May 14, 2018

Dear Mayor Frey,

The City of Minneapolis, and Twin Cities Region as a whole, is at a unique and critical moment to
address affordable housing challenges. Without significant leadership from the City, Minneapolis
will become as unaffordable as major coastal cities. We know that you recognize this. We
commend you for making affordable housing the top priority for your administration and for
asking us to provide a set of recommendations based on community input to inform your
housing priorities.

As you are aware, we convened a series of five meetings to solicit and refine ideas and
recommendations from the community and the public, nonprofit, and business leaders working
on issues of housing. February’s open, public forum was followed by four expert and stakeholder
roundtables on housing stability, rental production and preservation, homeownership, and how
the business community can be a partner in these efforts. The recommendations here are
directly linked to the insight and feedback we received through these meetings. We’ve
formatted this report to you as the final recommendations synthesized across all stakeholder
groups, followed by summaries of each of the community meeting and four roundtables.

During your campaign, you talked about the importance of affordable housing in every
Minneapolis community. Across each meeting and roundtable, stakeholders reinforced that
belief that every Minneapolis neighborhood needs affordable housing. For the City to be healthy
and resilient, each neighborhood must have a continuum of housing opportunities. Through
housing, Minneapolis’ continued growth will strengthen all neighborhoods.

We also note, as you have made clear in your speeches, that affordable housing is a regional
issue that needs a regional response. We encourage you to continue to reach out to other cities
in the region to engage in conversation and develop joint strategies to address our regional
affordable housing needs.

Stakeholders also noted that housing is also an opportunity to meaningfully support low-wealth
communities and communities of color. We know you’re familiar with the significant racial
disparities in housing and encourage you to target resources explicitly, though not exclusively, to
benefit low wealth communities and communities of color.

Finally, we heard multiple times that as a community, we generally know how to provide
affordable housing and support housing stability. The challenge in many cases is bringing these
efforts to scale.

Thank you for making affordable housing the top priority of your administration. And thank you
for the honor of serving as Co-Chairs of your affordable housing task force. We also want to
thank Andrea Brennan, Peter Ebnet, Margo Geffen, Neeraj Mehta, Ellen Sahli, and Emily Seddon
for their expertise and time throughout the community engagement process and in developing
and synthesizing the recommendations.

Sincerely,

Anne Mavity, Peter McLaughlin, and Tom Streitz

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 Increase annual City investment to $50
GOAL
million from a permanent dedicated source of
funds for affordable housing

Affordable Rental Affordable Rental Access to

Housing Renter Supports Affordable
Housing
Production Preservation -Ensure housing Homeownership
quality through
-Increase funding -Provide incentives Regulatory Services -Increase rate of
for development for current NOAH vacant lot
-Create and development
-Inclusionary zoning owners to preserve improve tools to
with TIF and/or affordability, while - Enhance down
maintaining and/or expand access to
other City housing payment
incentives improving safety assistance
and baseline -Prevent
-Rental subsidies to quality displacement -Increase
support education and
renters/units -Increase funding -Explore rental wrap-around
affordable at <30% for NOAH subsidies to support services through
AMI acquisition lowest-income and nonprofit partners
vulnerable renters

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AFFORDABLE HOUSING RECOMMENDATIONS

OVERARCHING GOALS

Over the course of the community meeting and roundtables, common themes emerged.
Stakeholders recognize that housing is a regional issue and requires a regional solution. While
Minneapolis is a critical partner in a regional solution, the City should not delay actions that will
address affordable housing shortages and tenant issues within the City. The City must act both as
a partner in regional efforts and to improve housing and support tenants within its boundaries.

The community meeting and roundtables highlighted two overarching goals for the City.

1. Increase funding. Regionally, the Twin Cities needs $1.1 billion for housing in order to
address current need and meet the demands of projected growth (Minnesota Housing
Partnership). As part of this, we recommend the City of Minneapolis establish a
permanent, dedicated source of funds for affordable housing that will increase the City’s
annual housing budget to $50 million of local funds . This is a $38-$39 million increase over
current funding levels. Because of the scale of the need, the City should focus on
leveraging its funds to attract private and federal investment in addition to funding
successful, existing programs.
a. Stakeholders encourage Mayor Frey to explore creative financing mechanisms,
including those not solely implemented by the City of Minneapolis and those
discussed during his campaign.
b. Stakeholders also shared ideas from other cities to create funding streams, such
as linkage fees or increases in sales tax.
2. Be accountable. Housing is an opportunity to meaningfully support low-wealth
communities and communities of color, repairing past harm. As the City targets resources
explicitly, though not exclusively, to benefit low wealth communities and communities of
color, we encourage an annual report out on who is benefiting from City investment in
housing.

SPECIFIC STRATEGIES

Within the above overarching goals, we’ve organized the prioritized recommendations from the
community meeting and roundtables into four functions of the City’s housing strategy:

• Affordable Rental Housing Production

• Affordable Rental Housing Preservation
• Renter Protections
• Access to Affordable Homeownership

AFFORDABLE RENTAL HOUSING PRODUCTION

1. Increase funding for development.

a. Remove $25,000 per unit cap on Affordable Housing Trust Fund. This will create
alignment between City resources and market conditions, removing the reliance

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AFFORDABLE HOUSING RECOMMENDATIONS

on workarounds such as the contingency fund in excess of the cap that helps
developers move “stuck projects” to closing.
b. Put a greater focus on production of units that are accessible to renters earning
<30% AMI.
c. When focusing on development for low-income renters, it is important to consider
who is low income. In Minneapolis, people earning <50% AMI are more likely to be
people of color. This strategy will help reduce racial disparities in housing.
2. Maximize market growth through inclusionary zoning with TIF and/or other City incentives.
Based on today’s market and availability of capital, this is a unique moment in time for
the City to be able to promote affordability. Stakeholders agreed that this opportunity
will be lost in one to four years.
a. Calibrate to market conditions to continue to promote growth and development.
b. Consider phasing and/or geographic targeting.
3. Provide rental subsidies to renters earning <30% AMI or developers in exchange for longer
affordability.
a. The City of Minneapolis could partner with the Minneapolis Public Housing
Authority or nonprofit partners who already have the program model and
infrastructure to administer rent subsidy programs.
b. Pilot project for direct subsidy to renter in the Promise Zone to support the success
of school children.

In addition to the priorities above, the stakeholders discussed regulatory relief at length. They
noted that many changes would only create marginal cost savings, but that changes would be
an important statement about the priorities of the City to the development community. We
encourage the City to explore ways to reduce fees and simplify requirements and administrative
processes.

AFFORDABLE RENTAL HOUSING PRESERVATION

1. Provide incentives for current owners of naturally occurring affordable housing (NAOH) to
preserve affordability, while maintaining and/or improving safety and baseline quality.
a. Expand use of 4d program.
b. Create a rental rehab program for small scale properties (<20 units).
2. Increase funds for a NOAH acquisition fund.
a. Support acquisitions by land bank, mission driven housing providers, and public
agencies (such as MPHA)

In addition to the priorities above, which support the preservation of unsubsidized affordable
housing, the Minneapolis Public Housing Authority (MPHA) has significant capital needs to
maintain their housing units. We encourage the City to explore ways in which it can be a partner
to (MPHA) in order to maintain safety and quality of the public housing units.

Hennepin County is an ally and partner for many of these strategies. The City should explore how
to leverage the County Sentencing to Service fix-up crews to support preservation efforts or the
new construction of single-family homes.

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AFFORDABLE HOUSING RECOMMENDATIONS

RENTER SUPPORTS

1. Emphasize the renter-focused function of Regulatory Services and align City departments
around proactive actions to ensure housing quality for tenants.
a. Hire more housing inspectors.
b. Establish Tenant Remedy Act or Rent Escrow Actions—appointment of
administrators and/or withholding of rent for repairs.
2. Create and improve tools to expand access to housing.
a. Improve/reform tenant rental screening within the City and as part of a state-
wide effort.
b. Support master leases by nonprofit partners to provide housing to people with
high barriers.
c. Increase ability to expunge unlawful detainers (evictions) from people’s record
when renters were evicted without cause or if they create and comply with a
settlement with the property owner.
3. Prevent displacement from eviction or after sale of property.
a. More funding for legal representation for those facing eviction.
b. Establish “notice to quit” rules that require landlords to provide notice to tenants
that they are out of compliance with their lease and giving them a specified time
frame to remedy the violation prior to filing an eviction.
c. Work with the County to reform emergency assistance so that renters can access
it when they need it.
d. Explore just cause eviction regulations.
e. Explore requirements for a notice of sale, plus 90 day tenant protections.

For the lowest income renters, housing stability can also be improved through rental subsidies.
Stakeholders encourage the City to explore possible rental subsidy models to expand access to
and stability in housing.

ACCESS TO AFFORDABLE HOMEOWNERSHIP

Stakeholders estimated that improving access to homeownership on a scale that would help
ease the affordable housing shortage would require $6 million per year (of the overall
recommended $50 million per year) in funding.

1. Double or triple vacant City lot development. Vacant lots are City assets and a critical
resource to addressing the housing shortage. Developing vacant lots will return the
properties to the tax rolls and benefit the property values and quality of life of neighbors.
a. Scale up the existing vacant lot program to develop 300 lots over three years.
b. The City should explore different levels of investment in development targeted at
different income levels.
c. Work with Hennepin County to also leverage tax forfeited property. There are
currently about 37 tax forfeited lots that are big enough for development.
d. County STS Homes could help build on vacant lots, connecting workforce
development and housing.

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AFFORDABLE HOUSING RECOMMENDATIONS

2. Enhance down payment assistance. Down payment assistance is already tied to

homebuyer education which helps the City reach underserved populations and create
sustainable homeowners. Many homebuyers use multiple sources of down payment
assistance to purchase their home. While this is unlikely to change, the City can enhance
how it uses and grows its assistance programs by:
a. Adding a new first-generation homebuyer program to complement traditional
first-time home buyer assistance programs.
b. Increasing assistance amount to $10,000 per household at <80% AMI to better
match the market conditions.
c. Improving process so that buyers can have a letter of commitment for funds prior
to executing a purchase agreement (similar to mortgage pre-approval letters).
3. Increase education/wrap-around services through nonprofit partners. Current City
assistance to nonprofits is tied to building capacity of homebuyers. Stakeholders
encourage the City to grow this model focusing on nonprofits that provide pre-purchase,
financial wellness, and post-purchase support.

Among the stakeholders there was additional interest in the City exploring:

• A 4-plex homeownership program.

• The production of senior units that will give people options to move out of their single-
family homes, thus freeing up houses for larger families. CURA may be a helpful research
partner to study this concept.

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SUMMARY OF MAYOR FREY’S
COMMUNITY FORUM ON AFFORDABLE HOUSING
FEBRUARY 15, 2018
UNIVERSITY OF MINNESOTA URBAN RESEARCH AND OUTREACH-ENGAGEMENT
CENTER, 2001 PLYMOUTH AVE N, MINNEAPOLIS, MN

SUMMARY

On February 15, 2018, Mayor Frey and the Co-Chairs of his Transition Team’s Affordable Housing Committee
Anne Mavity, Commissioner Peter McLaughlin, and Tom Streitz convened a community discussion on
affordable housing. Approximately 130 people attended the event.

Mayor Frey, Councilmember Gordon, and Councilmember Ellison set the stage for the brainstorming session
by highlighting the need for affordable housing and protecting the City’s renters. The discussion was
structured as two rounds of small group brainstorming on one of four issues:

• Preserving & Producing Rental Housing

• Housing Stability
• Homeownership
• Engaging the business community

Below is a summary of the ideas shared during the Community Meeting. This summary will be available to the
public, policy makers, and participants of Roundtables convened by the Mayor and Co-Chairs to outline
concrete action steps to meet affordable housing goals.

THEMES ACROSS TOPIC AREAS

Several goals and suggestions spanned the four topic areas. This summary attempts to highlight the similarities
between the topic areas, while the individual topic sections remain discrete for ease of use by policymakers.

Across all topic areas, participants focused on:

• establishing dedicated funding for affordable housing,

• incentivizing affordable housing developer and owner behavior to meet goals, and
• reducing regulations or making them more efficient.

Furthermore, across the three of the topic areas (Produce & Preserve Rental Housing, Housing Stability, and
Homeownership) there were the common themes of:

• increasing flexibility in zoning to allow for a variety of types of rental housing and homeownership
opportunities in each neighborhood, including nontraditional models like tiny homes and coops, and
• increasing incomes.

Finally, across the Produce & Preserve Rental Housing and Housing Stability topic areas there were common
themes of:

• preserving and building more affordable housing,

• increasing rent assistance to low-income individuals,
• rent control, and
• improving education on housing issues.

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Community Forum - Produce & Preserve Rental Housing Summary

PRODUCE & PRESERVE RENTAL HOUSING

Goals:

1. Ensure that there is sufficient housing for everyone throughout the entire city
2. Ensure that all areas have some amount of affordable housing
3. Manage housing policy & funding to achieve and sustain a 5% rental vacancy rate.

Kickstarter Ideas
1. Protect naturally occurring
affordable housing and
prevent displacement,
including keeping properties
affordable to residents after a
sale. Alternatively, City could
require buyers to provide
relocation assistance to
Policy
Short Term (4-6 Months)
1. Change zoning to allow for
multiple kinds of housing across
the city. End exclusionary
zoning practices.
2. Increase density.
3. Adopt an inclusionary housing
policy. The City could be as bold
as make 20% of all new units
Long Term (1-4) Years
1. Reduce cost of producing
rental housing to $120,000 per
unit by reducing regulation,
streamlining processes, and
making development process
more efficient. Specific policies
of focus should include parking
requirements, lot size

displaced tenants. available to 30% AMI. requirements, and inspection

4. Set affordability goals for each
neighborhood in the City.
processes.
2. It’s not enough to families to
have a “unit”. Create green
space and community space
for families, and preserve
spaces like Glendale.
3. Prioritize housing for people
recovering from addiction and
dependency. Specifically,
keeping rents at ~$400 per
month.

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Community Forum - Produce & Preserve Rental Housing Summary
Funding Kickstarter Ideas
1. Use bonding authority to increase
funds for affordable housing.
2. Provide incentives for a
commitment to affordability.
Loans/City funds/tax abatement
should come with a commitment
to affordability in perpetuity.
Alignment &
Partnerships
Kickstarter Ideas
1. Partner with the state on non-
traditional housing models.
2. Partner with Hennepin County
to clean up land.
Short Term (4-6 Months)
1. Increase funding for the
Affordable Housing Trust Fund.
Identify a dedicated, stable
source of funds for Trust Fund.
Short Term (4-6 Months)
1. City can help can help convince
bankers that the market has
changes to enable more
affordable developments to get
financing.
Long Term (1-4) Years
1. Transition expiring levees to
support affordable housing.
2. Use social impact funding for
housing.
Long Term (1-4) Years
1. Work with tenants to have a right
of first refusal when their building
is up for sale, and help tenants
purchase property if desired.
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Community Forum - Housing Stability Summary

HOUSING STABILITY

Goals:

1. Stop displacement
2. Improve access to affordable housing
3. Emphasize family housing

Kickstarter Ideas
1. Create more fair screening
criteria, including:
• “Ban the Box” for rental
applications, meaning
Policy
Short Term (4-6 Months)
1. Master leasing program to assume
the risk of tenants.
2. Rent control
3. Establish “just cause” eviction
Long Term (1-4) Years
1. Reduce period that an unlawful
detainer is on a person’s record.
2. Improve renter protections against
evictions.

landlords cannot screen for ordinance. 3. Voice housing as a right at the

past criminal convictions of 4. Require advanced notice of national level.
renters. eviction. 4. Bring back SROs with supportive
• End excessive income 5. Establish renter protection services.
requirements as rental insurance.
screening criteria.
• Cannot screen out for prior
unlawful detainers.
2. Improve renter protections and
establish a Renters’ Bill of Rights.

Kickstarter Ideas Short Term (4-6 Months) Long Term (1-4) Years
Funding

1. More funding for tenant
hotlines/legal aid.
1. Provide assistance before
evictions happen. Look at new
forms of assistance.
1. Increase funding for tenants.
2. Leverage funding from health
care system.
3. Use a stadium ticket tax to fund
housing.
4. Establish a public bank.

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Community Forum - Housing Stability Summary

Kickstarter Ideas Short Term (4-6 Months) Long Term (1-4) Years
Alignment &
Partnerships
1. Protect tenants that want code 1. Integrate housing with health 1. Ensure residents have a stable
and health violations addressed. and supportive services, reliable income.
2. Use homelessness prevention including support to age in 2. Help navigate all of the
funds for renters facing eviction. place. resources and the process.
3. Support formation of tenant 2. Work with mediators. 3. Help make shelter safer and less
unions. 3. Work with Hennepin County. expensive for person
4. Work with inspectors. experiencing homelessness.

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Community Forum - Homeownership Summary

HOMEOWNERSHIP

Goals:

1. Greater rates of homeownership, especially among POCI.

2. Ensure that people are prepared for homeownership if they want it and create paths to homeownership for them
3. Create new systems. Don’t just revise old systems.

Kickstarter Ideas Short Term (4-6 Months) Long Term (1-4) Years
1. Add variety of types/models to 1. Add “starter” housing stock. 1. Create pre-approved designs to
what is already being built, 2. Increase/improve financial reduce cost and increase speed
including: “rehab” programs to prepare of building homes, while
a. Coops people for homeownership. maintaining basic quality.
b. Tiny Homes 3. Remove red tape for buying, 2. Promote owner-occupied two to
Policy

c. Mobile Homes building, and rehabbing homes. four-unit buildings.

d. Cottages/Bungalows (400-800
SQF)
e. Intergenerational housing
f. Duplexes/Triplexes
g. Condos
h. Associations
2. Help people buy existing housing
stock that was converted to rental
during the foreclosure crisis.
Funding

Kickstarter Ideas Short Term (4-6 Months) Long Term (1-4) Years
1. Establish a wealth fund to support 1. Increase funding for the land
potential homebuyers. trust.
2. Increase funding from government
sources, including down payment
and closing cost assistance.

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Community Forum - Homeownership Summary
Kickstarter Ideas
Alignment &
Partnerships
1. Be clearer, more transparent, and
more uniform across
neighborhoods about processes
for neighborhood organization
involvement.
2. Work closely with nonprofits.
Short Term (4-6 Months)
1. Businesses can help remove
barriers and improve credit for
employees.
2. Provide homeownership
education at the neighborhood
level.
Long Term (1-4) Years
1. Help people move from Public
Housing to homeownership,
possibly through a lease to own
program.
2. Think creatively about safe and
vibrant neighborhoods.
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Community Forum - Engaging the Business Community Summary

ENGAGING THE BUSINESS COMMUNITY IN SOLVING HOUSING CHALLENGES

Goals:

1. Elevate housing issues within business community

In addition to discussing ideas that the City can pursue, participants also offered ideas for businesses that already appreciate the
importance of affordable housing. Businesses can:

• Increase the number of Black and People of Color they hire.

• Increase pay/upper management positions for Black and People of Color.
• Invest in microbusinesses through partnership or capital.
• Work with developers to demonstrate need and viability of housing developments to City and funders.
• Invest in job education, which will increase incomes over time.
• Provide incentives for homeownership.
• Provide funding for workforce housing.

Kickstarter Ideas Short Term (4-6 Months) Long Term (1-4) Years
1. Identify profitability metrics related 1. City provides incentive to 1. Provide land incentives or tax cuts
to housing for businesses to assist in businesses that pay employees a for businesses that help meet
Policy

housing issues. living wage. housing goals.

2. Identify City policies that may hold
businesses back from engaging on
housing issues
2. Establish local hiring requirements or
community benefit agreements
with businesses.
2. Tax companies that pay their
executives XX% above their
workforce.
3. Support and advocate for
increases to the federal minimum
wage

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Community Forum - Engaging the Business Community Summary

Funding
Kickstarter Ideas Short Term (4-6 Months) Long Term (1-4) Years
1. Help businesses incentivize 1. Secure funding from business for
homeownership. workforce housing development.

Kickstarter Ideas Short Term (4-6 Months) Long Term (1-4) Years
Alignment &
Partnerships

1. Work closely with businesses that 1. Launch a task force that engages 1. Public – Private Partnerships
invest in Black and People of Color business in housing issues.
owned businesses.
2. Moving beyond partnerships with
nonprofits, work with businesses
that focus on economic
development and landownership.
3. Support local businesses.

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SUMMARY OF MAYOR FREY’S HOUSING STABILITY
ROUNDTABLE
MARCH 16, 2018, 2:30-5PM AT THE MCKNIGHT FOUNDATION
This Roundtable was one of four on various, broad topics related to affordable housing in
Minneapolis. In February, Mayor Frey held a community meeting on affordable housing.
Throughout this community meeting, residents shared their vision for housing stability,
production/preservation of rental housing, homeownership, and engaging the business
community on housing issues. They also suggested strategies that could help Minneapolis reach
these goals. The four Roundtables that follow the community meeting are meant to engage
experts and stakeholders to advance/clarify these ideas, add new ideas, and prioritize
recommendations with specific action steps for the Mayor's Office. The final product of the four
Roundtables will be a report to the Mayor.

MAYOR’S WELCOME

Mayor Frey welcomed and thanked roundtable participants. He reiterated that affordable
housing is the number one priority of his administration. He noted that this roundtable would not
be just one meeting in a series of meetings. It will result in tangible policy at the City and
(hopefully) state levels.

DISCUSSION

Shannon Jones provided a Cheat Sheet on the Area Median Income in the Twin Cities from
CURA.

HOW CAN COMMUNITY VOICE BE INCLUDED WHEN DECISIONS ON ISSUES OF

HOUSING STABILITY ARE BEING MADE?

Continuous Engagement: Participants discussed that engagement with the community should
be continuous, and that it should build on previous engagement and data collection efforts.
Ultimately, it takes time to establish trusting, authentic relationships with the community and the
City should focus on that. One way to build stronger relationships is to include community voices
when defining the problem and coming up with solutions.

Promote Participation: Participants discussed various factors that can make it easier or harder for
community members to participate, including childcare, interpretation, where/how notice is
given. It was suggested that Minneapolis could host Pop-Up Meetings (modeled after City of St.
Paul) during which City staff go to people where they already are for conversation. The City can
also include low-income/wealth tenant representation on major boards and committees like
they encourage representation from other demographic groups. Ideally, if the region is really
committed to engagement, we will start seeing funders encourage and support these efforts.
Summary of Housing Stability Roundtable

Participants also discussed the importance of defining the problem and who is impacted, and
then making sure the impacted people are part of the decision-making process. It was noted
that tenants can only participate in the process when they know what the problem is; but often
by the time the problem is defined, the tenant is in crisis, which limits their ability to participate.

Tenant Organizing: Finally, participants discussed the importance of supporting and providing
resources for tenants to organize themselves. It is one thing to invite tenants to the table, and
another to let them set the table. This is especially important in buildings where low-
income/disabled renters are the minority. When there are just a couple people raising their
concerns in a building, they are not heard. We must support tenants coming together to amplify
each other’s voices.

WHAT DOES TRUE TENANT PROTECTIONS THAT IS CENTERED AROUND HOUSING

STABILITY LOOK LIKE, WHICH DOESN’T DISPROPORTIONATELY PUT THE BURDEN
ON THE TENANT TO SOLVE?

System Challenges: Participants noted that the conversation was focusing heavily on the tenant
experience and noted that it is also important to look at systems that prevent people from
becoming tenants (i.e. evictions, incarceration, mental health, etc.). Society has created a
system, even within the nonprofit sector, that screens people out of rental opportunities.

Landlord/Tenant Relationship: There is a significant imbalance of power in the landlord/tenant

relationship. Most landlords are good, ethical business people, and the bad landlords are outliers
in this community. However, for the most vulnerable renters, those outlying landlords are
commonly the norm. Currently, tenants are rarely in a position to negotiate. Many of the most
vulnerable renters won’t have a written lease. They are informal to the point of being dangerous.
There are structural solutions to this challenge. We can require written leases and recommend
changes in the lease structure to express the rights of the renter differently, without harming the
landlord’s business. Participating landlords were clear that they want to be a part of the solution.

Evictions: The power imbalance is also one of the causes of evictions. Too often, starting an
eviction is the first step in a dispute resolution process. The City/State must consider just cause
and pay or quit provisions to create a better dispute resolution process. Additionally, changes to
when evictions records could be changed so that if a landlord and tenant reach an agreement,
it doesn’t continue to appear on renters’ histories. Finally, the City should work to ensure more
legal representation for renters in court.

Regulatory Services: Improving the City Regulatory Services is another way to help check
landlord power over tenants. The City should hire more housing inspectors. Tiering should be
driven by consumers, rather than an allocation method for inspectors’ time. Tenant complaints
and safety concerns should affect property tiering. Incentivize being in the top tiers (like HUD
does) and penalize the worst offenders. The City could add a 4th (bottom) tier for licensing. In
Seattle, landlords are not able to raise rents until code violations/repairs are made. The City
could also consider some kind of rent control based on property values.

Supply shortages: It is very hard to find an apartment today, especially for people with
disabilities. Current methods of letting people know about housing availability doesn’t work.

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Summary of Housing Stability Roundtable

Many communities rely on word of mouth to learn about opportunities, but by then it’s often too
late. By the time you see a building being built, it’s often already leased. Owners should explore
new ways for rental listings to be distributed. Additionally, the City could do more to help
developers and owners access low cost capital to ensure continued supply.

Service Needs: Many landlords are not prepared to deal with specific needs of renters. For
example, they aren’t informed or equipped to deal with mental health issues. It’s not the
landlord’s job to be a service expert/provider, but it also shouldn’t lead to eviction or
homelessness. It is important to find ways to offer services on-site. The City or nonprofits could
also create a transitional step for renters, in which they do not take on full lease responsibility
right away.

Defining Need: As the City looks to system changes, it is important to consider where income cut
offs for support and services hurts people. The City should help people maintain subsidy, while
they are increasing their income. And the City should make sure that any reforms don’t produce
cliff effects. This gets to the larger issue of framing need in terms of Area Median Income. If the
City can define need on different, relational terms, it can help reduce these cliff effects. When
services are based on income, the cut offs should be net (how people budget) rather than gross
(AMI).

RECOMMENDATIONS

Participants broke into small groups to develop recommendations. After sharing out, participants
voted on their top three recommendations.

1. Dedicate a funding source to support housing stability for the lowest income residents by
identifying revenue streams available and increasing, repurposing revenue to focus on
lowest income renters, working regionally to secure funding, identifying how operating
expenses can be reduced and passing the savings on to support renters. Supporting
housing stability could be in the form of:
a. Short term: Development of affordable units and preservation of affordable units.
b. Short term: Provide supportive services. Consider reforms of the Emergency
Assistance system.
c. Long term: Master Leasing
2. Make Regulatory Services a consumer driven function. In other words, engage
Regulatory Services in solving landlord issues through strategies like re-inspections and
consistent enforcement. This could include an overall examination of the tiering system in
the long term. Specific strategies could include:
a. Re-inspections
b. Consistent enforcement and follow up on inspection
c. Tenant sign-off/acknowledgement of inspection
d. Tenant reviews orders
3. Improve access to housing by reforming screening criteria, especially for properties that
received government funding or tax breaks. Collect data on who is screened out of
access to housing overall, and access to quality housing. Ways to improve access
include but are not limited to:

17
Summary of Housing Stability Roundtable

a. Short term: Ban the box (criminal histories). Could include change to Crime Free
Ordinance to look at conduct on the premises and move to a model of shared
accountability.
b. Short term: Expungement of eviction records
c. Long term: Improving access for people with disabilities (accessible units and
accessible application processes)
d. Long term: Design way to track rental payment history and use it to replace
credit history in screening process.

Other suggestions from the small groups included:

• Short term: Institute a “notice to quit” requirement in Minneapolis, giving renters notice
that they have a specific amount of time to pay back rent, negotiate an agreement
with the landlord for payment plan, or leave a unit before an eviction is filed.
• Long term: Incentivize property owners to take risks renting to high-barrier populations by
providing protection through guarantees or mitigations for owners/operators. This could
include:
o A letter that pre-authorizes renters with incomes that are only 2x the rent amount.
o Guaranteed last month rent so landlords take a chance and give a dispute
process a chance.
• Long term: Allow renters to make repairs to their units and then deduct the cost from their
rent without risk of eviction.
• Long term: Displacement protections

AKNOWLEDGEMENTS

Thank you to Shannon Smith Jones and Will Delaney of Hope Communities for facilitating this
conversation. Thank you to The McKnight Foundation for providing the space and hospitality for
this Roundtable.

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MAYOR FREY’S BUSINESS ROUNDTABLE ON
AFFORDABLE HOUSING
MARCH 22, 2018, 2:30-4:00PM, THRIVENT FINANCIAL, 625 S 4TH AVE,
CONFERENCE ROOM 270, MINNEAPOLIS, MN 55415
This Roundtable was one of four on various, broad topics related to affordable housing in
Minneapolis. In February, Mayor Frey held a community meeting on affordable housing.
Throughout this community meeting, residents shared their vision for housing stability,
production/preservation of rental housing, homeownership, and engaging the business
community on housing issues. They also suggested strategies that could help Minneapolis reach
these goals. The four Roundtables that follow the community meeting are meant to engage
experts and stakeholders to advance/clarify these ideas, add new ideas, and prioritize
recommendations with specific action steps for the Mayor's Office.

Specifically, the Business Roundtable was a high-level conversation on how the shortage of
affordable housing impacts the competitiveness of businesses in Minneapolis and across the
region.

MAYOR’S WELCOME

The Mayor described his belief that everyone deserves a home, and that there are real costs to
housing instability or homelessness. Homelessness costs 3x as much as housing a person. The
effects of homelessness on children has additional consequences, including poor school
performance that down the road contributes to the City’s labor issues. In Minneapolis, 1 in 10 kids
experience homelessness in a given year. There is a great network of public and nonprofit
agencies that are working on these issues of housing, but to make real progress the business
community must be a partner as well. This meeting is part of that partnership.

HOW DO YOUR COMPANIES THINK ABOUT THE INTERSECTION BETWEEN HOUSING

AND BUSINESS INTEREST TODAY?

Housing is a workforce issue: The City needs to have a range of housing choices that are
accessible to the various levels of positions within business. Everyone needs housing that is
affordable to them.

Housing is an infrastructure issue: It takes strong and sound investment to build and maintain
housing, and there is an opportunity to innovate through technology. The market won’t get here
on its own; there must be robust public-private partnerships.

Housing is a factor in regional economic competitiveness: When businesses are competing for
anything, they have to make the case that the City has the infrastructure (like housing) to
handle it. Housing affordability is on the list of economic competitiveness factors, but it has never
been at the top. Now the issue is coming up increasingly, but businesses haven’t figured out their
Summary of Business Roundtable

role in the space. Housing issues aren’t limited to geographic barriers, so the conversation can
be about housing and transportation.

Housing is a talent recruitment issue: Businesses have so many open positions that aren’t getting
filled. Social responsibility is important to many young hires, and they may want to live in
downtowns.

WHAT ARE YOUR IDEAS FOR ENSURING THE CITY HAS ENOUGH AFFORDABLE
HOUSING?

Participants acknowledged that housing was a very complex issue and that tax changes are not
going to spark investment in affordable housing like they used to. Brainstormed ideas from the
group included:

• Planning: Set the housing goal that relates to broad regional goals and lay out the tool
box to achieve it. Give Minnesota Housing a long-term projection, so that they can be
prepared with the resources needed to meet the goal. Make sure financers, public
housing, and chambers know about the goal and the role they will play.
• Land use/Zoning: Business can be a partner in helping ensure that as surface parking lots
go away, some of the housing that is built is affordable. Allow for tiny homes or modular
homes. Allow for four-plexes across the City. Make the approval process faster.
• Opportunity Zones: Be intentional about using and leveraging Opportunity Zones. There
will be $4 trillion in capital gains available to these areas.
• Down payment assistance: Provide down payment assistance that works with
underwriting from any lender for homebuyers. Most people can afford a mortgage, but
not the down payment. Down payment assistance can also give homeowners an
important cushion to make repairs.
• Homebuyer Education: Educate potential home buyers on mortgage products. There are
good products out there. Collaborate with nonprofits and tailor the products to specific
types of home buyers.
• Small building loans: Make loans for repairs/upkeep for small buildings.
• Fund or Pool for Missing Middle: Create a fund or pool where the community can invest
in local affordable housing developments. This could also be a regional strategy. Return
could be slightly less than other investment opportunities because investors would benefit
from the community development.
• Property taxes and fees: Property taxes and fees are already high. Look at City and
County taxes. The City should not expect to raise more funds for housing by taxing
housing further. Property owners margins are already thinner than most people realize.
• Make specific asks: Ask the business community to help fill gaps. City must be very
specific about the need and expected outcomes.

Within all of the ideas shared, participants encouraged the City to think about the housing
challenges and solutions in a holistic, regional way to avoid potential unintended
consequences. Concern about unintended consequences was related both to potential
negative impact to those in need of housing and to an understanding that any kind of
controversy could cause businesses to step back from housing.

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Summary of Business Roundtable

WHAT ARE THE NEXT STEPS THE CITY AND BUSINESS COMMUNITY CAN TAKE
TOGETHER?

TOP PRIORITIES

1. Build awareness of housing is a key indicator of regional economic competitiveness.

Connect the dots for people—every employer knows that there is a workforce crisis,
connect it to housing. This will help lay the groundwork for partnerships and encourage
businesses to take on housing as a stewardship issue.
2. Collaborate. Public-private partnerships will be key to success.

OTHER RECOMMENDATIONS

• Create a housing plan that is connected to a broader regional plan and based on good
data. Work towards that plan, and test/try new ideas along the way. Policy will take too
long to meet immediate housing needs.
• Host a roundtable with B and C class asset owners and the Minnesota Multi Housing
Association.
• Look to other communities and understand how they have addressed housing issues.
• Launch a “Middle Market Fund”.
• Support higher-end housing today that will become more affordable as it ages.

AKNOWLEDGEMENTS

Thank you to Stephanie Brown of Yellow House Ideas for facilitating the conversation. Thank you
to Thrivent Financial for providing space and hospitality for the roundtable.

21
SUMMARY OF MAYOR FREY’S
PRODUCTION/PRESERVATION ROUNDTABLE
MARCH 27, 2018, 2:30-4:30PM
UNIVERSITY OF MINNESOTA URBAN RESEARCH AND OUTREACH-
ENGAGEMENT CENTER 2001 PLYMOUTH AVE N, MINNEAPOLIS, MN 55411
This Roundtable was one of four on various, broad topics related to affordable housing in
Minneapolis. In February, Mayor Frey held a community meeting on affordable housing.
Throughout this community meeting, residents shared their vision for housing stability,
production/preservation of rental housing, homeownership, and engaging the business
community on housing issues. They also suggested strategies that could help Minneapolis reach
these goals. The four Roundtables that follow the community meeting are meant to engage
experts and stakeholders to advance/clarify these ideas, add new ideas, and prioritize
recommendations with specific action steps for the Mayor's Office.

Specifically, the Production & Preservation Roundtable addressed the shortage of affordable
rental housing in Minneapolis by discussing regulatory, finance, and funding tools to build new
housing and preserve existing housing in all neighborhoods.

MAYOR’S WELCOME

The Mayor stated that affordable housing is the number one priority of his administration. He
would like Minneapolis to have truly integrated neighborhoods by race and income. Affordable
housing is a critical component of achieving that dream. The Mayor told participants that this
meeting was an initial step in a process to set policy and funding priorities, and that their
continued involvement will be critical to implementing the ideas that come out of the
Roundtable.

DISCUSSION

Participants discussed various barriers to meeting the City’s affordable housing goals and
possible strategies to overcome those challenges. Participants agreed that overall a regional
housing strategy and funding was important, but that the City shouldn’t wait for that to happen.
The City should work on their own initiatives, while also working at the regional level.

COST OF PRODUCTION/PRESREVATION

The increasing cost of production and preservation of subsidized and unsubsidized housing
exceeds both increases in renters’ incomes and any increases in rents. Rents not keeping pace
with rising capital and operating costs presents a huge challenge for operators. Because of
these high costs, new production toady is at risk of being lost in the future. Additionally,
increasing interest rates are putting operators’ already small margins at risk. When serving
individuals with incomes <30% AMI, making costs pencil out becomes even harder.
Summary of Production/Preservation Roundtable

Participants agreed bringing down costs would only lead to small gains towards the City’s
affordable housing goals. In order to bring down costs enough to make these gains, many small
changes would have to take place. Small changes included:

• Reduce construction costs through changes to state building code.

• Clarify what types of projects are acceptable, for instance making small area plans be in
alignment with comprehensive plans.
• Facilitating new “sleeping rooms”. Currently, operators need an existing license.
• Reduce fees, such as Park Dedication and Right of Way.
• Reduce property tax.
• Because multiple funding sources lead to different standards for inspections, streamline
inspections, by coordinating timing and tailoring to the type of unit (subsidized or
market). (State, federal, city, and county inspections should be the same form.)
o Alternatively, simplifying funding sources (i.e. one funder takes a larger portion of
one project) could reduce some inspection burden.

Participants also briefly discussed the Comp Plan proposal to allow new four-plexes in
Minneapolis. Participants agreed, four-plexes are cost effective to build, but very hard to
manage. Overall, operators need to figure out a scattered site portfolio strategy for this to work
well. Owner-occupied four-plexes could also be a promising strategy, but financing is an issue as
these type of homes as land and construction costs would likely be in the range of $1M, making
them unattainable for many.

REGULATORY BOTTLENECKS

The goal of many regulations is to help developers get to smart designs, but it is not working that
way. Examples of challenging regulations include:

• The Affordable Housing Trust Fund cap of $25k per unit or 15% of TDC is not enough to
create family sized units. It is also really challenging to use this resource on a scattered
site strategy.
• Parking requirements; although this is much less of a problem in Minneapolis.
• Inflexibility in code. Some flexibility could be offered when the code was not about
safety.

FUNDING

Developers and owners of affordable housing and naturally occurring affordable housing are
competing with institutional investors to buy apartment projects in Minneapolis. It can be very
hard to compete with these investors. The City probably has a two- to three-year window before
it will be impossible for nonprofit and local buyers to compete. Overall, participants agreed that
there needs to be more funding.

While local, national, and even international investors are looking to Minneapolis to place
capital, this is perhaps the biggest opportunity to impact the affordable housing crisis. Since the
market is short both affordable and market rate apartments, the City should embrace the fact

23
Summary of Production/Preservation Roundtable

that capital is available to support the creation of new supply. The City should take advantage
of this opportunity to leverage this influx of capital.

Dedicated source funding ideas included:

• The City should put more money into housing every year. Suggested amounts needed
were around $100 million.
• Do something creative and require affordability for development on City owned sites.
• The City should subsidize all housing, in exchange for some kind of
affordability/community benefit. This can leverage city/county/state capital with private
investment that is willing to invest in Minneapolis. Possible forms of subsidy include:
o 10 years of tax abatement
o TIF, either in the traditional sense of only being able to get affordability but for TIF
or broadly to be used to fund new affordable housing.
o Density bonus, but this won’t always help
o 4D tax reclassification

OTHER IDEAS

Participants agreed that while working on specific production and preservation issues, the City
must also focus on improving incomes of residents.

Participants also suggested the City offer a rent subsidy to complement the federal and state
rent subsidies.

Additionally, revenue from Low Income Housing Tax Credits can now be used to deeply
subsidize rents. Developers and operators should take advantage of these changes.

SUCCESSFUL STRATEGIES FROM OTHER CITIES

Participants agreed that we are in a unique moment, especially for preservation. Once naturally
occurring affordable housing is gone, it’s gone. Cities like San Francisco and Seattle have
experienced this. They were not able to find a strategy to stop the losses. Other cities are in
similar positions to Minneapolis—they are losing affordable housing, but can still make changes
to preserve it. Minneapolis should work closely with them to test preservation strategies. Ideas
from other Cities included:

• Dedicated funding source for affordable housing

o Washington DC: Mayor made the decision to use bonding to support housing
o Denver and LA: linkage fee to fund affordable housing
o Housing improvement area: seek legislative change to allow housing
improvement areas beyond condos in order to leverage the City’s balance
sheet.
• Colorado: Reduce local politics and NIMBYism by awarding TIF at the state level.

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Summary of Production/Preservation Roundtable

RECOMMENDATIONS

Participants voted for their top three recommendations for the City. The top three addressed the
need for a dedicated funding source for affordable housing.

1. Increase taxes/bonding to establish a sustainable and dedicated source of funds

2. Provide rent subsidies (either tenant or operating based)
3. Use TIF/tax abatement that is tied to affordability requirements, like inclusionary zoning
• However, the City should avoid policies, such as those in Portland, that have
brought construction of market rate apartments to a halt, as that would further the
housing crisis.
4. Reduction in fees for affordability

Other recommendations included:

• Scattered site loan program.

• Enhance the use of 4D tax reclassification
• Clarity in zoning
• Buy naturally occurring affordable housing
• Require longer affordability terms when developments include public investment
• Remove the cap on amount per unit available from the Affordable Housing Trust Fund
• Use density bonuses or establish density by right

AKNOWLEDGEMENTS

Thank you to Cathy Bennett of ULI Minnesota for facilitating this roundtable. Thank you to the
University of Minnesota Urban Research and Outreach-Engagement Center (UROC) for space
and hospitality.

25
MAYOR FREY’S AFFORDABLE HOMEOWNERSHIP
ROUNDTABLE
MARCH 29, 2018, 2:30-4:30 PM
MINNEAPOLIS CENTRAL LIBRARY, 300 NICOLLET MALL, MINNEAPOLIS, MN
55401
This Roundtable was one of four on various, broad topics related to affordable housing in
Minneapolis. In February, Mayor Frey held a community meeting on affordable housing.
Throughout this community meeting, residents shared their vision for housing stability,
production/preservation of rental housing, homeownership, and engaging the business
community on housing issues. They also suggested strategies that could help Minneapolis reach
these goals. The four Roundtables that follow the community meeting are meant to engage
experts and stakeholders to advance/clarify these ideas, add new ideas, and prioritize
recommendations with specific action steps for the Mayor's Office.

Specifically, the Homeownership Roundtable focused on how to support affordable

homeownership opportunities within the City of Minneapolis at a scale that can relieve housing
cost burden and competition for affordable rental units City-wide.

MAYOR’S WELCOME

The Mayor stated that affordable housing was the number one priority of his administration. The
City knows that lack of investment and supply are two of the causes that lower-income
homeowners are challenged to find homes in Minneapolis. The City is also aware and working to
change the significant racial gap in rates of homeownership. Homeownership is one of the
principal ways to build generational wealth, and therefore must be a priority for the City. The
Mayor hoped that this roundtable would generate policy and funding recommendations, and
how the City can help bring current efforts to scale.

DISCUSSION

Participants launched the conversation by sharing recommendations of the Homeownership

Opportunity Alliance, across sector collaboration that is designed specifically to address racial
disparities in homeownership. Recommendations included:

• Provide deeper and more expansive down payment assistance. $5k-$10k in down
payment assistance is not enough in this current market, and will be even less effective
over the next few years.
• Design specialty mortgage products, including ITIN loans for people without social
security numbers and interest-free (also referred to as Sharia complaint) loans that meet
religious and cultural needs of homebuyers.
• Allow for alternative forms of underwriting that enable access to credit. For example,
underwriter could look at rental payment history instead of credit score.
• Provide rehab assistance to allow people to age in place.
Summary of Affordable Homeownership Roundtable

HOMEBUYING PROCESS

Overall, participants agreed that affordable homeownership was a high touch business. It
requires long term, wrap around relationships with clients. From credit counseling, to homebuyer
education, to post-homebuyer education wrap around services must be provided to help
people be successful. Typically, this relationship lasts up to 2 years.

Participants agreed that we largely know what works to support affordable homeownership, but
haven’t been able to do it at scale. Some participants further urged the City to focus on
homeownership programs that aggressively target African Americans and other affected
communities to address the inequities created by city endorsed redlining and the displacement
caused by the implementation of the freeway system.

Participants discussed the process of achieving homeownership, and ideas for improving the
process:

1. Potential homebuyers need affordable rental housing to save up and prepare for
homeownership.
2. Homebuyers may need/seek out homebuyer education.
• Many nonprofits that provide these services (and post-purchase support) are at risk
financially. The City cannot afford to let these organizations disappear. Is there a fee-
for-service model in which lenders pay nonprofits for preparing buyers that use their
products, if it was managed by an outside entity?
3. Homebuyers need access to financing that meets their needs.
• Sellers aren’t allowed to incentivize buyers to buy, but lenders are able to incentivize
borrowers. How can we change this to reduce predatory lending?
• Lenders should be taught to build alternative credit histories. How can we get
underwriters to take a deeper look at credit scores? Is someone’s credit 580-620
because they are building it? Or because they tell from a 720? Underwriters are up
against goals to close, and therefore there is no incentive to take extra time with a
client to do this.
• Cost of mortgage is born by the private market. Can the City take on some risk to
help offer new products? Once we’ve tested new products there could be wider
adoption in the private market.
• Lenders and realtors can do more at the consultation level to help people
understand what they can afford, keep their lifestyle the same, and qualify for. Then
help them match that to available stock.
4. Some homebuyers need financial assistance.
• Many people need down payment assistance. Some sellers are only accepting
conventional loans, which may require more of a down payment. Providing down
payment assistance that was preapproved and stayed with people would allow
them to be more competitive when putting in offers on homes in this market.
5. Homebuyers must be able to find a home they can afford.
• There is a pipeline of hundreds of people that are approved for loans of $200k or less.

27
Summary of Affordable Homeownership Roundtable

• One challenge is that the stock a family can afford may not be big enough for that
family. At what point do we encourage buyers to buy smaller homes than they want
as a stepping stone to a larger home that truly fits their needs?
• As older homes are demolished, what is built in their place is much more expensive.
This is a challenge for lower-income homebuyers.
• The appraisal system drives availability at all income levels. The City can decide how
much to let me market run and how much to regulate.
6. Post-purchase support.

DEVELOPING HOMES

Participants agreed that there needed to be a dedicated funding source for affordable
homeownership. Compared to other cities, Minneapolis still has an opportunity to support lower-
income residents become homeowners.

Developers can’t build new homes for less than $225k (hard costs) right now. More funds are
needed to increase production. Development costs could be cut at the margins, but it is unlikely
that it will help bring development to the scale the City needs. The group discussed questions
such as:

• Is there a way to ensure perpetual affordability when there is public investment? How
can we balance preserving the public investment while providing wealth building
opportunities?
• How do we develop smaller sites with density?
• What is the need? Few families are looking for one-two bedroom units. Large family
housing is needed.

Rehab of a property usually costs more than $30k or $35k. Limits for rehab should allow costs to
go to $70k.

Current development and rehab programs are one a one-off project basis that pits nonprofit
developers against each other. The process also makes it hard to leverage other funds. It would
be better if developers could go to the private market and demonstrate matching funds from
the City.

Ideas included:

• Address the effects of redlining with financial assistance.

• Shorten plan review timelines. Habitat for Humanity uses 26 standard designs, it would be
great if a few could be pre-approved by the City.
• Enable coop models of ownership so that people can build equity without the such a
high level of upfront investment.
• Modular housing, although cost and time savings are marginal unless a manufacturing
facility can be opened in the metro.
• USDA support is very successful, but only available to smaller towns. It charges interest
based on income and provides local control over underwriting. Could this be replicated
in the seven-county area?

28
Summary of Affordable Homeownership Roundtable

• Build houses that can be expanded in the future by finishing basement or second floor.
• Gap financing can include a provision for shared appreciation to create a recycling
fund to support development at the City.

Participants also noted that the success of a home is more than just the structure. It is the
neighborhood around it. The City could ask developers to work in 5 block areas to create more
of a community. The EcoVillage is an example of this.

Participants discussed a program to help move seniors from single family homes to open up
stock. This is problematic because there is a shortage of senior housing and it contradicts age in
place priorities. All providers also want to make sure that seniors get the best price for their
home. There is a Land Trust program that helps cost burdened seniors stay in their home in
exchange for the land deed. Then, when seniors pass on or move, the property is affordable in
perpetuity.

Participants urged the City to build communities with sustainability in mind. To build for the
people that live in that community. Participants encouraged CPED to continue to emphasize
working with developers of color, and tracking progress.

Participants cautioned that we don’t know how the market will react to some of the more
creative solutions in this arena. If the market doesn’t support it, these solutions are just taking
more resources away from families we are trying to serve.

RECOMMENDATIONS

Participants agreed on the following recommendations:

Funding: At a minimum, the City should triple its annual investment in homeownership programs
and development. This would total roughly $6 million a year. If the City is able to test new
initiatives the investment could be increased five times, to include covering new
staff/administration.

Policy: Simplify down payment assistance. Allow for preapproval and offer higher amounts to
help make buyers competitive. Minnesota Housing recently raised their down payment
assistance. Minneapolis should offer at least $10k for households at 80% AMI. These households
will likely need $20k or $25k, and can combine City assistance with other sources. City should
would with households to tailor assistance to specific circumstances because down payment
assistance usually isn’t grants. Too much assistance may wipe out any equity when homeowner
eventually sells (deferred loans do not carry this risk). The City should be cautious about going
too much over 100% CLTV. Education is important for these homebuyers.

Partnerships: Connect economic develop and homeownership/housing initiatives. This will tie
employment with homeownership and affordable housing opportunities.

AKNOWLEDGEMENTS

Thank you to Kristin Beckmann for facilitating this roundtable. Thank you to Hennepin County and
the Minneapolis Central Library for providing space.

29