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Health, Education & Housing board warns moratorium would halt hundreds of affordable units
Summary
Charles Carpenter and counsel told Shelby County commissioners the city's health‑education‑housing PILOT program has facilitated hundreds of affordable units and that a moratorium on the board's activity would stop 500+ units now in the pipeline, while noting HHFB operates under a distinct statute and program structure.
Representatives of the City of Memphis Health, Education and Housing Facility Board told the Shelby County ad hoc committee that their PILOT program is legally and operationally distinct from municipal industrial development boards and is central to producing affordable multifamily housing in Shelby County.
"Right now, the anecdotal evidence says there are about 44,000 units needed to accommodate the citizens of Memphis and Shelby County," Charles Carpenter said, framing the board’s work as essential to addressing a large affordable‑housing deficit. He said HHFB projects rely on a capital stack (grants, tax credits, low‑income housing tax bonds) that frequently requires a PILOT to make debt service feasible and that there are 500+ affordable units currently in motion that would be jeopardized by a moratorium.
Carpenter and Corbin Carpenter outlined HHFB mechanics: a quitclaim deed and pilot agreement filed of record, a frozen assessed improvement basis (an illustrative 50% frozen value was described), tenant benefits included in modern agreements, and underwriting that compares a project’s pro forma with and without a PILOT. They rejected characterizations that HHFB had been uncooperative, noting the volume of records (20 years, tens of thousands of pages) and saying some requested materials are already public at the registrar's office.
Committee members raised compliance concerns — citing past problems with some national developers and asking how the HHFB enforces tenant protections and inspections. The HHFB representatives said monitoring includes an internal compliance team, external monitoring, environmental court and code enforcement partners, and that the board has terminated pilots on some troubled properties when necessary. They committed to work with the county committee to make data more accessible and to walk through distinctions between HHFB and IDB statutory authorities.
