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AFFH policy requirement is part of the upcoming grant contract with HUD. In response, St. Lucie County staff confirmed that the 2015 AFFH policy (see HUD fact sheet, attachment #2) applies to all HUD funds including HOME funds and that any recipient of funds under the new consolidated plan will be subject to the 2015 AFFH policy. Attachment #3 is the Florida Housing Coalition report regarding AFFH and local land use authority. Per the Board's previous discussion and concerns regarding the 2015 AFFH policy, staff is requesting that the Board consider whether or not it wants to continue with the Treasure Coast HOME Consortium beyond the current 2018 expiration. Staff will notify St. Lucie County of the Board's decision. ANALYSIS Indian River County's share of Treasure Coast HOME Consortium funds has been used for deferred payment fifteen year loans to Habitat for Humanity's (HFH) clients. The funds have been used for very low and low income households within the county. St. Lucie County has used 10% of the HOME consortium funds for administrative purposes and, in accordance with the partnership agreement is the "....lead entity having overall responsibility for ensuring the Consortium's HOME Program is carried out in compliance with the HOME Program". For Indian River County, there is a minimum amount of staff time required to process HOME applications since St. Lucie County is doing all application intake, processing, closing, and disbursement of funds. Consequently, there has been essentially no cost to Indian River County for consortium generated funds of approximately $85,000 each year. As structured, the Treasure Coast HOME consortium is beneficial to the county by providing additional funds on a regular basis to assist very low and low income households with their affordable housing needs. Under section 7 of the existing partnership agreement, the participating counties certify that each "... will cooperate with the other to undertake or aid in undertaking housing assistance activities for the Home Investments Partnership Program and that each will affirmatively further fair housing." Although IRC staff has no direct experience in administering the consortium program and in preparing the consortium consolidated plan, staff is aware of the consolidated plans generally which include data, assessments, analysis, and goals and objectives. An excerpt from St. Lucie County's HOME Consortium Consolidated Plan for 2012-2017 is included as a reference. As an additional resource, St. Lucie County staff have been invited to the April 4th BCC meeting to answer questions about the consortium and HUD obligations. Staff recognizes the concerns expressed about HUD's 2015 AFFH policy and the potential risk of "federal over -reach" into local land use and zoning issues. At this point in time, staff has no way of quantifying that risk. However, staff also recognizes the tangible benefits of participating in the consortium and current ability to comply with St. Lucie County and HUD requirements. Given the consortium benefits and past and present constructive working relationship with HUD at the local level, especially with respect to the rental assistance programs, Community Development is in favor of Indian River County continuing its participation in the Treasure Coast HOME Consortium beyond the 2018 expiration date. P209