DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver...

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DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME PROGRAMS

Transcript of DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver...

Page 1: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

DRAFT

2013 CITY OF VANCOUVER

ACTION PLAN

CDBG / HOME

PROGRAMS

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ACKNOWLEDGEMENTS

City of Vancouver

Timothy D. Leavitt, Mayor

Eric Holmes, City Manager

City Council

Jeanne Harris, Council Member

Jeanne E. Stewart, Council Member

Larry J. Smith, Council Member

Jack Burkman, Council Member

Bart Hansen, Council Member

Bill Turlay, Council Member

Community Development

Chad Eiken, Director

Community Development Block Grant (CDBG) & HOME Program

Peggy Sheehan, Program Manager

Martin Greenlee, Program Coordinator

Craig Frantz, Housing Rehab Specialist

Bryan Monroe, Associate Planner

Jonna Papajohn, Program Support

City of Vancouver CDBG and HOME Programs

415 W 6th Street (98660)● P.O. Box 1995

Vancouver, WA ● 98668-1995

Tel 360.487.7952 ● Fax 360.487.7965

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Vancouver’s 2013 Action Plan is the fifth year of the 2009-2013 Housing and Community

Development (H&CD) Consolidated Plan and marks the eleventh year as a CDBG

entitlement city. July 1, 2013 will also be the start of fifth year that Vancouver will receive

HOME entitlement funds. The Consolidated Plan coordinates public funding housing,

neighborhood development, economic development, and public services into a unified

approach. It establishes needs, resources, priorities, and proposed activities to be

undertaken with respect to the Community Development Block Grant (CDBG) and the

HOME Investment Partnerships (HOME) Programs, along with other Department of

Housing and Urban Development (HUD) programs. It is updated annually through the

“Action Plan”, which provides information regarding the projects and funding for the

upcoming year. The 2009-2013 Consolidated Plan can be found at Vancouver’s website at

www.cityofvancouver.us/cdbg and includes the following objectives:

Establish and Maintain a Suitable Living Environment and Economic

Opportunities

Ensure Decent Affordable Housing

Provide Services to End Homelessness

The City of Vancouver (Vancouver) is the fourth largest city in the state of Washington with

a population of 161,791 (2010 Census) and an approximate area of 48.5 square miles.

Additional census information and maps are available in Attachment C.

For narrative discussion, the document will refer to the all of the incomes on the chart as

“low-income”. The federal government publishes the median family income annually for

each area of the country. The Chart below indicates the income for a family of four living in

Vancouver. The complete chart is contained in Attachment B.

Median Family

Income FY 2013 Income Limit Category

Income Limit

for a 4 Person

Household

$68,300

Extremely Low (30% Area Median Income) $20,800

Very Low (50% Area Median Income) $34,700

60% Area Median Income $41,640

Low (80%) Income Limits $55,500

Source: U.S. Department of Housing and Urban Development, effective

December 11, 2012 for CDBG funds and March 15, 2013 for HOME funds.

Note: Vancouver is part of the Portland-Vancouver-Beaverton, OR-WA MSA

The 2013 Action Plan projects are funded with Vancouver’s CDBG and HOME entitlement

funds. Other funds that are available for Vancouver and Clark County providers include

Section 8, McKinney-Vento Homeless Assistance Act funds, Community Services Block

Executive Summary

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Grant (CSBG), Emergency Shelter and Homeless Prevention (ESHP), and the Fannie Mae

area grants; local funds include deed recording fees (HB2160, HB 2163, etc) that are

managed by the Clark County Department of Community Services. A comprehensive list

of other resources expected to be available is provided in Appendix D.

City of Vancouver CDBG Funds

Entitlement (estimated April 2013) $1,014,826

Carry-Forward $148,500

Anticipated Program Income $50,000

Total Funds $1,213,326

City of Vancouver HOME Funds

Entitlement (estimated April 2013) $532,732

Carry-Forward $0

Total Funds $691,924

The Department of Housing and Urban Development (HUD) has developed the following

outcome performance measures in the Federal Register Notice Dated March 7, 2006:

Availability/Accessibility - Applies to activities that make services infrastructure,

public services, public facilities, housing, or shelter available or accessible to low

and moderate-income people, including people with disabilities.

Affordability - Applies to activities that provide affordability in a variety of ways

in the lives of low- and moderate-income people, such as affordable housing,

basic infrastructure hook-ups, etc

Sustainability: Promoting Livable or Viable Communities - Applies to activities

aimed at improving communities or neighborhoods, helping to make them more

livable or viable by providing benefit to persons of low- and moderate-income.

The anticipated outcomes of program year 2013 projects are identified in each project

description and a summary is listed in the Outcome Measures section of the Action Plan.

Vancouver provides a detailed evaluation of its past performance each year in the

Consolidated Annual Performance Evaluation Report (CAPER). The 2011 CAPER (July 1

2011 – June 30 2012, marking the fourth year of the 2009-2013 Consolidated Plan, is

available for review at: http://www.cityofvancouver.us/ced/page/cdbg-plans-and-reports

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Vancouver City Council held a first reading on April 22, 2013 and a public hearing on May

6, 2013, for the 2013 Action Plan. The public hearing notice and list of projects were

published in The Columbian newspaper and distributed to the Vancouver Community

Library. The general public, representatives of City and County agencies, and

representatives of non-profit organizations were included in the process. The public

hearing was accessible to persons with physical disabilities and special needs

accommodations were available upon request. Citizen comments on the Action Plan are

provided in Appendix E.

Transcripts of the public hearing comments as well as a CVTV digital broadcast of the

public hearing are available by following links on Vancouver’s website at http://www.cityofvancouver.us/citycouncil/page/watch-council-meetings-and-workshops-cvtv.

Vancouver follows a detailed citizen participation plan. All citizens are encouraged to

participate in the Action Plan development and review process; including low- and

moderate-income people, minority and non-English-speaking persons, people with

disabilities or HIV/AIDS, homeless persons/agencies, and residents of public and assisted

housing developments.

Vancouver has taken action to assist other agencies and organizations in applying for

available funds and leveraging other resources to implement the housing strategies and

programs. Vancouver works with representatives from the private lending community,

financial experts, and private and non-profit housing developers and consultants who can

provide technical expertise in packaging development proposals. Vancouver has submitted

letters of support and verification of consistency for project applications, which support the

goals and objectives that are found in the H&CD Plan.

The CDBG and HOME applications strongly encourage leveraging funds by awarding

additional rating points based on the amount of committed matching funds. Projects

funded with program year 2013 CDBG and HOME funds had a total of $3,041817

committed matching funds. The amount of leveraged funds is expected to go up as projects

move forward, especially for housing construction projects, such as the Affordable

Community Environments Van Mall Senior Housing project. Attachment D lists the

resources expected to be available throughout Clark County and Vancouver to address the

priority needs and specific objectives identified in the Action Plan.

Citizen Participation

Resources / Leveraging Other Funds

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The City of Vancouver received a Section 108 loan that is used in conjunction with one-

million dollars received through Brownfields Economic Development initiative (BEDI).

This funding is being used for the Waterfront Access Project, for further detail regarding

this project see the Vancouver website http://www.cityofvancouver.us/cdbg. Vancouver

anticipates this project being completed in the fall of 2013.

Since 2003, Vancouver has been receiving a direct allocation of Community Development

Block Grant funds from the U. S Department of Housing & Urban Development. In 2009,

Vancouver began receiving an annual allocation of HOME Investment Partnership funding

directly from HUD. The Vancouver City Council is legally responsible for administration

of these programs in compliance with the HUD regulations and requirements and has

responsibility for the final allocation of funds for program activities. The Council has

designated responsibility for management of the programs to the Community Development

Block Grant (CDBG) staff of Vancouver’s Community Planning Department. The CDBG

staff is responsible for policy analysis, conducting the annual planning process, assisting

community partners to develop project activities and for managing and implementing

approved program activities throughout the year.

Vancouver is currently updating the Consolidated Plan and is improving the linkages with

the City Comprehensive Plan and other documents. Key partners in the planning and

implementation of activities include private non-profit organizations, city departments,

housing developers and the Vancouver Housing Authority. The Vancouver Housing

Authority manages public housing and Section 8 housing throughout Clark County and

owns three shelters within the Vancouver. The VHA Board of Commissioners is appointed

by the Mayor of Vancouver. Vancouver also coordinates with local and regional and

transportation agencies, such as the Southwest Washington Regional Transportation

Council and C-Tran, to provide residents of affordable housing access to public

transportation.

The strengths of the institutional system for delivering Action Plan programs are the

cohesiveness of Vancouver’s Departments as well as the collaboration of the community

partners. The primary weakness of the delivery system is a lack of financial resources to

meet needs.

Managing the Process

Institutional Structure and Coordination

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City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded

projects. Vancouver uses several monitoring tools to ensure compliance requirements of all

projects, including policies, contract requirements, results from monitoring or auditor

reports from other agencies, and on-site monitoring. All projects requesting CDBG and

HOME funds are evaluated to determine program eligibility and priority based on program

policies, local, state and federal regulations, and Consolidated Plans. City staff visits new

agencies in the first year of contracting. Ongoing agencies will have an onsite monitoring

visit every two years. Timelines may be adjusted based on staffing and agency

performance.

The Vancouver CDBG program ensures that, to the best of their ability, all records are

complete and agencies comply with the following applicable rules and regulations:

Political Activity; Davis-Bacon and Related Acts; Civil Rights; Cash Management; Federal

Financial Reports; Allowable Costs and Cost Principles; Drug Free Workplace Act; and

other administrative requirements.

The housing and community development needs of Vancouver are spread throughout the

community. Many of the projects listed within this document are not geographic-specific,

but are intended to benefit citizens city-wide. Other projects may be site-specific. When

available, this information is included with the project description.

Vancouver has defined an area considered to have a minority concentration as “an area

where the total percentage of minority persons is at least 20 points higher than the total

percentage of minorities for the City as a whole”. This is based on the HUD definition of a

minority neighborhood1. Attachment C shows areas of race and minority concentration and

low and moderate-income concentration and includes a map showing census tracts and

block groups.

Vancouver has two Neighborhood Revitalization Strategy Areas (NRSAs). The Esther Short

NRSA was approved by HUD in 2006 and the Central Vancouver NRSA was approved in

2007. These NRSA areas were approved by HUD again as part of the 2009-2013

Consolidated Plan. The Esther Short NRSA includes the Esther Short and Hough

neighborhoods in the downtown area. Projects funded with program year 2013 funds

located in this area include the Public Infrastructure Accessibility Improvements;

1 http://www.huduser.org/portal/glossary/glossary.html

Monitoring

Geographic Distribution

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The Central Vancouver NRSA includes the Rose Village, Central Park, Fourth Plain Village,

Bagley Downs, and Meadow Homes neighborhoods. Projects funded with program year

2013 funds located in this area include the Columbia River Mental Health Roof

Repair/Retrofit, Public Infrastructure Accessibility Improvements; and the Affordable

Community Environments – Van Mall Senior Housing project. In addition, Vancouver will

use funds for the Housing Rehabilitation program towards site specific projects located in

this area. For additional information on the NRSA areas, see the Neighborhood

Revitalization Strategy Plans on the city website at http://www.cityofvancouver.us/cdbg.

Vancouver goals and objectives under the Consolidated Plan are outlined below. Projects

funded with program year 2013 CDBG and HOME funds are listed within these goals and

objectives. Ongoing projects are reported annually in the CAPER. The Consolidated Plan

and the outlined projects are identified through the three program criteria of Community

Development, Affordable Housing, and Homelessness.

Vancouver organizes a volunteer committee comprised of City staff and community

members to prioritize all applications. This was the third year Vancouver utilized the

ZoomGrants™ online grant management system; which was more efficient, user-friendly,

and cost effective. Priorities are recommended to Vancouver Council based on a maximum

dollar amount. Staff negotiates contracts based on agency budget needs and available

funding. The following pages describe proposed programs, projects, and activities that will

be undertaken, given the resources available in the proposed budget. This Action Plan is

consistent with the statutory goals outlined in the strategies and the priority needs listed in

the 2009-2013 Consolidated Plan.

Annual Objectives and Description of Activities

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Objective One: Establish and Maintain a Suitable Living Environment

and Economic Opportunities

Strategy 1: Support acquisition of, and improvements to, facilities that provide services

to low-income families, elderly, or people with special needs.

CD-1.1: Support acquisition of, and improvements to, community facilities to enhance

service delivery to low-income persons. Facilities should consider

sustainability goals and be consistent with neighborhood and/or community

plans.

Columbia River Mental Health – Phase II Roof Repair/Retro Fit

PY 2013 CDBG Funding: $31,000

Description: Repair/ Retro fit of remaining 11,700 square feet of roof area

for mental health service facility. Repair will create a more energy efficient,

20 year roof that will reduce maintenance and utility costs.

Projected Beneficiaries: 7000 people

Project Location: 6926 NE Fourth Plain Blvd, Vancouver

Outcome: Sustainability

Strategy 2: Create and maintain revitalization efforts in neighborhoods by improving

their physical and social character.

CD-2.1: Improve publicly owned facilities (streets, sidewalks, storm drainage, water,

parks, and sewer) in eligible neighborhoods. Facilities should consider

sustainability goals and be consistent with neighborhood and/or community

plans.

City of Vancouver: Public Infrastructure and Accessibility

Improvements

PY 2013 CDBG Funding: $376,719

Description:

Projected Beneficiaries: To be determined

Projected Location:

Outcome:

CD-2.2: Acquire new properties for public use or facilities. Improve parks and

recreation facilities to enhance the livability of low- and moderate-income

neighborhoods. Facilities should consider sustainability goals consistent with

neighborhood and/or community plans.

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CD-2.3: Support activities improving Neighborhood Revitalization Strategy Areas and

establish new areas where appropriate.

Ongoing – reported annually in CAPERS

Strategy 3: Support community vitality through activities that promote a diverse

economic base and family wage jobs while providing opportunities for low-income

people to become financially independent.

CD-3.1: Support activities that retain or create jobs for low/moderate-income persons.

CD-3.2: Support business and community development through various loans and

grants including the Section 108 Loan Fund.

Strategy 4: Enhance quality of life for families and individuals by supporting public

services which predominantly serve people who are low/moderate-income.

CD-4.1: Maintain and support the capacity of local non-profit agencies that provide

community services.

Share - Hunger Response

PY 2013 CDBG Funding: $40,000

Description: Supports program costs of a community meal programs

serving over 90,000 meals annually.

Projected Beneficiaries: 4,500 low-income people

Project Location: Citywide

Outcome: Availability/Accessibility

CD-4.2: Collaborate with the Clark County staff and local service providers to assess

the community needs, develop plans for service design and funding

allocations.

Ongoing – reported annually in CAPERS

Objective Two: Ensure Decent Affordable Housing

Strategy 1: Increase the supply of housing that is affordable to renter households,

earning 60 percent or less of AMI. Projects should serve households within a range of

incomes, provide a range of unit sizes and meet recognized sustainability standards.

AH-1.1: Support the construction of, or conversion to, new and affordable rental

housing projects.

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AH-1.2: Support acquisition and/or rehabilitation of rental housing to increase

affordable housing stock.

AH1.3: Support creation or retention of housing for low-income elderly and special

needs populations.

Affordable Community Environments – Van Mall Senior Housing

PY 2013 HOME Funding: $122,000

PY 2013 CDBG Funding: $0

Description: Funding for direct construction costs and some soft cost

allocations to construct 45-unit senior living apartment complex.

Projected Beneficiaries: 45 households

Project Location: 3112 NE 62nd Avenue, Vancouver

Outcome: Affordability

Strategy 2: Preserve existing affordable housing threatened with loss due to condition,

location, expiring federal contracts, redevelopment efforts, lead-based paint, or other

situations.

AH-2.1: Support preservation/rehabilitation of existing low-income single-family

housing.

City of Vancouver - Housing Rehabilitation Program

PY 2013 CDBG Funding: $99,000

PY 2013 HOME Funding: $0

Description: Provides limited rehabilitation loans from $5,000 to $25,000

for homeowner-occupied housing throughout Vancouver.

Projected Beneficiaries: 4-20 low/moderate-income households

Project Location: City-wide (specific sites to be determined)

Outcome: Sustainability

AH-2.2: Support preservation/rehabilitation of existing low-income rental housing.

Vancouver National Historic Reserve – Infantry Barracks Rehabilitation

PY 2013 CDBG Funding: $100,000

PY 2013 HOME Funding: $0

Description: Rehabilitate a 12 -unit housing National Historic Register

building built in 1887. CDBG funds will be used for direct construction,

costs.

Projected Beneficiaries: 12households

Project Location:

Outcome: Sustainability

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Strategy 3: Promote homeownership opportunities for low- and moderate-income

households, including persons with disabilities and first-time homebuyers.

AH-3.1: Support homeowner assistance for first-time or low-income homebuyers and

encourage participation in pre- and post-purchase housing education.

Strategy 4: Plan for and support strategies and initiatives to promote fair housing and

increase access to housing and housing programs.

AH-4.1: Disseminate fair housing information to the public through support for

regional housing search services, through community agencies, and support of

fair housing conferences.

Ongoing – reported annually in CAPERS

AH-4.2: Provide fair housing technical assistance to housing providers and community.

Ongoing – City organizes fair housing trainings reported annually in CAPERS

Strategy 5: Maintain and support the capacity of local non-profit housing

organizations.

AH-5.1: Support continued operation of local non-profit agencies that develop and

provide low-income housing.

Affordable Community Environments – CHDO Operating Expenses

PY 2013 HOME Funding: $8,879

PY 2013 CDBG Funding: $0

Outcome: Sustainability

Columbia Non-Profit Housing – CHDO Operating Expenses

PY 2013 HOME Funding: $8,879

PY 2013 CDBG Funding: $0

Outcome: Sustainability

Second Step Housing – CHDO Operating Expenses

PY 2013 HOME Funding: $8,879

PY 2013 CDBG Funding: $0

Outcome: Sustainability

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AH-5.2: Coordinate with housing funders and advocacy organizations to streamline

funding applications, contracting and monitoring.

Ongoing

ZoomGrants™ Online Grant Management System

Vancouver will continue to utilize the online grant management system,

which is a more efficient, user-friendly, and cost-effective method of

funding applications.

Outcome: Sustainability

Objective Three: Provide Services to End Homelessness

Strategy 1: Prevention/diversion/discharge planning: Support programs aimed at

keeping at-risk people in housing and approaches to divert people from jail into

housing and treatment services.

HS-1.1: Increase housing stability for those at risk of homelessness by supporting and

expanding programs that help households maintain housing.

Salvation Army- Moving Forward Together

PY 2013 HOME Funding: $80,000

PY 2013 CDBG Funding: $70,000

Description: Provides one-on-one case management, life skills training,

housing services, and rental subsidies. CDBG Funding will be used for

staffing that provides housing services; HOME funding will be used for

rental subsidies.

Projected Beneficiaries: 48 households

Project Location: Citywide

Outcome: Affordability/Accessibility

HS-1.2: Increase coordination among programs that provide services to low-income

people in order to assess and respond to housing needs to prevent

homelessness. Work to ensure that public institutions discharge people into

housing.

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Strategy 2: Housing plus supportive services: Support services designed to expand the

affordable housing available and services to assist homeless people to reach self-

sufficiency.

HS-2.1: Preserve and expand the supply of permanent housing and permanent

supportive housing affordable to households with very low incomes.

Second Step Housing - Housing Services

PY 2013 HOME Funding: $0

PY 2013 CDBG Funding: $40,000

Description: Provide individualized case management housing services

for very low-income individuals and their families in transitional and

permanent housing units. CDBG funds will be used for personnel costs.

Projected Beneficiaries: 175 low and very low-income households

Project location: City-wide

Outcome: Affordability

HS-2.2: Preserve and expand the supply of transitional supportive housing for

individuals and families.

Share - ASPIRE

PY 2013 CDBG Funding: $50,000

PY 2013 HOME Funding: $250,000

Description: Provide transitional housing with rental subsidies and

services so that households pay no more than 30% of their income for

housing. CDBG Funding will be used for staffing that provides housing

services; HOME funding will be used for rental subsidies.

Projected Beneficiaries: 100 individuals

Project location: City-wide

Outcome: Affordability

HS-2.3: Increase access to educational and employment programs to increase earning

potential for individuals who are homeless, or at risk of homelessness.

Ongoing – reported annually in CAPERS

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Strategy 3: Short-term emergency response: Support programs that identify people

who are homeless, assess their needs, and move them into appropriate housing and

supporting services.

HS-3.1: Maintain an effective outreach program that links homeless people to

mainstream resources.

Share - Outreach

PY 2013 HOME Funding: $0

PY 2013 CDBG Funding: $40,000

Description: Support staff costs of outreach program that connects

homeless and low-income people with services.

Projected Beneficiaries: 500 very low-income people served

Project Location: City-wide

Outcome: Availability/Accessibility

HS-3.2: Ensure availability and access to clearinghouse, emergency shelter and services

in the existing shelter system.

Janus Youth –Staffing The Oaks

PY 2013 HOME Funding: $0

PY 2013 CDBG Funding: $40,000

Description: Provide shelter, case management, and social skills training

for youth who are deemed runaways or at-risk of harm at two homeless

shelters. CDBG funds will be used for personnel costs.

Projected Beneficiaries: 400 youth

Project Location: City-wide

Outcome: Availability/Accessibility

Council for the Homeless – Emergency Shelter Clearinghouse

PY 2013 HOME Funding: $0

PY 2013 CDBG Funding: $40,000

Description: Support staff costs of a call center that conducts screening

and referral to area shelters and resources.

Projected Beneficiaries: 2,000 very low-income people

Project Location: City-wide

Outcome: Availability/Accessibility

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Strategy 4: System-wide improvement: Support and improve the overall performance,

efficiency, and accountability of the homeless system.

HS-4.1: Plan and coordinate system-wide to efficiently manage limited resources for

ending homelessness.

Ongoing – reported annually in CAPERS

HS-4.2: Build on successful implementation and expansion of HMIS System in Clark

County.

Ongoing – reported annually in CAPERS

The table below identifies outcome measures for the activities in accordance with Federal

Register Notice dated March 7, 2006.

Objective Agency Project Outcome

Sustainable

Living

Environment

City of Vancouver Public Infrastructure

Improvements Availability/ Accessibility

Columbia River Mental Health Phase II Roof Repair/Retro Fit Sustainability

Council for the Homeless Housing Solutions Center Availability/ Accessibility

Janus Youth Programs The Oaks Staffing Availability/ Accessibility

Share Share Hunger Response/Outreach Availability/ Accessibility

Salvation Army Moving Forward Together Availability/ Accessibility

Decent

Housing

Affordable Community

Environments (ACE) CHDO Sustainability

Affordable Community

Environments (ACE) Van Mall Senior Housing Affordability

City of Vancouver Housing Rehabilitation Loan

Program Sustainability

Columbia Non-Profit Housing CHDO Sustainability

Second-Step Housing CHDO Sustainability

Second-Step Housing Housing Services Affordability

Share ASPIRE Rental Subsidies/

Housing Services Affordability

Vancouver National Historic

Reserve Infantry Barracks Sustainability

Economic

Opportunity

Outcome Measures

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Housing

Annual Affordable Housing Goals Vancouver partners with the Vancouver Housing Authority (VHA) and several non-profit

agencies to assist in projects designed to provide affordable rental and homeowner

housing, including assistance to people with disabilities and homeless individuals and

families.

The program year 2013 funding includes providing tenant-based rental assistance to

approximately 148 households, housing services for over 255 households, development of

rental housing, homeownership assistance, and reservation/rehab of existing low-income

single-family housing (4-20 households). See annual objectives and description of activities

section for specific projects and anticipated beneficiaries/outcomes.

Subsidized Housing (Administered by the Vancouver Housing Authority)

Vancouver partners with the Vancouver Housing Authority, the public housing authority

in the community, to meet the housing needs of low- to moderate-income individuals. The

Vancouver Housing Authority provides subsidized housing for over 7,500 Clark County

residents and over 60% of these residents are elderly or people with disabilities. There are

over 3,000 households currently on the waiting list for subsidized housing and the average

wait is 3-5 years. The VHA Moving to Work 2013 Annual Plan identifies public housing

needs and specific actions to be taken during the upcoming year. In addition, a list of on-

going public housing improvements is provided through the Five Year Capital Plan. These

documents are available at the Vancouver Housing Authority website at www.vhausa.com.

The VHA Resident Advisory Board is a voice for VHA residents, assisting with the

development of the VHA’s annual plan each year. In addition, several communities have

Resident Councils, a Resident Commissioner serves on the VHA Board, and two resident

service coordinators support resident initiatives and link residents with supportive services.

Vancouver has committed program year 2013 CDBG and HOME funds for the

rehabilitation of Barracks to become low-income housing. We have also committed funding

for the Van Mall Senior Housing project so that Affordable Community Environments

(ACE) for the construction costs - see annual objectives and description of activities section.

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Housing Rehabilitation Program Vancouver operates a housing rehabilitation program within the city limits of Vancouver.

Projects will be limited to a maximum amount of $25,000 to complete basic home repairs

that will bring the home up to Vancouver’s rehabilitation standards. Repairs will be made

for homeowners who are 80% or less of the area median income (AMI).

Income eligible homeowners will receive bids from pre-qualified contractors. The

homeowner will select a contractor and Vancouver will oversee the project. The contract

will be between the homeowner and the contractor with payment made to the contractor by

Vancouver. The goal of the housing rehabilitation program is to preserve the housing

supply of Vancouver; this is achieved by bringing the home up to our minimum standards

and local code.

Vancouver participates with the Council for the Homeless and area service providers to

enhance the community’s comprehensive Continuum of Care system to end homelessness.

This dynamic partnership includes collaborative efforts of a variety of community groups,

government agencies and a coalition of more than 48 homeless service providers.

Vancouver enhances coordination of public, private, and non-profit housing providers,

human service agencies, and social service providers through the following actions:

Works with other jurisdictions, including Clark County and the Vancouver Housing

Authority, to prioritize housing needs, provide services, and maximize the use of

federal, state, and local funds for affordable housing, community development, and

related services.

Participates in coordinated efforts for shelter and services assisting homeless

individuals and families.

In 2005, Washington State passed the Homelessness Housing and Assistance Act (ESSHB

2163) directing local governments to develop ten-year homeless plans “which shall be

aimed at eliminating homelessness, with a minimum goal of fifty percent by July 1, 2015.”

This act also requires a community wide plan to assist in accomplishing this task.

Vancouver along with Clark County and the area non-profit organizations was one of the

first jurisdictions to develop a Plan to End Homelessness. The plan includes a requirement

that the community completes a one-day count of people who are homeless. On January

31, 2013, a total of xxxx homeless people were counted (xxx sheltered, xxx unsheltered, and

xxx temporarily living with a friend.

Homeless and Special Needs

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The goals and objectives of the 10 Year Homeless Plan are listed in priority order:

1. Prevention: Increase housing stability for individuals and families at risk of

homelessness by supporting and expanding programs that provide short-term rental

housing assistance, eviction prevention services and other short-term supportive

services.

2. Diversion/Re-entry: Increase coordination and linkage among mainstream

programs that provide care and services to low-income people in order to

consistently assess and respond to their housing needs to prevent homelessness, and

ensure that public institutions (hospitals, prisons, jails, mental health facilities)

discharge people into housing.

3. Permanent Housing: Preserve and expand the supply of permanent housing and

permanent supportive affordable to persons with very low incomes.

4. Transitional/Supportive: Preserve and expand the supply of short-term supportive

housing for individuals and families.

5. Employment/Income Support: Increase access to educational and employment

programs to increase earning potential for individuals who are homeless, or at risk

of homelessness, and lead to self-sufficiency.

6. Outreach/Access/Linkage: Maintain effective outreach programs for persons who

are homeless and chronically homeless and are not engaged in the homeless service

system. Linkages should be created to easily connect those who are homeless to

mainstream resources, and create simple access points for comprehensive housing,

physical and mental health services, and chemical dependency treatment.

7. Access to Shelter: Ensure availability and access to staffed emergency shelter and

services in the existing shelter system.

8. Planning/Coordination: Plan and coordinate countywide and system wide to

efficiently manage limited resources for ending homelessness.

9. Data Analysis: Build on successful implementation and expansion of Homeless

Management Information Services (HMIS) in Clark County.

Vancouver has focused CDBG funds in program year 2013 on addressing the needs of

people who are homeless. Program year 2013 funded projects include, homeless outreach

services, emergency shelter services, case management, and training opportunities. See

Annual Objectives and Description of Activities section for specific projects and anticipated

beneficiaries/outcomes. Additional resources and actions directed towards homeless and

special needs populations are listed below.

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Washington Families Fund The Washington Families Fund is a public-private partnership to expand service-enriched

affordable housing for homeless families in Washington State. Established by the

Washington Legislature in 2004, the fund fills a critical need by providing stable, long-term

funding for housing-based services.

Administered by Building Changes, Washington Families Fund will help sustain existing

supportive services and create new programs statewide. The fund provides financing for

both on- and off-site support services tied to affordable housing, allowing non-profit

organizations to increase comprehensive and individualized case management services for

homeless families throughout the state. Community Services Northwest received a

$375,000 grant in 2011, as well as grants in previous years. The Share ASPIRE program has

also received funding through this program in 2005.

Bridges to Housing Bridges to Housing is an innovative and holistic approach to the growing and alarming

problem of family homelessness in the Portland-Vancouver metropolitan area. Bridges to

Housing will offer hope for a better future to the families and their children who are served

by the program and will inform local and national policy and practice. The program

involves planning and funding from four separate counties in two states. The project

combines government and private funding to develop and coordinate a regional model to

combat family homelessness. The Share ASPIRE program has received funds since 2006

and partners with the Vancouver Housing Authority to house Bridges to Housing families

throughout Clark County.

Housing Opportunities for People with AIDS The City of Portland receives and distributes funding for the HOPWA program for seven

counties in the metropolitan area including Clark County. For further information of

HOPWA activities, contact the City of Portland’s Bureau of Housing and Community

Development at (503) 823-2375 or http://www.portlandonline.com/phb.

Continuum of Care Vancouver participates with the Council for the Homeless and service providers to enhance

the community’s comprehensive Continuum of Care system to end homelessness in the

county. This dynamic partnership includes collaborative efforts of a variety of community

groups, government agencies and coalition of more than 40 homeless service providers. For

further information on the Council for the Homeless, contact Andy Silver at (360) 993-9561

or http://www.icfth.com/.

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Vancouver City Council approved an Analysis of Impediments to Fair Housing Choice in

September 2012. The analysis concluded that the City has solid policies and practices in

place to mitigate fair housing barriers. The associated survey indicated that Vancouver

residents feel empowered to find solutions when faced with housing discrimination. There

are very few census tracts within the city with higher than citywide average proportion of

minorities. The City has a very low volume of housing complaints. Since January 2006 only

59 complaints have been file by HUD residents. Of those complaints 50% were found to be

unsubstantiated and 20% were resolved through settlement agreement. No fair housing

legal actions have been filed within Vancouver in the last five years.

Along with the positive findings the analysis also highlighted areas in which there are

opportunities to improve fair housing conditions.

Housing has become less affordable and deeply subsidized rentals are scarce.

Between 2000 and 2010, the buying and renting power of Vancouver residents declined.

Specifically, the median contract rent for apartments in the city has increased 22 percent

increase from the median rent in 2000. To afford the increase in the median contract rent,

renters would need to earn $5,960 more per year. Instead, renter income increased by just

$1,400. The median-priced home in 2000 cost $70,000 more in 2010. To afford this increase,

homeowners would need to earn about $25,000 more per year. Homeowner income rose by

less than half of what was needed to keep up with housing value increases.

Based on 2009 data provided mortgage lending disparities may exist for Hispanic applicants.

In 2009, there were approximately 6,500 mortgage loan applications made by residents in

Vancouver. Loan origination rates varied by race and ethnicity. The largest gap in denials

was between Hispanic and non-Hispanic borrowers. In three of the City’s census tracts

with high proportions of Hispanic residents 2009 mortgage loan denials exceeded City

averages. Non-Hispanic borrowers’ origination rate was 13 percentage points higher than

Hispanic borrowers’. These census tracts could be at risk for disinvestment and decline if

access to private capital is limited.

Access of fair housing information could be improved.

Fair housing information is readily accessible on many websites but is lacking or hard to

find on some important obvious sites.

The City fair housing law is appears outdated because it does not cover all protected classes

as currently required by Federal law.

The City of Vancouver currently defers fair housing practices regulation to superseding

state and federal regulations. The City of Vancouver Municipal Code Section 8.44.040 was

Barriers to Affordable Housing

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initially adopted in 1968 following federal landmark civil rights legislation. The ordinance

has remained dormant since adoption and therefore does not offer the same protections as

current federal or state fair housing laws, which include protections for gender, familial

status, disability and (for state law) marital status, sexual orientation and veteran status.

The analysis recommended the City of Vancouver adopt the following Action Plan and

activities for reducing fair housing impediments:

ACTION ITEM 1. Support nonprofit and private sector efforts to increase the stock of

affordable housing, especially deeply subsidized rentals.

• Monitor Vancouver’s housing plans and policies (Consolidated Plan and

Comprehensive Plan) with emphasis on creating subsidized rental units.

• Locate publically funded units in high opportunity neighborhoods—those with few

poverty concentrations, good schools, access to public transportation and stable

pricing.

• Develop projects that include market rate housing in order to reduce affordable

housing concentrations and expand housing choice for low income individuals.

Considerations-Rising rental costs during the past decade (without corresponding increases

in renter income) and the very long waitlists for public housing authority units and

Housing Choice vouchers—combined with residents’ and stakeholders’ views of

inadequate affordable rental housing—make the lack of affordable rentals the top fair

housing barrier found in this AI. It is a difficult time for many cities to aggressively address

affordable housing shortages. As the economy improves and the city’s funds become less

constrained, Vancouver should closely follow its priorities identified in the Comprehensive

Plan and, in particular, add more deeply subsidized rental units to its housing stock.

Ideally, such units would be located in high opportunity neighborhoods—those with few

poverty concentrations, good schools and stable pricing—and developments with market

rate housing to reduce affordable housing concentrations and further housing choice for

low income individuals.

ACTION ITEM 2. Monitor potential areas of racial/ethnic concentrations and high

mortgage loan denials.

• Work with neighborhood associations in Fruit Valley, Fourth Plain Village, Harney

Heights and Meadow Homes to promote the investment of public dollars focused on

revitalization of these neighborhoods and provide housing improvements.

• Monitor Home Mortgage Disclosure Act (HMDA) data to further understand the

loan denials in the City.

Considerations-Racial and ethnic concentrations in the City are minimal, with just two

block groups showing high proportions of persons of Hispanic descent. Areas where

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minorities live in the City are somewhat correlated with census tracts with higher-than-

average mortgage loan denials. In addition, the City’s recent community survey the areas

with racial and ethnic concentration are also the areas where residents report the lowest

levels of the “feeling of safety walking…after dark.”

A lack of private capital investment combined with potential reluctance of residents to

locate in these areas due to safety concerns could lead to neighborhood disinvestment and

decline.

To better understand if disinvestment or discrimination is occurring, the City should

continue to attend neighborhood meetings in these areas, distribute fair housing

information and have discussions with residents to identify any fair housing concerns. The

City should also continue investing public dollars in neighborhood revitalization and

housing improvements in these areas.

ACTION ITEM 3. Continue to improve access to and dissemination of fair housing

information.

• Regularly update the City website to include additional fair housing information

including links to websites for more information on filing complaints in both

Spanish and English.

• Add a “Frequently Asked Questions” (FAQ) section.

• Work with local social service agencies to include a fair housing information section

with links on their web sites.

Considerations-The websites for the City, Vancouver Housing Authority, and Legal Aid

should be regularly updated with fair housing information.

Fair housing pages on websites should describe fair housing laws and residents’ rights and

provide links to websites for more information and filing complaints. All of this

information should be provided in Spanish and English. A Frequently Asked Questions

section is recommended with answers to questions such as “If I am not a U.S. citizen but I

feel that I have been discriminated against, what can I do?”

While the City has pursued a variety of strategies to impact the identified needs of the

community, the primary obstacle to meeting the underserved needs is the lack of sufficient

financial resources. See the annual objectives and description of activities and identified

need for specific projects and anticipated beneficiaries/outcomes.

Obstacles to Meeting Underserved Needs

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Foster and Maintain Affordable Housing

The City fosters and maintains affordable housing by:

Providing funds each year for the rehabilitation of owner-occupied housing for

people of low- and moderate-income;

Tenant-based rental assistance and housing services

Promoting affordable and public housing projects; and

Preserving the housing stock in the City of Vancouver through support of other

publicly-funded housing.

See annual objectives and description of activities for specific projects and anticipated

beneficiaries/outcomes.

Vancouver funds a rental assistance program and manages a housing rehabilitation

program; both of which require a lead based paint inspection on all homes built prior 1978.

Anti-Poverty Strategy

There were 28,105 people (17.5%) in Vancouver living below the poverty level, according to

the 2010 American Community Survey. Vancouver’s overall goal is to reduce the number

and percentage of persons living in poverty. Vancouver will use its CDBG and HOME

funds to reduce the impacts of poverty on low- and moderate-income families and

individuals in the community while working toward moving persons out of poverty.

Working with the community’s businesses and the workforce development programs, job

training opportunities for low-income persons will be expanded and public services

programs aimed at increasing self-sufficiency will be supported. The following strategies,

consistent with Vancouver’s overall Consolidated Plan strategies, will play a major role in

combating poverty over the next five years:

Support community vitality through activities that promote a diverse economic base

and family wage jobs while providing opportunities for low- and moderate-income

people to become financially independent;

Support services designed to expand affordable housing available and services to

assist homeless people to reach self-sufficiency; and

Support programs that identify people who are homeless, assess their needs, and

move them into appropriate housing and supportive services.

Lead-Based Paint

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The City of Vancouver received a Section 108 loan that is used in conjunction with one-

million dollars received through Brownfields Economic Development initiative (BEDI).

This funding is being used for the Waterfront Access Project, for further detail regarding

this project see the Vancouver website http://www.cityofvancouver.us/cdbg.

In 2009, the City of Vancouver received 2.8 million dollars through the Neighborhood

Initiative funds for the road and rail system improvement to reconnect Vancouver to the

Columbia River. This funding will be utilized for the waterfront access project street

component in the spring of 2013.

Vancouver has standardized procedures to ensure that the fiscal information regarding

entitlement funds that are submitted to HUD are correct and complete:

Once a letter of credit is approved and entitlement funds become available, separate

accounts are set up through Vancouver’s Budget Office;

When the contractor requests reimbursement, they are required to submit both a City of

Vancouver Request for Reimbursement and supplementary documentation of costs that

were incurred;

City staff review the documents to insure expenses are appropriate and eligible under

contracted provisions;

Progress reports are submitted quarterly;

If an inappropriate or ineligible cost is incurred, or if performance falls far below

projections, Vancouver will not reimburse the sub-grantee and will meet with them to

try to rectify the situation;

After review of the documents is completed, the voucher and supporting

documentation are reviewed through the financial management services.

Program Income Program income is any income generated from the use of Vancouver entitlement funds,

such as proceeds from loan repayments. Program income accrued must be used prior to

drawing additional program funds from the federal line of credit. Program income is

received by Vancouver and tracked through the finance department. Any program income

generated from the Housing Rehab program may be used to fund additional housing rehab

loans. HOME funds received from a project before the affordability period has expired are

recaptured funds and not HOME program income.

Section 108

Fiscal Controls

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HOME Requirements

Vancouver has received HOME funding since July 1, 2009. Vancouver is working with

local Community Housing Development Organizations (CHDO) and the Vancouver

Housing Authority along with HUD to develop affordable housing.

Affordable Homebuyer Assistance Programs Vancouver has used both HOME and CDBG funds to support homebuyer assistance

programs. When using HOME funds the city attaches deed clauses that enforce the

recapture provisions outlined below. When using CDBG funds we also include a recapture

provision in the deed. Currently Evergreen Habitat for Humanity is operating a homebuyer

program, which will following the re-sale provisions.

General provisions:

As stipulated in 24 CFR 92.254, housing acquired through HOME-funded affordable

homebuyer assistance programs must meet be the principal residence of the eligible family

through the affordability period described below. The property is secured by a deed of

trust specifying the affordability period a written agreement between the sub-recipient and

homeowner:

Assistance under $15,000 requires a 5-year affordability period;

Assistance from $15,000 to $40,000 requires a 10-year affordability period; and

Assistance over $40,000 requires a 15 year period.

Recapture Provisions:

If the housing acquired through City-sponsored affordable homebuyer assistance programs

does not continue to be the principal residence of the family for the duration of the

affordability period, Vancouver expects to recapture the entire amount of assistance

provided to the homebuyer. Vancouver will recapture the entire amount of the assistance

given unless the net proceeds are insufficient to recapture the full investment and enable

the homeowner to recover the down payment and capital improvements made by the

owner since purchase. In this case, the net proceeds will be divided proportionally using

the following formula:

Recaptured funds = Net Proceeds X HOME funds

HOME funds + Homeowner funds

Amount to homeowner = Net Proceeds X Homeowner funds

HOME funds + Homeowner funds

In case of transfer of ownership due to foreclosure or deed in lieu of foreclosure prior to the

satisfaction of the period of affordability requirement, and if there are no net proceeds from

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the foreclosure, repayment is not required and HOME requirements are considered to be

satisfied.

Resale Restrictions

In the case of homes being used by a developer for housing that is resold to an eligible

homeowner, the City of Vancouver will document the resale restrictions in the deed.

If HOME-assisted units do not continue to be the principal residence of the family for the

duration of the affordability period, the property may be made available for subsequent

purchase to a buyer, providing the following conditions are met:

The property is sold to another low-income homebuyer who will use the property as

his or her principal residence.

The original homeowner receives a fair return on investment (homebuyer’s down

payment plus capital improvements made to the house) by determining the shared

net proceeds.

The property is sold at a price that is affordable to a reasonable range of low-income

buyers.

Tenant-Based Rental Assistance Vancouver provides funding for tenant based rental assistance (TBRA) which is a rental

subsidy designed to help individual households afford housing costs such as rent, utilities

and security deposits. The funding is awarded to different programs in Vancouver and

prospective tenants meet the 60 percent of area median income guidelines. As stated in the

certification in the appendix, any funds to be provided "are an essential element of

Vancouver's annually approved housing strategy for expanding the supply, affordability,

and availability of decent, safe, sanitary and affordable housing."

There is a strong need for tenant-based rental assistance in the Vancouver community.

There were 28,105 people (17.5%) in Vancouver living below the poverty level, according to

the 2010 American Community Survey. The January of 2013 Point in Time count identified

xxx homeless people. The Emergency Shelter Clearinghouse based in Vancouver received

3,772 calls in 2012 from people seeking shelter 1,123 of which were children. Additional

local market conditions are described in the 2009-2013 Consolidated Plan.

Affirmative Marketing Vancouver has an Affirmative Marketing Plan in the 2009-2013 Consolidated Plan. In

addition, a list of agencies and organizations was developed for the consultation and

coordination efforts under this plan. The list agencies and organizations will be maintained

for affirmative outreach, and includes organizations serving ethnic, minority, senior and

disabled persons.

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Minority/Women’s Business Outreach (Any changes?) Vancouver will take the following affirmative outreach steps to encourage MWB

participation in HOME activities:

Procurement attends 1-2 outreach events every year, including events which directly

target women, disadvantaged and emerging small businesses.

Track registration of MBE (minority), WBE (women) and DBE (Disadvantaged)

certifications for companies that are registered in the State of Washington on all of our

rosters.

Advertise federally funded projects in at least one minority papers to help reach out to

the different groups and organizations. Papers are added upon request and we rotate

through our list as we advertise each project to ensure equal distribution. In addition to

advertising federally funded projects we also advertise our rosters in minority papers.

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Attachment A:

CDBG and HOME Certifications

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Certifications

In accordance with the applicable statutes and the regulations governing the Consolidated

Plan regulations, the City of Vancouver certifies that:

Affirmatively Further Fair Housing – The City of Vancouver will affirmatively further

fair housing, which means it will conduct an analysis of impediments to fair housing

choice within the City of Vancouver, take appropriate actions to overcome the effects of

any impediments identified through that analysis, and maintain records reflecting that

analysis and actions in this regard.

Anti-displacement and Relocation Plan – It will comply with the acquisition and

relocation requirements of the Uniform Relocation Assistance and Real Property

Acquisition Policies Act of 1970, as amended, and implementing regulations at 49 CFR

24; and it has in effect and is following a residential anti-displacement and relocation

assistance plan required under section 104(d) of the Housing and Community

Development Act of 1974, as amended, in connection with any activity assisted with

funding under the CDBG or HOME programs.

Drug Free Workplace – It will, or will continue to, provide a drug-free workplace by:

1. Publishing a statement notifying employees that the unlawful manufacture,

distribution, dispensing, possession, or use of a controlled substance is

prohibited in the grantee’s workplace and specifying the actions that will be

taken against employees for violation of such prohibition;

2. Establishing an ongoing drug-free awareness program to inform employees

about:

a. The dangers of drug abuse in the workplace;

b. The grantee’s policy of maintaining a drug-free workplace;

c. Any available drug counseling, rehabilitation, and employee assistance

programs; and

d. The penalties that may be imposed upon employees for drug abuse

violations occurring in the workplace;

3. Making it a requirement that each employee to be engaged in the performance of

the grant be given a copy of the statement required by paragraph 1;

4. Notifying the employee in the statement required by paragraph 1 that, as a

condition of employment under the grant, the employee will –

a. Abide by the terms of the statement;

b. Notify the employer in writing of his or her conviction for a violation of a

criminal drug statute occurring in the workplace no later than five

calendar days after such conviction;

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5. Notifying the agency in writing, within ten calendar days after receiving notice

under subparagraph 4(b) from an employee or otherwise must provide notice,

including position title, to every grant officer or other designee on whose grant

activity the convicted employee was working, unless the federal agency has

designated a central point for the receipt of such notices. Notice shall include the

identification number(s) of each affected grant;

6. Taking one of the following actions, within 30 calendar days of receiving notice

under subparagraph 4(b), with respect to any employee who is so convicted;

a. Taking appropriate personnel action against such an employee, up to and

including termination, consistent with the requirements of the

Rehabilitation Act of 1973, as amended; or

b. Requiring such employee to participate satisfactorily in a drug abuse

assistance or rehabilitation program approved for such purposes by a

federal, state, or local health, law enforcement, or other appropriate

agency;

7. Making a good Faith effort to continue to maintain a drug-free workplace

through implementation of paragraphs 1, 2, 3, 4, 5 and 6.

Anti-Lobbying – To the best of the City of Vancouver’s knowledge and belief:

1. No federal appropriated funds have been paid or will be paid, by or on behalf of

it, to any person for influencing or attempting to influence an officer or employee

of any agency, a Member of Congress, an officer or employee of Congress, or an

employee of a Member of Congress in connection with the awarding of any

federal contract, the making of any federal grant, the making of any federal loan,

the entering into of any cooperative agreement, and the extension, continuation,

renewal, amendment, or modification of any federal contract, grant, loan, or

cooperative agreement;

2. If any funds other than federal appropriated funds have been paid or will be

paid to any person for influencing or attempting to influence an officer or

employee of any agency, a Member of Congress, an officer or employee of

Congress, or an employee of a Member of Congress in connection with this

federal contract, grant, loan, or cooperative agreement, it will complete and

submit Standard Form-LLL, “Disclosure Form to Report Lobbying”, in

accordance with its instructions; and

3. It will require that the language of paragraph 1 and 2 of this anti-lobbying

certification be included in the award documents for all sub-awards at all tiers

(including subcontracts, sub-grants, and contracts under grants, loans, and

cooperative agreements) and that all sub-recipients shall certify and disclose

accordingly.

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Authority of Jurisdiction – The Consolidated Plan is authorized under state and local

law (as applicable) and the City of Vancouver possesses the legal authority to carry out

the programs for which it is seeking funding, in accordance with applicable HUD

regulations.

Consistency With Plan – The housing activities to be undertaken with CDBG and

HOME funds are consistent with the strategic plan.

Section 3 – It will comply with section 3 of the Housing and Urban Development Act of

1968, and implementing regulations at 24 CFR Part 135.

SIGNATURE ON FILE

Eric Holmes, City Manager Date

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Specific CDBG Certifications

The Entitlement Community certifies that:

Citizen Participation – It is in full compliance and following a detailed citizen

participation plan that satisfies the requirements of 24 CFR 91.105.

Community Development Plan – It’s consolidated housing and community

development plan identifies community development and housing needs and specifies

both short-term and long-term community development objectives that provide decent

housing, expand economic opportunities primarily for persons of low- and moderate-

income. (See CFR 24 570.2 and CFR 24 part 570)

Following a Plan – It is following a current Consolidated Plan (or Comprehensive

Housing Affordability Strategy) that has been approved by HUD.

Use of Funds – It has complied with the following criteria:

1. Maximum Feasible Priority. With respect to activities expected to be assisted

with CDBG funds, it certifies that it has developed its Action Plan so as to give

maximum feasible priority to activities which benefit low- and moderate-income

families or aid in the prevention or elimination of slums or blight. The Action

Plan may also include activities which the grantee certifies are designed to meet

other community development needs having a particular urgency because

existing conditions pose a serious and immediate threat to the health or welfare

of the community, and other financial resources are not available;

2. Overall Benefit. The aggregate use of CDBG funds including Section 108

guaranteed loans during program year 2012, shall principally benefit persons of

low- and moderate-income in a manner that ensures that at least 70 percent of

the amount is expended for activities that benefit such persons during the

designated period;

3. Special Assessments. It will not attempt to recover any capital costs of public

improvements assisted with CDBG funds including Section 108 loan guaranteed

funds by assessing any amount against properties owned and occupied by

persons of low- and moderate-income, including any fee charged or assessment

made as a condition of obtaining access to such public improvements.

However, if CDBG funds are used to pay the proportion of a fee or assessment

that related to the capital costs of public improvements (assisted in part with

CDBG funds) financed from other revenue sources, an assessment or charge may

be made against the property with respect to the public improvements financed

by a source other than CDBG funds.

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The jurisdiction will not attempt to recover any capital costs of public

improvements assisted with CDBG funds, including Section 108, unless CDBG

funds are used to pay the proportion of fee or assessment attributable to the

capital costs of public improvements financed from other revenue sources. In

this case, an assessment or charge may be made against the property with respect

to the public improvements financed by a source other than CDBG funds. Also,

in the case of properties owned and occupied by moderate-income (not low-

income) families, as assessment or charge may be made against the property for

public improvements financed by a source other than CDBG funds if the

jurisdiction certifies that it lacks CDBG funds to cover the assessment.

Excessive Force – It has adopted and is enforcing:

1. A policy prohibiting the use of excessive force by law enforcement agencies

within its jurisdiction against any individuals engaged in non-violent civil rights

demonstrations;

2. A policy of enforcing applicable state and local laws against physically barring

entrance to or exit from a facility or location which is the subject of such non-

violent civil rights demonstrations within its jurisdiction.

1. Compliance With Anti-discrimination Laws – The grant will be conducted and

administered in conformity with title VI of the Civil Rights Act of 1964 (42 USC 2000d),

the Fair Housing Act (42 USC 3601-3619), and implementing regulations.

Lead-Based Paint – Its notification, inspection, testing and abatement procedures

concerning lead-based paint will comply with the requirements of 24 CFR §570.608.

Compliance with Laws – It will comply with applicable laws.

SIGNATURE ON FILE

Eric Holmes, City Manager Date

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Specific HOME Certifications

The HOME participating jurisdiction certifies that:

Tenant Based Rental Assistance – If the participating jurisdiction intends to provide

tenant-based rental assistance:

The use of HOME funds for tenant-based rental assistance is an essential element of the

participating jurisdiction’s Consolidated Plan for expanding the supply, affordability,

and availability of decent, safe sanitary, and affordable housing.

Eligible Activities and Costs – It is using and will use HOME funds for eligible

activities and costs, as described in 24 CFR § 92.205 through 92.209 and that it is not

using and will not use HOME funds for prohibited activities, as described in § 92.214.

Appropriate Financial Assistance – Before committing any funds to a project, it will

evaluate the project in accordance with the guidelines that it adopts for this purpose and

will not invest any more HOME funds in combination with other federal assistance than

is necessary to provide affordable housing.

SIGNATURE ON FILE

Eric Holmes, City Manager Date

Page 36: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Appendix to Certifications

INSTRUCTIONS CONCERNING LOBBYING AND DRUG-FREE WORKPLACE REQUIREMENTS:

1. Lobbying Certification

This certification is a material representation of fact upon which reliance was placed

when this transaction was made or entered into. Submission of this certification is a

prerequisite for making or entering into this transaction imposed by section 1352,

title 31, U.S. Code. Any person who fails to file the required certification shall be

subject to a civil penalty of not less than $10,000 and not more than $100,000 for each

such failure.

2. Drug-Free Workplace Certification

a. By signing and/or submitting this application or grant agreement, the grantee is

providing the certification.

b. The certification is a material representation of fact upon which reliance is placed

when the agency awards the grant. If it is later determined that the grantee

knowingly rendered a false certification, or otherwise violates the requirements

of the Drug-Free Workplace Act, HUD, in addition to any other remedies

available to the Federal Government, may take action authorized under the

Drug-Free Workplace Act.

c. Workplaces under grants, for grantees other than individuals, need not be

identified on the certification. If known, they may be identified in the grant

application. If the grantee does not identify the workplaces at the time of

application, or upon award, if there is no application, the grantee must keep the

identity of the workplace(s) on file in its office and make the information

available for federal inspection. Failure to identify all known workplaces

constitutes a violation of the grantee’s drug-free workplace requirements.

d. Workplace identifications must include the actual address of buildings (or parts

of buildings) or other sites where work under the grant takes place. Categorical

descriptions may be used (e.g., all vehicles of a mass transit authority or state

highway department while in operation, state employees in each local

unemployment office, performers in concert hall or radio stations).

e. If the workplace identified to the agency changes during the performance of the

grant, the grantee shall inform the agency of the change(s), if it previously

identified the workplaces in question (see paragraph three).

f. The grantee may insert in the space provided below the site(s) for the

performance of work done in connection with the specific grant:

Place of Performance (Street address, city, county, state, zip code)

Page 37: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

415 W 6th Street Vancouver WA 98660

Check if there are workplaces on file that are not identified here.

The certification with regard to the drug-free workplace is required by 24

CFR part 24, subpart F.

3. Definitions of terms in the Nonprocurement Suspension and Debarment common

rule and Drug-Free Workplace common rule apply to this certification. Grantees’

attention is called, in particular, to the following definitions from these rules:

“Controlled substance: means a controlled substance in Schedules I through V of

the Controlled Substances Act (21 U.S.C. 812) and as further defined by

regulation (21 CFR 1308.1 1 though 1308.15);

“Conviction” means a finding of guilt (including a plea of nolo contendere) or

imposition of sentence, or both, by any judicial body charges with the

responsibility to determine violations of the federal or state criminal drug

statues;

“Criminal drug statute” means a federal or non-federal criminal statute

involving the manufacture, distribution, dispensing, use, or possession of any

controlled substance;

“Employee” means the employee of a grantee directly engaged in the

performance of work under a grant, including: (i) All “direct charge” employees;

(ii) all “indirect charge” employees unless their impact or involvement is

insignificant to the performance of the grant; and (iii) temporary personnel and

consultants who are directly engaged in the performance of work under the

grant and who are on the grantee’s payroll. This definition does not include

workers not on the payroll of the grantee (e.g., volunteers, even if used to meet a

matching requirement; consultants or independent contractors not on the

grantee’s payroll; or employees of subrecipients or subcontractors in covered

workplaces).

Page 38: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Attachment B:

HUD FY 2013 Income Limits Summary

Page 39: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

FY 2013 Income Limits Summary for Vancouver, Washington

Median Family Income

Income Limit Category

Number in Household

1 2 3 4 5 6 7 8

$68,300

Four-person household

80% of Median $38,850 $44,400 $49,950 $55,500 $59,950 $64,400 $68,850 $73,300

60% of Median $29,160 $33,360 $37,500 $41,640 $45,000 $48,360 $51,660 $55,020

50% of Median $24,300 $27,800 $31,250 $34,700 $37,500 $40,300 $43,050 $45,850

30% of Median $14,600 $16,650 $18,750 $20,800 $22,500 $24,150 $25,800 $27,500

Source: U.S. Department of Housing and Urban Development, effective December 11, 2012 for CDBG funds. Vancouver is part of the Portland-Vancouver-Beaverton, OR-WA MSA. See 2012 Income Limits for HOME Program effective March 15, 2013.

2013 HUD Rent Limits for Vancouver, Washington

Rent (Monthly) Number of Bedrooms

Studio 1 2 3 4 5 6

Fair Market Rent (FMR) (11/13/12)

$659 $766 $912 $1,344 $1,615 $1,857 $2,099

High HOME Rent (2/9/12) $675 $783 $905 $1,200 $1,319 $1,437 $1,555

Low HOME Rent (2/9/12) $638 $684 $821 $949 $1,058 $1,168 $1,277

Source: U.S. Department of Housing and Urban Development, effective November 13, 2012 for FMR and February 9, 2012 for High and Low HOME rent. Vancouver is part of the Portland-Vancouver-Beaverton, OR-WA MSA. NOTE: Projects with one to four HOME-assisted units are required to have assisted unit rents not exceed the lesser of the Fair Market Rent or High HOME Rent. Projects with five or more HOME-assisted units are required to have 20% of assisted unit rents not exceed the Low HOME Rent and 80% not exceed the lesser of the Fair Market Rent or High HOME Rent. Rents include utilities and must be reduced for tenant paid utilities.

Page 40: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Attachment C:

City of Vancouver Census Information & Maps

Page 41: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Figure 1: Vancouver Population Distribution by Race (2000-2010)

Source: 2000, 2010 U.S. Census

Figure 2: Vancouver Census Tract Block Groups with Race / Ethnicity

Concentrations, 2010

Source: U.S. Census 2010

Note: Vancouver has defined an area considered to have a minority concentration as an

area where the total percentage of minority persons is at least 20 points higher than the

total percentage of minorities for the City as a whole. This is based on the HUD

definition of a minority neighborhood2.

2 http://www.huduser.org/portal/glossary/glossary.html

Population

2000 2010

Total % Total %

Total Population 143,560 100% 161,791 100%

Race

White Alone 121,752 84.8% 130,960 80.9%

Black/African American Alone 3,593 2.5% 4,763 2.9%

American Indian/Alaska Native Alone 1,399 1.0% 1,629 1.0%

Asian Alone 6,470 4.5% 8,146 5.0%

Native Hawaiian/Other Pacific Islander Alone 779 0.5% 1,589 1.0%

Other Race 9,567 6.7% 14,704 9.1%

Ethnicity

Hispanic 9,013 6.3% 16,756 10.4%

Non-Hispanic or Latino 134,525 93.7% 145,035 89.6%

Census

Tract

Block

Group

Hispanic

Percentage

Neighborhood

410.05 2 34.8% Fruit Valley

427 1 37.6% Harney Heights

Page 42: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Figure 3: Vancouver Census Tracts with Concentrations of

Low/Moderate-Income Persons

Census

Tract

Block

Group

Total

Population

Low/Moderate

-Income

%

Neighborhood

0410.05 1 1149 1342 85.6% Fruit Valley

0410.05 2 434 611 71.0% Fruit Valley

0411.08 *3 1411 2322 60.8% Van Mall, Ogden

0411.09 3 2583 2978 86.7% Bagley Downs

0412.01 2 833 1270 65.6% Ellsworth Springs

0412.03 1 1267 1754 72.2% Ogden

0412.05 1 850 1488 57.1% Ogden

0413.12 1 641 923 69.4% North Image and Clark County

0413.13 1 1298 2207 58.8% Kevanna Park

0413.14 1 1067 2006 53.2% Image and N. Image

0413.14 1 1067 2006 53.2% Image and N. Image

0413.18 1 1025 1811 56.6% Landover Sharmel

0413.20 3 1243 1992 62.4% Bennington

0413.22 1 1275 2361 54.0% Not a recognized neighborhood

0413.22 2 822 1524 53.9% Mountain View

0416.00 *1 643 813 79.1%

Northcrest, Harney Heights and

Meadow Homes

0416.00 *2 2374 3032 78.3%

Meadow Homes, Harney Heights

and Bagley Downs

0417.00 1 1917 2285 83.9% Fourth Plain Village

0417.00 2 1228 1776 69.1% Rosemere

0418.00 1 993 1457 68.2% Rosemere

0418.00 *2 806 1234 65.3% Rosemere and West Minehaha

0418.00 *3 830 1216 68.3% Rosemere and Central Park

0419.00 1 608 1147 53.0% Shumway and Lincoln

0421.00 *2 864 1676 51.6% Lincoln and Carter Park

0423.00 *1 374 579 64.6% Hough and Esther Short

0423.00 *2 604 917 65.9% Hough and Esther Short

0423.00 *3 886 1286 68.9% Hough and Esther Short

0424.00 1 78 107 72.9% Esther Short

0424.00 2 229 229 100.0% Esther Short

0424.00 3 95 120 79.2% Esther Short

0425.00 *2 115 154 74.7% Arnada and Esther Short

0426.00 1 1472 1970 74.7% Central Park

0426.00 2 491 769 63.8% Hudson's Bay

0426.00 3 291 466 62.4% Hudson's Bay

0426.00 *4 550 1016 54.1%

Hudson's Bay, Columbia Way,

Riverview

0427.00 1 1350 1627 83.0% Harney Heights

Page 43: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Source: U.S. Census 2000 (SF3), Table P7 and U.S. Department of Housing

and Urban Development Low and Moderate Income Census Data 2000,

Washington.

0427.00 2 2098 2527 83.0% Harney Heights

0428.00 *2 720 1337 53.9%

Edgewood Park and Harney

Heights

0429.00 *1 587 1000 58.7%

Vancouver Heights and

Northcrest

0430.00 *2 646 993 65.1%

Vancouver Heights and Father

Blanchet Park

0431.00 1 942 1426 66.1% Vancouver Heights

0431.00 4 484 906 53.4% Vancouver Heights

Page 44: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Map 1: Vancouver Census Tract Block Group with Concentration of Low- and Moderate-Income

Persons, 2000

Page 45: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Attachment D:

Other Resources

Page 46: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Resources

Project Name Description Eligible Activities

I. Federal Programs

a. Formula/Entitlements

Community Development

Block Grant (CDBG)

Estimated annual allocation:

City: $1,213,326

Grants awarded on a formula basis for

housing and community development

activities. Most recipients must have low- or

moderate-income levels (up to 80% AMI),

or reside in a low/moderate-income target

area.

- Property acquisition, disposition, clearance

- Rehabilitation

- Homebuyer assistance

- Economic development

- Homeless assistance

- Public services (15% cap)

- Neighborhood revitalization

- Public facilities

HOME Investment Partnership

Program (HOME)

Estimated annual allocation:

City: $532,732

Flexible grant program awarded on a

formula basis to implement local housing

strategies. Recipients must be low- to

moderate-income (up to 80% AMI) for

homeownership, with low-income (up to 50%

& 60%) targeting for rental housing.

Requires 25% non-federal matching funds.

- New construction

- Site improvements

- Acquisition

- Demolition

- Rehabilitation

- Relocation

- Homebuyer assistance

- CHDO operating expenses

Section 8 Rental Assistance

Program

Rental assistance payments to owners of

private market rate units, or directly to

tenants (vouchers). Section 8 tenants must

be low-income (up to 50% AMI).

Administered by VHA.

- Rental assistance

Page 47: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Project Name Description Eligible Activities

I. Federal Programs

a. Formula/Entitlements

Housing Opportunities for

Persons with AIDS (HOPWA)

Grant administered through City of Portland

for housing assistance and supportive

services for low-income persons with HIV or

AIDS.

- Acquisition, rehabilitation, conversion, lease and repair of facilities

- New construction

- Rental assistance

- Short-term rent, mortgage and utility payments.

- Support services

- Planning

- Operating costs

I. Federal Programs

a. Formula/Entitlements

Economic Development Initiative

Grant (used in conjunction with

Section 108 loan funds)

Supportive Housing Program

Promotes development of supportive

housing and services for homeless.

Applicants may be government entities,

private non-profit agencies, or public non-

profit community mental health

associations.

Acquisition/rehabilitation, new construction,

and leasing for:

- Transitional housing

- Permanent housing for homeless with

disabilities

- Supportive services for homeless

Shelter Plus Care

Provides rental housing assistance in

connection with supportive services to be

provided with other sources of funds.

Assistance provided to homeless persons

with disabilities and their families. Selection

is on nationwide competitive basis.

- Tenant-based rental assistance

- Project-based rental assistance

- Sponsor-based rental assistance

- Section 8 Moderate Rehab Assistance for SRO dwellings

Section 202 – Supportive Housing for

the Elderly

FY2010 Appropriations – $449 million

Grants to non-profit agencies for supportive

housing for the elderly. Rental assistance is

available to elderly persons (up to 50% AMI)

- Acquisition/Rehabilitation

- New construction

- Rental assistance

- Support services

Section 811 – Supportive Housing for

Persons with Disabilities

FY2010 Appropriations – $300 million

Grants to non-profit agencies for supportive

housing for persons with disabilities.

Provides capital advances and/or project

rental assistance. Rental assistance

available to disabled people up to 50% AMI.

- Acquisition

- Rehabilitation

- New construction

- Rental assistance

Page 48: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

I. Federal Programs

b. Competitive Programs

FHA Single-Family Mortgage

Insurance Program

Section 203(b) is the primary FHA effort to

assist low/moderate-income homebuyers,

helping to purchase 1-4 family dwellings as

well as refinance existing residences. FHA

insures mortgages and provides coverage

in case of default.

Section 203(k) is used to insure financing for

acquisition and rehabilitation of existing 1-4

unit properties. Certain loan limits and

downpayment requirements apply.

- Purchase and refinance of single family

homes

- Acquisition, rehabilitation, relocation of

unit, refinance

2. State Programs

Emergency Shelter and Homeless

Prevention Program (ESHP)

Grants are awarded to non-profit agencies

to provide year round emergency shelter,

homeless prevention and case management

to individuals and families who are homeless

or at risk of becoming homeless

- Operations and essential services

activities

- Rent or mortgage subsidies to prevent

eviction/foreclosure and case manager

services to directly assist individuals and

families.

Washington State Department of

Commerce

Housing Trust Fund

Grants and loans to non-profit agencies for

low-income (60% AMI) housing construction,

acquisition, rehabilitation, homeowner

acquisition, or farm worker housing.

Competitive funds distributed semi-

annually.

- New Construction/Rehabilitation

- Homebuyer assistance

Washington State Housing Finance

Commission - Low-Income Housing

Tax Credit – 9% Tax Credit

2012 allocation - $15,257,586

www.wshfc.org

4% Tax Credit/State tax exempt bonds

– subject to annual volume cap

Federal tax credits available to invest in low-

income rental housing. Tax credit proceeds

are used to create rental housing. Tax

credits are awarded through the state on a

competitive basis. 20% of project units must

be set-aside for households earning 50%

AMI, or 40% of units at 80% AMI. Projects

competing for 9% tax credits typically set

income targeting at 40% AMI or below to

remain competitive.

- New Construction – Rental

- Substantial Rehabilitation – Rental

- Acquisition - Rental

Page 49: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

3. Private Resources/Financing Programs

Federal National Mortgage Association (Fannie Mae)

a. Community Home Mortgage

Improvement Program

Mortgages that fund purchase and

rehabilitation of a home.

- Home purchase

- Home rehabilitation

b. Community Second Mortgage

Loans

Second mortgage loans secured/subsidized

in conjunction with Fannie Mae Community

Lending fixed-rate first mortgage.

- Homebuyer assistance

- Rehabilitation

c. Fannie Neighbors

Second mortgage secured/subsidized by a

federal, state, or local government agency

at no or very low interest.

- Second mortgages

d. Fannie 97

Low down-payment mortgages for single-

family homes in underserved low-income

and minority communities.

3% down payment mortgages for low-

income homebuyers with non-profit

agencies or government agencies paying

closing costs.

- Homebuyer assistance

Federal Home Loan Bank Affordable

Housing Program (AHP)

Long-term housing financing (grants/loans)

for qualified homeownership and rental

housing development projects. Assistance

limited to households earning up to 80% AMI

(program is competitive and often requires

lower targeting). Funds distributed through

semi-annual grant process.

- New Construction

- Acquisition

- Purchase

- Rehabilitation

Private Lenders

The Community Reinvestment Act (CRA)

requires certain regulated financial

institutions to achieve goals for lending in

low/moderate-income neighborhoods. As a

result, most of the larger private lenders

offer one or more affordable housing

programs, such as first-time homebuyer,

housing rehabilitation, or new construction.

- Varies, depending on individual program

offered by bank

4. Local Resources

Document Recording Surcharge

(HB 2060)

Estimated $185,000 annually

A $10 surcharge on documents recorded in

the county, 60% goes to the county, 40%

returned to Washington State Department of

Commerce. All households assisted must

be at or below 50% of AMI.

- Emergency shelter operations

- Acquisition, construction

- Rental operating costs and voucher

Homelessness Housing and

Assistance Act

(HB 2163 and HB 1359)

Approximately $1,500,000 annually

HB 2163 requires a $ 10 surcharge on

documents recorded in the county, 61%

goes to the county, 39% returned to State

Department of Commerce. HB 1359

requires a $10 document surcharge, 90%

retained by County and 10% to State

Department of Commerce. All households

assisted must be homeless or formally

homeless.

- Homeless housing development

- Operating subsidies

- Outreach services

- Rental vouchers

- Services to prevent homelessness

Page 50: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Attachment E:

Citizen Comments

Page 51: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

First Reading - April 22, 2013, City Council Chambers

Vancouver did/ not receive questions/comments from concerned citizens. Comment s are listed

below. The City Council provided an explanation for the questions and issued an invitation to

attend the public hearing on May 6, 2013 to hear the staff report and have the opportunity for

further comment.

Public Hearing – May 6, 2013, City Council Chambers

Public Comment:

1.

2.

3.

Page 52: DRAFT 2013 CITY OF VANCOUVER ACTION PLAN CDBG / HOME … · 2013. 3. 29. · City of Vancouver staff report annually to HUD regarding all CDBG and HOME funded projects. Vancouver

Attachment F:

Action Plan Projects