HomeMy Public PortalAboutCPC Packet 011123 Jt w BAHTTown of Brewster Community Preservation Committee
2198 Main St., Brewster, MA 02631
cpcmeeting@brewster-ma.gov
(508) 896-3701
JOINT MEETING AGENDA
COMMUNITY PRESERVATION COMMITTEE &
AFFORDABLE HOUSING TRUST
Brewster Town Hall
2198 Main Street
January 11, 2023 at 4:00 PM
Pursuant to Chapter 107 of the Acts of 2022, this meeting will be conducted in person and via remote means, in accordance
with applicable law. This means that members of the public body may access this meeting in person, or via virtual means. In
person attendance will be at the meeting location listed above, and it is possible that any or all members of the public body
may attend remotely. No in-person attendance of members of the public will be permitted, and public participation in any
public hearing conducted during this meeting shall be by remote means only.
The meeting may be viewed by: Live broadcast (Brewster Government TV Channel 18), Livestream (livestream.brewster-ma.gov),
or Video recording (tv.brewster-ma.gov).
Members of the public who wish to access the meeting may do so in the following manner:
1.Phone: Call (929) 436-2866 or (301) 715-8592.Webinar ID: 837 7728 4808 Passcode: 326439
To request to speak: Press *9 and wait to be recognized.
2.Zoom Webinar: https://us02web.zoom.us/j/83777284808?pwd=NjB3WldRTGRxb0l0WXhIS1J0Y1NOQT09
Passcode: 326439
To request to speak: Tap Zoom “Raise Hand” button or type “Chat” comment with your name and address, then wait to be
Community
Preservation
Committee
Faythe Ellis
Chair
Sarah Robinson
Vice Chair
Sharon Marotti
Treasurer
Elizabeth Taylor
Clerk
Roland Bassett Jr.
Christine Boucher
Bruce Evans
Peggy Jablonski
Paul Ruchinskas
CPC Assistant
Beth Devine
1.Call to order
2.Meeting participation statement
3.Declaration of a quorum
4.Public Announcements and Comment – Members of the public can address the
Community Preservation Committee on matters not on the meeting’s agenda for a
maximum of 3-5 minutes at the Chair’s discretion. Under the Open Meeting Law, the
CPC is unable to reply, but may add items presented to a future agenda.
5.Discussion of Brewster Affordable Housing Trust (BAHT) Guidelines
6.Discussion of proposed Housing Trust Financial Plan
7.Discussion of projected BAHT funding requests to the CPC
8.Consideration of annual funding for BAHT from CPC
9.Potential funding and administration of the affordable home buy-down program
10.Motion to adjourn
Date Posted: Date Revised:
1/9/23
Town of Brewster
Affordable Housing Trust Fund
Program Guidelines & Application
Brewster Affordable Housing Trust Fund
Ned Chatelain
Tim Hackert
Madalyn Hillis-Dineen
Vanessa Greene
Donna Kalinick
Paul Ruchinskas
Maggie Spade-Aguilar
Staff contact: Jill Scalise, Housing Coordinator
Approved by the Brewster Affordable Housing Trust September 1, 2022
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Brewster Affordable Housing Trust Program Guidelines and Application 2
Program Guidelines & Application
Table of Contents
Housing Guidelines Page #
I. Brewster Affordable Housing Trust Mission Statement & Goals 3
II. Roles and Responsibilities of the Housing Trust 4
III. Priorities of the Housing Trust 5
IV. Eligible Activities 6
V. Funding Guidance 8
VI. Project Monitoring 9
VII. Reporting 10
VIII. Periodic Updating of the Guidelines 10
IX. Application Process 10
X. Selection Criteria 11
XI. Application Form/ Attachment List 12
Glossary of Housing Terms will be available on the new Town of Brewster website.
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Brewster Affordable Housing Trust Program Guidelines and Application 3
Town of Brewster
Affordable Housing Trust Fund
Program Guidelines and Application
I. Brewster Affordable Housing Trust Mission Statement and Goals
Housing Trust Mission Statement:
The Brewster Affordable Housing Trust (“BAHT”) seeks to expand and preserve year-round
rental and ownership homes that are affordable to moderate, low, and very low income
households. Our efforts will foster a welcoming environment for demographically and socio-
economically diverse populations. The BAHT is committed to education, collaboration, and
community engagement.
- Accepted April 4, 2019
Brewster Affordable Housing Trust (BAHT) Goals
The Trust has identified the following goals to use as guiding principles to implement Trust
Mission Statement:
1. Develop and Preserve Affordable Housing: The BAHT will develop and preserve
affordable housing and support the work of others seeking to do the same. Our work will serve
very low-, low-, and moderate-income individuals and families, which means households with up
to 100% Area Median Income (AMI).
2. Educate: The BAHT will work to educate individuals and organizations about Brewster’s
community housing and why affordable housing is important to the town, its residents and
visitors. Coordinating with the Brewster Housing Partnership (BHP), we will partner with other
housing organizations from within and outside Brewster to provide educational opportunities to
our citizens.
3. Advocate and collaborate: The BAHT will advocate for development proposals, projects,
local bylaws, state and federal laws, and other programs that advance our mission to create and
preserve affordable housing. We will collaborate with local, state, and federal officials as well as
public, non-profit and for-profit entities to achieve our goals.
4. Engage and Communicate: The BAHT will engage and communicate with town residents,
and listen to, and learn from, their ideas, so that our work reflects a broad consensus.
Originally approved by the Brewster Affordable Housing Trust August 15, 2019
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Brewster Affordable Housing Trust Program Guidelines and Application 4
II. Roles and Responsibilities of the Brewster Affordable Housing
Trust
Purpose of the Trust:
The purpose of the Trust is to provide for the preservation and creation of affordable housing in
the Town of Brewster for the benefit of low and moderate income households and for the
funding of community housing as defined in and in accordance with the provisions of
Massachusetts General Laws, Chapter 44, Section 55C. The Trust can use property, both real and
personal, and expend funds as the Board of Trustees deems most appropriate to carry out such
purpose consistent with the policies adopted from time to time by the Select Board regarding
affordable housing.
Management of the Trust:
The Trust is governed by a Board of Trustees consisting of seven Trustees who are appointed by
the Select Board for a term of two years. The Board is comprised of one member of the Select
Board, Housing Partnership, Community Preservation Committee, and Planning Board; two
residents at large; and the Town Administrator or his designee.
The Powers of the Trustees:
As stated in the Declaration of Trust, the Trustees may undertake any activity that would create
and preserve affordable housing for the benefit of low and moderate income households. Their
powers include, but are not limited to, the right to receive, purchase and convey real or personal
property; to sell, lease, exchange or transfer property; to execute deeds, contracts, and grant
agreements; to employ and compensate advisors and agents; to borrow money; to manage or
improve real property and to abandon property which the Board determines not to be worth
retaining; to issue policy goals and statements to serve as guidelines for the Trust and to provide
funds for the benefit of low and moderate income households to assist in the acquisition,
creation, preservation, rehabilitation and support of housing affordable for such families. Any
expenditure of funds in an amount over $50,000, and any sale, lease, exchange, transfer of
conveyance of property having a value in excess of $50,000, requires the approval of the Select
Board.
Funding of the Trust:
The Brewster Affordable Housing Trust Fund (the “Trust Fund”) was initially funded by the
dissolution of the Affordable Housing Fund and the transfer of the funds to the Trust Fund.
Community Preservation Act (“CPA”) funds, in accordance Section 5 of the CPA, may be
allocated to the Trust Fund. CPA funds appropriated into the Trust Fund may be used only for
CPA approved activities, such as the acquisition, creation, preservation, and support of
community housing, and for the rehabilitation of community housing acquired or created using
CPA Funds. Additionally, the Trust Fund has received free cash from the Town of Brewster,
including a portion of Brewster’s Short Term Rental Revenue; these monies are not subject to
the CPA restrictions, but are required to be used for the purposes of the Trust.
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Brewster Affordable Housing Trust Program Guidelines and Application 5
III. Housing Trust Priority Initiatives for FY 2022-23
A. Develop and Preserve Affordable Housing:
Develop new affordable housing (by building):
o Support and advance the development of community housing on the
Millstone Road property. Subsequent to RFP issuance, select developer
and support their efforts to develop rental housing in a timely manner.
Determine the amount of funding that the Trust should reserve for a
potential request, provide support through funding cycles and permitting
process, continue to engage the public.
o Participate in the exploration of the potential development of community
housing on the Cape Cod Sea Camps Parcels.
Develop new affordable housing (without building):
o Evaluate the effectiveness of the current accessory dwelling unit bylaws
and advocate for policy, financial, or implementation changes if necessary.
o Evaluate the effectiveness of the current rental voucher program.
o Revisit the feasibility of a rent-to-own program.
Evaluate the effectiveness and reach of the existing Community Development
Block Grant (CDBG) home rehabilitation program, refine procedures, and study
whether the Trust needs to explore supplementing the program in any way.
Continue to work to preserve the existing 3 Subsidized Housing Inventory (SHI)
homes in distress and other units through outreach and, when required, with
financial support.
Work with the Community Preservation Committee (CPC) to determine the future
of the Brewster Buy Down program
Develop rules and program guidelines for the BAHT, particularly around funding
requests
Participate in the Local Comprehensive Plan (LCP) process, including advocate
and explore a review of current zoning as it relates to housing.
B. Educate:
Hold at least annual forums and Select Board updates as well as regularly post
information on the Town website.
o Community Housing Fair and Forum
Hold ongoing joint meetings with other committees such as CPC, BHP, SB & FC
Hold, and/or participate in, Community Housing education sessions and forums
that address or include Fair Housing, Local Preference, and Regional
Partnerships.
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Brewster Affordable Housing Trust Program Guidelines and Application 6
IV. Eligible Activities
The Trust Fund can be used to support the following activities. Note that CPA funds must be used
only for those purposes specified in the CPA as allowable activities, while the Trustees may use
non-CPA funds for programs offering a broader range of purposes that are consistent with the
Declaration of Trust and the provisions of MGL Chapter 44, Section 55C.
A. PRESERVATION PROGRAMS
Preservation of Subsidized Housing Inventory (SHI) Affordable Homes:
1. Housing Preservation and Improvement Activities
The BAHT received a CPA grant of $500,000 in November 2019 to assist in the
preservation and acquisition of SHI homes. Funds will be prioritized for
affordable homes identified as non-compliant (for example, uninhabited) and/or
at risk of losing their affordable deed restriction.
In certain instances, the BAHT may use funds to preserve affordability of units
already included in the Town’s Subsidized Housing Inventory (“SHI”) by
providing funds for repairs necessary to enable residents to continue to reside in
their homes. This may include the purchase of homes in specific circumstances.
CPA Allowable Activities: CPA funds may be used for repairs that are necessary
to preserve affordable housing from injury, harm or destruction, which may
include, but are not limited to, the following:
Building envelope and site work to preserve the structural integrity of the homes
Roof, siding and window replacements to assure the water tightness of the
housing units
Upgrading of dangerous electrical or plumbing systems
Replacement of dangerous building systems that threaten the housing units
Failed Septic Systems
Installation of hard-wired smoke alarms, sprinklers and other building fire
suppression systems
Funds cannot be spent for maintenance or operating costs
Whether the BAHT will fund a particular project depends on the facts involved in each case, the
amount of funds sought, the eligibility of persons seeking assistance, the necessity of the repairs,
the funds available to the BAHT to support such program, whether the homes were acquired or
created originally with CPA funds, and other factors. The BAHT may obtain new deed
restrictions on properties to ensure the future affordability of the homes. There is no guarantee of
financial assistance.
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Brewster Affordable Housing Trust Program Guidelines and Application 7
B. SUPPORT PROGRAMS (Loans/Grants for Individuals)
1. Brewster Rental Assistance Program
Provide a monthly rent subsidy and support to income eligible households. This program
is currently managed by Housing Assistance Corporation (HAC) for the BAHT. For more
information, see the Housing Office Webpage or this link: Microsoft Word - FACT SHEET
Brewster Rental Assistance Program.docx (brewster-ma.gov)
CPA Allowable Activities:
Grants, loans, rental assistance, interest-rate write downs or other assistance
directly to individuals who are eligible for community housing for the purpose of
making housing affordable
2. Brewster Affordable Home Buyers Buy-Down Program
The Town of Brewster, through Community Preservation Funds, provides up to $30,000
of grant assistance for eligible buyers purchasing a home in Brewster. The program,
contingent on existing funds, is available to households qualifying at 80% AMI (Area
Median Income) who agree to place a permanent affordable housing deed restriction on
the home. The grant assistance is provided as an interest free loan which is forgivable
after 30 years if the owners remain in compliance with the terms of the restriction. This
program is overseen by the Community Preservation Committee and specific applications
for this program are available at Town Hall and on the Housing Office webpage: Buy-
Down Ready Buyer Application (laserfiche.com)
CPA Allowable Activities:
Grants, Loans, Rental assistance, interest-rate write downs or other assistance
directly to individuals who are eligible for community housing for the purpose of
making housing affordable
3. Community Development Block Grant (CDBG) Housing Rehabilitation &
Childcare Assistance Program
CDBG housing rehabilitation and childcare assistance funds are available for low to
moderate income Brewster households earning up to 80% of the Area Median Income.
Housing Rehabilitation funds can provide a 0% interest, deferred, forgivable loan to
make critical home repairs. The program is designed to improve the housing conditions
of income qualified households. Funds up to $50,000 are available to eligible residents to
pay for critical home repairs, like: roofing and siding, electrical, heating and plumbing
work, structural repairs, lead paint abatement and energy efficiency upgrades such as
windows and storm doors. This program is managed by The Resource Inc. (TRI) and
applications are available from TRI at jean@theresource.org. Childcare funding offers
eligible families subsidies of up to $6,000 per child, to assist families in seeking or
maintaining employment. Bailey Boyd Associates oversees the Childcare assistance and
applications are available here: Childcare Programs — Bailey Boyd Associates.
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Brewster Affordable Housing Trust Program Guidelines and Application 8
C. CREATION PROGRAMS (Development Loans/Grants)
1. DEVELOP NEW RENTAL HOUSING (Rental Expansion Program)
New Construction Units
Provide funding assistance to developers for construction of new affordable rentals with
deed restrictions required for long-term affordability.
2. DEVELOP NEW HOME OWNERSHIP HOUSING (Home Ownership
Expansion Program)
New Construction Units
Provide funding assistance to developers for construction of new home ownership
properties with deed restrictions required for long-term affordability.
V. Funding Guidance
The BAHT has established the following funding guidelines for eligible activities:
All financial transactions undertaken by the BAHT where Community Preservation Act
(CPA) funds are used must comply with the requirements of the Community Preservation
Act (CPA).
All affordable rental and homeownership units created through new construction must be
deed restricted.
Development loans provided under the Home Ownership and Rental Expansion Program
are limited to up to $100,000 per affordable unit and a maximum project amount
determined by the Trust. Tax credit units are limited to $50,000 per affordable unit. The
BAHT will determine the applicable interest rate to assist with project feasibility.
Payments will be deferred until the property is transferred unless the recipient is
determined to be in violation of loan terms (allowances for extenuating circumstances with
an appeal process), in which case payments will be due. Any loan proceeds will be
deposited into the Housing Trust Fund. All loans must be secured by a mortgage against
the property and may be subordinated to other project lenders. Deed riders for 10-15 years
are required for projects where the loan is more than $20,000 per unit and required for at
least 30 years or in perpetuity for loans of $50,000 or more per unit.
For rental developments, the project sponsor must enter into a Regulatory Agreement with
the Town and subsidizing agency that insures affordability in perpetuity to the greatest
extent possible.
A Land Development Agreement will be required for any Town-owned land.
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Brewster Affordable Housing Trust Program Guidelines and Application 9
In addition to BAHT approval, expenditures over $50,000 require Select Board approval.
Funding is directed to creating and preserving affordable housing for low and moderate
income households, as defined below:
Low-income housing – Housing for those persons and families whose annual income
is at or below 80% of the area median income (AMI) for the Barnstable County area as
determined annually by the U.S. Department of Housing and Urban Development
(HUD) and adjusted by household size.
Moderate-income housing – Housing for those persons and families whose annual
income is above 80% AMI but at or below 100% AMI for the Barnstable County area
as determined annually by HUD and adjusted by household size.
While funded projects can include income tiers above the 100% AMI threshold, the Trust
Fund cannot be used for projects that are solely targeted to income levels above the 100%
level.
Funding guidelines can be waived or modified, if permitted under applicable law,
upon a majority vote of the BAHT and, if required, by the Select Board.
VI. Project Monitoring
The BAHT, with staff support from the Housing Office and/or management agency,
will work with the state’s Department of Housing and Community Development
(DHCD) and project sponsors to insure that all units that have been funded by the Trust
Fund are eligible for inclusion on the SHI, meet all requirements to be counted as part
of the SHI, and are monitored to ensure the continued affordability of such units.
BAHT will also monitor the affordability of units that have received Trust funds but are
not eligible for inclusion on the SHI. In these cases, the BAHT, with support from the
Housing Office and/or a management company, will annually confirm the continued
occupancy and eligibility of unit occupants by:
Checking Assessors records and resident mail listings to verify the continued
occupancy of the units. If the units involve homeownership, the deed rider will
require that the occupant notify the Town upon any intent to sell, and the Town will
have an opportunity to purchase or resell the unit based on a prescribed process
included in the deed rider (adaptation of DHCD’s deed rider). If the units involve
rentals, send a letter to the project sponsor requesting documentation listing the
incomes of the tenants and a copy of their leases to ensure that the tenants meet the
income qualifications, and the rents continue to be affordable.
Checking the Barnstable County Registry of Deeds to make sure that there have
been no changes in ownership/residency.
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Brewster Affordable Housing Trust Program Guidelines and Application 10
Preparing an annual compliance report that documents the continued affordability of
these units.
VII. Reporting
With staff support from the Housing Office, the BAHT shall prepare an annual report that
summarizes the use of Trust funds during the fiscal year including amounts of funding, type of
funding, project description and status, as well as the balance in the Trust Fund. The books and
records of the Trust shall be maintained by the Town Accountant and audited annually as part of
the annual audit of the Town of Brewster. The results of the audit shall be provided to the Town.
VIII. Periodic Updating of the Guidelines
These Housing Guidelines shall be reviewed at least every three (3) years by the BAHT, with input
from the CPC and the Brewster Housing Partnership, and updated as necessary. The BAHT is
responsible for approving any changes and can also choose to amend the Guidelines any time if it
determines that certain requirements are no longer effective or viable or are necessary or
appropriate. Section III will be updated regularly to reflect the BAHT’s new FY priorities.
IX. Application Process
The application process involves providing information to the BAHT before funding
approvals can be granted. All submissions, scheduling and communications will be
coordinated through the Brewster Housing Office. The BAHT will accept applications on a
rolling basis.
Only those projects that receive the approval of the Board of Trustees and, if required, the
Select Board, are eligible to access funding from the Trust Fund. In making its determinations
on funding, the BAHT may consult with the Brewster Community Preservation Committee,
Planning Department and Planning Board, Zoning Board of Appeals, and/or other Town
commissions or boards. The approved applicant must enter into an agreement with the BAHT
that specifies the purpose and scope of the project, projected timeframe, and approved funding
for the project. The applicant must submit an original copy of the signed contract.
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Brewster Affordable Housing Trust Program Guidelines and Application 11
X. Selection Criteria
The BAHT will apply the following selection criteria in its review of applications:
Selection Criteria
The project/program proposal is consistent with the BAHT’s Funding Priorities. These
include the following:
1. Increase affordable housing opportunities for year-round community to the extent permitted by law,
by prioritizing opportunities that support the Trust’s mission to expand and preserve year-round rental
and home ownership homes that are affordable to moderate, low, and very low-income households.
These projects should provide a welcoming environment for demographically and socio-economically
diverse populations. Proposals may serve a range of local housing needs, even if some of the units may
not be eligible for inclusion in the state’s Subsidized Housing Inventory (SHI).
2. Advance the creation of year-round affordable rental units to serve Brewster's most financially
vulnerable residents and other income-qualified persons and households.
3. Identify and take advantage of existing structures and/or properties that have discounted or
nominal acquisition costs, such as town owned or tax foreclosure properties, to make the
development of affordable housing more financially feasible.
4. Promote affordable housing using methods that minimize impacts on the built environment, such
as accessory apartments, small infill developments in existing neighborhoods, or buy-down
initiatives that convert existing housing into affordable units.
5. Develop a range of projects to serve a range of housing needs including housing for families,
seniors, and special needs populations.
6. Encourage mixed-income development to promote diversity and inclusion.
The funding request is reasonable as a portion of the overall project costs and on a per-unit basis
and adheres to the BAHT Funding Guidelines.
The development pro forma demonstrates that the project is feasible (not applicable if Trust Funds are
requested for predevelopment activities to determine feasibility of a project).
The applicant has demonstrated significant leveraging of the requested BAHT Funds with other
public and/or private funding sources.
The applicant is qualified to undertake the project and has demonstrated success in similar
capacity with comparable projects.
The applicant has demonstrated appropriate site control.
Projects provide additional public benefits such as open space, environmental/conservation,
energy efficiency, historic preservation, public safety, economic development, etc.
The project meets demonstrated community needs.
The applicant has demonstrated project support by other Town boards, committees, the Cape
Cod Commission, other pertinent organizations, and Brewster citizens, as appropriate.
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Brewster Affordable Housing Trust Program Guidelines and Application 12
XI. Application Form/ Attachment List
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Brewster Affordable Housing Trust Program Guidelines and Application 13
Town of Brewster
Affordable Housing Trust
Application Package
APPLICATION FORM
Project/Program Name: ____________________________________________
Trust Program: __________________________________________
Project Location
Street Address: ______________________________ Assessor’s Map & Lot #:_______
Legal Property Owner of Record:___________________________________________________
Sponsor(s)/Organization: _________________________________________________________
Contact Person Name & Title: _____________________________________________________
Telephone: __________________________Email: ______________________________
Mailing Address: __________________________________________________________
Budget Summary
Total Trust Funds Requested:
Total Project Cost:
Sponsor’s Signature: _______________________________ Date: __________
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Brewster Affordable Housing Trust Program Guidelines and Application 14
Sponsor’s Printed Name & Title: ___________________________________________
Project Summary: Please summarize the proposed project and any special features (support
services, sustainability or energy conservation components, historic preservation, etc.)
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Brewster Affordable Housing Trust Program Guidelines and Application 15
1. Sources of Funds: Check all that apply, include dollar amount, and circle if funds are committed or
proposed.
Brewster Affordable Housing Trust $ __________________ committed/proposed
*Brewster Community Preservation Fund $ __________________
______________committed/proposed (*Some funding from the Trust is derived from Community Preservation Funds. Check this box if seeking
additional funds from the Community Preservation Committee.)
Private Bank Loan__________________$ committed/proposed
Sales Revenue $
Other: $
Other: $
Other: $
2. Uses of Funds: Check all that apply. Predevelopment (feasibility, engineering, appraisals,
environmental studies/testing/mitigation, legal work, etc.)
Acquisition
Preservation
Site Preparation (tree clearing, earth removal, etc.)
New Construction
Redevelopment
Administration
Operations
Marketing
Other (please explain)
3. Targeted Population: Check all that apply.
Family Senior/Elderly
Homeless/At Risk of Homelessness Special Needs (identify population): ___________
Housing with Support Services (identify service providers):
Other (identify):
4. Type of Housing: Check all that apply.
Homeownership: Rental:
Single-family Single Room Occupancy
Condominium Individual/Family
Cooperative Group Residence, Congregate
Other Other (identify):
committed/proposed
committed/proposed
committed/proposed
committed/proposed
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Brewster Affordable Housing Trust Guidelines 16
5. Unit Composition (If Applicable): List number of units in each category
Total <=30%
AMI
<=50%
AMI
<=80%
AMI
<=100%
AMI
<=120%
AMI
Market
Rate
SRO
1 Br
2 Br
3 Br
4 Br/+
Note: Refer to (www.huduser.org) for latest fair housing rates.
7. If applicable, Information about the Development Team including:
Owner/sponsor/development entity-
Experience-
Architect-
Engineer-
General Contractor (if known)-
Development Pro-forma-
Operating budget for rental project (For example- One Stop funding application)
Development pro-forma with sales prices for home ownership units.
Submission: All completed application packets should be submitted to:
Town of Brewster Affordable Housing Trust
Jill Scalise, Housing Coordinator
2198 Main Street
Brewster, MA 02631
Email: jscalise@brewster-ma.gov
Phone: 508-896-3701, ext. 1169
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Housing Trust 5 Year-Plan FY23-27
11.16.22
FY23 FY24 FY25 FY26 FY27
Carryforward Balance 1,195,879 1,190,879 893,879 714,569 1,053,821
Anticipated Revenues 1,891,900 2,870,580 2,344,461 2,519,557 2,425,927
Appropriations 1,896,900 3,167,580 2,523,771 2,180,304 2,567,196
End Balance 1,190,879 893,879 714,569 1,053,821 912,553
FY23 FY24 FY25 FY26 FY27
Projects:Funding Source
Housing Coordinator CPA- Salary Only 66,900 70,580 74,461 78,557 82,877 Benefits paid by the Town-approx. 35K/ year
Housing Program Asst.BAHT Salary Only -42,000 44,310 46,747 49,318 19 Hours- new non-benefitted position
Rental Assistance CPA 150,000 150,000 150,000
Preservaton of SHI Homes CPA 300,000 200,000
Buy Down Program CPA 300,000 300,000
Housing Production Plan CPA 30,000
212 Yankee Drive BAHT 75,000
Town Development of Other Properties BAHT 500,000 500,000
Outside Applications for Funding BAHT 50,000 50,000 50,000 50,000
Millstone Road Community Housing CPA/BAHT 1,000,000
Legal Expenses CPA/BAHT 5,000 5,000 5,000 5,000 5,000
Housing Rehabilitation-Child Care Vouchers CDBG-Regional Grant 1,300,000 1,500,000 1,700,000 1,700,000 1,700,000 Town is lead community for Dennis, Wellfleet and Brewster
Total Appropriations:1,896,900 3,167,580 2,523,771 2,180,304 2,567,196
Sources
Short Term Rentals Allocation 375,000 400,000 420,000 441,000 463,050 Financial Forecast 5% escalator
CPA Housing Coord. Wages 66,900 70,580 74,461 78,557 82,877
CPA Rental Assistance 150,000 150,000 150,000
CPA for SHI Homes -200,000
Proceeds on Re-sale of SHI Homes 150,000
CPA Buy Down 300,000 300,000
CPA Housing Production Plan 30,000
CPA Millstone Rd. Community Housing 250,000
Grants & Donations
Community Development Block Grant (CDBG)1,300,000 1,500,000 1,700,000 1,700,000 1,700,000
Total Revenues:1,891,900 2,870,580 2,344,461 2,519,557 2,425,927
CPA Rev 216,900 820,580 224,461 378,557 262,877
CPA Exp 516,900 570,580 224,461 378,557 262,877 390,675.00 5 year average
Estimated annual CPA revenue 1,492,304 1,529,612 1,567,852 1,607,048 1,647,225
Target Allocation Policy- Housing 30%447,691 458,884 470,356 482,115 494,167
TAP - Open Space 30%447,691 458,884 470,356 482,115 494,167
TAP - Recreation 10%149,230 152,961 156,785 160,705 164,722
TAP- Historic 10%149,230 152,961 156,785 160,705 164,722
CPA Recommended 20%298,461 305,922 313,570 321,410 329,445
1,492,304 1,529,612 1,567,852 1,607,048 1,647,225
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Town of Brewster
Housing Production Plan
2022-2027
APPROACH TO IMPLEMENTATION
The table below outlines the potential responsible parties for each strategy, as well as possible time frames for select strategies. The final two columns
on the right indicate whether the strategy follows a recommendation from the 2017 Housing Production Plan, and whether the strategy is connected to
DHCD guidelines for Housing Production Plans (as outlined in Table 23 of this HPP).
Implementation Table
Implementation Strategies
POTENTIAL
Responsible Entities
POTENTIAL
Time Frame
TBD
Follow-up to
2017 HPP
Strategy #
Meets DHCD
Guidelines for
HPP Strategies Lead Support
Regulatory Reform
#1
Reevaluate the existing ADU and ACDU bylaws and other
references to accessory apartments; explore amendments to
streamline these provisions and improve their efficacy.
Planning
Building
BHP
HC
SB
Early
(discussed) #1 ✓
#2 Amend zoning to clearly allow mixed uses that include housing
in business-zoned areas. Planning BHP, SB
HC, TA TBD #2
✓
#3
Reevaluate the existing multifamily dwelling bylaw (Section
179-34) and consider changes and other regulatory measures
to facilitate multi-unit residential development.
Planning HC, TA
SB TBD #5
✓
#4
Explore measures to require or encourage the inclusion of
affordable units in residential development over a certain
number of units.
Planning HC, TA
SB
TBD
#4
✓
#5 Allow and incentivize the adaptive reuse of existing buildings
for the creation of affordable and mixed income housing.
Planning
Building
TA, SB
HC
ZBA TBD #6
✓
#6
Utilizing the findings of the ongoing Integrated Water Resource
Management Plan, continue to identify appropriate wastewater
treatment systems to enable the creation of denser housing
development that can support the inclusion of affordable units.
Interdepartmental:
Health
TA, SB,
Planning Natural
Resources
HC TBD --
19
Town of Brewster Housing Production Plan
2022-2027
2
Implementation Table
Implementation Strategies
POTENTIAL
Responsible Entities
POTENTIAL
Time Frame
TBD
Follow-up to
2017 HPP
Strategy #
Meets DHCD
Guidelines for
HPP Strategies Lead Support
Funding & Assets
#7
Continue to work with nearby communities on the Cape by
pooling CPA funds and other resources to construct affordable
housing in suitable locations throughout the region and meet
regional housing needs.
CPC
TA
HC
SB
BHP
BAHT Ongoing #9 ✓
#8 Develop a five-year financial plan for the BAHT and determine
whether additional funding streams should be explored.
BAHT & Finance
(FT) Team & SB
HC
CPC
First
(In process) #7 & #8
#9
Based upon the BAHT five-year financial plan, explore other
funding opportunities to support housing initiatives at a range
of income levels.
BAHT, CPC, FT, SB,
TA & HC After #8 #7
#10
Explore local property tax incentives for the creation of
affordable housing, such as offering a reduction of property
taxes to an owner renting an affordable unit.
SB
TA
Finance
Assessor
HC
BAHT
TBD #8
#11 Develop criteria for assessing a property’s suitability for the
creation of affordable and attainable housing.
Planning
HC
BAHT
Building
Health
Cons
Comm,
Open Space
TA, SB
First #15 ✓
#12
Inventory existing Town-owned land using the criteria
developed to determine suitability for housing; develop and
issue an RFP for the development of affordable and attainable
housing on properties identified as suitable for housing
development.
Planning
HC
TA
BAHT
Cons Comm
Assessor
SB
Open Space
After #11 #15 ✓
#13
If deemed necessary based upon the findings of the Town-
owned land inventory, develop and issue an RFP for the
acquisition of privately held land for the creation of affordable
and attainable housing.
BAHT
TA
HC
Planning
SB After #12 -- ✓
20
3
Town of Brewster
Housing Production Plan
2022-2027
Implementation Table
Implementation Strategies
POTENTIAL
Responsible Entities
POTENTIAL
Time Frame
TBD
Follow-up to
2017 HPP
Strategy #
Meets DHCD
Guidelines for
HPP Strategies Lead Support
Education & Advocacy
#14 Develop a collaborative housing education plan that connects
to the Town’s Local Comprehensive Plan (LCP).
BAHT
BHP
HC
Vision
BHA
COA
Early
(In process) #13 & #16
#15
Continue to ensure regular participation by staff and members
of Town bodies in available trainings on housing-related issues
including fair housing, local and regional housing needs,
comprehensive permit administration, and other relevant
topics.
HC
BAHT
BHP
Planning
CPC
ZBA
SB
Finance
Ongoing #13
Local Policy & Planning Strategies
#16 Continue to make good use of 40B, including the Local Initiative
Program (LIP), as a vehicle for creating affordable housing.
BHP
BAHT
HC, TA
SB
ZBA
CPC
Ongoing
(Brewster
Woods,
Habitat)
#14 ✓
#17
Encourage public/private partnerships to facilitate the
collaborative production of affordable housing to meet a range
of community needs.
BAHT
BHP
HC
TA
SB
Planning
CPC
TBD -- ✓
#18
Continue to monitor the impacts of short-term rentals on the
availability of year-round rental units; review and consider
changes to local policies accordingly.
SB
Finance
TA
BAHT
HC Ongoing --
#19
Increase housing staff capacity to ensure continued and
consistent collaboration with the Building, Conservation,
Health, and Planning Departments.
TA
Finance
HC
Interdepartmental:
Building
Planning
TBD #12
21
Town of Brewster Housing Production Plan
2022-2027
4
Implementation Table
Implementation Strategies
POTENTIAL
Responsible Entities
POTENTIAL
Time Frame
TBD
Follow-up to
2017 HPP
Strategy #
Meets DHCD
Guidelines for
HPP Strategies Lead Support
Community Resources & Local Support
#20
Continue the CDBG-funded housing rehabilitation program to
enable income-eligible homeowners to make critical home
repairs.
HC
TA
Finance
Building
SB Ongoing --
#21 Evaluate current CPC-funded housing initiatives and consider
adjusting to meet current needs.
BAHT
CPC, SB
HC
BHP
Early/
Ongoing
(Discussed)
--
#22
Explore other opportunities for direct support for eligible
households, including partnerships with local non-profits and
housing assistance providers.
HC
BHP
BAHT
COA
CPC
BHA
TBD --
Notations:
BAHT- Brewster Affordable Housing Trust FT- Finance Team
BHA- Brewster Housing Authority HC- Housing Coordinator
BHP- Brewster Housing Partnership SB- Select Board
COA- Council on Aging TA- Town Administration
CPC- Community Preservation Committee ZBA- Zoning Board of Appeals
Cons Comm- Conservation Committee
22
Town of Brewster
Housing Production Plan
2022-2027
68
Alternatively (or in addition to IZ), the Town could enrich the underutilized Major Residential
Development (Section 139-35.2) or Planned Residential Development (Section 179-36) bylaws to
encourage the inclusion of affordable units, as suggested in the 2017 HPP. The Town could also
activate the “reserved” Affordable Multifamily Dwelling Units bylaw (Section 179-42.1[C][3]), which
the Use Regulations table indicates would be allowed by right (as opposed to special permit) in the C-
H district. However, as pointed out in the 2017 HPP, this should also involve revisiting the limitation
on number of bedrooms in the definition of “Affordable Multifamily Dwelling Units (AMDU)” in
Section 179-2 to eliminate potential fair housing conflicts. Additionally, reference to immediate family
should be removed from the definition of “Affordable Housing" in Section 179-2 to avoid confusion
about the intent of the bylaw.
STRATEGY 5. Allow and incentivize the adaptive reuse of existing buildings for the creation of affordable
and mixed income housing. In 2020, the Zoning Board of Appeals granted Elevation Financial a use
variance to develop the former Wingate Rehabilitation Center into housing. While this successful
public-private partnership will lead to the creation of 132 units of 55+ housing (27 units of which are
affordable), the legal mechanism by which this was accomplished is difficult to replicate.
Massachusetts law outlines the specific findings a ZBA must make to grant a variance, and generally
it is challenging to meet these requirements. Instead, the Town could explore allowing conversion of
existing structures to residential uses by special permit or incentivizing adaptive reuse of existing
structures to facilitate housing production.
STRATEGY 6. Utilizing the findings of the ongoing Integrated Water Resource Management Plan, continue
to identify appropriate wastewater treatment systems to enable the creation of denser housing
development that can support the inclusion of affordable units. The Town is currently in Phase III of its
Integrated Water Resource Management Plan, or IWRMP, a long-term project to develop an integrated
approach for the protection and restoration of the Town’s waters. This phase of the project will address
water resources planning, including an evaluation of wastewater management alternatives and bylaw
updates to implement the stormwater management recommendations of Phase II. The findings of this
project will help inform solutions that may enable the provision of denser development alongside
protection of the environment.
Funding & Assets
STRATEGY 7. Continue to work with nearby communities on the Cape by pooling CPA funds and other
resources to construct affordable housing in suitable locations throughout the region and meet regional
housing needs. Section 5(b)(1) of the Community Preservation Act legislation reads: “The community
preservation committee shall study the needs, possibilities and resources of the city or town regarding
community preservation, including the consideration of regional projects for community
preservation.” (Emphasis added.) Recognizing that addressing regional housing creation benefits all
area communities, Brewster has contributed CPA funds toward several regional housing initiatives in
recent years, including funding for homes for adults with autism in Orleans (Cape Cod Village, 2016)
and Dennis (FORWARD, 2019), a veterans’ home in Dennis (for CIVOC, 2021), and most recently
23
Town of Brewster
Housing Production Plan
2022-2027
69
toward Pennrose in Orleans, a redevelopment project that will provide sixty-two rental units. The
developer is proposing 65 percent local preference and 10 percent regional preference, the breakdown
approved by DHCD for the Village at Nauset Green in Eastham. Based on DHCD local preference
definitions, applicants who work in Orleans, for the Town of Orleans, or whose children attend the
Nauset Regional Middle or High School, are considered part of the local preference pool even if they
do not live in Orleans.
STRATEGY 8. Develop a five-year financial plan for the Brewster Affordable Housing Trust and determine
whether additional funding streams should be explored. Both the Select Board and Affordable Housing
Trust identify this as a key priority; the Select Board’s FY2022-2023 Strategic Plan includes Goal H-1
to “Identify Affordable Housing Trust operating/capital needs and develop funding plan,” and the
Affordable Housing Trust’s Key Priorities for 2022 include developing a “5-Year Financial Plan for the
Trust.”
STRATEGY 9. Based upon the BAHT five-year financial plan, explore other funding opportunities to
support housing initiatives at a range of income levels. Depending on the needs identified through the
BAHT’s financial plan, the Town can also look at creative ways to increase funding for housing
initiatives. As an example, the BAHT could establish a “Housing Opportunity Fund” and regularly
apply for CPA funds to build and replenish this resource annually. While Brewster has made excellent
use of CPA funds for housing initiatives, having more substantial funds available would enable the
BAHT to act quickly on property acquisition opportunities that may arise. The BAHT would still have
to apply to annually for such funds, but once these CPA funds were awarded to the Trust, they would
not need to be reappropriated at Town Meeting for a specific purpose. The Town of Hingham follows
this practice and has for several years, with their AHT stating in their 2021 CPA application, “Often
unknown opportunities to create new affordable housing units arise and require immediate
responses…. Replenishing the ‘opportunity fund’ will allow the Trust to respond quickly to those
opportunities…” The Town could also work to raise resident awareness that the BAHT can receive
tax-deductible gifts in the form of “real property, personal property or money, by gift, grant,
contribution, devise or transfer from any person, firm, corporation or other public or private
entity…“60 Strategy 14 discusses developing a collaborative housing education plan, which could
include a “fundraising” component that explains how residents can make such tax-deductible gifts to
the BAHT, sets fundraising goals, describes how funds and other gifts will be used, and so forth.
The Town can look to support the mission of the BAHT and the income levels it is intended to serve
(up to 110 percent AMI), as well as potentially funding housing initiatives beyond this level. While the
primary purpose of a Housing Production Plan is to increase the share of SHI-eligible units within a
community and work toward the state’s 10 percent minimum goal, there are also substantial housing
needs outside of these income levels because the supply of housing — particularly rental housing —
does not meet the demand. Provincetown addressed this need by passing of a home rule petition to
establish its Year-Round Market Rate Rental Housing Trust to “create and preserve year-round rental
60 MGL c. 44A, § 55C: Municipal Affordable Housing Trust
24
Town of Brewster
Housing Production Plan
2022-2027
70
units in the town of Provincetown including, but not limited to, market rate units for the benefit of
residents of the Town.” The Legislature approved the Town’s home rule petition, and the Trust was
officially established in 2016. Chatham has recently taken a similar step, approving three home rule
petitions in 2021 relating to funding the creation of housing for households earning up to 200 percent
of the area median income. One such measure was the local approval of a real estate transfer tax of 0.5
percent on the sale of homes over $2,000,000, paid by the purchaser, with proceeds going into a
“Housing Fund” that would have more leeway than the CPC or AHT in terms of income levels served.
In 2021, several other Massachusetts communities approved the submission of home rule petitions
relating to real estate transfer fees to the Legislature, although all of these petitions are pending at the
state level.
Because Brewster’s housing needs at lower income levels are the greatest as demonstrated by the
Needs Assessment, the Town should take care not to propose diverting existing funding sources away
from these needs and instead may wish to consider new funding solutions for income levels over 80
percent.
STRATEGY 10. Explore local property tax incentives for the creation of affordable housing, such as offering
a reduction of property taxes to an owner renting an affordable unit. By offering to reduce property taxes
for property owners that voluntarily participate in meeting the Town’s affordable housing needs,
Brewster can convert existing units to affordability fairly quickly and easily. Provincetown has had
affordable housing property tax exemptions of this type on the books for years. The law, passed in
2002, makes residential properties occupied by low-income households exempt from taxes. If only
some of a parcel is occupied by an eligible household, taxes are reduced proportionally to the
percentage of the square footage of the structure occupied by that household. Unlike many other
strategies in this section, a Provincetown-style tax incentive would not necessarily involve any formal
deed restrictions, meaning that affordable units created under such a law would not count towards
Brewster’s Subsidized Housing Inventory, but still can address important local needs. In addition,
such a measure would require Town Meeting approval to submit a home rule petition to the
Legislature.
Another way for a town to utilize property taxes to incentivize affordable housing development is
through tax increment financing (TIF). This approach targets new development by allowing a
property owner to waive or reduce property taxes for a set period, which can then be phased back in
gradually, in exchange for including some number of affordable units. TIFs require the establishment
of TIF-designated area approved by the Economic Assistance Coordinating Council, which essentially
requires that the area present “exceptional opportunities for economic development.” Such a measure
may be dependent on the direction of the Vision Planning process with regards to establishing a true
the Town Center or Town Centers.
STRATEGY 11. Develop criteria for assessing a property’s suitability for the creation of affordable and
attainable housing. Once developed, such criteria can be used in a variety of ways – as part of an RFP
for acquiring land for housing; to assess Chapter 61 properties being considered for acquisition; or for
25
1
Jill Scalise
From:Shirin Everett <SEverett@k-plaw.com>
Sent:Monday, August 29, 2022 2:03 PM
To:Donna Kalinick; Jill Scalise
Subject:BREW: Draft Housing Trust Guidelines 08.18.22 for Review
Attachments:KP-#828223-v1-BREW__BAHT_Guidelines.DOCX
Donna and Jill,
Attached are my recommended edits to the BAHT Guidelines. As you know, GL c. 44B expressly authorizes CPA funds to
be used in any municipality. Although GL c.44, s.55C, the Affordable Housing Trust Fund statute, is silent on where Trust
funds may be expended, it is my opinion that, since the purpose of GL c.44, s.55C is to create a local pool of funds, it
would be best for the BAHT to use CPA funds for projects that are located in other municipalities, and reserve non-CPA
AHT funds (such as AHT funds appropriated from free cash) for expenditures within the Town of Brewster.
Please let me know if you have any other questions.
Shirin Everett, Esq.
KP | LAW
101 Arch Street, 12th Floor
Boston, MA 02110
O: (617) 654 1731
F: (617) 654 1735
severett@k-plaw.com
www.k-plaw.com
This message and the documents attached to it, if any, are intended only for the use of the addressee and may contain information that is PRIVILEGED
and CONFIDENTIAL and/or may contain ATTORNEY WORK PRODUCT. If you are not the intended recipient, you are hereby notified that any
dissemination of this communication is strictly prohibited. If you have received this communication in error, please delete all electronic copies of this
message and attachments thereto, if any, and destroy any hard copies you may have created and notify me immediately.
From: Donna Kalinick <dkalinick@brewster-ma.gov>
Sent: Monday, August 29, 2022 11:31 AM
To: Shirin Everett <SEverett@k-plaw.com>; Jill Scalise <jwertz-scalise@brewster-ma.gov>
Subject: RE: Draft Housing Trust Guidelines 08.18.22 for Review
Thanks Shirin. Also as part of the review, can you tell us if the BAHT can fund projects outside of Brewster, similar to
what CPC can do with regional application such as Pennrose. Thanks. Donna & Jill
From: Shirin Everett <SEverett@k-plaw.com>
Sent: Tuesday, August 23, 2022 11:41 AM
To: Jill Scalise <jwertz-scalise@brewster-ma.gov>
Cc: Donna Kalinick <dkalinick@brewster-ma.gov>
Subject: RE: Draft Housing Trust Guidelines 08.18.22 for Review
Hi Jill, I’ll review and get back to you.
Shirin Everett, Esq.
KP | LAW
26
2
101 Arch Street, 12th Floor
Boston, MA 02110
O: (617) 654 1731
F: (617) 654 1735
severett@k-plaw.com
www.k-plaw.com
This message and the documents attached to it, if any, are intended only for the use of the addressee and may contain information that is PRIVILEGED
and CONFIDENTIAL and/or may contain ATTORNEY WORK PRODUCT. If you are not the intended recipient, you are hereby notified that any
dissemination of this communication is strictly prohibited. If you have received this communication in error, please delete all electronic copies of this
message and attachments thereto, if any, and destroy any hard copies you may have created and notify me immediately.
From: Jill Scalise <jwertz-scalise@brewster-ma.gov>
Sent: Tuesday, August 23, 2022 11:20 AM
To: Shirin Everett <SEverett@k-plaw.com>
Cc: Donna Kalinick <dkalinick@brewster-ma.gov>
Subject: Draft Housing Trust Guidelines 08.18.22 for Review
Hi Shirin,
The Housing Trust has been working to develop guidelines to better enable the Trust to fund affordable housing
activities. Please see the attached draft document for your legal review.
In addition to general review, we have a couple questions.
In the document, based on the Trust bylaws, it states that funds greater than $50,000 require Select Board
approval. Does this adequately address the current requirement?
Does Trust funding have to remain in Brewster? For example, could the Trust support a regional affordable
housing project like can be done with CPA funds?
The Housing Trust meeting is Thursday September 1st. We would appreciate the review by Monday August 29th so we
can put the document in the meeting packet on Tuesday.
Thank you,
Jill & Donna
Jill Scalise
Housing Coordinator
Town of Brewster
2198 Main Street, Brewster, MA 02631
508-896-3701 ext. 1169
Brewster Town Offices are open to the public Monday through Thursday from 8:30 to 4:00pm, and by appointment on
Fridays. For the latest updates on Town services, please visit www.brewster-ma.gov
27
Brewster Affordable Buydown Program Description 1.03.2023
Impact of the Buydown Program
Twelve properties have been purchased with buydown funds (includes state funding). All were
affordably purchased with housing costs under 30% of gross income. All received a universal deed rider.
- 10 properties were already on the Subsidized Housing Inventory (SHI). Reasons for buydowns:
resale formula unaffordable or required costs for needed property improvements.
- 2 were market-rate properties (1 single family home, 1 condo) Not currently on the SHI.
Current Affordable Buydown Program 2007- Present
Provides up to $30,000 for eligible buyers (up to 80% AMI) purchasing a home in Brewster. Requires
a permanent affordable home deed restriction on the home. The CPA funded award is an interest
free loan, forgivable after 15 years.
Current Funding of the Buydown Program
Original funding= $360,000 ($60,000 5/2007 TM & $300,000 11/2008 TM)
$62,500 remains in the CPC grant account
Average 1 buy-down/ year.
Anticipate 2023 CPA application for additional funds
Oversight of Buydown Program
Obtain funding (for example, submit CPA grant application for funds)
Vote on approval of buydown award requests
Evaluate & consider making program changes: For example, current program functioning
as a down payment & closing cost program. HAC is adjusting their SHI resale process.
Note: Housing Coordinator works with applicants and processes applications
Decision Points:
Whether to continue program?
If so, what entity to oversee the program?
How to fund the program?
How to operate the program, as is or make changes?
Background Information for decision points
28
Example of current affordable home resale that requires buydown assistance
Background: On January 5,2023 the Town received notice of intent to sell an affordable Yankee
Drive condo that was purchased in 2010 with a $30,000 CPA buydown grant. On January 9, the
Select Board approved exercising the Town’s right to locate an eligible purchaser. Housing
Assistance Corporation (HAC) is the Monitoring Agent working on the resale of the property. If
not sold to an eligible purchaser, the affordable deed restriction can be lost.
Resale Price: According to the affordable deed rider, Maximum Resale Price= $255,476
(Barnstable Median Family Income $115,600 X 2.21, resale multiplier from 2003 Regulatory
Agreement) According to Assessment, FY22 Fair Market Value was lower than adjusted value.
Affordability: A $49,476 buydown would make the property affordable at 80% AMI (Area
Median Income). Mortgage Calculator below used to determine an affordable purchase price .
Action: Within the next 30 days the CPC and/or Trust will need to address a potential buydown
of this property.
Affordable Purchase Price Limit
Sales Price $206,000
5% Down payment $10,300
Mortgage $195,700
Interest rate 6.88%
Amortization 30
Monthly P&I Payments $1,285.61
Tax Rate $6.99
monthly property tax $120
Hazard insurance $69
PMI $127
Condo/HOA fees (if applicable) $300
Monthly Housing Cost $1,901
Necessary Income: $76,059
Household Income:
# of Bedrooms 2
Sample Household size 3
80% AMI/"Low-Income" Limit $78,300
Target Housing Cost (80%AMI) $1,958
10% Window $68,513
Target Housing Cost (70%AMI) $1,713