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Presentation, discussion, and possible action regarding a waiver of 10 TAC §11.101(b)(4)(D) and (N) for Roosevelt Lofts (HTC #23210)
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RECOMMENDED ACTION
recommendation
WHEREAS, Roosevelt Lofts (the Development) received a 9% Housing Tax Credit (HTC) award in 2023 for the adaptive reuse of 25 low-income units for the elderly in San Angelo, Tom Green County;
WHEREAS, OPG Roosevelt Lofts Partners, LLC (the Development Owner or Owner) is requesting a waiver for 10 TAC §11.101(b)(4)(D) and (N), which are the requirements for screens on all operable windows and the requirement for Energy Star® or equivalently rated windows as Mandatory Development Amenities, for the one-building historic Development;
WHEREAS, the waiver request is because the Development also received tax credits through the Texas Historic Preservation Tax Credit program and the Federal Rehabilitation Tax Credit program, which required the Texas Historical Commission and the National Park Service to approve the replacement windows installed in the building, and these entities determined that the original building would not have had window screens and that the best acceptable windows that are the closest match to the original windows have a clear glazing which does not meet Energy Star® rating requirements;
WHEREAS, 10 TAC §11.101(b)(4) states that the Board may waive one or more of the requirements of the paragraph for Developments that include Historic Tax Credits, with evidence that the amenity has not been approved by the Texas Historical Commission or the National Park Service, as applicable;
WHEREAS, the Owner provided a letter dated January 6, 2026, from the Texas Historical Commission citing that the Development was subject to the Secretary of the Interior’s Standards for Rehabilitation and does not recommend window screens for the historic building and supports the waiver request; and
WHEREAS, the requested waivers do not negatively affect the Development, impact the viability of the transaction, impact Tex. Gov't Code §§2306.001, 2306.002, and 2306.6701, or affect the amount of the tax credits awarded;
NOW, therefore, it is hereby
RESOLVED, that the waiver requests for window screens and for Energy Star® or equivalently rated windows are approved for Roosevelt Lofts as presented to this meeting, and the Executive Director and his designees are each authorized, directed, and empowered to take all necessary action to effectuate the foregoing.
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BACKGROUND
Roosevelt Lofts received a 9% Housing Tax Credit award in 2023 for the adaptive reuse of 25 low-income units for the elderly in San Angelo, Tom Green County. All units in the Development are located in one building, which is listed in the National Register of Historic Places. Rehabilitation for adaptive reuse as multifamily housing of the historic former hotel building has been completed, and the Development was placed in service July 31, 2025.
In a letter dated January 15, 2026, Meredith Edwards, representative for the Owner, requested a waiver of 10 TAC §11.101(b)(4)(D) and (N), which require screens on all operable windows and Energy Star® or equivalently rated windows as mandatory amenities for adaptive reuse developments.
The Development also received tax credits through the Texas Historic Preservation Tax Credit program and the Federal Rehabilitation Tax Credit program, which required the Texas Historical Commission and the National Park Service to approve the replacement windows installed in the building, and these entities determined that the original building would not have had window screens, and that the best acceptable windows that are the closest match to the original windows were Pella Reserves Traditional Single-Hung (all wood) windows, which are now installed. In addition to lacking screens, these windows have a clear glazing, which does not meet Energy Star® rating requirements.
The Owner requests waiver of the requirements for window screens and for Energy Star® or equivalently rated windows for the historic Development. The Owner provided a letter dated January 6, 2026, from the Texas Historical Commission that supports the waiver request. This letter states that the building was constructed in 1929 as the Rainbow Hotel, subsequently operated as the Roosevelt Hotel, and served as an anchor for the north side of downtown San Angelo for many decades. It was concluded that window screens and highly glazed Energy Star® type windows were not historically present and would detract from the historical character of the building. The letter from the Texas Historical Commission states that changes to the windows at this point would damage the character of the building and would not meet the Secretary of the Interior’s Standards for Rehabilitation, thereby threatening the Development’s compliance with the tax credit programs and potentially triggering recapture of the federal tax credit already earned for the entire Development.
Staff recommends approval of the waiver requests for window screens and for Energy Star® or equivalently rated windows as presented herein. If this waiver is approved, the Land Use Restriction Agreement for the Development will be amended to remove the requirement for these amenities.