Lower Owes COAH 107 Affordable Housing Units

VILLAS — Lower Township has an obligation from the state’s Council on Affordable Housing (COAH) to provide 107 affordable housing units by 2018.
At an April 16 meeting, Lower Township Planning Board approved an affordable housing plan that will next be submitted to Township Council for their approval.
The plan was prepared by Andy Thomas of Thomas Planning Associates. He said the township’s COAH obligation is a combination of Round One, Two and Three regulations. Round One and Two consists unmet affordable housing obligations from 1987 to 1999 which totaled 324 housing units, said Thomas.
In 2004, COAH created Round Three affordable housing obligations covering Jan. 1, 2004 to 2018 under new rules not based on a fixed number of units needed but based on “growth share.”
“What that means simply is as a municipality grows, there will be an affordable housing obligation that goes along with that growth and COAH regulations say that on the residential side, for every five market rate units that are constructed, there will be an obligation of one affordable unit,” he said.
For every 16 new jobs created in the township by a business, one affordable unit must be constructed, said Thomas.
Under Round Three regulations, COAH predicted Lower Township would need 18 affordable units by 2018 based on the creation of 17 new jobs and the building of 88 market rate-housing units.
Thomas said the township has actually exceeded that projection. He said the Round Three obligation would now be based on actual development in the township since 2004 plus any new development anticipated between now and 2018.
Under Round Three, the township has an obligation of 100 affordable units, said Thomas. That produced an obligation of 324 units from Round One and Two and 100 units under Round Three for a total of 424 affordable housing units.
In addition, COAH has a rehabilitation component in Round Three, which specifies the township should rehab 72 housing units by 2018. Thomas said the township already has a “very successful rehab program and is well on its way to rehabbing that number of units.”
He said 59 units have been rehabbed since 2000.
Lower Township has existing affordable housing units with two ARC group homes and units at Townbank Manor apartments, Yorkshire Place and Victoria Commons, which are senior, affordable housing units. Thomas said the township could receive 122 credits for those units from a total of 307 units.
The township cannot receive credit for all those affordable units because COAH allows only 25 percent of its obligation to be met through senior housing, he said.
Haven House, a senior housing complex, opened 75 units last year but the township will only receive credit for 25 units, said Thomas.
The Round One and Two obligations of 324 units can receive credit of 122 units, which reduces the obligation to 202 units. The Round Three obligation can be reduced by 25 existing units in Haven House reducing the total affordable housing obligation from 424 to 277 units.
To further reduce its Round One and Two obligations, the township can use a vacant land inventory adjustment that indicates how much vacant, developable land could support affordable housing. He said wetlands and areas in farmland preservation and state and county owned properties are eliminated as possible sites.
Thomas said for properties that do not have sewer service available to them, which is most of the township, 7.9 acres of land would be needed to install one septic tank under new state Department of Environmental Protection regulations on the western side of the township.
On the eastern side of the township, 8.8 acres of land would be needed to install one septic tank, he said.
“This translates into needing at least 40 developable acres to get to that threshold of one affordable unit,” said Thomas.
He said there are no 40-acre parcels that are applicable.
Of vacant properties in the sewer service area, most are not large enough with many being a half-acre or less, said Thomas. Two potential properties remain for affordable housing, one off Route 9 and another along Delaware Bay near Ohio and New York avenues.
Thomas said those properties offered a potential of 32 affordable units.
“What this means is you can adjust your Round One and Two number all the way down to 32 units based on the affordable land that is left,” he said.
That leaves the township with a Round Three obligation of 75 affordable units dropping the township’s total obligation down to 107 units, said Thomas.
He recommended the township adopt an affordable housing fee ordinance on new development of 1.5 percent of assessed value of a new house or improvement and 2.5 percent on non-residential development. The money will go into a dedicated affordable housing trust fund in the township.
Another option is for the township to purchase homes at market rate prices and turn them into affordable housing by using money from the trust fund. The homes would be deed restricted for 30 years.
The program is limited to 10 “for sale” units and 10 rental units.
The township can adopt a growth share ordinance to cover a developer who builds five or more units which would require an affordable unit built on site, off site or making a payment into a fund. The required fee to be paid by a developer cover an affordable unit would be $182,000, said Thomas.
The township is required to pass an affordable housing ordinance which sets up how fees would be collected, standards for units and how the plan would be administered.
Thomas said doing a “filing” with COAH would protect the township for two years from a Builder’s Remedy Lawsuit. During those two years, the township can decide if it wants full certification which would protect it through 2018.
Income levels to be eligible for affordable housing in Lower Township are: moderate income, two-person household, maximum income of $43,047.
For a low income, two-person household, maximum income is $26,904.
Thomas said that translates into a maximum, home sale price of $148,000 for moderate income households and $91,000 for low income.
Rental prices are $918 per month for a two-person moderate income household and $528 per month for a low income, two-person household, he said.