Appendix C6: New Construction Rental - Baseline
This represents a typical market-rate project with an inclusionary set-aside, where 20% of the units are affordable and 80% of units are market-rate. Of the affordable units, half are at 50% AMI and, half are at 80% AMI. All townhomes will be rented at market rate.
Development Program and Assumptions
Baseline:
Current Inclusionary Development Costs
Baseline:
Current Inclusionary
Site Size (sf) 23,527 Land 5,820,000$ Total Number of Units 97 Construction and Soft Costs Affordable Units Required (a) 20% 20 Site Work 588,175$ Number of Market Rate Units 80% 77 Hard Costs - Residential 36,876,550$ Dwelling Units/Acre 180 Hard Costs - Parking 2,940,000$ Units (c) Soft Costs 8,889,040$
Studios 49 School Fee 421,205$ 1-Bedroom 20 Art Fee 323,238$ 2-Bedroom 18 Subtotal Const Costs Before Financing 50,038,207$ 3-Bedroom (Townhouses) 10 Financing Costs Average Unit Size 615 Points 450,344$ Net Residential Space (sf) 59,655 Construction Period Interest 3,152,407$ Common Area 21,816 Subtotal Financing Costs 3,602,751$ Total Residential Space (sf) 81,471 Capitalized Reserves -$ Total Open Space (sf) 4,292 Developer Fee (h) -$ Number of Parking Spaces 49 Total Development Costs 59,460,958$ Parking spaces per unit 0.51 Total Development Cost per Unit (inc. land) 613,000$ Development Costs Total Development Cost per Unit (exc. land) 553,000$ Land per Residential Unit (d) 60,000$
Land per Site sf 247$ Development Feasibility and Financing Construction Type Type 3 Net Operating Income (NOI) 2,597,123$ Site Work (per sq.ft. of site) 25$ Capi talized Value 57,713,833$ Hard Costs - Res (e) 450$ Less Total Development Cost (59,460,958)$ Hard Costs - Open Space 50$ Profit / (Loss) (1,747,125)$ Parking Costs (per podium space) 60,000$ Return on Cost -2.9% Soft Costs exc. Fees (as % of hard) (f) 22.0% Feasible for Market-Rate Project? (j) No Impact Fees (g) Sources of Financing
BUSD School Fee 5.17$ Supportable Loan 31,086,046$ 1% Arts Fee 0.8% Private Equity (k) 28,374,912$
Financing Costs (Construction) Traditional Capital Stack to Fill Gap Loan to Cost Ratio 60.0% LIHTC N/A
Interest Rate 7.0% City HTF N/A
Loan Fees 1.5% Other N/A
Construction Period (months) 30
Avg. Outstanding Bal During Construction 60.0% Operations Financing Costs (Permanent) Stabilized Gross Income 3,930,336$ Interest Rate 6.0% Less: Vacancy (196,517)$
Debt Coverage Ratio (Perm) 1.15 Less: Op Expenses excluding Property Taxes (582,000)$ Capitalized Reserve (# of months) (h) - Less: Property Taxes (j) (554,697)$ Nonprofit Developer Fee (i) 2,500,000$ Net Operating Income (NOI) 2,597,123$ Market Rents
Studios 2,850$ Affordability Metrics 1-Bedroom 3,500$ Average Project AMI 108% 2-Bedroom 4,400$ % of Units Serving ELI Households 0% 3-Bedroom (Townhouses) 6,800$ % of Units Serving VLI Households 10% Operations % of Units Serving Low Households 10%
Vacancy 5.0% % of Units Serving Moderate Households 0%
OpEx per unit (exc. prop taxes) 6,000$ % of Units Serving Above Mod Households 79% Property Tax Rate (j) 1.20% % Units Serving <=80% AMI Households 21% Cap Rate 4.50%
93 Attachment 2
Notes:
a) The inclusionary requirement applies to new residential developments above 5,000 square feet and can be met through a combination of providing units and paying a prorated fee This proforma assumes developers will meet the full affordable housing requirement on-site. b) The distribution of affordable and market-rate units by bedroom size is as follows:
Affordable Market Market Rate AMIs
Studios 10 39 105%
1-Bedroom 5 15 120%
2-Bedroom 5 13 125%
3-Bedroom 10 170%
Total 20 77
c) The development program is based on plans submitted in 2024 and includes stacked flats with an at-grade podium garage. The project received a 50% density bonus and includes a mix of stacked flats on floors 2 through 6, and two-story townhouses on floors 7 and 8. d) The land cost per unit was based on entitled projects located on sites larger than 1/3 acre that were sold along major commercial corridors, including San Pablo Avenue, University Avenue, and Shattuck Avenue. e) Hard costs includes all direct expenses associated with construction, including materials, labor, and equipment, required to construct the structure, excluding site work and parking, which are calculated separately. This figure captures the costs associated with Berkeley's Hard Hat and Bird Safe Building policies.
f) Soft costs include indirect expenses like design, insurance, and city fees, based on the City of Berkeley’s fee calculator. The soft-to-hard cost ratio generally aligns with the assumptions in Strategic Economics’ April 2024 report, Berkeley In-Lieu Fee and Housing Policies Economic Feasibility Analysis.
g) The current impact fees that apply to residential projects are:
Berkeley Unified School District fee
1% Arts Fee
The Affordable Housing In-Lieu Fee is available if a developer chooses to partially satisfy the inclusionary requirement by paying a fee. h) Market-rate projects typically do not capitalize operating reserves, instead relying on lease-up reserves or projected cash flow to cover operating costs. Reserves are more common in affordable housing or when required by lenders. i) The developer fee was calculated using the CTCAC Developer Fee Calculator provided by the State Treasurer's Office, based on an eligible basis that includes hard and soft costs, and assuming financing through 4% tax credits. For projects deemed infeasible by the market, this reflects the fee that affordable housing developers would expect to undertake this type of project. Because the baseline presents a market-rate, inclusionary development, no non-profit developer fee was included in the development costs. j) Mixed income projects may qualify for a partial property tax exemption under California's Revenue and Taxation Code Section 214(g).
The exemption is prorated based on the percentage of units restricted to low-income households. Additional requirements include a regulatory agreement, an appropriate ownership structure, and compliance with other eligibility criteria. A community land that owns the land can also qualify for a property tax exemption with higher income limits. This proforma assumes the property tax exemption applies only to the units designated for low-income households or below. k) This represents the funding needed to cover the gap between project costs and supportable debt. Market-rate projects close this gap using private equity, including developer contributions, preferred equity, and other private sources seeking competitive returns.
Sources: The Housing Workshop; Urban Math, 2024.
94 Attachment 2
Appendix C7: New Construction Rental - Half & Half
This assumes 50% of units will be affordable, with 10% serving 50% AMI and 40% serving 80% AMI households. The remaining will be market-rate. All townhomes will be rented at market rents to cross-subsidize. This project could qualify for SB 35/SB 423 streamlining.
Development Program and Assumptions
Option A:
Half & Half Development Costs
Option A:
Half & Half
Site Size (sf) 23,527 Land 5,820,000$
Total Number of Units 97 Construction and Soft Costs Affordable Units Required (a) 50% 49 Site Work 588,175$ Number of Market Rate Units (b) 50% 48 Hard Costs - Residential 42,375,843$ Dwelling Units/Acre 180 Hard Costs - Parking 2,940,000$ Units (c) Soft Costs 10,098,884$
Studios 49 School Fee 421,205$
1-Bedroom 20 Art Fee 367,232$
2-Bedroom 18 Subtotal Const Costs Before Financing 56,791,339$ 3-Bedroom (Townhouses) 10 Financing Costs
Average Unit Size 615 Points 511,122$
Net Residential Space (sf) 59,655 Construction Period Interest 3,577,854$ Common Area 21,816 Subtotal Financing Costs 4,088,976$ Total Residential Space (sf) 81,471 Capitalized Reserves 1,541,554$ Total Open Space (sf) 4,292 Developer Fee 2,500,000$ Number of Parking Spaces 49 Total Development Costs 70,741,869$ Parking spaces per unit 0.51 Total Development Cost per Unit (inc. land) 729,298$ Development Costs Total Development Cost per Unit (exc. land) 669,298$ Land per Residential Unit (d) 60,000$
Land per Site sf 247$ Development Feasibility and Financing Construction Type Type 3 Net Operating Income (NOI) 2,523,058$ Site Work (per sq.ft. of site) 25$ Capitalized Value 56,067,949$ Hard Costs - Res (e) 518$ Less Total Development Cost (70,741,869)$ Hard Costs - Open Space 50$ Profit / (Loss) (14,673,920)$ Parking Costs (per podium space) 60,000$ Return on Cost -20.7% Soft Costs exc. Fees (as % of hard) (f) 22.0% Feasible for Market-Rate Project? (k) No Impact Fees (g) Sources of Financing
BUSD School Fee 5.17$ Supportable Loan 30,199,533$ 1% Arts Fee 0.8% Gap Financing (l) 40,542,335$
Financing Costs (Construction) Subsidy per Affordable Unit 827,395$ Loan to Cost Ratio 60.0% Traditional Capital Stack to Fill Gap Interest Rate 7.0% Tax Credit Equity 12,984,374$
Loan Fees 1.5% City HTF 9,800,000$
Construction Period (months) 30 Other 17,757,962$
Avg. Outstanding Bal During Construction 60.0%
Financing Costs (Permanent) Operations
Interest Rate 6.0% Stabilized Gross Income 3,591,792$
Debt Coverage Ratio (Perm) 1.15 Less: Vacancy (179,590)$ Capitalized Reserve (# of months) (h) 6 Less: Op Expenses excluding Property Taxes (582,000)$ Nonprofit Developer Fee (i) 2,500,000$ Less: Property Taxes (k) (307,145)$ Market Rents Net Operating Income (NOI) 2,523,058$
Studios 2,850$
1-Bedroom 3,500$ Affordability Metrics
2-Bedroom 4,400$ Average Project AMI 99%
3-Bedroom (Townhouses) 6,800$ % of Units Serving ELI Households 0% Operations % of Units Serving VLI Households 9%
Vacancy 5.0% % of Units Serving Low Households 41%
OpEx per market unit (exc. prop taxes) 6,000$ % of Units Serving Moderate Households 0% OpEx Adjustment for Affordable Units (j) 15.0% % of Units Serving Above Mod Households 49% Property Tax Rate (k) 1.20% % Units Serving <=80% AMI Households 51% Cap Rate 4.50%
95 Attachment 2
Notes:
a) The inclusionary requirement applies to new residential developments above 5,000 square feet and can be met through a combination of providing units and paying a prorated fee This proforma assumes developers will meet the full affordable housing requirement on-site. b) The distribution of affordable and market-rate units by bedroom size is as follows:
Affordable Market Market Rate AMIs
Studios 26 23 105%
1-Bedroom 12 8 120%
2-Bedroom 11 7 125%
3-Bedroom 10 170%
Total 49 48
c) The development program is based on plans submitted in 2024 and includes stacked flats with an at-grade podium garage. The project received a 50% density bonus and includes a mix of stacked flats on floors 2 through 6, and two-story townhouses on floors 7 and 8. d) The land cost per unit was based on entitled projects located on sites larger than 1/3 acre that were sold along major commercial corridors, including San Pablo Avenue, University Avenue, and Shattuck Avenue. e) Hard costs includes all direct expenses associated with construction, including materials, labor, and equipment, required to construct the structure, excluding site work and parking, which are calculated separately. This figure captures the costs associated with Berkeley's Hard Hat and Bird Safe Building policies. This also incorporates an adjustment from the baseline market-rate project to reflect added costs associated with affordable projects, including prevailing wages. f) Soft costs include indirect expenses like design, insurance, and city fees, based on the City of Berkeley’s fee calculator. The soft-to-hard cost ratio generally aligns with the assumptions in Strategic Economics’ April 2024 report, Berkeley In-Lieu Fee and Housing Policies Economic Feasibility Analysis.
g) The current impact fees that apply to residential projects are:
Berkeley Unified School District fee
1% Arts Fee
The Affordable Housing In-Lieu Fee is available if a developer chooses to partially satisfy the inclusionary requirement by paying a fee. h) Capitalized reserves for a rental project are funds set aside to cover unforeseen costs during lease-up and operations. A standard reserve amount is equivalent to 3 to 6 months of operating expenses, including debt service. i) The developer fee was calculated using the CTCAC Developer Fee Calculator provided by the State Treasurer's Office, based on an eligible basis that includes hard and soft costs, and assuming financing through 4% tax credits. For projects deemed infeasible by the market, this reflects the fee that affordable housing developers would expect to undertake this type of project. j) An adjustment is made to reflect the higher operating costs in affordable projects, such as expenses related to regulatory compliance and reserves. This adjustment is applied when affordable units comprise more than 50% of the units or when the average AMI is below 70% AMI. k) Mixed income projects may qualify for a partial property tax exemption under California's Revenue and Taxation Code Section 214(g).
The exemption is prorated based on the percentage of units restricted to low-income households. A community land trust that owns the land can also qualify for a property tax exemption with higher income limits. l) This represents the funding needed to bridge the gap between the development cost and the supportable debt. Traditional market-rate projects rely on equity to close this gap, while affordable projects depend on tax-credit equity and other soft funding sources.
Sources: The Housing Workshop; Urban Math, 2025.
96 Attachment 2
Appendix C8: New Construction Rental - Predominantly Affordable This assumes an even distribution of units at 30% AMI, 50% AMI, 80% AMI, and market-rate rents. All townhomes will be rented at market rates to cross-subsidize the affordable units.
Development Program and Assumptions
Option B:
Predominantly
Affordable Development Costs
Option B:
Predominantly
Affordable
Site Size (sf) 23,527 Land 5,820,000$
Total Number of Units 97 Construction and Soft Costs Affordable Units Required (a) 80% 78 Site Work 588,175$ Number of Market Rate Units (b) 20% 19 Hard Costs - Residential 42,375,843$ Dwelling Units/Acre 180 Hard Costs - Parking 2,940,000$ Units (c) Soft Costs 10,098,884$
Studios 49 School Fee 421,205$
1-Bedroom 20 Art Fee 367,232$
2-Bedroom 18 Subtotal Const Costs Before Financing 56,791,339$ 3-Bedroom (Townhouses) 10 Financing Costs
Average Unit Size 615 Points 511,122$
Net Residential Space (sf) 59,655 Construction Period Interest 3,577,854$ Common Area 21,816 Subtotal Financing Costs 4,088,976$ Total Residential Space (sf) 81,471 Capitalized Reserves 1,131,392$ Total Open Space (sf) 4,292 Developer Fee 2,500,000$ Number of Parking Spaces 49 Total Development Costs 70,331,707$ Parking spaces per unit 0.51 Total Development Cost per Unit (inc. land) 725,069$ Development Costs Total Development Cost per Unit (exc. land) 665,069$ Land per Residential Unit (d) 60,000$
Land per Site sf 247$ Development Feasibility and Financing Construction Type Type 3 Net Operating Income (NOI) 1,712,357$ Site Work (per sq.ft. of site) 25$ Capitalized Value 38,052,371$ Hard Costs - Res (e) 518$ Less Total Development Cost (70,331,707)$ Hard Costs - Open Space 50$ Profit / (Loss) (32,279,336)$ Parking Costs (per podium space) 60,000$ Return on Cost -45.9% Soft Costs exc. Fees (as % of hard) (f) 22.0% Feasible for Market-Rate Project? (k) No Impact Fees (g) Sources of Financing
BUSD School Fee 5.17$ Supportable Loan 20,495,914$ 1% Arts Fee 0.8% Gap Financing (l) 49,835,793$
Financing Costs (Construction) Subsidy per Affordable Unit 638,920$ Loan to Cost Ratio 60.0% Traditional Capital Stack to Fill Gap Interest Rate 7.0% Tax Credit Equity 20,643,746$
Loan Fees 1.5% City HTF 15,600,000$
Construction Period (months) 30 Other 13,592,047$
Avg. Outstanding Bal During Construction 60.0%
Financing Costs (Permanent) Operations
Interest Rate 6.0% Stabilized Gross Income 2,616,984$
Debt Coverage Ratio (Perm) 1.15 Less: Vacancy (130,849)$ Capitalized Reserve (# of months) (h) 6 Less: Op Expenses excluding Property Taxes (652,200)$ Nonprofit Developer Fee (i) 2,500,000$ Less: Property Taxes (k) (121,578)$ Market Rents Net Operating Income (NOI) 1,712,357$
Studios 2,850$
1-Bedroom 3,500$ Affordability Metrics
2-Bedroom 4,400$ Average Project AMI 71%
3-Bedroom (Townhouses) 6,800$ % of Units Serving ELI Households 27% Operations % of Units Serving VLI Households 27%
Vacancy 5.0% % of Units Serving Low Households 27%
OpEx per unit (exc. prop taxes) 6,000$ % of Units Serving Moderate Households 0% OpEx Adjustment for Affordable Units (j) 15.0% % of Units Serving Above Mod Households 20% Property Tax Rate (k) 1.20% % Units Serving <=80% AMI Households 80% Cap Rate 4.50%
97 Attachment 2
Notes:
a) The inclusionary requirement applies to new residential developments above 5,000 square feet and can be met through a combination of providing units and paying a prorated fee This proforma assumes developers will meet the full affordable housing requirement on-site. b) The distribution of affordable and market-rate units by bedroom size is as follows:
Affordable Market Market Rate AMIs
Studios 42 7 105%
1-Bedroom 19 1 120%
2-Bedroom 17 1 125%
3-Bedroom 10 170%
Total 78 19
c) The development program is based on plans submitted in 2024 and includes stacked flats with an at-grade podium garage. The project received a 50% density bonus and includes a mix of stacked flats on floors 2 through 6, and two-story townhouses on floors 7 and 8. d) The land cost per unit was based on entitled projects located on sites larger than 1/3 acre that were sold along major commercial corridors, including San Pablo Avenue, University Avenue, and Shattuck Avenue. e) Hard costs includes all direct expenses associated with cosntruction, including materials, labor, and equipment, required to construct the structure, excluding site work and parking, which are calculated separately. This figure captures the costs associated with Berkeley's Hard Hat and Bird Safe Building policies. This also incorporates an adjustment from the baseline market-rate project to reflect added costs associated with affordable projects, including prevailing wages. f) Soft costs include indirect expenses like design, insurance, and city fees, based on the City of Berkeley’s fee calculator. The soft-to-hard cost ratio generally aligns with the assumptions in Strategic Economics’ April 2024 report, Berkeley In-Lieu Fee and Housing Policies Economic Feasibility Analysis.
g) The current impact fees that apply to residential projects are:
Berkeley Unified School District fee
1% Arts Fee
The Affordable Housing In-Lieu Fee is available if a developer chooses to partially satisfy the inclusionary requirement by paying a fee. h) Capitalized reserves for a rental project are funds set aside to cover unforeseen costs during lease-up and operations. A standard reserve amount is equivalent to 3 to 6 months of operating expenses, including debt service. i) The developer fee was calculated using the CTCAC Developer Fee Calculator provided by the State Treasurer's Office, based on an eligible basis that includes hard and soft costs, and assuming financing through 4% tax credits. For projects deemed infeasible by the market, this reflects the fee that affordable housing developers would expect to undertake this type of project. j) An adjustment is made to reflect the higher operating costs in affordable projects, such as expenses related to regulatory compliance and reserves. This adjustment is applied when affordable units comprise more than 50% of the units or when the average AMI is below 70% AMI. k) Mixed income projects may qualify for a partial property tax exemption under California's Revenue and Taxation Code Section 214(g).
The exemption is prorated based on the percentage of units restricted to low-income households. A community land trust that owns the land can also qualify for a property tax exemption with higher income limits. l) This represents the funding needed to bridge the gap between the development cost and the supportable debt. Traditional market-rate projects rely on equity to close this gap, while affordable projects depend on tax-credit equity and other soft funding sources.
Sources: The Housing Workshop; Urban Math, 2025.
98 Attachment 2
Appendix C9: New Construction Rental - 100% Affordable
This proforma models a 100% affordable housing project with an equal distribution of units at 30% AMI, 40% AMI, 50% AMI, and 60% AMI.
There are no market-rate units in this scenario.
Development Program and Assumptions
Option C:
100% Affordable Development Costs
Option C:
100% Affordable
Site Size (sf) 23,527 Land 5,820,000$
Total Number of Units 97 Construction and Soft Costs Affordable Units Required (a) (b) 100% 97 Site Work 588,175$ Number of Market Rate Units 0% - Hard Costs - Residential 42,375,843$ Dwelling Units/Acre 180 Hard Costs - Parking 2,940,000$ Units (c) Soft Costs 10,098,884$
Studios 49 School Fee 421,205$
1-Bedroom 20 Art Fee 367,232$
2-Bedroom 18 Subtotal Const Costs Before Financing 56,791,339$ 3-Bedroom (Townhouses) 10 Financing Costs Average Unit Size 615 Points 511,122$ Net Residential Space (sf) 59,655 Construction Period Interest 3,577,854$ Common Area 21,816 Subtotal Financing Costs 4,088,976$ Total Residential Space (sf) 81,471 Capitalized Reserves 699,190$ Total Open Space (sf) 4,292 Developer Fee 2,500,000$ Number of Parking Spaces 49 Total Development Costs 69,899,505$ Parking spaces per unit 0.51 Total Development Cost per Unit (inc. land) 720,613$ Development Costs Total Development Cost per Unit (exc. land) 660,613$ Land per Residential Unit (d) 60,000$
Land per Site sf 247$ Development Feasibility and Financing Construction Type Type 3 Net Operating Income (NOI) 838,441$ Site Work (per sq.ft. of site) 25$ Capitalized Value 18,632,027$ Hard Costs - Res (e) 518$ Less Total Development Cost (69,899,505)$ Hard Costs - Open Space 50$ Profit / (Loss) (51,267,478)$ Parking Costs (per podium space) 60,000$ Return on Cost -73.3% Soft Costs exc. Fees (as % of hard) (f) 22.0% Feasible for Market-Rate Project? (k) No Impact Fees (g) Sources of Financing
BUSD School Fee 5.17$ Supportable Loan 10,035,654$ 1% Arts Fee 0.8% Gap Financing (l) 59,863,851$
Financing Costs (Construction) Subsidy per Affordable Unit 617,153$ Loan to Cost Ratio 60.0% Traditional Capital Stack to Fill Gap -$ Interest Rate 7.0% Tax Credit Equity 25,631,802$
Loan Fees 1.5% City HTF 19,400,000$
Construction Period (months) 30 Other 14,832,049$ Avg. Outstanding Bal During Construction 60.0%
Financing Costs (Permanent) Operations
Interest Rate 6.0% Stabilized Gross Income 1,587,096$
Debt Coverage Ratio (Perm) 1.15 Less: Vacancy (79,355)$ Capitalized Reserve (# of months) (h) 6 Less: Op Expenses (669,300)$ Nonprofit Developer Fee (i) 2,500,000$ Less: Property Taxes (k) -$ Market Rents Net Operating Income (NOI) 838,441$
Studios 2,850$
1-Bedroom 3,500$ Affordability Metrics
2-Bedroom 4,400$ Average Project AMI 45% 3-Bedroom (Townhouses) 6,800$ % of Units Serving ELI Households 26% Operations % of Units Serving VLI Households 49%
Vacancy 5.0% % of Units Serving Low Households 25%
OpEx per unit (exc. prop taxes) 6,000$ % of Units Serving Moderate Households 0% OpEx Adjustment for Affordable Units (j) 15.0% % of Units Serving Above Mod Households 0% Property Tax Rate (k) 1.20% % Units Serving <=80% AMI Households 100% Cap Rate 4.50%
99 Attachment 2
Notes:
a) This proforma models a 100% affordable housing project, with all units available to households earning 60% of AMI or less. b) The distribution of affordable units by bedroom size is as follows:
Affordable Market
Studios 49
1-Bedroom 20
2-Bedroom 18
3-Bedroom 10 -
Total 97 -
c) The development program is based on plans submitted in 2024 and includes stacked flats with an at-grade podium garage. The project received a 50% density bonus and includes a mix of stacked flats on floors 2 through 6, and two-story townhouses on floors 7 and 8. d) The land cost per unit was based on entitled projects located on sites larger than 1/3 acre that were sold along major commercial corridors, including San Pablo Avenue, University Avenue, and Shattuck Avenue. e) Hard costs includes all direct expenses associated with construction, including materials, labor, and equipment, required to construct the structure, excluding site work and parking, which are calculated separately. This figure captures the costs associated with Berkeley's Hard Hat and Bird Safe Building policies. This also incorporates an adjustment from the baseline market-rate project to reflect added costs associated with affordable projects, including prevailing wages. f) Soft costs include indirect expenses like design, insurance, and city fees, based on the City of Berkeley’s fee calculator. The soft-to-hard cost ratio generally aligns with the assumptions in Strategic Economics’ April 2024 report, Berkeley In-Lieu Fee and Housing Policies Economic Feasibility Analysis.
g) The current impact fees that apply to residential projects are:
Berkeley Unified School District fee
1% Arts Fee
The Affordable Housing In-Lieu Fee is available if a developer chooses to partially satisfy the inclusionary requirement by paying a fee. h) Capitalized reserves for a rental project are funds set aside to cover unforeseen costs during lease-up and operations. A standard reserve amount is equivalent to 3 to 6 months of operating expenses, including debt service. i) The developer fee was calculated using the CTCAC Developer Fee Calculator provided by the State Treasurer's Office, based on an eligible basis that includes hard and soft costs, and assuming financing through 4% tax credits. For projects deemed infeasible by the market, this reflects the fee that affordable housing developers would expect to undertake this type of project. j) An adjustment is made to reflect the higher operating costs in affordable projects, such as expenses related to regulatory compliance and reserves. This adjustment is applied when affordable units comprise more than 50% of the units or when the average AMI is below 70% AMI. k) This project qualifies for a 100% property tax exemption. l) This represents the funding needed to bridge the gap between the development cost and the supportable debt. Traditional market-rate projects rely on equity to close this gap, while affordable projects depend on tax-credit equity and other soft funding sources.
Sources: The Housing Workshop; Urban Math, 2025.
100
Attachment 2
Appendix C10: New Construction Rental - Half & Half (Enhanced) This assumes 50% of units will be affordable, with 10% serving 50% AMI and 40% serving 80% AMI households. The remaining will be market-rate. All townhomes will be rented at market rents to cross-subsidize. This project could qualify for SB 35/SB 423 streamlining.
This version assumes no land cost, lower construction costs, and a lower permanent financing rate compared to the original scenario.
Development Program and Assumptions
Option A:
Half & Half
with Lower Costs Development Costs
Option A:
Half & Half
with Lower Costs
Site Size (sf) 23,527 Land
Total Number of Units 97 Construction and Soft Costs Affordable Units Required (a) 50% 49 Site Work 588,175$ Number of Market Rate Units (b) 50% 48 Hard Costs - Residential 38,913,325$ Dwelling Units/Acre 180 Hard Costs - Parking 2,940,000$ Units (c) Soft Costs 9,337,130$
Studios 49 School Fee 421,205$
1-Bedroom 20 Art Fee 339,532$
2-Bedroom 18 Subtotal Const Costs Before Financing 52,539,367$ 3-Bedroom (Townhouses) 10 Financing Costs
Average Unit Size 615 Points 472,854$
Net Residential Space (sf) 59,655 Construction Period Interest 3,309,980$ Common Area 21,816 Subtotal Financing Costs 3,782,834$ Total Residential Space (sf) 81,471 Capitalized Reserves 1,541,554$ Total Open Space (sf) 4,292 Developer Fee 2,500,000$ Number of Parking Spaces 49 Total Development Costs 60,363,755$ Parking spaces per unit 0.51 Total Development Cost per Unit (inc. land) 622,307$ Development Costs Total Development Cost per Unit (exc. land) 622,307$ Land per Residential Unit (d)
Land per Site sf -$ Development Feasibility and Financing Construction Type Type 3 Net Operating Income (NOI) 2,523,058$ Site Work (per sq.ft. of site) 25$ Capitalized Value 56,067,949$ Hard Costs - Res (e) 475$ Less Total Development Cost (60,363,755)$ Hard Costs - Open Space 50$ Profit / (Loss) (4,295,806)$ Parking Costs (per podium space) 60,000$ Return on Cost -7.1% Soft Costs exc. Fees (as % of hard) (f) 22.0% Feasible for Market-Rate Project? (k) No Impact Fees (g) Sources of Financing
BUSD School Fee 5.17$ Supportable Loan 43,002,648$ 1% Arts Fee 0.8% Gap Financing (l) 17,361,108$
Financing Costs (Construction) Traditional Capital Stack to Fill Gap Loan to Cost Ratio 60.0% Tax Credit Equity 12,072,751$
Interest Rate 7.0% City HTF 5,288,357$
Loan Fees 1.5% Other -$
Construction Period (months) 30
Avg. Outstanding Bal During Construction 60.0% Operations Financing Costs (Permanent) Stabilized Gross Income 3,591,792$ Interest Rate 3.0% Less: Vacancy (179,590)$
Debt Coverage Ratio (Perm) 1.15 Less: Op Expenses excluding Property Taxes (582,000)$ Capitalized Reserve (# of months) (h) 6 Less: Property Taxes (k) (307,145)$ Nonprofit Developer Fee (i) 2,500,000$ Net Operating Income (NOI) 2,523,058$ Market Rents
Studios 2,850$ Affordability Metrics
1-Bedroom 3,500$ Average Project AMI 99%
2-Bedroom 4,400$ % of Units Serving ELI Households 0% 3-Bedroom (Townhouses) 6,800$ % of Units Serving VLI Households 9% Operations % of Units Serving Low Households 41%
Vacancy 5.0% % of Units Serving Moderate Households 0%
OpEx per market unit (exc. prop taxes) 6,000$ % of Units Serving Above Mod Households 49% OpEx Adjustment for Affordable Units (j) 15.0% % Units Serving <=80% AMI Households 51% Property Tax Rate (k) 1.20%
Cap Rate 4.50%
101
Attachment 2
Notes:
a) The inclusionary requirement applies to new residential developments above 5,000 square feet and can be met through a combination of providing units and paying a prorated fee This proforma assumes developers will meet the full affordable housing requirement on-site. b) The distribution of affordable and market-rate units by bedroom size is as follows:
Affordable Market Market Rate AMIs
Studios 26 23 105%
1-Bedroom 12 8 120%
2-Bedroom 11 7 125%
3-Bedroom 10 170%
Total 49 48
c) The development program is based on plans submitted in 2024 and includes stacked flats with an at-grade podium garage. The project received a 50% density bonus and includes a mix of stacked flats on floors 2 through 6, and two-story townhouses on floors 7 and 8. d) The land cost per unit was based on entitled projects located on sites larger than 1/3 acre that were sold along major commercial corridors, including San Pablo Avenue, University Avenue, and Shattuck Avenue. e) Hard costs includes all direct expenses associated with construction, including materials, labor, and equipment, required to construct the structure, excluding site work and parking, which are calculated separately. This figure captures the costs associated with Berkeley's Hard Hat and Bird Safe Building policies. This version includes a downward adjustment to account for cost-saving strategies such as smaller unit sizes, reduced parking, modular construction, and similar approaches. f) Soft costs include indirect expenses like design, insurance, and city fees, based on the City of Berkeley’s fee calculator. The soft-to-hard cost ratio generally aligns with the assumptions in Strategic Economics’ April 2024 report, Berkeley In-Lieu Fee and Housing Policies Economic Feasibility Analysis.
g) The current fees that apply to residential projects are:
Berkeley Unified School District fee
1% Arts Fee
The Affordable Housing In-Lieu Fee is available if a developer chooses to partially satisfy the inclusionary requirement by paying a fee. h) Capitalized reserves for a rental project are funds set aside to cover unforeseen costs during lease-up and operations. A standard reserve amount is equivalent to 3 to 6 months of operating expenses, including debt service. i) The developer fee was calculated using the CTCAC Developer Fee Calculator provided by the State Treasurer's Office, based on an eligible basis that includes hard and soft costs, and assuming financing through 4% tax credits. For projects deemed infeasible by the market, this reflects the fee that affordable housing developers would expect to undertake this type of project. j) An adjustment is made to reflect the higher operating costs in affordable projects, such as expenses related to regulatory compliance and reserves. This adjustment is applied when affordable units comprise more than 50% of the units or when the average AMI is below 70% AMI. k) Mixed income projects may qualify for a partial property tax exemption under California's Revenue and Taxation Code Section 214(g).
The exemption is prorated based on the percentage of units restricted to low-income households. A community land trust that owns the land can also qualify for a property tax exemption with higher income limits. The property taxes in this enhanced version are held constant and match the original scenario. This approach ensures that differences in outcomes reflect the impact of the other factors. l) This represents the funding needed to bridge the gap between the development cost and the supportable debt. Traditional market-rate projects rely on equity to close this gap, while affordable projects depend on tax-credit equity and other soft funding sources.
Sources: The Housing Workshop; Urban Math, 2025.
102
Attachment 2
Appendix C11: New Construction Rental - Predominantly Affordable (Enhanced) This assumes an even distribution of units at 30% AMI, 50% AMI, 80% AMI, and market-rate rents. All townhomes will be rented at market rates to cross-subsidize the affordable units. This enhanced version assumes no land cost, lower construction costs, and a lower permanent financing rate compared to the original scenario.
Development Program and Assumptions
Option B:
Predominantly
Affordable with
Lower Costs Development Costs
Option B:
Predominantly
Affordable with
Lower Costs
Site Size (sf) 23,527 Land -$
Total Number of Units 97 Construction and Soft Costs
Affordable Units Required (a) 80% 78 Site Work 588,175$ Number of Market Rate Units (b) 20% 19 Hard Costs - Residential 38,913,325$ Dwelling Units/Acre 180 Hard Costs - Parking 2,940,000$ Units (c) Soft Costs 9,337,130$
Studios 49 School Fee 421,205$
1-Bedroom 20 Art Fee 339,532$
2-Bedroom 18 Subtotal Const Costs Before Financing 52,539,367$ 3-Bedroom (Townhouses) 10 Financing Costs
Average Unit Size 615 Points 472,854$
Net Residential Space (sf) 59,655 Construction Period Interest 3,309,980$ Common Area 21,816 Subtotal Financing Costs 3,782,834$ Total Residential Space (sf) 81,471 Capitalized Reserves 1,131,392$ Total Open Space (sf) 4,292 Developer Fee 2,500,000$ Number of Parking Spaces 49 Total Development Costs 59,953,593$ Parking spaces per unit 0.51 Total Development Cost per Unit (inc. land) 618,078$ Development Costs Total Development Cost per Unit (exc. land) 618,078$ Land per Residential Unit (d)
Land per Site sf -$ Development Feasibility and Financing Construction Type Type 3 Net Operating Income (NOI) 1,712,357$ Site Work (per sq.ft. of site) 25$ Capitalized Value 38,052,371$ Hard Costs - Res (e) 475$ Less Total Development Cost (59,953,593)$ Hard Costs - Open Space 50$ Profit / (Loss) (21,901,222)$ Parking Costs (per podium space) 60,000$ Return on Cost -36.5% Soft Costs exc. Fees (as % of hard) (f) 22.0% Feasible for Market-Rate Project? (k) No Impact Fees (g) Sources of Financing
BUSD School Fee 5.17$ Supportable Loan 29,185,171$ 1% Arts Fee 0.8% Gap Financing (l) 30,768,422$
Financing Costs (Construction) Subsidy per Affordable Unit 394,467$ Loan to Cost Ratio 60.0% Traditional Capital Stack to Fill Gap Interest Rate 7.0% Tax Credit Equity 19,185,150$
Loan Fees 1.5% City HTF 11,583,272$
Construction Period (months) 30 Other -$
Avg. Outstanding Bal During Construction 60.0%
Financing Costs (Permanent) Operations
Interest Rate 3.0% Stabilized Gross Income 2,616,984$
Debt Coverage Ratio (Perm) 1.15 Less: Vacancy (130,849)$ Capitalized Reserve (# of months) (h) 6 Less: Op Expenses excluding Property Taxes (652,200)$ Nonprofit Developer Fee (i) 2,500,000$ Less: Property Taxes (k) (121,578)$ Market Rents Net Operating Income (NOI) 1,712,357$
Studios 2,850$
1-Bedroom 3,500$ Affordability Metrics
2-Bedroom 4,400$ Average Project AMI 71%
3-Bedroom (Townhouses) 6,800$ % of Units Serving ELI Households 27% Operations % of Units Serving VLI Households 27%
Vacancy 5.0% % of Units Serving Low Households 27%
OpEx per unit (exc. prop taxes) 6,000$ % of Units Serving Moderate Households 0% OpEx Adjustment for Affordable Units (j) 15.0% % of Units Serving Above Mod Households 20% Property Tax Rate (k) 1.20% % Units Serving <=80% AMI Households 80% Cap Rate 4.50%
103
Attachment 2
Notes:
a) The inclusionary requirement applies to new residential developments above 5,000 square feet and can be met through a combination of providing units and paying a prorated fee This proforma assumes developers will meet the full affordable housing requirement on-site. b) The distribution of affordable and market-rate units by bedroom size is as follows:
Affordable Market Market Rate AMIs
Studios 42 7 105%
1-Bedroom 19 1 120%
2-Bedroom 17 1 125%
3-Bedroom 10 170%
Total 78 19
c) The development program is based on plans submitted in 2024 and includes stacked flats with an at-grade podium garage. The project received a 50% density bonus and includes a mix of stacked flats on floors 2 through 6, and two-story townhouses on floors 7 and 8. d) The land cost per unit was based on entitled projects located on sites larger than 1/3 acre that were sold along major commercial corridors, including San Pablo Avenue, University Avenue, and Shattuck Avenue. e) Hard costs includes all direct expenses associated with construction, including materials, labor, and equipment, required to construct the structure, excluding site work and parking, which are calculated separately. This figure captures the costs associated with Berkeley's Hard Hat and Bird Safe Building policies. This version includes a downward adjustment to account for cost-saving strategies such as smaller unit sizes, reduced parking, modular construction, and similar approaches. f) Soft costs include indirect expenses like design, insurance, and city fees, based on the City of Berkeley’s fee calculator. The soft-to-hard cost ratio generally aligns with the assumptions in Strategic Economics’ April 2024 report, Berkeley In-Lieu Fee and Housing Policies Economic Feasibility Analysis.
g) The current fees that apply to residential projects are:
Berkeley Unified School District fee
1% Arts Fee
The Affordable Housing In-Lieu Fee is available if a developer chooses to partially satisfy the inclusionary requirement by paying a fee. h) Capitalized reserves for a rental project are funds set aside to cover unforeseen costs during lease-up and operations. A standard reserve amount is equivalent to 3 to 6 months of operating expenses, including debt service. i) The developer fee was calculated using the CTCAC Developer Fee Calculator provided by the State Treasurer's Office, based on an eligible basis that includes hard and soft costs, and assuming financing through 4% tax credits. For projects deemed infeasible by the market, this reflects the fee that affordable housing developers would expect to undertake this type of project. j) An adjustment is made to reflect the higher operating costs in affordable projects, such as expenses related to regulatory compliance and reserves. This adjustment is applied when affordable units comprise more than 50% of the units or when the average AMI is below 70% AMI. k) Mixed income projects may qualify for a partial property tax exemption under California's Revenue and Taxation Code Section 214(g).
The exemption is prorated based on the percentage of units restricted to low-income households. A community land trust that owns the land can also qualify for a property tax exemption with higher income limits. The property taxes in this enhanced version are held constant and match the original scenario. This approach ensures that differences in outcomes reflect the impact of the other factors. l) This represents the funding needed to bridge the gap between the development cost and the supportable debt. Traditional market-rate projects rely on equity to close this gap, while affordable projects depend on tax-credit equity and other soft funding sources.
Sources: The Housing Workshop; Urban Math, 2025.
104
Attachment 2
Appendix C12: New Construction Rental - 100% Affordable (Enhanced) This proforma models a 100% affordable housing project with an equal distribution of units at 30% AMI, 40% AMI, 50% AMI, and 60% AMI.
There are no market-rate units in this scenario. This enhanced version assumes no land cost, lower construction costs, and a lower permanent financing rate compared to the original scenario.
Development Program and Assumptions
Option C:
100% Affordable with
Lower Costs Development Costs
Option C:
100% Affordable with
Lower Costs
Site Size (sf) 23,527 Land -$
Total Number of Units 97 Construction and Soft Costs Affordable Units Required (a) (b) 100% 97 Si te Work 588,175$ Number of Market Rate Units 0% - Har d Costs - Residential 38,913,325$ Dwelling Units/Acre 180 Hard Costs - Parking 2,940,000$ Units (c) Soft Costs 9,337,130$
Studios 49 School Fee 421,205$ 1-Bedroom 20 Art Fee 339,532$ 2-Bedroom 18 Subtotal Const Costs Before Financing 52,539,367$ 3-Bedroom (Townhouses) 10 Financing Costs Average Unit Size 615 Points 472,854$ Net Residential Space (sf) 59,655 Construction Period Interest 3,309,980$ Common Area 21,816 Subtotal Financing Costs 3,782,834$ Total Residential Space (sf) 81,471 Capitalized Reserves 699,190$ Total Open Space (sf) 4,292 Developer Fee 2,500,000$ Number of Parking Spaces 49 Total Development Costs 59,521,391$ Parking spaces per unit 0.51 Total Development Cost per Unit (inc. land) 613,623$ Development Costs Total Development Cost per Unit (exc. land) 613,623$ Land per Residential Unit (d)
Land per Site sf -$ Development Feasibility and Financing Construction Type Type 3 Net Operating Income (NOI) 838,441$ Site Work (per sq.ft. of site) 25$ Capitalized Value 18,632,027$ Hard Costs - Res (e) 475$ Less Total Development Cost (59,521,391)$ Hard Costs - Open Space 50$ Profit / (Loss) (40,889,364)$ Parking Costs (per podium space) 60,000$ Return on Cost -68.7% Soft Costs exc. Fees (as % of hard) (f) 22.0% Feasible for Market-Rate Project? (k) No Impact Fees (g) Sources of Financing
BUSD School Fee 5.17$ Supportable Loan 14,290,276$ 1% Arts Fee 0.8% Gap Financing (l) 45,231,115$
Financing Costs (Construction) Subsidy per Affordable Unit 466,300$ Loan to Cost Ratio 60.0% Traditional Capital Stack to Fill Gap -$ Interest Rate 7.0% Tax Credit Equity 23,808,556$
Loan Fees 1.5% City HTF 19,400,000$
Construction Period (months) 30 Other 2,022,559$ Avg. Outstanding Bal During Construction 60.0%
Financing Costs (Permanent) Operations
Interest Rate 3.0% Stabilized Gross Income 1,587,096$
Debt Coverage Ratio (Perm) 1.15 Less: Vacancy (79,355)$ Capitalized Reserve (# of months) (h) 6 Less: Op Expenses (669,300)$ Nonprofit Developer Fee (i) 2,500,000$ Less: Property Taxes (k) -$ Market Rents Net Operating Income (NOI) 838,441$
Studios 2,850$
1-Bedroom 3,500$ Affordability Metrics 2-Bedroom 4,400$ Average Project AMI 45% 3-Bedroom (Townhouses) 6,800$ % of Units Serving ELI Households 26% Operations % of Units Serving VLI Households 49%
Vacancy 5.0% % of Units Serving Low Households 25%
OpEx per unit (exc. prop taxes) 6,000$ % of Units Serving Moderate Households 0% OpEx Adjustment for Affordable Units (j) 15.0% % of Units Serving Above Mod Households 0% Property Tax Rate (k) 1.20% % Units Serving <=80% AMI Households 100% Cap Rate 4.50%
105
Attachment 2
Notes:
a) This proforma models a 100% affordable housing project, with all units available to households earning 60% of AMI or less. b) The distribution of affordable units by bedroom size is as follows:
Affordable Market
Studios 49
1-Bedroom 20
2-Bedroom 18
3-Bedroom 10 -
Total 97 -
c) The development program is based on plans submitted in 2024 and includes stacked flats with an at-grade podium garage. The project received a 50% density bonus and includes a mix of stacked flats on floors 2 through 6, and two-story townhouses on floors 7 and 8. d) The land cost per unit was based on entitled projects located on sites larger than 1/3 acre that were sold along major commercial corridors, including San Pablo Avenue, University Avenue, and Shattuck Avenue. e) Hard costs includes all direct expenses associated with construction, including materials, labor, and equipment, required to construct the structure, excluding site work and parking, which are calculated separately. This figure captures the costs associated with Berkeley's Hard Hat and Bird Safe Building policies. This version includes a downward adjustment to account for cost-saving strategies such as smaller unit sizes, reduced parking, modular construction, and similar approaches. f) Soft costs include indirect expenses like design, insurance, and city fees, based on the City of Berkeley’s fee calculator. The soft-to-hard cost ratio generally aligns with the assumptions in Strategic Economics’ April 2024 report, Berkeley In-Lieu Fee and Housing Policies Economic Feasibility Analysis.
g) The current fees that apply to residential projects are:
Berkeley Unified School District fee
1% Arts Fee
The Affordable Housing In-Lieu Fee is available if a developer chooses to partially satisfy the inclusionary requirement by paying a fee. h) Capitalized reserves for a rental project are funds set aside to cover unforeseen costs during lease-up and operations. A standard reserve amount is equivalent to 3 to 6 months of operating expenses, including debt service. i) The developer fee was calculated using the CTCAC Developer Fee Calculator provided by the State Treasurer's Office, based on an eligible basis that includes hard and soft costs, and assuming financing through 4% tax credits. For projects deemed infeasible by the market, this reflects the fee that affordable housing developers would expect to undertake this type of project. j) An adjustment is made to reflect the higher operating costs in affordable projects, such as expenses related to regulatory compliance and reserves. This adjustment is applied when affordable units comprise more than 50% of the units or when the average AMI is below 70% AMI. k) This project qualifies for a 100% property tax exemption. l) This represents the funding needed to bridge the gap between the development cost and the supportable debt. Traditional market-rate projects rely on equity to close this gap, while affordable projects depend on tax-credit equity and other soft funding sources.
Sources: The Housing Workshop; Urban Math, 2025.
106
Attachment 2
107
Appendix D: Additional Resources
Aiken, C., Murphy, M., & Raetz, H. (2024, October). The Emerging Spectrum of Government- Led and Publicly-Owned Housing Development Models. Retrieved from NYU Furman Center: https://furmancenter.org/files/The_Emerging_Spectrum_of_Government- Led_and_Publicly-Owned_Housing_Development_Models_V5_(2).pdf Aiken, C., Raetz, H., Murphy, M., & Bodulovic, T. (2024, October). Publicly Driven Development and Ownership of Housing: A Feasibility Study for Rhode Island. Retrieved from NYU Furman Center:
https://furmancenter.org/files/NYUFumanCenter_PublicDevelopment_FinalDraft_8-22- 24_(1).pdf
Alliance for Housing Justice. (2024). Series of White Papers on Social Housing. Retrieved from Social Housing: https://www.allianceforhousingjustice.org/social-housing California Housing Corporation. (2021). The Case for a Public Sector Housing Developer.
Retrieved from East Bay for Everyone - Social Housing:
https://eastbayforeveryone.org/socialhousing/
Carlson, H. J., & Baiocchi, G. (2023, June 30). Social Housing: How a New Generation of Activists are Reinventing Housing. Retrieved from Shelterforce:
https://shelterforce.org/2023/06/30/social-housing-how-a-new-generation-of-activists- are-reinventing-housing/
Center for American Progress. (2024, September 19). A New Vision for Social Housing in America. Retrieved from Center for American Progress:
https://www.americanprogress.org/article/a-new-vision-for-social-housing-in-america/ Dwell. (2024, August 7). A New Bill Would Reimagine Public Housing in Los Angeles. Retrieved from Dwell: https://www.dwell.com/article/a-new-bill-would-reimagine-public-housing-in- los-angeles-7eb3a19f
People's Action. (2019). A National Homes Guarantee: Briefing Book. Retrieved from People's Action: https://homesguarantee.com/wp-content/uploads/Homes-Guarantee-_-Briefing- Book.pdf
PolicyLink, Local Progress Impact Lab, PowerSwitch Action. (2025, January). Housing the People: How Local Governments are Building Social Housing Solutions for Public Good.
Retrieved from Social Housing Toolkit:
https://policylink.widen.net/s/wlphxh7qmf/social_housing_toolkit_jan2025 Right to the City. (2018). Communities Over Commoditites. Retrieved from Homes for All Campaign:
https://drive.google.com/file/d/1chGXRKcJBo8pGQfGZ0fqUvxGIFp0ewgm/view San Francisco Budget and Legislative Analyst Office. (2024, December 14). Policy Analysis Report: Financial Feasibility of Social Housing in San Francisco. Retrieved from SF Attachment 2
108
Board of Supervisors:
https://image.bos.sfgov.org/lib/fe3f15707564077d741374/m/1/6855a2a8-14ce-4fb3- ab29-19f13b43c88e.pdf
The Center for Public Democracy & Partners, Alliance for Housing Justice. (2024). Building Our Future: Grassroots Reflections on Social Housing. Retrieved from Alliance for Housing Justice: https://www.allianceforhousingjustice.org/social-housing/building-our-future- report
The Othering and Belonging Institute of UC Berkeley. (2024). Social Housing in California:
Reinvigorating Housing Investment for the Social Good. Retrieved from https://belonging.berkeley.edu/social-housing-california Von Hoffman, A. (2024, October 24). Can Public Housing Play a Role in a New American Social Housing System? Retrieved from Joint Center for Housing Studies of Harvard University:
https://www.jchs.harvard.edu/blog/can-public-housing-play-role-new-american-social- housing-system
Attachment 2
Attachment 3
Attachment 3