Honolulu’s Department of Planning and Permitting (DPP) is considering adjustments to its affordable housing requirement rules — but what these adjustments actually do is change the definition of “affordable,” and not necessarily in a good way.

One amendment would tie maximum monthly rent limits for housing units defined by the city as “affordable” for households with 80% area median income (AMI) or below — to a limit of 30% of gross income. In many cases, this maximum rent would rise above current limits, based on HUD “fair market” rent.

Reluctantly, we concede some logic of accepting this shift in calculations. DPP’s limit for renters at 80% AMI or below is based on a federal formula tailored to very low-income renters, while the city’s limits for higher incomes are set at 30% of gross income. Further, a 30% limit is the standard applied by the state for its affordable developments. The proposed amendment would make methodology consistent across the board, and by allowing for higher rents, also provides further incentive to developers to create more units.

The more problematic amendment deletes an existing requirement that affordable units be sold to households spending no more than 33% of their gross household income on monthly housing costs. This could allow more families to qualify, as supporters state, but it also paves the way for developers to routinely offer properties more costly than buyers with limited incomes currently qualify for, while calling them “affordable.”

Higher costs for buyers may benefit developers and investors, but that’s at cross-purposes with workers’ need for truly affordable housing. Eliminating the mortgage ceiling in definitions of “affordable” for those in the 80% to 100% income level would be bad policy, counteracting other efforts to ease the burden on limited-income households.

Several housing developers submitted DPP testimony that it’s difficult to produce units selling for prices low enough to allow limited-income buyers to qualify. But the solution to that problem is to lower costs, rather than raise prices. This may well involve lower profit margins or higher public subsidies; it may also involve changing the prevailing design of affordable housing projects. However, the 33% guideline is based on a practical reality, which is particularly hard to deny in Hawaii: Households with limited incomes struggle to make ends meet in these islands. If faced with higher housing costs, that struggle will become even more difficult.

Rather than approve “affordable” projects filled with units targeted owners cannot qualify for, the city’s approvals and cost-out process need more scrutiny and adjustment. To do otherwise shifts the burden of affordability away from developers and onto an increasingly struggling working class. How then to afford child care, or save for retirement? This is not the time to give ground on affordability.

“The proposed amendments weaken the definition of ‘affordable’,” Unite Here Local 5 stated in testimony, rightly. “If developers cannot sell units at the desired prices due to buyers not being able to qualify for mortgages at those prices, the solution is simple: Developers should mark down their units.”

The city’s definitions of “affordable” come into play when affordable housing is required as a condition of development, or when developers are granted “bonuses” to allowed height and density that increase their returns. Lin Wong, a DPP branch chief who took the unusual step of testifying as a private citizen, reasonably stated in opposing these amendments that an analysis of the benefits received by developers should be done before changing these rules. DPP must do so.

Much is at stake: DPP could decide on the proposed amendments to affordable housing requirement rules within the next 30 days. Hearing notices are posted at honolulu.gov/dpp.