SUITE 400
BERKEL E Y, CALIFORNIA 94704
510.848.3815
WWW.PLACEWORKS.COM
ATTACHMENT "E"
E1
i
Table of Contents
Introduction................................................................................................................................. ES-1 Background ................................................................................................................................. ES-1 Methodology ............................................................................................................................... ES-2 Feasibility Impact ......................................................................................................................... ES-4
1.1 Feasibility Studies Vs Nexus Studies ................................................................................. 1-1
1.2 Limits of Feasibility Studies .............................................................................................. 1-2
1.3 Legal Backgound ............................................................................................................... 1-2
1.4 Inclusionary Housing Ordinance Components ................................................................. 1-4
1.5 Density Bonus and Inclusionary Housing .......................................................................... 1-5
2.1 Housing Need in Antioch .................................................................................................. 2-1
2.2 Analytical Approach .......................................................................................................... 2-2
2.3 Density Bonus Units ......................................................................................................... 2-4
3.1 Affordable Housing Payments for For-sale Housing.......................................................... 3-1
3.2 For-Sale Development Prototypes and analyses............................................................... 3-3
3.3 Disposition Requirements .............................................................................................. 3- 17
4.1 Affordable Household Rents ............................................................................................. 4-1
4.2 For-Rent Development Prototypes and analyses .............................................................. 4-2
Appendices
Appendix A: Antioch Market Survey: Single Family Sales Data Appendix B: Antioch Market Survey: Multifamily Sales Data Appendix C: Antioch Market Survey: Townhome Sales Data Appendix D: Antioch Market Survey: Multifamily Rent Data
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TABLES
Table ES-1: City of Antioch 6th Cycle RHNA Allocation ............................................................................. ES-1 Table ES-2: 15% VLI Inclusionary Analysis, For-Sale Development Prototypes ......................................... ES-6 Table ES-3: Feasibility Summary, For-Sale Prototypes ............................................................................... ES-6 Table ES-4: Feasibility-3 Summary, Rental Development Prototypes ........................................................ ES-7 Table ES-5: Feasibility Summary, rental Prototypes .................................................................................. ES-8 Table 1-1: State Density Bonus Allowances ................................................................................................ 1-5 Table 2-1: City of Antioch 6th Cycle RHNA Allocation ................................................................................. 2-1 Table 2-2: Density Bonus as Percentage Increase in market-rate Units by Income .................................... 2-4 Table 3-1: HCD Income Limits by Household Size and Income Classification; Contra Costa County ........... 3-2 Table 3-2: Calculation of Affordable-Housing sales Price by Household Size and Income Classification (All data in 2024 Dollars); Antioch; 2024 ............................................................................... 3-2 Table 3-3: Prototype 1 Housing Sizes and Sales Values ............................................................................... 3-4 Table 3-4: Number of Units by Type and Affordability ................................................................................ 3-5 Table 3-5: Summary of Units ...................................................................................................................... 3-5 Table 3-6: Prototype 1 Project Income ....................................................................................................... 3-5 Table 3-7: Prototype 1 Project Costs ........................................................................................................... 3-6 Table 3-8: Prototype 1 Financial Feasibility Summary ................................................................................ 3-7 Table 3-9: Prototype 1 Feasibility Summary ............................................................................................... 3-7 Table 3-10: Prototype 2 Housing Sizes and Sales Values ............................................................................. 3-8 Table 3-11: Number of Units by Type and Affordability .............................................................................. 3-9 Table 3-12: Summary of Units .................................................................................................................... 3-9 Table 3-13: Prototype 2 Project Income ................................................................................................... 3- 10 Table 3-14: Prototype 2 Project Costs....................................................................................................... 3- 11 Table 3-15: Prototype 2 Financial Feasibility Summary ............................................................................ 3- 12 Table 3-16 Prototype 2 Feasibility Summary ............................................................................................ 3- 12 Table 3-17: Prototype 3 Housing Unit Sizes and Sales Values ................................................................... 3- 13 Table 3-18: Number of Units by Type and Affordability ............................................................................ 3- 14 Table 3-19: Unit Summary ........................................................................................................................ 3- 14 Table 3-20: Prototype 3 Project Income ................................................................................................... 3- 14 Table 3-21: Prototype 3 Project Costs....................................................................................................... 3- 15 Table 3-22: Prototype 3 Financial Feasibility Summary ............................................................................ 3- 16 Table 3-23: Prototype 3 Feasibility Summary ........................................................................................... 3- 16 Table 4-1: Calculation of Affordable Rents by Household Size and Income Classification (All data in 2024 Dollars); Antioch; 2024 ................................................................................................. 4-2 Table 4-2: Prototype 4 Housing Sizes and Monthly Rents (Assuming a 9.1 percent Rent increase) ............ 4-3 Table 4-3: Number of Units by Type and Affordability ................................................................................ 4-4 Table 4-4: Unit Summary ............................................................................................................................ 4-4 Table 4-5: Prototype 4 Project Income ....................................................................................................... 4-4 Table 4-6: Prototype 4 Project Costs ........................................................................................................... 4-5 Table 4-7: Prototype 4 Financial Feasibility Summary ................................................................................ 4-6 Table 4-8: Prototype 4 Feasibility Summary ............................................................................................... 4-7 Table 4-9: Prototype 5 Housing Sizes and Monthly Rents ........................................................................... 4-7 E3
iii
Table 4-10: Number of Units by Type and Affordability .............................................................................. 4-8 Table 4-11: Unit Summary .......................................................................................................................... 4-8 Table 4-12: Prototype 5 Project Income ..................................................................................................... 4-9 Table 4-13: Prototype 5 Project Costs....................................................................................................... 4- 10 Table 4-14: Prototype 5 Financial Feasibility Summary ............................................................................ 4- 11 Table 4-15: Prototype 5 Feasibility Summary ........................................................................................... 4- 11
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ES-1
Executive Summary
INTRODUCTION
The City of Antioch’s 6th Cycle (2023-2031) Housing Element was certified by the California Department of Housing and Community Development (HCD) on October 12, 2023. Program 2.1.10, Inclusionary Housing, of the Antioch Housing Element calls for the city to “Initiate a feasibility study for an inclusionary housing ordinance for City Council consideration.”1 Inclusionary housing ordinances (IHO) require that new market-rate residential development projects include a certain percentage of housing units at rents or sale prices that are affordable to lower-income households.
The objective of Program 2.1.10 is to develop 360 to 460 affordable units during the 2023-2031 planning period.
PlaceWorks, Inc. was engaged by the City of Antioch to prepare the City’s IHO, including this financial feasibility analysis (FFA). The FFA is intended to identify and understand the impacts that inclusionary housing requirements would have on the economic feasibility of building new, market-rate housing in the City. The FFA will assist the City in adopting policies that balance the simultaneous goals of creating more affordable housing while continuing to encourage market-rate housing development, so as to best serve the needs of all City residents.
BACKGROUND
The State of California requires every jurisdiction to adequately plan for its community’s housing needs, as specified by the Regional Housing Needs Allocation (RHNA). The RHNA breaks down the amount of housing units needed in each jurisdiction by income category, ranging from Very-Low Income to Above Moderate Income. Antioch has a 6
th cycle RHNA of 3,016 total units. Table ES-1 displays the City’s RHNA breakdown by income levels.
TABLE ES-1: CITY OF ANTIOCH 6TH CYCLE RHNA ALLOCATION
Income Group Units Percent
Very Low-Income (0-50% of AMI) 792 26.3%
Low-Income (51-80% of AMI) 456 15.1%
Moderate Income (81-120% of AMI) 493 16.3%
Above Moderate-Income (More than 120% of AMI) 1,275 42.3% TOTAL 3,016 100%
Source: Final Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area, 2023-2031.
1 Ibid, page 7-16.
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ES-2
METHODOLOGY
The economic impact of an inclusionary housing requirement on a housing project is ascertained by comparing the difference between the financial performance of a fully market-rate version of the project and one that includes the required number of below-market rate (BMR) units, while also receiving any available density bonus and other allowed incentives.
To complete this comparison, PlaceWorks prepared detailed analyses that assess the financial impact of seven inclusionary requirements on five prototypical housing projects approved by the city. The analyses identify the following:
The impact on feasibility of three different 15 percent affordability requirements:
o A 15 percent requirement for VLI units.
o A 15 percent requirement for LI units.
o A 15 percent requirement for MI units.
The impact on feasibility of three different 10 percent affordability requirements:
o A 10 percent requirement for VLI units.
o A 10 percent requirement for LI units.
o A 10 percent requirement for MI units.
The impact on feasibility of a 5 percent requirement for VLI units.
New housing developments that provide required inclusionary housing are eligible for an increase in the number of market rate units, over and above the zoning maximum. The number of additional units varies based on the percentage of units that are affordable and at what income level the units are affordable.
The largest density bonus is allowed for 15 percent of the units provided at a cost that is affordable to very low-income households. Such projects can exceed the zoning density by 50 percent. However, as discussed in subsequent sections, physically achieving that density can be challenging. Generally, if a project with a 50 percent density bonus can be physically accommodated on a site, then lesser density bonuses could also be accommodated. The presentation and discussion of each prototype uses a starting point of providing 15 percent of the units affordable to very low-income households and a corresponding 50 percent density bonuses. However, the discussion of the prototype feasibility also provides additional information about the other income levels and the 10 percent and five percent inclusionary requirements.
DEVELOPMENT PROTOYPES
PlaceWorks developed five housing development prototypes that reflect recent development projects in Antioch and are consistent with local land use regulation. Each prototype reflects inputs such as recent pipeline projects, allowable densities and zoning regulations, and residential market conditions to provide for the most accurate analysis possible within the limitations of a financial feasibility assessment.
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ES-3
As part of the work to develop the prototypes, PlaceWorks completed a market survey of home sales and rental rates to estimate achievable values of each protype. The PlaceWorks team used a recent software (Chrome) extension called Comp Crunch to download detailed residential rental and sales in Antioch from aggregators such as Zillow and Trulia, in August of 2024. Datasets include:
1. Multifamily residential rents and sale prices
2. Single family residential rents and sale prices
3. Townhome residential rents and sale prices
For-Sale Prototypes
PlaceWorks defined the following three development protypes for for-sale housing based on our review of recently constructed and permitted housing projects in Antioch:
Prototype 1: Large Lot, Single Family Development. Low-density single-family housing subdivision at a gross density of 4.0 dwelling units per acre.
Prototype 2: Small Lot, Single Family Development. Medium-density single-family housing subdivision at a gross density of 10.0 dwelling units per acre Prototype 3: For-Sale Townhouse Development. Medium-density townhome project comprising 70 side-by-side residential units at a gross density of 14.9 units per acre.
Rental Protypes
PlaceWorks defined the following two development protypes for for-rent housing based on our review of recently constructed and permitted housing projects in Antioch:
Prototype 4: Medium/High Density Multifamily Flats. Medium-scale apartment development with 83 units at a gross density of 20.2 units per acre.
Prototype 5: High Density Multifamily Flats. Large-scale apartment development with 237 units at a gross density of 26.9 units per acre.
The prototypes do not reflect any particular lot, parcel or location in Antioch. The financial feasibility of any prototype on a specific site would be expected to vary.
PRO FORMA ANALYSES
PlaceWorks prepared pro forma analyses for the market-rate development prototypes to identify whether, and how, various affordability requirements could be supported by each. The pro formas rely on multi-year cash flow projections to achieve the most accurate evaluation of project feasibility. The following metrics were used to determine project feasibility:
Internal Rate of Return, 15% minimum. Internal Rate of Return (IRR) was calculated to assess the feasibility of for-sale prototypes. IRR measures the developer’s return on investment with a discounted cash flow model. It is based on the net cash flow for each year during project planning, construction, and sale. The key feasibility question is whether cash flows from sales are large enough to pay back the initial investment, plus a sufficient return to compensate for the investment risk. For real estate investments, an IRR of 15 percent is generally considered the minimum threshold of financial feasibility.
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ES-4
Cash-on-Cash Yield, 6% minimum. PlaceWorks calculated cash-on-cash yield (CoC) to assess the financial feasibility of the for-rent prototypes. CoC is an industry standard that measures the net revenue relative to the developer’s investment for the first full year of occupancy. A CoC of six percent is generally considered the minimum threshold of financial feasibility.
FEASIBILITY IMPACT
The financial feasibility of each development prototype was analyzed under the following:
1. Market Rate Scenario. This scenario consists of a fully market rate development prototype, without the introduction of affordability requirements.
2. Inclusionary Scenarios. Each of these scenarios includes the density, number of units and unit types of the market rate scenario, but with one of the seven different required percentages of BMR units. These scenarios also includes the maximum number of new units allowed under California’s Density Bonus Law (Cal. Gov. Code Sections 65915 – 65918).
Feasibility impact analyses also includes discussions of the Base Scenario for each prototype. This scenario accounts for the affordability requirement but not state density bonus. It is used to illustrate the development implications of increased density, such as changes in the number of market rate and BMR units, as well as unit types.
FOR-SALE PROTOTYPES
Table ES-1 summarizes the financial feasibility of the Market Rate and 15 percent VLI inclusionary scenario for each for-sale development prototype. The table also includes the Base Scenarios to illustrate the breakdown of market rate and below market rate units that result when the 15 percent VLI affordability requirements are applied to the Fully Market Rate Scenario. As will be explained further, this analysis provides details of the 15 percent VLI inclusionary requirement for each prototype, as this scenario is a “starting point” that provides for the greatest density bonus under state law.
Table ES-2 provides a feasibility summary for the for-sale prototypes under all the seven inclusionary scenarios. As shown in Table ES-2, the Fully Market Rate Scenarios of all three for-sale residential development prototypes are financially feasible, assuming an IRR threshold of 15 percent. This is not surprising, as they are indicative of existing and planned development in the City. However, under various inclusionary scenarios, multiple for-sale prototypes saw a significant drop in IRR, such that they would not be financially feasible without additional densities:
Prototype 1, Large Lot Subdivision, would be extremely financially sensitive to inclusionary zoning.
It would not achieve a 15 percent IRR under any of the inclusionary requirement scenarios, even with State density bonus maximized.
Prototype 2, Small Lot Subdivision, would remain financially feasible under most of the inclusionary requirements scenarios. It would not achieve a 15 percent IRR under only the 15 percent Moderate Income requirement and 10 percent Moderate Income requirement. These scenarios offer the lowest density increases under State density bonus law.
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ES-5
Prototype 3, For-Sale Townhouse Development, would also remain financially feasible under most inclusionary scenarios. It would only not achieve 15 percent IRR under the 15 percent LI requirement and 10 percent MI requirement.
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ES-6
TABLE ES-2: 15% VLI INCLUSIONARY ANALYSIS, FOR-SALE DEVELOPMENT PROTOTYPES
Prototype 1: Large Lot SFD Prototype 2 Small Lot SFD Prototype 3: Townhome Development Fully Market
Rate Scenario
15%
Inclusionary
With Density
Bonus
Fully Market
Rate
15%
Inclusionary
With Density
Bonus
Fully Market
Rate Scenario
15%
Inclusionary
With Density
Bonus
Market-Rate
Units 220 187 297 303 258 410 70 59 94
BMR Units 0 33 33 0 45 45 0 11 11
Total Units 220 220 330 303 303 455 70 70 105
Feasibility
(IRR) 18.3% -1.6% 21.0% 26.5% 20.6% 15.5%
TABLE ES-3: FEASIBILITY SUMMARY, FOR-SALE PROTOTYPES
Prototype 1: Large Lot SFD Prototype 2 Small Lot SFD
Prototype 3: Townhome
Development
Fully Market Rate Scenario
No Inclusionary Housing 18.3% 21.0% 20.6%
15% Inclusionary Requirements
15% Very Low-Income -1.6% 26.5% 15.5%
15% Low-Income -7.1% 19.9% 12.8%
15% Moderate-Income -14.3% 11.1% 19.9%
10% Inclusionary Requirements
10% Very Low-Income -2.6% 24.6% 16.3%
10% Low-Income -5.3% 21.8% 12.6%
10% Moderate-Income -12.1% 13.4% 19.8%
5% Inclusionary Requirement
5% Very Low-Income -1.3% 24.4% 18.2%
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ES-7
RENTAL PROTOTYPES
Table ES-3 summarizes the financial feasibility of the Market Rate and 15 percent VLI inclusionary scenario for each rental development prototype. The table also includes the Base Scenarios to illustrate the breakdown of market rate and below market rate units that result when the affordability requirements are applied to the Fully Market Rate Scenario.
Table ES-4 provides a feasibility summary for the rental prototypes under all the seven inclusionary scenarios. As shown in Table ES-4, the Fully Market Rate Scenarios of both rental residential development prototypes are financially feasible based on a cash-on-cash yield threshold of six percent. However, the financial impacts of various inclusionary requirements differ between the prototypes:
Prototype 4, Medium/High Density Multifamily Flats, maintains feasibility only under requirements for VLI units. This is primarily because construction of VLI units allows for the greatest density increase under State Density Bonus law. Protype 5, High Density Multifamily Flats, maintains feasibility under all seven inclusionary scenarios.
TABLE ES-4: 15% VLI INCLUSIONARY ANALYSIS, RENTAL DEVELOPMENT PROTOTYPES
Prototype 4: Medium/High Density
Multifamily Flats
Prototype 5: High Density
Multifamily Flats
Fully Market
Rate Scenario
15%
Inclusionary
With Density
Bonus
Fully Market
Rate Scenario
15%
Inclusionary
With Density
Bonus
Market-rate Units 83 71 113 237 201 320
BMR Units 0 12 12 0 36 36
Total Units 83 83 125 237 237 356
Feasibility (Cash
on cash yield) 6.1% 6.2% 6.6% 6.3%
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ES-8
TABLE ES-5: FEASIBILITY SUMMARY, RENTAL PROTOTYPES
Prototype 4: Medium/High Density
Multifamily Flats
Prototype 5: High Density
Multifamily Flats
Fully Market Rate Scenario
No Inclusionary Housing 6.1% 6.6%
15% Inclusionary Requirements
15% Very Low-Income 6.2% 6.3%
15% Low-Income 4.9% 6.4%
15% Moderate-Income 5.2% 6.8%
10% Inclusionary Requirements
10% Very Low-Income 6.1% 6.3%
10% Low-Income 4.8% 6.4%
10% Moderate-Income 5.0% 6.6%
5% Inclusionary Requirement
5% Very Low-Income 6.1% 6.3%
OVERALL FEASIBILITY
This analysis finds:
An inclusionary housing requirement is not financially feasible to achieve with conventional single-family detached housing developments in Antioch. Subsequent work on this project will evaluate a potential in-lieu fee for an inclusionary housing requirement and its potential applicability to single-family detached housing development. An inclusionary housing requirement appears to be feasible for other types of development.
However, the feasibility is contingent on two important factors that the city will need to consider and, if moving forward with an inclusionary housing program, will need to incorporate into its ordinance:
1. Not all income levels are feasible for each type of development. If the city were to adopt a program, it should have a general percentage inclusionary requirement—i.e., 5 or 10 or 15 percent of the units should be restricted to occupancy by and be affordable to income- qualified households—but the developer should be allowed the flexibility to determine whether those units would be affordable to very low-income, low-income, or moderate- income households.
2. Achieving the densities allowed under the density bonus law in order to compensate for the costs of providing affordable housing may require a shift to more dense housing products. In other words, a small-lot, single-family detached housing development may need to incorporate a large number of townhomes to accommodate additional market-rate units, instead of being restricted to single-family detached units. Similarly, a multifamily project may need to be built taller and with reduced parking to achieve the allowable densities. These tradeoffs should factor into the consideration of an inclusionary housing requirement and E12
ES-9
should be acknowledged in the ordinance if the city moves forward with an inclusionary housing requirement.
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1. Introduction
The City of Antioch 6th Cycle (2023-2031) Housing Element (HE) was certified by the California Department of Housing and Community Development (HCD) on October 12, 2023. Housing Element Program 2.1.10, Inclusionary Housing, calls for the city to “Initiate a feasibility study for an inclusionary housing ordinance for City Council consideration.”
2 Inclusionary housing ordinances (IHO) require that
new market-rate residential development projects include a certain percentage of housing units at rents or sale prices that are affordable to lower-income households.
As stated in the Housing Element, the objective of Program 2.1.10 is to develop 360 to 460 affordable units during the 2023-2031 planning period.
PlaceWorks, Inc. was engaged by the City of Antioch to prepare the City’s IHO, including this financial feasibility analysis (FFA). The FFA is intended to identify the impacts that inclusionary housing requirements would have on the economic feasibility of building new, market-rate housing in the City.
The FFA will assist the City in adopting IHO regulations that facilitate affordable housing provision while continuing to encourage market-rate housing development.
Two key factors must be considered in the creation of inclusionary housing requirements:
1. The requirements should balance the interests of developers against the public benefit created by the production of affordable units.
2. The inclusionary housing requirements cannot deprive housing developers of a fair and reasonable return on their investment.
1.1 FEASIBILITY STUDIES VS NEXUS STUDIES
Feasibility studies and nexus studies are related yet serve different purposes. As explained further in Section 1.3, below, IHOs are typically adopted as local land use regulations via a jurisdiction’s use of its police power. Feasibility studies for IHOs determine the quantity of affordable housing that proposed development project(s) can bear while remaining financially feasible to develop.
In contrast, nexus studies do not assess project financial feasibility. Nexus studies are used to quantify various impact(s) of new development, calculate the cost of the impact(s), and determine the resulting fees to be imposed as a development condition. In the case of affordable housing, nexus studies document how much a proposed development project (either residential or non-residential) would contribute to the need for affordable housing and determine a maximum legally defensibility impact fee.
Ultimately, the jurisdiction can charge any fee up to that amount. Oftentimes, for affordable housing, cities account for financial feasibility and impose a fee lower than the maximum amount.
2 Ibid, page 7-16.
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1.2 LIMITS OF FEASIBILITY STUDIES
Feasibility studies differ from real estate appraisals, which establish a value for a specific property based on data from comparable properties and projects. The primary difference between an appraisal and a feasibility study is the scope. An appraisal is focused on a single property and is intended to provide an accurate estimate of the value of that property. A feasibility study is intended to represent an approximate typical value for a type of development that could occur on many different properties within a jurisdiction. The values of that theoretical development may vary greatly across different properties and with different developers.
Feasibility studies involve more complex calculations based on a wider variety of data. While market data on home sales prices and rents is available, feasibility studies also rely on data and assumptions about land values, construction costs, operating costs, unit sizes, parking costs, and other topics. As such, feasibility studies must be understood as approximations.
Finally, feasibility studies depend on specific input assumptions and are thus more open to interpretation than appraisals. While two certified appraisers are likely to return very similar property value estimates in most cases, two well-conducted financial feasibility studies may still draw varying conclusions about the impact of inclusionary housing requirements on project feasibility.
1.3 LEGAL BACKGOUND
Article XI, section 7 of the California Constitution grants each city and county the power “to make and enforce within its limits all local, police, sanitary and other ordinances and regulations not in conflict with general laws.” This is referred to as the police power of local governments. California Planning and Zoning Law (Gov. Code, §§ 65000 to 66035) establishes the Legislature’s intent to “provide only a minimum of limitation in order that counties and cities may exercise the maximum degree of control over local zoning matters.”
Approximately 200 jurisdictions in California, pursuant to their police power, have adopted IHOs that require developers to ensure that a certain percentage of housing units in a new development be affordable to VLI, LI and MI households. The majority of these include requirements for both for-sale and rental residential development projects.
A series of legal cases and legislation adopted by the State of California Legislature guide the creation and implementation of IHOs. These include, in chronological order:
Palmer/Sixth Street Properties L.P . v. City of Los Angeles. In 2009, the California Court of Appeal ruled that the local affordable housing requirements imposed by the City of Los Angeles violated the Costa-Hawkins Rental Housing Act (Costa-Hawkins). Costa-Hawkins allows landlords to set the initial monthly rent for a new unit, and then to increase the monthly rent to the market level each time a unit is vacated. The Court found that the imposition of long-term income and affordability restrictions on rental apartment units is a violation of this provision.
After the Palmer decision, most jurisdictions with inclusionary housing ordinances that included rental housing stopped applying the rental requirement. Some jurisdictions replaced affordable housing production models with a linkage or impact fee methodology.
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Latinos Unidos del Valle de Napa y Solano v. County of Napa. In 2013, the California Court of Appeal, held that inclusionary units qualify as affordable units for purposes of the Density Bonus Law. As a result of the ruling, developers can use the same affordable units to fulfill both inclusionary housing requirements and density bonus requirements. However, in order to exercise this option, the more stringent of the two programs’ requirements must be applied. California Building Assn. V. of San Jose (2015) 61 Cal.4th 435. In 2010, the City of San Jose adopted an inclusionary housing ordinance that applied a 15 percent inclusionary requirement.
The California Building Industry Association (CBIA) filed a lawsuit alleging that the requirements constituted an “exaction" that needed to be justified by the impact of the project. In a 2015, the California Supreme Court ruled that inclusionary requirements are not exactions, stating that they are “constitutionally legitimate” so long as the enforcement "bears a real and substantial relationship to the public interest." The court cited the need to increase the number of affordable units in California and the desirability of economically diverse communities.
This case has been widely interpreted to mean that an in-lieu fee payment option in an inclusionary housing program is not subject to the requirements of California Government Code §66000, the “Mitigation Fee Act.”
Assembly Bill 1505. AB 1505 was passed in 2017 and is known as the “Palmer Fix,” as it reaffirms the authority of local governments to include inclusionary requirements for rental units. AB 1505 amends Section 65850 of the California Government Code and adds Section 65850.01. It supersedes the holding in Palmer, to the extent that the decision conflicts with a local jurisdiction’s authority to adopt inclusionary housing programs on residential rental developments. It provides for limited, circumstantial review by HCD of financial feasibility studies in order to ensure that inclusionary housing programs do not “unduly constrain” the production of housing.
Per AB 1505, HCD retains the right to review the financial feasibility of only IHOs that require more than 15 percent of rental units be made affordable to households at 80 percent or less of the area median income (AMI), and for which one of the following applies:
1. The jurisdiction has failed to meet at least 75% of its RHNA allocation for above moderate income units. This test is measured on a pro-rated basis over the planning period, which is set at a minimum of five years; or
2. HCD finds that the jurisdiction has not submitted their Housing Element report for at least two consecutive years.
Even in cases where these criteria are met, HCD will only request evaluation of an IHO feasibility analysis based on information in the jurisdiction’s Housing Element, Annual Progress Report, stakeholder comment letter, phone call, news article, or at the request of a third-party.
Finally, HCD will not review the actual inclusionary housing program pursuant to AB 1505. HCD’s review is limited to a review of the financial feasibility study.
At this time Antioch has not met 75% of its recently-released 6th cycle RHNA allocation (see Section 2.1).
As such, should Antioch adopt an IHO whereby more than 15 percent of rental units are required to be restricted at less than 80% of AMI, HCD has the right to review this FFA.
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1.4 INCLUSIONARY HOUSING ORDINANCE COMPONENTS
The majority of inclusionary housing ordinances in California are comprised of a similar set of regulatory components. These include:
1. Threshold Project Size. Most inclusionary housing programs include a minimum threshold project size below which projects are not subject to the affordable housing production requirements. Typically, this threshold is between three to 10 units.
2. Applicable Geography. Most jurisdictions establish blanket affordability requirements that apply to all local projects. Some jurisdictions with diverse real estate landscape impose varying requirements for different subareas.
3. Income and Affordability Requirements. Income and housing affordability requirements are the key components of inclusionary housing. They vary throughout California. The majority of IHOs require that eligible projects include 10 to 20 percent affordable units. The following variations are common:
The inclusionary requirements vary for different levels of household affordability, including VLI, LI and MI households.
A sliding scale of inclusionary requirements for projects of varying size, developed to reduce the potentially disproportionate impact of inclusionary housing requirements on smaller projects. The length of the covenant period imposed on inclusionary units. However, the standards of 45 years for ownership housing units and 55 years for rental units set by California Health and Safety Code (H&SC) Section 33413 are commonly used.
4. Inclusionary Fulfillment Options. According to Cal. Gov. Code Section 65850 (g), jurisdictions may adopt IHOs with rental development requirements with the condition that they offer developers alternatives for fulfilling the affordable housing requirements. The most common options are:
Payment of an in-lieu fee, equal to the cost of constructing the required units, to a local housing trust fund or other mechanism to assist in the development of affordable housing units within the community. In-lieu fees can also be transferred to developers that specialize in affordable housing and have access to local, state and federal public funding sources that may support greater affordability than inclusionary housing requirements.
Construction of a defined percentage of income restricted units in an off-site location. The dedication or donation of land to the jurisdiction that is appropriate for the development of affordable housing.
The acquisition and rehabilitation of existing units.
5. Development & Design Standards. Most IHOs include standards to ensure that affordable units are built with the same construction and design quality as market rate units and are distributed evenly among market rates units rather than clustered or isolated in the development site.
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1.5 DENSITY BONUS AND INCLUSIONARY HOUSING
1.5.1 STATE DENSITY BONUS LAW
California’s Density Bonus Law (Cal. Gov. Code Sections 65915 – 65918) provides developers with tools to build affordable housing. The law requires jurisdictions to provide density bonuses based on a sliding scale, including up to a 50% increase in project densities depending on the amount of affordable housing provided.
The density bonus provides one method for developers to improve the feasibility of their project while still complying with an inclusionary housing ordinance. As stated in Section 2.4, Latinos Unidos del Valle de Napa y Solano v. County of Napa held that inclusionary units qualify as affordable units for purposes of Density Bonus Law. The case confirmed that the density bonus is a financial tool available to help developers achieve inclusionary housing requirements. Density bonus is commonly used to reduce the financial impact created by the imposition of inclusionary housing requirements. It should be noted, however, that payment of an in-lieu fee to meet inclusionary housing requirements does not qualify for density bonus.
Table 1-1 shows the scale of allowable state density bonus for increasing percentages of affordable units.
TABLE 1-1: STATE DENSITY BONUS ALLOWANCES
Affordable Unit Percentage
(Of Pre-Bonus Unit Total)
Very Low Income Density
Bonus Low Income Density Bonus
Moderate Income Density
Bonus (For-Sale Projects Only)
5% 20% - -
6% 22.5% - -
7% 25% - -
8% 27.5% - -
9% 30% - -
10% 32.5% 20% 5%
11% 35% 21.5% 6%
12% 38.75% 23% 7%
13% 42.5% 24.5% 8%
14% 46.25% 26% 9%
15% 50% 27.5% 10%
16% 50% 29% 11%
17% 50% 30.5% 12%
18% 50% 32% 13%
19% 50% 33.5% 14%
20% 50% 35% 15%
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1.5.2 LOCAL DENSITY BONUS
The City of Antioch’s adopted density bonus ordinance is included in Chapter 5, Article 35, of the Antioch Municipal Code. The ordinance was amended in 2014 to bring the City into compliance with State law and further modified in 2020 to mirror the State ordinance. Section 9-5.3502(H) of the City’s density bonus ordinance includes a provision which automatically adopts revisions to the State Density Bonus law as adopted by State Legislature.
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2. Methodology
The financial feasibility impact of an inclusionary housing requirement on a market-rate project is the difference between financial performance of a fully market rate development project and one that provides the required number of below-market rate (BMR) units, along with any density bonus and other incentives. Most commonly, this difference is measured as the difference in the rate of return that the developer would expect for the equity invested in the project. The difference can also be measured as the difference in the market-rate sales values or rents for units in the market-rate and those of the BMR development, when holding the rate of return equal. It can also be measured as the difference in the residual land value (how much the developer can afford to pay to acquire the development site) between the market-rate and the BMR development projects, keeping the rate of return equal.
2.1 HOUSING NEED IN ANTIOCH
Antioch has a history of successfully planning for state-mandated housing requirements.
The State of California requires every jurisdiction to adequately plan for its community’s housing needs, as specified by the Regional Housing Needs Allocation (RHNA). The RHNA breaks down the amount of housing units needed in each jurisdiction by income category, ranging from Very-Low Income to Above Moderate Income. Antioch has a 6
th cycle RHNA of 3,016 total units. Table 2-1 displays the City’s RHNA breakdown by income levels.
TABLE 2-1: CITY OF ANTIOCH 6TH CYCLE RHNA ALLOCATION
Income Group Units Percent
Very Low-Income (0-50% of AMI) 792 26.3%
Low-Income (51-80% of AMI) 456 15.1%
Moderate Income (81-120% of AMI) 493 16.3%
Above Moderate-Income (More than 120% of AMI) 1,275 42.3% TOTAL 3,016 100%
Source: Final Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area, 2023-2031.
As shown in Table 2-1, 42.3% of the Antioch’s RHNA requirement is dedicated to homes affordable to Above Moderate-Income households. A potential IHO would not include requirements for these homes.
The City’s RHNA directs that the City will need to plan for the construction of 493 Moderate, 456 Low- and 792 Very Low- Income housing units by 2031.
Inclusionary housing is one tool that will help the City to fulfill its affordable housing needs. Accomplishing state and local housing goals will require an additional combination of planning and zoning strategies, city policy decisions and regional coordination.
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This report summarizes the results of detailed financial feasibility analyses to assess the impact on feasibility of the requested inclusionary housing requirements on a series of prototypical housing projects. The analyses identify the following:
The impact on feasibility of three different 15 percent affordability requirements:
o A 15 percent requirement for VLI units.
o A 15 percent requirement for LI units.
o A 15 percent requirement for Moderate Income units.
The impact on feasibility of three different 10 percent affordability requirements:
o A 10 percent requirement for VLI units.
o A 10 percent requirement for LI units.
o A 10 percent requirement for Moderate Income units.
The impact on feasibility of a 5 percent requirement for VLI units.
New housing developments that provide required inclusionary housing are eligible for an increase in the number of market rate units, over and above the zoning maximum. The number of additional units varies based on the percentage of units that are affordable and at what income level the units are affordable.
The largest density bonus is allowed for 15 percent of the units provided at a cost that is affordable to very low-income households. Such projects can exceed the zoning density by 50 percent. However, as discussed in subsequent sections, physically achieving that density can be challenging. Generally, if a project with a 50 percent density bonus can be physically accommodated on a site, then lesser density bonuses could also be accommodated.
The presentation and discussion of each prototype uses a starting point of providing 15 percent of the units affordable to very low-income households and a corresponding 50 percent density bonuses.
However, the discussion of the prototype feasibility also provides additional information about the other income levels and the 10 percent and five percent inclusionary requirements.
2.2 ANALYTICAL APPROACH
The basic structure of the analysis is the development and application of financial feasibility pro formas for a set of housing project prototypes reflecting current development trends in Antioch and the region.
The analyses include:
1. Creation of residential development prototypes that are representative of new and planned market-rate development in the City of Antioch.
2. Estimation of market-rate sales prices and rents for the prototypes.
3. Calculation of the sales prices and rents the reflect affordable housing payments.
4. Calculation of the percentage of units that could be designated as inclusionary housing units while maintaining project financial feasibility.
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2.2.1 DEVELOPMENT PROTOTYPES
PlaceWorks developed a total of five for-sale and for-rent housing development prototypes that reflect recent development patterns in Antioch. The protypes were created using multiple inputs to ensure they are representative of local development patterns and provide for accurate analysis within the limitations of a financial feasibility assessment. These inputs include:
Ongoing consultation with City staff regarding current residential project applications to the City, desired housing development types, applicant inquiries and State input. Evaluation and integration of recently-constructed and approved single- and multi-family for-sale projects and rental projects.
Evaluation of housing project characteristics, densities and designs contained in multiple Antioch “Pipeline Project” lists obtained from city staff.
Project data from City of Antioch Housing Element and related documents.
Details of each development prototype are included in Chapters 3 and 4.
2.2.2 MARKET SURVEY
PlaceWorks completed a comprehensive local market survey of home sales and rent prices to estimate achievable values of the development protypes. In August of 2024, PlaceWorks used a Chrome software extension developed by the real estate industry to download and compile detailed market data from real estate aggregators Zillow and Trulia.
PlaceWorks’ survey of real estate sales prices included individual datasets for:
Single family homes
Multifamily homes
Townhomes
PlaceWorks’ survey of real estate rental prices included individual datasets for:
Single family homes
Multifamily homes
Townhomes
Each listing in both surveys includes:
Home type
Listing process/rent
Square footage
Price/rent per square foot
Number of bedrooms
Number of bathrooms
Raw results of the market survey are available in Appendices A through D.
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2.2.3 CALCULATION OF AFFORDBALE HOME PRICES & RENTS
PlaceWorks calculated affordable home values and rental process for inclusion in the pro form process.
These values were calculated using California Health & Safety Code (H&SC) Section 50052.5 calculation methodology.
Details and results of the calculation process are included in Section 3.1.
2.2.4 PRO FORMA ANALYSES
PlaceWorks prepared a series of dynamic pro formas for each development prototype to identify whether, and how, each market-rate housing project could support various affordability requirements.
Unlike static pro formas, dynamic pro formas rely on multi-year cash flow projections. This type of modeling requires a greater number of assumptions and inputs than static modelling. It allows for the most accurate evaluation of the feasibility of real estate projects. This approach facilitated calculation of the following metrics:
Internal Rate of Return. PlaceWorks calculated Internal Rate of Return (IRR) to assess the feasibility of the for-sale development prototypes. IRR measures the developer’s return on investment with a discounted cash flow model. It is more complex and more accurate than a simple return on cost metric. It is based on the net cash flow for each year during the planning, construction, and sale (for a for-sale product) or operation (for a for-rent product). Equity investors typically use IRR because it allows them to compare different investment opportunities.
In the initial years, a developer invests money into a project and then, in later years, receives return in the form of the sales value of the residential dwelling units, after repaying the construction loan. IRR can also be used with for-rent products (in which case the return is the annual net cash flow from operations and the ultimate sale of the project after a typically five- year holding period to capitalize on depreciation tax benefits). The key feasibility question is whether these later cash flows are large enough to pay back the initial investment plus a sufficient return to compensate for the investment risk. The IRR is essentially the rate that generates a $0 net present value for the series of cash flows. For real estate investments, an IRR of 15 percent is generally considered the threshold for a proposed project to be considered financially feasible. Cash-on-Cash Yield. PlaceWorks calculated Cash-on-Cash Yield to assess the financial feasibility of for-rent development prototypes. With for-rent residential projects, the developer may own and operate the project for an indeterminate number of years. IRR is a less effective evaluation metric because it requires a specific time horizon for the sale of the project and the final return. The cash-on-cash yield is an industry standard metric for rental projects, and it measures the net revenue relative to the developer’s investment for the first full year of occupancy. Specifically, it is calculated by dividing the expected net operating income (NOI), after debt service and taxes, by the required equity investment the developer puts up. For real estate investments, a cash-on-cash yield of six percent or more is generally considered the threshold for a proposed project to be considered financially feasible.
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Residual Land Value. Residual land value is the amount that a developer can afford to pay to acquire a site for development and a achieve a financially feasible rate of return. Residual land value is most often used to compare two or more alternatives for a development site or two or more land use regulations by determining which generates the highest residual land value.
However, a portion of the financial impact of inclusionary housing requirements can be absorbed by landowners in the form of lower residual land values (RLV). The impact of decreased RLV is reflected differently in financial feasibility analyses statewide, with no preferred direction. As detailed further in Chapters 3 and 4, PlaceWorks analyzed the financial feasibility of market-rate and BMR development prototypes assuming that the residual land value would remain the same.
2.2.5 SCENARIO ANALYSIS
The financial feasibility of each development prototype was analyzed under the following scenarios:
1. Fully Market Rate Scenario. This scenario consists of the density, number of units and unit type established in the original market-rate development prototype, without the introduction of affordability requirements.
2. Inclusionary Scenarios. Each of these scenarios includes the density, number of units and unit types of the market rate scenario, but with one of the seven different required percentages of BMR units.
These scenarios also includes the maximum number of new units allowed under California’s Density Bonus Law (Cal. Gov. Code Sections 65915 – 65918). The seven requirement scenarios are:
15 percent VLI units.
15 percent LI units.
15 percent MI units.
10 percent VLI units.
10 percent LI units.
10 percent MI units.
5 percent VLI units.
Each prototype analysis also includes a Base Scenario, which consists of the density, number of units and unit type established in the market rate scenario, as well as the affordability requirements of the inclusionary scenario. However, it does not include density bonus units. As such, it is not included in the feasibility analyses. It is used to illustrate the development implications of changing density programs on a development project that complies with affordability requirements, including changes in the number of market rate and below market rate units, and unit types.
2.2.6 SENSITIVITY ANALYSIS
PlaceWorks’ pro forma modelling includes sensitivity analyses that test the impact of a range of changes to key inputs. This type of analysis looks at the extent to which feasibility would be impacted under changing market or other assumptions. Inputs altered as part of the sensitivity analysis include:
Rental rates.
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Home values.
Project densities.
Combinations of housing project product type, such as multifamily units, single family homes, and townhouses.
2.3 DENSITY BONUS UNITS
Most of the housing being built in Antioch today is owner-occupied. With ownership housing, the primary affordable housing challenge is that, even at a reduced price, each household must still have the ability to pay (a down payment and meet debt-to-income limits) and the willingness to pay (credit score) to qualify for a conventional mortgage. As a result, many VLI, LI and MI households cannot afford to buy the typical for-sale unit in Antioch.
Because households have to qualify for mortgage financing to buy a home (even one created under an IHO), inclusionary housing programs tend to target MI households. However, the Antioch Housing Element has identified the development of 360 to 460 affordable units for households of various income levels as the specific objective of a future IHO. A combination of income levels impacts the manner in which for-sale projects may benefit from State Density Bonus law, which provides differing percentages for bonus market-rate housing units based on income level, as shown in Table 2-2.
TABLE 2-2: DENSITY BONUS AS PERCENTAGE INCREASE IN MARKET-RATE UNITS BY INCOME Percentage of Affordable Units Provided: 15% Affordable 10% Affordable 5% Affordable Household Income Class
Very Low-Income 50% Unit Increase 32.5% Unit Increase 20% Unit Increase Low-Income 27.5% Unit Increase 20% Unit Increase 0% Unit Increase Moderate-Income 10% Unit Increase 5% Unit Increase 0% Unit Increase
There is no State density bonus for LI or MI affordable units if they comprise less than 10 percent of the total number of units in a project. Some inclusionary housing programs leave it to the developer to balance the number of affordable units by income classification in order to obtain the density bonus that best supports financial feasibility. However, there is no guarantee that the market in conjunction with an inclusionary housing program with such flexibility will produce housing for all income levels.
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3. For-Sale Development Prototypes
This chapter inlcudes PlaceWorks’ analyses of the impact of the seven different affordability requirements on the financial feasibility of three prototypical for-sale residential development projects.
Each prototype is representative of recent development activity in Antioch. The three protoypes include:
Prototype 1: Large Lot SFD Subdivision
Prototype 2: Small-lot SFD Subdivision
Prototype 3: For-Sale Townhouse Development
Each protoype discussion includes the results of the financial feasibility anlyses under the scenarios described in Section 2.2.5:
1. Fully Market Rate Scenario. This is the fully-market rate project.
2. Inclusionary Scenarios. Each of these scenarios inlcude a different affordability requirement and the assocaited maximum number of new units allowed under State Density Bonus Law.
As explained under Section 2.1, we first present detailed financial analyses of the 15 percent VLI inclusionary scenario for each prototype. This facailitates exploration and anlaysis of the impact of the maximum density bonus allowed under State law. For each prototype, we then summarize the feasibility of the six other inclusionary scenarious.
This chapter opens with a discussion of State affordability classifications and metrics. It concludes with a discussion of the potential need for disposition requirements in the inclusionary housing program, to establish purchaser qualifications and affordable unit resale restrictions.
3.1 AFFORDABLE HOUSING PAYMENTS FOR FOR-SALE
HOUSING
The housing payment considered to be affordable for a given household is determined by household size and income. The calculated affordable housing payment is unrelated to the size (square footage) of the dwelling units (provided it has the appropriate number of bedrooms), the type of housing (single-family detached, townhouse, or condo), or the market-rate price of the unit. Calculated affordable housing payments for for-sale housing are provided in the following sections.
3.1.1 HOUSING INCOME CLASSIFICATIONS
There are several related but distinct income classifications used for public programs. This analysis is based on the most common classification for housing programs, the state Department of Housing and Community Development (HCD) Income Limits. Table 3-1 provides the HCD income limits for Contra Costa County for 2024. The data indicate the maximum income that a household with a given number of people can earn and be included in each income classification.
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TABLE 3-1: HCD INCOME LIMITS BY HOUSEHOLD SIZE AND INCOME CLASSIFICATION; CONTRA COSTA COUNTY Number of People: 1 2 3 4 5 6 7 8
Very Low-Income 54,500 62,300 70,100 77,850 84,100 90,350 96,550 102,800 Low-Income 84,600 96,650 108,750 120,800 130,500 140,150 149,800 159,500 Moderate-Income 130,800 149,500 168,150 186,850 201,800 216,750 231,700 246,650 Median Income 109,000 124,550 140,150 155,700 168,150 180,600 193,050 205,500 Source: California Department of Housing and Community Development, 2024 State Income Housing Limits.
Thus, a 3-person household with an annual income of $70,100 would be classified as VLI, while a 3-person family with an annual income of $108,750 would be classified as LI. When purchasing a home with some sort of public subsidy, support, or write-down, the household’s actual income is used to determine the affordable housing payment. For planning purposes, the maximum income for each income classification is used to determine the affordable housing payment and, thus, the affordable sales price.
3.1.2 AFFORDABLE-HOUSING SALES PRICES
The price that may be charged for affordable owner-occupied housing is based on annual income and household size. Affordable sales prices in Antioch are calculated in Table 3-2 for VLI, LI, and MI households.
TABLE 3-2: CALCULATION OF AFFORDABLE-HOUSING SALES PRICE BY HOUSEHOLD SIZE AND INCOME CLASSIFICATION (ALL DATA IN 2024 DOLLARS); ANTIOCH; 2024
Household Size: 1 2 3 4 5 6 7 8 9
Very Low-Income Households
Annual income limit 54,500 62,300 70,100 77,850 84,100 90,350 96,550 102,800 109,028 Affordable housing cost
(assumes 30% of annual
income limit)
16,350 18,690 21,030 23,355 25,230 27,105 28,965 30,840 32,708 Annual utility allowance 229 282 334 389 440 472 504 504 504 Annual housing affordable
payment 13,602 15,306 17,022 18,687 19,950 21,441 22,917 24,792 26,660 Monthly housing affordable
payment 1,134 1,276 1,419 1,557 1,663 1,787 1,910 2,066 2,222 Other housing costs 538 605 673 739 789 847 906 980 1,054 Mortgage payment 596 671 746 819 874 939 1,004 1,086 1,168 Affordable purchase price 110,473 124,312 138,249 151,772 162,030 174,139 186,127 201,356 216,530 Low-Income Households
Annual income 84,600 96,650 108,750 120,800 130,500 140,150 149,800 159,500 169,164 Affordable housing cost
(assumes 30% of annual
income limit)
25,380 28,995 32,625 36,240 39,150 42,045 44,940 47,850 50,749 Annual utility allowance 229 282 334 389 440 472 504 504 504 Annual housing affordable
payment 22,632 25,611 28,617 31,572 33,870 36,381 38,892 41,802 44,701 Monthly housing affordable
payment 1,886 2,134 2,385 2,631 2,823 3,032 3,241 3,484 3,725 Other housing costs 895 1,012 1,131 1,248 1,339 1,438 1,537 1,652 1,767 E27
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TABLE 3-2: CALCULATION OF AFFORDABLE-HOUSING SALES PRICE BY HOUSEHOLD SIZE AND INCOME CLASSIFICATION (ALL DATA IN 2024 DOLLARS); ANTIOCH; 2024
Household Size: 1 2 3 4 5 6 7 8 9
Mortgage payment 991 1,122 1,254 1,383 1,484 1,594 1,704 1,831 1,958 Affordable purchase price 183,812 208,007 232,421 256,421 275,085 295,479 315,873 339,507 363,054 Moderate-Income Households
Annual income 130,800 149,500 168,150 186,850 201,800 216,750 231,700 246,650 261,598 Affordable housing cost
(assumes 30% of annual
income limit)
39,240 44,850 50,445 56,055 60,540 65,025 69,510 73,995 78,479 Annual utility allowance 229 282 334 389 440 472 504 504 504 Annual housing affordable
payment 36,492 41,466 46,437 51,387 55,260 59,361 63,462 67,947 72,431 Monthly housing affordable
payment 3,041 3,456 3,870 4,282 4,605 4,947 5,289 5,662 6,036 Other housing costs 1,442 1,639 1,835 2,031 2,184 2,346 2,508 2,686 2,863 Mortgage payment 1,599 1,817 2,034 2,251 2,421 2,601 2,780 2,977 3,173 Affordable purchase price 296,381 336,778 377,152 417,355 448,810 482,118 515,425 551,852 588,273 Notes to Table 3-2
1. Data for annual income limit by household size and income classification is from Table 3-1.
2. The total payment for housing costs for owner-occupied housing is considered to be 30 percent of household income.
3. Annual utility allowance data are based on the Housing Authority of Contra Costa County 2024 Utility Allowances.
4. The annual housing affordable payment is the affordable housing cost less the utility allowance. The monthly housing affordable payment is the annual payment divided by 12.
5. Other housing costs assume a 5 percent down payment and a 95 percent loan to value ratio and include 1.5 percent taxes, 1 percent annual private mortgage insurance, and 0.57 percent annual homeowners’ insurance.
6. The mortgage payment is the monthly housing affordable payment less other housing costs. The affordable purchase price is based on the mortgage payment and assumes a 30-year fixed rate mortgage with a 5 percent down payment and a 5.5 percent annual percentage rate.
3.2 FOR-SALE DEVELOPMENT PROTOTYPES AND ANALYSES
This section describes the three for-sale development prototypes analyzed in this report, and the results of their financial feasibility analyses.
PlaceWorks defined three development prototypes for for-sale housing based on our review of recently constructed and permitted housing projects in Antioch:
Prototype 1: Large Lot, Single Family Development. Low-density single-family housing subdivision at a gross density of 4.0 dwelling units per acre.
Prototype 2: Small Lot, Single Family Development. Medium-density single-family housing subdivision at a gross density of 10.0 dwelling units per acre Prototype 3: For-Sale Townhouse Development. Medium-density townhome project comprising 70 side-by-side residential units, for a gross density of 14.9 units per acre.
These prototypes are intended to reflect generalized development patterns that are typical and/or allowable under current planning and zoning and to provide a generalized indication of the financial E28
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feasibility impacts of inclusionary housing requirements. The prototypes do not reflect any particular lot or parcel or location in the city. The financial feasibility of any prototypes on a specific site should be expected to vary from the generalized analysis provided below.
Each prototype includes detailed analyses of the impacts of a 15 percent VLI inclusionary housing scenario on project density, revenue, costs, and feasibility. It is assumed that State Density Bonus is maximized in these analyses.
This is followed by a summary feasibility analysis for each of the six other inclusionary housing scenarios described in Section 2.1.
3.2.1 PROTOTYPE 1: LARGE LOT, SINGLE-FAMILY DEVELOPMENT
3.2.1.1 PROTOTYPE DESCRIPTION
This prototype represents a historically common form of development in Antioch. The theoretical site is
55.0 acres in size. The base scenario includes 220 houses, 46 of which are BMR units, at a gross density of
4.0 units per acre. Table 3-3 shows the types of housing and estimated sales values.
TABLE 3-3: PROTOTYPE 1 HOUSING SIZES AND SALES VALUES
Unit Type Size (sq. ft.)
Market-Rate Sales
Value
Below-Market-
Rate Sales Value Difference
3-Bedroom 1,970 730,000 153,500 -576,000 -79.0%
4-Bedroom 2,320 830,000 170,100 -659,000 -79.5%
5-Bedroom 2,750 1,125,000 189,600 -936,000 -83.1%
Notes to Table 3-3:
1. Unit types, sizes, and market-rate sales values are PlaceWorks’ assumptions based on our assessment of the current market.
2. Below market-rate sales values are based on the data in Table 4-3, assuming that 3-bedroom units are a mix of 3- and 4- person households, 4-bedroom units are 5-person households, and 5-bedroom units are a mix of 7- and 8-person households.
As with all five analyses conducted for this report, PlaceWorks assessed the development implications of the base development scenario and seven inclusionary housing scenarios for this prototype. We compared the feasibility of the inclusionary housing scenarios to the fully market rate scenario. The number of each type/size of units resulting from the 15 percent VLI inclusionary housing scenario is provided in Table 3-4. As noted, this inclusionary housing scenario provides for the greatest number of additional units under State Density Bonus. Development summaries of the base scenario and 15 percent VLI scenario are shown in Table 3-5.
The base development scenario includes 220 total housing units. Per the inclusionary housing scenario presented here, 15 percent of the units (33 units) are for VLI households. A 15 percent VLI scenario would entitle the inclusionary housing alternative to a density bonus of 50 percent, or an additional 110 market-rate units. This brings the total potential size of the inclusionary housing scenario to 330 units. This is 6.0 units per acre on the hypothetical 55-acre site.
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TABLE 3-4: NUMBER OF UNITS BY TYPE AND AFFORDABILITY
Unit Type
Base Development Scenario 15% VLI Inclusionary Scenario Total Number of Units Below Market-Rate Units Market-Rate Units Total Number of Units 3-Bedroom 80 12 108 120
4-Bedroom 80 12 108 120
5-Bedroom 60 9 81 90
Total 220 33 297 330
TABLE 3-5: SUMMARY OF UNITS
Base Development Scenario 15% VLI Inclusionary Scenario Market rate units 220 297
Below market-rate units 0 33
Total number of units 220 330
Site area (acres) 55 55
Gross density (du/acre) 4.0 6.0
3.2.1.2 PROJECT REVENUE
In the following discussion of project revenues, costs and feasibility, the performance of the 15 percent VLI inclusionary housing scenario, including maximum State density bonus, is compared to a fully market- rate version of the protype.
The estimated project revenue for Prototype 1 is presented in Table 3-6. The only income for each of the scenarios is the sales of the completed housing units. In the 15 percent VLI inclusionary housing scenario, the average per unit sales value, $803,000 (across all market-rate and BMR units), is 8.1 percent lower than the average in a fully market rate project.
TABLE 3-6: PROTOTYPE 1 PROJECT INCOME
Fully Market Rate Project 15% VLI Inclusionary Scenario Average sales value 874,000 803,000
Gross sales value 192,300,000 265,000,000
Less sales commission and
marketing -9,610,000 -13,260,000
Total Net Sales Value 182,700,000 252,000,000
Notes to Table 3-6:
1. The average sales value is based on the sales values in Table 4-4 and the number of units in Table 4-5. The gross sales value is the average unit value multiplied by the total number of units.
2. The analysis assumes a 5.0 percent sales commission. The total net sales value is the gross sales value less the sales commission.
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3.2.1.3 PROJECT COSTS
Estimated project costs are provided in Table 3-7. The overall cost increases with additional units, from $142 million for the fully market rate project to $227 million for the inclusionary housing scenario. The cost per unit also increases, even with fixed costs, such as land acquisition, spread across more units, and less roadway per unit. The analysis estimates the per unit cost at $648,000 for the fully market rate project and $688,000 for the 15 percent VLI inclusionary housing scenario TABLE 3-7: PROTOTYPE 1 PROJECT COSTS
Fully Market Rate Project 15% VLI Inclusionary Scenario Land Cost
Estimated property value 23,400,000 23,400,000
Due diligence 818,000 818,000
Estimated land acquisition cost 24,200,000 24,200,000
Hard Costs
Site work 10,920,000 27,400,000
Building construction 102,300,000 153,500,000
Hard cost subtotal 113,200,000 180,800,000
Soft Costs
Design, entitlement, and other soft costs @10.0% 11,320,000 18,080,000 Contingency @10.0% 11,320,000 18,080,000
Total development impact fees (includes city,
school district & other) 6,750,000 10,120,000
Soft costs subtotal 29,400,000 46,300,000
Total Development Cost
Total cost (before financing) 142,600,000 227,000,000
- per unit 648,000 688,000
Notes to Table 3-7:
1. The estimated property value is a PlaceWorks estimate based on our analysis of sales data, asking prices, and residual land values. The analysis assumes a 5 percent of land cost allowance for due diligence activities related to land acquisition. The cash flow model assumes monthly option payments of 1 percent of the estimated property value during the entitlement period, but the option payments are part of the overall payment for land acquisition rather than an additional cost.
2. Building construction costs are calculated on a per square foot basis for finished floor area and a separate square foot basis for garages. The per square foot costs are taken from Craftsman Book Company’s 2024 National Building Cost Manual, with the source’s recommended adjustments for local cost differential. As noted in the source, the per square foot cost estimates include all construction costs: labor, materials, equipment, plans, building permit, supervision, overhead, and profit.
3. Development impact fees are calculated as $18,561 per dwelling unit plus $5.17 per square foot (for school district fees).
The analysis assumes that development impact fees are charged to market-rate and below-market-rate units. The city could waive development impact fees for the below-market-rate units, which could lessen the need for other subsidies, primarily the extent of the additional density bonus.
3.2.1.4 FINANCIAL FEASIBILITY
Table 3-8 summarizes the financial feasibility of the market rate and 15 percent VLI inclusionary scenarios. The analysis finds that the fully market rate project is financially feasible, generating an IRR of
18.3 percent. This is to be expected, however, because this is the type of development that has been occurring in Antioch. Requiring 15 percent VLI affordable housing and relying on the State Density Bonus Law to provide the incentive is not financially feasible, with an IRR of -1.6 percent.
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TABLE 3-8: PROTOTYPE 1 FINANCIAL FEASIBILITY SUMMARY
Fully Market Rate Project 15% VLI Inclusionary Scenario Development cost 166,800,000 251,000,000
Financing cost 2,190,000 3,330,000
Total project cost 169,000,000 255,000,000
Equity required 37,500,000 52,700,000
Net project income 182,700,000 252,000,000
Project IRR 18.3% -1.6%
Surplus/(Gap) w/15% IRR 2,600,000 -15,320,000
Residual land value w/15% IRR 26,800,000 8,860,000
Notes to Table 3-8:
1. Financing cost includes construction loan fees of 2.5 percent and carried interest for a 6.85 annual percentage rate, based on data from realtyrates.com. The total project costs are the development cost, from Table 3-6, plus the financing cost.
2. The construction loan amount is based on 50 percent of land acquisition and 84 percent of other construction costs, based on data from realtyrates.com.
3. The IRR is an annual rate of return based on monthly cash flow, assuming a 6-month entitlement period, 4 months of site work, 18 months of construction, and 3 months to complete sales.
The analysis considered other alternatives to achieve financial feasibility. The inclusionary housing project would require a 63 percent reduction in the sales value of the land in order to be financially feasible. The analysis also assessed changes in market-rate sales value. If the market could support a 7.4 percent in the price for new market-rate housing, the inclusionary housing scenario would be financially feasible. As noted in Chapter 2, this analysis is based on current housing prices, so an increase in sales prices for market-rate units is not assumed in the feasibility assessment.
3.2.1.5 FEASIBILITY SUMMARY: INCLUSIONARY SCENARIOS
Table 3-9 summarizes the financial feasibility of the market rate scenario of Prototype 1, as compared to all seven inclusionary scenarios assessed in this analysis.
TABLE 3-9: PROTOTYPE 1 FEASIBILITY SUMMARY
Large Lot, SFD Subdivision
Base Market Rate Project
No inclusionary housing 18.3%
15% Inclusionary Requirement
15% Very low income -1.6%
15% Low income -7.1%
15% Moderate income -14.3%
10% Inclusionary Requirement
10% Very low income -2.6%
10% Low income -5.3%
10% Moderate income -12.1%
5% Inclusionary Requirement
5% Very low income -1.3%
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As shown in the Table 3-9, Prototype 1 would not be feasible under any inclusionary housing scenarios.
This is primarily due to the fact that the affordable units would have to be sold at a 79 to 83 percent reduction in price relative to the sales price of market-rate housing. Even a 50 percent increase in the allowable density fails to generate a return sufficient to compensate for this difference.
3.2.2 PROTOTYPE 2: SMALL LOT, SINGLE-FAMILY DETACHED
HOUSING SUBDIVISION
3.2.2.1 PROTOTYPE DESCRIPTION
This prototype is similar to Prototype 1. It is a single-family detached residential subdivision, but it is developed at a higher gross density. The base scenario includes 303 houses on a 30.2-acre site, for a gross density of 10.0 units per acre. Table 3-10 shows the types of housing and estimated sales values. As will be discussed, the 15 percent VLI inclusionary scenario includes additional market rate and BMR townhouses, which are required to achieve the increase in density that is needed to make an inclusionary requirement feasible for this prototype.
TABLE 3-10: PROTOTYPE 2 HOUSING SIZES AND SALES VALUES
Unit Type Size (sq. ft.)
Market-Rate Sales
Value
Below-Market-
Rate Sales Value Difference
Single-Family Detached Housing
3-Bedroom 1,480 584,104 135,715 -448,389 -76.8%
4-Bedroom 1,970 682,251 153,490 -528,762 -77.5%
5-Bedroom 2,270 788,786 170,144 -618,642 -78.4%
Townhouses
2-Bed Townhouse 1,225 379,206 135,715 -243,491 -64.2%
3-Bed Townhouse 1,460 462,734 153,490 -309,244 -66.8%
3-Bed Townhouse 1,758 558,862 153,490 -405,372 -72.5%
Notes to Table 3-10:
1. Unit types, sizes, and market-rate sales values are PlaceWorks assumptions based on our assessment of the current market.
2. Below market-rate sales values are based on the data in Table 4-3, assuming that 3-bedroom units are a mix of 3- and 4- person households, 4-bedroom units are 5-person households, and 5-bedroom units are a mix of 7- and 8-person households.
As with all five prototype analyses conducted for this report, PlaceWorks assessed the development implications of the base development scenario and even inclusionary housing scenarios for this prototype. We compared the feasibility of the inclusionary housing scenario to the fully market rate scenario. The number of each type & size of units resulting from in the 15 percent VLI inclusionary housing scenario is provided in Table 3-11. As noted, this inclusionary housing scenario provides for the greatest number of additional units under State Density Bonus. Development summaries of the base scenario and 15 percent VLI scenario are shown in Table 3-12. The base development scenario includes 303 total housing units. Per the inclusionary scenario presented here, 15 percent of the units (46 units) are for VLI income households.
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A 15 percent VLI scenario would entitle the inclusionary housing alternative to a density bonus of 50 percent, or an additional 152 market-rate units. This brings the total potential size of the inclusionary housing scenario to 455 units. This is 15.1 units per acre on the hypothetical 30.2- acre site.
TABLE 3-11: NUMBER OF UNITS BY TYPE AND AFFORDABILITY
Unit Type
Base Development Scenario 15% VLI Inclusionary Scenario Total Number of Units
Below-Market-
Rate Units Market-Rate Units
Total Number
of Units
3-Bedroom 86 0 65 65
4-Bedroom 125 0 94 94
5-Bedroom 92 0 69 69
2-Bed Townhouse 13 51 64
3-Bed Townhouse 19 75 94
3-Bed Townhouse 14 55 69
Total 303 46 409 455
TABLE 3-12: SUMMARY OF UNITS
Base Development Scenario 15% VLI Inclusionary Scenario Market rate units 303 409
Below market-rate units 0 46
Total number of units 303 455
Site area (acres) 30.2 30.2
Gross density (du/acre) 10.0 15.1
3.2.2.2 PROJECT REVENUE
The estimated project revenue for Prototype 2 is presented in Table 3-13. The only income for each of the scenarios is the sales of the completed housing units. In order to achieve the target gross density of
15.1 units per acre, the inclusionary housing scenario would require changing some of the detached units into townhouses, as well as adding additional market rate and BMR townhouses. The total number of townhouses required would be 227. As a result, the average per unit sales value, $545,000 (across all market-rate and BMR units), is 20.6 percent lower than the average in a fully market rate version of the project.
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TABLE 3-13: PROTOTYPE 2 PROJECT INCOME
Fully Market Rate Project 15% VLI Inclusionary Scenario Average sales value 687,000 545,000
Gross sales value 208,000,000 248,000,000
Less sales commission -10,400,000 -12,410,000
Total Net Sales Value 197,700,000 236,000,000
Notes to Table 3-13:
1. The average sales value is based on the sales values in Table 4-8 and the number of units in Table 3-9. The gross sales value is the average unit value multiplied by the total number of units,
2. The analysis assumes a 6.0 percent sales commission. The total net sales value is the gross sales value less the sales commission.
3.2.2.3 PROJECT COSTS
The estimated project costs are provided in Table 3-14. The overall cost increases with additional units, rising from just over $163 million for the fully market rate version, to just over $196 million for the inclusionary housing scenario. However, the cost per unit decreases with fixed costs, such as land acquisition, spread across more units, and less roadway per unit with smaller lots sizes. The analysis estimates the per unit cost at $539,000 for the fully market rate scenario and $431,000 for the 15 percent VLI inclusionary housing scenario.
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TABLE 3-14: PROTOTYPE 2 PROJECT COSTS
Fully Market Rate Project
15% VLI Inclusionary
Scenario
Land Cost
Estimated property value 15,130,000 15,130,000
Due diligence 529,494 529,494
Estimated land acquisition cost 15,660,000 15,660,000
Hard Costs
Site work 8,860,000 11,290,000
Building construction 121,900,000 143,200,000
Hard cost subtotal 130,800,000 154,500,000
Soft Costs
Design, entitlement, and other soft costs @10.0% 13,080,000 15,450,000 Contingency @10.0% 13,080,000 15,450,000
Total development impact fees (includes city, school district & other) 8,600,000 11,610,000
Soft costs subtotal 34,800,000 42,500,000
Total Development Cost
Total cost (before financing) 165,600,000 197,000,000
- per unit 546,000 433,000
Notes to Table 3-14:
1. The estimated property value is a PlaceWorks estimate based on our analysis of sales data, asking prices, and residual land values. The analysis assumes a 5 percent of land cost allowance for due diligence activities related to land acquisition. The cash flow model assumes monthly option payments of 1 percent of the estimated property value during the entitlement period, but the option payments are part of the overall payment for land acquisition rather than an additional cost.
2. Building construction costs are calculated on a per square foot basis for finished floor area and a separate square foot basis for garages. The per square foot costs are taken from Craftsman Book Company’s 2022 National Building Cost Manual, with the source’s recommended adjustments for local cost differential. As noted in the source, the per square foot cost estimates include all construction costs: labor, materials, equipment, plans, building permit, supervision, overhead, and profit.
3. Development impact fees are calculated as $54,209 per single-family dwelling unit and $43,259 per townhouse unit. The analysis assumes that development impact fees are charged to market-rate and below-market-rate units. The city could waive development impact fees for the below-market-rate units, which could lessen the need for other subsidies, primarily the extent of the additional density bonus.
3.2.2.4 FINANCIAL FEASIBILITY
Table 3-15 summarizes the financial feasibility of the market rate and 15 percent VLI inclusionary scenarios. The analysis finds that the market-rate project is financially feasible, generating an IRR of 19.9 percent. This is a very lucrative return, but it is not surprising given the density the scenario achieves. As shown in Table 3-15, the feasibility of Prototype 2 increases to 24.1 percent IRR with a 15 percent VLI affordable housing requirement and maximization of State Density Bonus Law.
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TABLE 3-15: PROTOTYPE 2 FINANCIAL FEASIBILITY SUMMARY
Fully Market Rate Project 15% VLI Inclusionary Scenario Development cost 181,200,000 213,000,000
Financing cost 2,400,000 2,810,000
Total project cost 183,600,000 215,000,000
Required equity 37,500,000 43,100,000
Net project income 197,700,000 236,000,000
Project IRR 21.0% 26.5%
Surplus/(Gap) w/15% IRR 6,870,000 11,150,000
Residual land value w/15% IRR 22,000,000 26,300,000
Notes to Table 3-15:
1. Financing cost includes construction loan fees of 2.5 percent and carried interest for a 6.85 annual percentage rate, based on data from realtyrates.com. The total project costs are the development cost, from Table 3-6, plus the financing cost.
2. The construction loan amount is based on 50 percent of land acquisition and 84 percent of other construction costs, based on data from realtyrates.com.
3. The IRR is an annual rate of return based on monthly cash flow, assuming a 6-month entitlement period, 4 months of site work, 18 months of construction, and 3 months to complete sales.
It is important to note, however, that this development prototype is financially feasible under an inclusionary housing requirement because the analysis assumes that many of the single-family detached housing units are replaced with single-family attached housing units in order to achieve the allowable density bonus. While this meets the standards of the state density bonus law, the market may not support this change in the housing product type.
3.2.2.5 FEASIBILITY SUMMARY: INCLUSIONARY SCENARIOS
Table 3-16 summarizes the financial feasibility of the market rate scenario of Prototype 2, as compared to all seven inclusionary scenarios assessed in this analysis.
TABLE 3-16 PROTOTYPE 2 FEASIBILITY SUMMARY
Small Lot, SFD Subdivision
Base Market Rate Project
No inclusionary housing 21.0%
15% Inclusionary Requirement
15% Very low income 26.5%
15% Low income 19.9%
15% Moderate income 11.1%
10% Inclusionary Requirement
10% Very low income 24.6%
10% Low income 28.8%
10% Moderate income -13.4%
5% Inclusionary Requirement
5% Very low income 24.4%
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As shown in Table 3-16, Prototype 2 could be financially feasible with 15, 10, and 5 percent inclusionary requirements, provided that the developer is able to choose which income category to serve. This prototype is not feasible when building for moderate-income households. As mentioned above, however, the financial feasibility is contingent on replacing some single-family detached housing units with attached housing units.
3.2.3 PROTOTYPE 3: FOR-SALE TOWNHOMES
3.2.3.1 PROTOTYPE DESCRIPTION
This prototype is for a medium-density townhome project. The development comprises 70 side-by-side residential units on a 4.7-acre site, for a gross density of 14.9 units per acre. In the base scenario, 10 of the 70 units are BMR units. Table 3-17 shows the types of housing and estimated sales values.
TABLE 3-17: PROTOTYPE 3 HOUSING UNIT SIZES AND SALES VALUES Unit Type Size (sq. ft.)
Market-Rate
Sales Value
Below-Market-
Rate Sales Value Difference
2 bed / 2 bath 1,225 379,206 135,715 -243,491 -64.2%
3 bed / 3 bath 1,460 462,734 153,490 -309,244 -66.8%
3 bed / 3.5 bath 1,758 566,584 170,144 -396,441 -70.0%
Notes to Table 3-17:
1. Unit types, sizes, and market-rate sales values are PlaceWorks’ assumptions based on our assessment of the current market.
2. Below market-rate sales values are based on the data in Table 3-3, assuming that 1-bedroom units are a mix of 1- and 2- person households, and 2-bedroom units are 3-person households.
As with all five analyses conducted for this report, PlaceWorks assessed the development implications of the base development scenario and seven inclusionary housing scenarios for this prototype. We compared the feasibility of the inclusionary housing scenarios to the fully market rate scenario. The number of each type/size of units resulting from the 15 percent VLI inclusionary housing scenario is provided in Table 3-18. As noted, this inclusionary housing scenario provides for the greatest number of additional units under State Density Bonus. Development summaries of the base scenario and 15 percent VLI scenario are shown in Table 3-19.
The base development scenario includes 70 townhomes. Per the inclusionary housing scenario presented here, 15 percent of the units (10 units) are for VLI households. The project density is about 15 units per acre on the 4.7-acre site.
The 15 percent VLI scenario would entitle the inclusionary housing alternative to a density bonus of 50 percent, or an additional 34 market-rate units. This brings the total potential size of the inclusionary housing scenario to 104 units. This is about 22.0 units per acre on the hypothetical
4.7-acre site.
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TABLE 3-18: NUMBER OF UNITS BY TYPE AND AFFORDABILITY
Unit Type
Base Development
Scenario 15% VLI Inclusionary Scenario
Total Number of Units
Below-Market-
Rate Units Market-Rate Units
Total Number of
Units
2 bed / 2 bath 14 2 19 21
3 bed / 3 bath 35 5 47 52
3 bed / 3.5 bath 21 3 28 31
Total 70 10 94 104
TABLE 3-19: UNIT SUMMARY
Base Development Scenario 15% VLI Inclusionary Scenario Market rate units 70 94
Below market-rate units 0 10
Total number of units 70 104
Site area (acres) 4.7 4.7
Gross density (du/acre) 14.9 22.1
3.2.3.2 PROJECT REVENUE
The estimated project revenue for Prototype 3 is presented in Table 3-20. The only income for each of the scenarios is the sales of the completed housing units. In the 15 percent VLI inclusionary scenario, the average per unit sales value, $446,000 (across all market-rate and BMR units), is 6.5 percent lower than the average in a fully market rate version of the project.
TABLE 3-20: PROTOTYPE 3 PROJECT INCOME
Fully Market Rate Project 15% VLI Inclusionary Scenario Average sales value 477,000 446,000
Gross sales value 33,400,000 46,400,000
Less sales commission -1,670,000 -2,320,000
Total Net Sales Value 31,700,000 44,000,000
Notes to Table 3-20:
1. The average sales value is based on the sales values in Table 3-17 and the number of units in Table 3-18. The gross sales value is the average unit value multiplied by the total number of units.
2. The analysis assumes a 6.0 percent sales commission. The total net sales value is the gross sales value less the sales commission.
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3.2.3.3 PROJECT COSTS
Estimated project costs are provided in Table 3-21. The overall cost increases with additional units, rising from $26.5 million for the fully market rate project, to $40.6 million for the 15 percent VLI inclusionary housing scenario. With townhomes, there are fewer opportunities to spread costs across more units and lower costs with less road frontage constructed. To increase the density, each you could be built with a smaller footprint but with an additional story. However, higher townhouses may be less marketable.
Unlike the previous two scenarios, the cost per unit increases somewhat with an increasing number of units. The analysis estimates the per unit cost at $386,000 for the base scenario and $381,000 for the inclusionary housing scenario.
TABLE 3-21: PROTOTYPE 3 PROJECT COSTS
Fully Market Rate Project 15% VLI Inclusionary Scenario Land Cost
Estimated property value 2,440,000 2,440,000
Due diligence 500,000 500,000
Estimated land acquisition cost 2,350,000 2,350,000
Hard Costs
Site work 1,845,000 2,310,000
Building construction 19,180,000 28,500,000
Hard cost subtotal 21,000,000 30,800,000
Soft Costs
Design, entitlement, and other soft costs @10.0% 2,100,000 3,080,000 Contingency @10.0% 2,100,000 3,080,000
Total development impact fees (includes city, school
district & other) 1,828,000 2,710,000
Soft costs subtotal 6,030,000 8,870,000
Total Development Cost
Total cost (before financing) 27,100,000 39,700,000
- per unit 387,000 381,000
Notes to Table 3-21:
1. The estimated property value is a PlaceWorks estimate based on our analysis of sales data, asking prices, and residual land values. The analysis assumes a 5 percent of land cost allowance for due diligence activities related to land acquisition. The cash flow model assumes monthly option payments of 1 percent of the estimated property value during the entitlement period, but the option payments are part of the overall payment for land acquisition rather than an additional cost.
2. Building construction costs are calculated on a per square foot basis for finished floor area and a separate square foot basis for garages. The per square foot costs are taken from Craftsman Book Company’s 2022 National Building Cost Manual, with the source’s recommended adjustments for local cost differential. As noted in the source, the per square foot cost estimates include all construction costs: labor, materials, equipment, plans, building permit, supervision, overhead, and profit.
3. Development impact fees are calculated as $33,024 per one-bedroom unit and $43,259 per two-bedroom unit. The analysis assumes that development impact fees are charged to market-rate and below-market-rate units. The city could waive development impact fees for the below-market-rate units, which could lessen the need for other subsidies, primarily the extent of the additional density bonus.
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3.2.3.4 FINANCIAL FEASIBILITY
Table 3-22 summarizes the financial feasibility of the market rate and 15 percent VLI inclusionary scenarios. The analysis finds that the fully market rate project is financially feasible, generating an IRR of
20.6 percent. This is a very lucrative return, but it is not surprising given the density the scenario achieves.
As shown in Table 3-22, this prototype is financially feasible with a 15 percent VLI affordable housing requirement, although it is less lucrative than the market-rate scenario.
TABLE 3-22: PROTOTYPE 3 FINANCIAL FEASIBILITY SUMMARY
Fully Market Rate Project 15% VLI Inclusionary Scenario Development cost 29,500,000 42,100,000
Financing cost 389,000 557,000
Total project cost 29,900,000 42,700,000
Required equity 6,050,000 8,320,000
Net project income 31,700,000 44,000,000
Project IRR 20.6% 15.5%
Surplus/(Gap) w/15% IRR 650,000 153,500
Residual land value w/15% IRR 3,090,000 2,510,000
Notes to Table 3-22:
1. Financing cost includes construction loan fees of 2.5 percent and carried interest for a 6.85 annual percentage rate, based on data from realtyrates.com. The total project costs are the development cost, from Table 3-6, plus the financing cost.
2. The construction loan amount is based on 50 percent of land acquisition and 84 percent of other construction costs, based on data from realtyrates.com.
3. The IRR is an annual rate of return based on monthly cash flow, assuming a 6-month entitlement period, 4 months of site work, 18 months of construction, and 3 months to complete sales.
3.2.3.5 FEASIBILITY SUMMARY: INCLUSIONARY SCENARIOS
Table 3-23 summarizes the financial feasibility of the Prototype 3 market rate scenario and all seven inclusionary scenarios assessed in this analysis.
TABLE 3-23: PROTOTYPE 3 FEASIBILITY SUMMARY
For-Sale Townhouses
Base Market Rate Project
No inclusionary housing 20.6%
15% Inclusionary Requirement
15% Very low income 15.5%
15% Low income 12.8%
15% Moderate income 19.9%
10% Inclusionary Requirement
10% Very low income 16.3%
10% Low income 12.6%
10% Moderate income 19.8%
5% Inclusionary Requirement
5% Very low income 18.2%
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As shown in Table 3.23, the hypothetical townhouse project is generally financially feasible under 15, 10, and 5 percent inclusionary requirements provided that the developer is able to choose which income category to serve. With 15 and 10 percent inclusionary requirements, this protype is not financially feasible when providing housing affordable to moderate income households.
3.3 DISPOSITION REQUIREMENTS
An inclusionary ordinance will likely require that households purchasing an affordable unit qualify based on income and that the sales price qualify as affordable to that household. The program will also have to identify what restriction, if any, will be applied to future resales of these affordable units. Different state and federal programs have different requirements.
We recommend that the city’s ordinance restrict future resales so that the purchasing household also be income-qualified and the sales price represents an affordable housing payment for the purchasing household. We further recommend that this restriction be enforced by a deed restriction for a period of 45 years. This would be consistent with some federal affordable housing programs, but it is worth noting that it is unlikely that federal funding would be involved with mixed-income inclusionary housing projects.
As an alternative, Antioch could consider using provisions similar to the State Density Bonus Law. The original purchaser would still have to be income-qualified and the sales price would have to be qualified as affordable to the purchasing household. The purchasing household would not be restricted from selling the property in the future at then market-rates or to selling to households that are not qualified as low income. However, there would be an equity sharing agreement, and the city would receive the amount of the original sales price write-down and a proportional share of any appreciation in value.
Antioch could then use its share of the sales price to support other affordable housing projects and programs.
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4. Rental Housing Protoypes
This chapter includes PlaceWorks’ analyses of the impact of affordability requirements on the financial feasibility of two prototypical rental housing development projects. Each prototype is representative of recent development activity in Antioch. The two prototypes include:
Prototype 4: Medium/High Density Multifamily Flats. Medium-scale apartment development with 83 units at a gross density of 20.2 units per acre.
Prototype 5: High Density Multifamily Flats. Large-scale apartment development with 237 units at a gross density of 26.9 units per acre.
Each protoype discussion includes the results of the financial feasibility analysis under the scenarios described in Section 2.2.5:
1. Fully Market Rate Scenario. This is the fully-market rate project.
2. Inclusionary Scenarios. Each of these scenarios inlcude a different affordability requirement and the associated maximum number of new units allowed under State Density Bonus Law.
As explained under Section 2.1, we first present detailed financial analyses of the 15 percent VLI inclusionary scenario for each prototype. This facilitates exploration and analysis of the impact of the maximum density bonus allowed under State law. For each prototype, we then summarize the feasibility of the six other inclusionary scenarios.
This chapter also includes discussions of whether any of the scenarios would generate a feasibility surplus that could be used to pay a fee in lieu of providing affordable rental units on-site.
This chapter opens with a discussion of affordable household rents.
4.1 AFFORDABLE HOUSEHOLD RENTS
The affordable rent for a household is based on annual income and household size. Affordable rents are calculated in Table 4-1 for VLI, LI, and MI households.
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TABLE 4-1: CALCULATION OF AFFORDABLE RENTS BY HOUSEHOLD SIZE AND INCOME CLASSIFICATION (ALL DATA IN 2024 DOLLARS); ANTIOCH; 2024
Household Size: 1 2 3 4 5 6 7 8 9
Very Low-Income Households
Annual income limit 54,500 62,300 70,100 77,850 84,100 90,350 96,550 102,800 109,028 Affordable housing cost
(assumes 30% of annual
income limit)
16,350 18,690 21,030 23,355 25,230 27,105 28,965 30,840 32,708 Annual utility allowance 208 250 291 339 381 407 434 434 434 Annual affordable rent 13,854 15,690 17,538 19,287 20,658 22,221 23,757 25,632 27,500 Monthly affordable rent 1,155 1,308 1,462 1,607 1,722 1,852 1,980 2,136 2,292 Low-Income Households
Annual income limit 84,600 96,650 108,750 120,800 130,500 140,150 149,800 159,500 169,164 Affordable housing cost
(assumes 30% of annual
income limit)
25,380 28,995 32,625 36,240 39,150 42,045 44,940 47,850 50,749 Annual utility allowance 208 250 291 339 381 407 434 434 434 Annual affordable rent 22,884 25,995 29,133 32,172 34,578 37,161 39,732 42,642 45,541 Monthly affordable rent 1,907 2,166 2,428 2,681 2,882 3,097 3,311 3,554 3,795 Moderate-Income Households
Annual income limit 130,800 149,500 168,150 186,850 201,800 216,750 231,700 246,650 261,598 Affordable housing cost
(assumes 30% of annual
income limit)
39,240 44,850 50,445 56,055 60,540 65,025 69,510 73,995 78,479 Annual utility allowance 208 250 291 339 381 407 434 434 434 Annual affordable rent 36,744 41,850 46,953 51,987 55,968 60,141 64,302 68,787 73,271 Monthly affordable rent 3,062 3,488 3,913 4,332 4,664 5,012 5,359 5,732 6,106 Notes to Table 4.1:
1. Data for annual income limit by household size and income classification is from Table 3-1.
2. The total affordable rent payment is considered to be 30 percent of household income.
3. Annual utility allowance data are based on Contra Costa County Utility Allowances.
4. The annual housing affordable payment is the affordable housing cost less the utility allowance. The monthly housing affordable payment is the annual payment divided by 12.
4.2 FOR-RENT DEVELOPMENT PROTOTYPES AND ANALYSES
PlaceWorks defined two development scenarios for for-rent housing based on our review of recently constructed and permitted housing projects in Antioch:
Prototype 4: Medium/High Density Multifamily Flats. Medium-scale apartment development with 83 units at a gross density of 20.2 units per acre.
Prototype 5: High Density Multifamily Flats. Large-scale apartment development with 237 units at a gross density of 26.9 units per acre.
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These prototypes are intended to reflect typical for-rent multifamily development that can be expected to be built in Antioch. The prototypes are intended to provide a generalized indication of the financial feasibility impacts of inclusionary housing requirements. The prototypes do not reflect any particular lot or parcel or location in the city.
4.2.1 PROTOTYPE 4: MEDIUM-HIGH MULTIFAMILY DEVELOPMENT
4.2.1.1 PROTOTYPE DESCRIPTION
This prototype represents a fairly common suburban multifamily development. At just over 20 units per acre, this scale of development is fairly easy to arrange on a site, and it is fairly easy to accommodate all required parking and open space. This prototype has a three-story apartment building with 83 units on
4.1 acres. Table 4-2 shows the types of residential units and estimated rents.
TABLE 4-2: PROTOTYPE 4 HOUSING SIZES AND MONTHLY RENTS (ASSUMING A 9.1 PERCENT RENT INCREASE) Unit Type Size (sq. ft.)
Market-Rate
Rents
Below-Market-
Rate Rents Difference
1-bedroom 850 2,168 1,191 -978 -45.1%
2-bedroom 950 2,211 1,393 -818 -37.0%
3-bedroom 1,200 2,265 1,575 -690 -30.5%
Notes to Table 4-2:
1. Unit types, sizes, and market-rate rents are PlaceWorks’ assumptions based on our assessment of the current market and reflect an increase of 9.1 percent over current market rents.
2. Below-market-rate rents are based on the data in Table 4-1, assuming that studio units are 1-person households, 1- bedroom units are occupied by a mix of 1- and 2-person households, 2-bedroom units are occupied by 3-person households, and 3-bedroom units are occupied by a mix of 3- and 4-person households.
As with all five prototype analyses conducted for this report, PlaceWorks assessed the development implications of the base development scenario and seven inclusionary housing scenarios for this prototype. We compared the feasibility of the inclusionary housing scenarios to the fully market rate scenario. The number of each type/size of units resulting from the 15 percent VLI inclusionary housing scenario is provided in Table 4-3. As noted, this inclusionary housing scenario provides for the greatest number of additional units under State Density Bonus. Development summaries of the base scenario and 15 percent VLI scenario are shown in Table 4-4.
The base development scenario includes 83 total housing units. Per the inclusionary housing scenario presented here, 15 percent of the units (13 units) are for VLI households. A 15 percent VLI scenario would entitle the inclusionary housing alternative to a density bonus of 50 percent, or an additional 42 market-rate units. This brings the total potential size of the inclusionary housing scenario to 125 units. This is about 30.5 units per acre on the hypothetical
4.1-acre site.
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TABLE 4-3: NUMBER OF UNITS BY TYPE AND AFFORDABILITY
Unit Type
Base Development Scenario 15% VLI Inclusionary Scenario Total Number of Units
Below-Market-
Rate Units Market-Rate Units
Total Number of
Units
1-bedroom 32 5 43 48
2-bedroom 39 6 53 59
3-bedroom 12 2 16 18
Total 83 13 112 125
TABLE 4-4: UNIT SUMMARY
Base Development Scenario 15% VLI Inclusionary Scenario Market rate units 83 112
Below market-rate units 0 13
Total number of units 83 125
Site area (acres) 4.1 4.1
Gross density (du/acre) 20.2 30.5
4.2.1.2 PROJECT REVENUE
The estimated project revenue for Prototype 4 is presented in Table 4-5. The income for each of the scenarios is the monthly rents for the residential units. The estimated average monthly rent in the 15 percent VLI inclusionary housing scenario, $2,110 (across all market-rate and BMR units), is 4.0 percent lower than the average in a fully market rate version of the project. The analysis assumes a 33.5 percent allowance for vacancies and operations in the first full year of occupancy. The annual net operating income increases from $1.45 million in the fully market rate version, to $2.11 million in the inclusionary housing scenario.
TABLE 4-5: PROTOTYPE 4 PROJECT INCOME
Fully Market Rate Project 15% VLI Inclusionary Scenario Number of units 83 125
Average monthly rent 2,200 2,110
Gross annual income 2,190,000 3,170,000
Less vacancies and operations -735,000 -1,062,000
Annual net operating income 1,459,000 2,110,000
Notes to Table 4-5:
1. The average monthly rent is based on the rent by unit type in Table 4-3 and the number of units in Table 4-4. The gross annual income is the average monthly rent multiplied by 12 months.
2. The analysis assumes a 33.5 percent allowance for vacancies and operations. The national average across all apartments is
45.8 percent, based on data from realtyrates.com. A new apartment development in a community with very low multifamily vacancies can be expected to perform much better than the national average.
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4.2.1.3 PROJECT COSTS
The estimated project costs are provided in Table 4-6. The total development cost increases with additional units, rising from $21.62 million for the fully market rate project, to $32.19 million for the 15 percent VLI inclusionary housing scenario. However, the cost per unit decreases with fixed costs, such as land acquisition, spread across more units. The analysis estimates the per unit cost at 261,000 for the fully market rate project and 257,000 for the inclusionary housing scenario.
TABLE 4-6: PROTOTYPE 4 PROJECT COSTS
Fully Market Rate Project 15% VLI Inclusionary Scenario Land Cost
Estimated property value 2,130,000 2,130,000
Due diligence 500,000 500,000
Estimated land acquisition cost 2,050,000 2,050,000
Hard Costs
Site work 1,761,000 2,260,000
Building construction 14,940,000 22,600,000
Hard cost subtotal 16,700,000 24,900,000
Soft Costs
Design, entitlement, and other soft costs @10.0% 1,670,000 2,490,000 Contingency @10.0% 1,670,000 2,490,000
Total development impact fees (includes city,
school district & other)
1,639,000 2,280,000
Soft costs subtotal 4,980,000 7,250,000
Total Development Cost
Total cost (before financing) 21,700,000 32,100,000
- per unit 261,000 257,000
Notes to Table 4-6:
1. The estimated property value is a PlaceWorks estimate based on our analysis of sales data, asking prices, and residual land values. The analysis assumes a 5 percent of land cost allowance for due diligence activities related to land acquisition. The cash flow model assumes monthly option payments of 1 percent of the estimated property value during the entitlement period, but the option payments are part of the overall payment for land acquisition rather than an additional cost.
2. Building construction costs are calculated on a per square foot basis for finished floor area and a separate square foot basis for garages. The per square foot costs are taken from Craftsman Book Company’s 2022 National Building Cost Manual, with the source’s recommended adjustments for local cost differential. As noted in the source, the per square foot cost estimates include all construction costs: labor, materials, equipment, plans, building permit, supervision, overhead, and profit.
3. Development impact fees are calculated as $29,000 per studio unit, $33,024 per 1-bedroom unit, and $43,259 per 2- or more bedroom unit. The analysis assumes that development impact fees are charged to market-rate and below-market-rate units. The city could waive development impact fees for the below-market-rate units, which could lessen the need for other subsidies, primarily the extent of the additional density bonus.
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4.2.1.4 FINANCIAL FEASIBILITY
Table 4-7 summarizes the financial feasibility of a fully market-rate version of the project to the 15 percent VLI inclusionary housing scenario. The analysis finds that the fully market rate version of the project is financially feasible, generating a yield of 6.1 percent. Requiring 15 percent of the units to be affordable to VLI households while maximizing State Density Bonus law is also financially feasible, generating a yield of 6.2 percent.
TABLE 4-7: PROTOTYPE 4 FINANCIAL FEASIBILITY SUMMARY
Fully Market Rate Project 15% VLI Inclusionary Scenario Development cost 23,800,000 34,200,000
Financing cost 123,900 180,400
Total project cost 23,900,000 34,400,000
Required equity 4,930,000 6,810,000
Year 1 NOI (before debt service and taxes) 1,459,000 2,110,000 Cash-on-cash yield 6.1% 6.2%
Surplus/(Gap) w/6% Yield 306,000 730,860
Residual land value w/6% yield 2,360,000 2,784,720
Notes to Table 4-7:
1. Financing cost includes construction loan fees of 2.5 percent and carried interest for a 6.85 annual percentage rate, based on data from realtyrates.com. The total project costs are the development cost, from Table 4-6, plus the financing cost.
2. The cash-on-cash yield annual rate of return in the first full year of occupancy based on the net operating income after debt service and taxes divided by the required equity investment.
The analysis indicates that this development prototype could be financially feasible with a 15 percent VLI affordable housing requirement. However, the feasibility is contingent upon going from a three-story apartment building to a 4-story apartment building and the developer provide less per unit parking in order to accommodate the increase to a density of 30 units per acre.
4.2.1.5 FEASIBILITY SUMMARY: INCLUSIONARY SCENARIOS
Table 4-8 summarizes the financial feasibility of the market rate scenario and all seven inclusionary scenarios assessed in this analysis.
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TABLE 4-8: PROTOTYPE 4 FEASIBILITY SUMMARY
Medium/High Density Multifamily Flats
Base Market Rate Project
No inclusionary housing 6.1%
15% Inclusionary Requirement
15% Very low income 6.2%
15% Low income 4.9%
15% Moderate income 5.2%
10% Inclusionary Requirement
10% Very low income 6.1%
10% Low income 4.8%
10% Moderate income 5.0%
5% Inclusionary Requirement
5% Very low income 6.1%
As shown in Table 4-8, the financial feasibility of Prototype 4 is dependent on the density increase associated with providing VLI units. The yield of Prototype 4 falls below 6.0 percent when it complies with all LI and MI inclusionary requirements. The analysis indicates that this prototype could be feasible with 10, 10, and 5 percent inclusionary requirements if the developer is allowed to choose which income category to serve. However, the feasibility is contingent on going to four stories and obtaining a parking reduction through the state density bonus law.
4.2.2 PROTOTYPE 5: LARGER-SCALE APARTMENT DEVELOPMENT
4.2.2.1 PROTOTYPE DESCRIPTION
This prototype represents a suburban multifamily development at a scale and density that is not currently common in Antioch but that does occur elsewhere in the state and is consistent with the direction of housing and development policy in the current Antioch general plan update. This prototype includes a four-story apartment building with 237 units on 8.8 acres, resulting in a gross density of 26.9 units per acre. Table 4-9 shows the types of residential units and estimated rents.
TABLE 4-9: PROTOTYPE 5 HOUSING SIZES AND MONTHLY RENTS
Unit Type Size (sq. ft.)
Market-Rate
Rents
Below-Market-
Rate Rents Difference
1-bedroom A 700 2,182 1,191 -992 -45.5%
1-bedroom B 870 2,215 1,191 -1,024 -46.2%
2-bedroom A 950 2,230 1,393 -837 -37.6%
2-bedroom B 1,085 2,256 1,393 -863 -38.3%
2-bedroom C 1,115 2,261 1,393 -869 -38.4%
3-bedroom A 1,250 2,287 1,575 -712 -31.1%
Notes to Table 4-9:
1. Unit types, sizes, and market-rate rents are PlaceWorks’ assumptions based on our assessment of the current market.
2. Below-market-rate rents are based on the data in Table 4-7, assuming that 1-bedroom units are occupied by a mix of 1- and 2-person households, 2-bedroom units are occupied by 3-person households, and 3-bedroom units are occupied by a mix of 3- and 4-person households.
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As with all five prototype analyses conducted for this report, PlaceWorks assessed the development implications of the base development scenario and seven inclusionary housing scenarios for this prototype. We compared the feasibility of the inclusionary housing scenarios to the fully market rate scenario. The number of each type/size of units resulting from the 15 percent VLI inclusionary housing scenario is provided in Table 4-10. As noted, this inclusionary housing scenario provides for the greatest number of additional units allowed under State Density Bonus law. Development summaries of the base scenario and 15 percent VLI scenario are shown in Table 4-11. The base development scenario includes 237 total housing units. Per the inclusionary housing scenario presented here, 15 percent of the units (36 units) are for VLI households. A 15 percent VLI scenario would entitle the inclusionary housing alternative to a density bonus of 50 percent, or an additional 119 market-rate units. This brings the total potential size of the inclusionary housing scenario to 356 units. This is about 40.5 units per acre on the hypothetical
8.8-acre site.
TABLE 4-10: NUMBER OF UNITS BY TYPE AND AFFORDABILITY
Unit Type
Base Development Scenario 15% VLI Inclusionary Scenario Total Number of Units
Below-Market-Rate
Units Market-Rate Units Total Number of Units
1-bedroom A 54 8 73 81
1-bedroom B 48 7 65 72
2-bedroom A 50 8 68 76
2-bedroom B 24 4 32 36
2-bedroom C 43 6 58 64
3-bedroom A 18 3 24 27
Total 237 36 320 356
TABLE 4-11: UNIT SUMMARY
Base Development Scenario 15% VLI Inclusionary Scenario Market rate units 237 320
Below market-rate units 0 36
Total number of units 237 356
Site area (acres) 8.8 8.8
Gross density (du/acre) 26.9 40.5
4.2.2.2 PROJECT REVENUE
The estimated project revenue for Prototype 5 is presented in Table 4-12. The income for each of the scenarios is the monthly rents for the residential units. The estimated average monthly rent in the 15 percent VLI inclusionary housing scenario, $2,140 (across all market-rate and BMR units), is 4.0 percent lower than the average in a fully market rate version of the project. The analysis assumes a 33.5 percent allowance for vacancies and operations in the first full year of occupancy. The annual net operating E51
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income increases from $4.22 million in the fully market rate version, to $6.07 million in the inclusionary housing scenario.
TABLE 4-12: PROTOTYPE 5 PROJECT INCOME
Fully Market Rate Project 15% VLI Inclusionary Scenario Number of units 237 356
Average monthly rent 2,230 2,140
Gross annual income 6,340,000 9,130,000
Less vacancies and operations -2,120,000 -3,060,000
Annual net operating income 4,220,000 6,070,000
Notes to Table 4-12:
1. The average monthly rent is based on the rent by unit type in Table 4-3 and the number of units in Table 4-.4. The gross annual income is the average monthly rent multiplied by 12 months.
2. The analysis assumes a 33.5 percent allowance for vacancies and operations. The national average across all apartments is
45.8 percent, based on data from realtyrates.com. A new apartment development in a community with very low multifamily vacancies can be expected to perform much better than the national average.
4.2.2.3 PROJECT COSTS
The estimated project costs are provided in Table 4-13. The overall cost increases with additional units, rising from $59.0 million for the fully market-rate project, to $91.4 million for the 15 percent VLI inclusionary housing scenario.
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TABLE 4-13: PROTOTYPE 5 PROJECT COSTS
Fully Market Rate Project 15% VLI Inclusionary Scenario Land Cost
Estimated property value 4,560,000 4,560,000
Due diligence 500,000 500,000
Estimated land acquisition cost 4,400,000 4,400,000
Hard Costs
Site work 2,220,000 4,800,000
Building construction 43,100,000 65,600,000
Hard cost subtotal 45,300,000 70,400,000
Soft Costs
Design, entitlement, and other soft costs @10.0% 4,530,000 7,040,000 Contingency @10.0% 4,530,000 7,040,000
Total development impact fees (includes city,
school district & other) 4,670,000 7,020,000
Soft costs subtotal 13,740,000 21,100,000
Total Development Cost
Total cost (before financing) 63,600,000 96,100,000
Notes to Table 4-13:
1. The estimated property value is a PlaceWorks estimate based on our analysis of sales data, asking prices, and residual land values. The analysis assumes a 5 percent of land cost allowance for due diligence activities related to land acquisition. The cash flow model assumes monthly option payments of 1 percent of the estimated property value during the entitlement period, but the option payments are part of the overall payment for land acquisition rather than an additional cost.
2. Building construction costs are calculated on a per square foot basis for finished floor area and a separate square foot basis for garages. The per square foot costs are taken from Craftsman Book Company’s 2022 National Building Cost Manual, with the source’s recommended adjustments for local cost differential. As noted in the source, the per square foot cost estimates include all construction costs: labor, materials, equipment, plans, building permit, supervision, overhead, and profit.
3. Development impact fees are calculated as $33,024 per 1-bedroom unit and $43,259 per 2- or more bedroom unit. The analysis assumes that development impact fees are charged to market-rate and below-market-rate units. The city could waive development impact fees for the below-market-rate units, which could lessen the need for other subsidies, primarily the extent of the additional density bonus.
4.2.2.4 FINANCIAL FEASIBILITY
Table 4-14 summarizes the financial feasibility of a fully market-rate version of the project to the 15 percent VLI inclusionary housing scenario. The analysis finds that both the fully market-rate project and 15 percent VLI scenario are financially feasible, generating yield of 6.6 percent and 6.3 percent, respectively. At a 6.6 percent yield, the base development scenario would generate a surplus of $6.5 million. At a 6.3 percent yield, the inclusionary scenario would generate a surplus of $4.3 million.
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TABLE 4-14: PROTOTYPE 5 FINANCIAL FEASIBILITY SUMMARY
Fully Market Rate Project 15% VLI Inclusionary Scenario Development cost 63,600,000 96,000,000
Financing cost 333,000 509,000
Total project cost 64,000,000 96,600,000
Required equity 12,830,000 18,650,000
Year 1 NOI (before debt service and taxes) 4,220,000 6,070,000 Cash-on-cash yield 6.6% 6.3%
Surplus/(Gap) w/6% Yield 6,540,000 4,260,000
Residual land value w/6% yield 11,100,000 8,820,000
Notes to Table 4-13:
1. Financing cost includes construction loan fees of 2.5 percent and carried interest for a 6.85 annual percentage rate, based on data from realtyrates.com. The total project costs are the development cost, from Table 4-6, plus the financing cost.
2. The cash-on-cash yield annual rate of return in the first full year of occupancy based on the net operating income after debt service and taxes divided by the required equity investment.
The analysis indicates that this development prototype would be financially feasible with a 15% VLI inclusionary requirement. However, the feasibility is contingent on increasing the building height and reducing the amount of parking per unit.
4.2.2.5 FEASIBILITY SUMMARY: INCLUSIONARY SCENARIOS
Table 4-15 summarizes the financial feasibility of the Prototype 5 market rate scenario and all seven inclusionary scenarios assessed in this analysis.
TABLE 4-15: PROTOTYPE 5 FEASIBILITY SUMMARY
High Density
Multifamily Flats
Base Market Rate Project
No inclusionary housing 6.6%
15% Inclusionary Requirement
15% Very low income 6.3%
15% Low income 6.4%
15% Moderate income 6.8%
10% Inclusionary Requirement
10% Very low income 6.3%
10% Low income 6.4%
10% Moderate income 6.6%
5% Inclusionary Requirement
5% Very low income 6.3%
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As shown in Table 4-15, Prototype 5 remains financially feasible under all inclusionary scenarios.
However, the feasibility is contingent on the need for additional stories and obtaining a parking reduction through the state density bonus law.
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A PPENDIX A
A NTIOCH M ARKET S URVEY :
S INGLE F AMILY S ALES D A TA
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address price bed bath sqft pricePerSf lotArea lotAreaType homeType zestimate rentZestimate 822 W 4th St, Antioch, CA 94509 395000 2 1 1000 395 5227.2 sqft SINGLE_FAMILY 408500 2524 1527 Sandy Way, Antioch, CA 94509 499999 3 1 996 502.01 8276.4 sqft SINGLE_FAMILY 2684 5187 Grass Valley Way, Antioch, CA 94531 574888 3 2 1299 442.56 5000 sqft SINGLE_FAMILY 560900 3094 1313 August Way, Antioch, CA 94509 499950 3 2 1021 489.67 5662.8 sqft SINGLE_FAMILY 2580 4468 Deerfield Dr, Antioch, CA 94531 639000 5 3 2053 311.25 6098.4 sqft SINGLE_FAMILY 3321 2331 Peachtree Cir, Antioch, CA 94509 585000 3 2 1603 364.94 7840.8 sqft SINGLE_FAMILY 598900 2954 1703 Periwinkle Way, Antioch, CA 94531 528000 3 3 1636 322.74 2783.484 sqft SINGLE_FAMILY 542200 2923 5220 Fairside Way, Antioch, CA 94531 545000 3 3 1496 364.3 4356 sqft SINGLE_FAMILY 3041 65 Dunes Way, Antioch, CA 94509 549000 3 2 1075 510.7 9147.6 sqft SINGLE_FAMILY 2843 4011 Royal Links Ct, Antioch, CA 94509 750000 3 3 1659 452.08 0.59 acres SINGLE_FAMILY 787100 3466 5525 Sierra Trail Way, Antioch, CA 94531 749000 4 4 2803 267.21 5235.912 sqft SINGLE_FAMILY 753100 4048 5204 Puma Ct, Antioch, CA 94531 760000 4 3 2580 294.57 7840.8 sqft SINGLE_FAMILY 3673 220 Cobblestone Dr, Antioch, CA 94509 619900 3 2 2022 306.58 7405.2 sqft SINGLE_FAMILY 3163 5045 Carbondale Way, Antioch, CA 94531 890000 4 3 3360 264.88 0.27 acres SINGLE_FAMILY 4470 1015 W 4th St, Antioch, CA 94509 400000 3 1 1092 366.3 5227.2 sqft SINGLE_FAMILY 2345 5132 Furlong Way, Antioch, CA 94531 598000 4 3 1697 352.39 5227.2 sqft SINGLE_FAMILY 617900 3210 5 Inland Ct, Antioch, CA 94509 499900 3 3 1769 282.59 6534 sqft SINGLE_FAMILY 3490 2101 Banyan Way, Antioch, CA 94509 400000 2 1 809 494.44 3920.4 sqft SINGLE_FAMILY 2118 2432 Redwood Dr, Antioch, CA 94509 529000 3 3 1259 420.17 2613.6 sqft SINGLE_FAMILY 2757 4216 Amargosa Dr, Antioch, CA 94531 674000 5 3 2312 291.52 5227.2 sqft SINGLE_FAMILY 3517 3020 Larkspur Dr, Antioch, CA 94531 679000 4 3 2288 296.77 0.25 acres SINGLE_FAMILY 3372 2633 Whitetail Ct, Antioch, CA 94531 629999 3 2 2066 304.94 10742 sqft SINGLE_FAMILY 614400 3296 75 S Lake Dr, Antioch, CA 94509 619950 3 2 1676 369.9 10018.8 sqft SINGLE_FAMILY 3438 4624 Wolf Way, Antioch, CA 94531 660000 4 3 2221 297.16 4822.092 sqft SINGLE_FAMILY 645300 3290 1912 Yellowstone Ct, Antioch, CA 94509 657000 4 3 2128 308.74 9147.6 sqft SINGLE_FAMILY 697500 3131 3109 Barmouth Dr, Antioch, CA 94509 620000 4 2 1834 338.06 6534 sqft SINGLE_FAMILY 646900 3559 5008 Union Mine Dr, Antioch, CA 94531 950000 6 4 3859 246.18 9147.6 sqft SINGLE_FAMILY 4497 5117 Ebbetts Way, Antioch, CA 94531 675000 4 3 1987 339.71 SINGLE_FAMILY 666600 3414 2440 Johns Way, Antioch, CA 94531 688000 4 3 1987 346.25 6534 sqft SINGLE_FAMILY 703400 3428 1223 Hillcrest Ave, Antioch, CA 94509 1299000 4 4 2021 642.75 0.61 acres SINGLE_FAMILY 1368100 4270 501 Black Oak Ct, Antioch, CA 94509 700000 4 3 2604 268.82 0.27 acres SINGLE_FAMILY 3948 1137 L St, Antioch, CA 94509 419000 3 1 1013 413.62 5005.044 sqft SINGLE_FAMILY 420400 2334 615 W 12th St, Antioch, CA 94509 395000 2 1 924 427.49 3920.4 sqft SINGLE_FAMILY 2328 5352 Thunderbird Ct, Antioch, CA 94531 849000 5 3 3360 252.68 9890 sqft SINGLE_FAMILY 3524 Rio Grande Dr, Antioch, CA 94509 569999 3 2 1245 457.83 6969.6 sqft SINGLE_FAMILY 2873 2339 Shelbourne Way, Antioch, CA 94531 675000 4 3 2052 328.95 6534 sqft SINGLE_FAMILY 3646 3136 Persimmon St, Antioch, CA 94509 549000 3 2 1058 518.9 3049.2 sqft SINGLE_FAMILY 2836 2370 Peachtree Cir, Antioch, CA 94509 699000 4 3 1863 375.2 7840.8 sqft SINGLE_FAMILY 2950 2805 D St, Antioch, CA 94509 535000 3 1 1115 479.82 5009.4 sqft SINGLE_FAMILY 549300 2664 1220 W 7th St, Antioch, CA 94509 439000 3 1 1053 416.9 5001 sqft SINGLE_FAMILY 439700 2371 408 W 10th St, Antioch, CA 94509 448000 2 1 1050 426.67 4996.332 sqft SINGLE_FAMILY 2348 E57
3305 Bluejay Dr, Antioch, CA 94509 609000 3 2 1608 378.73 8712 sqft SINGLE_FAMILY 3294 4456 Deerfield Dr, Antioch, CA 94531 699000 4 3 2560 273.05 6098.4 sqft SINGLE_FAMILY 3409 5112 Paddock Ct, Antioch, CA 94531 699000 3 3 1797 388.98 6299 sqft SINGLE_FAMILY 681500 3360 2834 Bellflower Dr, Antioch, CA 94531 759000 4 3 2288 331.73 7104 sqft SINGLE_FAMILY 766800 3268 1305 W 7th St, Antioch, CA 94509 495000 2 2 1504 329.12 5001 sqft SINGLE_FAMILY 479600 2723 1216 W 7th St, Antioch, CA 94509 434000 3 1 1053 412.16 5001 sqft SINGLE_FAMILY 435600 2371 4131 Mattole Rd, Antioch, CA 94531 649000 4 3 2085 311.27 4791.6 sqft SINGLE_FAMILY 3389 5342 Frisanco Way, Antioch, CA 94531 760000 4 2 2031 374.2 5227.2 sqft SINGLE_FAMILY 768200 3561 109 W 15th St, Antioch, CA 94509 525000 3 2 1621 323.87 5227.2 sqft SINGLE_FAMILY 3427 3284 Madrone St, Antioch, CA 94509 495000 3 2 1124 440.39 3920.4 sqft SINGLE_FAMILY 2894 5188 Judsonville Dr, Antioch, CA 94531 1199900 4 3 3477 345.1 0.312902 acres SINGLE_FAMILY 1159400 4645 1232 Hillcrest Ave, Antioch, CA 94509 525000 3 2 1269 413.71 5662.8 sqft SINGLE_FAMILY 573600 2850 4618 Imperial St, Antioch, CA 94531 760000 4 3 3002 253.16 0.41 acres SINGLE_FAMILY 799800 3881 1821 Mount Silliman Way, Antioch, CA 94531 649900 4 3 1869 347.73 4500 sqft SINGLE_FAMILY 649200 3124 12 Beede Way, Antioch, CA 94509 769000 4 3 3732 206.06 0.25 acres SINGLE_FAMILY 4877 5210 Primrose Ct, Antioch, CA 94531 619000 3 3 1662 372.44 4791.6 sqft SINGLE_FAMILY 3429 1929 Johnson Dr, Antioch, CA 94509 595000 3 2 1419 419.31 5388.372 sqft SINGLE_FAMILY 2879 3366 S Francisco Way, Antioch, CA 94509 599000 3 2 1415 423.32 7920 sqft SINGLE_FAMILY 579600 3053 5341 McDowell Valley Ln, Antioch, CA 94531 740000 3 3 2213 334.39 3920.4 sqft SINGLE_FAMILY 3542 826 Gloucester St, Antioch, CA 94509 680000 4 3 2075 327.71 7840.8 sqft SINGLE_FAMILY 3528 2825 Bonita Ave, Antioch, CA 94509 519900 3 2 1100 472.64 5227.2 sqft SINGLE_FAMILY 2659 5025 Woodmont Way, Antioch, CA 94531 730000 4 3 2189 333.49 5245 sqft SINGLE_FAMILY 4584 Sand Dune Pl, Antioch, CA 94531 692990 4 3 2045 338.87 3050 sqft SINGLE_FAMILY 692600 3774 5109 Paddock Ct, Antioch, CA 94531 725000 5 3 2216 327.17 6098.4 sqft SINGLE_FAMILY 3494 2829 Longview Rd, Antioch, CA 94509 640000 3 2 1623 394.33 10454.4 sqft SINGLE_FAMILY 3173 5129 Rodeo Ct, Antioch, CA 94531 699500 4 3 2114 330.89 4791.6 sqft SINGLE_FAMILY 3746 2093 Catalpa Way, Antioch, CA 94509 762000 5 3 3392 224.65 5096.52 sqft SINGLE_FAMILY 4085 Homes Available Soon, Park Ridge Crest NaN SINGLE_FAMILY 3654 5542 Hazelbrook Ct, Antioch, CA 94531 889900 6 4 3146 282.87 9148 sqft SINGLE_FAMILY 861000 3914 5533 Sierra Trail Way, Antioch, CA 94531 869000 5 4 3529 246.25 5105.232 sqft SINGLE_FAMILY 847500 4520 1304 W 9th St, Antioch, CA 94509 499000 3 1 1380 361.59 5000.688 sqft SINGLE_FAMILY 486300 2356 2921 Honeysuckle Cir, Antioch, CA 94531 629900 4 2 1793 351.31 7475 sqft SINGLE_FAMILY 3109 5541 Sierra Trail Way, Antioch, CA 94531 899000 5 4 3529 254.75 6096 sqft SINGLE_FAMILY 883500 4537 3576 Country Side Way, Antioch, CA 94509 785000 4 3 2057 381.62 8276.4 sqft SINGLE_FAMILY 3874 3505 Davi Pl, Antioch, CA 94509 689000 3 3 2278 302.46 6098.4 sqft SINGLE_FAMILY 3413 3582 Mallard Way, Antioch, CA 94509 972950 5 3 3620 268.77 0.354109 acres SINGLE_FAMILY 945200 4432 5145 Arroyo Way, Antioch, CA 94531 615000 4 3 1680 366.07 5500 sqft SINGLE_FAMILY 604000 3316 5445 Guenoc Valley Ln, Antioch, CA 94531 925000 4 3 2457 376.48 3920.4 sqft SINGLE_FAMILY 3950 2548 Bluerock Dr, Antioch, CA 94531 735888 6 3 2813 261.6 5227.2 sqft SINGLE_FAMILY 751200 3501 4597 Imperial Way, Antioch, CA 94531 799000 5 3 2698 296.15 7629 sqft SINGLE_FAMILY 784900 3823 5621 Sierra Trail Way, Antioch, CA 94531 897000 5 4 3511 255.48 5227.2 sqft SINGLE_FAMILY 4467 1018 Fitzuren Rd, Antioch, CA 94509 425000 2 1 1080 393.52 5662.8 sqft SINGLE_FAMILY 433000 2236 E58
46 E Madill St, Antioch, CA 94509 529000 4 2 1312 403.2 5662.8 sqft SINGLE_FAMILY 2739 2103 Banyan Way, Antioch, CA 94509 395000 2 1 809 488.26 3049.2 sqft SINGLE_FAMILY 2117 2016 Aspen Ct, Antioch, CA 94509 758000 5 3 2899 261.47 10454.4 sqft SINGLE_FAMILY 4324 5337 Cardinal St, Antioch, CA 94509 850317 4 3 2992 284.2 7405.2 sqft SINGLE_FAMILY 830900 4935 Ridgeview Dr, Antioch, CA 94531 635500 3 3 1514 419.75 4356 sqft SINGLE_FAMILY 4529 Pronghorn Way, Antioch, CA 94509 722000 4 3 2330 309.87 5227.2 sqft SINGLE_FAMILY 3618 5235 Caneva Ct, Antioch, CA 94531 765900 4 3 1913 400.37 6300 sqft SINGLE_FAMILY 750900 3617 5524 Shell Ridge Way, Antioch, CA 94531 899000 5 4 3529 254.75 6658 sqft SINGLE_FAMILY 877900 4545 5221 Caneva Ct, Antioch, CA 94531 707500 3 2 1448 488.6 9640 sqft SINGLE_FAMILY 689700 3156 2911 Sunflower Dr, Antioch, CA 94531 668500 3 3 1831 365.1 8125 sqft SINGLE_FAMILY 648900 3128 3026 Hickorynut St, Antioch, CA 94509 998000 5 4 3414 292.33 0.271419 acres SINGLE_FAMILY 981100 4806 2904 Buckthorn Ct, Antioch, CA 94531 650000 4 3 2183 297.76 0.339532 acres SINGLE_FAMILY 630000 3510 4512 Bridle Ct, Antioch, CA 94531 646990 3 3 1732 373.55 2802 sqft SINGLE_FAMILY 630500 3138 5333 Cardinal St, Antioch, CA 94509 759174 4 2 2098 361.86 7405.2 sqft SINGLE_FAMILY 734300 4535 Bitter St, Antioch, CA 94531 849000 4 3 2557 332.03 6543 sqft SINGLE_FAMILY 827200 2975 2704 Hyacinth Ct, Antioch, CA 94531 729000 4 3 2288 318.62 7919.208 sqft SINGLE_FAMILY 706100 3557 5231 Caneva Ct, Antioch, CA 94531 722500 3 2 1448 498.96 5250 sqft SINGLE_FAMILY 705700 3117 208 Railroad Ave, Antioch, CA 94509 1199000 1 1 5227.2 sqft SINGLE_FAMILY 2133 211 W 20th St, Antioch, CA 94509 1199000 3 1 5227.2 sqft SINGLE_FAMILY 1139400 2246 4641 Ranch Point Way, Antioch, CA 94531 828990 5 3 2544 325.86 5298 sqft SINGLE_FAMILY 802600 3637 2014 C St, Antioch, CA 94509 1199000 4 2 7405.2 sqft SINGLE_FAMILY 501100 2681
E59
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A PPENDIX B
A NTIOCH M ARKET S URVEY :
M ULTIF AMILY S ALES D ATA
E60
address price
be
d
bat
h sqft
pricePer
Sf
lotAre
a
lotAreaTyp
e homeType
zestimat
e
rentZestima
te
705 E St, Antioch, CA 94509 825000 7 5 4492 183.66
10018.
8 sqft
MULTI_FAMI
LY 2481
34 E 16th St, Antioch, CA 94509 524990 5 3 1312 400.14 6969.6 sqft MULTI_FAMI
LY 557300 2871
2205 L St, Antioch, CA 94509 600000 5 4 2080 288.46 5662.8 sqft MULTI_FAMI
LY 2980
1101 Klengel St, Antioch, CA
94509 724900 4 2 1680 431.49 6534 sqft
MULTI_FAMI
LY 2321
604 Texas St, Antioch, CA 94509 550000 3 2 1700 323.53 6534 sqft MULTI_FAMI
LY 561400 2014
1516 Sycamore Dr, Antioch, CA
94509 949900 8 4 3300 287.85 8712 sqft
MULTI_FAMI
LY 2386
423 E 13th St, Antioch, CA 94509
371939
5 2 1
1312
0 283.49 0.53 acres
MULTI_FAMI
LY 1842
809 W 2nd St, Antioch, CA 94509 800000 2773 288.5 6969.6 sqft MULTI_FAMI
LY 3162
201 Rossi Ave, Antioch, CA 94509 600000 1767 339.56 5662.8 sqft MULTI_FAMI
LY 2375
E61
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A PPENDIX C
A NTIOCH M ARKET S URVEY :
T OWNHOME S ALES D ATA
E62
address
zipCod
e city state price
be
d bath sqft
pricePer
Sf
lotAre
a
lotAreaTy
pe homeType
zestimat
e
rentZestima
te
3508 Stone Pl, Antioch, CA
94509 94509
Antioc
h CA
51950
0 3 3 1510 344.04
1306.
8 sqft
TOWNHOU
SE 540400 2848
6 Avila Pl, Antioch, CA 94509 94509
Antioc
h CA
39800
0 3 3 1354 293.94 871.2 sqft
TOWNHOU
SE 2875
57 Madrid Ln, Antioch, CA
94509 94509
Antioc
h CA
39900
0 3 3 1390 287.05 871.2 sqft
TOWNHOU
SE 406400 2877
2604 Nevada Ln, Antioch, CA
94509 94509
Antioc
h CA
32900
0 2 2 960 342.71 871.2 sqft
TOWNHOU
SE 336300 2277
3510 Stone Pl, Antioch, CA
94509 94509
Antioc
h CA
49900
0 3 3 1349 369.9
1306.
8 sqft
TOWNHOU
SE 2831
2601 Ithaca Ln, Antioch, CA
94509 94509
Antioc
h CA
31500
0 2 1 845 372.78 871.2 sqft
TOWNHOU
SE 2051
3507 Dameron Pl, Antioch, CA
94509 94509
Antioc
h CA
49900
0 3 3 1510 330.46
1306.
8 sqft
TOWNHOU
SE 517700 2850
4 Avila Pl, Antioch, CA 94509 94509
Antioc
h CA
37900
0 3 3 1390 272.66 1002 sqft
TOWNHOU
SE 2877
2506 Princeton Ln, Antioch,
CA 94509 94509
Antioc
h CA
34500
0 2 2 1152 299.48 960 sqft
TOWNHOU
SE 2338
2507 Georgetown Ln, Antioch,
CA 94509 94509
Antioc
h CA
35000
0 2 2 1152 303.82 871.2 sqft
TOWNHOU
SE 2316
2308 Peppertree Way APT 2,
Antioch, CA 94509 94509
Antioc
h CA
19800
0 2 1 903 219.27
13.06 8 sqft
TOWNHOU
SE 1783
E63
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A PPENDIX D
A NTIOCH M ARKET S URVEY :
M ULTIFAMILY R EN T D ATA
E64
address zipCode city state rent bed bath sqft rentPerSf homeType 3915 Delta Fair Blvd, Antioch, CA 94509 94509 Antioch CA 1699 2 1 728 2.33 APARTMENT 600-712 O St, Antioch, CA 94509 94509 Antioch CA 1895 2 1 APARTMENT 318 Lawton St, Antioch, CA 94509 94509 Antioch CA 1600 1 1 1600 1 APARTMENT 2114 Peppertree Way APT 3, Antioch, CA 94509 94509 Antioch CA 2000 2 1 903 2.21 APARTMENT 2116 Lemontree Way UNIT 3, Antioch, CA 94509 94509 Antioch CA 2200 2 1 903 2.44 APARTMENT 1300 Sycamore Dr, Antioch, CA 94509 94509 Antioch CA 1750 2 1 903 1.94 APARTMENT 516 W Tregallas Rd APT 4, Antioch, CA 94509 94509 Antioch CA 1900 2 1 APARTMENT 500 Texas St APT 7, Antioch, CA 94509 94509 Antioch CA 1795 2 1 702 2.56 APARTMENT 500-522 H St #512, Antioch, CA 94509 94509 Antioch CA 1695 1 1 900 1.88 APARTMENT 912 Minaker Dr #2, Antioch, CA 94509 94509 Antioch CA 2250 2 1.5 1116 2.02 APARTMENT 1104 W 9th St #A, Antioch, CA 94509 94509 Antioch CA 1199 1 250 4.8 APARTMENT 610 W 2nd St, Antioch, CA 94509 94509 Antioch CA 2495 2 1 1400 1.78 APARTMENT 320 W 20th St APT 10, Antioch, CA 94509 94509 Antioch CA 1675 2 1 APARTMENT 723 W 4th St UNIT 1, Antioch, CA 94509 94509 Antioch CA 2150 1 1 715 3.01 APARTMENT 4756 Matterhorn Way #A, Antioch, CA 94531 94531 Antioch CA 2000 1 1 450 4.44 APARTMENT 52 E 16th St APT 6, Antioch, CA 94509 94509 Antioch CA 2250 2 1 750 3 APARTMENT 1512 Sycamore Dr APT 2, Antioch, CA 94509 94509 Antioch CA 2000 2 1 850 2.35 APARTMENT 2208 Lemontree Way UNIT 3, Antioch, CA 94509 94509 Antioch CA 1998 2 1 903 2.21 APARTMENT 618 W 7th St #5, Antioch, CA 94509 94509 Antioch CA 1800 1 1 650 2.77 APARTMENT 113 I St #2, Antioch, CA 94509 94509 Antioch CA 1300 1 450 2.89 APARTMENT 918 Marie Ave #B, Antioch, CA 94509 94509 Antioch CA 1700 1 1 600 2.83 APARTMENT 31 Sunset Dr UNIT B, Antioch, CA 94509 94509 Antioch CA 2200 2 1 APARTMENT 117 E Madill St, Antioch, CA 94509 94509 Antioch CA 1650 1 APARTMENT 901 J St APT 9, Antioch, CA 94509 94509 Antioch CA 1900 2 1 800 2.38 APARTMENT 2204 Lemontree Way UNIT 4, Antioch, CA 94509 94509 Antioch CA 1895 2 1 925 2.05 APARTMENT 1116 W 5th St #I, Antioch, CA 94509 94509 Antioch CA 2450 2 1 846 2.9 APARTMENT 1414 Sycamore Dr UNIT 4, Antioch, CA 94509 94509 Antioch CA 1700 2 1 900 1.89 APARTMENT 2200 Lemontree Way UNIT 4, Antioch, CA 94509 94509 Antioch CA 1900 2 1 925 2.05 APARTMENT 3609 Fairview Dr #4, Antioch, CA 94509 94509 Antioch CA 1795 2 1 900 1.99 APARTMENT E65
515 W 9th St #B, Antioch, CA 94509 94509 Antioch CA 1675 1 1 500 3.35 MULTI_FAMILY 137 Wilbur Ave APT 9, Antioch, CA 94509 94509 Antioch CA 2100 2 1 910 2.31 APARTMENT 2500 Wildflower Station Pl #40, Antioch, CA
94531 94531 Antioch CA 2200 1 1 675 3.26 APARTMENT
1216 Sycamore Dr APT 2, Antioch, CA 94509 94509 Antioch CA 1695 2 1 925 1.83 CONDO 923 W 9th St, Antioch, CA 94509 94509 Antioch CA 2250 4 4 2708 0.83 APARTMENT 2110 Peppertree Way APT 1, Antioch, CA 94509 94509 Antioch CA 1700 2 1 975 1.74 APARTMENT 1910 Cavallo Rd APT D, Antioch, CA 94509 94509 Antioch CA 1750 2 1 700 2.5 APARTMENT 234 Crest St #3, Antioch, CA 94509 94509 Antioch CA 1845 2 1 800 2.31 APARTMENT 2308 Spanos St APT 4, Antioch, CA 94509 94509 Antioch CA 1700 2 1 825 2.06 APARTMENT
E66
MEMORANDUM
DATE January 21, 2026
TO Zoe Merideth, Planning Manager; David Storer, Community Development Consultant City of Antioch, Planning Division
FROM Greg Goodfellow, Associate Principal
Steve Gunnells, Chief Economist
SUBJECT City of Antioch Inclusionary Housing Ordinance In-Lieu Fee Recommendation
SUMMARY
This memo recommends the amount for an in -lieu fee for the inclusionary housing requirement. It recommends an in-lieu fee in the amount of $202,500.00 per required, unconstructed inclusionary unit.
This memo includes the following sections and components:
In-Lieu Fee Analysis
1. Background
2. Methodology
3. Affordable Housing Gap Calculation
4. Fee Calculation
Recommendation
1. Resolution Establishing the Amount of the In-Lieu Fee Appendix:
Contra Costa County affordable housing projects awarded state tax credits in 2023 through 2025 ATTACHMENT "F"
F1
January 21, 2026 | Page 2
In-Lie Fee Analysis
1. Background
The City of Antioch is considering amending its Zoning Code to include an Inclusionary Housing Ordinance (IHO). The overall objectives of the IHO are to:
» Enhance the public welfare by increasing the supply of affordable housing. » Ensure future residential development is consistent with State, regional and local housing policies. » Generates sufficient affordable housing for the City to meet its obligations under the State Regional Housing Needs Assessment (RHNA).
The City is required to allow at least one method of compliance as an alternative to the developer providing the required number of affordable units on the same site as a new residential development project. The recommended alternative method of compliance is the option to pay a fee in -lieu of constructing inclusionary housing units.
The purpose of this memo is to provide a methodology for calculating the in-lieu fee and to recommend the amount of the fee.
2. Methodology
A. General Approach
The general approach is to determine the typical cost for the City to have an affordable housing unit built. The in -lieu fee would then be set at a level that would generate sufficient revenue to have the required number of affordable units built.
B. Example
A straightforward hypothetical example is a residential subdivision with 100 lots. The inclusionary housing provisions would require that 15 of the units (15 percent of the total) be below -market- rate units (BMR) that are restricted to low -income households. The remaining 85 units would be sold at market rate (MR) prices
1. If, instead of a mixed -income development project (i.e., 15 BMR and 85 MR units), the developer chose the alternative of paying an in-lieu fee, the proposed project would have 100 MR units, and
1 Under the state’s Density Bonus Law, a developer providing affordable housing units as part of a mixed-income residential development could also be eligible for a density bonus, which would permit the developer to construct additional market rate units. However, a developer choosing to pay a fee in- lieu of constructing affordable units is not eligible for a density bonus. For simplicity, the issue of density bonus units is omitted because it does not affect the in-lieu fee.
F2
January 21, 2026 | Page 3
the total amount of in -lieu fees paid should be sufficient to have 15 affordable housing units constructed elsewhere in Antioch.
If that cost were $200,000 per affordable unit, then the in-lieu fee for the project should be at least $3 million (15 BMR units X $200,000 per unit = $3 million).
C. Affordable Housing Development Finance
Most affordable housing is constructed and operated by specialized affordable housing developers.
They have expertise in accessing a variety of funding sources, and they have expertise in qualifying income-eligible households. The recommended fee derived in subsequent sections is based on five Contra Costa County affordable housing projects that the state awarded tax credits in 2023, 2024, and 2025. Details on these projects are provided in the Appendix in Tables A-1 through A-4.
There are three important types of funding for the permanent financing of affordable housing developments:
1. Low-Income Housing Tax Credits (LIHTC). These are tax credits that the federal government annually provides to states to distribute to affordable housing development projects. They are the primary source of permanent financing for affordable housing developments. In California, the Tax Credit Allocation Committee awards tax credits on a competitive basis annually. Affordable housing developers have indicated that it is not uncommon for an application to take up to three rounds before being successful. Howev er, they have also indicated that they are rather confident in their ability to eventually receive tax credit funding for projects.
2 As shown in Table A-4, in the five Contra Costa County affordable housing projects, tax credits accounted for 36 percent to 43 percent of the total permanent financing.
2. Bank financing. Affordable housing projects also rely on conventional bank financing for permanent funding, just as market rate developers do. Residents of affordable housing projects pay rent—albeit a reduced rent that is affordable. These rent payments cover the operation and maintenance expenses. The amount of rent in excess of operation and maintenance costs is used to repay the conventional bank financing. In addition, a portion of tenant rents are used to repay the developer, who often defers their fee from the time of construction to be paid back over time.
3. Additional funding sources. Finally, there various other sources of funding. These include deferred development fees, charitable giving, various construction tax credits and others.
2 There are two types of LIHTC, commonly referred to as 4 percent credits and 9 percent credits.
The affordable housing developers interviewed for this report say that the 9 percent credits are very challenging to get but that they are confident that they can obtain 4 percent tax credits for affordable housing projects. References to tax credits in this report refer to the 4 percent tax credits, and the permanent financing data in Table A-4 are for 4 percent tax credits.
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January 21, 2026 | Page 4
Successful affordable housing development often relies on piecing together a variety of other funding sources to fully fund a development. Part of the challenge is timing these other sources to coincide with the awarding of tax credit funding.
D. Fee Basis
Affordable housing developers have indicated their confidence in obtaining tax credits and conventional bank financing. If funding from in- lieu fees can make up the difference from all the other funding sources they usually piece together, they should be a ble to develop affordable housing in Antioch. Thus, the basis for the in-lieu fee is the gap between the development cost and the tax credit funds plus bank financing. This amount is calculated below.
3. Affordable Housing Gap Calculation
A. Average Development Cost
Table A-2 in the Appendix provides a breakdown of the development costs for each of the five Contra Costa County affordable housing projects. Generally, construction costs for affordable housing projects can be expected to b e similar across Contra Costa County jurisdictions, with the exception of the cost to acquire land.
Table 1, below, provides the total development cost for the five Contra Costa County affordable housing projects combined, the total number of affordable dwelling units across the five projects, and the resulting weighted average development cost per affordable residential unit. The data indicated that, on average, each unit of affordable housing costs $882,000 plus the cost to acquire land.
Table 1: Weighted Average Development Cost per Unit for Five Recent Affordable Housing Projects; Contra Costa County; 2024 and 2025 Total Development Cost $332,000,000
Total Number of Affordable Units 376
Average Development Cost per Unit $882,000
Source: PlaceWorks 2025, using cost data from the CA Tax Credit Allocation .
B. Average Project Financing
Table A -4 in the Appendix provides a breakdown of the funding sources used for permanent financing of the five Contra Costa County affordable housing projects. Table 2, below, shows the total permanent bank financing and the total federal tax credit equity as well as the weighted average per unit. The data indicate that, on average, the typical affordable housing unit is funded with $134,400 in conventional bank financing and $342,000 in federal tax credits.
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January 21, 2026 | Page 5
Table 2: Weighted Average Bank Financing and Federal Tax Equity per Unit for Five Affordable Housing Projects; Contra Costa County; 2023 through 2025
Total Number of Units 376
Total Permanent Bank Financing1 $50,500,000
Average Bank Financing per Unit $134,400
- Percentage of Average Cost per Unit 15.23%
Total 4% Federal Tax Credit Equity $128,500,000
Average Tax Credit Equity per Unit $342,000
- Percentage of Average Cost per Unit 38.75%
Source: PlaceWorks 2025, using funding data from the CA Tax Credit Allocation Committee. 1Total permanent bank financing also includes any deferred developer fee and general partner equity contribution.
D. Affordable Housing Financing Gap, Countywide
The affordable housing financing gap —which is the amount that the inclusionary housing in -lieu fee is intended to cover—is the difference between the development cost and the two types of permanent financing that affordable housing developers can reliably access. As shown in Table 3, the analysis estimates the average affordable housing financing gap per unit in Contra Costa County at $406,000. This is 46.02% of the average total cost per unit.
Table 3: Average Affordable Housing Financing Gap per Unit for Recent Five Affordable Housing Projects; Contra Costa County; 2023 through 2025 Construction Cost per Unit $882,000
Less Bank Financing -$134,400
Less Federal 4% Tax Credit Equity -$342,000
Financing Gap per Unit $406,000
- Percentage of Average Cost per Unit 46.02%
Source: PlaceWorks 2025, using cost and funding data from the CA Tax Credit Allocation Committee .
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January 21, 2026 | Page 6
E. Affordable Housing Financing Gap, Antioch
The estimated cost to develop a 100 percent affordable housing project in Antioch is based on a theoretical multifamily housing development. The development program is presented in Table 4. The cost estimate is based on an assumed affordable housing development project with 83 multifamily apartments (82 affordable units and 1 manager’s unit) in three story buildings on a 4.1-acre parcel. The cost estimate also reflects that the development project would provide one surface lot parking space per unit.
Table 4: Development Program for a Conceptual Affordable Housing Development; Antioch
Parcel Size (ac.) 4.1
Total Number of Units 83
- Affordable units 82
- Manager's unit 1
Density (du/acre) 20.2
Build Height (stories) 3
Gross Floor Area (sq. ft.) 104,900
Surface Parking Spaces 83
Source: PlaceWorks, 2025, based on a review of recent and entitled development projects in Antioch.
For the conceptual affordable housing development described above, the estimated development costs are provided in Table 5. The estimate includes $2.1 million for land acquisition, $21.4 million for hard construction costs, $ 9.1 million for soft costs, and $3. 4 million for financing costs. The total development cost, $36.1 million, equates to $440,000 per affordable dwelling unit.
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January 21, 2026 | Page 7
Table 5: Estimated Development Costs for a Conceptual Affordable Housing Development; Antioch; 2025
Land Acquisition Cost $2,130,000
Hard Costs
Site Work $3,570,000
Construction 17,840,000
Hard Cost Subtotal $21,400,000
Soft Costs
Design, entitlement, and other soft costs @25.0% $5,350,000 Contingency @10.0% $2,140,000
Impact Fees $1,639,000
Soft costs subtotal $9,130,000
Development cost (before financing) $32,700,000
Financing cost $3,410,000
Total development cost $36,100,000
- per affordable housing unit $440,000
Source: PlaceWorks, 2025.
Notes to Table 5:
1. The estimated property value is a PlaceWorks estimate based on our analysis of sales data, asking prices, and residual land values.
2. Building construction costs are calculated on a per square foot basis for finished floor area and a separate square foot basis for garages. The per square foot costs are taken from Craftsman Book Company’s 2026 National Building Cost Manual, with the source’s recommended adjustments for local cost differential. As noted in the source, the per square foot cost estimates include all construction costs: labor, materials, equipment, plans, building permit, supervision, overhead, and profit.
3. Development impact fees are calculated as $18,561 per dwelling unit plus $5.17 per square foot (for school district fees).
Finally, the affordable housing financing gap, defined as a percentage of development cost for recent projects in Table 3, is applied to the estimated cost for new affordable housing construction in Antioch.
With an estimated development cost of $ 440,000 per affordable dwelling unit and an expected financing gap of 46.02 %, the City would need to collect $ 202,500 through an in -lieu fee for each affordable inclusionary unit that a market rate developer opts to forego building.
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January 21, 2026 | Page 8
Table 6: Estimated Financing Gap per Unit for Affordable Housing in Antioch; 2025
Development Cost per Unit 440,000
Financing Gap Percentage (of costs) 46.02%
Financing Gap for Antioch Affordable Housing 202,500
Source: PlaceWorks, 2025.
4. In-Lieu Fee Calculation and Recommendation
The city should adopt a fee of $202,500 per affordable housing unit that is required under the inclusionary housing provisions in the Zoning Ordinance when the developer chooses to forego construction of those units. The city could also consider allowing developers the flexibility to provide some affordable housing units, which would earn a density bonus, and to pay the in-lieu on any required inclusionary units that are not provided, which would not be eligible for a density bonus.
On July 1 of each calendar year, the amount of the in-lieu fee should be increased based on the increase in the US Bureau of Labor Statistics ’ Chained Consumer Price Index for all Urban Consumers, not seasonally adjusted (C-CPI-U).
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Appendix:
Contra Costa County affordable housing projects awarded state tax credits in 2023, 2024 and 2025
Table A-1: Project Descriptions for Recent Affordable Housing Projects; Contra Costa County; 2023 through 2025 Project Number CA-24-649 CA-23-603 CA-24-681 CA-25-404 CA-25-483 Project Name Civic Crossing Mayfair Affordable Walnut Apartments TBV Villas at Renaissance
El Cerrito Plaza -
Parcel A South
Site Address 699 Ygnacio Valley
Road
11690 San Pablo
Avenue 3020 Fostoria Way
between San
Joaquin Street,
Modoc Avenue, and
Kings Place
515 Richmond Street
Walnut Creek, CA
94596 El Cerrito, CA 94530 Danville, CA 94526 Richmond, CA 94804 El Cerrito, CA 94530
PROJECT DESCRIPTION
# of Residential Buildings 1 1 2 2 1
# of Units 93 69 44 105 70
# of Tax Credit Units 92 68 43 104 69
Housing Type Large Family Large Family Large Family Large Family Large Family Unit Mix
SRO/Studio Units 24 15 0 4 0
1-Bedroom 21 18 20 7 30
2-Bedroom 24 18 12 37 20
3-Bedroom 24 18 12 53 20
4-Bedroom 0 0 0 4 0
Total 93 69 44 105 70
Source: PlaceWorks 2025, using data from the CA Tax Credit Allocation Committee.
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January 21, 2026 | Page 10
Table A-2: Project Cost Summary for Recent Affordable Housing Projects; Contra Costa County; 2023 through 2025 Project Number CA-24-649 CA-23-603 CA-24-681 CA-25-404 CA-25-483 Project Name Civic Crossing Mayfair Affordable Walnut Apartments TBV Villas at Renaissance El Cerrito Plaza - Parcel A South
Site Address 699 Ygnacio Valley
Road 11690 San Pablo Avenue 3020 Fostoria Way
San Joaquin Street,
Modoc Avenue, and Kings
Place
515 Richmond Street
Walnut Creek, CA El Cerrito, CA Danville, CA Richmond, CA El Cerrito, CA
TOTAL PROJECT COST
Land and Acquisition $9,306,567 2,113,536 $3,489,000 $5,876,713 $105,000 Construction Costs $52,098,375 $42,753,070 $11,964,020 $43,933,791 $47,083,668 Rehabilitation Costs 0 0 0 $0 $0
Construction Contingency $3,880,142 $2,198,862 $700,000 $3,509,047 $2,343,133 Soft Cost Contingency $589,140 $505,040 $370,000 $304,093 $467,472 Relocation 0 0 0 $0 $0
Architectural/Engineering $2,854,254 $2,214,298 $940,000 $2,644,408 $3,432,585 Const. Interest, Permanent
Financing $9,824,643 $10,275,496 $1,738,900 $5,931,447 $5,396,173 Legal Fees $138,190 $184,628 $140,000 $141,412 $320,000 Reserves $1,395,151 $424,796 $362,076 $645,169 $540,359 Other Costs $5,035,933 $3,709,821 $1,601,497 $4,830,344 $5,845,220 Developer Fee $3,500,000 $4,500,000 $2,590,917 $8,000,000 $4,078,800 Commercial Costs $1,808,872 0 0 $2,989,993 $0
Total $90,431,267 $68,879,547 $23,896,410 $78,806,417 $69,612,410
PER AFFORDABLE UNIT COSTS
Construction Cost per Sq. Ft. $825 $846 $303 $323 $729 Per Unit Cost $950,011 $998,254 $543,100 $717,713 $994,463 True Cash Per Unit Costs $936,356 $964,921 $541,034 $672,176 $989,106 Source: PlaceWorks 2025, using data from the CA Tax Credit Allocation Committee.
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January 21, 2026 | Page 11
Table A-3: Construction Finance Summary for Recent Affordable Housing Projects; Contra Costa County; 2023 through 2025 Project Number CA-24-649 CA-23-603 CA-24-681 CA-25-404 CA-25-483 Project Name Civic Crossing Mayfair Affordable Walnut
Apartments
TBV Villas at
Renaissance
El Cerrito Plaza -
Parcel A South
Site Address 699 Ygnacio Valley Road 11690 San Pablo
Avenue
3020 Fostoria
Way
between San
Joaquin Street,
Modoc Avenue,
and Kings Place
515 Richmond Street
Walnut Creek, CA 94596 El Cerrito, CA 94530 Danville, CA 94526
Richmond, CA
94804 El Cerrito, CA 94530
TOTAL PROJECT COST
Bank Financing $14,584,359 $10,560,458 $0 $19,462,570 $9,289,713 Bank Financing (Tax Exempt) $46,881,118 $35,141,577 $12,750,000 $39,172,547 $35,700,000 City $10,500,000 $1,886,105 $0 $0 $970,000
County Housing $6,833,819 $6,913,642 $0 $0 $5,376,423
Deferred Costs 0 $2,300,000 $362,076 $5,000,000 $1,001,837 State $3,889,406 $4,220,000 $0 $0 $9,750,000
Other $100 $500,000 $4,200,000 $6,250,000 $2,400,000
Other 0 $322,652 $3,079,900 $3,700,000 $2,597,220
Other 0 $0 $2,590,917 $100 $100
Tax Credit Equity $3,659,814 $2,732,027 $913,517 $2,894,032 $2,527,117 Total $86,348,616 $64,576,461 $23,896,410 $76,479,249 $67,085,293 Source: PlaceWorks 2025, using data from the CA Tax Credit Allocation Committee.
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January 21, 2026 | Page 12
Table A-4: Permanent Finance Summary for Recent Affordable Housing Projects; Contra Costa County; 2023 through 2025 Project Number CA-24-649 CA-23-603 CA-24-681 CA-25-404 CA-25-483 Project Name Civic Crossing Mayfair Affordable Walnut
Apartments
TBV Villas at
Renaissance
El Cerrito Plaza -
Parcel A South
Site Address 699 Ygnacio Valley Road 11690 San Pablo
Avenue
3020
Fostoria Way
between San
Joaquin Street,
Modoc Avenue,
and Kings Place
515 Richmond
Street
Walnut Creek, CA 94596 El Cerrito, CA 94530 Danville, CA 94526
Richmond, CA
94804 El Cerrito, CA 94530
TOTAL PROJECT COST
Bank Financing $1,209,000 $5,962,000 $7,850,000 $22,459,000 $3,977,000 City $10,500,000 $1,886,105 $0 $0 $970,000
County Housing $6,833,819 $6,963,642 $0 $0
County Other 0 $0 $0 $7,750,000 $5,376,423
State $24,793,697 $17,222,372 $0 $0 $24,598,570
State $9,414,110 $4,197,500 $0 $0 $6,300,000
Deferred Developer Fee $1,299,900 $2,300,000 $90,917 $5,000,000 $375,000 Tax Credit Equity $36,380,641 $29,525,276 $8,675,593 $28,647,317 $25,271,169 General Partner Equity and
Contribution $100 $0 $0 $100 $100
Other 0 $500,000 $4,200,000 $6,250,000 $2,400,000
Other 0 $322,652 $3,079,900 $3,700,000 $344,148
Other $5,000,000
Total $90,431,267 $68,879,547 $23,896,410 $78,806,417 $69,612,410 - Tax Credit Equity % of Total 40% 43% 36% 36% 36%
Source: PlaceWorks 2025, using data from the CA Tax Credit Allocation Committee.
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In-Lieu Fee Information for Contra Costa County
Jurisdiction Population In-Lieu Fee Information Example Fee for 1,000 Sq Ft Unit Antioch 117,000 No IHO
Brentwood 65,000 In-lieu only for 5-9 units and done project by project Clayton 10800 Project by project
Concord 123,000
Ownership: $20.00/sq ft
Rental $15.00/sq ft
Ownership: $20,000
Rental: $15,000
Danville 43,000 Project by project
El Cerrito 26,000
Ownership: $24.00/sq ft
Rental: $19.00/sq ft
Ownership: $24,000
Rental: $19,000
Hercules 26,000 Suspended ordinance around 2012 at dissolution of RDA Still in Municipal Code
Lafayette 25,000 No fee established
Martinez 37,000 No IHO
Moraga
17,000
Fee is based on number of units, and whether project is for-sale or rental 6 unit project - 13.00/SF for-sale and $8.30/SF for rental 10 or more units* - $39.00/SF for sale and $25.00/SF for rental.
*Rates for projects with ten or more units are prorated based on the portion of the inclusionary unit obligation to be satisfied with in-lieu fees. Proration is calculated by multiplying the applicable per square rate by a fraction, with the numerator of such fraction equal to the number of units for which in-lieu fees are proposed to be paid, and the denominator of such fraction equal to the total number of inclusionary units that are required.
6 unit project:
$13,000 for-sale
$8,300 rental
10 unit with all in-lieu fees:
$39,000 for-sale
$25,000 rental
Oakley 46,000 No IHO
Orinda 19,000 No IHO
Pinole 18,000 Project by project, if not all onsite
ATTACHMENT "G"
G1
In-Lieu Fee Information for Contra Costa County
J
urisdiction Population In-Lieu Fee Information Exa
mple Fee for 1,000 Sq Ft Unit
Type of Residential Project In-lieu Fee
Fees ranging from $34,200 to
$288,900, see column to the left
Low Density Owner Project: Mod Income: $34,200
VL Income: $288,900
Pittsburg 76,000 Owner Project Low Income: $146,600
VL Income: $206,500
Rental Projects
$154,00.00 (multiplied by fraction, less than
0.5, of inclusionary unit required)
Pleasant Hill 34,000 $271,350 per unit not built $271,350 per unit not built Richmond 114,000
Residential development projects proposed south of I-580 and on the Point San Pable Peninsula.
Rental Residential Development - $12 per square foot
Ownership Residential Development – May not pay in-lieu fee $12,000 for rental projects in
specific geographic area
San Pablo 34,000 No IHO
San Ramon 83,000
Less than 10 units $15.16/sq ft.
On-site required for projects greater than 10 units
Less than 10 units: $15,160
176,000 Applies to projects with 5 to 125 units only
Unincorp.
For Sale Housing In-Lieu Fee: $6,600.06 per market rate unit.
Fee equals 12% of total number of units in the development times $0 plus 3% of total number of units in the development times $220,002; i.e., (0.12 x total units) x ($0) + (0.03 x total units) x ($220,002).
For sale: $6,600.06
Rental: $24,200.55
Rental Housing In-Lieu Fee: $24,200.55 per market rate unit.
Fee equals 12% of total number of units in the development times $130,350 plus 3% of total number of units in the development times $285,285; i.e., [(0.12 x total units) x ($2,376) + (0.03 x total units) x ($5,184)]*(55 years).
Walnut Creek 70,000 $26.04/sq ft All units: $26,040
G2
January 29, 2026
City of Antioch
Planning Commission w ®
Webber, Jones, Perez, Riley, Suman, Spijker
200 H Street
Antioch, CA 94509
Via: Email to City Clerk
Dear Planning Commission Members,
I write in opposition to Agenda Item 6 for the Planning Commission meeting scheduled for February 4, 2026. Antioch should not adopt policies that make the production of much-needed housing within the City more difficult or more costly. I respectfully urge the Commission to vote no on the proposed inclusionary housing ordinance.
Attached as Exhibit I is my correspondence to the Mayor and City Council dated September 15, 2025. I will not restate those arguments here but request that they be incorporated by reference.
Please be advised that significant California case law exists, most notably Sheetz v. County of El Dorado, which substantially limits the ability of local governments to impose conditions on development permits. This precedent directly impacts the legality of mandatory inclusionary housing requirements.
Further, the matter of Wesley Yu v. City of East Palo Alto, relying on Sheetz, was resolved in favor of Mr. Yu. As a result, the City of East Palo Alto significantly modified its inclusionary housing ordinance. While the amount of compensation paid to Mr. Yu has not been publicly disclosed, the outcome underscores the legal risks associated with such ordinances.
Contrary to any assertion by City staff, there is no requirement under California law that a municipality or county adopt an inclusionary housing ordinance. The City of Antioch already satisfies the conditions necessary to remain eligible for housing and infrastructure funding from other agencies.
In conclusion, an inclusionary housing ordinance is unnecessary, unsupported by current case law, and of questionable constitutional validity. Adoption of this ordinance would expose the City to avoidable legal and financial risk.
I respectfully request a unanimous no vote on Agenda Item 6. Thank you for your consideration.
g) Each RE/MAX office 1s independently owned and operated. @ ATTACHMENT "H"
H1
Exhibit I
H2
mark markcynthia.com
From:
Sent:
To:
Cc:
Subject:
mark
Monday, September 15, 2025 2:07 PM
[email protected]
[email protected]; [email protected]; [email protected]; [email protected];
FW: City Council Agenda 9/16/2025
Subject: Opposition to the lnclusionary Housing Ordinance - Please Table the Matter Dear Mayor and Council Members,
Regrettably, I will not be able to attend the continued study session on the possible adoption of the lnclusionary Housing Ordinance (IHO). I will refrain from repeating points I've previously made, and instead focus on reiterating and expanding my core concerns. I speak for the silent majority of Antioch those who may not wear matching T-shirts, don't seek handouts, and work hard for what we earn and achieve.
This ordinance should be tabled until the resolution of the ongoing litigation involving the City of East Palo Alto. A copy of the federal filing has already been sent to each of you. Moving forward with the IHO at this time is premature and risks exposing the City of Antioch to similar legal challenges, which could place our city in a precarious and costly position.
At its core, lnclusionary Housing is a form of municipal coercion or extortion. Requiring developers to either pay fees or discount their products to support social policies is fundamentally flawed. We need more housing-not more barriers to building it. This ordinance disincentivizes development at a time when we should be encouraging it.
Now, let's address some of the arguments put forth by proponents:
Gentrification.
Critics claim gentrification is harmful. But by definition, gentrification involves the revitalization of neglected areas-improving housing, increasing property values, and expanding the tax base. From a broader community perspective, these outcomes are not negative-they're signs of progress. Yes, change can be uncomfortable and sometimes results in displacement, but change is the only constant in life. We can manage it-but we shouldn't fear it.
"Housing is a Human Right."
This is a popular slogan, but where is it substantiated? It's not in the Bible (Old or New Testament), not in the Quran, not in the Declaration of Independence, and not in either the U.S. or California Constitution. It is, simply put, a manufactured argument-emotionally compelling, perhaps, but not grounded in legal or historical precedent.
What we do agree upon in this country is the right to Life, Liberty, and the Pursuit of Happiness-not outcomes, but opportunities. We agree on the rule of law, equal justice, and individual responsibility. 1 H3
Underlying Ideology.
Though rarely stated outright, the lnclusionary Housing Ordinance is built on a fundamentally socialist ideology-one that demands others pay the price for systemic outcomes beyond their control. But socialism, like Marxism, is a failed model. It doesn't uplift communities; it burdens them and eventually collapses under its own weight.
If life hasn't turned out the way we want, the answer isn't to demand others pay the price. The answer is to adapt, to work harder, to upskill, to disengage from distractions-and to pursue our own happiness through self-reliance.
In closing, I urge you to table this ordinance. It is ill-timed, legally risky, economically unwise, and ideologically misguided.
M
Mark Jordan, Principal Broker RE/MAX Preferred Properties [email protected]/www.markcynthia.com
Main Office: , Antioch, CA 94509
Phone: / Cell: / FAX:
DRE#: / NMLS#:
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* Confidentiality Notice *
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This message is intended solely for the use of the addressee(s) and is intended to be privileged and confidential within the Broker client privilege. If you have received this message in error, please immediately notify the sender and delete all copies of this email message along with all attachments. Thank you.
From: City of Antioch
Sent: Monday, September 15, 2025 12:32 PM
To: mark
Subject: City Council Agenda
City of Antioch
2 H4
The Antioch City Council Special Meeting Agenda for the September 16, 2025 meeting is now available.
Council Meeting Agenda
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3 H5
Outlook
Coalition Comments on Item 6-1: lnclusionary Housing
From Joey Flegel-Mishlove
Date Tue 2/3/2026 10:55 AM
To Planning Division <[email protected]>
Cc Cortney Jones <[email protected]>; Jennifer Perez <[email protected]>; Kevin Riley <[email protected]>; William Spijker <[email protected]>; Ramesh Suman <[email protected]>; Seth Webber Corcoran <[email protected]>
@ 1 attachment (2 MB)
Antioch IHO Coalition Comments on Item 6-1, Feb. 3, 2026.pdf; CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.
Dear Antioch Planning Commission,
Attached please find a letter of support for Antioch's proposed lnclusionary Housing Ordinance signed by a coalition of community organizations. While our primary comment is support for an IHO, we also make two slight recommendations for strengthening the draft ordinance:
• Clarifying the ordinance's affordability requirements by setting a specific percentage of homes constructed under the ordinance that must be affordable to Extremely Low-Income residents • Setting an overall inclusionary rate of 20%
The organizations submitting this letter are:
California Center for Movement Legal Services; Contra Costa Budget Justice Coalition; East Bay Alliance for a Sustainable Economy; East Bay Housing Organizations; Ensuring Opportunity Campaign to End Poverty in Contra Costa County; Hope Solutions; Lift Up Contra Costa County; Monument Impact; Multi-Faith ACTION Coalition; Public Advocates; Rising Juntas; United Latino Voices of Contra Costa County.
Thank you,
Joey Flegel-Mishlove
Joey Flegel-Mishlove (he/him)
Senior Policy Associate
EAST BAY HOUSING ORGANIZATIONS (EBHO)
I
H6
Be a part of EBHO's movement for a just and equitable East Bay. Join or renew y_our membershiP for 2026!
Important Update: EBHO will be closed on Fridays throughout 2026. Thank you in advance for your patience. Visit us at ebho.org and follow us on Facebook, Linkedln. and lnstagram.
H7
February 1, 2026
Seth Webber, Chair
Cortney L. Jones, Vice-Chair
Jennifer Perez, Commissioner
Kevin Riley, Commissioner
Ramesh Suman, Commissioner
William Spijker, Commissioner
Re: Support for Antioch’s Inclusionary Ordinance
Dear Antioch Planning Commissioners,
The undersigned organizations write to you to share our collective support for a city-wide Inclusionary Housing Ordinance (IHO) in Antioch. We also offer two recommendations for amendments to the draft ordinance which we share in the spirit of collaboration, and with the hopes of crafting an ordinance that will best match the specific needs of the Antioch community. Our coalition includes Antioch community members most directly impacted by our region’s housing crisis, affordable housing developers, service providers, faith leaders, and policy experts, and together brings over 50 years of experience working with jurisdictions across the Bay Area in designing and implementing Inclusionary Housing Ordinances and other housing solutions. Our two recommendations for amending the IHO are: (1) Naming a specific percentage of homes constructed under the ordinance that must be affordable to Extremely Low-Income residents; and (2) Setting the IHO’s overall inclusionary rate at 20%.
We are deeply appreciative of the work Antioch’s elected leaders and staff have done so far to study the ordinance’s feasibility, gather community feedback, and create this draft ordinance. Passing an IHO in Antioch would be a major step towards a more affordable community for all Antioch residents.
We are very excited to see the ordinance moving forward and urge you to recommend the ordinance’s passage to the City Council.
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Why do we support an IHO?
An Inclusionary Housing Ordinance (IHO) requires that a certain percentage of all homes built in a new housing development are made affordable to low-income community members. The necessity of an IHO in Antioch is clear: with a growing population and plentiful opportunities for development, Antioch is an attractive city for housing developers. But, as was noted by one Planning Commissioner during an April 16 commission meeting, without an IHO, it is highly unlikely that developers will build housing affordable to the majority of Antioch residents. Indeed, despite the fact that Antioch is close to three years into our eight year housing element cycle, we have permitted only 4% of the 1294 homes for low-income residents we are required to plan for under our state-mandated Regional Housing Needs Allocation (RHNA).1 Over the next five years, we will need to plan to construct 1244 homes for our most vulnerable neighbors: an IHO will help us get there.
An IHO is a mainstream tool used to achieve greater housing affordability, and 14 out of our 19 neighboring jurisdictions in Contra Costa County already have an IHO in place. IHOs bring more affordable housing to our community without the City having to spend money to develop it. Instead, the policy asks private developers who will profit in our city to support our community by selling or renting some of their homes at affordable rates. While some developers decry these ordinances and claim that they make all development in our city infeasible, city staff has already researched the issue and found that even with an IHO, developers will continue to profit in Antioch at rates that ensure continued housing development at all price levels.2 In rare cases where on-site construction of affordable housing truly makes development infeasible, the ordinance provides an option for developers to pay an in-lieu fee, which the city may then use to fund 100% affordable housing developments at other sites throughout our community.
At a time when the costs of basic necessities like food, medicine, and housing continue to rise, while working people’s wages remain flat and social safety nets are under threat, we strongly support the Planning Commission and City Council adopting a well established tool to promote affordable housing in Antioch.
Requiring Affordability at the Extremely Low-Income Level
Any IHO must not only require affordable housing, it must also set parameters defining the level of affordability required. Most jurisdictions base this level of affordability on definitions created by the federal department of Housing and Urban Development (HUD) along with California’s department of Housing and Community Development (HCD). These agencies set affordability levels in relation to the Area Median Income (AMI) and have defined the following income categories:
2 PlaceWorks Consulting and Antioch Planning Department, “Financial Feasibility Study” Staff Report to the Antioch Planning Commission, April 16, 2025. Pages 8-11. 1 Partnership for the Bay’s Future “Housing Readiness Report - Antioch - Affordable Housing Permitting.” https://www.housingreadinessreport.org/antioch#reported-progress H9
Acutely Low-Income Less than 15% of AMI
Extremely Low-Income 15-30% of AMI
Very Low-Income 30-50% of AMI
Low Income 50-80% of AMI
Moderate Income 80-120% of AMI
Above Moderate Income More than 120% of AMI
The current draft ordinance you are considering sets a 15% overall inclusionary rate and requires 10% of all new housing to be affordable to residents defined as Very Low-Income, and 5% to be affordable to residents defined as Low-Income. Our coalition proposes this requirement be shifted so that 5% are required to be affordable each to Extremely Low-, Very Low-, and Low-Income Antioch residents.
Antioch’s 6th Cycle Housing Element update found that Antioch has a higher proportion of residents categorized as Extremely Low-Income than both Contra Costa County and the surrounding Bay Area:
close to one in every five Antioch residents qualifies as Extremely Low-Income.3 It further showed that Extremely Low-Income residents are “the most impacted by high housing costs,” with 77% of ELI residents spending more than half of their income on housing.4 Programs meant to address housing affordability should be clear in targeting those most impacted by our community’s housing affordability crisis. Failing to require homes that are affordable to the ELI community in Antioch would be a major missed opportunity in our IHO.
ELI in Contra Costa County is currently defined as an income of $47,950 for a family of four or $33,600 for an individual. Severe income inequality in the Bay Area inflates the Area Median Income, leaving many hardworking families categorized as Extremely Low-Income. Our ordinances must be specific and tailored to meet the particular needs of our community. In this case, that means ensuring that our affordability levels are targeted to serve the significant ELI community living in Antioch.
Setting a 20% Inclusionary Rate
The current draft ordinance you are considering requires 15% of homes in new developments to be affordable. Our coalition has consistently advocated that the overall inclusionary requirement in Antioch’s ordinance should be set at 20%. The reason for this is simple: Antioch and the broader Bay Area face an acute crisis of housing affordability. In Antioch, this crisis cannot be explained as simply a housing shortage; during the last Housing Element cycle, Antioch produced more than twice the aggregate target amount of housing set by the RHNA process.5 Instead, we must specifically name in Antioch a shortage of affordable housing. During this same period, Antioch permitted more than three 5 During the 5th Cycle Housing Element period, Antioch had a RHNA goal of 1,448 homes, and permitted 2,941 homes. Partnership for the Bay’s Future “Housing Readiness Report - Antioch - Reported Progress” 2025. https://www.housingreadinessreport.org/antioch/reported-progress 4 Ibid. pg. 2-13
3 City of Antioch. (2023) 2023-2031 Housing Element Update. “Housing Needs Assessment.” pg. 2-7 H10
times the amount of Above Moderate-Income housing targeted by our RHNA goals, but reached only 63% of our goals for Very Low-Income housing.6
Often, focusing on RHNA goals and numbers of “units” can miss the bigger picture. As market rate development continues to surge in Antioch without a concomitant growth of affordable housing options, our neighbors are being forced out of town and out of their homes. The Bay Area Equity Atlas reports that 66% of low-income Antioch residents live in areas at risk of displacement and gentrification7 and for two years in a row, Antioch has had a higher population of people experiencing homelessness than any other city in Contra Costa County.8
Our affordability crisis is a humanitarian disaster, and our IHO should go as far as possible towards meeting the urgent need to develop deeply affordable housing in Antioch.
Closing
Antioch staff and the consulting team at PlaceWorks have done a tremendous job researching and preparing this draft ordinance. We are deeply grateful to the City’s leadership and staff for advancing this ordinance to this point. We know that an Inclusionary Housing Ordinance alone will not solve the affordability crisis facing our community. Still, we lag behind almost all of our neighboring jurisdictions in adopting this straightforward tool to address the situation. With the inclusion of these two amendments, Antioch can pass a critical and impactful ordinance that is tailored specifically to the needs of our community. We are excited to see this ordinance move forward and offer ourselves as collaborators in developing this just and necessary ordinance.
Sincerely,
Joey Flegel-Mishlove, East Bay Housing Organizations, on behalf of:
California Center for Movement Legal Services
Contra Costa Budget Justice Coalition
East Bay Alliance for a Sustainable Economy
East Bay Housing Organizations
Ensuring Opportunity Campaign to End Poverty in Contra Costa County Hope Solutions
Lift Up Contra Costa County
Monument Impact
Multi-Faith ACTION Coalition
Public Advocates
Rising Juntos
United Latino Voices of Contra Costa County
8 Contra Costa County Health, Housing, and Homlessness, “2024 Point-In-Time Count,” and “2025 Point-In-Time Count,”
https://www.cchealth.org/home/showpublisheddocument/30271/638732359799630000 and https://www.cchealth.org/home/showpublisheddocument/32051 7 Bay Area Equity Atlas, “Gentrification Risk - Antioch, CA,” https://bayareaequityatlas.org/indicators/gentrification-risk?geo=07000000000602252 6 Ibid.
H11
Outlook
Antioch Planning Commis sion Submission for February 4th meeting, Agenda 6-1, lnclusionar y Housing Ordinance Public Hearing
From Benisa Berry
Date Tue 2/3/2026 3:53 PM
To Planning Division <[email protected]>
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.
Dear Members of the Antioch Planning Commission,
I am writing on behalf of the East Contra Costa Community Leaders Network (CLN) to express strong support for the staff's recommendation that the Planning Commission recommend that the City Council adopt an lnclusionary Housing Ordinance (IHO). Public Hearing of the lnclusionary Housing Ordinance recommendation is Item 6-1 on the February 4th Planning Commission meeting agenda.
This ordinance would represent a significant step forward in addressing Antioch's affordable housing needs and fulfilling the city's obligations under the Regional Housing Needs Allocation (RHNA) for the 2023-2031 cycle.
The IHO's requirement for developers to allocate 15% of new residential units as affordable housing or pay an in-lieu fee per unit is a balanced approach that promotes housing equity while maintaining project feasibility. The CLN requests the IHO include a minimum of 15% of new residential projects as affordable housing units, but requests consideration of 20% to support a meaningful impact. The comprehensive feasibility study conducted by PlaceWorks demonstrates that small-lot single-family, townhome, and multifamily rental projects can successfully incorporate affordable housing units under certain conditions, such as density • increases and parking reductions.
Furthermore, the community's overwhelming support for the I HO, as evidenced by the survey and workshop results, highlights the importance of this ordinance in addressing the housing challenges faced by Antioch residents. The establishment of a Housing Trust Fund (HTF) to manage in-lieu fees and support affordable housing projects further strengthens the city's commitment to creating a diverse and inclusive community.
I urge the Planning Commission to recommend the adoption of the lnclusionary Housing Ordinance to the City Council. This ordinance is a vital tool for ensuring that Antioch remains a city where residents of all income levels can find safe, quality, and affordable housing.
Thank you for your consideration.
Sincerely,
Benisa Berry
East County Community Leaders Network (CLN)
H12
CI
TY OF ANTIOCH
PLANNING COMMISSION
REGULAR MEETING
R
egular Meeting February 4, 2026
6:30 p.m. City Council Chambers
1. CAL
L TO ORDER
C
hairperson Webber called the meeting to order at 6:30 P.M. on Wednesday, February 4, 2026, in Council Chambers.
2. RO
LL CALL
P
resent: Commissioners Spijker, Riley, Vice Chairperson Jones and Chairperson Webber
Absent: Commissioners Suman and Perez
S
taff: Assistant City Attorney, Scott Thorne
Planning Manager, Zoe Merideth
Planning Consultant, David Storer
Minutes Clerk, Kitty Eiden
3. P
LEDGE OF ALLEGIANCE
C
hairperson Webber led the Pledge of Allegiance.
4. P
UBLIC COMMENT – None
5. CO
NSENT CALENDAR
5 -1 Planning Commission Meeting Minutes January 21, 2026 O
n motion by Commissioner Riley , seconded by Commissioner Jones the Planning Commission members present unanimously approved the Consent Calendar. The motion carried the following vote:
A
YES: Spijker, Riley, Jones and Webber
NOES: None
ABSTAIN: None
ABSENT: Suman and Perez
6. P
UBLIC HEARING
6 -1. Inclusionary Housing Ordinance - Staff recommends that the Planning Commission recommend the City Council adopt an Inclusionary Housing Ordinance (IHO). .
ATTACHMENT "I"
I1
PLANNING COMMISSION
Regular Meeting
February 4, 2026 Page 2 of 8
Planning Manager Merideth introduced Greg Goodfellow, Associate Principal, PlaceWorks, who presented the staff report dated February 4, 202 6, recommending the Planning Commission recommend the City Council adopt an Inclusionary Housing Ordinance (IHO).
P
lanning Manager Merideth added that the Planning Commission was providing direction on the IHO and Council would be setting the in-lieu fee by resolution.
C
hairperson Webber opened the public comment period.
De
vin Williams, Raise the R oof Coalition, wished everyone a happy Black History Month. He expressed support for the IHO, emphasizing that it should prioritize Antioch residents and incorporate a substantive affordability requirement, specifically a 20% inclusionary rate.
Additionally, he highlighted that the structure of the IHO should prevent in- lieu fees from becoming the default option for developers.
M
ark Jordan, expressed opposition to the IHO, citing concerns that it is not supported by current case law and raised questions regarding its constitutional validity. Additionally, he noted that the adoption of this ordinance could expose the City to unnecessary legal and financial risks.
G
reg Colley, Multifaith Action Coalition, expressed support for the IHO as recommended by staff.
He recommended the highest possible inclusionary requirement and prioritizing onsite construction. He urged the Planning Commission to recommend approval to the City Council.
He thanked the Planning Commission, Council and staff for organizing a professional process and comprehensive package.
J
oey Flegel—Mishlove, East Bay Housing Organizations, expressed support for the IHO and recommended that the requirements name extremely low -income housing and a 20% inclusionary rate.
R
everend Millie Phillips, Faith Alliance for a Moral Economy, thank ed the City for bringing forward the IHO . She supported the inclusion of extremely low-income housing and a 20% inclusionary rate.
K
hayla DiGiorgio, Hope Solutions, spoke in support of the IHO and encouraged the Planning Commission support shifting requirements so that 5% would be required at each level of extremely low, very low and low-income residents.
S
uzanne Dershowitz, Public Advocates, S enior Staff Attorney, thanked the City for advancing the IHO and urged the Planning Commission to recommend approval to the City Council.
Speaking to concerns raised by a previous speaker this evening, she commented there was no precedent that impacted the legality of the IHO . She noted that the IHO would make Antioch more competitive for grant funds and development in Antioch would remain profitable with the implementation of the IHO.
Ch
ris Palomo, Senior Organizer Nor Cal Carpenters Union, spoke in support of the IHO and requested that the Planning Commission recommend that the City Council direct staff to I2
PLANNING COMMISSION
Regular Meeting
February 4, 2026 Page 3 of 8
incorporate AB2011 labor standards into the policies governing the Housing Trust Fund and In- Lieu Fee program.
Chairperson Webber closed the public comment period.
Planning Consultant Storer clarified that if the Planning Commission was in support of forwarding a recommendation to the City Council, they could suggest adjusting the in-lieu fee to encourage the development community to build the units . He explained pro forma analysis related to the affordability requirements. He commented that the components of the Housing Trust Fund would include specific guidelines for use of those funds.
Commissioner Jones thanked staff and the consultant for the comprehensive report. She questioned if the area median income ( AMI) would fluctuate every year as the numbers increased. She expressed concern for using the counties data since Antioch’s AMI was lower.
Mr. Goodfellow responded that there was no assumption that the AMI would be updated annually; however, it would be subject to review when there was a significant increase or decrease in median income. He added that the in-lieu fee would be updated yearly based on the consumer price index. He mentioned that typically, IHOs were reviewed at least every four years.
He commented that county data was used for consistency.
In response to Chairperson Webber , Mr. Goodfellow clarified that the IHO did not include any labor standards; however, if Council desired, a policy could be added to the Housing Trust Fund.
Chairperson Webber stated it was important to create affordable housing and jobs that allowed people to live locally.
Planning Consultant Storer explained the guidelines within the Housing Trust Fund and noted that it would be managed by staff. He further noted it would provide money to comingle with other funding sources to advance projects. He stated should this item be forwarded to the City Council; they would adopt the guidelines by resolution.
Commissioner Jones stated she supported the IHO as presented. She noted she wanted the housing to be built without putting major constraints on the developers. She further noted the Trust Fund would allow for the opportunity to address how the funds should be used.
In response to Commissioner Jones, Planning Consultant Storer clarified that the Trust Fund was dedicated funding, prohibited to be used for the General Fund. He noted the Trust Fund would not be coming to the Planning Commission since it was not a land use structure. He reiterated that most of the time the money was used to co- mingle with non -profit builders to better leverage their projects. He further noted should the Planning Commission recommend that the City Council adopt the IHO, a Housing Trust Fund would be established and the resolution would include program guidelines.
Mr. Goodfellow added that the guidelines for the Housing Trust Fund were dynamic and would reflect local priorities.
I3
PLANNING COMMISSION
Regular Meeting
February 4, 2026 Page 4 of 8
In response to Commissioner Spijker, Planning Manager Merideth provided an overview of the City’s Regional Housing Needs Allocation (RHNA) numbers. Planning Consultant Storer added that the zoning map facilitates the market to lead toward the affordable categories and the IHO would direct those markets to produce units for the RHNA categories.
Commissioner Spijker stated he was concerned that the Housing Trust Fund would provide options that would not lead to the development of units.
Planning Consultant Storer explained that providing financial assistance to lower -income individuals through the Housing Trust Fund would achieve the same objective as constructing new units. He suggested that the City could implement an escalating factor to discourage developers from opting not to build. Additionally, he noted that the primary goal of the Housing Trust Fund wa s the creation of new affordable housing units, with a secondary goal of co- mingling funds.
Commissioner Spijker expressed his appreciation for the flexibility incorporated into the Housing Trust Fund. He also inquired whether there could be a legally permissible requirement to give preference to existing Antioch residents.
Assistant City Attorney Thorne responded that he would investigate the possibility of establishing a legally permissible requirement to provide preference to existing Antioch residents.
Mr. Goodfellow reported that another city had the same concern and had decided not to restrict preference solely to City residents but to residents of the County. He noted that, even after the adoption process, this approach remained questionable; however, to his knowledge, there had been no objections. He recommended that staff seek a legal opinion to determine whether such a preference could be incorporated.
Planning Consultant Storer added that the Planning Commission could forward a recommendation that the City Council consider prioritizing Antioch residents and then legal counsel could research the matter.
Commissioner Jones agreed with that recommendation.
Commissioner Spijker expressed concern that the staff report did not include data analyzing a 20% inclusionary rate.
In response to Commissioner Spijker, Planning Manager Merideth provided an overview of current projects that would be exempt since they had existing development agreements and entitlements. Mr. Goodfellow stated he had not experienced AB2011 being included in other IHOs; however, it could be included in the trust fund guidelines.
Commissioner Spijker reiterated that he would like to see the H ousing Trust Fund direct the money to be spent on building new units and spreading them throughout the City was preferable.
I4
PLANNING COMMISSION
Regular Meeting
February 4, 2026 Page 5 of 8
Planning Consultant Storer stated if the IHO was a pproved and they were not getting onsite development; they could amend the Ordinance to increase the fees.
Commissioner Jones questioned if a timing mechanism for reviewing the ordinance and Housing Trust Fund could be written in to the IHO.
Mr. Goodfellow confirmed a recommendation could be made to the City Council to include a timing mechanism to review in-lieu fees provided versus the units built.
Chairperson Webber asked if the Planning Commission could recommend that the City Council adopt the ordinance with a recommendation that a number of units be given preference to residents of Antioch.
In response to Commissioner Spijker, Planning Consultant Storer explained the establishment of administrative fees were unrelated to the in-lieu fees.
Mr. Goodfellow mentioned that they could use a third party to administrate the IHO/Housing Trust Fund. He stated upon further review, a City could prioritize resident preferences in the ordinance. He explained that a housing authority was a County level entity.
Planning Consultant Storer added there was a threshold of size of population before the City provided Housing Authority services. He noted there were non- profits dedicated to the administration of H ousing Trust Funds and the implementation of reviewing projects and agreements.
Acting Planning Manager Merideth added that the City of Antioch had Housing staff and consultants; however, a Housing Authority was a separate entity.
Commissioner Riley cautioned not to dissuade developers by having an in-lieu fee so expensive that there were no available options than to build affordable housing. He also raised the concern that the in-lieu fee might incentivize developers to pass additional costs onto consumers in other parts of the project. Despite these concerns, he stated he supported the IHO , trusting the staff and the consultant who conducted the analysis and developed the recommendations.
Planning Consultant Storer explained that lower land values and impact fees, made Antioch very attractive to developers.
Commissioner Jones commented that she believed the concerns raised by the Planning Commission could be resolved in the Housing Trust Fund guidelines.
Following discussion, the Planning Commission agreed that the IHO be approved as presented and supported forwarding the following recommendations to the City Council:
That the Housing Trust Fund be reviewed in detail for administrative guidelines to ensure funds are prioritized for development
That a number of units be prioritized to residents of Antioch I5
PLANNING COMMISSION
Regular Meeting
February 4, 2026 Page 6 of 8
That a two-year review process for the IHO and Housing Trust Fund for the purpose of looking at extremely low-income levels and modifying the Housing Trust Fund guidelines That the Housing Trust Fund give preference to local unions for AB2011 That the Housing Trust Fund look at options to prioritize extremely low-income housing
On motion by Commissioner Jones, seconded by Commissioner Riley the Planning Commission members present unanimously adopted a resolution of the Planning Commission of the City of Antioch recommending the City Council adopt an O rdinance adding title 9, chapter 5, article 43: Inclusionary Housing Ordinance to the Antioch Municipal Code. With the following recommendations:
That a review of the IHO and Housing Trust Fund Administrative Guidelines be conducted during the first quarter of the first year and every two years thereafter That the Housing Trust Fund housing shall be reviewed in detail for administrative guidance to ensure funds are prioritized for development That the housing units shall be prioritized for residents of Antioch That a review process shall be implemented for t he in-lieu fees with the flexibility to increase fees if a significant percentage of developers choose this option That the Housing Trust Fund gives preference to local unions for AB2011 That the Housing Trust Fund shall prioritize extremely low-income households
The motion carried the following vote:
AYES: Spijker, Riley, Jones and Webber
NOES: None
ABSTAIN: None
ABSENT: Suman and Perez
7. REGULAR ITEM
7-1. General Plan Advisory Committee Appointment Discussion
Chairperson Webber opened the public comment period.
Juan Pablo Galvan Martinez, Save Mount Diablo, gave a history of Commissioner Riley’s civic engagement and spoke in support of Commissioner Riley being appointed to the GPAC.
Chairperson Webber closed the public comment period.
Planning Manager Merideth presented the staff report dated February 4, 2025, recommending the Planning Commission discuss and select potential Commissioners to be appointed to the General Plan Advisory Committee (GPAC).
Commissioner Riley thanked Mr. Martinez for endorsing him and expressed interest in being appointed to the GPAC. He gave a history of this civic engagement.
I6
PLANNING COMMISSION
Regular Meeting
February 4, 2026 Page 7 of 8
Commissioner Spijker stated he was interested in being appointed to the GPAC and gave a personal history. H e stated he respected Commissioner Riley and Commissioner Jones’s decision making and thought process so he would consider withdr awing his name from consideration.
Commissioner Jones expressed interest in serving on the GPAC and gave a history of her professional history and civic engagement.
Following discussion, Commissioner Spijker withdrew his interest in serving on the GPAC.
On motion by Chairperson Webber , seconded by Commissioner Spijker the Planning Commission members present unanimously selected Commissioner Riley and Commissioner Jones as potential Commissioners to be appointed to the General Plan Advisory Committee (GPAC). The motion carried the following vote:
AYES: Spijker, Riley, Jones and Webber
NOES: None
ABSTAIN: None
ABSENT: Suman and Perez
8. ORAL/WRITTEN COMMUNICATIONS
Planning Manager Merideth announced GPAC applications for the general public were available and the deadline was February 27, 2026.
9. COMMITTEE REPORTS - None
10. NEXT MEETING: March 4, 2026
Chairperson Webber announced that the next Planning Commission meeting would be held on March 4, 2026.
11. ADJOURNMENT
On motion by Commissioner Spijker, seconded by Commissioner Jones, the Planning Commission members present unanimously adjourned the meeting at 8: 45 P.M. The
motion carried the following vote:
AYES: Spijker, Riley, Jones and Webber
NOES: None
ABSTAIN: None
ABSENT: Suman and Perez
Respectfully submitted:
I7
PLANNING COMMISSION
Regular Meeting
February 4, 2026 Page 8 of 8
Kitty Eiden
KITTY EIDEN, Minutes Clerk
I8
Inclusionary Housing
Ordinance City of Antioch
City Council
March 10, 2026
UPDATED 3/10/26 @ 3:24 PM
City of Antioch Inclusionary Housing Ordinance
PROJECT TEAM
City of Antioch
Zoe Merideth, Planning Manager
Kevin Scudero, Principal Planner
David Storer, Community Development Consultant
PlaceWorks, Inc.
Greg Goodfellow, Associate Principal
Steve Gunnells, Chief Economist
City of Antioch Inclusionary Housing Ordinance
TONIGHT’S HEARING
1. Introduce by title only and waive the first reading of an ordinance of the City Council amending the City of Antioch Municipal Code Title 9: Planning and Zoning to add Article 43: Inclusionary Housing
» 15% inclusionary requirement
» In-lieu option with annual update, paired with Housing Trust Fund » Affordable Housing Plan requirement
» Affordable unit quality standards
2. Adopt the resolution establishing an Inclusionary Housing Trust Fund (IHTF)
3. Adopt the resolution amending the Master Fee Schedule to add an in-lieu fee and an affordable housing compliance monitoring fee
PROPOSED IHO
IHO DEVELOPMENT
IN-LIEU FEE AND HOUSING TRUST FUND
6:45
7:00
7:30
2. 5.
3. 4.
RECOMMENDED ACTION6.
IHO BACKGROUND 1.
PLANNING COMMISSION RECOMMENDATIONS
IHO
Background
City of Antioch Inclusionary Housing Ordinance
INCLUSIONARY HOUSING 101
Requires new projects to set
aside % of units as BMR
» Privately-subsidized affordable
housing.
» Typically allows for payment of a fee
in lieu of constructing affordable
units.
Why in Antioch?
» City’s State “fair share” is 1,741 VLI,
LI and MI units.
» IHO study program established in
certified Housing Element.
» HE goal: Construction of 360-460
affordable units.
IHO
Development
City of Antioch Inclusionary Housing Ordinance
Inputs: Outreach & Analysis
In-Person Outreach
» February 4, 2024: Community
Meeting
» December 5, 2024: Developer
Focus Group
Online Outreach
» October 15, 2024: Community
Survey
» 2025: Local Staff Interviews
1. Financial Feasibility Analysis
» Assess impacts of affordability
requirements on “bottom line”
2. In-Lieu Fee Analysis
» Calculate local “affordable housing
financing gap”
» Fill gap with per-unit fee
3. Existing IHO Reviews
» Components and approaches
City of Antioch Inclusionary Housing Ordinance
2025 Study Sessions
April 26, 2025: Planning Commission
» Feedback on background, FFA, outreach
May 27, 2025: City Council
» Direction on general approach
August 26, 2025: City Council
» Follow-up discussion & specific questions
September 16, 2025: City Council
» Direction on specific policy points
Proposed
IHO
City of Antioch Inclusionary Housing Ordinance
Proposed Inclusionary Housing Ordinance
Projects: 5+ units, citywide
Requirement: 15% of MR units
» 10% affordable to VLI households
» 5% affordable to LI households
» Small projects: Alternating VLI/LI
until requirement met
Affordability Term: In
Perpetuity
In-lieu fee option: $202,500
per unbuilt unit
» Annual assessment
No other alternative
compliance
» Focus on on-site construction
No developer incentives
» Maximize state streamlining &
density bonus concessions
City of Antioch Inclusionary Housing Ordinance
Proposed Inclusionary Housing Ordinance
Affordable Housing Plan
» Submit with application
» Specify inclusionary calculations
» Illustrate inclusionary unit locations &
plans
» Detail process of household selection
» Establish annual reporting
requirements
Inclusionary Unit Standards
» Same proportion as MR units
» At least 90% size of MR units with the
same BR count
» Same BR count ratio as MR units
» Same exterior design and quality of
construction as MR units
» Meet all standards in Title 8 and 9 of
Antioch Municipal Code
In-Lieu Fee &
Inclusionary
Housing Trust
Fund
City of Antioch Inclusionary Housing Ordinance
In-Lieu Fee Analysis
▪ Approach used: “Affordability Housing Financing Gap”
1. Calculate full cost of developing a single affordable unit in Antioch ($440,000)
2. Calculate total reliable, per-unit financing ($237,512)
3. Subtract reliable financing from total cost to identify financing gap ($202,488) ▪ Adopt in-lieu fee to close financing gap = $202,500 per unbuilt unit City of Antioch Inclusionary Housing Ordinance
In-Lieu Fee Analysis
Review recent affordable development projects
» Unit costs
» Average Low-Income Housing Tax Credits (LIHTC) used
» Average bank financing used
Projects source: California State Treasurer’s Office
» Archive of all LIHTC projects
» Detailed project description, cost and financing information for each City of Antioch Inclusionary Housing Ordinance
In-Lieu Fee Analysis
▪ Financing affordable housing is an art
▪ Low-Income Housing Tax Credits
▪ Conventional bank financing
▪ A variety of other sources
▪ Example: El Cerrito Plaza –
Parcel A South
▪ 70 low-income units
▪ 1, 2, & 3 bedroom units
▪ $69.6 million
Source: Pyatok, Van Meter Williams Pollock, Einwiller Kuehl
City of Antioch Inclusionary Housing Ordinance
Financing of Affordable Housing
Bank Financing
6%
City
1%
County
8%
State
44%Deferred Developer Fee
1%
Tax Credit Equity
36%
Other
4%▪ Example: El Cerrito Plaza –
Parcel A South
▪ Typical: LIHTC and bank
▪ 5 other funding source
categories with further
subcategories
City of Antioch Inclusionary Housing Ordinance
Affordable Housing Development Cost
Total Development Cost $332,000,000
Total Number of Affordable Units 376
Average Development Cost per Unit $882,000
Average Cost Across Five CC Affordable Housing Projects 2023/25
City of Antioch Inclusionary Housing Ordinance
Affordable Housing Funding
Average Cost Across Five CC Affordable Housing Projects 2023/25 Total Number of Units 376
Total Permanent Bank Financing $50,500,000
Average Bank Financing per Unit $134,400
Total 4% Federal Tax Credit Equity $128,500,000
Average Tax Credit Equity per Unit $342,000
City of Antioch Inclusionary Housing Ordinance
Affordable Housing Development Gap
Average Cost Across Five CC Affordable Housing Projects 2023/25 Construction Cost per Unit $882,000
Less Bank Financing per Unit -$134,400
Less Federal 4% Tax Credit Equity per Unit -$342,000
Financing Gap per Unit $406,000
Percentage of Average Cost per Unit 46.02%
City of Antioch Inclusionary Housing Ordinance
Antioch Calculation Methodology
Model conceptual housing development
» Based on recent and entitled Antioch projects
» 83 units in three story buildings on 4.1 acres
Calculate development costs
» Total development cost, $36.1 million, equates to $440,000 per affordable dwelling unit
Expected financing gap
» Average 46.02% of total financing gap per unit from five CC case studies, applied to Antioch model = $202,500 financing gap City of Antioch Inclusionary Housing Ordinance
Revise per Affordable Developers
Vice President of Real Estate Development, Eden Housing » Increased per unit cost to account for higher finance costs, city/impact fees, design costs, legal fees
» In-lieu fee “feels like a reasonable amount”
Vice President of Development, Cypress Equity
» Increased per unit cost to account for higher soft costs » In-lieu fee “would go a long way in helping an affordable housing developer… a project that once wouldn’t pencil will now become feasible.”
City of Antioch Inclusionary Housing Ordinance
Inclusionary Housing Trust Fund
Repository of in-lieu fees
Council-approved Administrative Guidelines
» “…assist in the creation and preservation of affordable housing in the City of Antioch for the benefit of extremely low, very low, low and moderate-income households.” » Distribution and Uses include:
● Creation of new affordable units
● Preservation of existing affordable housing
● Assistance with multi-family rehabilitation programs
● Conversion of market rate units to
affordable housing units
● Support of the construction of
accessory dwelling units
February 4, 2026
Planning Commission
City of Antioch Inclusionary Housing Ordinance
February 4, 2026 PC Hearing
4-0 recommendation that City Council adopt IHO
1. Requested review: Prioritize Antioch residents for BMR eligibility » Potential conflict with State fair housing laws
» Staff response: Not recommended
2. Requested review: Establish preference to local unions in HTF » Potential conflict National Labor Relations Act; State Housing Element law; local zoning authority
» Staff response: Not recommended
City of Antioch Inclusionary Housing Ordinance
February 4, 2026 PC Hearing
3. Requested review: Ensure IHTF prioritizes funds for housing development
» Staff response: IHTF Admin Guidelines provide options for the City Council for how fund are spent and allows funds to be spent strategically on a variety of needs
4. Requested review: Ensure IHTF prioritizes ELI households » Staff response: ELI not included in RHNA; incorporated into VLI range
5. Requested review: Audit HTF in 1st quarter of year + each 2 years hereafter to determine % of projects using in-lieu fees » Staff response: City Council could include this recommendation in draft ordinance and IHTF Admin Guidelines
City of Antioch Inclusionary Housing Ordinance
RECOMMENDED ACTION
1. Introduce by title only and waive the first reading of an ordinance of the City Council amending the City of Antioch Municipal Code Title 9: Planning and Zoning to add Article 43: Inclusionary Housing
» 15% inclusionary requirement
» In-lieu option with annual update, paired with Housing Trust Fund » Affordable Housing Plan requirement
» Affordable unit quality standards
2. Adopt the resolution establishing an Inclusionary Housing Trust Fund (IHTF)
3. Adopt the resolution amending the Master Fee Schedule to add an in-lieu fee and an affordable housing compliance monitoring fee
Inclusionary Housing
Ordinance City of Antioch
City Council
March 10, 2026
Comment letter/Studies – BIA
(March 31, 2025 and March 10, 2026)
MERCATUS CENTER
STUDY (2019/2021)
TERNER REPORT (2024)
2. Mercatus Center for George Mason
University (publ. 2019/2021)
Study area: Baltimore-Washington area (Inclusionary Zoning/”IZ”) • References six studies - 4 of them within CA
I) Bento et al: published in 2009 - studies 1988 - 2005 ii) Tom Means & Ed Stringham: published in 2012 - studies from 1980 - 2000 iii) Ann Hollingshead: published in 2015 “suggest that inclusionary housing policies pre-Palmer (2009), in general, did promote housing affordability in the low-cost and moderate household incomes”
iv) Schuetz, Metzler and Been (2009): “They find no evidence that inclusionary housing policies lead to reductions in housing production in the Bay Area.”
3. Terner Center Report, 2024
• Study area: City of Los Angeles for Transit Oriented Communities Program - only for Multi-Family housing.
Uses a proprietary “simulator’ model - not for Single family production. • Argues not for the elimination of IHO’s but provides reasons why not to increase Inclusionary Housing levels to meet new state mandates for housing production. • “IZ has been shown to produce BMR housing”
• “IZ offers cities a way to boost their affordable housing production through private rather than public subsidy”
9 Agenda Item #
STAFF REP
ORT TO THE CITY COUNCIL
DATE: Regular Meeting of March 10, 2026
TO: Honorable May
or and Members of the City Council
SUBMITTE
D BY: Kevin Scudero, Principal Planner
APPROVED BY: David A. Storer, Interim Community and Economic Development Director
SUBJECT: City Council Appointments
to the General Plan Advisory Committee
RECOMMENDED ACTION
It is recommended that the City Council review and discuss City Council Appointments to the General Plan Advisory Committee (GPAC). Mayor Bernal will advance appointments for City Council approval by majority vote.
FISCAL IMPACT
There is no direct fiscal impact because of this action.
DISCUSSION
On January 13, 2026, the City Council authorized the formation of the GPAC. The GPAC will be composed of the following members:
• Two City Council Members;
• Two Planning Commission Members;
• Five members of the general public; and
• Two alternate members of the general public.
The item tonight is for the City Council to select the two members of the City Council to serve on the GPAC. There will be future agenda items for the appointment of Planning Commissioners and members of the general public to the GPAC.
ATTACHMENTS
A. GPAC Application Memo
City of Antioch
General Plan Advisory Committee Information
1 City of Antioch
General Plan Advisory Committee Information
This memo provides information for persons interested in being appointed to the Antioch General Plan Advisory Committee (GPAC).
Introduction
The City of Antioch has embarked on a multi-year process to update its General Plan. The Antioch General Plan is the City’s overarching policy guidance document and provides direction on a myriad of topics such as land use, housing, transportation, economic development, resource conservation, community health, parks, and open space.
The City of Antioch has hired a professional planning consulting firm, De Novo Planning Group, to assist the City with its General Plan Update. The City Council will also form a General Plan Advisory Committee (GPAC) to assist with preparation of the General Plan Update.
The GPAC will serve as one of the primary channels for the community to provide input and make recommendations on the General Plan Update. Participation by members appointed to the GPAC is temporary; the roles and responsibilities of its members will terminate with City Council adoption of the General Plan.
The charge of the GPAC is to:
1. Ensure City staff and the consultant team are aware of and understand community concerns, values and expectations.
2. Assist City staff and the consultant team in identifying critical issues that should be addressed in the planning process.
3. Identify areas of existing or potential conflicts and find ways to constructively resolve them.
4. Capitalize on the creative ideas and insights within the Antioch community for input into the General Plan.
5. Keep community organizations and interested citizens informed about the status of the planning process.
6. Provide recommendations to the Planning Commission and City Council supporting the General Plan.
The City Council intends to form a GPAC that represents a cross -section of the community, including residents and neighborhood groups, the business community, civic organizations, community-based organizations, development interests, and resource conservation interests. By ATTACHMENT "A"
A1
City of Antioch
General Plan Advisory Committee Information
2 ensuring that these groups are represented on the GPAC, the City of Antioch can be confident that a diverse range of viewpoints and interest areas will be considered as part of the General Plan Update process, ultimately resulting in a contemporary General Plan that best represents the community’s vision for the future.
GPAC Formation and Expectations
• Seven GPAC members from the general public (5 regular and 2 alternate) will be appointed by the City Council, with appointments anticipated to occur in March 2026. The committee will also include two City Council members and two Planning Commissioners. • The GPAC will meet up to a maximum of 12 times over the course of approximately 18 months. Meetings will generally occur once per month, but there may be months when no meetings are held.
• The first GPAC meeting is anticipated to be held in April 2026, and meetings will run through late 2027. At the first meeting staff will recommend a regular meeting date for the GPAC which will likely be either the first Tuesday or first Thursday of the month. • GPAC meetings will primarily be in-person evening meetings at City Hall, and will likely last 2-3 hours.
• GPAC members will be provided with agendas and reading materials prior to each meeting, and will be expected to attend all meetings prepared to discuss the topics identified on the agenda. Reading materials for each meeting may be 50 pages or more (including maps, tables, and graphics) and will include materials from the General Plan Existing Conditions Report, the General Plan community outreach results, and portions of the City’s existing General Plan.
• Meetings will be facilitated by City staff and the consultant team, and the GPAC will operate in the spirit of consensus. There will not be roll-call votes, and differing points of view will be recorded and presented to the City Council. The meetings will be structured as roundtable discussions, with defined opportunities for members of the public to provide comments.
• Regardless of the individual background or professional affiliation of a GPAC member, all members will be expected to participate in all meetings and provide input and feedback on all topics presented to the GPAC for discussion. The City is looking for full participants, not just individuals advocating for, or interested in, a single issue or topic. • GPAC meetings are generally anticipated to follow the following structure and address the following topics:
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City of Antioch
General Plan Advisory Committee Information
3 o The first meeting will provide an overview of the GPAC’s role, information on requirements for General Plans, a summary of feedback received to date from the community, and a discussion of high-level goals, priorities, and challenges for the Antioch community.
o The following 3-4 meetings will focus primarily on the topic of land use. The GPAC will discuss and provide input on growth patterns, development type, density, land use map changes, and other similar land use-related topics. The intent will be to develop a working draft of the updated Land Use Map with corresponding designations and densities.
o The subsequent 5-6 meetings will focus on other topics and issues covered under the General Plan, such as traffic/mobility, economic development, community health and wellness, utilities and public services, etc. Many of these topics overlap with land use, and with each other.
o The final two meetings will provide GPAC members with an opportunity to review and provide input on the entire Draft General Plan document prior to it being released for public review and comment.
• There will be several community workshops and public meetings held throughout the General Plan Update process, and GPAC members are encouraged to attend as many of these as possible.
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1 0
Agenda Item #
S
TAFF REPORT TO THE CITY COUNCIL
DAT
E: Regular Meeting of March 10, 2026
T
O: Honorable Mayor and Members of the City Council
SUBMITTED BY: David A. Storer, Interim Community and Economic Development Director
A
PPROVED BY: Bessie Marie Scott, City Manager
SUBJ
ECT: CSH Mahogany Housing HomeKey+ Program Update – 2436 Mahogany Way, Antioch (Antioch Inn and Suites/formerly Comfort Inn)
RECOMMENDED ACTION
It is recommended that the City Council receive the update from staff and the applicant regarding the CSH Mahogany Housing HomeKey+ application and provide any direction it deems necessary.
F
ISCAL IMPACT
This update on the status of the CSH Mahogany HomeKey+ application has no fiscal impact other than staff time to prepare this report.
T
he Council’s May 2025 approval obligated t he City provide a one-time contribution of $750,000 on receiving the HomeKey+ award from the State Department of Housing and Community Development (HCD) that will be used by the applicant , CSH Mahogany Housing for acquisition and rehabilitation of the current hotel facility at 2436 Mahogany Way in Antioch. In addition, the City Manager was authorized to execute an agreement that would provide a yearly operating subsidy of up to $1,200,000 annually for 5 years with two five-year extensions contingent on the property meeting the required HomeKey+ guidelines and affordable housing regulatory agreement.
DI
SCUSSION
P
roject location:
The property is a 123-unit motel on a 1.94-acre lot located at the northeast corner of Auto Center Drive and Hwy 4 at 2436 Mahogany Way in Antioch.
Antioch City Council Report
March 10, 2026 Agenda Item 10 2
Aerial view (Google)
View looking southeasterly (COA Staff)
Project Overview:
The proposed CSH Mahogany Housing Project is a rehabilitation project which will convert the motel units into 84 affordable units and one two- bedroom manager unit. Of the 84 units, 74 would be studios and 10 would be one- bedroom units. As part of the conversion, a few of the units will be merged to create one- bedroom units, a few units would be repurposed for uses for case management and for creation of common areas.
Each apartment will have a kitchenette, living room, bathroom, and bedroom. Non- residential conversion of the interior will include a community lounge, property management offices, resident supportive services and case management offices. One existing laundry room and the electrical room will maintain those functions, while a few rooms will be converted to resident services/case management and property management offices. The current site includes security fences, on-site parking spaces, spa and swimming pool, gates, and a trash enclosure. The property is composed of one
Antioch City Council Report
March 10, 2026 Agenda Item 10 3
building and has a common area and space for service amenities. The motel does not have any long-term residents and, resultantly, does not require any relocation.
Timeline:
At the time of the application to HCD, the applicant provided the following timeline for the project which has since lapsed:
The applicant provided the amended/targeted timeline below which is contingent on the award from HCD and NEPA clearance:
Construction start Apr 30, 2026 Construction completion Mar 31, 2027 Full Occupancy June 30, 2027
Current status:
The HomeKey+ award from HCD is pending approval but no decision has been made at the time of the preparation of this report. However, in anticipation of the award being approved, based on communications with HCD, City staff contractedwith Raney Planning & Management, Inc., to commence the environmental analysis required by the National Environmental Protection Act (NEPA). The NEPA analysis is required to be approved by the U.S. Department of Housing and Urban Development (HUD) prior to any federal funds being used once the award from HCD is granted. The NEPA analysis should be completed towards the end of May 2026, in the form of a Categorial Exclusion. At present, the draft environmental analysis has been sent to the State Department of Historic Preservation (SHPO) for it to determine if historic properties or archaeological resources are affected. Once the NEPA process is completed, a Public Notice of Intent to Request the Release of Funds (NOI/RROF) is published; sent to HUD for approval and thereby allowing the City Council to commit CDBG funds for purchase funding.
ATTACHMENTS
A. Joint application to and participation in the HomeKey+ program (originally approved by the City Council on May 22, 2025).
ATTACHMENT 1
RESOLUTION NO. 2025/89
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ANTIOCH
AUTHORIZING JOINT APPLICATION TO AND PARTICIPATION IN THE HOMEKEY+
PROGRAM
WHEREAS, A. The Department of Housing and Community Development Homekey+ grant funds pursuant to Health and Safety Code Section 50675.1.3 (Assem.
Bill No. 140 (2021-2022 Reg. Sess.), § 20.); Health and Safety Code Section 50675.1.5 (Assem. Bill No. 531 (2023-2024 Reg. Sess.); Section 14184.402 of the Welfare and Institutions Code; Section 5891.5 of the Welfare and Institutions Code; and Round 5 and 6 of the Homeless Housing, Assistance and Prevention (HHAP) grant program. (Assem.
Bill No. 129 (Chapter 40, Statutes 2023) and Assem. Bill No. 166 (Chapter 48, Statutes 2024), respectively; and
WHEREAS, The City of Antioch desires to jointly apply for Homekey+ grant funds with [CSH Mahogany Housing LP and California Supportive Housing], Therefore, Applicant is joining CSH Mahogany Housing LP and California Supportive Housing in the submittal of an application for Homekey+ f
consideration; and
WHEREAS, HCD is authorized to administer Homekey+ pursuant to the Multifamily Housing Program (Chapter 6.7 (commencing with Section 50675) of Part 2 of Division 31 of the Health and Safety Code. Homekey+ funding allocations are subject to the terms and conditions of the NOFA, the Application, the HCD-approved STD 213, Homekey+ Program.
NOW, THEREFORE, BE IT RESOLVED that the City Council hereby approves the submittal of a joint Application to HCD in response to the NOFA, and to jointly apply for Homekey+ grant funds in a total amount not to exceed $34,900,000 and City Funds not to exceed a one -time contribution of $75 0,000 on receiving the HomeKey + Award that will be used for acquisition and rehabilitation, in addition to a yearly operating subsidy of up to $1,200,000 annually for 5 years with two five-year extensions contingent on the * * * * * *
Docusign Envelope ID: B2F9C913-E3C1-431A-9BC2-2B7A16D24ACB ATTACHMENT "A"
A1
RESOLUTION NO. 2025/89
May 22, 2025