[subterranean]

Originally Posted by hybrydy

These low income units won't go to true 'low income' households. There's a major loss of low income housing ongoing.

Eligibility for regulated affordable housing is based on income. “Low-income” is defined by the U.S. Department of Housing and Urban Development (HUD) based on the area median income, or AMI. HUD calculates AMI as the median, or middle, income for a household in your metropolitan area.

https://detroitmi.gov/departments/ho...g/who-eligible

You're correct about federal AMI calculations, but there is no documentation whatsoever that I am able to find from the developer, the architect, the builder, MEDC, DEGC, Detroit Brownfield Redevelopment Authority, City of Detroit, MSHDA, or anywhere else for that matter that would indicate that these would actually be federally regulated affordable units.

In fact, everywhere I've seen the financials posted, including from Downtown Detroit Partnership, indicates that aside from Brownfield Tax Credits, their capital stack is 100% privately financed. If it had LIHTC or HOME or some other federal funds requiring a long-term affordability period, those would be listed, and would be enforced by a land use restrictive covenant for probably 50 years using the federal AMI standards.

Detroit did pass an inclusionary housing ordinance requiring new housing developments with city funding to contain 20% affordable units, but there doesn't appear to be any evidence of financial support from the city. Their Inclusionary Housing Guidelines don't contain anything about brownfield tax credits. Maybe it's because of a land deal. If so, then the City's 80% AMI limit explicitly states that it is based on MSHDA's Wayne County income limit, which for a family of 2 is $39,760 according to the previously linked guidelines. It further states that if MSHDA stops publishing their income limits for Wayne County then the Director will determine an alternative method for calculating AMI for the City. It's clear the rationale for using this lower income limit is that the regional AMI is not representative of Detroit.