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CC - Item 5A - Public Hearing on the Consolidated Annual Performance and Evaluation Report for FY 2008-09ROSEMEAD CITY COUNCIL STAFF REPORT TO: THE HONORABLE MAYOR AND CITY COUNCIL FROM: JEFF ALLRED, CITY MANAGER* DATE: OCTOBER 27, 2009 SUBJECT: PUBLIC HEARING ON THE CONSOLIDATED ANNUAL PERFORMANCE AND EVALUATION REPORT FOR FY 2008-09 SUMMARY The City of Rosemead's Community Development Department has completed its Consolidated Annual Performance Report (CAPER) for the July 1, 2008 through June 30, 2009 fiscal year. The CAPER describes the overall use of Community Development Block Grant (CDBG) and HOME Investment Partnerships (HOME) funds received from the Department of Housing and Urban Development (HUD) in relationship to the needs of the community as outlined in its 2005-2009 Consolidated Plan and FY 2008-09 Annual Action Plan. The City's overall objective in the CDBG and HOME programs is the development of viable communities by providing decent housing, a suitable living environment and expansion of economic opportunities primarily for low-to-moderate income persons. Staff Recommendation Staff recommends that the City Council conduct a public hearing and take public testimony on the City's FY 2008-09 Consolidated Annual Performance Report. No further City Council action is necessary. ANALYSIS The City submits a CAPER to HUD annually as one of the conditions of receiving federal funds under the CDBG and HOME programs. The CAPER outlines progress made in achieving goals established in the City's Five-Year Consolidated Plan and Annual Action Plan, including: 1) funds invested in projects and activities; 2) households and persons assisted; 3) actions taken to affirmatively further fair housing; and 4) other information relevant to grant-funded projects administered by the City of Rosemead which affect local housing and community development needs. The CAPER is useful for residents in deciding whether housing and community development programs are being carried out as intended. The CAPER permits the City to stay on track with its Five-Year Consolidated Plan and Annual Action Plan, and is designed to provide a maximum amount of useful information to policy makers and residents. ITEM NO. 5 A APPROVED FOR CITY COUNCIL AGENDA: City Council Report October 27, 2009 Page 2 of 4 During the 2008-09 FY, the City spent $1,403,323.77 of CDBG funds and $782,230.68 of HOME funds on a variety of community development projects. The purpose of this update is to give the public, as well as the City Council an opportunity to assess the effectiveness of the City's CDBG and HOME expenditures. A brief summary of the expenditures is attached for your reference. The CAPER was submitted to HUD on September 24, 2009 and the City has received verbal notification of its acceptance by HUD. PUBLIC NOTICE PROCESS Notice of the public hearing was published in the San Gabriel Valley Tribune on October 12, 2009, as well as through the regular agenda notification process. Prepared by: Michelle G. Ramirez Economic Development Administrator Submitt d by: BWneki Community Development Director Attachment A - Summary of Expenditures Attachment B - CAPER City Council Report October 27, 2009 Pace 3 of 4 ATTACHMENT A CDBG PROJECT EXPENDITURES PROJECT DESCRIPTION COMMITTED EXPENDED 2008-2009 FISCAL YEAR - CDBG Administration $ 207,696.00 $ 187,035.09 Administration - Program Income $ 10,143.00 $ 10,143.00 Fair Housing $ 25,000.00 $ 25,000.00 Residential Rehabilitation $ 346,336.07 $ 155,913.84 Emergency Grants $ 10,000.00 $ 4,000.00 Grants $ 150,000.00 $ 102,029.00 Grants - Program Income $ 17,416.00 $ 17,416.00 Rebates $ 30,000.00 $ 0.00 Lead/Asbestos Testing $ 16,500.00 $ 9,420.00 Lead/Asbestos Remediation $ 150,000.00 $ 110,266.00 Consolidated Code Enforcement $ 429,605.78 $ 429,605.78 Family Counseling Services $ 40,000.00 $ 39,94.00 People for People $ 27,600.00 $ 27,600.00 Rosemead School District $ 11,698.00 $ 7,283.16 Rosemead High School $ 13,650.00 $ 13,650.00 Senior Nutrition Program $ 77,824.00 $ 61,059.99 Senior Nutrition Program - Program Income $ 23,162.06 $ 23,162.06 Dinsmoore Historical House Renovation $ 150,000.00 $ 0.00 Targeted Public Works Projects $ 398,700.00 $ 179,799.85 PRIOR YEAR - CDBG City Hall ADA (FY 2006-07) - Carryover $ 330,000.00 $ 0.00 TOTAL $2,465,330.91 $1,403,323.77 Difference between budgeted and expended is $1,062,007.14. Out of this amount, $218,900.15 (Targeted Public Works Projects) was carried over into FY 2009-10 to complete previously approved projects, and $843,106.99 was reprogrammed into projects for FY 2009-10. City Council Report October 27, 2009 Page 4 of 4 ATTACHMENT A - CONT. HOME PROJECT EXPENDITURES PROJECT DESCRIPTION BUDGETED 2007-2008 FISCAL YEAR - CDBG Administration Community Housing Development Organization (CHDO) Set-Aside Community Housing Development Organization (CHDO) Operating Down Payment Assistance Loan Program Owner-Occupied Rehabilitation Program (Loans) TOTAL $ 150,978.64 $ 252,923.15 $ 24,806.00 $ 280,000.00 $1,296,743.62 $2,005,451.41 EXPENDED $ 75,186.48 $ 0.00 $ 24,806.00 $ 70,000.00 $ 612,238.20 $ 782,230.68 Difference between budgeted and expended is $1,223,220.73. The entire amount has been reprogrammed into projects for FY 2009-10. ATTACHMENT B CITY OF ROSEMEAD ~CONSOLID ED ANNUAL PERFORMANCE~AND //EVALUATION REPORT% FOR THE PERIOD COVERING of JULY 1, 2008- JUNE 309 2009 for THE UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT ( . _ Prepared by: - Yr F City of Rosemead 8838 E. Valley Boulevard Rosemead, California 91770 SEPTEMBER 2009>19' r~/ (Is 0 ":Z- Pon Al EID~ CITY OF ROSEMEAD CONSOLIDATED ANNUAL PERFORMANCE AND EVALUATION REPORT PERIOD COVERED: JULY 1, 2008 - JUNE 309 2009 Prepared by the City of Rosemead Community Development Department Contact Person: Mrs. Michelle Ramirez Economic Development Administrator (626) 569-2158 TABLE OF CONTENTS CONSOLDIATED ANNUAL PERFORMANCE AND EVALUATION REPORT 1 A. General 1 B. Managing the Process 1 SUMMARY OF RESOURCES AND DISTRIBUTION OF FUNDS 3 A. Resources Expected to be Available within the Jurisdiction During the 2008-09 Fiscal Year 3 1. Federal Resources 3 a. Program Income 3 b. Surplus for Urban Renewal Settlement 3 c. Grant Funds Returned 3 d. Income from Float Funded Activities 3 e. Urgent Need Activities 3 2. State and Local Resources 3 3. Other Resources 4 B. Consolidated Annual Performance and Evaluation Report 4 C. Section Summary 5 D. Regulatory Requirements for Submission of the CAPER 5 E. Integrated Disbursement and Information System 6 F. CAPER Submission and Review 6 ASSESSMENT OF ANNUAL PERFORMANCE 7 A. Actual Resources Available within the Jurisdiction During the 2008-09 Fiscal Year 7 1. Federal Resources 7 2. State and Local Resources 8 3. Other Resources 8 B. Affirmatively Furthering Fair Housing 9 C. Affordable Housing 13 1. Patterns of actual investment compared to planned investment patterns 13 a. Moderate Rehabilitation 13 b. Substantial Rehabilitation 13 c. Tenant Assistance 14 d. New Construction 14 e. First-Time Homebuyer 14 f Community Housing Development Organization (CHDO) 15 g. Section 215 15 2. Efforts to Address Worst Case Needs 15 D. Continuum of Care Narrative 16 1. Homeless 16 a. Housing and Services for Transition to Permanent Housing and Independent Living 18 b. Permanent Housing and Services for Those Not Capable of Achieving Independent Living 19 c. Permanent Affordable Housing Opportunities for Persons who Successfully Complete a Transitional Housing Program 19 d. Assistance for Preventing Low Income Individuals and Families with Children from Becoming Homeless 19 2. Population with Special Needs - Other Than Homeless 19 Elderly and Frail Elderly 20 Persons with Disabilities 21 Large Families 22 Female Headed Households 22 Persons with Alcohol or Drug Addictions 22 Persons Diagnosed with AIDS and Related Diseases 22 E. Other Actions Undertaken 23 1. Addressing Obstacles to Meeting Undeserved Needs, Fostering and Maintaining Affordable Housing 23 2. Eliminating Barriers to Affordable Housing 24 3. Overcoming Gaps in the Institutional Structure and Enhancing Coordination 25 4. Improving Public Housing and Fostering Resident Initiatives 27 5. Evaluating and Reducing Lead-Based Paint Hazards 27 6. Ensuring Compliance with Program and Comprehensive Planning Requirements 28 7. Reducing the Number of Persons Living Below the Poverty Level 28 Housing and Community Development 28 Economic Development 29 F. Leveraging Resources 29 1. Federal Resources and Program Funds Used 29 2. Non-Federal Resources and Program Funds Used 29 3. Leveraging of Non-Federal Resources 30 4. Matching Contributions 30 G. Citizen Comment 30 H. Self-Evaluation 30 1. Monitoring 31 CDBG PROGRAM ADDITIONAL NARRATIVE STATEMENTS 33 A. Housing Priorities and Needs 33 B. Impact on Identified Needs 33 C. Barriers to Fulfilling Strategies 33 D. Status of Grant Program 34 E. Performance Outcomes and Measurements 34 F. Changes to Program Objectives 34 G. Investment of Available Resources 34 1. Resources and Program Funds Used 34 2. Geographic Distribution of Investments 34 3. Certifications 35 4. Implementation of Five-Year Consolidated Plan 35 5. Funds not Used for National Objectives 35 H. One-For-One Replacement Summary 35 1. Displacement Summary 35 J. Public Facilities and Improvements 35 K. Infrastructure Improvements 36 L. Economic Development - Low/Mod Job Activities 36 M. Limited Clientele Activities 36 N. Program Income 36 0. Prior Period Adjustments 37 P. Lump Sum Agreements 37 Q. Loans 37 R. Housing Rehabilitation 37 S. Neighborhood Revitalization Strategy Area 37 T. Institutional Structure 36 U. Minority/Women's Business Outreach 40 V. Public Participation Requirements 41 HOME PROGRAM ADDITIONAL NARRATIVE STATEMENTS 43 A. Narrative Statement 43 B. Status of Grant Programs 43 C. American Dream Down Payment Initiative (ADDI) 43 D. MBE/WBE Outreach 43 E. Match Report 44 F. Adjustments and Improvements 44 G. Other Forms of Investment 44 H. Recapture Provisions in Mortgage Assistance Program 44 1. Inspection Results 44 J. Affinnative Marketing 44 REPORTS Summary of Activities (C04PR03) Financial Summary Report (COI PR26) Annual Performance Report - HOME Program (form HUD-40107) APPENDICES Appendix A Assessment of Five-Year Goals and Objectives Appendix B 15-Day Comment Period Publication program. CITY OF ROSEMEAD FY 2008-09 CONSOLIDATED ANNUAL PERFORMANCE AND EVALUATION REPORT A. General The Consolidated Annual Performance and Evaluation Report (CAPER) is a summary of the progress toward meeting the goals and objectives that were outlined in the City of Rosemead's Five-Year Consolidated Plan and its Annual Action Plans. The CAPER includes narrative responses to questions that recipients of Community Development Block Grant (CDBG) and HOME Investment Partnerships Act (HOME) Grantees must respond to each year as part of the year end close out of the Consolidated Plan. This report addresses the period of July 1, 2008 through June 30, 2009. The FY 2008-09 Annual Action Plan was submitted to the Department of Housing and Urban Development (HUD) in May 2008. The Five-Year Consolidated Plan and its accompanying Annual Action Plans: 1) identify needs and problems; 2) analyze market conditions and resources; 3) set priorities and adopt strategies for addressing identified activities and goals for programs in the coming fiscal year. B. Managing the Process The Community Development Department is responsible for planning, developing and implementing the City of Rosemead's CDBG and HOME programs. Collectively, these funds provide the following programs: • Owner-Occupied Rehabilitation Program • Commercial Rehabilitation and Economic Development Loan Program • Public Service Agency Program • Infrastructure Program (Capital Improvements) • Down Payment Mortgage Assistance Program • Community Housing Development Organization (CHDO) Program Funds are also used for specific community development projects including Code Enforcement, ADA improvements, lead testing and remediation, and assistance to the homeless and to battered women. The Community Development Department, in addition to the above grant administration, administers the Department of Justice Grants, several State of California Grants (Used Oil Grant and Cal Beverage Grant), and a Redevelopment Agency funded Commercial Rehabilitation Program. Reserved -2- SUMMARY OF RESOURCES AND DISTRIBTUION OF FUNDS A. Resources Expected to be Available Within The Jurisdiction During The 2008-09 Fiscal Year 1. Federal Resources The City of Rosemead was awarded $1,138,481 in Community Development Block Grant (CDBG) Entitlement funds and $496,123 in HOME Entitlement funds that were available to meet identified needs within Rosemead. At least 70% or more of the FY 2008-09 CDBG entitlement total was used for activities benefiting low and moderate-income residents of Rosemead. a. Program Income During the FY 2008-09, the City expected to receive $25,000 in CDBG program income. However, the City ended up receiving a total of $5.0,721.06, which included $21,769 from the repayment of prior CDBG funded housing loans and $28,952.06 from the Senior Nutrition Program. In addition, the City anticipated approximately $790,000 in CDBG carryover funds and $1,712,682 in HOME carryover funds from previous program year. These monies were budgeted/reprogrammed towards eligible CDBG and HOME activities during the FY 2008-09. b. Surplus from Urban Renewal Settlements During the FY 2008-09, no CDBG or HOME income was expected or received as a result of surpluses from urban renewal settlement. c. Grant Funds Returned to the Line of Credit During the FY 2008-09, no CDBG or HOME income was expected or received as a result of grant funds returned to the line of credit with HUD. d Income from Float Funded Activities During the FY 2008-09, no CDBG or HOME income was expected or received as a result of float-funded activities. e. Urgent Need Activities During the FY 2008-09, no CDBG or HOME activities were planned or undertaken as a result of an urgent need. The City continued to work with the Housing Authority of the County of Los Angeles who provides rental assistance to the residents of Rosemead through the Federal Section 8 Voucher program. The primary objective of this program is to assist low-income (0 to 50% of MFI) persons and households in making rents affordable. 2. State and Local Resources During the FY 2008-2009, the City continued to use federal entitlement dollars to leverage a variety of state and local funds, including but not limited to: ➢ Redevelopment Funds During the FY 2008-09, the City expected to receive funding from the Rosemead Community Development Commission to help offset the cost of purchasing a single-family home through the HOME CHDO Program. -3- ➢ General Funds During the FY 2008-09, the City expected to receive funding from the City's general fund account to help offset the cost of the Code Enforcement Program, Senior Nutrition Program, and several Targeted Public Works Projects (Annual Curb Ramps Construction Project and Annual Slurry Seal Construction Project). 3. Other Resources The following service providers who received CDBG funds for the 2008-09 fiscal year budgeted additional federal and non-federal funds to their activities through funding from other cities, in-kind donations, United Way and other charitable organizations, and the Federal and State governments. ➢ Family Counseling Services ➢ Morrison Health Care (Senior Nutrition Provider) ➢ People for People ➢ Rosemead High School ➢ Rosemead School District ➢ Southern California Housing Rights Center B. Consolidated Annual Performance and Evaluation Report The City of Rosemead must prepare a Consolidated Plan and an annual Action Plan, or strategy, setting forth the upcoming year's activities to receive Federal funds under certain housing and community development programs, such as the CDBG Program; HOME Investment Partnerships Program (HOME); Emergency Shelter Grant (ESG); and the Housing Opportunities for Persons with AIDS (HOPWA) programs. These plans provide residents and HUD with information on what the City intends to accomplish with these Federal funds (and other funds) in a specific fiscal year. The City prepared a five- year Consolidated Plan for the 2005 - 2009 period, and has submitted action plans to HUD for the first, second, third, and fourth fiscal years. All are available for review at the City of Rosemead's Community Development Department. This Consolidated Annual Performance and Evaluation Report (CAPER) provides information on project activities representing the third year of the 2005-2009 Consolidated Plan. HUD implemented the CAPER requirement in a field notice issued in 1997. HUD requires cities and counties receiving Consolidated Plan funds to develop priorities, strategies and performance indicators for project activities funded by HUD programs; and that the CAPER report performance against these goals. This requirement was imposed by the Government Performance and Results Act (GPRA) of 1993, which mandated that all recipients of federal financial assistance develop objective and measurable standards for measuring their performance. This allows HUD, local officials, and the public to evaluate the City's overall performance and ability to manage these funds. The CAPER also permits HUD and residents to detennine whether project goals are realistic, and whether activities and strategies undertaken during the last fiscal year actually made an impact on the goals set forth in the Consolidated Plan. This is accomplished by: Reviewing the various funds made available and activities leveraged during the reporting period; leveraged means other money or resources used in addition to ` HUD funds during the year; -4- • Revealing how the resources were used according to the priorities and strategies established in the Consolidated Plan; • Summarizing the number of persons or households helped with housing or supportive services during the reporting period; and • Describing other housing and community related activities during the Fiscal Year 2008-2009. The City is submitting its CAPER for the period July 1, 2008 through June 30, 2009, reporting accomplishments for Action Plan project activities and programs for this time. The CAPER also includes the status of projects that were created through reprogramming of CDBG funds from previous program years. C. Section Summary While the CAPER is a HUD reporting requirement, it is also an important tool for residents in deciding whether housing and community development programs are being carried out as intended. The CAPER permits the City to stay on track with its Consolidated Plan and annual Action Plans, and is designed to provide a maximum amount of useful information to policy makers and residents. CAPER reports are used to: • Provide HUD with necessary information to assess each grantee's ability to carry out its programs in compliance with applicable regulations and requirements; • Provide information necessary for HUD to report to Congress; and • Provide grantees with an opportunity to describe program achievements to residents. D. Regulatory Requirements for Submission of The Caper CDBG regulations require the city to submit a CAPER to HUD within 90 days of the close of the city's program year. This is in accordance with the Consolidated Plan regulations at 24 CFR (Code of Federal Regulations), Part 91. Prior to the 1996 Consolidated Plan program year, grantees submitted a Grantee Performance Report (GPR), which is now known as an Activity Summary. The new version of the report, the CAPER, is far more comprehensive in its requirements. The CAPER incorporates not only the old GPR, but also the reporting requirements for the four grants comprising the Consolidated Plan. These are the Community Development Block Grant (CDBG); Home Investment Partnerships Program (HOME); Emergency Shelter Grant (ESG); and the Housing Opportunities for Persons with AIDS (HOPWA) programs. The CDBG and HOME are the only sources of grant funds the city receives from the Federal government. -5- E. Inteerated Disbursement and Information System HUD reports to Congress and other agencies the progress that the city has made on planned activities in a data format that can be entered into computers, and that can result in generation of project reports, both in summary form and in a detailed manner. And, HUD requires accurate and timely information on grantee performance so that Congress and other stakeholders know that CDBG funds are benefiting intended recipients. For example, the HUD Grants and Program Income report gives information for all program funds and fund types for each fiscal year, including program income. This report gives information that helps fulfill Citizen Participation requirements by reporting on the amount of funds a City has available for the fiscal year (including program income, how much was committed, and how much was spent). To begin annual reporting, the City updates all current activities in IDIS to include required financial and performance information. For example, the IDIS system reports on funds spent for housing activities on individual properties; the CAPER narrative does not. IDIS is also used to obtain funds from the federal government for housing and community development activities. Project data must be complete in IDIS before funds can be requested from the city's line of credit. The IDIS-generated Activity Summary is a detailed document on program accomplishments since the inception of HUD reporting requirements, and is submitted simultaneously to HUD with the CAPER narrative. At any time during the year, HUD may monitor grantees to determine if programs are being carried out according to the rules and regulations that apply to them. For example, it can help HUD identify issues such as CDBG spending timeliness and projects that are getting off the ground too slowly. IDIS provides important information to help HUD determine performance levels. F. Caper Submission and Review Prior to submitting the CAPER to HUD for review, the city must make the report available to the public for examination and comment for a period of at least 15 days. After the CAPER is sent to HUD, the City again makes the final report available for review by residents and organizations. The final version includes a summary of comments received from residents. The city supports maximum public participation in preparation and review of the CAPER. Public comments received after the mandatory 15-day comment period will still be received, compiled and acted upon; comments will be forwarded to HUD to be included as a part of the CAPER. -6- & ASSESSMENT OF ANNUAL PERFORMANCE 4 This section of this document includes an assessment of the effectiveness of the City of Rosemead's performance during the reporting period in the achievement of its five-year strategy objectives and priorities. The Priority Needs Summary Table, located in the 2005- 2009 Consolidated Plan, prioritizes activities to assist renters, homeowners, homeless persons, and other persons with special needs who are in the low and moderate-income (0 to 80% of the MFI) categories. During the Fiscal Year (FY) 2008-09, the City was able to accomplish the majority of the goals that were described in pertinent Consolidated Plan documents. On the whole, the City has committed a large portion of its resources toward improving the quality and expanding the amount of housing stock in the City. During this reporting period the City expended the majority of its CDBG and HOME funds on housing programs and related services. The City continued in its commitment to stimulate housing rehabilitation and construction and to assist those low and moderate-income residents who are unable to compete in the traditional housing market. A. Actual Resources Available Within The Jurisdiction During The 2008-09 Fiscal Year 1. Federal Resources Program: Community Development Block Grant Grantee: City of Rosemead Expected: $2,294,378 ($1,138,481 Entitlement Grant, $790,000 Carryover Entitlement Grant, and $25,000 Program Income). Actual: $2,465,330.91 ($1,138,481 Entitlement Grant, $1,276,128.85 Carryover Entitlement Grant and $50,721.06 progra m income). Comments: The total amount of funds expended durin g the fiscal year was $1 ,403,323.77 (.93 Expenditure Rate). This included previous years' funding t hat was not expended as of the beginning of the fiscal year and program income expenditures. CDBG funds were commit ted and expended as fol lows: Committed Expended Administration $ 207,696.00 $ 187,035.09 Administration - Program Income $ 10,143.00 $ 10,143.00 Fair Housing $ 25,000.00 $ 25,000.00 Residential Rehabilitation $ 346,336.07 $ 155,913.84 Emergency Grants $ 10,000.00 $ 4,000.00 Grants $ 150,000.00 $102,029.00 Grants - Program Income $ 17,416.00 $ 17,416.00 Rebates $ 30,000.00 $ 0.00 Lead/Asbestos Testing $ 16,500.00 $ 9,420.00 Lead/Asbestos Remediation $ 150,000.00 $ 110,266.00 Consolidated Code Enforcement $ 429,605.78 $ 429,605.78 Family Counseling Services $ 40,000.00 $ 39,94.00 People for People $ 27,600.00 $ 27,600.00 -7- Rosemead School District $ 11,698.00 $ 7,283.16 Rosemead High School $ 13,650.00 $ 13,650.00 Senior Nutrition Program $ 77,824.00 $ 61,059.99 Senior Nutrition Program - Program Incom e $ 23,162.06 $ 23,162.06 Dinsmoore Historical House Renovation $ 150,000.00 $ 0.00 Targeted Public Works Project $ 398,700.00 $179,799.85 City Facilities ADA Improvements $ 330,000.00 $ 0.00 Total $2,465,330.91 $1,403,323.77 Program: HOME Investment Partnerships Program Grantee: City of Rosemead Expected: $2,208,805 ($496,123 Entitlement Grant and $1,712,682 Carryover Entitlement Grant). Actual: $2,005,451.41 ($496,123 Entitlement Grant and $1,509,328 .40 Carryover Entitlement Grant). Comments: The total amount of funds expended during the fiscal year was $785,430.68. This included previous years' funding that was not expen ded as of the beginning of the fiscal year and program income expenditures. HOME funds were committed and expended as follows: Committed Expended Administration $ 150,978.64 $ 75,186.48 Community Housing Development Organization (CHDO) Set-Aside $ 252,923.15 $ 0.00 Community Housing Development Organization (CHDO) Operating $ 24,806.00 $ 24,806.00 First Time Homebuyer Program $ 280,000.00 $ 70,000.00 Residential Rehabilitation Loan Program $1,296,743.62 $612,238.20 Total $2,005,451.41 $ 782,230.68 2. State and Local Resources The City funded monies from its general fund account to help offset the cost of the Consolidated Code Enforcement Program and the Senior Nutrition Program during the 2008- 09 fiscal year. 3. Other Resources The following service providers who received CDBG funds for the 2008-09 fiscal year budgeted additional federal and non-federal funds to their activities through funding from other cities, in-kind donations, United Way and other charitable organizations, and the Federal and State governments. ➢ Family Counseling Services Rosemead High School ➢ Morrison Health Care (Senior Nutrition Provider) Rosemead School District ➢ People for People Southern California Housing Rights Center -8- B. Affirmatively Furthering Fair Housing During the 2008-09 FY, the City continued to make a significant effort to affirmatively further fair housing and eliminate impediments to fair housing choice that are within its authority. On January 5, 1995, with the publication of the Consolidated Submission regulations for Community Planning and Development programs, significant new program requirements were established with regard to the long-standing obligation to affirmatively further fair housing. Localities seeking program funds through the Consolidated Submission procedure are required to certify that they will engage in fair housing planning; namely: (1) that they will conduct at the beginning of each five-year cycle an analysis of impediments (AI) to fair housing choice; (2) that they will carry out actions to overcome the effects of identified impediments; and (3) that they will maintain records and make available information and reports, including the analysis of impediments, to document actions undertaken to eliminate identified impediments. The City's first Al was completed in 1997 by the Fair Housing Council of San Gabriel Valley and the Center for Choice in Housing. A five-year update to the City's Al was completed in 2000, and then again in January 2006 by the Southern California Housing Rights Center (HRC). The City's Al is a comprehensive review of policies, procedures, and practices within Rosemead that effect the location, availability and accessibility of housing, and the current residential patterns and conditions related to fair housing choice. Fair housing choice should be understood as the ability of persons of similar incomes to have available to them the same housing choices, regardless of race, color, religion, sex, disability, familial status, or national origin. An impediment to fair housing choice is an action, omission, or decision taken because of race, color, religion, sex, disability, familial status, or national origin that restricts housing choices or the availability of housing choice. It is also any action, omission, or decision that has this kind of effect. Policies, practices, or procedures that appear neutral on their face, but which operate to deny or adversely affect the provision of housing to persons (in any particular protected class) may constitute such impediments. The 2005-2009 Al established nine (9) potential impediments that are identified below as well as the activities the City carried out during the 2008-09 FY to address these issues. Current Fair Housing Profile Housing Complaints from the Asian Population in Rosemead Potential Impediment: According to the 2000 census the Asian/Pacific Islander population made up 48.9% of the Rosemead population. But only 15.6% of Rosemead residents assisted by the HRC from 2003-2005 were Asian/Pacific Islander. The Rosemead Asian population is reporting housing issues less frequently which may indicate a need for more fair housing outreach and education to the Asian population in Rosemead. Accomplishments to Overcome Potential Impediment: • Submitted public service announcements regarding fair housing laws. -9- • Published articles on current fair housing topics in the Rosemead Resources Newsletter and on the City's website. Housing Discrimination Complaints Based on Familial Status Potential Impediment: The highest number of housing discrimination complaints by Rosemead residents have been based on familial status. This may indicate a need for more education of landlords on families with children and fair housing. Accomplishments to Overcome Potential Impediment: • Published articles on current fair housing topics in the Rosemead Resources Newsletter and on the City's website. • Distributed literature to Rosemead property owner and managers that explain the fair housing law that protects people with children under 18. Audit Testing The HRC conducted 20 phone tests to measure levels of housing discrimination in the City of Rosemead. Of this number, 10 were used to measure discrimination against people with disabilities and 10 were used to measure familial status discrimination (presence of children under 18). Disability Discrimination Potential Impediment: The HRC found that 50% of the disability phone tests showed evidence of discrimination against people with disabilities. Some examples of discrimination by property owners/mangers include not allowing service/guide dogs, requiring a "pet deposit" for service/guide dogs and discriminatory statements to discourage people with disabilities from applying for an available unit. These tests may indicate intentional discrimination against people with disabilities. They may also indicate a lack of awareness of the fair housing laws that protect people with disabilities from housing discrimination. Accomplishments to Overcome Potential Impediment: • Conducted one (1) workshop for Rosemead property owners and managers and one (1) workshop for Rosemead residents that included focusing on the disability provisions of the fair housing law. • Distributed literature on discrimination against people with disabilities to Rosemead property owners and managers. • Built collaborations with disability rights advocates to educate their clients on their right to equal housing opportunity. Familial Status Discrimination Potential Impediment: The HRC found that 40% of the familial status phone tests showed evidence of discrimination against people with children under the age of 18. These tests showed that property owners/managers gave higher security deposits, steering to first floor units, and flat- out denials of housing to people with children. Similar to the disability tests, this could indicate intentional discrimination against people with children under 18. They may also indicate a lack of awareness of the fair housing laws that protect people from being discriminated against because they have children in the household that are under 18. -10- Accomplishments to Overcome Potential Impediment: • Conducted one (1) workshop for Rosemead property owners and managers and one (1) workshop for Rosemead residents that included focusing on the familial status provisions of the fair housing law. Distributed literature to Rosemead property owner and managers that explain the fair housing law that protects people with children under 18. Built collaboration with Rosemead schools to distribute fair housing information to parents. Marital Status Discrimination Potential Impediment: The HRC found that 40% of the phone tests showed evidence of discrimination against people based on their marital status. The discrimination took the form of occupancy limits that may be overly restrictive and differential treatment of married and unmarried couples in the amount of the credit check fee. Interesting to note is that the HRC was not testing for marital status discrimination. Accomplishments to Overcome Potential Impediment: • Conducted one (1) workshop for Rosemead property owners and managers and one (1) workshop for Rosemead residents that included focusing on the marital status provisions of the fair housing law. • Distributed literature that explains the fair housing law that protects people from discrimination based on marital status. Community Survey The HRC also conducted a survey of 32 Rosemead residents. The participants of the survey were individuals who are currently residents of the City of Rosemead. The respondents were randomly chosen from the Yahoo! Yellow Pages. The goal of the survey was to measure awareness of the fair housing laws and the level of housing discrimination experienced by Rosemead residents. Awareness of the Fair Housing Laws Potential Impediment: The survey showed that 47% of respondents had no knowledge of the fair housing laws and 34% had very little knowledge of the fair housing laws. According to the 2000 census, the population of Rosemead is 53,505. From July 1, 2000 to February 28, 2005 the Housing Rights Center assisted 955 Rosemead residents, which represents 1.8% of the total population. The low level of awareness of the fair housing law may indicate the need for increased education and outreach activities in Rosemead. Accomplishments to Overcome Potential Impediment: • Conducted a fair housing awareness campaign for fair housing law (including familial status, disability, sexual harassment, etc.). • Increased literature distribution within the City. • Partnered with social service agencies that serve Rosemead residents to coordinate fair housing presentations for their clients. -1]- Rosemead Zoning Ordinance HRC reviewed provisions of the Rosemead Municipal Code ("RMC"), specifically Title 15 (Building and Constriction) and Title 17 (Zoning), for compliance with state and federal fair housing laws. Overly Restrictive Definition of Family Potential Impediment: Section 17.04.020 of the Rosemead Zoning Code has an overly restrictive definition of family. This definition restricts the housing choices of individuals with disabilities because it places numerical limits on unrelated person. The definition of "family" must emphasize the functioning of the members as a cohesive household and cannot distinguish between related and unrelated persons. Accomplishments to Overcome Potential Impediment: • Prepared anew definition of family to be included in the amended zoning code. Definitions of Bachelor Apartment Potential Impediment: Section 17.04.020 of the Rosemead Zoning Code defines a bachelor apartment as "[A]n apartment of dwelling unit in a multiple dwelling or apartment house, occupied or suitable for occupancy as a residence for one person." This occupancy limit could lead property owners to discriminate against families with children or couples in violation of federal and state fair housing laws. Accomplishments to Overcome Potential Impediment: • Removed the definition of a bachelor apartment from the zoning code. Reasonable Accommodations Potential Impediment. Pursuant to fair housing laws and also the Americans with Disabilities Act ("ADA"), the City of Rosemead should provide for reasonable accommodations for persons with disabilities. Accomplishments to Overcome Potential Impediment: • Prepared a notation for the off-street parking and nuisance abatement ordinances that explains that accommodations are available to people with disabilities. • Prepared an accommodation application procedure The analysis of impediments to fair housing choice in any community is a delicate and tedious process. The City recognizes the effect that discrimination has in limiting housing choice and equal opportunity in renting, selling, and financing housing. During the 2009-10 FY, the City will continue to address the potential impediments identified in the City's Al. By addressing these issues, the City hopes to take incremental steps toward overcoming and eliminating all the impediments identified in the City's Al. By contracting with a Fair Housing Organization to implement a Fair Housing Program within Rosemead during the 2009-10 FY, the City hopes to provide an extensive and comprehensive community education program to inform the community about fair housing laws. This will allow the City to make a significant impact in affirmatively furthering the goal of fair housing choice. -12- During the 2009-10 FY, the City will also make a significant impact in affirmatively furthering fair housing and eliminating impediments to fair housing choice by offering housing programs without impediments based on race, color, religion, sex, disability, familial status, or national origin. The City continually increases the awareness of the availability and benefits of City programs regarding housing choice and housing assistance through public information to the community. This information is distributed to the community in a number of ways, including notices placed in newspapers and on the City's newsletter. This proves to be a positive impact on the community by ensuring that the community is aware of the different services provided by the City of Rosemead. The City of Rosemead has a well established plan to continue making a significant effort toward affirmatively furthering fair housing and eliminate impediments to fair housing choice that are within its authority during the period of July 1, 2009 to June 30, 2010. The City has an ongoing commitment to preventing, reducing, and ultimately eliminating housing discrimination and other barriers related to equal opportunity in housing choice. C. Affordable Housing 1. Patterns of actual investment compared to planned investment patterns Investment during the period of July 1, 2008 to June 30, 2009 occurred as planned. The planned investment in the community included owner-occupied single-family home rehabilitation, rental assistance, new construction of non-rehabable housing units, first-time homebuyer, and CHDO participation. a. Moderate Rehabilitation The City has utilized the aforementioned federally funded housing programs to meet the communities housing needs. Through the CDBG program, Block Grant money as well as program income (loan paybacks) were used to assist owner/occupants in making improvements to their homes and eliminate substandard conditions. Forty (40) households received assistance for the period of July 1, 2008 to June 30, 2009, as summarized herein: PROGRAM GOAL ACTUAL Rebate Program 0 Grant Program 20 14 Emergency Grant Program 3 Lead/Asbestos Testing 20 12 Lead/Asbestos Remediation 15 11 TOTAL 55 40 b. Substantial Rehabilitation During the 2008-09 FY, the City operated an Owner-Occupied Rehabilitation Program with HOME Investment Partnership funds received by the Federal government. This program provided low interest (0 to 3%) deferred payment loans to seniors, persons with a disability and families of low and moderate income who own and occupy their homes and need financial assistance to make repairs and -13- improvements. The loan is secured by the Deed of Trust and payment is deferred until the sale, transfer of ownership, refinancing of the home, or 30 years from the date shown on the signed Deed of Trust and Promissory Note. Interest is calculated at 0% for senior citizens (62 years and older) and handicapped/disabled citizens and 3% simple interest rate for all others based on the principal owed. These loans may be used for both exterior and interior property improvements. All improvements must be approved by the City of Rosemead's Community Development Department prior to the work being done. All improvements must be done by a contractor who is properly licensed through the State of California and the City of Rosemead. The program complements the City's on-going CDBG funded housing rehabilitation programs that address less serious repair and maintenance needs. A total of 10 applicants were funded during the FY 2008-09 and a total of 5 loans were completed during this time period. c. Tenant Assistance Section 8 Voucher funds were used to provide rental assistance to very low- income (0 to 50% of MFI) residents within the City. The Housing Authority of the County of Los Angeles (HACoLA) serves the City of Rosemead and provides Section 8 assistance to the residents. d. New Construction There was no new construction of housing units during the FY 2008-09. e. First-Time Home Buyer Mortgage Assistance During the 2008-09 FY, the City continued its involvement in the First Time Homebuyer Program. The City provided HOME funds to assist low income residents with the purchase of their first home. The assistance was in the form of a silent second loan (no payments until the home is sold, transferred in ownership, refinanced or 30 years from the loan origination), and was available to low income families who have not owned a home within the previous three years. The amount of the loan varied depending on the value of the house to be purchased to assist the homebuyer in achieving a 25% down payment. The maximum allowable loan is currently $70,000. The cost of the property cannot exceed 95% of the area median purchase price as established by HUD or approved by HUD. The current limit for a single-family residence is $475,000 and for a condominium/town home unit the limit is $394,250. While the goal of the Program is to encourage long-term homeownership, the City recognizes that in some instances a Participant may wish to sell his or her home. Under the Program, there are no restrictions on the amount the home may be sold for after the expiration of the fifteen-year affordability covenant. However, if the Participant wishes to sell his or her property, the Participant must repay all outstanding principal, any equity share and/or interest. The City funded one (1) applicant during the FY 2008-09. -14- Community Housing Development Organization (CHDO) During the FY 2008-09, the City entered into an Agreement with Rio Hondo Community Development Corporation (RHCDC) for the production of affordable housing using the 15% CHDO set-aside funding as required under the Home Investment Partnerships (HOME) entitlement grant. The City did not approve any new projects during the FY 2008-09. It is anticipated that the City will complete at least one project with RHCDC during the FY 2009-10. g. Section 215 The City of Rosemead assisted in the creation of 1 home ownership units through the First Time Homebuyer Program and 1 rental unit through the CHDO program. 2. Efforts to Address Worst Case Needs Worst case housing needs are defined as low income (0 to 50% of MFI) renter households who pay more than half their income for rent, live in seriously substandard housing (which includes homeless people) or have been involuntarily displaced. In an effort to address worst case housing needs, a number of programs and services were offered during the FY 2008-09. These include the following: i People for People The City, through it CDB Program, entered into a contract with People for People to provide short-term services (food) directly. Its primary purpose is to assist the needy residents of the City. The group is made up of volunteers that raise funds year-round to provide distribution of food to families. i Section 8 Housing Assistance Agency The Housing Authority of the County of Los Angeles (HACoLA) serviced the City of Rosemead and provided Section 8 assistance to the residents. The primary objective of the Section 8 Voucher Rental Assistance program is to assist low-income (0 to 50% of MFI) persons and households, including those who are homeless or in danger of becoming homeless, in making rents affordable. i YWCA (Wings) The YWCA provided emergency shelter for women and children who become homeless as a result of domestic violence. Services include 24-hour access to emergency housing and crisis hotline, food and basic personal items, crisis support and advocacy, counseling and support groups, medical and legal advocacy, and specialized children's services. It should be noted that many other service providers within the City, who do not receive CDBG funds, provide assistance to households with high rent burdens, living in substandard conditions (including homeless) or who have been involuntarily displaced (see Continuum of Care Narrative section). The City of Rosemead offers rehabilitation assistance to owner-occupied single family units. Grants, emergency grants, and deferred loans are available to handicapped households. Eligible improvements include retrofit activities. In FY 2008-09, the City of Rosemead served 3 handicapped/disabled households through its Owner-Occupied Residential Rehabilitation Program. 15- D. Continuum of Care Narrative 1. Homeless Due to the lack of information from the Census 2000, the information concerning the nature and extent of homelessness in Rosemead comes from an analysis of secondary research sources (such as Federal agencies and national non-profit organizations). In December of 1993, the Los Angeles County Board of Supervisors and the Mayor and City Council of Los Angeles created the Los Angeles Homeless Services Authority (LAHSA). LAHSA provides funding and guidance for a vast network of local, non-profit agencies with missions to help people leave homelessness permanently. These agencies are dedicated to providing as much assistance as feasible to help homeless persons with housing, case management, counseling, advocacy, substance abuse programs, and other specialized services. The City is a member of the San Gabriel Valley Homeless Coalition and participates in the Countywide Continuum of Care through the Los Angeles Homeless Service Authority for HUD SuperNOFA funds. In this capacity, the City staff attends meetings of social service providers, supplies information to the umbrella organization responsible for coordinating the continuum, and receives information from them. In addition, the City works with public service agencies and others to identify services and service gaps in the community to ensure that citizens looking for services are referred to agencies that can be of the most assistance to them. As part of SPA-3 for homelessness, the City participates in the Los Angeles Service Authority (LAHSA) plan to eliminate homelessness by 2012. In 2005, the City's Community Development Department, in conjunction with Code Enforcement and the Los Angeles County Sheriff s Department, undertook a homeless count night. Potential sites were identified in advance as locations for the homeless. A homeless count was conducted at these sites, along with follow-up sites during the evening hours. As a result, staff encountered seven (7) persons at the twenty sites visited. All of these persons stated that they were homeless. Of these, three (3) were female and four (4) were male. Four (4) identified themselves as White, while three (3) identified themselves as Hispanic. They ranged in age from 32 to 63 years of age. The majority reported that they had alcohol or substance abuse issues, while three (3) were disabled. Homelessness ranged from 1 week after leaving a correctional facility to ten years or more. All respondents' received information regarding services, although the majority stated they didn't know if they would follow-up. This is the City's third homeless count since 1999. In the first count, eight (8) persons were found, of which four (4) stated they were homeless. Three (3) had alcohol/substance abuse problems and two (2) were mentally disabled. All declined services. In addition, in 1999, the Urban Research Group conducted a survey of homelessness in the San Gabriel Valley. It identified 18 persons who had requested services. Nine (9) of those persons lacked a permanent address. The homeless population was estimated at between 13 and 16. This represented a decline from the 1990 Census in which 20 individuals and one (1) family were identified as homeless. In the homeless count conducted in 2002, staff found four (4) persons, two (2) of whom claimed to be homeless and unsheltered, one (1) who was unresponsive, but appeared to be unsheltered and one (1) whom was intoxicated and sleeping. -16- Based on the three (3) counts, unsheltered homelessness within the City has remained low and fairly constant since a decline after the 1990 Census. It has ranged from approximately 16 to a low of 4. In response to homelessness, the City's Community Development Department, Housing Services Division, are responsible for responding to the homeless in a positive way to ensure that their needs are met. The City's Housing Services Division has provided staff with instructions to direct the needy and homeless to an agency or provider that meets its needs. On average, there are five or less requests for assistance per year. During the 2008-09 FY, the following support services continued to be available to Rosemead residents through the following agencies and service providers: 211 LA County: 211 LA County is dedicated to providing an easy-to-use, caring, professional source of guidance, advocacy, and 24 hours 7 days per week access to a comprehensive range of human services to the people of Los Angeles County. In addition, 211 LA County also has special contracts to operate the Cold Weather Shelter Hotline for the County of Los Angeles, and provides staffing and human services information for emergency centers during disasters. r Catholic Rainbow Outreach: Provides shelter and rehabilitation for men with drug and alcohol abuse problems. This shelter has 13 beds that are available. ➢ Down Payment Assistance Program: The City of Rosemead has funds available to assist low income residents with the purchase of their first home. The assistance is in the form is a silent second loan (no payments until the loan is paid or until 30 years from the loan origination), and is available to low income families who have not owned a home within the previous three years. The amount of the loan will vary depending on the value of the house to be purchased to assist the homebuyer in achieving a 25% down payment. The maximum allowable loan is currently $70,000. i Los Angeles Homeless Service Authority (LAHSA): LAHSA Emergency Response Teams (ERT's) are available to assist residents Monday through Friday from 8:00 a.m. to 5:00 p.m. LAHSA ERT's offer outreach services to homeless encampment dwellers, emergency services and shelter referrals to homeless families and unaccompanied adults and youth, direct emergency services and transportation, and emergency assistance and referrals to social service agencies for people in the County of Los Angeles who are homeless or at risk of experiencing homelessness. i People for People: Provides short-term services (food) directly. Its primary purpose is to assist the needy residents of the City. The group is made up of volunteers that raise funds year-round to provide distribution of food to families. ➢ Section 8 Housing Assistance Agency: Provides rental assistance through the Federal Section 8 Voucher program. The primary objective of the Section 8 Voucher Rental Assistance program is to assist low-income (0 to 50% of MFI) persons and households, including those who are homeless or in danger of becoming homeless, in making rents affordable. The Housing Authority of the County of Los Angeles (HACoLA) serves the City of Rosemead and provides Section 8 assistance to the residents. i The San Gabriel Pomona Valley Chapter of the American Red Cross: Provides emergency shelter for people who become homeless because of natural disasters. -17- i The Salvation Army: Provides a variety of services including shelter service for men and women focusing on substance abuse treatments and halfway houses, provides residential long-term treatment for persons with co-occurring mental and substance abuse disorders, overnight shelter, food, shower facilities, and case management to homeless persons. The Southern California Housing Rights Center: Provides counseling assistance to families at risk of homelessness. ➢ YWCA Wings: Provides emergency shelter for women and children who become homeless as a result of domestic violence. Services include 24-hour access to emergency housing and crisis hotline, food and basic personal items, crisis support and advocacy, counseling and support groups, medical and legal advocacy, and specialized children's services. If an individual or family was unable to be assisted immediately by one of the previously mentioned organizations, they were referred to the Info Line organization in order to be able to access either the Los Angeles County Voucher Program or other non-local shelters. Overall, the City has not experienced an overwhelming population of homeless persons and has not experienced an outpouring of public concern to provide additional services within its boundaries. Social service agencies and providers within Rosemead and adjacent communities (where nearly all major services are provided) have not expressed that there is an extraordinary need to provide emergency shelters within Rosemead, as adequate facilities are available nearby and are not always filled to capacity. The City was willing to consider amending the Municipal Code to permit emergency shelters by conditional use permit, and transitional housing by right, in the MFR (Multiple Family Residential) zone, assist developers and/or providers in the procurement of land, off-site improvements and/or financing for the construction of emergency shelters and/or transitional housing, and assist developers and/or providers in the purchase and rehabilitation of existing structures for transitional housing. However, no requests were received during the 2008-09 FY The City was willing to review and possibly support applications for programs and resources from eligible non-profits and other entities when Federal and/or State funding is limited to such entities. However, no requests were received during the 2008-09 FY The City was also willing to consider supporting the efforts of non-profit agencies that apply for funding to locate transitional, supportive, and permanent housing facilities within the City. For Fiscal Year 2008-09, the City did not receive any requests. a. Housing and Services for Transition to Permanent Housing and Independent Living During the 2008-09 FY, the City worked with the San Gabriel Valley Homeless Consortium to locate housing and services for transition to permanent housing and independent living when requested. -18- b. Permanent Housing and Services for Those Not Capable of Achieving Independent Living During the FY 2008-09, the City continued to join with other cities and organizations in the San Gabriel Valley Area to place the need for such services before the County, State and Federal government and private organizations. The City continued its affiliation with the San Gabriel Valley Homeless Consortium. c. Permanent Affordable Housing Opportunities for Persons who Successfully Complete a Transitional Housing Program During the 2008-09 FY, the City worked with the San Gabriel Valley Homeless Consortium and the Housing Authority of the County of Los Angeles to provide homeless families with a source of permanent, affordable housing that otherwise would not be available to them. In addition, in working with the San Gabriel Valley Homeless Consortium, the City would work with services, when available, that assisted with security deposits and utility connection fees for homeless families attempting to secure long-term rental housing. d. Assistance for Preventing Low Income Individuals and Families with Children (Especially Those with Incomes Below 30% of Median Family Income) from Becoming Homeless. During the FY 2008-09, the City continued to work with the Housing Authority of the County of Los Angeles to provide needed affordable housing in the area of Section 8 Vouchers. 2. Population with Special Needs - Other Than Homeless Certain segments of Rosemead's population have specialized housing needs. These groups generally are in need of housing assistance of one form or another, which may or may not be typical for the total needs of the City. These groups include elderly households, persons with disabilities, large families, female headed households, persons with alcohol or other drug addictions, and persons diagnosed with AIDS and related diseases. During the 2008-09 fiscal year, the organizations identified below continued to address special needs populations through a variety of services. The City supported the activities of these entities as critical partners who helped respond to the housing and service needs of low- income special needs populations. It was also the City's intention to support the efforts of non-profit agencies that apply for funding to locate housing facilities that serve persons with special needs within the City. For fiscal year 2008-09, the City did not receive any proposals that would work toward meeting this goal. There are several organizations/services that addressed special needs populations and were offered to all residents of Rosemead as shown below. 211 LA County: 211 LA County is dedicated to providing an easy-to-use, caring, professional source of guidance, advocacy, and 24 hours 7 days per week access to a comprehensive range of human services to the people of Los Angeles County. ➢ Down Payment Assistance Program: The City of Rosemead had funds available to assist low income residents with the purchase of their first home. The assistance is in the form is a silent second loan (no payments until the loan is paid or until 30 years from the loan origination), and is available to low income families who have not owned a home within the previous three years. The amount of the loan will vary depending on the value of the house to be purchased to assist the homebuyer in -19- achieving a 25% down payment. The maximum allowable loan is currently $70,000. ➢ East Valley Community Health Center: Provided free immunizations, medical examinations, HIV testing and low cost health services. ➢ Fair Housing Organization: The City provided landlord/tenant information and assistance through a contract with a Fair Housing Organization. ➢ Garvey Community Center/Rosemead Community Recreation Center: These centers provided a wide variety of activities including counseling services, social service programs, recreational programs, and information and referral services. ➢ LACountyHelps: LACountyHelps is a free and easy resource to find out if your family can get help from 26 different health and human services programs. ➢ Owner-Occupied Rehabilitation Programs: Households who own and occupy their home were able to apply for one of the Owner-Occupied Rehabilitation Programs offered by the City. Through these programs, funds were available to assist low and moderate-income (0 to 80% of MFI) homeowners in making needed rehabilitation improvements and upgrades to their single-family residence. Funds for these programs were limited and allocated on a first-come, first-served basis. The various programs the City offered were as follows: Loan Program, Emergency Grant Program, Grant Program, and Rebate Program. ➢ Housing Authority County of Los Angeles County: Provided rental assistance to the residents of Rosemead through the Federal Section 8 Voucher program. The primary objective of the Section 8 Voucher Rental Assistance program is to assist low-income (0 to 50% of MFI) persons and households, including those who are elderly and frail elderly, in making rents affordable. ➢ People for People: People for People was established to coordinate the acquisition and distribution of emergency food supplies by working through its member food agencies for low-income Rosemead residents who are at risk of homelessness. Elderly and Frail Elderly Many organizations and facilities provide services to the elderly throughout the County of Los Angeles. The list below identifies the organizations that offer services to the elderly and frail elderly of Rosemead and the types of services provided. ➢ Angelus/Garvey Senior Housing: There are presently two apartment complexes in Rosemead which are rented exclusively by low-income seniors (Angelus and Garvey Senior Apartments). There is only one (1) waiting list for both senior apartment complexes. Angelus Senior Apartments is made up of 50 1-bedroom units and Garvey Senior Apartment is made up of 64 1-bedroom units and 6 2-bedroom units. Congregate Meal Program for the Elderly: This service, which is sponsored by Volunteer Center of San Gabriel Valley, provided low-cost, nutritious meals to person who are 60 years and older. ➢ Dial-A-Ride: Free transportation service (Dial-A-Ride) was provided to senior residents as well as disabled residents. The program provided curb-to-curb transportation services for seniors, age 60 and older, and for people who have disabilities who are residents of Rosemead. Transportation was available to any destination in Rosemead for any type of trip including medical appointments, educational/recreational activities, shopping, and visits to friends and family. Transportation was also available, at no cost, for travel outside the City, a distance of five miles from City Hall, for medical or social service appointments. The City also -20- offered subsidized bus fare for the seniors through a contract with the Metropolitan Transit Authority (MTA). I i Senior Nutrition Program: The Senior Nutrition Program provided high quality, cost efficient, nutritious meals at two City locations (Garvey Community Center and Rosemead Community Center) to seniors living in Rosemead and promotes the role of nutrition in preventative health and long term care. ➢ Vietnamese American Senior Association: The Vietnamese American Senior Association helps Vietnamese seniors lead a happy and independent life by making sure that they have access to healthcare, social service, and recreational resources that they otherwise may not have access to due to language barriers. Persons with Disabilities The organizations and facilities listed below offered services to persons with physical and/or mental disabilities who reside in the City of Rosemead. ➢ Community Advocates for People's Choice (CAPC): CAPC, Inc. is a non-profit social service agency that served disabled adult Rosemead residents by providing supported employment, supported living, independent living, and community inclusion services. r Congregate Meal Program for the Disabled: This service, which is sponsored by Volunteer Center of San Gabriel Valley, provided low-cost, nutritious meal to disabled person. i Dial-A-Ride: Free transportation service (Dial-A-Ride) was provided to senior residents as well as disabled residents. The program provided curb-to-curb transportation services for seniors, age 60 and older, and for people who have disabilities who are residents of Rosemead. Transportation was available to any destination in Rosemead for any type of trip including medical appointments, educational/recreational activities, shopping, and visits to friends and family. Transportation was also available at no cost for travel outside the City, a distance of five miles from City Hall, for medical or social service appointments. The City also offered subsidized bus fare for seniors through a contract with the Metropolitan Transit Authority (MTA). Intercommunity Blind Center: Intercommunity Blind Center focuses on integrating the blind and visually impaired youth and adults into all aspects of the sighted world. Its purpose is to reach out to these individuals and their families and link them with the educational, recreational, vocational, social, and counseling opportunities offered by the Center, at no cost to the client, thus improving their quality of life. Intercommunity Child Guidance Center (ICGC): ICGC provided children, adolescents, and families in the community with affordable, culturally-sensitive, and professional mental health services which included crisis intervention, parenting education, child abuse prevention, mental health services, student training, foster care assessment, psychological counseling, and medication management. ➢ Metro Access: Metro Access was also available to those individuals whose disabling conditions fluctuate, or when weather or environmental factors prevent them from using the regular bus system. The purpose of the Metro Access is to ensure that safe, dependable transportation is available for individuals who truly cannot, because of their disability, use other types of public transportation. -21- ➢ Southern California Rehabilitation Services: Southern California Rehabilitation Services' mission is to empower persons with disabilities with the knowledge, skills, and confidence needed to achieve full participation in the community and the ability to promote opportunities for independence. Services included in-home service registry, housing assistance, peer counseling, independent living skills training, job development, information and referrals, and training on the Americans with Disabilities Act. Large Families The organizations and facilities listed below offered services to large families who reside in the City of Rosemead. ➢ Family Counseling: Family Counseling provided low-cost crisis intervention and crime prevention services to youth under the age of 18 and their families who meet certain income requirements. Professionally trained and licensed counselors offered help with substance abuse, addictions, psychotherapy and intervention. Female-Headed Households The organizations and facilities listed below offered services to female-headed households who reside in the City of Rosemead. ➢ YWCA Wings: Provides emergency shelter for women and children who become homeless as a result of domestic violence. Services include 24-hour access to emergency housing and crisis hotline, food and basic personal items, crisis support and advocacy, counseling and support groups, medical and legal advocacy, and specialized children's services. Persons with Alcohol or Other Addictions The organizations and facilities listed below offered services to persons with alcohol or other addictions who reside in the City of Rosemead. ➢ L.A. Center for Alcohol & Drug Abuse (L.A. CADA): L.A. CADA provided programs to help clients stop using drugs and alcohol. The agency offered both outpatient and in-home services. Substance abuse rehabilitation and educational programs were available, along with individual and family counseling and anger management training. Services offered included drug and alcohol rehabilitation for teens and adults, live-in drug rehabilitation for mothers, parenting classes, drug awareness education, counseling, and family reunification. ➢ Southern California Alcohol and Drug Programs (SCADP): SCADP offered residential recovery programs and outpatient programs for men and women to overcome substance abuse. Persons Diagnosed with AIDS and Related Diseases The organizations and facilities listed below offered services to persons diagnosed with AIDS and related diseases who reside in the City of Rosemead. ➢ L.A. Center for Alcohol & Drug Abuse (L.A. CADA): L.A. CADA provided AIDS awareness and HIV outreach programs. ➢ Southern California Alcohol and Drug Programs (SCADP): SCADP offered services for people living with AIDS or HIV. -22- E. OTHER ACTIONS 1. Addressing Obstacles to Meeting Undeserved Needs, Fostering and Maintaining Affordable Housing During the FY 2008-09, the City of Rosemead faced a number of obstacles in meeting affordable housing and community development needs and underserved needs through the CDBG and HOME program which included lack of affordable land for housing development, funding constraints to address community development needs, and continued reductions for CDBG, HOME, and other federal funding sources in each fiscal year. The City continued to look for non-traditional ways to develop affordable housing units and meet community development needs; work to combine funding sources and leverage private funds to develop affordable housing; and, to work with the federal government to ensure that sufficient funding continues in order to meet needs. The City of Rosemead tried to foster and maintain affordable rental and owner-occupied housing through the initiatives identified below. Successful implementation of these efforts relies on the collaborative effort of many community partners including public agencies, government, housing developers, non-profit agencies, and neighborhoods. The City used its own City newsletter, as well as community events to promote these services, and to promote its housing and community service programs: F.osterin and Maintainin Decent Affordable Standard Housin Administering Funding Target Population/ Activity / Description Agency Source Geographic Area RENTER HOUSEHOLDS Purchasing Assistance Activities Down Payment Assistance Program - The City of Rosemead had funds available to assist low income residents with the purchase of their first home. The assistance was in the form is a silent second loan (no payments until the loan is paid or until 30 years from the loan origination). and is available to low income families who have not owned a home City of Rosemead HOME < 80% MFI within the previous three years. The amount of the City o(Rosemead loan varied depending on the value of the house to be purchased to assist the homebuyer in achieving a 25% down payment. The maximum allowable loan was $70.000. Rental Subsidy Activities Housing Choice Voucher Program-This program Housing Authority County of Los Federal Section 8 <50%MFI provided rental assistance. Angeles City of Rosemead Fair Housing Activity Fair Housing Counseling Program -This program o MFI provided information to property owners and City of Rosemead CDBG City y of of Rosemead tenants about their rights and responsibilities. Loan Program -The City provided low interest (0 to 3%) deferred payment loans to low and moderate income homeowners who owned and occupied their homes and needed financial City of Rosemead HOME <80%MFI assistance to make repairs and improvements. The City of Rosemead loan is paid back through the sale. transfer of ownership. or refinancing of the home. -23- F.ostecin and Maintainin 21 Decent Affordable Standard Housin Administering Funding Target Population/ Activity /Description Agency Source Geographic Area OWNER HOUSEHOLDS Moderate and Substantial Rehabilitation Activities Eligible Low and Code Enforcement City of Rosemead CDBG Moderate Block Groups Citv of Rosemead Design Assistance - Staff planners and plan checkers were available during the regular City N/A Hall business hours to assist homeowners with City of Rosemead General Fund City of Rosemead property improvement questions. Grants Program - Grants were available to senior citizens (62 years or older) and disabled citizens for up to $ 10,000, at no cost to the homeowner. for City of Rosemead CDBG < 80% ME] repairs related to interior and exterior code City of Rosemead deficiencies and general home improvements. Emergency Grant Program - Emergency grants were available to all eligible income qualified applicants. The maximum emergency grant was Cit v of Rosemead CDBG <80%MEI $2,000 for corrections to emergency code _ City of Rosemead deficiencies that constitute an immediate health- safetv issue. Rebate Program - Rebates were available to income eligible homeowners, for correction of code deficiencies and general home improvements to the exterior of the house. Fifty percent (50%) City of Rosemead CDBG < 80%MFI rebates up to $15,000 were available from the City City of Rosemead after the homeowner satisfactorily completed the work and a yments to contractors. 2. Eliminating Barriers to Affordable Housing The City of Rosemead is committed to addressing the negative effects of public policies over which it has control. In order to promote integration and prevent low-income concentrations, the City designed its affordable housing programs to be available Citywide. This priority also serves to make sure that the City does not have any policies, rules, or regulations that would lead to minority or racial concentrations. Over the years, Rosemead has demonstrated a willingness to encourage housing development of all types. It has approved several zone changes and Code amendments to allow for development of a variety of housing types, including those that benefit low and moderate- income people. It also makes an effort to fast-track projects and process permits in a timely manner. During the FY 2008-09, the City maintained its current posture of openness and willingness to entertain new ideas and eliminate any regulatory barriers under its control in the provision of a variety of housing to meet the needs of all income groups. -24- In addition, during the FY 2008-09, the City continued to work cooperatively within existing legislatively mandated constraints and worked to develop and/or encourage public policies that foster further affordable housing development and assistance. 3. Overcoming Gaps in the Institutional Structure and Enhancing Coordination The implementation of the FY 2008-09 Action Plan was highly dependent upon the support and cooperation of numerous levels of government and the private sector, including for-profit and non-profit organizations. In order to eliminate gaps in institutional structures and to enhance coordination, the City remains actively involved with outside agencies and regional governmental entities, especially in the area of economic development. The City of Rosemead is governed by a five-member City Council. The City Council approved the funding priorities, was responsible for holding the hearings, and was responsible for approving the submission of the City's FY 2008-09 Action Plan. The City of Rosemead's Community Development Department is the lead agency in the coordination of the Action Plan and the CAPER. It coordinated the redevelopment and economic activities of the City, developed and implemented the programs that rehabilitate and preserve the neighborhoods in the City, and developed and rehabilitated affordable housing during the 2008-09 FY. As a lead agency, it was responsible for coordinating with any agencies and organizations receiving CDBG or HOME program funds. While the Community Development Department had the major responsibility for budgeting, project formulation and program implementation of the CDBG and HOME grant for the 2008-09 FY, other city departments played an important role as well. As shown below, there were several inter-departmental programs, primarily in the area of neighborhood quality of life that were composed of a wide variety of city agencies. All were funded through the CDBG and/or HOME program during the 2008-09 FY as a funding source; but in many cases, departmental funds and other funding augment and leveraged these funds. • City of Rosemead's Community Development Department • City of Rosemead's Finance Department • City of Rosemead's Recreation and Community Services Department • City of Rosemead's Public Works Department • City Attorney • Los Angeles Sheriffs Department • U.S. Department of Housing and Urban Development • State of California's Department of Housing and Community Development • Other local agencies • Non-profit organizations • Private sector owners In addition, the City was an active member of the following intergovernmental organizations: San Gabriel Valley Commerce and Cities Consortium; San Gabriel Council of Governments; the Southern California Association of Governments; California League of Cities; Contract Cities during the FY 2008-09. In the area of economic development, the City works with and/or is a participating entity with the following: 1) the Regional Business Assistance Network, 2) the Chamber of Commerce, 3) the San Gabriel Valley Community Development Corporation. -25- During the 2008-09 FY, the structure of the CDBG and HOME programs were decentralized. While the Community Development Department administered several program activities, including several housing rehabilitation programs, other project activities were administered by sponsoring departments and city-related agencies. Guidelines for expenditure of CDBG and HOME funds were provided as needed or changes in the program occur. The Community Development Department provided departments and city-related agencies with training in HUD grant regulations as needed or requested. There were many organizations that actively collaborated in the areas of housing, homeless services, community and economic development. The City, for its part, promoted and encouraged fair housing, housing assistance and single-family home rehabilitation through: • Continued utilization of the services of a fair housing organization to promote, educate and enforce fair housing in the community. • Continued working with the Housing Authority County of Los Angeles to implement its Section 8 Rental Assistance Program for the residents of Rosemead. • Continued use of CDBG, HOME, Redevelopment and State funds to assist low and very low-income homeowners in rehabilitating their homes and in eliminating substandard conditions. The City will continue to encourage the different rehabilitation programs through the use of advertising in Rosemead Resources. • Continued use of the Salvation Army and YWCA-Wings to provide shelter services for the citizens of Rosemead as needed. One of the biggest challenges the City of Rosemead faced during the 2008-09 FY was the lack of or ever decreasing amount of funds available in maintaining and furthering housing and community development goals. The City continually look for and/or applied for funding from the County of Los Angeles, the State of California and the Federal government that would assist the City in meeting its housing and community development goals. A related challenge was the need for better coordination and cooperation between the City and social service and health providers. For homeless activities, a seamless approach to provision of transitional and permanent housing services requires that such providers be actively involved in each facet of the Continuum of Care. The City participated with the Los Angeles Homeless Services Authority (LAHSA) for SPA 3 and with the East San Gabriel Homeless Coalition, as part of the regional Continuum of Care. Other housing activities, such as rehabilitation, demolition of abandoned or hazardous units, acquisition of sites for potential single family and multifamily affordable housing, home ownership assistance and new construction continue to need to be integrated within the social service and health provider community as well. The key to the City's strong institutional structure was the ability to develop and share data on the progress and status of beneficiaries through the development of integrated information systems. There were several data information systems in place that, to various degrees, track the progress of a variety of beneficiaries from initial intake, through provision of services, and to completion of participation. For example, the LAHSA committed itself to a five-year developmental plan for the Homeless Management Information System (HMIS). A primary goal is to integrate the HMIS with other databases in sharing of commonly needed information. -26- Institutions playing a major role in delivery of community development programs often had different mandates, and consequently different priorities and strategies to achieve them. These mandates are most often imposed by Congress, and reflected through the regulations of federal funding agencies. In several cases, goals could have overlapped or been in conflict with the City's goals. A major obstacle to delivery of services through a variety of institutions was the continuing trend in reduction of federal and state funds for a variety of needed programs. In addition, foundation giving has declined. While the primary actors in the grant process are the City Council and the Community Development Department, there were a significant number of city agencies and departments that oversaw a wide variety of grants and programs that provided services to low- and moderate-income city residents, and played an important role in implementing the CDBG and HOME program during the 2008-09 FY. 4. Improving Public Housing and Fostering Resident Initiatives There are no public housing developments in the City. Consequently, this section does not apply. 5. Evaluating and Reducing Lead-Based Paint Hazards As of FY 2001-02, the City of Rosemead began implementing the new HUD Lead Based Paint Regulations (Title X), which requires all federally assisted housing programs, including rehabilitation, homeownership and tenant-based subsidy systems, to address lead hazards. During the 2008-09 FY, the City continued its program of education and eradication of lead- based paint through the operation of its Owner-Occupied Rehabilitation Programs and Down Payment Assistance Loan Program. These two programs provided assistance to low-income homeowners; the target groups most likely to be living in older housing with lead-based paint. The City also had procured the service of a State Certified Lead Consultant to provide the following services: • Lead-based paint and soil inspection • Lead-based paint risk assessment • Lead-based paint hazard reduction monitoring • Post-hazard reduction clearance test. Under the Owner-Occupied Rehabilitation Programs, the City continued to provide each owner who participates with both oral and written information regarding the dangers of lead- based paint and what to do about it. Owners of properties constructed prior to 1978 were required to meet certain lead-based paint requirements prior to being assisted. These requirements include the following: • Distribution of lead-based paint notification pamphlets to all households occupying assisted units. • Inspection of all properties for defective paint surfaces. • Abatement of all defective paint surfaces that are identified at the time of the inspection. -27- Through the Owner-Occupied Rehabilitation Programs, financial assistance was provided to eradicate the problem. Full abatement was undertaken in all rehabilitation projects over $25,000. It was the responsibility of the City's Housing Programs Specialist to ensure that properties constructed prior to 1978 met the lead-based paint requirements and any abatement of defective paint surfaces were completed by contractors certified by the State of California Department of Health Services. A copy of the contractor's certification is kept on file. The Down Payment Assistance Loan Program also provided participants with oral and written information regarding the dangers of lead-based paint. The selected units underwent a Housing Quality Standards (HQS) inspection that checks for danger of lead-based paint and required any peeling, cracking, flaking, paint and/or chewable surfaces to be properly treated. The City personnel responsible for conducting the visual inspection of the units for HQS compliance have completed the Visual Assessment Course and received the proper course completion certification. In addition, the City would require clearance for all properties that fail an HQS inspection due to chipping, peeling, cracking surfaces greater than 2 sq. ft. on the interior and 20 sq. ft. on the exterior of the unit or in common areas. A risk assessment would be required to be completed by a certified risk assessor whenever the City is notified that a child with an environmental intervention blood lead level (EIB) plans to live/in a unit under the Down Payment Assistance Loan Program. 6. Ensuring Compliance with Program and Comprehensive Planning Requirements The monitoring section of the CAPER provides detail on the procedures used by city departments and agencies to assure compliance with Consolidated Plan program regulations, as well as the role City of Rosemead plays in review of eligibility and national objective of all project activities proposed for CDBG funding annually. The priorities, strategies and programs carried out through the Consolidated Plan are fully consistent with the city's general plan, and specific plans, and adhere to applicable CDBG and HUD statutes and regulations. 7. Reducing the Number of Persons Living Below the Poverty Level The City relies on cooperation from a wide range of services and agencies directed at helping people become self-sufficient, such as the Housing Authority County of Los Angeles's Family Self-Sufficiency Program. The Community Development Department is a partner through its provision of funds for community development, housing production, low or no cost residential improvements, economic development loan program and public service agency programs. These programs provide job opportunities, affordable housing, residential improvements including ADA and weatherization, food for the needy, improved commercial properties, counseling and other public services. In FY 2008-09, the City provided the following: Housing and Community Development • Housing Authority County of Los Angeles County - The Housing Authority County of Los Angeles continued to provide rental assistance and a Family Self-Sufficiency Program to the residents of Rosemead through the Federal Section 8 Housing Choice Voucher program. This program helped to provide extremely low and low-income tenants with affordable housing and assistance in becoming self-sufficient. -28- • Owner-Occupied Rehabilitation Programs - The City used a portion of its CDBG/HOME funds to assist those homeowners with income below the poverty level in making needed rehabilitation improvements by offering a variety of programs including a loan program, emergency grant program, grant program, and a rebate program. • First Time Homebuyer Program -The City used a portion of its HOME funds to assist low income residents with the purchase of their first home. The assistance was in the form of a silent second loan (no payments until the home is sold, transferred in ownership, refinanced or 30 years from the loan origination), and was available to low income families who have not owned a home within the previous three years. • Public Services - The City continued to provide public services (i.e. homeless prevention and counseling programs, nutritional food service, substance abuse, after-school tutoring programs, family counseling services, etc.). • Dial-A-Ride - Free transportation service (Dial-A-Ride) is provided to senior residents as well as disabled residents. The program provides curb-to-curb transportation services for seniors, age 60 and older, and for people who have disabilities who are residents of Rosemead. Transportation is available to any destination in Rosemead for any type of trip including medical appointments, educational/recreational activities, shopping, and visits to friends and family. Transportation is also available, at no cost, for travel outside the City, a distance of five miles from City Hall, for medical or social service appointments. The City also offers subsidized bus fare for the seniors through a contract with the Metropolitan Transit Authority (MTA). Economic Development The City partnered and supported activities that promote economic development including the following programs: • Commercial Rehabilitation Program and Economic Development Loan Program - The Redevelopment Agency will provide, as funds are available, economic development loans and rebates to business owners for fagade improvements to buildings located within the one of the City's Redevelopment Project Areas. • Business Attraction/Retention Program - The Redevelopment Agency will assist in attracting new businesses to the City as well as retaining the current businesses. F. Leveraging Resources 1. Federal Resources and Program Funds Used The goal expressed in the Action Plan for FY 2008-09 was to maximize use of available resources by committing to projects that are financially feasible and assist the greatest number of people and families. To this end, two resources were utilized during the FY 2008- 09 - the CDBG Program and the HOME Program. 2. Non-Federal Resources and Program Funds Used The City of Rosemead's General Fund contributed funding as leverage during the FY 2008- 09 to assist in the funding of the Code Enforcement Program and Senior Nutrition Program. -29- 3. Leveraging of non-Federal Resources See above. 4. Matching Contributions The City is a 100% HOME match reduction community; therefore, no HOME match is required. G. Citizen Comments Public participation has been encouraged in compliance with the City of Rosemead's Citizen Participation Plan (CPP) and by the Final Rule on the Consolidated Submission issued January 5, 1995. On September 8, 2009, notice of the availability of the Consolidated Annual Performance and Evaluation Report (CAPER) for the period of July 1, 2008 to June 30, 2009 was published in the San Gabriel Valley Tribune announcing the 15-day public comment period to begin on September 9, 2009 and concluded on September 23, 2009. Five (5) notices of the availability of the CAPER were also posted within the City of Rosemead. The CAPER was made available for review at the City Clerk's Office and the Community Development Department (Housing Services Division) at City Hall and at the Los Angeles County public library located in Rosemead. No comments were received by any agency or the community during the 15-day review period. H. Self-Evaluation The City of Rosemead continued its commitment of providing and encouraging fair housing, housing production, housing preservation and needed social service programs for the low to moderate income (0 to 80% of MFI) residents of Rosemead during the 2008-09 FY. Appendix A outlines the Action Plan objectives and shows how the activities undertaken in FY 2008-09 support the objectives of the community. The Action Plan for the FY 2008-09 was reflective of the 2005-2009 Five-Year Consolidated Plan. That is, the actions taken in the FY 2008-09 Action Plan were incremental steps toward accomplishing the Five-Year Consolidated Plan goals. Overall, the City's Housing Programs achieved most of the goals set out in the FY 2008- 09 Action Plan of its 2005-2009 Consolidated Plan. The City of Rosemead continued to commit a large portion of its resources toward improving the quality and expanding the amount of housing stock in the City. The City commitment to stimulate housing rehabilitation, new construction and to assist those low to moderate income (0 to 80% of MFI) residents who are unable to compete in the traditional housing market is evident by the housing programs and related services offered during the 2008-09 FY. -30- I. Monitoring The City operates in accordance with the monitoring plan developed for CDBG and HOME programs, including an annual single audit in conformance with OMB Circular A-133. There were no findings pertaining to the CDBG and HOME program in the audit for FY 2007-2008. The audit for FY 2008-2009 is currently in progress. Each budgeted project is first reviewed for compliance with the National Environmental Protection Agency regulations (NEPA). California Environmental Quality Act (CEQA) regulations may also apply. Projects that are community service in nature are exempt from NEPA. In FY 2008-2009, the City completed environmental reviews for its infrastructure projects, as well as for ongoing programs such as code enforcement, residential rehabilitation, and others. In addition, all applicable CDBG and HOME program projects are monitored regarding their conformance with Davis-Bacon requirements. The City also checks with the state board to ensure all contractors selected are licensed as well as the Federal debarred list to ensure all contracts can participate in a Federally-funded program. The City understands that all efforts using federal, state, and local resources to carry out its Action Plan must be conducted in accordance with established laws, regulations, and sound management and accounting practices. The City did not endure plan implementation by action or willful inaction. The following procedures were established for monitoring activities: • Ongoing, internal reviews of progress reports and expenditures. • Regular, internal meetings to coordinate staff efforts in regard to performance and compliance. • Periodic reports to appropriate City officials and other stakeholders. • Full review of audit statements and other documentation from subrecipients prior to disbursement of funds. • On-site visits of all subrecipients to ensure compliance with federal regulations. Technical assistance is provided where necessary. • Project and financial data on CDBG-funded activities will be maintained using the HUD software - IDIS (Integrated Disbursement information System). Use of this system will allow HUD staff easy access to local data for review and progress evaluation. • Timely submission of the Consolidated Annual Performance and Evaluation Report (CAPER). Under the supervision of the Community Development Director, the Economic Development Administrator oversaw the CDBG and HOME funded programs for the City. This position ensured that all of the CDBG- and HOME-funded programs were implemented in compliance with federal regulations and local policy. This included ensuring compliance with Davis-Bacon, environmental review, fair housing, minority and women owned business enterprises, Section 3, affirmative marketing through on-going monitoring of programs and services assisted with CDBG and HOME funds. -31- The Economic Development Administrator coordinated with the different internal departments receiving CDBG funds to operate the Code Enforcement Program, Owner- Occupied Rehabilitation Program, and the Targeted Public Works Projects. However, each program was administered or coordinated by the appropriate staff in each department and supervised by the Director and Assistant Director of that department. All project costs are paid on a reimbursement basis, rather than paid in advance. A request for reimbursement must have appropriate documentation attached to verify all expenditures. A current report of program activities for PSA's also accompanies each draw down request. These materials provide the data necessary to input data into the IDIS system. Collecting this data during the program year is helpful in reviewing performance goals on an on-going basis and in compiling year-end reports. Any discrepancies are addressed with the appropriate entities. Records on performance are kept in the project file. In regards to Public Works Projects, the City's Economic Development Administrator and Management Analyst were responsible for Davis-Bacon Compliance including monitoring of bid package, public bid process, a check with the State Contractor's License Board and federal Debarment system to ensure contractors were licensed and not debarred from federal contracts. Monitoring included further reviews of the contract to measure performance, Davis-Bacon wage rates, site visits and interviews of workers during constriction and prior to project close out. For subrecipients, the City had a subrecipient agreement that was used to measure agency compliance. The Management Analyst, under the direction of the Economic Development Administrator, coordinated with the CDBG-funded subrecipient's (i.e. Family Counseling Services, Morrison Health Care - Senior Nutrition Provider, People for People, Rosemead High School, Rosemead School District, and Southern California Housing Rights Center) in the administration and monitoring of their programs. The monitoring included on-site visits, interviews with program staff, telephone contacts and the review of quarterly reports. The City of Rosemead conducted on-site visits and follow-up with each of its public service agencies in FY 2008-2009. The lead person for the Consolidated Plan preparation and yearly reporting is the Economic Development Administrator under the supervision of the Community Development Director. -32- j CDBG PROGRAM ADDITIONAL NARRATIVE STATEMENTS A. Housing Priorities and Needs The City of Rosemead's Consolidated Plan described priorities for addressing housing needs. These needs are shown in the Priority Needs Summary Table of the Consolidated Plan. During the FY 2008-09, the City continued to successfully address these housing priorities and needs through the different housing programs and/or services as demonstrated throughout the City's FY 2008-09 CAPER'S report. The submission included and assessment of the relationship of CDBG funds to the high priority needs/objectives in the Plan, including an evaluation of the extent to which CDBG funds were used to benefit LMI persons. B. Impact on Identified Needs The City's programs are making an impact on those areas where it has identified needs in its Consolidated Plan, especially in the areas of youth services, meals for the elderly, infrastructure improvements and rehabilitation. In the area of rehabilitation, the City sees a need for continuing commitment to its aging housing stock and to the new units that will need rehabilitation in the future. In terms of youth services, the City is being proactive in assisting the community, which has identified the need for after-school activities, multi-cultural training and peer conflict resolution as ways to address youth violence, gang activity and "latch-key" children. As these children mature, these services will be needed for the next "generation" of children in order to continue to address these needs for this special population. During 2008-2009, the Family Counseling Program offered mental health counseling to at-risk youth and families, including gang diversion counseling. The Rosemead School District used CDBG funds to provide conflict resolution training and a peace fair for parents and youth from low/mod income households. The senior nutrition service program (along with its non-CDBG funded Para transit Program) has resulted in the successful provision of adequate nutrition and mobility for its aging population. Many of these people are living longer, and living independently longer, in part because of these services. The demand for these services may become even greater in the future because the current population will continue to age and use these services, even as a new generation of elderly begins to need services. Two major infrastructure improvement projects (Virginia Street and Alley Paving) were completed in the 2008-2009 program year. The Virginia Street project provided for a street reconfiguration for improved traffic access and other infrastructure improvements for a low- and moderate-income neighborhood. The Alley Paving project provided for the paving of dirt alleys to upgrade low- and moderate-income neighborhood areas. C. Barriers to Fulfilling Strategies Barriers to fulfilling strategies include increased cost to projects resulting from Davis- Bacon prevailing wage rates and delays due to environmental review process requirements. -33- D. Status of Grant Programs The City was able to meet the HUD Performance Policy by the end of FY 2008-2009, which includes meeting the required 1.5 program year ratio by the timeliness test date of May 2, 2009. By June 30, 2008, all grant programs were completed or in progress. The City will continue to make a focused effort to commit and expend CDBG funds in a timely manner. E. Performance Outcomes and Measurement In the past, the City has used quantifiable goals and objectives as part of its Consolidated Plan process. Beginning with the 2005-2010 Consolidated Plan cycle, the City has created quantifiable performance outcome measures for its projects (see Appendix A). This will help determine the success of projects in creating change within the community over time. F. Changes to Program Objectives No changes in program objectives were proposed in the City of Rosemead during the 2008-09 FY. G. Investment of Available Resources 1. Resources and program funds used As mentioned earlier, the goal expressed in the Annual Action Plan for FY 2008-09 was to maximize use of available resources by committing to projects that are financially feasible and assist the greatest number of people and families. To this end, the City pursued all available resources that were indicated in the Action Plan for FY 2008-09. 2. Geographic distribution of investment In order to prevent the concentration of low-income persons, City housing and social service programs were marketed and available throughout the City. The programs were not directed to any one geographical area but rather the extremely low to moderate- income (0 to 80% of the MFI) persons and families. The City wanted to promote a balanced and integrated community and was committed to providing assistance throughout the City. However, because of the income limitations, the programs generally benefit those households located within the quartile of census block groups in the City having the highest concentration of very-low and low- incomes. The only exception to this policy was the Code Enforcement activity which was limited to eligible low and moderate-income block groups based on an official designation of deteriorating and/or deteriorated areas and are referred to as an area benefit activity. An area benefit is an activity that meets the identified needs of low and moderate-income persons residing in an area where at least 51 % of the residents are low and moderate-income persons. The benefits of this type of activity are available to all persons in the area regardless of income. Potentially eligible activities include street improvements, fagade improvements in neighborhood commercial districts, graffiti removal, and code enforcement. -34- The new Low and Moderate-Income Summary Data (LMISD), resulting from the 2000 Census, became effective on July 1, 2003. The LMISD is the data that the City uses for our official determinations of activity compliance with the low and moderate-income area benefit national objective, in accordance with the Housing and Community Development Act of 1974, as amended, and the CDBG regulations. Because timely use of this data is required by regulation, any changes to the City's existing service area boundaries would need to be approved by the City Council. With the adoption of each Action Plan, the City Council approves the service area boundaries as the City's official low and moderate-income "Target Areas" and "Deteriorating Areas". The City has traditionally used 80% or more of its CDBG resources to benefit these special areas and/or to operate programs available exclusively to low and moderate-income people (whereas HUD regulations only require a minimum 70% low/mod benefit level for CDBG activities). In order to continue to achieve this high ratio of low/mod benefit for its CDBG resources, and because of the compelling need to assist these target areas, the City continued to target CDBG resources to these special geographic areas during the FY 2008-09. 3. Certifications To encourage fair housing, housing production and housing preservation, the city was willing to consider certifications of consistency for other entities' applications for Federal assistance. However, no requests were received during the 2008-09 FY. 4. Implementation of the Five-Year Consolidated Plan The resources made available during the 2008-09 FY allowed the City to continue its incremental steps toward accomplishing the Five-Year Consolidated Plan goals. The City will continue its efforts in meeting these goals. 5. Funds not Used for National Objectives There were no funds used that did not meet one of the three (3) national objectives for the CDBG program. H. One-For-One Replacement Summary There were no low and moderate-income housing units demolished/converted by the City during the period of July 1, 2008 - June 30, 2009 that trigger one-for-one replacement. 1. Displacement Summary There were no low and moderate-income households or businesses displaced by the City of Rosemead during the period of July 1, 2008 - June 30, 2009. J. Public Facilities and Improvements Public facilities and improvements include a wide variety of projects, including acquisition, construction, reconstruction, rehabilitation and installation of public improvements or facilities, such as parks, neighborhood facilities, and golf course, among many other activities. During the FY 2008-09, the City did not undertake any Public Facility Improvement Projects using CDBG funding. -35- K. Infrastructure Improvements Infrastructure Improvements include a wide variety of projects, including acquisition, construction, reconstruction, rehabilitation and installation of infrastructure, such as water/sewer improvements, street and sidewalk improvements, bus shelters, and bicycle routes, among many other activities. During the FY 2008-09, the City did undertake one project (Annual 2008-09 Curb Ramps Construction) that was funded in whole or part with CDBG funding. This project took place in eligible low and moderate-income block groups based on an official designation of deteriorating and/or deteriorated areas and are referred to as an area benefit activity. L. Economic Development - Low/Mod Job Activities The City continued outreach as part of its economic development program (adopted in FY 1996-1997). Economic development activities are those projects that are designed to create jobs or retain existing jobs; attract or retain businesses to an area, provide help to small businesses; acquire, construct, or rehabilitate buildings for businesses; and provide job training, among may other eligible activities. The City operates commercial rehabilitation programs under both the Rosemead Community Development Commission (RCDC) and the City. The programs are funded by RCDC through redevelopment agency funds and by the City through CDBG respectively. In FY 2008-2009, the City did not complete any RCDC-funded commercial rehabilitation projects or CDBG funded commercial rehabilitation projects. M. Limited Clientele Activities The City served limited clientele in the presumed eligible category for its homeless programs, ADA, and senior nutrition programs. For activities that did not fall within any of the categories of presumed limited clientele low- and moderate-income benefit, income data and certifications were collected to document that 51 % or more of the beneficiaries in these activities were of low- and moderate-income N. Program Income Through the CDBG program, Block Grant money as well as program income (loan paybacks) was used to fund the proposed projects listed in the FY 2008-09 One-Year Action Plan. According to the FY 2008-09 One-Year Action Plan, the City projected receiving approximately $0 in program income. However, the City actually received $50,721.06. These monies were applied towards CDBG Program Administration ($10,143), Owner-Occupied Rehabilitation Grant Program ($17,416), and the Senior Nutrition Program ($23,162.06). The program income received was posted to the IDIS system and drawn down prior to the draw of new CDBG funds. There was no income to revolving funds or to float-funded activities; there was no income from sale of real property or prior period adjustments. No loans were written off. There are no CDBG-funded parcels for sale and no lump sum drawdown payments were made. -36- O. Prior Period Adjustments There were no disallowed costs or prior period adjustments. P. Lump Sum Agreements There were no lump sum agreements or drawdowns during the reporting period. Q. Loans The City did not make any CDBG-funded deferred loans in FY 2008-2009 for residential rehabilitation. R. Housing Rehabilitation The following residential units (as described elsewhere in this report) were rehabilitated during FY 2008-2009: Type of Program # Units Completed Funds Spent CDBG (includes in Progress) Public Funds Private Funds Rebate 0 $ 0 $ 0 Grant 14 $123,445.00 $ 0 $ 0 Emergency Grant 3 $ 0 $ 0 Deferred Loan 0 $ 0.00 $ 0 $ 0 TOTAL 17 $123,445.00 $ 0 $ 0 S. Neighborhood Revitalization Strategy Areas The City does not have a Revitalization Strategy Area. The City does have two (2) special target areas within its low-moderate block groups. Target area # 1 is known as the Zapopan Target Area and Target Area #2 is known as the Jess Gonzalez Target Area. The strategy for the area includes the following: targeted pro-active code enforcement (CDBG), additional policing (non-CDBG), multi-family rehabilitation (HOME), single- family rehabilitation (CDBG), neighborhood clean ups (non-CDBG), commercial rehabilitation and economic development in surrounding corridors (CDBG, Redevelopment). T. Institutional Structure The implementation of the FY 2008-09 Action Plan was highly dependent upon the support and cooperation of numerous levels of government and the private sector, including for-profit and non-profit organizations. The City of Rosemead is governed by a five-member City Council. The City Council reviewed, held hearings, approved the funding priorities, and approved the submission of the FY 2008-09 Action Plan to HUD. The City of Rosemead's Community Development Department was the lead agency in the coordination of the Action Plan. It coordinated the redevelopment and economic activities of the City, developed and implemented the programs that rehabilitate and -37- preserve the neighborhoods in the City, developed and rehabilitated affordable housing, and provided rental assistance to the very low-income and special-needs segments of the City's population. As the lead agency, it was responsible for coordinating with any agencies and organizations receiving CDBG program funds. While the Community Development Department had the major responsibility for the Action Plan budgeting, project formulation, and program implementation, other City departments, government agencies, social service agencies, and Rosemead residents played an important role as shown below. There are several inter-departmental programs, primarily in the area of neighborhood quality of life that are composed of a wide variety of City agencies. All were funded through the CDBG or HOME as a funding source; but in many cases, departmental funds and other funding augment and leverage Action Plan Resources. • City of Rosemead's Community Development Department • City of Rosemead's Finance Department • City of Rosemead's Recreation and Community Services Department • City of Rosemead's Public Works Department • City Attorney • Los Angeles Sheriffs Department • U.S. Department of Housing and Urban Development • State of California's Department of Housing and Community Development • Other local agencies • Non-profit organizations • Private sector owners The structure of the CDBG and HOME program was decentralized. While the Community Development Department did administer several program activities, including several housing rehabilitation programs, other project activities were administered by sponsoring departments and City-related agencies. Guidelines for expenditure of CDBG and HOME funds were provided as needed or changes in the programs occur. Periodically, the Community Development Department provides departments and City-related agencies with training in HUD grant regulations. There were many organizations that actively collaborate in the areas of housing, homeless services, and community and economic development, and coordinate closely in both the preparation and implementation of the 2008-09 FY Action Plan. The City, for its part, promoted and encouraged fair housing, housing assistance, and single-family home rehabilitation through: • Continued utilization of the services of a fair housing organization to promote, educate and enforce fair housing in the community. • Continued working with the Housing Authority County of Los Angeles to implement its Section 8 Rental Assistance Program for the residents of Rosemead. -38- • Continued use of CDBG, HOME, Redevelopment and State funds to assist low and very low-income homeowners in rehabilitating their homes and in eliminating substandard conditions. The City will continue to encourage the different rehabilitation programs through the use of advertising in Rosemead Resources. • Continued use of the Salvation Army and YWCA-Wings to provide shelter services for the citizens of Rosemead as needed. One of the biggest challenges the City of Rosemead faced was the lack of or ever- decreasing amount of funds available in maintaining and furthering housing and community development goals. A related challenge was the need for better coordination and cooperation between the City and social service and health providers. For homeless activities, a seamless approach to provision of transitional and permanent housing services required that such providers be actively involved in each facet of the Continuum of Care. However, other housing activities, such as rehabilitation, demolition of abandoned or hazardous units, acquisition of sites for potential single family and multifamily affordable housing, home ownership assistance, and new construction need to be integrated within the social service and health provider community as well. The key to a strong institutional structure is the ability to develop and share data on the progress and status of beneficiaries through the development of integrated information systems. There are now several data information systems in place that, to various degrees, track the progress of a variety of beneficiaries from initial intake, through provision of services, and to completion of participation. For example, the Los Angeles Homeless Services Authority (LAHSA) is committing itself to a five-year developmental plan for the Homeless Management Information System (HMIS). A primary goal is to integrate the HMIS with other databases in sharing of commonly needed information. Institutions playing a major role in delivery of community development programs often have different mandates, and consequently different priorities and strategies to achieve them. These mandates are most often imposed by Congress, and reflected through the regulations of federal funding agencies. In several cases, goals may overlap or conflict. A major obstacle to delivery of services through a variety of institutions was the continuing trend in reduction of federal and state funds for a variety of needed programs. In addition, foundation giving continued to decline during the 2008-09 FY. While the primary actors in the Action Plan process was the City Council, and the Community Development Department, there were a significant number of City agencies and departments that oversee a wide variety of grants and programs that provided services to low and moderate-income City residents, and played an important role in implementing the Action Plan as mentioned above. -39- U. Minority/Women's Business Outreach In addition to prohibiting discrimination, fair housing and equal opportunity laws require recipients of federal housing funds to be proactive in encouraging participation in any projects or programs funded through federal sources. They must affirmatively market housing, employment and contracting opportunities to minorities, women, and low- income residents and businesses. During the 2008-09 FY, the City effectively promoted affirmative marketing through the following actions: • Use of the fair housing logo or equal opportunity language in marketing materials, posters on office walls, and referrals to a fair housing agency; • Use of funding agreements to require subrecipients to comply with requirements relating to equal employment opportunities; • Use of non-English language newspapers (as needed), informing service agencies about projects, and translators at public meetings; Furthermore, the City maintained the following marketing requirements and procedures: • Methods of informing the public, owners, and potential tenants about federal fair housing laws and the City's affirmative marketing policy. • Requirements and practices each Section 8 Housing Choice Voucher rental owner must adhere to in order to carry out the City's affirmative marketing procedures and requirements as stated in any written agreement between the City and a participating owner. • Procedures to be used to inform and solicit applications from the persons in the housing market area that are not likely to apply for the housing without special outreach. • Records that will be kept describing actions taken by the City and subrecipients in affirmatively marketing programs and projects. For employment and other economic development opportunities generated by certain HUD financial assistance the City shall, to the greatest extent feasible, and in conformance with existing Federal, State, and local law and regulations, be directed to low and very-low income persons, particularly those who are recipients of government assistance for housing, and to building contractors which provide economic opportunity to low and very-low income persons as required under Section 3. In addition, the City maintained the following employment and contracting requirements: • Adoption of a formal policy concerning nondiscrimination in employment, and a designated department to oversee compliance; • Procedures in notifying minority and female recruitment sources for Request for Proposals on City projects; • Placement of minority- and women-owned businesses (MBE/WBEs) on solicitation lists; and -40- • Use the services and assistance of the Small Business Administration and Minority Business Development Agency to encourage MBE/WBD participation in City projects. For all federally funded contracts, the City had set forms that were included in all bid packages. These forms consisted of a listing of federal equal employment opportunity/affirmative action requirements, requirements for contracting with small and minority-owned firms, women's business enterprise and labor surplus area information, certification regarding performance of previous contracts or subcontracts subject to the equal opportunity clause and the filing of required reports. V. Public Participation Requirements Public participation has been encouraged in compliance with the City of Rosemead's Citizen Participation Plan (CPP) and by the Final Rule on the Consolidated Submission issued January 5, 1995. On September 8, 2009, notice of the availability of the Consolidated Annual Performance and Evaluation Report (CAPER) for the period of July 1, 2008 to June 30, 2009 was published in the San Gabriel Valley Tribune announcing the 15-day public comment period to begin on September 9, 2009 and concluded on September 23, 2009. Five (5) notices of the availability of the CAPER were also posted within the City of Rosemead. The CAPER was made available for review at the City Clerk's Office and the Community Development Department (Housing Division) at City Hall and at both Rosemead Public Library located in Rosemead. No comments were received by any agency or the community during the 15-day review period. -41- Reserved -42- HOME PROGRAM i ADDITIONAL NARRATIVE STATEMENTS A. Narrative Statement HOME funding was programmed for CHDO set-aside, Mortgage Assistance to new homebuyers, Owner-Occupied Rehabilitation, and administrative expenses. As noted earlier, market prices and rising interest rates have combined to stall the City's HOME-funded Mortgage Assistance Program, as well as its RDA funded Home Buyer Program. In an effort to improve the implementation of the home ownership assistance programs, the City, in June 2006 revised the program to increase the amount of trust deed assistance to $70,000, increase the affordability period, increase the recapture of HOME funds used for down payment assistance. To address the program impact of the high cost of housing in the Los Angeles County area, City staff conducted a local survey of the price of housing sales in the City of Rosemead. This data analysis was submitted to HUD on September 12, 2006 for the purpose of requesting an increase in the maximum housing purchase price above the established Section 203(b) limit for Los Angeles County. HUD reviewed the analysis and at the end of October 2006 approved an increase in the maximum home purchase price of $394,250 for condominiums and $475,000 for detached single-family houses. Most of the City's housing and social service programs continued to be offered on a citywide basis. Households benefiting from the Rehabilitation Programs, Substantial Rehabilitation Program and the First-Time Home Buyer Down Payment Assistance Program were in the very low to moderate income (0 to 80% of the MFI) category. Households benefiting from the Section 8 Voucher program were in the very low to low-income (0 to 50% of the MFI) category. No location criterion is required to qualify for these programs. They were offered citywide. B. Status of Grant Programs The City, in the past, was not timely in its HOME commitments and expenditures. By June 30, 2009, all grant programs were completed, in progress, or funds reprogrammed as part of the FY 2009-10 Action Plan. This allowed for timely commitments and expenditures under the HOME Program. The City continues to make needed adjustments to the programs funded with HOME funds to ensure timely reservation and spending: C. American Dream Down Payment Initiative (ADDI) The City does not receive ADDI funds. This section does not apply to the City of Rosemead. D. MBE/WBE Outreach The City has conducted outreach for both minority and women home ownership, as well as to minority business and women-owned business enterprises (MBE/WBE). -43- The City has also conducted outreach to all Fannie Mae Community lenders and to all Real Estate financing entities in the Rosemead area. The City has held Home Ownership Fairs in prior years inviting local lenders and MBE/WBE firms, as well as conducting outreach through the City's non-profit organizations and through the School District. E. Match Report The City is a 100% HOME match reduction community. Therefore, there is no match requirement for the City of Rosemead. F. Adiustments and Improvements The City reallocated HOME funds in order to provide full funding to projects ready to move forward and to encourage timely expenditure of funds. G. Other Forms of Investment The City of Rosemead does not use atypical loans or grant instruments of non-conforming loan guarantees. H. Recapture Provisions in Mortgage Assistance Program HOME regulations at 24 CFR 92.254, Section (B) (ii) require that the participating jurisdiction "recoup all or a portion of the HOME assistance to the home buyers if the housing does not continue to be the principal residence of the family for the duration of the period of affordability." In accordance with this requirement, the City requires the repayment of HOME funds during the 15 year affordability period, along with a declining interest rate penalty and a pro-rata equity share provision. At the end of the affordability period, only HOME funds invested must be repaid. L Inspection Results The City has completed two (2) HOME-funded rental projects: Garvey Senior Apartments and Los Girasoles. As part of the City's ongoing monitoring requirements, both projects must supply annual rental verifications and the City conducts an annual habitability inspection. The City's annual rental verification reviews and inspections for Los Girasoles were completed on May 21, 2008 and Garvey Senior Apartments was completed in February 2008. The following findings were noted: All units passed. J. Affirmative Marketing During the 2008-09 FY, the City effectively promoted affirmative marketing through the following actions: • Use of the fair housing logo or equal opportunity language in marketing materials, posters on office walls, and referrals to a fair housing agency; • Use of agreements requiring home improvement contractors to comply with requirements relating to equal employment opportunities. -44- • Use of funding agreements to require the City's property management company and CHDO partner to comply with requirements relating to equal employment opportunities, as well as the affirmative marketing of available HOME-assisted rental units. • Use of non-English language newspapers (as needed), informing residents about the different housing programs available and providing translators at public meetings; Furthermore, the City maintained the following marketing requirements and procedures: • Methods of informing the public, owners, and potential tenants about federal fair housing laws and the City's affirmative marketing policy. • Records that will be kept describing actions taken by the City, the City's property management company, the City's CHDO partner, and independent contractors in affirmatively marketing programs and projects. • Description of policy to correct actions when requirements are not met. -45- Reserved -46- SUMMARY OFACTIVITIES Reserved M N Ol N O I P M N O O W W F a m 0 NWW Z El w.] 4 W Z F W d £ N ~ O w O 4 0 W > O O ❑ O E W m < ❑a (4 Oo m Za O 0 N z o ❑ 2 H a M U zH❑a~ a Z Z U o za o Haza~E V W O m W O El£ a o O E W 0 W o O x H In W N w' w U w N ti O ~ m o ~ I z OV o 0 £ w ❑ W Eoaw W U w H W H > O W W H W E F OOH U ❑ U m U U M °a a U UI ❑ M H w h £ a h N m E O Z Z O 0 >aa Z F Z W H a c~ H Z m H H > O H O V a w U N w U o aaN m~ a N o H F r H H N ~a O H m Z w a O F a H waQ U > H U > £ W H o a U F m 0 0 0 w ❑ 0 U x a a V o 0 0 0 0 0 0 0 0 o O w w (D H U S Z ~ H O a H D = 0 0 0 0 0 0 0 0 0 0 0 m a o a W E Z O F 0 O E U 0 z a H O W E E ❑ H m 3 a W u w a a > U> E. ] w H H H H m £ ~ x a a z U z D a p Z z > ry Za m w w U m U< ° aH a z a a a aa £ ❑ Z Z Z a Y U Q O ,Z H H H w z a ~i ••W a ❑H❑Faa I Z U Z a Z H U a H p H 3 H S E W ] a z . a %0 W r~'iZH>HZz'~'Ztx a ()PG EU<ZHwaUH W a cow HaH W Ha S E W E £ £ zQm 0 sma ° a iooooo0 000000 I M O O O O O 4 a H ❑ I a O N 0 N aa~ m N r O w U H O a U V q r ❑ W O w ❑ r E Z N aH Oaf W W m Z o a H£,~. 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