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HomeMy WebLinkAbout2015-076RESOLUTION 2015- 076 A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF INDIAN RIVER COUNTY, FLORIDA, APPROVING THE FIVE YEAR AND ANNUAL PUBLIC HOUSING AGENCY PLAN FOR INDIAN RIVER COUNTY. WHEREAS, the United States Department of Housing and Urban Development (HUD) requires each Public Housing Agency (PHA) to approve and submit a Five Year and Annual Plan to HUD; and WHEREAS, Section 511 of the Quality Housing and Work Responsibility Act (QHWRA) of 1998 created the agency Five Year and Annual Plan requirements; and WHEREAS, the Indian River County Board of County Commissioners Rental Assistance Department Housing Choice Voucher (HCV) Program Five Year and Annual Plan will include attachments and supporting documents such as the HCV Administrative Plan, Enterprise Income Verification (EIV) policy and required certifications; and WHEREAS, the public was duly notified of a public hearing to be held on June 23, 2015 at 9:00 am at the Indian River County Board of County Commission Chambers, 1801 27th Street, Vero Beach, Florida. WHEREAS, a public hearing was held at the above date and time and all public comments have been taken into consideration and the Indian River County Board of County Commissioners Rental Assistance Department has documented, prepared and submitted all necessary changes, as appropriate; and WHEREAS, the Indian River County Board of County Commissioners Rental Assistance Five year and Annual Plan with attachments and supporting documents will take effect for October 1, 2015; and NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF INDIAN RIVER COUNTY, FLORIDA: 1. The Indian River County Board of County Commissioners accepts, approves and adopts the IRC Five Year and Annual Plan and attached hereto, which will be effective October 1, 2015 and used by staff to appropriately administer the Housing Choice Voucher Program. RESOLUTION 2015-076 The foregoing Resolution was offered by Commissioner Flescher and seconded by Commissioner zorc and, upon being put to a vote, the vote was as follows: Chairman Wesley S. Davis Vice Chairman Bob Solari Ave Commissioner Joseph E. Flescher Ave Commissioner Peter D. O'Bryan Ave Commissioner Tim Zorc Aye The Chairman thereupon declared the Resolution duly passed and adopted this 23rd day of June, 2015. Attest: Jeffrey R. Smith, Clerk of INDIAN RIVER COUNTY, FLORIDA Court and Comptroller / BOARD OF COUNTY COMMISSIONERS By By Deputy Clerk - Wesley S. Davis, Chairman Approved: V- -C__.t Josep A. gird CounV ministrator Approved as to form and legal sufficiency: William K. DeBraal Deputy County Attorney PHA 5 -Year and U.S. Department of Housing and Urban OMB No. 2577-0226 Development Annual Plan Office of Public and Indian Housing 1.0 PHA Information PHA Name: Indian River County Board of County Commissioners PHA Code: FL132 PHA Type: ❑ Small ❑ High Performing ❑ Standard ® HCV (Section 8) PHA Fiscal Year Beginning: 10/2015 2.0 Inventory (based on ACC units at time of FY beginning in 1.0 above) Number of PH units: n/a Number of HCV units: 379 — (345 HCV and 29 VASH Vouchers) 3.0 Submission Type ® 5 -Year and Annual Plan ❑ Annual Plan Only ❑ 5 -Year Plan Only 4.0 pHA Consortia ❑ PHA Consortia: (Check box if submitting ajoint Plan and complete table below.) No. of Units in Each Participating PHAs PHA Program(s) Included in the Programs Not in the Program Code Consortia Consortia PH HCV PHA I: PHA 2: PHA 3: 5.0 5 -Year Plan. Complete items 5.1 and 5.2 only at 5 -Year Plan update. 5.1 Mission. State the PHA's Mission for serving the needs of low-income, very low-income, and extremely low income families in the PHA's jurisdiction for the next five years: The Indian River County Board of County Commissioners is committed to partnering with private owners and property managers in an efficient, professional and ethical manner as a team effort to provide decent, safe, sanitary and affordable housing for the clients that we serve in this community and to enhancing the housing stock for under privileged and low income, including seniors' and To assist and prepare low to moderate income residents in making a transition to a greater financial security; and To provide our clientele with empathy, dignity and responsive customer service: and To provide the highest quality customer service, with uncompromised integrity. form HUD -50075 (4/2008) 5.2 Goals and Objectives. Identify the PHA's quantifiable goals and objectives that will enable the PHA to serve the needs of low-income and very low-income, and extremely low-income families for the next five years. Include a report on the progress the PHA has made in meeting the goals and objectives described in the previous 5 -Year Plan. Current goals and objectives: 1. Expand the supply of assisted housing by: • Applying for additional vouchers as they become available from HUD or any other State funded program; • Conducting outreach efforts to potential landlords. 2. Improve the quality of assisted housing by: • Focusing of efforts to improve specific management functions, such as rent reasonableness reviews, income verification, voucher unit inspections and appropriate response to program violations on the part of the assisted tenants, including criminal activity; 3. Promote self-sufficiency and asset development of assisted households by: • Providing or attracting supportive services to improve recipients' employability and to educate recipient's on homeownership programs. 4. Administration of the HCV Program with excellence by: • Maintaining 95% or better utilization rate; • Providing quality service to customers and clients through open communication, workshops and/or meetings to explain the HCV Program, and completing no less than 98% of all annual recertification's on time. Progress on meeting the goals and objectives: 1. Expand and increase the amount of resources of assisted housing and increase the availability for persons in need: • HUD allocated 15 VASH Vouchers for homeless veterans in Indian River County. 2. Improve the quality of assisted housing: • Attained additional landlords to participate in our HCV program. 3. Promote self-sufficiency and asset development of assisted households: • Partnered with additional supportive service agencies to assist our households in providing participants with additional available supportive services. 4. Increase assisted housing choices: • Provided additional portability counseling for our assisted households. form HUD -50075 (4/2008) form HUD -50075 (4/2008) PHA Plan Update (a) Identify all PHA Plan elements that have been revised by the PHA since its last Annual Plan submission: Changes to the Five Year/Annual Plan: Changed PHA to Indian River County Board of County Commissioners and changes to the HCV Program Administration Plan via updates to chapters l through 17, which have been revised to meet HUD federal regulation changes effective for October 1, 2015: Chapter 3, added: "Any criminal act that constitutes moral turpitude ": Chapter 4, changed: "A preference will he offered to any family that has been residing in Indian River County for the past -24 months " to "12 months ". ". Chapter 6, added minor changes, Chapter 11, added minor changes. Chapter 13, added: "Foreclosure (HUD -52641 and Notice PIH 2010-49], Chapter 16, added: !RC purchasing policy compliance for expenditures. (b) Identify the specific location(s) where the public may obtain copies of the 5 -Year and Annual PHA Plan. Indian River County Board of County Commissioners -Rental Assistance Department, 1028 2Y' Place, Suite C. Vero Beach. Florida 32960 For a complete list of PHA Plan elements, see Section 6.0 of the instructions. Plan Elements: I . Eligibility, Selection and Admissions Policies, including De -concentration and Wait list Procedures: Available and addressed in the Administrative Plan; 2. Financial Resources: Attached 3. N/A 4. N/A 6.0 5. Grievance Procedures: Available and addressed in the Administrative Plan; 6. N/A 7. N/A S. N/A 9. N/A 10. Civil Rights Certification: Attached Certification; Additional information available and addressed in the Administrative Plan 11. Fiscal Year Audit: Attached 12. N/A 13. Violence Against Women Act 9VAWA): SafeSpace, Inc: Memorandum of Agreement to Collaborate; Additional information available and addressed in the Administrative Plan. 7.0 Hope VI, Mixed Finance Modernization or Development, Demolition and/or Disposition, Conversion of Public Housing, Homeownership Programs, and Project -based Vouchers. Include statements related to these programs as applicable. N/A 8.0 Capital Improvements. Please complete Parts 8.1 through 8.3, as applicable. N/A 8.1 Capital Fund Program Annual Statement/Performance and Evaluation Report. As part of the PHA 5 -Year and Annual Plan, annually complete and submit the Capital Fund Program Annual Statement/Performance and Evaluation Report, form HUD -50075.1, for each current and open CFP grant and CFFP financing. N/A 8.2 Capital Fund Program Five -Year Action Plan. As part of the submission of the Annual Plan, PHAs must complete and submit the Capital Fund Program Fit e- Action Plan, form HUD -50075.2, and subsequent annual updates (on a rolling basis, e.g., drop current year, and add latest year for a five year period). Large capital items must be included in the Five -Year Action Plan. N/A 8.3 Capital Fund Financing Program (CFFP). ❑ Check if the PHA proposes to use any portion of its Capital Fund Program (CFP)/Replacement Housing Factor (RHF) to repay debt incurred to finance capital improvements. N/A form HUD -50075 (4/2008) Housing Needs. Based on information provided by the applicable Consolidated Plan, information provided by HUD, and other generally available data, make a reasonable effort to identify the housing needs of the low-income, very low-income, and extremely low-income families who reside in the jurisdiction served by the PHA, including elderly families, families with disabilities, and households of various races and ethnic groups, and other families who are on the public housing and Section 8 tenant -based assistance waiting lists. The identification of housing needs must address issues of affordability, supply, quality, accessibility, size of units, and location. Active HCV Participants: I. HCV Section 8 Household composition report (HAPPY Software as of February 10, 2015): Member Count: 715 Elderly: 164 Disabled: 166 (count includes some elderly) Female: 490 Hispanic: 51 Household Composition report grouped by Zip Code: 32948: Member Count=8, Elderly=2, Disabled=l, Female=5, Hispanic=l 32958: Member Count=100, Elderly=42, Disabled=21, Female=70, Hispanic=12 32960: Member Count= 182, Elderly=23, Disabled=45, Female=l 18, Hispanic=18 32962: Member Count=] 76, Elderly=51, Disabled=28, Female=119, Hispanic=3 32966: :Member Count=59, Elderly=38, Disabled=34, Female=44, Hispanic=4 32967: Member Count= 180, Elderly=8, Disabled=34, Female=125, Hispanic=13 32968: Member Count=9, Elderly=0, Disabled=3, Female=6, Hispanic=0 Average Annual Total Income: $13,464.15 Active HCV Waiting List report: 2. Waiting list total as of February 16, 2015: 327 3. Totals by income percentage (HAPPY Software as of February 16, 2015): Extremely low income = 212 64.83% Very low income = 113 34.56% Low income = 1 .31% Over income limit = 1 .31% 4. Totals by Ethnicity: Hispanic = 22 6.69% and Non -Hispanic = 256 78.29% 5. Totals by Racial Group: American Indian/Alaska Native 0.00% Asian 0.00°l0 Black/African American 266 81.35% Native Hawaiian/Pac.Island 0.00% White 30 9.17%r 6. Totals by Bedroom Size: I BR: 77 2 BR: 194 3 BR: 50 4 BR: 6 Indian River County Board of County Commissioners Comprehensive Plan Housing Elements (known as the Consolidated Plan) states: COST BURDEN (from Indian River County Board of County Commissioners Comprehensive Plan): Generally, households needing assistance are those households in the extremely low and very low income categories. Those are households with annual incomes Tess than $24,999. According to the Census, 14,698 Indian River County households were in those two income categories in 2000. Because of high housing costs, many of those 14,698 households may have housing affordability problems. For renter households, housing cost includes contract rent and some allowance for utilities. In 2000, 4,414 (40.30%v) renter households with the county were paying more than 30 percent of their income for rent. In some cases, this represents an affordability problem, but in other cases this represents people choosing to spend a higher percentage of their income to obtain better housing. According to the Shimberg Center for Affordable Housing, 13,577 Indian River County households paid more than 30% of their income for housing in 2005. In that same year, 5,066 of those households paid more than 50%n of their income for housing. Table helow. provides a breakdown of cost burden between homeowner's and renters: Households paying between 30- 50% of income for housing Households paying more than 50% of income for housing Total Owner households 5,747 3,113 8,860 Renter households 2,764 1,953 4,717 Total 8,511 5,066 13,577 form HUD -50075 (4/2008) form HUD -50075 (4/2008) Strategy for Addressing Housing Needs. Provide a brief description of the PHA's strategy for addressing the housing needs of families in the jurisdiction and on the waiting list in the upcoming year. Note: Small, Section 8 only, and High Performing PHAs complete only for Annual Plan submission with the 5 -Year Plan. Strategy 1: Maximize the number of affordable units available by: • Establishing appropriate payment standards that will enable families to lease throughout Indian River County; • Aggressively marketing of the HCV Program to owners of units outside areas of minority and poverty concentration; • Participating in the Consolidated Plan process and development to ensure coordination of broader community strategies. Strategy 2: Increase the number of affordable housing to families in need by: • Applying for additional funding to lease up HCV vouchers should they become available; • Complying with subsidy standards in the HCV Administrative Policy; • Working with developers to encourage the creation of additional affordable rental units in targeted areas as identified in the County's comprehensive (consolidated) plan; 9.1 • Working with the Community Development Block Grant Director to ensure the development of units affordable to families at or below 50% of area median income (AMI). Strategy 3: Target available assistance for the elderly by: • Applying for special-purpose vouchers targeted to assist the elderly should these vouchers become available; • Affirmatively marketing to local non-profit agencies that assist the elderly population; • Continuing with preferences for the homeless one bedroom elderly population; Strategy 4: Target available assistance for the disabled by: • Applying for special-purpose vouchers targeted to assist the disabled should these vouchers become available; • Partnering and resourcing with local non-profit agencies that assist disabled head of households. Strategy 5: Coordinate activities to affirmatively broaden fair housing by: • Counseling and providing resources to housing participants as to location of units available outside of areas of poverty or minority concentration; • Resourcing and marketing to homeowners and property owners interested in participating in the Housing Choice Voucher Program; • Coordinating and providing fair housing meetings and/or workshops with HCV participants and HCV Landlords. Additional Information. Describe the following, as well as any additional information HUD has requested. (a) Progress in Meeting Mission and Goals. Provide a brief statement of the PHA's progress in meeting the mission and goals described in the 5 - Year Plan. The Indian River County Board of County Commissioners Rental Assistance Department HCV Program has made progress in meeting the Mission and Goals as established in the 5 year and Annual Agency Plan and HCV Administration Plan by: 1. Utilized the maximum housing assistance payment funds received by HUD by maintaining 98% of unit utilization for the HCV 10.0 Program; 2. Conducted education meetings to the HCV Program participants and HCV — Section 8 landlords; 3. Provided resources to our HCV Program participants to promote self-sufficiency; 4. Established Payment Standards to enable families to rent decent and affordable rental units in Indian River County: 5. Received 15 VASH Vouchers for the homeless Veterans in need. (b) Significant Amendment and Substantial Deviation/Modification. Provide the PHA's definition of "significant amendment" and "substantial deviation/modification": The Indian River County Board of County Commissioners Rental Assistance Department HCV Program defines " Significant Amendments" to be changes to Federal Regulations that may be required by HUD and any changes to the HCV Admin Policy which would significantly and substantially alter the HCV Program mission; and The Indian River County Board of County Commissioners Rental Assistance Department HCV Program defines "Substantial Deviation/Modifications" as a fundamental change to the HCV Program mission statement, goals or objectives identified in the Five Year and Annual Plan. form HUD -50075 (4/2008) 11.0 Required Submission for HUD Field Office Review. In addition to the PHA Plan template (HUD -50075), PHAs must submit the following documents. Items (a) through (g) may be submitted with signature by mail or electronically with scanned signatures, but electronic submission is encouraged. Items (h) through (i) must be attached electronically with the PHA Plan. Note: Faxed copies of these documents will not be accepted by the Field Office. (a) Form HUD -50077, PHA Certifications of Compliance with the PHA Plans and Related Regulations (which includes all certifications relating to Civil Rights)- ATTACHED (b) Form HUD -50070, Certification for a Drug -Free Workplace (PHAs receiving CFP grants only) -N/A (c) Form HUD -50071, Certification of Payments to Influence Federal Transactions (PHAs receiving CFP grants only) -N/A (d) Form SF -LLL, Disclosure of Lobbying Activities (PHAs receiving CFP grants only) -N/A (e) Form SF -LLL -A, Disclosure of Lobbying Activities Continuation Sheet (PHAs receiving CFP grants only) -N/A (f) Resident Advisory Board (RAB) comments. Comments received from the RAB must be submitted by the PHA as an attachment to the PHA Plan. PHAs must also include a narrative describing their analysis of the recommendations and the decisions made on these recommendations. - NO COMMENTS RECEIVED (g) Challenged Elements -NO ELEMENTS CHALLENGED (h) Form HUD -50075.1, Capital Fund Program Annual StatemendPerformance and Evaluation Report (PHAs receiving CFP grants only) — NIA (i) Form HUD -50075.2, Capital Fund Program Five -Year Action Plan (PHAs receiving CFP grants only) — N/A form HUD -50075 (4/2008) Table below, provides a breakdown of cost burden by income group: Household income as percentage of Area Median Income (AMI) Households paying between 30- 50% of income for housing Households paying 50% or more of income for housing Total (ELI) Less than 30% AMI 764 2,178 2 942 (VLI) 30-50% AMI 2,531 1,970 4,501 (LI) 51-80% AMI 1,796 434 2,230 (MI) 81-120% AMI 3,420 484 3,904 Total 8,511 5,066 13,577 SPECIAL HOUSING NEEDS (from Indian River County Board of County Commissioners Comprehensive Plan) : In determining housing needs, there are several population categories that warrant particular consideration. These are the elderly, the low income disabled, and farmworkers. One population category that warrants special consideration from a housing needs perspective is the elderly. The following table shows the percentage of Indian River County households headed by a person 65 or older as reported by the 1990 census, the 2000 census, and the 2005 Shimberg Center for affordable housing estimate: Percentage of Elderly Head of Households -Indian River Count 1990 Census 2000 Census 2005 Shimberg Percentage of Households headed by a person of 65 or older 28.75% 36.09% 41% Compared to other areas, Indian River County has a high percentage of elderly households. According to Shimberg Center for Affordable Housing, elderly households, in 2005 constituted 27% of all households statewide, while elderly households constituted 41 % of all county households. In Indian River County, future housing needs for elderly households (65+) were projected by utilizing Shimberg Center figures which indicate that, in 2005, 41% of households were headed by an elderly person. The following table shows the projected number of elderly households within the county through 2030: (Current 2013 Shimberg data is available on-line) Projected Number for Housing for Elderly (65+) (41% of Total Housing Units) The County targets its housing assistance resources to very low, low, and moderate income elderly households. By targeting assistance to very low, low and moderate income households generally, the county also provides assistance to elderly households which fall in those income categories and need assistance. PROJECTED HOUSING NEEDS (from Indian River County Board of County Commissioners Comprehensive Plan): Housing need is defined as the number of new dwelling units that must be constructed within a certain timeframe to accommodate a projected future population. For Indian River County, the University of Florida Bureau of Economic and Business Research (BEBR) population projections are used to project the number of future households and, consequently, the number of units needed to house those households. Assuming a 15% rate for seasonal and vacant units, the total needed units are then calculated. For years 2010, 2015, 2020, 2025, and 2030, the total number of additional units needed was determined by subtracting existing units from projected units. Based on those projections, an additional 26,839 units must be constructed between now and 2030. As in the past, virtually all of the housing units needed by 2030 will be constructed by the private sector. As such, market demand will dictate the pace of housing construction through 2030, and no county policies are needed to ensure that overall housing needs are met. While overall housing need will be met by the private sector, government assistance will be needed for those households in the lowest income categories. Treasure Coast Homeless Services Council, Inc. — Point In Time Report -Homelessness Fact Sheet for Indian River County Reporting agencies: Unsheltered: IRC Jail, New Horizons, The Source, Public Defender's office, Project Response, IRC -Vets, IRC School District, Fellsmare Community Enrichment Program, Breath of Heaven: Sheltered: Homeless Family Center, Samaritan Center, CHS — Youth Transition Center, Woman's Home, Safe Space. January 30, 2015: Total Homeless in County (HUD) = 812 Adults = 550 Children = 262 Disabled Adults = 71 Unemployed Adults = 80 Other Subset Data: Past Foster Care = 12 Persons 18-24 = 22 Veterans = 31 Elderly 62+ = 19 form HUD -50075 (4/2008) 2010 2015 2020 2025 2030 Elderly households (County tot 1 29,821 32,480 35,477 38,432 41,261 The County targets its housing assistance resources to very low, low, and moderate income elderly households. By targeting assistance to very low, low and moderate income households generally, the county also provides assistance to elderly households which fall in those income categories and need assistance. PROJECTED HOUSING NEEDS (from Indian River County Board of County Commissioners Comprehensive Plan): Housing need is defined as the number of new dwelling units that must be constructed within a certain timeframe to accommodate a projected future population. For Indian River County, the University of Florida Bureau of Economic and Business Research (BEBR) population projections are used to project the number of future households and, consequently, the number of units needed to house those households. Assuming a 15% rate for seasonal and vacant units, the total needed units are then calculated. For years 2010, 2015, 2020, 2025, and 2030, the total number of additional units needed was determined by subtracting existing units from projected units. Based on those projections, an additional 26,839 units must be constructed between now and 2030. As in the past, virtually all of the housing units needed by 2030 will be constructed by the private sector. As such, market demand will dictate the pace of housing construction through 2030, and no county policies are needed to ensure that overall housing needs are met. While overall housing need will be met by the private sector, government assistance will be needed for those households in the lowest income categories. Treasure Coast Homeless Services Council, Inc. — Point In Time Report -Homelessness Fact Sheet for Indian River County Reporting agencies: Unsheltered: IRC Jail, New Horizons, The Source, Public Defender's office, Project Response, IRC -Vets, IRC School District, Fellsmare Community Enrichment Program, Breath of Heaven: Sheltered: Homeless Family Center, Samaritan Center, CHS — Youth Transition Center, Woman's Home, Safe Space. January 30, 2015: Total Homeless in County (HUD) = 812 Adults = 550 Children = 262 Disabled Adults = 71 Unemployed Adults = 80 Other Subset Data: Past Foster Care = 12 Persons 18-24 = 22 Veterans = 31 Elderly 62+ = 19 form HUD -50075 (4/2008) PHA Certifications of Compliance with PHA Plans and Related lations U.S. Department of Housing and Urban Development Office of Public and Indian Housing Expires 4/30/2011 PHA Certifications of Compliance with the PHA Plans and Related Regulations: Board Resolution to Accompany the PHA 5 -Year and Annual PHA Plan Acting on behalf of the Board of Commissioners of the Public Housing Agency (PHA) listed below, as its Chairman or other authorized PHA official if there is no Board of Commissioners, 1 approve the submission of the 'x 5 -Year and/or X Annual PHA Plan for the PHA fiscal year beginning Ip �� hereinafter referred to as " the Plan ", of which this document is a part and make the following certifications and agreements with the Department of Housing and Urban Development (HUD) in connection with the submission of the Plan and implementation thereof. I. The Plan is consistent with the applicable comprehensive housing affordability strategy (or any plan incorporating such strategy) for the jurisdiction in which the PHA is located. 2. The Plan contains a certification by the appropriate State or local officials that the Plan is consistent with the applicable Consolidated Plan, which includes a certification that requires the preparation of an Analysis of Impediments to Fair Housing Choice, for the PHA's jurisdiction and a description of the manner in which the PHA Plan is consistent with the applicable Consolidated Plan. 3. The PHA certifies that there has been no change, significant or otherwise, to the Capital Fund Program (and Capital Fund Program/Replacement Housing Factor) Annual Statement(s), since submission of its last approved Annual Plan. The Capital Fund Program Annual Statement/Annual Statement/Performance and Evaluation Report must be submitted annually even if there is no change. 4. The PHA has established a Resident Advisory Board or Boards, the membership of which represents the residents assisted by the PHA, consulted with this Board or Boards in developing the Plan, and considered the recommendations of the Board or Boards (24 CFR 903.13). The PHA has included in the Plan submission a copy of the recommendations made by the Resident Advisory Board or Boards and a description of the manner in which the Plan addresses these recommendations. 5. The PHA made the proposed Plan and all information relevant to the public hearing available for public inspection at least 45 days before the hearing, published a notice that a hearing would be held and conducted a hearing to discuss the Plan and invited public comment. 6. The PHA certifies that it will carry out the Plan in conformity with Title VI of the Civil Rights Act of 1964, the Fair Housing Act, section 504 of the Rehabilitation Act of 1973, and title II of the Americans with Disabilities Act of 1990. 7. The PHA will affirmatively further fair housing by examining their programs or proposed programs, identify any impediments to fair housing choice within those programs, address those impediments in a reasonable fashion in view of the resources available and work with local jurisdictions to implement any of the jurisdiction's initiatives to affirmatively further fair housing that require the PHA's involvement and maintain records reflecting these analyses and actions. 8. For PHA Plan that includes a policy for site based waiting lists: • The PHA regularly submits required data to HUD's 50058 PIC/IMS Module in an accurate, complete and timely manner (as specified in PIH Notice 2006-24); • The system of site-based waiting lists provides for full disclosure to each applicant in the selection of the development in which to reside, including basic information about available sites. and an estimate of the period of time the applicant would likely have to wait to be admitted to units of different sizes and types at each site; • Adoption of site-based waiting list would not violate any court order or settlement agreement or be inconsistent with a pending complaint brought by HUD; • The PHA shall take reasonable measures to assure that such waiting list is consistent with affirmatively furthering fair housing; • The PHA provides for review of its site-based waiting list policy to determine if it is consistent with civil rights laws and certifications, as specified in 24 CFR part 903.7(c)(1). 9. The PHA will comply with the prohibitions against discrimination on the basis of age pursuant to the Age Discrimination Act of 1975. 10. The PHA will comply with the Architectural Barriers Act of 1968 and 24 CFR Part 41, Policies and Procedures for the Enforcement of Standards and Requirements for Accessibility by the Physically Handicapped. 11. The PHA will comply with the requirements of section 3 of the Housing and Urban Development Act of 1968. Employment Opportunities for Low -or Very -Low Income Persons, and with its implementing regulation at 24 CFR Part 135. Previous version is obsolete Page 1 of 2 form HUD -50077 (4/2008) 12. The PHA will comply with acquisition and relocation requirements of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 and implementing regulations at 49 CFR Part 24 as applicable. 13. The PHA will take appropriate affirmative action to award contracts to minority and women's business enterprises under 24 CFR 5.105(a). 14, The PHA will provide the responsible entity or HUD any documentation that the responsible entity or HUD needs to carry out its review under the National Environmental Policy Act and other related authorities in accordance with 24 CFR Part 58 or Part 50, respectively. 15. With respect to public housing the PHA will comply with Davis -Bacon or HUD determined wage rate requirements under Section 12 of the United States Housing Act of 1937 and the Contract Work Hours and Safety Standards Act. 16. The PHA will keep records in accordance with 24 CFR 85.20 and facilitate an effective audit to determine compliance with program requirements. 17. The PHA will comply with the Lead -Based Paint Poisoning Prevention Act, the Residential Lead -Based Paint Hazard Reduction Act of 1992, and 24 CFR Part 35. 18. The PHA will comply with the policies, guidelines, and requirements of OMB Circular No. A-87 (Cost Principles for State, Local and Indian Tribal Governments), 2 CFR Part 225, and 24 CFR Part 85 (Administrative Requirements for Grants and Cooperative Agreements to State, Local and Federally Recognized Indian Tribal Governments). 19. The PHA will undertake only activities and programs covered by the Plan in a manner consistent with its Plan and will utilize covered grant funds only for activities that are approvable under the regulations and included in its Plan. 20. All attachments to the Plan have been and will continue to be available at all times and all locations that the PHA Plan is available for public inspection. All required supporting documents have been made available for public inspection along with the Plan and additional requirements at the primary business office of the PHA and at all other times and locations identified by the PHA in its PHA Plan and will continue to be made available at least at the primary business office of the PHA. 21. The PHA provides assurance as part of this certification that: (i) The Resident Advisory Board had an opportunity to review and comment on the changes to the policies and programs before implementation by the PHA; (ii) The changes were duly approved by the PHA Board of Directors (or similar governing body); and (iii) The revised policies and programs are available for review and inspection, at the principal office of the PHA during normal business hours. 22. The PHA certifies that it is in compliance with all applicable Federal statutory and regulatory requirements. 1'L 13 _:), PHA Name PHA Number/HA Code 5 -Year PHA Plan for Fiscal Years 2015Uw,20111 �_".C� Annual PHA Plan for Fiscal Years 20 t S - 20 11, - APPROVED AS TO FORM AND LEGAL SUFFICIENCY BY DYLAN REINGOLD C''0UNTY ATTORNEY I hereby certify that all the information stated herein, as well as any information provided in the accompaniment herewith, is true and accurate- Warning: HUD will prosecute false claims and statements Conviction may result in criminal and/or civil penalties (18 U S C 1001 1010_ 1012 31 U S.C. 3729, 3802) Previous version is obsolete Page 2 of 2 form HIID-50077 (4/2008)