Introduction & General Information

Transcription

1 The Consolidated Plan (the Plan ) has been prepared to meet statutory planning and application requirements for the receipt and use of Community Development Block Grant ( CDBG ), HOME Investment Partnerships ( HOME ) and Emergency Shelter Grant ( ESG ) Program funding in suburban Hennepin County. The Plan is the third five-year Consolidated Plan developed for the Hennepin County Consortium since the US Department of Housing and Urban Development ( HUD ) consolidated the application process in HUD has prescribed the basic format, order of presentation and content for the Plan. Mission Congress has set forth three basic goals for the CDBG, HOME, and ESG entitlement programs: Provide Decent Housing Provide a Suitable Living Environment Expand Economic Opportunities The Plan will be used to: Establish housing and community development goals for the five-year period from 2010 to 2014 to continue to provide decent, safe, and affordable housing. Determine goals and strategies to provide adequate resources to address the needs of homeless families and individuals and persons with special needs. Encourage and support greater public awareness of current housing and community development needs in suburban Hennepin County. The Plan furthers the statutory goals through a collaborative process, whereby the jurisdiction establishes a unified vision for housing and community development actions. It also serves to create opportunities for strategic planning and citizen participation in a comprehensive context. Hennepin County Consortium Suburban Hennepin County has five CDBG entitlement jurisdictions: Urban Hennepin County (the county ) in cooperation with 41 suburban Hennepin communities, the cities of Bloomington, Eden Prairie, Minnetonka and Plymouth. The jurisdictions formed a joint cooperation consortium, called the Hennepin Housing Consortium, in order to receive the maximum amount of HOME funds in suburban Hennepin County. The county, per the joint cooperation agreement, is the lead of the Hennepin Housing Consortium. Since the Hennepin Housing Consortium s geographic area and agreement include all three jurisdictions, for the purpose of this Plan and related documents, references to the Hennepin County Consortium or the Consortium are for all jurisdictions and programs. The county is the entitlement jurisdiction for the ESG Program. Hennepin County Consortium Consolidated Plan FY

2 The county is the lead entity and responsibility for overseeing the development, implementation and evaluation of the Plan for the Consortium. Bloomington, Eden Prairie, Minnetonka and Plymouth have chosen to accept and use the Plan for their respective CDBG programs. Throughout the Plan, reference to suburban Hennepin County is used to describe the geographic area for the Consortium. Exhibit I.1 Hennepin County Housing Consortium NOTE: Consolidated Pool cities may change with different program years. Exhibit I.1 reflects the pool composition in the 2010 program year. 4 Hennepin County Consortium Consolidated Plan FY

3 Minneapolis qualifies as a separate entitlement for the HOME and CDBG programs. Defining Priorities and Allocating Funds Plan priorities were developed after a thorough review of demographic data, citizen and community input, other public policy and community plans, and historical funding results from the prior years in suburban Hennepin County. The priorities are specific to the HUD required categories and are provided in each chapter associated with that category. The allocation of funds differs by the HUD program: CDBG: The cities of Bloomington, Eden Prairie, Minnetonka and Plymouth receive direct CDBG allocations. The balance of the CDBG resources are administered by Hennepin County Housing, Community Works and Transit Department ( HCWT ) and allocated annually to the remaining suburban Hennepin County municipalities by applying the formula used by HUD in its national allocation to each community: population, poverty levels (double weighted), and overcrowding. The funds are pooled (the Consolidated Pool ) for those communities whose allocation results in a proportion less than 3.5 percent of the total pool. The CDBG funds are offered on a request for proposal basis for the Consolidated Pool communities. HOME: HOME funds are administered by HCWT and are offered on a request for proposal basis throughout suburban Hennepin County. ESG: ESG funds are administered by HCWT in cooperation with the county s Human Service & Public Health Department. Historically, funds have been used for its Rapid Exit from Shelter Program, which operates in county contracted homeless shelters. The obstacles to meeting underserved needs are included in the chapters describing the goals and strategies related to the need. Managing the Process Lead Agency On behalf of the Consortium, the county is the lead agency responsible for formulating plans and strategies for housing and community development objectives. The county is directly responsible for the Urban Hennepin County CDBG, HOME, and ESG programs. As the lead agency, the county strives to provide a coordinated approach to planning among the various jurisdictions, service providers, advocacy groups, and other agencies. The contact person is: Kevin Dockry, (612) Hennepin County Housing, Community Works, & Transit Department Housing Development Division 417 North Fifth Street, Suite 320, Minneapolis, MN Hennepin County Consortium Consolidated Plan FY

4 Consultation/Coordination for the Development of the Plan As lead agency, the county has overall responsibility for the Plan, including the housing and community development needs profile, the five-year strategic plan, and the annual action plans. The cities of Bloomington, Eden Prairie, Minnetonka and Plymouth have assisted with the Plan and have chosen to accept the Plan. However, they are responsible for the development of annual plans for their respective CDBG programs. The Plan is written in accordance with HUD guidelines regarding data requirements and the types of goals by income group and population. County staff consulted with a wide variety of organizations in the development of the Plan, as described below and in the Citizen Participation section. In addition to citizen and community partner consultations, the county assessed the current state of housing and community development needs by primary and secondary research to supplement the U.S. Census Data from Consultations with other entities- Housing Services: Community Action for Suburban Hennepin (CAPSH), Community Emergency Services Program (CEAP), Home Line, HousingLink, Intercongregational Communities Association (ICA), Interfaith Outreach and Community Partners (IOCP), Western Hennepin Affordable Housing Land Trust (WHAHLT) and, Western Communities Action Network (WeCAN.) Social Services: Hennepin County Human Services and Public Health Dept (HSPHD), Hennepin South Human Services Collaborative, Northwest Hennepin Human Service Council, Senior Community Services, Jewish Family & Children s Services, Family & Children s Services, Hope Community Services, Community Action for Suburban Hennepin (CAPSH) and, others. Fair Housing Services: Legal Aid Society of Minneapolis, Fund for an Open Society, Regional Fair Housing Implementation Council and the Regional Analysis of Impediments to Fair Housing and related fair housing focus groups and forums. Health Services: Most of the social service agencies listed above are able to provide referrals to appropriate health service providers. Homeless Services (including the chronically homeless): Heading Home Hennepin: Ten-Year Plan to End Homelessness, Hennepin County Office to End Homelessness, Continuum of Care for the Homeless Advisory Committee, Metropolitan Engagement on Shelter & Housing (MESH), Hennepin County Human Service & Public Health Dept- Housing & Homeless Initiative office. Lead-based Paint: Lead-based paint staff in the Hennepin County Dept. of Housing, Community Works & Transit. Metro Planning agencies: Metropolitan Council- Liveable Communities Program and Comprehensive Planning process and, Metro Housing & Redevelopment Authority. 6 Hennepin County Consortium Consolidated Plan FY

5 Data & Reports Among the reports and data reviewed were the following: The most recent five-year consolidated plans from the seven public housing authorities in Consortium cities; Surveys of housing and community development needs conducted in all Consortium communities; GVA Marquette Advisors, Apartment Trends, Fourth Quarter, 2009; Surveys of community partners and other organizations working in Consortium communities; HUD s Comprehensive Housing Affordability Strategy (CHAS) census data; The Wilder Foundation s Homeless in Minnesota 2006 report; The Next Decade of Housing in Minnesota: Twin Cities Regional Report, prepared by BBC Research and Consulting; Minneapolis- Hennepin County Plan to End Homelessness (2006) Minnesota Workforce Center, Hennepin County Surveys To better inform the consolidated planning process, the county surveyed 45 city representatives and over 80 community partners serving Consortium communities, including community-based organizations, both nonprofit and for-profit housing organizations, social service providers, health care providers, homeless service providers and lead paint hazard educational and advocacy organizations. The survey asked respondents: To prioritize various housing and community development needs for small and large families, as well as for elderly and special needs households. To describe the five top priority housing needs and community development needs. To offer strategies that they believe would address those priority needs. To identify regulatory barriers to the development of affordable housing in their communities. The results of those surveys are found throughout the Plan under appropriate needs and findings sections. HCWT staff to review the Consolidated Plan process and discuss city surveys. Hennepin County Consortium Consolidated Plan FY

6 Citizen Participation The Consortium instituted a citizen participation plan as part of the first consolidated planning process in The Citizen Participation Plan has served as the foundation for developing stronger relationships in the community. The Citizen Participation Plan has been updated to address the needs identified in the last five years. See Appendix B for the entire Hennepin County Citizen Participation Plan. Goals of the Citizen Participation Plan The Consortium supports and encourages the broad-based participation of citizens, community groups, and other interested agencies in both the development and the evaluation of the Plan s programs and activities. The citizen participation process is designed to encourage all residents, including non-english-speaking and minority populations. Extremely low and low-income persons are especially encouraged to participate in the process, particularly those individuals living in blighted areas and in public housing or other assisted housing. Attempts are made to include residents of areas where CDBG-funded projects currently exist or are proposed, such as assisted housing developments and targeted revitalization areas. In addition special outreach was made to agencies and organizations identified in the section on Consultation above. These include local and regional institutions and other organization including but not limited to the business community through their participation in local and regional job training and employment efforts, developers of affordable and special needs housing and, community and faith-based organizations Consolidated Plan Citizen Participation Community Reviews of Draft Plans April 9 to May 7: The Public Comment Draft was available during a thirty-day public comment period. May 4 Public hearing conducted by the Hennepin County Board of Commissioners. Written Response to Public Comments The county will consider all comments received. Summaries of all comments and responses will be included in Appendix F of the final Consolidated Plan. Thereafter, summaries of public comments will also be attached to any plan amendments, performance reports and annual plans. Institutional Structure Implementation Implementation of the Plan will involve a wide variety of community partners, including community organizations, for-profit and nonprofit corporations, social and public service 8 Hennepin County Consortium Consolidated Plan FY

7 agencies. The following housing development advocacy and education organizations that will be important to Plan implementation include: Common Bond Communities Hennepin County Office to End Homelessness Community Involvement Program (CIP) Corporation for Supportive Housing (CSH) Greater Metropolitan Housing Corporation (GMHC) Hennepin/Ramsey Lead Network Project for Pride in Living (PPL) Twin Cites Habitat for Humanity West Hennepin Affordable Housing Land Trust (WHAHLT) The following public service organizations that will be important to Plan implementation serving suburban Hennepin County include, but are not limited to: Community Emergency Assistance Program (CEAP) Children and Family Services Community Action Partnership for Suburban Hennepin (CAPSH) Community Involvement Programs (CIP) Hennepin County Human Service & Public Health Dept. (HSPHD) HOMEline Home Free Interfaith Outreach and Community Partners Inter-Congregation Association (ICA) Jewish Family and Children Services Perspectives, Inc. Northwest Hennepin Human Services Council Senior Community Services Five Cities Senior Transportation Sojourner Project The Legal Aid Society of Minneapolis Wayside House Western Community Action Network (WeCAN) Hennepin County Consortium Consolidated Plan FY

8 Strengths and Gaps in the Delivery System The strengths of the delivery system include a diverse and experienced base of housing, community development, and social service providers and organizations. Coordination among the state, the county, and regional and local governments has resulted in significant planning initiatives and working policy groups, such as the Hennepin County and City of Minneapolis Commission to End Homelessness, and the City County Task Force on Lead Hazard Control. One result of this coordination has been the consolidated request for proposal (RFP) issued by public and private funders statewide, including Hennepin County. Annually, the county issues its Coordinated Request for Proposals (CRFP) that includes funding from the county s Affordable Housing Incentive Fund (AHIF), Transit Oriented Development (TOD), Supportive Housing Initiative Fund (SHIF), and Group Residential Housing (GRH), and federal funding from the HOME program and Continuum of Care of the Homeless program. These funding opportunities are further coordinated with federal Community Development Block Grant (CDBG) and Emergency Shelter Grant (ESG) programs. Another example of the effectiveness of the coordination between the Consortium partners is the success of the Consortium in meeting the majority of the Consolidated Plan goals. The gaps that do remain in housing delivery result from the shortages of local, state and federal funding, such as rental assistance. Other gaps include remaining fragmentation of certain programs serving special needs populations. Although the consolidated RFP was noted above, a number of other funding sources continue to have separate submission requirements and deadlines. Each funding source also continues to have variations in program complexity and requirements. Monitoring CDBG Standards and Procedures Under the CDBG regulations, grantees are responsible for episodic subrecipient monitoring, which may consist of onsite reviews of files and activities or desk reviews of reports. Monitoring aims to ensure that subrecipients have complied with subrecipient agreements and CDBG rules, delivered agreed-upon products and services, and achieved the results or outcomes intended. Hennepin County is the CDBG grant recipient for the 41 cities participating in the Urban Hennepin County CDBG Program. The county retains 13 percent for overall program administration. The remaining 87 percent is awarded to projects in the participating cities. A city that receives CDBG fund is typically referred to as a subrecipient. In some cases a city may suballocate funds or delegate responsibility for implementing a project to another entity, and they re typically referred to as a Third-Party Subrecipient. For purpose of this section, the terms subrecipient and Third-Party Subrecipient will be collectively referred to as subrecipient. The county s monitoring standards and procedures fulfills the requirements and intent of the CDBG program by taking actions to monitor performance in meeting goals and objectives set forth in its Consolidated Plan, by ensuring compliance with rule and regulations, and the timely 10 Hennepin County Consortium Consolidated Plan FY

9 expenditure of funds. Specifically, the county s procedures are more fully described by answering the following questions: Who will undertake monitoring? Staff in the Housing Department responsible for administering the CDBG program has primary responsibility. Monitoring may also involve financial staff from the county s Financial Management & Accounting office, as well staff in the Housing Dept. responsible for program compliance areas including; Davis Bacon/Labor Standards, Environmental Review, and Uniform Acquisition and Relocation. CDBG administrative staff and Single Family Rehabilitation Program staff are responsible for all other compliance areas. How will subrecipients and/or programs be selected for monitoring? Hennepin County has an effective subrecipient management system that includes various elements. Execution of an agreement with each subrecipient is the first step in managing subrecipient compliance. This signed contract contains a scope of work and clearly specifies tasks to be undertaken and identifies applicable CDBG requirements. In addition, the agreement establishes benchmarks or measures of subrecipient performance. Subsequent procedures include providing orientation, training and technical assistance as appropriate. In any given year, most CDBG funds are allocated to ongoing programs such as Single Family Rehabilitation, which the county administers; and core services for seniors, families and youth provided by well established providers. These programs typically require less monitoring. Technical assistance is geared to staff turn-over and/or periodic training covering changes to the CDBG regulations. Newly funded programs and programs with a shorter track record require a much higher level of oversight including training, technical assistance and monitoring. Orientation meetings are offered at the pre-application stage. The focus of these meetings is to clearly convey requirements and responsibilities as a subrecipient of CDBG funds. It also provides CDBG staff the opportunity to assess applicant capacity to administer CDBG funds. On-site monitoring is done based on a risk assessment of the subrecipient and/or funded program to determine which ones to visit. The risk assessment process will consider seven factors to determine whether a subrecipient is a high, moderate, or low risk. The factors included: new subrecipient; new or expanding activities; multiple activities; past compliance problems; performance problems, staff turnover in key positions; and activities involving complex compliance issues. Based on a review of these factors, staff will develop an annual monitoring plan. These monitoring visits are an opportunity to provide technical assistance and individualized assistance to subrecipients. Risk assessment can also be used informally as a way to determine the subject areas to review during a given monitoring. What tools or methods will be used to monitor? Prior to going on-site, the following information previously provided by the subrecipient will accessed and reviewed-funding request form, subrecipient agreement, county reimbursement (payment) documentation, program compliance documentation, program performance data, and applicable correspondence. Note: this information can also be used for risk assessment. Hennepin County Consortium Consolidated Plan FY

10 The county will contact the subrecipient by letter or to set a mutually agreeable date for onsite monitoring. The purpose and parameters of the monitoring will be conveyed at this time. During the monitoring one or more checklists may be used depending on the use of funding (property acquisition, public services, etc.). Program and/or client files may also be reviewed on a sample basis. How does the county communicate monitoring findings? Any finding will be communicated by letter to the highest ranking staff person at the city and/or provider agency. In a worse-case situation, applicable to a non-correctable finding, possibly requiring the repayment of funds, a meeting would be held with the highest ranking officials for the subrecipient to explain the issue. If the finding is a result of something beyond their control (error of omission vs. commission) an effort would be made to minimize any financial hardship on the subrecipient. Each finding will be addressed in a manner appropriate to its level of seriousness. Example; a finding that could have a negative impact on the county s CDBG funding would be very serious, while a finding applicable to a county procedural step would be least serious. What procedures are used to ensure effective management and oversight of monitoring? The Housing Department Administrative Manager and senior program staff are primarily responsible for following established monitoring standards and procedures. Significant effort is made at the front-end of the subrecipient management process including but not limited to; projects/programs selected for funding, contracting stage, providing technical assistance & oversight during implementation, ensure all CDBG compliance requirements have been met before reimbursement (payment) is made, and performance outcomes are appropriately documented. How is monitoring documented? The project file will include copies of correspondence applicable to the monitoring including but not limited to: initial letter or to subrecipient, monitoring notes and/or checklist(s), post-monitoring letter to subrecipient documenting what documentation was reviewed along with any findings and/or corrective actions required, and subrecipient response as applicable to the monitoring. As warranted, the county will take followup action to continue monitoring any areas identified as a finding or concern until program compliance is fully addressed and the subrecipient risk-level can be reduced. Conclusion: The Housing Department and CDBG staff work hard to engage subrecipients as partners in the delivery of community development programs, which means creating a culture of communication, trust, and mutual support. Further, no CDBG program funds are expended until compliance with all program requirements is documented. Housing Dept staff is always ready, willing and able to provide guidance and direction for the successful implementation of CDBG funded projects and programs. This approach has served the program well for more than 30 years. HOME Program Standards and Procedures Hennepin County monitors to ensure compliance and for the opportunity to provide clarification and technical assistance. Recipients are provided the opportunity to ask 12 Hennepin County Consortium Consolidated Plan FY

11 questions and request clarification. Annual monitoring has been an important communication and partnership building tool. Initial Our goal is that within three months of construction or beginning of lease up, projects should submit completion information for the project. If not already requested, the Consortium will mail a Final Certification of Development to the project. The checklist includes a Project Budget Certification, Rental Compliance Report, and other items that may still be needed to complete the file. A physical inspection will be completed on the project, if necessary. An on-site review may be completed to review and confirm the information. At the monitoring meeting, we review the request items from the checklist. We provide time for questions and input. After all information has been reviewed and approved, the project will be completed in the HUD information and disbursement system to obtain the Project Completion and begin the affordability period. Annual At the beginning of each year, the Consortium will confirm contact information and addresses for all HOME assisted projects. The list will be used to send the monitoring notification letter and the Monitoring Checklist to each project. The checklist includes rent rolls, rent schedules, annual audits, insurance certificates, affirmative marketing plans and efforts. The requested information includes the Project Compliance Report. The letter will provide a deadline for returning the information (typically 45 to 60 days). In order to verify information submitted on rents, incomes, marketing, leases, tenant selection and other HOME requirements, the Consortium staff will need to conduct on-site reviews. The review will generally include reviewing at least 20 percent of the HOME assisted unit files. On-site reviews may not visit every project, every year. The Consortium will weigh a number of factors to prioritize on-site reviews. The factors include but are not limited to: the type of project it is; when the last on-site review occurred; has the project had staff turnover; are there current compliance issues; have there been previous compliance issues. An additional letter will be sent out informing the project of the on-site and requesting an appointment for the review. At the monitoring meeting, we review the request items from the checklist. We provide time for questions and input. After the monitoring has been completed, the Consortium will review any findings and notify the property by letter if there are issues and/or concerns that need to be completed in order to be in compliance with the HOME Program regulations. Physical Inspections At the beginning of each year a report is produced to identify the HOME projects that need physical inspections. Projects must be inspected on the following schedule: 1-4 units every three years, 5-25 units every two years and more than 26 units every year. Inspection requests are generated and the County inspectors set up the inspections appointments and Hennepin County Consortium Consolidated Plan FY

12 complete the necessary inspections. Inspection reports note any identified deficiencies. Follow-up is required and additional inspections are completed to verify that any deficiencies were corrected by the owner. Additionally, recipients are asked to send in any other inspections that have been completed on the project in that year. If available they submit them and we review them. They help us get a picture of issues in between our required inspections. Assessment Hennepin County will monitor all rental projects that were completed prior to the annual reporting period. The annual reporting period ends on June 30th. Inspections are completed to ensure that the HOME units meet the Consortium Construction and Rehabilitation Standards. Any deficiencies noted by our inspectors have been corrected by the appropriate agency. ESG Program Standards and Procedures ESG Program monitoring is done by the county s Human Service & Public Health Department. Subgrantee requirements are spelled out in a subrecipient funding agreement. Typically there is only one subrecipient (subgrantee) in each program year. The agreement identifies program reporting and payment requirements including specific services to be provided, documentation and monthly reporting of client case records, along with other requirements of the ESG program and county agreements. Provider costs are reimbursed with ESG funds only when the provider s monthly report is completed, submitted and reviewed for accuracy. Provider outcomes are reported monthly to the county and annually to HUD. Rapid Exit from Shelter, the only program currently funded by ESG, operates as part of a comprehensive program under the Family Homeless Prevention and Assistance Program (FHPAP) to assist homeless families and single adults exit from County paid shelter. As a part of that FHPAP program, program staff meets every other month with county staff and other providers and participates in the FHPAP Advisory committee. Following is a description of the county s contract monitoring process: Each month the ESG expense reports are reviewed to make sure that the money is spent on the correct service categories and in roughly the correct proportions. Monthly expense reports are also reviewed to ensure that the provider is on schedule to spend their entire contracted amount during the correct spending time frames. Monthly reports are also reviewed to ensure that correct levels of service are being provided. Should underspending or under-service occur, the grant manager will contact the provider to ensure the provider is aware of the situation and will work to get back on schedule with their spending or their level of service. On an annual basis, the contract analyst confirms that the provider had been meeting the necessary administrative requirements for contracting with Hennepin County. At least every other year, the contract analyst and the program contract manager will make a contract monitoring site visit to each provider's location. During the site visit, the administrative requirements for contracting with Hennepin County will be reviewed. 14 Hennepin County Consortium Consolidated Plan FY

13 The site visit will also include a review of the spending schedule and level of service delivery. During the site visit, Hennepin County staff also review client files to ensure that eligibility for services is documented, delivery of services is documented, and then expenses are also documented. Hennepin County staff will ask for confirmation on the way that ESG services are staffed. A contract monitoring checklist is used to structure the site visit activities. When the contract monitoring site visit has ended, the visits are documented with a post visit report that lists the site visit participants, the items that were discussed during the visit, any findings and recommendations of the visit, and any other issues, questions or concerns that were discussed along with any necessary time frames for follow up. Lead-Based Paint Hazards Numbers of Impacted Housing Units According to the 2000 Census, approximately 135,000 housing units in suburban Hennepin County were built before It is estimated that approximately 101,000 of these units may contain lead-based paint. 1 This estimate includes approximately 19,650 rental units and 81,400 owner-occupied units. HUD's Comprehensive Housing Affordability Strategy (CHAS) data for 2000 provides a crosstabulation of numerous data items by the household income of the respondent. From these data, it is possible to estimate the number of housing units with lead-based paint hazards occupied by low-income households. Note, however, that not all housing units built prior to 1970, nor all units with lead-based paint, are hazardous. Only testing for lead will provide the information necessary to determine the presence of hazards. Shown below is an estimate of units occupied by low-income households (with incomes 0-50 percent of AMI) by age and housing type that potentially contain lead-based paint was the last year that lead-based paint could be sold. Census data do not provide for the identification of housing units built between 1970 and 1978 and so the year 1970 is used here as a proxy. This data, therefore, understates the potential problem. 2 There are several formulas for estimating lead hazards. The estimates in Exhibit I.2 were derived by multiplying the total number of units occupied by low-income households by the following formulas: 90 percent (+/- 10 percent) of housing units built before 1940 may contain lead based paint; 80 percent (+/- 10 percent) of housing units built may contain lead-based paint; 62 percent (+/- 10 percent) of housing units built between 1960 and 1969 may contain lead-based paint. Hennepin County Consortium Consolidated Plan FY

14 Exhibit I.2 HOUSING UNITS WITH POTENTIAL LEAD HAZARDS OCCUPIED BY LOW-INCOME HOUSEHOLDS Before Renters Owners Renters Owners Renters Owners Bloomington Plymouth Other Suburban Hennepin County 625 1,287 2,702 2,702 5,488 1,291 Total: Suburban Hennepin County 742 1,381 3,102 4,698 6,226 1,694 Source: CHAS Databook, U.S. Census 2000 Consortium Lead Hazard Activities As a recipient of federal funds, the Consortium is required to take all necessary actions to comply with the requirements for lead-based paint risk assessment, notification, inspection, and correction of deteriorated or defective surfaces of the Lead Safe Housing Rule (section 1012/1013 of Title X: The Residential Lead-Based Paint Hazard Reduction Act of 1992 of the Housing and Community Development Act of 1992). The county has implemented the Lead Safe Housing rule including the evaluation of dwellings, the reduction of lead-based paint hazards, and the notifications to occupants. The regulations target units that were built prior to 1978 and are occupied by persons in an atrisk group, including children six and under and pregnant women. The county has fully integrated the lead based paint regulations into its existing single-family rehabilitation programs. The county is now working to make sure contractors are trained in the new EPA Renovation, Repair, and Painting Rule. In addition, the county has applied for and received seven HUD-funded lead hazard control grants totaling over $21 million, beginning in October 1, 2003 and currently set to run through December 31, These grants demonstrate the county s continued efforts to provide affordable and safe housing to its residents. Through the end of 2009 the grants have created 1578 lead-safe units for families in Hennepin County. The grants provide funds for testing and relocation cost and up to $8000 in grants for lead-based paint hazard reduction. The recruitment prioritizes families with children with elevated blood lead levels. However the program also tries to make units lead-safe before children are poisoned by targeting Housing Choice Voucher rental units and low income home owners. The funds may be used throughout Hennepin County. Six members of the county staff are licensed risk assessors, abatement supervisors and project designers. Rehabilitation program design changes such as project planning, inspection, and monitoring have all been modified and adjusted to incorporate the requirements pertaining to the Lead Safe Housing Rule in both the rehabilitation process and the administration of lead hazard control grants. The county draws from a small group of contractors who are qualified, willing and able to perform the lead hazard reduction work 16 Hennepin County Consortium Consolidated Plan FY

15 properly. The county also has an ongoing relationship with its own health department to assist with the rehabilitation activities when an elevated blood level (EBL) income-eligible client is identified in a suburban community. Certified external consultants are also used on a case-by-case basis in both single and multi-family rehabilitation projects. The following map identifies cases of children under the age of six with elevated blood lead levels throughout Hennepin County. Hennepin County Consortium Consolidated Plan FY

16 Exhibit I.3 Elevated Blood Lead Levels => 10 ug/dl In Hennepin County Suburban Area Children < 6 Years Source: Minnesota Department of Health 18 Hennepin County Consortium Consolidated Plan FY

17 Affirmatively Furthering Fair Housing Analysis of Impediments Entitlement jurisdictions are required to certify to the U.S. Department of Housing and Urban Development (HUD) that they will affirmatively further fair housing. The certification has three elements, which require that government entities: 1. Complete an Analysis of Impediments to Fair Housing Choice; 2. Take actions to overcome the effects of any impediments identified through the analysis; and 3. Maintain records reflecting the analysis and actions taken. An Analysis of Impediments to Fair Housing Choice (AI) is an examination of the impediments or barriers to fair housing that affect protected classes within a geographic region. HUD defines impediments to fair housing choice in terms of their applicability to state and federal law. In Minnesota, this would include: Any actions, omissions or decisions taken on the basis of race, color, religion, sex, disability or handicap, familial status, national origin, creed, sexual or affectional orientation, marital status, and receipt of public assistance which restrict housing choices or the availability of housing choice. Any actions, omissions or decisions which have the effect of restricting housing choices or the availability of housing choice on the basis of the protected classes listed previously. The AI process involves a thorough examination of a variety of sources related to housing, affirmatively furthering fair housing, the fair housing delivery system and housing transactions, which affect people who are protected under fair housing law. AI sources include census data; home mortgage industry data; federal, state and local housing complaint data; surveys of housing industry experts and stakeholders; and other housing information. Regional Analysis of Impediments: In 2009 the Consortium, along with other metro-area entitlement jurisdictions and stakeholders working together under the direction of the Fair Housing Implementation Council, prepared a new Regional Analysis of Impediments to Fair Housing. The previous AI was done in The Analysis is for the Five-Year Consolidated Plan period. The Fair Housing Implementation Council (FHIC) is the lead agency representing city and six county entitlement jurisdictions. Following an extensive Request for Proposal process, Western Economic Services, LLC based in Portland, Oregon was selected to update the Regional Analysis of Impediments. The AI was completed in October Public Involvement: One method used to gather public input about perceived impediments to fair housing was a Web-based survey to gain feedback from more than 300 stakeholders throughout the region. Hennepin County Consortium Consolidated Plan FY

18 The purpose of the survey was to gain a more qualitative analysis of the knowledge, experiences, opinions and feelings of stakeholders regarding fair housing, and to gauge the stakeholders understanding of affirmatively furthering fair housing. Other methods included use of focus groups, forums and public presentations of the draft report. Three fair housing focus groups were held on specific topics; home purchase finance industry, zoning and public policy, and rental market industry. Two fair housing forums were held to present preliminary findings of the AI to the public, afford the public the opportunity to assist in guiding the AI development process, provide the public an opportunity to express their personal perspective, commentary and testimony. Lastly, the draft report was available for public review for a 30-day comment period. During this time three public presentations of the draft report were done to provide additional opportunity for input on the draft AI and development process. The FHIC conducted a final review meeting in September All concluding public input and comments were incorporated into the final report. The final report and technical appendix are available on the Hennepin County website - Identified Impediments to Fair Housing Choice: The regional AI uncovered several issues that can be considered barriers to affirmatively furthering fair housing and, consequently, impediments to fair housing choice. In addition, the AI attempts to breakdown issues by entitlement jurisdiction. Many of the regional issues are also issues at the local jurisdiction level. Following is a composite of issues/impediments identified in suburban Hennepin County that can affect current and prospective residents. Note: while many of the impediments are beyond the direct control and authority of the county and suburban cities, the Consortium will: 1. Insufficient interest in fair housing, which, in turn, implies a lack of desire to affirmatively further fair housing or entertain fair housing planning. 2. Lack of sufficient fair housing outreach and education. 3. While some protected classes, or a portion of the some protected classes, have avenues for advocacy, there is insufficient system capacity to address the level of prospective demand for fair housing services. 4. Lack of an effective referral system for fair housing concerns. 5. Lack of understanding of what qualifies as a fair housing issue, particularly as it relates to landlord/tenant disputes and affordable housing production. 6. Discriminatory terms and conditions for protected classes in the rental market, specifically racial and ethnic minorities and persons with disabilities. 7. Discrimination of Section 8 voucher holders. 8. Some zoning and land use regulations by units of local government may be construed to have a disparate impact. 9. Some local government housing actions and/or policies may not be in the spirit of affirmatively furthering fair housing. 20 Hennepin County Consortium Consolidated Plan FY

19 10. Policies and practices that have contributed to concentrations of protected classes in some areas. 11. Disproportionately high denial rates for racial and ethnic minorities in the home mortgage industry. 12. Denial rates for home mortgages are disproportionately high in low-income areas. 13. Lender originated HALs (high interest rate loans) are disproportionately targeted to minority racial and ethnic groups, leading to increased foreclosure risks for this group. Suggested actions to address these issues/impediments include: 1. Stimulate additional fair housing outreach and education activities. 2. Enhance coordination of fair housing activities, including a better referral system. 3. Enhance homebuyer education. 4. Encourage inclusive housing location policies for both private and public housing providers. 5. Enhance outreach and education to rental housing providers and continue supporting compliant-based testing and enforcement. 6. Work with other entitlement jurisdictions, including the State, to establish a coordinated, consistent reporting system to better document and track fair housing complaints, enforcement and testing, and outreach and education activities. 7. Encourage local government actions that are more in the spirit of affirmatively furthering fair housing, such as minimizing NIMBYism (Not In My Back Yard.) Fair Housing Strategies and Goals Strategies Prioritize use funding allocated by the Hennepin County Consortium to its Fair Housing Initiative to address identified impediment. Require affirmative marketing plans for recipients of HUD entitlement funds, as appropriate. Provide CDBG funding for a tenant hotline, tenant advocacy and mortgage foreclosure and prevention services. Use the ESG Program, which supports the Family Homeless Prevention and Assistance Program, to assist homeless families living in shelters to locate permanent housing in non-concentrated areas and to overcome barriers that may impede this effort. Hennepin County will continue to provide other funding and services for projects that respond to housing barriers experienced by persons served by county-funded social services. Hennepin County Consortium Consolidated Plan FY

20 Hennepin County will continue to emphasize municipal responsibilities for approving, siting, and/or operating publicly-assisted housing, and will utilize its entitlement eligibility resources and resources of the Hennepin County Housing and Redevelopment Authority available to support the development of affordable housing. Goals Hennepin County and Consortium Cities will continue to make entitlement funding available for fair housing services, including education and outreach efforts, enforcement and testing and special projects. The Consortium will continue to coordinate fair housing actions with the FHIC to equitably address fair housing barriers regionally and locally and provide funding to support these actions. Specific fair housing goals and actions will be identified in the Consortium s Annual Action Plan beginning with the 2010 Plan. Performance Measurement System In developing the Plan, HUD has encouraged grantees to incorporate performance measures into the five-year and annual Action Plans. The purpose is to make the Plan more resultsoriented and useful to grantees in assessing progress toward addressing housing and community development needs. Also, it would provide HUD a uniform method of reporting information, aggregated across all grantees, to Congress. In response to this initiative, the Consortium will develop specific performance measures within a framework developed by the Joint Grantee/HUD/Office of Management and Budget (OMB) Performance Measurement Working Group. The framework is described later in this section. Specific performance measures are not described in this Plan. The Consortium intends to include specific performance measures in the annual Action Plan, beginning with Program Year Actual performance will be measured and reported in the Consolidated Annual Performance and Evaluation Report (CAPER). This report is prepared by the Consortium and submitted annually to HUD. As background, performance measurement is simply an organized process for gathering information to determine how well programs and projects are meeting needs, and then using that information to improve performance and better target resources. Performance measurement systems typically include the following components to make a clear connection between identified goals and desired outcomes. Goals are the proposed solutions to problems or needs identified by the grantee during the consolidated planning process. Inputs include resources dedicated to or consumed by the program such as money, staff, equipment, and supplies. 22 Hennepin County Consortium Consolidated Plan FY

21 Activities are what the program does with inputs to fulfill its mission. Activities include the strategies, techniques and other efforts to address the problems identified by the grantee. Outputs are the direct products of the program s activities. They are usually measured in numerical terms, such as number of low-income households served, number of units constructed or rehabilitated, number of people provided services, etc. Outcomes are benefits that result from a program. Outcomes typically relate to a change in conditions, status, attitudes, skills, knowledge or behavior. Common outcomes could include improved quality of life for program participants, improved quality of housing stock, or neighborhood revitalization. GOALS Proposed solutions to identified problems or needs. Preserve existing housing stock Improve neighborhood stability INPUTS Resources dedicated to or consumed by program. Money Staff Contractors Lead testing ACTIVITIES What program does with inputs to fulfill its mission/purpose. Intake/loan applic. Inspection Rehab specifications Loan approval Contractor selection, etc OUTPUTS Direct products of activities Number of homes rehabilitated Number of customers served OUTCOMES Benefits that result from program. Increased percentage of standard housing units Revitalization of neighborhood To measure outcomes, indicators will be identified that relate to goals established in the Consolidated Plan. Indicators are used to measure performance. The development of a performance measurement system will continue to be an evolving process, in which the Consortium continues to work with its various partners to develop a results-oriented system that will provide meaningful information at the local and national level. The Framework HUD MAIN OBJECTIVES Create a Suitable Living Environment Provide Decent, Affordable Housing Create Economic Opportunities Hennepin County Consortium Consolidated Plan FY

22 The Consortium will determine under which objective to report the outcomes from projects and activities, and would choose the outcome category(ies) based on purpose of project or activity. The intent is to establish three-outcome categories -- Accessibility, Affordability and Sustainability, under which project/activity outcomes would be reported. Outcomes Accessibility Affordability Sustainability A basic formula that represents both the logic and practical approach of this outcome framework follows: Examples: Output (## s) + Outcome Statement + Activity = Objective Five hundred (500) senior households + have access to + chore services = for the purpose of creating a suitable living environment. Fifty (50) households + have affordable housing + through a down-payment assistance = program for the purpose of creating decent, affordable housing. One hundred (100) persons + have access to new jobs + through extension of a water line to a business = for the purpose of creating economic opportunity. Indicators and outputs are the nuts and bolts of the outcome framework and need to be considered carefully as new data and reporting requirements that could result from instituting a performance measurement system. Summary of Objective and Outcome Expectations Consistent with HUD s performance measurement initiative, the Hennepin County Consortium will summarizing how it proposes to allocate HUD CDBG, HOME and ESG Program funding and what outcomes are expected, i.e., how low-income households will benefit. However, specific information on Urban Hennepin County or each of the entitlement cities performance measure system is included in their section of the annual Action Plans. 24 Hennepin County Consortium Consolidated Plan FY