August 8, 2024 - Below Market Rate (BMR) Fund Expenditures on Administrative Costs Compared to Other Cities
CITY COUNCIL INFORMATIONAL MEMORANDUM
Date: August 8, 2024
To: Cupertino City Council
From: Pamela Wu, City Manager
Re: Below Market Rate (BMR) Fund Expenditures on Administrative Costs Compared to
Other Cities
Background
At the April 3, 2024, City Council meeting, staff was directed to conduct research on
neighboring jurisdiction’s expenditures of Below Market Rate (BMR) Affordable Housing
Fund (AHF) on administrative fees. In accordance with a City Council resolution which
was passed and adopted on May 19, 2020, the City maintains a BMR AHF. In accordance
with the BMR Housing Mitigation Program Procedural Manual section 2.2.2. eligible
activities for this fund are related to the predevelopment and development of affordable
housing. Eligible activities include: administration of the BMR program, land acquisition,
new construction, acquisition and/or rehabilitation of buildings for conversion to
permanent affordability, preservation of “at-risk” BMR units, substantial rehabilitation,
rental operating subsidies, down payment assistance, direct gap financing, fair housing
enforcement, and to benefit the needs of extremely low-income households and persons
with special needs. The City has historically expensed the administrative costs from the
BMR AHF in accordance with the BMR Housing Mitigation Program Procedural Manual
Section 2.2.2.
Revenues for the fund come from a Housing Mitigation Fee that is collected from
construction development projects that is calculated from net added square footage of
residential and non-residential development based upon the Consumer Price Index. In
addition, there is an in-lieu fee for fractional BMR units (when the requirement of
affordable units to be provided by the developer results in a non-whole number with a
decimal between .1 and .4).
Staff has contacted the following neighboring jurisdictions to research common uses for
local BMR funds and specifically, how administrative costs are covered:
Table 1: Santa Clara County Jurisdictions and Comparative BMR Administration Funds
Jurisdiction
Pays for BMR Admin
through BMR Fund
Pays for BMR Admin
through General Fund
City of Campbell No Yes
City of Cupertino Yes No
City of Gilroy Half* No
City of Los Altos Unknown Unknown
Town of Los Gatos Unknown Unknown
City of Milpitas Yes No
City of Monte Sereno No Yes
City of Morgan Hill Unknown Unknown
City of Mountain View Yes No
City of Palo Alto Unknown Unknown
City of San Jose Yes No
City of Santa Clara Half* No
County of Santa Clara Yes Yes
City of Saratoga No Yes
City of Sunnyvale Yes No
*Jurisdictions which paid for BMR administration halfway through a local BMR fund would fund the other
half through another separate local fund
Sustainability Impact
No sustainability impact.
Fiscal Impact
No fiscal impact.
_____________________________________
Prepared by: Nicky Vu, Senior Housing Coordinator
Reviewed by: Benjamin Fu, Director of Community Development
Approved for Submission by: Pamela Wu, City Manager
Attachments:
A – Comparative Santa Clara County Jurisdictions BMR Administration
ATTACHMENT A
Comparative Santa Clara County Jurisdictions BMR Administration
City of Campbell
• The City of Campbell does not currently have a dedicated BMR housing fund but
is proposing the creation of one to their City Council in August 2024.
• BMR administration is done through a housing consultant and is currently paid
for through their general fund.
Cities of Saratoga and Monte Sereno
• Neither the City of Saratoga nor the City of Monte Sereno maintain a local BMR
housing fund.
City of Santa Clara
• BMR administration was previously done through a housing consultant but going
forth BMR rental will be done by in-house staff while ownership BMR
administration will be managed by a housing consultant.
• Staff which work in BMR administration charge half of their time to a locally
dedicated affordable housing fund and remaining half to the Redevelopment
Successor Agency (RDA) fund.
Town of Los Gatos
• BMR administration has been managed by a housing consultant.
City of Gilroy
• The City of Gilroy maintains a local BMR fund that covers for BMR administration
costs.
• BMR administration for both rental and ownership housing is managed by a
housing consultant.
City of Morgan Hill
• The City of Morgan Hill contracts both BMR rental and BMR ownership
administration to a housing consultant.
City of Sunnyvale
• BMR administration is done by two in-house staff (an associate level staff for rental
BMR and a manager for ownership BMR).
• Staff salaries are paid for through a local BMR fund which collects revenues
through that in-lieu fees, fractional fees, commercial linkage fees, and BMR
ownership fees.
City of Mountain View
• The City of Mountain View maintains a BMR fund that collects revenues through
BMR in-lieu fees, housing impact fees and rental housing impact fees. A rolling
NOFA is released for affordable development proposals.
• BMR administration is managed by a consultant, and paid through the local BMR
fund.
• An in-house staff person acts as a liaison and a portion of their salary is charged
to the BMR fund.
Cities of Palo Alto and Los Altos
• Both the City of Palo Alto and the City of Los Altos contract their BMR
administration through a housing consultant.
City of Milpitas
• The City of Milpitas maintains a BMR fund which they refer to as the Milpitas
Housing Authority.
• BMR home ownership administration is managed by a housing consultant, which
is paid through the Milpitas Housing Authority. Individual rental property
managers are responsible for maintaining rental BMR units within developments.
City of San Jose
• The City of San Jose has an in-house staff team to manage both rental and
ownership BMR administration programs and lists all affordable rental units on
the City website through a third-party website.
• Staff salaries are paid through a local BMR fund that collects revenues through
loan fees, monitoring fees, and loan repayments.
County of Santa Clara
• The County of Santa Clara has an in-house staff team to manage both rental BMR
and ownership BMR administration.
• While the County manages its own BMR fund, it does not collect enough fees
through development to offset staff salaries who administer the BMR program.
Staff salaries are paid through their general fund and partially through
administration fees charged to developments.