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HomeMy WebLinkAbout12091RESOLUTION NO. 12091 A RESOLUTION AMENDING THE 2010-2014 CONSOLIDATED PLAN AND 2010-2011 ACTION PLAN APPROVING THE NEIGHBORHOOD STABILIZATION PROGRAM, THE NEIGHBORHOOD STABILIZATION PROGRAM GRANT APPLICATION IN THE AMOUNT OF $1,460,506, AND AUTHORIZING THE DEPARTMENT OF HOUSING AND CITIZEN SERVICES TO SUBMIT THE PLAN TOGETHER WITH ALL REQUIRED AND NECESSARY CERTIFICATIONS, ASSURANCES AND DOCUMENTATION TO THE U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT, AND AUTHORIZING THE PRESIDENT OF THE CITY COUNCIL TO EXECUTE SAME WHEREAS, the Housing and Economic Recovery Act of 2008 established the Neighborhood Stabilization Program (NSP) to assist communities around the nation in addressing problems associated with sub prime lending and home foreclosures; and WHEREAS, the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 provided an additional $1 billion for the NSP that was originally established under the Housing and Economic Recovery Act of 2008; and WHEREAS, the City of Pueblo, based on HUD formula, has been allocated $1,460,506 in Neighborhood Stabilization Program 3 grant funds; and WHEREAS, federal regulations, effective October 19, 2010 and published in the Federal Register (FR–5447–N–01) on October 19, 2010, set forth requirements governing the expenditure of Neighborhood Stabilization Program funds, establishing certain funding ratios for allocating grant funds, and requiring the set aside of 25% of the grant funds to insure benefit to persons of lower-income; and WHEREAS, all Neighborhood Stabilization Program 3 grant funds must be expended under the Community Development Block Grant national objective of low- and moderate income benefit expanded to include individuals and families whose income does not exceed 120% of area median income; and WHEREAS, priority must be given for the expenditure of Neighborhood Stabilization Program 3 grant funds in areas of greatest need. NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF PUEBLO, that: SECTION 1. The substantial amendment to the City of Pueblo’s 2010-2011 Consolidated Annual Action Plan, copies of which have been previously distributed to the members of the City Council and the original having been on file in the City Clerk’s Office for public inspection, is hereby approved, adopted and incorporated herein. SECTION 2. The Director of the Department of Housing and Citizen Services is authorized to execute all documents associated with the Neighborhood Stabilization Program implementation related with the purchase, rehabilitation and conveyance of abandoned and foreclosed upon properties, and is further authorized to move funding among NSP 3 activities as required to ensure timely expenditures SECTION 3. This Resolution shall become effective upon final approval and passage. INTRODUCED: February 28, 2011 BY: Chris Kaufman COUNCILPERSON Background Paper for Proposed RESOLUTION AGENDA ITEM # J-2 DATE: February 28, 2011 DEPARTMENT: HOUSING AND CITIZEN SERVICES DIRECTOR: ADA RIVERA CLARK TITLE A RESOLUTION AMENDING THE 2010-2014 CONSOLIDATED PLAN AND 2010-2011 ACTION PLAN APPROVING THE NEIGHBORHOOD STABILIZATION PROGRAM, THE NEIGHBORHOOD STABILIZATION PROGRAM GRANT APPLICATION IN THE AMOUNT OF $1,460,506, AND AUTHORIZING THE DEPARTMENT OF HOUSING AND CITIZEN SERVICES TO SUBMIT THE PLAN TOGETHER WITH ALL REQUIRED AND NECESSARY CERTIFICATIONS, ASSURANCES AND DOCUMENTATION TO THE U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT, AND AUTHORIZING THE PRESIDENT OF THE CITY COUNCIL TO EXECUTE SAME ISSUE Should City Council approve the required substantial amendment to the 2010-2011 Annual Action Plan in order to receive $1,460,506 in Neighborhood Stabilization Program 3 Community Development Block Grants? RECOMMENDATION Approval of the Resolution. BACKGROUND The Department of Housing and Urban Development (HUD) has granted Pueblo $1,460,506 in Neighborhood Stabilization Program 3 Community Development Block Grant funds under Section 2301(b) of the Housing and Economic Recovery Act of 2008 (Pub. L. 110–289, approved July 30, 2008) (HERA), as amended, and through an additional allocation of funds provided under Section 1497 of the Wall Street Reform and Consumer Protection Act of 2010 (Pub. L. 111–203, approved July 21, 2010) (Dodd-Frank Act). Pueblo, as a recipient of the funds, is required to amend the FY 2010 Action Plan to include the additional funding. The “substantial amendment” identifies the activities to be undertaken by the City in compliance with the Federal Register notice. There is a required 15-day public comment period on the substantial amendment. This period th began on Saturday, February 12. Notices were published in the Pueblo Chieftain and on the City’s website. The application is due to HUD on March 1, 2011. The Plan was distributed to Council under separate cover copies of the amended Plan were available at the City Clerk’s Office, Housing and Citizen Services, and the City’s website. To date no written comments have been received. FINANCIAL IMPACT The grant will provide $1,460,506 in federal funds to include administrative funding. HOME Investment Partnership Act funds will be used in furtherance of the allowable activities. Upon receipt of the grant award letter all funding sources will be identified and brought to the City Council for appropriation. There are no match requirements. CITY OF PUEBLO PUEBLO, COLORADO ‘'D 1 NEIGHBORHOOD STABILIZATION PROGRAM 3 APPLICATION DRAFT SUBSTANTIAL AMENDMENT TO THE 2010 -2014 CONSOLIDATED PLAN AND THE 2010 -2011 ANNUAL ACTION PLAN Page 1 N 'a'' a > ri „ t 4 nF,"",Y .; '� - �.,�:xM.�, � c� �` : ,�, rte. ■ • OMB Number: 4040 -0004 Expuation Date: 01312009 Application for Federal Assistance SF-424 version 02 '1 Type of Submission: `2. Type of Application if Revision, select appropriate letter(s) ❑ Preapplication ® New ® Application ❑ Continuation 'Other (Specify) ❑ Changed/Corrected Application ❑ Revision 3. Date Received 4 Applicant Identifier 5a. Federal Entity Identifier *5b. Federal Award Identifier State Use Only 6. Date Received by State: 17 State Application Identifier 8. APPLICANT INFORMATION: 'a. Legal Name: City of Pueblo, A Municipal Corporation 'b. Employer/Taxpayer Identification Number (EINITIN). c. Organizational DUNS: 84- 6000615 010620284 d. Address: 'Street 1 200 S. Main Street Street 2: 'City Pueblo County Pueblo 'State. Colorado Province. 'Country USA 'Zip / Postal Code 81003 e. Organizational Unit: Department Name: Division Name. Department of Housing and Citizen Services t. Name and contact Information of person to be contacted on matters involving this application: Prefix: Ms. 'First Name: Ada Middle Name: Maria 'Last Name: Clark Suffix: Title: Director Organizational Affiliation. *Telephone Number 719 -553 -2845 Fax Number 719- 553 -2855 'Email: adaclark @pueblo.us Page 2 • OMB Number: 4040 -0004 Expiration Dare 01.31'2009 Application for Federal Assistance SF-424 Version 02 '8. Type of Applicant 1 Select Applicant Type: C City or Township Govemment Type of Applicant 2: Select Applicant Type. Type of Applicant 3: Select Applicant Type: 'Other (Specify) '10 Name of Federal Agency' Housing and Urban Development 11 Catalog of Federal Domestic Assistance Number 14.218 CFDA Title: Community Development Block Grant *12 Funding Opportunity Number 'Title: 13. Competition Identification Number' Title: 14. Areas Affected by Project (Cities, Counties, States, etc.): City of Pueblo 15. Descriptive Title of Applicant's Project: Recipient will use the funds awarded to stabilize neighborhoods whose viability has been, and continues to be, damaged by the economic effects of properties that have been foreclosed upon and abandoned. The City will pursue 3 activities: 1) purchase and rehabilitation; 2) redevelopment; and 3) land banking of abandoned and foreclosed properties, which will be sold to eligible households. Page 3 OMB Number: 4040 -0004 Expiration Date: 0131:2009 Application for Federal Assistance SF-424 Version 02 16. Congressional Districts Of: 'a. Applicant: 3 'b. Program/Project: 3 17 Proposed Project: 'a. Start Date' 04 -01 -2011 *b. End Date: 04 -01 -2014 18. Estimated Funding ($): 'a. Federal $1,460,506 'b Applicant 'c. State 'd. Local 'e. Other 'f. Program Income 'g. TOTAL $1 460,506 '19. Is Application Subject to Review By State Under Executive Order 12372 Process? ❑ a. This application was made available to the State under the Executive Order 12372 Process for review on ❑ b. Program is subject to E.0 12372 but has not been selected by the State for review. c. Program is not covered by E. 0 12372 '20. Is the Applicant Delinquent On Any Federal Debt? (If "Yes" provide explanation.) ❑ Yes ® No 21 'By signing this application, I certify (1) to the statements contained in the list of certifications" and (2) that the statements herein are true, complete and accurate to the best of my knowledge. I also provide the required assurances" and agree to comply with any resulting terms if I accept an award. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties. (U S. Code, Title 218, Section 1001) '* I AGREE '*The list of certifications and assurances, or an Internet site where you may obtain this list. is contained in the announcement or agency specific instructions Authorized Representative: Prefix: Mr. *First Name: Ray Middle Name: 'Last Name. Suffix: Aquilera 'Title. President of the City Council 'Telephone Number 719 - 553 -2655 I Fax Number 719 - 553 -2698 Email: raguilera@pueblo.us 'Signature of Authorized Representative: 2 i1 'Date Signed:2 /282011 Authorized for Local Reproduction Standard Form 424 (Revised 10/2005) Prescribed by OMB Circular A -102 Page 4 `¢. _ .... •y,( s K ,., e a _,..x .. ,� t.z'._� .Mn k, 'y'a.w k... r ':`k,�.n `�.,fi.�� 1. NSP3 Grantee Information NSP3 Program Administrator Contact Information Name (Last, First) Ada Rivera Clark Email Address adaclark(pueblo.us Phone Number 719 - 553 -2850 Mailing Address 2631 E. 4 St. Pueblo, CO 81001 1 Areas of Greatest Need Map Submission The map generated at the HUD NSP3 Mapping Tool for Preparing Action Plan website is included as an attachment. Data Sources Used to Determine Areas of Greatest Need Describe the data sources used to determine the areas of greatest need. Response The Department of Housing and Urban Development (HUD) provided local governments with an estimate of the number of homes that have completed or were at risk of becoming foreclosed by using the following data 1 Rate of Subprime Loans. This is measured with HMDA data on high cost and high leverage loans made between 2004 and 2007 2 Increase in Unemployment Rate between March 2005 and March 2010 These data are from the BLS Local Area Unemployment Statistics, at the city and county level 3 Fall in Home Value from Peak to Trough Home value data at the Metropolitan Area level is available quarterly through March 2010 from the Federal Housing Finance Agency Home Price Index. HUD rated each census tract and / or neighborhood on a scale from 1 to 20, with 20 being the areas with greatest need using this data This foreclosure score allows local governments to target funding to those areas with the highest percentage of home foreclosures, the highest percentage of homes financed by subprime mortgage related loans and those areas likely to face a significant rise in the rate of home foreclosures. The Department of Housing and Citizen Services mapped various neighborhoods within the City to identify those areas of greatest need in which we could have the greatest impact, as recommended by the Notice of Formula Allocations. Eight areas were mapped in the Bessemer neighborhood Eight areas were mapped in the Southside neighborhood Seven areas were mapped in the Northside neighborhood Five areas were mapped in the Eastside neighborhood The areas were chosen initially based on housing prices and income levels. The HUD NSP3 Mapping Tool was used to retrieve information on foreclosures within the outlined areas, pp Page 5 • , .»; ,� ' „ 3., , �'�" ,�``Jrm . r ..r .... r .. r r _ , . ..� �' F . n P .. .. , t �aY� .,.a 4 `.," y and to determine the impact percentage that would be required under the grant. The Department of Housing and Citizen Services worked with the real estate agency currently under contract for NSP 1 to provide information on the listings in the areas that are being considered The information contained in the report provided the following: list price, selling price, sold /list ( %), price /sq ft ($), price /acre ($); days on market. Realty Tract data was also used to map listings in the proposed target areas to gain a visual perspective of where impacts could be made NSP1 projects were overlayed on these maps to add an additional layer of impact. Determination of Areas of Greatest Need Describe how the areas of greatest need were established. Response HUD has established several recommended guidelines for communities to use when selecting their NSP target area Primarily, HUD is recommending that the community be able to address at least 20% of the REO properties. Because NSP3 funding is only $1,460,506, it is estimated that 16 properties will be acquired and rehabilitated with NSP3 funds (HUD is not allowing communities to use the homes that may be subsequently purchased with NSP3 program income in this application) This means that the NSP3 site will need to be modest in size The areas selected lay within census tracts 6, 7, 8, 12, 20 and 21, some of which are part of the NSP 1 target areas. Initial review of the data provided by the above - mentioned sources revealed several areas of greatest need In an effort to meet the impact requirement under the grant, the City chose to concentrate on three areas. The NSP3 target area consists of three neighborhoods - Bessemer, Eastside, Westside /Downtown There were certainly areas of much greater need, based on the number of foreclosures in a neighborhood, however the number of units required to be processed in conjunction with the funding available precludes the City from making a substantial impact in those areas. The selected target areas have smaller land areas and show impact numbers that could be reasonably achieved with the funding that will be made available from NSP 3 and HOME funding. The neighborhoods identified by the NSP3 grantee as being the areas of greatest need must have an individual or average combined index score for the grantee's identified target geography that is not Tess than the lesser of 17 or the twentieth percentile most needy score in an individual state For example, if a state's twentieth percentile most needy census tract is 17, the requirement will be a minimum need of 17 If, however, a state's twentieth percentile most needy census tract is 15, the requirement will be a minimum need of 15 Area 1 Bessemer Target 1 Neighborhood NSP3 Score 20 State Minimum Threshold NSP3 Score 17 Total Housing Units in Neighborhood 1780 Area Benefit Eligibility Percent Persons Less than 120% AMI 87 91 Percent Persons Less than 80% AMI 69.53 Page 6 USPS Residential Addresses in Neighborhood 1767 Residential Addresses Vacant 90 or more days (USPS, March 2010) 146 Residential Addresses NoStat (USPS, March 2010) 23 Total Housing Units to receive a mortgage between 2004 and 2007 491 Percent of Housing Units with a high cost mortgage between 2004 and 2007 41.56 Percent of Housing Units 90 or more days delinquent or in foreclosure 11.33 Number of Foreclosure Starts in past year 61 Number of Housing Units Real Estate Owned July 2009 to June 2010 Metropolitan Area (or non - metropolitan area balance) percent fall in home value since peak value (Federal Housing Finance Agency Home Price Index through June 2010) -8 Place (if place over 20,000) or county unemployment rate June 2005. 7 6 Place (if place over 20,000) or county unemployment rate June 2010. 9 9 Estimated number of properties needed to make an impact in identified target area (20% of REO in past year) 13 The above number is higher than the number of properties that can be purchased with the funding being made available, however, as NSP1 funds were targeted to this area the impact will be larger Area 2 Eastside URA Target 1 Neighborhood NSP3 Score 20 State Minimum Threshold NSP3 Score 17 Total Housing Units in Neighborhood 755 Area Benefit Eligibility Percent Persons Less than 120% AMI 92.54 Percent Persons Less than 80% AMI 83 78 USPS Residential Addresses in Neighborhood 748 Residential Addresses Vacant 90 or more days (USPS, March 2010) 96 Residential Addresses NoStat (USPS, March 2010) 8 Total Housing Units to receive a mortgage between 2004 and 2007 196 Percent of Housing Units with a high cost mortgage between 2004 and 2007 48.39 Percent of Housing Units 90 or more days delinquent or in foreclosure 12.25 Number of Foreclosure Starts in past year 26 Number of Housing Units Real Estate Owned July 2009 to June 2010 15 Metropolitan Area (or non - metropolitan area balance) percent fall in home value since peak value (Federal Housing Finance Agency Home Price Index through June 2010) -8 Place (if place over 20,000) or county unemployment rate June 2005. 7 6 Place (if place over 20,000) or county unemployment rate June 2010. 9.9 •Bureau of Labor Statistics Local Area Unemployment Statistics Page 7 Estimated number of properties needed to make an impact in identified target area (20% of REO in past year) 5 Area 3 Downtown Target 1 Neighborhood NSP3 Score 20 State Minimum Threshold NSP3 Score 17 Total Housing Units in Neighborhood 901 Area Benefit Eligibility Percent Persons Less than 120% AMI 92.91 Percent Persons Less than 80% AMI 77 13 USPS Residential Addresses in Neighborhood 875 Residential Addresses Vacant 90 or more days (USPS, March 2010) 84 Residential Addresses NoStat (USPS, March 2010) 23 Total Housing Units to receive a mortgage between 2004 and 2007 176 Percent of Housing Units with a high cost mortgage between 2004 and 2007 43 77 Percent of Housing Units 90 or more days delinquent or in foreclosure 11.19 Number of Foreclosure Starts in past year 22 Number of Housing Units Real Estate Owned July 2009 to June 2010 13 Metropolitan Area (or non - metropolitan area balance) percent fall in home value since peak value (Federal Housing Finance Agency Home Price Index through June 2010) -8 Place (if place over 20,000) or county unemployment rate June 2005. 7 6 Place (if place over 20,000) or county unemployment rate June 2010. 9 9 •Bureau of Labor Statistics Local Area Unemployment Statistics Estimated number of properties needed to make an impact in identified target area (20% of REO in past year) 5 Page 8 ; 4 " '_, s� -.' R _ "'A „ %'. .. .',k� r, �.a 4.r ,a 2 Definitions and Descriptions Definitions Term Definition Blighted Structure "Blighted Area" means an area that, in its present condition and use and, by reason of the presence of at least four of the following factors, substantially impairs or arrests the sound growth of the municipality, retards the provision of housing accommodations, or constitutes an economic or social liability, and is a menace to public health, safety, morals, or welfare [a] Slum, deteriorated, or deteriorating structures; [b] Predominance of defective or inadequate street layout; [c] Faulty lot layout in relation to size, adequacy, accessibility, or usefulness, [d] Unsanitary or unsafe conditions; [e] Deterioration of site or other improvements, [f] Unusual topography or inadequate public improvements or utilities; [g] Defective or unusual conditions of title rendering the title non - marketable, [h] The existence of conditions that endanger life or property by fire or other causes, [i] Buildings that are unsafe or unhealthy for persons to live or work because of building code violations, dilapidation, deterioration, defective design, physical construction, or faulty or inadequate facilities, [j] Environmental contamination of buildings or property; [k.5] The condition of health, safety, or welfare factors requiring high levels of municipal services or substantial physical underutilization or vacancy of sites, buildings or other improvements, [I] If there is no objection of such property owner or owners and the tenant or tenants of such owners, in and, to the inclusion of such property in an urban renewal area, "blighted area' also means an area that, in its present condition and use and, by reason of the presence of any one of the factors specified in paragraphs [a] to [k.5] of this subsection (2), substantially impairs or arrests the sound growth of the municipality, retards the provision of housing accommodations, or constitutes an economic or social liability, and is a menace to the public health, safety, morals or welfare For purposes of this paragraph (1), the fact that an owner of interest in such property does not object to the inclusion of such property in the urban renewal area does not mean that the owner has waived any rights of such owner in connection with laws governing condemnation SOURCE COLORADO REVISED STATUTE 31 -25- 103(2) Affordable Rents Rents are considered affordable when household rent payments do not exceed HUD - defined Fair Market Rent Limits and Rent Payments added to a household utility allowance do not exceed 30% of a family's adjusted income Page 9 Descriptions Term Definition Long -Term Affordability The City will utilize a "Recapture Method" as defined by 24 CFR 92.254 (5) (ii) through liens on each property to ensure that the homeowner cannot recapture a windfall profit. All NSP funds will be recaptured if NSP homeowners should sell their homes before the time period of designated "Long -Term Affordability" expires. These recapture provisions will be enforced by a note and second mortgage on the property The City will follow the HOME program standards as a minimum in complying with the long -term affordability component of the NSP3 program Funding provided per rental or homeownership unit less than $15,000 will have a 5 -year affordability period, funding provided between $15,000 - $40,000 per unit will have a 10 -year affordability period, and funding greater the $40,000 per unit will have a 15 -year affordability period New construction rental projects will have a 20 -year affordability period, regardless of the amount of subsidy, as required by the HOME regulations. Repayments will be re- invested in the NSP program on eligible activities. Housing Rehabilitation Standards The City of Pueblo Rehabilitation Program Standards establish the requirements that all properties must meet, following the completion of any rehabilitation using federal, state or local funds. The standards require that, upon completion, all homes meet the following statutory requirements: 1997 Uniform Housing Code, Section 8 Housing Quality Standards HUD Lead Safe Work Practices HOME, CDBG and NSP program regulations (if applicable) The rehabilitation standards also specify the types of products that must be installed to insure that any older obsolete products and appliances, such as windows, doors, lighting, hot water heaters, furnaces, boilers, air - conditioning units, and refrigerators are replaced with Energy Star - labeled products. The rehabilitation specifications require that water efficient toilets, showers and faucets be installed when these fixtures are replaced Because technology is improving and the cost for Energy Star appliances continues to decrease, the standards are constantly changing to provide the products with the lowest energy demand New homes and gut rehabilitation projects will also be required to meet the standard for Energy Star Qualified New Homes. Should there be any gut rehabilitation of mid or high rise multifamily housing, that housing must all be designed to meet the American Society of Heating, Refrigerating and Air Conditioning Engineers Standard 90 1 -2004, Appendix G plus 20 percent. Page 10 . 1.,! *-,0 :. "ux « `x+.`' as;_ 3 k*. a a _a'� 4• . X = , t n,, s s' ! ..fir,.,, a ! R The rehabilitation standards require compliance with the accessibility standards at 24 CFR part 8. 3 Low - Income Targeting Low - Income Set -Aside Amount Enter the low- income set -aside percentage in the first field The field for total funds set aside will populate based on the percentage entered in the first field and the total NSP3 grant. Identify the estimated amount of funds appropriated or otherwise made available under the NSP3 to be used to provide housing for individuals or families whose incomes do not exceed 50 percent of area median income Response Total low- income set -aside percentage (must be no Tess than 25 percent) 25.00% Total funds set aside for low- income individuals = $365,126.50 Meeting Low - Income Target Provide a summary that describes the manner in which the low- income targeting goals will be met. Response All NSP3 funds will be used to assist persons whose income does not exceed 120% of area median income, however, priority will be given to persons whose income does not exceed 80% of area median income No less than 25% of the grant must be used for the redevelopment of abandoned or foreclosed upon homes or residential properties that will be used to house individuals or families who do not exceed 50% of the area median income The DHCS will meet the requirement by placing an emphasis on the acquisition of an existing multi- family property to rehabilitate or by the redevelopment of land for multi - family purposes. The funding required to meet the 25% set -aside amount will also allow for the redevelopment of 2 to 3 single - family properties for this target population Ideally the requirement will be met through the development of rental housing. 4 Acquisition and Relocation Demolition or Conversion of LMI Units Does the grantee intend to demolish or convert any low- and moderate - income dwelling units (i.e , 5 80% of area median income)? Yes If yes, fill in the table below Question Number of Units The number of low- and moderate - income dwelling units —i.e , <_ 80% of area median income — reasonably expected to be demolished or converted as a direct Page 11 .. .. , to �fi... c r: ,.a .x�`'r. r_.,s *:,a� rr-. result of NSP- assisted activities. 5 The number of NSP affordable housing units made available to low -, moderate -, and middle- income households —i.e , <_ 120% of area median income — reasonably expected to be produced by activity and income level as provided for in DRGR, by each NSP activity providing such housing (including a proposed time schedule for commencement and completion) 5 The number of dwelling units reasonably expected to be made available for households whose income does not exceed 50 percent of area median income 0 5 Public Comment Citizen Participation Plan Briefly describe how the grantee followed its citizen participation plan regarding this proposed substantial amendment or abbreviated plan. Response The NSP3 Action Plan was posted on the City's website for a minimum of 15 -days. A presentation was made to City Council during a Worksession on February 7, 2001 In addition, the City published a public notice informing citizens of the availability of the Plan for review and comments in the Pueblo Chieftain newspaper on February 12, 2011 Council adopted the NSP 3 Action Plan on February 28, 2011 Summary of Public Comments Received The summary of public comments received is included as an attachment. 6. NSP Information by Activity Enter each activity name and fill in the corresponding information If you have fewer than seven activities, please delete any extra activity fields. (For example, if you have three activities, you should delete the tables labeled "Activity Number 4," "Activity Number 5," "Activity Number 6," and "Activity Number 7 " If you are unsure how to delete a table, see the instructions above The field labeled "Total Budget for Activity" will populate based on the figures entered in the fields above it. Consult the NSP3 Program Design Guidebook for guidance on completing the "Performance Measures" component of the activity tables below Activity Number 1 Activity Name Housing Redevelopment Select all that apply ❑ Eligible Use A. Financing Mechanisms ❑ Eligible Use B Acquisition and Rehabilitation Uses ❑ Eligible Use C. Land Banking ❑ Eligible Use D Demolition ® Eligible Use E Redevelopment CDBG Activity or 24 CFR 570.201(a) Acquisition, Activities (b) Disposition, Page 12 (c) Public facilities and improvements, (e) Public services for housing counseling, but only to the extent that counseling beneficiaries are limited to prospective purchasers or tenants of the redeveloped properties, (i) Relocation, and (n) Direct homeownership assistance (as modified below) 24 CFR 570.202 Eligible rehabilitation and preservation activities for demolished or vacant properties. 24 CFR 570.204 Community based development organizations. HUD notes that any of the activities listed above may include required homebuyer counseling as an activity delivery cost. National Objective Low Moderate Middle Income Housing (LMMH) The City will redevelop 6 homes to be sold to those clients whose income does not exceed 120% AMI Once the redevelopment work is completed, the homes will be marketed for sale Duration of Assistance Assistance will be regulated by HOME Affordability Requirements to ensure long -term affordability Tenure Ownership and rental Rate of Interest Rate Funding will be provided as a soft second at 0% Activity Description interest. Beneficiaries. Properties will be sold to households at 120% or below of the area median income The City of Pueblo will give local contractors priority rating on the RFP Contractors who hire new employees must, to the maximum extent possible, hire workers who live in the NSP3 program area and contract with small businesses that are either owned and operated by persons residing in the vicinity of the project. A provision will be inserted in all contracts incorporating this requirement. Location Description Bessemer, Eastside URA, Westside /Downtown Source of Funding Dollar Amount Budget NSP3 $700,000 HOME Investment Partnership Act $350,000 (Other funding source) $0 00 Total Budget for Activity $1,050,000 Performance Measures Six properties will be redeveloped as housing and sold to clients at or below 120% AMI Projected Start Date 4/1/2011 Projected End Date 4/1/2014 Page 13 Name Department of Housing and Citizen Responsible Services Organization Location 2631 E 4 St. Pueblo, CO 81003 Administrator Contact Info Ada Clark, Director adaclarkPpueblo.us; 719 - 553 -2850 Activity Number 2 Purchase and rehabilitate homes and residential properties that have been Activity Name abandoned or foreclosed upon, in order to sell or rent such homes and properties. Select all that apply ❑ Eligible Use A. Financing Mechanisms Use • Eligible Use B Acquisition and Rehabilitation ❑ Eligible Use C. Land Banking ❑ Eligible Use D Demolition ❑ Eligible Use E Redevelopment 24 CFR 570.201(a) Acquisition 24 CFR 570.201(b) Disposition CDBG Activity or 24 CFR 570.201(e) Public services for housing counseling, but only to the Activities extent that the counseling beneficiaries are limited to prospective purchasers or tenants of the assisted properties. 24 CFR 570.201(i) Relocation National Objective Low Moderate Middle Income Housing (LMMH) DHCS will acquire 5 foreclosed and abandoned properties in the targeted area for sale or lease to eligible families The ownership program will be substantially the same as the NSP1 program now being administered by DHCS for the City The homes will be sold to eligible families for the appraised price or the cost of acquisition and rehabilitation, whichever is less. At the time of sale of the home, the sales price, less any subsidy needed to make the home affordable to the borrower, will be repaid to the NSP program and used for other NSP3 eligible activities. The rental program will also be substantially the same as the NSP1 program being administered by the DHCS. Upon completion of the rental units, the property will be transferred to a local non - profit for ownership To insure Activity Description that the rents are affordable, the maximum that the non - profit will be able to charge for rent will be the HOME high rents. The subsidy will be structured to provide long term affordability This activity will address local housing market conditions by rehabilitating structures in high risk neighborhoods. This target area has many homes that were built in the earlier part of the century and the systems have become obsolete, as well as the structure not meeting code The rehabilitation of these units will allow for safe , decent and sanitary housing to the low to moderate - income population Duration of Assistance Assistance will be regulated by HOME Affordability Page 14 • x. • _ • ._ � 7 Requirements to ensure long -term affordability Tenure Ownership and rental Rate of Interest Rate Funding will be provided as a soft second at 0% interest. Beneficiaries. Properties will be sold to households at 120% or below of the area median income The City of Pueblo will give local contractors priority rating on the RFP Contractors who hire new employees must, to the maximum extent possible, hire workers who live in the NSP3 program area and contract with small businesses that are either owned and operated by persons residing in the vicinity of the project. A provision will be inserted in all contracts incorporating this requirement. Location Description Bessemer, Eastside URA, Westside /Downtown Source of Funding Dollar Amount Budget NSP3 $460,000 HOME Investment Partnership Act $200,000 (Other funding source) $0.00 Total Budget for Activity $660,000 Performance Measures Purchase and Rehabilitation of 5 abandoned or foreclosed properties Projected Start Date 4/1/2011 Projected End Date 4/1/2014 Name Department of Housing and Citizen Responsible Services Organization Location 2631 E. 4 St. Pueblo, CO 81003 Administrator Contact Info Ada Clark, Director adaclark@pueblo.us; 719 - 553 -2850 Page 15 Activity Number 3 Activity Name Land Banking Select all that apply ❑ Eligible Use A. Financing Mechanisms ❑ Eligible Use B Acquisition and Rehabilitation Use ® Eligible Use C. Land Banking n Eligible Use D Demolition ❑ Eligible Use E Redevelopment CDBG Activity or 24 CFR 570.2019(a)Acquisition, and (b)Disposition Activities National Objective Low Moderate Middle Income Housing (LMMH) The City will acquire and dispose of property within 10 years by 1) holding and maintaining the home in its portfolio for future redevelopment; 2) demolishing the home if it is blighted and maintain the property in its portfolio, 3) selling the cleared site to a developer for redevelopment; or 4) rehabilitating the home and either selling it to an eligible hombuyer or to a local non - profit partner as a rental property The City will hold properties within its Vacant Lot Recycle Program This activity will address local housing market conditions by demolishing and land banking blighted structures in high risk neighborhoods. These lots will be maintained and redeveloped as the neighborhood is stabilized and demand for rental or homeownership opportunities returns. Duration of Assistance Assistance will be regulated by HOME Affordability Requirements to ensure Tong -term affordability Tenure Ownership and rental Activity Description Rate of Interest Rate Funding will be provided as a soft second at 0% interest. Beneficiaries. Properties will be sold to households at 1200 or below of the area median income Benefits. The demolition of blighted properties will eliminate health and safety concerns of existing neighbors, as well, as providing for the immediate aesthetic improvements that the demolition of such structures provides. In the long -term it will provide for safe and decent affordable housing for low to moderate - income families. New homes and gut rehabilitation projects will also be required to meet the standard for Energy Star Qualified New Homes, which will provide for continued affordability through savings in energy consumption. Page 16 x � ,. b tz fl 1r' The City of Pueblo will give local contractors priority rating to contractors who hire, to the maximum extent possible, workers who live in the NSP3 program area and contract with small businesses that are either owned and operated by persons residing in the vicinity of the project. A provision will be inserted in all contracts incorporating this requirement. Eligible activities are costs directly associated with deconstruction and demolition (includes utility shut -off and hazardous materials testing and removal), clearance, removal and disposition of materials, site restoration (grading, seeding, curb replacement) Location Description Bessemer, Eastside URA, Westside /Downtown Source of Funding Dollar Amount Budget NSP3 $154,456 $0 (Other funding source) $0 Total Budget for Activity $154,456 Performance Measures Properties acquired estimated at 5 Projected Start Date 4/11/2011 Projected End Date 4/11/2014 Name Department of Housing and Citizen Responsible Services Organization Location 2631 E 4 St. Pueblo, CO 81003 Administrator Contact Info Ada Clark, Director adaclarkPpueblo.us; 719 - 553 -2850 Page 17 4:, � s v .. -.. _ _. a . ��. , , � ,, a � �:P', .��nti � +ta4° K „ t 5 e , ° "�.e x��a,M�'ta Activity Number 4 Activity Name Administration Select all that apply El Eligible Use A. Financing Mechanisms ❑ Eligible Use B Acquisition and Rehabilitation Uses ❑ Eligible Use C. Land Banking ❑ Eligible Use D Demolition ❑ Eligible Use E Redevelopment CDBG Activity or Administration — General Management and Oversight as allowed under 24 Activities CFR 570.206 National Objective N/A Funding will provide for the administration of the NSP 3 program over a 3 Activity Description year - period Staff will develop request for proposals for professional services and contractors. construction supervision, accounting and reporting to HUD Location Description Department of Housing and Citizen Services Source of Funding Dollar Amount Budget NSP3 $146,050 HOME Investment Partnership Act $0.00 (Other funding source) $0.00 Total Budget for Activity $146,050 Performance Measures N/A Projected Start Date 4/1/2011 Projected End Date 4/1/2014 Department of Housing and Citizen Name Services Responsible Location 2631 E 4 St. Pueblo, CO 81003 Organization Administrator Contact Info Ada Clark, Director adaclarkPpueblo.us, 719 - 553 -2850 Page 18 7 Certifications Certifications for State and Entitlement Communities (1) Affirmatively furthering fair housing. The jurisdiction certifies that it will affirmatively further fair housing, which means that it will conduct an analysis to identify impediments to fair housing choice within the jurisdiction, take appropriate actions to overcome the effects of any impediments identified through that analysis, and maintain records reflecting the analysis and actions in this regard (2) Anti - displacement and relocation plan. The applicant certifies that it has in effect and is following a residential anti - displacement and relocation assistance plan (3) Anti - lobbying. The jurisdiction must submit a certification with regard to compliance with restrictions on lobbying required by 24 CFR part 87, together with disclosure forms, if required by that part. (4) Authority of jurisdiction. The jurisdiction certifies that the consolidated plan or abbreviated plan, as applicable, is authorized under state and local law (as applicable) and that the jurisdiction possesses the legal authority to carry out the programs for which it is seeking funding, in accordance with applicable HUD regulations and other program requirements. (5) Consistency with plan. The jurisdiction certifies that the housing activities to be undertaken with NSP funds are consistent with its consolidated plan or abbreviated plan, as applicable (6) Acquisition and relocation. The jurisdiction certifies that it will comply with the acquisition and relocation requirements of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended (42 U.S.C. 4601), and implementing regulations at 49 CFR part 24, except as those provisions are modified by the notice for the NSP program published by HUD (7) Section 3. The jurisdiction certifies that it will comply with section 3 of the Housing and Urban Development Act of 1968 (12 U.S.C. 1701u), and implementing regulations at 24 CFR part 135 (8) Citizen participation. The jurisdiction certifies that it is in full compliance and following a detailed citizen participation plan that satisfies the requirements of Sections 24 CFR 91 105 or 91 115, as modified by NSP requirements. (9) Following a plan. The jurisdiction certifies it is following a current consolidated plan (or Comprehensive Housing Affordability Strategy) that has been approved by HUD [Only States and entitlement jurisdictions use this certification j (10) Use of funds. The jurisdiction certifies that it will comply with the Dodd -Frank Wall Street Reform and Consumer Protection Act and Title XII of Division A of the American Recovery and Reinvestment Act of 2009 by spending 50 percent of its grant funds within 2 years, and spending 100 percent within 3 years, of receipt of the grant. (11) The jurisdiction certifies: Page 19 a that all of the NSP funds made available to it will be used with respect to individuals and families whose incomes do not exceed 120 percent of area median income, and b The jurisdiction will not attempt to recover any capital costs of public improvements assisted with CDBG funds, including Section 108 loan guaranteed funds, by assessing any amount against properties owned and occupied by persons of low- and moderate - income, including any fee charged or assessment made as a condition of obtaining access to such public improvements. However, if NSP funds are used to pay the proportion of a fee or assessment attributable to the capital costs of public improvements (assisted in part with NSP funds) financed from other revenue sources, an assessment or charge may be made against the property with respect to the public improvements financed by a source other than CDBG funds. In addition, with respect to properties owned and occupied by moderate - income (but not low- income) families, an assessment or charge may be made against the property with respect to the public improvements financed by a source other than NSP funds if the jurisdiction certifies that it lacks NSP or CDBG funds to cover the assessment. (12) Excessive force The jurisdiction certifies that it has adopted and is enforcing: a A policy prohibiting the use of excessive force by law enforcement agencies within its jurisdiction against any individuals engaged in nonviolent civil rights demonstrations, and b. A policy of enforcing applicable state and local laws against physically barring entrance to, or exit from, a facility or location that is the subject of such nonviolent civil rights demonstrations within its jurisdiction (13) Compliance with anti - discrimination laws. The jurisdiction certifies that the NSP grant will be conducted and administered in conformity with Title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d), the Fair Housing Act (42 U.S.C. 3601- 3619), and implementing regulations. (14) Compliance with lead -based paint procedures. The jurisdiction certifies that its activities concerning lead -based paint will comply with the requirements of part 35, subparts A, B, J, K, and R of this title (15) Compliance with laws. The jurisdiction certifies that it will comply with applicable laws. (16) Vicinity hiring. The jurisdiction certifies that it will, to the maximum extent feasible, provide for hiring of employees that reside in the vicinity of NSP3 funded projects or contract with small businesses that are owned and operated by persons residing in the vicinity of NSP3 projects. (17) Development of affordable rental housing. The jurisdiction certifies that it will be abide by the procedures described in its NSP3 Abbreviated Plan to create preferences for the development of affordable rental housing for properties assisted with NSP3 funds. L,A<W February 28, 2011 Signature /Authorized Official Date President of Citv Council Title Page 20 Attachment 1— Mapping Submission Neighborhood ID 2883056 NSP3 Planning Data Grantee ID' 0812780E Grantee State: CO Grantee Name: PUEBLO Grantee Address: Grantee Email. adaclark @pueblo.us Neighborhood Name. Bessemer Target 1 Date:2011 -02 -04 00:00:00 NSP3 Score The neighborhoods identified by the NSP3 grantee as being the areas of greatest need must have an individual or average combined index score for the grantee's identified target geography that is not less than the lesser of 17 or the twentieth percentile most needy score in an individual state. For example, if a state's twentieth percentile most needy census tract is 18, the requirement will be a minimum need of 17 If however a state's twentieth percentile most needy census tract is 15, the requirement will be a minimum need of 15 If more than one neighborhood is identified in the Action Plan, HUD will average the Neighborhood Scores, weighting the scores by the estimated number of housing units In each identified neighborhood. Neighborhood NSP3 Score. 20 State Minimum Threshold NSP3 Score 17 Total Housing Units in Neighborhood: 1780 Area Benefit Eligibility Percent Persons Less than 120% AMI: 87.91 Percent Persons Less than 80% AMI 69.53 Neighborhood Attributes (Estimates) Vacancy Estimate LISPS data on addresses not receiving mail In the last 90 days or "NoStat" can be a useful measure of whether or not a target area has a serious vacancy problem. For urban neighborhoods, HUD has found that neighborhoods with a very high number vacant addresses relative to the total addresses In an area to be a very good indicator of a current for potentially serious blight problem. The LISPS "NoStat" Indicator can mean different things. In rural areas, it is an indicator of vacancy However it can also be an address that has been issued but not ever used, it can indicate units under development, and it can be a very distressed property (most of the still flood damaged properties in New Orleans are NoStat). When using this variable, users need to understand the target area identified. In addition the housing unit counts HUD gets from the US Census indicated above are usually close to the residential address counts from the USPS below However If the Census and LISPS counts are substantially different for your identified target area, users are advised to use the Information below with caution. For example if there are many NoStats in an area for units never built, the USPS residential address count may be larger than the Census number if the area is a rural area largely served by PO boxes it may have fewer addresses than housing units. USPS Residential Addresses in Neighborhood: 1767 Residential Addresses Vacant 90 or more days (LISPS, March 2010): 146 Residential Addresses NoStat (LISPS, March 2010). 23 Page 21 Foreclosure Estimates HUD has developed a model for predicting where foreclosures are likely That model estimates serious delinquency rates using data on the leading causes of foreclosures - subprime loans (HMDA Census Tract data on high cost and highly leveraged loans), increasing unemployment (BLS data on unemployment rate change), and fall in home values (FHFA data on house price change). The predicted serious delinquency rate is then used to apportion the state total counts of foreclosure starts (from the Mortgage Bankers Association) and REOs (from RealtyTrac) to individual block groups. Total Housing Units to receive a mortgage between 2004 and 2007 491 Percent of Housing Units with a high cost mortgage between 2004 and 2007 41.56 Percent of Housing Units 90 or more days delinquent or in foreclosure: 11 33 Number of Foreclosure Starts in past year 61 Number of Housing Units Real Estate Owned July 2009 to June 2010' 37 HUD is encouraging grantees to have small enough target areas for NSP 3 such that their dollars will have a visible impact on the neighborhood. Nationwide there have been over 1.9 million foreclosure completions in the past two years. NSP 1 2, and 3 combined are estimated to only be able to address 100 000 to 120 000 foreclosures. To stabilize a neighborhood requires focused investment. Estimated number of properties needed to make an impact in identified target area (20% of REO in past year): 13 Supporting Data Metropolitan Area (or non - metropolitan area balance) percent fall in home value since peak value (Federal Housing Finance Agency Home Price Index through June 2010): -8 Place (if place over 20,000) or county unemployment rate June 2005' 7.6 Place (if place over 20,000) or county unemployment rate June 2010' 9 9 'Bureau of Labor Statistics Local Area Unemployment Statistics Market Analysis. HUD is providing the data above as a tool for both neighborhood targeting and to help inform the strategy development. Some things to consider 1 Persistent Unemployment. Is this an area with persistently high unemployment? Serious consideration should be given to a rental strategy rather than a homeownership strategy 2. Home Value Change and Vacancy Is this an area where foreclosures are largely due to a combination of falling home values, a recent spike In unemployment, and a relatively low vacancy rate'? A down payment assistance program may be an effective strategy 3. Persistently High Vacancy Are there a high number of substandard vacant addresses in the target area of a community with persistently high unemployment? A demolition /land bank strategy with selected acquisition rehab for rental or lease- purchase might be considered 4 Historically low vacancy that is now rising. A targeted strategy of acquisition for homeownership and rental to retain or regain neighborhood stability might be considered. 5. Historically high cost rental market. Does this market historically have very high rents with low vacancies? A strategy of acquiring properties and developing them as long -term affordable rental might be considered. Latitude and Longitude of corner points - 104.612761 38.249640 -104 612803 38.237371 - 104.625506 38.237101 -104 625421 38.249707 Page 22 Blocks Comprising Target Neighborhood 081010020003006, 081010020003008, 081010020003012,081010020003011 081010020003010 081010020003007 081010020004012,081010020004011 081010020004010 081010020004009 081010020004008,081010020004007 081010020004004 081010020005000 081010020005001 081010020005003, 081010020005005,081010020005007 081010020005008 ,081010020005006, 081010020005004 081010020005002, 081010021001002,081010021001004 081010021001011, 081010021001010 081010021001009 081010021001003 081010021002000 ,081010021002002, 081010021002003 081010021002001 081010021002004 081010021002006 ,081010021002008, 081010021002010 081010021002014 081010021002013 081010021002012,081010021002011 081010021002009 081010021002007 081010021002005 081010021003000 081010021003012, 081010021003011 081010021003010 081010021003009 081010021003008 ,081010021003007, 081010021003006, 081010021003005,081010021003004 081010021003017 081010021003016, 081010021003015 081010021003014 081010021003013 081010021003001 081010021003003, 081010021003002, 081010022001002,081010022001003 081010022001001 081010022001004 081010022001005,081010023001000 081010023001001 081010023001003 ,081010023001002, 081010024001000 081010024001012,081010024001011 081010024001001 081010025001000 081010025001001 081010025001019 081010025002000 081010025002016 ,081010025002021, 081010025002020,081010025002019 081010025002018 081010025002017 081010025003000 081010025003002,081010025003001 Page 23 HUD USER GIS Maps Page 1 of 2 IE MONDAY FEBRUARY' 07 2011 I l Site Map 1 Print 1. Pool HOME ABOUT PD&R RESEARCH FINDER PERIODICALS DATA SETS QUICK LIN r , ...,.. ' Nei hborhood Stabilization Tikeeee he vel ��t� ;it a t oft 'v, ,, dr a the assac. le¢# x ,::.41f, .'� ' '° r Program Grants foreclosed and are creating e .1",'' '*w+ 9 e , ` , communities. 1 _'. ''''. v.", 4 ,. 44, a .1 'Enter an Address, city or state Go I I Select a State Select a C, Map Options Clear 1 Reset Click Mode Zoom 1 Info NSP3 Legend ( °, — Tract Outline Click here for an Overview NSP3 Options v �re +a i 15 Current Zoom Level ¢ °i~f e` e e vv 0 :noel Ave • k' n P c � ti .. °, r Show Tracts Outline (Zoom ' +) 4.4,- e `� q e c ° 9H& Q o , , rn DRAW OM y,c . q � . o �, d 4 S 1 r Ave .'fir 4 r °r' n + VIEW DATA .4.,,,,, , ,yam 1 AO ��_��.. to VIEW PROJECTS 1 a y v rri m K P u 4 t ,e Finmyn Arc g rn I, g METNO4M?td'X3Y INSTRUCTIONS i , p y "r " AgrarnAm uk ii Agate Pi IA .. m Y. P e, . y 07 v, s* n The NSP3 mapping tool now provides a sa Ave v, M ' ,A, Masa Ave ° ♦tesaAVe summary NSP3 score for all projects C 1. drawn Click on "View Projects ", which t..,) t i S "` ? ,, k will list all of the projects (target areas) la 1. ry t have data calculated It shows the W Nonhrlu vr+ . ' W NOrtherrs Ave 63 E Northern Ave NSP3 score for each target area along with =, the total estimated housing units in that .t° l .*Ol r op area At the bottom of the list is a sum of •_ 2 {44.1( t rk all housing units in all target areas and the ,K � '° NSP3 score for all target areas drawn e r.Pntrat A •so € 3' 'r Grant are advised to know their state N v 4 e minimum and if the summary score is leas r `r a than the state minimum the grantee should delete, add, or revise target areas a r „ . ,v vion Ave r it A.e v, gi Note that if you delete or add, the tool only R recalculates after you close the `View 1 g R Projects" box and reopen it. HUD also .ietisor Ave X. T. advises grantees to think carefully about a a karaacA. "a the size of their target areas in total If awstarr A a °t Slate Ave those target areas have a very large ruin Ave `l: to - number of total housing units relative to . m "" gy the dollars available, HUD will likely ask 1 x 2 ii - 1` I st - c that the grantee reduce the number andlor I S anncs Ave t LESEEf" ?' Jones x w 1. �v < y •q size of their target areas ! p a m m m M. t ogan Ave ,� m 5 Logan Ave A 4 , Lakeview Ave m etr ec 5t o t„ 4 Os" http. / /www huduser orgl/1VSPINSP3.html 2/7/2011 Page 24 Neighborhood ID 4452453 NSP3 Planning Data Grantee ID: 0812780E Grantee State: CO Grantee Name: PUEBLO Grantee Address: Grantee Email: adaclark @pueblo.us Neighborhood Name: Eastside URA Target 1 Date:2011 -02 -04 00:00:00 NSP3 Score The neighborhoods identified by the NSP3 grantee as being the areas of greatest need must have an individual or average combined Index score for the grantee's identified target geography that is not less than the lesser of 17 or the twentieth percentile most needy score In an individual state. For example, If a state's twentieth percentile most needy census tract is 18, the requirement will be a minimum need of 17 If, however a state's twentieth percentile most needy census tract is 15, the requirement will be a minimum need of 15. If more than one neighborhood is identified in the Action Plan, HUD will average the Neighborhood Scores, weighting the scores by the estimated number of housing units In each Identified neighborhood. Neighborhood NSP3 Score: 20 State Minimum Threshold NSP3 Score: 17 Total Housing Units In Neighborhood: 755 Area Benefit Eligibility Percent Persons Less than 120% AMI: 92.54 Percent Persons Less than 80% AMI 83.78 Neighborhood Attributes (Estimates) Vacancy Estimate USPS data on addresses not receiving mail in the last 90 days or 'NoStat' can be a useful measure of whether or not a target area has a serious vacancy problem. For urban neighborhoods, HUD has found that neighborhoods with a very high number vacant addresses relative to the total addresses in an area to be a very good indicator of a current for potentially serious blight problem. The LISPS "NoStat" indicator can mean different things. In rural areas, it is an indicator of vacancy However it can also be an address that has been Issued but not ever used, it can indicate units under development, and it can be a very distressed property (most of the still flood damaged properties in New Orleans are NoStat). When using this variable, users need to understand the target area Identified. In addition, the housing unit counts HUD gets from the US Census indicated above are usually close to the residential address counts from the USPS below However if the Census and USPS counts are substantially different for your identified target area, users are advised to use the Information below with caution. For example if there are many NoStats in an area for units never built, the USPS residential address count may be larger than the Census number if the area is a rural area largely served by PO boxes it may have fewer addresses than housing units. LISPS Residential Addresses in Neighborhood: 748 Residential Addresses Vacant 90 or more days (USPS. March 2010): 96 Residential Addresses NoStat (USPS, March 2010): 8 1/3 Page 25 '? a a a rf d L � ■ ,2 +. ■�+ m �.$�e at.;+ � ,4.�� . t a „4�'�s ��yx, w�.�?h,•,;";21 Foreclosure Estimates HUD has developed a model for predicting where foreclosures are likely That model estimates serious delinquency rates using data on the leading causes of foreclosures - subprime loans (HMDA Census Tract data on high cost and highly leveraged loans), increasing unemployment (BLS data on unemployment rate change), and fall in home values (FHFA data on house price change). The predicted serious delinquency rate is then used to apportion the state total counts of foreclosure starts (from the Mortgage Bankers Association) and REOs (from RealtyTrac) to individual block groups. Total Housing Units to receive a mortgage between 2004 and 2007 196 Percent of Housing Units with a high cost mortgage between 2004 and 2007 48.39 Percent of Housing Units 90 or more days delinquent or in foreclosure: 12.25 Number of Foreclosure Starts in past year 26 Number of Housing Units Real Estate Owned July 2009 to June 2010: 15 HUD is encouraging grantees to have small enough target areas for NSP 3 such that their dollars will have a visible Impact on the neighborhood. Nationwide there have been over 1.9 million foreclosure completions in the past two years. NSP 1 2, and 3 combined are estimated to only be able to address 100,000 to 120.000 foreclosures. To stabilize a neighborhood requires focused investment. Estimated number of properties needed to make an impact in identified target area (20% of REO in past year): 5 Supporting Data Metropolitan Area (or non - metropolitan area balance) percent fall in home value since peak value (Federal Housing Finance Agency Home Price Index through June 2010): -8 Place (if place over 20,000) or county unemployment rate June 2005' 7.6 Place (if place over 20,000) or county unemployment rate June 2010' 9.9 'Bureau of Labor Statistics Local Area Unemployment Statistics Market Analysis: HUD is providing the data above as a tool for both neighborhood targeting and to help Inform the strategy development. Some things to consider 1 Persistent Unemployment. Is this an area with persistently high unemployment? Serious consideration should be given to a rental strategy rather than a homeownership strategy 2. Home Value Change and Vacancy Is this an area where foreclosures are largely due to a combination of falling home values, a recent spike in unemployment, and a relatively low vacancy rate? A down payment assistance program may be an effective strategy 3. Persistently High Vacancy Are there a high number of substandard vacant addresses in the target area of a community with persistently high unemployment? A demolition /land bank strategy with selected acquisition rehab for rental or lease- purchase might be considered 4 Historically low vacancy that is now rising. A targeted strategy of acquisition for homeownership and rental to retain or regain neighborhood stability might be considered. 5. Historically high cost rental market. Does this market historically have very high rents with low vacancies? A strategy of acquiring properties and developing them as Tong -term affordable rental might be considered Latitude and Longitude of corner points 104.599929 38.274575 - 104.592333 38.274676 104.591861 38.263692 -104 598856 38.263827 2/3 Page 26 . r f1 � ,dcw Blocks Comprising Target Neighborhood 081010008002019 081010008002018, 081010008002013, 081010008002012, 081010008003003, 081010008003005, 081010008003023, 081010008003022, 081010008003021 081010008003020, 081010008003019 081010008003014, 081010008003013, 081010008003012, 081010008003011, 081010008003010, 081010008003009, 081010008003008, 081010008003006, 081010008003004 081010008003002, 081010008004016, 081010008004019 081010008004018, 081010008004017, 081010012002000, 081010012002001, 081010012002003, 081010012002007 081010012002018, 081010012002017 081010012002016, 081010012002015, 081010012002014 081010012002013, 081010012002012, 081010012002011, 081010012002010, 081010012002009 081010012002008, 081010012002006, 081010012002002, 081010012003003, 081010012003016, 081010012003013, 081010012003012, 081010012003009, 081010012003008, 081010012003002, Page 27 .. .., a x¢ :: ' t > ,. .,, _ a...,,._.� ., - _.. HUD USER GIS Maps Page 1 of 2 IIM MONDAY FEBRUARY 07 2071 1 11I , t,e+ Site Map I Print I Font HOME ABOUT PD &R RESEARCH FINDER PERIODICALS DATA SETS QUICK LIN F .. ...,:*::.,.,,...:,....:..,",„ .........„:„.,....„.:::„:".„.....,.:,..:!,......:,,„,:.,,0",„,.:1„000:,...7":„... ....„":„..., .......„..,.......„....•..........,.....::.. M. y` 'S :S r w The Neighborhood Siabii Prr Ne Stabilization aes the pmuleans assooaated,h a j , + -9v • . '' '�,:i ` Program Grants foreclosed upon and are creating e s Y %.. communities. err .,r V Enter an Address, city or state Go Select a State select C Map Options Clear I Reset Click Mode Zoom I Info NSP3 Legend ( %) — Tract Outline Click here for an Overview NSP3 Options lath st E rain sr vin si 15 Current Zoom Level ■ k ' E )th st zE et" St r Show Tracts Outline (Zoom 11+) z a E eel st • �,,' x _ . E 7M St DRAW • N• E itI fit - - y , rt E . to St " - _ " $ E eth St VIEW DATA tn'tllfr '" - 8fh $t t Al YIEW PROJECTS 4 k : ;. t ' a E SIN 51 _ E Stn a E` Rh NZ ,' E ift 8t '�i ® E uh St ' 5 +rust s E 4th St • t""` - z METHODOLOGY INSTRUCTIONS �? E 3' E 3rd 5t 0 z n E2ndSt E 2nd St t �. ltrat�frxd '- . ,. The NSP3 mapping tool now provides a . , P irk summary NSP3 score for all projects r . ' 7gtN E tst st u drawn Click on "View Projects", which E isr sr g wilt list all of the projects (target areas] a' m a. Lower that have data calculated It shows the °' m y afi v, East Side K NSP3 score for each target area along with g E AsM & a E asir se E r zn the total estimated housing units in that n f area At the bottom of the list is a sum of o S 3 6eect st all housing units in all target areas and the E Hooch sr ` ' E 2 F NSP3 score for all target areas drawn.. Grantees are advised to know their state dy, s * fit; ISMMD�i minimum and if the summary score is less •_ . t 11 than the state minimum the grantee Murr rq "' f `' at Ds should delete add or revise target areas a Note that if you delete or add, the tool only .. recalculates after you close the "View a,, to Projects' box and reopen it. HUD also a Fir Si advises grantees to think carefully about t * rn ° the size of their target areas in total If d n those target areas have a very large ma c- 1 Ivy, number of total housing units relative to the dollars available, HUD will likely ask f, N y that the grantee reduce the number and /or ,rove '' ✓ *O' size of their target areas A te, S.? "My Crrurrty Rd 3.Y¢nya r - �. littp.//www liuduser org/NSP/NSP3.htnil 2/7/2011 Page 28 Neighborhood ID 7428100 NSP3 Planning Data Grantee ID' 0812780E Grantee State: CO Grantee Name: PUEBLO Grantee Address: Grantee Email: adaclark ©puebio.us Neighborhood Name Downtown Target 1 Date:2011 -02-04 00:00:00 NSP3 Score The neighborhoods identified by the NSP3 grantee as being the areas of greatest need must have an individual or average combined index score for the grantee's identified target geography that is not less than the lesser of 17 or the twentieth percentile most needy score in an individual state. For example, if a state's twentieth percentile most needy census tract Is 18, the requirement will be a minimum need of 17 If however a state's twentieth percentile most needy census tract is 15, the requirement will be a minimum need of 15. If more than one neighborhood is identified in the Action Plan, HUD will average the Neighborhood Scores, weighting the scores by the estimated number of housing units in each identified neighborhood. Neighborhood NSP3 Score* 20 State Minimum Threshold NSP3 Score: 17 Total Housing Units in Neighborhood: 901 Area Benefit Eligibility Percent Persons Less than 120% AMI 92.91 Percent Persons Less than 80% AMI 77 13 Neighborhood Attributes (Estimates) Vacancy Estimate LISPS data on addresses not receiving mail in the last 90 days or "NoStat" can be a useful measure of whether or not a target area has a serious vacancy problem. For urban neighborhoods, HUD has found that neighborhoods with a very high number vacant addresses relative to the total addresses in an area to be a very good indicator of a current for potentially serious blight problem. The USPS "NoStat" indicator can mean different things. In rural areas, it is an indicator of vacancy However it can also be an address that has been issued but not ever used, it can indicate units under development, and It can be a very distressed property (most of the still flood damaged properties in New Orleans are NoStat). When using this variable, users need to understand the target area identified. In addition, the housing unit counts HUD gets from the US Census indicated above are usually close to the residential address counts from the USPS below However If the Census and USPS counts are substantially different for your Identified target area, users are advised to use the information below with caution For example if there are many NoStats in an area for units never built, the LISPS residential address count may be larger than the Census number' if the area is a rural area largely served by PO boxes it may have fewer addresses than housing units LISPS Residential Addresses in Neighborhood: 875 Residential Addresses Vacant 90 or more days (LISPS, March 2010): 84 Residential Addresses NoStat (LISPS, March 2010): 23 1/3 Page 29 # Foreclosure Estimates HUD has developed a model for predicting where foreclosures are likely That model estimates serious delinquency rates using data on the leading causes of foreclosures - subprime loans (HMDA Census Tract data on high cost and highly leveraged loans), increasing unemployment (BLS data on unemployment rate change), and fall in home values (FHFA data on house price change). The predicted serious delinquency rate is then used to apportion the state total counts of foreclosure starts (from the Mortgage Bankers Association) and REOs (from RealtyTrac) to individual block groups. Total Housing Units to receive a mortgage between 2004 and 2007 176 Percent of Housing Units with a high cost mortgage between 2004 and 2007 43.77 Percent of Housing Units 90 or more days delinquent or in foreclosure. 11 19 Number of Foreclosure Starts in past year 22 Number of Housing Units Real Estate Owned July 2009 to June 2010' 13 HUD is encouraging grantees to have small enough target areas for NSP 3 such that their dollars will have a visible impact on the neighborhood. Nationwide there have been over 1.9 million foreclosure completions in the past two years. NSP 1 2, and 3 combined are estimated to only be able to address 100,000 to 120,000 foreclosures. To stabilize a neighborhood requires focused investment. Estimated number of properties needed to make an impact in identified target area (20% of REO in past year). 5 Supporting Data Metropolitan Area (or non - metropolitan area balance) percent fall In home value since peak value (Federal Housing Finance Agency Home Price Index through June 2010). -8 Place (if place over 20 000) or county unemployment rate June 2005' 7 6 Place (If place over 20,000) or county unemployment rate June 2010' 9.9 'Bureau of Labor Statistics Local Area Unemployment Statistics Market Analysis: HUD is providing the data above as a tool for both neighborhood targeting and to help inform the strategy development. Some things to consider 1 Persistent Unemployment. Is this an area with persistently high unemployment? Serious consideration should be given to a rental strategy rather than a homeownership strategy 2. Home Value Change and Vacancy Is this an area where foreclosures are largely due to a combination of falling home values, a recent spike in unemployment, and a relatively low vacancy rate? A down payment assistance program may be an effective strategy 3. Persistently High Vacancy Are there a high number of substandard vacant addresses in the target area of a community with persistently high unemployment? A demolition /land bank strategy with selected acquisition rehab for rental or lease- purchase might be considered 4 Historically low vacancy that is now rising. A targeted strategy of acquisition for homeownership and rental to retain or regain neighborhood stability might be considered. 5. Historically high cost rental market. Does this market historically have very high rents with low vacancies? A strategy of acquiring properties and developing them as long -term affordable rental might be considered. Latitude and Longitude of corner points - 104.624004 38.279898 - 104.607997 38.279932 - 104.607782 38.271004 -104 622974 38.270768 Page 30 M ? SC' +"f - . ,��'�'x „ r�; ». ^'?� °^� Blocks Comprising Target Neighborhood 081010006001005, 081010006001007,081010006001019 081010006001018,081010006001017 081010006001016,081010006001015 081010006001014 081010006001013 ,081010006001012, 081010006001011 081010006001010 081010006001009 081010006001008 ,081010006001006, 081010006001004 081010006002005 081010006002007 081010006002016 ,081010006002015, 081010006002014 081010006002013 081010006002012,081010006002011 081010006002010 081010006002009 081010006002008 081010006002023 081010006002022,081010006002021 081010006002020 081010006002019 081010006002018,081010006002017 081010006002006, 081010007001016,081010007001010 081010007001009, 081010007001006 ,081010007002003, 081010007002005,081010007002007 081010007002015 081010007002014 081010007002013, 081010007002012,081010007002011 081010007002010,081010007002009 081010007002008, 081010007002033, 081010007002032,081010007002031 081010007002030 081010007002029 081010007002028, 081010007002027, 081010007002026,081010007002025 ,081010007002042, 081010007002041 081010007002040 081010007002039 081010007002038,081010007002037 081010007002036,081010007002035 081010007002034 081010007002047 081010007002046, 081010007002045,081010007002044 081010007002043 081010007002024 081010007002023, 081010007002022,081010007002017 081010007002006,081010007002004 4 Page 31 a w.a �,. 4,""`"�c.`..sr�l��.` 1‘ , HUD USER GIS Maps Page 1 of 2 mo MONDAY FEBRUARY 27 20,1 , li ill . il, l ' . 1 'Nib SiteMap I Print j F oni HOME ABOUT PD&R RESEARCH FINDER PERIODICALS DATA SETS QUICK LIN i e , ****%,, % * 4 '''' ' Neighborhood Stabilization The "elQhbartte Slak14"Wil Pil • n ..‘„ 4, %n„,, P rogram Grants taddfore:os"etclheupoINQtr:a:crealrigtecl: c .!% , •1,,,, ' "**0.,, , \** ' , \ yri n ' • ''' 4 ' N, " .( cominumbes 'Enter an Address, city or state Go 1 1 Select a State - J Seiect a I CA Map Options Clear I Reset Click Mode Zoom 1 Info NSP3 Legend (%) — Tract Outline Click here for an Overview NSP3 Options 15 Current Zoom Level DRAW VIEW DATA VIEW PRCMECTS f i 4 i 2J . ,,,,, idm s l t atil St Alley N 1 r Show Tracts Outline (Zoom 11+) W 11191W (- w W 1 rib St '4 T I t > i•neth st 4 .. W 18th St ' 0, , 2 . I lith St z H ■ , 0 vy ism st v , le W 18th St IN 1Sth St 0 ' W 18th St a J., I I V W . 5t ., . , El 0 ,' 1 '''' '''''' - VI .2:le -;', 2j i'i _ ,, 4, ," t ..f E3 MET RODOLODV INS TRUCTIONS 1 ,, 1 :" , W ". The NSP3 mapping tool now provides a summary NSP3 score for all projects „ , . , 1 ,,, A, t, 1” i i 1 -- drawn. Click on "View Projects”, which 7 a 1 will list all of the projects (target areas) = ' that have data calculated It shows the NSP3 score for each target area along with 1..' C'4 the total estimated housing units in that `t= "" area At the bottom of the list is a sum of .„„ all housing units in all target areas and the , . , ",- NSP3 score for all target areas drawn ' C3 Grantees are advised to know their state It - - minimum and if the summary score is less :Nik 1 r, than the state minimum the grantee - `4 s''‘ '-'-, ,/., ,,,, ,:, , :, ' = -,'■ ' = . t should delete, add, or revise target areas C-• Note that if you delete or add, the tool only , ". 1 44 ' - 4 recalculates after you close the "View ""'• '''''', i ci" - - - z Projects" box and reopen it HUD also , , ,,k , h , , I 0 — — ' advises grantees to think carefully about ,A'-,-,':-- IN ath st W 4th St 96 the size of their target areas in total If ..' Q ,N.-,.. 1 z z 8V.. those target areas have a very large .,„„ . number of total housing units relative to ("Ai the dollars available HUD will likely ask 41- ._ that the grantee reduce the number andlor o, ,A,t/ VI 4) ,, Aro south Co$orado Downtown NI. ,i, ,.., ower 1,..a,ny , ., - w istSt S 1 size of their target areas P 0 Reservair.:44eiew ,,_ ..,, 1 . t w E p I .,. ,-,.. .. ,..., tAttl 0 ,a, i44' y /Amman ' ' ‘,1 lt, '44. (,,,,nventhin rim CID llttp./iwww huduser orgiNSP/NSP3,html 2/7/2011 Page 32 Attachment 2 — Public Comments I I 1 I I I I I I Pag 33 ? � "n, f`J`-3ri,mi °Fr x'"K i* .i,s` ;; t 5iWk.a< .`. g. kA a° Arl ..e ii .&1 C t k. .614 , .tSii ,, . „s ,.. „ a:. '.w. , ? §., ,„ a ill :: yV m.'rt.'` ,a`.?`' E, l;a.. . k ?,...h; NAgg;,(.' -* Page 1 of Ada Clark From Ada Clark Sent: Friday February 25 2011 4 10 PM To 'leadtwi @yahoo com' Cc Jerry Pacheco Subject: Response to Comments on the Substantial Amendment to FY 2010 Action Plan Dear Mr Fancher. I aim in receipt of your continents regarding the Substantial Amendment of the 2010 Annual Action Plan for the Neighborhood Stabilization Program (NSP) 3 grant. The City received your continents on Sunday February 20. 2011 via email. The Department of Housing and Urban Development (HUD) has allocated the City of Pueblo $1 460,506 in Neighborhood Stabilization Program 3 Community Development Block Grant fluids under Section 2301(b) of the Housing and Econonnc Recovery Act of 2008 (Pub. L. 110- 289 approved July 30 2008) (HERA). as amended. and through an additional allocation of funds provided under Section 1497 of the Wall Street Reform and Consumer Protection Act of 2010 (Pub L. 111 -203 approved July 21 2010) (Dodd -Frank Act). Pueblo. as a recipient of the funds, is required to amend the FY 2010 Action Plan to include the additional funding. The Federal Register notice established part of the process to be followed by recipients in order to receive the grant The City is complying with the requirements of the Notice. The grant does not require a local match. However the City will be snatching the grant with HOME Investment Partnership Act grant funds, and in 2012 will most probably use City general revenue HOME matching funds on some of the properties purchased. At this time we cannot detesnune what that amount may be. In your email you object to the rebuilding of houses on properties that are demolished with NSP 3 grant funding. In order for demolition activities to be eligible , the grantee must build housing on the site within a 10 -year period (under the Land Banking criteria) or inunediately (under the Redevelopment criteria) The option of leaving parcels vacant is not available to the City nor is it an acceptable vehicle of neighborhood revitalization. Vacant parcels of land relay abandosnnent and disinvestinents, which further depress housing values in neighborhoods. The grant also encourages a mix of incomes by allow ing households with incomes of up to 120% of area median to participate in the program (incomes over $60.000) up from the traditional 80% of area median income ($45 100) You state that the Plan is flawed, as it did not contain information that you felt provided a Hiller picture of our community The Federal Register simply requires that grantees inform the citizenry how it intends to spend the NSP3 grant award. which is not meant to address the larger issues of domestic violence, alcohol abuse. the needs of the disabled or the revision of City ordinances for the purpose of property maintenance standards though all have merit It is the intent of the City to purchase and demolish or rehabilitate substandard housing and rebuild safe and decent housing within the most highly affected neighborhoods with substandard housing units. This grant and its predecessor (NSP1) provided the City and the Department of Housing and Citizen Services a wonderful opportunity sty to revitalize neighborhoods. Some of the neighborhoods we are working in under the NSP1 grant have not seen new housing construction in many many years. We see this grant as a positive event in the history of these neighborhoods. 2/2.5/2011 Page 34 _ I '�'�k �„- i ti ,-.c � .,x, .�" r 7 � .a. .. r, '21 •..' n _ �'�. �. z �" A ,... .A � "d rN z�1 .�! . d „.� t {. a. �7" _ ,__ Page 2 of Please feel free to contact me with any further questions you may have about the Neighborhood Stabilization Program 3 grant and the required substantial amendment. I can be reached at 719 -553 -2845 Sincerely Ada 7?iNercvClark Ada Rivera Clark Director - -- On Suu, 2/20/11, harry fancher <leadtwicvahoo.com> wrote: From. Ian.) fancher <1eadtwiyyahoo.com=- Subject: Substantial Amendment to FY 2010 Action Plan To: housing@pueblo.us Date: Sunday February 20 2011 10.57 AM To: ADA CLARK Director City Pueblo Housing This plan is flawed. City of Pueblo has made no offer ni the Plan to match these proposed funds. City of Pueblo should commit a matching amount of 40% to show that City Political leaders and their pals are indeed committed to making real change and HUD should not provide funding for this Plan unless City Pueblo makes a commitment to matching said grant at 40 %. There is another substantial flaw in the Plan: The plan to rebuilt on land once demolition of substandard unsafe shacks are demolished is flawed. There should be no rebuild i n the target areas and instead rebuild should be outside these census trakc areas to ensure that desegregation of the concentration camps for Hispanic surnamed American citizens is assured. This Plan as written only ensures that continued concentration of low incomed people into these areas. This splan is also flawed since grant writer has not included the Highschool dropout rates for these targeted teen pregnancies levels, domestic violence data is omitted, alcohol addiction rates in these areas are not included in the flawed grant as written. This grant and the proposed activities will only continue a racist tradition of long standing m City of Pueblo which is to segregate low income Hispanic surnamed people from the affirmative action Hispanic surnamed citizens who have moved out and left behind the poorist of the poor the least educated of the educated, the disabled of the disabled in large munbers, and this plan does not propose a housing ordinance thaat would require home owiiers in these areas taargetd in plan to have thier shun rentals inspected for safety and health as well as proper code enforcements if not also building ode violations. This plan has no conunittment by Hispanic Leaders to truely make neede changes to stop concentrating low incomed people into these decayed concentgration camps where munerous ancient shacks are being lived in thta are difficult to heat in winter 2/25/2011 Page 35 � FKd•. , + Page 3 of L HUD ashould reject this plan until a more perfect plan is submitted by city Pueblo thta shows all concerned that local political hacks will conning resources to improve the life of oppressed American Citizens, citizens who are now living in a state of hell called a plice state. HUD should not approve this plan until this plan includes a committrnent by the Pueblo CITY /County Health Department that acknowledges and acts in these census tracks in said PLAN to deal with domestic violence and alcoholism as cornnnunity health issues needing delt with on an open front. Of course when one City Council member has a relative that sells alcohol and another Councilman who took money for his election campaign from the alcohol lobby one cannot expect conmuttment to see alocholism as a community health problem. Additionally the Pueblo County District Attorney needs to make open public comment for the record that men who acccess teen children will be prosecuted for sexual assault whitlun the fullist extent of the law The DA has not taken this stance and will not and so therefore enables a bad situation of unwanted children due to sexual assualt to be accepted as a community standard not to be challenged. HUD should toss this junk graant into the trash and require a more detailed comnittment by City of Pueblo Council. City / Couunty Health Department. the D.A. and also our good fiiends at the County Commissioners office. City Council also needs to enact ordinance to close down alleys in the Plan target areas as these are notlung but avenues of criminal activity such as burglary of homes. This Grant application is typical of City of Pueblo: notlung new poorly written. poorly articulating with proper nomencalture what desired outcomes acre and predicated upon supporting documentation. There has been no true conunittment of this city council and or any other regime that has come before to stop racism in housing. to stop denial of unfair activities by local lenders who with malice and afore thought created the mess as depictecd in the grant Plan. Lenders. realators, realestate appraisers. and home inspectors for buyers as well as banks created all these disgusting numbers being used by City of Pueblo to attempt to get HUD to throw money away and yet there has been little to none criminal prosecution of these criminal elements that have preyed up low income Hispanic people and the concentration camps that Dept of Conunerce conveinently label as low income census tracks. These are concentration camps of welfare recipoients. Doctors. dentists. hospitals. and a long lsit fo others live very well due to our low income qwelfare recipients and thes ecensus tracks are nothing but places of failure and over the many years feeders into the so called crinunal juastice system. HUD officials are major players in causing the existing situation. All are on the dole and yet call thems4elves professionals. They are nothing but facilitators of misery wwho provide httle oversight ur how HUD funds have been utiklized over the last 30 years. HUD is a defunct system of spoils. Witness HUD money that is tacked onto spending bills for the pals fo senators and lower house corrupt politicals who allege that they want a better america. when in faact it is nothing but more of the same. corruption of Inman rights. Rewrite the grant, add more detail, have other collaborators provide input, deny enriclunent of corrupt banks who have cn•eated this sony situation found i n the Plan neighborhoods. I k uwo that HUD will agree to this scans called a plan because the political boys and girls have provided their couunents thata this is good for the POOR. Run when a clown in political clothing starts singing that a specific plan such as this is GOOD for the poor when in fact this is another welfare trip for the banks and another example of lack of comnuttment by Cityh Council to fix a broken system that exploits low incomed American 2/25/2011 Page 36 ,' alt: ".� s.? ,,x 2wr o- 7 r� . °- 5 L� ',' =t �e S, .. ., �. <.. -'s x,. � .< x. 6 ,r ' u, .„d s�t' #z H:�# '�r 1r,a k Page 4 of 4 Hispanic surnamed citizens. Lorenzo Esteban Fancher also known as Larry Stephen Fancher submits this continent and prays that HUD officals will read same and deny city of Pueblo aapplication. Page 37 Appendix: NSP3 Action Plan Contents Checklist The checklist below is an optional tool for NSP3 grantees to help to ensure that all required elements of the NSP3 Substantial Amendment or the Abbreviated Plan are submitted to HUD This checklist only includes the minimum required elements that must be included in the NSP3 Action Plan and grantees may want to add additional details. This document must be protected, as described above, in order to use the checkboxes in this checklist. 1. NSP3 Grantee Information Did you include the Program Administrator's name, address, phone, and email address? 2 Areas of Greatest Need Yes Does the narrative description describe how funds will give priority emphasis to areas of greatest need? Does the narrative description specifically address how the funds will give priority emphasis to those areas: o With the highest percentage of home foreclosures? o With the highest percentage of homes financed by subprime mortgage related loan; and o Identified by the grantee as likely to face a significant rise in the rate of home foreclosures? Did you create the area of greatest needs map at http:/ /www.huduser.org /NSP /NSP3.html? Did you include the map as an attachment to your Action Plan? ONLY Applicable for States: Did you include the needs of all ❑ entitlement communities in the State? 3 Definitions and Descriptions Are the following definitions and topics included in your substantial j amendment?. j / A ® Blighted structure in context of state or local law, NSP3 Application Instructions Draft 11/5/2010 Page i i s— ✓ " m r r+.' .. u,,k - a -3 tl : t c , s , ; "' r , t ', ar t a r ,-1,4144,A; � ru .,. * y o.... a�av� ,., ,:. .w w . u�:�ume, 1 • Affordable rents, ® j • Ensuring long term affordability for all NSP funded housing projects, • Applicable housing rehabilitation standards for NSP funded projects 4 Low - Income Targeting I I __.., Yes es._... 1 Did you identify the estimated amount of funds appropriated to provide housing that meets the low- income set aside target? Did you provide a summary describing how your jurisdiction will meet its low- income set aside goals? 5. Acquisition & Relocation w.._ � __.. �w � .._ Yes For all acquisitions that will result in displacement did you specify• • The planned activity, • The number of units that will result in displacement, • The manner in which the grantee will comply with URA for those residents? 6. Public Comment r .Yes' . Did you provide your draft of the NSP3 substantial amendment for a minimum of 15 days for public comment? Did you include the public comments you received on the NSP3 ❑ substantial amendment in your plan? 7 NSP Information by Activity Check all that apply Did you include a description of all eligible. NSP3 activities you plan to implement with your NSP3 award? For each eligible NSP3 activity you plan to implement did you include. NSP3 Application Instructions Draft 11/5/2010 Page ii a ' c'xx� � .��' z�, ,:.t 4. • Eligible use or uses? ® j • Correlated eligible CDBG activity or activities? • Associated national objective? • How the activity will address local market conditions? ❑ • Range of interest rates (if any)? • Duration or term of assistance? • Tenure of beneficiaries (e.g. rental or homeowner)? • If the activity produces housing, how the design of the activity will ensure continued affordability? • How you will, to the maximum extent possible, provide for vicinity hiring? o Procedures used to create affordable rental housing ❑ preferences? o Areas of greatest need addressed by the activity - or.activities? • Amount of funds budgeted for the activity? • Appropriate performance measures for the activity (e.g. units of housing to be acquired, rehabilitated, or demolished for the income levels represented in,DRGR) ? • Expected start and end dates of the activity? • Name and location of the entity that will carry out the activity? Z 8. Certifications )i7 Did you sign and submit the certification form applicable to your ❑ jurisdiction? 9 Additional Documentation Yes Did you include a signed SF -424? ❑ NSP3 Application Instructions - Draft 11/5/2010 Page iii ` s " ' + �a�e «�. n ,., c�a,..+: ,� �' k� e.. � :.a- 3. .. ,. , � i,' �, "` ? ' !! ' �t x �^ �` ° t �.?�t. to '�' a "" : > , ..0 ''� r " ue, NSP3 Application Instructions - Draft 11/5/2010 Page iv x .e . - - -. - -. v °- 4' ¶" • - .. - „ 4 t : : 1 J . • r . ' c 4: IV 4 i J , 1 1 ( : & � .. , 1. r , • :': •: i , ' ... ‚ . - , ; . : • :. •• : . - -. •: ....... .: ': :;- • v _ • 4 \ 41 . .. $ t f 1Z. a . f 2 ? . - . . ..... ..:. .;:; . . 3 -' ............ -. . - . .'. :.- - - \ , . , I I AFT AM J4; tP r