Here are some comments and input on HODC’s second proposal for low-income housing facility at American Legion Hall site, 1925 Wilmette Avenue.
I. INITIAL COMMENTS
Since withdrawing its first PUD plan for the American Legion Hall site on Wilmette Avenue, HODC has been holding meetings and seeking the community’s input for its next PUD plan. We provide this input not because we believe that HODC is necessarily a suitable developer for the type of housing it seeks to develop in Wilmette, but, rather,
because it has actively sought the community’s input on the type of housing that the community may want to see at the American Legion site. Our input on the type of low income housing should not be construed as our endorsement or acknowledgement of HODC as an acceptable developer of such housing.
Numerous residents have uncovered from public municipal records what they believe to be examples of HODC’s poor track record in developing and managing comparable (i.e., low to very low income, rental-only housing) facilities in Evanston, Skokie and elsewhere. They have also raised their concerns over HODC’s business model and financial limitations. Some have also expressed their concerns over HODC’s latest facility in Glenview that had to be shut down indefinitely with the construction less than 50% completed because of budget cuts and financial limitations. Others have also voiced their concerns about HODC’s prior management of an affordable (but not low income), senior-only housing facility in Wilmette (“the Atrium”) that led to a number of financial and mold problems for the facility.
In short, HODC has not demonstrated to the community that it is a suitable longterm partner for Wilmette to develop and manage the type of low income housing it wants to develop in Wilmette. Our hope is that the community should not rush into a low income housing facility with a developer with a questionable track record simply for the sake of increasing low income housing stock in the village or to appease a small, but vocal, group of low income housing advocates, many of which do not even reside in Wilmette.
This is a town that prides itself for trying to do things the right way and making informed decisions. That should be the case here. We should make sure that any low income housing facility that requires the Village’s assistance (through zoning ordinance variances, special use permits, etc.) is planned, developed and managed properly by a
competent developer for the sake of its future tenants, its neighbors and, of course, the community.
II. WHAT WE WOULD LIKE TO SEE GENERALLY
We believe that the community will prefer an ownership-based facility that mixes “market rate” units with “affordable” units. The Village’s Master Plan calls for 15% of the units of a planned unit development building being affordable.” It, however, does not contemplate 100% low income facilities, much less 100% rental-only, low income facilities as HODC has proposed for Wilmette.
HODC has repeatedly brushed aside the community’s suggestions at the community meetings to align its proposal closely with the Village’s Master Plan for Affordable Housing. HODC has stated that it will not consider any ownership-based
option. That is unfortunate. Again, we urge HODC to reconsider its position and look beyond its current business model that has not worked well given HODC’s financial limitations. For the time being, however, regardless of the ownership structure of the proposed facility, we believe that any new low-income housing facility at 1925 Wilmette Avenue should have the following building and management attributes set forth below.
We believe that these attributes are reasonable for both the developer and the host community, are carefully tailored to address the unmet low-income housing needs of Wilmette and surrounding communities (particularly for their seniors whose ranks will only continue to grow), and attempt to hold the developer accountable for proper development and management of the proposed facility.
In addition, we believe that HODC must also demonstrate to the community, in a detailed plan, as part of its overall PUD submission, how it plans to address the serious concerns that have been raised about its poor track record and financial limitations. HODC should also address the viability of its current business model of developing low to
very low income, rental only facilities, funded entirely with public subsidies and tax credit equity, in light of the significant budget cuts at the state and federal levels1 and HODC’s difficulties in completing its construction project in Glenview in light of such budget cuts.
Our hope is that HODC is sincere about wanting to listen to the community’s input on this issue and that it will consider our suggestions as carefully and thoughtfully as we have prepared them. We hope to see in the 2nd HODC plan a proposed facility which the community will be proud to call its own and where our seniors, disabled, veterans, local
workers and other deserving but underserved families can live with dignity, security and community support. What we do not want to see is a rework (albeit with minor cosmetic changes) of HODC’s highly flawed and now-withdrawn 1st PUD plan.
1 See, for example, http://www.chicagotribune.com/suburbs/skokie/news/ct-skr-cdbg-grants-tl-0114-
20160111-story.html.
2 See http://dailynorthshore.com/2015/12/07/affordable-housing-at-standstill-in-glenview/
3
III. BUILDING CONFIGURATION
A. Ground Floor – 2 Income-Generating Units, Office and Common Rooms3
• 1 retail unit – providing jobs for residents and cash flow for the developer
• 1 professional service office – providing cash flow for the developer
• Community Room – needs to be bigger than 290 square feet (as proposed in 1st
PUD proposal) to be functional and truly useful for tenants
• Laundry room
• Management Office – for an on-site manager
• Bathroom for management and visitors – to avoid similar problems at HODC’s Evanston facilities that lacked bathrooms for visitors (1st PUD plan drawings did not show any common bathroom)
• Building (1st and 2nd floors and underground parking) should be fully handicap
accessible (1st PUD plan did not show handicap accessible ramps, elevator,
doors, etc. even though it proposed a three-story facility)
B. Second Floor – 5 Residential Units (12-13 tenants maximum)
• Three 1-bedroom units – for one or more of the following (6 people maximum):
o 1 set-aside for non-disabled senior(s) (2 person maximum)
o 1 set-aside for veterans (2 person maximum)
o 1 set-aside for disabled resident(s) (2 person maximum)
o 1 set-aside for local worker(s) (2 person maximum)
• Two 2-bedroom units for one or more of the following (6 persons maximum for
both units or 7 persons if tenants include school-aged children)
o 1 set-aside for disabled resident(s) and caretaker or disabled-headed
family
3 The inclusion of market-rate income-generating units is likely to serve as an additional incentive for the
developer to maintain the facility adequately.
4
o 1 set-aside for veteran family
o 1 set-aside for local worker family
C. Underground Parking – (23-25 spaces)
• Wilmette zoning ordinance compliant number of underground parking spaces
(1.5 spaces/unit) for 5 residential units with a south-facing entrance to allow
space for emergency and service vehicles and to maintain attractive appearance
from curbside
• Wilmette zoning ordinance compliant number of parking spaces for retail and
non-residential units
o 6 units for Retail Space
o 4 units for Professional Service Office
o 2 units for Management Office
o 3 units overflow/customers/visiting social service personnel
D. Access to Property and Configuration of Driveway
• 2 points of access into and out of the complex
• Circular drive for picking up handicapped/elderly tenants (1st PUD plan
contemplated allowing service and emergency vehicles to park on the front
lawn, which does not comply with the zoning ordinance)
• Sufficient space for emergency and other service vehicles to access the front, the
sides and the back of the building
• Sufficient space for snow removal/temporary snow storage onsite
E. Exterior to Match nearby Buildings
• Red brick exterior – consistent with the current exterior façade of American
Legion Hall building and nearby (non-single family house) buildings
IV. MANAGEMENT AND ACCOUNTABILITY
A. Independent Board
• Board (5 members) to oversee Building Owner/Developer’s management,
tenant selection and escrow account (as noted below)
5
o Wilmette residents – 3 (appointed by Village Board)
o Building Owner/Developer – 1
o Wilmette Village Board member – 1
B. Proposed Developer’s Fees and Management
• Clear identification of “hard costs” vs. “soft costs” consistent with IHDA
regulations on proper calculation of the maximum allowable developer’s fees
for projects of this type
• Clear identification of the proposed numbers of (a) Permanent Supportive
Housing (PSH) units and (b) PSH tenants, if any
• If any PSH unit is being proposed or contemplates housing any PSH or PTSD
diagnosed tenant, HODC’s plans for hiring onsite mental health professional(s)
to adequately support PSH/PTSD tenants
• Clear and binding plans and standard operating procedures for tenant selection,
maintenance, eviction and marketing
• Clear identification of priority population classes for tenant selection purposes
• Explanation of High overall developer’s fees and overall costs (for its 1st plan,
HODC proposed $325 per square foot or $4.76 million for 14,652 square feet,
which is exceedingly high even for “market rate” buildings with higher grade and
more expensive finishes4)
C. Financial Accountability of Developer and Escrowing of Developer’s Fees
• Construction and development contingency financing plan to avoid the type of
problems that HODC is experiencing with its low income housing facility in
Glenview whose construction has been stopped indefinitely with less than 50%
completed
• Budget for on-site manager
4 According to an informal survey of local builders, the commonly accepted rule of thumb is $150 to $200
per square foot plus land acquisition costs. HODC’s land acquisition cost is about $30 per square foot.
6
• Budget for an on-site certified mental health professional if PSH tenants are to
be housed (which would allow Developer to collect the maximum developer’s
fees allowed under IHDA regulation and which would generate additional
developer’s fees to fund this expense)
• 75% of proposed developer’s fee to be escrowed and released to the developer
annually over 10 years to hold the developer accountable for its projection and
maintenance
• Escrowed developer’s fees to be used as “first money out” to cover any project
budget shortfalls up to an annual cap (to assure positive cash flows for Building
Owner/Developer). In other words, Developer will receive at least some
developer’s fee each year albeit in an reduced amount if there is a budget
shortfall.
Please find the attached communication from our group to HODC in response to HODC’s request for community input for its 2nd PUD plan, which we understand will be submitted in the near future. Our hope is that HODC will consider our suggestions as thoughtfully and objectively as we have attempted to prepare them.
In addition, we ask Mr. Adler to kindly forward this communication to each of the Plan Commissioners, Mr. Bielinski and the Village Board Trustees.
Respectfully submitted,
Wilmette Residents United for Transparency and Informed Decisions on American Legion Post 46 Redevelopment
Letters to the Editor represent the writers’ opinions and not necessarily those of Daily North Shore.