HUNTSVILLE HOUSING AUTHORITY

HUNTSVILLE HOUSING AUTHORITY PUBLIC NOTICE APRIL 7, 2016 In accordance with HUD requirements, the Huntsville Housing Authority had developed an Allocation Plan (or Designated Housing Plan) that seeks to designate the public housing units in the Todd Towers (The Todd) development (100 units total) as elderlyonly units. This action will result in The Todd being available only to person that are 62 or older. All Huntsville Housing Authority residents, any advocacy groups for elderly and/or disabled persons, and any interested citizens are invited to review this Designated Housing Plan Monday through Friday, between 9:00 AM and 4:00 PM, local time, at the following locations until May 9, 2016: Huntsville Housing Authority 200 Washington Street Huntsville, Alabama 35801 The Todd 204 Greene Street Huntsville, Alabama 35801 The plan can also be viewed online at the Huntsville Housing Authority website, www.hsvhousing.org. The plan will be submitted to the Huntsville Housing Authority Board of Commissioners for approval in May 2016, before subsequent submission to the U. S. Department of Housing and Urban Development. Any written comments may be directed to Danielle Thomas, Director of Housing Operations: HAND - DELIVERY Danielle Thomas Huntsville Housing Authority 200 Washington Street Huntsville, Alabama 35801 USPS Mail Danielle Thomas Huntsville Housing Authority P.O. Box 486 Huntsville, Alabama 35804-0486

Designated Housing Plan For the Huntsville Housing Authority April 7, 2016 Prepared By: Huntsville Housing Authority 200 Washington Street P.O. Box 486 Huntsville, AL 35804 Submitted To: U.S. Department of Housing and Urban Development Office of Public and Indian Housing Public Housing Management and Occupancy Division Room 4222 451 Seventh Street, S.W. Washington, D.C., 20410-5000 Approved by Huntsville Housing Authority Board of Commissioners, 2016 1

I. Introduction The Huntsville Housing Authority ( HHA ) is submitting a Designated Housing Plan ( Plan ) to the U.S. Department of Housing and Urban Development ( HUD ) to designate 100 public housing units to elderly only status. This Plan will establish the percentage of elderly to non-elderly disabled residents at AL047000011 Todd Towers (The Todd). After approval of the Plan, non-elderly disabled public housing applicants will be directed to other elderly/disabled or family units located at Johnson Towers or other units located throughout HHA sites. When there are insufficient elderly families on the waiting list who wish to reside in a designated elderly development, near elderly applicants (those who are 55-61 years of age) will receive preference over other families for designated elderly units. The average number of vacancies at The Todd per month is two (2). Therefore, the probability that the elderly and near elderly waiting list will be exhausted, is extremely remote. At the current rate of attrition, it will take approximately two and one-half years to transition the Todd to a 100% elderly site. HHA currently maintains a site-based waiting list system in addition to its community-wide waiting list. There are separate waiting lists for Johnson Towers and The Todd that are both designated as elderly/disabled sites, and the incentive sites that require families to be employed 30 hours a week for more than one year in order to be eligible. Incentive Sites and Elderly/Disabled Designated Sites Site Number Site Name Number of Units 047-00008 Johnson Towers 120 047-000011 The Todd 100 047-000018 Mahogany Row 12 047-000016 Scattered Sites 26 047-000019 Stone Manor 49 047-000020 Wind Trace/Cotton Row 24 047-000021 Cotton Row II 8 047-000022 Cotton Row III 8 047-000023 Stepping Stone/Stones Throw 6 047-000024 9010 Mahogany Row 4 Source: Huntsville Housing Authority 2016 The decision to submit this Plan is based primarily on two broad factors, which are supported in greater detail throughout the Plan: 1. Serving the growing need for affordable, age-appropriate housing among Huntsville s lowincome elderly population; and, 2. Balancing the needs of the elderly, who have seen a decrease in available affordable units, with the non-elderly disabled, who have seen an increase in available units due to a variety of programs and preferences. Based on an analysis of the waiting list and the data presented in the City of Huntsville s 2015-2020 Consolidated Plan, the HHA proposes to convert The Todd to an elderly only site. The Plan will be subject to a public notice process with notice to the HHA Resident Advisory Board as well as a public hearing. 2

II. Background and Supporting Information A. Justification for Designation In 2013, there were 44.7 million people who were 65 years or older in the U.S. This number represented 14.1% of the population, or about one in every seven Americans. By 2060, there will be approximately 98 million older persons, or more than twice the number as in 2013. People 65 years of age or older represented 14.1% of the population in the year 2013 but are expected to grow to 21.7% of the population by 2040. The over 85 years of age population is projected to triple from 6 million in 2013 to 14.6 million in 2040. Source: U.S. Department of Health and Human Services Administration for community living. www.aoa.acl.gov The latest U. S. Census data for Huntsville showed that there were 66,709 households in 2010. Of those 25,553 were 62 and over and 8,740 were fifty-five to fifty-nine years old. Historical Background Demographic Population Of Homes With People 62 Year Old And Over in 8.740Huntsville Households In Huntsville Containing People Over 62 Total Households: 66,709 62 years and over 25,553 55 to 59 years 8,740 Households with individuals 65 years and older 20,142 Source: U.S. Census Bureau. Census 2000 Summary File 4 On January 5, 2005, the Department of Housing and Urban Development (HUD), Office of Public and Indian Housing (PIH) published Notice PIH 2005-2. This Notice reiterated the streamlined requirements for designating public housing projects for occupancy by elderly families only, disabled families only, or elderly and disabled families only. This Notice also included the requirements and procedures for renewal of, or changes to, previously HUD approved designation plans and describes threshold requirements that must be met by public housing authorities submitting designated housing plans (DHP) the Assistant Secretary for Public and Indian Housing (PIH) signed a Re-delegation of Authority effective January 7, 2005, assigning responsibility for reviewing requests for plan renewals to the respective local HUD Public Housing Field Offices. New plans will be reviewed by PIH Public Housing Management and Occupancy Division, with input from the local HUD Public Housing Field Offices. The Notice requires PHAs to justify that the proposed designation is necessary to achieve the housing goals for the jurisdiction under the Comprehensive Housing Affordability Strategy (CHAS). Since this is no longer referred to as such in most official documents, but rather as the "Consolidated Plan", it would be permissible to refer to the Consolidated Plan as a valid source of information for justifying a proposed designation. According to the statutory requirement contained in Section 7 of the U.S. Housing Act of 1937, HUD has sixty (60) days to complete its review and communicate its decision (approval/disapproval) to the PHA submitting the plan/request. Once approved, new plans remain in effect for five (5) years from the date of initial approval and, at the PHA's request, may be renewed for additional two (2) year increments. 3

The Housing for Older Persons Act of 1995 (Pub. L. 104 76, 109 Stat. 787, approved December 28, 1995) (HOPA) revised the definition of the original exemption contained in the Act for housing designed and operated for occupancy by persons who are 55 years of age of older. Relevant Selections from the City of Huntsville s Consolidated Plan 2015-2020 Based on information available to the City of Huntsville, Alabama, the Consolidated Plan for 2015-2020 describes the significant characteristics of Huntsville s housing market, including the supply, demand, condition and cost of housing and the housing stock available to serve lowincome, elderly, and persons with disabilities and their families. In general, the market analysis determined that the housing needs for the City of Huntsville are as follows: additional affordable housing units for small families and the elderly additional affordable owner occupied units increased quality and improved condition of existing rental units The Consolidated Plan also provides a summary of the objectives and outcomes identified as: Needs Assessment Overview: The five categorical needs areas that guided the assessment process were: Decent, Affordable housing needs Suitable living environment concerns Public facilities needs Public service activities Encouraging economic development Actions that address the availability and affordability of decent housing for low to moderate income residents emerged as a priority in each of the processes employed to assess the needs in the community. There was consistent concern regarding the quality and livability of low to moderate income neighborhoods. The need to support service programs particularly those for people with special needs such as the elderly and physically challenged. In addition, social service needs of tutoring, mentoring, after school programs for children, youth from low to moderate income families were highly ranked; as were support services for moving families to self sufficiency. More renter-occupied units had one or more of the four housing problems (7,533) in comparison to owner-occupied units (3,510). The majority of both of these households were in the very low median family income category (74% of renter units and 51% of owner occupied units). More elderly owner-occupied housing units were both cost burdened and severely cost-burdened than renter-occupied units. Single family renter households were more overcrowded than single family owner-occupied units. In general, the market analysis determined that the housing needs for the City of Huntsville were as follows: additional affordable housing unit for small families and the elderly additional affordable owner-occupied units increased quality and improved conditions of existing rental units Source: City of Huntsville, AL Consolidated Plan for 2016-2015 and the 2007 2011 CHAS 4

The Plan meets the needs of the low-income population of Huntsville by providing adequately for both the elderly and non-elderly disabled based on population trends, emerging demand, and available resources. This Plan is consistent with the City s Consolidated Plan and U. S. Census data publications. HHA is committed to providing the opportunity for affordable housing to both the elderly and non-elderly disabled households at all of its developments throughout Huntsville and is therefore not proposing to create any additional elderly-only developments except The Todd in the near future. It is worth noting that HUD s definitions of elderly and disabled households in the context of designated housing does not allow for a complete picture of the actual households living in HHA elderly/disabled developments. Any head of household (HOH) age 62 or older is classified as elderly, per 31 24 CFR 5.403 which defines an elderly family as a family whose head (including co-head), spouse, or sole member is a person who is at least 62 years of age. A disabled family is defined as a family whose head (including co-head), spouse, or sole member is a person with a disability. Regardless of disability status, the number of disabled households is underrepresented because HHA does not track units devoted to disabled residents that do not require special accommodations.. A full consideration of how HHA is meeting the needs of the public housing community should take into account the following occupancy figures: 1) non-elderly disabled who have aged in place; 2) non-elderly who will soon age in place, and 3) elderly who are also disabled at the time of admission. Currently, there are 3,946 people residing in HHA public housing at 21 sites that include the two elderly/disabled designated towers and incentive sites. There are 2,072 adults of whom 14% or 298 are 62 years of age or older, 15% or 329 are near-elderly and 51. other adults children elderly near elderly Source: Huntsville Housing Authority 2016 In addition, there are 67 elderly applicants on the waiting list for The Todd and 53 elderly applicants on the Johnson Towers waiting list. Also, there are 75 applicants on the waiting list who are near-elderly or between the ages of fifty-five and sixty-one. The following chart shows an analysis of the current waiting list for elderly, near-elderly and disabled applicants. The waiting time for a unit at one of the elderly/disabled towers is approximately 9 months to one year. 5

Elderly and Near Elderly Waiting List 250 200 150 100 50 0 Eldery & Elderly Only Near Elderly Elderly & Disabled Disabled Near Elderly Only HOH Source: Huntsville Housing Authority 2016 According to Housing America's Older Adults Meeting the Needs of an Aging Population, with the oldest baby boomers now past age 65, growth of the older population, in terms of both number and share, is well on its way. However, the largest impacts of this demographic shift are still a decade or more off as millions more households reach the ages when physical, financial, and social challenges increase sharply. Today, just over 34 percent of the US population is aged 50 and over, and their numbers are rising rapidly with the aging of the baby-boom generation. The oldest baby boomers hit age 50 in the mid-1990s, nearly doubling the number of people in the preretirement age group of 50 64 from 32.5 million in 1990 to 58.8 million in 2010. With the oldest boomers now crossing the 65 year-old threshold, population growth among 65 74 year olds is set to soar. There is still time to prepare for the evolving needs of older adults by expanding the supply of housing that is affordable, safe, and accessible. These changes will improve not only quality of life for older adults, but also the livability of communities for people of all ages. Source: Housing America's Older Adults-Meeting the Needs of an Aging Population www.jchs.harvard.edu B. Project Description Downtown Huntsville's Todd Towers (renamed The Todd) was originally completed in 1970. The sixstory high-rise building contains 100 units that have been designated for the elderly and disabled for many years. In 2015, HHA used $1.75 million in Capital Funds to complete exterior improvements that alleviated leaks and installed energy-efficient windows. New wall-mounted air conditioners were also installed in each unit. The Todd Senior Housing Project (Plan) will provide an opportunity to offer much needed affordable elderly housing units in Huntsville. It will fill a need identified in the City's Five-Year Plan. There are 100 efficiency and one-bedroom units in the building. All will be occupied by elderly on a fixed or limited income as they are vacated through attrition. The building is equipped with two elevators, exterior ramps for easy street access, automatic doors and other special features for the physically challenged. The entrance doors to each apartment have access to the exterior walkways and provide easy accessibility to the elevator tower. There is also a community room located on the first floor that has an ample meeting area and computers with internet access for use by the residents. A resident operated store is also available on the first floor that provides snacks, toiletries and other items. The Todd apartments have an occupancy rate of 100%. In addition to filling a gap in the City's identified affordable housing needs, these apartments are conveniently located in the downtown area with easy access to public transportation, medical services and shopping. 6

The following table details the development and the numbers of units to be designated. This Plan designates 100% of the units for occupancy by elderly households. Development Number Development Name Program Type Available Units Elderly Designated Percentage Non- Elderly Disabled 0 Bedroom 1 Bedroom 2 Bedrooms AL047000011 Todd Towers (The Todd) Low Income Rental 100 100% 0% 60 37 2 The HHA also provides residential outreach services to its elderly and disabled residents. Social service coordinators provide linkages to community resources that provide supportive and social services for the elderly and persons with disabilities residing in public housing. HHA provides this service to help residents continue to live in place, independently, without having to move to more expensive assisted care environments. C. Alternative Resources The list below shows affordable housing units that have handicapped accessible units and are also subsidized. HHA has no plans at this time to secure additional resources or housing assistance for The Todd site. Apartments At Russel Erskine 115 Clinton Ave. East Huntsville, AL 35801 Spring Branch Apartments 217 Binford Drive SW Huntsville, AL 35805 Garden Park Apartments 2301 Old Blue Spring Road NW Huntsville, AL 35810 The Lighthouse 1940 Max Luther Drive Huntsville, AL 35811 Brook Haven Apartments 135 Fairview Farm Way Huntsville, Al 35811 Castlewood Apartments 2400 First Street Huntsville, AL 35816 Dunwoody Place 5401 Millennium Drive Huntsville, AL 35806 Garden Cove apartments 3315 Dunn Street Huntsville, AL 35805 Lakeshore Crossing Apartments 6300 Rime Village Drive Huntsville, AL 35806 Mountain Ridge Apartments 449 Hobbs Road Huntsville, AL 35803 Stonehurst Apartments 2040 Blue Springs Road Huntsville, AL 35810 Olympia Gardens 3332 Meridian Street Huntsville, AL 35816 Castlewood Apartments 2400 First Street Huntsville, AL 35816 The Lighthouse Apartments 1940 Max Luther Drive Huntsville, AL 35811 Cherokee Bend Apartments 4177 Newson Road Huntsville, AL 35805 Westlake Apartments 1901 Sparkman Drive Huntsville, AL 35816 Source: lowincomehousing.us 7

D. No Eviction or Lease Termination Due to Designation The HHA will not evict or require mandatory transfers for any residents that currently reside at The Todd that do not meet the elderly resident criteria. As current residents leave the site of their own volition, new residents who meet the elderly criteria as established by HUD will be offered units. E. Voluntary Relocation Because of the Designation The HHA has no plans to relocate any of the current residents of The Todd in order to convert the building to a senior only site. HHA s Admissions and Occupancy Policy (ACOP) allows residents to transfer or the HHA to make necessary transfers. According to the HHA Admissions and Occupancy Policy, HHA will maintain a centralized transfer list to ensure that transfers are processed in the correct order and that procedures are uniform across all properties. F. Inapplicability of Uniform Relocation Assistance and Real Property Acquisition Policy Act of 1970. HHA tenants will not be considered to be displaced for purposes of the Uniform Relocation Assistance and Real Property Acquisition Policy Act of 1970 because of the designation of The Todd or any existing project or building, or portion thereof, of public housing. G. Eligibility of near-elderly The HHA plans to transition all units at The Todd to elderly occupied units. Current residents will not be asked to relocate. If there are not enough applicants on the waiting list, near elderly (applicants between the age of 55 and 61) will be offered units at The Todd. III. HUD DHP Review Checklist Items The following information is provided to answer questions in the HUD Review of Designated Housing Plans checklist not addressed elsewhere in this Plan. 1) The HHA does not have any outstanding court orders, Voluntary Compliance Agreements, or Section 504 Letters of Findings at this time. 2) Regarding fair housing, the proposed designation in this Plan will not increase minority concentrations as the elderly/non-elderly disabled population percentages apply at all of HHA s elderly/disabled developments. 3) HHA operates a separate site-based waiting list for the incentive sites of its public housing developments. 8

IX. Request for Approval The HHA requests that HUD approve this application for a new Designated Housing Plan as follows: Designation of Todd Towers (The Todd) as an Elderly Only Site. The designation will be phased in as vacancies occur at the site. No current resident will be asked to relocate from their unit. Near-elderly persons may occupy units at the site if there are insufficient elderly applicants at the time of a vacancy. X. Duration of Plan The Huntsville Housing Authority will assure that: i) At least 80 percent of the occupied units are occupied by at least one person who is 55 years of age or older; (ii) The housing facility or community publishes and adheres to policies and procedures that demonstrate the intent required under this subparagraph; and (iii) The housing facility or community complies with rules issued by the Secretary [of HUD] for verification of occupancy, which shall (I) Provide for verification by reliable surveys and affidavits; and (II) Include examples of the types of policies and procedures relevant to a determination of compliance with the requirement of clause (ii). Such surveys and affidavits shall be admissible in administrative and judicial proceedings for the purposes of such verification. The new requirements under HOPA are equivalent to the original provisions of the Fair Housing Act. Like the original section 807(b)(C) of the Act, HOPA requires that a facility or community seeking to claim the 55 and older exemption show three factors: (1) That the housing be intended and operated for persons 55 years of age or older; (2) that at least 80 percent of the occupied units be occupied by at least one person who is 55 years of age or older; and (3) the housing facility or community publish and adhere to policies and procedures that demonstrate its intent to qualify for the exemption. The housing facility or community must also comply with rules issued by HUD for the verification of occupancy. 9