Executive Summary



HOUSING MARKET STUDY

Sundown Heights

Red tail lane and coyote drive

Lapwai, Idaho

Prepared for:

Nez Perce Tribal Housing Authority

February 4, 2004

HOUSING MARKET STUDY

Sundown Heights

Lapwai, Idaho

Prepared for:

Nez Perce Tribal Housing Authority

P.O. Box 188

Lapwai, ID, 83540

Prepared by:

John Prior

Prior & Associates

1900 Grant Street, Suite 720

Denver, Colorado 80203

(303) 861-2728

info@

February 4, 2003

Executive Summary

I. SUBJECT DESCRIPTION

• THE SUBJECT OF THIS REPORT IS THE MARKET FEASIBILITY OF A 12-UNIT SINGLE-FAMILY RENTAL PROJECT IN LAPWAI, IDAHO.

• The subject will be part of a single-family residential subdivision. The units will be in one-story, detached structures that have vinyl exteriors with wood accents, pitched shingle roofs, and varied facades.

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• Each unit will be located on a lot that has front, rear, and side setbacks and a driveway with carport.

• The subject’s common amenities will include an on-site laundry facility and park with playground equipment and basketball court.

• Each unit will have central air conditioning, a refrigerator, range, dishwasher, disposal, exhaust fan, and washer/dryer connection.

• The subject will be developed through Low Income Housing Tax Credit program and targeted to households with incomes less than 60% of the area median income (AMI).

• The following table describes the subject’s unit distribution by type, size, income restriction and rent structure.

|Subject Summary |

|Unit Type |Number of Units |Square Feet |% of Median Income |Proposed Rent |

|3BR/2BA |1 |1,350 |30% |$190 |

|3BR/2BA |1 |1,350 |40% |$300 |

|3BR/2BA |1 |1,350 |50% |$300 |

|3BR/2BA |7 |1,350 |60% |$300 |

|3BR/3BA |2 |1,800 |60% |$300 |

|Source: Project Sponsor |

II. Location and Market Area

• THE NEZ PERCE RESERVATION IS ALONG HIGHWAY 95, 89 MILES SOUTHEAST OF SPOKANE, WASHINGTON AND 260 MILES NORTH OF BOISE, IDAHO.

• The Nez Perce Reservation has a population of 17,291 and is within Nez Perce County, which has a population of 37,402.

• The subject, which is in a residential neighborhood in the western part of Lapwai, will appeal to persons who live or work in Lapwai and adjacent communities in and around the Nez Perce Reservation, including Potlatch and Lewiston.

• The project market area, which includes the Nez Perce Reservation and the Lewiston census subdivision, has 85,849 residents.

III. Economic and Demographic Profile

• NEZ PERCE COUNTY'S ECONOMY IS BASED ON RETAIL TRADE, MANUFACTURING, SERVICE, AND TOURISM.

• The subject is in Nez Perce County, which has had an average annual job growth rate of 0.8% since 1993. Between 1993 and 1998, employment rose to 23,009, or 2.3% per year.

• A downturn in the county's general economy in 1998 led to a loss of 906 jobs from 1998 through 2002.

• However, the county’s economy recovered in 2003. During the last year, employment climbed 2.8%.

• The Idaho Department of Labor projects that employment will increase 2.4% per year through 2010 in the subject’s North Idaho economic region.

• The average annual wage of Nez Perce County employees who are covered by unemployment insurance was $14,683 in 1999. Wages have been increasing 3.0% per year.

• The market area should gain 30 renter households per year through 2008.

• The project's proposed units are most suitable for households with between three and six persons, who account for 30.6% of market area renters.

• The project will appeal to households with incomes between $5,700 and $32,600 who comprise 37% of market area households.

• Fifty-eight percent (58%) of the Nez Perce County households who have incomes below 60% of the area median are renters.

iv. HOUSING pROFILE

• RENTAL HOUSING ON THE NEZ PERCE RESERVATION PORTION OF THE MARKET AREA PRIMARILY CONSISTS OF SEVERAL SINGLE-FAMILY UNITS, ONE LIHTC COMMUNITY, HUD LOW-RENT DUPLEXES AND AN AGE-RESTRICTED HUD LOW-RENT PROJECT.

• The LIHTC project, Whitebird, was built in the 1973, then was rehabilitated and converted to a LIHTC property of single-family rentals targeted to the same income group as the subject. Since its renovation, Whitebird has maintained full occupancy. It is now filling three vacant units with households on its 190-applicant waiting list.

• Larger non-income restricted projects are located nine miles west in the city of Lewiston. The LIHTC units in Lewiston are in good condition and were built in the 1990s and at least 98% occupied. Market-rate units were built in the 1960s, 1970s and 1980s, are in average to below average condition, and offer inferior in-unit amenities. These projects are 98% occupied.

• Over the last ten years, an average of 35 new multifamily units per year were constructed in all Nez Perce County jurisdictions, including the market area.

• Since the beginning of 2003 18 multifamily permits were issued in the county, of which, all were built in Lewiston.

• There are two rental projects with a total of 15 non-income restricted units under construction in Lewiston. Besides the subject, no rental units are planned on the Nez Perce Reservation.

• According to rental property managers the vacancy rates of small multifamily and single family detached rental units did not change in the past year. Of the 15 apartment projects surveyed, no property manager reported a lower occupancy rate from the previous year.

• In January 2003 the vacancy rate at surveyed single- and multi-family rental units was 2.5%.

• All three vacant three-bedroom/one-bathroom units were at Whitebird, which is filling its empty units with applicants on its waiting list. The 18-unit market-rate duplex community in Lapwai, 425 yards east of the site, is 100% occupied and in deteriorating condition.

• The subject will have no discernable impact on the occupancy levels of LIHTC units in the market area. The market area is gaining 30 renter households per year.

• The 2.5% overall vacancy rate has remained stable over the past year. There are no other LIHTC rental projects in the development pipeline for Nez Perce County or the city of Lewiston.

• None of the surveyed projects were offering concessions in January 2004.

V. Evaluation of Proposed Project

• THE SUBJECT IS FURTHER FROM COMMUNITY STORES, GENERAL SERVICES, AND MAJOR EMPLOYMENT OPPORTUNITIES THAN ITS MAJOR COMPETITORS, WHICH ARE CONCENTRATED IN LEWISTON.

• The subject will have above average unit sizes and in-unit amenities.

• The project’s three-bedroom units have rents ($190 and $300) that are at least 49% and 44% below the weighted averages for LIHTC and market-rate units in the area, respectively.

• If the subject has no rent or income restrictions, it could attain a market-rate rent of $575.

• The sponsor’s proposed rents are at least 48% below its market rent and provide a good value to potential tenants.

|subject’s pro forma and derived market rents |

|Unit Type |Pro Forma Rent |Derived Market Rent |Percent Difference |

|3 Bedrooms, 2 Baths |$190/$300 |$575 |67% / 48% |

|3 Bedrooms, 3 Baths |$300 |$575 |48% |

|Source: Prior & Associates Analysis, January 2004 |

VI. Demand for Proposed Project

• THE SUBJECT WILL APPEAL TO LOW-INCOME HOUSEHOLDS THREE TO SIX PERSONS IN SIZE WITH ANNUAL INCOMES BETWEEN $5,700 AND $32,600.

• The market area is projected to gain 30 new renter households per year through 2008. Of these households, 37.3% are income-qualified for the subject’s LIHTC limits.

• When the subject is ready to be placed in service there will be a net demand for 194 new rental units, including 58 in the subject’s target price range.

vII. Conclusion

THE SUBJECT CAN ATTAIN ITS REQUIRED MARKET SHARE BECAUSE:

← The current vacancy rate is 2.5%. Over the next two years the market area will need additional units to account for its increase of 60 renter households. However, there are 23 rental units in the development pipeline, which will not be sufficient to accommodate the area’s renter household growth.

← The LIHTC units have a 3.4% vacancy rate. There are 190 applicants on the waiting list at the nearest LIHTC project, Whitebird, which offers similar units and in-unit features as the subject.

• The proposed rents, which are 48% and 67% below their market values, offer a very good value to potential tenants.

• We expect that the subject will fill six units per month and be fully occupied within two months.

PROJECT DESCRIPTION

1 Project Overview

Project Sponsor: Nez Perce Tribal Housing Authority

Project Name: Sundown Heights

Location: Southwest of the City of Lapwai, ID

Census Tract: 9901 (Not a Qualified Census Tract)

Project Type: LIHTC

Area Median Family Income: $46,900

2 Target Market

The subject is a new construction project containing 12 units developed through the Federal Low Income Housing Tax Credit (LIHTC) program and targeted to single-family low-income households.

All units have income and/or age restrictions. Twelve (12) units will be restricted to households with incomes less than 60% of the area median.

Occupancy will be restricted to households with annual incomes below 60% of the area median. Households who have up to six persons and incomes less than $32,600 are potential tenants for the proposed units.

3 Project Concept

The subject is a planned community, rental apartment complex located in twelve one-story walk-up structures that have vinyl siding exteriors, uniform elevations and pitched shingle roofs located on a irregularly shaped sites. The units all have private exterior entrances. Parking is attached to buildings. The buildings face the streets and common areas are interspersed in clusters throughout the site. Landscaping consists of grass and is in average condition. We reviewed the sponsor's elevations, site plans and floor plans dated January 2004, and determined that they will be competitive with other properties.

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4 Unit Features, Common Amenities and Tenant Services

Each unit will have:

← Central Air Conditioning

← Range

← Refrigerator

← Dishwasher

← Disposal

← Kitchen Exhaust Fan

← Washer/Dryer Connection

← Central Heating

The subject will offer the following common amenities, security features and tenant services:

← Laundry facility - on-site

← Parks

← Nature trails

← Community facilities

5 6 Parking

The subject will supply one carport and surface parking for the 12 units.

7 Utilities

The following table describes the project's utility combination:

|UTILITY SCHEDULE |

|Utility |Type |Who Pays |

|Heat |Electric |Tenant |

|Electricity |N/A |Tenant |

|Air Conditioning |Electric |Tenant |

|Hot Water |Electric |Tenant |

|Cooking |Elictric |Tenant |

|Water |N/A |Tenant |

|Sewer |N/A |Tenant |

|Trash Collection |N/A |Tenant |

|Source: Project Sponsor |

9 Unit Mix, Size and Rent Structure

The following chart, supplied by Nez Perce Tribal Housing Authority and HUD, lists the subject's proposed unit distribution by unit type, size, income restriction, and rent structure.

|unit type sizes and rent |

|Unit Type |Number of Units |Square Feet |% of Median |Maximum Gross Rent|Utility Allowance |Maximum Net Rent |Proposed Rent |

| | | |Income | | | | |

|3BR/2BA |1 |1,350 |30% |$366 |$176 |$190 |$190 |

|3BR/2BA |1 |1,350 |40% |$487 |$176 |$311 |$300 |

|3BR/2BA |1 |1,350 |50% |$610 |$176 |$434 |$300 |

|3BR/2BA |7 |1,350 |60% |$731 |$176 |$555 |$300 |

|3BR/2BA Split |2 |1,800 |60% |$731 |$176 |$555 |$300 |

|Source: Nez Perce Tribal Housing Authority; HUD |

Project Location

The subject of this report is the construction of a 12- unit single-family housing subdivision in Nez Perce Reservation, Idaho in the North Region portion of the state. Nez Perce Reservation is along Highway 95, 89 miles southeast of Spokane, Washington and 180 miles north of Boise, Idaho. Nez Perce Reservation has a population of 17,291 and is within Nez Perce County, which has a population of 37,402.

Location Map

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The subject is Coyote Drive, Parade Avenue, and Red Tail Lane and is in a new community subdivision, a rural area. The site is 0.3 miles east from Highway 95 and 10 miles west of Lewiston, the closest retail and general service opportunities.

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COMMUNITY AND SITE INFORMATION

1 Site Characteristics

1 Site Location

The subject is in a residential neighborhood in the western part of the city. This area is a very low- to low-income Native American community that developed during the 1960s.

2 Visibility and Access

The subject is on a minor street. This location has a low volume of passing traffic and limited visibility.

3 Physical Characteristics

The proposed development site is a hilly, irregular, approximately seven-acre tract that is vegetated with native grasses. There is no current zoning regulations prohibiting uses. The sponsor will need to proceed to construction. The site is designated for residential purposes.

4 Surrounding Land Uses

North: Along the site's boundary to the north, Lapwai Head Start is a pre-school with 5,000 square feet that is in average condition for the area. The pre-school has a positive impact on the community because it provides educational opportunities within walking distance of the subject.

Further to the north, 0.2 miles from the subject, A Street is a two-lane minor street that has a low traffic volume and connects Willow Avenue to the elementary school.

Beyond this, to the north, 0.3 miles from the subject, Lapwai Elementary School is a public school with 70,000 square feet that is well maintained. The public school has a positive impact on the community because it is within walking distance of the subject.

South: Along the site's boundary to the south, is a vacant multiple-acre hilly site vegetated with native grasses.

Further to the south, 0.5 miles from the subject, 457 Road is a two-lane collector street that has a medium traffic volume and connects Main Street to 461 Road.

Beyond this, to the south, is a vacant multiple-acre hilly site vegetated with native grasses.

East: Along the site's boundary to the east, is an existing scattered single-family homes consisting of ranch structures that were built in the 1980s, with 800 square feet of living space. The units generally are in average to deteriorating condition. Most homes have two or three bedrooms, one bath, and no garage or carport. They sell for approximately $85,000.

Further to the east, 0.3 miles from the subject, Main Street is a two-lane collector street that has a medium traffic volume and connects Highway 95 to 461 Road.

Beyond this, to the east, 0.4 miles from the subject, is an existing scattered single-family homes consisting of ranch structures that were built in 1960s, with 800 square feet of living space. The units generally are in average to deteriorating condition. Most homes have two or three bedrooms, one bath, and no garage or carport. They sell for approximately $85,000.

West: Along the site's boundary to the west, is a vacant multiple-acre hilly site vegetated with native grasses.

2 Nearby Community Infrastructure

1 Retail Shopping Areas

The closest convenience store is Thunderbird IV, located at Main Street and Locust Avenue, 419 yards to the northeast of the subject.

Valley Foods, a nearby independent grocery store with approximately 50,000 square feet of space, is in a stand-alone building at Maple Avenue and 2nd Street East, which is 0.5 miles northeast of the subject.

K-Mart, located at 1815 21st Street, Lewiston, 9.4 miles to the west of the subject, is a discount retail store of approximately 50,000 square feet.

2 Nearby Employment Opportunities

Most market area tenants have blue collar occupations. Many work at government agencies and factories. The closest major employment center is the Potlatch Lumber, which is located at 805 Mill Road, Lewiston. This employment complex, which includes lumber production, is seven miles northwest of the subject.

3 Schools

The subject is in the Lapwai School District, which Idaho Department of Education rates as below average in comparison to other schools in the state. Children will attend the Lapwai (K - 6) Elementary School, Middle School, and Lapwai (7 - 12) High School. The elementary school is 0.2 miles north of the subject, the middle school is and the high school is 0.25 miles north. Busing is available to all schools for students who live a minimum of one mile away. Northwest Community College is 0.1 mile north of the site. Lewis-Clark State College, 10.6 miles west, is the closest four year college.

4 Public Transportation

Like most other rural communities, the market area has no public transportation.

Community Health Reps provides dial-a-ride type services to various client appointments, as scheduled, daily. The one-way fare is complimentary.

5 Social Services

Assembly of God Church, which is 0.3 miles northeast from the subject, provides childcare at a weekly cost of $2.25 per hour. The library is 0.3 miles northeast of the subject. Government services are available at Tribal offices, 0.25 miles northeast of the subject.

Lapwai Senior Center, which is 0.3 miles northeast from the subject, provides arts and crafts classes and exercise facility, 8 am to 4:30 pm, weekdays. St. Joseph's Regional Medical Hospital, the nearest full service hospital, is 10.6 miles west of the subject. The nearest medical facility is Nimiipuu medical clinic, 0.2 miles north of the subject. Parks and Recreational Opportunities

6 Parks and Recreational Opportunities

A planned neighborhood park, is a park located at near the subject site, 0.1 miles east of the subject. This facility has basketball courts, children's play equipment, trails, and other amenities.

Approximately 0.25 miles northwest of the subject is the Pi Nee Was Boys and Girls Club, which has a gymnasium, meeting rooms for community activities, and other amenities. The center is open 3 pm to 6 pm, weekdays.

7 Public Safety

The crime rate in the subject's neighborhood is average for the area. Safety is not an important factor that tenants consider when renting in the market area. Most nearby apartment complexes have no security measures. Properties and street signs near the subject have sporadic graffiti. Neighborhood anti-crime initiatives include community policing. According to the Tribal Police, crime activity is not changing.

3 Community and Site Strengths and Weaknesses

Strengths

• The subject is within walking distance of Head Start, the Lapwai Boys and Girls Club, the elementary and high schools and a distance learning facility.

• It has a community park located in the subdivision.

• Health services, social services, housing counseling services, and law enforcement support are immediately available to the Nez Pierce Reservation, and the subject site.

Weaknesses

• The closest retail and general service opportunities are in Lewiston, nine miles west of the subject.

PROJECT SITE

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FROM SOUTH LOOKING NORTH

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FROM NORTH LOOKING SOUTH

COMMUNITY FACILITIES MAP

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MARKET AREA BOUNDARIES

The subject is in Lapwai, Idaho, an Indian reservation that provides shelter for persons who live on the Nez Perce Reservation or in nearby communities. The town of Lapwai is north of the Nez Perce National Forest and of .

Public school students attend classes in the Lapwai School District 341, which serves the city of Lapwai. The school system is rated below average compared to other districts in the state. The primary circulation area of the Lewiston Morning Tribune includes the greater Lewiston area. All of the surveyed projects that advertise reported that they place ads in the Lewiston Morning Tribune, including Lapwai, Lewiston, and unincorporated communities in Nez Perce County.

Local rental properties appeal to tenants who live in the Lewiston area, work in manufacturing or service fields, and have annual incomes between $5,000 and $35,000. The LIHTC units at Whitebird, the sponsor's existing LIHTC project in Lapwai, appeal to a similar tenant base. The subject will draw tenants from the reservation itself, as well as people in the Lewiston area, especially those with employment or family ties on the reservation.

These factors suggest that the subject's primary market area (PMA) includes the Lewiston Census Division and the Nez Perce Reservation. The PMA has 85,849 inhabitants and the following approximate boundaries:

North: Nez Perce Reservation boundary

South: Nez Perce Reservation boundary

East: Nez Perce Reservation boundary

West: Snake River

Households outside these boundaries are not apt to live at the subject. To the north of the market area is the state of Oregon and Washington, which have different governments. East of the market area is the Nez Perce National Forest, which is sparsely populated. To the north and south are sparsely populated unincorporated county areas.

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ECONOMIC profile

1 Overview

The North Region of Idaho, is the area south of the Canadian border and north of the Idaho County southern limits,. Its regional economy is based on service, and ancillary supporting businesses. In the last 50 years or so, tourism has become a large part of the state's economy, especially in the northern region. Coeur d'Alene and the surrounding area continues to see phenomenal growth. Population and per capita income levels continue to rise while many local companies flourish and new businesses opt to move into the area.

The subject is in Lapwai, which is a growing reservation area that offers employment in tribal government, the gaming industry and health care services. Lapwai is ten miles east of Lewiston.

2 Employment Trends

The subject is in Nez Perce County, which has had an average annual job growth rate of 0.8% since 1993. A downturn in the county's general economy in 1998 led to loss of 906 jobs over a period of four years, followed by an employment increase of 422 by November 2003 to 22,525, a 2% gain.

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The county's employment base has increased during 2003. Its November 2003 employment level (22,525) increased 2.8% from its November 2002 level (21,911).

|UNEMPLOYMENT RATES |

| |1993 |2002 |November 2002 |November 2003 |

|United States |6.9% |5.8% |5.6% |5.6% |

|State of Idaho |6.2% |5.8% |5.7% |4.8% |

|Nez Perce County |3.9% |4.0% |3.3% |3.4% |

|Source: Bureau of Labor Statistics |

4 Employment by Sector

Wage and salary employment in the Nez Perce County area rose 3.7% per year between 1997 and 1999. During this time, the transportation/utilities/communications sector and retail trade industry sectors accounted for 62% of the job growth. Persons employed in these sectors have wages that will enable them to qualify for the proposed units.

|EMPLOYMENT BY INDUSTRY, 1997 – 1999 Nez Perce County |

| |1997 |1999 |Change |Average Annual Wage |

| | | |# |% of Change | |

|Retail Trade |4,149 |4,267 |118 |21.4% |$7,942 |

|Manufacturing |2,997 |3,081 |84 |15.2% |$24,153 |

|Trans/Utilities/Comm |1,174 |1,396 |222 |40.2% |$15,615 |

|Local Government |1,549 |1,591 |42 |7.6% |$14,127 |

|State Government |1,125 |1,143 |18 |3.3% |$15,448 |

|Finance/Ins/RE |1,234 |1,267 |33 |6.0% |$15,781 |

|Wholesale Trade |852 |839 |(13) |(2.4%) |$14,201 |

|Lumber Production |617 |603 |(14) |(2.5%) |$20,750 |

|Construction |742 |821 |79 |14.3% |$16,495 |

|Food processing |135 |118 |(17) |(3.1%) |$20,084 |

|Total Employment |14,574 |15,126 |522 |100.0% |$14,683 |

|Source: Idaho Department of Labor |

6 Major Employers

The Greater Lewiston area's major private and public sector employers are in the manufacturing, health care and educational services sectors. The three major employers for Lapwai residents are Potlatch, the tribal government, and Clearwater River Casino.

|MAJOR private and public sector EMPLOYERS, |

|greater lewiston |

|Company |Industry |Employees |

|Pottatch |Manufacturing |3,000 |

|St. Joseph Regional Medical Center |Helath Care |854 |

|Nez Perce Tribal Government |Local Government |734 |

|Blount |Manufacturing |730 |

|Lewiston Independent School District |Education |703 |

|Regence BlueShield of Idaho |Insurance |480 |

|Lewis-Clark State College |Education |384 |

|Clearwater River Casino |Gaming |301 |

|Twin City Foods |Food Processing |300 |

|City of Lewiston |Local Government |299 |

|Source: Lewiston Chamber of Commerce |

7 Future Employment Trends

The Idaho Department of Labor projects that employment will increase in the economic region of the state in which the subject is located 2.4% per year through 2010.

8 Wages

The average annual wage of Nez Perce County employees who are covered by unemployment insurance was $14,683 in 1999. Wages have been increasing 3.0% per year. Within the project market area, most residents have manufacturing jobs and have average annual earnings of $24,153.

|AVERAGE ANNUAL WAGE 1997 – 1999 |

|Nez Perce County |

| |1997 |1999 |Annual Percent |

| | | |Change |

|Services |$11,917 |$13,100 |4.7% |

|Retail Trade |$7,830 |$7,942 |0.7% |

|Manufacturing |$23,111 |$24,153 |2.2% |

|Local Government |$13,221 |$14,127 |3.3% |

|Trans/Utilities/Comm |$14,566 |$15,615 |3.5% |

|Fin/Ins/RE |$14,921 |$15,781 |2.8% |

|State Government |$14,311 |$15,448 |3.8% |

|Wholesale Trade |$13,204 |$14,201 |3.6% |

|All Sectors |$13,833 |$14,683 |3.0% |

|Source: Idaho Department of Labor |

Demographic Profile

1 Population

Since 2000, population has been decreasing slightly at 0.9% per year in the primary market area (PMA) and decreasing slightly at 0.3% in the Nez Perce Reservation. Applied Geographic Systems and the State of Idaho projects that the PMA's population will increase 0% per year to 85,934 by 2008.

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2 Households

Between 2000 and 2003, the primary market area gained 420 households per year. The PMA is projected to gain 103 households per year through 2008. This increase on the Nez Perce Reservation accounts for 2% of the market area growth. The reversal of the areas economic downturn in the late 1990s and the projected 2.4% per year employment increase has lead to a steady increase of households in the market area during the early 2000s.

|HOUSEHOLDS, 1990-2004 |

| |Households |Annual Increase |

| | |Number |Percent |

|Nez Perce County |

|2000 |14,994 | |

|2003 |15,369 |125 |0.8% |

|2008 |15,872 |101 |0.6% |

|Nez Perce Reservation |

|2000 |6,796 | |

|2003 |6,822 |9 |0.1% |

|2008 |6,833 |2 |0.0% |

|Primary Market Area |

|2000 |19,879 | |

|2003 |21,140 |420 |2.0% |

|2008 |21,657 |103 |0.5% |

|Source: Applied Geographic Systems and the State of Idaho |

3 Household Tenure

Renters comprise 29.4% of the households in the primary market area, and 31.2% in Nez Perce County. This tenure pattern suggests that the PMA is gaining 30 renter households per year.

4 Household Size

In 2000 there were 2.49 persons per renter household on the Nez Perce Reservation and 2.37 in the primary market area. The project's proposed units are most suitable for households with between three and six persons, who account for 30.6% of market area renters.

|RENTER HOUSEHOLD SIZE, MARKET AREA 2000 |

|Persons in Household |All Households |Renters |Percent Renters |

|1 Person |5,324 |2,278 |42.8% |

|2 Persons |7,686 |1,745 |22.7% |

|3 Persons |2,918 |892 |30.6% |

|4 Persons |2,452 |607 |24.8% |

|5 Persons |946 |191 |20.2% |

|6 Persons |380 |105 |27.6% |

|7 or More Persons |173 |46 |26.6% |

|Total |19,879 |5,864 |29.5% |

|Source: 1990 U.S. Census of Population and Housing, STF1A |

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5 Household Income

The rents for its income-restricted units will start at $190 per month. Households with annual incomes above $5,700 can qualify for these units without spending more than 30% of their income for rent. The subject will appeal to households with incomes between this amount and $32,600, which is the maximum income for a six person household at the 60% AMI threshold. These units are targeted to 42% of reservation households and 37% of market area households.

|INCOMES OF MARKET AREA HOUSEHOLDS, 1999 |

| |Reservation |Market Area |

| |Households |Percent |Households |Percent |

|Less than $5,000 |484 |7.1% |1,332 |6.3% |

|$5,000-$14,999 |962 |14.1% |2,663 |12.6% |

|$15,000-$24,999 |1,166 |17.1% |3,150 |14.9% |

|$25,000-$34,999 |1,037 |15.2% |2,959 |14.0% |

|$35,000-$49,999 |1,275 |18.7% |3,784 |17.9% |

|$50,000-$74,999 |1,132 |16.6% |4,037 |19.1% |

|$75,000-$99,999 |450 |6.6% |1,818 |8.6% |

|$100,000 or more |314 |4.6% |1,395 |6.6% |

|Total |6,820 |100.0% |21,138 |100.0% |

|Source: National Decision Systems, Inc. |

Renters generally have lower incomes than owners. According to a special census tabulation prepared for the U.S. Department of Housing and Urban Development (HUD), 58% of households in Nez Perce County with incomes less than 60% are renters.

|household incomes by tenure, 2000, Nez Perce County |

|Percent of Median |Households |Renters |Percent |

|0 – 30% |1,653 |1,151 |69.6% |

|31% - 40% |952 |535 |56.2% |

|41% - 50% |952 |535 |56.2% |

|51% - 60% |857 |357 |41.7% |

|61% - 80% |1,715 |713 |41.6% |

|81% - 95% |6,860 |1,202 |17.5% |

|Over 95% |2,287 |401 |17.5% |

|Total |15,276 |4,894 |32.0% |

|Total under 50% |3,557 |2,221 |62.4% |

|Total under 60% |4,414 |2,578 |58.4% |

|Source: HUD CHAS Databook |

Housing Profile

1 Market Area Overview

Rental housing on the Nez Perce reservation consists of several single-family units, one LIHTC community, HUD low-rent duplexes and an age-restricted HUD low-rent project. The LIHTC project was built in the 1973, rehabilitated in the 2000s, and is in above average condition in comparison to the other residential units in the community. The project, Whitebird, is 90% occupied with a waiting list of 190 applicants. The vacancies will be filled when the appropriate contacted waiting list applicants respond to the housing authority.

The larger non-income restricted projects are located nine miles west in the city of Lewiston. The LIHTC units in Lewiston are in good condition and were built in the 1990s and at least 98% occupied. Market-rate units were built in the 1960s, 1970s and 1980s, are in average to below average condition, and offer inferior in-unit amenities. These projects are 98% occupied.

According to property management companies, vacancy rates and charged rents have remained constant over the past year. Two companies with a total of 359 single-family rental units have a combined vacancy rate of 2.5%. Many ranch-style units were built in the pre-WWII era and are in average condition.

2 Housing Inventory

1 Number of Units

From 1993 to 2002 permit issuing jurisdictions in the Nez Perce County authorized the construction of 1,268 new dwellings. Multifamily permits averaged 35 units per year and accounted for 27.7% of the development activity. In 1996, 33% of the construction occurred. During this period, multifamily housing starts averaged 116 per year. Of the 352 multifamily permits permitted in this period of time, 97% were built in the city of Lewiston. Since the beginning of 2003, 18 multifamily permits were issued in the county, of which, all were built in Lewiston.

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According to the U.S. Department of Commerce, since 1993, 352 multifamily units and 916 single-family units were approved in the Nez Perce County. The subject is on the Nez Perce Reservation. This area had no multifamily housing starts or 0% of the regional total.

There has been no new apartment construction in the last two years.

2 Projects Planned or Under Construction

The Nez Perce County Planning and Building Department reported that no large multifamily projects have been permitted in the past two years. The City of Lewiston Development Department indicated that there are two projects with a total of 15 units under construction in the city of Lewiston. In addition to the subject, one development with eight dwellings is planned in the market area.

Of the projects in the various stages of development, three are in the primary market area.

The subject will compete with none of the projects in the development pipeline because of the lack of income restrictions.

3 Unit Types

In 2000, multifamily units comprised 45.8% of the rental units. Of the remaining rentals, 42.4% were single-family homes, 12% mobile homes, and 0.0% other structural types.

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4 Age and Condition of Rental Units

The subject's market area is in a non-metropolitan community. Most of the rental units were built before 1970 and are in average condition.

The market area's rental housing inventory contains small multiple dwellings and single-family homes that are generally in the subject's target price range. The rental inventory also includes small multifamily projects, primarily in deteriorating, below average quality, duplex structures that are between 30 and 40 years old. Many of the units on the Nez Perce Reservation portion of the market area are in substandard condition. According to the Nez Perce Tribal Housing Needs Assessment approximately 40% were considered to be substandard due to their dilapidated condition, or inadequate plumbing, heating, or electrical systems.

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5 Bedroom Distribution

In 2000, 32.1% of the market area's rental units were efficiency or one-bedroom units and 39.6% were two-bedroom units. Dwellings with three or more bedrooms accounted for 28.2% of the market area's rental housing. The average renter household in the subject's market area is 2.37 persons and 68% of the rental units are one- or two-bedrooms in size. The Reservation portion of the market area had an average renter household size of 2.49 persons.

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According to a rental housing unit survey conducted by Prior & Associates, 21% of the market area apartments have one bedroom, 56% two, 20% three and 3% have four bedrooms.

|BEDROOMS IN MARKET AREA apartments |

|Unit Type |Surveyed Projects |Subject |

| |Number |Percent |Number |Percent |

|One Bedroom |77 |21.0% |---- |---- |

|Two Bedrooms |205 |56.0% |---- |---- |

|Three Bedrooms |72 |19.7% |12 |100.0% |

|Four Bedrooms |12 |3.3% |---- |---- |

|Total |366 |100.0% |12 |100.0% |

|Source: Survey by Prior & Associates, January 2004 |

7 Unit Size

The average sizes of the surveyed units ranged from 619 to 1,168 square feet.

|unit sizes (in square feet) |

|Unit Type |Surveyed Units |Subject |

| |Range |Average | |

| |Minimum |Maximum | | |

|1BR/1BA |525 |772 |619 |---- |

|2BR/1BA |759 |1,008 |867 |---- |

|3BR/2BA |1,135 |1,135 |1,135 |1,350/1,800 |

|4BR/2BA |1,153 |1,303 |1,168 |---- |

|Source: Survey by Prior & Associates, January 2004 |

8 Consumer Housing Preferences

When they select units, consumers give strong consideration to price and unit condition.

3 Rental Vacancy Rates

1 Historic Trends

According to rental property managers, the vacancy rates of small multifamily and single family detached rental units did not change in the past year. Of the 15 apartment projects surveyed, no property manager reported a lower occupancy rate from the previous year. The units most comparable to the subject in terms of location, price, and target market have had occupancy levels that are no different than other surveyed units. The four LIHTC projects surveyed have an average 96% occupancy rate, and the empty units are temporarily vacant while they are being filled from waiting lists, which are maintained at all projects. Whitebird, the LIHTC single-family three-bedroom rental community on the Nez Perce Reservation, has a waiting list consisting of 190 applicants.

2 Current Vacancy Rates

The vacancy rate in surveyed multifamily and single-family units was 2.5% in January 2004. Each structural type had comparable occupancy levels. Each unit type had a similar ratio of empty units.

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In January 2004 the average vacancy rate at 367 surveyed LIHTC and non-income restricted units projects was 2.5%. Vacancy rates were highest in three-bedroom/one-bathroom units.

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The subject's primary competitors are LIHTC units located in Lapwai or Lewiston, which were built or rehabbed in the 1990s, are in good condition, and consist of three-bedroom units. The average vacancy rate of these units, 3.4%, exceeds the average for all surveyed units.

Its units will contend less directly with units that were built in the 1960s, 1970s and 1980s, are in average to below average condition, and offer inferior in-unit amenities. These products had an average vacancy level of 2.1%, which is less than the surveyed unit mean.

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All three vacant three-bedroom/one-bathroom units were at Whitebird, a single-family LIHTC community on the Nez Perce Reservation. However, the housing authority maintains a waiting list of 190 applicants and is waiting on responses from contacted applicants to fill the units. The 18-unit HUD low-rent and market-rate duplex community in Lapwai, 425 yards east of the site, is 100% occupied and in deteriorating condition.

3 Turnover

According to U.S. Census Bureau, the average yearly turnover rate in rental units units in the market area is 44%. The average annual turnover rate was 21.4% at surveyed market area apartment projects.

We expect that during the subject's lease-up period, the annual turnover rate among its group of potential market area residents will be 21%, the average for the market area. After the subject reaches stabilized occupancy, its annual turnover rate should be 10%. This is the rate experienced by White Bird, a single-family LIHTC community located 0.3 miles northeast of the subject's site.

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4 Absorption

The one market-rate project that opened in the market area during the last year is 100% occupied, however lease-up information was not attained.

5 Impact on Rental Occupancy Rates

The 2.5% overall vacancy rate has remained stable over the past year. There are no other LIHTC rental projects in the development pipeline for Nez Perce County or the city of Lewiston. Except for the subject, there are 15 rental units that are scheduled to open in the next two years. The planned increase in supply will not be sufficient to satisfy the market area's anticipated rental household growth. Thus, the subject will help alleviate the market area's increasing demand for rental housing.

4 Rents and Other Revenues

1 Historic Trends

According to rental property managers the rents charged by rental units did not change in the last year. The units most comparable to the subject in terms of location, price, and target market have had rent increases that are lower than other surveyed units. Of the 15 surveyed projects, only one project raised its rents approximately $25. The remaining 14 projects maintained similar rents to the ones they had a year ago.

2 Current Rents

The weighted average rent of 15 surveyed LIHTC and non-income restricted projects ranged from $351 for one-bedroom/one-bathroom to $552 for three-bedroom/two-bathroom in January 2004. The weighted market average rent for three-bedroom/one-bathroom units is lower than that of the two-bedroom/one-bathroom units because White Bird, a single-family unit LIHTC community, offers one unit at the 30% AMI threshold, $190. The subject's rents are well below the weighted average rent of surveyed units, $552.

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The subject's primary competitors are LIHTC units that were built or rehabbed in the 1990s, are in good condition, and consist of three-bedroom units As noted in the following table, the rents are at least 49% below the weighted average market rent. However, the surveyed three-bedroom/two-bathroom units are in Lewiston, which is closer to retail options and major services.

Its units will contend less directly with units that were built in the 1960s, 1970s and 1980s, are in average to below average condition and offer inferior in-unit amenities. These units are at least 44% under the weighted average market rent. The rent adjustment analysis described in page VIII-I and in Exhibit A indicates that if the subject had no rent or income restrictions, it could command a market rent of $575.

The LIHTC weighted average rent for three-bedroom/two-bathroom units are above that of the market-rate units because the LIHTC units are offered in newer construction with superior amenity packages.

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The subject is within the service area of the Idaho Housing and Finance Association, which has 600 Section 8 vouchers.

Section 8 recipients can find rental units that meet HUD's Fair Market Rents and Housing Quality Standards.

The sponsor's proposed rents are under the Section 8 rent limits. Therefore, households with rental assistance can inhabit these proposed units. The Idaho Housing and Finance Association has approximately 500 applicants on the waiting list to receive rental assistance. It takes applicants close to a year to be processed from the waiting list.

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3 Lease Terms, Premiums and Additional Revenues

The most common lease term is one year. Most rental properties charge a security deposit. The average move-in cost at the subject's primary competitors was equal to one month's rent.

Rent discounts and incentives became less frequent over the last year. No surveyed projects were offering rent concessions.

The subject will not charge any premiums.

5 Comparable Units

The subject's units are most comparable to average to below average modest single-family homes and duplex rental units located in Lapwai, Idaho (Comparables #1 and #2) that are within a half of a mile of the site. They were built in the 1970s and 1980s and appeal to Native American low-income households. In comparison to the subject, these units have about the same amenities and higher rents.

The subject is less comparable to multifamily units located in Lewiston, Idaho. These developments (Comparables #3 through #15) are average garden and townhouse products that are between five and 25 years old years old, and in above average to average condition. They are located approximately ten miles west and attract low- to moderate-income households. Their amenities are less extensive and the subject and their rents are higher.

Comparables #16 through #19 are ranch-style single-family units that are located in Lewiston, Idaho and provide shelter for moderate-income households. They generally are at least 30 years old, in average condition, and of average quality. In comparison to the subject they have comparable amenities and higher prices.

The following pages describe projects that will compete with the subject for tenants.

Comparable Projects

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The market area also includes apartment projects that are either not comparable to the subject or excluded from our analysis due to non-competitiveness or other factors. The chart below lists these projects that were excluded from our survey.

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6 Homeownership Units

Owner-occupied dwellings comprise 76% of the market area's housing stock. The average price of homes for sale in the subject's zip code (83540) January 2004 was $93,267. the lowest of the three dwellings had prices below $79,900. Homes less than this amount included mobile homes.

Most ranch-style were built in 1970s, contained 800 square feet of living space, and were in below average condition. They usually included laundry room and carport.

The FNMA underwriting standards require that homebuyers should not spend more than 28% of their incomes on housing. As noted in the following table, these guidelines suggest that at the current 5.61% for a 30-year fixed term loan, the total monthly expense (including mortgage payments, property taxes, insurance premiums) needed to support a $79,900 home is $561. This amount is higher than all of the subject's units. The minimum annual income required to purchase the home, $24,046, is within the income range of the subject's LIHTC limits.

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The costs of single-family homes near the subject suggest that home ownership is a viable option for tenants who can qualify for the subject's LIHTC units set at the 50% and 60% AMI threshold, but not its LIHTC units set at the 30% and 40% AMI threshold. Therefore, the subject can expect that units for sale will be a source of competition and turnover in the LIHTC units set at the 50% and 60% AMI threshold.

EVALUATION OF THE PROPOSED PROJECT

1 Location

The subject is in a rural area in a residential neighborhood. Its location on a minor street provides it with limited access, but good visibility. The properties surrounding the site are in poor condition. The site’s access to major arterials, regional shopping malls, and grocery stores is comparable to that of its competitors located on the reservation but inferior to those in Lewiston. Its overall location is inferior to its competitors because of the lack of retail and general service opportunities located on the reservation.

Overall Rating: Below Average

2 Project Design

The units will be located in 12 ranch-style structures with vinyl siding with wood accents, uniform elevations, and a pitched shingle roof. Each unit has a private exterior entry. This design is comparable to single-family units in the market area.

Overall Rating: Average

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3 Site Plan

The project will occupy a portion of the seven-plus acre site. The remaining area will be used for open space, parking, recreation areas and community facilities. The main driveway enters the site off Parade Avenue, a minor street. The parking will be located in carports. The landscaping will consist of grass. The subject’s site plan is typical of other single-family rentals in the market area.

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Overall Rating: Average

4 Age and Condition

The project will be in newer and better condition than that of the existing rental stock, which was constructed in the 1960s, 1970s and 1980s.

Overall Rating: Above Average

5 Project Amenities

The planned development will have a basketball court, carports, playground, and central laundry. These common area features are better than those offered by the subject’s competitors. These developments on average offer a central laundry facility.

|EXTERIOR AMENITIES OF COMPARABLE SURVEYED DEVELOPMENTS |

| |

Overall Rating: Above Average

6 Parking

The project will have one carport per residence. There will be no premium charged for the space. The other projects provide similar parking accommodations.

Overall Rating: Average

7 Unit Mix

In 2000, there were 2.49 persons per renter household on the Nez Perce Reservation and 2.37 in the primary market area. The project's proposed units are most suitable for households with between three and six persons, who account for 30.6% of market area renters.

Overall Rating: Average

8 Unit Size

The project’s three-bedroom units will have 1,350 and 1,800 square feet of living space. These units will provide between 19% and 37% more space than the typical market area unit.

|average UNIT size (in square feet) |

|Unit Type |Comparable Units |Subject |

| |Range |Average | |

| |Minimum |Maximum | | |

|3BR/1.5BA |1,120 |1,232 |1,163 |N/A |

|3BR/2BA |1,135 |1,135 |1,135 |1,350/1,800* |

|Source: Survey by Prior & Associates, January 2004 |

*The 1,800 square foot unit has three bathrooms

Overall Rating: Average

9 Floor Plans

1 Three-Bedroom/Three-Bath

The three-bedroom/three-bathroom unit provides 1,800 square feet of living space. Coming through the main entrance the unit opens into the living area. To the left of the living area is a hallway, which leads to a storage closet at the end and two doors on either side of the hall. The door on the left side is the entrance to the master bedroom, which contains a full bathroom and walk-in closet, both of which are located to the right. The door to the right of the main hallway leads to another full bathroom. Straight ahead of the living area is the kitchen and dining areas, a door in the kitchen area opens to the utility closet on the other side of the room. In the dining area a flight of stairs go down into a basement area. At the bottom of the staircase is a L-shaped hallway, to the right is a door at the end of the hallway leading to the backyard area and immediately to the right is a door to the downstairs bathroom. Straight ahead from the staircase is a hallway with two consecutive doors on the left side going to the two remaining bedrooms, the second of which has a walk-in closet. The unit plan provides ample space and circulation for furniture placement.

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Overall Rating: Average

2 Three-Bedroom/Two-Bath

The three-bedroom/two-bathroom unit offers 1,350 square feet of living space. Through the main entrance is the living area and straight ahead of that is a dining and kitchen area. To the left of the living area is a hallway, which has three doors, leading to the utility/storage closet, a full bathroom, and the master bedroom, which has a full bathroom and walk-in closet. The right side of the hallway has two consecutive doors leading to the other two-bedrooms. The unit plan provides adequate space and circulation for furniture placement.

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Overall Rating: Average

10 Unit Amenities

Each unit will have washer/dryer connections, storage closet, walk-in closet, refrigerator, stove, dishwasher, and garbage disposal. These amenities are superior to its competitors that on average only offer tenants a refrigerator, stove, and washer/dryer connection.

|IN-UNIT AMENITIES OF COMPARABLE SURVEYED DEVELOPMENTS |

| |

Overall Rating: Above Average

11 Tenant Services

The community will not offer any ancillary services to its tenants, which is comparable to other complexes in the market area.

Overall Rating: Average

12 Utilities

The units will use electricity for hot water, space heat, and cooking. The owner will pay for sewer, water, and trash removal. This arrangement is standard for the market area.

Overall Rating: Average

13 Rents, Premiums and Other Revenues

The subject's location is inferior to its Lewiston competitors. Its unit sizes and unit amenities are superior. The subject also has comparable project amenities. When these differences are taken into account, the subject's proposed rents are attainable.

The rent grid in Appendix A evaluates these differences and determines the market rents the units could attain if it had no rent or income restrictions. This analysis, which applied a 25% location adjustment to account for the subject’s below average location, indicates that the subject’s market rent is $575. Since the subject’s proposed rents are 48% and 67% below its market value, the subject offers a good value to potential tenants.

Overall Rating: Above Average

14 Summary of Project Strengths and Weaknesses

Strengths

• The subject’s units are at least 19% larger then the weighted average of surveyed three-bedroom units.

• The subject will offer tenants a superior amenity package than that of its competitors.

• The subject’s proposed rents offer a very good value.

Weaknesses

• The subject is not close to retail shopping and general service opportunities.

Demand for the proposed project

1 Sources of Demand

The potential tenants for the proposed project include both households who now live within the market area or households that the market area gains between now and when the project is ready for occupancy. As noted in Section VI, the market area now has 21,140 households and is gaining 103 households per year.

The subject will appeal to households who have sufficient incomes to pay the proposed rents and want one of the unit types that the subject will offer. Commercial underwriters and owners of conventional market-rate projects generally require that the monthly contract rent should not exceed one-third of a tenant's income. They increase the ratio to 40% for income-restricted projects.

2 Tenant Profile

The proposed project will attract households with three to six persons, and incomes between $5,700 and $32,600 per year. In addition, the project will attract households with incomes below $5,700 who have Section 8 rental assistance.

3 New Unit Demand

The state of Idaho and AGS, Inc. projects the market area will gain 103 households per year or 206 households over the next two years when the subject will be placed into service. IHFA guidelines for estimating demand allow for consideration of the following components of renter demand:

• Pent-up demand, as demonstrated by unit vacancy below the 5% balanced market theory.

• Demand based on population growth.

• Reductions based on developments under construction and planned.

Following these guidelines, the following table estimates the demand for rental units in the market area by 2006, when the proposed project will be placed in service. The pent-up demand component compares the current 2.5% vacancy rate and the 5% vacancy rate that would be present in a balanced rental market suggests an additional pent-up demand of 156 units.

Expected household growth in the market area suggests that 61 new rental units, including 23 LIHTC units, will be required by 2006 to meet the existing household growth. The estimate is derived by applying the county’s projected growth to the percentage of renter households to generate a demand for an additional 61 rental units. Adding pent-up demand and new renters, as described above, produces a gross demand for an additional 217 rental units. Tenants who are within the subject’s income range will need 58 of these units. The number of required LIHTC units is a little under five times the 12 units proposed by the subject’s sponsor.

|rental housing demand in the market area, 2003 - 2005 |

| |Total Households |Income Qualified Households |

| | |Primary Market Area |

|Household Growth |

|New Households 2004-2006 |206 |206 |

|Percent Income Qualified |100.0% |37.3% |

|Percent Renter |29.5% |29.5% |

|Units Need for Growth |61 |23 |

|Pent-Up Demand |

|Total Households |21,140 |21,140 |

|Percent Renter |29.5% |29.5% |

|Percent Income Qualified |100.0% |37.3% |

|Renter Households |6,236 |2,326 |

|Balanced Vacancy Rate (5%) |312 |116 |

|Current Vacancy Rate |2.5% |2.5% |

|Current Vacancies |156 |58 |

|Pent-Up Demand |156 |58 |

|Units Needed (Gross) |217 |81 |

|Units Under Construction |

| |15 |15 |

|Units Planned |

| |8 |8 |

|Rental Units Needed |194 |58 |

|Source: Analysis by Prior & Associates, January 2004 |

CONCLUSIONS

1 Feasibility of Proposed Project

The subject can attain its required market share because:

← The current vacancy rate is 2.5%; over the next two years the market area will need units to account for its increase of 60 renter households in the next two years. However, there are only 23 rental units in the development pipeline.

← The LIHTC units have a 3.4% vacancy rate. There are 190 applicants on the waiting list at the nearest LIHTC project, Whitebird, which offers similar units and unit features as the subject.

← The proposed rents, which are 48% and 67% below their market values, offer a very good value to potential tenants.

2 Pool of Potential Tenants

The tenant pool will include households with three to six persons who have incomes between $5,700 and $32,600. Households with incomes below $5,700 may occupy the proposed units if they have Section 8 vouchers. Approximately 25% of the subject’s residents may be Section 8 recipients.

3 Absorption Rate

We expect that the subject will fill six units per month and be fully occupied within two months.

Contact list

Office or Company Contact Person Phone Number

Nez Perce Tribal Housing Authority Celia Gibson 208.843.2229

City of Lewiston Community Development Brian Rusche 208.746.1318

County of Nez Perce Planning & Building Sue Grogan 208.799.3197

County of Nez Perce Assessor Office George Green 208.799.3010

Certification

This study has been prepared in conformance with the standards adopted by NCAHMA for the market analysts’ industry. These standards include the Standard Definitions of Key Terms Used in Market Studies for Affordable Housing Projects, and Model Content Standards for Market Studies for Rental Housing Projects. These Standards are designed to enhance the quality of market studies and to make them easier to prepare, understand, and use by market analysts and by the end users. These Standards are voluntary only, and no legal responsibility regarding their use is assumed by the National Council of Affordable Housing Market Analysts.

Prior & Associates, Inc. is duly qualified and experienced in providing market analysis for Affordable Housing. Prior & Associates, Inc., a member in good standing of the National Council of Affordable Housing Market Analysts (NCAHMA). The company’s principals participate in the National Council of Affordable Housing Market Analysts (NCAHMA) educational and information sharing programs to maintain the highest professional standards and state-of-the-art knowledge. Prior & Associates, Inc. is an independent market analyst.

No principal or employee of Prior & Associates, Inc. has any financial interest whatsoever in the development of which this analysis has been undertaken. The relationship of the market analyst is limited to that of an independent market analyst. The fee assessed for the study was not contingent on the outcome of the analysis.

To the best of our knowledge, all data contained in this report is correct to the extent that the local, state and federal recording agencies, and demographic suppliers accurately record and publish this data. All projections were based on current professionally accepted methodology.

The market analyst made a physical inspection of the market area, reviewed all relevant data, conducted personal interviews with local apartment managers, government officials, local real estate professionals, and service providers, and independently established the conclusions for this report.

By: Prior & Associates, Inc

By: [pic]____________________________

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