April 12, Michael Hiler, Office Chief State of Ohio Office of Housing and Community Partnerships POB 1001 Columbus, OH

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April 12, 2010 Michael Hiler, Office Chief State of Ohio Office of Housing and Community Partnerships POB 1001 Columbus, OH 43216-1001 Dear Mr. Hiler: Re: Amendment of NSP Target Areas Attached is the City of Lima s request to amend its NSP target areas. This request is based on your memorandum (of Feb 26/10) allowing target area amendment. In essence, of the original eight target areas, by retaining two without changes in geography (City-wide Demo and West End) and proposing to expand the North End target area to fully encompass seven census block groups. We also propose combining the five other target areas into one area but with an expanded geography covering 11 census block groups to be the South End target area. As a result, we shall have four target areas in our NSP Action Plan, as amended, namely: City-wide Demolition North End West End South End We hope that you find the attached documentation sufficent. Thank you for your consideration of this request, and we look forward to notification of amendment approval. /Signed/ David. J. Berger Mayor cc: CPD, HUD-ColumbusOH

Amendment of Target Areas City of Lima NSP Action Plan A. SUMMARY OF REQUEST The City of Lima is requesting permission to amend its target areas, through consolidation and expansion. Figure 1 summarizes our proposed actions and results thereof. Of the original eight target areas, we propose retaining two without changes in geography (City-wide Demo and West End). However, we are proposing Fig. 1 Proposed actions on current target areas. to expand the North End area to fully encompass the seven census block groups only partially included in the original plan ; and would like to consolidate the five other target areas into one area with an expanded geography that fully covers 11 census block groups. Item E below provides the justifications for these actions. B. CONTEXT The City of Lima NSP Action Plan has 8 identified Target Areas or TAs (Fig. 2): 1. City-wide demolition 2. Pine Street Area 3. North End 4. Southwest 5. South End 6. Southeast 7. West End 8. East End For TA-1, while covering the whole city, demolition activities are being carried out in phases according to the numerical order of the target areas. Additional Fig. 2 Boundaries of current target areas. Amendment of Target Areas City of Lima NSP Action Plan Page 1 / 5

citywide demolition outside target areas will be carried out after target areas are complete. TA-2 to TA-8 are areas where other NSP projects will be carried out: Homeownership Downpayment (w/ Rehab) Assistance, Housing Development, and Land Banking. B. STATUS OF IMPLEMENTATION Except for Demolition, which had gone through 18 structures as of Mar31/10, none of the other projects had advanced since the program started in Sept/09 (Fig. 3). However, the administrative systems for these projects are in place. Fig. 3 Status of Implementation. C. IMPLEMENTATION ISSUES 1. Homeownership Downpayment (with Rehab) Assistance NSP Regulations require that housing units must be bank-foreclosed, real estate-owned (REO) properties located within identified target areas. There are a number of issues to these limitations. a. Target Areas By NSP Regulations, the selection of target areas was based on an array of data sets that when overlaid on top of each other directed grant recipients to areas of greatest need. One of the data set deemed crucial was the Projected Foreclosures in the Next 18 Months (supplied by HUD). Crucial because it points to census tracts where future foreclosures would have occurred and such foreclosed units are those that are eligible for purchasing through the Downpayment Assistance Program. With this, and in combination with the map showing current foreclosures, we delineated our target areas focusing on those with the highest concentration of current foreclosures over projected foreclosures. Unfortunately, the projected foreclosures did not occur in those areas and our mistake was being very conservative in delineating boundaries of the target areas. b. Availability and Status of Repair of REOs Since the projected foreclosures mostly did not occur in the target areas we have selected, those REOs that come about in the target areas range in presence from very few to none at all. This is evident in the weekly MLS (multiple listing service) listings we obtain from both local real estate Amendment of Target Areas City of Lima NSP Action Plan Page 2 / 5

brokers and REO Clearing House data. Regardless of whether they occur in target areas or not, most REO units that come available are being rapidly acquired by investors who rehab the units for rental purposes. Those left in the market are in really bad state-of-repair making rehab costs quite prohibitive or even uneconomic as average housing cost in Lima is low while rehab costs remain market driven (high). c. Buyer Expectations Most of our identified target areas are in highly-impacted residential neighborhoods. Even with the $10,000 NSP downpayment assistance and $15,000 in rehabilitation assistance coupled with up to another $10,000 in HOME funded downpayment grants, a prospective first-time homebuyer would forego this bonus incentive in favor of available housing outside the target areas, which meet their expectations (high move-in quality, number of rooms, availability of enclosed garage, or more yard space). D. EFFORTS ON MARKETING, PROMOTIONS, OUTREACH Integral to the Lima NSP Action Plan is making its components publicly known. Special efforts are given to high-impact project components such as Housing and Demolition. A subcomponent of Housing is the Homeownership Downpayment (with Rehab) Assistance. 1. Public Presentations Since the Lima NSP Action Plan was approved by Ohio-DOD, a total of 12 public presentations have been rendered (for elected officials, for local area banks, real estate agents/brokers, housing providers, fair housing and credit counseling services providers and housing developers; and for neighborhood associations). In these gatherings, flyers on the downpayment assistance project were disseminated. 2. Flyers Specifically for this NSP Housing sub-component, we developed and disseminated a flyer that highlights the eligible household incomes, target areas, possible rehab assistance, and potential additional downpayment incentives from other non-nsp programs (like the city s traditional First Home Lima Program). 3. Housing Counseling Another sub-component of Housing is homeownership training. Through LACCA (Lima Allen County Council on Community Affairs) the City of Lima will provide 14 hours of training to each participant. LACCA will provide a 12 hour in class program focusing on financial literacy, home ownership preparation, foreclosure prevention. An additional 2 hours of property maintenance training is provided by New Lima Housing for the Future to provide training in basic home repair and maintenance. 4. Tie-Ins The city s Housing Staff has fostered a regular, though informal functional linkage with local lenders and real estate agents. This provides the city with a weekly update of MLS listings of REOs that come into the market. Moreover, the city has Amendment of Target Areas City of Lima NSP Action Plan Page 3 / 5

retained the services of REO Clearinghouse, which supplies us with a complementary listing of foreclosed residential properties owned by banks and mortgage companies. These lists, in turn, are processed into maps by the city to show the locations of the available REOs relative to identified target areas. (See related discussion on issues regarding availability of REOs in Item C.1.b above.) 5. Public Information Additionally, information on NSP housing programs is available on the City of Lima Website and the City of Lima public access cable television station. Articles in the Lima News and City monthly and quarterly neighborhood information publications have highlighted the NSP home buyer opportunities, unfortunately without success in attracting home buyers due to the limited number of eligible units identified in target areas. E. RATIONALE FOR AMENDING TARGET AREAS Using the same HUD-supplied data sets on USPS Vacancy Status (by Census Tract) and Foreclosures (by Census Tract), and overlain with our own data sets on 2-year Tax Delinquent Parcels, Vacant Parcels, and Demolition List, the areas of greatest need as defined by NSP did not change from the ones we have identified in our original Action Plan (see attached excerpt of section on Areas With Greatest Need, Lima NSP Action Plan). We wish to consolidate/expand existing target areas within already qualified as greatest need areas. However, in order to capture more bank-foreclosed REOs that are relatively in good or better state-of-repair, we must: 1. Expand the North End (Target Area #3) in all directions to fully cover 7 census block groups, namely: CT-123.1, CT-123.2, CT-123.3, CT-124.2, CT-129.2, CT-130.2, and CT- 131.3 (Fig. 5). 2. Combine and expand Target Areas 2, 4, 5, 6 and 8 (Pine, Southwest, South End, Southeast, and East End, respectively) from the Ottawa River southward to fully cover 11 census block groups, namely: CT-126.1, CT-126.2, CT-127.1, CT-127.2, CT-134.1, CT-134.2, CT-134.3, CT-134.4, CT-136, CT-137, and CT-138.1 (Fig. 5). The bases for these changes are: 3. Most of the REOs that came into the market in the last 18 months are located in these areas (see Fig. 4; Orange dots; page 5). 4. Most of the purchases through the city s traditional first-time homebuyer program occurred in these areas; suggesting that most of the housing choices of potential NSPeligible homebuyers would be located in these areas (see Fig. 4; Green dots; page 5). 5. The expanded target areas provide more choices of available housing-types and neighborhoods to locate into, where such neighborhoods are deemed within areas in need of stabilization (see Fig. 5 New Target Areas; page 5). Amendment of Target Areas City of Lima NSP Action Plan Page 4 / 5

Fig-4. Location of REOs and downpayment-assisted housing purchases. Fig-5. New target areas (overlain with original target areas). Amendment of Target Areas City of Lima NSP Action Plan Page 5 / 5

Excerpt from Lima NSP Action Plan F. AREAS WITH GREATEST NEED T he fo r e g o i n g s e c t i on presented data and analysis of current local conditions that are recognized to bring about blight, neighborhood disinvestment and abandonment. This section introduces and describes the target areas for the NSP endeavor that were selected based on all information presented above and complemented by additional local data described here. The proceeding discussions follow the order of prioritization of the areas, which prioritization was based on need and feasibility of implementing the activities identified for each target area. the Lima community has selected a number of areas deemed to have the greatest need for targeted neighborhood stabilization efforts (see Figure 7). 1. Figure 7. Selected Areas With Greatest Need Additional Local Data To make stabilization efforts in the selected areas more significant and meaningful, city staff reviewed complementary local data on the following and overlaid these on the foregoing maps: Two-year tax delinquent parcels Within city-limits alone, there are about 1,426 certified 2-year tax delinquent parcels with foregone property tax revenues amounting to $3.8 million in 2008. Together these parcels occupy at least 96 acres City-maintained abandoned parcels As of January 2009, there are 376 parcels abandoned by their owners all over Lima that are being maintained by the city. Together these parcels occupy at least 15 acres that will require at least $166,000 to maintain (grass-cutting, 4x a year) annually. Of the 376 abandoned parcels, 330 of them are certified 2-year tax delinquents, as well. Vacant lots As of December 2008, there were more than 1,800 vacant parcels within city-limits. Together these parcels occupy at least 150 acres, most of it zoned for residential use. Figure 7 is the composite of all these data mapped out by overlay. The maps used in-aid of area selection are found in Appendix 2. The ODOD-required table on Final Recommendations follows on (on pages 25 and 26), which details the Housing Needs and Recommended NSP Activities per Target Area. City of Lima NSP Action Plan Page 24