Disaster Recovery Program Hurricanes Dolly and Ike

Transcription

1 Disaster Recovery Program Hurricanes Dolly and Ike General Housing Activities Application: Round 2.2 Dear Applicant: The Texas General Land Office (the Land Office) is pleased to provide you with a copy of the Community Development Block Grant Disaster Recovery Program s 2011 Housing Program Application for General Housing Applicants related to Hurricanes Dolly and Ike Round 2.2. This application is made available for CDBG Disaster Recovery General Housing Applicants under the Consolidated Security, Disaster Assistance, and Continuing Appropriations Act, (Public Law ), enacted on September 30, 2008 for the purpose of assisting in the recovery activities related to disaster relief, longterm recovery, and restoration of infrastructure, housing and economic revitalization in areas affected by Hurricanes Dolly and Ike. The Land Office believes local knowledge of what needs to be done for recovery will be the determining factor in the long-term success of these funds. Accordingly, each selected applicant will be responsible for project development and day-to-day management under the oversight of the Land Office. Applicants must comply with the Housing and Urban Development (HUD) approved Conciliation Agreement regarding Case No (Title VIII) and Case. No (Section 109). Disaster Recovery applicants and funded entities are required to carry out citizen participation procedures in accordance with the Citizen Participation Plan as described in this application and for complying with the requirements of the Hurricanes Dolly and Ike Round 2 Housing Guidelines. Applicants are cautioned that despite the expedited application process, they are still responsible for ensuring that all citizens have equal access to information about project activities. Each applicant is required to conduct at least one (1) public hearing prior to submitting an application. Applications must be submitted by 5:00pm on Friday, December 9, 2011 to the address listed below. Questions about this application should be directed to the following: Texas General Land Office Disaster Recovery Program ATTN: Dennis Ku 301 Congress Avenue. Suite 600 Austin, Texas Phone: Toll Free: [email protected] We look forward to working with you to provide assistance to the areas impacted by Hurricanes Dolly and Ike. Sincerely, Jorge Ramirez Disaster Recovery Program Director Texas General Land Office

2 TABLE OF CONTENTS Grant Administrator Selection... 3 SF-424: APPLICATION FOR ASSISTANCE & CERTIFICATION... 4 Tab I Threshold Requirements for Housing Recipients... 5 EXHIBIT 1. Previous Participation Information... 6 II. Affirmatively Furthering Fair Housing Threshold... 8 III. Capacity Threshold Background/Program Experience Personnel/Staff Capacity Financial Capacity Monitoring Program Goals and Objectives Audit Requirements Insurance/Bonding/Worker s Compensation IV. Benchmark Requirements Tab II Housing Project Detail I. Project Overview II. Project Summary Tab III - National Program Objectives, Low-Moderate Income Calculation, & Project Budget Tab IV Listing of Properties Currently Owned or Managed - Multifamily Tab V Citizen Participation Plan Plan Requirements Local Certifications List of Required Attachments

3 Grant Administrator Selection Applicants who will not be using staff to administer their programs must select three (3) preferred Grant Administrative Firms from the Land Office s Master List of Qualified Administrators which are acceptable to the applicant for the operation of the Round 2.2 Disaster Recovery Program grant. This selection is for post-award activities. The Land Office will contract with one of the selected firms to provide these services. The Land Office will negotiate with the Grant Administrative Firm to develop mutually agreeable staffing hourly rates and cost of expenses and related services, and will issue Work Orders for the provision of services to support funded projects. The Land Office will not issue a Work Order to a Grant Administrative Firm until the Applicant / Grantee receives a Disaster Recovery grant award from the Land Office. The cost of preparing application documents may be reimbursed at the Land Office s discretion from the Disaster Recovery grant, if budgeted, but cannot be reimbursed until after the Disaster Recovery grant contract has been fully executed by the parties. See the list of firms and required selection form at: 3

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5 Tab I Threshold Requirements for Housing Recipients In order to receive funding, it is necessary for each applicant to: demonstrate they are eligible to participate in the Program; demonstrate that they have the capacity to administer the Program; identify eligible activities that meet the needs of the region and affirmatively further fair housing; comply with the Conciliation Agreement; be recommended in the regional Methods of Distribution (MOD) adopted by the Council of Government for the applicant s jurisdiction; and define in detail the proposed scope of work. All application activities must meet the requirements of the Community Development Block Grant Disaster Recovery Program: Hurricanes Dolly and Ike Round 2 Housing Guidelines located at Each of these items must be addressed to enable the Land Office to award and commence the preparation of the necessary contracts for execution. (NOTE: Public Housing activities are addressed in a separate Public Housing application). Applicants for housing activities must meet the following threshold requirements at the time of application: I. Applicants are not eligible to receive a new contract until any unresolved audit findings, questionable or disallowed costs are resolved. Applicant must be in good standing with any outstanding program commitments. II. III. IV. Applicant may not be listed as debarred on federal or state debarment lists. The activities undertaken will affirmatively further fair housing and comply with the Conciliation Agreement. The applicant must have sufficient capacity to administer these funds. Submission of application documents, due December 9, 2011, may be made electronically via Adobe Portable Document File (*.pdf) format. The Land Office requests that electronic submission of any spreadsheets be in a format readable by Microsoft Excel with all formulas intact. In addition, the Land Office requests electronic submission of word-processing documents be in a format readable by Microsoft Word. The electronic submission may utilize a CD-ROM submitted with the hard copy, or sent separately via to Dennis Ku at [email protected]. The completed application must be signed by an authorized signatory. Applicants will have sixty (60) calendar days following contract execution to submit local Housing Guidelines to the Land Office for approval. 5

6 EXHIBIT 1. Previous Housing Participation Information SECTION 1. Previous Participation and Background Certification Form Although the Disaster Recovery Program is administered by the Land Office, these Sections 1 and 2 must reflect TDHCA-assisted affordable housing or related supportive services activities. Review the information for accuracy and full disclosure as incomplete forms or disclosure may result in disqualification of the application or an administrative deficiency. If the Applicant has no previous experience with TDHCA funding, enter N/A in the TDHCA Activity ID# column. Attach an additional sheet if necessary. Applicant Printed Name: Harris County List the Applicant Legal Name for each current or pending application of the Applicant: SECTION 1. EXPERIENCE WITH TDHCA OR OTHER APPLICABLE HOUSING CONSTRUCTION/REHAB. PROGRAMS (LIST ALL IN THE PREVIOUS 10 YEARS) TDHCA Activity ID # 1 Grantee, Contractor, or Sub- Recipient Name Grantee, Contractor, or Sub- Recipient City Total # of Units CDBG HOME HTF HTC NSP Other: Disaster Recovery (CDBG) Contract Begin Contract End Disclosure Harris County Harris County Harris County Unincorporated Harris County 88 08/07 12/10 Unincorporated Harris County /09 07/11 Unincorporated Harris County 50 08/09 07/11 1 TDHCA Activity ID #: Final Development, Contract or Loan Number used by TDHCA to identify the development or activity. 2 Disclosure: Check the box if the development or activity has known past non-compliance or defaults, technical or otherwise. If disclosures exist, then provide on separate document a description of the issue and note whether it has been cured. Examples of disclosures include: defaults, mortgage relief, assignments, foreclosures, material/mechanic s liens, legal action, issuance of IRS Form 8823, instances of non-compliance with local building codes or planning regulations, and other program findings of non-compliance.

7 SECTION 2. EXPERIENCE WITH TDHCA OR OTHER APPLICABLE SERVICE RELATED ACTIVITIES (CDBG, HOME, HTF, CSBG, etc. where the funds were not used for Construction) LIST ALL IN THE PREVIOUS 10 YEARS TDHCA Activity ID # 3 Grantee, Contractor, or Sub- Recipient Name Grantee, Contractor, or Sub- Recipient City Contract Amount CDBG HOME HTF CSBG Other: ESG Contract Begin Contract End Harris County Houston $78,000 09/09 08/10 Disclosure 4 3 TDHCA Activity ID #: Final Development, Contract or Loan Number used to identify the development or activity. 4 Disclosure: Check the box if the development or activity has known past non-compliance or defaults, technical or otherwise. If disclosures exist, then provide on separate document a description of the issue and note whether it has been cured. Examples of disclosures include: defaults, mortgage relief, assignments, foreclosures, material/mechanic s liens, legal action, issuance of IRS Form 8823, instances of non-compliance with local building codes or planning regulations, and other program findings of non-compliance.

8 8 II. Affirmatively Furthering Fair Housing Threshold Prior to submitting an application for housing funds, applicants must review the Partial Analysis of Impediments to fair housing in the service area and describe how this application will address identified fair housing obstacles with these funds under Tab II, Housing Project Detail, in the appropriate narrative section. Demonstration of compliance with this requirement is done through the applicant s adoption and submittal of an approved Fair Housing Activity Statement Texas Form ( FHAST Form ) with the application. The FHAST Form is intended to be a process conducted by a locally-appointed FHAST Work Group, resulting in a locallydefined Fair Housing Action Plan. Activities proposed in the application must be in accordance with the findings of the adopted FHAST form. Attach a copy of the approved & adopted FHAST Form with the application. Applicants must also ensure that the housing needs of very low, low and moderate income households are assisted with housing in proportion to the relative percentages of the overall population which suffered housing damage within the communities being served as demonstrated through the local Needs Assessment. Demonstration of how the Needs Assessment serves as the basis for program design must be reflected in the application. Attach a copy of the Needs Assessment Summary Data with the application. Upon award, each applicant of CDBG Disaster Recovery will be subject to the Disaster Recovery rules under 10 TAC Part 1 Chapter 54 as follows: 5 Each applicant must document compliance regarding actions taken to affirmatively further fair housing as defined by the Partial Analysis of Impediments and to maintain records reflecting the analysis and any actions in this regard. Within six (6) months of the contract start date the Applicant must: (1) Have an affirmative marketing plan in place (the Housing Program Guidelines for Dolly and Ike Round 2 funding further elaborate on affirmative marketing requirements). (2) Establish clear policies in regard to serving people as required under the Civil Rights Act of 1964 and subsequent amendments. Applicants must collect and furnish to the Land Office, on forms to be provided by the Land Office, demographic data concerning the race, color, religion, sex, national origin, age, handicap and familial status (children under 18 living with parents or legal custodians, pregnant women and people securing custody of children under the age of 18) of program beneficiaries. (3) Identify the impediments to Fair Housing and have processes in place to work with recipients to meet the goals of the Fair Housing Act, as identified in the adopted FHAST Form. (4) Design activities for income-qualified applicants who live in FEMA-designated High Risk areas or areas of high minority and/or poverty concentration, as approved by the Land Office. (5) Adopt a formal complaint process. III. Capacity Threshold The Land Office will greatly rely on local operation of the Program and will work closely with each applicant to ensure adequate program administration capacity. Each contract will contain provisions requiring adherence to all applicable federal and state rules and regulations. Failure to abide by the regulations may 5 Rulemaking authority outlined in the TAC may be amended in the future.

9 result in monitoring findings by the Land Office or HUD and determinations of the ineligibility of certain expenses. The Applicant will be required to repay the State for any ineligible expenses. To help prevent findings of ineligibility in the delivery of services, disaster recovery housing funds will only be granted to eligible applicants with the capacity to carry out the housing activities provided in the Application. Sufficient capacity may be obtained from third-party sources who will work as an agent for the Applicant, by collectively demonstrating capacity through agreements, or through the staff of the Applicant. Applications must demonstrate, to the reasonable satisfaction of the Land Office that the Applicant will have the capacity to administer program funds for each of the elected housing programs in a manner which complies with the Action Plan, Action Plan Amendments, and all applicable local, state, and federal legal and regulatory requirements. This required demonstration of capacity may be addressed in one or more of the following ways: By demonstrating the Applicant s proven capacity to administer program funds efficiently as a Subrecipient of funding to the satisfaction of the Land Office; or By the Applicant partnering with one or more other local governments or other entities with proven capacity to administer program funds efficiently as a Subrecipient of the state. Applicants must substantiate that one or more of the above criteria are met by providing supporting documentation for each topic below. 1. Background/Program Experience To demonstrate relevant experience, please describe programs similar in scope of activities and amounts of funding that were successfully completed in the past by the applicant. Describe past programs involving work with vulnerable populations including outreach, case management, and the demographics of the populations served. Also describe past programs involving Community Development Block Grant (CDBG) or other HUD funds, particularly in the disaster recovery context. Briefly describe experience here: Harris County has successfully managed CDBG-Disaster funding with Hurricane Katrina and Rita funding from For Katrina/Rita related funding, Harris County has managed the distribution of $20 million to provide immediate and ongoing public services, community development and housing activities. The development and monitoring of programs to assist Katrina/Rita affected residents provided Harris County with valuable experience in coordinating and developing services in response to a hurricane. Harris County has a proven track record of providing housing related services using direct urban county entitlement funding from the U.S. Department of Housing & Urban Development (HUD) under the Community Development Block Grant (CDBG) and HOME Investment Partnership programs for over 15 years. Over the past six years, the county has provided housing related services to over 1,500 families in homeownership assistance, construction of new single- and multi-family units, and rehabilitation of single- and multi-family units. In PY2010, the County served over 216 families in 15 housing related service programs and expended over $7.5 million during the program year (Harris County CAPER PY2010). The characteristics of clients served in PY2010 were: 22% white, 27% black, 45% Hispanic, and 6% other; 96% owners and 4% renters; and 11% earned less than 30% of MFI, 11% earned 30-60% MFI, and 78% earned 60-80% MFI. Currently, the County is managing $85 million in Hurricane Ike Recovery projects with Round 1 funding. Harris County has contracted with the consulting, engineering, construction, and operations firm, Camp Dresser & McKee, Inc. (CDM), to administer housing services for Round 1 funding. As program administrator, CDM is responsible for day to day management of the program including creating and maintaining a management information system, conducting outreach and providing case management for potential clients. Harris County will be the sole program administrator for Round 2 funding and will contract directly with developers and 9

10 service agencies to provide housing. All Harris County programming will be adjusted and tailored to address the needs assessment. 10

11 2. Personnel/Staff Capacity List all key staff of the applicant that will be directly involved in the administration of the program(s); include titles/positions and briefly describe the roles each key staff member will have and their qualifications to conduct the work included in this application. Please indicate whether the Applicant has a personnel policy manual with an affirmative action plan and a grievance procedure. Discuss any plans to expand staffing to accommodate this/these new program(s) along with general qualifications. Briefly list key staff here: (Attach a copy of the organizational chart with the application. ) Daphne Lemelle is the Director of HCCSD s Housing and Community Development Division, and will provide leadership and management for the Comprehensive Disaster Plan. Ms. Lemelle has served Harris County as a professional in community development for fifteen years. She is a member of the National Community Development Association and is a certified grants manager. Ms. Lemelle oversees program development and manages the HCCSD Disaster Recovery funding for Hurricanes Katrina/Rita. Ms. Lemelle holds a B.S. in Psychology and a B.S. in Training and Development from the University of Houston. Christy Lambright is Assistant Director for Planning and Development for Harris County Community Services Department. Ms. Lambright has served in this capacity for four years and has been a part of CSD staff for 12 years. In this capacity, Ms. Lambright is responsible for all of Harris County s planning efforts and serves as the day to day manager for current Harris County disaster projects for Hurricanes Katrina/Rita and Hurricane Ike. Ms. Lambright served as the County point of contact for the Damage Assessment. Ms. Lambright is also the Harris County representative to the Regional Plan for Sustainable Communities Coordinating Council. Ms. Lambright holds a B.S. in Development and a MUP in Urban Planning from Texas A&M University. Craig Atkins is the Chief Financial Officer for the Harris County Community Services Department, responsible for leadership and oversight of all fiscal matters. Mr. Atkins has been with Harris County for 10 years and has served in his current capacity for nine years. Mr. Atkins has over 20 years of experience in public and nonprofit fiscal leadership, including positions as auditor and controller. Mr. Atkins has provided leadership in all financial matters for the County s nearly $200 million in CDBG-Disaster funds for Hurricanes Katrina/Rita and Ike. Mr. Atkins holds a BBA in Accounting from Louisiana State University. The Grants Management Division is supervised by Elizabeth Winfrey, has 20 years of community development and management experience. Elizabeth received her B.A. in Economics from St. Mary s University and her M.A. in Public Administration from the University of Houston and currently oversees compliance monitoring of entitlement and competitive HUD funding for HCCSD. As Assistant Director, Elizabeth manages 3 Managers, 1 Supervisor and 15 Project Monitors and is responsible for knowledge of federal regulations and guidelines governing the use of grant funds for acquisition, construction, public services, and affordable housing activities. Harris County details its grievance procedures in its personnel policies. The County has an Equal Employment Opportunity Plan, which can be found at 11

12 3. Financial Capacity Describe the Applicant s fiscal management procedures, including financial reporting, record keeping, accounting systems, payment procedures, and audit requirements. If a third party is to be used, describe the duties necessary to carry out the activities described in the application. Briefly explain financial capacity here: The Harris County Community Services Department (HCCSD) operates under a comprehensive set of Administrative and Financial Policies and Procedures in addition to County-wide procedures. These policies and procedures are in place to facilitate internal controls, review and approve all transactions, communicate and monitor financial operations and provide ongoing budgetary evaluation. The Harris County Auditor acts as an internal audit unit that reviews each of the Department s transactions. Harris County accounts for its activities under the Generally Accepted Accounting Principles (GAAP) for State and Local Governmental units. County procedures also ensure compliance with all applicable Office of Management and Budget (OMB) circulars and Cost Principles when accounting for State and Federal program and administrative funds. Harris County maintains and appropriately retains open and accessible financial records. All Harris County financial activities are recorded in the Integrated Financial and Administrative Solution (IFAS) system. Each year, the County employs Deloitte and Touche to perform the Comprehensive Annual Financial Report audit and the OMB A-133 Single Audit. 4. Monitoring Program Goals and Objectives Attach copies of all data collection tools that will be used to verify achievement of program goals and objectives in accordance with benchmark requirements. If a third party will be used, describe how the Applicant will monitor the third party for programmatic compliance and how the Applicant will monitor their progress. Briefly describe monitoring program here: As a current HUD Entitlement Grantee, Harris County requires all subgrantees to submit monthly reports that identify expenditures and units served to ensure that the subgrantees are up to date with their spending and units of service agreed upon in the service contract. Both programmatic and financial staff review these reports to ensure eligible costs and activities. All reports are due within ten working days of the end of the monthly reporting period, and staff contact grantees that fail to submit timely reports until the subgrantee submits reports. Funding is withheld from grantees until Harris County receives accurate and eligible monthly reports. This monthly desk monitoring will continue with the program, though timeliness of reports may require more stringent deadlines for reporting. In addition, Harris County will conduct on site monitoring at least annually. Agencies are notified in writing of any findings resulting from monitoring visits and are given a date by which all findings are to be addressed, as well as corrective actions that must be taken to address the findings. The monitoring letter also addresses concerns and makes recommendations for improvement. Harris County will use its established procedures and will incorporate any additional requirements on an as-needed basis. Subrecipients for housing projects are required to submit an initial report and monthly progress reports to the County. The reports are used to track progress towards goals identified in the contract and application phase of the project. 5. Audit Requirements In accordance with the Office of Management and Budget Circular A-133, the Federal Government requires that organizations expending $500,000 or more in Federal financial assistance in a fiscal year must secure a 12

13 Single Audit. If the Applicant already conducts audits of all its funding sources, submit a copy of the most recent audit. Did applicant expend $500,000 or more in Federal financial assistance in the last fiscal year? YES NO If yes, attach a copy of the Single Audit to the application. Harris County completes a full audit, including a single audit, annually. The full audit and notes to the audit for the entire County can be found at 6. Insurance/Bonding/Worker s Compensation State whether or not the Applicant has liability insurance coverage, in what amount, and with what insuring agency. State whether or not the Applicant pays all payroll taxes and worker s compensation as required by Federal and State laws. State whether or not the Applicant has fidelity bond coverage for principal staff who handle the Applicant s accounts, in what amount, and with what insuring agency. Describe insurance coverage here: The County pays all worker s compensation and payroll taxes as required by Federal and State laws. The county is self-insured/self-funded for Liability exposures in accordance with the Texas Tort Claims Act with maximum liability of $100,000 per person and $300,000 per occurrence. The county purchases Fidelity coverage through Fidelity & Deposit Company. The limit is $3,000,000 and the deductible is $5,000 per occurrence. IV. Benchmark Requirements The contract term for awards will not exceed thirty-six (36) months for multifamily rental projects and twentyfour (24) months for all other housing activities under the Contract at the discretion of the Land Office, which will be evaluated according to benchmark requirements found under 10 TAC

14 Tab II Housing Project Detail I. Project Overview Select all activities that the Applicant is applying to administer or that program funds will be used for. Housing activities shall be administered by the Land Office in accordance with federal and state laws and regulations, and terms of the HUD approved Conciliation Agreement. Activities selected here should be reflected in Tab III: Excel Project Budget Form. Activity Description Act. Code Description Single Family Homeowner Assistance Program Rehabilitation, Reconstruction, New Construction HAP - LMI Rehabilitation or reconstruction of original, hurricane-damaged property, including HOP and non-hop activities.* May involve clearance, demolition, and proper disposal of construction waste; replacement or rehabilitation of damaged hurricane manufactured housing units; elevation of homes; relocation and/or buyout. New Construction (outside of HOP) is limited to situations where local codes and/or zoning will not allow reconstruction. *HOP eligibility to be determined at individual Individual Mitigation Measures (IMM) Rental Rehabilitation, Reconstruction, New Construction - Multifamily Rental Rehabilitation, Reconstruction, New Construction Single Family IMM - LMI R LMI- Multi R LMI - Single application phase. Activities designed to mitigate future disaster damage, such as hardening and elevation. (IMM activities must mitigate and/or reduce risk beyond the pre-disaster condition. Costs associated with meeting minimum code and standard requirements are not IMM. However, costs associated with going above and beyond minimum current code and standard requirements to reduce risk and damage from future disasters may be considered IMM activities.) Rental - Clearance, Demolition, Removal, New/Reconstruction, and Rehabilitation for multifamily rental projects. Rental - Clearance, Demolition, Removal, New/Reconstruction, and Rehabilitation for single-family rental stock recovery. Demolition Only DEMO - SB Demolition of structures with proper disposal of construction waste. Rapid Housing Recovery Pilot Program (certain regions only) RHRP Rapid, efficient, large-scale production of temporary and permanent housing following natural disasters. Homebuyer Assistance Program HBA - LMI Planning Activities 205-P Planning only activities. Including HOP and non-hop activities.* Acquisition of original hurricane-damaged property and relocation. Relocation will involve acquisition and may involve rehabilitation, reconstruction or new construction. Non-HOP assistance will be more limited to down payment, principal reduction, closing costs, etc. *HOP eligibility to be determined at individual application phase. General Administration 206-GA General Administrative activities. Grant Administration is limited to 2% of the grant amount. Project Delivery 4-PD - LMI Project Delivery associated with a specific activity that will be carried out under the CDBG DR program. Project Delivery is limited to 10% of the grant amount. 14

15 II. Project Summary The Applicant must describe the proposed project by answering the following questions: 1. Describe the extent of the needed improvements for the affected area(s), including a description of damage or destruction to housing units, and the extent of the need by persons affected by Hurricane Dolly or Ike as determined by the local Needs Assessment. Harris County has admirably provided quick responses in the recovery and rebuilding efforts. Sensing the urgency for planning not only for immediate needs but also long-term recovery, and the impending flow of federal funds to stimulate recovery, Harris County embarked on the ambitious goal of cataloging and defining both the estimates of total damages from the storm, and cost estimates of the unmet needs. The Harris County Damage Assessment captures as much data as possible from the unincorporated areas in Harris County plus every incorporated area except the City of Houston. These participating communities were canvassed for information regarding repair estimates from storm damage, hazard mitigation options, economic losses of businesses, and public services needs with the ultimate goal of calculating unmet needs of Harris County. One of the largest and most important tasks of recovery is identifying, documenting, and reporting the costs of all damages incurred by the storms. Resources are scarce, yet timeliness is critical. It is equally important to identify the impact of those damages to the communities and its residents. The Harris County Damage Assessment is a guidebook for long-term planning and recovery. Hurricane Ike was one of the costliest storms in recent years with a projected cost of $3.58 billion in residential housing damage in Harris County, excluding the city of Houston. Harris County has a total of more than 532,300 residential units (single family, multi-family, and mobile home). Of the total units, about 230,502 or 43.3 percent, experienced damage ranging from affected to destroyed. As reported in the Hurricane Ike Impact report developed by the State of Texas, Division of Emergency Management, an average of 27% of the wind damaged homes were uninsured and an average of 61% of the flood damages were uninsured. Total projected housing damage for unincorporated Harris County is estimated at $2.37 billion with expected funding of $2.11 billion from FEMA and other sources. This leaves a gap or unmet need of $261 million to be addressed in order to provide the necessary financial assistance to the residents of Harris County that was impacted by Hurricane Ike. Additionally, projected housing damage for incorporated Harris County is estimated at $1.2 billion with an estimated $1.07 billion in funding expected to be received from FEMA and other sources, leaving a gap or unmet need of $132 million. This creates a total unmet housing need for Harris County of $394 million. With this application, Harris County has evaluated its housing and non-housing programs from Round One in terms of Fair Housing. We have assessed the locations of non-housing facilities to minority concentration and poverty and have attempted to reduce barriers to housing choice. 2. Describe how the Applicant will prioritize the provision of decent, safe and sanitary housing for the elderly and disabled populations with an emphasis on housing choice and design to reduce maintenance and insurance costs as well as provide for the provision of independent living options. 15

16 Describe here: Harris County will support projects with Disaster Recovery funding that serve elderly and disabled populations. The County will ensure this funding is used in a way that emphasizes housing choice by supporting projects throughout the County and with preference to new construction projects that are not located in areas characterized by concentrated poverty or minority populations. Harris County will also require that projects submitted for rehabilitation are fortified for future storms and include energy efficient measures to reduce utility and maintenance costs. The county will also encourage provisions for independent living by ensuring that all new construction has the ability to be accessible. The new rental complexes are located near amenities. 3. Describe how the Applicant proposes to resolve the identified needs with the activities described in this application. This should include details on the work to be performed, including the housing activities to be undertaken, the number and types of units to be built, the goals and objectives of the project, and the method of approach. Describe here: Harris County will increase the availability of safe, decent affordable housing for low income residents and special needs populations by constructing new housing to address the specific needs of affected populations, performing rehabilitation on housing damaged by Hurricane Ike, demolishing and replacing housing that is substandard and hardening existing housing to endure future disasters. Harris County s goal with use of these funds is to improve the housing stock throughout the County and fortifying existing housing against future disasters. The goal is to provide decent, safe and affordable housing for all Harris County residents, regardless of race, ethnicity, sex, income, disability or religious affiliation. Harris County will achieve these goals by partnering with nonprofit and for profit housing developers skilled in serving special populations and experience developing housing in specific communities. Work to be performed includes: Buyout and Demolition of single family and multi-family housing units damage by Hurricane Ike Rehabilitation of 150 Single Family Rental units to retain these affordable units Construction of 75 Single family Rental units to replace housing units lost Rehabilitation of approx. 900 Mutli-Family Rental units to retain these affordable units Creation of approx 270 Multi-family rental units to replace housing units lost and housing displaced populations Homebuyer assistance available to 10 households affected by Hurricane Ike 4. Identify the location of proposed activities. 16

17 Identify location(s), by address if available: Attach a map of proposed locations with the application FM 529 Road, #252; 5000 Watkins Way, #196; 5001 Watkins Way, #68; Ferness Lane; Kuykendahl Road; 3805, 3809, 3815 Main Street; 3815 Gulf Freeway; block of Tidwell west of 9,000 block of E Sam Houston Parkway 5. Describe how the Applicant will identify clients, the estimated number of clients to be served, and description of population in terms of age, gender, ethnicity, income level, and other defining characteristics. This should include a description of how program outreach and administration will be tailored to meet the needs of the affected population. Describe client identification and outreach here: Harris County proposes to serve 1,488 households. Of those, 1,216 households will be low income, and at least 87 households will be considered extremely low-income, with a household income at or below 30 percent of the area median income. The gender, age and ethnicity of the clients served will vary by project. At least 55 units will be set aside specifically for homeless men with a history of substance abuse. The expected racial and ethnic make-up of residents varies by project type and is influenced by the location of each project. Generally, the units are expected to serve about 38 percent African American, 31 percent Hispanic, 29 percent White and one percent Asian. At least 8 units have been identified as specifically for residents with physical disabilities, though several projects will likely serve clients with an identified disability. Each project will be required to affirmatively market housing units in ways that can reach the special populations served. This includes but is not limited to local and community newspapers, ethnic language and interest publications, faith based organizations within specific communities, mainstream service providers, nonprofits and community organizations that provide direct services, local media as appropriate, in government buildings and offices, resource and benefits offices and web based and other electronic posting. 6. Describe the process used by the Applicant to gather public input, including participation by neighborhood organizations, community development organizations, social service organizations, community housing development organizations, and members of each distinct affected community or neighborhood which might fall into the assistance category of low to moderate income communities. Describe the client input process here: Harris County solicited public input on the use of funds through multiple avenues. The County released a request for proposals (RFP) to utilize the funding, and advertised the available funding through its mailing list and community partner mailing lists. The RFP for Disaster Recovery funding is made available to the public and all eligible applicants are considered for funding. County staff hosted two public hearings and made the draft application available on its website. The County also made a public announcement through the Houston Chronicle requesting comments for the proposed activities. Staff also attended public events and submitted information through partner organizations listserve to announce the availability of funding. Harris County also had Language Line translation services available for non English speaking residents in attendance at the public hearings. For any housing projects receiving Harris County funding, the agency must hold a public hearing for the subject project; regardless of whether such a hearing was required by any state agency or program. Notice must be provided to HCCSD. Notices must have been sent at least two weeks in advance of the public hearing to all community groups within a two mile radius of the proposed project site and HCCSD representative must attend. If public hearing occurs prior to application, applicant is to provide meeting minutes to HCCSD at the 17

18 time of application submission. The project must be properly characterized. For example, if a project is described as a senior affordable housing project, its occupancy must be limited to seniors and such must be contained in its bond covenants or loan documents. Applicant should receive at least two letters of support from the community in favor of development. 7. Describe any known factors that may present fair housing obstacles and how those obstacles will be addressed with these funds. Be very specific about how those factors were taken into account and how they specifically propose to address Affirmatively Furthering Fair Housing (AFFH) requirements, compliance with the Conciliation Agreement and the Fair Housing Activity Statement Texas Form ( FHAST Form ) adopted by the Applicant. To the extent that such solutions may increase the cost of delivery, the applicant should also describe their assessment of those cost factors and the final recommendations for use of these funds. Describe fair housing factors here: One of the biggest fair housing obstacles in Harris County is the availability of affordable housing, especially for special populations. The majority of the homeless population in Harris County comes from racial minorities and qualifies as disabled. These two factors limit housing choice for these protected classes outside of areas that have concentrations of minorities or concentrations of poverty. In addition, because of limited or no income for the homeless population housing choice is severely limited in a disaster situation. To address the needs of this population, the County proposes to use funds to buyout a property that serves as housing for homeless individuals located an area with a high minority concentration that is extremely prone to flooding and was affected by Hurricane Ike. The County, in partnership with developers throughout the community, will replace these units with new construction throughout the County. The replacement units will be scattered site across multiple projects and will be located in areas that are not characterized by concentrated minority populations or concentrated poverty. Limited affordable housing also poses an obstacle to Fair Housing for low income minority groups. With 17 percent of Harris County residents below the poverty line per the 2010 Census, minorities are disproportionately represented among the lowest income residents. There is limited housing choice for this protected class outside of areas with high concentrations of poverty and/or minorities. Because much of the housing stock in these areas is substandard, the loss of housing during disaster adversely affects this populations. To address this obstacle, Harris County is selecting to rehabilitate rental units, both single and multi-family, that are located outside of the concentrated areas. One project will specifically address the needs of low-income households with large families by retaining the units lost for this protected class. Harris County will add new single family housing on the east side of the County to address this obstacle to fair housing for large families. 8. Describe the process including the setting of goals that will be utilized by the Applicant to meet Section 3 Requirements. Applicants will be required to provide job opportunities to low-income residents and businesses, to the greatest extent possible. The Land Office will develop minimum thresholds and impose quarterly reporting requirements that will include, but not be limited to, the demographics and addresses of hires and local efforts towards stated goals. 18

19 Describe Section 3 Plan here: Harris County requires all recipients of funding for construction to comply with Section 3 requirements that, to the greatest extent feasible, preference for hiring be given to low and very low income persons, particularly those who are recipients of governmental assistance for housing, and to businesses that provide economic opportunities for these persons. Harris County bases its goals off of subrecipient projections of Section 3 qualified hires at the beginning of the contract period. Subrecipients are asked to indicate the number of employees per job category, which will have to be hired for the contract, including numeric goals for hiring within project area residents, minority, female employees, and Section 3 residents. Job categories include: Para-professional/ Professionals/ Managers/ Clerical, Laborer, Mechanic, Apprentice/Trainee. Subrecipients must also detail the extent to which they project to include small business, minority or women owned business or Section 3 business interests as subcontractors for their projects. Harris County provides subrecipients with relevant resources to identify such business. Subrecipients are required to conduct outreach to minority, women, Section 3 residents, Section 3 business concerns, and project area residents and businesses informing them of employment and contracting opportunities for any construction contract. Evidence of good faith effort solicitations must be documented and attached to the Section 3 Plan. Harris County will set goals against those reported goals of each subrecipient, and will monitor the progress toward those goals monthly. 9. Describe how the Applicant will ensure that it adheres to the Land Office s expenditure performance requirements. The expenditure performance requirement also requires that the Applicant provide an expenditure rate submittal at least every six months, or as requested by the Land Office, from contract execution date. Describe planned expenditure process here: As part of the project development and request for proposals process, Harris County required that all projects submit a project implementation plan with their application. This plan details specific activities that will be carried out during the project and is linked directly to the proposed budget. Harris County will use this schedule to monitor subrecipient progress and ensure that the projects stay on target with budget and expenditures. Tab III - National Program Objectives, Low-Moderate Income Calculation, & Project Budget 19

20 Benefit to Low-Moderate Income (LMI) is the only National Objective that is approved for the Rental Program under Round 2. Benefit to LMI is the principal National Objective that is approved for the Single Family Program under Round 2, with projects serving the elimination of Slum and Blight to be eligible upon request and approval from the Land Office. LMI activities shall benefit households whose total annual gross income does not exceed 80% of Area Median Income (AMI), adjusted for family size. Income eligibility will be determined and verified in accordance with 24 CFR Part 5 requirements using procedures as stated in the Technical Guide for Determining Income and Allowances, 3rd Edition (HUD-1780-CPD). The most current income limits, published annually by HUD, shall be used by the applicant to verify the income eligibility of each household applying for assistance at the time assistance is provided. LMI economic subcategories are as follows: Very low: Household s annual income is up to 30% of the area median family income, as determined by HUD, adjusted for family size Low: Household s annual income is between 31% and 50% of the area median family income, as determined by HUD, adjusted for family size Moderate: Household s annual income is between 51% and 80% of the area median family income, as determined by HUD, adjusted for family size The Applicant must provide a budget breakout for the entire grant award. Complete the attached Excel Budget Form for the total allocation for the Applicant, by National Objective and LMI category, including all housing activities. Additional information that is normally included in a CDBG application may be collected during the contract stage to limit the amount of information required in the application. All applicants must keep financial records for the proposed project at an officially designated site that is accessible to the public. The funds must be adequately managed on a timely basis using generally accepted accounting principles. Attach a copy of the Excel Project Budget Form with the application. Tab IV Listing of Properties Currently Owned or Managed - Multifamily All applicants for multifamily rental funds must provide a complete listing with addresses of multifamily properties currently owned or managed. Attach a listing of all properties with the application, if applicable. 20

21 Tab V Citizen Participation Plan A grant to a locality under the Texas General Land Office (the Land Office) Financial Management Disaster Recovery Program (Disaster Recovery) may be awarded only if the locality certifies that it is following a detailed citizen participation plan that provides for and encourages citizen participation at all stages of the Disaster Recovery Program. Disaster Recovery applicants and funded entities are required to carry out citizen participation procedures in accordance with the Citizen Participation Plan as described in this application. Each applicant certifies, by signing the Form 424 that it has and will comply with the requirements of the Citizen Participation Plan as stated in this section. Each applicant must maintain a citizen participation file which includes a copy of the Plan Requirements below; the applicant's complaint procedures; any technical assistance provided by the applicant; and public notices, minutes, and attendance lists for public hearings. Applicants are cautioned that despite the expedited application process, they are still responsible for ensuring that all citizens have equal access to information about project activities. Each applicant is required to conduct at least one (1) public hearing prior to submitting an application. In conjunction with the posting of the public hearing the Applicant must post the application on the Applicant s website. Plan Requirements The Plan Requirements include the following: 1. Outreach Efforts: Provide for reasonable public notice, appraisal, examination, and comment on the activities proposed for the use of Disaster Recovery funds. These efforts shall include: i. Provide for and encourage citizen participation, particularly by low and moderate income persons who reside in slum or blighted areas and areas in which Disaster Recovery funds are proposed to be used; ii. Ensure that citizens will be given reasonable and timely access to local meetings, information, and records relating to an entity s proposed and actual use of Disaster Recovery funds; iii. Furnish citizens information, including but not limited to: a. The amount of Disaster Recovery funds expected to be made available; b. The range of activities that may be undertaken with the Disaster Recovery funds; c. The estimated amount of the Disaster Recovery funds proposed to be used for activities that will meet the national objective of benefit to low and moderate income persons; and d. The proposed Disaster Recovery activities likely to result in displacement and the entity s anti-displacement and relocation plan. iv. Provide citizens with reasonable advance notice of, and opportunity to comment on, proposed activities in an application to the state and, for grants already made, activities which are proposed to be added, deleted or substantially changed from the entity s application to the state. Substantially changed means changes made in terms of purpose, scope, location or beneficiaries as defined by criteria established by the state. v. These outreach efforts may be accomplished through one or more of the following methods: 21

22 a. Publication of notice in a local newspaper. A published newspaper article may also be used so long as it provides sufficient information regarding program activities and relevant dates; b. Notices prominently posted in public buildings and distributed to local Public Housing Authorities and other interested community groups; c. Posting of notice on the local entity website (if available); or d. Individual notice to eligible cities and other entities as applicable using: i. Certified mail ii. Electronic mail or fax iii. First class (regular) mail iv. Personal delivery (e.g., at a Council of Governments [COG] meeting); 2. Complaint Procedures: The applicant/recipient must have written citizen complaint procedures that provide a timely written response (within 15 working days) to complaints and grievances. Citizens must be made aware of the location and the days and hours when the location is open for business so they may obtain a copy of these written procedures. 3. Technical Assistance: When requested, the applicant/recipient shall provide technical assistance to groups representative of persons of low and moderate income in developing proposals for the use of Disaster Recovery funds. The level and type of assistance shall be determined by the applicant/recipient based upon the specific needs of the community's residents. 4. Public Hearing Provisions: Although the Federal Notice [Docket No. FR-5256-N-01] regarding Disaster Recovery Grantees Under 2008 Supplemental CDBG Appropriations specifically removes the mandate for public hearings at either the state or local government level for projects proposed under this Fund, the applicant is required to conduct at least one (1) public hearing prior to submitting an application. In addition, all notices of any public hearings or requests for public comment that relate to the administration of Disaster Recovery funds must be submitted to the Land Office to post on the Land Office s website. For each public hearing scheduled and conducted by a Disaster Recovery applicant or recipient, the following public hearing provisions shall be observed: i. Public notice of all hearings must be published at least seventy-two (72) hours prior to the scheduled hearing. The public notice must be published in a local newspaper. Each public notice MUST include the DATE, TIME, LOCATION and TOPICS to be considered at the public hearing. A published newspaper article may also be used to meet this requirement so long as it meets all content and timing requirements. Notices should also be prominently posted in public buildings and distributed to local Public Housing Authorities and other interested community groups. ii. Each public hearing shall be held at a time and location convenient to potential or actual beneficiaries and will include accommodation for persons with disabilities. Persons with disabilities must be able to attend the hearings and an applicant must make arrangements for individuals who require auxiliary aids or services if contacted at least two days prior to each hearing. iii. When a significant number of non-english speaking residents can be reasonably expected to participate in a public hearing, an interpreter will be present to accommodate the needs of the non-english speaking residents. The applicant must also comply with the following citizen participation requirements in the event that the applicant receives funding from the Disaster Recovery Program: 1. The funded entity is highly encouraged to hold a public hearing concerning any substantial change, as determined by the Land Office, proposed to be made in the use of Disaster Recovery funds from one eligible activity to another. 2. Upon completion of the community development program activities, the funded entity is encouraged to hold a public hearing and review its program performance, including the actual use of Disaster Recovery funds. 22

23 3. If applicable, the funded entity must retain documentation of the hearing notice(s), attendance list(s), minutes of the hearing(s), and any other records concerning the actual use of funds for a period of three years after the project is closed out. Such records must be made available to the public in accordance with Chapter 552, Government Code. The applicant must submit to GLO at [email protected] all notices of any public hearings or requests for public comment the applicant may have that relates to the administration of Hurricane Recovery funds that are provided to the applicant. GLO will post such notices received on its website. Such postings will not fulfill the applicant s responsibility under Chapter 551 of the Texas Government Code.The applicant certifies compliance with these Citizen Participation Plan requirements by signing the 424 FORM. Local Certifications Each applicant for Disaster Recovery funding must certify by signing the 424 Form that Local Certifications included in this Application have been followed in the preparation of any Disaster Recovery Program application and that they will continue to be followed in the event of funding. Each applicant must comply with the provisions of the National Environmental Policy Act, Council on Environmental Quality regulations, as well as the requirements set forth in Title 24 Code of Federal Regulations Part 58 and applicable Land Office policy directives. All applicable federal and state laws, including environmental, labor (Davis-Bacon), procurement procedures, and civil rights requirements apply to the use of these funds. With respect to the expenditure of funds provided under a Disaster Recovery contract, each Disaster Recovery grantee is required to certify that: 1. It will minimize displacement of persons as a result of activities assisted with such funds. 2. The program will be conducted and administered in conformity with Title VI of the Civil Rights Act of 1964 (42 USC 2000d et seq.) and the Fair Housing Act (42 USC ), and that it will affirmatively further fair housing, as specified by the Land Office. 3. It will provide for opportunities for citizen participation and access to information with respect to its disaster recovery programs and it is following the Land Office's Disaster Recovery Program Citizen Participation Plan. 4. It will not attempt to recover any capital costs of public improvements assisted in whole or in part with Disaster Recovery funds by assessing any amount against properties owned and occupied by persons of low to moderate income, including any fee charged or assessment made as a condition of obtaining access to such public improvements unless: (A) disaster recovery grant funds are used to pay the proportion of such fee or assessment related to the capital costs of such public improvements that are financed from revenue sources other than such funds; or (B) for purposes of assessing any amount against properties owned and occupied by persons of low and moderate income who are not persons of very low income, the grantee certifies that it lacks sufficient funds under this contract to comply with the requirements of clause (A). 5. It will comply with the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, with provisions as waived under the Federal Notice [Docket No. FR-5256-N-01] regarding Disaster Recovery Grantees Under 2008 Supplemental CDBG Appropriations and will follow a residential anti-displacement and relocation assistance plan, as specified by the Land Office, in the event that displacement of residential dwellings will occur in connection with a project assisted with Disaster Recovery funds. 6. It has adopted or will adopt and enforce 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 enforce applicable State and local laws against physically barring entrance to or 23

24 exit from a facility or location which is the subject of such nonviolent civil rights demonstrations within its jurisdiction. 7. To the best of the Disaster Recovery grantee s knowledge and belief: (A) No Federal appropriated funds have been paid or will be paid, by or on behalf of the Disaster Recovery grantee, to any person for influencing or attempting to influence an officer or employee of any agency, a member of Congress, an officer or employee of Congress, or an employee of a member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement. (B) If any funds other than Federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a member of Congress, an officer or employee of Congress, or an employee of a member of Congress in connection with this Federal contract, grant, loan, or cooperative agreement, the Disaster Recovery grantee shall complete and submit Standard Form-LLL, "Disclosure Form To Report Lobbying", in accordance with its instructions. (C) The Disaster Recovery grantee shall require that the language of this certification be included in the award documents for all sub-awards at all tiers (including subcontracts, sub-grants, and contracts under grants, loans, and cooperative agreements) and that all subrecipients shall certify and disclose accordingly. 8. Funds will be used solely for necessary expenses related to disaster relief, long-term recovery, and restoration of infrastructure in areas covered by a declaration of major disaster under Title IV of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C et seq.) as a result of natural disasters that occurred and were declared in Disaster Recovery funds will not be used for any activity in an area delineated as a special flood hazard area in FEMA s most current flood advisory maps, unless it also ensures that the action is designed or modified to minimize harm to or within the floodplain, in accordance with Executive Order and 24 CFR Part

25 List of Required Attachments In addition to this completed application, please submit the following attachments: N/A Previous Participation Form (if applicable) N/A Fair Housing Activity Statement Texas Form ( FHAST Form ) Needs Assessment Summary Data Single Audit (if applicable) Organizational Chart Project Location Map Tab III: Excel Project Budget Form N/A N/A Tab IV: Listing of All Properties (if applicable) Grant Administrator Selection Form (if applicable) 25

26 Fair Housing Activity Statement Texas Recognizing that each jurisdiction is unique, this Fair Housing Activity Statement - Texas is intended to be used in conjunction with the Analysis of Impediments, Phase I as a form to help the applying jurisdictions perform assessments of their impediments to fair housing choice, plan actions to address identified impediments, and communicate their plans to the State of Texas and HUD. BEFORE beginning to fill out this form, each jurisdiction should: (1) Participate in the regional FHAST Form training. (2) Review the 2010 Texas Interim Phase I AI in detail; (3) Gather relevant information (see instructions in Appendix A); (4) Convene a FHAST Working Group to assess the data collected in #2 and fill out the FHAST form (see instructions in Appendix A.) Impediment #1 Protected classes may experience disparities in home mortgage lending and high cost loans. No local action is required at this time. Impediment #2 There is inadequate information available to the real estate community, governments and the public about fair housing requirements and enforcement procedures. No local action is required at this time. Impediment #3 The public is not sufficiently aware of their Fair Housing rights and how to obtain the assistance necessary to protect those rights. 1. Consistent with the Fair Housing Act, the State of Texas, and funded sub-recipients should continue to promote and conduct events to celebrate April as Fair Housing Month, and direct sub-recipients to do the same. These events can demonstrate support for fair housing and build awareness. We will commit to undertake Fair Housing Month activities. (Check all that apply.) Passage of a resolution by our governing body. Activities in schools. Placing posters in public buildings. Governing body will hold a special hearing to solicit input from the community. Other. Please specify.

27 When will you undertake these activities? Not Applicable (Explain) 2. Consistent with the Fair Housing Act, the State of Texas and funded sub-recipients have historically conducted fair housing activities at various times of the year and should continue to fund, depending on sufficient appropriations, or collaborate with public and private agencies, organizations and groups to plan and conduct fair housing activities. We will conduct/sponsor/fund in fair housing activities at various times of the year other than April as Fair Housing Month. Attach a description of these activities and identify the organizations and agencies you have worked with. When will you do this? Not Applicable (Explain) Impediment #4 "Not in my Backyard (NIMBY) may be an impediment to fair housing in Texas communities. 1. NIMBY opposition needs to be anticipated and planning and outreach should occur on the front end of projects. To mitigate defensive and reactive responses, planning should include strategies for education, outreach and marketing that provide accurate information and promote the positive aspects and benefits of affordable housing to build support among community residents. [1] 2. The Department of Housing and Urban Development (HUD) provides extensive information about Fair Housing and examples at Generally communities should consider: Working with local officials, editorial boards, religious and civic organizations and other community leaders to initiate education programs. Seeking opportunities to present information to community organizations by requesting to be placed on their meeting agendas. Including a visit to the Group Home residence as part of an education program. Answering all questions. Talking with local neighborhood leaders, including elected representatives, and setting up a neighborhood meeting. Setting up a liaison committee consisting of advocates, group residents, and neighborhood residents to discuss issues. Identifying areas that meet AFFH targets where the community supports development, has worked with community groups and potentially uses funds to assist the development of multi-family affordable housing. We have developed an anti-nimbyism action plan. [Attach a copy or description] We will develop an anti-nimbyism action plan. [Designate who will be responsible for developing this plan.] When will you do this?

28 Not Applicable (Explain) Impediment #5 Certain governmental policies and practices may not meet current HUD policy concerning affirmatively furthering fair housing. Jurisdictions should act to ensure that their policies and procedures affirmatively further fair housing, address mal-distribution of resources, and that they do not unnecessarily impact housing choice. 1. As part of certifying that a community is affirmatively furthering fair housing, jurisdictions that have long-term infrastructure plans should review them to determine if the plan promotes racial concentrations or otherwise inadvertently results in disparate treatment of members of protected classes. While not intended to direct a community to hire a consultant, it is anticipated that a community will review its long-term infrastructure plans as part of this recommended action. In reviewing the project list (Appendix F of the Phase 1 AI) there are many projects that are listed as being of community-wide benefit. The records do not indicate the actual location of projects or provide adequate discussion of how the projects benefit the entire community. We have a long-term infrastructure plan and will review the plan to determine if it promotes racial concentrations or otherwise inadvertently results in disparate treatment of members of protected classes as it relates to the availability of housing. When will you do this? 2011 Not Applicable (Explain) We have already collected information on the locations of protected populations and have adequate information for insuring that new projects with citywide benefits will not perpetuate illegal differences in treatment. We will use the information in the AI to ensure that proposed projects do not perpetuate illegal differences in treatment. When will you do this? 2011 Not Applicable (Explain) 2. As it has been determined under federal law that Fair Housing applies to all federal housing and community development funds, to reduce siloing the fair housing component into only housing-related programs, fair housing should be considered in all activities for all local community planning staff. We have determined that consideration of Fair Housing implications has already been incorporated into all aspects of planning in this jurisdiction. [Please attach supporting documentation.] We will review and insure that Fair Housing implications are addressed in all aspects of planning in this jurisdiction in a manner consistent with the guidelines provided by the state at the FHAST form training and maintain documentation of that review.

29 When will you do this? Not Applicable (Explain) 3. It would be beneficial for local elected officials to require senior staff of any subrecipient such as a city or county including managers and attorneys to receive available Fair Housing training within the first 12 months of their employment or engagement. We have a policy in place providing for all senior staff including managers and attorneys to receive Fair Housing training within their first 12 months on the job, and for long-term senior staff to receive regular updated training. [Attach copy of policy] We do not have such a policy and will develop and implement one. When will you do this? Not Applicable (Explain) 4. As part of what is usually a common initial training by the associations that provide education opportunities for newly-appointed board members or newly-elected council or commissioners court members of cities and counties, the state should request that training include specific information on the Fair Housing Act with a discussion of affirmatively furthering fair housing obligations. No local action is required at this time. 5. Local communities should consider limiting the concentration of infrastructure improvements like wastewater treatment, solid waste disposal, or similar necessary but not desirable infrastructure projects in residential areas where there are concentrations of protected classes. We have an official policy that limits the concentration of certain infrastructure improvements. [Attach a copy.] We have official policies and procedures that take the location of protected classes into account when deciding where to locate undesirable infrastructure improvements. [Attach a copy.] We do NOT have limits on the concentration of undesirable infrastructure improvements or policies and procedures that take the residential location of members of protected classes into account, but will develop formal limits or official policies and procedures. When will you do this? Not Applicable (Explain)

30 6. Communities electing to provide publicly financed housing incentives should be requested to call for recipients to engage in affirmative marketing. We have a policy requiring Affirmative Marketing Plans from developers seeking tax abatements or other supports for new housing. We do not have such a policy and will develop and implement one. Not Applicable (Explain) When will you do this? If a jurisdiction is a non-entitlement community, when working in LMI areas to replace roads or other infrastructure, the jurisdiction should consider making application for additional sources of funding to provide assistance to repair substandard housing associated with the project (i.e., TDHCA or HUD.) We formally consider accessing supplementary funds when infrastructure proposals are developed. [Attach policies.] We have not consistently done this in the past and we will develop a process to formally consider making housing funding applications when funds for infrastructure projects are sought. When will you do this? Not Applicable (Explain) Harris County is an Entitlement Community 8. Most infrastructure projects take into account items like curb cuts, sidewalks, hearing and visually impaired indicators at intersections. When approving non-federally funded projects, similar special needs construction should be required for infrastructure improvements. Projects should also address other legacy discrimination issues, such as accessibility in public areas like courthouses, community centers and other high traffic areas. We currently require that applications for non-federally-funded infrastructure projects are ADA compliant and address other legacy discrimination issues. We do not have such a requirement. We will develop one. When will you do this? 2011 Not Applicable (Explain) 9. Each jurisdiction applying for Community Development Block Grant funds or other federal housing and community development funds should submit a Fair Housing Activities Statement Texas (FHAST) with their application, reviewing their infrastructure needs and housing needs and how the proposed activity promotes fair housing or results in more equitable treatment of protected classes. Projects with community-wide benefits should be accompanied by explicit commitments on the part

31 of the local jurisdictions to undertake additional activities to affirmatively further fair housing along with a monitoring and reporting process. We submit a FHAST form. When will you begin to do this? 2011 Not Applicable (Explain) 10. As part of the non-housing disaster recovery program, jurisdictions should consider low-income areas and areas populated principally by members of protected classes to determine the potential for flooding and consider making infrastructure expenditures to help protect the impacted communities including colonias. We have reviewed LMI areas and areas populated principally by members of protected classes, and prioritized infrastructure expenditures to help protect the impacted communities including colonias. We have not done this in the past but will conduct such a review and consider these infrastructure projects in the future. When will you do this? 2011 Not Applicable (Explain) 11. If applicable, all policies should be reviewed regarding denying applicants access to disaster recovery CDBG funds if their residence is located in the flood plain. If the policy does not allow participation by restricting building in flood plains, then the policy should be assessed to see if alternative housing programs could be implemented for the residents. Local jurisdictions should analyze the results and see if protected classes are more frequently harmed by flood plain restrictions. This action does not apply to the GLO CDBG Disaster Relief Fund that limits property purchase unless TXCDBG receives satisfactory evidence that the property to be purchased was not constructed or purchased by the current owner after the property site location was officially mapped and included in a designated flood plain. We have completed this review and analysis and will take action on our findings. We have not completed this review and analysis. We will do so and take appropriate actions based on our findings for Round 2 programs. When will you do this? 2011 Not Applicable (Explain) 12. When an entire community is in a flood plain, the community should establish clear standards that allow for proper elevation or relocation, and that also allows for visitability/special needs considerations consistent with state [3] and federal law. [3] Texas Government Code Section

32 We have established clear standards that allow for proper elevation of homes or for relocation, and also allow for visitability/special needs considerations consistent with state and federal law. [Attach documentation.] We have not developed these standards but will do so for Round 2 programs. When will you do this? 2011 Not Applicable (Explain) 13. Local jurisdictions that accommodated the relocation of disaster survivors resulting in concentrations of protected class survivors in specific areas should establish Moving to Opportunity Programs and include renters in their Moving to Opportunity Programs as defined under Round 2. This action step applies to our jurisdiction. We will establish a Moving to Opportunity Program for disaster survivors as part of our Round 2 housing recovery program. When will you do this? 2011 Not Applicable (Explain) 14. Consistent with the process established in the Conciliation Agreement, local jurisdictions and state agencies should work together to determine a demographic and economic profile of victims of the natural disaster and establish goals for assisting these populations in no less that the proportions they were impacted by the disaster. These goals should be performance goals and disaster recovery funds should be extended incrementally in a manner to ensure that these populations are equitably assisted with benefits. We will cooperate with state agencies to carry out this action step. When will you do this? 2011 Not Applicable (Explain) 15. All infrastructure programs funded with disaster recovery funds should be designed so that any publicly accessible infrastructure projects and associated facilities are fully accessible to persons with disabilities. We have established clear policies and procedures to insure that all infrastructure programs funded with disaster recovery funds will be designed so that any publicly accessible infrastructure projects and associated facilities are fully accessible to persons with disabilities. [Attach documentation.] We have not developed these standards and policies; we will do so for Round 2 infrastructure projects. The person or entity responsible for developing these standards will be Harris County Community Services Dept..

33 Not Applicable (Explain) When will you do this? Consistent with the Conciliation Agreement, family and elderly public housing units damaged or destroyed by the disaster should be reconstructed or repaired in a manner that affirmatively furthers fair housing utilizing disaster recovery funds within 24 months of approval of the initial application for disaster recovery assistance for the local jurisdiction. We affirm that family and elderly public housing units damaged or destroyed by the disaster will be reconstructed or repaired in a manner that affirmatively furthers fair housing utilizing disaster recovery funds within 24 months of submission of the initial application for disaster recovery assistance by the local jurisdiction. Not Applicable (Explain) Impediment #6 Governmental entities at all levels do not appear to have been proactive in the enforcement of both the Fair Housing Act and the obligation to affirmatively further fair housing. The State and subrecipients should implement a robust and effective structure for identifying and pursuing suspected violations. 1. Given the potential for increase in Fair Housing enforcement action by federal and state agencies and private organizations, an ongoing fair housing testing program for areas that receive federal housing and community development funds could be beneficial to protect state agencies and sub-recipients from potential repayment. Fair housing enforcement is a valid use of CDBG funding and can be used to establish testing programs by agencies trained in HUD testing procedures. The state, or local jurisdictions combining together, should consider conducting tests in areas that include the following: steering in sales and rental; the denial of and different terms and conditions based on race, national origin, familial status, and disability in sales and rental; predatory and disparate terms and conditions in lending and insurance; and foreclosure modification schemes targeting minority neighborhoods. The state should also consider education to applicable entities on self-testing and self-correction. We currently have a testing program for Fair Housing violations. For more information. We do not have a testing program for Fair Housing violations and plan to establish one. When will you do this? Not Applicable (Explain) 2. TDHCA should, as a pilot program, allocate funds to independent third parties or a combined jurisdiction team identified in point 1 of this section to provide similar testing to determine if additional enforcement is necessary.

34 No local action is required at this time. 3. Impacted agencies that provide certification that they are affirmatively furthering fair housing as required by federal law, should consider publishing a public document on enforcement that provides the public and communities with a clear description (and chart) of the state and Federal Fair Housing Act. On documents concerning housing and community development programs that are provided to the public, we will list fair housing enforcement contacts and procedures consistent with the State suggested language when it is provided in Not Applicable (Explain) When will you do this? Each community should place on its website (if one is available) the contact, at the local, state, and federal levels, for reporting a Fair Housing complaint, if citizens believe they were victims of housing discrimination. We have published the contact information at the local, state and federal levels for reporting a Fair Housing complaint. [Attach a copy or URL.] We have not done so but will do so. When will you do this? 2011 Not Applicable (Explain) 5. Each local jurisdiction should publish on its website a clear statement, approved jointly by TDHCA, expressing the jurisdiction's obligation to affirmatively further fair housing and providing a method for reporting suspected noncompliance to the state and to HUD. The jurisdiction s contact person should be able to refer to clear local Fair Housing procedures for the complaint process, keep logs and records of all inquiries, allegations, complaints and referrals. These reports should be sent to the appropriate funding agency. Where these reports show that a jurisdiction has administered programs inconsistently with the AI and had the effect of discouraging applications from members of protected classes who are deemed eligible under the plan for assistance, affirmative marketing plans should be developed and submitted to the appropriate agency. We have published a policy statement expressing our jurisdiction s obligation to Affirmatively Further Fair Housing. [Attach a copy or URL.] We will publish a policy statement consistent with the language the State provides in When will you do this? 2011

35 Not Applicable (Explain) We have developed clear procedures for the Fair Housing complaint process. [Attach a copy] We will develop clear procedures for the Fair Housing complaint process once more guidance in given by the State in When will you do this? 2011 Not Applicable (Explain) We keep complete logs and records of all Fair Housing inquiries, allegations, complaints and referrals and have a policy statement about these legal records. We will begin keeping required logs and records. When will you do this? 2011 Not Applicable (Explain) We have remedial procedures for developers, landlords, home sellers and others whose actions may be inconsistent with Fair Housing laws and regulations. We do not have remedial procedures but will develop them. The agency or person who will be responsible for developing these procedures is Harris County Community Services Dept. When will you do this? 2011 Not Applicable (Explain) Impediment #7 Many local jurisdictions have zoning codes, land use controls, and administrative practices that may impede fair housing choice and fail to affirmatively further fair housing. 1. The law anticipates that ordinances creating disparate impact should also be reviewed for change. If a disparate impact is determined to exist by the local jurisdiction, it could repeal or amend the restriction, use public funds to offset the cost through homebuyer assistance programs, or waive fees or other offsets to make the home more affordable. We recently conducted or updated a Fair Housing Review of our ordinances and codes. We have not done so but will conduct a review

36 We have a policy statement/guidance for those responsible for developing codes/ordinances that reminds them to consider and document the Fair Housing/AFFH implications of any new rule. We do not have such a policy/guidance but will develop one when suggested guidelines are provided by the State in When will you do this? 2011 Not Applicable (Explain) 2. To help limit concentrations that could be considered impediments to affirmatively furthering fair housing, jurisdictions that have long term planning documents for housing growth or redevelopment, or revitalization plans, should consider allowing or encouraging mixed income affordable housing in the plan and provide incentives for development of this type of housing in areas that are not concentrated. We recently conducted a Fair Housing Review and took/are taking appropriate action concerning our planning documents. [Attach a list of plans reviewed, a summary of findings, and actions you will take to remove impediments] We have not done so but will conduct a Fair Housing Review after the State provides suggested guidelines in When will you do this? 2011 Not Applicable (Explain) We have identified residential areas that show concentrations or underrepresentation of protected groups, and we encourage mixed-income affordable housing and other strategies to widen housing choice throughout our jurisdiction. We have not done so but will include this in our FHAST plan once guidelines are provided by the State in When will you do this? Not Applicable (Explain) 3. Local jurisdictions seeking CDBG Disaster Recovery funds from the state should consider offering expedited permitting and review processes for affordable housing projects within high opportunity target zones. We currently offer incentives to developers to locate affordable housing projects in high opportunity neighborhoods and prevent overconcentration. We have not done so but will.

37 When will you do this? Not Applicable (Explain) Impediment #8 Inadequate planning for re-housing after an emergency situation creates a situation where persons who are uninsured or under-insured, low income, or special needs can be displaced for long periods of time. 1. Some legislators, the Sunset Commission, and communities acknowledge that while temporary disaster housing is a federal program, Texas should continue to provide guidance to local governments on additional planning that needs to be done as part of the emergency preparedness planning to most efficiently work with FEMA. No local action is required at this time. 2. As much of what FEMA has previously offered is travel trailers or manufactured housing, local governments should review their zoning requirements or other land use provisions that restrict temporary housing or housing on an existing lot during the building process and look at potential waivers that do not risk or negatively impact health, safety, and welfare during a period after disasters so that low income persons can move back to their existing communities with temporary housing while waiting for redevelopment. We have reviewed our zoning requirements and other land use provisions and have provided waivers or other accommodations for post-disaster housing. We have not done so but will review our zoning and look at potential waivers. When will you do this? Not Applicable (Explain) Impediment #9 There are impediments in public and private actions and private attitudes to housing choice for persons with disabilities. 1. To meet federal Fair Housing requirements for zoning and neighborhood uses, jurisdictions should look to determine if there are direct or indirect limitations in codes that would prevent facilities or personal residences from providing assistance or communities of choice or service-enriched environments that directly impact special needs persons. 2. Local jurisdictions should work to ensure that zoning or code requirements do not unnecessarily impose stricter commercial building requirements, such as emergency access or protection services, on group homes, thereby dramatically increasing housing costs for persons with special needs. We have reviewed our codes and ordinances and have addressed/are addressing any impediments relating to special needs persons, including (1)

38 rules that might prevent facilities or personal residences from providing assistance or communities of choice or service-enriched environments that directly impact special needs persons, and (2) rules that might unfairly increase the costs to special needs persons. We have not done so but will conduct a review and address any impediments identified once guidelines are provided by the State in When will you do this? 2011 Not Applicable (Explain) 3. Local jurisdictions should consider coordinating with the legislatively created Housing and Health Services Coordination Council for best practices on working with supportive services. We agree to coordinate with the legislatively created Housing and Health Services Coordination Council staffed by TDHCA for best practices on working with supportive services. When will you do this? Not Applicable (Explain) Impediment #10 There are barriers to mobility and free housing choice for Housing Choice Voucher holders including: inadequate tenant counseling services and mobility assistance, failure of PHAs to apply for the FMR pilot demonstration funds, and government policies, procedures, and regulations that tend to decrease participation by private housing providers and to restrict available housing to racially or low-income populated neighborhoods with little access to economic, educational, or other opportunity. No local action beyond compliance with Round 2 Housing Guidelines is currently required but communities are encouraged to work with local public housing authorities to understand and overcome these impediments. Impediment #11 Loss of housing stock in Hurricanes Dolly and Ike compounded the shortage of affordable housing in disaster recovery areas. This shortage is particularly acute in safe, low-poverty neighborhoods with access to standard public services, job opportunities and good schools. No local action is required at this time. TDHCA will develop a statewide strategic plan including guidance for local jurisdictions on the following Action Steps in To help offset the costs of developments that feature reduced rents without government support, local jurisdictions should consider establishing density

39 bonuses to allow for higher levels of units per site for multifamily developments and single-family developments that propose increased affordability. 2. TDHCA and HUD have developed programs that preserve affordable housing. Continuing in this vein, the state and local jurisdictions should work to preserve existing affordable housing development and discourage them from converting to market rate housing. Requirements should be included in all publicly funded developments providing tenants with early and clear notification of the intention of management to convert to market rate housing and providing first right of refusal to nonprofit and public entities and organizations to purchase units to maintain affordability. 3. The state and local jurisdictions should consider using CDBG funds to buy down the cost of land in high-cost and high-opportunity development areas to increase affordable housing options in these areas. Impediment #12 Lack of financial resources for both individuals and housing providers limits Fair Housing choice. Using an effective program under Section 3 of the Housing and Urban Development Act of 1968 may help members of protected classes gain economic opportunities necessary to allow them to exercise fair housing choice. 1. The state is maximizing its resources in Round 2 of the Ike/Dolly funding to affirmatively further fair housing in single family and multi-family developments. As called for in the Conciliation Agreement, the state is looking to provide more integrated housing options for persons in racially concentrated or poverty concentrated neighborhood groups. In single-family programs, the state should require subrecipients to offer the opportunity to relocate out of floodplain areas, concentrations of racial minorities, or concentrations of poverty through the Homeowner Opportunity Program. Any relocation should be into an area that does not result in simply relocating the high-concentration from one area to another. Local jurisdictions will be responsible for complying with Section 3 as part of their contract with the state. 2. Jurisdictions receiving federal funds from HUD, directly or indirectly, should ensure they have a compliant Section 3 program to meet HUD requirements regarding notification to LMI eligible persons of potential job creation at the impacted neighborhood level with federal funds. We have in place a Section 3 program that meets the requirements of federal law and regulations regarding potential job creation at the impacted neighborhood level and the use of federal funds to hire local LMI eligible persons. We confirm that appropriate staff persons in this jurisdiction have already received training on Section 3, regarding job creation for local LMI persons including members of protected classes. [Attach Section 3 plan and list of staff names and training dates]

40 We have not done so but will develop a Section 3 program that meets the requirements of federal law and regulations and that ensure appropriate staff receive training. When will you do this? 2011 Impediment #13 Location and lack of housing accessibility and visitability standards within political jurisdictions limits fair housing choice for persons with disabilities. 1. Local jurisdictions should consider establishing incentives for affordable housing applicants to create an increased set-aside of housing units for persons with disabilities or persons who are elderly without violating the existing TDHCA integrated housing rule. 2. TDHCA and local jurisdictions should consider adding proximity to medical facilities as a scoring incentive for competitive programs using federal funds for proximity to medical facilities. 3. TDHCA should require that all federally funded housing construction be built to accessibility standards found in Texas Government Code We have formally considered: 1) establishing incentives for affordable housing developers to create an increased set-aside of housing units for persons with disabilities or persons who are elderly without violating the existing TDHCA Integrated Housing Rule; 2) providing point incentives for units in proximity to medical facilities for competitive programs using federal funds; and 3)requiring new housing built with federal funds to be built with structures that allow for accessible features, regardless of whether the original occupant needs the features, as called for by state law. [Attach documentation of the review and resulting actions.] We have not undertaken the above review, but plan to do so. When will you do this? Not Applicable (Explain) Impediment #14 Many colonias residents live in developments that have insufficient infrastructure and protections against flooding and are impacted by flooding beyond events like Hurricanes Dolly and Ike. 1. The state, COGs, and local jurisdictions should examine the infrastructure needs in colonias, in particular the use of CDBG disaster recovery funds to provide drainage improvements to correct flooding problems in the wake of Hurricane Dolly, and the historical provision of public infrastructure and housing assistance to meet those needs in border and non-border colonias. We have identified the unserved infrastructure needs of colonias within our jurisdiction and whether these infrastructure improvements are eligible for disaster recovery funding and, if so, whether those projects will be funded.

41 We have not undertaken the above review, but plan to do so. When will you do this? 2011 Not Applicable (Explain) No Colonias in Harris County Impediment #15 Minority neighborhoods in disaster areas are primarily served by nonregulated insurance companies that do not adhere to underwriting guidelines and may be discriminated against in the provision of insurance. Texas has passed aggressive statues to prevent insurance redlining. National research indicates that protected classes face unwarranted disparities in the cost of insurance, the amount of coverage, and cancellation of policies without notice to the homeowner. No local action is required at this time. Impediment #16 Many jurisdictions do not have adequate Analysis of Impediments to Fair Housing or Fair Housing Plans, and do not keep sufficient records of their activities. 1. Recipients of CDBG funds from HUD for housing should maintain records as required by the Fair Housing Act, HUD regulations, and the Conciliation Agreement in order to document that they are carrying out their commitments and affirmatively furthering fair housing. We currently maintain all required records to document our AFFH actions and compliance with Fair Housing laws, HUD and State regulations, and the Conciliation Agreement. [Attach details of the records now kept and identify the person or entity responsible for keeping these records.] We have not done so but do so in compliance with GLO guidance. When will you do this? Not Applicable (Explain) 2. As required under the Conciliation Agreement, the State will conduct a new Statewide AI after HUD approval of the Phase 1 AI. Entitlement communities should conduct new AIs or update current AIs to ensure that they address all recommended data and issues and specifically address issues related to all protected classes under the Fair Housing Act. Race and national origin, as well as the other protected classes, must be identified independent of low and moderate-income categories in order to understand the impact of actions, practices, regulations, ordinances, and other factors on them. We recently completed a formal Analysis of Impediments, are currently updating an existing AI, or are conducting our first AI. [Attach most recent AI or draft.] We are using the FHAST form process to analyze our impediments to fair housing and plan how to address them.

42 When will you do this? 2011 Not Applicable (Explain) Alternative or additional Local Action Steps developed by this jurisdiction: To address unique impediments to fair housing within each community, local jurisdictions are encouraged to develop alternative action steps to be adopted in lieu of or in addition to those set out in the State of Texas Interim Analysis of Impediments to fair housing. If your jurisdiction elects to propose alternative or additional action steps, please describe them below. We plan to take additional Action Steps, described in an Attachment. We will not take additional FH Action Steps at this time. When will you do this? Not Applicable (Explain)

43 Fair Housing Activity Statement Texas Jurisdiction: Harris County Attachments The following are additional elements and activities requested in the Fair Housing Activity Statement Texas (FHAST). They are organized by FHAST form Impediment number and question. Impediment #3 2. Attach a description of AFFH activities and identify the organizations and agencies you have worked. Currently, Harris County conducts several Fair Housing activities during the year. The Housing Resource Center is a service provided by the county through Community Service Department that provides information on affordable housing and community resources to the public. One of the many services provided is education materials on Fair Housing at one to three community events a month throughout the county and a compliant/referral helpline and website. These activities will continue in The County s Downpayment Assistance Program (DAP) provides homeownership assistance grants to qualified homebuyers. DAP also educates mortgage lenders who wish to work with the program on Federal laws, such as Fair Housing, and the program requirements. Organizations that we have worked with include: Harris County Housing Authority, Neighborhood Centers Inc., United Way of Greater Houston, County Precincts Community centers and social service programs, local small cities, Harris County Transit Services, Elderly Service Provider Network, Houston Apartment Association, Houston Area Realtor Association, and Coalition for the Homeless of Houston Harris County. Impediment #4 2. Who will develop the anti NIMBYism action plan? The anti NIMBYism action plan will be incorporated into the Harris County Analysis of Impediments and Fair Housing plan, which is due to HUD with the County s Consolidated Plan in Responsible entity is the Harris County Community Services Department. Impediment #5 1. Harris County selected that We have a long term infrastructure plan and will review the plan to determine if it promotes racial concentrations or otherwise inadvertently results in disparate treatment of members of protected classes as it relates to the availability of housing. Due to the length of the County s Capital Improvement Plans, the county will need additional time to review the plans and report findings. We estimate completion by 2013 when the County completes it Analysis of Impediments for submission to U.S. HUD.

44 7. If a jurisdiction is a non entitlement community, when working in LMI areas to replace roads or other infrastructure, the jurisdiction should consider making application for additional sources of funding to provide assistance to repair substandard housing associated with the project (i.e., TDHCA or HUD.) Not Applicable as Harris County is an Entitlement community with HUD. The county is a recipient of CDBG and HOME funds which it has used to provide activities such repairs to substandard single family and multi family housing, homeownership activities, infill housing construction, lead based paint control in single family homes, and the construction of new multi family units for the homeless and low income families throughout the county including LMI areas. 11. If applicable, all policies should be reviewed regarding denying applicants access to disaster recovery CDBG funds if their residence is located in the flood plain. After reviewing the county s housing policies governing access to disaster recovery CDBG funds, Harris County s disaster recovery single family housing rehabilitation/reconstruction nor the rental housing programs restrict participation due to residence s location in the 100 or 500 years floodplains. Harris County has State approved housing policies and procedures that allow for the provision of disaster recovery TX CDBG funds to be allocated to eligible applicants whose housing units are located in the floodplain. The single family housing rehabilitation and reconstruction program in Harris County s Round 1 contract has served many homeowners in the 100 and 500 years floodplains with most of these, in addition to the repair of their homes, receiving elevation services to lift their homes 24 inches above base flood elevation. The Harris County Buyout program seeks eligible repetitively flooded homes, often in the floodway or floodplain, for acquisition to assist homeowners to move to areas outside the 100 years floodplain. 12. When an entire community is in a flood plain, the community should establish clear standards that allow for proper elevation or relocation, and that also allows for visitability/special needs considerations consistent with state and federal law. Harris County has established standards for elevation in its CDBG disaster recovery housing program as 2 feet above base flood elevation as stated in the county s Hurricane Ike Recovery Program General Construction Matters document in Part II item 13 (pg II 3) and also directs the addition of visitability/special needs elements to reconstructed single family units as required by Federal and State law. Excerpt of Housing Standards on this topic is attached. These standards were approved by the State during Round One. Impediment #6 1. Fair Housing enforcement and testing program. Harris County does not currently have official testing. The Housing Resource Center does take complaints for families seeking housing who believe they have been discriminated against. County staff seek to resolve the issue between the parties, however, if no resolution can be found cases are documented and referred to HUD Fair Housing. The County is also planning to establish a partnership with the numerous non profit organizations who are testing to share data. This will be apart of the county s Fair Housing Plan and Analysis of Impediments due to HUD in 2013.

45 4. Each community should place on its website (if one is available) the contact, at the local, state, and federal levels, for reporting a Fair Housing complaint, if citizens believe they were victims of housing discrimination. Harris County provides this information at

46 Impediment #7 2. To help limit concentrations that could be considered impediments to affirmatively furthering fair housing, jurisdictions that have long term planning documents for housing growth or redevelopment, or revitalization plans, should consider allowing or encouraging mixed income affordable housing in the plan and provide incentives for development of this type of housing in areas that are not concentrated. List of Housing Related Plans Reviewed for Mixed Income Housing Goals: Harris County Consolidated Plan This plan discusses the county s goals and objective over a five year period toward improving the quality of life in the low and moderate income areas of Harris County. The plan offers some encouragement to developers toward mixed income affordable housing via general housing goals and objectives, but does not offer specific programs or incentives for development. Harris County Affordable Housing Standards The purpose of this document is to describe the Harris County Community Services Department s housing policy objectives, the range of activities available to advance these objectives, and the manner in which those activities will be designed, evaluated, and selected for funding. The overall goal to these guidelines and standards is to ensure the development of quality affordable housing and achieve compliance with applicable Federal, State, and local laws, regulations, and policy objectives. These standards encourage the creation of quality mixed income multi unit developments in non concentrated areas of the county via the HCCSD s annual request for proposals process. Impediment #12 2. Jurisdictions should have a compliant Section 3 program to meet HUD requirements. Attach Section 3 plan and list of staff names and training dates. Section 3 Employment and Minority Business Plan is attached as Appendix A to this document. The following are dates and staff attending Section 3 training: May 5, 2010 HUD Section 3 Training Elizabeth Winfrey Judit Haracsek October 27, 2010 TDHCA CDBG Disaster Recovery Section 3 Training Dwight Wolf Gregory Frazier Michelle Leija

47 Impediment #14 1. The state, COGs, and local jurisdictions should examine the infrastructure needs in colonias, in particular the use of CDBG disaster recovery funds to provide drainage improvements to correct flooding problems in the wake of Hurricane Dolly, and the historical provision of public infrastructure and housing assistance to meet those needs in border and non border colonias. Harris County has no Colonias. Harris County has done extensive research of infrastructure needs in its HUD target areas. Findings were documented in the Harris County Consolidated Plan, neighborhood plans developed by Community Services Department and the Precinct Two Infrastructure Assessment submitted to HUD in Impediment #16 1. Recipients of CDBG funds from HUD for housing should maintain records as required by the Fair Housing Act, HUD regulations, and the Conciliation Agreement in order to document that they are carrying out their commitments and affirmatively furthering fair housing. Harris County CSD maintains a report of AFFH actions in its annual CAPER to HUD. It describes AFFH goals to be achieved and actions taken. CSD through its Housing Resource Center (HRC) maintains records of residents seeking housing assistance (including discrimination complaints) via the HRC website and phone helpline. 2. We recently completed a formal Analysis of Impediments, are currently updating an existing AI, or are conducting our first AI. [Attach most recent AI or draft.] Harris County has an existing Fair Housing Plan and AI, but is also in the process of creating a new plan and AI for submission with its next Consolidated Plan in January Existing plan is attached as Appendix B.

48 Harris County Needs Assessment Harris County is the most populated county in the H-GAC region and is located near the geographic center. Several small communities are located along the waterfront of Galveston Bay. Harris County experienced wind, rain, flooding, and storm surge during Hurricane Ike. Harris County has areas that are highly urbanized, suburban, coastal and rural. The Harris County analysis includes unincorporated Harris County and all cities therein, with the exception of the City of Houston which has a separate disaster recovery housing program. FEMA Housing Damage Data FEMA housing damage data indicates Hurricane Ike damaged 30,804 homes in Harris County (not including the 84,382 damaged within the city of Houston); with 89% of the homes receiving minor damage. The majority of damage occurred in 5 cities - Baytown, Humble, La Porte, Pasadena, and Seabrook and the unincorporated area of Spring. See Map 1-4 for distribution of FEMA Claims by income of household. Summary of Round 1 Disaster Recovery Housing Program Harris County self administers its $56.2 million Round 1 disaster recovery housing program which will serve approximately 500 households, 55 households more than the contact requirement. During Round 1 the county placed an emphasis on single-family owner occupied housing recovery. In Round 2.2, the county should focus on the replacement of rental units especial those that replace or house displaced populations. Based on data provided by the Harris County Recovers Homeowner Assistance Program, Harris County has received 1,924 applications from across the county, see Map 5-7 and currently has 592 active applications: 1-Barrett, 103-Baytown, 2-Bellaire, 10-Channelview, 39-Crosby, 7-Cypress, 9-Deer Park, 1- El Lago, 8-Friendswood, 8-Galena Park, 9-Highlands, 1-Hockley, 158-Houston (unincorporated), 1- Huffman, 17-Humble, 2-Jacinto City, 22-Katy, 1-Kingwood, 46-La Porte, 2-Nassau Bay, 49-Pasadena, 1- Pearland, 40Seabrook,19-Shoreacres, 12-South Houston, 21-Spring, and 3-Tomball. The program has GLO approval for 296 households as of Nov. 30, 2011 in the setup system. The County has 254 units in construction phase with 52 of those completed. Of the funds awarded to households, 77% are low-to moderate-income households. Concentrations of Poverty and Minority Concentration The Harris County analysis includes unincorporated Harris County and all cities therein, with the exception of the City of Houston. Harris County has 81 areas of ethnicity and minority concentration 5 Black African American and 76 Hispanic. The areas are located in 7 cities and parts of the unincorporated county. Baytown 16 areas (Hispanic) Galena Park 6 areas (Hispanic)

49 Jacinto City 4 areas (Hispanic) Pasadena 32 areas (Hispanic) La Porte 1 area (Black African American) Missouri City 2 areas (Black African American) Unincorporated County (Aldine CDP) 2 areas (Hispanic) Unincorporated County (Cloverleaf CDP) 6 areas (Hispanic) Unincorporated County (Barrett CDP) 2 areas (Black African American) Harris County has 16 areas of concentrated poverty, located in 5 cities and unincorporated areas of the county. Baytown 3 areas of concentrated poverty Humble 1 area of concentrated poverty League City - 1 area of concentrated poverty Pasadena - 7 areas of concentrated poverty South Houston - 2 areas of concentrated poverty Unincorporated County (Cloverleaf CDP) 2 areas of concentrated poverty Round 2.2 Housing Focus Based on the successful focus in Round 1 on single family owner occupied rehabilitation and reconstruction, Harris County agrees with the H-GAC assessment that the focus of Round 2.2 funding should be toward rental housing activities. Approximately, 40 percent of the County s housing units are rental units (2010 ACS). Data for Harris County s most impacted areas indicate percent of households with $9,000 or less in annual income rent rather than own a home. Although FEMA damage data for rental properties is not readily available for this study, the relative share of renters in the very low income category, combined with the emphasis of the program on low-moderate income households indicates there is likely an unmet need for assistance to rental properties, particularly in high opportunity areas. The homeless populations have also been overlooked in the Ike recovery. During Hurricane Ike, 13,000 homeless persons (including families) experienced displacement from homeless shelters, that lost power, to the streets. During a survey of homeless individuals by the Coalition for the Homeless of Houston-Harris County in 2010, 3.7 percent of homeless reported that their status was due to Hurricane Ike. Many homeless agencies, such as The Men s Center, not only lost power but also sustained damage to supportive housing units and facilities. During Hurricane Ike, The Men s Center was able to house 182 individuals, but turned away over 200 more homeless individuals in the days after the storm. In Round 2.2, Harris County will consider projects that provide an increase to the supply of permanent supportive housing and services to the homeless. Housing options considered in Round 2.2 will also help replace inadequate housing. Harris County, in partnership with the Flood Control District, has identified several multifamily and single family properties plagued by persistent flooding, including during Hurricane Ike, for buyout and demolition. If these projects are selected, properties acquired will become part of the flood control system and will be used to mitigate future flooding. In the case of single family owner occupied properties, qualified homeowners may be eligible for relocation assistance.

50 GEOGRAPHIC DATA FEMA CLAIMS HOUSEHOLD INCOME CATEGORY DATA COG COUNTYNAME TRACT BLKGRP femahhvlow femahhvlowpct femahhlow femahhlowpct femahhmod femahhmodpct femahhnlm femahhnlmpct H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

51 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

52 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

53 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

54 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

55 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

56 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

57 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

58 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

59 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

60 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

61 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

62 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

63 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

64 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

65 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

66 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

67 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

68 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

69 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

70 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

71 H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County H-GAC Harris County

72 Map 1: Harris County FEMA Claims by Household Income - Very Low Income (30%) µ Harris County Houston City Limit FEMA Claims by Household - Very Low Income Miles

73 Map 2: Harris County FEMA Claims by Household Income - Low Income (50%) µ Harris County Houston City Limit FEMA Claims by Household - Low Income Miles

74 Map 3: Harris County FEMA Claims by Household Income - Moderate Income (80%) µ Harris County Houston City Limit FEMA Claims by Household - Moderate Income Miles

75 Map 4: Harris County FEMA Claims by Household Income - Non Low to Moderate Income µ Harris County Houston City Limit FEMA Claims by Household - Non Low-Mod Income Miles

76 CITY OF HOUSTON CITY OF PASADENA CITY OF BAYTOWN CITY OF LA PORTE CITY OF TOMBALL CITY OF HUMBLE CITY OF DEER PARK CITY OF KATY CITY OF WEBSTER CITY OF SEABROOK CITY OF GALENA PARK CITY OF BELLAIRE CITY OF FRIENDSWOOD CITY OF PEARLAND CITY OF JERSEY VILLAGE CITY OF SOUTH HOUSTON CITY OF PEARLAND PINEY POINT VILLAGE CITY OF LEAGUE CITY CITY OF JACINTO CITY WEST UNIVERSITY PLACE CITY OF MORGANS POINT CITY OF NASSAU BAY CITY OF TAYLOR VILLAGE CITY OF MISSOURI CITY CITY OF HUNTERS CREEK VILLAGE CITY OF SPRING VALLEY CITY OF WALLER CITY OF BUNKER HILL VILLAGE CITY OF SHOREACRES CITY OF HILSHIRE VILLAGE CITY OF STAFFORD Legend HDRP Applicants (n = 1,765) City Name CITY OF BAYTOWN CITY OF BELLAIRE CITY OF BUNKER HILL VILLAGE CITY OF DEER PARK CITY OF EL LAGO CITY OF GALENA PARK CITY OF HEDWIG VILLAGE CITY OF HILSHIRE VILLAGE CITY OF HOUSTON CITY OF HUMBLE CITY OF HUNTERS CREEK VILLAGE CITY OF JACINTO CITY CITY OF JERSEY VILLAGE CITY OF KATY CITY OF LA PORTE CITY OF MISSOURI CITY CITY OF MORGANS POINT CITY OF NASSAU BAY CITY OF PASADENA CITY OF PEARLAND CITY OF SEABROOK CITY OF SHOREACRES CITY OF SOUTH HOUSTON CITY OF SOUTHSIDE PL CITY OF SPRING VALLEY CITY OF STAFFORD CITY OF TAYLOR VILLAGE CITY OF TOMBALL CITY OF WALLER CITY OF WEBSTER PINEY POINT VILLAGE WEST UNIVERSITY PLACE HDRP Applicants Map Miles µ

77 Legend HDRP Eligible Active (n=655) Harris County Tract ACS 5-Yr Percent Poverty 0% - 8% 8.01% - 16% 16.1% - 25% 25.1% - 40% 40.1% % HDRP Eligible Active Applicants and Poverty Map Miles µ U.S. Average Rate 2011

78 Legend HDRP Eligible Active (u = 655) Minority No (n=255) 39% Yes (n=400) 61% Harris County Tract Percent Minority (ACS 5 Yr) 0% - 65% 65.1% - 100% HDRP Eligible Active Applicants and Minority Concentration Map Miles µ

79 Harris County Audit Due to the large size of this document, below is the link to the Harris County audit

80 Community Services Department David Turkel Director Office of Finance Services Craig Atkins Deputy Director / CFO Office of Administrative Services Jessica Deculus Deputy Director A/P Grant Accounting Financial Accounting Financial Monitoring Payroll Administration Information Technology Office of Housing & Community Development Office of Social Services Office of Economic Development Office Transit Services Daphne Lemelle Deputy Director Ellen Seaton Deputy Director Nancy Powell Deputy Director Ken Fickes Deputy Director Development Direct Services Grants Management Planning Aid & Assistance Bereavement Veterans Services Tax Abatement Zoning Transportation

81 Ike Housing Applications received by 11/18/2011 µ ( The Bridges Apartments ( Sierra Estate Meadows ( Forrester Lord Glen ( Enclave at Copperfield Apt's ( Tidwell Lakes Ranch ( SGV Investment Homes TMC Recovery - Project IKE, New Construction TMC Recovery - Project IKE ( ( Knowles-Temenos Place Apartments II ( Magnolia Glen ( Jarmese Apartments ( Housing Applications Harris County - GLO Demographic Data La Maison Apartments Low/Mod Percentage Less than 51% Low/Mod 51% or Greater Low/Mod CITY OF HOUSTON Miles Enclave at Quail Crossing Phase II Enclave at Quail Crossing Phase I ( (

82 GENERAL HOUSING ACTIVITIES APPLICATION: ROUND 2.2 Tab III: Excel Project Budget Form Region: Applicant: Required Estimated Slum & Budget Breakout by LMI Population Budget Breakout by Slum & Blight Budget Total Estimated Low/Mod Households Served Blight HH (if applicable) Required Required Required Subtotal Subtotal Total Required Required Required Subtotal Optional Activity Type Very Low HH (<30%) Low HH (31%-50%) Moderate HH (51%-80%) Budget for Combined HH Budget for Slum & Blight (if applicable) Very Low HH (<30%) Low HH (31%-50%) Moderate HH (51%-80%) Number of Combined LMI HH Served Number of Slum & Blight HH Project/ Construction* $0.00 $0.00 $ R LMI - Single $ 9,380, $9,380, $0.00 $9,380, R LMI- Multi $ 1,441, $ 7,779, $ 5,073, $14,293, $0.00 $14,293, DEMO - SB $1,853, $0.00 $1,853, HBA - LMI $100, $0.00 $100, BUYOUT $8,981, $0.00 $8,981, $0.00 $0.00 $ $0.00 $0.00 $ $0.00 $0.00 $ Acquisition $8,075, $0.00 $8,075, Engineering $0.00 $0.00 $ Project Delivery 1 $4,850, $0.00 $4,850, Administration 2 $970, $0.00 $970, TOTAL: $1,441, $7,779, $14,453, $48,503, $0.00 $48,503, $0.00 "HH" equals Households. *Eligible activities should be identified using the Project Overview Categories selected on Tab II of the application. Select from the drop-down list in Column A of this Excel sheet. 1 Project Delivery is capped at 10% of the grant amount. 2 Administration is capped at 2% of the grant amount.