action plan year 2014-2015 publiccommentv11 city is one of the nation’s fastest growing cities and...

CONSOLIDATED PLAN FY 2010 ‐ 2015

PY 2014‐2015 ACTION PLAN PUBLIC COMMENT VERSION 1.1

DRAFT

Marni Sawicki, Mayor James Burch, Councilmember, District 1 John Carioscia, Councilmember, District 2 Lenny Nesta, Councilmember, District 3 Richard Leon, Councilmember, District 4 Rana Erbrick, Councilmember, District 5 Rick Williams, Councilmember, District 6

Derrick L. Donnell, Ed.D. Councilmember, District 7

John Szerlag, City Manager

Citizen Advisory Board(CAB) for Community Development Block Grant

Iris Lugo Carmen Salome Arnold Small

Robert Renshaw Charlotte Yager

Contact Person: Amy Yearsley, AICP, Housing Coordinator Address: Department of Community Development

City of Cape Coral PO Box 150027

Cape Coral, Florida 33915‐0027 Telephone: 239‐573‐3182

Email: [email protected]

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Fifth Program Year Action Plan

The CPMP Fifth Annual Action Plan includes the SF 424 and Narrative Responses to Action Plan questions that CDBG, HOME, HOPWA, and ESG grantees must respond to each year in order to be compliant with the Consolidated Planning Regulations. The Executive Summary narratives are optional.

Narrative Responses

GENERAL

Executive Summary 91.220(b) The Executive Summary is required. Include the objectives and outcomes identified in the plan and an evaluation of past performance. The Program Year 5 Action Plan provides details on the specific activities the City will undertake during the PY 2014‐2015 to implement its Five Year Strategic Plan. Because this is the fifth year of the Five Year Strategic Plan, a majority of the narrative responses required for the Action Plan mirror the responses for the Five Year Strategic Plan. Community Profile The City of Cape Coral is located on the southwest coast of Florida. The City was incorporated in August 1970 and is a 119.5 square mile pre‐platted (subdivided) community, with approximately 400 miles of fresh and salt water canals and over 1,370 miles of roads. According to the 2000 U.S. Census, the City of Cape Coral’s population was 102,286, an increase of thirty‐six percent (26%) or 27,295 persons from the 1990 Census figures. The City is one of the nation’s fastest growing cities and the third largest Florida city in land mass. The City’s population grew to 154,305 according to the 2010 U.S. Census. This is an increase of over 50% or 52,019 persons from the 2000 Census. Cape Coral was the fourth fastest growing city with populations over 100,000 in the Nation in 2006. Beginning in 2008, however, it was listed by Realtytrac.com in the top 10 of cities with the highest foreclosure rates in the nation. The combination of the growth rate and housing foreclosure issues brought forth both challenges and opportunities. The City itself is now rebounding with consistent increases in traditional sales, prices and values. Today, the Cape Coral market has gone from having one of the worst foreclosure rates in the country to one of the fastest appreciating markets in the state of Florida. In Lee County, the median sale price improved 19 percent year over year in January 2014, to $ 185,000. The average sale price improved 12 percent to $ 312,000. (Florida Weekly, Housing is Back). This increase in housing price is again making it difficult for low and moderate income residents to buy a home in Cape Coral.

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CHANGE IN POPULATION and HOUSEHOLDS 1990 ‐ 2010

1990 2000 2010

Population 74,991 102,286 167,208

Households 29,749 40,417 63,497 Source: U.S. Census Bureau (1990 & 2000) 2010 Estimates, Shimberg Center for Housing Studies, University of Florida

2009 U.S. Metro Foreclosure Market Data Properties with Foreclosure Filings

Rate Rank

Metro Name Total 1/every X HU (rate)

%HU with FC Filings

%Change from 2008

%Change from 2007

‐‐ U.S. Total 2,824,674 45 2.21 21.21 119.67

1 Las Vegas‐Paradise, NV Total 94,682 8 12.04 41.12 212.19

2 Cape Coral‐Fort Myers, FL Total 42,734 8 11.87 4.13 234.12

3 Merced, CA Total 8.389 10 10.10 1.18 124.85

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Riverside‐San Bernardino‐Ontario, CA Total 126,376 11 8.80 12.55 143.90

5 Stockton, CA Total 19,540 12 8.62 ‐7.51 84.22

6 Modesto, CA Total 14,812 12 8.53 ‐0.48 101.09

7 Orlando‐Kissimmee, FL Total 72,141 12 8.17 54.01 357.86

8 Phoenix‐Mesa‐Scottsdale, AZ Total 133,809 12 8.03 36.98 343.12

9 Port St. Lucie, FL Total 15,530 12 7.58 21.52 217.55

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Miami‐Fort Lauderdale‐Pompano Beach, FL Total 172,894 14 7.16 43.50 198.28

Source: Realty Trac HUD Requirements The City of Cape Coral PY 2014‐2015 One Year Action Plan was prepared in accordance with 24CFR Sections 91.100 through 91.230 of the U.S. Department of Housing and Urban Development’s (HUD) Consolidated Plan regulations. The Consolidated Plan combines in one report important information about the City of Cape Coral’s demographics and economic activity as well as detailed information on the housing and job needs of its residents. For each succeeding year, the City of Cape Coral is required to prepare a one‐year Action Plan to notify citizens and HUD of the City’s intended actions during that particular fiscal year. This plan includes citizen and stakeholder input and is due to HUD no later than August 8, 2014.

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Evaluation of Past Performance The City reports on its progress towards goals set in the Consolidated Plan and Action Plans in the Consolidated Annual Performance and Evaluation Report (CAPER). The fiscal year 2013‐2014 CAPER is due to HUD December 31, 2014. The overall goals of the City’s Action Plan for Program Year 2012‐2013 were to provide and sustain decent housing, and a suitable living environment, and to expand economic opportunities for the lower income residents.

To achieve the above goals with the City’s limited financial resources, the following priorities were developed and objectives accomplished by coordination of the private sector, City resources, and the City’s Planning Division:

Decent housing: Maintain and increase the affordable housing stock in the City by providing housing rehabilitation programs and affordable housing ownership programs to serve the extremely low, low, and moderate income population. Suitable living environment: Provide support to the non‐profit agencies that serve the elderly, homeless, and handicapped, as well as the extremely low, low, and moderate income residents of the City. The services identified include assistance for the hearing impaired, developmentally disadvantaged, homeless or near homeless, victims of domestic violence and financial counseling services. Expand the economic opportunities of the extremely low, low and moderate income persons: Support of eligible business in the City with financial or supportive measures to create additional job opportunities. This includes financial assistance, job training programs, technical business assistance and infrastructure necessary to support the business.

FY 2012‐2013 Outcomes:

19 substandard owner occupied units were rehabilitated 1 unit was connected to City water and sewer 2 foreclosed housing units were purchased and will be rehabilitated utilizing CDBG funds

7 homes were purchased rehabilitated and resold to low income households by two different housing agencies utilizing CDBG funds.

13 foreclosed homes rehabilitated with NSP1 and NSP3 funds were sold.

1 home purchased a rehabilitated with CDBG dollars was available for sale to low moderate income households at the end of the reporting period

4,745 low/moderate income Cape Coral households were provided services through seven (7) different programs

Eighteen (18) income qualified residents attended training to open new businesses. Thirteen (13) new businesses were created.

General Questions 1. Describe the geographic areas of the jurisdiction (including areas of low income families and/or

racial/minority concentration) in which assistance will be directed during the next year. Where appropriate, the jurisdiction should estimate the percentage of funds the jurisdiction plans to dedicate to target areas.

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2. Describe the basis for allocating investments geographically within the jurisdiction (or within the EMSA

for HOPWA) (91.215(a)(1)) during the next year and the rationale for assigning the priorities. 3. Describe actions that will take place during the next year to address obstacles to meeting underserved

needs. 4. Identify the federal, state, and local resources expected to be made available to address the needs

identified in the plan. Federal resources should include Section 8 funds made available to the jurisdiction, Low‐Income Housing Tax Credits, and competitive McKinney‐Vento Homeless Assistance Act funds expected to be available to address priority needs and specific objectives identified in the strategic plan.

Action Plan General Questions response: Geographic Allocation of the Jurisdiction/Basis of Allocating Investments Currently, HUD sets the low/moderate income threshold for the City of Cape Coral at 39.2%. The City of Cape Coral has 29 census block groups that meet the income threshold. However, the minority/low income populations are dispersed throughout the City in such that no one geographic area can meet HUD’s jurisdiction requirements of low income or racial/ethnic minority concentration at this time. The City anticipates that these block groups will significantly change once 2010 Census data is released by the US Department of HUD. The priorities in the allocation of the resources the City expects to receive would be located throughout the community. There are no neighborhoods where there are extreme concentrations of slum or blight, however, the City of Cape Coral does have an area designated as blighted under Florida Statutes. Only 29 Census Blocks qualify as meeting the low‐moderate income criteria as provided in 24 CFR 570.208 (a), (1), (ii). If projects are funded which must meet area low‐moderate income benefit criteria, they will be in these block groups.

Qualifying Census Tract and Block Groups

Census Tract Block Group

010408 2

010307 2

010304 1

010202 9

010302 3

010803 1

010306 3

010201 5

010202 7

010502 3

010404 3

010102 6

010404 2

010103 5

010802 1

010201 2

010601 1

010401 3

010302 1

6

010502 6

010602 3

010803 4

010202 8

010201 7

010801 3

010201 3

010305 1

010802 2

010307 3

The primary distribution of the population benefiting from the grant assistance program will be City‐wide and in most cases extremely low, low, and moderate income limited clientele, elderly, handicapped or homeless persons will be served. The City’s housing programs are concentrated on scattered sites throughout the City. The priority community development needs and public service locations will be throughout the City. The basis for establishing the priority for each category will be through needs analysis and public input received during the citizen participation process. The maps indicating the locations of sidewalk, housing and public services projects for PY 2014‐2015 are located in Appendix A. The maps indicating racial/ethnic concentrations and the low/moderate income block groups are located in Appendix A. ACTIONS TO ADDRESS OBSTACLES TO MEETING UNDERSERVED NEEDS The main obstacle to meeting under‐served needs is primarily that the needs outweigh the available financial resources. The City will continue to explore ways to leverage funding and partnership with other agencies to accomplish its housing and community development goals. AVAILABLE RESOURCES AND PROPOSED ACTIVITIES Available Resources:

CDBG ALLOCATION (PROGRAM YEAR 2013) $859,788

Reallocation of Prior Years CDBG Funding (Various Years 2010‐2012) $132,078

TOTAL FUNDING AVAILABLE $991,866

Proposed Activities:

ACTIVITY SUBRECIPIENT CATEGORY AMOUNT

Acquisition/rehabilitation/resale Cape Coral Housing Development

Housing $298,954

Acquisition/rehabilitation/resale Habitat for Humanity Housing $129,954

Owner‐occupied Housing Rehabilitation

Cape Coral Housing Development

Housing $129,954

Utility Connection Program Housing $40,000

Sidewalks (Year 2) City of Cape Coral Public Works Public Facilities $42,078

Emergency Assistance Cape Coral Caring Center Public Services $19,494

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Emergency Shelter Abuse Counseling and Treatment

Public Services $30,505

Special Needs (Transportation) City of Cape Coral Parks and Recreation


Emergency Utility Assistance Community Cooperative Ministries


Public Services Grace Community Center Public Services $13,493

Special Needs (Deaf Services) Deaf Service Center Public Services $17,495

Senior Services Dr. Piper Center Public Services $14,993

Economic Development Goodwill Industries of SWFL Economic Development

$40,000

Program Planning & Administration City of Cape Coral Administration $171,958

TOTAL $991,866

The complete description of each activity is listed in the proposed project tables. Program income shall be allocated to the agency that generated such income. In the event the agency no longer exists, program income generated by housing activities will be budgeted to the same activity. The City reserves the right to retain a portion of the income for administrative, public services and/or any other eligible activity subject to substantial amendment policies.

Managing the Process 1. Identify the lead agency, entity, and agencies responsible for administering programs covered by the

consolidated plan. 2. Identify the significant aspects of the process by which the plan was developed, and the agencies,

groups, organizations, and others who participated in the process. 3. Describe actions that will take place during the next year to enhance coordination between public and

private housing, health, and social service agencies. Action Plan Managing the Process response: LEAD AGENCY The City of Cape Coral Department of Community Development ‐ Planning Division is responsible for the planning and coordination of the City’s Five‐Year Consolidated Plan including Annual Action Plans. This office operates and administers the City’s Community Development Block Grant (CDBG), Neighborhood Stabilization Program (NSP), and state affordable housing (State Housing Initiatives Partnerships) programs. PLAN DEVELOPMENT PROCESS The City of Cape Coral’s Consolidated Plan/Annual Action Plan was developed through a collaborative effort of public, private and non‐profit organizations. All local governments were consulted and participated in preparation and review of the plans. Housing and social service organizations, other public agencies that were surveyed/consulted in the development of the plan include:

Cape Coral Housing Development Corporation

Cape Coral Caring Center

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Abuse Counseling and Treatment, Inc.

Community Cooperative Ministries, Inc.

Dr Piper Senior Center

City of Cape Coral Parks and Recreation Department

City of Cape Coral Public Works Department

Deaf Services Center

Peace by Piece Learning Center

Center for Independent Living

Renaissance Manor, Inc.

Habitat for Humanity

Lee County Health Department

Lee County Homeless Coalition

Lee County Housing Authority Housing Authority of the City of Fort Myers

CONSULTATION AND COORDINATION The City participates in a variety of coordination efforts that involve other local governments, public and assisted housing providers, health care agencies, mental health organizations, service providers, transportation providers, economic development agencies, employment agencies, and the private sector. The Florida Department of Children and Families was consulted for direction and data on state efforts for youth, elderly, the disabled, and the homeless. Department staffs were consulted for updates on programs in these areas. In addition, the numerous non‐profit agencies working for these populations were consulted through the Providers Survey and follow‐up contacts. In the case of homelessness, consultation occurred with the Lee County Coalition for the Homeless, Florida, Inc. in preparation of the Consolidated Plan. Homeless Strategy The City of Cape Coral has coordinated a partnership with the City of Fort Myers and Lee County to provide a countywide approach to homelessness. The City of Cape Coral joined the effort of Lee County by committing CDBG funds to the County‐wide Ten (10) Year Plan to End Homelessness. This approach covers the entire continuum of care from emergency shelter to transitional housing to independence and finally home ownership for the entire local area. Lee County is the lead agency for the Continuum of Care (CoC) program and Emergency Shelter Grant (ESG) programs in Fort Myers – Cape Coral Metropolitan Statistical Area (MSA). Lead‐Based Paint Consultation In preparation for the Consolidated Plan, the Lee County Health Department was consulted to analyze data on lead‐based paint poisoning cases for the last 5 years by zip code locations. Adjacent Government Coordination The City of Cape Coral along with the City of Fort Myers and Lee County all worked on the updating the Analysis of Impediment to Fair Housing for the entire area to coordinate efforts for promoting fair housing in the area. The City of Cape Coral will notify both the City of Fort Myers and Lee County on priority non‐community development needs that go beyond the City limits of Cape Coral. The City coordinates with the City of Fort Myers and Lee County on items of mutual interest.

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HOPWA In August 2005, the City of Cape Coral received notification from the U.S. Department of Housing and Urban Development that the City has qualified to receive a Housing Opportunities for Persons with AIDS (HOPWA) formula grant on behalf of the Cape Coral – Fort Myers, Metropolitan Statistical Area in federal FY 2006. The City chose to enter into an agreement with HUD and the State of Florida Department of Health for the funds to be administered at the State level, by the State of Florida Department of Health to ensure uninterrupted services to persons living with HIV/AIDS. Public Housing Consultations Public housing agencies operating in Lee County include the Lee County Housing Authority (LCHA) and the Housing Authority of the City of Fort Myers (HACFM). In preparation for the Consolidated Plan, the Five‐Year Public Housing Plans of the both housing authorities were analyzed along with current year funding and waiting lists for all agencies.

Citizen Participation 1. Provide a summary of the citizen participation process. 2. Provide a summary of citizen comments or views on the plan. 3. Provide a summary of efforts made to broaden public participation in the development of the

consolidated plan, including outreach to minorities and non‐English speaking persons, as well as persons with disabilities.

4. Provide a written explanation of comments not accepted and the reasons why these comments were not accepted.

*Please note that Citizen Comments and Responses may be included as additional files within the CPMP Tool.

Action Plan Citizen Participation response: CITIZEN PARTICIPATION PROCESS The City of Cape Corals’ Action Plan PY 2014 was developed through collaborative effort of public, private and non‐profit organizations. The City’s Citizens’ Advisory Board‐Community Development Block Grant (CAB‐CDBG) held two meetings to solicit citizen input and comments. All meeting notices were published in the local newspapers and meeting invitations were sent to social service agencies that serve low income people in the City of Cape Coral. There were total of four public meetings/hearings to solicit public input and comments. Additionally, the draft one year action plan and recommended funding levels was posted on the City of Cape Coral website at www.capecoral.net for a period of thirty‐days and a notice of availability for public comment was placed in the Fort Myers News Press. The City’s Citizen Participation Plan, meeting minutes, adopting resolution, public comments, and affidavits of meeting notice are included in Appendix B. SUMMARY OF CITIZEN COMMENTS Citizen Comments on the City of Cape Coral Consolidated Plan for the Annual Action Plan for HUD PY 2014 is included as Appendix B. EFFORTS TO BROADEN PUBLIC PARTICIPATION/OUTREACH The City of Cape Coral’s PY 2014 Action Plan was the focus of four major public meetings. The dates and

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times of public hearings and meetings were established to ensure adequate notice to the residents and organizations of the City. All notices for public hearings, and workshops were published in the local newspaper, the Fort Myers News Press and posted on the City’s website. Public notices were forwarded to social service agencies and distributed as handouts at agency meetings. The Plans were made available for public inspection at the City Clerk’s office. Additionally, the draft one year Action Plan and recommended funding levels was posted on the City of Cape Coral website at www.capecoral.net for a period of thirty‐days. The City of Cape Coral encourages citizens to participate in the development, of the Plan, any substantial amendments to the Plan, and the annual performance report. The City encourages participation among all citizens, especially low and moderate income, minority and, non‐English speaking persons, as well as persons with disabilities. Participation of residents of public and assisted housing is also encouraged through cooperation with public housing agencies. The City also provides technical assistance to organizations and individual representatives of targeted groups who are interested in submitting a proposal for funding. PUBLIC COMMENTS All public comments will be accepted and will be noted in this document and the appendices.

Institutional Structure 1. Describe actions that will take place during the next year to develop institutional structure. Action Plan Institutional Structure response: The City of Cape Coral's institutional structure includes private industry, non‐profit organizations, and public institutions. The City utilizes various City Departments and several non‐profit organizations that partner with the private sector and the community at large to deliver services and benefit lower income families and individuals.

Monitoring 1. Describe actions that will take place during the next year to monitor its housing and community

development projects and ensure long‐term compliance with program requirements and comprehensive planning requirements.

Action Plan Monitoring response: MONITORING OF PROGRAM At least once annually, or as set forth in the City’s Monitoring Policy, the City will perform on‐site monitoring for federal, state and contract compliance of each of its subrecipients. In addition, the City will monitor the progress of subrecipients accomplishments through correspondence, site visits, and monthly, quarterly, and annual reports submitted by the subrecipients. The City developed and follows “Community Development Block Grant (CDBG) Subrecipient Monitoring Policy and Procedures” which ensure compliance with 24 CFR 570 which governs the CDBG program. This includes program performance, financial performance and regulatory performance. These efforts ensure long term compliance with the requirements of HUD formula grant programs. Technical assistance is provided to subrecipients to maintain compliance with federal, state and contract standards. If a compliance issue is discovered, appropriate actions will be taken to resolve the issue.

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Community Development Block Grant (CDBG) Subrecipient Monitoring Policy and Procedures is included in Appendix C.

Objectives In response to HUD Community Planning and Development (CPD) Notice: CPD‐03‐09, Development of State and Local Performance Measurement Systems for Community Planning and Development (CPD) Formula Grant Program, the City of Cape Coral has developed Performance Measurement Systems. There are two components of performance measurement:

Productivity

Program impact Performance measurement is done in two stages, first information is collected to determine how well programs and projects are meeting needs, and then that information is analyzed to determine performance gaps and then available resources are applied to these gaps. Strategy for Performance Measurement Beginning with the FY 2006 CDBG application cycle, the City required all applicants to use the “outcome and performance measurement model” in their application and future reporting. The overall goals to be achieved through the outcome and performance measurement model are:

Improve programs and services offered by the City and its subrecipient agencies

Provide a record of accountability to the community

Provide information on how well the program is achieving its goals and objectives Outcome and Performance Measurement Model is included in Appendix D.

Objective Category Decent Housing Which includes:

Objective Category: Suitable Living Environment Which includes:

Objective Category: Expanded Economic Opportunities Which includes:

assisting homeless persons obtain affordable housing

improving the safety and livability of neighborhoods

job creation and retention

assisting persons at risk of becoming homeless

eliminating blighting influences and the deterioration of property and facilities

establishment, stabilization and expansion of small business (including micro-businesses)

retaining the affordable housing stock

increasing the access to quality public and private facilities

the provision of public services concerned with employment

increasing the availability of affordable permanent housing in standard condition to low-income and moderate-income families, particularly to members of disadvantaged minorities without discrimination on the basis of race, color, religion, sex, national origin,

reducing the isolation of income groups within areas through spatial deconcentration of housing opportunities for lower income persons and the revitalization of deteriorating neighborhoods

the provision of jobs to low-income persons living in areas affected by those programs and activities under programs covered by the plan

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familial status, or disability increasing the supply of

supportive housing which includes structural features and services to enable persons with special needs (including persons with HIV/ADOS) to live in dignity and independence

restoring and preserving properties of special historic, architectural, or aesthetic value

availability of mortgage financing for low income persons at reasonable rates using non-discriminatory lending practices

providing affordable housing that is accessible to job opportunities

conserving energy resources and use of renewable energy sources

access to capital and credit for development activities that promote the long-term economic social viability of the community

Lead‐based Paint 1. Describe the actions that will take place during the next year to evaluate and reduce the number of

housing units containing lead‐based paint hazards in order to increase the inventory of lead‐safe housing available to extremely low‐income, low‐income, and moderate‐income families, and how the plan for the reduction of lead‐based hazards is related to the extent of lead poisoning and hazards.

Action Plan Lead‐based Paint response: The City’s Homebuyer assistance program and single‐family owner‐occupied rehabilitation program that rehabilitate homes constructed prior to 1978 will be provided a complete visual assessment of all painted surfaces to identify deteriorated paint, and will be provided paint stabilization of deteriorated painted surfaces, and a clearance examination, as required. Lead‐based paint hazards information will be provided to all homebuyers assisted by these programs. The City will follow its Lead‐Based Paint Hazards Policy in the administration of the City’s Housing program to reduce and eradicate lead‐based housing units in the City.

HOUSING

Specific Housing Objectives *Please also refer to the Housing Needs Table in the Needs.xls workbook.

1. Describe the priorities and specific objectives the jurisdiction hopes to achieve during the next year.

2. Describe how Federal, State, and local public and private sector resources that are reasonably expected to be available will be used to address identified needs for the period covered by this Action Plan.

Action Plan Specific Objectives response: Goal: Provide and sustain decent housing for the lower income residents. Strategy 1: Provide additional affordable housing units in the City of Cape Coral. This would include rental units, home ownership opportunities, elderly rental units, and housing for persons with special needs. Objective one: Provide an additional eight (8) units of single‐family affordable housing additional units.

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Objective two: Rehabilitate approximately twelve (12) existing single‐family homes owned and occupied by extremely low and low income families. Objective three: Acquire, rehabilitate and resale approximately ten (10) units of foreclosed and/or vacant homes through the NSP program. Objective four: Connect twenty (20) homes to City water and sewer. Objective five: Support private sector endeavors to provide additional affordable housing units in the City. Strategy 2: Reduce the barriers to affordable housing in the City of Cape Coral. Objective one: Review the City’s Local Housing Assistance Plan each year in order to determine what incentives have been implemented, which are not valid, and what should be implemented in order to increase the stock of affordable housing in the City. Objective two: Monitor the impact of City policy and actions on affordable housing through review of all development plans, codes, regulations, policies and ordinances.

Needs of Public Housing 1. Describe the manner in which the plan of the jurisdiction will help address the needs of public housing

and activities it will undertake during the next year to encourage public housing residents to become more involved in management and participate in homeownership.

2. If the public housing agency is designated as "troubled" by HUD or otherwise is performing poorly, the jurisdiction shall describe the manner in which it will provide financial or other assistance in improving its operations to remove such designation during the next year.

Action Plan Public Housing Strategy response: The Public Housing Agency Plan for both the Lee County Housing Authority (LCHA) and the Housing Authority of the City of Fort Myers (HACFM) were reviewed. Both agencies cited increasing the availability of decent, safe, and affordable housing opportunities as one of their goals. To obtain these goals, both agencies will offer education programs along with credit rebuilding and job training as needed. HACFM has been designated as a HUD approved housing counseling agency and holds credit building workshops, homeownership and foreclosure prevention seminars throughout the year for residents and the public. Section 8 homeownership vouchers are available to qualified buyers and have been layered with City housing programs. LCHA was designated a “Standard Performer” and HACFM was designated a “High Performer” by HUD in 2009.

Barriers to Affordable Housing 1. Describe the actions that will take place during the next year to remove barriers to affordable housing. Action Plan Barriers to Affordable Housing response: ACTIONS TO REDUCE BARRIERS TO AFFORDABLE HOUSING

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1. The City has adopted the Local Housing Incentive Plan (LHIP) as required to receive the State of Florida’s Affordable Housing Program funding (State Housing Initiatives Partnership (SHIP) Program). This plan led to the following actions to reduce barriers:

Expedited Permitting ‐ affordable housing projects are assigned priority status and reviewed in an expedited manner

Ongoing review of policies and procedures

Provisions for Transfer of Development Rights

Flexible Density for the Provision of Affordable Housing

Reduction in Street Width Requirements for affordable single family subdivision

Zero‐lot Line Configuration

Inventory of locally owned public lands suitable for affordable housing

2. The City of Cape Coral will research and review alternative methods to financing affordable housing including but not limited to, density incentive programs, linkage fees, and Inclusionary housing ordinances.

3. The City of Cape Coral is utilizing CDBG, NSP, and SHIP funds to provide counseling and financial

assistance to first time income eligible homebuyers to purchase either existing or newly constructed homes.

4. The City is utilizing CDBG and SHIP funds to provide financial assistance to income eligible city

residents to rehabilitate owner‐occupied dwellings.

HOMELESS

Specific Homeless Prevention Elements *Please also refer to the Homeless Needs Table in the Needs.xls workbook.

1. Sources of Funds—Identify the private and public resources that the jurisdiction expects to receive during the next year to address homeless needs and to prevent homelessness. These include the McKinney‐Vento Homeless Assistance Act programs, other special federal, state and local and private funds targeted to homeless individuals and families with children, especially the chronically homeless, the HUD formula programs, and any publicly‐owned land or property. Please describe, briefly, the jurisdiction’s plan for the investment and use of funds directed toward homelessness.

2. Homelessness—In a narrative, describe how the action plan will address the specific objectives of the Strategic Plan and, ultimately, the priority needs identified. Please also identify potential obstacles to completing these action steps.

3. Chronic homelessness—The jurisdiction must describe the specific planned action steps it will take over the next year aimed at eliminating chronic homelessness by 2012. Again, please identify barriers to achieving this.

4. Homelessness Prevention—The jurisdiction must describe its planned action steps over the next year to address the individual and families with children at imminent risk of becoming homeless.

5. Discharge Coordination Policy—Explain planned activities to implement a cohesive, community‐wide Discharge Coordination Policy, and how, in the coming year, the community will move toward such a policy.

6.

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Action Plan Homeless Needs response: In an effort to reduce planning duplication, mainstreaming resources, and collaborative efforts to assist homeless and at‐risk homelessness residents, the county‐wide continuum of care (CoC) plan has been existence since 1995 in Lee County. The City of Cape Coral is a member of Lee County Coalition for the Homeless, Florida, Inc. (Coalition) and participates in the continuum of care process for the entire area. The Coalition coordinates delivery of the Continuum of Care programs within the community. Coalition members include former and current homeless individuals, veterans, persons with HIV/AIDS, residents of the community, private business and community foundation representatives, non‐profit organizations, advocates, treatment providers, and local government representatives. Lee County Department of Human Services is the lead entity for HUD’s CoC grant programs, the state of Florida Office on Homelessness grants, and other state mandated contracts for Medicaid, mental health, and substance abuse. The City of Cape Coral is holds a seat on the Lee County Continuum of Care Board.

SOURCE OF FUNDS SOURCES OF FUNDS (COUNTY‐WIDE)1 The following funds are available to address the homeless needs in the community:

HUD Continuum of Care (Shelter plus Care, Supportive Housing & etc.)

Community Development Block Grant

HOME

Emergency Shelter Grant

State Homeless Challenge Grant

State Homeless Grant in Aid

TANF

State Housing Initiatives Partnership

HOPWA CITY OF CAPE CORAL SOURCE FUNDS

Community Development Block Grant (CDBG) Program

State Housing Initiatives Partnership (SHIP) Program The Lee County Continuum of Care, which consists of local agencies and other providers of housing or services for the homeless, annually prepares an application for federal funding to support programs that meet the needs of Lee County residents who are homeless. The Lee County has been awarded $2,164,377 for the 2012 Continuum of Care grant from the U. S. Department of Housing and Urban Development (HUD). The grant application included funding requests for HUD’s Supportive Housing Program and Shelter Plus Care Program for permanent and transitional housing, emergency shelter, and services for the homeless provided by Salus Care, Renaissance Manor, Salvation Army, and Lee County Department of Human Services. The City of Cape Coral supports homeless prevention activities and assistance utilizing both CDBG & SHIP funds.

1 These funds are not a complete list of available resources. There are other public & private funds available to address the homeless needs.

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HOMELESS STRATEGY COUNTY‐WIDE CONTINUUM OF CARE HOMELESS STRATEGIES

The City of Cape Coral supports and participates in the area‐wide continuum of care strategic plan to assist the homeless and chronically homeless and prevent homelessness. CITY OF CAPE CORAL’ S HOMELESS STRATEGY Along with the Lee Continuum of Care Homeless Strategies, the following strategies and objectives address the homelessness within the City of Cape Coral:

Strategy 1: Provide a facility and services to assist the homeless and persons who are near homeless in the City.

Objective One: Funding support for the City’s food pantries and agencies assisting the needy. This will require the maintenance of support at the current level. It is expected that these facilities will continue to serve over two hundred (200) persons every month. Objective Two: Monitor the capacity of county homeless facilities and the homeless population in the City of Cape Coral to determine if additional facilities are needed in Cape Coral. Objective Three: Support funding available (including Continuum of Care) and support applications by social service providers that benefit the homeless or keep families from becoming homeless. Strategy 2: Support the County‐wide effort to end Chronic Homelessness Objective: Eliminate Chronic Homeless with supportive services and housing programs.

CHRONIC HOMELESSNESS STRATEGY In concert with the national emphasis, the Lee Continuum in 2002 prioritized the elimination of chronic homelessness by 2012 as a demonstrable step in alleviating all Homelessness in Lee County. The Lee Continuum Chronic Homeless Strategy is coordinated with, the chronic homeless efforts of all cities in the county. In 2004 the chronic homeless baseline data has been assembled and the population is being monitored in the HMIS. The 2009 Homeless Count and Survey show 16 Chronically Homeless persons in shelters and 161 others on the streets or other unsheltered locations for a total of 177 Chronically Homeless persons in Lee County. The 2009 Continuum goal emphasize the importance of a finalized Chronic Homelessness Goals and Performance Measures and the establishment of the countywide organizational structure.

The Cape Coral‐Fort Myers MSA is the fourth fastest growing urban area in the United States having added 30% to the population since 2000. Approximately 25,000 new residents are added to the area each year. In the face of this extremely rapid population increase it can be assumed that the population of Chronic Homeless residents is increasing. Chronic Homelessness activities are coordinated the HUD Continuum of Care Plan. Chronic Homelessness is the number one priority in the Lee County Continuum of Care application to the HUD Supportive Housing and Shelter Plus Care programs. Moving chronic homeless into permanent housing and independent living is the focus of the Lee County priority objective. The CoC Plan shows 76 available beds for the 177 Chronically Homeless persons identified in 2009. HUD Consolidated Plan Homeless Strategic Plan is coordinated with the Lee County Continuum of Care (CoC) application and with the development of the Lee County 10‐Year Plan to end Homelessness, Lee’s

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Investment for Everyone (LIFE) – The Ten Year Plan to End Homelessness. A major development in the elimination of homelessness is the completion of the Lee County 10 Year Plan to End Homelessness. The development of the plan ran from 2007 to completion in 2009. The plan details the local situation and proposes major goals and action steps for ending homeless in Lee County. Barriers to eliminating chronic homelessness. As noted above, approximately 25,000 new residents are added to the area each year. In the face of this extremely rapid population increase it can be assumed that the population of Chronic Homeless residents is increasing. This means that strategies must attempt to bring reductions in a population that has a natural annual increase.

HOMELESS PREVENTION The City of Cape Coral provides programs and resources to allow formerly homeless and at‐risk‐of homelessness residents to access to affordable permanent housing. The City’s local resources include the federal CDBG and the state SHIP funds. The City also allocates its CDBG and SHIP funds to provide foreclosure counseling and agencies that provide homeless services. Local agencies provide prevention, outreach, assessment and supportive services for homeless persons and for residents at‐risk of homelessness. Public and private agencies and programs in Lee County provide services including: Mortgage Assistance, Rental Assistance, Utilities Assistance, Foreclosure Prevention, Counseling/Advocacy, and Legal Assistance. Outreach and Assessment for homeless residents is done through Legal Assistance, Street Outreach, Mobile Clinic, and Law Enforcement. Supportive Services for homeless residents include: Counseling/Advocacy, Case Management, Life Skills, Alcohol & Drug Abuse, Mental Health Counseling, Healthcare, HIV/AIDS, Education, Employment, Child Care, and Transportation. The Homeless Strategic Plan Section following shows local discharge planning actions to prevent individuals leaving institutions from falling into homelessness.

DISCHARGE COORDINATION POLICY State Policy The Florida Statutes set out state discharge guidelines and notes that the intent of the Legislature is to ensure that persons leaving care and custody are not discharged into homelessness. The Florida State Department of Corrections requires contracted halfway houses in order to secure full employment for clients and to discharge clients into transitional or permanent housing residence. (The Federal Bureau of Prisons Halfway House Program has the same requirements.) Local Policy The Lee County Homeless Continuum of Care has Memoranda of Understanding on Discharge Planning with the Lee County Sheriff, The Lee Memorial Health System, SalusCare, and the Children’s Network of Southwest Florida, LLC. Several programs and outreach services work to keep persons at, or nearing, the point of discharge from the local jail and sheriff's stockade from becoming homeless and entering the homeless Continuum. Persons discharged from prison have access to the Lee County Department of Human Services Family Self Sufficiency Program, which provides first month or eviction rental assistance. The hospitals of the Lee Memorial Health System and Southwest Regional Health System conduct discharge planning with patients. Policies of the systems direct that patients are not discharged to the streets. Lee County Foster Care Programs are operated under the state‐contracted Children’s Network of Southwest Florida, LLC. Discharge

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assistance is provided through the Independent Living Program in which funding for education and associated rent and basic assistance to youth discharged from the system.

Emergency Shelter Grants (ESG) (States only) Describe the process for awarding grants to State recipients, and a description of how the allocation will be made available to units of local government. Action Plan ESG response: Not Applicable.

COMMUNITY DEVELOPMENT

Community Development *Please also refer to the Community Development Table in the Needs.xls workbook.

1. Identify the jurisdiction's priority non‐housing community development needs eligible for assistance by CDBG eligibility category specified in the Community Development Needs Table (formerly Table 2B), public facilities, public improvements, public services and economic development.

2. Identify specific long‐term and short‐term community development objectives (including economic development activities that create jobs), developed in accordance with the statutory goals described in section 24 CFR 91.1 and the primary objective of the CDBG program to provide decent housing and a suitable living environment and expand economic opportunities, principally for low‐ and moderate‐income persons. *Note: Each specific objective developed to address a priority need, must be identified by number and contain proposed accomplishments, the time period (i.e., one, two, three, or more years), and annual program year numeric goals the jurisdiction hopes to achieve in quantitative terms, or in other measurable terms as identified and defined by the jurisdiction.

Action Plan Community Development response: Current Year Non‐Housing Community Development Needs The City has identified the following CDBG eligible categories for non‐housing community development needs eligible for assistance in the Program Year 2014:

General Public Services

Senior Services

Handicapped Services

Transportation Services

Emergency Shelter

Current Year Community Development Objectives The following community development objectives will be accomplished in the PY 2014: Objective One: Maintain and increase the affordable housing stock in the City by providing housing rehabilitation programs and affordable housing ownership programs to serve the extremely low, low, and moderate income population:

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Provide an additional eight (8) units of single‐family affordable housing additional units.

Rehabilitate approximately twelve (12) existing single‐family homes owned and occupied by extremely low and low income families.

Acquire, rehabilitate and resale approximately ten (10) units of foreclosed homes through the NSP program.

Connect twenty (20) households to city water and sewer. Objective Two: Provide support to agencies which serve the elderly and handicapped, as well as the extremely low, low, and moderate income residents of the City. The services identified include assistance for the hearing impaired, senior job training, and transportation services:

Provide support to three (3) social service agencies and the City of Cape Coral Parks and Recreation Department to provide assistance to approximately 1980 people/households.

Objective Three: Provide services to the homeless and near homeless population within the City:

Provide support to three (3) social service agencies that provide emergency assistance and shelter to homeless and at‐risk homeless – approximately 3,479 households

Objective Four: Provide infrastructure to low moderate income areas:

Provide 2,700 linear feet of sidewalks in a low moderate income block group. Note this project is a two year project.

Objective Five: Expand the economic opportunities of the extremely low, low and moderate income persons in the City through the support of eligible business in the City with financial or supportive measures to create additional job opportunities.

Provide microenterprise training to approximately 60 people.

Long Term Community Development Objectives The long term community development objectives serve to provide facilities and services that address the identified needs within the community. Objective One: Increase the accessibility of neighborhood facilities including park and recreation facilities, service centers and child care centers, which primarily serve the very low, low, and moderate income persons. Objective Two: Maintain and improve the infrastructure of very low, low, and moderate income persons to include sidewalks and alternative transportation opportunities. Objective Three: Maintain and increase the support for public services which serve the needs of the very low, low, and moderate income persons of the City and which provide opportunities for decent housing, a suitable living environment and expanded economic development opportunities. The need for senior services, handicapped services, youth services, transportation services, employment training, and child care services are considered a high priority. Objective Four: To provide accessibility to all public facilities in the City, which are needed to service the needs of the very low, low, and moderate income person. Support the funding of projects that would make the facilities and service accessible to the target population.

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Objective Five: Expand the economic opportunities of the extremely low, low and moderate income persons in the City through the support of eligible business in the City with financial or supportive measures to create additional job opportunities. This includes financial assistance, job training programs, technical business assistance and infrastructure necessary to support the business. Objective Six: Continue with support of existing programs that provide decent housing and a suitable living environment for very low, low and moderate income residents through energy efficient improvements, the removal of lead based paint hazards, and housing code enforcement programs. Identify additional programs which address the aforementioned goals.

Antipoverty Strategy 1. Describe the actions that will take place during the next year to reduce the number of poverty level

families. Action Plan Antipoverty Strategy response: The City of Cape Coral’s goal is to reduce the number of poverty level families through economic development, affordable housing, and service programs coordinated by various entities throughout the City of Cape Coral, the City of Fort Myers, and Lee County. Recognizing the need to overcome poverty is one component of a complex set of issues. Beyond implementing economic development, affordable housing, and service coordinating programs, families in poverty must be provided the opportunity to overcome personal and socioeconomic barriers to gain control of their lives. According to the 2000 Census, 1,623 families in Cape Coral had a 1999 income below the poverty level. This number represents 5.3% of families resides in the City. In comparison, in 2010, there were 11.4 % of families in Cape Coral had a 2009 income below the poverty level. The poverty level families have drastically increased in the last ten years. This number is higher for families with children under 18 (18.3%) and female headed households with children under 5 years of age (43.6%). In order to help individuals rise above the poverty level and become self‐sufficient, the City of Cape Coral in conjunction with Lee County and the State of Florida, including private, non‐profit agencies and organizations have designed and implemented various programs. The City of Cape Coral has established an Economic Development Office. This office promotes and assists businesses in locating and expanding operations and facilities in the City. The affordable housing programs provided by the Cape Coral Housing Development Corporation, Habitat for Humanity of Lee and Hendry Counties, and the Section 8 rental programs administered by the Lee County Housing Authority and the Housing Authority of the City of Fort Myers will enable lower income families to reduce their overall housing costs. These programs enable families to utilize a larger part of their income for other necessities. The programs often allow people to live closer to their place of employment, which in turn may reduce their travel costs. These efforts will reduce further the number of poverty level families in the City.

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NON‐HOMELESS SPECIAL NEEDS HOUSING

Non‐homeless Special Needs (91.220 (c) and (e)) *Please also refer to the Non‐homeless Special Needs Table in the Needs.xls workbook.

1. Describe the priorities and specific objectives the jurisdiction hopes to achieve for the period covered by the Action Plan.

2. Describe how Federal, State, and local public and private sector resources that are reasonably

expected to be available will be used to address identified needs for the period covered by this Action Plan.

Action Plan Specific Objectives response: Objectives Goal: Provide the services and facilities to serve persons with special needs within the City. Objective One: Provide support to agencies that assist persons with special needs within the City. Strategy: Provide transportation to the special need populations through the City’s paratransit program. This program is anticipated to provide vital transportation services to approximately eighty (80) persons. Available Resources The available funding resources include Community Development Block Grant funds, HUD’s Section 211 (senior housing), HUD’s Section 811 (special needs housing), HUD’s Continuum of Care funds, the State of Florida State Apartment Incentive Loan (SAIL) program, the State of Florida State Housing Initiatives Partnership (SHIP) program, and Low Income Housing Tax Credit (LIHTC) programs.

Housing Opportunities for People with AIDS *Please also refer to the HOPWA Table in the Needs.xls workbook.

1. Provide a Brief description of the organization, the area of service, the name of the program contacts, and a broad overview of the range/ type of housing activities to be done during the next year.

2. Report on the actions taken during the year that addressed the special needs of persons who are not homeless but require supportive housing, and assistance for persons who are homeless.

3. Evaluate the progress in meeting its specific objective of providing affordable housing, including a comparison of actual outputs and outcomes to proposed goals and progress made on the other planned actions indicated in the strategic and action plans. The evaluation can address any related program adjustments or future plans.

4. Report on annual HOPWA output goals for the number of households assisted during the year in: (1) short‐term rent, mortgage and utility payments to avoid homelessness; (2) rental assistance programs; and (3) in housing facilities, such as community residences and SRO dwellings, where funds are used to develop and/or operate these facilities. Include any assessment of client outcomes for achieving housing stability, reduced risks of homelessness and improved access to care.

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5. Report on the use of committed leveraging from other public and private resources that helped to address needs identified in the plan.

6. Provide an analysis of the extent to which HOPWA funds were distributed among different categories of housing needs consistent with the geographic distribution plans identified in its approved Consolidated Plan.

7. Describe any barriers (including non‐regulatory) encountered, actions in response to barriers, and recommendations for program improvement.

8. Please describe the expected trends facing the community in meeting the needs of persons living with HIV/AIDS and provide additional information regarding the administration of services to people with HIV/AIDS.

9. Please note any evaluations, studies or other assessments that will be conducted on the local HOPWA program during the next year.

Action Plan HOPWA response: In August 2005, the City received notification from the U.S. Department of Housing and Urban Development (HUD) that the City has qualified to receive a Housing Opportunities for Persons with AIDS (HOPWA) formula grant on behalf of the Cape Coral – Fort Myers, Metropolitan Statistical Area in federal FY 2006. The City chose to enter into an agreement with HUD and the State of Florida Department of Health for the funds to be administered at the State level, by the State of Florida Department of Health to ensure uninterrupted services to persons living with HIV/AIDS.

Specific HOPWA Objectives Describe how Federal, State, and local public and private sector resources that are reasonably expected to be available will be used to address identified needs for the period covered by the Action Plan. Specific HOPWA Objectives response: Not Applicable. Please see HOPWA response above.

Other Narrative

Include any Action Plan information that was not covered by a narrative in any other section.

Fair Housing The City of Cape Coral along with the City of Fort Myers and Lee County jointly conducted the area‐wide Analysis of Impediments to Fair Housing in 2005. The City of Cape Coral updated the Analysis of Impediments to Fair Housing in 2010 to reflect the changes in the housing market condition of increase in foreclosures and declining real estate market. The following impediments were identified in the City of Cape Coral:

The lack of affordable homes

The absence of information regarding the use of Section 8 Vouchers in Cape Coral

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The following action plan has been developed to correct the impediments:

OBJECTIVE MAKING FAIR HOUSING A REALITY IN THE CITY OF CAPE CORAL

GOAL #1 REDUCE INCIDENCE OF DISCRIMINATION IN THE SALE OR RENTAL OF HOUSING

Fair Housing Activities

Action/Agreement required

Measurable Results

Program/Staff Responsibility

Time Period for Completion

Monitoring Staff and Frequency

Provide fair housing education and outreach activities

Contract with local fair housing agency, Disseminate FH information via TV/News Media

Number of completed workshops

City of Cape Coral/Lee County Office of Equal Opportunity

Ongoing

Housing Coordinator

Annually with CAPER

Provide fair housing counseling and referral services to individuals with complaints of discrimination.

None Number of Cape Coral residents served

Lee County of Equal Opportunity

Ongoing

Housing Coordinator

Annually with CAPER

Implement a fair housing media campaign

Provide public service announcements, and community forums on public radio and television (including the county and municipal television channels)

Increased number of Cape Coral residents served

City of Cape Coral or subcontractor

October 2015

Housing Coordinator

Annually with CAPER

Provide fair housing training subrecipient agencies and city employees implementing the City’s housing programs.

Identify categories of city employees that fair housing training should be mandatory

Number of employees/subrecipients trained


October 2015

Housing Coordinator

Annually with CAPER

GOAL 2: PROVIDE FOR AFFORDABLE HOUSING

Monitor affirmative marketing plans and efforts of housing developers receiving federal and state funding

Review results of on‐site monitoring visits conducted by subcontractor and implementation of corrective action

Compliance of all sub‐recipients with fair housing and affirmative marketing requirements


Ongoing

Housing Coordinator

Annually

Support pre‐purchase Provide training or Increased diversity City of Cape Coral or

Ongoing Housing

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counseling programs contract for professional services

in Cape Coral subcontractor Coordinator

Annually with CAPER

Emphasize mixed income housing in all neighborhoods

Select neighborhoods being targeted for redevelopment

Increase in racially, ethnic economically and diverse neighborhoods.


Ongoing

Housing Coordinator

Annually with CAPER

Provide information and technical assistance on housing development programs

Provide training or contract for professional services

Increase in affordable housing development


Ongoing

Housing Coordinator

Annually with CAPER

GOAL 3: REDUCE DISCRIMINATION IN LENDING

Adoption and Maintenance of Lender Guidelines

Review and updating of these guidelines

Reduced foreclosures and predatory loans


Ongoing over five year period

Housing Coordinator

Annually with CAPER

Promote public awareness

Partner with community and/or other entitlement jurisdictions for homeownership fair(s)

Level of participation in homeownership fair(s)/number of fairs


Ongoing over five year period

Housing Coordinator

Annually with CAPER

GOAL 4: IMPROVE REGIONAL TRANSPORTATION

Support the improvement in the tri‐County regional transportation system

Participation in metropolitan planning organization

Attendance at MPO meetings

City of Cape Coral and County Municipalities

Ongoing Housing Coordinator

Annually with CAPER

Section 3 Employment Opportunities for Very Low and Low Income Persons Employment opportunities generated by HUD entitlement funded projects in the City of Cape Coral are prioritized for low‐income residents in conformance with HUD Section 3 requirements of 24 CFR 135. The following activities will be conducted by the City of Cape Coral to comply with Section 3:

The City will make efforts in meeting at least the minimum numerical goals set forth at 24 CFR Part 135.30

- 30 percent of the aggregate number of new hires shall be Section 3 residents

- 10 percent of all covered construction contracts shall be awarded to Section 3 business

concerns

- 3 percent of all covered non‐construction contracts shall be awarded to Section 3

business concerns

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Complying with the specific responsibilities of 24 CFR Part 135.32

The required Section 3 Report, HUD SF 60002 is forwarded annually to HUD and is available to the public at the Planning Division office.

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SF 424

THIS PAGE INTENTIONALLY LEFT BLANK

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Certifications


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Appendix A ‐ Demographic and Project Maps

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Project Location Map

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Sidewalk Project Location Map

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Appendix B ‐ Citizens Participation THIS PAGE INTENTIONALLY LEFT BLANK

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Appendix C ‐ Monitoring

Document Name: Community Development Block Grant (CDBG) Subrecipient Monitoring Policy and Procedures

Document History:

Revision Date Comments

A 07/20/06 Initial Document

B 09/15/08 Update Approval: Document Owner: A. Yearsley

*** NOTE ***

Electronically Controlled Document

Revision level Can be Verified by Comparing with the Document Control List

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1.0 PURPOSE

1.1 To formalize a policy and create procedures to monitor the subrecipients of the City’s Community Development Block Grant (CDBG) program in accordance with 24 CFR 85.40(a).

1.2 By monitoring, the City can ensure that subrecipients comply with all regulations governing

their administrative, financial and programmatic operation and achieve their performance objectives on schedule and within budget.

1.3 The procedures are to serve as a reference and will provide the guiding principles for

subrecipient monitoring by City Staff.

2.0 SCOPE

2.1 The procedures are to be used by staff responsible for the CDBG program. 2.2 The policies and procedures in this document pertain solely to the monitoring of

subrecipients of the City’s CDBG program. These subrecipients will be monitored on all aspects of their respective programs to ensure compliance with 24 CFR 570 which governs the CDBG program. This includes program performance, financial performance and regulatory performance.

3.0 RELATED DOCUMENTS

3.1 24 CFR § 85.40 3.2 Pre‐monitoring letter to subrecipient 3.3 Post‐monitoring letter to subrecipient

3.4 Subrecipient Monitoring Checklist

3.5 Subrecipient Monitoring Report

3.6 Project Close‐Out Checklist

4.0 PROCEDURE

4.1 Monitoring Schedule. Within the City’s Annual Action Plan, submitted to the US Department of Housing and Urban Development, shall be a monitoring schedule for the applicable fiscal years’ activities. Monitoring of subrecipients begins during the project selection process and continues until the terms and conditions of the subrecipient agreement have been completed. There are two types of program monitoring: in‐house desk review and on‐site visit. Each subrecipient shall be scheduled for at least one on‐site visit during the program year and again at the close out of the project.

4.1.1 Risk assessment is conducted to determine which subrecipients will require the

most comprehensive monitoring. Low risk subrecipients are organizations that have satisfactory past performance, little turnover of key staff members, and

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that receive no more than $10,000. High risk subrecipients are have no past performance history, or receive more than $20,000, or are experiencing significant changes or key staff turn over.

4.1.2 Low‐risk subrecipients are monitored through at least one on‐site visit during each program year. If Low‐Risk subrecipients are multi‐year subrecipients and found to have no findings and less than three (3) concerns, they may be moved to an alternating year schedule. However, the City retains the right to monitor on an annual basis if necessary and the agency must at a minimum be monitored every other year.

4.1.3 High‐risk subrecipients are monitored through on‐site visits as often as City staff deems necessary to evaluate project performance and ensure compliance with all federal requirements. Length and complexity of the activity and the experience and capacity of the subrecipients are considered.

4.1.4 City staff is available at any time to offer technical assistance to subrecipients. 4.2 In‐house Desk Review Monitoring Process. Desk Reviews will help aid in identification of

potential problem areas. City staff shall examine progress reports, financial information, and compliance reports submitted by subrecipients to assess performance and identify compliance issues. If questions or concerns arise from the in‐house desk review, staff should expand the scope of the desk review.

4.3 Preparation for the Monitoring Visit. In preparation for the monitoring visit, staff shall review

in‐house written documentation including, but not limited to, the following items: subrecipient’s application, subrecipient agreement, monthly reports, drawdown requests, previous monitoring reports, etc.

4.4 On‐site Monitoring Process. City staff shall first contact the subrecipient by telephone to

explain the purpose of the monitoring visit and arrange mutually convenient dates for the monitoring.

4.4.1 The Notification Letter. A formal notification letter shall be sent to the subrecipient two

weeks prior to the agreed upon monitoring date. The letter shall include the date of the on‐site visit and scope of the monitoring, a description of the materials to be reviewed during the visit, the expected duration of the monitoring, City staff that will be involved, what office space is required, and what members of subrecipient staff should be made available. A sample notification letter is included as “Pre‐monitoring letter to subrecipient.”

4.4.2 The Entrance Conference. City staff shall hold an entrance conference with the

subrecipient’s director and appropriate financial and program staff at the beginning of the monitoring. The purpose of the entrance conference is to ensure that all subrecipient staff has a clear understanding of the purpose, scope and schedule of the monitoring.

4.4.3 Documentation and Data Acquisition. During the monitoring staff shall keep a written

record of the steps followed and information reviewed during the visit. Staff shall utilize the “Subrecipient Monitoring Checklist” to conduct the monitoring. Staff shall document all conversations between City staff and subrecipient staff as well as sources of all information.

4.4.4 The Exit Conference. At the end of the monitoring visit, City staff shall meet with key

representative of the subrecipient organization to prevent the tentative conclusions of the monitoring. There are four objectives that should be achieved:

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4.4.4.1 Present preliminary results of the monitoring visit. 4.4.4.2 Provide an opportunity for the subrecipient to correct any misconceptions or

misunderstandings on City staff’s part. 4.4.4.3 Secure additional information from subrecipient staff to clarify or support their

position. 4.4.4.4 Provide an opportunity for subrecipient to report on steps they are already taking to

correct any deficiency. Staff shall maintain careful notes on the exit conference in order to document what was explained to the subrecipient and the subrecipient’s response to the tentative findings.

4.4.5 The Monitoring Letter. A sample monitoring letter is included as “Post‐Monitoring Letter to Subrecipient”. The monitoring letter shall identify fully every finding and concern. A “finding” will be issued for noncompliance with the rules and regulations of the CDBG program. A finding must be correctly identified, based on applicable law, regulation, or program policy, and supported by the facts presented in the monitoring letter. For each finding, a corrective action shall be provided for the subrecipient to take. A “concern” is an instance where the deficiency is not a finding, or where noncompliance may occur in the future because of weaknesses in the subrecipients operations. For each concern, a recommendation shall be provided for improvement. The monitoring letter shall include deadlines for the subrecipient to provide a written response to the monitoring letter that describes how any findings will be resolved and deadlines for correcting each deficiency. The monitoring letter shall be mailed to the subrecipient within two weeks of the exit conference.

5.0 RESPONSIBILITY

5.1 It is the responsibility of the CDBG/SHIP Team Coordinator and related staff to assure compliance with this policy.

5.2 It is the responsibility of the CDBG/SHIP Team Coordinator to update the CDBG Subrecipient Monitoring policy when changes occur to federal legislation regarding the CDBG program, upon request of Department of Housing and Urban Development Staff, when an existing document is revised, and/or as needed.

End of Document

Appendix D – Outcomes Based Performance Measurement

OUTCOMES BASED PERFORMANCE MEASUREMENT PROGRAM

GUIDANCE DOCUMENT Beginning with the 2005‐2006 CDBG Application, the City of Cape Coral will require all applicants to use the “outcome and performance measurement model” in their application and future reporting. This applies to any applicant seeking CDBG funding. What is the Performance Measurement Model? Here is how HUD sees it.

Goals Proposed Solutions to problems or needs identified in the Consolidated Action Plan.

Preserve existing housing stock Increase property values Improve neighborhood stability Create a suitable living environment for low and moderate income persons

Inputs Resources dedicated to or consumed by the program.

Money Staff/staff time Contractors Facilities Equipment

Activities What the program does with the inputs to fulfill its mission.

Client Intake Client meetings/sessions Client follow up Client referral Facilities Equipment

Outcomes Benefits that result from the program

Increased percentage of housing units that are standard Improved quality of life for program participants Revitalization of a neighborhood

Outputs The direct products of program activities.

Number of clients/customers served Number of classes held Number of loans processed Number of homes rehabilitated

Why is the City of Cape Coral requiring this?

The Office of Management and Budget is assessing the effectiveness of all federal programs

HUD in a September 3, 2003 Notice (CPD‐03‐09) states that “by program year 2005, HUD anticipates that grantees will have implemented some form of a performance measurement system to reflect a way to gauge what constitutes a success in each grantee’s jurisdiction.”

And finally, there is this critique of the CDBG program in President Bush’s FY 2005 budget.

o “ This year the Administration rated the CDBG program as needing improvement based

on several areas of weakness: Lack of clarity in the program’s purpose and design Weak targeting of funds by the CDBG formula and by grantees to areas of

greatest need Lack of transparent program and performance information, and finally, Lack of annual output and long‐term outcome performance measures

What will be the benefits of this outcome and performance measurement model?

1. It will enable the City and your agency to see if the activity really makes a difference in the lives of people.

2. It will help the City or agency to improve services.

3. It will provide the City with clearer evidence that the resources provided actually produce benefits

for people.

4. It will demonstrate to the general public that the activity produces benefits that merit support. What HUD is looking for and wanting from us…

Here is how HUD defines the terms used in the Outcome and Performance Measurement model. GOALS describe future expected outcomes. They are not measurable and focus on ends, not means to an end. INPUTS are resources an agency uses to achieve objectives. E.g. staff, staff time, facilities, equipment, supplies, dollars. Inputs also include constraints on the program, such as laws, regulations, and requirements for receiving funds.

A program uses INPUTS to support ACTIVITIES

ACTIVITIES are what an agency does with its inputs, the services it provides to fulfill its mission. Activities include the strategies, techniques, etc., that comprise the agency’s service methodology. ____________________________________________________________________________

ACTIVITIES are not OUTCOMES OUTPUTS are the direct products of an agency’s activities, usually measured in terms of the volume of work accomplished, e.g. number of clients served, linear feet of curb and gutter installed, units rehabilitated, sessions held. This was all that was required of you in the past.

BUT, NOW

All OUTPUTS must have identified OUTCOMES ____________________________________________________________________________

OUTCOMES are the benefits to individuals, families, organizations, and communities derived form participation in a program or service. Outcomes are produced during or after their involvement in an activity. How is the participant, client, community different following the activity? What was the impact of the activity?

OUTCOMES become the OBJECTIVES of the activity

OUTCOME MEASUREMENT – THE FINAL STEP

What indicators, verifiable information or data will you use to measure an outcome to see if it was actually attained? These outcome measurements will vary depending on the project.

More on Outcomes… In addition to traditional measures of OUTPUTS, namely numbers served, etc., and services provided, OUTCOME language describes the impact on the client. Outcomes are:

Measurable Simple, clear and understandable Realistic Specifies a time frame Measures and end, not a means to an end.

HUD provides these examples: 1. For example, in addition to stating that employment and training services were provided to 50 clients

(an output), outcome language would state that of those 50 clients receiving employment and training services, 10 obtained full time jobs above minimum wage including benefits and are employed 90 days

after placement 20 obtained permanent full time jobs at minimum wage without benefits and are employed 60

days after placement 10 obtained part time temporary jobs within 30 days in the program 5 are participating in on the job training programs; and 5 remain unemployed after 90 days in the program.

2. For example, in addition to stating 20 families received case management services (an output),

outcome language would state that of those 20 families receiving case management services within the past 90 days: 5 families increased their household income by 20% or more 4 families obtained safe affordable rental housing 1 family purchased a home 3 persons received there GED

1 person completed Adult Basic Education curriculum 1 person opened a home based child care center 5 families are currently receiving case management services and are sill working towards achieving

goals on their case management plan. Some very brief examples.

A Housing Project GOALS Provide affordable decent housing to income eligible persons INPUTS $125,000 budget 1 full time 2 part time staff 1 full time contractor ACTIVITIES Client intake Client counseling Client credit clean up Preparation of construction specs Loan approval Progress Inspection Etc. OUTPUTS 5 new homes constructed OUTCOMES Number of the families buying homes through the program will report a significant increase in quality and affordability compared to their previous housing situation or homeownership among LMI persons will increase by a certain percentage/ OUTCOME MEASUREMENT Evaluation of the previous housing situations through on site visits before the move and/or a survey (after the move) of the new homebuyers, or homeownership census data.

A Public Facilities Project GOALS Improve secondary roads to current city standards INPUTS $350,000 budget City project manager City Park staff ACTIVITIES Engineering Bid Construction Bid Davis Bacon Oversight OUTPUTS 1,850 linear feet of new asphalt, curb, gutter and sidewalk on one side of the

street 20 trees planted for beautification OUTCOMES At completion of project, improved road rideability, vehicle and pedestrian

safety and improved drainage

OUTCOME MEASUREMENT Rideability as measured by such devices as Mays Meter

A Public Services Project GOALS Youth will have a safe place for constructive after school activities INPUTS Agency provides budget of $125,000 MSW Program manager Part time volunteer recruiter ACTIVITIES Tutoring ‐ child meets with volunteer tutors 4 afternoons per week for two hours OUTPUTS 25 children receive individual tutoring in after school program OUTCOMES 50% of the students make honor roll for the first time after 6 months of individual

tutoring OUTCOME MEASUREMENT School honor roll records and progress reports for each child

Appendix E ‐ Lead Based Paint The City of Cape Coral’s Department of Community Development has developed an Action Plan/Policy to address lead‐based hazards that might be present within the pre‐1979 housing stock. The creation of this Plan will help City staff and grantees in identifying and mitigating lead‐based paint hazard within the City’s older housing stock. It will also serve to inform residents about the potential health hazards related to lead‐based paint and how to eradicate these. The Action Plan is divided into seven (7) sections:

1. Dissemination of Information 2. Evaluation of Dwellings for Lead‐Based Paint Hazards 3. Reduction of Lead Hazards 4. Implementation of Ongoing Maintenance Procedures 5. Responding to Children with Environmental Intervention Blood Lead Levels (EIBLL) 6. Personnel Qualifications 7. Exemptions 8. Program Administration

The City of Cape Coral will support any application for lead‐based paint hazard abatement grants, especially those that will benefit residents classified as extremely low, low, and moderate‐income. Dissemination of Information

1. Grantees must provide residents and purchasers of residential property the EPA/HUD/Consumer Product Safety Commission (CPSC) Lead Hazard Information Pamphlet, or an EPA equivalent.

2. Grantees should ensure that property owners provide purchasers and lessees with available information or knowledge regarding the presence of lead‐based paint and lead‐based paint and hazards prior to selling or leasing a residence.

3. In the contract or lease, sellers and lessors of pre‐1978 housing must include disclosure and acknowledgement language and a warning statement about the dangers of lead‐based paint.

4. A grantee must provide a notice no later than fifteen (15) days after a lead hazard evaluation has been received that shows a presence of lead‐based paint or lead‐based paint hazards. If a visual assessment was performed, a notice of evaluation is not required.

5. A notice of lead hazard reduction activities must be posted in a public area no later than fifteen (15) days after lead hazard reduction activities have been completed.

The City of Cape Coral will obtain informational materials from HUD, EPA, the National Lead Information Center, and other related sources. Pamphlets and brochures will be made available in the Department of Community Development and through non‐profits conducting educational programs related to housing. Evaluation of Dwellings for Lead‐Based Paint/Hazards

1. Dwellings built in and prior to 1978 will be examined to check for lead‐based paint hazards. 2. Under the new regulation, there is a requirement for lead hazard evaluation for every activity.

Evaluation methods consist of visual assessment, paint testing, and risk assessment. 3. Nothing precludes the grantee from conducting additional lead hazard evaluation measures

beyond the minimum established for each activity. 4. Certified professionals must conduct evaluations to determine the presence of lead‐based

paint hazards. 5. The new regulation provides options for implementing lead hazard evaluation requirements

to allow grantees the flexibility to implement the most cost‐efficient method.

6. There are three (3) cost‐effective methods by which a grantee can implement the lead‐based paint/hazard evaluation requirement. These are: a. Paint Testing: When paint stabilization or interim controls are required, the designated

party may conduct paint testing on all surfaces with non‐intact paint. If there is no lead‐based paint present, lead hazard reduction activities are not required. If a surface contains lead‐based paint, the specified treatment must be conducted.

b. Lead Hazard Screen: A lead hazard screen may be used to determine whether a complete risk assessment is required. If lead‐based paint hazards are detected, a full risk assessment must then be conducted.

c. Presumption of Lead‐Based Paint and/or Lead‐Based Paint Hazards: An alternative to performing lead‐based paint evaluation activities is to presume that lead‐based paint and/or lead‐based paint hazards are present. In this situation, a grantee must conduct one of the following lead hazard reduction methods:

1. If interim controls are required, conduct standard treatments in lieu of interim

controls on all applicable surfaces, including soil, to control lead‐based paint hazards that may be present.

2. If abatement is required, abate all applicable surfaces, including soil, to control lead‐based paint hazards that may be present.

Reduction of Lead Hazards:

1. Lead Hazards shall be reduced through methods that include paint stabilization, interim controls, standard treatments, and abatement.

a. Paint Stabilization: This lead hazard reduction method reduces exposure to lead‐based

paint by addressing deteriorated paint on exterior and interior surfaces through repairs, safe paint removal, and repair or abatement.

b. Interim Controls: These methods temporarily reduce exposure to lead‐based paint hazards through repairs, painting, maintenance, special cleaning, occupant protection measures, clearance, and education programs. Interim Controls require safe practices and include the following:

1. Paint stabilization 2. Treatment for friction and impact surfaces 3. Treatment for chewable surfaces 4. Lead‐contaminated dust control 5. Lead‐contaminated soil control

c. Standard Treatments: In some cases, standard treatments may be conducted in lieu of

Interim Controls on all applicable surfaces. All standard treatment methods must follow the same safe work practice and clearance requirements that apply to Interim Control activities. These methods include:

1. Paint stabilization 2. Smooth and cleanable horizontal surfaces 3. Correcting dust‐generating conditions 4. Bare residential soil

d. Abatement: Abatement permanently removes lead‐based paint and lead‐based paint

hazards by removing lead‐based paint and its dust, or permanently encapsulating or enclosing the lead‐based paint, replacing components with lead‐based paint, and

removing or permanently encapsulating the lead‐based paint, replacing components with lead‐based paint, and removing or permanently covering lead‐contaminated soil. Encapsulation and enclosure require ongoing maintenance to check their effectiveness.

Implementation of Ongoing Maintenance Procedures:

1. In cases where the assistance provided by the grantee involves an ongoing relationship with a property, the grantee is responsible for ensuring that owners perform ongoing maintenance to ensure that lead hazard reduction measures are maintained. In other cases, ongoing maintenance is encouraged.

2. Grantees or property owners must ensure that maintenance activities are conducted to minimize the threat of lead‐based paint hazards.

3. Clearance must be conducted at the conclusion of repair, interim controls, or abatement performed as part of ongoing maintenance.

4. Maintenance activities are not required if a clearance report indicates that all building components with lead‐based paint have been removed or if a current risk assessment indicates that no lead‐contaminated soil or lead‐contaminated dust is present.

Responding to Children with Environmental Intervention Blood Lead Levels (EIBLL):

1. The new regulation clarifies that action is required when a child’s blood lead level is found to have a confirmed concentration of lead in whole blood equal to or greater than twenty (20) micrograms per deciliter for a single test or of fifteen (15) micrograms per deciliter in two (2) tests taken at least three (3) months apart. Because the standard for an Elevated Blood Lead Level (EBL) child is different, the term “Environmental Intervention Blood Lead Level” is used instead.

2. The new regulation requires grantees administering tenant‐based rental assistance activities to conduct a risk assessment, and it requires the owner to conduct either interim controls or abatement when a child is with an Environmental Intervention Blood Lead Level is identified.

3. Identification of a child with an Environmental Intervention Blood Lead Level may be made by either the grantee or a State or local health agency. Grantees must notify their State or local health agencies whenever they identify a child with this condition. They must also ask State and local health agencies to keep them notified of new identifications.

4. If the unit continues to receive assistance, this requirement applies even if the family decides to move.

Personnel Qualifications:

1. A person performing paint stabilization, interim controls, or standard treatments must be trained in accordance with the OSHA Hazard Communication Requirement (29 CFR 1926.59) and either be supervised by an individual certified as a lead‐based paint abatement supervisor or must have successfully completed one of the following courses:

a. A Lead‐Based Paint Abatement Supervisor course, accredited in accordance with 40 CFR

745.225. b. A Lead‐Based Paint Abatement Worker course, accredited in accordance with 40 CFR

745.225. c. The Lead‐Based Paint Maintenance Training Program entitled “Work Smart, Work Wet,

and Work Clean to Work Lead Safe,” prepared by the National Environmental Training Association for EPA and HUD.

d. The “Remodeler’s and Renovator’s Lead‐Based Paint Training Program,” developed by HUD and the National Association of the Remodeling Industry; or

e. An equivalent course approved by EPA or HUD.

2. Abatement must be conducted by certified abatement workers who successfully completed a

Lead‐Based Paint Abatement Worker Course accredited by EPA. These workers must be supervised by a lead‐based paint abatement supervisor certified under a State program authorized by EPA, or conducted by EPA.

3. A Clearance examination involves a visual assessment and dust testing to determine if the unit is safe for occupancy. If an unit fails a clearance examination, the unit must be recleaned and retested until clearance is achieved.

Exemptions

1. The current regulation provides exemptions for certain types of units, such as those that do not contain lead‐based paint.

2. The new regulation refines and expands the list of possible exemptions to include units where lead‐based paint may exist but is not a threat to humans, and dwellings where it is unlikely that children will be exposed to lead‐based paint hazards.

3. In some situations, evaluation and lead hazard reduction for lead‐based paint are not required because lead‐based paint is unlikely to exist.

4. Residential structures built prior to January 1, 1978 in areas where lead‐based paint was banned are exempt from lead‐based paint requirements. To receive this exemption, grantees must apply to HUD.

5. Properties not found to have lead‐based paint during earlier testing that meets the requirements of prior evaluations are exempt from lead‐based paint requirements.

6. Properties where all lead‐based paint has been identified and removed are exempt from lead‐based paint requirements.

7. Unoccupied units that will be demolished are exempt. 8. Property not used for human residential habitation is exempt. 9. Rehabilitation that does not disturb painted surfaces is exempt, although the pamphlet is still

required. 10. Zero‐room dwelling units, including single‐room occupancy (SRO) units, are exempt. 11. Housing specifically designed for the elderly or the disabled is exempt, unless a child under

age six (6) resides in the unit. Program Administration

1. The Department of Community Development will be responsible for the coordination of resources (administrative, financial, informational, and instructional) needed to address lead‐based paint hazards within the City of Cape Coral.

2. CDBG Program staff will be the primary point of contact for subrecipients and recipients with comments, concerns, and questions regarding the implementation of the new lead‐based paint regulation and how it applies to Cape Coral.

3. CDBG Program staff is in the process of assembling materials to educate rental property owners, homeowners, and occupants of rental housing about the new lead‐based paint requirements.

4. Furthermore, staff is developing working relationships with lead professionals and key partners such as risk assessors, clearance technicians, and public health departments in the Cape Coral/Lee County area.

Appendix F – Resolution THIS PAGE INTENTIONALLY LEFT BLANK

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