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Council considers HUD Section 108 loan to support Enterprise redevelopments; members question density, school and environmental impacts

January 27, 2025 | Howard County, Maryland


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Council considers HUD Section 108 loan to support Enterprise redevelopments; members question density, school and environmental impacts
Howard County officials and representatives from Enterprise discussed CB3, a proposed use of HUD Section 108 financing to support redevelopment of two existing affordable housing communities (noted in the meeting as Randle/Ramley and Waverly Winds) and other Enterprise projects. The plan discussed would have HUD lend to the county under Section 108; Howard County would sub‑loan proceeds to Enterprise, and the county would use a portion of its annual Community Development Block Grant (CDBG) entitlement to cover a $350,000 per‑year commitment for 20 years. Enterprise representatives said the nonprofit developer will repay the remaining required payments from project cash flow.

How the financing works: staff described Section 108 as a loan mechanism that allows an entitlement community to borrow up to five times its annual CDBG allocation for eligible projects; the county would be obligated to make an annual payment (the county committed to pay $350,000 per year from CDBG entitlement administrative funds in the presentation), while Enterprise would be required to cover other amortization amounts as projects reach cash‑flow maturity. Participants said similar financing had been used previously in the county (for Burgess Mill and the Roger Carter Center) but that the county has not used Section 108 regularly in recent years.

Project and unit details discussed in the meeting:
- Randle/Ramley: the redevelopment replaces about 41 existing units with 82 proposed units (exact net counts and bedroom breakdowns were discussed), including a mix of deeply affordable units and some market‑rate units. Council members pressed Enterprise on façade design and resident amenity/yard placement.
- Waverly Winds: noted in the presentation as increasing from 62 existing units to 123 proposed units; project unit breakdown included categories by area median income (AMI) bands and deep affordability tiers.
- Legacy at Twin Rivers (formerly noted in discussion): speakers said completed redevelopment was being tracked for school impacts.

Council concerns and follow‑ups: several councilmembers and board members asked for additional documentation before acting on the Section 108 request. Key requests and concerns included:
- an amortization schedule and clearer illustration of which payments the county will cover and which payments Enterprise will make over time (staff said the initial years will include interest‑only payments covered in part by the county’s $350,000 commitment while project cash flow matures); staff also said HUD typically fixes the interest rate via a public offering within 12 months of closing, which will change the precise interest cost.
- requests for the county to provide a breakdown of prior county investment or subsidy for each of the five projects in the broader package and to explain how this loan compares to other options for producing affordable housing.
- school impacts: councilmembers asked for enrollment impacts and follow‑up data about students generated by prior redevelopments (for example, Legacy at Twin Rivers) and requested counts of children likely to be generated by the proposed projects; staff referenced an APFO‑style student‑generation formula and said a previous analysis indicated roughly 4–5 additional students for a comparable completed project, but officials did not provide a full post‑occupancy student count at the meeting and committed to follow up.
- environmental and tree impacts: councilmembers asked about specimen‑tree removals, Phase I/Phase II environmental site assessments (staff said Phase I has been done and Phase II is underway), and a list of environmental waivers sought for projects (Enterprise/department committed to provide that list).

Other points: Enterprise representatives confirmed the projects are rental communities (not for‑sale) and said replacements generally mirror existing bedroom counts or increase deep‑affordability units; staff noted the county could consider Section 108 for other eligible uses (community centers, for‑sale housing, infrastructure), but no for‑sale projects were presented for this loan. Council members asked whether Enterprise’s large national philanthropic gifts (referenced in public reporting) could be available for these projects; Enterprise staff said much donated funding is donor‑restricted and not available for site‑specific capital gaps.

What’s next: councilmembers requested an amortization schedule, a breakdown of county subsidy across the package of projects, a list of environmental waivers sought, post‑occupancy school enrollment figures from prior redevelopments and an accounting of available CDBG administrative balances. Staff and Enterprise said they would provide the requested follow‑up material before the council acts on any loan authorization.

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Scribe from Workplace AI
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