Annual PHA Plan (Standard PHAs and Troubled PHAs)

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1 Annual PHA Plan (Standard PHAs and Troubled PHAs) U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No Expires: 02/29/2016 Purpose. The 5-Year and Annual PHA Plans provide a ready source for interested parties to locate basic PHA policies, rules, and requirements concerning the PHA s operations, programs, and services, and informs HUD, families served by the PHA, and members of the public of the PHA s mission, goals and objectives for serving the needs of low- income, very low- income, and extremely low- income families. Applicability. Form HUD ST is to be completed annually by STANDARD PHAs or TROUBLED PHAs. PHAs that meet the definition of a High Performer PHA, Small PHA, HCV-Only PHA or Qualified PHA do not need to submit this form. Definitions. (1) High-Performer PHA A PHA that owns or manages more than 550 combined public housing units and housing choice vouchers, and was designated as a high performer on both of the most recent Public Housing Assessment System (PHAS) and Section Eight Management Assessment Program (SEMAP) assessments if administering both programs, or PHAS if only administering public housing. (2) Small PHA - A PHA that is not designated as PHAS or SEMAP troubled, or at risk of being designated as troubled, that owns or manages less than 250 public housing units and any number of vouchers where the total combined units exceeds 550. (3) Housing Choice Voucher (HCV) Only PHA - A PHA that administers more than 550 HCVs, was not designated as troubled in its most recent SEMAP assessment and does not own or manage public housing. (4) Standard PHA - A PHA that owns or manages 250 or more public housing units and any number of vouchers where the total combined units exceeds 550, and that was designated as a standard performer in the most recent PHAS or SEMAP assessments. (5) Troubled PHA - A PHA that achieves an overall PHAS or SEMAP score of less than 60 percent. (6) Qualified PHA - A PHA with 550 or fewer public housing dwelling units and/or housing choice vouchers combined, and is not PHAS or SEMAP troubled. A. PHA Information. A.1 PHA Name: PHA Code: PHA Type: Standard PHA Troubled PHA PHA Plan for Fiscal Year Beginning: (MM/YYYY): PHA Inventory (Based on Annual Contributions Contract (ACC) units at time of FY beginning, above) Number of Public Housing (PH) Units Number of Housing Choice Vouchers (HCVs) Total Combined Units/Vouchers PHA Plan Submission Type: Annual Submission Revised Annual Submission Availability of Information. PHAs must have the elements listed below in sections B and C readily available to the public. A PHA must identify the specific location(s) where the proposed PHA Plan, PHA Plan Elements, and all information relevant to the public hearing and proposed PHA Plan are available for inspection by the public. At a minimum, PHAs must post PHA Plans, including updates, at each Asset Management Project (AMP) and main office or central office of the PHA. PHAs are strongly encouraged to post complete PHA Plans on their official website. PHAs are also encouraged to provide each resident council a copy of their PHA Plans. PHA Consortia: (Check box if submitting a Joint PHA Plan and complete table below) Participating PHAs PHA Code Program(s) in the Consortia Lead PHA: Program(s) not in the Consortia No. of Units in Each Program PH HCV Page 1 of 6 form HUD ST (12/2014) PAGE 1

2 B. Annual Plan Elements B.1 Revision of PHA Plan Elements. (a) Have the following PHA Plan elements been revised by the PHA? Y N Statement of Housing Needs and Strategy for Addressing Housing Needs Deconcentration and Other Policies that Govern Eligibility, Selection, and Admissions. Financial Resources. Rent Determination. Operation and Management. Grievance Procedures. Homeownership Programs. Community Service and Self-Sufficiency Programs. Safety and Crime Prevention. Pet Policy. Asset Management. Substantial Deviation. Significant Amendment/Modification (b) If the PHA answered yes for any element, describe the revisions for each revised element(s): (c) The PHA must submit its Deconcentration Policy for Field Office review. B.2 New Activities. (a) Does the PHA intend to undertake any new activities related to the following in the PHA s current Fiscal Year? Y N Hope VI or Choice Neighborhoods. Mixed Finance Modernization or Development. Demolition and/or Disposition. Designated Housing for Elderly and/or Disabled Families. Conversion of Public Housing to Tenant-Based Assistance. Conversion of Public Housing to Project-Based Assistance under RAD. Occupancy by Over-Income Families. Occupancy by Police Officers. Non-Smoking Policies. Project-Based Vouchers. Units with Approved Vacancies for Modernization. Other Capital Grant Programs (i.e., Capital Fund Community Facilities Grants or Emergency Safety and Security Grants). (b) If any of these activities are planned for the current Fiscal Year, describe the activities. For new demolition activities, describe any public housing development or portion thereof, owned by the PHA for which the PHA has applied or will apply for demolition and/or disposition approval under section 18 of the 1937 Act under the separate demolition/disposition approval process. If using Project-Based Vouchers (PBVs), provide the projected number of project based units and general locations, and describe how project basing would be consistent with the PHA Plan. B.3 Civil Rights Certification. Form HUD-50077, PHA Certifications of Compliance with the PHA Plans and Related Regulations, must be submitted by the PHA as an electronic attachment to the PHA Plan. B.4 Most Recent Fiscal Year Audit. (a) Were there any findings in the most recent FY Audit? Y N (b) If yes, please describe: Page 2 of 6 form HUD ST (12/2014) PAGE 2

3 B.5 Progress Report. Provide a description of the PHA s progress in meeting its Mission and Goals described in the PHA 5-Year and Annual Plan. B.6 Resident Advisory Board (RAB) Comments. (a) Did the RAB(s) provide comments to the PHA Plan? Y N (c) If yes, comments must be submitted by the PHA as an attachment to the PHA Plan. PHAs must also include a narrative describing their analysis of the RAB recommendations and the decisions made on these recommendations. B.7 Certification by State or Local Officials. Form HUD SL, Certification by State or Local Officials of PHA Plans Consistency with the Consolidated Plan, must be submitted by the PHA as an electronic attachment to the PHA Plan. B.8 Troubled PHA. (a) Does the PHA have any current Memorandum of Agreement, Performance Improvement Plan, or Recovery Plan in place? Y N N/A (b) If yes, please describe: C. Statement of Capital Improvements. Required for all PHAs completing this form that administer public housing and receive funding from the Capital Fund Program (CFP). C.1 Capital Improvements. Include a reference here to the most recent HUD-approved 5-Year Action Plan (HUD ) and the date that it was approved by HUD. Page 3 of 6 form HUD ST (12/2014) PAGE 3

4 Instructions for Preparation of Form HUD ST Annual PHA Plan for Standard and Troubled PHAs A. PHA Information. All PHAs must complete this section. A.1 Include the full PHA Name, PHA Code, PHA Type, PHA Fiscal Year Beginning (MM/YYYY), PHA Inventory, Number of Public Housing Units and or Housing Choice Vouchers (HCVs), PHA Plan Submission Type, and the Availability of Information, specific location(s) of all information relevant to the public hearing and proposed PHA Plan. (24 CFR (4)(e)) PHA Consortia: Check box if submitting a Joint PHA Plan and complete the table. (24 CFR (a)) B. Annual Plan. All PHAs must complete this section. B.1 Revision of PHA Plan Elements. PHAs must: Identify specifically which plan elements listed below that have been revised by the PHA. To specify which elements have been revised, mark the yes box. If an element has not been revised, mark no." (24 CFR 903.7) Statement of Housing Needs and Strategy for Addressing Housing Needs. Provide a statement addressing the housing needs of low-income, very low-income and extremely low-income families and a brief description of the PHA s strategy for addressing the housing needs of families who reside in the jurisdiction served by the PHA. The statement must identify the housing needs of (i) families with incomes below 30 percent of area median income (extremely low-income), (ii) elderly families and families with disabilities, and (iii) households of various races and ethnic groups residing in the jurisdiction or on the waiting list based on information provided by the applicable Consolidated Plan, information provided by HUD, and other generally available data. The identification of housing needs must address issues of affordability, supply, quality, accessibility, size of units, and location. (24 CFR 903.7(a)(1)) Provide a 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. (24 CFR 903.7(a)(2)(ii)) Deconcentration and Other Policies that Govern Eligibility, Selection, and Admissions. PHAs must submit a Deconcentration Policy for Field Office review. For additional guidance on what a PHA must do to deconcentrate poverty in its development and comply with fair housing requirements, see 24 CFR (24 CFR (b)) Describe the PHA s admissions policy for deconcentration of poverty and income mixing of lower-income families in public housing. The Deconcentration Policy must describe the PHA s policy for bringing higher income tenants into lower income developments and lower income tenants into higher income developments. The deconcentration requirements apply to general occupancy and family public housing developments. Refer to 24 CFR 903.2(b)(2) for developments not subject to deconcentration of poverty and income mixing requirements. (24 CFR 903.7(b)) Describe the PHA s procedures for maintain waiting lists for admission to public housing and address any site-based waiting lists. (24 CFR 903.7(b)). A statement of the PHA s policies that govern resident or tenant eligibility, selection and admission including admission preferences for both public housing and HCV. (24 CFR 903.7(b)) Describe the unit assignment policies for public housing. (24 CFR 903.7(b)) Financial Resources. A statement of financial resources, including a listing by general categories, of the PHA s anticipated resources, such as PHA operating, capital and other anticipated Federal resources available to the PHA, as well as tenant rents and other income available to support public housing or tenant-based assistance. The statement also should include the non-federal sources of funds supporting each Federal program, and state the planned use for the resources. (24 CFR 903.7(c)) Rent Determination. A statement of the policies of the PHA governing rents charged for public housing and HCV dwelling units, including applicable public housing flat rents, minimum rents, voucher family rent contributions, and payment standard policies. (24 CFR 903.7(d)) Operation and Management. A statement of the rules, standards, and policies of the PHA governing maintenance and management of housing owned, assisted, or operated by the public housing agency (which shall include measures necessary for the prevention or eradication of pest infestation, including cockroaches), and management of the PHA and programs of the PHA. (24 CFR 903.7(e)) Grievance Procedures. A description of the grievance and informal hearing and review procedures that the PHA makes available to its residents and applicants. (24 CFR 903.7(f)) Homeownership Programs. A description of any Section 5h, Section 32, Section 8y, or HOPE I public housing or Housing Choice Voucher (HCV) homeownership programs (including project number and unit count) administered by the agency or for which the PHA has applied or will apply for approval. (24 CFR 903.7(k)) Community Service and Self Sufficiency Programs. Describe how the PHA will comply with the requirements of community service and treatment of income changes resulting from welfare program requirements. (24 CFR 903.7(l)) A description of: 1) Any programs relating to services and amenities provided or offered to assisted families; and 2) Any policies or programs of the PHA for the enhancement of the economic and social self-sufficiency of assisted families, including programs under Section 3 and FSS. (24 CFR 903.7(l)) Safety and Crime Prevention. Describe the PHA s plan for safety and crime prevention to ensure the safety of the public housing residents. The statement must provide development-by-development or jurisdiction wide-basis: (i) A description of the need for measures to ensure the safety of public housing residents; (ii) A description of any crime prevention activities conducted or to be conducted by the PHA; and (iii) A description of the coordination between the PHA and the appropriate police precincts for carrying out crime prevention measures and activities. (24 CFR 903.7(m)) A description of: 1) Any activities, services, or programs provided or offered by an agency, either directly or in partnership with other service providers, to child or adult victims of domestic violence, dating violence, sexual assault, or stalking; 2) Any activities, services, or programs provided or offered by a PHA that helps child and adult victims of domestic violence, dating violence, sexual assault, or stalking, to obtain or maintain housing; and 3) Any activities, services, or programs Page 4 of 6 form HUD ST (12/2014) PAGE 4

5 provided or offered by a public housing agency to prevent domestic violence, dating violence, sexual assault, and stalking, or to enhance victim safety in assisted families. (24 CFR 903.7(m)(5)) Pet Policy. Describe the PHA s policies and requirements pertaining to the ownership of pets in public housing. (24 CFR 903.7(n)) Asset Management. State how the agency will carry out its asset management functions with respect to the public housing inventory of the agency, including how the agency will plan for the long-term operating, capital investment, rehabilitation, modernization, disposition, and other needs for such inventory. (24 CFR 903.7(q)) Substantial Deviation. PHA must provide its criteria for determining a substantial deviation to its 5-Year Plan. (24 CFR 903.7(r)(2)(i)) Significant Amendment/Modification. PHA must provide its criteria for determining a Significant Amendment or Modification to its 5-Year and Annual Plan. Should the PHA fail to define significant amendment/modification, HUD will consider the following to be significant amendments or modifications : a) changes to rent or admissions policies or organization of the waiting list; b) additions of non-emergency CFP work items (items not included in the current CFP Annual Statement or CFP 5-Year Action Plan) or change in use of replacement reserve funds under the Capital Fund; or c) any change with regard to demolition or disposition, designation, homeownership programs or conversion activities. See guidance on HUD s website at: Notice PIH (24 CFR 903.7(r)(2)(ii)) If any boxes are marked yes, describe the revision(s) to those element(s) in the space provided. B.2 New Activities. If the PHA intends to undertake any new activities related to these elements in the current Fiscal Year, mark yes for those elements, and describe the activities to be undertaken in the space provided. If the PHA does not plan to undertake these activities, mark no. Hope VI or Choice Neighborhoods. 1) A description of any housing (including project number (if known) and unit count) for which the PHA will apply for HOPE VI or Choice Neighborhoods; and 2) A timetable for the submission of applications or proposals. The application and approval process for Hope VI or Choice Neighborhoods is a separate process. See guidance on HUD s website at: (Notice PIH ) Mixed Finance Modernization or Development. 1) A description of any housing (including project number (if known) and unit count) for which the PHA will apply for Mixed Finance Modernization or Development; and 2) A timetable for the submission of applications or proposals. The application and approval process for Mixed Finance Modernization or Development is a separate process. See guidance on HUD s website at: (Notice PIH ) Demolition and/or Disposition. Describe any public housing projects owned by the PHA and subject to ACCs (including project number and unit numbers [or addresses]), and the number of affected units along with their sizes and accessibility features) for which the PHA will apply or is currently pending for demolition or disposition; and (2) A timetable for the demolition or disposition. This statement must be submitted to the extent that approved and/or pending demolition and/or disposition has changed as described in the PHA s last Annual and/or 5-Year PHA Plan submission. The application and approval process for demolition and/or disposition is a separate process. See guidance on HUD s website at: (24 CFR 903.7(h)) Designated Housing for Elderly and Disabled Families. Describe any public housing projects owned, assisted or operated by the PHA (or portions thereof), in the upcoming fiscal year, that the PHA has continually operated as, has designated, or will apply for designation for occupancy by elderly and/or disabled families only. Include the following information: 1) development name and number; 2) designation type; 3) application status; 4) date the designation was approved, submitted, or planned for submission, and; 5) the number of units affected. Note: The application and approval process for such designations is separate from the PHA Plan process, and PHA Plan approval does not constitute HUD approval of any designation. (24 CFR 903.7(i)(C)) Conversion of Public Housing. Describe any public housing building(s) (including project number and unit count) owned by the PHA that the PHA is required to convert or plans to voluntarily convert to tenant-based assistance; 2) An analysis of the projects or buildings required to be converted; and 3) A statement of the amount of assistance received to be used for rental assistance or other housing assistance in connection with such conversion. See guidance on HUD s website at: (24 CFR 903.7(j)) Conversion of Public Housing. Describe any public housing building(s) (including project number and unit count) owned by the PHA that the PHA plans to voluntarily convert to project-based assistance under RAD. See additional guidance on HUD s website at: Notice PIH Occupancy by Over-Income Families. A PHA that owns or operates fewer than two hundred fifty (250) public housing units, may lease a unit in a public housing development to an over-income family (a family whose annual income exceeds the limit for a low income family at the time of initial occupancy), if all the following conditions are satisfied: (1) There are no eligible low income families on the PHA waiting list or applying for public housing assistance when the unit is leased to an over-income family; (2) The PHA has publicized availability of the unit for rental to eligible low income families, including publishing public notice of such availability in a newspaper of general circulation in the jurisdiction at least thirty days before offering the unit to an over-income family; (3) The over-income family rents the unit on a month-to-month basis for a rent that is not less than the PHA's cost to operate the unit; (4) The lease to the over-income family provides that the family agrees to vacate the unit when needed for rental to an eligible family; and (5) The PHA gives the over-income family at least thirty days notice to vacate the unit when the unit is needed for rental to an eligible family. The PHA may incorporate information on occupancy by over-income families into its PHA Plan statement of deconcentration and other policies that govern eligibility, selection, and admissions. See additional guidance on HUD s website at: Notice PIH (24 CFR ) (24 CFR 903.7(b)) Occupancy by Police Officers. The PHA may allow police officers who would not otherwise be eligible for occupancy in public housing, to reside in a public housing dwelling unit. The PHA must include the number and location of the units to be occupied by police officers, and the terms and conditions of their tenancies; and a statement that such occupancy is needed to increase security for public housing residents. A police officer means a person determined by the PHA to be, during the period of residence of that person in public housing, employed on a full-time basis as a duly licensed professional police officer by a Federal, State or local government or by any agency of these governments. An officer of an accredited police force of a housing agency may qualify. The PHA may incorporate information on occupancy by police officers into its PHA Plan statement of deconcentration and other policies that govern eligibility, selection, and admissions. See additional guidance on HUD s website at: Notice PIH (24 CFR ) (24 CFR 903.7(b)) Page 5 of 6 form HUD ST (12/2014) PAGE 5

6 Non-Smoking Policies. The PHA may implement non-smoking policies in its public housing program and incorporate this into its PHA Plan statement of operation and management and the rules and standards that will apply to its projects. See additional guidance on HUD s website at: Notice PIH (24 CFR 903.7(e)) Project-Based Vouchers. Describe any plans to use Housing Choice Vouchers (HCVs) for new project-based vouchers, which must comply with PBV goals, civil rights requirements, Housing Quality Standards (HQS) and deconcentration standards, as stated in (b)(1) and set forth in the PHA Plan statement of deconcentration and other policies that govern eligibility, selection, and admissions. If using project-based vouchers, provide the projected number of project-based units and general locations, and describe how project-basing would be consistent with the PHA Plan. (24 CFR 903.7(b)) Units with Approved Vacancies for Modernization. The PHA must include a statement related to units with approved vacancies that are undergoing modernization in accordance with 24 CFR (a)(1). Other Capital Grant Programs (i.e., Capital Fund Community Facilities Grants or Emergency Safety and Security Grants). For all activities that the PHA plans to undertake in the current Fiscal Year, provide a description of the activity in the space provided. B.3 Civil Rights Certification. Form HUD-50077, PHA Certifications of Compliance with the PHA Plans and Related Regulation, must be submitted by the PHA as an electronic attachment to the PHA Plan. This includes all certifications relating to Civil Rights and related regulations. A PHA will be considered in compliance with the AFFH Certification if: it can document that it examines its programs and proposed programs to identify any impediments to fair housing choice within those programs; addresses those impediments in a reasonable fashion in view of the resources available; works with the local jurisdiction to implement any of the jurisdiction s initiatives to affirmatively further fair housing; and assures that the annual plan is consistent with any applicable Consolidated Plan for its jurisdiction. (24 CFR 903.7(o)) B.4 Most Recent Fiscal Year Audit. If the results of the most recent fiscal year audit for the PHA included any findings, mark yes and describe those findings in the space provided. (24 CFR 903.7(p)) B.5 Progress Report. For all Annual Plans following submission of the first Annual Plan, a PHA must include a brief statement of the PHA s progress in meeting the mission and goals described in the 5-Year PHA Plan. (24 CFR 903.7(r)(1)) B.6 Resident Advisory Board (RAB) comments. If the RAB provided comments to the annual plan, mark yes, submit the comments as an attachment to the Plan and describe the analysis of the comments and the PHA s decision made on these recommendations. (24 CFR (c), 24 CFR ) B.7 Certification by State of Local Officials. Form HUD SL, Certification by State or Local Officials of PHA Plans Consistency with the Consolidated Plan, must be submitted by the PHA as an electronic attachment to the PHA Plan. (24 CFR ). Note: A PHA may request to change its fiscal year to better coordinate its planning with planning done under the Consolidated Plan process by State or local officials as applicable. B.8 Troubled PHA. If the PHA is designated troubled, and has a current MOA, improvement plan, or recovery plan in place, mark yes, and describe that plan. If the PHA is troubled, but does not have any of these items, mark no. If the PHA is not troubled, mark N/A. (24 CFR 903.9) C. Statement of Capital Improvements. PHAs that receive funding from the Capital Fund Program (CFP) must complete this section. (24 CFR (g)) C.1 Capital Improvements. In order to comply with this requirement, the PHA must reference the most recent HUD approved Capital Fund 5 Year Action Plan. PHAs can reference the form by including the following language in Section C. 8.0 of the PHA Plan Template: See HUD Form approved by HUD on XX/XX/XXXX. This information collection is authorized by Section 511 of the Quality Housing and Work Responsibility Act, which added a new section 5A to the U.S. Housing Act of 1937, as amended, which introduced the 5-Year and Annual PHA Plan. Public reporting burden for this information collection is estimated to average 9.2 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. HUD may not collect this information, and respondents are not required to complete this form, unless it displays a currently valid OMB Control Number. Privacy Act Notice. The United States Department of Housing and Urban Development is authorized to solicit the information requested in this form by virtue of Title 12, U.S. Code, Section 1701 et seq., and regulations promulgated thereunder at Title 12, Code of Federal Regulations. Responses to the collection of information are required to obtain a benefit or to retain a benefit. The information requested does not lend itself to confidentiality. Page 6 of 6 form HUD ST (12/2014) PAGE 6

7 Attachment B.1(b) Revision of PHA Plan Elements PAGE 7

8 Statement of Housing Needs and Strategy for Addressing Housing Needs. Statement of Housing Needs Housing Needs of Families on the Waiting List Waiting list type: (select one) Public Housing # of families % of total families Annual Turnover Waiting list total 6002 Extremely low % income <=30% AMI Very low income % (>30% but <=50% AMI) Low income (>50% but <80% AMI) 221 4% Families with % children Elderly families % Families with % Disabilities Black % White 60 1% Other 59 1% Single % Characteristics by Bedroom Size (Public Housing Only) 1BR % 2 BR % 3 BR 86 1% 4 BR 468 8% 5 BR 121 2% 5+ BR PAGE 8

9 Housing Needs of Families on the Waiting List Is the waiting list closed (select one)? Yes If yes: HOW LONG HAS IT BEEN CLOSED (# OF MONTHS)? 8 MONTHS Does the PHA expect to reopen the list in the PHA Plan year? Yes Does the PHA permit specific categories of families onto the waiting list, even if generally closed? No Housing Needs of Families on the Waiting List (INCLUDES ALL EXCEPT MOD REHAB) Waiting list type: (select one) Section 8 tenant-based assistance # of families % of total families Annual Turnover Waiting list total Extremely low income <=30% AMI % Very low income (>30% but <=50% % AMI) Low income (>50% but <80% % AMI) Families with children % Elderly families % Families with Disabilities % Black % White % Other % Is the waiting list closed (select one)? No Yes HOW LONG HAS IT BEEN CLOSED (# OF MONTHS)? 47 MONTHS (JANUARY 2013) Does the PHA expect to reopen the list in the PHA Plan year? No Yes Does the PHA permit specific categories of families onto the waiting list, even if generally closed? No Yes Age 62+ Applicants for Project-Based Vouchers PAGE 9

10 Financial Resources [24 CFR Part (b)] Financial Resources: Planned Sources and Uses Sources Planned $ Planned Uses 1. Federal Grants (FY 2016 grants) a) Public Housing Operating Fund $4,813,047 b) Public Housing Capital Fund $1,608,359 c) HOPE VI Revitalization d) HOPE VI Demolition e) Annual Contributions for Section 8 Tenant-Based Assistance f) Public Housing Drug Elimination Program (including any Technical Assistance funds) g) Resident Opportunity and Self- Sufficiency Grants h) Community Development Block Grant i) HOME Other Federal Grants (list below) SNAP Grant Mod Rehab & SRO Assistance RAD 2. Prior Year Federal Grants (unobligated funds only) (list below) CFP GA06P CFP GA CFP GA $21,172,505 $130,000 $975,000 $1,169,776 $1,828,594 $750,000 $2,144,478 $2,268,645 S8 Tenant-Based Assistance S8 Project-Based Assistance PH Capital Improvements 3. Public Housing Dwelling Rental Income Dwelling Rents (net) $2,435,393 Operations Maintenance Charges & Other $503,139 Operations 4. Other Income (list below) Non-Dwelling Rentals (net) $177,308 Operations Investment, Public Housing $44,500 Operations Investment, Section 8 $5,150 Operations PAGE 10

11 Financial Resources: Planned Sources and Uses Sources Planned $ Planned Uses HOPE VI Endowment Fund $200,000 Former PH Residents Self-Sufficiency 5. Non-federal sources (list below) Total resources $40,225,892 [24 CFR Part (d)] PAGE 11

12 Community Service and Self-Sufficiency Programs. Services and Programs Program Name & Description (including location, if appropriate) Estimated Size Resident Services Program This program works collaboratively with various agencies, organizations and businesses to determine how programs and services can be made available to residents. Early Learning Program The Early Learning Program is a unique web based opportunity for parents to learn fun, educational ways to engage their children. Sessions are held weekly for parents and children ages 6 weeks- 4 years old. Personal Empowerment Program The Personal Empowerment Program is a weekly program, which focuses on an array of topics to encourage, celebrate and support individuals and families residing in public housing. Available to all residents Available to all PH residents with children ages 6wks to 4yrs old All adult PH residents Economic Opportunity Authority (EOA) Certified Housing Counselors Program EOA has counselors certified by the National Federation of Housing Counselors to provide counseling services, without cost, to consumers interested in buying a home. The Housing Authority will continue to refer residents to EOA for counseling. Available to all residents Allocation Method (waiting list/random selection/specific criteria/other) Access (development office / PHA main office / other provider name) N/A Neighborhood Resource Center Eligibility (public housing or Section 8 participants or both) Public housing N/A HAS Neighborhood Resource Center Public Housing N/A Blackshear Community Center Public Housing N/A referral Public housing and Section 8 PAGE 12

13 Chatham County Department of Family and Children Services (DFCS) DFCS administers the Temporary Assistance to Needy Families (TANF) program and all related programs and services pursuant to the Welfare Reform Act. Step Up Savannah Step Up acts as a convener, attracts outside resources, adapts and creates effective programs and products, trains neighborhood and nonprofit leaders, and advocates for policies that will improve the lives of low-income families. Step Up Programs include the Chatham Apprentice Program, which helps unemployed and underemployed Chatham County residents find or create career paths that offer decent wages and opportunities for advancement. HAS partners with the organization to provide employment training and other resources to residents. EOA Headstart Program Childcare program. Senior Citizens, Inc. Offers a variety of services to the senior population including various classes, training and support services. Also provides hot meals to seniors through Meals on Wheels. All TANF recipients Pursuant to MOU referral Public housing and Section 8 Available to all residents Pursuant to MOU Neighborhood Resource Center Public housing & Section Waiting lists, referrals, first priority to Housing Authority residents EOA (618 W. Henry Street), Housing Authority neighborhoods Public housing Undetermined N/A Referral; Meals on Wheels located at Neighborhood Resource Center. Public Housing PAGE 13

14 Significant Amendment/Modification A significant amendment or modification of the 5-year plan or annual plan includes a major deviation from any activity, proposed activity, or policy provided in the agency plan that would affect services or programs provided to residents. This definition does not include minor budget revisions to previously approved activities; changes in organizational structure; changes resulting from HUD-imposed regulations; or minor policy changes; or changes to flat rent schedules and policies that will remain in compliance with Sections 210 and 243 of Title II of Public Law , the Consolidated Appropriations Act of 2014, 24 CFR 903.7(d) and implementing HUD guidance. As part of the Rental Assistance Demonstration (RAD), the Housing Authority of Savannah is redefining the definition of a substantial deviation from the PHA Plan to exclude the following RAD-specific items: The decision to convert to either Project Based Rental Assistance or Project Based Voucher Assistance; A. 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; B. Changes to the construction and rehabilitation plan for each approved RAD conversion; and C. Changes to the financing structure for each approved RAD conversion PAGE 14

15 Attachment B.1(c) Deconcentration Policy PAGE 15

16 Deconcentration of Poverty and Income-Mixing [24 CFR and 903.2] The HAS's admission policy must be designed to provide for deconcentration of poverty and income-mixing by bringing higher income residents into lower income projects and lower income residents into higher income projects. A statement of the HAS s deconcentration policies must be in included in its annual plan [24 CFR 903.7(b)]. The HAS s deconcentration policy must comply with its obligation to meet the income targeting requirement [24 CFR 903.2(c)(5)]. Developments subject to the deconcentration requirement are referred to as covered developments and include general occupancy (family) public housing developments. The following developments are not subject to deconcentration and income mixing requirements: developments operated by a HAS with fewer than 100 public housing units; mixed population or developments designated specifically for elderly or disabled families; developments operated by a HAS with only one general occupancy development; developments approved for demolition or for conversion to resident-based public housing; and developments approved for a mixed-finance plan using HOPE VI or public housing funds [24 CFR 903.2(b)]. Steps for Implementation [24 CFR 903.2(c)(1)] To implement the statutory requirement to deconcentrate poverty and provide for income mixing in covered developments, the HAS must comply with the following steps: Step 1. The HAS must determine the average income of all families residing in all the HAS's covered developments. The HAS may use the median income, instead of average income, provided that the HAS includes a written explanation in its annual plan justifying the use of median income. HAS Policy The HAS will determine the average income of all families in all covered developments on an annual basis. Step 2. The HAS must determine the average income (or median income, if median income was used in Step 1) of all families residing in each covered development. In determining average income for each development, the HAS has the option of adjusting its income analysis for unit size in accordance with procedures prescribed by HUD. HAS Policy The HAS will determine the average income of all families residing in each covered development (not adjusting for unit size) on an annual basis. Step 3. The HAS must then determine whether each of its covered developments falls above, within, or below the established income range (EIR), which is from 85% to 115% of the average family income determined in Step 1. However, the upper limit must never be less than the income at which a family would be defined as an extremely low-income family (federal poverty level or 30 percent of median income, whichever number is higher). Excerpt from HAS ACOP Effective 06/14/2016 PAGE 16

17 Step 4. The HAS with covered developments having average incomes outside the EIR must then determine whether or not these developments are consistent with its local goals and annual plan. Step 5. Where the income profile for a covered development is not explained or justified in the annual plan submission, the HAS must include in its admission policy its specific policy to provide for deconcentration of poverty and income mixing. Depending on local circumstances the HAS s deconcentration policy may include, but is not limited to the following: Providing incentives to encourage families to accept units in developments where their income level is needed, including rent incentives, affirmative marketing plans, or added amenities Targeting investment and capital improvements toward developments with an average income below the EIR to encourage families with incomes above the EIR to accept units in those developments Establishing a preference for admission of working families in developments below the EIR Skipping a family on the waiting list to reach another family in an effort to further the goals of deconcentration Providing other strategies permitted by statute and determined by the HAS in consultation with the residents and the community through the annual plan process to be responsive to local needs and HAS strategic objectives A family has the sole discretion whether to accept an offer of a unit made under the HAS's deconcentration policy. The HAS must not take any adverse action toward any eligible family for choosing not to accept an offer of a unit under the HAS's deconcentration policy [24 CFR 903.2(c)(4)]. If, at annual review, the average incomes at all general occupancy developments are within the EIR, the HAS will be considered to be in compliance with the deconcentration requirement and no further action is required. HAS Policy For developments outside the EIR the HAS will take the following actions to provide for deconcentration of poverty and income mixing: Skipping a family on the waiting list to reach another family in an effort to further the goals of deconcentration. Excerpt from HAS ACOP Effective 06/14/2016 PAGE 17

18 Order of Selection [24 CFR (e)] The HAS system of preferences may select families either according to the date and time of application or by a random selection process. HAS Policy Families will be selected from the waiting list based on preference. Among applicants with the same preference, families will be selected on a first-come, firstserved basis according to the date and time their complete application is received by the HAS. When selecting applicants from the waiting list, the HAS will match the characteristics of the available unit (unit size, accessibility features, unit type) to the applicants on the waiting lists. The HAS will offer the unit to the highest ranking applicant who qualifies for that unit size or type, or that requires the accessibility features. By matching unit and family characteristics, it is possible that families who are lower on the waiting list may receive an offer of housing ahead of families with an earlier date and time of application or higher preference status. Factors such as deconcentration or income mixing and income targeting will also be considered in accordance with HUD requirements and HAS policy. Excerpt from HAS ACOP Effective 06/14/2016 PAGE 18

19 Attachment B.2(b.1) New Activities PAGE 19

20 Mixed Finance Modernization or Development. The site of the former Robert Hitch Village property, adjacent to Savannah s historic district, is slated for future mixed finance development. The community will include market, tax credit and public housing units. The first phase of construction is currently underway. This phase includes seventy-two (72) multifamily units with the following unit distribution: Six 1-BR; Forty-two 2-BR; and Twentyfour 3-BR units. The first phase will include the extension of the current street grid from downtown Savannah to the new community. Laundry will be provided in all units and the community will feature street parking, a BBQ and covered patio area for entertaining, fitness center, community room and mail center. Phase II is expected to begin construction in January 2017 with vertical site work beginning in March or April This phase will include 100+/- energy efficient units on 3.3 acres adjacent to Phase I. This phase will feature a community playground and picnic area, along with new community leasing and resident activity space. All buildings and structures on the site will mirror the character of historic downtown Savannah. Demolition and/or Disposition. HAS submitted a disposition application to HUD in 2016 for the vacant Francis Bartow Place real estate property (GA ). Francis Bartow Place was demolished in 2002 due to a severe termite infestation, and the tract has remained vacant for the last thirteen years. HAS plans to partner with a local non-profit service provider through the sale or long-term ground lease of this large tract on Augusta Avenue. The property will be used for the construction of a large social services building for this non-profit. The planned expansive facility will include family apartments, program units serving the homeless, veterans, single mothers and transitional living spaces. There will be emergency shelter, kitchen and recreational facilities and children play areas. The whole facility will provide a 185- bed permanent overnight capacity. The construction of this state of the art facility will have a positive and significant impact on Savannah s homeless and low-income population and will further HAS s mission of service. HAS has submitted a disposition application and is updating the current application with the necessary environmental review. The timeline for disposition will be contingent on HUD approval. Conversion of Public Housing to Project-Based Assistance under RAD. HAS is a participant in the HUD Rental Assistance Demonstration (RAD). HAS has received Housing Assistance Payments Contracts (CHAPs) for all developments in its portfolio, with the exception of Simon Frazier Homes (GA ) and Yamacraw Village (GA ). Notwithstanding the foregoing, HAS will evaluate redevelopment and repositioning opportunities for Simon Frazier Homes and Yamacraw Village, including conversion to RAD. HAS will be converting to a mix of Project Based Rental Assistance (PBRA) and Project Based Vouchers (PBV) under the guidelines of PIH Notice , Rev-1 and any successor notices. Upon conversion to PBRA, HAS will adopt the resident rights, participation, waiting list and grievance procedures listed in Section 1.7.B and 1.7.C of PIH Notice , Rev-1. PAGE 20

21 Additionally, HAS is currently compliant with all fair housing and civil rights requirements and is not under a voluntary compliance agreement. RAD was designed by HUD to assist in addressing the capital needs of public housing by providing HAS with access to private sources of capital to repair and preserve its affordable housing assets. Please be aware that upon conversion, HAS s Capital Fund Program budget will be reduced by the pro rata share of public housing developments converted as part of the Demonstration, and that HAS may also borrow funds to address their capital needs. HAS also plans to contribute operating reserves and capital funds. The contribution amount will be determined based on funding availability. The Housing Authority of savannah has formed a limited liability corporation in partnership with the redevelopment team of the Robert Hitch Village property and RAD. This marks the first time that HAS will participate in this capacity in a development transaction. HUD approved all RAD related activities as part of a Significant Amendment to the PHA Plan in See Attachment B.2(b.2) for an update to the 2015 amendment. Project Based Vouchers. HAS currently has 271 project based vouchers in its HCV portfolio. In the coming FY 2017, HAS plans to accept applications for 100 project based vouchers. The vouchers will be provided for new and existing construction in the Savannah, GA MSA. Units with Approved Vacancies for Modernization. During FY 2017, HAS will be continuing modernization work in Fred Wessels Homes (GA ) and Edgar Blackshear Homes (GA ) under the RAD program. There will be a total of 350 units in these neighborhoods that will be in approved vacancy status for modernization in accordance with 24 CFR (a)(1). Other Capital Grant Programs. HAS may submit an application for the Emergency Safety and Security Grant during FY The application will be in partnership with the Savannah-Chatham Metropolitan Police Department. PAGE 21

22 Attachment B.2(b.2) Rental Assistance Demonstration PAGE 22

23 ATTACHMENT B.2(b.2) HAS will be converting properties below to Project Based Vouchers under the guidelines of PIH Notice , REV-1 and any successor Notices. Upon conversion to Project Based Vouchers the Authority will adopt the resident rights, participation, waiting list, and grievance procedures listed in Section 1.6 of PIH Notice , REV-2; and Joint Housing PIH Notice H /PIH These resident rights, participation, waiting list and grievance procedures are appended to this Attachment. RAD was designed by HUD to assist in addressing the capital needs of public housing by providing HAS with access to private sources of capital to repair and preserve its affordable housing assets. Please be aware that upon conversion, the Authority s Capital Fund Budget will be reduced by the pro rata share of Public Housing Developments converted as part of the Demonstration, and that HAS may also borrow funds to address their capital needs. HAS will also be contributing Operating Reserves in the amount of $2,168,660, Capital Funds in the amount of $276,189, and Replacement Housing Factor (RHF) Funds in the amount of $3,750,865 towards the conversions. Below, please find specific information related to the Public Housing Developments selected for RAD: HERBERT KAYTON HOMES Total Units: 163 PIC Development ID: GA (A) Pre- RAD Unit Type: Multi family Conversion type: PBRA Post-RAD Unit Type if different (i.e., Family, Senior, etc.) Transfer of Assistance: (if yes, please put the location if known, and # of units transferring) No Capital Fund allocation of Development: (Annual Capital Fund Grant, divided by total number of public housing units in PHA, multiplied by total number of units in project) Bedroom Type Number of Units Pre- Conversion 163 Number of Units Post-Conversion 163 $231,988 Change in Number of Units per Bedroom Type and Why (De Minimis Reduction, Transfer of Assistance, Unit PAGE 23

24 Reconfigurations, etc.) No Studio/Efficiency 0 One Bedroom 31 Two Bedroom 56 Three Bedroom 56 Four Bedroom 14 Five Bedroom 6 Six Bedroom 0 (If performing a Transfer of Assistance): (Explain how transferring waiting list) PICKENS PATTERSON TERRACE Total Units: 76 PIC Development ID: GA (A) Pre- RAD Unit Type: Multi family Number of Units Pre- Conversion 76 Conversion type: PBRA Post-RAD Unit Type if different (i.e., Family, Senior, etc.) Number of Units Post-Conversion 76 Transfer of Assistance: (if yes, please put the location if known, and # of units transferring) No Capital Fund allocation of Development: (Annual Capital Fund Grant, divided by total number of public housing units in PHA, multiplied by total number of units in project) $108,166 Change in Number of Units per Bedroom Type and Why PAGE 24

25 Bedroom Type (De Minimis Reduction, Transfer of Assistance, Unit Reconfigurations, etc.) Studio/Efficiency 0 One Bedroom 30 Two Bedroom 30 Three Bedroom 16 Four Bedroom 9 Five Bedroom 0 Six Bedroom 0 (If performing a Transfer of Assistance): No (Explain how transferring waiting list) SINGLE HOMES Total Units: 60 FAMILY PIC Development ID: GA (B) Pre- RAD Unit Type: Multi family Conversion type: PBRA Post-RAD Unit Type if different (i.e., Family, Senior, etc.) Transfer of Assistance: (if yes, please put the location if known, and # of units transferring) No Capital Fund allocation of Development: (Annual Capital Fund Grant, divided by total number of public housing units in PHA, multiplied by total number of units in project) Bedroom Type Number of Units Pre- Conversion 60 Number of Units Post-Conversion 60 $85,394 Change in Number of Units per Bedroom Type and Why (De Minimis Reduction, Transfer of Assistance, Unit Reconfigurations, etc.) No PAGE 25

26 Studio/Efficiency 0 One Bedroom 0 Two Bedroom 0 Three Bedroom 35 Four Bedroom 25 Five Bedroom 0 Six Bedroom 0 (If performing a Transfer of Assistance): (Explain how transferring waiting list) HORACE STILLWELL TOWER Total Units: 210 PIC Development ID: GA Pre- RAD Unit Type: Elderly/Disabled Conversion type: PBRA Post-RAD Unit Type if different (i.e., Family, Senior, etc.) Transfer of Assistance: (if yes, please put the location if known, and # of units transferring) No Capital Fund allocation of Development: (Annual Capital Fund Grant, divided by total number of public housing units in PHA, multiplied by total number of units in project) Bedroom Type Number of Units Pre- Conversion 210 Number of Units Post-Conversion 210 $298,880 Change in Number of Units per Bedroom Type and Why (De Minimis Reduction, Transfer of Assistance, Unit Reconfigurations, etc.) No Studio/Efficiency 0 One Bedroom 209 Two Bedroom 1 Three Bedroom 0 Four Bedroom 0 Five Bedroom 0 Six Bedroom 0 PAGE 26

27 (If performing a Transfer of Assistance): (Explain how transferring waiting list) ASHLEY MIDTOWN Total Units: 67 PIC Development ID: GA Pre- RAD Unit Type: Multi family Conversion type: PBRA Post-RAD Unit Type if different (i.e., Family, Senior, etc.) Transfer of Assistance: (if yes, please put the location if known, and # of units transferring) No Capital Fund allocation of Development: (Annual Capital Fund Grant, divided by total number of public housing units in PHA, multiplied by total number of units in project) Bedroom Type Number of Units Pre- Conversion 67 Number of Units Post-Conversion 67 $95,357 Change in Number of Units per Bedroom Type and Why (De Minimis Reduction, Transfer of Assistance, Unit Reconfigurations, etc.) No Studio/Efficiency 0 One Bedroom 0 Two Bedroom 41 Three Bedroom 26 Four Bedroom 0 Five Bedroom 0 Six Bedroom 0 (If performing a Transfer of Assistance): (Explain how transferring waiting list) ASHLEY MIDTOWN II PIC Development ID: GA Conversion type: PBRA Transfer of Assistance: PAGE 27

28 Total Units: 20 Pre- RAD Unit Type: Multi family Post-RAD Unit Type if different (i.e., Family, Senior, etc.) (if yes, please put the location if known, and # of units transferring) No Capital Fund allocation of Development: (Annual Capital Fund Grant, divided by total number of public housing units in PHA, multiplied by total number of units in project) Bedroom Type Number of Units Pre- Conversion 20 Number of Units Post-Conversion 20 $28,465 Change in Number of Units per Bedroom Type and Why (De Minimis Reduction, Transfer of Assistance, Unit Reconfigurations, etc.) No Studio/Efficiency 0 One Bedroom 0 Two Bedroom 10 Three Bedroom 10 Four Bedroom 0 Five Bedroom 0 Six Bedroom 0 (If performing a Transfer of Assistance): (Explain how transferring waiting list) SUSTAINABLE FELLWOOD PIC Development ID: GA Conversion type: PBRA Transfer of Assistance: (if yes, please put the location if known, and # of units transferring) No PAGE 28

29 Total Units: 40 Pre- RAD Unit Type: Multi family Post-RAD Unit Type if different (i.e., Family, Senior, etc.) Capital Fund allocation of Development: (Annual Capital Fund Grant, divided by total number of public housing units in PHA, multiplied by total number of units in project) Bedroom Type Number of Units Pre- Conversion 40 Number of Units Post-Conversion 40 $56,930 Change in Number of Units per Bedroom Type and Why (De Minimis Reduction, Transfer of Assistance, Unit Reconfigurations, etc.) No Studio/Efficiency 0 One Bedroom 9 Two Bedroom 19 Three Bedroom 10 Four Bedroom 2 Five Bedroom 0 Six Bedroom 0 (If performing a Transfer of Assistance): (Explain how transferring waiting list) SUSTAINABLE FELLWOOD PHASE II Total Units: 40 PIC Development ID: GA Pre- RAD Unit Type: Multi family Conversion type: PBRA Post-RAD Unit Type if different (i.e., Family, Senior, etc.) Transfer of Assistance: (if yes, please put the location if known, and # of units transferring) No Capital Fund allocation of Development: (Annual Capital Fund Grant, divided by total number of public housing units PAGE 29

30 in PHA, multiplied by total number of units in project) $56,930 Bedroom Type Number of Units Pre- Conversion 40 Number of Units Post-Conversion 40 Change in Number of Units per Bedroom Type and Why (De Minimis Reduction, Transfer of Assistance, Unit Reconfigurations, etc.) No Studio/Efficiency 0 One Bedroom 4 Two Bedroom 15 Three Bedroom 21 Four Bedroom 0 Five Bedroom 0 Six Bedroom 0 (If performing a Transfer of Assistance): (Explain how transferring waiting list) SUSTAINABLE FELLWOOD PHASE III Total Units: 20 PIC Development ID: GA Pre- RAD Unit Type: Multi family Conversion type: PBRA Post-RAD Unit Type if different (i.e., Family, Senior, etc.) Transfer of Assistance: (if yes, please put the location if known, and # of units transferring) No Capital Fund allocation of Development: (Annual Capital Fund Grant, divided by total number of public housing units in PHA, multiplied by total number of units in project) $28,465 PAGE 30

31 Bedroom Type Number of Units Pre- Conversion 20 Number of Units Post-Conversion 20 Change in Number of Units per Bedroom Type and Why (De Minimis Reduction, Transfer of Assistance, Unit Reconfigurations, etc.) No Studio/Efficiency 0 One Bedroom 17 Two Bedroom 3 Three Bedroom 0 Four Bedroom 0 Five Bedroom 0 Six Bedroom 0 (If performing a Transfer of Assistance): (Explain how transferring waiting list) Resident Rights, Participation, Waiting List and Grievance Procedures **Note: Over the next five years, HAS staff will be receiving training and certification for tax credit property management. HAS also intends to continue eligibility for all FSS and ROSS participants throughout and after the conversion to RAD. The Housing Authority has not established its waiting list and grievance procedures at this time; however all policies and procedures related to the establishment of the waiting list and grievance process will be in accordance with PIH Notice , REV-1, as outlined below. PIH Notice , REV-1 Section 1.7.B 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 Section 1.7.A.8 on conditions warranting a PAGE 31

32 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 phase-in for larger increases in rent. This policy must be in place at conversion and may not be modified after conversion. Section I: Public Housing Projects PIH (HA) Rental Assistance Demonstration Final Implementation 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 58 3 (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 projectspecific 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. 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 PAGE 32

33 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) For more information on serving persons with LEP, please see HUD s Final guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons (72 FR 2732), published on January 22, Section I: Public Housing Projects PIH (HA) Rental Assistance Demonstration Final Implementation 59 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:44 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 PAGE 33

34 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 than 15.) While a voucher agency is not required to establish a project 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. 44 The Choice-Mobility requirements that apply to covered PBRA projects differ from the requirements that apply to covered PBV projects. Section I: Public Housing Projects PIH (HA) Rental Assistance Demonstration Final Implementation 60 HUD s goal is to have 100 percent of residents in the Demonstration offered a Choice-Mobility option within a reasonable time after conversion. However, as HUD recognizes that not all PHAs will have vouchers sufficient to support this effort, HUD will: o Provide ranking factor points where a voucher agency has committed to provide vouchers to the covered PBRA project of a PHA without a voucher program (see Section 1.11D). Additionally, voucher agencies that make such a commitment will receive: o Priority points for new HCV FSS coordinator positions in an upcoming FSS competition and o The bonus points provided under the Section Eight Management Assessment Program (SEMAP) for deconcentration.45, The sponsoring agency must commit to the full term of the initial HAP, must undergo a significant amendment to its Annual Plan (no later than 60 days after execution of the project s CHAP), and must comply with section 8(o)(6)(A) relating to selection preferences. 46 In order to implement this incentive, HUD is waiving provisions under 24 CFR 985.3(h) to provide donating agencies with bonus points under the SEMAP for deconcentration. 47 A veteran is, for the purpose of HUD-VASH, a person who served in the active military, naval, or air service, and who was discharged or released under conditions other than dishonorable and is eligible for Veterans Administration health care. Grant a good-cause exemption from the Choice-Mobility requirement for no more than 10 percent of units in the Demonstration. HUD will only consider requests for good-cause exemptions from the following types of PHAs: o Public housing only agencies, defined as agencies that own units under a public housing ACC, but do not administer, directly or through an affiliate, a Housing Choice Voucher program; or o Combined agencies that currently have more than one-third of their turnover vouchers set aside for veterans, as defined for the purpose of HUD-VASH, or homeless populations, as defined in 24 PAGE 34

35 CFR To be eligible for this exemption, the PHA s admission policies must have been formally approved by the PHA s board prior to the time of application. HUD will issue these exemptions in the following order of priority: 1) small public housing-only PHAs; 2) all other public housing-only PHAs; and 3) combined agencies that currently have more than one-third of their vouchers set Section I: Public Housing Projects PIH (HA) Rental Assistance Demonstration Final Implementation 61 aside for veterans and/or homeless. See Section 1.11 for more information on Choice-Mobility exemptions in the competition. 6. Future Refinancing. Owners must receive HUD approval for any refinancing or restructuring of permanent debt within the HAP contract term to ensure the financing is consistent with longterm preservation. (Current lenders and investors are also likely to require review and approval of refinancing of the primary permanent debt.) 7. Submission of Year-End Financial Statements. Covered projects converting assistance to PBRA must comply with 24 CFR Part 5 Subpart H, as amended, revised, or modified by HUD from time to time regarding submission of financial statements Classification of Converting Projects as Pre-1981 Act Projects under Section 16(c) of the United States Housing Act of For purposes of ensuring maximum flexibility in converting to PBRA, all such projects converting to PBRA shall be treated as Pre-1981 Act Projects under Section 16(c) of the US Housing Act of Section 16(c)(1) of the US Housing Act of 1937, which applies to pre-1981 Act projects, restricts occupancy by families that are other than very low-income to 25% of overall occupancy. Thus, owners of projects converting to PBRA may admit applicants with incomes up to the low-income limit. HUD Headquarters tracks the 25% restriction on a nationwide basis. Owners of projects converting to PBRA do not need to request an exception to admit low-income families. In order to implement this provision, HUD is waiving section 16(c)(2) of the US Housing Act of 1937 and 24 CFR 5.653(d)(2) and is instituting an alternative requirement that owners of projects converting to PBRA adhere to the requirements of section 16(c)(1) of the US Housing Act of 1937 and 24 CFR 5.653(d)(1). 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 PAGE 35

36 Year 3: Year 3 AR and all subsequent recertifications Year 3 AR and any IR in Year 3: Full Multifamily housing TTP 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 recertifications 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 Site Selection and Neighborhood Standards Review The Housing Authority of Savannah s RAD redevelopment efforts will begin with the transfer of assistance to the former Robert Hitch Village site. This traditional public housing community was demolished in 2010; and is the focus of a much anticipated redevelopment effort. The redevelopment of Robert Hitch Village is the cornerstone of the East Savannah Gateway Transformation Plan. HAS was a FY 2011 Choice Neighborhoods Planning grantee, engaging the community in a two-year planning process from 2012 through HUD approved the Transformation Plan for the East Savannah Gateway in March The newly developed former Robert Hitch Village property will be a mixed-finance, mixedincome community that will include market, tax credit and public housing units. The City of Savannah will be introducing a new street pattern into the new community. This will continue the grid pattern of Savannah s landmark historic district into what was previously an area of isolated and concentrated poverty. The development will feature a community center, fitness center, computer room, mail center and new street parking. The new site will exceed all neighborhood standards for a community of choice that is accessible to residents of all incomes. Please note that the Housing Authority of Savannah is mindful of including comparable opportunities for all minority families and will adhere to all standards outlined in CFR The construction of the former Robert Hitch Village property will be the start of deconcentrating poverty and increasing opportunities for minority families in east Savannah neighborhoods. PAGE 36

37 Relocation Plans A Relocation Plan is currently being developed. The Accessibility and Relocation Checklist will be submitted with the Financing Plan. PAGE 37

38 Attachment B.3 Civil Rights Certification PAGE 38

39 Certifications of Compliance with PHA Plans and Related Regulations (Standard, Troubled, HCV-Only, and High Performer PHAs) U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No Expires 02/29/2016 PHA Certifications of Compliance with the PHA Plan and Related Regulations including Required Civil Rights Certifications Acting on behalf of the Board of Commissioners of the Public Housing Agency (PHA) listed below, as its Chairman or other authorized PHA official if there is no Board of Commissioners, I approve the submission of the 5-Year and/or X Annual PHA Plan for the PHA fiscal year beginning 2017, hereinafter referred to as the Plan, of which this document is a part and make the following certifications and agreements with the Department of Housing and Urban Development (HUD) in connection with the submission of the Plan and implementation thereof: 1. The Plan is consistent with the applicable comprehensive housing affordability strategy (or any plan incorporating such strategy) for the jurisdiction in which the PHA is located. 2. The Plan contains a certification by the appropriate State or local officials that the Plan is consistent with the applicable Consolidated Plan, which includes a certification that requires the preparation of an Analysis of Impediments to Fair Housing Choice, for the PHA's jurisdiction and a description of the manner in which the PHA Plan is consistent with the applicable Consolidated Plan. 3. The PHA has established a Resident Advisory Board or Boards, the membership of which represents the residents assisted by the PHA, consulted with this Resident Advisory Board or Boards in developing the Plan, including any changes or revisions to the policies and programs identified in the Plan before they were implemented, and considered the recommendations of the RAB (24 CFR ). The PHA has included in the Plan submission a copy of the recommendations made by the Resident Advisory Board or Boards and a description of the manner in which the Plan addresses these recommendations. 4. The PHA made the proposed Plan and all information relevant to the public hearing available for public inspection at least 45 days before the hearing, published a notice that a hearing would be held and conducted a hearing to discuss the Plan and invited public comment. 5. The PHA certifies that it will carry out the Plan in conformity with Title VI of the Civil Rights Act of 1964, the Fair Housing Act, section 504 of the Rehabilitation Act of 1973, and title II of the Americans with Disabilities Act of The PHA will affirmatively further fair housing by examining their programs or proposed programs, identifying any impediments to fair housing choice within those programs, addressing those impediments in a reasonable fashion in view of the resources available and work with local jurisdictions to implement any of the jurisdiction's initiatives to affirmatively further fair housing that require the PHA's involvement and by maintaining records reflecting these analyses and actions. 7. For PHA Plans that includes a policy for site based waiting lists: The PHA regularly submits required data to HUD's PIC/IMS Module in an accurate, complete and timely manner (as specified in PIH Notice ); The system of site-based waiting lists provides for full disclosure to each applicant in the selection of the development in which to reside, including basic information about available sites; and an estimate of the period of time the applicant would likely have to wait to be admitted to units of different sizes and types at each site; Adoption of a site-based waiting list would not violate any court order or settlement agreement or be inconsistent with a pending complaint brought by HUD; The PHA shall take reasonable measures to assure that such a waiting list is consistent with affirmatively furthering fair housing; The PHA provides for review of its site-based waiting list policy to determine if it is consistent with civil rights laws and certifications, as specified in 24 CFR part 903.7(c)(1). 8. The PHA will comply with the prohibitions against discrimination on the basis of age pursuant to the Age Discrimination Act of The PHA will comply with the Architectural Barriers Act of 1968 and 24 CFR Part 41, Policies and Procedures for the Enforcement of Standards and Requirements for Accessibility by the Physically Handicapped. 10. The PHA will comply with the requirements of section 3 of the Housing and Urban Development Act of 1968, Employment Opportunities for Low-or Very-Low Income Persons, and with its implementing regulation at 24 CFR Part The PHA will comply with acquisition and relocation requirements of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 and implementing regulations at 49 CFR Part 24 as applicable. Page 1 of 2 form HUD ST-HCV-HP (12/2014) PAGE 39

40 PAGE 40

41 Attachment B.6(c) Resident Advisory Board (RAB) Comments PAGE 41

42 ATTACHMENT B.6(c) The Housing Authority of Savannah developed the FY 2017 Agency Plan in full cooperation with the Resident Advisory Board (RAB), which consists of representatives for its public housing neighborhoods and the Housing Choice Voucher Program. During the planning process, the RAB consulted with each of their Residents Associations, neighbors and fellow community members to bring back concerns and interests on behalf of the communities they represent. This leads to ongoing discussion and analysis between HAS and residents during the course of plan development. All issues brought to staff during the planning meetings are given full consideration and prioritized and addressed at an Executive level. HAS considers the development of the plan to be a collaborative process with its residents, who are always encouraged to have open communication with members of the HAS team. All recommendations and comments are incorporated into the compilation of the plan as RAB meetings are conducted. The minutes of these meetings follow. PAGE 42

43 PAGE 43

44 PAGE 44

45 PAGE 45

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