Moving to Work Annual Plan

Transcription

1 2014 Moving to Work Annual Plan Final Version Boulder Housing Partners 4800 Broadway, Boulder, CO (720)

2 Boulder Housing Partners Board of Commissioners Angela McCormick, Chair Karen Klerman, Vice Chair Tom Hagerty Dick Harris Stephen Eckert Valerie Mitchell Robin Chavez Susan Ageton Scott Holton Executive Director Betsey Martens Senior Management Jim Koczela, Chief Financial Officer Stuart Grogan, Director of Development Jeremy Ehrhart, Director of Property Operations Penny Hannegan, Director of HR and Organizational Excellence René Brodeur, Director of Resident Services Tim Beal, Director of Property Management Terry Johnson, Director of Maintenance Services Karen Kreutzberg, MTW and Federal Policy Manager Boulder Housing Partners provides assistance to nearly 2,000 households through five housing programs. The agency s portfolio represents one-third of the affordable housing units in Boulder County. In 2009, BHP s Board of Commissioners endorsed a goal to make BHP the nation s first net-zero energy housing authority.

3 Boulder Housing Partners 2014 MTW Annual Plan Table of Contents (I) Introduction. 2 (II) General Housing Authority Operating Information. 10 (III) Proposed MTW Activities.. 17 (IV) Approved MTW Activities. 38 (V) Sources and Uses of Funds. 41 (VI) Administrative. 44 Appendix A: Ten Year Plan for RHF Funds Revised March 6, 2014 to include HUD comments Approved March 11, 2014 by HUD MTW Office

4 Section I: Introduction Short-Term and Long-Term Goals and Objectives Boulder Housing Partners (BHP) became part of the Moving to Work Demonstration Program in This 2014 plan describes our plans for our third year in the demonstration. When Congress created MTW in 1996, it clearly stated its objectives for the demonstration and Public Housing Agencies (PHAs) participating in it. These objectives are:. To reduce cost and achieve greater cost effectiveness in federal expenditures;. To give incentives to families with children whose heads of household are either working, seeking work, or participating in job training, educational or other programs that assist in obtaining employment and becoming economically self-sufficient; and. To increase housing choices for low-income families. These objectives form the centerpiece of BHP s MTW initiatives, along with two additional goals that are unique to Boulder s needs: - Pilot a rent policy that will encourage self-sufficiency, assure accurate reporting of income and ensure that customers are not overly rent burdened; and - Preserve, transform and revitalize our public housing. Over the past two years, both BHP and our customers have experienced the potential of MTW flexibility to streamline process and reduce regulatory burden related to our customer experience. In 2012 we implemented:. Rent reform for elderly households and households with persons with disabilities;. Rent simplicity measures for all households;. Voucher reform for all households: elimination of the 40% cap on income and implementation of a flat utility allowance; and. Public housing conversion with the submission of a proposal to HUD to convert the balance of our public housing to conventional financing supported by project-based vouchers. In 2013, we: - Simplified the Housing Quality Standard (HQS) Inspections schedule for all households; - Began the phase-in period of eliminating Utility Reimbursement Payments for all households; - Commenced a new Local Voucher Program in Partnership with Safehouse Progressive Alliance for Non-Violence; and - Paved the way for BHP to use Replacement Housing Factor Funds for other Affordable Housing. In 2014, our focus is two-fold: on simplifying the rent calculation for work-abled families, and converting our public housing to a Section 8 platform which will allow for substantial renovation and transformation of the asset. We are currently working on a proposal to HUD that will blend elements of the traditional public housing disposition program with the Rental Assistance Demonstration (RAD) program in order to address the needs of the entire public housing inventory. The goal for the 2014 Plan is to continue our vision of meeting the growing need for quality affordable housing that provides a strong focus on outcomes for our residents. Boulder Housing Partners 2

5 In our short experience, we have come to understand that MTW flexibility will allow us to truly become a strategic organization by allowing us the flexibility to evaluate our opportunities and our challenges and respond. Our 2014 Plan follows quite closely the strategy that we articulated in our application. This Plan provides detail on the following proposed activities: : Rent Reform for Section 8 Housing Choice Voucher Work-Abled Families : Rent Reform for Public Housing Work-Abled Families : Limit of One Interim Decrease Recertification for Elderly and Disabled Households : Removal of the Flat Rent Option in Public Housing : Changes in Mobility Options to the Woodlands Family Self-Sufficiency Program : Rent Limits and Rent Reasonableness for Project-Based Voucher Projects To frame our long-term thinking, Boulder Housing Partners continues to use five overarching MTW goals listed below. In addition BHP has developed the following principles that have guided our MTW plan. With MTW flexibility, BHP plans to be able to: Use federal housing resources as compelling tools to create positive change for families, Manage converted public housing as a real estate asset and a vital part of our community s infrastructure, Encourage the community, and our prospective customers, to perceive public housing as a place to Live, Learn, and Earn, Accelerate the shift of staff focus from paper to people, Complete the transformation of a public agency from bureaucratic to entrepreneurial, Accelerate changes in outcomes for families from tepid to catalytic, Enhance our role in the industry from thinkers to doers, and Provide a more complete continuum of housing choices. The centerpiece of our vision for MTW flexibility hinges on receiving a positive response to the Public Housing Disposition application that was submitted to HUD in February 2012 and the Rental Assistance Demonstration (RAD) application that was submitted in October Provided disposition is granted, we will be able to continue with the principles that are outlined above. Our long-term goals and expectations are described below. The Moving to Work program has three statutory goals. BHP s program includes an additional two goals that better articulate our program, and are consistent with the statutory goals. Not every item listed below requires MTW flexibility. We include these items in order to tell a more complete story of what we are trying to achieve. Goals in Year Three (2014) are also described in detail below in the discussion about proposed MTW Activities. Boulder Housing Partners 3

6 MTW Goal 1 Reduce cost and achieve greater cost effectiveness in federal expenditures In 2012 and 2013 (Years 1 and 2), we: 1. Streamlined and simplified the rent calculation and re-certification process for elderly households and people with disabilities, 2. Simplified the process for income and asset verification for all households, 3. Implemented a a 26.5% of rent with no deductions for elderly households and people with disabilities, replacing the complicated 30% of income-with-adjustments-to-rent system.implemented a flat utility allowance, 4. Excluded income from assets with a value less than $50,000 and disallowed participation for households with assets greater than $50,000, 5. Created an MTW Resident Advisory Committee to assist us in longer-term thinking and program evaluation, 6. Structured our evaluation metrics and benchmarks, 7. Implemented an HQS inspection schedule that follows the recertification schedule, and 8. Completed our planning to implement a flat tiered rent program for families, including the design of a rent reform study (implementation in year 3). In 2014 (Year 3), we plan to: 1. Implement rent reform for work-abled families in the Section 8 Housing Choice Voucher and Public Housing Programs that will reward increased income, remove penalties for reporting income and mirror the private market in order to facilitate and incent a transition from assisted housing to market rate housing. At the same time, we plan to conduct a research study in partnership with the University of Colorado to measure the impact of rent reform for residents and participants, 2. Eliminate all interim recertifications (with the exception of elderly and disabled households which will be able to request one interim decrease per year) and allow households to increase income without the immediate corresponding increase in rent, and 3. Allow BHP to set rents and determine rent reasonableness at Project-Based Voucher Communities. In 2015 and beyond (Years 4 10), we expect to: 1. Make standard documents more customer friendly The focus will be the legal documents associated with the programs beginning with the lease and the HAP contract. Customers currently find the documents cumbersome and difficult to follow. The result is that they miss the key requirements and suffer the consequences. 2. Make the voucher program lease length more flexible Many university towns, like Boulder, have a leasing season centered on the school year. This creates many situations in which a landlord is unwilling to sign a one-year lease. Boulder Housing Partners 4

7 3. Revise and simplify our portability policy The industry has long discussed a variety of needed changes to the administration of portable vouchers. We would like to use MTW flexibility to experiment with a number of ideas that would make local administration more streamlined. MTW Goal 2 Create incentives for families to work, seek work or prepare for work In 2012 and 2013 (Years 1 and 2), we: 1. Streamlined and simplified the rent calculation and re-certification process for households with earned income, 2. Simplified the process for income and asset verification for all households, 3. Completed our planning to implement a flat tiered rent program for work-abled families in the Section 8 Program, and 4. Completed our planning for rent reform for the work-abled families in the Public Housing Program. In 2014 (Year 3), we plan to: 1. Implement rent reform for work-abled families in the Section 8 and Public Housing Programs, 2. Complete planning for our resident mobility program, and 3. Complete planning for community center construction, and 4. Eliminate all interim recertifications (with the exception of allowing elderly and disabled households once interim decrease per year) which allows households to increase income without the immediate corresponding increase in rent. In 2015 and beyond (Years 4 10), we plan to: 1. Create a service delivery center at each of our family housing sites. With Public Housing conversion, BHP plans to create a community center at an additional three communities and expand the center we currently have at one of our communities. We believe that service delivery close to home is a more highly leveraged and effective platform. 2. Expand the staffing of our Resident Services program. With increased efficiencies created under MTW, our goal is to expand the staffing of our Resident Services Program so that every public housing resident is assigned a service coordinator and voucher households will begin to have access to the Resident Services Department 3. Expand the program that provides college tuition to BHP students participating in the I Have a Dream program partnership. Boulder Housing Partners 5

8 The I Have A Dream (IHAD) program continues to affirm its intention to place a classroom of Dreamers at every public housing site that can accommodate their classroom programming needs. In other words, if we build it, they will come. We are strongly committed to doing everything we can to make this opportunity available for the children and young adults of our communities. 4. Expand our Community Service and Section 3 programs to build social capital by greater involvement in the community. BHP residents who have long been out of the workforce need to update their skills and experience and build networks in order to make re-entry possible and successful. We propose to expand our community service and Section 3 programs by developing a pre-employment training program. 5. Create a system to reward households for progress towards self-sufficiency. BHP will work with residents to create a system that rewards their progress towards selfsufficiency and their efforts to make their home and neighborhood a better place to live. We will work with residents to create this system. We suggest that we model it after the Cornerstone Rental Equity program 1. This program matches many of the ideas we have about enhancing the benefits of renting a home and engaging residents in building equity. 6. Expand our current work with the Bridges Out of Poverty program. The Bridges Out of Poverty model examines the sources and impact of generational poverty on families, reveals the hidden rules and norms of social class, and supports families as they learn how they can change their behavior to embrace a mental model of prosperity. BHP wants to use MTW to test the part of the theory that housing solutions will be compromised unless we are addressing the intrinsic beliefs that people hold about being poor. MTW Goal 3 Increase housing choices for low-income households In 2012 and 2013 (Years 1 and 2), we: 1. Removed the cap on income spent on rent in the voucher program. 1 Cornerstone Renter Equity is a management system where residents have a stake in the property where they live by using their contributions to maintain and improve property values and rental income with compensating financial equity. Residents sign a contact with Cornerstone that enables them to earn up to $10,000 in financial equity in ten years, provided they complete routine work assignments, attend management meetings, and fulfill lease commitments. Residents receive a monthly statement of their earnings, but they must stay in their homes for five years before their credits are vested and are eligible for cash payments. After becoming vested in the Renter Equity Fund, individuals may borrow up to 80% of the value of their credits for any reason. Boulder Housing Partners 6

9 In 2014 (Year 3), we plan to: 1. Use MTW funding flexibility to create 31 newly constructed units of permanent supportive housing for chronically homeless individuals, 2. Implement both minimum and maximum time limits at Woodlands, a Project-Based Voucher Community with services provided by the Family Self-Sufficiency Program, and 3. Design a process to test mobility for residents from a Multi-Family Property with a Section 8 Project-Based Contract using Section 8 Housing Choice Vouchers (which will be proposed as an activity in a future MTW Annual Plan). In 2015 and beyond (Years 4 10), we expect to: 1. Increase the cap on project-basing vouchers to dedicate up to 60 vouchers for housing for individuals re-entering the community following homelessness or incarceration. BHP has seen the need to provide a supportive setting in which people can re-gain skills to live more successfully in the community. 2. Use resources leveraged from the conversion of public housing, along with MTW flexibility, to create at least 100 new affordable units renting to families at 40% of the area median income. Another critical gap in the housing continuum is the lack of options for households ready to move off of federal housing subsidy. Using the flexibility provided to us under the MTW program we propose to increase our Boulder Affordable Rentals inventory by 24%. 3. Implement a damage claim for landlords participating in the voucher program. A key component of our MTW plan is to make the voucher program more attractive to private landlords. As part of a recruitment tool, we propose to use HAP funds to create a fund for damage claims. 4. Create a Section 8 homeownership program in partnership with the city of Boulder and Thistle Community Housing. Creation of a homeownership program may not require MTW flexibility, but doing so will round out the critical interventions that BHP can make in the housing ladder. We propose to partner with Thistle Community Housing because of their long track record of developing affordable homeownership opportunities. Thistle is Boulder s largest non-profit housing developer specializing in mixed-income homeownership opportunities and community land trust development. Boulder Housing Partners 7

10 MTW Goal 4 Pilot a rent policy that will encourage self-sufficiency, assure accurate reporting of income and ensure that customers are not overly rent burdened In 2012 and 2013 (Years 1 and 2), we: For elderly households and people with disabilities: 1. Adopted a simplified rent based on 26.5% of gross income, 2. Eliminated all deductions, 3. Excluded income from assets below $50,000, 4. Began scheduling re-certifications so that they will occur every three years, 5. Eliminated third-party verifications except at admissions and for audited files, 6. Eliminated all interim increases, except for increases in unearned income, and 7. Limited to one the number of interim decreases. For family households: 1. Excluded income from assets below $50,000, 2. Eliminated third-party verifications except at admissions and for audited files, 3. Eliminated earned income disregard and interim recertifications for increases in income, and 4. Planned for the implementation of the flat tiered rent system for the work-able households. In 2014 (Year 3), we will: 1. Implement a flat tiered rent system for work-abled families in the Section 8 program, 2. Implement a new rent structure based on percentage of income towards rent for the workabled families in Public Housing, 3. Implement a rent reform study to test the outcomes and effects of our rent reform, 4. Remove the flat rent choice in Public Housing to ensure that all families are paying rent according to income, and 5. Eliminate all interim recertifications for all households (with the exception of one decrease per year for elderly and disabled households). In 2015 and beyond (Years 4 10), we plan to: 1. Continue to evaluate the rent reform study for the alternate rent strategies, and 2. Monitor and evaluate the new rent structures for all households. MTW Goal 5 Preserve, transform and revitalize our public housing In 2012 and 2013 (Years 1 and 2), we: 1. Simplified the process to project base vouchers, and 2. Submitted an application to HUD for Public Housing Disposition according to the rules found in Section 18 Boulder Housing Partners 8

11 In 2014 (Year 3), we expect to: 1. We are assuming a successful Section 18/RAD approach to conversion and therefore 2014 will be a planning year for public housing conversion in which we finalize renovation plans, manage the entitlements for each property and begin to package the financing. Actual renovation and conversion is currently planned for implementation in In 2015 and beyond (Years 4 10), we plan to: 1. Use MTW flexibility to project base 337 units in former public housing developments converted into a tax credit partnership. We are currently in the review process under the 2011 rules of the Section 18 disposition process. If we are successful in securing approvals to dispose of public housing, we will begin phased implementation and renovation in MTW Year 4 (2015). 2. Test three mobility options for families in the converted public housing properties: none, full and conditional. BHP wants to use MTW flexibility to test whether families who are able to move with vouchers will achieve greater outcomes than those whose mobility is limited. Boulder Housing Partners 9

12 Section II: General Housing Authority Operating Information The following tables describe Boulder Housing Partners housing options under the Public Housing and Section 8 Housing Choice Voucher Programs. There are currently 337 total units in the public housing program and 608 vouchers in the voucher program. At the beginning of 2014, BHP has 89 vouchers that are project-based vouchers. By the end of 2014, we anticipate having an additional 31 project-based at 1175 Lee Hill, and plans in place to project-base 133 at converted public housing sites in early The timing of public housing conversion is dependent on approval, financing and actual renovation of the projects. II.1.Plan.HousingStock A. MTW Plan: Housing Stock Information Planned New Public Housing Units to be Added During the Fiscal Year # of UFAS Units AMP Name and Number Bedroom Size Total Units Population Type * Fully Accessible Adaptable None X X X X X X X X Type Noted * X X Total Public Housing Units to be Added 0 * Select Population Type from: Elderly, Disabled, General, Elderly/Disabled, Other If Other, please describe: Description of "other" population type served Planned Public Housing Units to be Removed During the Fiscal Year PIC Dev. # / AMP and PIC Dev. Name Number of Units to be Removed Explanation for Removal CO Family Sites 192 Approval requested under Public Housing Disposition/RAD, see justification at the end of the tables Boulder Housing Partners 10

13 CO Elderly Sites 145 Approval requested under Public Housing Disposition/RAD, see justification at the end of the tables Total Number of Units to be Removed 337 New Housing Choice Vouchers to be Project-Based During the Fiscal Year Property Name Anticipated Number of New Vouchers to be Project- Based * Description of Project Walnut Place 80 Kalmia 53 Converted public housing property, 80 units for the elderly and persons with disabilities (planning for 2014, projected implementation in 2015) Converted public housing property for mixed population (planning for 2014, projected implementation in 2015) Lee Hill 31 Newly constructed housing for chronically homeless disabled individuals (lease up anticipated to begin in August 2014) Anticipated Total New Vouchers to be Project-Based 164 Anticipated Total Number of Project-Based Vouchers Committed at the End of the Fiscal Year 253 Anticipated Total Number of Project-Based Vouchers Leased Up or Issued to a Potential Tenant at the End of the Fiscal Year 253 *New refers to tenant-based vouchers that are being project-based for the first time. The count should only include agreements in which a HAP agreement will be in place by the end of the year. Boulder Housing Partners 11

14 Other Changes to the Housing Stock Anticipated During the Fiscal Year No other changes are anticipated to be made during the 2014 Fiscal Year. Examples of the types of other changes can include but are not limited to units that are held off-line due to the relocation of residents, units that are off-line due to substantial rehabilitation and potential plans for acquiring units. General Description of All Planned Capital Fund Expenditures During the Plan Year In 2014, BHP plans to accomplish the following capital work at our public housing sites. Concrete work at Madison and Kalmia - $5,000; Video/Surveillance Cameras at Walnut Place - $20,000; Ditch repairs at Walnut Place due to Boulder Flood - $20,000; All Sites solar systems maintenance including rodent guards - $40,000; Metron Water meters at Northport and Walnut Place - $20,000; Total on CIP in $105,000. Balance to be spent on MTW planning efforts. BHP continues to plan for a major renovation of these properties through Section 18 and RAD dispositions, and therefore the balance of available CFP funds will be used in that planning effort in Boulder Housing Partners 12

15 II.2.Plan.Leasing B. MTW Plan: Leasing Information Planned Number of Households Served at the End of the Fiscal Year MTW Households to be Served Through: Planned Number of Households to be Served* Planned Number of Unit Months Occupied/ Leased*** Federal MTW Public Housing Units to be Leased 330 3,960 Federal MTW Voucher (HCV) Units to be Utilized 608 7,296 Number of Units to be Occupied/Leased through Local, Non- Traditional, MTW Funded, Property-Based Assistance Programs ** Number of Units to be Occupied/Leased through Local, Non- Traditional, MTW Funded, Tenant-Based Assistance Programs ** Total Households Projected to be Served * Calculated by dividing the planned number of unit months occupied/leased by 12. ** In instances when a local, non-traditional program provides a certain subsidy level but does not specify a number of units/households to be served, the PHA should estimate the number of households to be served. ***Unit Months Occupied/Leased is the total number of months the PHA has leased/occupied units, according to unit category during the fiscal year. Reporting Compliance with Statutory MTW Requirements If the PHA has been out of compliance with any of the required statutory MTW requirements listed in Section II(C) of the Standard MTW Agreement, the PHA will provide a narrative discussion and a plan as to how it will return to compliance. If the PHA is currently in compliance, no discussion or reporting is necessary. BHP is currently in compliance. Boulder Housing Partners 13

16 Description of any Anticipated Issues Related to Leasing of Public Housing, Housing Choice Vouchers and/or Local, Non- Traditional Units and Possible Solutions Housing Program Description of Anticipated Leasing Issues and Possible Solutions Public Housing Section 8 HCV Program When units are converted under disposition/rad, a level of rehabitalitation will be done at the properties causing leasing issues during the actual rehab, currently scheduled for Leasing issues may arise depending on funding that is actually provided under budget authority, as well as number of tenant protection vouchers received under disposition. II.3.Plan.WaitList C. MTW Plan: Wait List Information Wait List Information Projected for the Beginning of the Fiscal Year Housing Program(s) * Wait List Type** Number of Households on Wait List Wait List Open, Partially Open or Closed*** Are There Plans to Open the Wait List During the Fiscal Year Federal MTW Public Housing Units Community wide for all of public housing 774 Closed No Federal MTW Housing Choice Voucher Program Program specific for S8HCVP only (BHP conducts a lottery, not a wait list) 250 (still in lottery pool from 2013) Closed Yes Boulder Housing Partners 14

17 Federal MTW Housing Choice Voucher Program Site-based for PBV Broadway East 386 Closed Yes Rows for additional waiting lists may be added, if needed. * Select Housing Program: Federal MTW Public Housing Units; Federal MTW Housing Choice Voucher Program; Federal non- MTW Housing Choice Voucher Units; Tenant-Based Local, Non-Traditional MTW Housing Assistance Program; Project-Based Local, Non-Traditional MTW Housing Assistance Program; and Combined Tenant-Based and Project-Based Local, Non- Traditional MTW Housing Assistance Program. ** Select Wait List Types: Community-Wide, Site-Based, Merged (Combined Public Housing or Voucher Wait List), Program Specific (Limited by HUD or Local PHA Rules to Certain Categories of Households which are Described in the Rules for Program Participation), None (If the Program is a New Wait List, Not an Existing Wait List), or Other (Please Provide a Brief Description of this Wait List Type). *** For Partially Open Wait Lists, provide a description of the populations for which the waiting list is open. N/A If Local, Non-Traditional Housing Program, please describe: N/A If Other Wait List Type, please describe: N/A If there are any changes to the organizational structure of the wait list or policy changes regarding the wait list, provide a narrative detailing these changes. Changes may occur in 2014, depending on conversion of the remaining public housing units. In the event that disposition of Public Housing or RAD conversion is approved, a Relocation Specialist will be in charge of relocating residents from current public housing units that will undergo renovation, currently planned for Depending on the amount of renovation for each of the eight properties, the majority of relocations should be temporary and may include the use of hotels and vacant units. The current wait list for public housing would be depleted prior to converting to project-based voucher lists, or some other system. Boulder Housing Partners 15

18 Justification for Disposition/RAD conversion As part of our Moving to Work Plan, we propose to dispose some sites outside of the public housing program and convert the rest under RAD in order to effectively utilize our public housing as a platform from which to deliver MTW-envisioned services; and to enable the full rehabilitation of these sites, ensuring their long-term viability as affordable housing for low income families and individuals. The disposition, conversion to project-based voucher subsidy and RAD, and rehabilitation are essential to achieving HUD s goals for Moving to Work Demonstration Agencies: the opportunity to design and test innovative, locally-designed strategies that use Federal dollars more efficiently, help residents find employment and become self-sufficient, increase housing choices for low-income families, The preservation, transformation and revitalization of our public housing through disposition, conversion and rehabilitation are one of BHP s central goals for us as a Moving to Work agency. We plan to finance a robust resident services program through the annual operating structure of these sites, which will allow us to achieve 100% service enrichment at all of our public housing properties. By disposing of and/or converting these eight sites, BHP will be able to use various affordable housing financing tools to perform comprehensive rehabilitation at the eight sites. Rehabilitation will be supported through the sale of 4% low income housing tax credits (LIHTC) and private activity bonds (PAB). BHP s anticipated level of rehabilitation for these eight sites would not be possible utilizing Capital Funds or other funding mechanisms associated with the public housing program. Leveraging the sale of LIHTCs in combination with private activity bonds is the most effective mechanism for enabling this level of rehabilitation while still providing affordability. Rehabilitation will eliminate any deferred maintenance and will bring substantial capital improvements to the sites, reducing the site s ongoing maintenance costs. Any energy and water efficiency measures included as part of the rehabilitation will reduce monthly energy bills, improving the operating performance of these sites and maintaining the affordability of this housing for our residents. Rehabilitation at the family sites will allow us to refurbish units into viable community gathering spaces, another BHP goal under Moving to Work. These community centers will support after-school programming for youth and a place for their parents to meet. The project financing will allow BHP to fund substantial replacement reserves, to prepare for the future needs of these sites. In addition, the improvements performed will make the sites more desirable places for our residents to call home. At disposition or conversion to RAD, some housing will be converted into BHP s project-based voucher program and others will be converted into RAD project-based subsidy contracts which will support comparably affordable rents for low-income families and individuals into the future. The historic level of subsidy plus rent that BHP has received from these sites under the public housing program has been lower than needed in order to bring significant capital improvements, operating reserves, and service-enrichment to all residents at all sites. Participation of these eight sites in the project-based voucher program and RAD s project-based contracts will secure the sites operating stability in the longterm by generating more rental and subsidy revenue at these eight sites to be used for future operations, capital investment and resident services. The rental subsidy offered under the project-based programs will preserve the sites as affordable housing for the community. Boulder Housing Partners 16

19 Section III: Proposed MTW Activities Activity : Rent Reform for Section 8 Work-Abled Families A. MTW Initiative Description This activity s main objective is to simplify the rent calculation for those families participating in the Section 8 Housing Choice Voucher Program who are work-abled. Work-abled families are all households whose head of household, spouse, or co-head is not elderly (elderly is defined as 62 years of age or older) or a person with disabilities. Work-abled households living at the Woodlands Project-Based Voucher Community are exempt from this rent reform. 2 Determining the rent portion for a work-abled Section 8 family will be a two-step process. Step one: Using the family size and gross income (without any deductions), the family will qualify in an income tier. Step two: The income tier and actual bedroom size of the unit where the family is living will determine the portion of rent the family will pay. In the case of a mixed-citizen family, a flat fee per ineligible family member will be added to the family s portion of the rent. The utility allowance will be deducted from the family s portion. (In the case of the utility allowance being greater than the rent amount, the family s portion will be equal to zero.) This amount will be deducted from the lower of the contract rent or payment standard for the voucher size for which they qualify. If contract rent is above the payment standard, the portion that is above the payment standard will be added to the family s portion of the rent. The detailed elements included in rent reform are: Flat Tiered Rent System The flat tiered rent system consists of 10 income tiers. A family s applicable income tier is determined by gross annual income and family size. The tiers are based on area median income (AMI) and increase along with family size. Within an income tier, a family s rent burden is higher at the bottom and lower at the top. The tiers are designed so that rent burden is 30% for families in the middle of the tier. Rent calculation becomes very simple. A family s rent is determined by locating the tier appropriate to their income and following it out to the appropriate bedroom size. This flat rent remains in place for however long the household s income remains within that tier. The model is based on gross annual income and is shown below (formulas are built into the chart to increase family and bedroom size as needed): 2 Note: This flat tiered rent system will not be applied to the project-based voucher holders at Woodlands participating in the Family Self-Sufficiency Program. Their rent calculation, which currently includes an escrow account when income increases, will remain the same. The number of work-abled families in the Section 8 program is approximately 240 (excluding families at Woodlands). Boulder Housing Partners 17

20 Rent Chart Bedrooms Income Tier $ ,015 1, ,050 1,185 1, ,070 1,120 1,200 1,355 1,530 Minimum rent In this flat tiered rent system, the minimum rent would increase from the current amount of $50 to between $120 - $180 per month depending on bedroom size. The lowest figure is based on 30% of the average Temporary Aid to Needy Families (TANF) monthly benefit amount. Biennial recertifications All families will be recertified and their rent will be calculated using the flat tiered rent system at Boulder Housing Partners 18

21 the same time, effective July 1, The recertification will then take place every other year. At recertification, rent would be based on: 1. current gross income if it is stable and predictable, or 2. past 2 years of gross income (annualized) if income is not stable or no income is currently being reported Stable and predictable income is defined as income that is not temporary, expected to continue for the foreseeable future and not seasonal in nature. Example of stable income: a person is hired to work a specific number of hours earning a certain amount of money per hour. If the participant is reporting no income at recertification, they will be required to meet with their Section 8 Occupancy Specialist to determine if there are any benefits or services they may be eligible to receive. No interim recertifications Two key goals of our rent reform initiative are to, one, mimic the market and two, to incentivize and reward work by closing the loophole in which participants can strategically reduce income in order to receive a lower rent. All interim recertifications will be eliminated with the exception of changes in family composition or status, or if the family moves. If the participant is claiming zero income at the biennial recertification, they would be subject to interim recertifications until at least one source of income has been reported that places them into income tier two. Flat fee per ineligible family member The current regulations associated with rent calculation require us to prorate the assistance if a family includes members who are not eligible for assistance. This calculation will be replaced with a flat fee of $180 per ineligible family member per month. This amount will be added to the family s portion of the rent prior to determing the amount of assistance that the family will receive. B. MTW Statutory Objective This activity will: 1. Reduce cost and achieve greater cost effectiveness in federal expenditures; and 2. Create incentives for families to work, seek work or prepare for work. C. Anticipated Impacts BHP anticipates this activity will: o o o o o o Streamline the recertification process for work-abled families Maintain a stable rent burden for families for two years Simplify the rent calculation, making it easier to understand and calculate Encourage participants to increase income Significantly reduce administrative time to allow Section 8 Occupancy Specialists to focus on connecting participants to other resources for which they may qualify Reduce the time and cost for participants to gather the documentation for recertification Boulder Housing Partners 19

22 Potential negative consequences include: o o Possible financial burdens to families who lose income during the period of time between recertifications. BHP will work with Emergency Family Assistance Association to develop a safety net program for these situations. Foregone HAP savings if resident income increases during the period of time between recertifications D. Anticipated Schedule BHP proposes to implement the flat tiered rent system for all households at the same time, effective July 1, For work-abled households currently on the program and who would have a recertification effective between January 1, 2014 and June 1, 2014, the rent would be recalculated using the information already obtained from the participant family, effective July 1, For all households with recertifications scheduled between August and December, they would be recertified effective July 1, For all those households who are new to the program as of March 1, 2014, the flat tiered rent system would apply from the date of new admission and no new recertification would be done July 1. The next recertification for new families would be scheduled for BHP intends to update the income and rent charts, along with minimum rent, in This will allow for the rent reform to be stable for five years. Mass recertification for work-abled households will occur every two years, during a three-month period. In the year in which no recertifications for work-abled will be conducted, staff will be able to focus on connecting participants to services, assisting households new to the program with leasing up, conduct inspections (versus contracting them out), etc. Activity Metrics Information Metric Baseline Benchmark Implementation schedule Total cost of task (decrease) Staff time savings Increase in household income Increase in positive outcomes in employment status: Full Time Current staff hours required per recertification X number of recertifications (prior to implementation) x average of $26 per hour Current staff hours required per recertification X number of recertifications (prior to implementation) Averge household income at time of recertification in 2014 Number of households employed full time at time of recertification in % reduction over the twoyear recertification period 40% reduction over the twoyear recertification period Increase of 2% in household income Number of residents employed full time expected to increase by 2% All households will be recertified in 2014 and then not again until Results achieved by December 31, All households will be recertified in 2014 and then not again until Results achieved by December 31, Results achieved by December 31, 2016 Results achieved by December 31, 2016 Boulder Housing Partners 20

23 Increase in positive outcomes in employment status: Part Time Increase in positive outcomes in employment status: Educational program Increase in positive outcomes in employment status: Job Trainee Increase in positive outcomes in employment status: Unemployed Number of households employed part time at time of recertification in 2014 Number of student households at time of recertification in 2014 Number of job trainee households at time of recertification in 2014 Number of unemployed households at time of recertification in 2014 Number of TANF households at time of recertification in 2014 Number of households receiving services aimed to increase self-sufficiency at time of recertification in 2014 Number of residents employed part time expected to increase by 2% Results achieved by December 31, 2016 No change anticipated Results achieved by December 31, 2016 No change anticipated Results achieved by December 31, 2016 Number of unemployed residents expected to decrease by 2% Number of residents receiving TANF expected to decrease by 2% Results achieved by December 31, 2016 Number of households receiving TANF (decrease) Results achieved by December 31, 2016 Number of households receiving services aimed to increase self-sufficiency Number of families moved to self-sufficiency. Selfsufficiency defined as exiting program and moving into market rental or home ownership None Number of households receiving services aimed at increasing self-sufficiency expected to increase by 2% 1 (one) Results achieved by December 31, 2016 Results achieved by December 31, 2016 Due to the biennial recertification schedule, information will not be collected from participating families in Benchmarks will be reported on in E. Data Source for Metric Data BHP will be able to collect data to measure this activity from our financial and management reports using our in-house database. BHP will also use a process improvement approach to documenting time required in performing all the steps associated with our current rent calculation. We will use that information as the baseline from which to measure improvements. Need/Justification for MTW Flexibility F. Authorization Cited Attachment C, Section D. 1. c: The Agency is authorized to define, adopt and implement a reexamination program that differs from current program requirements. Attachment C, Section D. 2. a: The Agency is authorized to adopt and implement any reasonable policies to calculate the tenant portion of the rent that differs from current program requirements. Boulder Housing Partners 21

24 G. Explanation for Authorization MTW flexibility is needed in order to implement the flat tiered rent system, increase the minimum rent, conduct biennial recertifications, charge a flat fee per ineligible member, and eliminate interim recertifications except in certain cases. Additional Rent Reform Activity Information H. Impact Analysis Based on our data modeling, this activity will impact work-abled families in the following areas: Resident rent based on a percentage of income: the tiers are formulated so that families in the middle of each tier would have a rent burden equal to 30%. As families move through the income tier, the rent burden is designed to decrease. When income is at the lower end of the tier, rent burden is highest. However, as income increases and rent stays the same, rent burden decreases. Rent burden within the tiers ranges from 48% (at the very low income tiers) to 22% (at the very high income tiers). The tiers allow for families to increase their earnings without immediately experiencing a corresponding increase in rent, thereby allowing families to keep the extra disposable income. Minimum rent By implementing a minimum rent of between $ depending on bedroom size, based on 2012 data, we will increase the number of families paying a minimum rent from the current number of 24 to 39. However, 11 of these families will experience a rent decrease by basing their rent on the tiers. These 11 families currently have a rent portion (based on 30% of adjusted gross income) that is higher than the proposed minimum rents. By placing these families on the flat tiered rent system, their rent portion will actually decrease. All families who experience an increase in their out-of-pocket rent due to the new minimum rent amount will be granted a 12-month transition period. Maximum rent increase All work-abled families will begin the flat tiered rent system at the same time. Provided that all other factors contributing to the rent calculation remain the same (such as income, utility allowance, contract rent, unit size), households who will experience an increase of more than 7% in their out-of-pocket costs will have increase limited to 7% of their portion. Based on 2012 data, approximately 28% of the households will fall into this hardship category. This will be the hardship limit in 2014 at the time of system implementation. Prior to the second recertification under the new rent system in 2016, it will be determined if this hardship will continue. Rent burden overall average rent burden increases slightly, from 29.8% to 31%. Considering all of the program advantages and customer benefits in moving to a flat tiered rent, we believe this is reasonable as rent continues to be affordable, and the cost of the program is neutral. In the transition from the current rent calculation to the flat tiered system, rent burden cannot drop below 24%. This limit on rent burden will only be in effect in 2014, when families transition from the current rent structure to the flat tiered rent structure. Proration factor the flat fee per family member not eligible for assistance is $180. By switching from the current system of prorating the amount of assistance (average cost per family per month is $348) to adding a flat fee per ineligible member (average cost per family is $317), we Boulder Housing Partners 22

25 reduce the overall cost of mixed citizenship status by 9% and make it easier for families to understand the calculation. Cost to the program this model (using 2012 data) results in a slight increase to the cost of the program of approximately $3,500 annually which is a 2% increase for the Section 8 work-abled population. I. Hardship Case Criteria Maximum rent increase During the first recertification, all families will transition from rent based on a percentage of adjusted gross income (gross income minus deductions) to the flat tiered rent based on gross income (without deductions) and bedroom size. The families portion of rent will not increase more than 7%, provided all other factors remain the same, including amount of income, contract rent, utility allowance, unit size, etc. Minimum rent During implementation, those families who experience an increase in their outof-pocket rent due to the new minimum rent amount will be granted a 12-month transition period, provided that all other factors remain the same, including, but not limited to, amount of income, contract rent, utility allowance, unit size. No interim recertifications Exceptions will be made to this policy based on reasonable accommodation requests, as well as extenutating circumstances or situations, such as returning to school. Requests will be evaluated on a case-by-base basis. J. Annual Reevaluation of Rent Reform Activity This activity will be part of our rent study as required by our MTW Standard Agreement. The study will be conducted as a within subjects study, comparing the same set of subjects at time of implementation of the rent reform and then again two years later at the first recertification. The study will be designed and conducted by a research team from the University of Colorado who has contracted with BHP for this purpose. BHP intends to update the income and rent charts, along with minimum rent, in This will allow for the rent reform to be stable for five years. K. Transition Period As of March 1, 2014, all new admissions for work-abled households will have their rent portion calculated using this flat tiered rent system. All current households will have their rent portion change as of July 1, Activity : Rent Reform for Public Housing Work- Abled Families A. MTW Initiative Description This activity s main objective is to simplify the rent calculation for those families living in the Public Housing Program who are work-abled. Work-abled families are all households whose Boulder Housing Partners 23

26 head of household, spouse, or co-head is not elderly (elderly is defined as 62 years of age or older, or 50 and over in the case of Walnut Place residents) or a person with disabilities. 3 Rent based on 26.5% of gross income The rent for work-abled families in public housing will be based on 26.5% of gross income with no adjustments or deductions to income. In lieu of the current deductions for dependents and child care expense, rent will be based on a lower percentage of gross income (from the current 30% of adjusted gross income towards rent). This is the same rent calculation that was implemented for the eldery/disabled households in Currently, there is only one family in public housing who is claiming a child care expense deduction. Minimum rent In this rent structure, the minimum rent would increase from $50 to $120 per month. This new figure is based on 30% of the average Temporary Aid to Needy Families (TANF) monthly benefit amount. Biennial recertifications To comply with our study design in which the same group will be compared against itself at different times, all families will be recertified using the new rent calculation at the same time, effective August 1, The recertification will then take place every other year. At recertification, rent would be based on: 1. current gross income if it is stable and predictable, or 2. past 2 years of gross income (annualized) if income is not stable or no income is currently being reported Stable and predictable income is defined as income that is not temporary, expected to continue for the foreseeable future and not seasonal in nature. An example of stable income is a person hired to work a specified number of hours earning a certain amount of money per hour. If the resident is reporting no income at recertification, they will be required to meet with their property manager to determine if there are any benefits or services for which they may be eligible. They will also need to report any new sources of income until their portion of the rent (based on 26.5% of gross income) is equal or greater to $120. No interim recertifications A goal of rent reform is to mimic the market and eliminate potential for participants to intentionally reduce income in order to receive a lower rent. All interim recertifications will be eliminated with the exception of changes in family composition or status. If the resident is claiming zero income at the biennial recertification, they would need to report an increase in income if obtained prior to their next recertification and rent would be calculated based on the new source of income. 3 Separate rent reform structures are being proposed for the Section 8 and Public Housing work-abled families. This was based on the make-up of the population (80% of the families in public housing are mixed citizen families whose lower subsidy burden is advantageous in public housing and this will continue under the rent reform proposed) and the confines of our rent study. Per our MTW Agreement, the rent policy should be designed to encourage employment and self-sufficiency by participating families. The goal of the study is to meet HUD s purposes of evaluating the MTW demonstrations. (Please see Section VI for further information on the rent study.) Boulder Housing Partners 24

27 Flat fee per ineligible family member The current rent calculation requires us to prorate the assistance if a family includes members who are not eligible for assistance. This will be replaced with a flat fee of $90 per ineligible family member per month. B. MTW Statutory Objective This activity will: 1. Reduce cost and achieve greater cost effectiveness in federal expenditures; and 2. Create incentives for families to work, seek work or prepare for work. C. Anticipated Impacts BHP anticipates this activity will: o o o o o o Streamline the recertification process for public housing work-abled families Maintain a stable rent burden for families for two years Simplify the rent calculation, making it easier to understand and calculate Encourage residents to increase income Significantly reduce administrative time to allow property managers to focus on connecting residents to other resources and services for which they may qualify Reduce the time and cost for residents to gather the documentation for recertification Potential negative consequences include: o o Possible financial burdens to families who lose income during the period of time between recertifications. BHP will work with Emergency Family Assistance Association to develop a safety net program for these situations Foregone rental income when income increases during the period of time between recertifications and rent is not recalculated D. Anticipated Schedule BHP proposes to put everyone on the rent reform structure at the same time, effective August 1, For work-abled households currently living in public housing and who would have a recertification effective between January 1, 2014 and July 1, 2014, the rent would be recalculated using the information already obtained from the family effective August 1, For households whose recertification is scheduled between September and December 2014, their recertification will be effective August 1, For all those households who are new to the program as of March 1, 2014, the rent reform structure would apply from the date of new admission and no new recertification would be done August 1. The next recertification for these families would be scheduled for Mass recertification for work-abled households will occur every two years, during a three-month period. In the year in which no recertifications for work-abled will be conducted, staff will be able to focus on connecting participants to services, assisting households new to the program with leasing up, conduct inspections (versus contracting them out), etc. Boulder Housing Partners 25

28 Activity Metrics Information Metric Baseline Benchmark Total cost of task (decrease) Staff time savings Increase in household income Increase in positive outcomes in employment status: Full Time Increase in positive outcomes in employment status: Part Time Increase in positive outcomes in employment status: Educational Program Increase in positive outcomes in employment status: Job Trainee Increase in positive outcomes in employment status: Unemployed Number of households receiving TANF (decrease) Number of households receiving services aimed to increase self-sufficiency Number of families moved to self-sufficiency. Selfsufficiency defined as exiting program and moving into market rental or home ownership Current staff hours required per recertification x X number of recertifications (prior to implementation) x average of $26 per hour Current staff hours required per recertification x X number of recertifications (prior to implementation) Average household income at time of recertification in 2014 Number of households employed full time at time of recertification in 2014 Number of households employed part time at time of recertification in 2014 Number of student households at time of recertification in 2014 Number of job trainee households at time of recertification in 2014 Number of unemployed households at time of recertification in 2014 Number of TANF households at time of recertification in 2014 Number of households receiving services aimed to increase self-sufficiency at time of recertification in 2014 None 40% reduction over the twoyear recertification period 40% reduction over the twoyear recertification period Increase of 2% in household income Number of residents employed full time expected to increase by 2% Number of residents employed part time expected to increase by 2% No change anticipated No change anticipated Number of unemployed residents expected to decrease by 2% Number of residents receiving TANF expected to decrease by 2% Number of households receiving services aimed at increasing self-sufficiency expected to increase by 2% 1 (one) Implementation schedule All households will be recertified in 2014 and then not again until Results achieved by December 31, All households will be recertified in 2014 and then not again until Results achieved by December 31, Results achieved by December 31, 2016 Results achieved by December 31, 2016 Results achieved by December 31, 2016 Results achieved by December 31, 2016 Results achieved by December 31, 2016 Results achieved by December 31, 2016 Results achieved by December 31, 2016 Results achieved by December 31, 2016 Results achieved by December 31, 2016 Due to the biennial recertification schedule, information will not be collected from participating families in Benchmarks will be reported on in Boulder Housing Partners 26

29 E. Data Source for Metric Data BHP will be able to collect data to measure this activity from our financial and management reports using our internal database. BHP will also use a process improvement approach to documenting time required in performing all the steps associated with our current rent calculation. We will use that information as the baseline from which to measure improvements. Need/Justification for MTW Flexibility F. Authorization Cited Attachment C, Section C. 4: The Agency is authorized to restructure the annual and interim review process in order to affect the frequency of the reviews and the methods and process used to establish the integrity of the income information provided. Attachment C, Section C. 11: The Agency is authorized to determine family payment, including total tenant payment, the minimum rent, utility reimbursements and tenant rent. The Agency is authorized to adopt and implement any reasonable policies for setting rent in public housing including but not limited to eastablishing definitions of income and adjusted income, or earned income disallowance that differ those in current statues or regulations. G. Explanation for Authorization MTW flexibility is needed in order to eliminate deductions, base rent on 26.5% of gross income, charge a flat fee per ineligible famiy member, conduct bienniel recertifications, and eliminate interim recertifications. Additional Rent Reform Activity Information H. Impact Analysis Resident rent based on a percentage of income to compensate for the elimination of dependent and child care deductions, the percentage of income towards rent decreases from 30% to 26.5%. This is the same percentage we use for the elderly/disabled households and allows for rent burden to remain essentially the same. Minimum rent currently we have two work-abled families in public housing whose income puts them at the minimum rent of $50. Implementing a minimum rent of $120 will cause five families to experience an increase in rent burden. These families will be granted a 12-month transition period and will be linked to a service coordinator to help with the transition and to determine if there are any benefits or services available to them. Rent burden overall rent burden increases slightly, from 29.5% to 30.2%. Considering all the variables, we believe this is acceptable as the rent continues to be affordable, and cost of the program is neutral. Rent burden for fully eligible families remains below 25%, while rent burden for the mixed citizen families is 31.5%. Maximum rent increase the hardship policy will limit any increase to 7%. In this model, 58% of families experience an increase, while 42% experience a decrease. Among families experiencing an increase in rent, the average change is $64 (3.5% of average income). Twenty-two of these families experience an increase because residents portion of the rent will not be capped (see Boulder Housing Partners 27

30 Activity ); however rent burden is 26.5% of gross income. Among families experiencing a decrease in rent, the average change is -$61 (4.7% of average income). Across the entire population, the weighted average change in rent is an increase of $11 which accounts for 1% of the average income. Proration factor the flat fee per ineligible family member is $90. Under the current rent model, the average cost per family for having ineligible family members is $192. Using a flat fee per member of $90, the average cost per family is $178, a decrease of 7%. Cost of the program for public housing, the cost of the program is measured by the difference in resident rental income between current and proposed rent structures. This structure is as close to net zero as possible and results in an increase of $156 annually in our model using 2012 data. I. Hardship Case Criteria Maximum rent increase The hardship policy for rent reform in public housing includes capping the maximum increase at 7% (unless rent burden is less than 26.5%) and connecting families at the minimum rent to resident services. Data analysis shows that 34% of current families qualify for the 7% maximum increase. The hardship cap will only be effective if all other variables stay the same, such as income and utility allowance. Minimum rent During implementation, for those families who experience an increase in their out-of-pocket rent due to the new minimum rent amount will be granted a 12-month transition period, provided that all other factors remain the same, including amount of income, utility allowance, unit size, etc. No interim recertifications Exceptions will be made to this policy based on reasonable accommodation requests, as well as extenuating circumstance, such as a household member who wishes to return to school and needs to reduce their income. Requests will be evaluated on a case-by-base basis. J. Annual Reevaluation of Rent Reform Activity This activity will be part of our rent study as required by our MTW Standard Agreement. The study will be conducted as a within subjects study, comparing the same set of subjects at time of implementation of the rent reform and then again two years later at the first recertification. The study will be designed and conducted by the University of Colorado Research team who has contracted with BHP for this purpose. K. Transition Period As of March 1, 2014, all new admissions into public housing for work-abled households will have their rent portion calculated using this rent structure. All current households will have their rent portion change as of August 1, 2014 using the new rent structure. Boulder Housing Partners 28

31 Activity : Limit of One Interim Decrease Recertification per year for Elderly Households and Persons with Disabilities A. MTW Initiative Description This activity s main objective is to allow for households which are elderly (defined as 62 or over, with the exception of residents living in public housing at Walnut Place where the age is 50 or over) or persons with disabilities to be able to increase their income by keeping any increases they receive, regardless of the source. In Activity , these households were allowed to keep increases in income, but only when it was associated with a source of income that had already been reported and used in the calculation for their rent. This will apply to all elderly and disabled households in the Section 8 and Public Housing programs At the time of the regularly scheduled recertification (which is based on a triennial cycle), current income will be used to calculate the household s portion of the rent. If there is a loss of income after the recertification, households will be able to request one interim decrease per year during the three-year cycle. At recertification, rent would be based on: 1. current gross income if it is stable and predictable, or 2. past 2 years of gross income (annualized) if income is not stable or no income is currently being reported (or since their last interim recertification) Stable and predictable income is defined as income that is not temporary, expected to continue for the foreseeable future and not seasonal in nature. Example of stable income: a person is hired to work a specific number of hours earning a certain amount of money per hour. If the resident or participant is reporting no income at recertification, they will be required to meet with their Section 8 Occupancy Specialist or property manager to determine if there are any benefits or services they may be eligible to receive. B. MTW Statutory Objective This activity will: 1. Reduce cost and achieve greater cost effectiveness in federal expenditures; and 2. Create incentives for the elderly and persons with disabilities to work, seek work or prepare for work. C. Anticipated Impacts BHP aniticipates that this activity will: o o o Allow households with persons with disabilities to increase their income and experiment with how many hours they can work within their limitations without having to continually report changes in income to BHP Streamline the recertification process for these families Encourage residents and participants to increase income Boulder Housing Partners 29

32 o o Significantly reduce administrative time to allow occupancy specialists and property managers to focus on connecting residents and participants to other resources and services for which they may qualify Reduce the time and cost for residents to gather the documentation for interim recertifications Potential negative consequences include: o Foregone rental income and reduced housing assistance payments when income increases during the period of time between recertifications and rent is not recalculated D. Anticipated Schedule This policy will be in effect on March 1, 2014 with approval of the 2014 MTW Annual Plan. Activity Metrics Information Metric Baseline Benchmark Implementation schedule Total cost of task (decrease) Staff time savings Increase in household income Increase in positive outcomes in employment status: Full Time Increase in positive outcomes in employment status: Part Time Increase in positive outcomes in employment status: Educational Program Increase in positive outcomes in employment status: Job Trainee Increase in positive outcomes in employment status: Unemployed Number of families moved to self-sufficiency - defined as moving into market rental or home ownership Current staff hours required per recertification x 66 interim recertifications (prior to implementation) x average of $26 per hour Current staff hours required per recertification x 66 interim recertifications (prior to implementation) Averge household income at time of recertification in 2014 Number of households employed full time at time of recertification in 2014 Number of households employed part time at time of recertification in 2014 Number of student households at time of recertification in 2014 Number of job trainee households at time of recertification in 2014 Number of unemployed households at time of recertification in 2014 None 40% reduction over the twoyear recertification period 40% reduction over the twoyear recertification period Increase of 2% in household income Number of residents employed full time expected to increase by 2% Number of residents employed part time expected to increase by 2% No change anticipated No change anticipated Number of unemployed residents expected to decrease by 2% None (due to the demographics of the these households) Effective 1/1/14 for all households. Results achieved by December 31, 2017 as some households are on triennial recertification. Effective 1/1/14 for all households. Results achieved by December 31, 2017 as some households are on triennial recertification. Results achieved by December 31, 2017 Results achieved by December 31, 2017 Results achieved by December 31, 2017 Results achieved by December 31, 2017 Results achieved by December 31, 2017 Results achieved by December 31, 2017 Results achieved by December 31, 2017 Boulder Housing Partners 30

33 E. Data Source for Metric Data BHP will rely on our operating data base for financial information. Need/Justification for MTW Flexibility F. Authorization Cited Attachment C, Section C. 4.: The Agency is authorized to restructure the annual and interim review procress in order to affect the frequency of the reviews and the methods and process used to establish the integrity of the income information provided. Attachment C, Section C. 11: The Agency is authorized to determine family payment, including total tenant payment, the minimum rent, utility reimbursements and tenant rent. The Agency is authorized to adopt and implement any reasonable policies for setting rent in public housing including but not limited to establishing definitions of income and adjusted income, or earned income disallowance that differ from those in current statues or regulations. Attachment C, Section D. 1. c: The Agency is authorized to define, adopt and implement a reexamination program that differs from current program requirements. Attachment C, Section D. 2. a: The Agency is authorized to adopt and implement any reasonable policies to calculate the tenant portion of the rent that differs from current program requirements. G. Explanation for Authorization MTW flexibility is needed in order to eliminate interim recertifications. H. Additional Rent Reform Activity Information Hardship cases: Exceptions will be made to this policy based on reasonable accommodation requests, as well as extenuating circumstances. Requests will be evaluated on a case-by-base basis. Activity : Removal of Flat Rent Option for all Public Housing Households A. MTW Initiative Description The main objective of this activity is to ensure that the limited resource of public housing operating subsidy is applied equitably for all public housing residents and families are not being over-subsidized. This activity will remove the option for residents to pay the flat rent if their portion of the rent based on their income exceeds the flat rent, allowing for all families to pay rent according to their income. This portion of the activity will apply to all households in public housing (both work-abled and elderly/disabled households). B. MTW Statutory Objective This activity will: 1. Reduce cost and achieve greater cost effectiveness in federal expenditures. Boulder Housing Partners 31

34 C. Anticipated Impacts BHP anticipates this activity will: o Increase rental revenue Potential negative consequences include: o Remove opportunities for households to save money by maintaining a rent burden less than 26.5% D. Anticipated Schedule Beginning in 2014 with the implementation of rent reform for work-abled families, no family will be given the option to choose the flat rent. For elderly and disabled public housing families, the option will be removed at their next regularly scheduled recertification (they are currently on a triennial recertification cycle). Activity Metrics Information Metric Baseline Benchmark Implementation schedule PHA rental revenue in dollars (increase) Pubilc Housing rental revenue at time of recertification in 2014 Increase to Public Housing rental revenue by $135,000 Results achieved by December 31, 2016 E. Data Source for Metric Data BHP will be able to collect data to measure this activity from our financial and management reports using our internal database. Need/Justification for MTW Flexibility F. Authorization Cited Attachment C, Section C. 11: The Agency is authorized to determine family payment, including total tenant payment, the minimum rent, utility reimbursements and tenant rent. The Agency is authorized to adopt and implement any reasonable policies for setting rent in public housing including but not limited to establishing definitions of income and adjusted income, or earned income disallowance that differ from those in current statues or regulations. The Agency is authorized to adopt and implement term limits for its public housing assistance. G. Explanation for Authorization MTW flexibility is needed in order to allow for all residents to pay rent based on 26.5% of gross income. Boulder Housing Partners 32

35 Additional Rent Reform Activity Information H. Impact Analysis In the data analysis, 22 of the 135 public housing work-abled families rent will increase because their portion is more than the flat rent. The average impact to these families is an increase of $154 which amounts to an increase of 5% of average income. Of the 195 elderly/disabled households, three of the households will experience an increase in their portion of the rent at their next regularly scheduled recertification. The average increase for these three households is $147, or an increase of 6% of average income. The rent burden for all families will be 26.5%. I. Hardship Case Criteria Exceptions will be made to this policy based on reasonable accommodation requests, as well as extenuating circumstances. Requests will be evaluated on a case-by-base basis. J. Annual Reevaluation of Rent Reform Activity This activity will be reviewed every time the situation ocurrs to determine if changes are needed to the activity. K. Transition Period This will be in effect for all public housing residents at the time of the regularly scheduled recertification, which for the elderly and disabled households will be on a triennial recertification. For the work-abled families, it will be in effect at their annual. Activity : Changes in mobility options for the Woodlands Family Self-Sufficiency Program A. MTW Initiative Description The main objective of this activity is to facilitate and encourage families participating in the Family Self-Sufficiency (FSS) Program at Woodlands to move through BHP s housing continuum. BHP built the Woodlands Community in 1995 in partnership with Boulder County Housing Authority (BCHA). BHP provides housing assistance through the Section 8 Vouchers that are project-based at the community. BCHA provides case management services through the FSS Program and is funded through HUD. Families are selected first to participate in the FSS program and then receive housing assistance by living at Woodlands. While in the program, the case management services focus on education and employment with the goal of families being self-sufficient within five years. In year four, the emphasis is on graduating from the program and seeking housing options outside of Woodlands. For participants to receive maximum benefit from the program and the community at Woodlands, BHP proposes to allow participants who live there to request the next available voucher and move no sooner than three years of successful participation in the program. Exceptions would include job offers in a different location, access to schooling that would require a move, or extenuating circumstances to be determined on a case-by-case basis. In order to continue the movement through the housing continuum and the momentum that is created while participating in the program, participants who successfully graduate from the Boulder Housing Partners 33

36 program will be required to move from Woodlands once they successfully graduate from the program, and allow them to leave with the next available voucher (if needed by the family). At all points of exit from the program (due to exentuating circumstances, after three years, and upon successful graduation), as long as the participant family is in compliance with the FSS and Section 8 Program, the family may request the next available voucher (if needed by the family). B. MTW Statutory Objective This activity will: 1. Increase housing choices for low-income households. C. Anticipated Impacts BHP anticipates this activity will: o Reduce wait time for applicants on the FSS wait list Potential negative consequences include: o Increased pressure on families who will need to move upon graduation D. Anticipated Schedule This activity will be in effect for all Woodlands participants upon approval of the 2014 MTW Annual Plan. Exceptions based on reasonable accommodation due to a disability can be made depending on the circumstances. Activity Metrics Information Metric Baseline Benchmark Implementation schedule Average applicant time on FSS wait list in months (decrease) average waitlist time was 10.3 months Average waitlist time expected to decrease by 1 month To be reported annually as it occurs E. Data Source for Metric Data BHP and BCHHS FSS Program staff will monitor the requests to move, as well as the successful graduations, using internal housing software systems. Need/Justification for MTW Flexibility F. Authorization Cited Attachment C, Section D, 4: The Agency is authorized to determine waiting list procedures, tenant selection procedures and criteria and preference. Attachment C, Section D, 1 b.: The Agency is authorized to determine the length of the lease period, when vouchers expire and when vouchers will be reissued.. Boulder Housing Partners 34

37 G. Explanation for Authorization MTW flexibility is required in order to allow for minimum occupancy limits prior to requesting the next available voucher and to set the maximum occupancy limit at this project-based voucher site. Additional Rent Reform Activity Information This section is not applicable for this activity. Activity : Rent Limits and Rent Reasonableness for Project-Based Voucher Projects A. MTW Initiative Description This activity s main objective is to reduce cost, eliminate redundancy and increase efficiency by allowing the Housing Authority to establish appropriate rent limits in project-based voucher projects and conduct its own rent reasonsableness procedures for setting rents at Project-Based Voucher (PBV) Communities where the developer is required, or has chosen, to conduct a market study. This would apply to all projects where BHP will project base vouchers. BHP will establish reasonable rents for the PBV sites using data gathered from the following sources: 1. First priority: a market study that has been prepared as a requirement of the Low Income Housing Tax Credit (LIHTC) program. These studies are extensive, wellresearched and provide a high level of detail about rents in comparable units. In BHP s experience a LIHTC market study provides a broader range of information than a traditional rent reasonable study. 2. Second priority: a review of the proposed rents compared to Fair Market Rents and the Payment Standard; 3. Third priority: a review of Market Comps and average rents in the area based on local surveys that are current at the time of setting rents. With these three sources of data, a BHP team that is not associated with the proposed project, in the event that the petitioner is BHP, will review the proposed rents and assure that the rents do not exceed 10% of the range established as reasonable for each bedroom size. Amenities and services provided at the project will be considered as part of the evaluation process. Reasonable will be defined as the lower of:. An amount determined by BHP based on the research and criteria above, not to exceed 110% of the applicable fair market rent;. The reasonable rent; or. The rent requested by the owner. While this activity is proposed for all future PBV LIHTC projects, in 2014 this activity will specifically be used to set the rents at 1175 Lee Hill, a 31-unit permanently supportive housing site for the chronically homeless. This community is modeled after the Housing First model, where housing is established first and case management services are provided to ensure the success of the residents. We expect that this project will save resources and will increase Boulder Housing Partners 35

38 housing choices by allowing a voucher rent to exceed the LIHTC standards when reasonable and appropriate. In a high cost market like Boulder s, with land cost contributing to almost half of the total development cost, and when services provided are extraordinary it can be appropriate to approve a voucher rent. B. MTW Statutory Objective This activity will: 1. Reduce cost and achieve greater cost effectiveness in federal expenditures; and 2. Increase housing choices for low-income families. C. Anticipated Impacts BHP aniticipates that this activity will: o o o o Eliminate the current redundancy between procuring a market study and a rent reasonableness study Elminate the cost of procuring two studies, when one study can answer the rent reasonableness question Create efficiency in the process of setting rents by using data that is easily accessible Create 31 units of affordable housing with critical case management services attached to provide stable housing first for these chronically homeless households Potential negative consequences include: o Establishing or allowing a rent that is not reasonable for the product or the market D. Anticipated Schedule Vouchers are anticipated to be project-based at 1175 Lee Hill upon completion of construction, currently projected for August Activity Metrics Information Metric Baseline Benchmark Implementation schedule Total cost of task (decrease) $6,000 Number of new housing units made for households at or below 80% AMI as a result of activity Number of housing units preserved for households at or below 80% AMI that would otherwise not be available Cost expected to decrease by $6,000 to $0 for each project December 31, 2014 for Lee Hill /1/ /1/2015 E. Final Projected Outcome We expect that this project will save resources and will increase housing choices by allowing a voucher rent to exceed the LIHTC standards when reasonable and appropriate. In a high cost Boulder Housing Partners 36

39 market like Boulder s, with land cost contributing to almost half of the total development cost, and when services provided are extraordinary, it can be appropriate to approve a voucher rent. Anything that BHP can do with MTW flexibility to facilitate the production of more affordable housing is essential. This activity will help. F. Data Source for Metric Data BHP will rely on our operating data base for financial information. Need/Justification for MTW Flexibility G. Authorization Cited Attachment C, Section D. 2. c.: The Agency is authorized to develop a local process to determine rent reasonableness that differs from the currently mandated program requirements. H. Explanation for Authorization We expect that this project will save time and money and will increase housing choices by allowing a voucher rent to exceed the LIHTC standards when reasonable and appropriate. In a high cost market like Boulder s, with land cost contributing to almost half of the total development cost, and when services provided are extraordinary it can be appropriate to approve a voucher rent. Anything that BHP can do with MTW flexibility to facilitate the production of more affordable housing is essential. This activity will help. I. Additional Rent Reform Activity Information This section is not applicable for this activity. Boulder Housing Partners 37

40 Section IV: Approved MTW Activities Implemented Activity Rent simplification specifically for elderly households and people with disabilities The main objective of this activity was to simplify the rent calculation for elderly households and persons with disabilities who are living on a fixed income. This activity focuses on four areas: 1) rent based on 26.5% of gross income; 2) triennial recertifications; 3) income disregard and 4) a limit on interim decreases. This activity was approved and implemented in Activity will limit interim decrease recertifications to one per year during the triennial recertification cycle and eliminate all interims for any increase in income, including new sources. All other aspects of this activity remain in effect. No other significant changes are being made. Activity Rent simplification specifically for family households This activity aims to simplify the rent calculation for family households by eliminating all interim increases, eliminate earned income disregard, and planning for a flat tiered rent system. This activity was approved and implemented for Activities and 2 eliminate all interim recertifications. Planning for a flat tiered rent system is now completed and included as Activity As part of Activity , elimination of earned income disregard remains in effect. Activity Rent simplification for all households The goal of this activity was to implement a series of changes to simplify the income and asset verification process for all families. This activity was first identified and approved for 2012 and included allowing households to provide asset and income documentation; exclude income from assets and allow for self-certification of assets that total $50,000 or less; and limit asset totals to $50,000 or less upon admissions to the public housing and Section 8 program. This activity was approved and implemented for BHP does not anticipate any changes to the activity or metrics in Activity Eliminate the 40% of income cap in the voucher program The goal of this activity was to provide more rental choices to Section 8 voucher holders with their voucher by eliminating the 40% of income towards rent cap when they initially lease up. This activity was approved and implemented in BHP does not anticipate any changes to the activity or metrics in Activity Implement a flat utility allowance for the voucher program This activity s main objective was to increase voucher holder s ease of understanding of the rent calculation and how utilities affect the maximum contract rent allowed. This activity was approved and implemented in BHP does not anticipate any changes to the activity or metrics in Boulder Housing Partners 38

41 Activity Housing Quality Standards Inspection Schedule The main objective of this activity was to replace Activity This activity aligns the HQS inspection with the recertification schedule. In 2013, for all households who are elderly or a person with disabilities, the inspection schedule now follows the recertification schedule which is conducted every three years. In 2014, when Activity is implemented, inspections for the work-abled family households will line up with the recertification schedule. This activity was approved and implemented in BHP does not anticipate any changes to the activity or metrics in Activity Eliminate Utility Reimbursement Payments The focus of this activity was to ensure that all p ublic housing residents and Section 8 participants are contributing towards their rental payment (or at a minimum to ensure that residents and participants are not receiving payment to live on housing assistance). Households who received a utility reimbursement payment (URP) in April 2013 will continue to receive one through March 2014, unless there is a change in their circumstances that removes the URP. No new instances of URP were allowed after April 1, BHP does not anticipate any changes to the activity or metrics in Activity Local Voucher Program in Partnership with Safehouse Progressive Alliance for Nonviolence This activity focuses on continuing BHP s partnership with Safehouse Progressive Alliance for Nonviolence (SPAN). The activity, which provides eight families who are victims of domestic violence with housing assistance through BHP and case management services through SPAN, allows BHP to use vouchers for transitional housing. This activity was approved and implemented in BHP does not anticipate any changes to the activity or metrics in Activity Use of Replacement Housing Factor Funds for other affordable housing This activity allows BHP to use Replacement Housing Factor (RHF) Funds to build other affordable housing units. In 2014, BHP will use RHF Funds at 1175 Lee Hill, a 31-unit community for chronically homeless using the Housing First model. Construction is expected to begin in October BHP does not anticipate any changes to the activity or metrics in Not Yet Implemented Activity Allow BHP to commit project-based vouchers to cover 100% of the units at converted public housing developments This activity was first identified and approved for In February 2012, BHP submitted a disposition application for 100% of our public housing units. The activity includes the flexibility to waive the 20% cap on project-based vouchers, define excepted units and create a local project-based voucher program for former public housing sites. As of October 14, 2013, BHP continues to work with HUD using current programs to dispose of all public housing units and convert them to project-based voucher communities Boulder Housing Partners 39

42 using Section 18 or RAD. No additional vouchers were project based in The flexibility under this activity has not yet been applied. Based on current information, 2014 will be a planning year for BHP. Once disposition is granted and RAD has been determined, BHP will complete the financing, begin planning the renovations, and schedule the work to begin in 2015, at which time the vouchers would also be project-based at the converted public housing sites. BHP does not anticipate any changes or modifications to this activity, nor are different authorizations needed from what was initially proposed. On Hold BHP does not have any approved activities that are on hold. Closed Out Activity Implement a landlord self-certification system for HQS inspections for the voucher program This activity was not implemented. When the activity was written, the objective was to reduce the frequency of inspections for those participants and landlords who were in compliance with HQS inspections and had been for the past year or more. When it came time to implement the activity, it became apparent that the responsibility of certifying to the standards would put a burden on the landlords, as well as the agency to ensure that landlords were completing the forms and returning them. The activity was re-written and approved in the 2013 MTW Annual Plan under Activity The new activity will allow the inspection cycle to follow the recertification schedule. Boulder Housing Partners 40

43 Section V: MTW Sources and Uses of Funds V.1.Plan.Sources and Uses of MTW Funds A. MTW Plan: Sources and Uses of MTW Funds Estimated Sources of MTW Funding for the Fiscal Year PHAs shall provide the estimated sources and amounts of MTW funding by FDS line item. Sources FDS Line Item FDS Line Item Name Dollar Amount ( ) Total Tenant Revenue 1,331, HUD PHA Operating Grants 5,917, Capital Grants 355, ( ) Total Fee Revenue Interest Income Gain or Loss on Sale of Capital Assets Other Income 100, Total Revenue 7,703,500 Estimated Uses of MTW Funding for the Fiscal Year PHAs shall provide the estimated uses and amounts of MTW spending by FDS line item. Uses FDS Line Item FDS Line Item Name Dollar Amount ( ) Total Operating - Administrative 942, Management Fee Expense 428, Allocated Overhead ( ) Total Tenant Services 44,000 Boulder Housing Partners 41

44 93000 ( ) Total Utilities 322, Labor ( ) ( ) ( ) ( ) Total Ordinary Maintenance Total Protective Services Total insurance Premiums Total Other General Expenses 807,000 25,000 86, , ( ) Total Interest Expense and Amortization Cost 84, Total Extraordinary Maintenance Housing Assistance Payments + HAP Portability-In 0 4,486, Depreciation Expense 543, All Other Expenses Total Expenses 7,891,500 Describe the Activities that Will Use Only MTW Single Fund Flexibility The 2011 CFP funds will be used on the rent control study that is required of BHP and described in detail in Section 7, C. of this Plan, the 2012 CFP funds will be used for operations, and the 2013 CFP funds will be used for predevelopment work on the Public Housing Disposition project. V.2.Plan.Local Asset Management Plan B. MTW Plan: Local Asset Management Plan Is the PHA allocating costs within statute? Yes Is the PHA implementing a local asset management plan (LAMP)? No Boulder Housing Partners 42

45 If the PHA is implementing a LAMP, it shall be described in an appendix every year beginning with the year it is proposed and approved. The narrative shall explain the deviations from existing HUD requirements and should be updated if any changes are made to the LAMP. Has the PHA provided a LAMP in the appendix? No PHAs should provide a brief summary of any changes in the Local Asset Management Plan in the body of the Plan. Assumptions for Sources of funds in 2014 Total Tenant Revenue No change from 2013 budget which is tracking close to actual YTD HUD PHA Operating Grants (BHP is assuming full year PH funding, conversion/disposition to occur in 2015) HCVP HAP, Admin and PH Op Subsidy additional 8% reduction from 2013 actual funding due to sequestration $50,000 of remaining 2011 CFP used for operations expense of contractor performing MTW modeling and analysis Capital Grants 2012 increment used in full on predevelopment work for PH disposition project Other Income Estimate of Solar rebates, QECB interest rebate from IRS, insurance dividend etc. Total Cash Sources 7,703,500 Total Uses 7,891,500 Less Depreciation: -543,000 Plus sources used on Capital Items (2012 CFP) for which no line was included in the HUD form 355,000 Total Cash Uses 7,703,500 Diff 0 Boulder Housing Partners 43

46 Section VI: Administrative A. Board Resolution 44

47 45

48 46

49 B. Public Review This 2014 MTW Annual Plan was made public for review from September 10, 2013 through October 14, The Plan was posted to our website. Two public hearings were held on September 23, 2013 at the main office of Boulder Housing Partners. A total of 12 public housing residents and Section 8 participants attended. Comments were all positive with no suggestions for changes. Prior to writing the draft Plan, 11 meetings were held with interested stakeholders. These meetings were held to discuss the proposed changes and solicit comments and suggestions. There was a meeting held at each of the eight public housing sites. Two meetings were held for Section 8 participants. One meeting was held with our partner agencies. A total of 194 people were in attendance (157 were public housing residents, 33 Section 8 participants, and 4 partners). These meetings were held between July 22 and August 6, 2013 (with the exception of the partner meeting which was held on June 14, 2013). In November 2012, BHP began the discussion with MTW Resident Advisory Committee (RAC) regarding different types of rent structures. In January 2013, BHP held two MTW RAC meetings to further narrow down the different types of rent structures. Twenty-one people participated in January. In May 2013, separate meetings were held for MTW RAC members based on the program in which they were participating. The rent structure for each program (which are proposed in this Plan) was discussed in detail at these meetings. Eighteen residents and participants attended in May. C. Agency-Directed Evaluation of the Demonstration BHP is working in partnership with the University of Colorado (CU) to develop the rent controlled study to evaluate the effects of the rent reform structures that will be put into place in The proposed approach to the study, as authored by the research team at CU, is as follows: 1. Purpose of the Study As part of its MTW Agreement, BHP proposes two interventions: designing and adopting a new rent model, and promoting resident services. With these interventions, BHP aims to meet MTW program objectives by: - Increasing the proportion of working households - Increasing average income from employment - Decreasing the number of staff hours in recertification process related to income changes - Decreasing the number of paybacks due to unreported increases in income By initiating an experimental study in Boulder, Colorado, the effects of the proposed interventions on Public Housing and Section 8 Voucher program households economic selfsufficiency will be evaluated. Boulder Housing Partners 47

50 2. Research Questions Four main questions will be asked: (1) To what extent did the new rent model increase the proportion of working households? (2) To what extent did the new rent model and access to resident services increase the proportion of working households? (3) To what extent did the new rent model increase households average income from employment? (4) To what extent did the new rent model and resident services increase households average income from employment? Boulder Housing Partners is expecting that the new rent model will yield an increase of 2% in number of working families and an increase of 2% in average earned income. In addition to earned income, dependence on public subsidies and private actors will be assessed to measure the change in Moving-to-Work participants economic self-sufficiency. Other household outcomes, such as rent burden, childcare expenses and placement issues, mobility (private and public transportation), level of education and school performance, access to resources, access to food, health status, participation in community and social support networks, and personal and job skills may also be evaluated. 3. Research Design To assess household impacts of its two proposed MTW interventions (rent reform for the Section 8 and Public Housing work-abled families), BHP will examine how and to what extent a new rent model will affect Section 8 MTW household outcomes. In addition, it will assess possible impacts of the selective, site-specific introduction of improvement in resident services for public housing residents. In the research design, the new rent model and the improvement in resident services function as independent variables. The dependent variables (household outcomes) include: earned income from employment employment status rent burden childcare expenses and placement issues mobility (private and public transportation) level of education / school performance access to resources (legal, financial, etc.) access to food health status participation in community and social support networks personal and job skills The selection of the preferred method depends on several considerations, including the available population in a community, or sample size that can be drawn from a population. Boulder Housing Partners 48

51 Statistical power analysis helps researchers understand how large a sample is needed to enable statistical judgments that are accurate and reliable. Estimating the required sample size before an experimental study is important because if sample size is too low, the experiment will lack the precision to provide reliable answers to the questions it is investigating. If sample size is too large, time and resources will be wasted, often for minimal gain. Statistical power analysis helps researchers to estimate the required sample size. Ideally, the research design would include a treatment group and a control group, not exposed to any intervention with data collection at baseline and after implementation of the interventions (or some variation thereof that could include phased introduction of the interventions). Realistically, the size and composition of BHP s resident population make a different research design more appropriate. Splitting the total resident population of 398 households into treatment and control groups would produce numbers too small for meaningful statistical analysis. This size limitation is exacerbated by the certainty of a less than 100% initial response rate. 4 Response rates will decline further in subsequent data collection, made more problematic due to annual attrition of about 10% resulting from resident turnover. Research has shown that BHP would need a minimum of 800 households to participate in a control study to have the ability to produce meaningful data; BHP has a total population of 398 households eligible for the study. As to composition, BHP s resident population includes two distinct groups: households in public housing (N=135) and households with housing choice vouchers (N=263). The former live in spatial clusters and include significantly more Latino households, creating two distinctly different subpopulations. If households from across both subpopulations would be randomly assigned to treatment and control groups, the analysis would need to partial out confounding influences, associated with subpopulation characteristics and not arising from the intervention. Doing so would require statistical techniques that assume a larger number of households. Alternatively, each of the two subpopulations of an already small total resident population each could be split into a treatment and a control group. However, also this scenario would produce numbers too small for meaningful analysis. Therefore, the logical research design involves a within-subjects experiment. This approach examines an assumed relationship between, for example, rent burden and earned household income, by manipulating an independent variable (e.g., rent paid), and comparing dependent variable values (e.g., job earnings), resulting from independent variable changes, with known baseline conditions. Control groups as in between-subjects experiments are not needed because each household at Time 1 is compared with itself at Time 2 and Time 3 (see Figure 4). 4 Even with personal follow-up visits, past studies have reported significant non-response rates. Typical examples of the proportion of public housing residents participating in survey research are: 2% (Hynes et al. 2000) 53% (Bennett et al. 2007) 56% (phone survey; Digenis-Bury et al. 2008) 62% and 79% (personal interviews with return visits; Cora et al. 2007) 65% (mail survey with follow up phone calls), 58% (Goetz 2010). 85% (personal interviews; Kleit 2003) 91% (survey with follow up visits to qualify for MTO; Ludwig et al. 2001) Boulder Housing Partners 49

52 Figure 4: Visualization of within-subjects research design T 1 T 2 T 3 Section 8 Voucher Program (N T1 =263) New rent Structure I Earned income Employment status Rent burden Childcare issues Mobility Access to food Etc. Earned income Employment status Rent burden Childcare issues Mobility Access to food Etc. Earned income Employment status Rent burden Childcare issues Mobility Access to food Etc. Public Housing Program (N T1 =135) New rent Structure II + Resident Services Earned income Employment status Rent burden Childcare issues Mobility Access to food Etc. Earned income Employment status Rent burden Childcare issues Mobility Access to food Etc. Earned income Employment status Rent burden Childcare issues Mobility Access to food Etc. Pre-intervention Survey Post-intervention Survey Post-intervention Survey From an ethical perspective, another advantage of the within-subjects design is that it avoids the thorny issue of having to withhold from (control group) households an intervention that is expected to benefit residents. BHP plans to target Section 8 households for rent reform. Public housing households will also experience some rent reform, as well as improved resident services in select projects, enabling an exploration of impacts through comparison over time and with projects that will not see a change in resident services Data Collection and Analysis A mixed-method approach, using quantitative and qualitative methods, will be used to collect and analyze primary data from MTW participants and BHP staff: 5 The number of households in these comparisons will be too small for statistical analysis, but qualitative data can nonetheless provide valuable insights to guide further program development Boulder Housing Partners 50

53 Data sources MTW households MTW program staff Data collection Instruments * Questionnaires * Focus groups * Interviews * Interviews * Secondary (archival) data Questionnaires for Measuring MTW Households Economic Self-Sufficiency A baseline questionnaire survey will be administered to all sample members (MTW households) immediately before adopting the new rent model and starting the resident services. The same questionnaire will be administered to MTW households at the end of year 2 to measure the affect of the proposed interventions on their economic self-sufficiency. Questionnaire surveys have been the most common technique for assessing individual s self-sufficiency (see, for example, Abt Associates Inc. et al., 2006; Gowdy and Pearlmutter, 1993; Pinsoneault, 2006; Ramey, 2010; Women s Foundation of Genesee Valley, 2004). This method was chosen particularly due to its potential for the researchers to help them compare pre- and post-cases in a reliable manner. D. Annual Statement/Performance and Evaluation Report (HUD ) Boulder Housing Partners 51

54 Annual Statement/Performance and Evaluation Report U.S. Department of Housing and Urban Development Capital Fund Program, Capital Fund Program Replacement Housing Factor and Office of Public and Indian Housing Capital Fund Financing Program OMB No Expires 4/30/2011 Part I: Summary PHA Name: Boulder Housing Partners Grant Type and Number Capital Fund Program Grant No: CO06P Replacement Housing Factor Grant No: CO06R Date of CFFP: Type of Grant Original Annual Statement Reserve for Disasters/Emergencies Revised Annual Statement (revision no: ) Performance and Evaluation Report for Period Ending: 09/30/2013 Final Performance and Evaluation Report FFY of Grant: 2011 FFY of Grant Approval: 2011 Line Summary by Development Account Total Estimated Cost Total Actual Cost 1 Original Revised 2 Obligated Expended 1 Total non-cfp Funds Operations (may not exceed 20% of line 21) 3 79,234 79,234 $48, $48, Management Improvements Administration (may not exceed 10% of line 21) 39,617 39,617 $28, $28, Audit Liquidated Damages Fees and Costs 22, Site Acquisition Site Improvement Dwelling Structures 254, Dwelling Equipment Nonexpendable Non-dwelling Structures Non-dwelling Equipment Demolition Moving to Work Demonstration 277,317 $205, $205, Relocation Costs Development Activities 4 1 To be completed for the Performance and Evaluation Report. 2 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 3 PHAs with under 250 units in management may use 100% of CFP Grants for operations. 4 RHF funds shall be included here. 52 form HUD (4/2008)

55 Annual Statement/Performance and Evaluation Report U.S. Department of Housing and Urban Development Capital Fund Program, Capital Fund Program Replacement Housing Factor and Office of Public and Indian Housing Capital Fund Financing Program OMB No Expires 4/30/2011 Part I: Summary PHA Name: Boulder Housing Partners Type of Grant Grant Type and Number Capital Fund Program Grant No: CO06P Replacement Housing Factor Grant No: CO06R Date of CFFP: FFY of Grant:2011 FFY of Grant Approval: 2011 Original Annual Statement Reserve for Disasters/Emergencies Revised Annual Statement (revision no: ) Performance and Evaluation Report for Period Ending: 09/30/2013 Final Performance and Evaluation Report Line Summary by Development Account Total Estimated Cost Total Actual Cost 1 Original Revised 2 Obligated Expended 18a 1501 Collateralization or Debt Service paid by the PHA 0 18ba 9000 Collateralization or Debt Service paid Via System of Direct 0 Payment Contingency (may not exceed 8% of line 20) 20 Amount of Annual Grant:: (sum of lines 2-19) 396, , , , Amount of line 20 Related to LBP Activities 0 22 Amount of line 20 Related to Section 504 Activities 0 23 Amount of line 20 Related to Security - Soft Costs 0 24 Amount of line 20 Related to Security - Hard Costs 0 25 Amount of line 20 Related to Energy Conservation Measures 0 Signature of Executive Director Date Signature of Public Housing Director Date 1 To be completed for the Performance and Evaluation Report. 2 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 3 PHAs with under 250 units in management may use 100% of CFP Grants for operations. 4 RHF funds shall be included here. 53 form HUD (4/2008)

56 Annual Statement/Performance and Evaluation Report U.S. Department of Housing and Urban Development Capital Fund Program, Capital Fund Program Replacement Housing Factor and Office of Public and Indian Housing Capital Fund Financing Program OMB No Expires 4/30/2011 Part II: Supporting Pages PHA Name: Boulder Housing Partners Grant Type and Number Capital Fund Program Grant No: CO06P CFFP (Yes/ No): No Replacement Housing Factor Grant No: CO06R Federal FFY of Grant: 2011 Development Number Name/PHA-Wide Activities CO Kalmia PHA Wide General Description of Major Work Categories General Renovation including siding, windows, roofs, gutters, interiors, parking lot repairs Kitchen Renovations--AC Backflow Preventers Playground Renovation--Diagonal Court Bathroom Remodel--Arapahoe Court Electrical Outlet Upgrade--Manhattan Kitchen Renovations--Diagonal Court Replace Roof Ventilator--Walnut Place Replace HVAC in Common Area-- Walnut Place Permanent Soccer Goal Installation-- Diagonal Court Development Account No. Quantity Total Estimated Cost Total Actual Cost Status of Work Original Revised 1 Funds Obligated ,551 0 Funds Expended $79,234 $48, $48, All projects complete. PHA Wide--Admin Administrative Fees ,617 39,617 28, , On-going Move to Work Emergency Elevator Repairs at Walnut Place Solar Snow Guards at Manhattan, Kalmia, Iris/Hawthorne Certified Needs Assessments, Appraisals- -predevelopment for all public housing site renovation work Principle and Interest Payment on QECB for Energy Performance Contract Program and Salary Cost Associated with Move to Work Program Furniture for Northport Community Room , , , On-going form HUD (4/2008) 54

57 Annual Statement/Performance and Evaluation Report U.S. Department of Housing and Urban Development Capital Fund Program, Capital Fund Program Replacement Housing Factor and Office of Public and Indian Housing Capital Fund Financing Program OMB No Expires 4/30/2011 Part I: Summary PHA Name: Boulder Housing Partners $355,006 Grant Type and Number Capital Fund Program Grant No: CO06P Replacement Housing Factor Grant No: CO06R Date of CFFP: FFY of Grant: 2012 FFY of Grant Approval: 2012 Type of Grant Original Annual Statement Reserve for Disasters/Emergencies Revised Annual Statement (revision no: ) Performance and Evaluation Report for Period Ending: 9/30/2013 Final Performance and Evaluation Report Line Summary by Development Account Total Estimated Cost Total Actual Cost 1 1 Total non-cfp Funds Original Revised 2 Obligated Expended Operations (may not exceed 20% of line 21) Management Improvements Administration (may not exceed 10% of line 21) $35, Audit Liquidated Damages Fees and Costs Site Acquisition Site Improvement Dwelling Structures Dwelling Equipment Nonexpendable Non-dwelling Structures Non-dwelling Equipment Demolition Moving to Work Demonstration $319, Relocation Costs Development Activities 4 1 To be completed for the Performance and Evaluation Report. 2 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 3 PHAs with under 250 units in management may use 100% of CFP Grants for operations. 4 RHF funds shall be included here. 55 form HUD (4/2008)

58 Annual Statement/Performance and Evaluation Report U.S. Department of Housing and Urban Development Capital Fund Program, Capital Fund Program Replacement Housing Factor and Office of Public and Indian Housing Capital Fund Financing Program OMB No Expires 4/30/2011 Part I: Summary PHA Name: Boulder Housing Partners Type of Grant Grant Type and Number Capital Fund Program Grant No: CO06P Replacement Housing Factor Grant No: CO06R Date of CFFP: No FFY of Grant:2012 FFY of Grant Approval: 2012 Original Annual Statement Reserve for Disasters/Emergencies Revised Annual Statement (revision no: ) Performance and Evaluation Report for Period Ending: 9/30/2013 Final Performance and Evaluation Report Line Summary by Development Account Total Estimated Cost Total Actual Cost 1 Original Revised 2 Obligated Expended 18a 18ba 1501 Collateralization or Debt Service paid by the PHA 9000 Collateralization or Debt Service paid Via System of Direct Payment Contingency (may not exceed 8% of line 20) 20 Amount of Annual Grant:: (sum of lines 2-19) 21 Amount of line 20 Related to LBP Activities 22 Amount of line 20 Related to Section 504 Activities 23 Amount of line 20 Related to Security - Soft Costs 24 Amount of line 20 Related to Security - Hard Costs 25 Amount of line 20 Related to Energy Conservation Measures Signature of Executive Director Date Signature of Public Housing Director Date 1 To be completed for the Performance and Evaluation Report. 2 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 3 PHAs with under 250 units in management may use 100% of CFP Grants for operations. 4 RHF funds shall be included here. 56 form HUD (4/2008)

59 Annual Statement/Performance and Evaluation Report U.S. Department of Housing and Urban Development Capital Fund Program, Capital Fund Program Replacement Housing Factor and Office of Public and Indian Housing Capital Fund Financing Program OMB No Expires 4/30/2011 Part II: Supporting Pages PHA Name: Boulder Housing Partners Grant Type and Number Capital Fund Program Grant No: CO06P CFFP (Yes/ No): No Replacement Housing Factor Grant No: CO06R Federal FFY of Grant: 2012 Development Number Name/PHA-Wide Activities All public housing properties--kalmia, Manhattan, Madison, Diagonal Court, Iris Hawthorn, Arapahoe Court, Walnut Place, Northport General Description of Major Work Categories Move to Work Demonstration--to support pre-development and renovation costs for disposed of public housing assets Development Account No. Quantity Total Estimated Cost Total Actual Cost Status of Work Original Revised 1 Funds Obligated 2 Funds Expended $319, To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 2 To be completed for the Performance and Evaluation Report. 57 form HUD (4/2008)

60 Annual Statement/Performance and Evaluation Report U.S. Department of Housing and Urban Development Capital Fund Program, Capital Fund Program Replacement Housing Factor and Office of Public and Indian Housing Capital Fund Financing Program OMB No Expires 4/30/2011 Part I: Summary PHA Name: Boulder Housing Partners $355,006 Grant Type and Number Capital Fund Program Grant No: CO06P Replacement Housing Factor Grant No: CO06R Date of CFFP: FFY of Grant: 2013 FFY of Grant Approval: 2013 Type of Grant Original Annual Statement Reserve for Disasters/Emergencies Revised Annual Statement (revision no: ) Performance and Evaluation Report for Period Ending: Final Performance and Evaluation Report Line Summary by Development Account Total Estimated Cost Total Actual Cost 1 1 Total non-cfp Funds Original Revised 2 Obligated Expended Operations (may not exceed 20% of line 21) Management Improvements Administration (may not exceed 10% of line 21) $35, Audit Liquidated Damages Fees and Costs Site Acquisition Site Improvement Dwelling Structures Dwelling Equipment Nonexpendable Non-dwelling Structures Non-dwelling Equipment Demolition Moving to Work Demonstration $319, Relocation Costs Development Activities 4 1 To be completed for the Performance and Evaluation Report. 2 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 3 PHAs with under 250 units in management may use 100% of CFP Grants for operations. 4 RHF funds shall be included here. 58 form HUD (4/2008)

61 Annual Statement/Performance and Evaluation Report U.S. Department of Housing and Urban Development Capital Fund Program, Capital Fund Program Replacement Housing Factor and Office of Public and Indian Housing Capital Fund Financing Program OMB No Expires 4/30/2011 Part I: Summary PHA Name: Boulder Housing Partners Type of Grant Grant Type and Number Capital Fund Program Grant No: CO06P Replacement Housing Factor Grant No: CO06R Date of CFFP: No FFY of Grant:2013 FFY of Grant Approval: 2013 Original Annual Statement Reserve for Disasters/Emergencies Revised Annual Statement (revision no: ) Performance and Evaluation Report for Period Ending: Final Performance and Evaluation Report Line Summary by Development Account Total Estimated Cost Total Actual Cost 1 Original Revised 2 Obligated Expended 18a 18ba 1501 Collateralization or Debt Service paid by the PHA 9000 Collateralization or Debt Service paid Via System of Direct Payment Contingency (may not exceed 8% of line 20) 20 Amount of Annual Grant:: (sum of lines 2-19) 21 Amount of line 20 Related to LBP Activities 22 Amount of line 20 Related to Section 504 Activities 23 Amount of line 20 Related to Security - Soft Costs 24 Amount of line 20 Related to Security - Hard Costs 25 Amount of line 20 Related to Energy Conservation Measures Signature of Executive Director Date Signature of Public Housing Director Date 1 To be completed for the Performance and Evaluation Report. 2 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 3 PHAs with under 250 units in management may use 100% of CFP Grants for operations. 4 RHF funds shall be included here. 59 form HUD (4/2008)

62 Annual Statement/Performance and Evaluation Report U.S. Department of Housing and Urban Development Capital Fund Program, Capital Fund Program Replacement Housing Factor and Office of Public and Indian Housing Capital Fund Financing Program OMB No Expires 4/30/2011 Part II: Supporting Pages PHA Name: Boulder Housing Partners Grant Type and Number Capital Fund Program Grant No: CO06P CFFP (Yes/ No): No Replacement Housing Factor Grant No: CO06R Federal FFY of Grant: 2013 Development Number Name/PHA-Wide Activities All public housing properties--kalmia, Manhattan, Madison, Diagonal Court, Iris Hawthorn, Arapahoe Court, Walnut Place, Northport General Description of Major Work Categories Move to Work Demonstration--to support pre-development and renovation costs for disposed of public housing assets Development Account No. Quantity Total Estimated Cost Total Actual Cost Status of Work Original Revised 1 Funds Obligated 2 Funds Expended $319, To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 2 To be completed for the Performance and Evaluation Report. 60 form HUD (4/2008)

63 APPENDIX A: Ten Year Plan for RHF Funds Replacement Housing Factor (RHF) Plan: 1175 Lee Hill Boulder Housing Partners (BHP) intends to use both the First and Second Increment Replacement Housing Factor (RHF) funds to develop a 31-unit permanent supportive housing community for the chronically homeless in partnership with the Boulder Homeless Shelter (Shelter). BHP will continue to accumulate both the First and Second Increment RHF funds associated with the removal of the Broadway East public housing units from inventory in Our intention is to accumulate these RHF funds for five consecutive years as is allowed by 24 CFR (i)(7). Moreover, as a Moving to Work (MtW) Agency, BHP is requesting HUD approval under Option 3 of the Broader Uses of Funds Amendment to the Standard MTW Agreement which states RHF Funds Included in the MTW Block Grant and Used for Development Purposes with Obligation and Expenditure Deadlines Met. This option provides BHP with additional flexibility while still ensuring adherence to the appropriations law. Project History BHP, in partnership with the Shelter, has long sought the opportunity to expand the number of permanent supportive housing units in the city of Boulder. BHP began its permanent supportive housing program in 2000 with an enormously successful partnership with the Mental Health Center providing ten homes for chronically homeless individuals at the Holiday Neighborhood in north Boulder. In 2006, BHP partnered with the Shelter to create the Boulder County Housing First program. It, too, has produced noteworthy results. We now have a compelling opportunity to greatly increase the number of individuals served in the program and we would like to bring RHF funds to the project as an integral piece of the development puzzle. Project Description Each of the 31 units would be available to households who meet the definition of chronically homeless. All of the units would be developed as permanently affordable rental housing pursuant to the deed restrictions and covenants that the City of Boulder will record against the property. This project will serve households most in need of affordable housing and will be a project-based extension of the Housing First program already in place. The Shelter will take referrals for leasing these units from a number of sister agencies in Boulder County. The Shelter will then provide case management for these clients (with several bi-lingual case managers) as long as they stay in housing. BHP will act as landlord and property manager. Development Method The project is pursuing the mixed finance method described by HUD and is relying on a creative and powerful combination of funding sources. BHP has been awarded over $7.5 million in construction financing and has secured 31 project based vouchers to support operations. As of January 2014, the project s construction is 10 percent complete. We anticipate the building will be ready for occupancy by September Lee Hill, LLC, a wholly controlled subsidiary of BHP, will serve as Developer and in that role be responsible for managing the pre-development activities, securing capital and entitlements, and arranging for construction. BHP will be the property manager upon completion and be responsible for facility operations. The Shelter will assist with securing capital (primarily charitable and governmental Boulder Housing Partners 61

64 contributions), providing programming and design assistance, and coordinating the ongoing case management. Site Information The site is located at 1175 lee Hill Drive Boulder, CO The legal description is as follows: Lot 1, Front Range Business Zone, except that portion conveyed to the City of Boulder in Quit Claim Deed recorded February 19, 1991 on Film 1662 as Reception No ; and also excepting that portion conveyed to the City of Boulder by Warranty Deed recorded March 7, 1995 on Film 2039 as Reception No , County of Boulder, State of Colorado. The site is approximately one acre in size and is vacant and naturally vegetated with weeds and grasses. It is located in a developed mixed use are in north Boulder. The adjacent properties generally consist of commercial and residential properties. Directly to the north is the Shelter and across North Broadway to the east is the BHP office building. To the south is Lee Hill Drive, across which is a Holiday Inn Express hotel. To the west is Frontage Road Drive, across which are vacant land and a commercial building consisting of automotive repair facilities. A local bus stop is located on the south property line with service to medical, educational, and other supportive facilities. Aerial Photo of the Site Project Costs and Budget Total anticipated costs for the project are $7.5 million. All of the costs detailed in the attached Project Budget table are related to land acquisition, predevelopment and construction of the facility. Appraisal As of April 14, 2009, the appraised market value for the property was $805,000, or $18/sf. See the attached appraisal for additional information. Financial Feasibility The project is financially viable and is fully funded. Any surplus generated from development would be used to fund long-term reserves and no public housing dollars would be included in the reserves. This estimate includes a 7% owner contingency. See the attached Sources and Uses table for details. Boulder Housing Partners 62

65 Zoning The project is fully entitled and is properly zoned. Facilities See the Project Description above for a description of the facilities and the services to be provided to the prospective occupants. Relocation Not Applicable Life Cycle Analysis BHP will conduct a life-cycle cost analysis of the installation, maintenance, and operating costs of the heating and cooling systems prior to installation pursuant to section 13 of the Act (42 U.S.C. 1437k). Project Development Schedule 2009 Summer: Negotiations to acquire property 2010 May: BCATH Worthy Cause Tax Funds awarded ($832,150) June: Property acquisition finalized July: City of Boulder 2010 grant awarded ($121,000) August: Initiate predevelopment activities and community outreach process October: Begin zoning approval process 2011 Predevelopment, planning and community outreach 2012 July: Low Income Housing Tax Credit (LIHTC) application due City of Boulder 2011 grant awarded September: Begin LIHTC partnership due diligence and GC procurement December: Zoning approval awarded 2013 September: Begin construction 2014 September: Complete construction, begin lease up Environmental Assessment BHP and the Shelter conducted a Phase 1 Environmental Survey Assessment (ESA) in April The assessment has revealed no evidence of recognized environmental conditions in connection with the property. See the attached Phase 1 ESA report for additional information. As stated earlier, if required by HUD, the property could undergo a Part 50 or Part 58 Environmental Review to gain a ( FONSI ) or finding of no significant impact if HUD wishes that that be done. Occupancy and Operation Policies BHP completed a revised Admissions and Continued Occupancy Policy (ACOP) in June A copy can be provided to HUD upon request. Boulder Housing Partners 63

66 New Construction Certification Residential real estate in the north Boulder market is comprised predominantly of single family detached and attached (duplexes, triplexes) homes. According to Zillow (see below), the average home price in this market is $534,000. Acquiring an existing property in this neighborhood to develop public housing would be cost prohibitive and would not result in 31 units of housing, as compared to new construction. Attachments Project Budget table Appraisal for 4851 N. Broadway Boulder, CO Sources and Uses table Phase 1 ESA Boulder Housing Partners 64

67 24 CFR (d) Project Costs & Budget Project Costs Table DESCRIPTION OF WORK Budget Site Investigation ALTA Survey $ 3,000 Title Work 20,000 Phase I Environmental 2,000 Soils Report 3,000 Technical Consultant 10,000 Neighborhood Meetings 2,500 Appraisal 10,000 Independent Liaison 2,000 Traffic Study 2,500 Totals $ 55,000 Design & Entitlement City Processing Fees 45,000 Sustainability/Energy Consultant 10,000 Cost Estimation 5,000 Landscape Architect 10,000 Civil Engineer 15,000 M/P Engineer 8,000 Electrical Engineer 8,000 Structural Engineer 15,000 Acoustical Engineer 2,500 Waterproofing Consultant 2,500 Architect 100,000 Misc. Other 20,000 Totals $ 241,000 Other Soft Costs Project Administration 250,000 Developer Counsel 30,000 Lender Counsel 15,000 General Liability Insurance 50,000 Builder's Risk 20,000 Performance Bond 150,000 Owner's Rep 25,000 Tax Credit Consultant 30,000 Totals $ 570,000 Financing Costs Construction Interest 28,155 Construction Loan Origination Fee 18,700 Permanent Loan Origination Fee - Bank Inspection 8,000 Performance Bond 33,333 LIHTC Fees 110,000 Syndication Costs 45,000 Totals $ 243,189 Site Work/Construction Interim Costs Fencing and Security 2,000 Environmental Mitigation 10,000 Deconstruction - ROW Improvements 20,000 Site Clearing & Grub 5,000 Tree Work - Misc/Other 5,000 Totals $ 42,000 Horizontal Construction Basic Infrastructure 150,000 Basic Landscaping 50,000 Road Work 50,000 Totals $ 250,000 Land Transfer Purchase 848,000 AAM Risk Fee 25,350 Broker Fees 26,084 Closing Costs 620 Totals $ 900,054 Building Hard Costs Multifamily Construction 1,868,750 Community Area 373,750 FF&E 50,000 Solar Installation 0 Developer Fee 336,125 Totals $ 2,628,625 Contingencies and Reserves Owner's Construction Contingency 155,070 Operating Expenses Reserve 218,421 Debt Service Reserve - Totals $ 373,491 TOTAL DEVELOPMENT COSTS $ 5,303,358

68 24 CFR (f) Financial Feasibility Sources and Uses Table Program Unit Type # % of total PS&TH - Vouchers: 1 bedroom 1 bath 29 94% PS&TH - Public Housing ACC: 1 bedroom 1 bath 2 6% % Income Mix # 30% AMI 31 Statistics LIHTC pay in: cents on the dollar $ 0.73 $ $0.75 current mkt LIHTC Qualified Basis 100% Effective Income $ 374,862 Gross less vacancy loss Operating Expenses $ 262,105 Inlcudes reserves Net Operating Income $ 112,757 Annual Debt Service $ - Owner Contingency (% of Ttl Dev Budget) 7.00% % typical Developer Fee (% of Ttl Dev Budget) 6.00% 8-12 % typical Project Sources and Uses Sources Permanent Loan: $ - Tax Credits: $ 2,205,164 Per Unit $ 71,134 Grants: Replacement Housing Factor Funds (1st increment) $ 349,413 Replacement Housing Factor Funds (2nd increment) $ 300,000 BCATH Worthy Cause Tax Funds (land acquisition) $ 832,150 BCATH Worthy Cause Tax Funds (equity transfer) $ 500,000 CO Division of Housing (amt per unit ) $ 263,500 McKinney-Vento $ 400,000 City of Boulder 2010 $ 121,000 City of Boulder 2011 $ 200,000 Private grants $ 200,000 Total Sources $ 5,371,227 Uses Land Purchase $ 900,054 Soft Costs $ 1,109,189 Site Work & Horizontal Construction $ 292,000 Contingencies and Reserves $ 373,491 Construction $ 2,578,625 Total Uses $ 5,253,359 Per Unit $ 169,463 Sources less Uses (Gap) $ 117,868

69 A SUMMARY APPRAISAL OF VACANT COMMERCIAL LAND 4851 BROADWAY BOULDER, COLORADO For Boulder Community Hospital c/o Bill Munson, Administration P.O. Box 9019 Boulder, Colorado DATE OF VALUATION April 14, 2009 DATE OF REPORT April 28, 2009 BY WILLIAM GRAFF and COMPANY William C. Graff, MAI, President 7149 Cedarwood Circle Boulder, Colorado (303)

70 William Graff and Compapy!:~fiinillerciat~hriat'Estatit~mf!~aisals~ 7149 Cedarwood Circle Boulder CO 8030 I (303) graffco@gmail.com William C. Graft~ MAI --~~- -~~--~~~--~~--~~~- File 9018 April28, 2009 Boulder Community Hospital c/o Bill Munson, Administration P.O. Box 9019 Boulder, Colorado Re: Summary appraisal of vacant commercial land at 4851 Broadway in Boulder, Colorado Dear Mr. Munson: At your request, I have made a personal inspection of the referenced property and surrounding neighborhood for the purpose of estimating the market value of the subject property. The intended user ofthis report is Boulder Community Hospital. There are no other intended users and no one other than the intended user stated in this report may rely on this appraisal. The rights to be appraised are those of the fee simple estate. This Jetter of transmittal is attached to a report that has been prepared in conformity with the rules and regulations of the Appraisal Institute and in accordance with my understanding of the Uniform Standards of Professional Appraisal Practice (USP AP) and FIRREA minimum standards. This report is intended to be a summary appraisal report per USP AP standards. This report is prepared subject to the contingent and limiting conditions that are presented on following pages. Do not rely on this report unless you accept these contingent and limiting conditions. The subject property is vacant commercial land located on the northwest comer ofbroadway and Lee Hill Road in north Boulder, Colorado. The site totals approximately 44,822 square feet and it enjoys good comer visibility in a developing area. There are no known leases impacting the subject site, and thefee simple estate will be analyzed in this report. Credit Crisis Discussion With the recent difficulties on Wall Street and in the credit markets, an overview discussion of the Boulder real estate market relative to these issues is appropriate. The Boulder residential market price trend, both detached single-family and attached multi-family, was relatively flat to slightly down over the year ending February 28, 2009 and appears to be holding up relatively

71 well to date compared to the national data. The median selling price of a single-family detached house declined 7.1 percent over the year ending February 28, 2009, based on 703 sales. The average selling price was up 0.7 percent during that time frame. However, the number of detached sales was down about 25 percent over the prior 12 months. The median selling price of an attached residential unit rose 3. 7 percent while the average price rose 4.9 percent, based on 729 sales. The number of attached sales was down 6 percent over the prior 12 months. The attached unit prices were skewed to the upside by the sales of several expensive new condos in the downtown market. My discussion with brokers indicates thatthere is still demand for residential units in Boulder although the strength of the demand has softened over the past six months. The suburban residential condominium market is overbuilt. The downtown market is also overbuilt, particularly for units priced above $800,000. The Boulder commercial real estate market is also weakening at least somewhat, depending on the submarket. Office vacancy rates in the downtown area increased from the five to six percent range in the first quarter of2008 to 13.5 percent in the first quarter of2009. Office rental rates in the downtown area have declined slightly over the past six months or so. Overall Boulder office vacancy rates are 12.1 percent as of first quarter 2009, up from 10.2 percent as of fourth quarter Retail vacancy rates in the downtown market declined from 8.0 percent in the first quarter of2008 to 7.I percent in the first quarter of2009. Retail rental rates have been flat over the past few months. Overall Boulder industrial vacancy rates have been flat over the past few months and rental rates have been flat. The Boulder County unemployment rate is around 6.3 percent as of March 2009, well below the national rate but up from 4.8 percent in December The highest unemployment rate in Boulder County over the past I 0 years was 6.6 percent in The Boulder County unemployment rate is well below both the Colorado rate (7.5 percent) and the U.S. rate (8.5 percent). However, if the overall national economy goes into a prolonged significant recession it is likely that the Boulder market will be negatively impacted. The tightening of credit has resulted in difficulty in financing commercial real estate in Boulder but the best properties and the borrowers with the best credit are still able to obtain mortgage loans. Loan to value ratios have declined. Mortgage interest rates have increased somewhat over the past year or so, and capitalization rates have increased. There is no significant amount of new office or retail space under construction in Boulder. The market is nervous and if the credit markets continue to be restricted over the longer term it could have a more significant negative impact on the Boulder market. In general, the Boulder market is outperforming most other areas to date. Important Assumptions The value estimate presented in this report assumes market conditions as of April2009. Because of the credit crisis and related national issues, the local real estate market has become very defensive and the number of sale transactions has declined significantly over the past six months. We are in somewhat unprecedented times and market conditions could weaken further over the next few months or conditions could stabilize and then improve. Since the local market is in a state of flux, it is important to recognize that market conditions could change significantly over the next few months, either up or down. The appraiser has not been provided recent environmental reports or assessments for the subject property. The value estimate presented in this report expressly assumes that the subject property is not significantly adversely impacted by any environmental issues. If further study reveals thatthe subject property is significantly adversely impacted by environmental issues, the value estimate presented in this report may be invalid and a new valuation analysis may be necessary. 3

72 Final Market Value Conclusion Jn my opinion, the market value of the subject property, as is, as of April 14, 2009, was: $18.00 PER SQUARE FOOT OR EIGHT HUNDRED FIVE THOUSAND DOLLARS ($805,000) Marketing Period/Exposure Time The estimated reasonable marketing period and exposure time for the subject property, as is discussed and supported in this report, is approximately six to twelve months. It is noted that any estimate of exposure time is difficult under current strained market conditions. Respectfully submitted, WILLIAM GRAFF AND COMPANY LU~C. William C. Graff, President, Certified General Appraiser State of Colorado CGO I 4

73 TABLE OF CONTENTS INTRODUCTION AND GENERAL INFORMATION Page Summary of Salient Facts and Conclusions Contingent and Limiting Conditions... 7 Purpose and Intended Use of the Appraisal Date of Value Estimate... I 0 Scope of the Appraisal Definition of Market Value Property Rights Appraised DESCRIPTIONS, ANALYSES AND CONCLUSIONS City and Regional Data Neighborhood Description Subject Property Description Identification of the Property Legal Description History of Ownership Zoning Real Estate Taxes Site Description Improvements Description Personal Property and Fixtures Highest and Best Use Valuation Introduction Sales Comparison Approach Marketing Period Certification of the Appraiser Background and Qualifications of the Appraiser... 37

74 SUMMARY OF SALIENT FACTS AND CONCLUSIONS Location: Owner of Record: Legal Description: Property Rights Appraised: Date of Value: Zoning: Site Description: Flood Zone: Improvements Description: Special Improvement District: Highest and Best Use: The subject property is located at 4851 Broadway in north Boulder, Colorado. Conununity Hospital Association Included on page 19. Fee simple estate April 14, 2009 The subject is zoned BT-2 (Business Transitional- 2), City of Boulder. The site is an irregular shaped, but nearly rectangular, comer parcel containing approximately 44,822 square feet. The subject property is not located in an identified I 00 year flood hazard area. The site is unimproved vacant land. None Probably to warehouse the land over the near term until market conditions improve, then conunercial or mixed use development. Valuation Summary: Final Estimate of Market Value, As Is, As of Aprill4, 2009: $805,000 6

75 CONTINGENT AND LIMITING CONDITIONS This report is prepared subject to the following contingent and limiting conditions. Do not rely on this report unless you accept these contingent and limiting conditions. This is a sununary appraisal report which is intended to comply with the reporting requirements set forth under Standard Rule 2-2(b) of the Uniform Standards ofprofessional Appraisal Practice for a sununary appraisal report. As such, it might not include full discussions of the data, reasoning, and analyses that were used in the appraisal process to develop the appraiser's opinion of value. Supporting documentation concerning the data, reasoning, and analyses is retained in the appraiser's file. The information contained in this report is specific to the needs of the client and for the intended use stated in this report. The appraiser is not responsible for unauthorized use of this report. The value estimate presented in this report assumes market conditions as of April2009. Because of the credit crisis and related national issues, the local real estate market has become very defensive and the number of sale transactions has declined significantly over the past six months. We are in somewhat unprecedented times and market conditions could weaken further over the next few months or conditions could stabilize and then improve. Since the local market is in a state of flux, it is important to recognize that market conditions could change significantly over the next few months, either up or down. I assume no responsibility for matters legal in nature, nor do I render any opinion as to title, which is assumed to be marketable. All existing liens and encumbrances, if any, have been disregarded, and the property is appraised as though free and clear and held under responsible ownership and competent management. This appraisal report has been prepared for the sole and exclusive use of my client. It may not be used or relied upon by any other party. Any party who uses or relies upon any information in this report, withoutthe preparer's written consent, does so at their own risk. Any information in this report furnished by others is believed to be reliable; however, the appraiser assumes no responsibility for its accuracy. The appraisal report may contain estimates or opinions of future financial performance or prospective value based on reasonable expectations as of the date the report was prepared. It is understood that it is difficult to predict future market conditions and any such projection is based on the then current market conditions and the best available information regarding future trends. The appraiser is not responsible for unforeseeable events or trends that alter market conditions prior to the effective date of the prospective value or analysis. The value of real estate is subject to change over time, both up and down. If future market conditions differ significantly from the projected future market trends presented in this report, the value(s) presented in the report may be invalid, and an updated report may be necessary. Although parcel dimensions were taken from a source considered to be reliable, this should not be construed as a land survey. The exact land size and legal description should be verified by a licensed engineer or land surveyor. 7

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107 PHASE I ENVIRONMENTAL SITE ASSESSMENT 4851 NORTH BROADWAY BOULDER, COLORADO Prepared for: BOULDER HOUSING PARTNERS 4800 North Broadway Boulder, Colorado Attention: Ms. Shannon Cox Baker Project No. DN44, May 4, West 12th Avenue Denver, Colorado Phone: Fax:

108 TABLE OF CONTENTS EXECUTIVE SUMMARY... i 1.0 INTRODUCTION Purpose Scope of Services Limitations SITE DESCRIPTION AND LOCATION Location and Legal Description General Description of Site and Improvements General Uses of Adjoining Properties USER PROVIDED INFORMATION Title Records Environmental Liens Activity and Use Limitations Specialized Knowledge Valuation Reduction for Environmental Issues Commonly Known or Reasonably Ascertainable Information Owner, Site Manager, and Occupant Information Reason for Performing a Phase I ESA Previous Environmental Assessments Other Owner Provided Information RECORDS REVIEW Physiography Geology and Soils Ground Water Water Wells Oil/Gas Wells Physical Setting Analysis of Migration of Hazardous/Petroleum Substances HISTORICAL USE INFORMATION Historical Aerial Photographs and Topographic Maps Sanborn Fire Insurance Maps Cultural Features Map Historical City Directories Building Department Results Assessor Records REGULATORY AGENCY RECORDS Summary of Findings Detailed Discussion of Findings Leaking Underground Storage Tanks (LUST) Registered Tank (UST/AST) Facilities RCRA Generators Local Government Records...15 BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc

109 7.0 SITE RECONNAISSANCE Methodology and Limiting Conditions Description of Site Structures and Roads Site Observations Solid Waste or Disposal Areas Stockpiles of Soil and /or Debris Review of Adjacent Properties DEVIATIONS Exceptions and Deletions Data Gaps FINDINGS AND OPINION Summary of Site Historical Use Nearby Environmental Concerns Storm Water Discharges Associated with Construction Activity CONCLUSIONS AND RECOMMENDATIONS QUALIFICATIONS...21 REFERENCES FIGURE 1 TOPOGRAPHIC AREA MAP FIGURE 2 SITE PLAN APPENDIX A SITE PHOTOGRAPHS APPENDIX B AERIAL PHOTOGRAPH APPENDIX C ENVIRONMENTAL FIRSTSEARCH TM REPORT APPENDIX D INTERVIEW CORRESPONDENCE APPENDIX E RESUMES BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc

110 EXECUTIVE SUMMARY This report presents the results of the Phase I Environmental Site Assessment (ESA) that was performed by CTL Thompson, Inc. for Boulder Housing Partners. The vacant parcel of land (site) is located at 4851 Broadway in Boulder, Colorado. The Phase I ESA was conducted in general conformance with the methods and procedures described in the American Society for Testing and Materials (ASTM) E , Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process. The site is currently vacant land vegetated with native weeds and grasses. We did observe obvious evidence of materials that had been dumped on the site, which included historic farming equipment, piles of manure, and landscaping waste. We did not observe obvious evidence of staining or building materials associated with the piles. We also observed solid waste that appears to have blown onto the site from surrounding properties. The site is generally surrounded by commercial and residential properties. The surrounding properties were generally developed in the early 1950s. We did not find obvious evidence of a recognized environmental condition in connection with the site. This executive summary does not contain all the information that is found in the full report. The report should be read in its entirety to obtain a more complete understanding of the information provided and to aid in any decisions made or actions taken based on this information. BOULDER HOUSING PARTNERS VACANT PARCEL OF LAND 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc i

111 1.0 INTRODUCTION This report was prepared by CTL Thompson, Inc. (CTL) for Boulder Housing Partners and presents the results of the Phase I Environmental Site Assessment (ESA) for the vacant parcel of land located at 4851 North Broadway in Boulder, Colorado. The Phase I ESA was conducted in general accordance with the contract signed by Boulder Housing Partners and CTL, dated February 16, 2010 for the High Mar Property and subsequent authorization dated March 29, Purpose The purpose of the Phase I ESA was to identify Recognized Environmental Conditions (REC), to the extent feasible, pursuant to the methods and procedures described in the American Society for Testing and Materials (ASTM) Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessments, E A REC is defined as the presence or likely presence of hazardous substances or petroleum products on a site under conditions that indicate an existing release, a past release, or a material threat of a release of hazardous substances or petroleum products into structures on the site or into the ground, ground water, or surface water of the site. The term includes hazardous substances or petroleum products even under conditions in compliance with laws. The term is not intended to include de minimis conditions that generally do not present a material risk of harm to public health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies. 1.2 Scope of Services The scope of services for this assessment consisted of a records review, a site reconnaissance, historical research, interviews, and documentation of findings in a report. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 1

112 1.3 Limitations This Phase I ESA was prepared in general accordance with ASTM Standard E There may be additional environmental issues present at the site that are outside the scope of this practice that include, but are not limited to, the following: Asbestos-containing materials; Radon; Lead-based paint; Lead in drinking water; Cultural and historic resources; Mold and fungi; Industrial hygiene; Indoor air quality; Health & safety; Ecological resources; Endangered species; Biological or infectious agents and pathogens; Wetlands; Jurisdictional waters of the U.S; Regulatory compliance; High voltage power lines; and, Mine subsidence. CTL provided an opinion based upon the condition of the site on the day it was observed and a review of existing and reasonably ascertainable regulatory records and historical information. Our scope did not include chemical testing of soil, ground water, air, or building materials. The opinion, conclusions, and recommendations of this report are not intended to be used or relied upon by parties additional to Boulder Housing Partners. With the written consent of our client, CTL may be available to contract with other parties to provide an opinion or conduct additional environmental assessment services. Due to latent conditions and other contingencies which may become evident in the future, the current assessment does not result in any guarantee the subject site is free and clear of hazardous materials. Should additional surface, subsurface or chemical data become available, the conclusions and recommendations contained in this report shall not be considered valid unless the data is reviewed and the conclusions of this report are modified or approved in writing by our firm. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 2

113 We believe that this investigation was conducted in a manner consistent with that level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the locality of the project. No warranty, express or implied, is made. 2.0 SITE DESCRIPTION AND LOCATION 2.1 Location and Legal Description The Vacant Parcel of Land site is addressed as 4851 North Broadway in Boulder, Colorado. The site is approximately 1.0 acres in size. The site is legally described by the Boulder County Assessors office as: Lot 1, Front Range Business Zone, except portion conveyed to the City of Boulder in Quit Claim Deed recorded February 19, The site is located in Section 12, Township 1 North, Range 71 West of the 6th Principal Meridian, in Boulder County, Colorado. The site location and plan are shown on Figure 1 (Topographic Map) and Figure 2 (Site Plan). 2.2 General Description of Site and Improvements The site is generally vacant and naturally vegetated with weeds and grasses. We did observe various materials that have been placed on the site, which included historic faming equipment, pile of manure, and landscaping waste. 2.3 General Uses of Adjoining Properties The site is located in a developed mixed use area in north Boulder, Colorado. The adjoining properties generally consist of commercial and residential properties. Additional details regarding our observations of adjacent properties are presented in Section 7.4 of this report. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 3

114 3.0 USER PROVIDED INFORMATION Ms. Shannon Cox Baker of Boulder Housing Partners (Client) and Mr. William A Munson Jr., with Community Hospital Association (Owner) provided information which was used to complete Sections 3.1 thru 3.10 of this report. Copies of the returned questionnaires are presented in Appendix D. 3.1 Title Records Boulder Housing Partners provided Commitment of Title Documents for the site prepared by United Title Company. The legal description for the site included in the document was described as Lot 1, Frontage Road Business Zone, except that portion conveyed to the City of Boulder in Quit Claim Deed recorded February 19, 1991 on Film 1662 as Reception No ; and also excepting that portion conveyed to the City of Boulder by Warranty Deed recorded March 7, 1995 on Film 2039 as Reception No , County of Boulder, State of Colorado 3.2 Environmental Liens An environmental lien is a charge, security, or encumbrance upon title to a property to secure the payment of a cost, damage, debt, obligation, or duty arising out of response actions, cleanup, or other remediation of hazardous material or petroleum products upon a property. Boulder Housing Partners and Community Hospital Association were not aware of existing environmental liens on the site. 3.3 Activity and Use Limitations Environmental AULs are legal or physical restrictions or limitations on the use of, or access to, a site or facility to: 1) reduce or eliminate potential exposure to hazardous substances or petroleum products in the soil or ground water on the property, or 2) prevent activities that could interfere with the effectiveness of a response action, in order to ensure maintenance of a condition of no significant risk to public health or the environment. These legal or physical restrictions may include engineering controls, BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 4

115 institutional controls, or land use restrictions. Boulder Housing Partners and Community Hospital Association were not aware of existing environmental liens on the site. 3.4 Specialized Knowledge Boulder Housing Partners and Community Hospital Association were not aware of specialized knowledge or experience related to previous environmental activities on the site. 3.5 Valuation Reduction for Environmental Issues Boulder Housing Partners and Community Hospital Association were not aware of valuation reduction of the site because of environmental issues. 3.6 Commonly Known or Reasonably Ascertainable Information Boulder Housing Partners and Community Hospital Association were not aware of commonly known or reasonably ascertainable information regarding environmental issues related to the site. 3.7 Owner, Site Manager, and Occupant Information Mr. Munson Community Hospital Association has been associated with the site since October The site is vacant. 3.8 Reason for Performing a Phase I ESA site. Boulder Housing Partners requested a Phase I ESA prior to acquisition of the BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 5

116 3.9 Previous Environmental Assessments Boulder Housing Partners were not aware of previous environmental studies on the site Other Owner Provided Information Boulder Housing Partners and Community Hospital Association indicated that they were not aware of the storage of hazardous substances, or the presence of tanks, buried drums, imported soil, or solid waste at the site. 4.0 RECORDS REVIEW CTL reviewed existing sources listed in the REFERENCES section to assess the soils, geologic and hydrogeologic conditions of the general vicinity of the site. 4.1 Physiography The site is located on relatively flat terrain, as presented on the topographic map (Figure 1). The site slopes downward to the east-southeast. The elevation of the site is approximately 5588 feet above mean sea level. The predominant surface water feature in the vicinity of the site is Fourmile Canyon Creek. Fourmile Canyon Creek is located approximately 2,000 feet south of the site and generally flows from northwest to southeast. 4.2 Geology and Soils A review of geologic maps indicates that the site soil generally consists of bouldery cobble gravel, which decreases in grain size eastward from the mountains, underlain by claystone, sandstone and interbedded claystone/sandstone. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 6

117 4.3 Ground Water It is our experience that the flow direction of shallow, unconfined ground water is generally controlled by topography. Based on topography, we estimate the general direction of ground water flow below the site is to the east-southeast. Topographic data suggests areas up-gradient of the site are generally to the west-northwest. Based on our review of The Depth to Water Table, In The Boulder-Fort Collins-Greely Area, Front Range Urban Corridor, Colorado, the depth to ground water is believed to between 10 and 20 feet below ground surface. 4.4 Water Wells Water wells were identified through the Colorado Division of Water Resources online water well permit database. The database did not indicate the presence of water wells on the site. 4.5 Oil/Gas Wells Oil and gas wells were identified through the Colorado Oil and Gas Conservation Commission online database. The database did not indicate the presence of operating or abandoned oil/gas wells on the site. 4.6 Physical Setting Analysis of Migration of Hazardous/Petroleum Substances A hypothetic spill of a hazardous or petroleum substance on the site would be expected to migrate along the ground surface to the east-southeast toward Fourmile Canyon Creek. Off-site surface spills on the adjoining parcels to the west and northwest appear to have the highest potential to migrate on-site. Based on local topography, we estimate ground water generally flows to the southeast. Sources of contamination to ground water beneath the site, if present, would most likely be located to the westnorthwest. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 7

118 5.0 HISTORICAL USE INFORMATION 5.1 Historical Aerial Photographs and Topographic Maps Historical aerial photographs of the site and surrounding area were reviewed for 1937, 1955, 1964, 1972, 1984, 1995, 2005, and 2007; a copy of the 2007 photograph is presented in Appendix B. USGS topographic maps were reviewed for 1957, 1966, and 1966 revised An interpretation of the aerial photographs and maps is presented, as follows: 1937: The site is generally vacant land and appears to be in agricultural use, possibly wheat. Adjacent properties to the west and north appear to be associated with the same agricultural use. Lee Hill Drive and North Broadway bound the site to the south and east respectively, across which the land is vacant and naturally vegetated : In the 1955 photo the site and properties to the north and west generally remain vacant but are no longer being used for agriculture. The adjacent property south across Lee Hill Drive appears to now be developed by a hotel. To the southeast the National Guard Amory is present. A commercial building is present east of the site across North Broadway. Generally the site and surrounding properties is 1964 photo are the same, with the exception of the land to the west of the site, which consists of an unimproved road, two buildings and multiple cars : The site generally is unchanged. The surrounding properties appear to be generally the same with the exception of those to the north and west. In the 1972 photo the adjacent property to the north appears to be developed by a building and a dirt track. An additional area of the property to the west has been disturbed and additional cars are present compared to previous years : In the 1984 photo the site and adjacent properties to the south and east are generally unchanged. The property to the north appears to no longer be developed by what appeared to be a building; it appears that only a concrete pad is present and the remains of the dirt track. West of the site a longer building is now present. Again numerous cars are parked adjacent to the buildings on the property. Also present are commercial buildings to the northeast. In the 1999 photo cars or other equipment are present on the site. In the 1999 photo the property to the south has been redeveloped with its current improvement, and an additional building has been constructed on the property west of the site. The adjacent properties to the north and east are unchanged. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 8

119 : The site is generally vacant and the surrounding properties appear much as they do today. The adjacent property to the north is developed by newer commercial building. The land to the east across North Broadway is improved by a new commercial building as well. Again cars are parked adjacent to the west of the site. 5.2 Sanborn Fire Insurance Maps Sanborn fire insurance maps were a tool used by the fire insurance industry to evaluate property risk. The maps often show details of historic dwellings, commercial buildings, and factories, indicate property uses and addresses, and show locations of items such as wells, cisterns, and fuel storage tanks. Sanborn Fire Insurance Map coverage was not available for the site and surrounding area. 5.3 Cultural Features Map The 1937/41 cultural features map shows the site as vacant or agricultural land. Broadway is mapped adjacent to the east of the site. Generally the surrounding properties are vacant or agricultural land. The City Limits of Boulder are mapped south of the site. 5.4 Historical City Directories Historic city directories were reviewed for the site and listings adjacent the site from 1950 to We searched for the portions of Broadway from 4750 to 4891, and Lee Hill Drive from 1000 to Table I provides the directory listings for the time frame reviewed for those addresses adjacent or within close proximity of the site. The predominant use of the adjacent properties was commercial. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 9

120 Table I City Directory Listings Address Listing Date(s) 4750 N Broadway (7000 N. Broadway)* Boulder National Army Reserve N Broadway Holiday Inn N Broadway Boulder Housing Partners 2008 Foothills Community Apartments N. Broadway (6000 N. Broadway)* All Star Gas N Broadway (site) No Listings N Broadway Boulder Shelter for the Homeless N Broadway Bustop Bar N Broadway Elan Motorsports N Broadway Moores Automotive German Motors Boulder Yellow Cab N. Broadway (5901 N. Broadway)* 1001 Lee Hill Drive 1001 Lee Hill Drive 1001 Lee Hill Drive Four H Motel Centennial Arc Products, Sculder Welding, KMH Construction, Dillroods Auto, Boulder Excavating, Blasirs Auto James Luttes, Thomas Patchet, All is Numerology, Boulder Excavating, KMH Construction, Larson Engineering Affordable Motors, Carriage Shop, Spencer- Crowley, Wolfsburg Motors Lee Hill Drive CDOT Lee Hill Drive CDOT Note: * - Indicates addresses for listings on the 1960s City Directories. Generally use of the surrounding properties consisted of commercial use, which included automotive repair facilities located west and northwest of the site and topographically up-gradient. The automotive repair facilities currently and historically located up-gradient from the site are not listed on the Regulatory Database. It is likely that based on the operation that some of these facilities should have been listed on the Resource Conservation Recovery Act (RCRA) database as a Conditionally Exempt Small Quantity Generator (CESQG). This means the facilities listed produce less than 220 lbs (100 kg) of hazardous waste per calendar month. Since few of the nearby automotive repair facilities are listed, it suggests they are possibly not following RCRA regulations or they are not generating waste. However, based on the typical amounts of hazardous BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 10

121 waste being stored and used, it is unlikely the facilities present a REC for the site, but are considered a low environmental business risk. 5.5 Building Department Results The site is vacant and historically has been agricultural in use, as a result we did not review building department records for the site. 5.6 Assessor Records We reviewed Boulder County Assessor online files for the site. Assessor records indicate the site is vacant, but has been used temporarily as a fire cracker sales stand. 6.0 REGULATORY AGENCY RECORDS Regulatory agency records were provided by Environmental FirstSearch Report (FirstSearch). The report, dated March 29, 2010, is presented in Appendix C. The search radii were extended by 0.25 mile to account for the size of the site. 6.1 Summary of Findings Table II presents a summary of the regulatory agency records findings provided by FirstSearch. The findings presented in Table II are those that were determined to be topographically up-gradient and/or in near proximity to the site to warrant further discussion. All findings in the regulatory database are presented in the FirstSearch report in Appendix C. The findings and their locations are listed by address along with a description of their distance and topographic location in relation to the site. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 11

122 Table II Summary of Selected Nearby Regulatory Agency Findings Distance and Estimated Topographic Location Search Radius 1 Mile ½ Mile ¼ Mile Findings National Priority List (NPL) RCRA CORRACTS RCRA Treatment, Storage, Disposal (TSD) CERCLIS/NFRAP Colorado Voluntary Cleanup List (VCL) Solid Waste Leaking Underground Storage Tank (LUST) Registered Tanks (UST/AST) Institutional Controls/Engineering Controls (AUL) Spills (ERNS) RCRA Generator Other HW All Star 4810 N. Broadway Boulder Bins 4900 N. Broadway All Star Gas 4929 N. Broadway CDMA Boulder Armory OMS 4750 N. Broadway Boulder County Road Maintenance 820 Lee Hill Road ~300 feet east Down-gradient ~350 feet east Down-gradient ~475 feet northeast Cross-gradient ~500 feet southeast Down-gradient ~740 feet west Up-Gradient X X X X X X X X X It should be noted that in addition to the findings presented in Table II, the FirstSearch TM Report indicated four (4) unmapped findings that are unaddressed but potentially in the vicinity of the site, which are Anderson Rubble Dump, Scandinavian Auto Service, Boulder Canyons and S.LF and Lee Hill Road. These findings could not be assessed due to incomplete address information, with the exception of Scandinavian Auto Service, which according to a previous Phase I ESA prepared for the adjacent property north of the site was listed as being located at 4939 Broadway, putting the facility north and topographically cross-gradient of the site. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 12

123 6.2 Detailed Discussion of Findings This section discusses those findings listed in Table II which are located topographically up-gradient of the site or which otherwise warrant further discussions Leaking Underground Storage Tanks (LUST) The Colorado Department of Labor and Employment (CDLE), Division of Oil and Public Safety (OPS) regulates active and inactive LUST findings which have been reported to the state. There were two (2) LUST finding listed within 1/2 mile of the site, which warranted further discussion. CDMA Boulder Armory OMS 1 (4750 North Broadway) is located southeast of the site and topographically down-gradient. OPS records for the facility indicate the site received a No Further Action closure letter for the tank leak event in September Based on location and regulatory records, we do not believe the facility presents a REC for the site. Boulder County Road Maintenance District 3 (820 Lee Hill Drive) is located west of the site and potentially up-gradient. OPS records for the facility indicated the site received two No Further Action closure letters for the tank leak events in September 1996 and June OPS records indicate that there were as many as four USTs on site, which have reportedly all been closed. Based on the regulatory records, we do not believe the facility presents a REC for the site Registered Tank (UST/AST) Facilities This is a list of USTs and ASTs registered with CDLE, Division of OPS. There were four (4) UST/AST facilities listed within ¼ mile of the site, which warranted further discussion. All Star (4810 North Broadway) is located adjacent to the east of the site and topographically down-gradient. All Star Gas (4929 North Broadway) is located north of the site and topographically cross-gradient. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 13

124 Regulatory records for these facilities do not indicate a recorded release. Based on location and regulatory records we do not believe these two facilities present a REC for the site. CDMA Boulder Amory OMS 1 (4750 North Broadway) is located southeast of the site and topographically down-gradient. This facility was previously discussed in Section and based on location and regulatory records does not present a REC for the site. Boulder County Road Maintenance District 3 (820 Lee Hill Drive) is located west of the site and potentially up-gradient. The facility was previously discussed in Section Again the facility reportedly had as many as four USTs in operation, which have all been closed (removed). As many as three ASTs were located on the site. OPS records that only two are currently in use. Besides the two previously documented leak events, which received closure there have been no other documented releases as a result we do not believe the facility presents a REC for the site RCRA Generators RCRA generators are facilities which generate regulated hazardous wastes under the Resource Conservation and Recovery Act (RCRA). RCRA generator facilities are classified as Large Quantity, Small Quantity, or Conditionally Exempt Small Quantity Generators. There were three (3) RCRA Generators listed within 1/4 mile of the site, which warranted further discussion. Boulder Bins (4900 North Broadway) is located northeast of the site and topographically cross-gradient. Based on location, we do not believe the facility presents a REC for the site. CDMA Boulder Armory OMS 1 (4750 North Broadway) is located southeast of the site and topographically down-gradient. The facility has previously been discussed, and based on location is does not present a REC for the site. Boulder County Road Maintenance District 3 (820 Lee Hill Drive) is located west of the site and potentially up-gradient. The facility is listed as a RCRA NLR. The facility has not been subject to corrective action and no violations are reported with the property. Based on the regulatory records for the facility, we do not believe it presents a REC for the site. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 14

125 6.3 Local Government Records We sent a request to Boulder County Health Department for spills and incident reports in the vicinity of the site. Ms. Wendy Blanchard indicated the presence of seven (7) HazMat sites, and four (4) dumps site listed within one (1) mile of the site. The HazMat listings are located as follows: 1133 Quince located south of the site and topographically cross-gradient. The release included approximately 0.5 gallons of an unknown liquid North Broadway located south of the site and topographically crossgradient. The release included an unknown amount of sewage Lee Hill located approximately one mile west and topographically up-gradient. The release included approximately 100 gallons of an unknown wet solid North Broadway located north and topographically cross-gradient. The facility is reported as having two releases a release of an unknown quantity of sewage and approximately 50 gallons of diesel fuel North Broadway located south and topographically cross-gradient. The release included the approximately 50 gallons of diesel fuel th located southeast and topographically down-gradient. The release included approximately 100 grams of radioactive uranyl nitrate, which was reportedly contained and taken to CU-Boulder. Based on distance and location and do to the likelihood the ground water was not impacted, we do not believe the listings present a REC for the site. The four dump sites, described as Evergreen Tree (Broadway and Fourmile Creek), Everitt Clark (2130 Tamarack), Degge Site (1500 Violet), and Boulder City Dump (N 26 th Street), are not located on or adjacent to the site. Based on locations provided we do not believe the listed dumps present a REC for the site. We contacted the Boulder Fire Department by mail requesting information pertaining to spills and releases of hazardous materials. We received a response from BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 15

126 the Boulder Fire Department in writing, which indicated they had no records for 4851 N. Broadway dating back to Boulder Fire Department records predating 2000 are contained on microfilm and are accessible by incident report number only. As a result it is the opinion of CTL that obtaining earlier incident information would not be sufficiently useful, or change the likelihood for the presence of a REC on the site. 7.0 SITE RECONNAISSANCE The following section discusses observations made during our site reconnaissance. 7.1 Methodology and Limiting Conditions Mr. Nick Talocco conducted a site visit on April 1, The site has open access from Lee Hill Drive. The majority of the site was accessed by walking. A photographic record of the site reconnaissance is presented in Appendix A. 7.2 Description of Site Structures and Roads The site is predominately vacant and with the exception of landscape waste and manure piles, and historical farming equipment that has been placed at the site. Lee Hill Drive, North Broadway and Frontage Road Drive bound the site to the south, east and west respectively. 7.3 Site Observations During our reconnaissance, we specifically looked for obvious evidence of the site features listed in Tables III. Table III lists features typically observed outside of site structures. An X located within each table indicates that the feature was readily observable. Those features which were observed on the site are discussed in further detail within the following subsection(s). BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 16

127 Aboveground Storage Tanks Table III Exterior Site Features Stained Soil and/or Pavement Air Emissions Sources X Stockpiles of Soil or Debris Cultivated Land/Crops Sumps and Pits Hazardous Material Storage High Power Transmission Lines Natural Gas Pipelines Odors Petroleum Pipelines Physical Irregularities Placed Fill or Imported Soils Railroad Lines Septic Systems or Leach Fields Stressed Vegetation Surface Water, Streams, Ponds, Lagoons Transformers (Potential PCB) Underground Storage Tanks Unidentified Piping Below Grade Unidentified Substance Containers Vehicle Maintenance Areas Waste Water Discharge Waste Treatment Processes Wells (Agricultural, Water Supply) Wells (Monitoring) X Solid Waste or Disposal Areas Wells (Oil or Natural Gas) Solid Waste or Disposal Areas We observed evidence of solid waste that appeared to have blown onto the site from surrounding developed properties. Generally we observed old newspaper, paper cups and plastic bags. These items do not present a REC for the site but should be removed from the site and disposed of properly Stockpiles of Soil and/or Debris We observed a pile of landscape waste and piles of manure. The pile of landscape waste primarily consisted of plant waste, and plastic containers in which the plants are sold. Additionally the piles contained some soil. We did not observe obvious evidence of staining or building materials associated with these piles. Debris piles on site also consisted of dirt and manure (animal droppings). No significant staining was observed associated with these piles. Based on our observations we do not believe the piles observed present a REC for the site. We do however recommend these piles be removed from the site and properly disposed of. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 17

128 It should be noted that we also observed evidence of historical farming equipment present on the site. Again this does not present a REC, but we do recommend they be removed from the site. 7.4 Review of Adjacent Properties General observations of properties adjacent to the site were performed in conjunction with on-site observations made on April 1, Developed property in the vicinity of the site consists of transportation corridors, single-family residences, and commercial use. Properties immediately adjacent to the site are described below, based on outdoor observations from the site or nearby public streets. North: The site is bounded by Boulder Shelter for the Homeless. East: The site is bounded by North Broadway across which is the Boulder Housing Partners office building. South: The site is bounded by Lee Hill Drive, across which is a Holiday Inn Express. West: The site is bounded by Frontage Road Drive, across which is vacant land and then a commercial building consisting of automotive repair facilities. Observation of adjacent properties did not reveal obvious visual indications of environmental concern. We did not observe obvious evidence of landfills, lagoons, pits, or other waste treatment or disposal operations; underground storage tanks, spills, releases, or discharge of hazardous material; or air emissions which could negatively impact the site. 8.0 DEVIATIONS 8.1 Exceptions and Deletions ASTM Standard E for Phase I Environmental Site Assessments, Section 8.3.2, states that all obvious uses of the site shall be identified from the present, back BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 18

129 to the site s obvious first developed use, or back to 1940, whichever is earlier. The term developed use includes agricultural uses (i.e., cultivated land/agricultural crops) and placement of fill. In our opinion, livestock rangeland is not a developed use. The historical documentation for this assessment went back to 1937 on the basis of historical aerial photographs, which showed the property as predominantly vacant land being used agriculturally. We were not able to ascertain the date of first agricultural use, thus the historical documentation was not fully satisfied for the ASTM standard. It is the opinion of CTL that obtaining earlier historical information would not be sufficiently useful, reasonably ascertainable, or change the likelihood for the presence of a REC on the site. 8.2 Data Gaps Based on the information presented in this report, we do not believe that there are significant data gaps which would affect our ability to identify recognized environmental conditions associated with the site. 9.0 FINDINGS AND OPINION 9.1 Summary of Site Historical Use The site is currently vacant land vegetated with native weeds and grasses. We did observe obvious evidence of materials that had been dumped on the site, which included historic farming equipment, piles of manure, and landscaping waste. We did not observe obvious evidence of staining or building materials associated with the piles. We also observed solid waste that appears to have blown onto the site from nearby properties. The site is generally surrounded by commercial and residential properties. The surrounding properties were generally developed in the early 1950s. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 19

130 9.2 Nearby Environmental Concerns There were several facilities listed on the regulatory database. These facilities do not present an environmental concern on the basis of regulatory status, ground water not impacted, distance, and/or topographic gradient. We did not find evidence of a REC associated with the site due to adjacent property use. 9.3 Storm Water Discharges Associated With Construction Activity Under current Federal/state regulations, construction sites that disturb one acre, or are part of a larger development in which total disturbed area is equal to or greater than one acre, are required to apply for a General Permit for Storm Water Discharges Associated With Construction Activity (General Permit) from the Colorado Department of Public Health and Environment (CDPHE). Some Municipal Separate Storm Sewer Systems (MS4s) also require additional permitting for construction sites within their jurisdiction. The General Permit application must be submitted to the CDPHE at least 10 days prior to the start of construction activities. The General Permit requires a Storm Water Management Plan (SWMP) to be developed, implemented, and modified as needed from before commencement of construction activities until final stabilization is complete and a Notice of Termination has been submitted to the CDPHE. Furthermore, the General Permit requires that site inspections be performed at least every 14 calendar days and within 24 hours following a storm event that causes significant movement of sediment on-site. The local MS4 may require more frequent inspections. Complete and current storm water management plans should be kept on-site. CTL can assist with your storm water management and compliance needs, if desired CONCLUSIONS AND RECOMMENDATIONS We have performed a Phase I Environmental Site Assessment (ESA) in general conformance with the scope and limitations of ASTM Practice E of 4851 North Broadway, the site. Any exceptions to, or deletions from, this practice are described in BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 20

131 Section 8.1 of this report. This assessment has revealed no evidence of recognized environmental conditions in connection with the property QUALIFICATIONS This Phase I ESA was supervised by, and the report reviewed by, Mr. Matthew Wardlow, a licensed Professional Engineer (P.E.) registered in the State of Colorado. Mr. Wardlow has performed or reviewed over 1,000 Phase I ESAs in the State of Colorado, and has been practicing within the local environmental consulting profession for at least eleven (11) years. The resumes of the individuals conducting this Phase I ESA are included in Appendix E. Mr. Wardlow and Mr. Talocco declare that, to the best of their professional knowledge and belief, they meet the definition of Environmental Professionals as defined in of 40 CFR 312. We have the specific qualifications based on education, training and experience to assess a property of the nature, history and setting of the subject site. We have developed and performed all appropriate inquiries in general conformance with the standards and practices set forth in 40 CFR Part 312. We believe that this ESA was conducted in a manner consistent with that level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the locality of the project. No warranty, express or implied, is made. BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc 21

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133 REFERENCES Colorado Aerial Photo Service, Aerial Photographs, Stereo Pairs, from 1937, 1955, 1964, 1972, 1984, 1995 and Colorado Division of Water Resources, online Water Well Permit Database, Colorado Oil and Gas Conservation Commission, online Oil/Gas Well Permit Database, CTL Thompson, Inc., Environmental Owner Questionnaire, completed and returned April 14, 2010 by Community Hospital Association. CTL Thompson, Inc., Environmental Client Questionnaire, completed and returned March 29, 2010 by Boulder Housing Partners. Cultural Feature Map, 1938/41, Environmental FirstSearch, Inc. Environmental Database Search, Environmental FirstSearch, Inc. (dated March 29, 2010). Google Earth Courtesy of the USGS, Aerial Photograph, 1999, U.S. Geological Survey, Geologic Map of the Greater Denver Area, Front Range Urban Corridor, Colorado (USGS Map No. I-856-H, Donald E. Trimble and Michael N. Machette, 1979). U.S. Geological Survey Topographic Map, Boulder Quadrangle, Colorado (1957, 1966, and 1966 revised 1979). BOULDER HOUSING PARTNERS VACANT PARCEL OF LAND 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc

134 N T 1 N R 71 W Scale: 1 ~ 2200 Approximate Site Boundary Source: U.S.G.S. Topographic Map Boulder Quadrangle, Colorado 1984 BOULDER HOUSING PARTNERS 4851 NORTH BRAODWAY CTL PROJECT NO. DN Topographic Area Map Fig. No. 1

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136 APPENDIX A SITE PHOTOGRAPHS BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc

137 Description: View Direction: View of site West Description: View Direction: Landscape debris N/A Description: View Direction: Manure pile N/A Description: View Direction: Landscape and manure debris piles N/A SITE PHOTOGRAPHS 4851 N. BROADWAY Site Reconnaissance APRIL 2010 CTL T Project No. DN44, Page 1 of 2

138 Description: View Direction: Commercial property and vacant land West Description: View Direction: Boulder Housing Partners and Broadway East Description: Holiday Inn Express View Direction: South Description: Boulder Shelter for the Homeless View Direction: North SITE PHOTOGRAPHS 4851 N. BROADWAY Site Reconnaissance APRIL 2010 CTL T Project No. DN44, Page 2 of 2

139 APPENDIX B AERIAL PHOTOGRAPH BOULDER HOUSING PARTNERS 4851 NORTH BROADWAY CTL І T PROJECT NO. DN44, S:\PROJECTS\44800\DN \200\2. Reports\R1\DN R1.doc

140 CTL T PROJECT NO. DN-44, AERIAL PHOTOGRAPH Approximate Site Location N