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HomeMy WebLinkAboutRplcmnt Housing Pln - Adobe Villas 45330 Ocotillo DrSUCCESSOR AGENCY TO THE PALM DESERT REDEVELOPMENT AGENCY / PALM DESERT HOUSING AUTHORITY JOINT CONSIDERATION STAFF REPORT REQUEST: ADOPT SARDA RESOLUTION NO. 034 AND PDHA RESOLUTION NO. 63 APPROVING THE REPLACEMENT HOUSING PLAN FOR ADOBE VILLAS APARTMENTS SUBMITTED BY: Jessica Gonzales, Management Analyst - Housing DATE: May 22, 2014 CONTENTS: SARDA Resolution No. 034 PDHA Resolution No. 63 Adobe Villas Apartments Replacement Housing Plan Recommendation By Minute Motion, That the Successor Agency to the Palm Desert Redevelopment Agency ("SARDA") and the Palm Desert Housing Authority ("PDHA") Boards waive further reading and adopt SARDA Resolution No. 034 and PDHA Resolution No. 63 , which resolutions approve the Replacement Housing Plan for the Adobe Villas Apartments, substantially in the form attached to the resolutions. Executive Summary The former Palm Desert Redevelopment Agency ("Agency") was required by law to adopt a Replacement Housing Plan ("RHP") whenever the Agency took action that would lead to the destruction or removal of dwelling units from the low and moderate income housing market. As part of the proposed development of a public parking lot on the Adobe Villas Apartments property ("Project"), the former Agency proposed the removal of 12 apartment units, of which 5 units were available to low and moderate income households. Pursuant to applicable provisions of the Community Redevelopment Law, such removal required that the former Agency "replace" those units within four years. A meeting of the Agency was scheduled and noticed for July 14, 2011, at which the RHP (which identifies the designated replacement units that were and/or would be available to replace the 5 units within the required time period) would have been considered. On July 14, 2011, the former Agency Board continued the consideration of the adoption of the RHP to an unspecified date due to pending enactment of AB X1 26, which prohibited the former Agency from adopting a redevelopment housing plan. With the passage of AB X1 26, redevelopment agencies were dissolved on February 1, 2012 and the Project was placed on hold. In anticipation of the Successor Agency to the Palm Desert Redevelopment Agency ("SARDA") Long -Range Property Management Plan ("PMP") being approved by the Department of Finance Staff Report Adobe Villas SARDA Resolution No. 034 and PDHA Resolution No. 63 May 22, 2014 Page 2 of 3 , ("DOF"), the SARDA and Palm Desert Housing Authority ("Housing Authority") as successors to the former Agency are jointly herein considering the adoption of the RHP that was previously noticed by the former Agency on June 9, 2011 as required pursuant to Health and Safety Code Sections 33413 and 33413.5. The subject property is designated for governmental use in the PMP and the previously contemplated Project is scheduled to proceed upon approval of the PMP. Background In April 14, 2011, the Palm Desert City Council and former Agency Board approved a Relocation Plan ("Plan") for Adobe Villas Apartments. Only 7 of the 12 units were occupied at the time the City/Agency approved the Plan. The Project would require the displacement of the tenants occupying these 7 units. The former Agency provided relocation assistance and benefits to these tenants. The former Agency proposed the removal of the existing 12 apartment units that make up the Adobe Villas Apartments. Pursuant to Health and Safety Code Sections 33413 and 33413.5, the former Agency was required to adopt a Replacement Housing Plan ("RHP") whenever the former Agency took action that would lead to the destruction or removal of dwelling units from the low and moderate income housing market in order to ensure that the removed or destroyed housing will be replaced. The law further required the former Agency to replace the removed or destroyed housing units within four years. The former Agency prepared a RHP based on the redevelopment and removal of the Adobe Villas Apartments located at 45-330 Ocotillo Drive, Palm Desert (identified as APN 627-232- 005). Five of the twelve units at Adobe Villas were occupied by low and moderate income households at the time the former Agency approved the redevelopment of the property to construct the Project. Accordingly, the former Agency must replace these 5 units within the four-year time limit. The tenants occupying these 5 units vacated the units by July 30, 2011 and since then, the property has remained vacant. On July 14, 2011, the former Agency Board continued Resolution No. 587 that considered the adoption of the Replacement Housing Plan ("RHP") to a date uncertain due to pending passage of AB X1 26. With the Governor's enactment of ABX1 26, redevelopment agencies were dissolved on February 1, 2012 and the Project was placed on hold. In anticipation that the SARDA Long -Range Property Management Plan ("PMP") will be approved by the Department of Finance ("DOF"), the SARDA and Housing Authority as successors to the former Agency are jointly herein considering the adoption of the RHP that was previously noticed by the former Agency and the City of Palm Desert on June 9, 2011 as required pursuant to Health and Safety Code Sections 33413 and 33413.5. The RHP previously prepared by the former Agency and herein being considered, describes and details the housing units (existing and/or approved) that will be used to 'replace' the housing units removed. The RHP includes (1) the general location of housing to be rehabilitated, developed, or constructed; (2) an adequate means of financing such rehabilitation, development, or construction, (3) a finding that the replacement housing does not require the approval of the voters pursuant to Article XXXIV of the California Constitution, or that such approval has been obtained, (4) the number of dwelling units housing persons and families of low or moderate income planned for construction or rehabilitation, and (5) the timetable for Staff Report Adobe Villas SARDA Resolution No. 034 and PDHA Resolution No. 63 May 22, 2014 Page 3of3 meeting the RHP's relocation, rehabilitation, and replacement housing objectives. The RHP has been available for review by the public since June 9, 2011. Staff therefore recommends that the SARDA and Housing Authority Board approve the RHP, substantially in the form as presented to comply with the requirements of Health and Safety Code Sections 33413 and 33413.5. Fiscal Analysis No further fiscal impact is anticipated at this time with the exception of the previously approved consultant costs for the development of the Replacement Housing Plan and the relocation assistance benefits to the tenants. Submitted by: Jes ica Gon /P� Paul Gibs Apploval. ent Analyst (Director of Finance Department Head: .Janet . Moore, Director of Housing r(Ple- ,l' . BY SA -RDA 0 ON ()6-` (9A • ;5 P/ VERIFIED BY PDG Original on file with City Cle 's Office J n M. Wohlmuth, City Manager/Executive Director BY HOUSG AUTH _0 or\ - Ala •a0/4 VERIFIED BY: fe'n- PLA Original on file with City CllFk's Offic€ (AYES: Benson, Harnik, Spiegel, Weber, and Tanner; NOES: None) G:\HOUSING\Patty Leon\JMM\staff report\Adobe Villas Apartments - Staff Report 5-15-14 doc RESOLUTION NO. SA -RDA 034 A RESOLUTION OF THE SUCCESSOR AGENCY TO THE REDEVELOPMENT AGENCY APPROVING THE REPLACEMENT HOUSING PLAN FOR ADOBE VILLAS APARTMENTS NOW, THEREFORE, THE SUCCESSOR AGENCY TO THE PALM DESERT REDEVELOPMENT AGENCY HEREBY FINDS, DETERMINES, RESOLVES AND ORDERS AS FOLLOWS: Section 1. The former Palm Desert Redevelopment Agency ("Agency") proposed to develop a public parking lot on the Adobe Villas Apartments property ("Project"). The property is located at 45-330 Ocotillo Drive in Palm Desert, California and identified as APN 627-232-005 (the "Property"). Section 2. The former Agency was required to adopt a Replacement Housing Plan ("RHP") that details the measures the Agency would take to replace, within four years, the 5 units to be removed from the low and moderate income housing market. Section 3. As part of the Project the former Agency proposed to remove the 12 multi -family apartment units at the Property of which 5 were available to lower and moderate income households. Section 4. On June 9, 2011, the former Agency provided public notice of its consideration of the adoption of the RHP pertaining to the Project as required by Health and Safety Code Sections 33413 and 33413.5. The RHP provided the measures the former Agency would take to replace the 5 housing units to be removed from low and moderate income housing market in connection with the Project. Section 5. On July 14, 2011, at its regularly scheduled meeting of the Agency Board, consideration of the RHP was continued to an unspecified date due to pending enactment of AB X1 26. Section 6. With the Governor's enactment of AB X1 26, redevelopment agencies were prohibited from adopting redevelopment housing plans. On February 1, 2012, the former Agency was dissolved. Section 7. On February 9, 2012, the City adopted Resolution SA -RDA No. 2012-001 declaring the Successor Agency to the Palm Desert Redevelopment Agency ("SARDA") as the successor entity to the former Agency to perform the obligations under the dissolution legislation and wind down the affairs of the Agency. RESOLUTION NO. SA -RDA 034 Section 8. As part of the dissolution, the SARDA is required to prepare a long-range Property Management Plan ("PMP") which outlines the disposition strategies for all properties owned by the former Agency. The PMP identified this property to be retained for government use. Upon approval of the PMP by the State Department of Finance, the Project will move forward as contemplated by the former Agency. Section 9. The SARDA, now hereby adopts the RHP substantially in the form attached hereto and incorporated herein by this reference pursuant to Health and Safety Code Section 33413 and 33413.5. The RHP details the measures the Palm Desert Housing Authority ("Housing Authority") will take to replace the housing units removed from low and moderate income housing market in connection with the Project. PASSED, APPROVED AND ADOPTED by the Successor Agency to the Palm Desert Redevelopment Agency, this day of 2014 by the following vote, to wit: AYES: NOES: ABSENT: ABSTAIN: Van G. Tanner, Chairman ATTEST: Rachelle D. Klassen, Secretary G.\HOUSING1Patty Leon1JMM\staff report1SARDA\RESOLUTIONS\Reso Replacement Housing Plan - Adobe Villas 5-20-11 Revised 5-9-14 for SARDA.doc RESOLUTION NO. HA-63 A RESOLUTION OF THE PALM DESERT HOUSING AUTHORITY APPROVING THE REPLACEMENT HOUSING PLAN FOR ADOBE VILLAS APARTMENTS THE PALM DESERT HOUSING AUTHORITY HEREBY FINDS, DETERMINES, RESOLVES AND ORDERS AS FOLLOWS: Section 1. The former Palm Desert Redevelopment Agency ("Agency") proposed to develop a public parking lot on the Adobe Villas Apartments property ("Project"). The property is located at 45-330 Ocotillo Drive in Palm Desert, California and identified as APN 627-232-005 (the "Property"). Section 2. As part of the Project the former Agency proposed to remove the 12 multi -family apartment units at the Property of which 5 were available to low and moderate income households. Section 3. The former Agency was required to adopt a Replacement Housing Plan ("RHP") that details the measures the Agency would take to replace, within four years, the 5 units to be removed from the low and moderate income housing market. Section 4. On June 9, 2011, the former Agency provided public notice of its consideration of the adoption of the RHP pertaining to the Project as required by Health and Safety Code Sections 33413 and 33413.5. The RHP provided the measures the former Agency would take to replace the 5 housing units to be removed from the low and moderate income housing market in connection with the Project. Section 5. On July 14, 2011, at its regularly scheduled meeting of the Agency Board, consideration of the RHP was continued to an unspecified date due to pending enactment of AB X1 26. Section 6. With the enactment of AB X1 26, redevelopment agencies were prohibited from adopting redevelopment housing plans. On February 1, 2012, the former Agency was dissolved. Section 7. On February 9, 2012, the City Council adopted Resolution No. 2012-07 designating the Palm Desert Housing Authority ("Housing Authority") as the successor in interest by operation of law to all housing activities and assets of the former Agency. On October 11, 2012, the Housing Authority Board adopted Resolution No. HA-47 accepting the housing functions and housing assets of the former Agency. RESOLUTION NO. HA-63 Section 8. The Housing Authority hereby adopts the RHP substantially in the form attached hereto and incorporated herein by this reference pursuant to Health and Safety Code Sections 33413 and 33413.5. The RHP details the measures the Housing Authority will take to replace the housing units removed from the low and moderate income housing market in connection with the Project. Section 9. The Executive Director of the Housing Authority shall have the authority to implement and administer the RHP in accordance with its terms so long as such action is not inconsistent with the RHP's intent. PASSED, APPROVED AND ADOPTED by the Palm Desert Housing Authority, this day of 2014 by the following vote, to wit: AYES: NOES: ABSENT: ABSTAIN: Van G. Tanner, Chairman ATTEST: Rachelle D. Klassen, Secretary G \HOUSING\Patty Leon\JMM\staff report\ RESOLUTIONS\Adobe Villas apartments - Resolution.doc 12812-0001\1712216v3.doc NOTICE OF PROPOSED ADOPTION OF REPLACEMENT HOUSING PLAN AND AVAILABILITY OF REVIEW NOTICE IS HEREBY GIVEN that the Successor Agency to the Palm Desert Redevelopment Agency ("SARDA") as successor to the former Palm Desert Redevelopment Agency ("PDRDA") and the Palm Desert Housing Authority ("Authority") as housing successor to the former PDRDA will jointly consider the adoption of a Replacement Housing Plan ("RHP") for the proposed demolition of a twelve multi -family unit property and redevelopment of the property currently known as the Adobe Villas Apartments (the "Property") located at 45-330 Ocotillo Drive in Palm Desert, California and identified as APN 627-232-005 at its meeting of May 22, 2014. The time, date and place of the meeting is as follows: TIME: 4:00 p.m. DATE: May 22, 2014 PLACE: Palm Desert City Hall Chambers 73-510 Fred Waring Drive Palm Desert, California 92260 At this meeting, the SARDA and Authority as successors will jointly consider the adoption of the RHP that was previously noticed by the PDRDA and the City of Palm Desert on June 9, 2011 as required pursuant to Health and Safety Code Sections 33413 and 33413.5, in connection with the redevelopment and removal of the Adobe Villas Apartments located at 45-300 Ocotillo Drive, Palm Desert and identified as APN 627-232-005. Any of the units that are required to be replaced must be replaced within the four-year time limit pursuant to California Health and Safety Code Section 33413. The RHP includes (1) the general location of housing to be rehabilitated, developed, or constructed; (2) an adequate means of financing such rehabilitation, development, or construction, (3) a finding that the replacement housing does not require the approval of the voters pursuant to Article XXXIV of the California Constitution, or that such approval has been obtained, (4) the number of dwelling units housing persons and families of low or moderate income planned for construction or rehabilitation, and (5) the timetable for meeting the RHP's relocation, rehabilitation, and replacement housing objectives. A copy of the above -referenced RHP is available for public review and copying at the office of the City Clerk of the City of Palm Desert located at the above address. Any person wishing to be heard regarding the proposed adoption of the RHP may appear at the May 22, 2014 meeting or may send written comments to the undersigned at the address shown above. In compliance with the Americans with Disabilities Act, if you need special assistance to participate in a SARDA and/or Authority meeting or other services offered by the City of Palm Desert, please contact the City Clerk's Office at (760) 346-0611. Notification at least 48 hours prior to the meeting or time when services are needed will assist the City staff in assuring that reasonable arrangements can be made to provide accessibility to the meeting or service. Signed this day, the 12th day of May, 2014 Ra e D. Klassen, Secretary-10 the Successor Agency to the Palm Desert Redevelopment Agency and Palm Desert Housing Authority 1234545v1 G \cil Clrt\Glona Sancnei\LL6AL NOTICLS\Nooce - *mot Apinnnl Nnu"nt Pin - Aoeoe VWa. - 0111101e do< FINAL Replacement Housing Plan for the Property Located at 45-330 Ocotillo Drive in the City of Palm Desert Prepared by: City of Palm Desert Redevelopment Agency 73510 Fred Waring Drive PALM DESERT, CA 92260-2524 JuLY 2011 TABLE OF CONTENTS A. Introduction 1 B. Units to Be Replaced 2 C. Annual Income Restrictions 3 D. Location Of Replacement Housing 3 E. Financing the Replacement Housing 4 F. Non -Applicability of Article XXXIV of the California Constitution 4 G. Time Table for Replacement Housing 5 H. Summary 5 Addendum 1 - Expected Location of Income -Restricted Replacement Units 6 LIST OF TABLES Table 1: Replacement Housing Requirements by Bedroom Size & Income Level 2 Table 2: Housing Eligibility by Annual Income Level 3 Table 3: Affordable Housing Projects/Banked Units & Bedrooms 4 Adobe Villas Apartments City of Palm Desert Replacement Housing Plan July 2011 A. INTRODUCTION This Replacement Housing Plan ("RHP") is being prepared by the Palm Desert Redevelopment Agency ("Agency') in conjunction with the demolition of a twelve unit multi -family property and subsequent redevelopment of the property currently known as the Adobe Villas Apartments (the "Property"). The Property is located at 45-330 Ocotillo Drive in Palm Desert, California and identified as APN 627-232-005. The Agency and/or the City of Palm Desert ("City") are proposing to develop a public parking lot on the Property ("Project"). Attachment 1 shows the location of the Project. The City owns the property. This RHP has been prepared by the Agency as a result of the planned removal of the 12 units described above and in order to satisfy the requirements for replacement housing contemplated under the Community Redevelopment Law. The Agency intends to make this RHP available for review and comment for the prescribed period of 30 days. This RHP describes the following, per Community Redevelopment Law ("CRL"): • The general location of the replacement housing (see Section D below); • An adequate means of financing the replacement housing (see Section E below); • A finding that the replacement housing does not require the approval of the voters of the City of Palm Desert pursuant to Article XXXIV of the California Constitution (see Section F below); • The number of replacement housing units planned for construction and rehabilitation (see Section D below); and • The timetable for meeting the replacement housing objectives (see Section G below). The Agency's goal in preparing this RHP is to demonstrate that it is feasible to provide replacement housing in accordance with the requirements of federal law and the CRL. Section 33413(a) of the Community Redevelopment Law (Health and Safety Code Section 33000, et seq.) requires that whenever dwelling units housing persons and families of lower or moderate income are destroyed or removed from the lower and moderate income housing market as part of a redevelopment project, which is subject to a written agreement with a redevelopment agency or where financial assistance has been provided, the agency shall within four years of the destruction or removal, rehabilitate, develop, construct, or cause to be rehabilitated, developed, or constructed, for rental or sale to persons and families of lower or moderate income, an equal number of replacement dwelling units that have an equal or greater number of bedrooms as those destroyed or removed units at affordable housing costs within the territorial jurisdiction of the agency. When dwelling units are removed after January 1, 2002, 100% of the replacement dwelling units shall be available at affordable housing cost to persons in the same or a lower income category, as the persons displaced from those destroyed or removed units. Section 33413.5 of the Community Redevelopment Law requires an agency to adopt a replacement housing plan whenever the agency executes an agreement for acquisition of real property, or an agreement for the disposition and development of property or an owner participation agreement which would lead to the destruction or removal of dwelling units from the Adobe Villas Apartments City of Palm Desert Replacement Housing Plan July 2011 1 lower and moderate income housing market. The replacement housing plan shall identify the impacts that a particular redevelopment project will have on the community's supply of lower and moderate income housing and detail the measures that the agency will take to ensure that the appropriate replacement housing is produced within the four year time limit. Replacement Units must have an equal or greater number of bedrooms as the removed units. The replacement units must be within the agency's jurisdiction and in standard condition, and must be affordable to lower and moderate income households, for the longest feasible time, as determined by the agency, but for not less than 45 years for ownership units and 55 years for rental units. B. UNITS TO BE REPLACED At the time the City and Agency approved the Project, seven of the twelve units to be removed were occupied. The Agency expects that these units will be vacated by July 30, 2011. Five of the seven occupied dwelling units have been determined to be units occupied by lower to moderate -income households. Pursuant to the Community Redevelopment Law, these five units shall be replaced with dwelling units having an equal or greater number of bedrooms. The units to be replaced consist of 2 one -bedroom units and 3 two -bedroom units. As a result, the replacement units must consist of at least eight bedrooms. Based on the income levels of the persons displaced from the units, four of the replacement units must be available at affordable housing cost to lower income households and one of the replacement units must be available at affordable housing cost to a moderate income household. The units are anticipated to be removed in the year 2011. Therefore, all replacement units must be available by 2015, within 4 years after removal of the units. Table 1 defines the replacement housing obligation by income level. The numbers under each household income category indicate the total units to be replaced and the numbers in parenthesis indicate the total number of bedrooms destroyed for each income level. TABLE 1 REPLACEMENT HOUSING REQUIREMENTS BY BEDROOM SIZE & INCOME LEVEL Unit Size Very -Low Income Low Income Moderate Income Totals One Bedroom (1) (1) (2 0 ) Two Bedroom 1 1 1 3 (2) (2) (2) (6) Adobe Villas Apartments City of Palm Desert Replacement Housing Plan July 2011 2 C. ANNUAL INCOME RESTRICTIONS California Health and Safety Code Sections 50079.5 and 50105 provide that the moderate, low and very -low income limits established by the U. S. Department of Housing and Urban Development ("HUD") are the state limits for those income categories. Sections 50079.5 and 50105 direct the Department of Housing and Community Development ("HCD") to publish the income limits. The following figures, shown in Table 2, are approved for use in the County of Riverside to define and determine housing eligibility by income level: TABLE 2 HOUSING ELIGIBILITY BY ANNUAL INCOME LEVEL Income Category 1 2 3 4 5 6 7 8 Person Person Person Person Person Person Person Person Extremely Low (30% of Median) Very Low (50% of median) Lower (80% of median) Median (100% of median) Moderate (120% of median) Area Median Income: $65,000 SOURCE: HCD, June 2010. 13,650 15,000 17,550 19,500 21,100 22,650 24,200 25,750 22,750 26,000 29,250 36,400 41,600 46,800 45,500 52,000 58,500 54,600 62,400 70,200 D. LOCATION OF REPLACEMENT HOUSING 32,500 35,100 52,000 56,200 65,000 70,200 78,000 84,250 37,700 40,300 42,900 75,400 64,500 68,650 75,400 80,600 85,800 90,500 96,700 102,95 0 The Agency has several options available to provide replacement housing, including units subject to a restrictive covenant, acquisition, rehabilitation, new construction, and the allocation of "banked" dwelling units from prior development activity. The Agency has previously funded, restricted or caused to be developed, affordable housing projects that provide surplus dwelling units and bedrooms that can be allocated by the Agency for future housing obligations. The Agency has a number of "banked" dwelling units/bedrooms to satisfy the replacement housing obligation. Such units together with the approved units that have not yet been constructed, (identified in Table 3 and Addendum 1) constitute a sufficient number of replacement units. As described in Table 3, the following affordable housing units/bedrooms have been developed, or are planned to be developed, within the Agency's jurisdiction. All such units are/will be available at an affordable housing cost to lower or moderate income households and subject to a restrictive covenant ensuring such affordability for not less than 55 years for rental units and 45 years for owner occupied units. Addendum 1, at the end of the RHP, outlines the locations or proposed locations of these affordable units. Adobe Villas Apartments City of Palm Desert Replacement Housing Plan July 2011 3 Table 3 Affordable Housing Projects/Banked Units & Bedrooms Unit Size Net Banked (Existing) Units / No. of Bedrooms Projects Units/Bedrooms to be provided (Approved but not yet constructed) Required Replacement Units / No. of Bedrooms E. FINANCING THE REPLACEMENT HOUSING Very Low Moderate Income Low Income Income 2/3 2/3 8/16 0/0 31/52 31 /50 2/3 2/3 1/2 The Agency is authorized to finance its activities with moneys from various sources, including the City of Palm Desert, State of California, United States Government, property tax increment funds, interest income; Agency bonds, or other available sources. The existing units to be used for replacement units, have been acquired, constructed or rehabilitated with various funding sources including tax increment funds; below market rate financing through the sale of tax exempt mortgage revenue bonds; redevelopment twenty percent set -aside funds; and developer funds. Funding for the development of affordable housing units identified in the preceding section as "approved but not yet constructed" may utilize a variety of sources including: State or Federal grants and loans, tax increment funds; below market rate financing through the sale of tax exempt mortgage revenue bonds; redevelopment twenty percent set -aside funds; and developer funds. Specific funding for future replacement housing units may be through the use of any combination of the above described methods and sources. As replacement units, the Agency may count units developed by private developers pursuant to the City's Density Bonus program provided that units are subject to a restrictive affordable housing covenant enforceable by the Agency. F. NON -APPLICABILITY OF ARTICLE XXXIV OF THE CALIFORNIA CONSTITUTION It is hereby found and determined that the replacement housing identified in this RHP does not require approval of the voters of the City of Palm Desert pursuant to Article XXXIV of the California Constitution. A portion of the housing identified in this RHP is not subject to the voter approval requirements of Article XXXIV because such housing is or will be privately owned, not exempt from real property taxes by reason of public ownership, and not financed with direct long term financing from a public body. In addition, the Agency will not "develop, construct, or acquire" housing as described in Section 1 of Article XXXIV of the California Constitution because in providing assistance to developers, the Agency will only monitor construction or rehabilitation of the project and compliance with conditions of the assistance to the extent of carrying out routine governmental functions, performing conventional activities of a lender, and imposing constitutionally mandated or statutorily authorized conditions. Adobe Villas Apartments City of Palm Desert Replacement Housing Plan July 2011 4 G. TIME TABLE FOR REPLACEMENT HOUSING The Agency has provided a considerable degree of continuing support in the construction and/or rehabilitation of replacement housing units sufficient to address the replacement requirements of affordable housing discussed in this RHP. It is the intent of the Agency to use "banked" previously developed housing units and if necessary housing units that have been approved but not yet constructed to fulfill its replacement housing requirement. The Agency acknowledges that replacement housing units must be affordable in the same, or lower income categories than those being removed from the lower and moderate income housing market and will ensure that this result is realized. Further, any units developed as replacement housing units will be completed within four years and will remain income -restricted for the appropriate period as required by law. H. SUMMARY In summary, a total of 18 bedrooms and 12 dwelling units will be removed; eight bedrooms in five units occupied by lower and moderate income households will be replaced. Based on the 100% replacement criteria by income level, the Agency through a variety of replacement housing options will replace the eight bedrooms affordable to lower to moderate income households by using previously developed housing units as well as units that have been approved but not yet constructed. The result of the above actions will yield the required number of replacement dwelling units as mandated under Community Redevelopment Law. The Agency recognizes its legal and community responsibilities in this matter and will make a sincere, good -faith effort to accomplish these goals. The Agency retains its option to use other approaches and strategies not discussed herein to fulfill its replacement housing obligations in a timely manner. Adobe Villas Apartments City of Palm Desert Replacement Housing Plan July 2011 5 ADDENDUM 1 - EXPECTED LOCATION OF INCOME -RESTRICTED REPLACEMENT UNITS The following are the proposed and expected locations of income -restricted units which will be used to meet the Agency's replacement obligation of five units with not less than eight bedrooms. Bedrooms & Income: Replacement location: Scheduled Completion: Very Low Income: Las Serenas Completed 73-315 Country Club Drive Palm Village Completed 73-650 Santa Rosa Way Low Income: Las Serenas Completed 73-315 Country Club Drive Palm Village Completed 73-650 Santa Rosa Way Canterra Apartments 11 To be completed 74-401 Hovley Lane Moderate Income: Sares Regis 35-751 Gateway Drive Completed Palm Desert 103 To be completed (Formerly Emerald Brook/WNRA) It is the adopted policy of the Agency to promote the assimilation of affordable housing throughout the City to the maximum extent possible in order to avoid concentrations of lower - income housing in certain neighborhoods. Adobe Villas Apartments City of Palm Desert Replacement Housing Plan July 2011 6