Date: March 17, 2022

To: Mayor and City Council

From: Geoff Fruin, City Manager

Re: Forest View Relocation Proposal

Introduction

This memo intends to provide a succinct background on the Forest View redevelopment project
that has been planned and discussed over the last approximately seven years. It further
provides information on the current situation and makes a recommendation for the City to offer
voluntary relocation assistance to residents of the manufactured housing park.

The idea for a City funded relocation plan first was presented to the City Council in September
of 2021 when discussing preliminary uses for the American Rescue Plan Act State and Local
Fiscal Recovery Fund (ARPA) that Iowa City was awarded earlier in 2021. As City staff began to
work through the federal rules and develop a proposal, we stayed engaged with the Forest View
Tenants Association and the Center for Worker Justice. Meetings were held on November 9th
and January 19th so that staff could better understand the current situation and so that residents
could better understand our views on the project status and need for relocation. Furthermore, a
draft of this memo was provided to the Center for Worker Justice on February 11, 2022 to share
with the Tenants Association and provide comment back to staff prior to finalizing the memo and
forwarding to the City Council. Staff received feedback in the form of the attached letter from the
Center Worker Justice on March 10th, 2022.

Staff would like to acknowledge the positive, collaborative approach that the Tenants
Association has demonstrated. While there may be disagreements on specific matters
associated with this complex issue, there continues to be a shared desire to work together
toward a positive resolution. This continued collaborative approach will be critical when
executing any future relocation effort.

Background

Forest View is the name of a long-established manufactured housing park located south of
Interstate 80 and west of Dubuque Street in Iowa City. In recent years, the term Forest View has
also been used to describe a larger 73-acre area that not only encompasses the existing
manufactured housing park but also includes large areas of undeveloped land in the same
general vicinity. On the following page there is an aerial image showing the existing
manufactured housing park and larger surrounding area
In 2017, the City adopted an amendment to the North District Plan that included updated
housing, transportation and design goals along with commercial, single-family and multi-family
uses for the larger Forest View area. In 2019, the City approved a conditional zoning agreement
for redevelopment of approximately 73 acres and reviewed a preliminary plat that included
commercial, multi-family, and single-family lots along with nine outlots. The conditional zoning
agreement requires, among other conditions, that the development team provide relocation
assistance. Since that time, the owner of the property, North Dubuque, LLC, has not been able
to commence construction on the redevelopment project. Further, in the last several months it
has been communicated to the City that the project will not proceed as originally planned and
new buyers and/or project partners are actively being sought. Due to significant changes in
market conditions over the last few years, particularly in the commercial and hospitality sectors,
it is unlikely any future plat submission will mirror prior proposals.

The condition of the manufactured housing park, as well as individual housing units within, have
continued to deteriorate in recent years. The number of households residing in the park has
dropped precipitously from approximately one hundred at the time of rezoning to less than sixty
today. With the hope of redevelopment looming, North Dubuque, LLC has not invested to any
great extent in the infrastructure and common spaces. As lot rents have stayed flat and the
number of renters has diminished, it is likely that the overall financial viability of maintaining the
park has long passed. Furthermore, households living in the Forest View neighborhood have
likely been hesitant to pursue needed repairs to individual units due to talks of redevelopment
as well as financial pressures directly related to the pandemic. This collective lack of investment
has accelerated deterioration of the neighborhood and mobile homes, putting occupying
households at a heightened risk of housing instability and significantly impacting their health,
safety and quality of life.

For the last two years, the City has used emergency housing funds to partner with non-profit
agencies and the labor community on critical repairs to individual housing units in the Forest
View neighborhood before each winter season. At the urging of remaining residents, the City
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has also worked with the owner to remove abandoned trailers and eliminate safety hazards.
Residents have also reported deteriorating private infrastructure, including roadways and
utilities. It appears that temporary repairs are frequently being made to the private infrastructure
in the manufactured housing park.

In September of 2021, staff proposed using a portion of federal American Rescue Plan Act
(ARPA) dollars to relocate remaining residents to safer and more stable housing situations. The
relocation effort is intended to prevent an increasingly likely situation of sudden displacement
that could be caused by a significant private infrastructure failure or a future decision by an
owner to close the manufactured housing park. The relocation effort is intended to proactively
provide upfront financial support and connections to social service resources to assist remaining
households with relocating to areas of higher economic opportunity and safer housing
alternatives of their choosing.

Project History and Current Status

Conversations surrounding the redevelopment of the Forest View manufactured housing park
and surrounding properties started to gain traction in 2015 and 2016. A sampling of milestone
dates showing the evolution of this effort are summarized below:

 December 2016: The Forest View Mobile Home Park Relocation Plan completed. The
plan was prepared by HBK Engineering, LLC in partnership with North Dubuque, LLC,
the residents of Forest View Mobile Home Park and the Center for Worker Justice.

 August 2017: The City adopted Resolution 19-90, an amendment to the North District
Plan that included updated housing, transportation and design goals along with
commercial, single-family and multi-family uses for the larger Forest View area.

 February 2018: North Dubuque, LLC and Forest View Tenants Association jointly
applied for a rezoning and preliminary plat covering approximately 73 acres of land.

 May 2018: A revised Forest View Mobile Home Park Relocation Plan was completed.
The Plan was prepared by HBK Engineering, LLC in partnership with North Dubuque,
LLC, North Dubuque Developer, LLC, the residents of Forest View Mobile Home Park
and the Center for Worker Justice.

 June 2019: The City Council approved Ordinance 19-4794 – Rezoning 73.15 acres to
OPD/RS-12 for 50.82 acres and OPD Highway Commercial (OPD/CH-1) for 20.45 acres
and Neighborhood Public OPD/P-1 for 1.88 acres. The applicants included North
Dubuque, LLC, and the Forest View Tenants Association. The rezoning was subject to a
Conditional Zoning Agreement (CZA). Key next steps before building permits could be
approved include a detailed affordable housing agreement and an updated traffic study.
The owner also began the process of requesting Tax Increment Financing (TIF) support
for the public infrastructure components of the project. The preliminary plat application,
however, was incomplete, thus was not approved.

 March 2020: Onset of the COVID-19 pandemic and associated economic impacts on
households, businesses, and commercial property markets.

 June 2021: The OPD Plan expired per City Code standards as no building permits were
issued within two years of the plan approval.

 Current Status: The City has received no indication that the development will move
forward as previously planned. Communications on the implementation of the relocation
plan and the required affordable housing agreement stalled back in November of 2019.
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 Portions of the 73-acre site have been listed for sale. Staff has fielded a few infrequent
inquiries from prospective buyers but does not have information to suggest that a sale is
imminent. At this time, especially with the continued impact of the pandemic on
commercial markets, staff does not see any immediate movement toward
redevelopment of this property. Should interest emerge, it will likely be at least a year
before a new plan could be prepared, reviewed, approved and commenced. It is not
uncommon for projects of this magnitude to take several years to move into a
construction phase.

Overview of Conditional Zoning Agreement (CZA)

The existing CZA, which constitutes part of the zoning code regulating development of this
property, imposes conditions on the development necessary to meet public needs created by
the rezoning application. One of those public needs created is the need to relocate the current
residents upon redevelopment. The CZA requires, among other things, the owner to execute an
affordable housing agreement detailing the terms of the relocation assistance before a building
permit is issued. The provisions of the agreement shall be guided by the principles of the
aforementioned Forest View Mobile Home Park Relocation Plan dated May 2018 attached to
the CZA. That plan was prepared by HBK Engineering, LLC in partnership with North Dubuque,
LLC, North Dubuque Developer, LLC, the residents of Forest View Mobile Home Park, and the
Center for Worker Justice. The affordable housing agreement must be reviewed for compliance
with the CZA and approved by the City.

Significant points of the Relocation Plan include:

 All persons who were residents on the day the CZA was signed (6/4/2019) are eligible
for the assistance outlined in the plan. Eligible means any resident that is in good
standing with the property and abiding by a current lease (if one exists).
 57 new modular homes were to be built in a new Forest View neighborhood based on
the number of income-eligible residents and their desire to remain in the new
development. The CZA also outlined several conditions related to the design of the
homes.
 The owner was to provide the opportunity for income-eligible residents to participate in a
lease-to-purchase pathway to homeownership.
 Each resident was to receive at least one-year advance notification of the date they must
move.
 Three replacement housing options were outlined including, (1) moving to a new
modular home in the Forest View neighborhood if income-eligible (lease-to-own option),
(2) relocating to housing outside the development, or (3) relocating to new multi-family
buildings to be constructed within the development (with lease-to-own option).
 Units were to be similar in size, function, and location and be decent, safe, sanitary, and
affordable. Affordable is not defined in the Relocation Plan. However, conversations at
the time anticipated residents being able to start with rent that was comparable to their
current lot rent with an annual inflationary factor.
 The owner was to hire a relocation coordinator to assist with the relocation activities and
options available.
 For those moving to a different location or living situation, a maximum replacement
housing payment was limited to a maximum of $7,200 per household. This expense was
to be covered by the owner.

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  Moving expenses paid per the Fixed Resident Moving Cost Schedule for Iowa based on
number of rooms with furniture.
The intent of the affordable housing agreement that is required by the CZA, and yet never
finalized, was to move from these general principles to detailed mechanics for satisfying the City
Council’s intentions.

Because the overall development is stalled and unlikely to ever move forward as it was
envisioned in 2019, the conditions of the CZA are likewise unlikely to be satisfied. Realistically,
staff anticipates a future rezoning will be necessary to move forward with any development and,
with that, a new conditional zoning agreement will be needed.

Current Site Conditions and Emergency Winter Repairs

The current Forest View neighborhood continues to suffer from a lack of investment. The
property owner is not reinvesting into the private infrastructure and common areas. Most tenants
are similarly not reinvesting in their individual units. This disinvestment cycle will only continue in
the coming months until either individual units or the entire manufactured housing park is no
longer sustainable.

Absent other actions from the owner or City, it is likely that the park’s private infrastructure and
common areas will continue to rapidly deteriorate and eventually get to the point where there is
no other option than to close the manufactured housing park. This eventual course leaves
residents with no support resources and risks that they will face sudden and unplanned
displacement. State law only requires sixty days of notice to terminate a month-to-month lot
lease at a manufactured housing park, and it is staff’s understanding that there are not any long-
term lot leases in place.

Over the last two years, the City has worked to support volunteer-led mobile home repair
programs aimed at making individual units in Forest View safer heading into the winter months.
In September of 2020, the City approved a $5,000 request by the Iowa City Federation of Labor
to support the purchase of materials and volunteer efforts by the local labor community to assist
twenty-four households with mobile home repairs.

In September of 2021, the City entered an agreement with Habitat for Humanity for $17,500 to
provide home repair and weatherization services to Forest View residents. Habitat has
commenced work on a number of units and will complete the project and report back to the City
on the use of our funds by March 30, 2022.

While these emergent home repair programs have provided some relief, they are best thought
of as temporary fixes to household units that have for the most part exceeded their intended
lifespan. A yearly home repair program is simply not a viable long-term solution for this situation.

Relocation Justification and Overview of Possible Scenarios

The City of Iowa City does not have a legal obligation to intervene in the current situation at the
Forest View neighborhood. Rather, the City’s interest is in assisting our residents in relocating to
safer and more stable housing and to do so in a way that provides households time to plan and
potentially access support resources. Without intervention at this time, there is a substantial risk
of sudden displacement, which can be incredibly disruptive and difficult for households to
navigate. Sudden displacement situations often do not allow for adequate time to coordinate
with needed support services and resources and thus the risk of housing insecurity is greatly
increased.

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While the City is not obligated to offer relocation assistance, the City Council can voluntarily
offer such a program. In recent years, Iowa City has twice directed such relocation assistance
voluntarily:

1. Rose Oaks (2016): In 2016 a new owner of this multi-family property embarked on a
redevelopment and rehabilitation project resulting in the current branded housing
development named The Quarters. No rezoning was necessary and no federal or state
law triggered mandatory relocation assistance. The City Council directed staff to make a
one-time payment of $250 to each household that had a valid lease at the time. A check
was mailed to the last address on record for the tenant. This assistance totaled
$34,000. The City also funded translation services and contracted with Shelter House for
an amount not to exceed $15,000 in HOME funds to assist tenants to secure and rent
other units in Johnson County. The City further assisted with some project coordination
by placing the property manager in contact with local non-profits, including the United
Way, to assist with moving, helping locate units and other assistance.

2. Hawkeye Trailer Court (Prairie Du Chien Road - 2018): The City Council approved a
rezoning request in July of 2018 to redevelop an existing mobile home park at 1705
Prairie Du Chien to a multi-family residential property. As part of the Conditional Zoning
Agreement, the developer was required to provide a nine-month transition period for the
residents to vacate and $2,000 in financial assistance. In addition, an agreement was
entered with Shelter House to provide relocation services to the park residents. Shelter
House provided $14,958 in direct relocation assistance (up to $2,000 per household) to
eight households. Case management expenses from Shelter House totaled
$2,598. Total assistance provided by the City through the Shelter House contract was
$17,557.

In addition to looking at these past examples, the City can craft a program based on the
framework required by the federal government when relocation results from federal or federally
assisted projects. That regulatory requirement is the Uniform Relocation Act (URA).

The purpose of URA is to ensure that persons displaced as a result of federal or federally
assisted projects are treated fairly, consistently, and equitably so that such displaced persons
will not suffer disproportionate injuries as a result of projects designed for the benefit of the
public as a whole. Furthermore, the purpose is to ensure that agencies implement these
regulations in a manner that is efficient and cost effective.

Under the URA, “displaced persons” (as defined in the regulations) shall receive three types of
assistance: 1) replacement housing assistance payments, 2) moving expenses payments, and
3) relocation advisory services. Displaced persons must also receive at least a 90-day written
notice to vacate prior to requiring possession. Regulations for relocation are found at 49 CFR
Part 24.

Replacement housing assistance payment for a tenant is based on the following formula:

42 months x {(lesser of x or y) – (base monthly rent)}.

 X = Average rent and estimated utilities of comparable replacement dwelling
 Y = Rent and estimated utilities of a new dwelling occupied by tenant
 Base monthly rent = lesser of a) average monthly cost of rent and utilities for
reasonable time at current unit prior to relocation, or b) if person is low income
(under 80% median income), then it is 30% of “average monthly gross income”
(as defined in the regulations).

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Whatever the total calculated from the above formula, the maximum assistance is capped at
$7,200. In practice, low-income households almost always reach the maximum assistance level
of $7,200. It should be noted that the 2019 Conditional Zoning Agreement for the Forest View
project also utilized the cap of $7,200 when contemplating replacement housing assistance to
an off-site unit.

To aid in the understanding of this URA calculation, below is an example scenario:

Current rent + utilities $750

Rent + estimated utilities of x value = $900 $900 (lesser value of x and y)
comparable unit
Rent + estimated utilities of y value = $925
newly leased unit
Calculation: 42 x {(900-750)} = $6,300
If the household is low-income, a second calculation is necessary:
Average gross monthly $2,000
household income
Calculation 42 x {900 - (.30*2,000)} =$12,600
Assistance capped at $7,200

Under this scenario, if the household did not qualify as low income, they would receive $6,300 in
replacement housing payments, plus moving expenses. If the household is low income, it would
receive the maximum of $7,200 in replacement housing payments, plus moving expenses.
Tenants have the option of being reimbursed for the actual cost to move or to receive a fixed
amount. It has been staff’s experience that tenants move themselves and opt for the fixed
amount which is based on the number of rooms with furniture. The federal Fixed Moving Cost
Schedule for a mobile home with six rooms is $1,100.

While the City does not have household information for residents currently living in Forest View,
we do understand the base lot rent to be $310. Given the cost of leasing a comparable unit in
Iowa City, it is safe to assume the assistance would likely by capped at $7,200 per household,
plus moving expenses, under the federal standards.

In summary, the City Council has a number of options to consider. As a reminder, there is no
legal obligation to pursue a relocation package. However, in staff’s view such action is prudent.
Thus, the City can look to recent past examples or the commonly used federal standard. A
unique opportunity that presents itself with this scenario, is that the City has recently received
funding under the American Rescue Plan Act (ARPA). While the City has a plethora of potential
options for use of these funds, intervening in this situation to help residents relocate to safer
housing that will provide a greater chance for stability and upward economic mobility seems
appropriate and consistent with the guidance and intent of this law and the established strategic
goals of the City.

Key Issues

As the City considers an approach to relocation, there are several key factors that must be
considered. A brief explanation of these critical issues is addressed below:

 Amount of assistance: As discussed above, the amount of assistance to be provided is

flexible. While the assistance provided in the Rose Oaks and Prairie DuChein cases
provided some benefit to those tenants, the overall amount likely only addressed very
short-term, urgent matters and was not intended to provide longer-term stabilizing
solutions. The federal URA cap that was also explicitly noted in the Relocation Plan that
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 was jointly developed by tenants and the owner has a cap of $7,200, plus a moving
expense allowance. This level of assistance would be more meaningful given the
extremely low lot rents in Forest View but would not stretch as far as it may in other
relocation situations involving higher existing rental rates.

 Funding source: The City budgets $50,000 per year for emergent housing issues
including displacement scenarios. Anything beyond the $50,000 will have to come from
an unbudgeted source or from other funded City initiatives. The City Council previously
signaled support for using federal ARPA funds to facilitate this relocation. U.S. Treasury
guidance has recently provided clarification that such a program would be an eligible use
of ARPA funds. Utilizing this grant source will spare the City from using unbudgeted
funds but will also bring some potential limitations.

 Eligibility: The City will need to determine who is eligible for relocation assistance. This
includes making decisions on income-levels and current residency versus residency
from a date in the past, such as the date of the Conditional Zoning Agreement. Defining
eligibility will have significant impacts on overall costs and eligible funding sources.

 Timeframe: Once a relocation payment is offered, there will need to be an established

timeframe to accept the benefits and vacate the current property. The federal URA
standard requires a tenant to be given ninety days before being required to move.
Considerations must take into account the park ownership’s ability to keep it functioning,
as well as key dates including the start of the school year and onset of winter weather. It
is important to note that the City cannot force anyone to move, and any relocation
payment predicated on a move date is a voluntary matter for residents.

 Future affordable housing on the property: Separate from but related to the relocation
discussion, staff is working with the current owner to ensure that any future development
has a significant affordable housing component. While the City cannot compel land
dedication, staff is having conversations surrounding the potential dedication of land to
the City that would be banked for future publicly controlled affordable housing. The size
of dedication would be approximate to the area on the 2019 preliminary plat that
contained the 57-lot new Forest View residential neighborhood. If a land dedication is
not able to be worked out with the owner, staff will lean on the 2019 Conditional Zoning
Agreement to ensure any future buyer knows that the community expects a significant
affordable housing development to be pursued with the eventual redevelopment of this
property. Under either scenario, the future of affordable housing on this site is unknown
and could be several years away from materializing.

City Staff’s Relocation Proposal

After careful consideration of the current site conditions, the funding opportunity with federal
American Rescue Plan Act (ARPA) dollars, and the lack of any foreseeable progress on site
redevelopment, staff is recommending that the City move forward with a relocation package to
current residents in the Forest View neighborhood.

Based on the March 10th feedback from the Tenants Association through the Center for Worker
Justice, staff recommends expanding the pool of eligible residents from current residents
(approximately 50-60 households), to households that resided in the Forest View neighborhood
when the City staff first proposed the concept of relocation assistance, or September 1, 2021.
This would effectively capture any households that moved out in anticipation of the 2021-22
winter months.

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While the 2019 Conditional Zoning Agreement contemplated assistance to households that lived
there at the date of signing (approximately 100 households), broadening that eligibility will
significantly increase costs and require alternative, non-grant, funding sources as using ARPA
funds for all residents no longer living in the neighborhood is not possible. The development as
approved in 2019 is not moving forward and the benefits in that plan will not be realized by
anyone. City staff is recommending the City Council focus on the critical, acute need of those
that are current residents or moved from the neighborhood since September 1st of 2021.

ARPA rules enumerate relocation assistance as an eligible use and presumes eligibility when
provided to a disproportionately impacted community. To simplify administration of programs
provided to households, the Treasury permits a maximum household income of $40,626 to be
considered disproportionately impacted (households can also qualify if they meet certain federal
assistance program eligibility limits). Thus, to be eligible for relocation assistance, the City will
need to certify households meet this income threshold. The U.S. Treasury encourages self-
certification to ease administration and limit barriers and staff concurs with this approach. In
addition, staff would aim to create a simple method to satisfy proof of residency requirements.

In their March 10th, 2022 response letter, the Center for Worker Justice advocates that the City
treat Forest View as a class of households that were disproportionately impacted by COVID.
This would allow a few households to receive relocation assistance even if their income is
higher than the $40,626 threshold. Proving a disproportionate COVID impact requires
quantitative and qualitive data collection and thus could be potentially more intrusive for
residents. Essentially, the City would have to show how COVID impacted this neighborhood
more than other neighborhoods. It is unlikely that generally stating that loss of employment,
educational hardships or other struggles were disproportionally evident in Forest View will
satisfy federal requirements. In order to avoid having to satisfy this burden of proof and the
associated data collection from residents, staff recommends that self-certification of income (or
prescribed federal assistance program eligibility) remain a necessary component of the
relocation assistance package.

Staff’s proposal is modeled after the federal URA standard but recognizes the $7,200 cap, plus
moving expenses, in the URA and also detailed in the Conditional Zoning Agreement is likely
not sufficient enough to assist households that are only currently paying $310 in monthly lot
rent. To determine a relocation amount, staff is proposing using a standard two-bedroom unit
size, calculated as follows:

Unit Fair Utility Max Current Monthly 24 Federal Total

Size Market Allowance Rent Lot Subsidy Months Moving Assistance
Rent (-) (=) Rent (=) (x) Allowance Per Eligible
(FMR) (-) (+) Household
2 BD $1,036 $116 $920 $310 $610 $14,640 $1,110 $15,750

The formula takes the difference between what is paid today versus the federal Fair Market
Rent for our area and multiplies that gap by 24 (months). After adding the federal moving
allowance, the total relocation assistance for each household would be $15,750. For the
purposes of this relocation program, staff is recommending that each mobile home unit strictly
represents one household, regardless of the number or relationship of adult occupants.

The $15,750 amount is more than double the federal URA and contemplated 2019 Conditional
Zoning Agreement maximum replacement housing amount of $7,200, plus moving expenses.
With an estimated 50-60 households living in Forest View today, the total investment from the
City will be between $787,500 to $945,000 in household relocation payments plus expenses for

Page 9 of 12
partner agencies to provide support services. This number may increase slightly if the City
expands eligibility to households that resided in Forest View back to September 1, 2021.

It is staff’s understanding that disaster assistance funds, including ARPA funds, are not taxable
per IRS guidance. However, if the City uses another funding source the payments could indeed
be considered taxable income.

Relocation assistance of this nature is typically paid in a single lump sum payment. The
beneficiary of the assistance has full discretion on how to use the funds and has no obligation to
report such use to the City going forward. Thus, it could be used for future rent and utilities, a
down payment on a new home, or other needs as determined by the household. Based on
feedback from the Tenants Association through the March 10th letter from the Center for Worker
Justice, staff recommends that participating households be able to access 25% of the
assistance prior to relocation (moving expenses, security deposit, etc.) and the remaining 75%
upon move out from the Forest View neighborhood.

Staff recommends requiring all households accepting the relocation to vacate the manufactured
housing park by December 9, 2022. Avoiding another winter season will greatly reduce the risk
of an unplanned, forced displacement. It will also help ensure that persons find safer, more
suitable housing opportunities for the cold weather season. Assuming the relocation assistance
could be ready by June 1, 2022, the December 9th date provides households six months to find
and relocate to safe, quality housing in areas with greater economic opportunity. This exceeds
the federal minimum of 90 days and the state landlord/tenant law minimum of 60 days. As we
aim for a date beyond the state minimum amount, it should be noted that the owner could move
to closure sooner than agreed upon in any relocation plan.

If the City Council initiates a relocation program, staff will begin to work with area non-profits
that can be resources for residents through this process. The City would offer technical
assistance funds to the non-profits in exchange for services to help residents relocate to new
neighborhoods of their choosing that provide for higher economic opportunity. Such assistance
is encouraged in the ARPA regulations and will help ensure compliance with the final U.S.
Treasury rules.

As previously noted, the City will continue to work with current owner on the possibility of a land
dedication for future affordable housing. The City cannot compel such dedication, but to date
the owner has expressed interest in further exploring this partnership. If the City is able to obtain
land in this redevelopment area, either from current or future owners, it will be able to oversee
the development of an affordable housing project.

Typically, the City would take time to determine any goals for the site (level of affordability,
permanency of affordability, neighborhood design elements, etc.) and then issue a Request for
Proposals to seek development partners. The City would then explore such proposals and
determine the feasibility of each and the preferred path forward. This process could take up to a
year or more based on past experiences. Furthermore, proposed funding sources could take a
while to secure and may limit eligibility of future residents. Realistically, any development of land
that may be dedicated to the City is likely several years down the road at best.

Knowing that a process like this can be extremely complex, staff does not support making any
commitments providing existing Forest View residents any rights of first refusal to undefined
affordable projects in the future. Doing so could prove misleading to residents who have already
been counting on redevelopment for over five years. Setting up further expectations that the City
cannot guarantee may provide additional false hope and may influence decisions on immediate
housing choices associated with this relocation effort. Further, any commitments or guarantees
may constrain the feasibility of future affordable housing efforts. Some residents may not be
eligible to reside in units utilizing certain funding sources due to income levels, citizenship status
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or other complicating factors. For all of these reasons, staff does not recommend that the City
Council make any firm commitments to residents on future affordable housing opportunities in
this area. This does not mean that the City cannot vigorously pursue affordable housing on the
site and explore scenarios in the future that may prioritize former residents. However, it should
be made clear that no guarantees can be made and that the prospect of any future housing
should not influence household relocation decisions needed this year.

Conclusion

There is a long, complicated history with the Forest View redevelopment project. While the best
intentions were focused on providing new housing opportunities for residents of the
manufactured housing park, the project proved to be infeasible. Unfortuantely, the years of no
progress were layered with slowly fading hope which has led to a significant deterioration of the
neighborhood and individual housing units. The COVID-19 pandemic exacerbated the issue.
Waiting for a private market solution is no longer an option and the City must decide whether to
intervene or simply wait for the inevitable closure of the manufactured housing park. The latter
would be a lose/lose situation for all involved, including the residents, property owner and
greater Iowa City community.

Staff is attempting to find a solution that provides meaningful resources for current residents to
find new housing in areas of their choosing that will be safer, more stable and provide for
greater future economic opportunity. At the same time, we are working with the current owner to
try to ensure that broader affordable housing goals that were set forth in the Relocation Plan
and the 2019 rezoning are able to be achieved with any future development proposal from a
new owner. While these efforts fall short of the lofty expectations that were unable to be
achieved from the past redevelopment proposal, they would result in a benefit to current
residents, the property owner and the greater Iowa City community.

Unfortunately, current site conditions and economic challenges create a situation where time for
action is critical. All stakeholders need to work together, and balance drawn out debates on the
specifics of this effort with the expediency of a solution. A failure to work together toward a
workable, albeit imperfect, solution will increase the likelihood of the aforementioned lose/lose
outcome.

Staff is happy to answer questions and guide Council through any changes you might wish to
pursue to this proposal.

City Council Discussion

To assist the City Council with discussion on this complex topic, staff has prepared several
optional guiding questions with the assumption that there is agreement to proceed with crafting
a voluntary relocation program for the Forest View neighborhood:

1. Staff has proposed offering relocation to households that were established in the Forest
View neighborhood as of September 1, 2021, the month in which pursuing a relocation
was first recommended. Other options include, but are not limited to:
a. Current residents
b. Residents established in Forest View as of March 3, 2021
c. Residents established as of the date of the Conditional Zoning Agreement (June
of 2019)
If the Council opts for option (c), consideration should be given to non-ARPA funding
sources and potentially limiting assistance to $7200 per household, as was
contemplated in the Conditional Zoning Agreement for off-site relocation.

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 2. Does the Council agree that self-certification of income (or eligibility in a prescribed
federal assistance program) is a preferred approach over collecting data and information
from residents that could potentially show the neighborhood was disproportionality
impacted by COVID? The latter may allow those with incomes over the eligible threshold
to access relocation funds paid through ARPA.

3. Is the Council comfortable with staff’s proposal for a total relocation amount of $15,750
and the plan to offer 25% in advance of moveout and 75% upon moveout?

4. Is there agreement that in order to access the funding households must voluntarily
vacate the property by December 9, 2022?

5. Staff intends to contract with a few non-profit organizations to provide relocation support
for those needing such services. Accessing support services will be optional for
households and not required to access relocation benefits. Is this City Council
comfortable with this arrangement or is a strict case management approach preferred?

6. Staff recommends against any guarantee or first right of refusal related to future
affordable housing on the 73-acre redevelopment site. We are comfortable exploring
these possibilities should they arise. Is the Council comfortable with this approach?

It is possible that the City Council may need more time to process these issues and make final
decisions. Once final decisions have been reached, staff will prepare a resolution to formalize
the voluntary relocation program.

Attachment: March 10, 2022 Letter from the Center for Worker Justice of Eastern Iowa

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