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RES 2022-0255 - South Central Omaha CBA and EBA ���� City Clerk Office Use Only: RESOLUTION NO. 21, Publication Date (if appli able): -7 Agenda Date: If' ) 7 C)Z 2_ Department: 't ittilii Submitter: L1ck1c fir) 'Id 17 Pik CITY OF OMAHA LEGISLATIVE CHAMBER Omaha, Nebraska RESOLVED BY THE CITY COUNCIL OF THE CITY OF OMAHA: WHEREAS, the primary objectives of the City of Omaha's Master Plan and Community Development Program are to encourage additional private investment and infill development within inner city neighborhoods; to eliminate the conditions which are detrimental to the public health, safety and welfare by developing vacant and/or underutilized property within these neighborhoods; and, WHEREAS, Nebraska State Statute Section 18-2109 requires that before any redevelopment plan be prepared, the City Council must declare that the proposed redevelopment area, hereinafter called a Community Redevelopment Area (CRA), meets the standards established by Nebraska's Community Development Law as being a substandard and blighted area in need of redevelopment; and, WHEREAS, Nebraska's Community Development Law was amended as a result of Nebraska's 106th legislative session which added the definition of Extremely Blighted Area (EBA), State Statute Section 18-2103 (13), and which was primarily intended to promote home- ownership and to facilitate affordable housing development throughout the State of Nebraska; and, WHEREAS, a non-refundable state income tax credit of five thousand dollars ($5,000.00) could be available to qualifying individuals who purchase qualifying residences as a primary residence in "designated extremely blighted areas"; and, WHEREAS, the study area evaluated a broad area to establish qualifying Community Redevelopment Areas and Extremely Blighted Areas that also contained the potential redevelopment projects pursuant to the analysis included in Exhibit "A" attached hereto and made a part hereof; and, WHEREAS, the general boundaries of the study are Pacific, Pierce and Mason (Bridge) Streets between 1-480 and South 16th Street on the north, South 16th 21 St and 24th Streets between Mason and 1-80 on the east, and 1-80, Oak, Elm and Vinton Streets between I- 480 and South 16th Street on the south, and 1-480 from 1-80 to Pacific Street on the west as shown on the map included in Exhibit "B" attached hereto and made a part hereof; and, WHEREAS, the proposed Extremely Blighted Area is within an area concurrently being designated as a CRA and is within the corporate limits of the City of Omaha and will be designated as both "Community Redevelopment Area" and as "Extremely Blighted Area" upon City Council approval; and, RESOLUTION NO.2D2Z-VL7 WHEREAS, this analysis and designation shall supplement areas already declared blighted and substandard and shall recertify the areas within the study area already declared blighted and substandard; and, WHEREAS, at its public hearing on February 2, 2022, the City of Omaha Planning Board approved the designation of the study area as both a Community Redevelopment Area and an Extremely Blighted Area for the same area shown on the map included in Exhibit "B". NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF OMAHA: THAT, the proposed Community Redevelopment Area and Extremely Blighted Area designation of the same area shown on the map included in Exhibit "B" attached hereto and made a part hereof, which has a study area generally bounded, by Pacific, Pierce and Mason (Bridge) Streets between 1-480 and South 16th Street on the north, South 16th 21 st and 24th Streets between Mason and 1-80 on the east, and 1-80, Oak, Elm and Vinton Streets between 1-480 and South 16th Street on the south, and 1-480 from 1-80 to Pacific Street on the west are hereby declared to meet the definitions of both a Community Redevelopment Area and an Extremely Blighted Area in compliance with the requirements of Nebraska Community Development Law and are hereby designated as both a CRA and as an EBA. 3219 nsp APPROVED AS TO FORM: e-/Z ASST. CITY ATTORNEY DATE Adopted: APR 05 2022 n Attest: City/Clerk Approved: I A4k/ Mayor EXHIBIT I;January, 2022 Community Redevelopment Area (CRA) Designation And Extremely Blighted Area (EBA) Analysis 25th and Center CRA/EBA This analysis first defines a study area based on US Census geography, then examines the demographic data specified in the State of Nebraska's Community Development Law as criteria for determining an area's eligibility for designation as a Community Redevelopment Area (CRA). It also evaluates the study area's eligibility for the newer Extremely Blighted Area (EBA) designation using the appropriate additional criteria set forth in state law. The overall condition of the built environment within the study area is also examined in detail. The built environment is comprised of buildings, structures and public infrastructure. The purpose of this analysis is to determine whether the area qualifies for formal designation as a CRA, to determine if the area also qualifies for the EBA designation, and to establish boundaries that are consistent with the law. When it is determined that the entirety of a study area meets the criteria for CRA and EBA designation, additional factors are evaluated to determine whether designation should encompass the entire area or if a more limited portion of it should be designated. Existing land uses, zoning designations, and the future land use plan are factors that help determine which portions of the study area, if any, warrant designation, as these influence the potential for future redevelopment projects. The analysis in this report relies on U.S. Census Bureau data at both the Census Tract level and the Block Group level. Census data for the larger Census Tract level area is initially examined, then Block Group level data are evaluated. The broader study area examined in this report is comprised of Census Tracts 20 and 33. Further analysis examined the smaller, more targeted area comprised of Census Block Groups 1 and 2 within Census Tract 20, and Census Block Groups 1 and 2 within Census Tract 33. Ultimately, the area recommended for designation in this CRA and EBA is defined within this study. The boundaries follow Census geography. They are irregular and the written description, below, is very general. However, the boundaries of the area recommended for designation are specifically illustrated on Map A: NORTH Pacific, Pierce and Mason (Bridge) Streets, between I-480 and South 16th Street; EAST South 16th, 21St, and 24th Streets between Mason and I-80; SOUTH I-80, Oak, Elm and Vinton Streets between 1-480 and South 16th Street; WEST I-480 from I-80 to Pacific Street. The data and analysis that follows in the remainder of this report establish that the entire area of the two Census Tracts meet the criteria for CRA designation of the Nebraska Community Development Law, and also meets the criteria for the EBA designation. Further analysis of the smaller Census Block Groups was undertaken to reaffirm that portions of the overall study area are eligible for the designation. The area ultimately recommended for CRA and EBA designation 1 EXHIBIT I;January, 2022 in this report is a smaller, more targeted portion of the study area comprised of four Census Block Groups. The specific boundaries are shown on an attached exhibit labelled Map A. The study area contains a patchwork mix of older developments with commercial, industrial, rail and residential uses all heavily intermingled. Incompatible land uses are often located in abrupt proximity to one another, giving the area an appearance of having developed in a rather random, haphazard manner. The development of the area has also been significantly impacted by the disruptive and intrusive influences of an interstate highway, a major main line rail corridor, and two viaducts (located on both Vinton and Martha Streets). These barriers not only discourage development of parcels to their highest and best use, they also interrupt the street layout in the area making connectivity problematic. Redevelopment of the study area is additionally impacted in a negative way by some very challenging topography. The infrastructure is relatively old compared to the City overall. Street paving is in very poor condition in many locations, some street segments lack paving entirely, and many streets have substandard lane widths, poor storm drainage, and a lack of sidewalks. To the extent possible, the proposed CRA boundary has been drawn to avoid inclusion of single family residential neighborhoods, while maximizing the amount of sites where new non- residential economic reinvestment may be anticipated to occur. Some of the larger businesses, spaces and land uses within the area include A&R Salvage & Recycling, the Grede Casting foundry, Morgan's Place Storage, a concrete crushing and recycling operation, the historic Quartermaster Depot, James F. Lynch city park, Superior Lighting, Nox-Crete, Immaculate Conception Catholic Church, the Vinton Square commercial strip mall, and Elliott Equipment Company. Nebraska Community Development Law Section 18-2103 of Nebraska Community Development Law establishes specific criteria for local governments to examine when considering an area for formal designation as a CRA. The purpose of this evaluation is to identify and compare the characteristics of the study area to the established criteria and thereby determine whether such designation is appropriate. If the area is deemed qualified and eligible for the designation, the governing body—in this case the City*of Omaha—may declare the area to be a CRA, enabling the City to seek the remedies established by law. A formal declaration of the substandard and blighted conditions allows the creation of an area redevelopment plan for the designated area. The area redevelopment plan describes the existing conditions of the area and identifies the redevelopment activities that will be undertaken to reduce or eliminate the deteriorating conditions within the area. The following written analysis establishes that there are conditions within a portion of the study area that meet the state law requirements. The boundaries of that area are defined in this study, and the area recommended for CRA designation can properly and legitimately be established as a CRA by the Omaha City Council. Land Use The area recommended for CRA designation consists of 1,530 parcels. With street and rail rights-of-way included, the entire study area is about 683.19 acres in size. Residential is the largest category of land use in the area, occupying about 24.4 percent of the land area. Industrial 2 EXHIBIT I;January, 2022 uses occupy about 22.1 percent of the area. The 17.5 percent for civic, religious and exempt land uses is relatively high, mainly due to the inclusion of railroad properties in this category. The amount of vacant land is notable since 18.3 percent is relatively high and the vacant land includes many sites appropriate for job generating commercial and industrial uses. Land Use Land Use Acres Percent Civic, Religious, Exempt 119.60 17.50% Commercial 39.61 5.80% Industrial 150.89 22.09% Residential 166.91 24.43% Vacant 125.15 18.32% Street ROW 80.84 11.83% • Total 683.19 - 100.00% Criteria for Community Redevelopment Area (CRA) Designation The State of Nebraska's Community Development Law sets forth several specific requirements that must be met for a City to designate a Community Redevelopment Area. The terms "Sub- standard" and "Blighted" are included in the law, each with a separate definition and each with its own specific set_of requirements. A geographic area under consideration for CRA desig- nation must meet the,requirements of both definitions. Additionally, the term "blighted" is - further broken down into two components; Part A and Part B. The study area must also meet the requirements of both parts A and B of the "blighted" definition to be eligible for designation as a CRA. The following includes a description of each criterion, an explanation of why the subject area does or does not meet the criterion and a determination: a"Yes" or"No" response indicating whether the criterion is met. Blighted; Part A The Nebraska Community Development Law definition of Blighted: ...which by reason of the presence of a substantial number of deteriorated or deteriorating structures, existence of defective or inadequate street layout, faulty lot layout in relation to size, adequacy, accessibility, or usefulness, insanitary or unsafe conditions, deterioration of site or other improvements, diversity of ownership, tax or special assessment delinquency exceeding the fair value of the land, defective or unusual conditions of title, improper subdivision or obsolete platting, or the existence of condi- tions which endanger life or property by fire and other causes, or any combination of such factors, substantially impairs or arrests the sound growth of the community, retards the provision of housing accommodations, or constitutes an economic or social liability and is detrimental to the public health, safety, morals or welfare in its present condition... 3 EXHIBIT I;January, 2022 The physical characteristics observed in the study area demonstrate that the Part A definition of "blighted" described in Nebraska Community Development Law is applicable. The area is an older industrial area in Omaha, with structures of varying ages. The residential dwellings in the overall study area have a median age greater than 80 years in both Census Tracts 20 and 33. Based on the year built data from Douglas County Assessor records, the median age of the nonresidential building is 71 years in Census Tract 20 and 112 years in Census Tract 33. The residential structures, on average, are generally older than the nonresidential structures. The Douglas County Assessor utilizes a hierarchy of building condition ratings to establish the assessed value of properties with improvements. The hierarchy of building condition categories, as listed from the best condition to the worst in descending order, are: "very good," "good," "average," "fair," "poor," and "worn out." Within the area recommended for CRA designation, just 84 of the 1,317 structures are designated as being in the "good" or"very good" condition categories. The overall condition of the residential buildings is below average, at best. Of 1,165 residential structures rated by the Douglas County Assessor, 408 are in the "fair," "poor" or "worn out" categories, which constitutes 35.0 percent of the structures. Similarly, 65 of the 152 nonresidential structures (42.8 percent) are in the same categories. Most of the industrial structures are quite old, constructed in the 1950s or earlier. They are also very simple utilitarian structures in most instances, such as pole barn structures of metal skinned prefabricated construction. There are a couple very large vacant, neglected masonry commercial structures that are essentially building shells exposed to the elements. As previously cited in this analysis, curbs, gutters, and sidewalks are absent in a few areas, existing street pavement widths are often too narrow and/or in need of repair, and storm water drainage facilities are inadequate. Economic redevelopment of sites to a level approaching their highest and best use is effectively discouraged by the presence of deteriorated buildings, aging infrastructure and the presence of rail, express highway and viaduct land uses. A comprehensive windshield survey of the study area was undertaken to establish this assessment of building conditions and infrastructure conditions. Criterion met? Yes. Blighted; Part B Several components are set forth in Part B of the Community Development Law to determine if an area meets the definition of the term "blighted." These are quantifiable criteria. In this part, only one component need be considered affirmatively to meet the Part B portion of the "blighted" definition. For four of five components, U. S. Census data provides the necessary information for deter- mining whether the blight criteria is met. The Census Data used for this analysis relies primarily on Census Block Group data. The geographic area analyzed in this study involves four Census Block Groups, located within two Census Tracts. The City examines the data at both the Census Tract level and the Block Group level as a way to cross reference data to help assure accuracy, and as a means to ensure that data validity at the Census Block Group level is verified and not skewed by some anomaly. 4 EXHIBIT I;January, 2022 The 2000 and 2010 Census data is used for the population counts, as required by Community Development Law. Data from the U.S. Census Bureau's five year American Community Survey (ACS) data is used for the other criteria as it provides the most current and relevant data for the economic criteria. In this case, the 2019 5-year ACS data is the most current, and has been used for the evaluation. Each component of the Part B definition of blight is listed below along with an explanation of results and whether the three Block Groups involved in the study area meet the criterion. 1) Unemployment in the designated area is at least one hundred twenty percent of the state or national average. According to the 2019 American Community Survey (ACS) published by the U.S. Census Bureau, the unemployment rate for the State of Nebraska is 3.34 percent. One hundred-twenty percent of the state rate therefore sets the threshold for this TIF criterion at 4.01 percent. The unemployment rate for the entirety of Census Tracts 20 and 33 are 8.3 and 7.2, respectively, both of which exceeds the threshold required for designation. The unemployment rate for Block Groups 1 and 2 of Census Tract 20 is 7.1 and10.5 percent, respectively, both of which also exceed the threshold for CRA designation. The unemployment rate for Block Groups 1 and 2 of Census Tract 33 is 2.0 and 11.7 percent. The 2.0 percent unemployment does not exceed the threshold, but the rate for the entire Tract that contains Block Group 1 of Census Tract 33 does exceed the threshold for the unemployment rate. Because the margin of error is less for the larger Census Tract area than it is for the smaller Block Group area, the area can still be considered to be exceeding the threshold and is still eligible for designation under Community Development law. Criterion met? Yes. 2) The average age of the residential or commercial units in the area is at least forty years. According to the U.S. Census Bureau, the median age of residential structures in both Block Groups 1 and 2 of Census Tract 20 exceeds 82 years, as the Census data shows the majority of the homes were built in 1939 or earlier. The data is the same for Block Groups 1 and 2 of Census Tract 33: the majority of homes were built in 1939 or earlier, and thus have a median age of 82 years or more. These all exceed the required threshold of 40 years. Data for nonresidential structures isfrom the Douglas County Assessor's records. The median age of nonresidential structures in Block Groups 1 and 2 of Census Tract 20 is 94 years and 51 years, respectively. The median age of nonresidential struc- tures in Block Groups 1 and 2 of Census Tract 33 is 116 years and 98 years, respectively. Criterion met? Yes. 3) More than half of the plotted and subdivided property in an area is unimproved land that has been within the city for forty years and has remained unimproved during that time. The majority of the lots in the study area have been developed with improvements. Criterion met? No. 5 EXHIBIT I;January, 2022 4) The Per Capita Income (PCI) of the area is lower than the average per capita income of the city or village in which the area is designated. According to the 2019 U.S. Census American Community Survey, the PCI for Omaha is $33,401. The PCI for the entirety of Census Tracts 20 and 33 is $17,454 and $14,460, respectively. These income figures are substantially less than the City overall. The PCI for Block Groups 1 and 2 of Census Tract 20 is $21,838 and $17,349. The PCI for Block Groups 1 and 2 of Census Tract 33 is $13,771 and $14,969. In all instances for all of these geographical areas, the PCI is less than the overall Citywide PCI. Criterion met? Yes. 5) The area has had either stable or decreasing population based on the last two decennial census counts. State Community Development Law considers an area's population to be stable or decreasing when the population has a growth rate less than five (5) percent. The rationale is that areas with a rapidly growing population are developing quickly, and therefore can not be considered to be "blighted." According to the 2000 and the 201.0 U.S. Census counts, the population in Block Group 1 of Census Tract 20 grew by 22.7 percent, while the population of Block Group 2 declined slightly (by 0.8 percent). In Census Tract 33, the population of Block Group 1 grew by 8.5 percent. and in Block 2 the population declined by 4.5. Thus two of the Block Groups meet the criteria for designation, while the other two do not. Side note: the unusual population growth prompted further investigation into the area's demographics. Remarkably, the residential populations of the two "growing" Block Groups happened despite a notable lack of growth in the housing stock. In fact, the number of housing units in Block Group 1 of Census Tract 20 grew by just 13 units, while the population increased by 184 people. Also, the number of housing units in Block Group 1 of Census Tract 33 actually declined by 13 units, while the population grew by 102 persons. This demonstrates the area is not growing rapidly because of expansive new development, but rather that the existing housing stock is accommodating a larger average household size. Criterion met? No. Three of five of the components of Part B of the definition of blight are affirmative. These include the median year built, the low per capita income, and the relatively high unemployment. Criterion Met? Yes. Substandard The following is the definition of the term "substandard," as adopted into Nebraska Community Development Law: An area in which there is a predominance of buildings or improvements, whether nonresidential or residential in character, which, by reason of dilapidation, deterioration, age or obsolescence, inadequate provision for ventilation, light, air, sanitation, or open 6 EXHIBIT I;January, 2022 spaces, high density of population and overcrowding, or the existence of conditions which endanger life or property by fire and other causes, or any combination of such factors, is conducive to ill health, transmission of disease, infant mortality,juvenile delinquency, and crime, (which cannot be remedied through construction of prisons), and is detrimental to the public health, safety, morals, or welfare. The criteria described in the definition of the term "substandard" is very similar to the criteria in the Part A definition of"blighted,"to a considerable degree. Both definitions put an emphasis on the age and condition of buildings and the public infrastructure. Thus the observations in the following paragraph are somewhat repetitious of the descriptions under the "Blighted, Part A" section of this study. The characteristics observed in the overall study area exhibit sufficient age, wear and tear such that the definition of"substandard" set forth in Nebraska Community Development Law is applicable. In general terms, both the commercial buildings and the residential buildings in the study area are much older than the 40 year threshold, and-the windshield survey reveals that deferred maintenance and deterioration are clearly present, at a level sufficient to discourage reinvestment and redevelopment, to some extent. The infrastructure is also very old, with much of it in fair to poor condition. In some instances, it is in very poor condition. The pavement widths are narrow, there are large, heavy electrical transmission lines that are very obtrusive, storm drainage systems are undersized or absent in many locations, and sidewalks are lacking along many public streets. As mentioned previously, other blighting influences that discourage- • redevelopment include proximity to an interstate highway and a railroad mainline corridor, two large local street viaducts, and some very challenging topography. Criterion met? Yes. Extremely Blighted Area (EBA) Analysis The Community Redevelopment Area (CRA) designation is the foundation for establishing the use of the Tax Increment-Financing (TIF) tool. The Extremely Blighted Area(EBA) designation builds upon the City's efforts to support redevelopment opportunities in more challenging areas; areas where specific redevelopment goals are emphasized. TIF is a mechanism to assist financing redevelopment whether it is located in a CRA or an EBA. Since a project located within a CRA already qualifies for TIF, the City of Omaha endeavors to continue enhancing redevelopment efforts through the designation of EBAs which may involve the use of TIF. Request for Study to Designate a New Extremely Blighted Area (EBA) The City of Omaha Planning Department received a request to examine the area previously describe in this study to determine its eligibility for designation as an EBA. A potential TIF project developer is considering a new multiple family affordable housing development north and west of Center and South 26th Streets. While the current study was being drafted,the Planning Department also became aware of another redevelopment project within the study area. Another developer has begun preliminary planning for a recreation and wellness campus located north of Deer Park Boulevard, between I-480 and the Union Pacific mainline rail corridor. They also expressed an interest in participating in the City's TIF program, and a desire for CRA and EBA designations. 7 EXHIBIT I;January, 2022 Within an EBA,the potential TIF project owner may be eligible for a 20 year TIF term rather than the 15 year term typically used in a CRA. Designation of the study area as an EBA will provides other new benefits that assist revitalization of the areas. EB designation allows qualified homebuyers purchasing homes as their primary place of residence to be eligible for a state income tax credit. The Nebraska Department of Revenue can provide details about this credit. The potential TIF project owner would also be eligible for special funding through a state affordable housing development program. Process, and EBA Eligibility Criteria At the beginning of 2021, staff received the most current ACS Census data for poverty and unemployment rates from David Drozd, Research Coordinator for the Center for Public Affairs Research(CPAR)at the University of Nebraska at Omaha to conduct this study. The data obtained was the U.S. Census Bureau's 2019 ACS Five (5)-Year Estimates. This data was used to evaluate • the potential for designating the study area as extremely blighted. The standard of measurement or threshold criteria for qualifying as an EBA is summarized as follows: • Average rate of poverty for the selected Census geographies of the study area must be greater than 20 percent. and • Average rate of unemployment for the selected Census geographies of the study area must be at least 200 percent of the average unemployment rate in the state-during the same time period. Nebraska's average unemployment rate at the Census Block Group level according to the 2019 ACS Five(5)-Year Estimates was 3.3 percent, while 200 percent of this rate was 6.68 percent. Findings The average rate of poverty for the study area was 21.8 percent, which exceeds the eligibility threshold. The average rate of unemployment for the study area was 8.31 percent, which exceeds the 6.68 percent threshold that represents 200 percent of the statewide 3.3 percent unemployment rate. Recommendation The Planning Department recommends approval of both the requested CRA and EBA designations for the study area shown on Map A. The Census demographic statistics exceed the threshold criteria of the Nebraska Community Development Law for CRA eligibility and the conditions of both the buildings and infrastructure in the study area are consistent with the state law definitions of "blighted" and "substandard" necessary for CRA designation. 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