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Report - 2022 Commercereports 2022 Csdhd Affordable Housing Cost Data Report And Let

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2022 Commercereports 2022 Csdhd Affordable Housing Cost Data Report And Let

Summary

A March 30, 2023 transmittal letter from the Washington State Department of Commerce to the Secretary of the Senate and the Chief Clerk of the House, followed by the Annual Affordable Housing Cost Data report to the Washington State Legislature dated December 2022. The letter cites Section 1029(4) of the 2019-21 capital budget and Section 1067(5) of the 2021-23 capital budget and is signed by the managing director of the Housing Finance Unit. The report, from the Washington State Housing Finance Commission and the Department of Commerce, covers projects reporting final cost data in state fiscal year 2022, cost containment, supply chain issues, inflation, interest rates and data definitions. It describes a $250 million Microsoft line of credit for bond recycling and closes with project tables, including Attachment B.

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“Report - 2022 Commercereports 2022 Csdhd Affordable Housing Cost Data Report And Let.” Original at app.leg.wa.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2022-commercereports-2022-csdhd-affordable-housing-cost-data-report-and-let/, SHA-256 9f1fff4bc79f0d9e16c9f1537e22b4779cdc6f34bf3691e2be6a26b6dc812f55.

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                                     STATE OF WASHINGTON
                           DEPARTMENT OF COMMERCE
         1011 Plum Street SE  PO Box 42525  Olympia, Washington 98504-2525  360-725-4000
                                       www.commerce.wa.gov

March 30, 2023


Ms. Sarah Bannister, Secretary of the Senate
312 Legislative Bldg.
PO Box 40482
Olympia, WA 98504-0482

Mr. Bernard Dean, Chief Clerk of the House of Representatives
338B Legislative Bldg.
PO Box 40600
Olympia, WA 98504-0600

RE:    2022 Housing Trust Fund Affordable Housing Cost Data Report (Due Dec. 1, 2022)

Dear Ms. Bannister and Mr. Dean:

The Department of Commerce (Commerce) submits this letter to satisfy the reporting
requirements in Section 1029(4) of the 2019-21 capital budget and restated in Section 1067(5) of
the 2021-23 capital budget:

   “(b) Beginning December 1, 2019, and continuing annually, the department must provide the
   legislature with a report of its final cost data for each project under this section. Such cost
   data must, at a minimum, include total development cost per unit for each project completed
   within the past year, descriptive statistics such as average and median per-unit costs,
   regional cost variation, and other costs that the department deems necessary to improve cost
   controls and enhance understanding of development costs. The department must coordinate
   with the housing finance commission to identify relevant development costs data and ensure
   that the measures are consistent across relevant agencies.”

Commerce and the Washington State Housing Finance Commission (Commission) administer
the two major programs that provide resources to develop and preserve affordable housing in
Washington: Commerce’s State Housing Trust Fund (HTF) and the Commission’s Low Income
Tax Credit (LIHTC) program. The two entities collaborate on policies and coordinate
investments in affordable housing across the state. Twenty-eight percent of the Commission’s
projects reporting this year are also funded by the HTF. Read more here [INSERT LINK TO
WSHFC REPORT].

The low number of reports makes it impractical to provide analysis or conclusions on cost
containment at this time. However, the high number of projects expected to be completed in the
coming years will yield more robust future reports under this proviso.
Page 2



Please contact me by phone at 360-725-2973 or email at nathan.lichti@commerce.wa.gov if you
have any questions regarding this report or need additional information.

Sincerely,




Nate Lichti
Managing Director
Housing Finance Unit
Housing Division

Copy: JLARC
                ANNUAL AFFORDABLE
                 HOUSING COST DATA
            Report to the Washington State Legislature
                                      December 2022




Submitted by the Washington State Housing Finance Commission
               and Washington State Department of Commerce
CONTENTS
INTRODUCTION ............................................................................................................................................. 1
   The Low-Income Housing Tax Credit Program.......................................................................................... 1
   Reporting Requirements ........................................................................................................................... 2
COST DATA AND COST CONTAINMENT ........................................................................................................ 2
   CPA Cost Certified Data............................................................................................................................. 2
   Cost Containment Policy ........................................................................................................................... 3
   Current Conditions: Supply Chain Issues, Inflation and Increased Interest Rates .................................... 3
   New Financing Tools to Stretch Federal Resources .................................................................................. 4
DATA DEFINITIONS & METHODOLOGY ......................................................................................................... 5
   Definitions ................................................................................................................................................. 5
   Methodology ............................................................................................................................................. 7
2022 REPORT ON LOW-INCOME HOUSING TAX CREDIT PROJECTS .............................................................. 8
   Source of Project Costs ............................................................................................................................. 9
   State Housing Trust Fund Involvement ..................................................................................................... 9
   Funding Sources in 2021-22 LIHTC Projects ............................................................................................ 10




INTRODUCTION
The Low-Income Housing Tax Credit Program

The Washington State Housing Finance Commission (Commission) administers the Low-Income Housing
Tax Credit (LIHTC) program which finances the construction and preservation of affordable multifamily
housing units through federal tax incentives. Housing credit in the 9% program is awarded through an
annual competitive process in which projects are evaluated and scored according to the Commission’s
established criteria. The 4% housing tax credit combines tax credit equity with tax-exempt bonds and
the tax-exempt bonds are allocated through a competitive process. These programs are governed by
the Internal Revenue Service (IRS) and annual state allocations are determined by a per capita formula.

The Department of Commerce (Commerce) administers the Housing Trust Fund, a state program that
makes grants and low-interest loans for low-income housing. Commerce and the Commission
collaborate on policies and partner on making investments in affordable housing across the state. In any
given year, 30-50% of our projects “overlap,” meaning that they receive both a Housing Trust Fund
award and a LIHTC allocation of federal housing tax credits.




                                                                                                                                                                1
Reporting Requirements

In 2017, the Legislature directed the Joint Legislative Audit and Review Committee (JLARC) to analyze
the costs of developing low-income housing (i.e., affordable to households making less than 80 percent
of the area median income). In their final report, published in January 2019, JLARC made
recommendations to Commerce and the Commission to improve cost efficiency, controls, and
monitoring, including the following recommendation:

        Commerce and the Commission should report development cost data to the Legislature
        annually. Data should include the total development cost per unit for each project, descriptive
        statistics (such as average and median per unit costs), regional cost variation, and other cost
        data that agencies deem necessary to improve cost controls and enhance the Legislature's
        understanding of development costs. Commerce and the Commission should coordinate to
        identify relevant development cost data and ensure that measures are consistent across the
        agencies. The costs should be published in a format that allows the Legislature and the agencies
        to track development costs over time.

In 2019, pursuant to the JLARC report, the Legislature included JLARC’s recommendation in the 2019-21
Capital Budget appropriation for the HTF (Section 1029), as follows:

        (b) Beginning December 1, 2019, and continuing annually, the department must provide the
        legislature with a report of its final cost data for each project under this section. Such cost data
        must, at a minimum, include total development cost per unit for each project completed within
        the past year, descriptive statistics such as average and median per unit costs, regional cost
        variation, and other costs that the department deems necessary to improve cost controls and
        enhance understanding of development costs. The department must coordinate with the housing
        finance commission to identify relevant development costs data and ensure that the measures
        are consistent across relevant agencies.

This report responds to the recommendation made by JLARC to provide relevant development cost data
and analysis for LIHTC affordable housing projects to the Legislature. The data in this report includes
projects that have submitted to the Commission their final development cost data during state fiscal
year 2022 (July 1, 2021, to June 30, 2022). The numbers provided are derived from the Certified Public
Accountant-prepared cost certifications and the analysis relies on benchmarks established in previous
reports including a series of assumptions and definitions that allow for consistent measures and data
characteristics across the two programs and state agencies.



COST DATA AND COST CONTAINMENT
CPA Cost Certified Data

Since the inception of the federal Low-Income Housing Tax Credit (LIHTC) program in 1987, the
Commission has collected and tracked cost data. Developers cannot obtain approval from the IRS for the
housing tax credits until their costs are certified. They must submit a CPA-generated report of the total


                                                                                                           2
sources and uses of the project’s funding to obtain Form 8609 from the IRS, which enables their
investors to claim the housing tax credits and thus provide equity for the project.

Cost Containment Policy

In addition to the cost-certification process, the Commission has a robust cost-containment strategy
which is essential to the future success and continued credibility of the Housing Tax Credit program. Given
the finite resource of the Housing Tax Credit, the primary objective of these cost-containment policies is
to balance cost containment with promoting quality development. As referenced in the JLARC report, the
Commission follows key national best practices for monitoring and controlling costs.

To this end, in 2012, the Commission developed and established total development cost (TDC) limits to
benchmark and analyze costs against metrics. These limits vary according to region to better measure
and acknowledge the different cost drivers throughout the state. The Commission reviews these limits
annually (and resets them if necessary) using third-party data from Engineering News-Record (ENR). The
TDC limits are documented in the Development Cost Limit Schedule as part of the LIHTC application
process.

As part of the competitive application process, points are awarded based on a percentage of the amount
under the TDC limit and based on the comparative cost of projects in the geographic pool. Projects are
subject to the Development Cost Limit Schedule in place at the time of application. As part of the
application, projects must provide a detailed breakdown of all anticipated project costs.

Based on our ongoing analysis and work with the Housing Development Consortium of Seattle/King
County Cost Analysis workgroup, we adjusted our cost limits for projects applying for resources in 2022
to reflect more granular nuances of costs found between Seattle and Balance of King County.
Numbers are now being presented to reflect that change below.

Commerce’s application recognizes the less costly projects with higher prioritization in funding but does
not apply a strict cost limit like the Commission. There are wide-ranging variations of project types,
including single family construction/renovation, congregate shelters, acquisition rehabs and new
construction in all types of communities. Therefore, Commerce finds the scoring to be a fairer method
of recognizing and containing costs.

Current Conditions: Supply Chain Issues, Inflation and Increased Interest Rates

As was stated in last year’s report, significant issues evolving out of the pandemic continue to have a
large impact on real estate and construction projects. Disruption in the supply chain of many materials
and products, inflation, and a volatile subcontractor market have increased project costs. For example,
the cement strike in the Puget sound region delayed many of the projects that were in construction
which then had a ripple effect on projects waiting to break ground. In addition, interest rates have been
increasing, affecting projects in development as well as projects just trying to close on their financing.
The Commission and the Department of Commerce worked collaboratively to ensure projects could still
move forward with full financing in place.




                                                                                                          3
New Financing Tools to Stretch Federal Resources

As described in the introduction to this report, a significant part of the Low-Income Housing Tax Credit
program (the “bond/credit” or “4%” program) relies on federal tax-exempt bonds that then combine
with federal tax-credit equity. These bonds are capped for each state based on population. Washington
is a nationwide leader in the use of this program to build and preserve affordable housing. In recent
years, dramatically increased demand in this program has far exceeded the annual bond cap available.
The Commission has responded with several innovative financing programs to stretch our limited bond
cap with the help of corporate and other private capital. These tools are most useful for “workforce
housing” projects, rather than housing that serves the lowest incomes and most vulnerable (such as for
the homeless). They include:

    •   Bond recycling partnership with Microsoft:
        In this national award-winning partnership, Microsoft provides the Commission with a $250
        million line of credit to facilitate the recycling of housing bonds. Through bond recycling, as
        short-term affordable housing bonds are paid off, a certain amount of the repaid principle can
        be reissued to finance new affordable housing projects. Microsoft’s line of credit not only lowers
        the cost of each transaction, making individual projects pencil for developers, it also gives the
        Commission a structure and mechanism for recycling bonds on a much larger scale than we
        were able to do before. In 2021-22, we issued $102.4 million in recycled bonds that helped bring
        9 projects with 1,297 units to fruition.

    •   Evergreen Impact Housing Fund:
        A collaboration between the nonprofit Seattle Foundation and the Commission, the Evergreen
        Fund brings in private capital from socially motivated investors – including large corporate
        donors – to supplement and extend the LIHTC bond program. Microsoft, and a coalition of
        credit unions have contributed to the EIHF, which fills the gaps currently unfilled by bonds and
        housing credits to make 4% LIHTC projects feasible again in high-growth urban areas of King
        County. Since implementation in 2020, the fund has invested $34.9 million, financing four LIHTC
        projects with a total of 745 units. Meanwhile, equity investors and philanthropists can
        contribute to the fund and earn a return.




                                                                                                           4
DATA DEFINITIONS & METHODOLOGY
The data included in this report is based on Total Residential Project Cost (TRPC), which
includes the total cost of the residential portion of a project, including land, capitalized reserves,
and offsite infrastructure improvements.

Total Residential Development Cost (TRDC) is the Total Residential Project Cost minus the cost
of land, reserves, and infrastructure. The Commission uses TRDC for purposes of analyzing
projects against limits and determining competitive points because TRDC better reflects the
costs over which the developer has control. Some developers, for example, may be building on
donated land, while others may have paid market price.

Definitions
The following table shows the key data and criteria that have been agreed upon by both the Commission
and Commerce for reporting cost data.

 Field                     Description

                                           General Project Data
 Sponsor                   Project Sponsor (the primary developing organization)
 Project Name              Project Name
 Program Type              4% or 9% Low-Income Housing Tax Credit program
 Project Address           Project Address
 Project City              Project City
 Project County            Project County
 Zip                       Project Zip
 New Construction OR       New Construction vs. Acquisition/Rehabilitation of an existing building
 Acquisition/Rehab
 Total Units               Includes all physical units in the property:
                             • Low-Income Housing Units (income- and rent-restricted units);
                             • Common Area Units (which include manager-occupied units and
                               sometimes community areas); and
                             • Market Rate Units (units renting at market rate without income or
                               rent restrictions).
 Total Residential         Includes all residential areas including common areas and parking; does
 Square Feet               not include commercial square footage

                                             Project Cost Data

 Total Residential         All costs including land, capitalized reserves, and infrastructure costs
 Project Cost              associated with the residential budget. All subtotals below are for
                           residential costs.



                                                                                                         5
Land/Acquisition        Cost for acquiring land, buildings and any closing costs
Subtotal
Construction Subtotal   Materials, labor, and associated costs of residential construction; any site
                        or infrastructure work; and contingency
Professional Fees       Engineering, architecture, appraisals, market studies, Geotech,
Subtotal                topography, environmental reports, legal fees, development consultant,
                        developer fees
Financing Costs         Loan fees, interest expenses and insurance
Subtotal
Capitalized Reserves    Operating and/or replacement reserves
Subtotal
Other Development       Real estate tax, insurance, relocation, bidding costs,
Costs Subtotal          permits/fees/hookups, impact mitigation fees, development period
                        utilities, nonprofit donation, accounting audit, marketing leasing expenses,
                        and any carrying costs at rent up reserve
                                       Sources of Financing
State Housing Trust     True = The project includes an investment from the Washington State
Fund?                   Housing Trust Fund; may also include State HOME funds, National Housing
                        Trust Funds.
State Housing Trust     Amount awarded from the Washington State Housing Trust Fund (through
Fund Amount             Dept of Commerce); may also include State HOME funds and National
                        Housing Trust Funds allocated through the Dept of Commerce.
Private Equity from     Private equity generated from federal Low-Income Housing Tax Credits
LIHTC
Other State Source      Capital appropriations
Federal Source          HUD Choice Neighborhoods, may also include other federal resources, if
Summary                 available direct from the Federal level
Local Source            Housing Authority capital funds, local HOME funds (HUD), local housing
Summary                 levies, other city or county investments
Private Source          Tax exempt private activity bond cap (issued by either Commission or
Summary                 Housing Authority), permanent loans, other federal tax credits,
                        subordinate loans, etc.
Sponsor Source          Deferred developer fee, sponsor loan, sponsor contribution, Net Operating
Summary                 Income (NOI) during lease-up, seller note
                                         “Cost Per” Data
Cost Per Unit           Total Residential Project Cost divided by Total Units
Cost Per Total          Total Residential Project Cost divided by Total Residential Square Feet
Residential Square
Footage




                                                                                                       6
Methodology

The analysis provided in this report is focused on describing or summarizing total residential
development cost data and uses common descriptive statistics such as measures of central tendency.
This method of analysis was chosen with the goal of providing a simple but meaningful presentation of
the data. It is important to note that this method of analysis deals with quantitative data only and
should not be used to generalize or make unsupported conclusions about the cost of affordable
multifamily housing projects not included in this data set.




                                                                                                        7
2022 REPORT ON LOW-INCOME HOUSING TAX CREDIT
PROJECTS
The charts and points below highlight data found in the list of projects placed in service from July
1, 2021, through June 30, 2022, provided as Attachment A.

Note: Median costs, instead of average costs, are used below to capture the central location of
the dataset’s distribution when outliers are present in the data.

Total Projects, Units and Median Costs – 2019-2022
                                                      Median units            Median cost           Median cost
        Fiscal Year            Total Projects
                                                      per project              per unit            per square foot
 July 2021 - June 2022                32                    99                  $316,097                 $392
 July 2020 - June 2021                33                   95                   $262,331                 $284
 July 2019 - June 2020                43                   108                  $259,105                 $280
 July 2018 - June 2019                51                   114                  $207,496                 $239



Costs by County and Construction Type – 2021-22
 New Construction:                                         Acquisition/Rehab:

                                      Median Cost                                                     Median Cost
                      Median Cost         Per                                     Median Cost             Per
      County                                                     County
                       Per Unit       Residential                                  Per Unit           Residential
                                      Square Foot                                                     Square Foot
  Clark                $262,696            $405             Benton                  $282,759               $296
  King                 $329,339            $383             Clark                   $295,508               $400
  Balance King*        $318,710            $335             King                    $317,128               $528
  Seattle*             $337,544            $537             Balance King*           $310,225               $441
  Kittitas             $255,084            $237             Seattle*                $324,030               $542
  Pierce               $351,338            $414             Walla Walla             $227,279               $214
  Snohomish            $307,990            $277
  Thurston             $224,962            $243
  Whatcom              $358,974            $367
  Yakima               $294,459            $441
 Med of All                                                Med Of All
                       $301,224            $375                                     $289,134               $348
 New Const:                                                Acq/Rehab:

*The City of Seattle-King County and the “balance” of King County are listed here separately in addition to King
County.

                                                                                                                   8
Source of Project Costs
Construction costs, including labor and materials, are the major cost drivers of these projects. Project
cost categories are defined above in the Data Definitions Table.



                                     Other Development
                  Financing Costs
                                            Costs
                        1%
       Capitalized                           8%
        Reserves
          2%
                              Professional
                                  Fees
                                  14%                  Construction
                                                           Costs
                                                        (including
                                                       material and
                              Land/Acquisition
                                                          labor)
                                    Costs
                                                           57%
                                    19%




State Housing Trust Fund Involvement
How many 2021-22 projects include funding from the Washington State Housing Trust Fund?




                                                             Includes
                                                           Housing Trust
                                                               Fund
                                                               28%

                                   No Housing
                                   Trust Fund
                                      72%




                                                                                                           9
Funding Sources in 2021-22 LIHTC Projects
Note: Private debt includes tax-exempt bonds issued by the Commission or by the local housing
authority. The State Funds category is solely made up of State Housing Trust Fund.



                                Federal                         Local Funds
                                $600,275                        $74,407,274
                                                                    6%



                               LIHTC Private
                                  Equity
                               $460,656,868
                                   37%                       Private Debt
                                                             $484,807,268
                                                                 39%



                                        Sponsor Funds
                      State Funds        $203,829,232
                      $21,550,339            16%
                          2%




Attachment A: Full List of 2021-22 LIHTC Projects in this Dataset


Attachment B: Additional Non-LIHTC Projects Funded only by the Housing Trust Fund (Not
Included in Charts Above)


                                                                                                10
ATTACHMENT A: Full List of 2021-22 LIHTC Projects
                                                                                                                                                                   Cost per Total
                                                 Housing Trust                                      New Construction OR
                  Project Name                                          City             County                           Total Units           Cost per Unit    Project Residential        Population Served
                                                    Fund?                                            Acquisition/Rehab
                                                                                                                                                                    Square Foot
1800 Hillside Terrace                          Yes               Tacoma             Pierce        New Construction                       64 $          342,072   $              428 Disabled/Homeless
Arlington Drive Youth Campus                   Yes               Tacoma             Pierce        New Construction                       58 $          376,623   $              497 Homeless
Belmont 1                                      No                Seattle            King          New Construction                       90 $          353,788   $            1,236 Disabled
Bonanza                                        Yes               Seattle            King          Acquisition/Rehab                      87 $          497,350   $              700 General
Chuck Austin Place                             Yes               Yakima             Yakima        New Construction                       41 $          294,459   $              441 Homeless
Columbia Park                                  No                Richland           Benton        Acquisition/Rehab                     139 $          282,759   $              296 Large Household
Coronado Springs Cottages                      No                Seattle            King          Acquisition/Rehab                     148 $          298,247   $              538 General
DESC 22nd Avenue PSH                           Yes               Seattle            King          New Construction                       85 $          325,422   $              537 Homeless
Encore Apartments                              No                Seattle            King          New Construction                       60 $          383,974   $              782 Disabled
Kent Permanent Supportive Housing              Yes               Kent               King          New Construction                       80 $          308,082   $              511 Homeless
La Madera Apartments                           No                Federal Way        King          Acquisition/Rehab                      76 $          190,716   $              270 Disabled/Large Household
Opportunity Place Apartments                   No                Seattle            King          Acquisition/Rehab                     145 $          324,030   $              542 Disabled
Othello Park Apartments                        No                Seattle            King          New Construction                      106 $          337,544   $              383 Disabled/Large Household
Panorama Apartments                            No                Snoqualmie         King          New Construction                      191 $          329,339   $              238 Disabled/Large Household
Renton Crest                                   No                Renton             King          Acquisition/Rehab                     274 $          310,225   $              441 Elderly/Large Household
Reserve at Lacey                               No                Lacey              Thurston      New Construction                      241 $          224,962   $              243 Elderly
Riverview Apartments                           No                Everett            Snohomish     New Construction                      203 $          352,687   $              292 Disabled/Large Household
Samish Way Redevelopment                       Yes               Bellingham         Whatcom       New Construction                       69 $          358,974   $              367 Disabled/Homeless
Sea Mar Vancouver Family Housing               No                Vancouver          Clark         New Construction                       70 $          304,653   $              286 Large Household
South Wilbur Manor Apartments                  No                Walla Walla        Walla Walla   Acquisition/Rehab                      38 $          227,279   $              214 Large Household
Spurling Court Apartments                      Yes               Ellensburg         Kittitas      New Construction                       49 $          255,084   $              237 Homeless
Station House                                  No                Seattle            King          New Construction                      110 $          321,968   $              374 General
The Confluence                                 No                Tukwila            King          New Construction                      103 $          383,883   $              359 Large Household
The Elwood                                     No                Vancouver          Clark         New Construction                       46 $          220,740   $              524 Homeless
The View by Vintage                            No                Bonney Lake        Pierce        New Construction                      408 $          210,783   $              235 Large Household
Traditions at Federal Way                      No                Federal Way        King          New Construction                      200 $          246,285   $              312 Disabled/Elderly
Van Vista Assisted Living                      No                Vancouver          Clark         Acquisition/Rehab                      95 $          295,508   $              400 Elderly
Villas at Arlington                            No                Arlington          Snohomish     New Construction                      312 $          263,293   $              263 Large Household
Vintage at Seatac Apartments                   No                Seatac             King          New Construction                      170 $          268,640   $              437 Disabled
Watermark                                      No                Auburn             King          New Construction                      221 $          380,593   $              288 Disabled/Large Household
Woodland North                                 No                Lake Forest Park   King          Acquisition/Rehab                     105 $          412,688   $              517 General
YWCA Pierce County Affordable Family Housing   Yes               Tacoma             Pierce        New Construction                       55 $          360,605   $              401 Homeless
ATTACHMENT B: Additional Non-LIHTC Projects Funded By Housing Trust Fund (No LIHTC – Not
Included in Charts Above)

                                                                                  New Construction OR                   Total                           Cost per Total Project
         Project Name             Site Name              City         County                            Total Units                Cost per Unit                               Population Served
                                                                                   Acquisition/Rehab                  Bedrooms                         Residential Square Foot

FFC Homes XII A/R        Kitsap County/Bremerton   Bremerton      Kitsap       Acquisition/Rehab                 3           3 $             193,000   $                 341 Dev Disabled
FFC Homes XII A/R        Pierce County/Puyallup    Tacoma         Pierce       Acquisition/Rehab                 3           3 $             244,333   $                 431 Dev Disabled
FFC Homes XII A/R        Longview                  Longview       Cowlitz      Acquisition/Rehab                 3           3 $             193,667   $                 342 Dev Disabled
Hearthstone Apartments   Hearthstone Apartments    Medical Lake   Spokane      Acquisition only                 48 n/a         $              32,205   $                  36 General


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