Affordable Housing Options and Pitfalls

Here's the entire article that was put into 5 parts for easier reading earlier. If you want to learn more about what's going on specifically in McKinney, skip to the last two sections. 

Affordable housing means different things to different people. To some, it means reasonable property appraisals and low taxes, so they can pay their apartment rents and home mortgages. To others, affordable housing means reduced apartment rents often referred to as workforce housing, rent-controlled housing, below-market housing, or rent-capped housing. This kind of affordable housing is generally for those earning around 60%-50% of the median income. For those who earn even less, in the 30% of median range, they qualify for housing choice or section 8 vouchers that can be used at any apartment with an opening and takes the vouchers. 

Below are the income levels HUD uses. Note that HUD doesn't go by Collin county median income, but by the Dallas Metro area median income. According to the U.S. Census Bureau, Collin county's median income is $86,188 and McKinney's median income is $83,257.

What kinds of jobs do people hold who are in the 60% of median income or less range most in need of rent-capped apartments?

Teachers? In MISD, the starting teacher salary is $52,350. Teachers would not have low enough income to meet the 60% of median income threshold unless they were single parents with more than 5 children.
Police? In McKinney, the starting police salary is $57,889.
Firemen? In McKinney, the starting salary is $55,556.

Rent-capped apartments are made more for many entry level, retail, maintenance, secretarial, restaurant, teaching aides, day care, tradesmen, and factory workers. College students with part-time jobs would qualify too. 

Whether you believe promoting or paying to provide below-market housing is a job for the city of McKinney or not, it is still important to learn about the topic. Because our city takes federal and state funding, the strings attached require at least some city effort.  

Below, three of the usual tools for promoting rent-capped housing will be explored, including their positives and negatives: non-profits, LIHTC, and housing set-asides. After that, some past city actions, City Council decisions, and citizen responses will be reviewed. Hopefully, in the end, we can move forward with realistic and cost-effective decisions that will make as much sense in 20 years as they do now.  

Non-Profits 

When groups like Habitat for Humanity are in control and require little or no government funding, they make the best use of their money. There are few government requirements for locations, amenities, applications, materials used, or populations served. This means they can keep the costs down. McKinney is getting a shipping container community because Habitat for Humanity can work out of the box to address housing needs. 

Studies show that the more requirements put on developers from cities, states, or the federal government, the higher the costs will be. Here’s a Citylab.com article that gives the reasons why government subsidized housing is more expensive than when non-profits, who fund the projects themselves with few strings attached, do it themselves:

...As we wrote earlier this year, California Governor Jerry Brown made that point in his state budget. He’s said that he’s not putting any new state resources into subsidizing affordable housing until state and local governments figure out ways to bring the costs down. Last year, opposition from labor and environmental groups blocked the governor’s proposal to exempt affordable housing from some key regulatory requirements. Brown had offered $400 million in additional state funds for affordable housing if that proposal was adopted. Brown took that money off the table.“We’ve got to bring down the cost structure of housing and not just find ways to subsidize it,” Brown said in his budget speech.”

How would the city promote involvement with non-profits while avoiding the usual higher costs involved when government gets involved? Grants are a possible work around on this issue. McKinney Community Development Corporation (MCDC) gives grants to non-profits on an annual basis. 

Voluntary or Involuntary Affordable Housing Set-Aside or Inclusionary Zoning Requirements


This tool to promote affordable housing was popular among a few running for City Council last election cycle and it has been discussed as an option here in McKinney by city staff. Set-asides ask or require developers to set-aside a percentage of their apartment units for affordable housing. Involuntary housing set-asides are not allowed in Texas. Voluntary set-asides are allowed.

When set-asides are voluntary, it's a carrot and stick type of deal. Developers exchange the percentage of rent-controlled apartments for something developers want, like more floors than is normally allowed by the city, higher density, other variances, etc. If developers don't want to build set-asides at their own developments, they can pay a fee to the city to get the same perks. 

The problem with set-asides (see part 1, non-profits) is that the more hoops developers are required to jump through to develop in a city, the more expensive and undesirable building in a city becomes without cities constantly adjusting the required set-aside percentages based on an ever changing economic and business climate.

If a city decides to constantly monitor and evaluate the percentages, the city government will have to hire more people ensure the variable percentages reflect the market, which can be very difficult. There will also need to be city employees tasked with ensuring the set-asides are used properly and stay affordable for however long they are designated to stay affordable. Here’s an excerpt of an article that discusses the complexities of getting the percentages right:

If affordable housing requirements are set too high, the concern is that developers may not be able to make sufficient profits, and they will choose not to build or to build in another community with fewer requirements.Because landowners obviously can’t move to another community, they will have to lower land prices to attract developers – meaning that landowners are the ones whose profits ultimately drop. If land prices fall too far, landowners may decide not to sell – leading to a decrease in housing production overall.

 This reduction in the supply of new housing would, over time, increase the cost if housing – exactly the opposite of an inclusionary program’s intended goal.

While there is not much evidence of this outcome occurring at any significant level in real programs,* this is an appropriate concern that plays a central role in the debate whenever any community considers the right level of affordable housing requirements. Most communities address this risk by setting requirements well below the level that might negatively impact the supply of land for housing. 

In a number of communities, economic feasibility analyses have been useful in helping policymakers get the details right and to build public support for an inclusionary policy. Typically, this kind of analysis involves staff or consultants researching development economics and demonstrating how much local projects can realistically support the costs associated with provision of affordable housing without adversely affecting construction or housing values.

Some in McKinney have suggested that set-asides are similar to parkland dedication that McKinney already requires of all developers. Why not ask for an affordable housing dedication? First off, parkland dedications are mandatory and housing set-asides cannot be mandatory. Secondly, parkland dedication generally benefit everyone, including the developers. Developers know that major selling points for potential residents are greenbelts, parks, and open spaces. On the other hand, requiring a developer to cap and freeze the rents on a percentage of their apartments forever means developers can never profit from them. And, if a set-aside fee dedication can somehow be enacted here, there will have to be an entirely new section of the city government added to oversee new subsidized housing that would have to be built by the government. 

Even if cities find the right balance in percentages and properly oversee the program, the promises of voluntary set-asides are largely never recognized. Many cities find that voluntary set-asides do not give them enough affordable units to be effective or developers simple chose not to participate in the program. The cities that are legally allowed to force developers to set-aside units for affordable housing generally do so eventually. From Shelterforce.org: 

Mandatory inclusionary housing programs—or zoning programs—as most Rooflines readers probably know, are programs which require developers of market-rate housing to set aside a percentage of their houses or apartments as affordable housing. Programs vary widely; some programs are citywide, some are triggered by zoning changes, and some apply to certain zoning districts in a town or city...In the course of that experience, predictably enough, people have long since learned that mandatory is better than voluntary. Given a voluntary program, a lot of developers will duck the option, or choose to forego the incentives that come with the affordable housing strings attached. In a mandatory program, they figure out how to make it work. And after a while, as has been seen just about everywhere it’s been tried, it becomes normal, part of doing business.”

According to Housing Set-Asides: An Activist Toolkit, there are many reasons to make set-asides involuntary:

Housing is simply too important of a need to be left as a voluntary option. Requiring a set-aside citywide, instead of effectively requiring it only in certain parts of the city (as the TIF requirement does) or otherwise making it voluntary, would make a fair, predictable, and even playing field for all developers. The current voluntary program puts developers who volunteer to provide affordable housing at a disadvantage, since negotiating the program takes time. Also, a mandatory set-aside would be far more effective at creating affordable housing than voluntary programs could be—in California, all cities and towns have voluntary set-asides, but only those which require set-asides have successfully created units.

Here's an article from before the Mayor of New York made the voluntary set-asides involuntary:

  “Mayor Bill de Blasio wants to create more affordable units by making inclusionary zoning mandatory: In areas rezoned to allow more density, developers would have to set aside inclusionary units, whether they used the additional density permitted by the zoning or not. By imposing this mandate, the mayor hopes to get both bigger buildings and more affordable units within those buildings.

This approach has met resistance, both within New York and elsewhere around the country. In 2009, a California appeals court threw out mandatory inclusionary zoning requirements because they violated the state’s law against new rent controls. Gov. Jerry Brown, who championed residential development as mayor of Oakland, has turned down mandatory inclusionary zoning proposals twice…In his 2013 veto message, Governor Brown wrote, “As mayor of Oakland, I saw how difficult it can be to attract development to low- and middle-income communities. Requiring developers to include below-market units in their projects can exacerbate these challenges, even while not meaningfully increasing the amount of affordable housing in a given community.”

4% and 9% Low Income Housing Tax Credits (LIHTC)

The LIHTC program provides indirect subsidies to developers with many strings attached. The federal government gives states the ability to give out tax credits. States dole out the tax credits to the developers who apply and meet certain requirements. Syndicators find large corporations to buy tax credits. The large corporations use the tax credits to reduce their federal taxes. Developers use the money from the tax credit sale to build their developments. 

In Texas, the Texas Department of Housing and Community Affairs (TDHCA) is charged with handling the applications and awarding the tax credits. The 9% HTCs are awarded on a very competitive point basis; every point helps. With 9% LIHTC awards, there are few funding gaps. The 4% HTCs are not competitive. There are funding gaps with these. Generally, other program awards, city investment, bonds, and partnerships with non-profits make 4% HTC developments workable. This is generally how mixed-income 9% HTC properties are renovated 15-30 years down the line. After the tax credits are given to developers, there is little federal or TDHCA oversight of the properties. The TDHCA doesn’t always ensure the developments make sense before giving out the awards either. The TDHCA has a long list of requirements. One TDHCA requirement is to ensure that fewer developments occur in high LIHTC concentrated areas. Instead, they want LIHTC developments to be in other areas (which will be discussed later).

There are several cost-efficiency issues with LIHTCs that are becoming worse. According to an article from NPR, this tax credit mechanism is growing more expensive and providing fewer low income housing options. Here are some excerpts from it:

In a joint investigation, NPR — together with the PBS series Frontline — found that with little federal oversight, LIHTC has produced fewer units than it did 20 years ago, even though it's costing taxpayers 66 percent more in tax credits.

 In 1997, the program produced more than 70,000 housing units. But in 2014, fewer than 59,000 units were built, according to data provided by the National Council of State Housing Agencies.

 Industry representatives don't dispute the numbers; they say these trends are the result of rising construction costs, decreasing federal dollars that funded other housing subsidy programs, and stricter state requirements to build homes for the lowest-income households. They also say the business is less profitable than it used to be.

 But NPR and Frontline also found that little public accounting of the costs exists, even among government officials and regulators charged with monitoring the program. Some key lawmakers say that needs to change.

 Betsy Julian and Mike Daniel, civil rights lawyers who have been investigating the program for years, say the thriving private industry is a sign that the scales may have tilted away from the tenants. 

 "It's a frightfully expensive way to provide low-income housing and it's got layers of profit built into it that we think we have to provide in order to get people to do something for poor people," Daniel says.

Julian says 30 years ago, attending affordable housing conferences was different than it is today.

"I have the feeling that I'm in the room with nothing but a bunch of rich guys and gals," she says. "That's an impression that has to do with the ambience and the sense that there's a lot of money to be made around affordable housing."

So why are LIHTC costs higher if fewer units are being produced?

The IRS, which oversees the program, declined a request from NPR and Frontline for an interview. We also reached out to more than 20 industry officials, including the leadership of the Housing Advisory Group and the Affordable Housing Tax Credit Coalition, which represent investors and syndicators such as Boston Capital, PNC Real Estate and Cohn Reznick LLP. They did not agree to an interview but answered questions by email through lawyers representing the industry.

They say several factors have led to higher costs and fewer housing units; primarily, increased construction costs. Indeed, NPR and Frontline found in an analysis of government and NCSHA data that the inflation rate associated with rising construction costs accounts for about half of the overall increase during the last 20 years.

The representatives also noted the decline in grants from two other federal subsidies developers used to help pay for these buildings — the Community Development Block Grant and the HOME Investment Partnership program. Still, fewer than one-third of tax credit units have received grants from these programs historically, according to data from the NCSHA.

Many states also are requiring tax credit buildings to target even poorer renters, which means less rent to cover any debt. But data from the NCSHA show that the proportion of LIHTC tenants in the lowest income category rose from just 4 to 9 percent of new units from 2000 to 2014 across the country.

McKinney is most likely to see 4% and 9% LIHTC mixed-income development applications. Application time for both is the first 3 months of the year. Awards come out around July. 

Rubber Stamping or Thoughtful Planning?

In the quest for more affordable units, some want any and all 4% and 9% HTCs approved without discussions or conversations--even if they don't make sense. If anyone raises questions about developments, costs, appropriateness, HTC concentrations in certain areas, or special requests by developers, they must be against helping low-income people, or worse. This all or nothing outlook can be detrimental to financial responsibility, transparency, and it may even hinder the cause down the line. There are also people who don’t want any below-market housing at all. They’ll come up with all sorts of reasons not to approve or pay for something. Some reasons to deny a resolution of support may be legitimate, though. There’s got to be somewhere in the middle to meet between those who want any and all units no matter how expensive or illogical they are and those who will find any real or imagined reason not to support any units.

There is money to be made off the 9% and 4% HTCs. Most LIHTC developers are for-profits and they bring with them many who are also seeking profits: land owners, land brokers, property management companies, consultants, tax credit syndicators, etc. Cities should do their due diligence as they would for any other project that will get government funding, even if its indirect funding and even if direct funding won't happen for a few decades. 

For example, if cities want to protect the existing below-market housing stock in the future, they will most likely have to make a financial investment of some sort to keep the housing affordable. Otherwise, the properties will possibly go to market rate, especially in areas where property values are high (or will be high in 15-20 years). Looking 15-20 years down the road is responsible. Looking 15-30 years down the line prevents opportunistic property parking too.  

Sometimes, unfortunately, one of the last thoughts is of the needs of the people who will actually be living in the HTC developments short and long term. If there is multifamily land somewhere, anywhere, developers will find a way to put an HTC apartment there— whether there is street access or not, whether there are enough parking spaces for residents, or whether there are water or sewer connections or not. 

Recently, a developer came before the City Council in search of points for a 9% HTC application called Maddox Square that would be located on property that had no direct access to any street. Instead, the residents would have to enter through other business parking lots to get to it. There were also issues with where the easements to the entrances were located.  City Council declined to give its support because of the questions about appropriateness, safety, and easements. Due to the time constraints of the application process, the developer chose to not wait until the easement issue was settled before pulling out.

The next day, a Dallas Morning News article was published about the missed opportunity and much of the blame was put at the feet of a church nearby that didn't want their busy parking lot used as an entrance to an apartment. The same article also stated that there was more oversight with LIHTC apartments:

...Those kinds of properties have more oversight than market-rate rentals because, if they are not managed properly and become neglected, their tax credits could be yanked back. 

This is just not an accurate statement to make if we go by the PBS and Frontline joint investigation into HTCs that was posted in part 3 of this series. 

Here's testimony from a government official from an NPR article about the lack of federal oversight of the program:

Diaz [Daniel Garcia-Diaz, an auditor with the Government Accountability Office while testifying before the U.S. Senate Committee on Finance] noted that the IRS has only audited seven of the 58 state agencies that administer the program in more than 30 years, and when audits were completed, significant problems were found.

"The LIHTC program is a very hard program to review," he told lawmakers at the hearing, called as the committee revisits the tax code to look for solutions to a growing shortage of low-income housing in the U.S. "The lack of information at a federal level, basic information about allocations awarded to projects, placed-in-service dates, are just very difficult for us to review." 

The IRS is able to take the tax credits back from developers and investors when projects go bad, but Garcia-Diaz said the IRS is unable to tell auditors how many times that has happened, if ever. NPR and FRONTLINE found at least three instances where some of the largest affordable housing developers in the country were charged with stealing money from the program.

Even though this potential affordable housing project was declined for a serious logistical concern, many were unhappy that it wasn’t rubber stamped and approved anyway. If we operate on an “at all costs” or “approve it now and worry about it later” mentality, we’re not being smart. Is our bottom line that we just want to be able to say we have a certain number of affordable units or do we care about the quality of life for those who live in and around the units? We can care about both by taking each potential development on a case by case basis. We don’t need to rubber stamp all proposed developments to prove we care about providing rent-capped housing.

Sometimes, the City Council approves parking variances or other exceptions for LIHTC projects that later prove problematic. Limiting parking spots saves developers money. Limiting or removing all enclosed or covered parking also saves money. But, allowing developers to save money in this way lowers the quality of the developments for the city and for the residents. Either the city has parking requirements, or it doesn’t. 

On 12/5/17 at about the 1:10 mark on the City Council meeting video, a land broker speaking on behalf of the developer for the Sphinx Throckmorton planned 4% HTC on the east side of McKinney, told the City Council that they were requesting an exception to the city-wide parking requirement of 1 space per unit and 0.5 per bedroom of the city to a flat 1.7 spaces per unit. He told City Council:

“We’re asking for the reduced parking being 1.7 spaces per unit because the research and the experiences [have] shown that these people don’t have as many cars, that the clients for this project won’t have as many cars, and the 1.7 parking spaces per unit is sufficient to meet that requirement.”

In the letter of intent to Planning and Zoning, he gave this explanation, “6. As noted in the attached Development Regulations, parking for the multifamily units is computed at 1.7 parking spaces per unit, which is in keeping with parking ratios for similar TDHCA multi-family projects” as the reason they were asking for an exception. 

The Sphinx development is slated to have 39, 1 bedroom/1-bathroom units, 131, 2 bedrooms/2-bathroom units, and 50, 3 bedrooms/2-bathroom units. This exception means that 181 units that are 2 bedrooms or more will be missing at least 1 more spot that they would have gotten in any other apartment in the city. And, why is it that workforce apartment dwellers wouldn’t have as many cars as other people anyway? We know that a lack of parking spots caused a problem at Newsome Homes (a 4% HTC project) this year. Management tried to restrict who could park in the parking lot because there were not enough parking spaces. Why wouldn’t there be a problem at the new development too? 

After the presentation by Sphinx and during the discussion of the same item, one of McKinney’s City Councilmen berated the entire City Council body (which included the Mayor) on video for wanting details of the project and for questioning the details of the role the McKinney Housing Finance Corporation (MHFC) is planning to take on as co-developer of the deal. The plan is to have the MHFC purchase 2 tracks of land as a non-profit, including an entire tract of retail land that isn't planned to have any affordable housing on it and lease it back to the developers (watch the 12/5/17 Sphinx Throckmorton video for details). 

Westridge Villas is off Westridge and Custer. In 2015, a developer decided to apply for a 9% HTC for a mixed-income apartment building in a very small sliver of an area that happened to be in Frisco’s ETJ. The developer picked the ETJ because if it had been in Frisco, there would have been development standards and an apartment wouldn’t have been allowed on that land due to logistical issues. She asked the city of Frisco to give her a resolution of support even though the development wasn’t in the city of Frisco. Frisco denied the points because she hadn’t asked to be annexed, hadn’t built according to Frisco code, and didn’t have or ask for a development agreement with the city. See documentation here.

The developer also had no way of getting sewage or water to the apartments. Her 9% HTC application wasn’t competitive enough because Frisco didn’t give her a resolution of support. She then applied for a HOME loan from TDHCA. TDHCA awarded it to her even though there was no way for her to get water or sewer connections to the apartment. She then asked TDHCA to make the HOME loan a 0% with 40 year payback even though HOME loans are 3% and 30 years. She was denied. She continued building. She, McKinney, and Frisco had issues because she demanded they provide her utilities even though she was on county land. She then threatened to sue Frisco through the Public Utilities Commission. Frisco finally annexed her property 2 years later. Her apartment complex hasn’t been built to city code. Many people who watched the PBS video on the subject didn't know about all these details because they weren't presented in the video. If you watch the entire PBS expose video on the link above, you'll get to see some of the abuses of the LIHTC program by developers in Florida that highlights the lack of oversight of the program. 

Do we want City Council to rubber stamp every single LIHTC application because we're only looking at units, or do we want some sort of thought process or evaluation of each and every application?

Is McKinney Winging it Again?

McKinney accepts federal funds, so McKinney must comply with certain HUD regulations and requirements to receive funding for the CDBG program (just to name one). Between 2008 and 2012, McKinney, Frisco, many other cities, and the TDHCA were sued by Inclusive Communities Project (ICP) because ICP said they all promoted concentrations of low-income people in low-income areas. McKinney's issue was that the majority of low-income housing was on the east-side, which ICP considered to be a violation of the Fair Housing Act.

Somehow the burden of correcting the situation landed on the McKinney Housing Authority (MHA). The MHA put out a Request for Qualifications for high opportunity areas (low-poverty and good schools) in McKinney. This effort resulted in MHA putting two 9% HTC  apartments on McKinney Ranch Parkway, on the west-side of McKinney. They were rushed in to satisfy the legal agreement. Since then, there have been several application for west-side HTCs that ended up going nowhere. There are various reasons HTC applications are either pulled or not given enough points. Land deals and financing fall through. Developers change their minds.

Meanwhile, after TDHCA's issues with ICP, the TDHCA changed their system for awarding HTCs by giving more points for 9% HTC applications that were going into high opportunity areas. The TDHCA also focused on "De-Concentration Factors" to prevent too many LIHTC tax credit awards in areas deemed oversaturated. This is how the limitations on developments in certain census tracts came about. And, it is important because McKinney's largest east-side census tracts is now considered oversaturated with more than 20% HTCs per total households. The full over 20% HTC rule reads:

“(e) Limitations on Developments in Certain Census Tracts. An Application that proposes the New Construction or Adaptive Reuse of a Development proposed to be located in a census tract that has more than 20 percent Housing Tax Credit Units per total households as established by the 5-year American Community Survey shall be considered ineligible unless the Governing Body of the appropriate municipality or county containing the Development has, by vote, specifically allowed the Development and submits to the Department a resolution stating the proposed Development is consistent with the jurisdiction’s obligation to affirmatively further fair housing. The resolution must be submitted by the Full Application Delivery Date as identified in §11.2 of this chapter or Resolutions Delivery Date in §10.4 of this title, as applicable.”

In 2016, McKinney created a Concerted Revitalization Plan (CRP) to ensure that the TDHCA would award funding for the redevelopments of three, very old McKinney Housing Authority properties on the east-side, even though they were on the east-side. McKinney was concerned enough about the concentration issues and TDHCA rules that discouraged them, to develop a CRP. Below is a statement from a city official about the purpose of the CRP, according to McKinneyonline.com:

“The Community Revitalization Plan is a city sponsored plan for the revitalization of the McKinney Housing Authority Properties. The plan allows the housing authority to bring greater outside equity to the redevelopment to the three remaining properties on the east side of McKinney – Merritt Homes, Cockrell and Lloyd-Owens,” said Janay Tieken, Housing and Community Development Manager.

Today, has the situation in McKinney improved? Have we de-concentrated the east-side or done anything to prevent even higher concentrations? According to the new 2018 TDHCA calculations, census tract 309 (the largest one on the east-side) has 34.34% HTCs per total households—over 14.34% more than TDHCA limitations allow. From email communication with the person who runs TDHCA's numbers, the rule was revised to add cities with over 100,000 on this list. The screen shot is below. 

The east-side of McKinney is the only census tract in all of Collin county to be put on this list. Plano doesn't even have the concentration overage of McKinney. If McKinney wants to put in any more HTC units on census tract 309, City Council must pass a resolution stating the development is within the city's obligation to affirmatively further fair housing. Is McKinney willing to prove they are meeting their obligations if the federal government disagrees? Is McKinney unconcerned that we're the only city in Collin county with such a high concentration of HTC properties in one area?

Currently, McKinney is working with an LIHTC developer to add over 200 more HTC units to the oversaturated east-side census tract 309 (the Sphinx Throckmorton project). It is very possible that McKinney could come back and say that the Concerted Revitalization Plan can be stretched to justify adding a new development (and not just the three McKinney Housing Authority redevelopment properties as we were told in 2016). It would be a stretch, for sure. 

When City Council voted on the Concerted Revitalization Plan on 1/17/17, the agenda item on Legistar stated the intent of the resolution was to redevelop MHA properties. Additionally, the Concerted Revitalization Plan discussed all three of the MHA properties specifically in relation to utilizing the LIHTC program to help finance their rebuilding.

17-065 Consider/Discuss/Act on a Resolution Approving the Concerted Revitalization Plan to Assist in the Redevelopment of McKinney Housing Authority Properties 

Even though the east-side does need more of these types of living units, the federal government has been making an effort to stop concentrating low-income housing in low-income areas for well over 10 years. All their programs promote high opportunity, low-poverty HTC development areas, and their programs discourage high-poverty, low-opportunity areas. 

From looking at what has happened since the original lawsuit, there doesn't seem to be any sort of coordinated, big picture plan going on as far as how many HTC units should be built, where they should be built, or whether we should rush to rubber stamp or plan ahead for the right ones. 

On the other hand, maybe McKinney doesn't need a coordinated plan. According to McKinney's numbers, we have a very high percentage of LIHTC units compared to other cities in our county. We have double the amount of Plano. Again, all of this is worth discussion.