Plan Commission Fails Math Quiz On Mill Creek Project

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Facade reflecting older design

Last Thursday, Mill Creek’s West Dallas Modera Trinity project presented to, and unanimously passed, Plan Commission (catch-up here, here). Did any of the commissioners do the math?

The base zoning approved was a building height of 95 feet (85 feet of building and 10 feet for mechanicals – sea of roof air conditioners, elevator housings, etc.) and 100 residential units. This equates to five stories of apartments and either a two- or three-story garage.

In other words, brick and stick construction on top of a concrete parking garage – a product Dallas residents have come to revile.

But, if affordable units were added, the project could grow to 350 units and 14 stories on a portion of the lot (creating a backwards “L” when viewed from Beckley). It’s an outcome Mill Creek has never rendered.

What Was Approved

To increase height to 160 feet: 10 percent affordable

  • Mixed-Income Housing Bonuses: 5 percent of units in income band 1 (81 percent to 100 percent AMFI – Average Median Family Income) and 5 percent of units in income band 2 (61 percent to 80 percent of the AMFI). Note: this is the same 10 percent found in the 350-unit option below and would match Staff Recommendations on income bands.

Increase dwelling units to 280: 14 affordable units

  • Mixed-Income Housing Bonuses: 5% of units in income band 1 (81 percent to 100 percent AMFI)
    • Staff Recommends: 5 percent of units in income band 3 (51 percent to 60 percent of the AMFI)

Increase dwelling units to 350: 35 affordable units

  • Mixed-Income Housing Bonuses: 5 percent of units in income band 2 (61 percent to 80 percent of the AMFI) AND
  • Mixed-Income Housing Bonuses: 5 percent of units in income band 1 (81 percent to 100 percent AMFI)
  • Staff Recommends: 5 percent of units in income band 3 (51 percent to 60 percent of the AMFI) and 5 percent of units in income band 2 (61 percent to 80 percent of the AMFI) to allow a maximum number of dwelling units to 350

Note: The staff recommendations were accepted by Plan Commission. These didn’t alter the percentage of affordable housing, city staff just lowered the income bands required (resulting in more-affordable housing).

Counting the Balcony Bumps (old design footprint)

The Math

At 100 units and five floors of residential, that’s 20 units per floor with an average unit size of 2,143 square feet (based on Mill Creek’s estimate of 42,864 rentable square feet per floor). No way that’s being built by Mill Creek – or anyone – in this location.

At 280 units and five residential floors, it’s 56 units per floor averaging 765 square feet – now we’re talking – a sea of one bedroom units. Even the six townhouses will only be 900 square feet (400 square feet per floor – after around 100 square feet get eaten by a staircase).

The cost for this – which is what is reflected in the only building they’ve rendered – is 14 affordable units.

Counting the balconies on the rendering says this is the plan.

Frankensteined 14-Stories (Since no one else would show it)

14 Stories And 350 Units? No Way.

In order to get to 350 units, a further 5 percent of affordable units must be added (totaling 10 percent). Because affordable is based on the whole project and not just the additional units, this equals 35 affordable units – 21 more than the 280-unit design.

Are we to believe that in order to use the additional 70 units the developer will sacrifice 21 of those units to affordable? No, the math doesn’t work.

To get to 350 units, you’d need the added eight stories of residential supplied by the 14-story tower. That would change the construction type from brick/stick to steel reinforced concrete – something I’ve been told increases construction costs by as much as 30 percent.

A 30 percent bump in overall construction costs and a loss of 21 units to affordable?  The math doesn’t work.

And Mill Creek has said repeatedly that the tower option would require subsidies – so the city would essentially be footing a considerable ticket to get those added 21 affordable units. The city could build 21 bigger, better affordable units on land they own and likely for less money than subsidies would ultimately cost.

So there’s a reason Mill Creek hasn’t rendered the 14-story option – they have no intention of building it. There’s a reason Mill Creek has offered to remove the 14-story option from their Planned Development District language – they have no intention of building it.

It seems that Plan Commission is the only one who hasn’t done the math or read the writing on the renderings.

But Let’s Say They Do

Let’s say that the city has a brain fart and grants the subsidies required to make 350 units and 14-stories financially feasible. It’s in the future. It’s assuming monies not in evidence.

Why is Plan Commission approving a scenario so unlikely the developer won’t even render it and that requires undefined subsidies city council would have to grant?  I’m not saying that were the stars to align I’d oppose the 14-story option. I am asking why Plan Commission would approve a plan that requires undefined and unapproved municipal financial intervention. (Oh, and I’d want to see the renderings before I approved it.)

I say, IF Mill Creek and the city come to the table with the financing, THEN the Plan Commission should re-evaluate adding the 14-story option to the PD documents. Otherwise, all that’s been done is enrich the land so that when the neighborhood gentrifies further and the Modera falls apart, the next developer has a ready-made option to rebuild without presenting that plan to the city first – and who knows what will be deemed appropriate when Modera’s three-inch trees have finally matured 20-plus years into the future?

When this project reaches city council, the “ghost zoning” for a 160-foot, 350-unit option should be stripped out of the PD documents – something that will apparently be unopposed by Mill Creek themselves.

Shown to Peer Review and Plan Commission but not public slide deck

Finally, Show It

During Plan Commission it was repeatedly mentioned that the six recommendations from Peer Review had been incorporated into the final plans – and yet Mill Creek also said the images being presented to Plan Commission were the same as those presented to Peer Review.

First of all, that’s slightly misleading. While Peer Review and Plan Commission saw the same slides, a highly abridged deck was posted by Peer Review for the public to see. Those slides only show an outdated/smaller footprint with seemingly fewer units and a larger amenity deck. So yes, both entities saw the same slides, but the public slides left out a lot – and almost none of the renderings shown to Plan Commission or Peer Review take the new footprint into account.

Next, I’m a visual guy. How exactly can Peer Review’s changes be properly incorporated if the renderings haven’t changed? Several of those recommendations were to the Trinity side of the building – screening parking for example. I think we would all benefit from seeing that.

Yes, I understand inserting appropriate wording into the PD says it, but it should also be seen. Words should be reflected in images that are part of the permanent file – hardly a unique deficiency of this project.

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Jon Anderson

Jon Anderson is's condo/HOA and developer columnist, but also covers second home trends on An award-winning columnist, Jon has earned silver and bronze awards for his columns from the National Association of Real Estate Editors in both 2016, 2017 and 2018. When he isn't in Hawaii, Jon enjoys life in the sky in Dallas.

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