City of Highland Park Affordable Housing Plan 2020

Introduction and Background

The Illinois Affordable Housing Planning and Appeals Act (AHPAA), Public Act 093-0595, was
adopted by the Illinois General Assembly in 2003. Effective January 1, 2004, communities that
were identified by the Illinois Housing Development Authority (IHDA) as having less than 10% of
affordable housing were defined as “non-exempt” from the requirements of the Act.1 On
December 28, 2018, IHDA notified the City of Highland Park that it continues to be a non-exempt
community.2

Pursuant to AHPAA, non-exempt communities are required to submit an affordable housing plan
to IHDA within 18 months of notification. The plan must identify the number of affordable
housing units that are necessary to exempt the community from the Act, identify lands within the
jurisdiction that are most appropriate for the construction of affordable housing, identify possible
incentives that the local government may provide to attract the development of affordable
housing, and identify the selection of one of three prescribed goals to increase local affordable
housing stock.

One of the goals recommended in the Act is to require a minimum of 15% of all new development
or redevelopment be affordable. The City of Highland Park continues its commitment to meeting
this goal through its Inclusionary Housing Zoning requirements. The City of Highland Park
submits this Affordable Housing Plan to restate its commitment to increasing the number of
affordable housing units and to comply with all aspects of the Affordable Housing Planning and
Appeals Act.

Highland Park’s Commitment to Affordable Housing

The City of Highland Park has long recognized the importance of providing affordable housing
and has a history of taking action to address the community’s affordable housing needs. The
following provides a brief timeline of Highland Park’s commitment to affordable housing.
 1973: The City established its Housing Commission in 1973.
 1978: Through the Housing Commission’s efforts, the City opened its first affordable
housing development in 1978 – The Frank B. Peers Building. This development is owned
and operated by the City’s Housing Commission and provides 67 affordable rental units
serving seniors and persons with disabilities. The development is supported through the
Federal Project-Based “Section 8” rental subsidy program, which pays fair market rental
costs above 30% of each household’s annual income.
 1980: The Housing Commission became the operator of the Walnut Place, a 68 unit
development. Walnut Place is owned by the Highland Park Apartment Associates, a
private entity separate and apart from the City of Highland Park and the Housing

1 Public Act 093-0595 and its amendments are codified at 310 ILCS 67/1 et seq. (“Act”).
2 IHDA’s 2018 Non-exempt Local Governments: https://www.ihda.org/wp-content/uploads/2015/07/2018-NELG-
List-Final.pdf

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 Commission. The development provides 56 rental units for seniors and persons with
disabilities and 12 rental units for families, also made affordable through the Section 8
Program.
 1982: The Ravinia Housing Development was opened in 1982; it is owned and operated
by the City’s Housing Commission and provides 17 affordable rental units for families, also
made affordable through the Federal “Section 8” Program.
 1998: The City supported the development of Sunset Woods Condominiums, a 60-unit
affordable project for seniors. The development opened in 2002, and was financed with a
combination of public and private funding, including Lake County’s HOME Program, City
land donation, and IHDA’s Trust Fund program. The development provides 60
permanently affordable units for seniors, 46 privately owned condominiums and 14 rental
units. The 14 rental units are owned by the Housing Commission and operated through a
property management contract with Housing Opportunity Development Corporation
(HODC)3.
 January 2001: The City Council adopted an Affordable Housing Planning and
Implementation Plan (AHP) as an element of the City’s Comprehensive Master Plan.
 May 2002: The City established an Affordable Housing Trust Fund (HTF) to provide
financial resources for affordable housing development and preservation. The HTF is
funded primarily by a demolition tax and by fees required in lieu of providing affordable
housing units per the City’s Inclusionary Housing Ordinance. Additionally, the HTF is
authorized to receive resources and property from both public and private sources.4
 March 2003: The City Council approved a resolution updating the 2001 AHP and
reaffirming its recommendations.5 As a result of the recommendations in the AHP, the
City has taken on a number of initiatives designed to increase the number of affordable
housing units.
 March 2003: The City launched a community land trust, the Highland Park Illinois
Community Land Trust (HPICLT), now known as Community Partners for Affordable
Housing (CPAH). CPAH is a private, non-profit, 501(c)(3) organization created for the
benefit of the Highland Park community for the purpose of providing permanently
affordable housing on the land that it owns. The Community Land Trust has created 61
units of permanently affordable housing in Highland Park since 2003, and has recently
expanded its operations and partnerships with other north suburban communities.6
 August 2003: The City adopted an Inclusionary Housing Ordinance that requires 20%
of the units in all new developments, with five or more units, be affordable.7 As of October
2019, the Inclusionary Housing Ordinance has led to the addition of 5 permanently
affordable homes, 15 affordable rental units, and commitments for an additional 28 units
with either permanent or long-term affordability.

3 A third party property manager, who manages the 14 units owned by the City’s Housing Commission.
4 See Attachments 2-4- Ordinance, Housing Trust Fund; Brochure Housing Trust Fund; and Ordinance, Demo. Tax
5 See Attachment 1- Affordable Housing Needs and Implementation Plan -2003
6 See Attachment 5- CPAH 2018-2019 Annual Report and Brochures
7 See Attachments 6- Ordinance, Article 21 Inclusionary Housing as Amended October 28, 2019

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  2019: City Council adopts amendments to the City’s inclusionary housing regulations to
encourage the development of new affordable housing units by providing greater clarity,
more certainty, and additional flexibility in meeting the affordable unit requirements.
However, at least 15% (after market-rate unit bonuses) of units in new developments must
be affordable.
 The amendments: Clarify amenities required for affordable units, and fee waiver
calculation,
 Allow for partial payments in-lieu and payments in-lieu for fractional units,
 Make market-rate unit bonuses by-right,
 Distribute payments-in-lieu over a project’s development; and
 Requires that in addition to ownership units, that rental units also be affordable in
perpetuity.

These changes are expected to encourage the creation and preservation of affordable housing in
the community. The proposed change in the way the fees-in-lieu and cash payments are
calculated should increase contributions to the Housing Trust Fund, which can then be used to
further the preservation and development of affordable housing through the City’s affordable
housing grant-making activities. Additionally, the requirement that new rental units remain
affordable in perpetuity guarantees permanent affordable housing options to multiple successive
occupants, independent of fluctuations in the housing market.
IHDA’s Assessment of Affordable Housing in Highland Park
IHDA’s most recent report of Non-Exempt Local Governments from 2018 indicates that the
number of Affordable Housing Units in Highland Park increased by 283 units since its last report
in 2013.8 The increase brings the City’s proportion of units that are affordable to 9.3%, close to
the 10% required to exempt the City from the reporting requirements of AHPAA. Highland Park
now has the highest proportion housing units that are affordable of all municipalities within the
State with less than 10% affordable units. In addition to the use of IHDA’s estimating technique9,
the City continues to encourage IHDA to add a measure to its report to enable communities to
report the number of their housing units that have permanent or long-term affordability
requirements. Adding a measure of long-term and permanent affordability like this offers the
following advantages:
 It is a true measure of affordability, because permanent and long-term affordability is not
subject to shifting market forces;

 It further acknowledges community policy actions that expand the affordable housing
stock

8 IHDA’s 2013 Non-Exempt list estimated the number of affordable housing units in Highland Park at 773.
9Examples of how IHDA estimates the number of affordable housing units within a community can be located in the
Affordable Housing Planning and Appeals Act: 2018 Non-Exempt Local Government Handbook:
https://www.ihda.org/wp-content/uploads/2015/07/2018-AHPAA-Handbook-Final.pdf

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Affordable Housing Plan
The Affordable Housing Plan below is intended to comply with the requirements of the Affordable
Housing Planning and Appeals Act.
1. A statement of the total number of affordable housing units that are necessary
to exempt Highland Park from the Affordable Housing Planning and Appeal Act
(AHPAA)

City of Highland Park Housing Units by Type

Total Housing Units
11,361
(U.S. Census, 2016 Annual Community Survey, 5-year est.)

10% of Total Housing Units

1,136
(AHPAA’s threshold number of affordable housing units)

Highland Park’s Est. Total Affordable Housing Units

1,056
(per IHDA’s 2018 Report of Non-Exempt Local Governments)

Number of additional affordable units needed to

exempt the City of Highland Park from AHPAA 80

2. Identification of lands and structures most appropriate for affordable housing

 Highland Park is a built-up community, with minimal amounts of developable land

remaining. However, by virtue of Highland Park’s Inclusionary Housing ordinance, which
requires that at least 15% of the units in all developments that include a residential
component of 5 or more dwelling units be set-aside as affordable housing, all sites that are
suitable and zoned exclusively for residential development or mixed use including
residential are suitable sites for affordable housing. 10
 All sites currently under developed relative to their current zoning are potential sites
appropriate for affordable housing. For example, sites where there are single homes in
multi-family districts and sites where there are limited multi-family units in districts that
allow for more intense multi-family development.
 Sites currently zoned industrial may be also be appropriate for residential redevelopment
in the future. For example, the former Solo Cup Company site currently zoned for industry
may provide a potential opportunity for a large multi-family residential development and
the addition of affordable housing units through the application of the City’s inclusionary
housing requirements. The City has received a preliminary proposal for redevelopment of
the site, which would include a mix of multi-family apartments, townhomes, and carriage
houses.

10
See Attachment 7, Map, Zoning Ordinance Districts

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  The U. S. Navy is offering for sale and redevelopment 37 acres at the southern end of Fort
Sheridan. This site also provides a potential opportunity for a large residential
development which would also provide additional affordable housing units through the
application of the City’s inclusionary housing requirements.
 Construction has been completed for 52-unit, two phase, multi-family Planned
Development at 807-833 Laurel Avenue. The project includes four rental units and three
permanently affordable for-sale units.
 Construction has been completed for an 8-unit condominium development at 1633-1645
McGovern Street. When the project is completed, it will include one permanently
affordable for-sale unit.
 Construction is underway on a 30-unit mixed-use development at 555 Roger Williams
Avenue which when completed will include five affordable rental units.
 The City approved a proposal of a 161-unit multi-family development at 1850 Green Bay
Road, which is currently under construction. The developer’s Inclusionary Housing Plan
includes providing 17 on-site affordable rental units, and providing a cash payment of
$1.25 million to the Housing Trust Fund in lieu of providing the additional 10 affordable
units required by the ordinance. These monies will be used to acquire and produce
affordable housing units.

3. Incentives that Highland Park will provide to attract affordable housing

The following City policies provide incentives for the development of affordable housing:

 City Council recently approved a number of amendments to the Inclusionary Housing

policy designed to provide more flexibility and clarity for meeting the requirements of the
ordinance. In October 2019, the City changed the code to allow developers to provide a
mix of affordable units on-site and payments in-lieu.
 The City’s Inclusionary Housing Ordinance has always provided developers market rate
unit and density bonuses designed to attract development and encourage affordable unit
production by providing incentives that help defray the cost of affordable housing units.
The October 2019 amendments to the City inclusionary housing code allow developments
to take advantage of all the attributable bonuses available for any affordable units provided
on-site by-right.
 The recent Inclusionary Housing Ordinance amendments made the previously
discretionary 0.5 market-rate unit density bonus a by-right, increasing the total
by-right density bonuses allowed to 1.5 market-rate units for each affordable unit
provided. The changes reduce uncertainty regarding allowable units.
 The Inclusionary Housing ordinance also provides for a waiver of all development-
related fees and costs attributable to the affordable units, including application
fees, building permit fees, plan review fees, inspection fees, sewer and water tap
fees, demolition permit fees, and the demolition tax.

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  The City Council has the authority to waive development impact fees attributable
to the development of affordable units. To the extent any impact fees attributable
to affordable units are not waived, the Inclusionary Housing ordinance allows that
such fees can be paid from the City’s Affordable Housing Trust Fund.
 Developers of affordable housing in excess of the 20% affordable unit requirement in the
Inclusionary Housing Ordinance, may apply for grants from the Affordable Housing Trust
Fund.

4. Goal for purpose of compliance with the Illinois Affordable Housing Planning
and Appeal Act

The City of Highland Park’s goal for complying with the AHPAA is requiring a minimum of
10% of affordable housing within its jurisdiction. For the 2020 update, IHDA determined that
the City of Highland Park within 0.7% of reaching the 10% goal for affordability, with an
affordability rate of 9.3%. The City intends to continue to work towards this goal through the
application of its Inclusionary Housing Ordinance and implementation of its Scattered Site
Grant program.

Attachments:
1) Aff Hsg. Needs and Implementation Plan - 2003
2) Ordinance, Housing Trust Fund
3) Brochure, Housing Trust Fund
4) Ordinance, Demolition Tax
5) CPAH 2018-2019 Annual Report and Brochures
6) Ordinance, Article 21 Inclusionary Housing as amended October 28, 2019
7) Map, Zoning Ordinance Districts