"Is this pricing wood-frame Garden construction into a state that pays a real, quantified premium for concrete and steel?"
Structural type is a financing decision in Florida, not just a cost decision
FHFC's Leveraging Classification (Phase 4's sorting-chain tiebreaker) runs a construction-type multiplier directly into a deal's ranking: new-construction Garden buildings get a 1.0 multiplier unless built to "Enhanced Structural Systems" standard (0.93), Mid-Rise runs 0.97 (Non-ESS) vs. 0.9021 (ESS), and High-Rise carries the steepest discount at 0.8835 — with any 7-plus-story High-Rise automatically qualifying as ESS. ESS itself is a specific, real standard: all exterior walls, other external load-bearing elements, and the lowest occupied story's floor must be 100% poured concrete/masonry, 100% steel, or a combination totaling 100% of both.
ESS construction is rewarded twice, not once: it also raises the maximum Hard Cost Factor / Total Development Cost cap — in the Small/Medium-county RFA family this guide otherwise cites, a Garden ESS building can carry up to $258,000/unit against a Garden Non-ESS cap of $233,000/unit, and a Mid-Rise ESS building up to $285,000/unit against $258,000/unit for Non-ESS (the large-county RFAs run higher, cost-tiered caps of their own — confirm which RFA's Exhibit C actually governs the deal before using either table). A pro forma that only models the direct cost of concrete/masonry/steel construction, without also modeling its Leveraging Classification and TDC-cap benefit, understates its real value in a competitive Florida deal.
No state prevailing wage — but the local landscape is actively changing
Florida has no state prevailing-wage statute. Local living-wage/prevailing-wage ordinances have historically filled part of that gap in some jurisdictions (Miami-Dade, Broward, and Palm Beach Counties among them), but 2024 legislation (HB 433 and HB 705, signed April 11, 2024) began preempting those local wage mandates on construction contractors and subcontractors. Secondary legal reporting found this session describes full statewide preemption of local wage mandates as scheduled for September 30, 2026 — this specific date was not independently confirmed against the enrolled bill text this session and should be re-verified before being relied on operationally. Federal Davis-Bacon prevailing wage requirements still attach independently of state law whenever federal funds (HOME, CDBG, etc.) are layered into the capital stack.
High-Velocity Hurricane Zone: a real, county-limited cost layer
Established in 1992 after Hurricane Andrew, the Florida Building Code's High-Velocity Hurricane Zone provisions apply only in Miami-Dade and Broward Counties — nowhere else in the state. Wind design speeds there run 165–186 mph in Miami-Dade and 156–180 mph in Broward depending on Risk Category, and every window, door, shutter, and roof assembly must carry a Miami-Dade Notice of Acceptance or equivalent certification, with impact-rated glazing or approved shutters required regardless of distance from the coast. Outside those two counties, standard statewide Florida Building Code wind provisions apply, but without the HVHZ product-certification layer — a real cost and procurement difference a deal just across the county line does not carry.
Where this goes wrong
- Pricing a Garden wood-frame deal without modeling the Leveraging Classification cost of that choice — the multiplier spread between High-Rise and Garden Non-ESS construction can be the difference between Group A and Group B in the sorting chain.
- Assuming Florida prevailing-wage rules mirror Davis-Bacon on every deal — Florida has no state prevailing-wage law, and 2024 legislation is actively preempting the local wage mandates that used to apply in counties like Miami-Dade and Broward; federal Davis-Bacon only attaches when federal funds are actually in the stack.
- Treating HVHZ requirements as a statewide standard — they apply only in Miami-Dade and Broward Counties.
- Sourcing windows, doors, shutters, or roofing in an HVHZ county without confirming Miami-Dade NOA or equivalent certification for the specific product substituted — a common, expensive field discovery at final inspection.
- Modeling only the direct cost benefit of concrete/masonry/steel construction — ESS also raises the Hard Cost Factor/TDC cap, and missing that double benefit understates its real financial value.
- Relying on the September 30, 2026 full local-wage-preemption date without independently confirming it against the enrolled bill text — this session's source was secondary legal-industry reporting, not the statute itself.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies