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HomeMy WebLinkAbout20-10REDEVELOPIMENT AUTHORITY OF THE CITY OF OSHKOSH MARCH 18, 2020 20-10 RESOLUTION (CARRIED LOST LAID OVER WITHDRAWN ) PURPOSE: ACCEPT AND SUPPORT 2020-2024 CONSOLIDATED PLAN, 2020 ACTION PLAN, CITIZENS PARTICIPATION PLAN, AND ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE PLAN UNDER THE CITY'S COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM WHEREAS, the primary objective of Title I of the Housing and Community Development Act of 1974, as amended, is the development of viable urban communities, by providing decent housing and a suitable living environment and expanding economic opportunities, principally for persons of low- to moderate -income; and WHEREAS, the City has developed a 2020-2024 Consolidated Plan and 2020 Annual Action Plan that contains a housing and homeless needs assessment, housing market analysis, an assessment of non -housing community development needs, strategies, priority needs and objectives, which ensures that the activities to be carried out meets one of the national objectives of benefit to low- to moderate -income families; or aid in the prevention or elimination of slums and blight; or meet other community development needs having a particular urgency because existing conditions pose a serious immediate threat to the health and welfare of the community; and WHEREAS, as part of the community development block grant (CDBG) application process, the City must demonstrate it is affirmatively furthering fair housing by conducting an Analysis of Impediments (AI) to Fair Housing Choice which identifies any impediments to fair housing choice and what steps the City will take to address those impediments; and WHEREAS, as part of the development of the Consolidated Plan, Annual Action Plan and Fair Housing Choice Plan, HUD regulations 24 CFR Part 91.105 requires adoption of a Citizen Participation Plan that provides a pathway for all citizens to exercise their voice and influence decisions that affect their community, neighborhoods and way of life. MARCH 18, 2020 20-10 RESOLUTION CONT'D NOW, THEREFORE, BE IT RESOLVED by the Redevelopment Authority of the City of Oshkosh, that the City of Oshkosh 2020-2024 Consolidated Plan, 2020 Annual Action Plan, Analysis of Impediments to Fair Housing Choice plan and the Citizens Participation Plan, all on file in the Community Development office, are hereby accepted; and the Redevelopment Authority requests that the Oshkosh Common Council support and approve of these Plans. ITEM: REVIEW AND ACCEPTANCE OF 2020-2024 CONSOLIDATED PLAN 2020 ANNUAL ACTION PLAN AND CITIZENS PARTICIPATION PLAN ITEM: ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE BACKGROUND The RDA is being asked to review and accept the 2020-2024 Consolidated Plan, 2020 CDBG Annual Action Plan, Citizens Participation Plan and Analysis of Impediments to Fair Housing Choice for the City's Community Development Block Grant Program. The City requested proposals and Urban Design Ventures from Pennsylvania was selected to assist in the development of these Plans. During the development of these Plans, numerous stakeholders were consulted through individual meetings, roundtable discussions, and phone calls. Additionally, the City developed an online resident survey on Survey Monkey and Polco, as well as a mailing campaign including a paper questionnaire in the City's water bills. There was a total of 1,159 responses, with a response rate just under 2%. ANALYSIS 2020-2024 Consolidated Plan Every five years, the City is required by the U.S. Department of Housing and Urban Development (HUD) to prepare a five-year Consolidated Plan to assess our affordable housing, community development, economic development and strategic planning needs. These needs and priorities are then addressed annually through the submittal of the Annual Action Plan, which presents specific activities the City will accomplish with Community Development Block Grant (CDBG) funds. Basic comments received from the on-line surveys and questionnaires, included: • Need for affordable housing • Need for living wage employment • Need for integrated housing and supportive service network • Need for improvements on fair housing reporting • Need for infrastructure improvements • Need for transportation improvements • Need for additional recreation facilities Based on all comments received to date, the 2020-2024 Consolidated Plan proposes the following six strategies to address priority needs of low- to moderate -income persons and households in the community: 1) Housing Strategy: need for decent, safe, and sanitary housing that is affordable and accessible to homebuyers, homeowners and renters. 2) Homeless Strategy: need for housing, services and facilities for homeless persons and persons at -risk of becoming homeless. 3) Other Special Needs Strategy: need for housing, services and facilities for persons with special needs. 4) Community Development Strategy: need to improve community facilities, infrastructure, public services and quality of life in Oshkosh. 5) Economic Development Strategy: need to encourage employment and to promote economic opportunities in Oshkosh. 6) Administration, Planning and Management Strategy: need for planning, administration, management and oversight of federal, state, and local funded programs. Funding will be provided on a community wide basis but directed primarily to low and moderate income (LMI) populations, as well as within LMI census tracts and block groups. The City will use the Consolidated Plan's goals and strategies to allocate CDBG funds over the next 5 years as well as provide direction to partners collaborating on addressing the needs of LMI persons. 2015 Annual Action Plan Annually, the CDBG Action Plan is prepared to demonstrate how federal funds from HUD will be spent. Please refer to page 104 of the Consolidated Plan document for the 2020 Annual Action Plan. The 2020 Program Year runs from May 1 thru April 30. The 2020 CDBG entitlement allocation is $841,094 (see attached proposed budget). HUD regulations require that at least 70% of CDBG funds benefit LMI persons over a one to three year certification period. As proposed, over 70% of the 2020 CDBG funds subject to LMI benefit calculations will be expended on activities that benefit LMI persons. Staff is recommending that the City allocate $118,000 for public service activities and programs that will benefit LMI persons/households in the community. The Public Service allocation cannot represent no more than 15% of the total annual allocation, including previous years contract payments made after the end of the previous program year. Owner occupied housing improvement applications (non-public service) are due to the Community Development Department on March 16. These applications do not include first time homebuyer's assistance, emergency repairs or rehabilitation of rental properties. Non - Public Service allocations are included in the 70% of CDBG funds spent for LMI persons. Staff is recommending that the City allocate $205,094 for the owner occupied Housing Rehabilitation Program. A new housing code violation program recently approved by Council will allocate $50,000, and $200,000 is being allocated for the creation of new affordable rental units by a private developer. Remaining funding is recommended for Central City Redevelopment for removal of slum and blight ($150,000), Neighborhood Initiatives ($25,000) to make improvements to infrastructure in the public right-of-way, Fair Housing Activities ($19,000), and Administration ($74,000). CITIZENS PARTICIPATION PLAN As part of the development of a Consolidated Plan and Fair Housing Plan, HUD regulations 24 CFR Part 91.105, requires adoption of an updated citizen participation plan that at a minimum includes the following broad elements: • Description of the public participation process, including public hearings and public comment periods • Ensured opportunities for involvement of affected persons and other concerned citizens in the planning process • Transparency of the planning process and freedom of access to draft Plans • Instructions to guide the public's submission of comments and the standards for the grantee's response • Procedures for continuity of participation throughout all stages of the appropriate Plan's development The Citizen Participation Plan is a pathway for all citizens to exercise their voice and influence decisions that affect their community, neighborhoods and way of life. The Citizens Participation Plan, as proposed, meets or exceeds the requirements of 24 CFR 91.105. ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING As an entitlement community receiving CDBG funds, Oshkosh must demonstrate it is affirmatively furthering fair housing by conducting a Fair Housing Analysis which identifies any impediments to fair housing choice and what steps the city will take to address those impediments. The Fair Housing Act was originally passed in 1968 to protect buyers and renters from discrimination based on their race, color, religion, sex, national origin, disability or familial status from sellers and landlords by making it unlawful to refuse the sale or rental of a property to persons included under the category of a protected class. The City's current Analysis of Impediments (Al) to Fair Housing Choice plan was approved in 2013 by the Plan Commission, Common Council and HUD. The proposed AI will outline progress made since the 2013 Plan, explore the continuation of impediments where necessary, and identify any new impediments to fair housing choice. This new Al Plan is designed to act as a planning tool, providing Oshkosh with the necessary framework to strategically reduce any identified impediments to fair housing choice over the next 5 years and continue to make modifications based on events and activities in the community during this time period. In the preparation of the proposed Fair Housing Plan, staff and the City's consultant reviewed the most recent demographic data for the area from the US Census Bureau, US Department of Housing and Urban Development, the Housing Authority's Five Year and Annual Public Housing Action Plan, and conducted one on one interviews and round table discussions with various City and County Departments, the Oshkosh/Winnebago County Housing Authority, community, social service and advocacy agencies, and included fair housing questions on the SurveyMonkey and Polco citizens surveys. Based on available data, public input and research, the consultant identified four impediments to Fair Housing Choice in Oshkosh, as well as defined specific goals and strategies to address each impediment. Impediment 1: Need for fair housing education and outreach. Goal: Improve the public's knowledge and awareness of the Fair Housing Act, related laws, regulations and requirements. Strategies to address: a) educate residents; b) educate realtors, bankers, housing providers, and others of their responsibilities under the Fair Housing Act and Americans with Disabilities Act; c) educate policy makers and city staff, d) support fair housing organizations and legal advocacy groups to assist persons who may be victims of housing discrimination; e) identify the language and communication needs of LEP persons; f) continue to partner with regional jurisdictions and housing providers to encourage fair housing choices. Impediment 2: Need for affordable housing Goal: Increase supply of decent, safe, and sanitary housing that is affordable and accessible through new construction and rehabilitation of various types of housing, especially for LMI households. Strategies to address: a) support and encourage private developers and non-profit housing providers to construct or rehab affordable and mixed -income housing; b) support and encourage rehabilitation of existing renter occupied and owner occupied housing units for households below 80% AMI; c) support homebuyer education, training programs and down payment assistance to increase number of owner occupied housing units; d) provide federal, state and local funding in response to HMDA data discrimination patterns to support higher loan to value ratios for minority homebuyers; e) create data base of decent, safe and sanitary housing that is affordable and accessible for households below 80% AMI. Impediment 3: Need for accessible housing Goal: Increase supply of accessible housing through new construction and rehabilitation for persons with disabilities. Strategies to address: a) promote need for accessible and visitable housing by support and encouraging private develop0ers to develop, construct, or rehab housing that is accessible to persons with disabilities; b) provide financial assistance for accessibility improvements to renter - occupied and owner -occupied housing units to enable seniors and persons with disabilities to remain in their homes; c) promote and enforce ADA and Fair Housing requirements for landlords to make 'reasonable accommodations' to their rental properties so units are accessible to tenants. Impediment 4: Public Policy Goal: Revise the City Zoning Ordinance to promote the development of various types of affordable housing throughout the City. Strategies to address: a) revise the Zoning Ordinance to include additional definitions, statements and revisions; b) Adopt a written Reasonable Accommodation Policy for housing developers and the Planning/Commission Commissions to follow when reasonable accommodation requests are made concerning zoning and land use as it applies to protected classes under the Fair Housing Act; c) develop financial incentives to encourage developers and housing providers to offer more affordable housing options in the City; d) encourage LMI, minorities and protect class resident participation in various City Boards/Commissions, Final Step The City is accepting public comments on these Plans until April 6, 2020. A summary of all comments received by the City will be included with each respective Plan as an exhibit. Comments can be mailed to Darlene Brandt, Oshkosh City Hall, 215 Church Avenue, Room 201, Oshkosh, WI 54901 or email dbrandt@ci.oshkosh.wi.us. Questions can be directed to Ms. Brandt at 920.236.5029. Prior to Council consideration, these plans are reviewed by the Plan Commission for consistency with the City's Comprehensive Plan, as amended, official maps, and other planned activities of the City. The RDA's review will accept and support the Plans and Programs/Activities proposed in providing decent housing and a suitable living environment and expanding economic opportunities, principally for persons of low- and moderate -income, and recommend their approval by the Common Council. In this regard, staff has reviewed all proposed projects and activities and none have been identified as being contrary to the Comprehensive Plan, official maps, or other planned activities of the City and applicable Federal regulations. RECOMMENDATIONS/CONDITIONS Staff recommends acceptance of the 2020-2024 Consolidated Plan and 2020 Annual Action Plan, Citizens Participation Plan and Analysis of Impediments to Fair Housing Choice plan for the Community Development Block Grant Program, and requests that Council approve the Plans. Proposed 2020 Action Plan Community Development Block Grant Program PROPOSED BUDGET I. Housing Programs Housing Rehab $205,094 Code Violation $ 50,000 Rental Rehab $200,000 II. Neighborhood Initiatives $ 25,000 III. Central City Redevelopment $150,000 IV. Public Service $118,000 V. Administration & Planning Fair Housing $ 19,000 Program Administration 74,000 TOTAL ALLOCATION $841,094 6