Transmittal - 3/29/2022ERIN MENDENHALL DEPARTMENT of COMMUNITY
Mayor and NEIGHBORHOODS
Blake Thomas
Director
SALT LAKE CITY CORPORATION
451 SOUTH STATE STREET, ROOM 404 WWW.SLC.GOV
P.O. BOX 145486, SALT LAKE CITY, UTAH 84114-5486 TEL 801.535.6230 FAX 801.535.6005
CITY COUNCIL TRANSMITTAL
________________________ Date Received: _________________
Lisa Shaffer, Chief Administrative Officer Date sent to Council: _________________
______________________________________________________________________________
TO: Salt Lake City Council DATE: March 28, 2022
Dan Dugan, Chair
FROM: Blake Thomas, Director, Department of Community & Neighborhoods
__________________________
SUBJECT: Update on the status of the Thriving in Place plan and the Housing Loss
Mitigation (18.97) ordinance.
STAFF CONTACT: Blake Thomas, Director, Community and Neighborhoods, 385-270 -4638 ,
blake.thomas@slcgov.com
Angela Price, Policy Director, Community and Neighborhoods, 385-315 -9024 ,
angela.price@slcgov.com
Susan Lundmark, Project Manager, Transportation Division, 801-535 -6112,
susan.lundmark@slcgov.com
DOCUMENT TYPE: Information item
RECOMMENDATION: No action needed
BUDGET IMPACT: None
BACKGROUND/DISCUSSION: In December 2020, the Department of Community and
Neighborhoods (CAN) presented The Future of Housing: A Collective Vision for an Equitable
Salt Lake City to the City Council. The intent of that presentation was to discuss various housing
policy topics identified as goals in Growing SLC: A Five Year Housing Plan. These included the
vision for an equitable and holistic city, data analysis, a summary of comprehensive solutions
and policies including the Gentrification Mitigation Plan and the Housing Loss Mitigation
Lisa Shaffer (Mar 29, 2022 18:19 MDT)03/29/2022
03/29/2022
(HLM) ordinance, among other equitable housing concepts, and identification of next steps for
moving forward various housing policies.
Since the policy briefing in 2020, the Administration has selected Baird and Driskell to oversee
the Gentrification Assessment and Displacement Mitigation Plan or Thriving in Place (TIP). In
addition to a robust, community-driven planning process, data analysis and mapping, and policy
recommendations to mitigate displacement, the Baird Team will also guide policy changes to the
City’s Mitigation of Residential Housing Loss ordinance (18.97).
This summary will provide the City Council with an update on:
• An overview of Thriving in Place including information on the engagement activities that
are currently underway and next steps;
• 2022 legislative requirements that are applicable to housing loss mitigation; and
• A detailed analysis of the Mitigation of Residential Housing Loss ordinance (18.97),
including the history of the ordinance, a summary of the current ordinance, adopted
ordinance constraints, technical discrepancies, policy considerations, next steps, a legal
analysis of common questions, and an HLM project summary.
The TIP Plan and HLM ordinance both address the goal of “increasing housing opportunities for
cost burdened households” in Growing SLC: A Five Year Housing Plan and meet several
objectives outlined in the plan.
The Administration welcomes the opportunity to work with the City Council to present the data
and engagement efforts that are happening in the TIP Plan and seek guidance on policy
directives to mitigate involuntary displacement and create a more equitable Salt Lake City.
The TIP Plan will inform the update to Growing SLC, which will be underway shortly. Both
plans will be brought before the City Council throughout the process and will be presented for
adoption when completed.
Thriving In Place
In June 2020, the City Council allocated FY21 funding for a Gentrification Assessment and
Displacement Mitigation Plan to understand the breadth and depth of involuntary displacement
and formulate policies and programs to mitigate any such displacement that might occur. After a
Request for Proposals (RFP) process was initiated and completed, a consultant team was retained
in September 2021, which consists of the following researchers and thought leaders in the fields
of gentrification and displacement:
• Baird & Driskell Community Planning (led by David Driskell);
• Urban Displacement Project, University of California Berkeley (UDP; led by Dr. Tim
Thomas); and
• University of Utah Department of City and Metropolitan Planning (CMP; led by Dr. Ivis
Garcia and Dr. Alessandro Rigolon).
Together with the consultant team, City staff (together, the Team) are guiding the Plan, now
called Thriving in Place, using the following overarching actions:
• To understand gentrification pressures in Salt Lake City;
• To document patterns of involuntary displacement, including those related to housing
costs, eviction, and demolition; and
• To find policy solutions to help people choose to stay, live, and thrive in Salt Lake City
even as the city grows and changes.
This briefing will provide an overview of TIP and what the Team has learned from early
community engagement. It is the intent of the Administration and the Consultant team to come
back to the City Council in a future meeting with an in-depth analysis of the Listening and
Learning phase and to seek guidance before the Crafting Collaborative Solutions phase.
• Phase 1: Listening and Learning – Focuses on defining and understanding the problem
and includes extensive community engagement and data collection.
o Quantitative data collection and analysis is led by UDP.
o Qualitative data collection through numerous community engagement activities.
o Information gathered in this phase provides context on experiences of
displacement, community asset mapping, and neighborhood challenges to ensure
policies are aligned to mitigate displacement pressures specific to Salt Lake City
neighborhood needs.
• Phase 2: Crafting Collaborative Solutions – Develops a Displacement Mitigation Plan
that includes actionable policy recommendations.
o Recommendations will include a shared framework that can guide action across
sectors, including the City, other governmental agencies, and community-based
organizations and partners.
o Recommendations will be informed by Phase 1 engagement and a review of
existing policies, programs, and practices. A second round of input from
community and stakeholders will inform priorities for action and
recommendations for policy changes.
Phase One - Community Engagement
From the outset, there has been an effort to have a community-led process that includes extensive
and equitable community engagement. The Team is listening to residents and partners through a
variety of engagement methods, including online and in-person. The Team reviews engagement
efforts and statistics weekly to ensure equitable representation and recalibrates outreach tactics if
needed. TIP is currently in the Listening and Learning phase. Details of engagement efforts are
outlined below:
• City Steering Committee – This committee consists of City staff and includes
representatives f rom various departments to ensure collaboration and impactful policy
development.
• Community Working Group – This 22 -member advisory group was formed to guide
the community engagement process and ensure inclusion, provide input and feedback on
the process design, outreach materials, and draft strategies as they emerge, and serve as
liaisons to groups and organizations in which they are involved. The group has met twice
so far, with notes from the meetings posted here.
• Project Launch Interviews – These confidential one-on-one interviews with 15 key
community representatives helped shape the Team’s engagement strategy and refinement
of the Plan’s goals. Interviews were completed in late Fall 2021 and are summarized
here .
• Public Website and Online Survey – The Thriving in Place website, available in
English and Spanish, was launched in February 2022 to provide educational information
for residents and to serve as an online engagement tool. To date , the website has seen
3,100 visits from 2,600 unique visitors, 46% of which have been via mobile device. An
online survey (English and Spanish) was launched in conjunction with the project website
and to-date has been completed by over 1,000 individuals.
• Intercept (in-person) Surveys – Two CMP classes are conducting in-person “intercept”
surveys at various locations throughout the city , with an emphasis on Westside
neighborhoods. The demographics of these survey respondents tend to be younger, more
diverse, and more likely to be renters than the population that has responded to the online
survey. To date, over 300 interview surveys have been completed. We anticipate over
700 in-person intercept surveys will be conducted.
• Community Liaisons – The project team has hired six community liaisons with
experience and connections in communities of color, non-English speakers, and lower
income neighborhoods to help ensure equitable engagement and input. The liaisons are
conducting in -person engagement with small groups in culturally appropriate formats,
touching on the same themes and questions as the survey but in a more formal way.
While the methodology will not engage as many residents, the value of the input will be
significant.
• Youth Workshops – The CMP classes have hosted numerous engagement activities for
youth to discuss change in their neighborhoods and their perspectives and ideas related to
gentrification and displacement.
• Community Events - The project team has been participating in a variety of community
events (e.g., Neighborhood House Family Fun, tabling with Ventanilla de Salud, and
Sunday Mass at Our Lady of Guadalupe Church, among others). They will also be
hosting a mural-painting event at Three Creeks Confluence Park on April 16th.
• Other engagement efforts by the Team to help ensure people are aware of the project
and opportunities for engagement include:
o CMP students discussing TIP at Westside Community Council meetings in
February and March 2022;
o Introducing and discussing TIP at board meeting for University Neighborhood
Partners in March 2022;
o Presenting at Salt Lake City Human Rights Commission (HRC) and Salt Lake
Community Network (SLCN) meetings;
o CMP students distributing hundreds of flyers, door hangers, and sidewalk stencils;
and
o Sending out City Council citywide mailer for housing related efforts to all
residential addresses in Salt Lake City during the first week of April 2022.
Phase Two - Mapping and Data Analysis
Data gathered from the project’s community engagement efforts will be complemented with in-
depth analysis of the city’s neighborhoods through a mapping and analysis led by UDP. UDP is
developing a map using advanced statistical analysis to identify where the highest rates and risk
of displacement are currently occurring in Salt Lake City by analyzing hundreds of variables.
These variables include housing markets, property types, population demographics, changes over
time, administrative data, and many other variables (see UDP’s Housing Precarity Risk Model as
an example of this type of modeling). UDP then maps the model’s output values to identify areas
that need the most support and protection. The final map will show four distinct characteristics:
areas with low displacement risk, elevated risk, high risk, and extreme risk.
Timeline and Next Steps
The project is in the final stages of Phase One, Listening and Learning. In May 2022, the Team
will summarize the community input received and connect it with the results of UDP’s mapping
and data analysis. Phase Two , Crafting Collaborative Solutions, includes the Team working with
the Community Working Group and members of the City Steering Committee to share results
and identify key take-aways, as well as identify areas for policy recommendations. Phase Two ,
Craftin g Collaborative Solutions, will run from May through August 2022. A few key dates are
outlined below:
• April 16 - Mural painting at Three Creeks Confluence Park.
• April 18 - Conclusion of Phase One engagement activities.
• April 26 - Student presentations (from the two CMP classes) on outreach efforts at
Glendale Community Learning Center.
• May - Summary of Phase One findings and UDP’s displacement analysis presented to the
Team.
• May/June - Presentation to Planning Commission on TIP.
• May/June - Small group work sessions to distill Phase One findings and agree on
direction for Phase Two (we expect to return to City Council in mid to late June to share
results).
• June/July - Phase Two begins with preliminary policy options and near-term
recommendations.
• July/August - Evaluation of policy options and refinement of recommendations.
• July/August - Presentation to Planning Commission on TIP.
• August/September - Planning Commission and City Council process for TIP.
Housing Loss Mitigation
History
In 1994, the City Council commissioned an independent economic evaluation to analyze the
impact and loss of affordable housing and potential mitigation measures. The impetus of the
study was a substantial shortage of affordable housing in the Central City, University, and
Capitol Hill neighborhoods. The driving forces behind the shortage were the demolition of
housing stock for commercial and institutional purposes or assemblage of land by speculators.
Since inception, the policy has been centered around a land-use transition from residential to
commercial or a petition to expand parking. A Housing Mitigation Plan and Statement is
required before final approval of a parking conditional-use is granted or a zoning change is
approved that would allow commercial use on properties that currently have residential dwelling
units (1995 ordinance does not contemplate land use changes but rather demolition of units). The
initial plan required an analysis of adverse impacts, dwelling units that will be demolished, fair
market value for demolished units, square feet of land to be rezoned, and a mitigation plan that
addresses the loss of residential zoned land, residential units, or residential character. To mitigate
the identified loss, developers can replace the housing within two years of the entitlement
application approval, pay a fee that is the difference between the fair market value and the
replacement cost, or pay a flat fee of $3,000 per dwelling unit to be demolished.
Adopted Ordinance
The c urrent ordinance, Chapter 18.97 Mitigation of Residential Housing Loss, was adopted in
2012, and states: “The purpose of the chapter is to mitigate the loss of affordable housing stock
due to new development with due consideration for vested or protected property rights.” The
ordinance requires a Housing Mitigation Plan for:
• Any application for a demolition permit that will result in a loss of one or more
residential units in a residential zone;
• A request for a conditional use permit to expand parking in a residential or mixed -use
zone; and
• Any petition for a zoning change that would permit a non-residential use of land that
includes residential dwelling units within its boundaries.
A Housing Mitigation Plan and Housing Impact Statement shall be submitted unless the
applicant meets certain provisions such as a non-conforming use, a master plan calling for non-
residential use, or proposed demolition because of health and safety issues. The Housing Impact
Statement must identify adverse impacts on the residential character of the neighborhood, the
address of units targeted for demolition, fair market value and state of repair of units targeted for
demolition, square footage of land that will be impacted, and a mitigation plan to address the loss
of residential zoned land, units, or residential character. Permitted mitigation measures include
replacing the lost housing units or paying a fee to the Housing Trust Fund that equals the
difference between the fair market value of the housing units to be eliminated or demolished and
the replacement cost of building new units of similar square footage.
Adopted Ordinance Constraints
• Affordability - The adopted ordinance does not include an assessment of the loss of
affordable housing in the Housing Impact Statement nor does it require replacement of
affordable units.
• Purpose - The purpose statement of the Chapter is to mitigate the loss of affordable
housing, but the policy does not analyze or mitigate demolition of affordable units.
• Trigger - The ordinance is triggered by a demolition permit, a parking conditional use
permit, or a zoning amendment from residential to commercial. The trigger does not
address the loss of affordable housing. The Housing Impact Statement is required during
the e ntitlement process which is challenging because a parcel may be rezoned and not see
development or the fee for many years.
• Formula - The formula takes the current fair market value of the building (excluding
land value) from the Salt Lake County Assessor and subtracts the International Code
Council (ICC) square foot replacement costs of the building. The structure of this formula
typically yields a negative number and, therefore, the City is not receiving funding to
mitigate the loss of residential units.
• Process – Currently, an application is submitted to Building Services, then passed to the
Planning Division, which creates the report, and is then reviewed and approved by the
Director of Community and Neighborhoods. There is no clear ownership over the process
as it touches multiple divisions at different stages in the project timeline.
2022 Legislative Requirements
There are two new statutory requirements that are applicable to the establishment of a Housing
Loss Mitigation f und and the City’s ability to require moderate-income housing units in a land
use decision. Those bills are:
• HB 462 Utah Housing Affordability Amendments - authorizes the City to establish a
Housing Loss Mitigation fund to preserve existing, subsidized, and new moderate-income
housing (lines 708-710).
• HB 303 Local Land Use Amendments - states that a city may only require moderate
income housing units as a condition of approval of a land use application if:
o The developer and the city enter into a written agreement (does not specify
development agreement); or
o The city provides incentives that are agreed to by the developer (lines 828-838).
Additionally, HB 303 prohibits a city from approving or denying a land use application based on
a developer’s decision to incorporate moderate-income housing units in their development.
HB 462 and HB 303 define moderate income housing as 80% AMI or below. These two policies
are compatible with the adopted Housing Loss Mitigation ordinance as well as the proposed
Affordable Housing Zoning Incentives, RMF-30, Shared Housing, Parking Reduction, and
Accessory Dwelling Unit ordinances.
Technical Discrepancies
• Section 18.64.050 Residential Demolition Provisions does not align with 18.97
Mitigation of Residential Housing Loss. The City Attorney’s Office has done a legal
analysis and drafted amendments to clean up technical discrepancies between 18.64.050
and 18.97.
• The purpose statement to mitigate the loss of affordable housing in 18.97 does not align
with the policy or the mitigation plan as there is no data collected on affordability of units
nor is there a requirement to replace the demolished housing with affordable units.
• Housing Loss Mitigation touches multiple chapters in the code rather than being
contained within a demolition or development section. HLM could be contained within a
development code, but this would require substantial amendments to various chapters
within the Municipal Code.
• If a payment is collected, ordinance 18.97 directs that payment to the Housing Trust
Fund. The Housing Trust Fund is being moved from Community and Neighborhoods to
the Redevelopment Agency (RDA) and is being changed to the Housing Development
Loan Program.
• 18.97.040 requires a report to the Housing Advisory and Appeals Board (HAAB) but
does not give the HAAB authorizing power to deny the report, mitigation plan, or
petition.
• The current formula does not yield a positive number and needs to be amended to
mitigate the loss of residential units. A fee justification study and an amendment to the
consolidated fee schedule to include the HLM will be required.
Policy Considerations
• Is the policy objective to mitigate the loss of all housing or just affordable housing? If the
objective is targeted at affordable housing, the ordinance will need to be amended so the
policy is reflective of that objective.
• Does the fee constitute an impact, linkage, or flat fee? A fee justification study will need
to be conducted to amend the mitigation formula to yield a positive number.
• When should the plan be required and the fee collected? Is it beneficial to have the plan
during the entitlement process for upzoning legislative decisions? HLM is a demolition -
focused ordinance, should this be the policy objective?
• What are the policy objectives of the fee? Should the fee be paid to the Housing
Development Loan Program, held in the RDA, or another funding source that can be used
for the mitigation of displacement?
• Should the amended ordinance require affordable units for an upzone?
• What constitutes naturally occurring affordable housing? Currently the City does not
track affordable housing units unless the units have been subsidized by city, county, state,
or federal funds. Is it the intention of the City Council to start tracking affordable units
through the entitlement process or business license rental application?
• The current ordinance is focused on the loss of housing and does not contemplate the loss
of local businesses for the development of housing. Is this a policy objective that should
be considered in the amendment to the ordinance?
Next Steps
The Administration understands the frustration of the public to amend the Housing Loss
Mitigation ordinance to preserve and develop affordable housing. The following actions are
recommended:
• The City Council, working in conjunction with the Administration, can assist in the
development of the policy objectives of the new HLM ordinance.
• The City Attorney’s Office has conducted a thorough review of the code and has drafted
proposed amendments to clean up the technical issues. This does not address the policy
considerations outlined above; rather, it cleans up technical inconsistencies. If preferred
by the Council, the technical changes to HLM could be transmitted while the TIP study is
being completed. The Administration recommends waiting to make any policy changes
due to the robust engagement process happening within the TIP Plan.
• The Zions Public Finance study that was conducted in Summer 2021 did not produce a
specific enough outcome for the City to rely on. The Administration is going to go to bid
in Spring 2022 for a consultant to conduct a fee justification study. This study will be
running concurrently with TIP.
• The TIP study that is currently underway is analyzing displacement metrics and will
develop mitigation measures in addition to policy changes to the current HLM ordinance.
These policies will need to be adopted by the City Council after they go through the
engagement process.
• Once the policy considerations are determined, the City Attorney’s Office will draft
amendments to the relevant ordinances.
Housing Loss Mitigation Legal Analysis of Common Questions
• Can the City institute a rent control policy?
o Utah Code Section 57-20-1 prohibits the City from enacting an ordinance or
resolution that would control rents or fees on private residential property unless it
has the express approval of the Legislature. Lease agreements are a contractual
matter between private parties and the City does not have jurisdiction to halt an
eviction.
• Should the City issue a moratorium on development?
o A temporary land use regulation, or “moratorium”, can be imposed by the City
Council to prohibit a development activity if the Council finds a compelling,
countervailing public interest to do so. This is a policy decision that the Council
would have to make. However, the temporary regulation cannot exceed six
months. The purpose of a temporary land use regulation is to halt (or, in some
cases, allow) a development activity immediately for a temporary period while
more permanent regulations are developed, presented to the public and the
planning commission, and transmitted to the Council for action. Prohibiting
development activity while waiting for a study to be produced could possibly be
justified by the Council, but it seems unlikely that land use regulations could be
ready for adoption within the six -month moratorium period, especially when the
findings of the TIP study are not yet known.
• Why is the City not requiring the development of affordable units in all new housing
projects?
o Utah Code Section 10-9a-535 as outlined in HB 303 states that a city may not
require moderate income housing units in the approval of a project unless the
developer agrees to the incentives. This provision does permit cities to adopt
incentive-based policies for the inclusion of moderate-income housing in a new
development, though this cannot be a requirement.
• Does the current h ousing loss mitigation ordinance protect affordable housing?
o The current housing loss mitigation ordinance (18.97.010) states that the “purpose
of this chapter is to mitigate the loss of affordable housing stock due to new
development with due consideration for vested or protected property rights.” The
conditions upon which an applicant would need to comply with the HLM
ordinance outlined in 18.97.020 and develop a mitigation plan are when a
residential unit (does not state affordable unit) is demolished to expand vehicle
parking in a residential zone or when a land use transitions from residential. This
ordinance does not prohibit the demolition of affordable housing units but simply
protects against the loss of a residential unit. Additionally, it does not prohibit a
developer from increasing the number of units on a parcel, nor does it consider
the affordability of the existing or new units. These are policy considerations for
the amendments to the new ordinance.
Housing Loss Mitigation Best Practices
There are few analogous ordinances in other municipalities. Most ordinances and fees in other
cities are Housing Mitigation Fees, meaning that they are applied to new developments that do
not include a minimum percentage of affordable units. The most similar policy to Salt Lake
City’s housing loss mitigation ordinance (18.97) is a demolition permit surcharge, which is a
current pilot project in Chicago, Illinois. This surcharge, along with other fees from around the
country, are outlined below.
Chicago, IL
Demolition Permit Surcharge
• A temporary surcharge (March 29, 2021 - April 1, 2022) in a pilot area.
o Applied in addition to other demolition fees, surcharges, and taxes imposed by
City, State, or other political subdivisions.
o Ordinance requires a written report no later than 150 days prior to expiration
identifying:
The amount of revenue generated through the surcharge;
Its observed effect on development activity in the applicable pilot area;
and
Any other information that the committee reviewing the surcharge’s
impact may require.
• A flat fee of $15,000 for the demolition of detached houses, townhouses, or two-flats.
• A flat fee of $5,000 per dwelling unit for the demolition of multi-unit residential
buildings.
• Exemptions:
o If replacement development designates 50% of units as affordable at 60% AMI or
lower; or
o Demolition is determined to be necessary to remedy conditions imminently
dangerous to life, health, or property.
• Funds from this surcharge are deposited into an Affordable Housing Opportunity Fund.
Somerville, MA
Project Mitigation Contribution or Linkage Fee Program for Affordable Housing
• Requires that linkage fees be collected on any project that:
o Requires zoning relief; and
o Contains a single-use or combination of uses exceeding a square-foot threshold
(30,000 sq ft) set by the Board of Alderman (City Council).
• Project mitigation contributions are made to the Somerville Affordable Housing Trust
Fund for the purpose of the creation of affordable rental and homeownership units.
• The rate per square foot was $10.75 for FY 2021-2022.
• The Project Mitigation Contribution is adjusted on March 1 of each year based on the
change in the Consumer Price Index for All Urban Consumers over the previous calendar
year.
Berkeley, CA
Affordable Housing Mitigation Fee
• Similar to an inclusionary zoning policy.
• The Affordable Housing Mitigation Fee per unit of market-rate rental housing is $39,746.
o The fee is offset if affordable units are included in the project and is waived if at
least 20% of units in a project are affordable.
50% of affordable units must be affordable at 30% AMI with the
remaining affordable units affordable at 50% AMI.
Avon, CO
Employee Housing Mitigation Linkage Fee
• The purpose is to create housing for workers generated by new development.
• Applies to new multi-family residential (3+ units), commercial, accommodation units,
industrial, and other non-residential development within the Town.
• A formula is used to calculate the fee. The fee is based on the number of workers
required per square foot of new space.
Aspen, CO
Affordable Housing Impact Fee
• A 2012 study suggested calculating the fee for their program by taking the difference
between the market price of housing and the price that is affordable to households at
targeted income.
Seattle, WA
Affordable Housing Incentive Program (Chapter 23.58C)
• Ordinance applies to development in Seattle that requests extra floor area and includes
dwelling units in the following cases:
o new construction;
o addition to existing structure that increases number of units;
o alterations within an existing structure that increases total number of units; and
o change of use that increases the total number of units.
• In return for extra floor area, ordinance provides a performance option (directly
supplying affordable housing units as allowed by code) or a payment option.
Performance option must satisfy median income requirements listed in the ordinance.
• Payment option includes a fee per square foot (SF) of new construction (units). Fee
amount varies by zoning code of the construction. Fee amounts are listed in tables in the
ordinance and range from $5.50/SF to $20.75/SF in the downtown zones and from
$7.00/SF to $32.75/SF in certain zones outside of downtown.
• Payments are deposited into an account managed by the Seattle Director of Housing to
support the development of affordable housing.
PUBLIC PROCESS: Briefing
EXHIBITS: Exhibit 1 – Zions Public Finance Study
One South Main Street, 18th Floor, Salt Lake City UT 84133-1904 Telephone: 801.844.7373 Fax: 801.844.4484
23 September 2021
Angela Price
Policy and Project Manager
Department of Community and Neighborhoods
Salt Lake City Corporation
Re: Housing Loss Mitigation Analysis
Zions Public Finance (ZPFI) examined a sample of 207 properties in and around Salt Lake City and compared
the market value determined by the Salt Lake County Assessor to asking prices as currently listed on various
real estate services. Results indicate that list prices on for-sale properties are significantly higher than
assessed values on the Assessor’s tax rolls.
The computed difference seems higher than most would expect. Traditionally, assessors tend to value
homes at somewhere between 90 and 110 percent of market value and prefer the lower end of this
range. In the graph below, that would be in the first column representing only a small percentage of
homes, where the listed value is 11 percent higher than market value. However, market values overall are
currently a lot higher than expected.
0
5
10
15
20
25
30
35
40
Number of HomesAmount Above Assessed Market Value
Homes Above Assessed Market Value
2
Zions Public Finance, Inc. | September 2021
Housing Loss Mitigation Analysis | Salt Lake City, Utah
Recent migration to Salt Lake County, among other factors, has contr ibuted to a substantial housing
shortage, prompting many owners to try to sell for significantly more than prices seen a few years ago.
Due to the lack of housing inventory, buyers were more willing to buy at high prices.
Additionally, many of the listed homes that ZPFI studied had been on the market for some time. This is
evidence that the sellers priced their homes much higher than what the actual market value would be.
The assessor’s database is based off the 2020 tax year, where officials likely calculated market value
during the year 2019. In 2020, realtors at slrealtors.com report that home prices increased by 11.8
percent. In 2021, Deseret News reported an increase of 17 percent. Together, this represents a potential
increase of 30.8 percent since the 2020 tax roll was calculated. As a comparison, if the tax rolls were
thirty percent higher, many of the houses sampled fall in the range expected.
ZPFI has calculated that the average house on the market is listed $268,701 higher than its assessed value.
This translates to a 70.8 percent markup on assessed values. The increase in selling price varies by house
price – for homes listed at less than $250,000, listings are at a 58 percent premium. For houses above $1
million, the premium increases to 103 percent above assessed value. Between $250,000 and $1 million,
there is a gradual increase from 58 to 103 percent. The following three graphs show the distribution of
homes listed at between $250,000 and $500,000, between $500,000 and $1,000,000, and those homes
listed above $1 million.
0
5
10
15
20
25
Number of HomesAmount Above Assessed Market Value
Homes Above Assessed Market Value
Listed Between $250,000 and $500,000
3
Zions Public Finance, Inc. | September 2021
Housing Loss Mitigation Analysis | Salt Lake City, Utah
0
2
4
6
8
10
12
14
Number of HomesAmount Above Assessed Market Value
Homes Above Assessed Market Value
Listed Between $500,000 and $1,000,000
0
0.5
1
1.5
2
2.5
3
3.5
Number of HomesAmount Above Assessed Market Value
Homes Above Assessed Market Value
Listed Above $1,000,000
4
Zions Public Finance, Inc. | September 2021
Housing Loss Mitigation Analysis | Salt Lake City, Utah
Other noteworthy findings include that the difference is much smaller for condos, which are on average
47 percent more expensive compared to the 75 percent increase in price for non-condos (including
townhomes and single-family homes). Additionally, larger homes are priced 74 percent higher than the
assessor’s database while smaller homes (less than 1500 square feet) are priced 63 per cent higher.
Despite the difference, larger homes are listed at $120 higher per square foot compared to the database
while the increase is $140 for smaller homes.