Among its wide range of services, HR&A provides housing policy and implementation consulting services to the courts and the legal community, public agencies, private developers and not-for-profit organizations.

Housing policy and analysis

These housing-related services include:

• Preparation of housing and community development policies and needs analyses, ranging in scale from large metropolitan areas to individual neighborhoods.

• Analysis and assessment of metropolitan area housing markets.  The firm's expertise is considerable with respect to the Los Angeles area, but its experience is also informed by related work in other parts of the US.

• Design and implementation of innovative programs to produce and preserve market rate and affordable housing, including multi-million dollar Northridge earthquake multi-family recovery programs for Los Angeles and Santa Monica, and redevelopment of public housing projects into mixed-income developments in a number of cities around the US.

• Preparation of market rate and affordable housing development financing plans, including design of real estate partnerships involving complicated tax and legal struc­tures with public and private participants, the issuance of tax-exempt financing and structuring tax-advantaged equity investments.

• Expertise in federal fair housing requirements, including analysis of data used in the establishment of race-neutral admission to tenancy in public housing.

The following are summaries of recent and ongoing experience that illustrate HR&A’s substantial qualifications in housing policy and analysis. 

Affordable Housing Policy

• City of Santa Monica, HR&A developed an Accessory Housing and Parks Production Program.  The program’s  goal was to produce affordable housing and additional public open space over a 10-year period through the application of a two-tier levy on commercial office space.  Following negotiations with various interest groups, a modified version of the program was adopted as an implementation program in the Land Use Element of the City's General Plan, and subsequently as a part of the City's zoning ordinance.

More recently, HR&A prepared a complete revision to the City’s inclusionary housing program to include a menu of options developers of market rate multi-family housing could use to meet the need for affordable housing associated with their projects.  The options include a fee per square foot of new development.  HR&A also prepared a “nexus” study to support the in-lieu fee component of the new program.  In 1999 and again in 2004, HR&A recalculated the in-lieu fee to account for changed market circumstances, and recommended other changes to the fee program for the city’s consideration.

• Westside Urban Forum HR&A prepared a model affordable rental housing production program for this association of Los Angeles area public and private sector land use and planning professionals.  The project included a detailed review of the policies, programs and laws by which rental housing is now being produced in the five cities located on the Westside of the Los Angeles metro area (the western Council Districts of Los Angeles plus the cities of Beverly Hills, West Hollywood, Culver City, Santa Monica and Malibu).  It also included an analysis of the development costs for five case study affordable housing projects and comparisons of affordable and market rate rental housing development costs.  The model program identified potential procedural, policy, legal and financial mechanisms which, if adopted by the Westside cities, that could significantly increase the production of new rental units affordable to very low-, low- and moderate-income households.

• Los Angeles Collaborative for Community Development, HR&A conducted a three year evaluation of the performance of the Collaborative, an umbrella group of national and local foundations, corporations, and the City of Los Angeles which provides operating support and training to more than a dozen community-based development organizations responsible for building special needs and affordable housing throughout Los Angeles County.  HR&A evaluated each organization’s housing production record before and after joining the Collaborative, it progress in achieving various organizational objectives and in meeting other community development goals.

• Community Redevelopment Agency of the City of Los Angeles, HR&A performed a detailed assessment of existing housing and social service needs in the "Skid Row" section of the Los Angeles Central Business District to guide future redevelopment policy formulation and implementation. This effort included an analysis of the area's Single Room Occupancy (SRO) housing stock, and special studies of the demography of the population.  HR&A's population research included the first authoritative estimate of the number of "unsheltered" individuals who regularly sleep in the Skid Row area (i.e., those who sleep in places other than missions, shelters and SROs), which was chosen in 1987 as one of the two most authoritative and methodologically accurate efforts in the United States by the United States General Accounting Office. 

• City of West Hollywood, HR&A evaluated the relationship between new commercial development and demand for housing, public open space and child care facilities.  The analysis resulted in a program of performance requirements, in-lieu fees and program administration guidelines, including the drafting of an implementing ordinance and resolution.  The program was approved unanimously by the West Hollywood Planning Commission and by City Council action in August, 1989. 

• City of Los Angeles City Attorney and the Department of City Planning, HR&A prepared an analysis to support new regulations, including in-lieu fees, for affordable housing that will apply to specified market rate developments pursuant to 1982 State legislation requiring policies to address affordable housing in the coastal zone.  HR&A was specifically named to conduct this analysis in a settlement agreement between the City and plaintiff affordable housing advocates alleging that the City had not properly implemented the State requirements.

• National Equity Fund (NEF) On behalf of the Low Income Housing Tax Credit syndication subsidiary of the Local Initiatives Support Corporation (LISC), HR&A conducted a Management and Organizational Assessment.   NEF, which is actually a "family" of funds headquartered in Los Angeles, Chicago and New York, had experienced explosive growth in its investment portfolio over the last eight years, from an organization that began with a staff of eight to a company with over $1 billion in investments and a staff of over 125 underwriters, attorneys, asset managers and executive and support staff.  Using HR&A's own management analysis method,  we prepared a series of "road maps" of the workings of the organization, together with notation of points of difference between de jure (written) and de facto (actual) procedures. From this analysis HR&A prepared an Issues Roster which focused further discussion and recommendations for the organization in addressing structural and strategic issues that emerged as a result of their rapid growth. Our report was used by the organization's incoming CEO as guidance in preparing his strategic and business plan.  HR&A then worked with NEF’s Acquisitions and Asset Management Departments to enhance the organization’s underwriting and portfolio management practices.

• Cities of Los Angeles and Santa Monica, Calif., HR&A was retained to produce authoritative estimates of the extent of damage to each city’s multi-family housing stock in the wake of the 1994 Northridge earthquake as part of requests for federal emergency funds.  HR&A then helped design each city’s emergency loan program to assist the reconstruction effort.  HR&A also facilitated discussions for each city with major private lenders and negotiated modifications to federal programs at HUD and the U.S. Small Business Administration to make their programs more suitable to emergency housing reconstruction needs.  In Santa Monica, HR&A also provided initial underwriting review of loan applications.

• Under a grant from the James Irvine Foundation, HR&A performed an analysis of a large scale sample-based survey of tenants who received assistance following the Northridge earthquake on behalf of the Department of Housing and Urban Development (HUD), which funded the survey, but had insufficient resources to fund the analysis.  In addition, HR&A explored the role of non-profit agencies in Los Angeles in providing post-earthquake emergency assistance to tenants.  These analyses form part of the HUD evaluation of lessons with respect to Federal emergency assistance from the Northridge earthquake, where HUD, as well as the Federal Emergency Management Agency (FEMA) were, for the first time, joint providers of aid.  Prof. Mary Comerio of the University of California, Berkeley was the co-analyst on this project, which was also partly funded by a grant from the National Science Foundation.

• County of Santa Barbara, HR&A recalculated the in-lieu fee that applies to most kinds of market rate residential development to help fund the development of affordable housing.  Using a calculation definition from the 1993 Housing Element that is described in only general terms, HR&A prepared detailed financial analyses for prototypical subdivision projects in each of the County’s five Housing Market Areas to determine the factors used in the County’s fee formula.  The updated fees were approved by the Board of Supervisors earlier this year.  HR&A was then retained by the County to explore alternative in-lieu fee calculation approaches, the merits of a new fee that would be imposed on non-residential development to help fund affordable housing, and development of new affordable housing strategic plan for the County.

• St. Louis, MO Housing Authority, HR&A, in conjunction with Abt Associates, is providing financial analysis for the Darst-Webbe Near Southside Redevelopment Area, which will include approximately 685 newly constructed rental and home ownership units and several community facilities.  The project received a $46.8 million 1995 HOPE VI grant, but the Housing Authority has faced numerous difficulties in moving the project forward and defaulted on its HOPE VI Grant Agreement in 1997.  HR&A has been retained to provide the financial analysis component of the Revitalization Plan as part of a HUD technical assistance program for troubled HOPE VI projects. 

• Omaha NE Housing Authority (OHA),  HR&A is assisting in the design and development of a program to create 325 units of mixed-finance rental and home ownership units throughout the City of Omaha.  Pursuant to the settlement of a lawsuit by relocated tenants, HUD has provided approximately $30 million in development funds to create scattered site units throughout Omaha over a three- year period.  HR&A is assisting OHA in capitalizing on a strong existing state and local affordable housing delivery system and in leveraging HUD public housing funds with other HUD resources, including HOME and CDBG funds, in order to maximize production over a relatively short time frame.

• Detroit Housing Commission (DHC),  HR&A served as financial advisors for a 120-unit off-site development related to the Jeffries Homes development, which received a $39.4 million 1993 HOPE VI grant.  HR&A worked with DHC staff to develop conceptual design and capital resource requirements for the off-site mixed finance program.  HR&A conducted extensive research through interviews with local community development organizations, private developers, city agencies and the state housing finance agency, and developed financial pro forma for alternative development scenarios.  HR&A also undertook several additional analyses as needed for various aspects of the on-site development.

• Indianapolis Housing Authority (IHA), HR&A serves as the financial advisor for the implementation of the Concord Village/ Eagle Creek HOPE VI development, funded in 1995 by a $30 million HOPE VI Grant.  The overall development includes 170 units of on-site public housing rental and 50 units of off-site, tax credit units.  HR&A developed financial pro forma analyses for both the off-site and on-site mixed finance scenarios, and for the off-site tax-credit component.  HR&A also facilitated negotiations with the developer partner, prepared the Mixed Finance Proposal, assisted in the preparation and submission of the mixed finance evidentiary package and is participating in the final negotiations prior to closing the transaction. 

• For the Cities of New York, Houston and Chester (PA),  HR&A is part of an interdisciplinary team, providing advisory services for public housing revitalization efforts.  Under the United States Department of Housing and Urban Development’s HOPE VI Urban Revitalization Demonstration Program, these and other cities received grants to plan for and implement comprehensive neighborhood revitalization programs.  Central to HUD’s program is the leveraging of public investment to effect a widespread revitalization in and around targeted public housing developments.  HR&A’s role is to design innovative financing strategies, identify creative methods for leveraging public funding and provide expertise in development planning and implementation.

• Community Services Society of New York, HR&A developed and estimated the implied impact of two new programs that would alter existing City housing programs to redistribute the benefits of these programs more heavily toward very low-income tenants in the City.

• New York City Employees Retirement System HR&A developed and implemented a program for using pension fund investments to finance affordable housing.  Under the plan, the retirement system purchased specially designed mortgage-backed securities comprised, in part, of loans to moderate-income households who would not otherwise qualify for mortgages.

• Philadelphia Redevelopment Authority of the City of Philadelphia, HR&A served as financial advisor to assisted in the revitalization of the 800-unit Southwark project.  HR&A acted as advisor on $32,800,000 a tax-exempt bond issue to fund a loan for the acquisition, demolition and reconstruction of the project.  The Redevelopment Authority will purchase the project and resell it to a private partnership.  Upon completion, the construction loan will be repaid from a combination of HUD modernization funds and the proceeds of the sale of the Low Income Housing Tax Credit.  The newly constructed 525 unit development will be conveyed to a new owner, a limited partnership, the general partner of which is comprised of a national not-for-profit organization and a 501(c)(3) corporation formed by the existing residents of the Southwark project.

• Metropolitan Boston Housing Partnership and the Neighborhood Development Support Collaborative, HR&A designed an asset management training program for non-profit community development corporations in Boston.  HR&A collected and evaluated operating expense data on 383 CDC-owned multifamily properties in Massachusetts and prepared a set of  common asset management performance standards and benchmarks.   Based on the outcome of the data collection and research effort, HR&A then developed and delivered a series of training workshops on asset management practices to Board Members, Executive Directors and staff at Boston CPC.    The purpose of the effort was to create a set tools to assist CDCs in evaluating the performance of their multifamily properties in relation to comparable properties in the market and to generally agree upon parameters of excellence.

• Neighborhood Progress Inc., the Enterprise Foundation and the Local Initiatives Support Corporation, HR&A has been retained to produce a blueprint for non-profit housing production system priorities over the next five years, aiming at stabilizing and rebuilding housing markets and achieving broader community revitalization in Cleveland neighborhoods.  The blueprint will include an analysis of trends, resources and capacity that impact developing a sustainable, multi-year, housing production system for Cleveland’s non-profit community.

• Hamilton County, Tennessee and Chattanooga Neighborhood Enterprise, Inc., members of the firm designed a housing finance program to provide low cost mortgages for rehabilitation and new construction in targeted areas and involving the use of multiple subsidies in order to serve lower income families.  The program resulted in the issuance of $12.5 million of tax-exempt bonds for mortgages.

Analysis of Metropolitan Housing Markets and Rent RegulationSystems

Since 1984, HR&A has been developing special knowledge to analyze and assess metropolitan area housing markets and alternative systems of rent regulation.  The firm's expertise in these areas is considerable with respect to the Los Angeles area, but its experience is also informed by related work in other parts of the U.S.  Among recent HR&A assignments which demonstrate this are:

• City of Santa Monica, HR&A prepared a series of housing issue and real estate financial analyses in support of the City of Santa Monica’s 1998-2003 update of its Housing Element.  This included an estimate of the City’s “fair share” of new housing needed to accommodate future household growth, during a period in which the regional planning agency did not prepare city-specific allocations.  HR&A also analyzed the impacts, individually and cumulatively, of regulations that were alleged in recent litigation against the City to be “governmental constraints” on the development of new housing within the meaning of the California Government Code -- the City’s approach to implementing the State’s Ellis Act; permits to remove existing apartments from the jurisdiction of the City’s Rent Control Law; the City’s conditional use permit process for new condominiums; an “inclusionary housing” ordinance requiring that 30 percent of the units in each new multi-family project be reserved for lower-income households; and several actions to rezone multi-family neighborhoods.  In addition, HR&A conducted a detailed telephone survey of renters in the City’s rent-controlled and uncontrolled apartment stock, and projected the impacts on the controlled apartment stock of a new State law that gradually removes the City Charter’s limitations on rent increases when apartments are voluntarily vacated. 

In 2000, HR&A prepared related analyses of seven City housing programs to determine whether they operate as “constraints,” as part of the City’s 2000-2005 Housing Element Update.  The analysis was accepted by HCD as meeting the requirements of State law and that Housing Element was also certified.

• City of Los Angeles and the City of Santa Monica, immediately following the 1994 Northridge earthquake, HR&A evaluated City data on the extent and damage to the multi-family housing stock, identified resources that could be deployed to repair the damage and served as liaison with federal housing officials, banks, and multifamily property owners.  HR&A designed Los Angeles’ initial $30 million loan program to finance reconstruction, where other private and public resources were not available.  This program served as model for Santa Monica’s application for a similar size loan program.  HR&A helped design the loan underwriting guidelines for Santa Monica and provided preliminary underwriting review for some of its more complicated loan applications.

• San Gabriel Valley Council of Governments, an association of 30 cities in Los Angeles County, HR&A provided a detailed review of the method by which the Southern California Association of Governments (SCAG) calculated each jurisdiction’s share of regional housing need for the 2000-2005 planning period.  HR&A’s work involved assisting the cities to devise and negotiate alternative allocations to account for differences with the SCAG approach, while keeping the total assignment to the subregion constant.  HR&A also managed the formal subregional appeals process established by SCAG for final determination of fair share assignments.

• Westside Cities Subregion, the SCAG subregional planning area that includes the cities of Beverly Hills, Culver City, Santa Monica and West Hollywood, HR&A  provided technical assistance regarding SCAG’s revised population, household and employment forecasts to the year 2020, and SCAG’s development of the1999 Regional Housing Needs Assessment.

• For the City of Los Angeles, HR&A was the prime contractor in the first compre­hensive, socioeconomic, highly quantitative review of the rental housing stock in the City of Los Angeles.  The study also included several communities around the City which had not enacted rent stabilization ordinances.  This effort, begun in 1984 and completed in 1985, included large-scale surveys of landlords, tenants, mobile home park owners and mobile home residents.  It was one of the largest consulting contracts ever let by the City of Los Angeles at that time, and the data it generated represented the only informa­tion on the cost and benefit structure of rental housing in any city other than New York.  The study results were the basis for the first successful City Council effort to review and update the Rent Stabilization Ordinance which had been enacted six years before.

In 1988, HR&A was engaged to perform a second review which updated and supple­mented its original work.  This second study was again used as the basis for City Council review and updating of the Ordinance.  In 1993, HR&A was retained by the City to perform a third and even more comprehensive analysis of its rent stabilization ordinance in the context of the behavior of the entire metropolitan housing market.  The final report of that effort was published in December 1995.

• City of Los Angeles, HR&A performed an authoritative analysis of the economics of the City's Single Room Occupancy housing stock, which predominates in the Skid Row area of downtown and other older sections of the City.  The analysis was ordered by the City pursuant to a moratorium on SRO rent increase, and designed to assist the City Council to determine whether, and if so how, to regulate rent in this special category of low income housing.  This analysis was updated and refined as part of the 1994 Rental Housing Study.

• Office of the Mayor of the City of Los Angeles, HR&A assembled and interpreted secondary data from a wide variety of public and private sources on Citywide housing needs, housing characteristics, and patterns of public and private housing production.  The tables and graphs produced as a result of this effort yielded a concise portrait of issues affecting the City's housing stock.  They formed the core of the Briefing Book prepared for the Mayor's Blue Ribbon Committee for Affordable Housing, and were used in the formulation of subsequent City housing policies, including the City's first Comprehensive Housing Affordability Strategy and an update of its Housing Element. 

• City of Los Angeles, HR&A completed an analysis of the financial and social consequences to renters, apartment owners and condominium owners of implementing an ordinance to require the installation of fire sprinklers in existing high-rise residential buildings.  The firm's analysis included a detailed review of the cost of constructing and financing alternative fire safety systems, and the effects that paying the costs of these alternatives might have on those who occupy and own such structures.

• Rent Stabilization Board of the City of Berkeley, HR&A prepared expert analyses of the appropriate methods for implementing two aspects of the City's rent regulations, those with respect to the treatment of net operating income and to definition of a fair return on investment to landlords, after previous provisions had been declared in violation of the due process clause of the California constitution and the City was required by the Court to modify them.  HR&A's work was cited with approval by the majority in the August, 1994 California Court of Appeals decision in City of Berkeley v. City of Berkeley Rent Stabilization Board, in which the City sought unsuccessfully to overturn new regulations adopted by the Rent Control Board that were based in part on HR&A's analysis.

• New York State Department of Housing and Community Development, HR&A performed an evaluation of the existing rent registration data base system, which collects information from the rent control systems of all cities in the state which operate such programs. HR&A helped the Department advise the Governor about ways to make the huge data collection system more useful for policy and regulatory goals of the State, and less burdensome to participants in the system.

• City of Olathe, Kansas, HR&A prepared a series of housing studies for this suburban city in the bi-state Kansas City metro area.  HR&A’s analyses included a five-year housing demand forecast (single-family and apartments), estimates of the fiscal impacts that various development products have on the City and the local school district, and analysis of the property value impacts of non-residential uses adjacent to single-family subdivisions.

Project-Specific Housing Policy, Analysis and Transaction Experience

Other examples of the firm's extensive national track record of service in the areas of housing policy, including direct transaction experience, are:

• County of Los Angeles Community Development Commission (CDC), HR&A has, since 1999, assisted with various aspects of CDC’s Industry Fund affordable housing development loan program.  For 15 single-family, multi-family and special needs projects approved for funding these services have included detailed review of project finances and implementation steps, due diligence review, extensive consultations with applicants and County staff to finalize deal structures, drafting complex loan documents, and negotiations regarding the loan documents with borrowers, their professional consultants and financial partners, County staff and the County’s outside real estate counsel.  Eight of these projects, with Industry Fund loans totaling nearly $10 million, have proceeded to loan closing.  In addition, HR&A has also provided application review, scoring, appeal review and staffing of Independent Review Panel services for about 70 multi-family and senior’s apartment project applications considered under the program, and has provided similar application review services for several other County financing programs.

• Universal Studios, Inc., HR&A analyzed the employment, housing, population and economic and fiscal impacts in Los Angeles County of a proposed $3 billion Specific Plan that will nearly double the intensity of development at Universal City, the home of Universal Studios, Inc.’s film studio, studio tour, various entertainment retail uses, commercial office buildings and hotels.  HR&A’s analyses are part of the project’s Draft Environment Impact Report.

• Los Angeles City Planning Department, The Walt Disney Company, 20th Century Fox Studios, Catellus Development Company, Kaiser Permanente Los Angeles Medical Center, Shappell Industries, Valencia Company, Wilshire/Barrington Associates, the Trump Organization, JMB Realty, Hillman Properties and UCLA, HR&A prepared analyses of employment, housing, population and/or school enrollment impacts of large-scale and long-range development plans, and the degree of conformity between these projects and growth management policies adopted by local and regional planning agencies.

• TransAction Companies, Ltd., HR&A designed and conducted a telephone survey of a random sample of households at an 800-unit apartment complex in Los Angeles in order to assemble household demographic data and  residents' attitudes about the complex.  These data assisted the developer in formulating a redevelopment plan for the property and in pursuing required entitlements.  HR&A also prepared an analysis of the economic viability of the project and four alternatives to it that were analyzed in the project's Environmental Impact Report.  In addition, HR&A prepared technical analysis of project-related housing issues, advised the developer on the merits of proposed permit approval conditions suggested by City officials and others, and provided public hearing testimony on the relationship between the project and City of Los Angeles housing policies.

• New York State Housing Finance Agency, HR&A presently serves as real estate finance consultant. Following an analysis of the agency’s multifamily underwriting guidelines and procedures, and a previous engagement as special workout consultant to the agency, HR&A has been retained by the Agency to assist in program development, advise on multifamily financings, conduct workouts for distressed properties, and implement a staff training program. HR&A’s past assignments for the Agency include preparation of a remedial management plan for two distressed assisted living facilities that had been financed by tax-exempt bonds issued by the agency.

• Arcorp Properties, the principal developer of the New Jersey "gold coast," HR&A conducted an economic analysis of the consequences of a massive mixed use development which includes several million square feet of commercial office space, over 1,000 dwelling units, a large retail complex and a marina.

• Department of Community Development of the City of Raleigh, North Carolina, members HR&A prepared an analysis of housing market conditions and continues to serve on an ongoing basis, as advisor to the agency in the issuance of general obligation debt to finance local housing needs.

• New York City Housing Development Corporation, members of the firm prepared a report on options for modifying or expanding the New York City Rehabilitation Mortgage Insurance Corporation to enhance mortgage insurance options in New York City, in order to expand the availability and affordability of financing for multi-family and single-family housing

• For Shelby County, Tennessee, members of the firm prepared a report analyzing the past financial performance of the County's tax-exempt mortgage revenue bond programs and outlining potential new programmatic efforts.

• In conjunction with the Community Preservation Corporation of New York City, members of the firm prepared a implementation plan for the development of a consortium comprised of local banks and savings associations to increase access to financing for not-for-profit developers in Cleveland.

Analysis of Development Fees Imposed on Private Homebuilders

HR&A is frequently called upon by public and private clients to prepare or critique "nexus" studies now required under Calif. Government Code Section 66000, et. seq., the Calif. Education Code, the U. S. Supreme Court's decisions in Nollan v. California Coastal Commission and Dolan v. City of Tigard, and various California Supreme Court and Appellate Court decisions.  Among the firm's recent assignments of this type are the following:

• For William Lyon Homes, Inc., HR&A prepared a detailed critique of new school fees proposed by the San Ramon Valley Unified School District in the San Francisco East Bay, under new State regulations pursuant to SB 50, the School Facility Program.  HR&A’s analysis concluded that the proposed fees did not comply with the State regulations in a number of respects.  The analysis provided the development company with negotiating leverage to modify conditions of approval for a large subdivision proposal that was already in process when the new State law took effect.

• For Casden Properties, Inc., HR&A is analyzing the implications of new school fees imposed by the Inglewood Unified School District on a 2,000-unit residential project on a portion of the Hollywood Park property.  HR&A’s analysis includes preparation of the school facilities impact section of the project’s environmental documentation, and assistance in formulating mitigation alternatives to the otherwise applicable fee.

• For Castle & Cooke Development Corporation, HR&A analyzed the impacts from a number of large-scale residential projects on a variety of elementary and secondary school districts in Kern County.  The project included developing alternative student generation rates and calcula­tions of "fair share" impact costs pursuant to applicable State law.

• For Olympia & York, HR&A prepared analysis of the degree to which the Wood Ranch residential project had already contributed a fair share of infrastructure and other community benefits such that the City of Simi Valley was not justified in asking for additional fees in order to extend an existing Development Agreement.

• For Landmark Land Company, HR&A prepared a critique of the City of Rancho Mirage's approach to impact fee calculations, and prepared an alternative, nexus?]based approach to fee calculations for a proposed 527?]unit subdivision.

• For TransAction Companies, Ltd., HR&A analyzed the economic consequences to a 200-unit condominium proposal of a City of Santa Monica requirement that 30% of the units be made affordable to low- and moderate-income households, as well as other "inclusionary" housing alternatives which might be offered to the City.