PHA 5-Year and Annual Plan

Transcription

1 PHA 5-Year and Annual Plan U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No Expires 8/30/ PHA Information PHA Name: The West Palm Beach Housing Authority PHA Code: FL009 PHA Type: Small High Performing Standard HCV (Section 8) PHA Fiscal Year Beginning: (MM/YYYY): 04/01/ Inventory (based on ACC units at time of FY beginning in 1.0 above) Number of PH units: 568 Number of HCV units: Submission Type 5-Year and Annual Plan Annual Plan Only 5-Year Plan Only 4.0 PHA Consortia PHA Consortia: (Check box if submitting a joint Plan and complete table below.) Participating PHAs PHA Code PHA 1: PHA 2: PHA 3: Year Plan. Complete items 5.1 and 5.2 only at 5-Year Plan update. Program(s) Included in the Consortia Programs Not in the Consortia No. of Units in Each Program PH HCV 5.1 Mission. State the PHA s Mission for serving the needs of low-income, very low-income, and extremely low income families in the PHA s jurisdiction for the next five years: To provide safe, decent and affordable housing to persons and families with limited financial resources and to provide residents with access to programs which will assist them in making the transition to greater financial security 5.2 Goals and Objectives. Identify the PHA s quantifiable goals and objectives that will enable the PHA to serve the needs of low-income and very low-income, and extremely low-income families for the next five years. Include a report on the progress the PHA has made in meeting the goals and objectives described in the previous 5-Year Plan. Goal: Manage the West Palm Beach Housing Authority s existing housing stock in an efficient and effective manner and seek to expand the stock of affordable housing in West Palm Beach: Objectives: (1) The West Palm Beach Housing Authority will maintain its vacancy rate at no more than 2% (2) The West Palm Beach Housing Authority will continue to decrease the number of days for unit turnaround to less than 5 days. (3) The West Palm Beach Housing Authority will improve and re-emphasize policies and procedures for resident orientation. (4) The West Palm Beach Housing Authority will strive to eliminate pest infestations in all developments. (5) The West Palm Beach Housing Authority shall maintain Section 8 lease up at 100%. (6) The West Palm Beach Housing Authority shall attain high performer status. (7) The West Palm Beach Housing Authority will contain to maintain rent collections at 99% or more. (8) The West Palm Beach Housing Authority will contemplate purchases of expiring use buildings as well as other viable real estate options. (9) Acquire existing properties and land for subsequent development (10) Revitalize the Dunbar Village and Southridge by Hope VI Revitalization and/or Demolition grants or by any other means possible. (11) The West Palm Beach Housing Authority will pursue opportunities to partner with the City of West Palm Beach, Housing Partnership, private developers and other viable housing development entities. (12) Pursue the development of a continuum of care for independent living to assisted living, adult day services, and other programs that may include multi-generational housing. (13) Establish commercial/retail ventures along Tamarind Avenue. (14) Develop Paul Lawrence Dunbar Senior Complex in Dunbar Village. (15) Rehabilitate /Construct a Twin Lakes Community Center and Training Facility. (16) Apply for any and all local, State and Federal funding opportunities including 9% LIHTC, Tax Exempt Bonds and CRA financing. Goal: Improve community quality of life and economic viability. Objectives: (1) The West Palm Beach Housing Authority shall achieve a level of customer satisfaction that gives the agency the highest score possible in this element of the Public Housing Assessment System, specifically in the areas of Safety, Communication and Neighborhood appearance. (2) The West Palm Beach Housing Authority shall continue to remove all graffiti within 24 hours of discovering it. (3) The West Palm Beach Housing Authority shall achieve proper curb appeal for all of its public housing development through landscaping, lawn maintenance, trash pick-up and other means. (4) The West Palm Beach Housing Authority shall create an appealing, up-to-date environment in its developments. (5) The West Palm Beach Housing Authority shall continue to use its De-concentration policies in an effort to mix its public Page 1 of 2 form HUD (4/2008)

2 housing development populations as much as possible with respect to ethnicity, race and income. (6) The West Palm Beach Housing Authority will pursue plans to implement mixed finance/mixed income housing developments using public/private collaborations. (7) To emphasize quality of life issues for WPBHA elderly residents by improving social services and health care on-site. (8) Partner with the City for Vickers House South to secure provision of services in the Southern area. (9) Create Economic Initiatives, Department of Financial Services to include a Bank and an IDA (Individual Development Account) (10) Establish revenue streams by offering contracted services to a public and private sector customer base. (11) The WPBHA will pursue Green housing opportunities for both existing units and for new construction including sustainable irrigation systems. (12) The West Palm Beach Housing Authority consistent with its mission to preserve and enhance the availability of affordable housing commits to the allocation of up to twenty percent (20%) or 619 of its Housing Choice Vouchers (HCV) as Project- Based Vouchers in order to accomplish this objective. Goal: Provide a safe and secure environment in the West Palm Beach Housing Authority s public housing developments. Objectives: (1) The West Palm Beach Housing Authority shall continue to evaluate all developments using second generation Crime Prevention through Environmental Design criteria and implement the recommendations. (2) The West Palm Beach Housing Authority continues to reduce crime in its developments. (3) The West Palm Beach Housing Authority shall develop more youth activities by partnering with existing social service agencies. (4) The West Palm Beach Housing Authority shall refine the memorandum of understanding between the jurisdiction s police force and this agency in order to develop strategies for identifying and reducing crime and in order to reduce police response time, and will provide to the greatest extent possible security in all developments. (5) The West Palm Beach Housing Authority shall reduce its evictions due to violation of criminal laws, by implementing aggressive screening procedures. Goal: Promote self-sufficiency and asset development of families and individuals. Objectives: (1) The West Palm Beach Housing Authority shall continue working with its partners to ensure that to the greatest extent possible that residents are working or engaged in job training. (2) Continue the successful Section 8 Homeownership Program Goal: Reduce dependency on federal funding. Objectives: (1) The West Palm Beach Housing Authority shall operate so that income exceeds expenses every year. (2) Diversify existing public housing portfolio and develop funding alternatives Re-brand agency as developer/provider of affordable housing. 6.0 PHA Plan Update (a) PHA Plan elements that have been revised by the WPBHA since its last Annual Plan submission: The plan has been amended to add: The conversion of three Asset Management projects, Twin Lakes, Pleasant City/Robinson Village and Dunbar Village from the Public Housing program to Project Based Rental Assistance (PBRA) under HUD s Rental Assistance Demonstration (RAD) program, and includes Significant Amendments provided in Attachment R Revised section 8:0 Capital Improvements) to reflect the financial effects of converting properties to RAD on the Capital Fund Budgets. Plans to convert the 148 units of Southridge elderly to HCV project-based vouchers. All 17 chapters of the Section 8 Administrative plan has been revised for clarity and updated with recent rule changes. Significant updates include changes in the use of administrative fee reserves or Unrestricted Net Assets (UNA) and rules regarding Lifetime Registered Sex Offenders. (b) The public may obtain copies of the 5-Year and Annual PHA Plan Division Avenue, West Palm Beach, Florida or on the West Palm Beach Housing Authority s website Eligibility, Selection and Admissions Policies including De-concentration and Wait List Procedures: Based on local housing needs and priorities, The WPBHA has established a system of preferences for the selection of families admitted to its programs. The WPBHA may change these preferences to respond to changes in local housing needs or emergency housing situations. The WPBHA verifies preference claims at the time an application is reviewed. Pursuant to federal regulation, once an applicant name reached the top of the waiting list and meet preference requirements, they are screened to ensure they meet income eligibility. The WPBHA maintains a waiting list for the tenant-based HCV program, a wait list for the public housing program and a separate site based wait list for the Project-Based Voucher (PBV) Program. The WPBHA describes its policy regarding Eligibility, Selection, Admissions, De-concentration and Wait List procedures in more detail in the WPBHA s Section 8 HCV Administrative Plan and the Admissions and Occupancy Policy (ACOP).

3 6:0 2 Financial Resources. Based upon FY 2013 funding levels, the WPBHA anticipates receiving funding or funding commitments of about $34,688,206 from HUD during FY2014. FINANCIAL RESOURCES Planned Sources and Uses SOURCES PLANNED $ PLANNED USES 1. Federal Grants (FY 2014 grants) a) Public Housing Operating Fund 1,200, b) Public Housing Capital Fund 700,000 c) Annual Contributions for Section 8 HCV Tenant- Based Assistance 30,000, d) LIPH FSS (ROSS) 40,206 e) HCV FSS 88,000 Other Federal Grants (list below) - Estimated - used for Operations Estimated -used as HUD Regs allow H.A.P. FSS Coordinator /Case Manger FSS Coordinator /Case Manger Replacement Housing fund - Total 2014 Grants estimated 32,028, Prior Year Federal Grants (unobligated funds only) (list below) a) Public Housing Capital Fund (CFP) 0 b) American Recovery and Reinvestment Act (ARRA) 0 c)replacement Housing Fund (RHF) 0 Total Unobligated prior-year grants 3. Public Housing Dwelling Rental Income 1,240, Other income (list below) 0 a) Section 8 Administrative Fees 1,420, Non-federal sources (list below) 0 Total Resources $34,688, Rent determination: There are no changes to rent determination policies planned for 2014 which means that the WPBHA s minimum rent for both the Housing Choice Voucher Program and the Public Housing program remain at $50 per month with hardship conditions as prescribed by QHWRA. In 2014 the Housing Choice Voucher (HCV) program will operate with payment standards s that fall within a range of 90% to 110% of FMR levels, although exceptions are permitted if authorized b HUD. The WPBHA provides the flat rent structure for the Public Housing program. Also, the WPBHA as per 24CFR excludes incremental earnings and benefits resulting from a family member s participation in a qualifying employment training program Operations and Management: The policies of the Public Housing and HCV programs are reviewed annual and revised as necessary. The WPBHA has an organization chart showing its management structure on file. The WPBHA has established Public Housing AMP s and four property groups each managed by a Property Manager all in accordance with HUD guidelines. The WPBHA has implemented rules, standards and policies to effectively manage its operations. Following are some of the policies the WPBHA has put in place and are on file at the WPBHA administrative office: Management and Maintenance Policies Admissions and Continued Occupancy (ACOP) Policy Drug- Free Workplace Section 8 HCV Administrative Plan Ethics Policy Public Housing Residential Dwelling Leases for our various FMLA Policy properties. Tenant Selection Policy Harassment Policy

4 Maintenance Policy which includes an Integrated Pest Control and Extermination Physical Examination Policy Procurement Policy Deceased Tenant Procedures Family Self Sufficiency Action Plan Fixed Asset Procedure Abandoned Vehicle Procedure Fraud Policy Affirmatively Furthering Fair Housing Housekeeping Policy By-Laws Yard Maintenance Policy Capitalization Policy Capitalization Policy Disposition Policy Credit Card Policy Grievance Procedures Petty Cash Investment Policy Facilities Use Human Resource Policy Office Safety Policy Pet Policy Alarm System Procedures Motor Vehicle Policy On Call Policy Safety Policy Statement Abandoned Vehicle Policy Bid Protest Procedures Internet Use Policy, and Laptop Policy Admissions and Continued Occupancy (ACOP) Policy Use of System 6:05 Grievance Procedures: For the Section 8 HCV program the informal hearing and review procedures are covered in Chapter 16 of the HCV Administrative plan is available as a standalone document Designated Housing for Elderly and Disabled Families. The 148 Southridge development is a HUD approved designated elderly development. It is currently the only designated elderly development and has 148 units Community Service and Self-Sufficiency: The WPBHA has implemented the community service requirement, which requires most nonworking adult residents of public housing to perform at least 8 hours of community service per month. This requirement is applicable for residents at all public housing developments. The WPBHA as part of its mission provides its participants with access to programs which will assist them in making the transition to greater financial security. The WPBHA has implemented successful HUD FSS (Family Self-Sufficiency) programs for both the HCV and Public Housing programs. The WPBHA is also a HUD approved Housing Counseling Agency that provides the following to participants: o o o o o o o o Fair Housing Pre-Purchase Education Workshops Financial Management/Budget Counseling Non-Delinquency Post Purchase Workshops Pre-purchase Counseling Pre-purchase Homebuyer Education Workshops Predatory Lending Education Workshop Rental Housing Counseling Rental Housing Workshops resolving/preventing Mortgage Delinquency Workshops 6.08: Safety and Crime Prevention is committed to the safety and crime prevention in all WPBHA owned properties. Despite limited funding, the WPBHA provides after hours security surveillance of targeted properties. Security cameras and alarm systems are tools the WPBHA uses to assist with responding to crime. 6.09: Pets: The WPBHA s Pet policy is included in the ACOP. 6.10: Civil Rights Certification is included in the WPBHA s Plan Certifications 6.11: Fiscal Year Audit of the WPBHA for the period ended March 31 st 2012, received an unqualified opinion with no audit findings. 6.12: Asset Management: In 2008 the West Palm Beach Housing Authority successfully transitioned to HUD s Asset Based management model. Developments were grouped based on geography and size. Four Asset Management Projects (AMPs) were created as follows: Dunbar Village, Southridge, RobinsonVillage/Pleasant City and Twin Lakes. This model included the implementation of project based accounting, project-based management, a Central Cost Center, centralized services, and review of project performance. 6.13: Violence Against Women Act (VAWA): The WPBHA has incorporated the appropriate VAWA provisions, including notification, into the ACOP and the HCV Administrative Plan and the Public Housing Dwelling Lease.

5 7.0 Hope VI, Mixed Finance Modernization or Development, Demolition and/or Disposition, Conversion of Public Housing, Homeownership Programs, and Project-based Vouchers. Include statements related to these programs as applicable. Mixed Finance: The WPBHA will pursue mixed finance developments in Dunbar Village, Robinson Village/Pleasant City, Twin Lakes and Southridge including any Hope VI successor programs funded by U.S. HUD. Acquisition: The WPBHA will apply for an allocation of Low Income Housing Tax Credits for affordable housing development. The WPBHA will continue to pursue various options for the acquisition of additional affordable housing and plans to secure partnerships with private developers and funders in furtherance of this goal. Modernization or Development: Plans for modernization are identified in the WPBHA Capital Fund Program Annual Statement Demolition and/or Disposition: Over the last few years the West Palm Beach Housing Authority received approval from HUD to demolish 56 units in Dunbar Village. The WPBHA plans to pursue demolition of additional units in Dunbar Village. Conversion of Public Housing: Under the Rental Assistance Demonstration (RAD) Program, the WPBHA has submitted an application to HUD to convert the following Asset Management Projects (AMP) from the Public Housing program to Project-Based Rental Assistance (PBRA): Twin Lakes, RobinsonVillage/Pleasant City, and Dunbar Village Twin Lakes built in 1962, is located in census tract 21 and situated on a 12 acre site. It is adjacent to single family homes and is close to retail, shopping, restaurants, transportation, and Lake Mangonia and Clear Lake recreation areas. All buildings are single story, with 28 single family type homes, and 46 duplexes. There is off street parking for residents, generous back yards, and individual walkways and well treed lots. There would be no change in the number or bedroom size of the units proposed for conversion, and there is no plan for the transfer of assistance at the time of conversion. The converted units would utilize a site-based waiting list. Pleasant City/Robinson Village: The Pleasant City development is a scattered site built in It is bounded on the north by Northwood Road (one block north of 23rd Street), and on the south by Palm Beach Lakes Boulevard (12th Street). The western boundary is the FEC railroad which runs in a north-northwesterly direction, and the eastern boundary is Dixie Highway. The development overall comprises 22 city blocks, or approximately 122 acres. A recognizable street grid exists within the neighborhood. The Robinson Village development is located between 45 th Street and Haverhill and consists of 60 units; there are also 20 units at nd Street (Robinson Villa) and 4 units at 619 Sixth Street. All these units have been recently renovated. There is no plan to change the number or bedroom size of the units proposed for conversion, and no plan to transfer assistance at the time of conversion. The converted units would utilize a site-based waiting list. Dunbar Village was built in 1940, and these units are made up of one and two-story barracks-style housing and are physically isolated from the surrounding neighborhood. The WPBHA is currently pursing various financing options for the re-development of Dunbar Village. Project-based Vouchers The West Palm Beach Housing Authority consistent with its mission to preserve and enhance the availability of affordable housing commits to the allocation of up to twenty percent (20% ) or 619 of its Housing Choice Vouchers (HCV) as Project-Based Vouchers. The WPBHA plans to undertake voluntary conversion to project-based assistance for the Southridge, elderly development, and plans to project-based at least 99 vouchers for the Paul Lawrence Dunbar Senior Complex. Currently, 27 project based vouchers have been assigned to Royal Poinciana and 20 to Colony Oaks. In 2012 HUD approved the concept for a 221 (d) (4) insured project consisting of 99 Project Based Vouchers for seniors. This development will be named the Paul Laurence Dunbar Senior Complex out of respect for the historical and cultural context of Dunbar Village. Relocation Funds. The WPBHA plans to apply for Relocation funds in the next fiscal year. Homeownership: The WPBHA presently administers the Family Self-Sufficiency (FSS) Homeownership programs for Section 8 and Public Housing and the Section 8 Homeownership Program. There are currently 212 families participating in the FSS Program (Section 8 179, Public Housing- 33). The Section 8 Homeownership was implemented in 2008, and a maximum of 110 vouchers have been assigned to the program. The WPBHA will continue to develop homeownership opportunities in Merry Place and Colony Oaks. RHF The WPBHA is scheduled to complete 9 units of public housing using RHF funds by January Capital Improvements. Please complete Parts 8.1 through 8.3, as applicable. 8.1 Capital Fund Program Annual Statement/Performance and Evaluation Report. As part of the PHA 5-Year and Annual Plan, annually complete and submit the Capital Fund Program Annual Statement/Performance and Evaluation Report, form HUD , for each current and open CFP grant and CFFP financing. These statements are attachments to this document as required under section 11.0(h). 8.2 Capital Fund Program Five-Year Action Plan. As part of the submission of the Annual Plan, PHAs must complete and submit the Capital Fund Program Five-Year Action Plan, form HUD , and subsequent annual updates (on a rolling basis, e.g., drop current year, and add latest year for a five year period). Large capital items must be included in the Five-Year Action Plan. See Attachments.

6 8.3 Capital Fund Financing Program (CFFP). Check if the PHA proposes to use any portion of its Capital Fund Program (CFP)/Replacement Housing Factor (RHF) to repay debt incurred to finance capital improvements. Housing Needs. Based on information provided by the applicable Consolidated Plan, information provided by HUD, and other generally available data, make a reasonable effort to identify the housing needs of the low-income, very low-income, and extremely low-income families who reside in the jurisdiction served by the PHA, including elderly families, families with disabilities, and households of various races and ethnic groups, and other families who are on the public housing and Section 8 tenant-based assistance waiting lists. The identification of housing needs must address issues of affordability, supply, quality, accessibility, size of units, and location. Palm Beach county Renter Households by Detailed Income and Cost Burden: 9.0 All Households 30% or Less of AMI to 60% of AMI Greater than 60% AMI Total Total Total Total Households Households Households Households % of Households w/a > 40% Cost Burden 40.01% to 60% Cost Burden 60.10% or More Cost Burden to 6% Cost Burden 60.01% or more Cost Burden to 60% cost Burden 155, % 31, % 69.1% 36, % 35.1% 86, % 3.1% 60.01% or More Cost Burden Source: U.S. Census American Community Survey; University of Florida bureau of Economic & Business Research 2012 Population Projections. According to the 2013 Schimberg Center Rental Market Study, rents are up in Florida while homeownership is down, and more than 700,000 lowincome Floridians pay more than they can afford for their rent. The median rent in Florida increased from $816 to $950 per month from 2000 to During the same period, median renter income fell from $34,000 to $30,343 (all in 2011 dollars). Extremely low-income (ELI) renters have the most severe needs. For every 100 ELI households Florida has only 31 affordable available rental units (units that cost less than 40% of income and are not already rented by higher income household.). More than one fourth of low income, cost burdened renters are elderly. Of all cost burdened renter households, 20 percent are headed by someone age and nine percent are heady by someone age 75 or older. ( Anne Ray, 2013 Schimberg Market Study) Strategy for Addressing Housing Needs. Provide a brief description of the PHA s strategy for addressing the housing needs of families in the jurisdiction and on the waiting list in the upcoming year. Note: Small, Section 8 only, and High Performing PHAs complete only for Annual Plan submission with the 5-Year Plan. The Rental Market Study indicates that the supply and quality of affordable rental housing for low income families is limited. The WPBHA has employed the following strategy for addressing housing needs of families in its jurisdiction and on the waiting List. 9.1 The WPBHA opened the Waiting List for project-based vouchers for its Colony Oaks development on 03/26/2013 and 05/09/2013 for the Royal Poinciana development respectively. These Wait Lists are currently open. The Wait list for the Housing Choice Voucher (HCV) Program was opened for applications on September 8 th 2011, and was closed on Thursday September 22, The WPBHA received 18,804 applications and via a lottery, placed 5000 applicants on this Wait list. As of October 2013 there are currently 4950 applicants on this Wait List. Vouchers are being issued as they become available. The Public Housing Wait List opened on July 10 th 2012, and closed on July 20 th The WPBHA now has on its Public Housing Wait List 5096 applicants. Individuals are being housed by bedroom size. The WPBHA will continue to do the following: Maximize the number of available assisted housing units by maintaining a minimal vacancy rate in the Public Housing program and a high utilization rate in the Housing Choice Voucher program Increase the supply of assisted housing units by developing new public housing units and applying for new vouchers as made available Upgrade the Public Housing stock through the effective expenditure of Capital Funds Provide economic opportunities for residents through provision of social service programs like the FSS program and Section 3 component of construction contracts 10.0 Additional Information. Describe the following, as well as any additional information HUD has requested.

7 (a) Progress in Meeting Mission and Goals. Provide a brief statement of the PHA s progress in meeting the mission and goals described in the 5- Year Plan. Goal: Manage the West Palm Beach Housing Authority s existing housing stock in an efficient manner and seek to expand the stock of affordable housing in West Palm Beach. The West Palm Beach Housing Authority (WPBHA) owns and maintains one of the oldest public housing developments in the State of Florida and the United States: Dunbar Village. Put into service in 1940, the WPBHA has over the past 73 years done its best to keep these units in a safe, decent, sanitary condition. Through storms, hurricanes, a few fires and untold trials and tribulations, Dunbar Village has remained virtually unchanged. It has done noble service, but now must be retired. Towards that end, the WPBHA has demolished 25 of its 60 dwelling buildings. In 2013, nine units of new construction public housing were built on the Dunbar site. This townhouse type building has been named Sabal Palm Place and is a non-smoking facility. Although HUD Multifamily approved our concept for a 221 (d) (4) insured project, consisting of 99 Project Based Vouchers for seniors in 2012, we await an invitation to submit the final application for funding. The WPBHA has named this development the Paul Laurence Dunbar Senior Complex out of respect for the historical and cultural context of Dunbar Village. In November of 2013 the WPBHA along with its partner Landmark Development submitted an application for 9% Low Income Housing Tax Credits. This 120 unit family project, named Silver Palm Place will replace an additional 14 buildings at the Dunbar site. Awards will be made by Florida Housing Finance Corporation before the end of Units in the remaining AMP s have been the beneficiaries of Capital Funds and Disaster Recovery Initiative funds (administered by Palm Beach County.) A new grant in 2013 will replace the badly deteriorated driveway and parking lot at Southridge, the senior development. The WPBHA is currently exploring possibilities with the City of West Palm Beach to take ownership in an expiring use LIHTC property in which the city and a local nonprofit have an interest, thereby preserving and maintaining a rent to own model in a critical area of the city. Goal: Improve community quality of life and economic viability. The WPBHA continues to promote and encourage the Resident Councils in all developments. The Health Center at Dunbar Village (also known as the gym ) has become a hub of physical exercise, nutritional workshops and strength training. In 2013, the WPBHA applied for 501 ( c) ( 3) status for the Pine Ridge Holistic Life Center which will partner with health care providers, urban agriculturalists and others to create and promote healthy lifestyle alternatives for housing authority residents and the community at large. Pine Ridge will operate from a site adjacent to Dunbar Village. Goal: Provide a safe and secure environment in the West Palm Beach Housing Authority s public housing developments. Security patrols continue. Security personnel work hard to keep residents and the premises from undesirable intruders and behavior. Resident s willingness to cooperate with law enforcement appears to be on the rise and cooperation with the City Police Department has increased dramatically. The WPBHA has maintained and expanded it security camera program; in 2013 a perpetrator breaking into the maintenance facility was identified and apprehended. The WPBHA will prosecute this burglar to the fullest extent of the law. Goal: Promote self-sufficiency and asset development of families and individuals. In 2013, the WPBHA received the credentials to be a HUD Certified Housing Counseling Agency. Staff in the FSS department has received advance training in Foreclosure Prevention and Financial Management and has found the community at large to be very receptive to its training programs. The Section 8 Homeownership Program continues its success with seven closings this year. The WPBHA has continued its commitment to implement the Section 3 requirements of all contracts. Through the efforts of the Section 3 Compliance Officer, the local workforce has benefited from Capital Projects Funds, Disaster Recovery Funds and Replacement Housing Factor Funds to an unprecedented degree. Goal: Reduce dependency on federal funding. The WPBHA is actively seeking income producing property, that can be purchased with affordable housing preservation funds or in rare instances assumable mortgages. The WPBHA currently owns and manages 400 units of non-assisted rentals and plans to use the eventual cash flow from these properties to support its existing public housing stock. Without such resources, public housing will be choked from existence in the very near future. (b) Significant Amendment and Substantial Deviation/Modification. Provide the PHA s definition of significant amendment and substantial deviation/modification The West Palm Beach Housing Authority will consider the following changes to its Annual and 5-year plan to be significant. Any Change required by amendment in federal statutes, regulations or HUD notices that in the opinion of the West Palm Beach Housing Authority (WPBHA) has either substantial programmatic or financial or administrative burdens beyond the programs under administration at the start of the Plan Year. Any change that the WPBHA Board determines to be significant. Any additional plans for demolition of any housing owned or managed by the WPBHA. The following RAD-specific items will be excluded from this definition Changes to the Capital Fund Budget produced as a result of each approved RAD Conversion, regardless of whether the proposed conversion will include use of additional Capital Funds; and

8 Changes to the construction and rehabilitation plan for each approved RAD conversion; and Changes to the financing structure for each approved RAD conversion. Site Selection and Neighborhood Standards RAD Relocation Plan 11.0 Required Submission for HUD Field Office Review. In addition to the PHA Plan template (HUD-50075), PHAs must submit the following documents. Items (a) through (g) may be submitted with signature by mail or electronically with scanned signatures, but electronic submission is encouraged. Items (h) through (i) must be attached electronically with the PHA Plan. Note: Faxed copies of these documents will not be accepted by the Field Office. (a) Form HUD-50077, PHA Certifications of Compliance with the PHA Plans and Related Regulations (which includes all certifications relating to Civil Rights) (b) Form HUD-50070, Certification for a Drug-Free Workplace (PHAs receiving CFP grants only) (c) Form HUD-50071, Certification of Payments to Influence Federal Transactions (PHAs receiving CFP grants only) (d) Form SF-LLL, Disclosure of Lobbying Activities (PHAs receiving CFP grants only) (e) Form SF-LLL-A, Disclosure of Lobbying Activities Continuation Sheet (PHAs receiving CFP grants only) (f) Resident Advisory Board (RAB) comments. Comments received from the RAB must be submitted by the PHA as an attachment to the PHA Plan. PHAs must also include a narrative describing their analysis of the recommendations and the decisions made on these recommendations. (g) Challenged Elements (h) Form HUD , Capital Fund Program Annual Statement/Performance and Evaluation Report (PHAs receiving CFP grants only) (i) Form HUD , Capital Fund Program Five-Year Action Plan (PHAs receiving CFP grants only)

9 ATTACHMENT R Rental Assistance Demonstration (RAD) The West Palm Beach Housing Authority (WPBHA) is amending its annual and 5-year PHA Plan because it is an applicant for the Rental Assistance Demonstration (RAD) program. If approved, the WPBHA will be converting to Project Based Rental Assistance (PBRA) under the guidelines of PIH Notice , REV-1 and any successor Notices. Upon conversion to PBRA, the WPBHA will adopt the resident rights, participation, waiting list and grievance procedures listed in PBRA: Section 1.7.B & 1.7.C of PIH Notice , REV-1). These resident rights, participation, waiting list and grievance procedures are appended to this Attachment. Additionally, the WPBHA is currently compliant with all fair housing and civil rights requirements and is not under a Voluntary Compliance Agreement Compliance Agreement. RAD was designed by HUD to assist in addressing the capital needs of public housing by providing the WPBHA with access to private sources of capital to repair and preserve its affordable housing assets. Please be aware that upon conversion, the WPBHA s Capital Fund Budget will be reduced by the pro rata share of Public Housing Developments converted as part of the Demonstration, and that the WPBHA may also borrow funds to address their capital needs. The WPBHA will also be contributing Operating Reserves in the amount of $3,071,536 and Capital Funds in the amount of $551,000 towards the conversion.

10 Public Housing Developments Selected for RAD: Development #1 Name of Public Housing: Twin Lakes Total Units: 148 PIC Development ID:FL Pre-RAD Unit Type: Family Conversion Type: PBRA Transfer of Assistance : NO Post RAD Unit Type: Capital Fund allocation Family of Development: $250,000 Bedroom Type Number of Units Pre- Number of Units Post Change in Number of Units Conversion Conversion per Bedroom Type and why Studio/ Efficiency 0 0 N/A One Bedroom 0 0 N/A Two Bedroom N/A Three Bedroom N/A Four Bedroom N/A Five Bedroom 6 6 N/A Six Bedroom 0 0 N/A If performing a Transfer Assistance: Explain how transferring waiting list

11 Development #2 Name of Public Housing: Pleasant City/Robinson Village Total Units: 134 PIC Development ID:FL Pre-RAD Unit Type: Family Conversion Type: PBRA Transfer of Assistance : NO Post RAD Unit Type: Capital Fund allocation Family of Development: $200,000 Bedroom Type Number of Units Pre- Number of Units Post Change in Number of Units Conversion Conversion per Bedroom Type and why Studio/ Efficiency 0 0 N/A One Bedroom N/A Two Bedroom N/A Three Bedroom N/A Four Bedroom 0 0 N/A Five Bedroom 0 0 N/A Six Bedroom 0 0 N/A If performing a Transfer Assistance: Explain how transferring waiting list

12 Development #3 Name of Public Housing: Dunbar Village Total Units: 134 PIC Development ID:FL Pre-RAD Unit Type: Family Conversion Type: PBRA Transfer of Assistance : Pending Tax Credit application Post RAD Unit Type: Family Capital Fund allocation of Development: $101,000 Bedroom Type Number of Units Pre- Number of Units Post Change in Number of Units Conversion Conversion per Bedroom Type and why Studio/ Efficiency N/A One Bedroom N/A Two Bedroom N/A Three Bedroom N/A Four Bedroom 0 N/A Five Bedroom 0 0 N/A Six Bedroom 0 0 N/A If performing a Transfer Assistance: Explain how transferring waiting list

13 Resident Rights, Participation, Waiting List and Grievance Procedures PBRA Resident Rights and Participation 1. No Rescreening of Tenants upon Conversion. Pursuant to the RAD statute, at conversion, current households are not subject to rescreening, income eligibility, or income targeting provisions. Consequently, current households will be grandfathered for conditions that occurred prior to conversion but will be subject to any ongoing eligibility requirements for actions that occur after conversion. For example, a unit with a household that was over-income at time of conversion would continue to be treated as an assisted unit. Thus, the first clause of section 8(c)(4) of the Act and 24 CFR (b), concerning determination of eligibility and selection of tenants, will not apply for current households. Once that remaining household moves out, the unit must be leased to an eligible family. 2. Right to Return. Any resident that may need to be temporarily relocated to facilitate rehabilitation or construction will have a right to return to an assisted unit at the development once rehabilitation or construction is completed. Where the transfer of assistance to a new site is warranted and approved (see Section 1.6.B.7 and Section1.7.A.8 on conditions warranting a transfer of assistance), residents of the converting development will have the right to reside in an assisted unit at the new site once rehabilitation or construction is complete. Residents of a development undergoing conversion of assistance may voluntarily accept a PHA or Owner s offer to permanently relocate to another assisted unit, and thereby waive their right to return to the development after rehabilitation or construction is completed. 3. Phase-in of Tenant Rent Increases. If a resident s monthly rent increases by more than the greater of 10 percent or $25 purely as a result of conversion, the rent increase will be phased in over 3 years, which a PHA may extend to 5 years. To implement this provision, HUD is waiving section 3(a)(1) of the Act, as well as 24 CFR (definition of total tenant payment ), to the limited extent necessary to allow for the phase-in of tenant rent increases. A PHA must set the length of the phase-in period to be three years, five years or a combination depending on circumstances. For example, a PHA may create a policy that uses a three year phase-in for smaller increases in rent and a five year phasein for larger increases in rent. This policy must be in place at conversion and may not be modified after conversion. The below method explains the set percentage-based phase-in an owner must follow according to the phase-in period established. For purposes of this section Calculated Multifamily TTP refers to the TTP calculated in accordance with regulations at 24 CFR and the most recently paid TTP refers to the TTP recorded on the family s most recent HUD Form Three Year Phase-in: Year 1: Any recertification (interim or annual) performed prior to the second annual recertification after conversion 33% of difference between most recently paid Total Tenant Payments (TTP) and the calculated Multifamily housing TTP Year 2: Year 2 Annual Recertification (AR) and any Interim Recertification (IR) in prior to Year 3 AR 66% of difference between most recently paid TTP and calculated Multifamily housing TTP Year 3: Year 3 AR and all subsequent re-certifications Year 3 AR and any IR in Year 3: Full Multifamily housing TTP

14 Five Year Phase-in Year 1: Any recertification (interim or annual) performed prior to the second annual recertification after conversion 20% of difference between most recently paid TTP and the calculated Multifamily housing TTP Year 2: Year 2 AR and any IR prior to Year 3 AR 40% of difference between most recently paid TTP and calculated Multifamily housing TTP Year 3: Year 3 AR and any IR prior to Year 4 AR 60% of difference between most recently paid TTP and calculated Multifamily housing TTP Year 4: Year 4 AR and any IR prior to Year 5 AR 80% of difference between most recently paid TTP and calculated Multifamily housing TTP Year 5 AR and all subsequent re-certifications Full Multifamily housing TTP Please Note: In either the three year phase-in or the five-year phase-in, once Multifamily housing TTP is equal to or less than the previous TTP, the phase-in ends and tenants will pay full multifamily housing TTP from that point forward. 4. Public Housing Family Self-Sufficiency (PH FSS) and Resident Opportunities and Self Sufficiency (ROSS-SC). Current PH FSS participants will continue to be eligible for FSS once their housing is converted under RAD. All owners will be required to administer the FSS program in accordance with the participants contracts ofparticipation and future guidance published by HUD. Owners may not offer enrollment in FSS to residents in projects converted to PBRA that were not enrolled in the PH FSS program prior to RAD conversion, nor may owners offer FSS enrollment to any new residents at the project. Owners will be allowed to use any funds already granted for PH FSS coordinator salaries until such funds are expended. All owners will be required to provide both service coordinators and payments to escrow until the end of the Contract of Participation. Please see future FSS Notices of Funding Availability and other guidance for additional details, including FSS coordinator funding eligibility under a RAD conversion. As the PH FSS grant is the source of funding for PH FSS, program compliance will continue to be monitored by the Office of Public and Indian Housing. Current ROSS-SC grantees will be able to finish out their current ROSS-SC grants once their housing is converted under RAD. However, once the property is converted, it will no longer be eligible to be counted towards the unit count for future public housing ROSS-SC grants nor will its residents be eligible to be served by future public housing ROSS-SC grants. 5. Resident Participation and Funding. Residents of covered projects converting assistance to PBRA will have the right to establish and operate a resident organization in accordance with 24 CFR Part 245 (Tenant Participation in Multifamily Housing Projects). In addition, in accordance with Attachment 1B, residents will be eligible for resident participation funding. 6. Resident Procedural Rights. The information provided below must be included as part of the House Rules for the associated project and the House Rules must be furnished to HUD as part of the Financing Plan submission. See Attachment 1E for a sample Addendum to the House Rules.

15 a. Termination Notification. HUD is incorporating additional termination notification requirements to comply with section 6 of the Act for public housing projects converting assistance under RAD, that supplement notification requirements in regulations at 24 CFR and the Multifamily HUD Model Lease. i. Termination of Tenancy and Assistance. The termination procedure for RAD conversions to PBRA will additionally require that PHAs (as owners) provide adequate written notice of termination of the lease which shall not be less than: A reasonable period of time, but not to exceed 30 days: o If the health or safety of other tenants, owner employees, or persons residing in the immediate vicinity of the premises is threatened; or o In the event of any drug-related or violent criminal activity or any felony conviction; or 14 days in the case of nonpayment of rent. ii. Termination of Assistance. In all other cases, the requirements at 24 CFR , the Multifamily HUD Model Lease, and any other HUD multifamily administrative guidance shall apply. b. Grievance Process. In addition to program rules that require that tenants are given notice of covered actions under 24 CFR Part 245 (including increases in rent, conversions of a project from project-paid utilities to tenant-paid utilities, or a reduction in tenant paid utility allowances), HUD is incorporating resident procedural rights to comply with the requirements of section 6 of the Act. RAD will require that: i. Residents be provided with notice of the specific grounds of the proposed owner adverse action, as well as their right to an informal hearing with the PHA (as owner); ii. Residents will have an opportunity for an informal hearing with an impartial member of PHA s staff (as owner) within a reasonable period of time; iii. Residents will have the opportunity to be represented by another person of their choice, to ask questions of witnesses, have others make statements at the hearing, and to examine any regulations and any evidence relied upon by the owner as the basis for the adverse action. With reasonable notice to the PHA (as owner), prior to hearing and at the residents own cost, resident may copy any documents or records related to the proposed adverse action; and iv. PHAs (as owners) provide the resident with a written decision within a reasonable period of time stating the grounds for the adverse action, and the evidence the PHA (as owner) relied on as the basis for the adverse action. The PHA (as owner) will be bound by decisions from these hearings, except if the: i. Hearing concerns a matter that exceeds the authority of the impartial party conducting the hearing.

16 ii. Decision is contrary to HUD regulations or requirements, or otherwise contrary to federal, State, or local law. If the PHA (as owner) determines that it is not bound by a hearing decision, the PHA must promptly notify the resident of this determination, and of the reasons for the determination. 7. Earned Income Disregard (EID). Tenants who are employed and are currently receiving the EID exclusion at the time of conversion will continue to receive the EID exclusion after conversion, in accordance with regulations at 24 CFR After conversion, no other tenants will be eligible to receive the EID. If a tenant receiving the EID exclusion undergoes a break in employment, ceases to use the EID exclusion, or the EID exclusion expires in accordance with 24 CFR , the tenant will no longer receive the EID exclusion and the Owner will no longer be subject to the provisions of 24 CFR Furthermore, tenants whose EID ceases or expires after conversion shall not be subject to the rent phase-in provision, as described in Section 1.7.B.3; instead, the rent will automatically be adjusted to the appropriate rent level based upon tenant income at that time. 8. Capital Fund Education and Training Community Facilities (CFCF) Program. CFCF provides capital funding to PHAs for the construction, rehabilitation, or purchase of facilities to provide early childhood education, adult education, and job training programs for public housing residents based on an identified need. Where a community facility has been developed under CFCF in connection to or serving the residents of an existing public housing project converting its assistance under RAD, residents will continue to qualify as PHA residents for the purposes of CFCF program compliance. To the greatest extent possible the community facility should continue to be available to public housing residents. C. PBRA: Other Miscellaneous Provisions 1. Access to Records, including Requests for Information Related to Evaluation of Demonstration. PHAs must agree to any reasonable HUD request for data to support program evaluation, including but not limited to project financial statements, operating data, Choice-Mobility utilization, and rehabilitation work. 2. Davis-Bacon Act and Section 3 of the Housing and Urban Development Act of 1968 (Section 3). The Davis-Bacon Act (prevailing wages, the Contract Work Hours and Safety Standards Act, and other related regulations, rules, and requirements) and Section Section I: Public Housing Projects PIH (HA) Rental Assistance Demonstration Final Implementation 573 (24 CFR Part 135) apply to all initial repairs that are identified in the Financing Plan to the extent that such repairs qualify as construction or rehabilitation. (The Davis-Bacon Act only applies for projects with nine or more units.) 3. Establishment of Waiting List. In establishing the waiting list for the converted project, the PHA shall utilize the project-specific waiting list that existed at the time of conversion. If a project-specific waiting list does exist, but the PHA is transferring the assistance to another neighborhood, the PHA must notify applicants on the wait-list of the transfer of assistance, and on how they can apply for residency at the new project site or other sites. Applicants on a project-specific waiting list for a project where the assistance is being transferred shall have priority on the newly formed waiting list for the new project site in accordance with the date and time of their application to the original project's waiting list.

17 If a project-specific waiting list for the project does not exist, the PHA shall establish a waiting list in accordance 24 CFR 903.7(b)(2)(ii)-(iv) to ensure that applicants on the PHA s public housing community-wide waiting list have been offered placement on the converted project s initial waiting list. For the purpose of establishing the initial waiting list, PHAs have the discretion to determine the most appropriate means of informing applicants on the public housing waiting list given the number of applicants, PHA resources, and community characteristics of the proposed conversion under RAD. Such activities should be pursuant to the PHA s policies for waiting list management, including the obligation to affirmatively further fair housing. A PHA may consider contacting every applicant on the public housing waiting list via direct mailing; advertising the availability of housing to the population that is less likely to apply, both minority and non-minority groups, through various forms of media (i.e. radio stations, posters, newspapers) within the marketing area; informing local non-profit entities and advocacy groups (i.e., disability rights groups); and conducting other outreach as appropriate. Applicants on the agency s centralized public housing waiting list who wish to be placed onto the newly-established waiting list are done so in accordance with the date and time of their original application to the centralized public housing waiting list. Any activities to contact applicants on the public housing waiting list must be conducted accordance with the requirements for effective communication with persons with disabilities at 24 CFR 8.6 and the obligation to provide meaningful access for persons with limited English proficiency (LEP). To implement this provision, HUD will not apply 24 CFR , regarding selection and admission of assisted tenants. However, after the initial waiting list has been established, the PHA shall administer its waiting list for the converted project in accordance with 24 CFR Mandatory Insurance Coverage. The project shall maintain at all times commercially available property and liability insurance to protect the project from financial loss and, to the extent insurance proceeds permit, promptly restore, reconstruct, and/or repair any damaged or destroyed property of a project, except with the written approval of HUD to the contrary. 5. Choice-Mobility. HUD seeks to provide all residents of covered projects with viable Choice-Mobility options. PHAs that are applying to convert the assistance of a project to PBRA are required to provide a Choice-Mobility option to residents of covered projects in accordance with the following: a. Resident Eligibility. Residents have a right to move with tenant-based rental assistance (e.g., Housing Choice Voucher (HCV)) the later of: (a) 24 months from date of execution of the HAP or (b) 24 months after the move-in date. b. Voucher Inventory Turnover Cap. Recognizing the limitation on the availability of turnover vouchers from year to year, a voucher agency would not be required, in any year, to provide more than one-third of its turnover vouchers to the residents of covered projects. While a voucher agency is not required to establish a voucher inventory turnover cap, if implemented the voucher agency must create and maintain a waiting list in the order in which the requests from eligible households were received. c. Project Turnover Cap. Also recognizing the limited availability of turnover vouchers and the importance of managing turnover in the best interests of the property, in any year, a PHA may limit the number of Choice-Mobility moves exercised by eligible households to 15 percent of the assisted units in the project. (For example, if the project has 100 assisted units, the PHA could limit the number of families exercising Choice-Mobility to 15 in any year, but not less