City Council Report
City Council Meeting: January 11, 2022
Agenda Item: 8.A
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To: Mayor and City Council
From: Andy Agle, Director, Community Services Department, Housing and Human Services
Subject: Adoption of CEQA Findings and Authorization to enter into Agreement with EAH, Inc. for the 1318 Fourth Street Affordable Housing Development Recommended Action
Authorize the City Manager to negotiate and execute an Exclusive Negotiating Agreement with EAH, Inc. for a mixed-use, affordable housing development on the Cityowned site located at 1318-20 Fourth Street and adopt the CEQA Findings in this Staff Report under “Environmental Status”.
Executive Summary
As part of the City’s longstanding efforts to encourage affordable housing development on City-owned land, on April 9, 2019, Council authorized the issuance of a Request for Proposals to develop affordable housing on the City-owned site located at 1318-20 Fourth Street. An evaluation committee composed of representatives from several City departments, as well as an independent affordable housing expert, reviewed nine proposals from seven development teams. The selection of the development team was delayed due to the reduction of staff in summer 2020 and the need to focus on immediate housing programs in response to the COVID-19 pandemic. In July 2021, Council restored staff in the Housing and Human Services Division which allowed the selection process to resume.
Staff recommends selection of EAH Housing, Inc. (EAH) development team, based on the team’s depth of experience in development and operations, the overall development and financing concepts for the site, and high level of experience in permanent 2 of 18
supportive housing, larger developments, supportive services, property management, and management philosophy. Under the recommended proposal, EAH would manage the property once occupied and all residents would be supported with services to ensure housing retention and good-neighbor actions. The unique needs of the households occupying the supportive housing component of the development would be addressed by intensive case management services from The People Concern, who would also connect residents with outside services as needed. EAH Supportive Services staff would act as liaison to The People Concern to ensure seamless coordination. The People Concern’s services for households with special needs would include personal case management, benefits counseling, mental health counseling, health care, substance use services, money management, and legal assistance provided directly and through partner agencies.
If approved by Council, the City would enter into an Exclusive Negotiating Agreement (ENA) with EAH and would conduct a community outreach process to provide opportunities for stakeholder input before finalizing development concepts and designs.
Once the community outreach and design process are completed, staff would present the final development concept, design, and financial terms, including a long-term ground lease, for Council approval.
Background
The Santa Monica community has long supported the preservation and production of affordable housing as a core local value. As market pressures have affected the affordability of housing in Santa Monica, the City Council has continued to identify the urgency and need for more affordable housing. Reflecting community sentiment, in 2015, Council identified Maintaining an Inclusive and Diverse Community as one of its strategic goals, and in 2019, Council identified Affordability as a Framework Priority.
Creating more affordable housing is a key element to maintaining economic diversity and affordability in Santa Monica. In February 2021, the Council identified addressing 3 of 18
homelessness as a top priority and endorsed the four pillars approach1to addressing homelessness, which include creating more affordable housing.
Acting on this priority, the Housing Commission explored opportunities to enhance the City’s efforts to support affordable housing. The Housing Commission identified creating affordable housing on City-owned land as a strategy to reduce or eliminate one of the largest expenses in the creation of affordable housing: the cost of land. In meetings between October 2018 and February 2019, the Housing Commission identified the Cityowned site located at 1318-20 4 th Street (Project Site), as the City-owned property most suitable for development of affordable housing. Per the Housing Commission’s recommendation, Council authorized issuance of a Request for Proposals (RFP) for development of affordable housing on the Project Site on April 9, 2019 (Attachment A).
Staff issued the RFP on August 15, 2019.
On October 12, 2021, Council adopted the 6th Cycle Housing Element Update (2021- 2029) (Housing Element) and authorized its submittal to the California Department of Housing and Community Development. The adopted Final Housing Element proposes the use of City-owned sites as a key strategy to increase the supply of affordable housing. At Council’s direction, staff included a program that City-owned sites would be prioritized for 100 percent affordable housing as the City has few remaining vacant sites available for residential development. As land acquisition is typically the largest cost in developing affordable housing, the use of City-owned land would alleviate the impact of land cost on the feasibility of affordable housing development and allow the City’s limited Housing Trust Fund resources to be used more effectively in producing affordable housing.
1 Santa Monica’s four pillar approach to addressing homelessness: (1) Prevent housed Santa Monicans from becoming homeless, (2) Address the behavioral health needs of vulnerable residents, (3) Advocate for regional capacity to address homelessness, (4) Maintain access to safe, fun, and health open spaces. 4 of 18
Discussion
Development Proposals and Evaluation Committee
The City received nine proposals from seven development teams, provided as Attachment B. Each team included at least a lead developer, a social services provider, and an architect. Some of the teams included a co-developer, a landscape architect, and/or a variety of other consultants and partners.
An Evaluation Committee was formed to evaluate the proposals. The Evaluation Committee included staff from the following departments for a comprehensive review and comparison of the proposals:
• City Attorney’s Office
• Former Community and Cultural Services
• Former Housing and Economic Development
• Former Planning and Community Development; and
• Public Works
The Evaluation Committee also included a consultant, Kathe Head of Keyser Marston Associates, who created a detailed application checklist and project summary sheets for each proposal, and provided insight into the proposals’ financing strategies, which are provided as Attachment C.
Phase One Evaluation – Review of Proposals
The evaluation consisted of two phases. In the first phase, members of the Evaluation Committee reviewed the proposals of development teams and individually scored them on a scale of 0 to 100, using the criteria in the RFP. Staff assigned possible points to the criteria for the Evaluation Committee’s use as follows:
• Overall Development Concept (25 points)
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• Development and Operational Experience (35 points)
• Design Experience (10 points)
• Financing Analysis and Capacity (30 points)
The scores from each Evaluation Committee member were combined to identify an average score for each proposal, shown in the following table. A score of 70 or higher was required to proceed to the second evaluation phase, which consisted of interviews.
Table 1: Phase One - Evaluation Committee Scores
Team / Proposal Average
Score
Qualified for
Phase Two
Interview?
EAH (proposal 2) 87.44
Yes
EAH (proposal 1) 86.67
Abode Communities 84.22 Yes
Community Corporation of Santa
Monica + Metropolitan Pacific 81.67 Yes
Venice Community Housing 67.33 No
Step Up + Jamboree Housing 61.78 No
Innovative Housing Opportunities 60.56 No
Clifford Beers (proposal 1) 53.67
No
Clifford Beers (proposal 2) 52.33
While the development concept would be presented for community and stakeholder input before a design is finalized, the Evaluation Committee considered the proposed concepts as representing the teams’ approach in designing a mixed-use affordable housing development which aspires to achieve multiple community goals. The goals of the RFP included affordable housing which serves a variety of low-income household types (individuals, small/large households), a significant component of supportive housing for persons experiencing homelessness, retail and commercial uses that 6 of 18
complement existing downtown uses, and opportunities for affordable nonprofit space.
In evaluating the development concept submitted to the City, the Evaluation Committee considered the following factors: the number of residences proposed, the compatibility of the commercial use with supportive housing, and the approach regarding supportive and general resident services. The development and operational experience criterion focused on the experience of both the developer (including supportive housing in particular, as well as broader affordable housing experience) and of the social service provider. The developer’s experience was considered for both development and property management. The architect’s experience with developments of comparable complexity, scale, and nature was the determining factor for each team’s design experience criterion score. Key factors in the financing analysis and financial capacity criterion included the developer’s experience with the financing sources identified, the amount of City funding involved, and the provision of financial statements. Six of the proposals were structured to not require any City housing trust funds and therefore scored higher than proposals requiring the City’s financial assistance in addition to a land subsidy. Since the selection process was paused in July 2020 due to staff reductions and the ongoing COVID-19 public health crisis, some of the funding sources identified in the proposals in 2019 may no longer be available or may have changed.
Once a development team is selected, the proposed financing would need to be reevaluated, given the changes in the current funding environment.
Phase One scores were used to determine qualification for a Phase Two interview and were not used in Phase Two ranking.
Phase Two Evaluation – Interviews
The evaluation’s second phase consisted of interviews with the qualifying development teams (see above Table 1). The Evaluation Committee scheduled interviews with the respondent teams who scored above the threshold score. Specific questions were provided to the interviewees in advance focusing on the following topics:
1. The compatibility of the commercial component with the residential component. 7 of 18
2. An overview of the community involvement plan.
3. A description of the team’s design approach.
4. The possibility for greater density, particularly considering incentives provided by California Assembly Bill 1763.
5. A description of the supportive / social services plan and integration with the provider’s broader provision of services.
6. An updated financing strategy.
As a result of the COVID-19 pandemic, the Evaluation Committee held interviews virtually.
Following the interviews, the Evaluation Committee asked follow-up questions of the three teams. The questions were customized slightly for each team’s proposal details, and focused on the following:
1. The mix of funding sources in the financing strategy.
2. The strategy for success of the commercial component, identifying an alternative option in case community input were to result in the first option not being suitable.
3. The physical and visual connections between the Project Site and the surrounding areas.
After the development teams responded to these questions, provided as Attachment D, and the Evaluation Committee prepared a final rating.
At that point, the project was delayed as a result of the COVID-19 pandemic, restructuring of City resources, and prioritization of programs and projects that provided immediate response to those in need during the health crisis. In July 2021, a Senior Development Analyst was restored to the Housing and Human Services Division, enabling City staff to resume this project.
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As the original proposals were submitted in November 2019, staff contacted all seven proposers in August 2021 to ensure that: (1) the development team was still interested in the RFP, and (2) that their original proposal(s) was still valid. Seven (7) proposers responded, of whom were still interested and stated that their original proposal(s) was still valid. The development team comprised of Jamboree Housing and Step Up responded that only Jamboree Housing was interested in moving forward in the process and would utilize an in-house service provider. However, the Jamboree development team did not qualify for Phase Two of the Evaluation Committee process.
Final Selection
Based on the conclusions of the Evaluation Committee regarding the seven development team proposals, interviews, and subsequent questions/responses, staff recommends the selection of EAH due to the depth and breadth of the development team’s experience with larger developments and supportive housing, including the strength of support services and property management, and management philosophy.
EAH has demonstrated experience in affordable housing development and property management including larger developments and supportive housing developments.
Throughout its housing development and management portfolio, EAH has developed 24 properties where each property involved more than 100 apartments. EAH has developed 16 special needs or supportive housing properties. Additionally, EAH manages 32 properties where each property involved more than 100 apartments.
Currently, EAH has two developments either under construction or in the pipeline in the City of Santa Monica. One of these developments, Magnolia Villas (located at 1445- 1453 10th Street), a housing development for individuals over the age of 62, is currently on track to complete construction by the end of 2021. The other development, The Laurel (located at 1413 Michigan Avenue) will provide permanent supportive housing and is currently in the process of securing construction and long-term financing. When EAH expanded into Southern California in 2016, its first offices were based in Santa Monica but are now located in Tarzana.
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EAH was founded in 1968 in Northern California and has since expanded throughout California and Hawaii working with 55 different municipalities including the City of Santa Monica and City of Los Angeles. The organization serves over 20,000 residents in 110 properties in California and Hawaii, of which 70 percent are owned and managed by EAH and 30 percent professionally managed by EAH on behalf of other property owners. The properties include housing for families, seniors, people with disabilities and special needs, veterans, and formerly homeless households. In its 53-year history, EAH has developed and acquired 98 properties with over 7,900 residences. In Southern California, EAH has over 1,200 existing apartments under property management.
Additionally, at the time of proposal submission, EAH had 50 apartment communities under construction in Southern California with an additional five developments in the pipeline.
EAH has over five decades of providing homes for low-income individuals and families of all income levels and sizes, including operating seven mixed-income buildings incorporating special needs with other low-income populations. As developers, EAH has experience developing affordable housing development greater than 100 residences as well as supportive housing developments. EAH has developed 4,729 apartments in properties containing over 100 residences and 632 apartments in properties for special needs. Additionally, EAH is currently developing two communities in Los Angeles which blends supportive and family housing above ground floor retail, which is similar to the City’s request in the RFP of including 50 supportive housing residences in addition to other affordable housing.
Collectively, the EAH development team has decades of experience working in Santa Monica. The People Concern (TPC), EAH’s social service partner, was founded in Santa Monica over 50 years ago, and has a proven track record of working locally with extremely vulnerable homeless individuals facing complex barriers to housing. Over several decades as a grantee of City funds, TPC has maintained a 93 percent housing retention rate of high-need Santa Monica program participants currently in supportive housing. TPC recently formed a dedicated Housing Retention department to ensure that people moving into supportive housing have wrap-around clinically-based services. The 10 of 18
Housing Retention department provides a variety of comprehensive, integrated services to its participants, including mental health care, wellness program, income assistance and medical care. As one of the largest homeless and domestic violence service providers in Los Angeles County, TPC operates six interim housing facilities across Los Angeles County and supports over 1,750 people in supportive housing apartments.
Partnered with EAH, TPC has a proven track record of working with vulnerable homeless individuals and the local unhoused population.
The Evaluation Committee valued EAH’s philosophy of strong communication and collaboration between property management and services management to ensure positive results for all residents alike. Close collaboration is crucial in this context given the competing goals that arise between property management, which is typically geared to represent the property-owner’s interest, and social services, which supports residents in retaining their housing and being good neighbors through assertive and intensive case management. Additionally, the close collaborative relationship between EAH and TPC illustrates a strong willingness to work together in a real and meaningful way, thus benefiting future residents by reducing returns to homelessness.
To create a stable community for all residents, EAH proposes that all residents would be supported with services. The unique needs of the households occupying the supportive housing component of the development would be addressed by intensive case management services by TPC, who would also connect residents with outside services, as needed. EAH Supportive Services staff would act as a liaison to TPC to ensure seamless coordination. EAH services would include physical and mental health services, education programming, civic engagement, and healthy eating. TPC’s services for households with special needs would include personal case management, benefits counseling, mental health counseling, health care, substance use services, money management and legal assistance provided directly and through partner agencies.
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EAH’s proposed development team consists of the following:
Developer EAH Housing Inc (EAH)
Management & Resident Services EAH Housing (EAH)
Service Provider The People Concern
Architect Van Tilburg, Banvard & Soderbergh
Retail Broker Epsteen & Associates
Construction Manager AMJ Construction Management
Financial Consultant California Housing Partnership
Retail Consultant The Lynch Group Inc
The EAH development team submitted two proposals, which both ranked ahead of the other submissions. One proposal, Option #1, could achieve 120 apartments with 50 supportive housing apartments, and the second proposal, Option #2, could achieve 150 apartments with 50 supportive housing apartments. Both proposals could provide additional apartments beyond the amount proposed if Assembly Bill 1763 [2019] was incorporated; however, the additional apartments would be expected to require additional investment of the City’s Housing Trust Fund dollars.
Overall, the Evaluation Committee noted EAH’s development team strengths in its developer experience of larger developments and permanent supportive housing developments, integrated services program and property management, and concept for maximizing the number of apartments in the development.
Should the Council select EAH’s development team, EAH would solicit feedback from the community regarding the preferred development mix that best meets the City’s objectives while minimizing the necessity of additional City funding. EAH’s proposal strongly detailed its community outreach process to ensure that community stakeholders would be incorporated into the process and neighbors’ concerns would be heard early in the design process. Given the high-profile location within the City, EAH has outlined a four-phase community outreach plan for the development process that would extend beyond project approval through full occupancy of the development. 12 of 18
Staff Recommendations
The Evaluation Committee found that the development team led by EAH Housing, Inc submitted a proposal that best satisfied the requirements of the RFP evaluation criteria and would be able to develop the Project Site successfully with a process that would appropriately solicit community input and would satisfy the City’s objectives for the development.
The next step after Council approval of the development team is the execution of an Exclusive Negotiating Agreement (ENA). The ENA would establish the framework to allow staff to negotiate the proposed development terms with EAH for City approval at a later date, which would include the ground lease terms, proposed financing, the community input process, schedule of performance, and the length of time to complete negotiations. Once all requirements of the ENA have been met, staff would return to Council with proposed development terms for consideration.
Construction of the affordable housing development would be preceded by a community engagement process to incorporate community feedback on the design, the groundfloor commercial uses and design, apartment-type mix, and precise housing program.
Housing Commission Action
At the October 21, 2021 Housing Commission meeting, the Commission voted 5-0-1 to request staff to reflect that there were six Commissioners present, of which two Commissioners recused themselves from recommending a particular development team, and the remaining four Commissioners were unable to reach a consensus on the selection of a development team.
There was a motion presented to support the EAH development team proposal, followed by a motion to support the Community Corporation of Santa Monica and Metropolitan Pacific development team proposal. Both motions did not have enough votes to pass.
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Additionally, the Housing Commission voted 5-1 supporting a recommendation that whichever development team is selected by Council, that the development team would work with the City to maximize the number of persons to be housed on the City-owned site in a cost-effective manner.
Past Council Actions
Meeting Description
10/12/2021 City Council adopted the final 6th Cycle Housing Element Update (2021-2029)
07/13/2021 City Council awards Bid #2610 and RFP #2610 for the Demolition of Parking Structure #3
06/25/2021 City Council provided direction to staff on the draft concepts and strategies to include in the 6th Cycle Housing Element Update
04/09/2019 City Council authorized staff to issue RFP for the development of affordable housing on the City-owned land.
Environmental Status
The City-owned property at 1318/1320 Fourth Street currently houses the City’s Parking Structure #3 (“PS 3”), which was approved for demolition by the City Council in several prior actions as well as by the Coastal Commission, as more specifically described in detail in the July 13, 2021 City Council staff report, which is attached to this staff report as Attachment E.
The July 13, 2021 staff report also outlines the prior environmental review for the demolition of PS 3 as well as the construction of affordable housing. A summary of this environmental review is set forth below.
On February 28, 2006, the City Council certified the Final Program Environmental Impact Report (“Final PEIR”, State Clearinghouse No. 2002121122) for the City of Santa Monica Downtown Public Parking Program (“Downtown Parking Program”). The Final PEIR analyzed demolition and reconstruction of Parking Structure 1 located at 1234 4th Street, PS 3 located at 1320 4th Street, and Parking Structure 6 located at 14 of 18
1431 Second Street. The Notice of Determination was filed on May 12, 2006. (Notice of Determination, Attachment D to the July 13 staff report.) On April 26, 2011, an addendum to the Final PEIR was approved by the Council to analyze removal of PS 3 and replacement of the PS 3 spaces within Parking Structure
6. (Addendum attached to Council Report March 8, 2011, Attachment K to the July 13, 2021 staff report.)
The Final EIR for the Downtown Community Plan (DCP) also analyzed a build-out scenario of 3,024 housing units, including PS 3 as an identified site for housing development. Demolition and development of affordable housing would also be exempt from environmental review pursuant to Government Code Section 65457. “Government Code section 65457 provides an exemption from environmental review for a residential development that is consistent with a broader specific plan for which an environmental impact report previously has been certified.” (Concerned Dublin Citizens v. City of Dublin (2013) 214 Cal.App.4th 1301.) The City further finds that no grounds for supplemental or subsequent environmental review have occurred since approval of the DCP. As noted above under discussion of the DCP, the Project site was also determined to be exempt from parking and aesthetics analysis pursuant to SB 743 (Pub. Res. Code Section 21099(d)).
The demolition of PS 3 requires a ministerial demolition permit, issued by the City’s Building Official. Ministerial projects proposed to be carried out by public agencies are exempt from the California Environmental Quality Act (“CEQA”) (Public Resources Code sections 21000 et seq.). Pub. Resources Code § 21080(b)(1); title 14 CCR § 15369; Friends of Juana Briones House v. City of Palo Alto (2010) 190 Cal.App.4th 286.)
On May 13, 2021, the Coastal Commission approved the demolition of PS 3 with standard conditions. Section 13096 of Title 14 of the California Code of Regulations requires Commission approval of Coastal Development Permit applications to be 15 of 18
supported by findings showing the approval, as conditioned, to be consistent with any applicable requirements of CEQA. Section 21080.5(d)(2)(A) of CEQA prohibits a proposed development from being approved if there are feasible alternatives or feasible mitigation measures available which would substantially lessen any significant adverse effect which the activity may have on the environment.
The Commission’s regulatory program for reviewing and granting Coastal Development Permits has been certified by the Resources Secretary to be the functional equivalent of CEQA. (14 CCR § 15251(c).) The Commission noted that the City of Santa Monica is the lead agency, and the Commission is a responsible agency for the purposes of CEQA. The Commission noted the City’s determination as the lead agency that the proposed demolition is exempt under CEQA Section 21080(b)(1) and made findings as the responsible agency that the relevant coastal resource impacts of the proposed project were disclosed in the Commission staff report that was considered at the May 13, 2021 public hearing before the Commission. In addition, the Commission determined that the proposed project was conditioned in order to minimize and mitigate impacts to coastal resources consistent with Chapter 3 of the Coastal Act. As conditioned, the Commission found that there are no feasible alternatives or additional feasible mitigation measures available that would substantially lessen any significant adverse effect that the activity may have on the environment, either individually or cumulatively with other past, present, or reasonably foreseeable probable future projects. Therefore, the Commission found that the proposed project, as conditioned to mitigate the identified impacts, is the least environmentally damaging feasible alternative and can be found consistent with the requirements of the Coastal Act to conform to CEQA.
In order to satisfy its obligations under the Housing Accountability Act (Government Code section 65589.5), the City adopted Resolution No. 11239 (CCS) on March 10, 2020, modifying the discretionary review thresholds for 100% affordable housing projects, such as the one contemplated for development on the PS 3 site, would be subject only to a ministerial approval process. 100% affordable housing projects are 16 of 18
defined as “[h]ousing projects with a minimum of 25% of the units deed restricted or restricted by an agreement approved by the City for occupancy by 60% Income Households or less and the remainder of the housing units are deed restricted or restricted by an agreement approved by the City for occupancy by 80% Income Households or less. Such projects may include nonresidential uses not to exceed 33% of the project’s total floor area.” The effect of Resolution 11239 (CCS) is that Tier 2 housing projects that meet the qualifications of a “housing development project” under the Housing Accountability Act would be subject to ministerial approval and would not require environmental review. Cal. Pub. Res. § 21080(b)(1); CEQA Guideline §15369 (ministerial approvals).
However, even without the effect of Resolution No. 11239 (CCS), in order to facilitate housing approvals, CEQA already contains express exemptions for infill housing, including the following:
(i) CEQA § 21155.4; CEQA Guideline §15182 (projects proximate to transit or residential projects pursuant to the Downtown Community Plan); (ii) CEQA Guideline §15183.3 (streamlining for infill projects); (iii) CEQA § 21083.3 (CEQA restrictions on residential zoning and community plans); and
(iv)CEQA § 21159.21 (exemption for qualified housing projects) (v) Cal. Gov’t Code § 65583.2 (by-right owner occupied or multifamily housing not a “project” under CEQA)
The exact scope of the future 100% affordable housing development cannot be described in this report with certainty because the two options proposed for development by EAH have not been presented to stakeholders and the broader community for input and approved by the City Council. However, it is reasonably foreseeable that the City, once it selects a housing developer, will proceed with negotiating the terms and conditions of conveyance of the site for a 100% affordable 17 of 18
housing project that would meet the definition of “housing development project” within the meaning of the Housing Accountability Act, as well as the CEQA exemptions referenced above. Additionally, the act of entering into an Exclusive Negotiating Agreement does not implicate CEQA. (See Neighbors to Preserve the Waterfront v.
City and County of San Francisco (2013, 1st App. Dist. Case No. A134220.)2 Furthermore, demolition and development of housing at the project site have already been programmatically analyzed in several prior CEQA documents, and the City further finds that no grounds for supplemental or subsequent environmental review have occurred.
Financial Impacts and Budget Actions
There is no immediate financial impact or budget action as a result of the recommended action. Staff would return to Council with proposed business terms associated with the proposed development, including any required investment of Housing Trust Funds or other City resources.
Prepared By: Claudia Kompa, Executive Administrative Assistant Approved Forwarded to Council
Attachments:
A. Attachment A - 1318 4th St Affordable Housing Development RFP B. Attachment B1 - Proposals Received (Abode Communities) C. Attachment B2 - Proposals Received (Clifford Beers Housing Option 1) D. Attachment B3 - Proposals Received (Clifford Beers Housing Option 2) E. Attachment B4 - Proposals Received (CCSM + Metropolitan Pacific) F. Attachment B5 - Proposals Received (EAH Option 1)
G. Attachment B6 - Proposals Received (EAH Option 2)
H. Attachment B7 - Proposals Received (Innovative Housing Opportunities) 2 Available at: https://www.courts.ca.gov/opinions/nonpub/A134220.PDF 18 of 18
I. Attachment B8 - Proposals Received (Jamboree Housing + Step Up on Second) J. Attachment B9 - Proposals Received (Venice Community Housing + National CORE)
K. Attachment E - July 13, 2021 Staff Report (Web Link) L. Attachment C - KMA Detailed Application Checklist and Project Summary M. Attachment D - Phase Two Supplemental Questions and Responses N. Written Comments
O. Council PowerPoint
P. EAH Presentation
Q. Community Corp. Presentation
R. Abode Communities Presentation