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HomeMy WebLinkAboutDraft HOME-ARP Allocation Plan HOME-ARP Allocation Plan City of Iowa City Neighborhood & Development Services This plan is subject to change pending HUD approval. 1 Table of Contents Introduction ................................................................................................................................................................2 Consultation ...............................................................................................................................................................2 CONSULTATIONS HELD .................................................................................................................................................2 SUMMARY OF FEEDBACK ..............................................................................................................................................5 Public Participation .....................................................................................................................................................5 PUBLIC PARTICIPATION PROCESS ....................................................................................................................................5 Needs Assessment and Gaps Analysis ........................................................................................................................6 HOME-ARP Activities ..................................................................................................................................................8 THE METHOD FOR SOLICITING APPLICATIONS ....................................................................................................................8 USE OF HOME-ARP FUNDING .....................................................................................................................................8 USE JUSTIFICATION ......................................................................................................................................................8 HOME-ARP Production Housing Goals .......................................................................................................................9 Preferences .................................................................................................................................................................9 USE OF PREFERENCES ..................................................................................................................................................9 REFERRAL METHODS ................................................................................................................................................ 10 LIMITATIONS IN A HOME-ARP RENTAL HOUSING OR NCS PROJECT ................................................................................. 10 UNMET NEEDS OF OTHER QUALIFYING POPULATIONS ..................................................................................................... 10 HOME-ARP Refinancing Guidelines ......................................................................................................................... 10 APPENDIX A ............................................................................................................................................................. 11 Citizen Participation......................................................................................................................................... 11 2 Introduction The American Rescue Plan Act of 2021 (“ARP”) appropriated $5 billion to communities across the U.S. to provide housing, services, and shelter to individuals experiencing homelessness and other vulnerable populations. These funds were allocated by formula to jurisdictions that qualified for funding through the HOME Investment Partnership Program (HOME Program) from the U.S. Department of Housing and Urban Development (HUD). Eligible activities that may be funded with HOME-ARP include: • Development and support of affordable housing • Tenant-based rental assistance • Provision of supportive services • Acquisition and development of non-congregate shelter units Funds must primarily benefit individuals and households in the following Qualifying Populations: • Experiencing homelessness • At risk of homelessness • Fleeing domestic violence, dating violence, sexual assault, stalking or human trafficking • Other populations with high risk of housing instability The City of Iowa City received a total of $1,789,981 in HOME-ARP funding and expects to make $1,521,981 in HOME- ARP funds available for allocation in two competitive funding rounds. Consultation In order to inform the HOME-ARP allocation plan, the City of Iowa City consulted with agencies who serve the qualifying populations. This consultation was conducted via survey, virtual stakeholder meetings, in-person meetings, and conference calls. Specific consultations were held with the Iowa Balance of State CoC Lead Agency, Institute for Community Alliances; the Iowa City Housing Authority; and at the regular meeting of the Johnson County Local Homeless Coordinating Board (LHCB). Additional individual consultation meetings were held with individual service providers upon request. CONSULTATIONS HELD • Local Homeless Coordinating Board Consultation o December 8, 2021 • Iowa Legal Aid Consultation o January 11, 2022 • Domestic Violence Intervention Program (DVIP) Consultation o January 17, 2022 • The Housing Fellowship (THF) Consultation o February 18, 2022 • Institute for Community Alliances Consultation o April 7, 2022 3 ORGANIZATIONS CONSULTED: Agency/Org Consulted Type of Agency/Org Method of Consultation Feedback Johnson County Local Homeless Coordinating Board (LHCB) Homeless Services Virtual Stakeholder Meeting Feedback summarized by agency below. Shelter House Homeless Services Virtual Stakeholder Meeting Rental rehab; pest control; Case management critical; prioritize below 30% AMI Domestic Violence Intervention Program (DVIP) Domestic Violence Services Virtual Stakeholder Meeting; Survey Highest priorities: Rental Assistance Med/High Priorities: Development of Affordable Housing; Supportive Services Other: Overall decrease in DV shelters across the state; Lack of available units for families needing 3+ BR both in shelter and affordable rentals; Larger than recommended caseloads. Iowa Legal Aid Legal, Eviction Prevention, Fair Housing, Civil Rights Virtual Stakeholder Meeting Need for Supportive Services, homelessness prevention Iowa City Housing Authority Public Housing Agency Virtual Stakeholder Meeting; In person meeting Highest Priority: Supportive Services, TBRA Need for rent assistance, application fees, housing for larger families, agencies understaffed. Johnson County Affordable Housing Coalition Affordable/Fair Housing Advocacy Virtual Stakeholder Meeting Highest priority: PSH Hawkeye Area Community Action Program (HACAP) CHDO, Homeless Services Virtual Stakeholder Meeting General lack of affordable housing Inside Out Reentry Services for People in the Criminal Justice System Virtual Stakeholder Meeting; Survey Highest Priority: Development of Affordable Housing Med/High Priority: Rental Assistance; Supportive Services Other: Lack of 1br & Efficiency units; challenges with finding housing for individuals with criminal backgrounds; more funding for case management Johnson County Social Services County Government Virtual Stakeholder Meeting Renters are cost burdened. Shortage of affordable housing, specifically one bedrooms and units for larger families. Supportive services also needed. 4 Housing Trust Fund of Johnson County Housing Services Virtual Stakeholder Meeting; Survey Highest Priority: Rental Assistance, Development of Affordable Housing; Supportive Services Medium Priority: NCS Other: Financial challenges in getting into housing (deposit, first month rent, etc.); shortage of affordable housing and operational financial support for service providers Waypoint Domestic Violence & Mental Health Virtual Stakeholder Meeting Suggestion for housing programs for victims of homicide and/or homeownership programs. (Not HOME-ARP eligible) The Housing Fellowship CHDO, Housing Provider Virtual Stakeholder Meeting Renters are significantly cost burdened. Highest priority is development of affordable housing followed by eviction prevention/rental assistance. Concerns about construction timing & costs due to supply chain challenges. Institute for Community Alliances CoC Virtual Stakeholder Meeting Supportive services and operating expenses are a high priority. Pandemic impacted workforce significantly and caseloads are high. Always need more affordable housing as well. Anonymous Organization addressing fair housing & civil rights Survey Highest priorities: Rental Assistance, Development of Affordable Housing Med/High priorities: Supportive Services, NCS Other: Low to middle income underserved, paying high rents. Veteran's Affairs Veteran's Services Virtual Stakeholder Meeting No specific comments provided. Abbe Health Mental Health Services Virtual Stakeholder Meeting No specific comments provided. United Action for Youth (UAY) Youth Services, Mental, Homeless Services Virtual Stakeholder Meeting No specific comments provided. Amerigroup Healthcare Services Virtual Stakeholder Meeting No specific comments provided. National Association for Mental Illness (NAMI) Mental Health Services Virtual Stakeholder Meeting No specific comments provided. CommUnity Crisis Services and Food Bank Food Services, Mental health, Housing Services Virtual Stakeholder Meeting No specific comments provided. Iowa City Community School District (ICCSD) School District/Youth & Family Services Virtual Stakeholder Meeting No specific comments provided. Iowa City Free Lunch Program Food Services Virtual Stakeholder Meeting No specific comments provided. 5 SUMMARY OF FEEDBACK The most frequent response that we received was that the City of Iowa City’s affordable housing inventory is not meeting the demand. Specifically, the availability of affordable one bedroom and efficiency units is below demand as well as the availability of affordable housing for households requiring more than 3 bedrooms. In addition, service providers reported an increased need for funding for operations for case management staff to assist persons at risk of or experiencing homelessness. While this need is certainly documented, there was additional concern regarding sustainability of funding for supportive services outside of one-time funds. Other populations identified include those who are “rent burdened”, paying more than 30% of their monthly income in rent, in low to middle income brackets. Additional feedback received indicated that housing and services for special populations (specifically: victims of domestic violence, youth experiencing homelessness, & individuals with criminal backgrounds) and general rental assistance would also be beneficial in the community. Public Participation In accordance with Section V.B of the Notice (page 13), the City of Iowa City is providing for and encouraging citizen participation in the development of the HOME-ARP allocation plan. Residents will receive notice of the 27-day comment period via press release as required by the citizen participation plan. This includes notice posted on the City Clerk’s Bulletin Board on the First Floor of City Hall, publishing of notices in one or more newspapers of general circulation, and announcement on City websites including access to relevant documents for review. Documents are also available to the public at City Hall. Public hearings will be held at during the July 21st, 2022 Regular Meeting of the Housing and Community Development Commission meeting and at the August 16th, 2022 Regular Meeting of the City Council. PUBLIC PARTICIPATION PROCESS Date(s) of Outreach Mode of Outreach Summary of Response/Attendance Summary of Comments Received Summary of Comments not Accepted and Reason 7/21/2022 Public Notice Newspaper ad to solicit public input on HOME-ARP Allocation Plan N/A N/A 7/21/2022 through 8/16/2022 Public Comment Period TBD TBD See Appendix A TBD See Appendix A 7/21/2022 Public Hearing TBD TBD See Appendix A TBD See Appendix A 8/16/2022 Public Hearing TBD TBD See Appendix A TBD See Appendix A 6 Needs Assessment and Gaps Analysis To assess the needs of HOME-ARP qualifying populations, the City of Iowa City reviewed the current shelter and housing inventory, the size of the populations, and the system of supportive services in the community. To conduct the needs assessment and gaps analysis, the City of Iowa City utilized current data, including the 2021 Point In Time Count (PIT), the 2021 Iowa Balance of State Continuum of Care Housing Inventory Count (HIC), the most recent Comprehensive Housing Affordability Strategy (CHAS) data, and consultation with the Institute for Community Alliances, who is the lead agency for the Iowa Balance of State Continuum of Care (IA BoS CoC) as well as the IA BoS CoC Homeless Management Information System (HMIS) administrator. The findings of this assessment can be found in the table below. HOME-ARP Qualifying Populations Relevant HOME-ARP Eligible Uses Housing Type/Status Current State Current Need Gaps 1. Homeless 3. Fleeing, or attempting to flee, Domestic Violence, Dating Violence, Sexual Assault, Stalking, or Human Trafficking Acquisition & Development of Non- Congregate Shelters Supportive Services Emergency Shelter (Congregate & Non- Congregate) Currently 78 emergency shelter units are available year-round with an additional 40 units of temporary winter shelter operating December through March annually. 10 units (20 beds) are dedicated to Victims of Domestic Violence. The remaining 68 are dedicated to single adults. Emergency Shelter opportunities for Families with Children and families fleeing Domestic Violence. However, there were no unsheltered families with children on the local PIT count. Gap identified specific for a qualifying population. Development of Affordable Rental Housing Supportive Services TBRA Transitional Housing Currently 6 units (9 beds) of Transitional Housing available for victims of domestic violence. And additional 10 units of Veteran's Transitional Housing available (GPD). An additional 7 units specific to homeless Youth (16-22) are available. Additional options for homeless youth. Referrals and waiting lists are increasing, particularly for youth in the LGBTQ+ community. Gap identified for a specific subpopulation. Development of Affordable Rental Housing Supportive Services TBRA Permanent Supportive Housing Currently 187 units (196 beds) of PSH currently or imminently available. Of these, 3 units are dedicated to families while 89 are for single adults and 95 are for single veterans. As of the 2021 HIC submission, only 99 units occupied. (Due to new construction, etc.) 2021 PIT Count identified 11 (sheltered) families experiencing homelessness. 2021 PIT Count also identified 68 (sheltered) and approximately 8 unsheltered single individuals. Gap in permanent supportive housing availability across the board, but specifically in the category of family housing. 7 2. At-Risk of Homelessnes s 4. Other Populations (Other families requiring services or housing assistance to prevent homelessness & at greatest risk of housing instability) Development of Affordable Rental Housing Supportive Services TBRA Cost Burdened Renters with Income <=30% AMI According to CHAS data for 2014-2018, approximately 15,365 households rent their home in Iowa City. Of those, 47.1% have income less than 30% AMI. For those renters who have been identified as having income <30% AMI, 71.9% are identified as having a cost burden over 50% of their monthly income. 71.9% of renters who have income that is <30% AMI are identified as having a severe cost burden, and additional 5.8% (total of 77.7%) are identified as having at least 1 of 4 Housing Problems as defined by the CHAS, meaning 77.7% of renters in this income category are at great risk of housing instability. While there are several assistance options for households experiencing literal homelessness in the community, the number of assistance programs for housed individuals with a significant cost-burden are limited, one-time emergency assistance, or temporary in nature and do not serve to stabilize the household long-term. 4. Other Populations (Other families requiring services or housing assistance to prevent homelessness & at greatest risk of housing instability) Development of Affordable Rental Housing Supportive Services TBRA Cost Burdened Renters with Income <=50%AMI According to CHAS data for 2014-2018, approximately 15,365 households rent their home in Iowa City. Of those 18.2% have income less than 50% AMI, but greater than 30% AMI. For those renters who have been identified as having income <=50% AMI, 29.9% are identified as having a cost burden over 50% of their monthly income. 29.9% of renters who have income that is <=50% AMI are identified as having a severe cost burden, an additional 56.3% (total of 86.2%) are identified as having at least 1 of 4 Housing Problems as defined by the CHAS, meaning 86.2% of renters in this income category are at great risk of housing instability. 8 HOME-ARP Activities THE METHOD FOR SOLICITING APPLICATIONS The City of Iowa City is soliciting applications for HOME-ARP funds. Applications will be reviewed by the Housing and Community Development Commission (HCDC) who will make the final funding recommendations to City Council. The HCDC will not allocate funds to a subrecipient or contractor to administer the entirety of the HOME- ARP grant nor will funds be awarded prior to HUD’s acceptance of the HOME-ARP allocation plan. Prospective applicants were notified of the solicitation of applications via press release. An applicant guide and virtual Q&A sessions were held to assist applicants in learning more about the application process. The City of Iowa City will oversee the administration of HOME-ARP funds and will not administer HOME-ARP activities directly. The City of Iowa City will hold a second funding round for HOME-ARP funds to supplement and provide matching funds to Iowa City agencies seeking HOME-ARP funds from the State of Iowa. USE OF HOME-ARP FUNDING Funding Amount Percent of the Grant Statutory Limit Supportive Services $ 671,855 Acquisition and Development of Non-Congregate Shelters $ 500,000 Tenant Based Rental Assistance (TBRA) $ 0 Development of Affordable Rental Housing $ 316,739 Non-Profit Operating $ 33,387 1.87% 5% Non-Profit Capacity Building $ 0 0% 5% Administration and Planning $ 268,000 15 % 15% Total HOME ARP Allocation $ 1,789,981 USE JUSTIFICATION In accordance with the requirements in HOME-ARP Implementation Notice CPD 21-10, The City of Iowa City has utilized the consultation process and the needs assessment and gap analysis to determine that the priority needs for the qualifying populations in the community are an increase in the availability of affordable housing units and funds to support both new and existing supportive services programs serving qualified populations. As a result of this analysis, the funds have been allocated primarily to these activities. Based on the most recent Point In Time Count (PIT) and Housing Inventory Count (HIC), the number of general shelter beds appears to be meeting the needs of the community, therefore development of non-congregate shelter is not a priority at this time for the general population. However, based on consultations, victims of domestic violence have unique shelter needs and greatly benefit from a non-congregate setting. Additionally, while rental assistance was identified as a needed service in the community, it was determined that rather than TBRA, short to medium term rental assistance with additional supportive services to assist in stabilization of the household overall would be the most effective use of resources. 9 HOME-ARP Production Housing Goals The City of Iowa City anticipates that HOME-ARP funding will be utilized to produce three (3) to five (5) additional rental housing units for qualifying populations and seven (7) units of non-congregate shelter for individuals and families fleeing domestic violence. In addition to the new units proposed, HOME-ARP funds will be utilized to provide supportive services, including rental assistance, to over 1200 individuals in more than 500 households. Preferences A preference provides a priority for the selection of applicants who fall into a specific QP or category (e.g., elderly or persons with disabilities) within a QP (i.e., subpopulation) to receive assistance. A preference permits an eligible applicant that qualifies for a PJ-adopted preference to be selected for HOME-ARP assistance before another eligible applicant that does not qualify for a preference. A method of prioritization is the process by which a PJ determines how two or more eligible applicants qualifying for the same or different preferences are selected for HOME-ARP assistance. For example, in a project with a preference for chronically homeless, all eligible QP applicants are selected in chronological order for a HOME-ARP rental project except that eligible QP applicants that qualify for the preference of chronically homeless are selected for occupancy based on length of time they have been homeless before eligible QP applicants who do not qualify for the preference of chronically homeless. In accordance with Section V.C.4 of the Notice (page 15), the HOME-ARP allocation plan must identify whether the PJ intends to give a preference to one or more qualifying populations or a subpopulation within one or more qualifying populations for any eligible activity or project. • Preferences cannot violate any applicable fair housing, civil rights, and nondiscrimination requirements, including but not limited to those requirements listed in 24 CFR 5.105(a). • The PJ must comply with all applicable nondiscrimination and equal opportunity laws and requirements listed in 24 CFR 5.105(a) and any other applicable fair housing and civil rights laws and requirements when establishing preferences or methods of prioritization. USE OF PREFERENCES The City of Iowa City will not be implementing a preference for one or more qualifying populations. However, the City recognizes that individual applicants may implement preferences for their projects. To ensure a preference is not present in funding decisions and all qualifying populations are able to benefit from HOME-ARP funds, scoring criteria has been developed which awards the most points to programs who serve all qualifying populations. While projects with preferences may still be funded, the City of Iowa City will ensure that HOME-ARP funds are distributed so that they are accessible to all qualifying populations. The consultation process and needs assessment identified that while all populations are in need, there are specific populations which are underserved. Specifically, victims of domestic violence, youth experiencing homelessness, families with children, single individuals experiencing homelessness, and cost-burdened renters are the most in- need populations. While the decision for funding will not be impacted by the population served, we expect that individual applicants will have preferences for one or more of these groups. Funding decisions will be made such that all qualified populations have access to programs utilizing HOME-ARP funds. 10 REFERRAL METHODS Applicants for HOME-ARP funding from the City of Iowa City will utilize different referral methods for their programs as appropriate. Programs with a preference for chronically homeless individuals will utilize the Coordinated Entry (CE) system in place for the Johnson/Washington County Coordinated Services Region of the Iowa Balance of State. The CE system prioritizes participants based on acuity as well as chronologically according to the applicable VI- SPDAT. Applicants operating programs that do not utilize coordinated entry will operate a separate waiting list or referral system that is ordered chronologically. The City of Iowa City will ensure that funding decisions are made such that all qualified populations have access to programs utilizing HOME-ARP funds. LIMITATIONS IN A HOME-ARP RENTAL HOUSING OR NCS PROJECT The City of Iowa City anticipates that some applicants will implement a preference for their individual projects based on the specialized services that the applicant offers. Specifically, the City anticipates that funds utilized for the development of non-congregate shelter will have a preference for qualifying participants in Category 3 – fleeing domestic violence. Participants that have experienced these traumatic events require specialized care and consideration and are more likely to take part in and benefit from supports which are specific to their needs. According to numerous sources, including the World Health Organization, it has been seen around the world that domestic violence is increasing due to the pandemic. Victim-survivors have been forced to isolate in their homes with their abusers due to the pandemic which has in turn increased the lethality of domestic violence for many individuals served by these service providers. Non-congregate shelter offers not only the privacy and safety needed for these families to process their traumatic experiences with the support of service providers who have specialized training, but protection from concerns that result from the COVID-19 pandemic. Furthermore, as participants are fleeing dangerous situations, their privacy is of the utmost importance. A safe, confidential, and secure shelter which is limited to participants in similar situations helps to ensure greater safety from perpetrators as access to the shelter is restricted. UNMET NEEDS OF OTHER QUALIFYING POPULATIONS The City of Iowa City does not anticipate that the limitation of populations served with the anticipated non- congregate shelter project will negatively impact other qualifying populations. According to the needs assessment and consultation, the community need for non-congregate shelter for the general population is not a priority at this time. The current availability of shelter beds is generally proportionate to the population identified in the Point in Time count. The identified need for non-congregate shelter was specifically limited to Category 3 – fleeing domestic violence. Additionally, other projects funded through HOME-ARP will serve all qualifying populations without these limitations in place. HOME-ARP Refinancing Guidelines The City of Iowa City does not intend to use HOME-ARP funds to refinance existing debt secured by multi-family rental housing. 11 APPENDIX A Citizen Participation (Note: To be inserted following public comment period.)