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HC Resolution No. 18-05 Approving the FY 2017-18 CDBG Program Consolidated Annual Performance and Evaluation Report (CAPER)RESOLUTION NO. 18-05 A RESOLUTION OF THE HOUSING COMMISSION OF THE CITY OF CUPERTINO APPROVING THE FY 2017-18 CDBG PROGRAM CONSOLIDATED ANNUAL PERFORMANCE AND EVALUATION REPORT (CAPER) WHEREAS, the Housing and Community Development Act of 1974 provides that funds be made available for the Community Development Block Grant (CDBG) Program; and WHEREAS, the City of Cupertino is required to submit a FY 2017-18 CAPER (Exhibit 1) to the United States Department of Housing and Urban Development (HUD) for review and approval; now, therefore: WHEREAS, the City of Cupertino makes the certifications required by 24 CFR Sections 91.225 and 570 .303 as contained in the FY 2017-18 CDBG Annual Action Plan; now, therefore: BE IT FURTHER RESOLVED that the Housing Commission of the City of Cupertino hereby approves the FY 2017-18 CAPER; and BE IT FURTHER RESOLVED that the City Manager is hereby authorized to submit the FY 2017-18 CAPER approved by the Housing Commission of the City of Cupertino to HUD. PASS ED AND ADOPTED at a regular meeting of the Housing Commission of the City of Cupertino on this September day of 13, 2018 by the following vote: AYES: NOES: ABSENT : ABSTAIN: Members of the Housing Commission Vice Chair Zhao, Daruwalla, Kapil none Chair Bose, Goyal none ./ Erick Serrano Associate Planner APPROVED: J Z ao Vice Chair, Housing Commission Exhibit 1 City of Cupertino 2017 /18 Consolidated Annual Performance Evaluation Report CUPERTINO Prepared by the Department of Community Development 10300 Torre Avenue Cupertino, CA 95014 Approved by Housing Commission September 13, 2018 Resolution No. 18-05 CAPER Table of Contents CR-05 -Goals and Outcomes ................................................................................................... 5 Progress the jurisdiction has made in carrying out its strategic plan and its action plan. 91.520(a) ............................................................................................................................... 5 Comparison of the proposed versus actual outcomes for each outcome measure submitted with the consolidated plan 91.520(g) ................................................................................... 5 Assess how the jurisdiction 's use of funds addresses the priorities and specific objectives identified in the plan .............................................................................................................. 5 CR-10 -Racial and Ethnic composition of families assisted ................................................. 7 Describe the families assisted. 91.520(a) .............................................................................. 7 CR-15 -Resources and Investments 91.520(a) ....................................................................... 8 Identify the resources made available .................................. Error! Bookmark not defined. Identify the geographic distribution and location of investments ...... Error! Bookmark not defined. Leveraging ............................................................................................................................. 8 Explain how federal funds leveraged additional resources .................................................. 8 Other Federal Grant Programs .............................................................................................. 8 County of Santa Clara and Local Housing and Community Development Sources ............. 8 Below Market-Rate (BMR) Affordable Housing Fund (AHF) ............................................. 9 General Fund Human Service Grants (HSG) Program ......................................................... 9 CR-20 -Affordable Housing 91.520(b) .................................................................................. 10 Evaluation of the jurisdiction's progress in providing affordable housing .......................... 10 Discuss the difference between goals and outcomes .......................................................... 10 Discuss how these outcomes will impact future annual action plans ................................. 10 CR-25 -Homeless and Other Special Needs 91.220(d, e); 91.320(d, e); 91.520(c) ............. 12 Evaluate the jurisdiction's progress in meeting its specific objectives for reducing and ending homelessness ........................................................................................................... 12 Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs ................................................................................................................... 12 Addressing the emergency shelter and transitional housing needs of homeless persons .... 12 Helping low-income individuals and families avoid becoming homeless , especially extremely low-income individuals and families ................................................................. 12 Helping homeless persons ( especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living .................................................... 12 CR-30 -Public Housing 91.220(h); 91.320U) ........................................................................ 14 Actions taken to address the needs of public housing ......................................................... 14 Actions taken to encourage public housing residents to become more involved in management and participate in homeownership ................................................................. 14 Actions taken to provide assistance to troubled PHAs ....................................................... 14 CR-35 -Other Actions 91.220U)-(k); 91.320(i)-U) ................................................................ 15 Actions taken to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing 91.220 U); 91.320 (i) ........................................................... 15 Actions taken to address obstacles to meeting underserved needs. 9I.220(k); 91.3200) .. 15 Actions taken to reduce lead-based paint hazards. 91.220(k); 91.320U) ............................ 15 Actions taken to reduce the number of poverty-level families. 91.220(k); 91.3200) ......... 16 CAPER 2 Actions taken to develop institutional structure. 91.220(k); 91.320U) ............................... 16 Actions taken to enhance coordination between public and private housing and social service agencies. 91.220(k); 91.320G) ................................................ , ............................... 16 Identify actions taken to overcome the effects of any impediments identified in the jurisdictions analysis of impediments to fair housing choice. 91.520( a) ........................... 17 CR-40 -Monitoring 91.220 and 91.230 ................................................................................. 19 Describe the standards and procedures used to monitor activities ...................................... 19 Citizen Participation Plan 91.lOS(d); 91.1 lS(d) ................................................................. 19 Describe the efforts to provide citizens with reasonable notice and an opportunity to comment on performance reports ........................................................................................ 19 CR-45 -CDBG 91.520(c) ........................................................................................................ 20 Specify the nature of, and reasons for, any changes in the jurisdiction's program objectives and indications of how the jurisdiction would change its programs as a result of its experiences .......................................................................................................................... 20 Does this Jurisdiction have any open Brownfields Economic Development Initiative (BEDI) grants? .................................................................................................................... 20 [BEDI grantees] Describe accomplishments and program outcomes during the last year. 20 CAPER 3 List of Tables Table 1 -Accomplishments -Program Year & Strategic Plan to Date ....... Error! Bookmark not defined. Table 2 -Table of assistance to racial and ethnic populations by source of funds ................ Error! Bookmark not defined. Table 3 -Resources Made Available ............................................. Error! Bookmark not defined. Table 4 -Identify the geographic distribution and location of investments Error! Bookmark not defined. Table 5 -Number ofHouseholds ................................................... Error! Bookmark not defined. Table 6 -Number of Households Supported ................................. Error! Bookmark not defined. Table 7 -Number of Persons Served ............................................ Error! Bookmark not defined. CAPER 4 CR-05 -Goals and Outcomes Progress the jurisdiction has made in carrying out its strategic plan and its action plan. 91.520(a) Below is a description of the progress the City of Cupertino has made in achieving the goals outlined in its strategic plan and annual action. In fiscal year (FY) 2017/18, the City achieved its annual goals and is on track to meet the five (5) year goals outlined in the Consolidated Plan. It should be noted that in FY 2016/17 , the City decided to change the funding source of ECHO Housing, its fair housing non-profit service partner, to Below Market Rate Affordable Housing Funds (BMR AHF). Over the last two (2) years, the fair housing program has been funded with CDBG funds. While the change has resulted in no CDBG funds being utilized for fair housing services , the City continues to fund ECHO Housing to provide fair housing services . The agency has met or exceeded its annual goals. Comparison of the proposed versus actual outcomes for each outcome measure submitted with the consolidated plan and explain, if applicable, why progress was not made toward meeting goals and objectives. 91.520(g) Categories, priority levels, funding sources and amounts, outcomes/objectives, goal outcome indicators, units of measure, targets , actual outcomes/outputs, and percentage completed for each of the grantee's program year goals. Table 1-A lish ts-P y & Strate!!:ic Plan to Dat Goal Category Source/ Amount Indicator Unit of Measure Affordable Housing Affordable Housing CDBG: $167,823.20 Rental units rehabilitated Household Housing Unit Affordable Housing Affordable Housin g CDBG: $64,000.00 Homeowner Housing Household Housing Unit Rehabilitated Non-Housing Community CDBG: Public service activities other Fair Housing than Low/Moderate Income Persons Assisted Development $0 Housing Benefit Public service activities other Homelessness Homeless CDBG: $32 ,488 .00 than Low/Moderate Income Persons Assisted Housing Benefit Non-Homeless Special Needs Public service activities other Strengthen Neighborhoods Non-Housing Community CDBG : $15,495.05 than Low/Moderate Income Persons Assisted Development Housing Benefit Assess how the jurisdiction's use of funds, particularly CDBG, addresses the priorities and specific objectives identified in the plan, giving special attention to the highest priority activities identified. CAPER 5 The City Council adopted the 2015-2020 Consolidated Plan on April 7, 2015. Overall, the City has performed well at meeting the major goals outlined in the Consolidated Plan. In total , the City's CDBG program assisted one hundred seventy seven (177) persons access needed services. Of these persons , one hundred twenty-two (122) were extremely-low income, twenty-five (25) were very-low income , twenty five (25) were low-income , and five (5) were moderate-income. As illustrated in Table 1, the City has effectively utilized the CDBG funding to target the provision of services to seniors as well as the provision of shelter and services to homeless individuals and families. Unfortunately , the City has not been effective at producing new units for low-income and special needs households. The major barrier to accomplishing this goal has been the real estate market in Cupertino and the lack of available land. However, in FY 17 /18 and FY 18 /19, the City has (and will) utilized CDBG funds to provide funding to rehabilitation projects of affordable rental housing units that provide housing opportunities to extremely-low-, very-low, and low-income households. In FY 15/16, the City also provided CDBG funds for rehabilitation work at Le Beaulieu Housing Development, an affordable housing development for low income seniors. Additionally, the City has increased its efforts to promote development of affordable housing throughout the City . The City joined the Santa Clara County HOME Consortium in 2015. HOME funds can be used to fund eligible affordable housing projects for acquisition, construction, and rehabilitation. Starting in FY 2015-16, developers of affordable housing projects were eligible to competitively apply through an annual RFP process. Applications are submitted to the Santa Clara County Office of Supportive Housing (OSH) for the HOME funds to help subsidize affordable housing projects within the City. If the City receives HOME funds from its participation in the HOME Consortium, the required twenty-five percent (25%) matching funds will be provided from the City's BMR AHF. Currently, the BMR AHF has an available balance of approximately $6,000,000. The Veranda, which will be developed by Charities Housing, applied for and received $500 ,000 in HOME funds from the HOME Consortium. The property will provide eighteen (18) units oflow- income senior housing and one (1) property manager unit to eighteen (18) households. The City provided a twenty-five (25%) match for the project. It should also be noted that the City utilizes a performance measurement system to monitor its progress at meeting its goals and objectives . The performance measurement system lists objectives, outcomes, indicators as well as one-year goals and five-year objectives for each goal statement. Goals include providing an adequate supply ofresidential units for all economic segments of the population and providing housing that is affordable for a diversity of Cupertino households. CAPER 6 CR-10 -Racial and Ethnic composition of families assisted Describe the families assisted (including the racial and ethnic status of families assisted). 91.520(a) Table 2 -Table of assistance to racial and ethnic populations by source of funds CDBG White 104 Black or African American 11 Asian 52 Asian/White 1 American Indian or American Native 1 American Indian/Alaska Native White 2 Other multi-racial 6 Total 177 Hispanic 17 Not Hispanic 160 In total, the City's CDBG program served one hundred and seventy seven (177) individuals. Of those individuals, fifty nine percent (59%) were White; six percent (6%) were African American; twenty nine percent (29%) were Asian; and six percent (6%) were either American Indian/American Native, American Indian/Alaska Native/White, Asian/White or Other, Multi- racial. Approximately, ten percent (10%) were Hispanic. CAPER 7 CR-15 -Resources and Investments 91.520(a) Table 3 -Resources Made Available Source of Funds CDBG Narrative Please see above. T bl 4 Id t'f th a e -en 1 :y h 0 d 0 t 0 b t' e geograp 1c IS rI u ion an d I t' oca ion o f. t t mves mens Target Area Planned Percentage Actual Percentage Narrative of Allocation of Allocation Description NIA NIA NIA The funds were distributed citywide. Narrative Not applicable. The City has not established specific target areas to focus the investment of CDBG funds . Leveraging Explain how federal funds lev eraged additional resources (private, state and local funds), including a description of how matching requirements were satisfied, as well as how any publicly owned land or property located within the jurisdiction that were used to address the needs identified in the plan. The City encourages all non-profit housing developers to leverage funding resources. It is the City 's goal to leverage all funding with other resources. All the public service projects carried out with CDBG funds from the City involved the leveraging of other funding sources. For instance, many of the non-profits funded by the City receive monies from the United Way , charitable foundations , local jurisdictions, and/or other federal funding. Other Federal Grant Prog ram s In addition to the entitlement dollars listed above, the federal government has several other funding progran1s for community development and affordable housing activities. These include: the Section 8 Housing Choice Voucher Program, Section 202, Section 811, the Affordable Housing Program (AHP) through the Federal Home Loan Bank, and others. It should be noted that, in most cases , the City would not be the applicant for these funding sources as many of these programs offer assistance to affordable housing developers rather than local jurisdictions. County of Santa Clara and Local Hou s ing and Community Deve lopment Sources CAPER 8 There are a variety of countywide and local resources that support housing and community development programs. Some of these programs offer assistance to local affordable housing developers and community organizations while others provide assistance directly to individuals. These resources are discussed below. Below Market-Rate Affordable Housing Fund (BMR AHF) The BMR AHF receives its revenue from the payment of housing mitigation fees from non- residential ( office, commercial, retail, research and development (R&D), hotel and industrial) and residential development. The non-residential housing mitigation fee jobs/housing nexus study acknowledges housing needs created by the development of office, commercial, retail, hotel, R&D and industrial development. A fee is applied to new square footage of non-residential development in the City. The fees collected are deposited in the City's BMR AHF and are to be used for the provision of affordable housing. A portion of the BMR AHF funds will be targeted to benefit extremely low-income households and persons with specials needs (such as the elderly, victims of domestic violence, and the disabled, including persons with development disabilities). In FY 2017 /18, the City allocated $380,000 in BMR AHF to local non profit organizations that provide fair housing services, BMR program administration, landlord/tenant rental mediation, and an affordable rental housing renovation project. General Fund Human Service Grants (HSG) Program Arumally, the City Council allocates approximately $40,000 from the General Fund to public and human service agencies within the City of Cupertino. The monies were utilized to fund a long- term care ombudsman, client services for victims of domestic violence, and legal assistance to semors. As mentioned previously, the City joined the Santa Clara County HOME Consortium in 2015. HOME funds can be used to fund eligible affordable housing projects for acquisition, construction, and rehabilitation. Starting in FY 2015-16, developers of affordable housing projects were eligible to competitively apply through an annual RFP process. Applications are submitted to the County OSH for the HOME funds to help subsidize affordable housing projects within the City. If the City receives HOME funds from its participation in the HOME Consortium, the required twenty-five percent (25%) matching funds will be provided from the City's BMR AHF. Currently, the BMR AHF had an available balance of approximately $6,000,000. The Veranda, which will be developed by Charities Housing, applied for and received $500,000 in HOME funds from the HOME Consortium. The property will provide ( eighteen) 18 units low-income senior housing and one ( 1) property manager unit. The City provided a twenty-five percent (25%) match for the project. It should be noted that the City does not own any vacant land that is suitable for development. CAPER 9 CR-20 -Affordable Housing 91.520(b) Evaluation of the jurisdiction's progress in providing affordable housing, including the number and types of families served, the number of extremely-low income, low-income, moderate-income, and middle-income persons served. Table 5 -Number of Households One-Year Goal Actual Number of homeless households to 0 0 be provided affordable housing units Number of non-homeless 11 14 households to be provided affordable housing units Number of special-needs 0 0 households to be provided affordable housing units Total 11 14 a e -um ero T bl 6 N b fH ouse o s h Id S t d uppor e One-Year Goal Actual Number of households supported 0 0 through rental assistance Number of households supported 0 0 through the production of new units Number of households supported 11 14 through the rehab of ex isting units Number of households supported 0 0 through the acquisition of existing units Total 11 14 Discuss the difference between goals and outcomes and problems encountered in meeting these goals. The City 's annual goals w ere ex ceed in this FY. Rebuilding Together assisted eight homeowners with the rehabilitation of their homes which is slightly higher than the seven housing unit goal. WVCS completed rehabilitation repairs on six affordable housing rental units which are occupied by extremely-low, very-low, and low-income households. Discuss how these outcomes will impact future annual action plans. As discussed above , the City exceeded its goals this FY. The City will continue to address the needs highlighted in its 2015-2020 Consolidated Plan and does not foresee any changes to its Annual Action Plan . As mention above , although fair housing activities are no longer funded with CDBG dollars, the City continues to fund a fair housing service provider with its BMR CAPER 10 AHF funds . The fair housing service provider meets it goals of investigating ten ( 10) cases of suspected housing discrimination. Include the number of extremely low-income, low-income, and moderate-income persons served by each activity where information on income by family size is required to determine the eligibility of the activity. Table 7 -Number of Persons Served Number of Persons Served CDBG Actual HOME Actual Extremely Low-income 122 0 Very Low-income 25 0 Low-income 25 0 Moderate-income 5 0 Above Moderate-income 0 0 Total 177 0 Narrative Information In total , one hundred and seventy seven (177) persons were serve d through the City's CDBG funded services. Of the individuals, one hundred and twenty two (122) were extremely-low income, twenty five (25) were very-low income, twenty fi v e (25) were low-income, and five (5) were moderate-income . CAPER 11 CR-25 -Homeless and Other Special Needs 91.220(d, e); 91.320(d, e); 91.520(c) Evaluate the jurisdiction's progress in meeting its specific objectives for reducing and ending homelessness through: Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs. Through the assistance of Santa Clara County Measure A funds, six ( 6) units will be reserved at The Veranda as permanent supportive housing units for homeless seniors , aged sixty-two (62) or older, with disabling conditions. The Veranda is one of the first developments to take advantage of Measure A funding. In 2017 , the City provided $3 ,672 ,000 in BMR AHF to The Veranda, a low-income senior development. Of the nineteen (19) units at The Veranda, six ( 6) have been set aside as Measure A units designed to serve extremely low-income formerly homeless individuals. Through the City's participation in the Santa Clara County HOME Investment Partnerships Program (HOME) Consortium , The Veranda secured $500,000 in HOME funds. Addressing the emergency shelter and transitional housing needs of homeless persons. The City supports efforts to end homelessness. The City allows zoning for emergency shelters. This has allowed the Faith in Action Silicon Valley Rotating Shelter Program to set-up overnight shelter beds in churches throughout the City. As part of the 2014-2022 Housing Element update , the City updated its z oning code to comply with SB No . 2 regarding emergency shelters. In FY 2016-17 , the City provided $23 ,400 to Maitri through the General Fund Human Service Grant's (HSG) Program. Maitri provides transitional housing for adult women and children who are victims of domestic violence . The majority of the household served by Maitri are homeless. Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: likely to become homeless after being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); and, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs In FY 17/18, the City of Cupertino provided $32,488 in CDBG funds to WVCS to administer its Community Access to Resources and Education (CARE) program. The program provides sh011- term rental assistance to support homeless families transitioning to permanent ·housing. It should be noted that CDBG dollars are not utilized to fund the short term rental assistance. Additionally, the program allocates Red Cross emergency rental grants and emergency utility payments to assist low-income individuals and families on the verge of homeless maintain their housing. CAPER 12 Additionally, in FY 17/18, the City provided General Fund HSG and/or BMR AHF to the following organizations: • Senior Adult Legal (SALA)-Received $10,100 from the HSG. SALA provided free legal services to sixty-five (65) Cupertino residents age sixty (60) or older. Ninety one percent (91 % ) were seen at a SALA appointment at the Cupertino Senior Center and the rest were served through a SALA site in another city or our Central Office in San Jose. All clients were presumed low/moderate income ( 51 % to 80% AMI) by HUD because they are elderly (age 60 or older). In addition, 48% were age 75 or older, a demographic placing them at risk of abuse, isolation, or institutionalization. • Maitri -Received $23,400 from the Human Services Grant. The Anjali Transitional House (TH) served 34 women and children for 5,043 bednights and provided adult residents with 361 case management sessions. The TH provided residents with a safe, longer-term housing option (up to nine months), as well as culturally appropriate and customized support that helped them gain the self-confidence and skills needed to rebuild their lives. Residents engaged in activities such as English and driving classes, and employment and housing searches. • Catholic Charities -$6,500 from the Human Services Grant. Catholic Charities provided needed advocacy of our elders in long-term care. Helping homeless persons ( especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again As mentioned above, the City provided $32,488 in CDBG funds to WVCS to administer its Community Access to Resources and Education (CARE) program. The program provides short- term rental assistance to support homeless families transitioning to permanent housing. Additionally, the program allocates Red Cross emergency rental grants and emergency utility payments to assist low-income individuals and families on the verge of homeless maintain their housing. In total, the City allocated approximately $47,983 in CDBG, $45,000 in BMR AHF and $40,000 in HSG money to provide a variety of support services for low-income Cupertino households. Services provided include the provision of food, clothing, legal assistance, emergency rental assistance, and a variety of other services. CAPER 13 CR-30 -Public Housing 91.220(h); 91.3200) Actions taken to address the needs of public housing Not applicable. The Housing Authority of the County of Santa Clara (HACSC) owns and manages four public housing units, which are all located in the City of Santa Clara. There is no public housing in Cupertino. Actions taken to encourage public housing residents to become more involved in management and participate in homeownership While the majority of their units have been converted to affordable housing stock, HACSC is proactive in incorporating resident input into the agency's policy-making process. An equitable and transparent policy-making process that includes the opinions of residents is achieved through the involvement of two tenant commissioners, one being a senior citizen, on the HACSC board. Actions taken to provide assistance to troubled PHAs Not applicable. CAPER 14 CR-35 -Other Actions 91.220U)-(k); 91.320(i)-U) Actions taken to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment. 91.220 U); 91.320 (i) Actions taken to address obstacles to meeting underserved needs. 91.220(k); 91.320U) As mentioned in the Consolidated Plan, the City's highest need is for affordable units for low- income and special needs households. One of the primary impediments to creating the affordable units is the high cost of land in Cupe1iino and rising construction costs. In order to fund 100% affordable developments, the City adopted a housing mitigation program in 1993. Originally, the program required all new residential developments to dedicate 10% of its housing as affordable . In 2002, the City updated the Housing Element and raised the requirement to 15%. For smaller developments with less than seven units, developers can build one BMR unit or pay an in-lieu fee. This in-lieu fee allows the City to accumulate funds to use for affordable developments. In the past ten years, the City has accumulated over five million dollars in fees. These fees have been used to fund the Stevens Creek Village 40-unit development for single-persons and small households; Vista Village, a 24-unit development aimed at housing small and medium size families; and Senior Housing Solutions ' purchase of a home for use as senior congregate care. To ensure that the mitigation fees continue to be adequate to mitigate the impacts of new development on affordable housing needs, the City completed a nexus study update in 2015. The purpose of the nexus study update was to allow the City to consider appropriate mitigation fee charges and possible affordable percentage requirements. The City Council adopted the updated residential and non-residential housing mitigation fees on May 5, 2015. The fees went into effect on July 6 , 2015. A more recent revision of fee schedule went into effect in August 2017. The City has increased its efforts to promote development of affordable housing throughout the City. The City joined the Santa Clara County HOME Consortium in 2015. HOME funds can be used to fund eligible affordable housing projects for acquisition, construction, and rehabilitation. Starting in FY 2015-16, developers of affordable housing projects were eligible to competitively apply through an annual RFP process. Applications are submitted to the County OSH for the HOME funds to help subsidize affordable housing projects within the City. The Veranda, which will be developed by Charities Housing, applied for and received $500,000 in HOME funds from the HOME Consortium for FY 18/19. The property will provide 18 units low-income senior housing and one property manager unit to 18 households. The City provided a 25% match for the project. Actions taken to reduce lead-based paint hazards. 91.220(k); 91.320U) The number of units with potential lead-based paint hazards in the City is likely less than 500. Lower income households will occupy some percentage of these units, but how many is not known. In addition to working with the County Health Department to identify and assist any CAPER 15 children with elevated blood lead levels, the City will, as part of its efforts to address the rehabilitation needs of its housing stock, provide assistance to persons seeking to mitigate lead hazards in the home. Currently, City staff has a policy to test any property being assisted with CDBG funds for the presence oflead based paint if the property was constructed prior to 1978. If the property tests positive for the presence of lead based paint, then the City assists with the abatement of the paint. In all cases, the property owners and tenants are notified of the presence of the lead based paint. The City also assists the contractor with finding contractors trained on how to deal with lead based paint or receiving training themselves. Actions taken to reduce the number of poverty-level families. 91.220(k); 91.320(j) As mentioned earlier, the City funds WVCS's Community Access to Resources and Education (CARE) program to provide those living below the poverty level with food, clothing and emergency rental assistance. These are basic necessities that those living at or below the poverty level cannot afford due to limited incomes. WVCS also provides job search assistance and basic computer classes in an attempt to reduce the number of persons living below the poverty level. Additionally, the City makes it a high priority to provide affordable rental units to extremely-low income households. Actions taken to develop institutional structure. 91.220(k); 91.320(j) The City continues to participate with other local jurisdictions in sharing information and resources regarding CDBG and other housing programs. Meetings take place on a quarterly basis. Additionally, when projects are funded by multiple jurisdictions, the jurisdictions involved cooperate in an effort to reduce duplication of work and reduce project monitoring costs. City staff will continue the following collaborative efforts to improve institutional structure: • Joint jurisdiction Request for Proposals and project review committees • Coordination on project management for projects funded by multiple jurisdictions • HOME Consortium between member jurisdictions for affordable housing projects The City is also represented at the Santa Clara County Association of Planning Officers (SCCAPO) and Silicon Valley Leadership Group's Housing Action Coalition (HAC) meetings . These meetings are especially important in fostering regional approaches to providing affordable housing. Actions taken to enhance coordination between public and private housing and social service agencies. 91.220(k); 91.320(j) The City benefits from a strong jurisdiction and region-wide network of housing and community development partners, such as Regional Housing Working Group and the CoC. To improve intergovernmental and private sector cooperation, the City participated with other local jurisdictions and developers in sharing information and resources. CAPER 16 In addition to the actions listed above, the City continues to partner with nonprofit agencies to host a yearly Housing Fair to provide residents with access to developers, BMR managers, and housing agencies and programs. The City also leveraged its BMR AHF to assist nonprofit affordable housing developers, including assisting Charities Housing with the financing of The Veranda, a 100% affordable senior housing development, by providing a 25% match requirement to the County's HOME Consmtium funds. Identify actions taken to overcome the effects of any impediments identified in the jurisdictions analysis of impediments to fair housing choice. 91.520(a) On January 12, 2012, the City Council adopted a new Analysis oflmpediments (Al) to Fair Housing Choice and the recommended policies and actions to respond to the fair housing impediments identified in the document. The document states that the primary impediments to fair housing choice are access to affordable housing and knowledge of fair housing services. The City has implemented the following in response to the impediments identified in the AI: • Facilitate access to below market rate (BMR) units. The City will continue to assist affordable housing developers and market rate developers in advertising the availability of BMR and affordable units via a link on the City 's website and the United Way's 2-1-1 program, phone referrals, and other media outlets. The City will also facilitate communications between special needs service providers and affordable housing developers, to ensure that home seekers with special needs have fair access to available units. • City staff continues to contract with a fair housing provider to conduct outreach and education regarding fair housing for home seekers , landlords, property manager, real estate agents, and lenders. ,~ • In addition to outreach, the fair housing provider will conduct fair housing testing in local apartment complexes. • The City will periodically review the Zoning Ordinance to ensure regulations are consistent with fair housing laws and do not constrain housing production. If particular zoning requirements impede fair housing or production, the City will amend the regulations. • The City will continue to support the HACSC to ensure adequate outreach to minority, limited English proficiency, and special needs populations regarding the availability of public housing and Section 8 vouchers. • The City will continue to plan for higher residential and employment densities where appropriate to maximize linkages between employers and affordable housing. • The City will continue to work with local transit agencies to facilitate safe and efficient routes for the various forms of public transit. Eden Council for Hope and Opportunity (ECHO) received $10,000 from the City's BMR AHF for support of fair housing activities. These activities included the provision of fair housing counseling, case investigation services and outreach and educational activities to increase community awareness of fair housing. Below is a list of the activities carried out by ECHO to increase community awareness of fair housing activities in Cupertino. • Conducted 3 tester trainings; • Conducted 4 fair housing presentations; • Distributed 1,340 educational brochures throughout the City at City Hall, the library, and CAPER 17 ------------------- senior center; • Participated in Fair Housing Month activities in Santa Clara County and the City; CAPER 18 CR-40 -Monitoring 91.220 and 91.230 Describe the standards and procedures used to monitor activities carried out in furtherance of the plan and used to ensure long-term compliance with requirements of the programs involved, including minority business outreach and the comprehensive planning requirements The City continues to actively monitor all subrecipients and projects ensuring compliance with program and comprehensive planning requirements. Monitoring involves review of quarterly reports, invoices with backup material, and review of agency audit reports. Annual on-site monitoring is carried out for all CDBG subrecipients and consists of reviewing client files, financial records, policies, procedures and compliance with federal requirements as detailed in the subrecipient contracts. Citizen Participation Plan 91.105( d); 91.llS(d) Describe the efforts to provide citizens with reasonable notice and an opportunity to comment on performance reports. A draft CAPER was made available on the City website (www.cupertino.org/housing) and at City Hall for the required 15-day public comment period (August 27, 2018 through September 10, 2018). An advertisement was placed in the Cupertino Courier, a newspaper of general circulation on August 26, 2018, advertising the availability of the CAPER for public review and comment. If citizens could not physically come into City Hall to review the report, a report could be mailed or e-mailed to the citizen free of charge. The City also makes available a TDD phone number for the hearing impaired. The City also conducted a public hearing at the Cupertino Housing Commission meeting held on September 13, 2018 allowing the public an opportunity to comment on the CAPER. CAPER 19 CR-45 -CDBG 91.520( c) Specify the nature of, and reasons for, any changes in the jurisdiction's program objectives and indications of how the jurisdiction would change its programs as a result of its experiences. Does this Jurisdiction have any open Brownfields Economic Development Initiative (BEDI) grants? Not applicable . [BEDI grantees] Describe accomplishments and program outcomes during the last year. Not applicable. CAPER 20