Memorandum

Date: June 5, 2019

To: Chair Ross and Housing Commission

From: Charmain Later, Senior Planner

cc: Joel Fontane, Director Community Development

Subject: Albion Residential (1850 Green Bay Road) Staff Comments

The City of Highland Park took ownership of the 1850

Green Bay Road property when it was deeded to the City
from the Park District of Highland Park in 1949. Shortly
thereafter the Karger recreation building was
constructed on the site. The City Council approved a
purchase and sale agreement for the Karger Center
property in January, 2018 with Albion Jacobs Highland
Park, LLC who is proposing to construct a 161-unit
multifamily building on the site, contingent upon
zoning approvals.

The applicant has amended their proposed plans from

the last time the applicant came before the Housing
Commission with preliminary plans. At that time the
Housing Commission continued the matter to a later
meeting until additional application information could
be provided.

The developers are requesting preliminary and final approval from the Housing Commission with
a cash payment in-lieu and staff request that the Housing Commission consider and make a
recommendation on the applicants Inclusionary Housing Plan. The Housing Commission’s
recommendation will be presented to the City Council for their consideration and final approval.

The Albion development is required to include 27 inclusionary housing units. This number
accounts for the modification granted by the City Council to allow the developer a partial payment
in-lieu payment for some of the required units while also market rate unit bonuses for the
affordable units actually provided on site.

The developer is proposing to provide 17 units on site and is requesting to make a cash payment
for the remaining 10 units. Per Section 150.2108 of the Code, a cash payment in-lieu of affordable
units for this project requires approval by the City Council, after a recommendation is received by
the Housing Commission. The applicant proposes making a payment in-lieu of $1.25M for 10
affordable units that will not be provided. The proposal requires approval of certain departures
from the Code through a Section 150.2114 consideration as well.

The application submitted by the applicant is attached along with staff’s analysis of the proposal
and zoning compliance.

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Introduction
The following provides staff’s review of the applicant’s affordable housing plan. For ease of reference and
evaluation, this document is organized by relevant subsection of Article 21 of the City’s Code related to
inclusionary housing. It lists the relevant sub-section title, provides relevant excerpts from the Code along with
staff’s comments. Throughout this document words in italics are excerpts from the City Code and those in
brown represent staff’s comments. In summary, the housing plan proposed employs an alternative means of
compliance through a cash payment in-lieu of affordable units for a portion of the affordable units required.
It also requests certain departures from the standards in Article 21 related to the distribution of affordable units
by type (# of bedrooms), or target income level, and related to amenities. The alternative means of compliance
requires a discretionary finding to be allowed through subsection 150.2108, and the other departures from
standards require a subsection 150.2114 consideration. The Commission should make the required findings in
subsection 2103(3) in the above context of the requested alternative means of compliance and departures.
150.2103 (2) Review Procedure.
(a)(i) Housing Commission Review. Within 60 days after the filing of a complete preliminary Inclusionary Housing Plan, the
Housing Commission shall review the Inclusionary Housing Plan, and shall recommend either the approval (with or without
modifications) or the rejection of the Inclusionary Housing Plan. The Housing Commission shall transmit its findings of fact and
recommendation to the City Council. The failure of the Housing Commission to provide a recommendation within such 60 day
period, or such further time to which the applicant may, in writing, agree, shall be deemed a recommendation against the approval
of the Inclusionary Housing Plan.

Recommendation
The Housing Commission should consider the housing plan, deliberate and direct staff to draft findings as
appropriate for final action at its next meeting.

Background
Sec. 150.2101. - Covered Development Projects.
Pursuant to Section 150.2101, the proposed 161 unit multifamily residence is a covered development
subject to the provisions of Article 21.
Sec. 150.2102. - Percentage of Affordable Housing Units Required.
The Albion proposed 161 unit development has received preliminary approval by the City Council on
February 25, 20191 that included a modification2 that allows the applicant to benefit from bonus units
for all on-site affordable units provided.

1
Section 3(E) from Resolution R-38-2019 – Resolution Approving a Preliminary Development Plan for a Planned Development at
1850 Green Bay Road, states: “E. Inclusionary Housing Modification. A modification from Section 150.2106 (B) of the Zoning Code
to permit the Applicant to provide some but not all, of the required inclusionary housing units on the Property, and to pay a fee in
lieu for the remaining required inclusionary housing units, and to thereby obtain a bonus of 1.5 additional market rate dwelling units
within the proposed planned development for each inclusionary dwelling unit provide on the Property.”
2 Section 150.2106(C) “No Density Bonuses with Payment of Fee-In-Lieu. No density bonus shall be provided pursuant to this Section

150.2106 for any development for which a cash payment in lieu of construction of the required affordable units is made pursuant to
Section 150.2103 of this Article.”

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The applicant proposes to provide 144 market rate and 17 on-site affordable units. Accounting for
modification above, this development is required to provide a cash payment in-lieu of 10 affordable
units3 to satisfy the inclusionary housing requirements of the Code. (See attached “Affordable Units
& Payment In-Lieu” chart.)
The proposed payment in-lieu, however, requires a subsection 2108 discretionary consideration as to
whether the proposed payment is equal to or greater than what would otherwise be required. The
Housing Commission is required to make a recommendation whether the proposed payment of
$1,125,000 meets that standard. More on this matter later in Required Findings below.

Application Requirements -
Sec. 150.2103. - Application and Inclusionary Housing Plan.
The Applicant has provided a complete preliminary and final affordable housing application.
(A) Application. For all covered development projects, the Applicant shall file an application for approval thereof on a form
provided and required by the City. The application shall require, and the Applicant shall provide, among other things, general
information about the nature and scope of the covered development, as well as such other documents and information as the Director
of the City's Department of Community Development, or his or her designee ("Director"), may require. The Director shall also
have the authority to require, as part of the application submittal, such portions of the inclusionary housing plan required under
Subsection (B) of this Section as the Director shall deem necessary to properly evaluate the proposed covered development under the
requirements and provisions of this Article.
(B) Inclusionary Housing Plan. As part of the approval of a covered development project, the Applicant shall present to the Housing
Commission and the City Council an inclusionary housing plan that outlines and specifies the covered development's compliance
with each of the applicable requirements of this Article, in accordance with the following:
(1) Required Submittals for Inclusionary Housing Plan. The plan shall specifically contain, at a minimum, the following information
regarding the covered development project;
(a) Preliminary Plan.
(i) A general description of the development, including whether the development will contain rental units or
individually owned units, or both;
(ii) The total number of market rate units and affordable units in the development;
(iii) The total number of attached and detached residential units;
(iv) The number of bedrooms in each market rate unit and each affordable unit;
(v) The square footage of each market rate unit and each affordable unit;
(vi) The location within any multiple-family residential structure and any single-family residential development
of each market rate unit and each affordable unit.
(vii) Floor plans for each affordable unit;
(viii) The amenities that will be provided to and within each market rate unit and affordable unit; and (ix)
The pricing for each market rate unit and each affordable housing unit.
(b) Final Plan.

3Based on a now 161 unit building. Note that since preliminary approval the applicant has reduced the total number of units proposed.
This change, along with the proposed bifurcation between on-site and payment in-lieu, yields the number of affordable units.

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 (i) All of the information required for the preliminary Inclusionary Housing Plan pursuant to Section
150.2103(B)(1)(a) of this Article;
(ii) The phasing and construction schedule for each market rate unit and each affordable unit;
(iii) Documentation and plans regarding the exterior and interior appearances, materials, and finishes of the
development and each of its individual units;
(iv) A description of the marketing plan that the applicant proposes to utilize and implement to promote the
sale or rental of the affordable units within the development; and
(v) A description of the specific efforts that the applicant will undertake to provide affordable housing units to
households pursuant to the priorities set forth in Section 150.2110 of this Article.

Required Findings
There are three sets of standards that the Commission must apply to consider all elements of this
application: 1) the standards found in Section 2103, which are common to all Housing Plan
applications; 2) the subsection 2108 standard, which applies narrowly to the proposed alternative
means of compliance consideration, in this case, a payment in-lieu of providing all affordable units
on-site as otherwise required; and 3) the set of standards found in sub-section 150.2114 related to other
departures from the Code.
Section 2103(3) - Standards of Review. The Housing Commission shall not recommend the approval of a preliminary or
final Inclusionary Housing Plan, and the City Council shall not approve a preliminary or final Inclusionary Housing Plan, except
upon making the following findings:
(a) That the applicant has demonstrated that the proposed affordable housing units are designed to accommodate the needs
of the target households;
The applicant proposes affordable units with similar finishes and amenities as the market rate
units provided at rental rates in accordance with the City’s Pricing Schedule distributed among
the three required income tiers4 as required (see 150.2107 and 150.2109 for details). Please see
the attached Technical Guide developed for the Albion project regarding the assignment of
the appropriate unit rents to each of the required income tiers.

 The Commission should consider whether the distribution of affordable units by type
and cost of parking amenities addresses target household groups.
(b) That the location, floor plan, fixtures and finishes, and amenities of each proposed affordable housing unit satisfy the
applicable provisions of this Article and are suitable for the needs of the target households;
The applicant’s proposal exceeds minimum requirements for interior unit amenities and
satisfies the applicable provisions of this Article.
(c) That each affordable housing unit is designed to accommodate family living needs for common space and dining areas;
and
The floor plans provided meet this standard as they provide adequate accommodations for
expected household sizes.

4 0% to 50% AMI, 51% - 80% AMI, and 81% to 120% AMI see Sec. 150.2109. - Target Income Levels for Affordable Housing Units.

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 (d) That the proposed affordable housing units, and the development as a whole, conform to the applicable standards and
requirements of this Chapter.
For the proposed project, this standard can be met only in combination with the subsection
2108 and subsection 2114 findings below.
Sec. 150.2108. - Alternatives to On-Site Affordable Housing Units.
(A) Applicability. In lieu of the provision of affordable housing on the site of the covered development as otherwise required by
Section 150.2102 of this Article, the City Council, following consideration by and a recommendation from the Housing
Commission, may approve one or more of the three alternatives for affordable housing as set forth in Subsection B of this Section.
Utilization and the requirements of the provisions of this Section shall be specifically set forth in the affordable housing development
agreement for the covered development. This Section shall not be utilized unless the applicant demonstrates to the satisfaction of the
City Council that the alternate means of compliance will further affordable housing opportunities in the City to an equal or greater
extent than compliance with the otherwise applicable on site requirements of this Article.
(B) Available Alternatives. Any one or more of the following affordable housing alternatives may be utilized in lieu of all or part
of the otherwise applicable on site requirements set forth in Section 150.2102 of this Article: (1) A cash payment to be deposited
directly into the Affordable Housing Trust Fund for purposes authorized under Section 33.1133 of this Code in an amount not
less than the per unit payment established pursuant to Section 150.2102(C)(2) of this Article; (2) A dedication of land to the
Highland Park Housing Commission or the Commission's not-for-profit designee; or (3) The provision of affordable housing units
at another site within the City.
The Commission must consider whether the proposed alternative means of compliance will further
affordable housing opportunities in the City to an equal or greater extent than compliance with the
otherwise applicable on-site requirements of this Article.
The applicant proposes a bifurcated approach to meeting the requirements of this Article. The
applicant proposes providing 17 affordable units on-site and providing a payment in-lieu of $1.25M for
the remaining 10 units required. Staff believe that the proposed payment will bolster the City’s
affordable housing trust fund helping the City’s housing program sustain activity during future
recessionary periods. Recessionary periods present important opportunities to acquire affordable
units at lower costs than during other points in the economic cycle. Equally important, these funds
could also help sustain the affordable units the City already has.
For the past five years the City’s housing trust fund balance has stagnated and is currently insufficient
to sustain the City’s housing program through a significant recessionary period. The Trust Fund’s
current balance can only sustain about two years of activity at desired levels. Given the high variability
of the Trust Fund’s revenue sources (demo tax and payments in-lieu), the payment in-lieu of
affordable housing units would greatly help the City sustain the Fund’s ability to achieve affordable
housing production that will ultimately result in an equal or greater number of affordable units being
secured through its scattered site grant-making program. Equally important, these funds will help
the City maintain the affordable housing capacity it has developed through years of funding these
activities.
Sec. 150.2114. - Departures from Requirements.
The Housing Commission may recommend, and the City Council may approve, departures from any of the standards set forth in
this Article, upon making each of the following findings:
(A) Due to specific and unique circumstances, undue hardship would be caused by the literal enforcement of the standards
and requirements set forth in this Article;

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 (B) By virtue of excellence in design, the proposed departure from the standards does not result in a diminished or lower
quality affordable dwelling unit, but provides a functionally equivalent dwelling unit; and
(C) The proposed affordable housing units otherwise meet the purpose and intent of this Article.
The departures permitted by subsection 150.2114 do not extend beyond anything more than the
physical attributes of the units themselves. Therefore, departures from the required total number of
affordable units to be provided, the amount of a cash payment in-lieu, or any other discretionary
consideration provided by Article 21 cannot be sought through use of subsection 150.2114 “Departures
from Requirements” consideration. However, other departures can be considered through the
application of this sub-section. In this proposal, the distribution of units by type (bedrooms) required
in subsection 150.2107 has not been met see below for details and analysis. This subsection could also
be used to consider departures from income requirements, and amenities.

Analysis of Affordable Units Proposed

Sec. 150.2107. - Integration of Affordable Housing Units.
(A) Location of Affordable Housing Units. Affordable housing units shall be dispersed among the market rate
units throughout the covered development.

Floor plans for each of the five floors show the location of the affordable units relative to market
rate units and staircases, elevators, trash rooms, utility closets, common rooms etc. The
affordable units are widely distributed throughout the building, however, some of the
affordable units are located near stairwells and other similar areas of the building but not to a
greater extent than the market rate units.

(B) Phasing of Construction. The inclusionary housing plan and the development agreement shall include a phasing
plan that provides for the timely and integrated development of the affordable housing units as the covered development
project is built out. The phasing plan shall provide for the development of the affordable housing units concurrently with
the market rate units. […]The phasing plan shall also provide that the affordable housing units shall not be the last
units to be built in any covered development.
The proposed construction phasing is compliant with Code. The application states: “Unit
turnover will occur on a floor by floor basis from the ground up. All units on each particular
floor will be delivered at the same time. The inclusionary units will (have) delivery
simultaneous with the market rate units on at particular floor.”

(C) Exterior Appearance. The exterior appearance of the affordable housing units in any covered development shall be
visually compatible with the market rate units in the development. External building materials and finishes shall be
substantially the same in type and quality for affordable housing units as for market rate units.

Exterior of the units proposed are understood by staff to be the same as the market rate units.

(D) Unit Amenities. Amenities that are provided with a market rate unit shall also be provided, with the affordable
units. For purposes of this Subsection (D), "amenities" shall include, without limitation, basements, front porches, storage
lockers, balconies, roof decks, outdoor patios, off-street parking, enclosed parking, appliances, and similar unit features
and additions.
The types of unit amenities will be similar to the market rate units as required. The application
states that the affordable units will be built to the same finish and quality of the market rate

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units and have access to all of the amenities offered throughout the development (see
application). Note that the applicant indicated that there is no storage offered outside of units.
However, the applicant indicates that the cost of parking is not included for any of the
development units. Instead, parking is proposed to be distributed on a first come first serve
basis and is charged at market rate ($150) for each space. Charging affordable unit tenants for
parking may not be in keeping with the purpose and intent of the Inclusionary Housing Code
as it could have significant implications for affordability. Charging for parking was addressed
recently in the McGovern House planned development approval, and further addressed by the
Housing Commission during its review of Article 21 last year. For reference, the following
provides the provisions in the McGovern House approval related to parking and storage:
“Parking and Storage Fees. As set forth in the inclusionary Housing Plan, Declarant
may not charge off-street parking and storage fees to the residents of the Affordable
Housing Rental Units on the Property in excess of the following maximums:
1. Off-Street Parking. The lesser of: (a) the reduced parking permit fee charged by the
City to low-income households; and (b) the parking fee charged to residents of
market-rate dwelling units on the Property, multiplied by the ratio of the sum of
monthly rent and utilities charged to the tenants of the Affordable Housing Rental
Units to the sum of monthly rent and utilities charged to the tenants of the market-
rate dwelling units.
2. Storage. The storage fee charged to residents of market-rate dwelling units on the
Property, multiplied by the ratio of the sum of monthly rent and utilities charged to
the tenants of the Affordable Housing Rental Units to the sum of monthly rent and
utilities charged to the tenants of the market-rate dwelling units.” - Section 5(I) Affordable
Unit Declaration of Covenants, Conditions, and Restrictions for McGovern House Rental Units
2/3/2016.

Currently, the City’s Low Income Parking Permit fee for a resident Garage Overnight permit,
is $15 per month.
For reference, in August 2018, as part of its review of proposed changes to Article 21, the
Housing Commission recommended, and the PDC agreed, that one parking space per
affordable unit must be included in the rent and without additional charge to the tenant as
follows:
“Proposed Amendment Related to Parking.
One parking space per affordable unit will be included in the rent and free of any
additional charge.
 Additional parking can be made available in the same fashion and
using the same method for allocation as market rate units.
o Premium parking spaces, such as indoor parking, shall not be required to be
allocated to the affordable units free of charge provided that required parking
is provided elsewhere on site.

Proposed Amendment Related to Storage.

o If all market rate units within a development have additional storage space
then the affordable units should also have similar extra storage space,
included in their rent as described above for parking.

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 o Where storage spaces are not made available to all units due to an insufficient
ratio of storage units to units, then affordable units should have access to
them in the same manner as the market rate units do.”

o (E) Interior Appearance and Finishes. Affordable housing units may differ from market
rate units with regard to interior finishes and gross floor area, provided that:

(1) The bedroom mix of affordable units shall be in equal proportion to the bedroom mix of the market rate units.
The bedroom mix for the affordable units is not in equal proportion to the bedroom mix
of the market rate units as required by Section 150.2107(E)(1) of the Code. Staff have
reviewed the floor plans provided and determined that the “convertible” units have
bedroom counts as stated, however, it is important to note that any conversion of dens to
bedrooms has implications for the distribution of affordable units by bedroom and for the
calculation of impact fees5.

PROPOSED by APPLICANT REQUIRED

Sub- # of
Total Proportion Proportion Affordable Difference
Total Mkt of Mkt Sub-Total of Affordable Units Proposed
Unit # of Rate Rate Units Affordable Units Required vs.
Type Units Units by Type Units Required (rounded) Required
Studio 30 24 17% 6 17% 3 -3
1 bed 68 63 44% 5 44% 7 2
2 bed 63 57 40% 6 40% 7 1
TOTAL 161 144 100% 17 100% 17
Note that in the application, the applicant used calculated the proportion of units by unit type based
on the total # of units instead of using the number of market rate units as required.

The proposed distribution by unit type enables the required distribution of units by
income tier for the studio and two bedroom units. Since the proposed number of units for
the one bedroom units is an odd number (5), staff would allocate that unit to the 65% AMI
category in the absence of any other specific request by the applicant. The applicant has
not proposed a distribution by income tier for the above 6/5/6 distribution. The
Commission must decide the income distribution for the one bedroom units it finds
acceptable. Allocation of the odd unit to the 65% AMI income tier yields the lowest
departure from the Code’s required distribution.6

According to the applicant the only way the Albion can financially achieve the required
3/7/7 distribution of units by type is to depart from the target income levels for
affordability as follows:

5 The calculation of impact fees is not a matter before the Housing Commission for consideration. This statement is provided to alert
the applicant that the potential implications of bedroom count changes extends beyond the distribution of affordable housing units by
number of bedrooms, which is within the Housing Commission’s scope of consideration.
6 150.2109 requires that units be distributed evenly among three income tiers – 45% AMI, 65% AMI and 100% AMI.

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 Albion Alternate Distribution of Units
by Income Tier w/Required Distribution by Unit Type

Target Income Tier

(%AMI)
Distribution
by Unit
Unit Type 45% 65% 100% Type
Studio 1 1 1 3
1 Bed 2 2 3 7
2 Bed 2 2 3 7
Total 5 5 7 17
% Distribution 29% 29% 41% 100%
% Required 33% 33% 33%

Due to the odd number of affordable units proposed, the Commission must evaluate the
tradeoff between providing the distribution of units by unit type vs. providing units by
target income tier as required. Since there are 17 on-site affordable units proposed it is not
possible to exactly meet the Code’s required distribution of units by income tier (see
150.2109). Instead, the applicant must exceed the required distribution in one income tier.
Regardless of whether the Commission chooses to minimize the departure from the
income distribution or unit type, the distribution of units by income tier must be
articulated. Departures from the standards in Article 21 can be considered and allowed
through subsection 150.2114.

For reference, the following distribution of units by type was approved for McGovern
House in 2016.
McGovern House Distribution of Units by Income Tier w/Req Distribution by Unit Type
Target Income Tier
(%AMI)
% by
Distribution
Unit
by Unit
Type
Unit Type 45% 65% 100% Type
Studio N/A N/A N/A N/A
1 Bed 4 2 0 6 55%
2 Bed 0 2 3 5 45%
Total 4 4 3 11
% Distribution 36% 36% 27% 100%
% Required 33% 33% 33%

Relief was provided for the distribution of units by type as this building’s market rate units are
comprised of 55% 2-bed units and 45% 1-bed. The distribution of affordable units as 45% 2-bed
and 55% 1-bed as shown above.

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 (2) The differences between the affordable housing units and the market rate units shall not include improvements related
to energy efficiency, including mechanical equipment and plumbing, insulation, windows, and heating and cooling systems.
All interior fit and finishes for the affordable units are proposed to be the same as
market rate units.
(3) The interior gross floor area for the affordable housing units shall be no less than the lesser of
(a) 75 percent of the gross floor area of market rate units with a comparable number of bedrooms, or
(b) the minimum size requirements outlined in the table below; provided, however, that interior gross floor area
shall not include areas devoted to vertical circulation, basements, off-street parking, lockers and similar storage
areas, and mechanical rooms.” […]
The table below provides a comparison of affordable unit area proposed vs. required.
The table shows that the proposed size of units exceed what is required by the Code,
but are less than the average for the market rate units, thus requiring conformance
with this sub-section 150.2107(E). Note that the last column of this table is derived
using the average market rate unit area by unit type provided by the applicant as shown
in the table below it. The proposed size of the units meet the requirements of this sub-
section 150.2107(E)(3) as shown in the tables below.

Proposed Affordable Unit Areas:

Minimum
Area (SF)
Affordable Required per 75% of
# Unit Area (SF) Section Market rate
UNIT Bedrooms AMI Proposed 2107(E)(3) unit
Unit 108 Studio 45% AMI 558 450 500
Unit 123 Studio 45% AMI 551 450 500
Unit 212 Studio 65% AMI 514 450 500
Unit312 Studio 65% AMI 514 450 500
Unit 412 Studio 100% AMI 514 450 500
Unit 512 Studio 100% AMI 514 450 500
Unit 106 1 Bedroom 45% AMI 762 750 735
Unit 206 1 Bedroom 45% AMI 815 750 735
Unit 306 1 Bedroom 65% AMI 815 750 735
Unit 406 1 Bedroom 65% AMI 815 750 735
Unit 506 1 Bedroom 100% AMI 815 750 735
Unit 218 2 Bedroom 45% AMI 955 950 1,059
Unit 222 2 Bedroom 45% AMI 970 950 1,059
Unit 318 2 Bedroom 65% AMI 955 950 1,059
Unit 322 2 Bedroom 65% AMI 970 950 1,059
Unit 418 2 Bedroom 100% AMI 955 950 1,059
Unit 422 2 Bedroom 100% AMI 970 950 1,059
Source: Albion Application. Note last column calculated by staff.

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 Average Area of Market Rate Units by Type:

Total #
of Mkt
Rate Avg. Unit Proposed Rent
Unit Type Units Area (SF) range
Studio 24 667 $1,600 - $2,000
1 Bedroom 63 979 $2,300 - $3,000
2 Bedroom 57 1,412 $3,500 - $5,000
Source: Albion Application.

Sec. 150.2109. - Target Income Levels for Affordable Housing Units.

Since there are 17 on-site affordable units proposed it is not possible to exactly meet the Code’s
required distribution of units by income tier (see below) because it is an odd number. Instead, the
applicant must exceed the required distribution in one income tier. Regardless of whether the
Commission chooses to minimize the departure from the income distribution or unit type, the
distribution of units by income tier must be articulated. Allocating the odd unit to the 65% AMI
income tier will yield the least departure from the required distribution. Departures from the standards
in Article 21 can be considered and allowed through subsection 150.2114.
(B) Rental of Affordable Housing Units. In covered development projects that contain rental units:
(i) no less than 33 percent of the affordable housing units shall be rented or leased to households with gross incomes from
zero percent to 50 percent of the Chicago area median income at a price, as determined pursuant to Subsection (C) of this
Section, that, on average, is affordable to a household with an annual income that is 45 percent of area median income;
(ii) no less than 33 percent of the affordable housing units shall be rented or leased to households with gross incomes
between 51 percent and 80 percent of the Chicago area median income at a price, as determined pursuant to Subsection
(C) of this Section, that, on average, is affordable to a household with an annual income that is 65 percent of area median
income; and
(iii) no more than 33 percent of the affordable housing units shall be rented or leased to households with gross incomes
between 81 percent and 120 percent of the Chicago area median income at a price, as determined pursuant to Subsection
(C) of this Section, that, on average, is affordable to a household with an annual income that is 100 percent of area
median income.
If fewer than three affordable units will be provided, such units shall be rented or leased to low-income households at a
price, as determined pursuant to Subsection (C) of this Section that does not exceed what is affordable to a household
with an annual income that is 65 percent of area median income.
Sec. 150.2111. - Marketing of the Affordable Housing Units.
The proposed marketing plan uses the City’s waitlist for inclusionary units as required and is
otherwise satisfactory. Staff note that the applicant has not elected to use the City’s assistance in
marketing affordable units.

(A) Good Faith Marketing Required. All sellers and lessors of affordable units are responsible for marketing the affordable units,
and shall engage in good faith marketing efforts to inform members of the public who are qualified to purchase or rent affordable
units of the availability of such units for sale or rent. Prior to the initiation of public marketing efforts to sell or lease an affordable
housing unit, the seller or lessor thereof shall submit to the Director of Community Development a description of the marketing plan

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that the applicant proposes to utilize and implement to promote the sale or rental of the affordable units within the development to
the appropriate income groups.
(B) City Assistance with Marketing. At the applicant's request, the City or its designee shall assist the applicant in marketing the
affordable housing units to eligible households, for an additional charge to be determined by the City.
Sec. 150.2112. - Period of Affordability.
The proposed units will be made affordable as required.
(B) Rental of Affordable Housing Units. In developments that contain rental units, affordable housing units shall be rented to low
and moderate income households in accordance with Section 150.2110 of this Article for 25 years from the date of the issuance of
the certificate of occupancy for the respective unit. The owner shall execute and record any documents required by Section 150.2104
of this Article to ensure compliance with this Subsection. (1) In the event that the owner of a covered rental development sells the
development before the end of the 25-year affordability period, the new owner shall be required to continue to provide the affordable
housing units in accordance with Section 150.2110 of this Article for the remainder of the 25-year period. (2) If the owner of a
covered rental development converts the development to condominiums or other form of individual unit ownership, the development
shall be subject to the for-sale development requirements set forth in Subsection 150.2109(A) of this Article. (3) The Housing
Commission or its designee shall have the right, but not the obligation, to purchase any for-sale affordable housing units in the
development pursuant to Section 150.2113 of this Article.
Sec. 150. - 2113 Affordability Controls.
The following subsection is provided for the Commission’s reference regarding affordability controls.
(B) Rental Affordable Housing Units. For covered rental developments that contain affordable housing units, the owner of the
development shall execute and record such documentation as required by Section 150.2104 of this Article to ensure the provision
and continuous maintenance of the affordable housing units. Such documentation shall include the provisions of this Article and
shall provide, at a minimum, each of the following:
(1) The affordable housing units must be leased and occupied by eligible households.
(2) The affordable housing units must be leased at rent levels affordable to eligible households for a period of 25 years
from the date of the initial certificate of occupancy.
(3) Preference for the affordable housing units shall be given to eligible households pursuant to the priorities set forth in
Section 150.2110 of this Article.
(4) The calculated maximum rental price is an upper limit, but shall not be construed as a guarantee that the unit will
be rented at that price.
(5) Market conditions, and characteristics of the affordable housing unit, may result in the rental of an affordable housing
unit at a price lower than the calculated maximum rental price. (C) Subleasing Prohibited. Subleasing of affordable units
shall not be permitted without the express written consent of the Director.

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Affordable Units & Payment In‐Lieu (assumes density that does not exceed the Zoning Code)
Total Req Aff 
Grand Total  Units w/o Mkt. 
Units in  Rate Bonus 
1850 Green Bay Rd.  Albion Development Building? Units
161 32.2
A B C D E F G

Proposed # of  Req # Pmt In‐Lieu  Tot #  Adjusted  Affordable 

Affordable         of Affordable  Affordable  Bonus Unit  Mkt. Rate  Grand Total  Effective Rate 
On‐Site Units Units Units Req Adj Factor Units Units (including Pmt in‐leu)
Given (C‐A) (E*20%) (A*1.5) (F‐D) Given (C/F)
0 32.2 32.2 0.0 161.0 161 20.0%
1 30.9 31.9 1.5 159.5 161 19.8%
2 29.6 31.6 3.0 158.0 161 19.6%
3 28.3 31.3 4.5 156.5 161 19.4%
4 27.0 31.0 6.0 155.0 161 19.3%
5 25.7 30.7 7.5 153.5 161 19.1%
6 24.4 30.4 9.0 152.0 161 18.9%
7 23.1 30.1 10.5 150.5 161 18.7%
8 21.8 29.8 12.0 149.0 161 18.5%
9 20.5 29.5 13.5 147.5 161 18.3%
10 19.2 29.2 15.0 146.0 161 18.1%
11 17.9 28.9 16.5 144.5 161 18.0%
12 16.6 28.6 18.0 143.0 161 17.8%
13 15.3 28.3 19.5 141.5 161 17.6%
14 14.0 28.0 21.0 140.0 161 17.4%
15 12.7 27.7 22.5 138.5 161 17.2%
16 11.4 27.4 24.0 137.0 161 17.0%
17 10.1 27.1 25.5 135.5 161 16.8%
18 8.8 26.8 27.0 134.0 161 16.6%
19 7.5 26.5 28.5 132.5 161 16.5%
20 6.2 26.2 30.0 131.0 161 16.3%
21 4.9 25.9 31.5 129.5 161 16.1%
22 3.6 25.6 33.0 128.0 161 15.9%
23 2.3 25.3 34.5 126.5 161 15.7%
24 1.0 25.0 36.0 125.0 161 15.5%
25 ‐0.3 24.7 37.5 123.5 161 15.3%

104
Albion at Highland Park
Technical Assistance Reference
Affordable Unit Rents by Income Tier & Type (Assumes that Rent Includes water and gas utility)1
(based on July 1, 2019 Pricing Schedule)
Unit Rents Req. to be
Req. Avg. Unit Rent for Max Rent2 (see Sec. 150.2109
Affordable on Avg. to
Income Tier Type/# of all units of this type for important limitations to Unit #
those earning the % of
(% AMI) Bedrooms within Income Tier charging Max Rent) (Utilities Assigned
AMI shown below per Sec. included)
(Utilities included)
150.2109 HP Code
$702 $780 108
0-50% 0 45%
(affordable to 45% AMI) (affordable to 50% AMI) 123
$802 $891 106
0-50% 1 45%
(affordable to 45% AMI) (affordable to 50% AMI) 206
$902 $1,002.50 218
0-50% 2 45%
(affordable to 45% AMI) (affordable to 50% AMI) 222

$1,014 $1,248.75 312

51-80% 0 65%
(affordable to 65% AMI) (affordable to 80% AMI) 212
306
$1,158.63 $1,426.25
51-80% 1 65%
(affordable to 65% AMI) (affordable to 80% AMI) 406

$1303.25 $1,605 318

51-80% 2 65%
(affordable to 65% AMI) (affordable to 80% AMI) 322

$1,560 $1,872 412

81-120% 0 100%
(affordable to 100% AMI) (affordable to 120% AMI) 512
$1,782.5 $2,139
81-120% 1 100% 506
(affordable to 100% AMI) (affordable to 120% AMI)

$2,005 $2,406 418

81-120% 2 100%
(affordable to 100% AMI) (affordable to 120% AMI) 422

1) Assumes that Rent Includes heat and water. 2)The Max Rent is the highest rent that can be charged for a particular income tier and unit type
combination, see Section 150.2109 of the City's Code for very important limitations on rents related to the Max Rent. About this table: This table is
provided as a technical assistance aid for those renting units in the Albion Multifamily Rental building in accordance with its development approvals and
Section 150.2109 of the Highland Park Code. Important Note: pursuant to Sec. 150.2109 of the City Code all units of a particular type (# of bedrooms)
within a given income tier are, on average, required to be affordable to those earning the percent of AMI shown in the table above. 3)Reported Rent
information provided by Albion (as of 5.30.2019) Disclaimer: This table is provided as a convenience for property owners. If any information shown in
this table conflicts with the City's Code or development approvals the latter shall hold. Questions? Please call the Dept. of Community Development,
Planning Division and ask for Charmain Later, Senior Planner and Housing Pgm Manager - (847) 432-0867.

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