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Comment: Long term affordability is desirable but to say that it should be forever is not helpful. HICDC has developed low income housing on land leased from private parties. Such sites would not be available if the requireent is that the land can only be used for affordable housing - forever. The practical result would be to reduce affordable housing production. <br />Policy HSG-5.2 Privately Constructed Affordable Units: All affordable units shall remain affordable for 40 years. <br />Comment: This policymay well reduce the number of housing units produced including afforable units. It is well beyond what the housing m arket has faced up to now. The economics of housing requirements and credits is very complex, to have aspirational statements codified without solid analysis is quite dangerous and could result in the opposite effect. For example, years ago the state required that all new housing projects going thoruhgh the LUC have 60% afforable housing. I believe the total production under those requiremnts was zero, the requirements were then reduced and housing production commenced. The initial policy resulted in years of non-production until the requiremnte were reduced to a feasible level. <br />Policy HSG-5.3 Redevelopemnt Shall Not DisplaceAffordable Units. Where there are concentrations of exisitng affordabunits, redevelopment plans or projects shall ensure that units comparable in number and affordability to the existing units are provided in the new project, with priorit given to displaced residents to purchase or rent. <br />Comment: Where there are existng affordable units the cost basis is almost assuredly low, much lower than the cost of new construction. To have the newly constructed units be as affordable as the old units will requre large subsidies such as Project Based Section 8 voucers which are very limited. urther, for those households with income above 50% AMI such vouchers are unavailable. The intent of maintain the afforable housing supply is good but to make it absolute will be counter productive. <br />HOUSING POLICY PROPOSAL <br />It would be most useful if the Housing Section state that providing the necessary backbone infrastructure for futuure residential growth areas is a critival function that only governemnet can provide and should provide. The lack of infrastructure is the largest impediment to developing land for housing.