Governing Body Public Comment form - Rhiannon Samuel

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From: City of Santa Fe
To: Governing Body Public Comment
Subject: New submission from your Governing Body Public Comment form
Date: Tuesday, August 11, 2026 3:33:00 PM
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Submitted on: Tuesday, August 11, 2026 at 3:32pm
First Name: Rhiannon
Last Name: Samuel
Your Email Address: rsamuel@credanm.org
Your District: Outside of a Council District
Meeting Date: 8/12/26
Section of Agenda you would like to comment on: Legislation (Public Comment)
Your Comment: CREDA New Mexico, the Commercial Real Estate Development
Association, respectfully submits this comment in opposition to Bill No. 2026-11 and
the proposed changes to the Santa Fe Homes Program fee-in-lieu calculation.
CREDA represents more than 290 commercial real estate professionals and companies
across New Mexico, collectively representing more than 15,000 employees. Our
membership includes the developers, builders, investors, brokers, architects, engineers,
contractors, lenders, and other professionals who are actively building and investing in
communities throughout our state.
We recognize the severity of the housing crisis and strongly believe that the
development community must be an active partner in addressing it. Our members want
to build more housing, including affordable housing, and we support thoughtful policies
that expand housing opportunities for New Mexicans.
Our concern is that this proposal, while well-intentioned, could unintentionally
undermine that goal.
Changing the fee-in-lieu calculation from 65% AMI to 30% AMI represents a
substantial increase in the cost of development. The City's own example demonstrates
an increase from approximately $330,000 to more than $1 million—a 206% increase for
the same hypothetical project.
Such a dramatic increase raises legitimate concerns about development feasibility and
its impact on overall housing production. Development projects must absorb significant
costs related to land, construction, financing, labor, materials, infrastructure, and
regulatory requirements. Adding hundreds of thousands of dollars to the cost of a
project can make projects that might otherwise be feasible financially infeasible,
resulting in projects being delayed, reduced, redesigned, or not built at all.
We believe the City should carefully consider whether increasing the fee to this degree
will ultimately result in more affordable housing—or simply make it more difficult to
build housing in Santa Fe.

We also encourage the City to evaluate the potential impacts on the broader housing
supply, including whether the increased cost could contribute to higher rents and
reduced housing production. Generating additional funding for affordable housing is an
important goal, but it should not come at the expense of the overall housing supply.
CREDA believes there is an opportunity to develop a more effective approach in
partnership with the development community—one that generates meaningful
affordable housing resources while maintaining the economic feasibility necessary to
continue building housing.
We respectfully ask the City Council to reject Bill No. 2026-11 as currently proposed
and work collaboratively with the development community on policies that advance our
shared goal: increasing the supply of housing and making Santa Fe more affordable for
everyone.
CREDA and its members stand ready to be part of that solution.