HomeMy WebLinkAboutCity of Tamarac Resolution R-2016-012Temp. Reso. No. 12725
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December 23, 2015
CITY OF TAMARAC
RESOLUTION NO. R-2016-
A RESOLUTION OF THE CITY COMMISSION OF THE CITY
OF TAMARAC, FLORIDA, APPROVING A SECOND
AMENDMENT TO THE FISCAL YEAR 2014/2015 ANNUAL
ACTION PLAN FOR EXPENDITURE OF THE U.S. HOUSING
AND URBAN DEVELOPMENT COMMUNITY
DEVELOPMENT BLOCK GRANT FUNDS FOR THE
FIFTEENTH PROGRAM YEAR TO PROVIDE FOR
REALLOCATION OF FUNDS; PROVIDING FOR CONFLICT, -
PROVIDING FOR SEVERABILITY; AND PROVIDING FOR
AN EFFECTIVE DATE.
WHEREAS, on June 25, 2014, the City Commission of the City of Tamarac
("City") adopted Resolution No. 2014-R-65 which approved the specific activities within
the Fiscal Year 2014/2015 Annual Action Plan for the expenditure of the U.S. Housing
and Urban Development Community Development Block Grant ("CDBG") Funds in an
amount of $355,970 for the City's Fifteenth Program Year; and
WHEREAS, on October 28, 2015, the City Commission adopted
Resolution R-2015-107, and approved the First Amendment to the Fiscal Year
2014/2015 Annual Action Plan reallocating funds in the amount of $35,237.00 within
the approved activities; and
WHEREAS, previously, the City of Tamarac adopted the City of Tamarac Five
Year Consolidated Plan for FY 2010-2015 via Resolution No. 2010-R-102 which
established the City's strategic priorities for the CDBG program during this period; and
WHEREAS, funding received for the CDBG program must be utilized for eligible
CDBG activities; and
Temp. Reso. No. 12725
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December 23, 2015
WHEREAS, each year a new Annual Action Plan is required to detail projects,
activities, and programs to be funded by that year's funding allocation in compliance
with the adopted Consolidated Plan; and
WHEREAS, the City desires to process a second amendment to the Fiscal Year
2014/2015 Annual Action Plan to provide for the re -allocation of funds within the
approved activities, as provided in Exhibit 1" which is attached- hereto and incorporated
herein by reference; and
WHEREAS, the City Commission finds that this second amendment to the Fiscal
Year 2014/2015 Annual Action Plan meets one of three national objectives, as defined
by Congress, including benefiting low and moderate income people, helping to eliminate
slum and blight, or addressing existing conditions that pose a serious or immediate
threat to the health and welfare of the community; and
WHEREAS, the Community Development Director recommends the approval of
the activities contained in this second amendment to the Fifteenth Program Year Annual
Action Plan for Fiscal Year 2014/2015; and
WHEREAS, the City Commission of the City of Tamarac, Florida deems it to be
in the best interest of the citizens and residents of the City of Tamarac to approve this
amendment to the Fiscal Year 2014/2015 Annual Action Plan for expenditure of the
U.S. Housing and Urban Development Community Development Block Grant funds in
the amount of $355,970.00 for the Fifteenth Program Year.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE
CITY OF TAMARAC, FLORIDA.-
Temp. Reso. No. 12725
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December 23, 2015
SECTION 1: The foregoing "WHEREAS" clauses are hereby ratified and
confirmed as being true and correct and are hereby made a specific part of this
Resolution. All exhibits attached hereto and referenced herein are incorporated and
made a specific part of this Resolution.
SECTION 2: That the City Commission hereby approves the attached
Second Amendment to the Fiscal Year 2014/2015 Annual Action Plan for expenditure of
the U.S. Housing and Urban Development Community Development Block Grant funds
in the amount of $355,970.00 for the Fifteenth Program Year, a copy of which is
attached hereto as Exhibit "1" and incorporated herein by reference.
SECTION 3: The City Clerk is hereby directed to provide a signed copy of
the Second Amendment to the appropriate Broward County and Housing and Urban
Development (HUD) Representatives.
SECTION 4: All resolutions or parts of resolutions in conflict herewith, are
hereby repealed to the extent of such conflict.
SECTION 5: If any clause, section, other part or application of this
Resolution is held by any court of competent jurisdiction to be unconstitutional or invalid, in
part or application, it shall not affect the validity of the remaining portions or applications of
this Resolution.
SECTION 6: This Resolution shall become effective immediately upon its
passage and adoption.
Temp. Reso. No. 12725
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December 23, 2015
PASSED AND ADOPTED BY THE CITY COMMISSION OF THE CITY OF
TAMARAC, FLORIDA THIS 3 DAY OF q,9WtUj2016.
ATTEST:
PATRICIA TEUFE dMC
CITY CLERK
I HEREBY CERTIFY that I
Have approved this
RESOLUTION as to form.
SA UEL S. G R N,
CITY ATTORNEY
CITY OF TAMARAC, FLORIDA
Y . •
rn
H. DRESSLER
P. BUSHNELL
M. GOMEZ
D. GLASSER
D. PLACKO
1
li
Exhibit "1"
CITY OF TAMARAC, FL
Annual Action Plan
Community Development Block
Grant (CDBG) Program
Fiscal Years 2014/2015
1st Amendment — October 2015
2nd Amendment — January 2016
Prepared by:
City of Tamarac
Community Development Department
Housing Division
Submitted to:
U.S. Department of Housing and Urban Development
The Office of Community Planning and Development
Miami Field Office
TABLE OF CONTENTS
Annual Action Plan
Executive Summary 91.220(b)
4
Citizen Participation Plan 91.220 (b)
5
Resources 91.220 (c) (1) and (c) (2)
7
Annual Objectives 91.220 (c) (3)
10
Description of Activities 91.220 (d) and (e)
11
Objectives
14
Performance Measurements
15
Geographic Distribution/Allocation Priorities 91.220 (d) and (f)
16
Annual Affordable Housing Goals 91.220 (g)
16
Public Housing 91.220 (h)
17
Homeless and Special Needs 91.220 (i)
18
Barriers to Affordable Housing 91.220 Q)
23
Other Actions 91.220 (k)
24
Program Specific Requirements
CDBG 91.220 (1) (1) 25
HOME 91.220 (1) (2) 26
HOPWA 91.220 (1) (3) 29
Other Narratives and Attachments
Section 3 Initiatives 29
Davis Bacon Initiatives 29
Fair Housing 30
PLAN ATTACHMENTS:
Resolution -Submission Approval for Annual Action Plan 2nd Amendment
►J
CITY OF TAMARAC
FY 2014/2015 Annual Action Plan
DUNS #077270940
City of Tamarac
Mayor Harry Dressler
Vice -Mayor Michelle Gomez
Commissioner Pamela Bushnell
Commission Diane Glasser
Commissioner Debra Placko
City Manager Michael C. Cernech
Our Vision
The City of Tamarac, Our Community of Choice -Leading the nation in
quality of life through safe neighborhoods, a vibrant community,
exceptional customer service and recognized excellence.
Our Mission
We "Committed to Excellence... Always"
It is our job to foster and create an environment that:
Responds to the Customer
Creates and Innovates
Works as a Team
Achieves Results
Makes a Difference
Our Values
As stewards of the public trust, we value:
Vision
Integrity
Efficiency
Quality Service
3
2 014- 2 015 Annual Action Plan
plot"pop
The CPMP Annual Action Plan includes the SF 424 and Narrative Responses
to Action Plan questions that CDBG, HOME, HOPWA, and ESG grantees
must respond to each year in order to be compliant with the Consolidated
II III I g g y p
Planning Regulations.
A01
NAME OF JURISDICTION.
Annual Action Plan:
Consolidated Plan Time Period:
CITY OF TAMARAC, FL
FY 20141201 S
FY 201012011— FY 201412015
Annual Action Plan includes the SF 424 and is due every year no less than 45 days prior to the
start of the grantee's program year start date. HUD does not accept plans between August 15
and November 15.
Executive Summary 91.220(b)
The Executive Summary is required. Include the objectives and outcomes identified in the
plan and an evaluation of past performance.
The City of Tamarac participated in the U.S. Department of Housing and Urban
Development (HUD) entitlement allocation formula as a recipient of federal funds for
the first time in Fiscal Year 2000. The City is recently embarked on its second five-
year cycle to receive HUD Federal grant allocations providing funds to promote
affordable housing initiatives and socio-economic programs to address identified
community development needs. In Fiscal Year 2014-2015, it is estimated that the
City of Tamarac will receive a total of $355,970.00 consisting of a direct allocation in
the amount of $348,258.00 and unclaimed reallocation funds from the City of
Weston in the amount of $7,712.00 in Community Development Block Grant (CDBG)
funds, to address identified community development needs. Entitlement allocations
from other HUD funds may become available in future years. To receive CDBG
funding, the City must assess local housing and community development needs and
resources, and socioeconomic impediments toward building viable neighborhoods.
The statutes for the HUD CDBG grant programs set forth three basic goals which
are closely related to the major commitments and priorities of the U.S. Department
of Housing and Urban Development (HUD).
F
Each of these goals must primarily benefit very low, low and moderate income
persons within the context described below:
1. To provide suitable living environment
2. To provide decent housing
3. To expand economic opportunities
This annual action plan incorporates priorities and programs addressing these goals.
EXISTING PROGRAM
The City of Tamarac receives federal funding under both the CDBG and HOME
program. Additional funds are received from the State's, State Housing Initiative
Partnership (SHIP) Program. To date activities approved using these funding
sources focus on housing assistance (home rehabilitation), public service, and public
facilities improvements. These activities benefit residents by direct assistance or
indirectly through area -wide or limited clientele activities based on low -moderate
income determinations.
ACCOMPLISHMENTS
Over the last year, U.S Department of Housing and Urban Development (HUD)
funds (CDBG & HOME) have assisted with the following:
v Provided home rehabilitation for owner -occupied homes.
v Installed and repaired sidewalks and accessibility pads.
v Provided a full-time temporary information and referral specialist that assisted
residents in obtaining referrals, counseling and other social service needs.
Citizen Participation 91.220(b)
2. Provide a summary of the citizen participation and consultation process (including efforts to
broaden public participation in the development of the plan.
Citizen Participation and Consultation
The Citizen Participation Plan in accordance with the Housing and Community
Development Act of 1974, as amended and 24 CFR Part 91, Subpart B: Citizen
Participation and Consultation sets forth the citizen participation plan requirements.
This section of the Act provides for and encourages citizen participation with
particular emphasis on persons of low and moderate income, in addition to slum and
blighted areas. Consistent with the Act, the City of Tamarac provides citizens
reasonable and timely access to local meetings, information and records. In
addition, technical assistance is made available to low and moderate income
representative groups. The Citizen Participation Plan details the process to develop
needs, review proposed activities and program performance as well as the manner
in which hearings are advertised and conducted. (Citizen Participation Plan -
attached hereto)
The City published a public notice on May 24, 2014 for the 30-day public review
period which began May 25, 2014 and ended June 25, 2014. A public hearing was
held during the City Commission meeting on June 25, 2014 which by resolution
adopted the Annual Action Plan and authorized its submission to the U.S.
Department of Housing and Urban Development prior to the July 15, 2014 deadline.
The citizen participation process provides ample time for written complaints and
grievances. Through the on -going efforts of our Neighborhood Partnership Program,
the City stimulates and enhances neighborhood vitality and customer satisfaction by
addressing the concerns and special needs of neighborhoods through progressive
and collaborative planning. In the spirit of collaboration the City staff serves as
consultants and facilitators. Throughout all stages of the program, the City of
Tamarac Community Development Department staff is responsible for the effective
development and inclusion of citizen comments in all phases of the CDBG Program.
All projects must be proven feasible prior to receiving HUD funds, as many require
documentation indicating financial feasibility and conformance with applicable
regulations and constraints (i.e. zoning, land use, flood plan, etc.). Projects will not
be funded if the proposed project duplicates an existing program which the public
sector administers.
Community Development/Housing to solicit project
April 9, 2014
recommendations from Department heads
Advertisement for 30-day review period and Public
May 24, 2014
Hearing on proposed FY 13/14 Annual Action Plan
Beginning of 30-day review period
May 25.2014
Planning Board approval of recommended activities
June 4, 2014
End of 30-day review period
June 25, 2014
Commission approval and review/public hearing of
June 25, 2014
recommended activities for final approval
Send HUD RROF Form 7015.15
Sept. 30, 2014
Wait for HUD Clearance to commit funds
Funding Agreement from HUD issued
October 1, 2014
Advertisement for 1 st Amendment
October 18, 2015
Approval of 15t Amendment by City Commission
October 28, 2015
Public Hearing
Advertisement for 2nd Amendment
January 3, 2016
Approval of 2nd Amendment by City Commission
January 13, 2016
Public Hearing
2
3. Provide a summary of citizen comments or views on the plan.
No comments were received on the Annual Action Plan.
No comments were received regarding first amendment.
No comments were received regarding second amendment.
4. Provide a written explanation of comments not accepted and the reasons why these
comments were not accepted.
Had any comments been received, the City would have responded and considered
accordingly. No comments were received.
Resources 91.220(c)(1)) and (c)(2)
5. Identify the federal, state, and local resources (including program income) the jurisdiction
expects to receive to address the needs identified in the plan. Federal resources should
include Section 8 funds made available to the jurisdiction, Low -Income Housing Tax Credits,
and competitive McKinney-Vento Homeless Assistance Act finds expected to be available to
address priority needs and specific objectives identified in the strategic plan.
As an entitlement recipient of CDBG, HOME and SHIP funds, the City intendeds to
allocate according to priority need. For the next year, the City expects the housing
market to continue its slow recovery from the drastic slump it has been in since
2005. The appropriate federal and state resources described below will be utilized
and applications will be submitted and or supported in achieving the City's listed
projects and actions outlined in this section.
FEDERAL RESOURCES
Community Development Block Grant (CDBG)
The Community Development Block Grant (CDBG) was first authorized by the U.S.
Congress in 1974, by the Housing and Community Development Act of 1974
(HCDA), with subsequent amendments. The primary purpose of the HCDA is the
development of viable urban communities, by providing decent housing and a
suitable living environment and expanding economic opportunities, principally for
persons of low and moderate income. At least 70% of all CDBG funds must be
spent on activities which benefit low or moderate income persons. Funds are used
for housing to benefit low and moderate income persons, public facilities and
improvements, expanded public services that include employment training, child
care, fair housing counseling or recreational needs; rehabilitation of private or
publicly owned buildings; economic development activities that create or retain jobs
for low and moderate income persons.
Home Investment Partnerships Program (HOME)
In FY 2002, the City of Tamarac became a member of the Broward County HOME
Consortium along with the Entitlement Cities of Tamarac, Margate, Deerfield Beach,
Sunrise, Lauderhill, Plantation, Davie, Pembroke Pines, Miramar, and Coconut
Creek was recently added. The United States Congress passed the National
Affordable Housing Act In 1990. This Act created a variety of affordable housing
programs, including the Home Investment Partnerships Act (HOME).
The City of Tamarac receives an allocation of these funds as a member of the
Consortium. The purpose of the HOME program is to provide funds to local
jurisdictions to strengthen public -private partnerships to provide more affordable
housing through acquisition, rehabilitation, and new construction of housing, and
tenant based rental assistance. In addition, HUD rules require that at least 15% of
HOME funds be set aside for community housing development organizations to
develop affordable housing. HOME funds may be used to provide: affordable
renter/owner occupied units; tenant based rental assistance; administrative and
planning costs; and payment of operating expenses of community housing
development organizations. Housing development costs include acquisition, new
construction, re -construction, pre -development and financing costs.
STATE RESOURCES
State Housing Initiative Partnership (SHIP) Program
The City of Tamarac typically receives an annual allocation under this program.
Florida Housing administers the State Housing Initiatives Partnership program
(SHIP), which provides funds to local governments as an incentive to create
partnerships that produce and preserve affordable homeownership and multifamily
housing. The program was designed to serve very low, low and moderate income
families.
When the program is funded, SHIP funds are distributed on an entitlement basis to
all 67 counties and 53 Community Development Block Grant entitlement cities in
Florida. In order to participate, local governments must establish a local housing
assistance program by ordinance; develop a local housing assistance plan and
housing incentive strategy; amend land development regulations or establish local
policies to implement the incentive strategies; form partnerships and combine
resources in order to reduce housing costs; and ensure that rent or mortgage
payments within the targeted areas do not exceed 30 percent of the area median
income limits, unless authorized by the mortgage lender.
SHIP dollars may be used to fund emergency repairs, new construction,
rehabilitation, down payment and closing cost assistance, impact fees, construction
and gap financing, mortgage buy -downs, acquisition of property for affordable
housing, matching dollars for federal housing grants and programs, and
homeownership counseling. SHIP funds may be used to assist units that meet the
standards of chapter 553; SHIP funds may also be used to assist manufactured
housing constructed after June 1994 in accordance with the installation standards
defined in the rules of the Department of Highway Safety and Motor Vehicles.
8
A minimum of 65 percent of the funds must be spent on eligible homeownership
activities; a minimum of 75 percent of funds must be spent on eligible construction
activities; at least 30 percent of the funds must be reserved for very -low income
households (up to 50 percent of the area median income or AMI); an additional 30
percent may be reserved for low income households (up to 80 percent of AMI); and
the remaining funds may be reserved for moderate -income households (up to 120
percent of AMI.). It is important to note that no more than 5 percent of SHIP funds
may be used for administrative expenses. However, if a local government makes a
finding of need by resolution, a local government may use up to 10 percent for
administrative expenses. Funding for this program was established by the passage
of the 1992 William E. Sadowski Affordable Housing Act. Funds are allocated to
local governments each month on a population -based formula. These funds are
derived from the collection of documentary stamp tax revenues, which are deposited
into the Local Government Housing Trust Fund. Total actual disbursements are
dependent upon these documentary stamp collections.
The allocation of SHIP funds for fiscal year 2014/2015 has not yet been released.
6. Explain how federal funds will leverage resources from private and non-federal public
sources.
To the extent of the activities described in this Annual Action Plan, private leveraging
is not likely. Most of the leveraging comes from sources under the State SHIP
Program or Down Payment Assistance Programs from lending institutions in the
form of the first mortgage subsidies for first time homebuyers.
In FY 2008 and 2010, the City received grant allocations under the Neighborhood
Stabilization Program (Round 1 and Round 3). These programs also provide
homeownership opportunities utilizing private lending institutions which may be
leveraged with CDBG funds.
0
Annual Objectives 91.220(c)(3)
*If not using the CPMP Tool. Complete and submit Table 3A.
*If using the CPMP Tool: Complete and submit the Summary of Specific Annual Objectives
Worksheets or Summaries.xls
Goals and objectives to be carried out during the action plan period are indicated by
placing a check in the following boxes.
❑
Objective Category
❑
Objective Category:
❑
Objective Category:
Decent Housing
Expanded Economic
Expanded Economic
Opportunities
Opportunities
Which includes:
Which includes:
Which includes:
❑
assisting homeless
❑
improving the safety
❑
job creation and retention
persons obtain
and livability of
affordable housing
nei hborhoods
❑
assisting persons at
®
eliminating blighting
❑
establishment, stabilization
risk of becoming
influences and the
and expansion of small
homeless
deterioration of
business (including micro -
property and facilities
businesses)
®
retaining the affordable
®
increasing the access
❑
the provision of public
housing stock
to quality public and
services concerned with
private facilities
employment
®
increasing the
❑
reducing the isolation
❑
the provision of jobs to low -
availability of
of income groups
income persons living in
affordable permanent
within areas through
areas affected by those
housing in standard
spatial
programs and activities under
condition to low-
deconcentration of
programs covered by the plan
income and moderate-
housing opportunities
income families,
for lower income
particularly to
persons and the
members of
revitalization of
disadvantaged
deteriorating
minorities without
neighborhoods
discrimination on the
basis of race, color,
religion, sex, national
origin, familial status,
or disability
❑
increasing the supply of
❑
restoring and
❑
availability of mortgage
supportive housing
preserving properties
financing for low income
which includes
of special historic,
persons at reasonable rates
structural features and
architectural, or
using non-discriminatory
services to enable
aesthetic value
lending practices
persons with special
needs (including
10
persons with HIV/AD
IS) to live in dignity
and independence
❑
providing affordable
®
conserving energy
❑
access to capital and credit
housing that is
resources and use of
for development activities that
accessible to job
renewable energy
promote the long-term
opportunities
sources
economic social viability of
the community
Description of Activities 91.220(d) and (e)
*If not using the CPMP Tool: Complete and submit Table 3C
*If using the CPMP Tool: Complete and submit the Projects Worksheets and the Summaries
Table.
7. Provide a summary of the eligible programs or activities that will take place during the
program year to address the priority needs and specific objectives identified in the strategic
plan.
Public Service (Full -Time Inform. & Referral Specialist) $43,166.00 $ 26,129.00
This activity will include funding for a full-time information and referral specialist to
provide information and referral services to elderly residents, ongoing case
management, implementation of the Senior Program and the Volunteer Program,
addressing calls and managing an on -going caseload. Approximately one hundred
(100) unduplicated clients will be served by the Information and Referral Specialist
this fiscal year. These activities are eligible under 24 CFR section 570.201(e), and
will benefit low and moderate income persons as qualified under 570.208(a)(2),
limited clientele.
2"d Amendment — January 13, 2016
Reallocation of funds from Public Services to Home Rehabilitation.
Public Service (Counseling) $10,W rv,220 00 $ 7,070.00
This activity will include funding for individual and group counseling to individuals,
families, and single mothers and children.. Approximately 30 individuals will receive
counseling services this fiscal year. These activities are eligible under 24 CFR
section 570.201(e), and will benefit low and moderate income persons as qualified
under 570.208(a)(2), limited clientele.
2"d Amendment — January 13, 2016
Reallocation of funds from Public Services to Home Rehabilitation.
Residential Rehabilitation (Minor Home Repair) $191,391.00 $211,577.00
This activity will provide minor home repairs to a minimum of eight (8) low to
moderate -income households who are experiencing conditions in and around the
home that pose a threat to health, safety, and welfare of the household occupants.
11
This project will be carried out on a citywide basis. This activity is eligible under 24
CFR Section 570.202(a) and will benefit low and moderate -income households on
an area -wide basis.
1 st Amendment — October 28, 2015
Reallocation of funds from Home Rehabilitation to Program Administration.
2nd Amendment — January 13, 2016
Reallocation of funds from Public Services to Home Rehabilitation.
Rehabilitation Services $ 40,000.00
This program activity includes marketing, application in -take and review and
verification for eligibility, communication with general contractors, specification
review and on site problem solving inspections and other services related to the
completion of residential rehabilitation projects.
Auditing Services $ 5,000.00
Since the FY 2010 CDBG program is an expenditure driven program that may result
in total federal expenditures exceeding $500,000, the City is required under the U.S.
Single Audit Act and the OMB Circular A-133 to have an annual compliance audit
conducted. These activities are presumed to benefit low and moderate -income
persons and are eligible under 24 CFR 570.206(a).
Program Administration $ 30,967.00 $ 66,194.00
This activity will provide general management, oversight, and coordination of the
programs. Also, this activity will provide for an annual grant audit, and provide
provision of fair housing services designed to further the fair housing objectives of
the Fair Housing Act, 42 U.C.C. 3601-20. These activities are presumed to benefit
low and moderate -income persons and are eligible under 24 CFR 570.206(a).
1st Amendment — October 28, 2015
Reallocation of funds from Home Rehabilitation to Program Administration
12
FY 2014/2015 Activity Distribution
■ Program Administration
(Administration, Fair Housing & Audit)
■ Public Services (Information &
Referral Specialist and Counseling)
Home Rehabilitation
■ Rehabilitation Services
HOME FY 2014-2015 PROPOSED PROJECTS DESCRIPTIONS
(Broward County Consortium Member)
Home Rehabilitation Minimum of 3 households
SHIP FY 2014-2015 PROPOSED PROJECTS DESCRIPTIONS
Home Rehabilitation Minimum of 8 households
NEIGHBORHOOD STABILIZATION PROGRAM (ROUND 3) DESCRIPTIONS
Foreclosure/Abandoned Property Acquisition & Rehabilitation for the purpose of
re -sale to income eligible homebuyers in areas of greatest need as identified in
the City's FY2010/2011 Substantial Action Plan Amendment.
13
Describe the outcome measures for activities in accordance with Federal Register Notice dated
March 7, 2006, i.e., general objective category (decent housing, suitable living environment,
economic opportunity) and general outcome category (availability/accessibility, affordability,
sustainability).
The City plans to fund the above activities to produce outcomes that fulfill HUD's
objectives as follows:
Accessibility, Affordability, and Sustainability for the purpose of creating
suitable living environments.
Project: Public Service
Information & Referral Specialist
Counseling Services
Accessibility, Affordability, and Sustainability for the purpose providing
decent affordable housing.
Project: Home Rehabilitation
Rehabilitation Services
a
Home Rehabilitation
Home Rehabilitation
PERFORMANCE
MEASUREMENTS FY 2014-2015
8 -CDBG PER
YEAR
3 — HOME PER
YEAR
CDBG,
Number of homes
8 — SHIP PER
1
Home Rehabilitation
HOME, SHIP
assisted
YEAR
DH-3
Application intake,
review and
Rehabilitation
processing for
2
Services
I CDBG, HOME
above homes
DH-3
100
Full -Time
Number of
unduplicated
Information &
unduplicated
residents
3
Referral Specialist
CDBG & CITY
clients/cases
PER YEAR
SL-1
30
Number of
unduplicated
Counseling
unduplicated
residents
4
Services
CDBG & City
clients
PER YEAR
SL-1
Decent Housing DH-1 DH-2 DH-3
Suitable Living Environment SL-1 SL-2 SL-3
Economic ODDortunity EO-1 EO-2 EO-3
15
Geographic Distribution/Allocation Priorities 91.220(d) and (f)
8. Describe the geographic areas of the jurisdiction (including areas of low income families
and/or racial/minority concentration) in which assistance will be directed during the next
year. Where appropriate, the jurisdiction should estimate the percentage of funds the
jurisdiction plans to dedicate to target areas.
The City utilizes data from the 2000 Census to create a low -moderate income map
for the City. All projects proposed take place within those designated areas. The
City will update its low -moderate income map upon the release of the 2010 Census
data. (Low -Moderate Income Map -attached hereto)
9. Describe the reasons for the allocation priorities, the rationale for allocating investments
geographically within the jurisdiction (or within the EMSA for HOPWA) during the next
year, and identify any obstacles to addressing underserved needs.
The main focus is maintaining affordable housing and public services to all low -
moderate income residents of Tamarac, including those with special needs.
The major obstacle is funding, or lack thereof. Both federal and state allocations
fluctuate and are often decreased from year to year making planning for the future
and meeting the needs of the underserved difficult.
Another obstacle may be the lack of data to justify allocating funds to what may
appear to be an unmet need. The 2000 Census is out dated, certain data sets from
the 2010 Census is not available yet, and local resources may be unavailable to
confirm an unmet need.
Annual Affordable Housing Goals 91.220(g)
*If not using the CPMP Tool: Complete and submit Table 3B Annual Housing Completion
Goals. *If using the CPMP Tool: Complete and submit the Table 3B Annual Housing
Completion Goals.
10. Describe the one-year goals for the number of homeless, non -homeless, and special -needs
households to be provided affordable housing using funds made available to the jurisdiction
and one-year goals for the number of households to be provided affordable housing through
activities that provide rental assistance, production of new units, rehabilitation of existing
units, or acquisition of existing units using funds made available to the jurisdiction. The
term affordable housing shall be defined in 24 CFR 92.252 for rental housing and 24 CFR
92.254 for homeownership.
Home Rehabilitation will be the affordable housing activity funded in the FY
2014/2015 Annual Action Plan. It is anticipated that a minimum of eight (8) dwelling
units for FY 2014/2015 will receive assistance under this program.
16
The City of Tamarac intends to allocate funds to sustaining the existing housing
stock, making funds available for barrier free accessibility, and preserving homes
through strengthening and mitigation, and ensuring there is affordability in
homeownership. In conjunction with the City's HOME and SHIP program funds, the
City will provide funding for Home Rehabilitation, including Disaster Mitigation,
Barrier Free Accessibility, Code Correction, and Emergency Repairs, as well as
Down Payment Assistance to low -moderate income households. The total
rehabilitation cost may be limited to a minimum of five hundred dollars ($500) to a
high of thirty thousand dollars ($30,000). The program will target low income
households. However, moderate -income households will also be eligible to
participate utilizing non-CDBG funds.
The housing units that are considered for rehabilitation will be classified in one of
three groups. The categories are:
(i) Standard Condition
(ii) Substandard Condition, or
(iii) Dilapidated Condition
Typically, most units will be classified
not have major physical damage.
painting, minor exterior wood and
improvements.
as "standard condition" indicating that they do
Repair work will include fagade treatment,
:)r masonry repairs, and energy efficiency
Units that are classified as "Substandard" will typically require repairs in the frame,
foundation, roof or superstructure of the unit. Additionally, improvements may
include repair and/or replacement of exterior doors and windows. Lastly, a unit may
be determined to be "substandard" if it is missing some or all of the plumbing
facilities.
As part of the Home Rehabilitation activity, the City will provide inspections, bid write-
up, financial counseling for the homeowner and underwriting for each rehab job. All
work will be based on a competitive bid process from a pre -approved list of
participating contractors. All participating contractors will be State licensed
contractors with the necessary bonding (if required) and insurance. The contractors
will be paid directly from CDBG funds.
The housing rehabilitation will be in the form of a deferred loan grant to eligible low
and moderate income homeowners.
Public Housing 91.220(h)
The service provider for public and rental subsidy housing for the City of Tamarac is the
Broward County Housing Authority (BCHA) and other local Housing Authorities within
17
the county. This agency receives referrals via the North County Satellite office of the
Broward County Bureau of Family and Children Services. Families renting in Tamarac,
and in need of public housing, can receive assistance from the County's North Satellite
office. To date, there is no public housing sites located in the city's jurisdiction.
However, there is one HUD housing project that was built in 1974 in the adjacent City of
Coral Springs; a majority of the units are for the elderly.
I.I. Describe the manner in which the plan of the jurisdiction will help address the needs of
public housing and activities it will undertake during the next year to encourage public
housing residents to become more involved in management and participate in
homeownership.
Residents wishing to participate in homeownership activities are required to attend
an 8-hour Housing Counseling course. Additionally, residents seeking guidance
which are not yet ready for homeownership are recommended to visit a local
housing counseling agency for both group sessions as well as one-on-one sessions
to determine their weaknesses and become educated on the ways to best become
"buyer ready".
12. If the public housing agency is designated as "troubled" by HUD or otherwise is performing
poorly, the jurisdiction shall describe the manner in which it will provide financial or other
assistance in improving its operations to remove such designation during the next year.
The Broward County Housing Authority (BCHA) nor any of the county's housing
authorities are a "troubled" agency. They received grant funds for numerous sources
due to their quality programming and staff. As a HUD Certified Housing Counseling
Agency, they assist residents from all over the South Florida area as well as
participate regularly in outreach and educational workshops.
Homeless and Special Needs 91.220(i)
The City of Tamarac does not currently fund any homeless or homeless prevention
strategies. Any homeless identified within the City are assisted through the Homeless
Initiative Program (HIP). The City of Tamarac's Social Service Division is also available
to assist residents with resources within the County.
A Point in Time survey was conducted in January 2014. Although dispersed throughout
the entire county, the vast majority of homeless persons were concentrated within the
older communities of Pompano Beach, Fort Lauderdale, and Hollywood, where the
majority of services to the homeless are provided and shelters are located.
As a partner of the Broward Homeless Initiative Partnership (HIP), Tamarac participates
in regular meetings and workshops to assist in addressing the needs of the County's
homeless population.
18
The Broward County 2014 Point -in -Time Count, conducted in a 24-hour time period on
January 22, identified that 2,766 individuals were homeless according to the federal
definition of homelessness: they were living in places not meant for human habitation,
emergency shelters or transitional housing programs. The count is required by U.S.
Housing and Urban Development (HUD) and Florida's Office on Homelessness.
The total number of sheltered and unsheltered persons experiencing homelessness in
Broward County decreased by 2 percent, from 2,810 to 2,766.
The Broward Regional Health Planning Council (BRHPC), Hands on Broward, 2-1-1
Broward and the Homeless Initiative Partnership Advisory (Partnership) Board headed
up the 2014 Point -in -Time Count effort in collaboration with volunteers, consisting of
County staff, homeless services agencies, law enforcement agencies, individuals,
advocates, faith -based, foster care providers, youth and community -based
organizations. Trained volunteers fanned out across the County to homeless
encampments, labor pools, meal programs and homeless shelters. The results were
tabulated by Dr. Patrick Hardigan of Nova Southeastern University.
The Partnership Board identified the following as contributing factors for the reduction in
this year's count:
successful programmatic efficiencies implemented during the past two years; and
lack of participation by non -continuum affiliated agencies/programs.
Broward County HIP provided the following data for the January 2014 Point In Time
count for Broward County.
19
Paint -in -Time Summary Homeless Populations Summary
for FL-601- Ft Lauderdale/Bro and County CoC
Date of PIT Count: 1f22l2014
Population: Sheltered and Unsheltered Count
Total Households and Persons
TdW Number of
NWWheld
732
638
3
788
2p1
Total Number of
Perm
917
93,
35
$7
2,766
I ir4ber eyf Ghl
185
255
40
480
�i�n�er:e iS)
Number
93
+�3
(
44
20
(18 D �4j
Numbero(Persam
639
58l
795
� &
(aver. age 24)
!Gender
Female
Able
TtartjMcler
Ethnicity
Race
356 361 18 1917 932
558 572 17 679 11#826
3 2 a 3 e
Emergemy
ho
121
20
Safe haven
1 .34 864 2 515
54 1 15 251
Paint In Tine Smwnary for FL-601- Ft LduderdaWBFow-ard Courty CzC
Emergermy
Transit mal
Safe Haven
White
374
345
23
428
1,170
Black or African:-
503
557
12
397
1,469
Amg.rican
Asian
6
1
0
1
S
American Indian or
5
7
0
14
26
Alaska dative
Native H"aiiar or
1
9
0
0
10
Other Pacific, Islander
MultoeRaces
28
16
0
39
- 3
Point -in -Time Subpopulations Summary for FL-601 Ft
Lauderdale/BrOward County COC
Elate of PIT Count: 1rM014
Population. Sheltered and Unsheltered Count
Chronically Homeless Suhpopulations
A
Emergency Safe;
Shelters Haver
ChwieapyHomeless Individuals
116 35 346 497
Chron[oly Nameless Famir s
crow Numberaf Families)
Chronically Homeless Families
18 #a 28
�'1 o4 Persons in I-lousehow)
Other Homeless Subpopulations
pwims kr eYrr&cfency
shoWrs, transitional
trotissrg and same havers
Adults With a Serious Mental Ilkww
393 175 568
Adults with a Substame Use
fi�2 240 am
Ms"der
Adultswtth HIVI IDS
135 11 146
Viefts;of Domestic Violence
45 0 45
21
Point -in -Time Summary Veterans for FL-601 - Ft
Lauderdale/Broward County CoC
Date of PIT Count 1/2212014
Population- Sheltered and Unsheltered Count
Total Households and Persons
Emergency
Transitional
Safe Haven
Total Number of
53
87
2 86 228
Households
Total Number of
Persons
59
go
2 92' 243
Total Number of
88
2 86 229
Veterans53
Gender
Ethnicity
Race
Emergency TeamW=W-tWe f4ven`
Female 4 7 d 4 15
Mile 49. 81 21 02 '214
Trans—pender 0 0 0 0
NW-HispanictNoO,-
Lqbn 6
liispaniainc
am
50 80 2 ?9 211
3 8 0 7 to
Emergency -rF2nSMM21
27 48
22
53 1 129
Black orAftican-
22
35
1
27
as
lam can
Asian
6
1
Q
0
i
American Indian or
3
it
3
8
Alaska Native
NOW HWffaiian or
1
Q
Q
1
00W Pacific IsWnder
Mulliple Daces
tl
2
Q
3
5
13. Describe, briefly, the jurisdiction's plan for the investment and use of available resources
and describe the speck planned action steps it will take over the next year aimed at
eliminating chronic homelessness.
As part of the Broward County Homeless Consortium, the City takes part in on -going
communication with HIP and local homeless advocates to consider funding options
those cities may incorporate into the Annual Action Plans. Additionally, the County
has hired a consultant to prepare an updated report on the status of the County's
homeless population with action steps to consider.
14. Describe specific action steps to address the needs of persons that are not homeless
identified in accordance with 91.215(e).
15. Homelessness Prevention —Describe planned action steps over the next year to address the
individual and families with children at imminent risk of becoming homeless.
Barriers to Affordable Housing 91.2200)
16. Describe the actions that will take place during the next year to remove barriers to
affordable housing.
The City continues to support affordable housing efforts by focusing on the grants
available through the CDBG, SHIP, HOME and NSP programs. By partnering with
Broward County Home Consortium and Florida Housing Finance Authority, the City
is able to refer residents for home ownership counseling and lender's programs as a
way to negate predatory lending. The City also has lender requirements which must
be met in order to fund individual requests for assistance to ensure fair housing
practices.
The City of Tamarac is a participating member of the Broward Housing and
Community Development Task Force which allows for participating agencies to
share commons barriers to affordable housing and important resources to
overcoming them. The Task Force addresses foreclosure prevention, fair housing,
incentives, homebuyer assistance and any other topics related to housing and
community development.
23
Additionally, the City currently has several incentive strategies for builders and
developers working with affordable housing programs that target very low, low and
moderate households.
Incentive Strategies:
• Permits, as defined in s. 163.3164(7) and (8), for affordable housing
projects are expedited to a greater degree than other projects.
• The City expedites the processing of affordable housing permits through a
pre -application conference.
• Affordable housing projects are identified by sales price consistent with
the SHIP program's housing value limits.
• The building and Community Development Departments have employees
that serve as liaisons with developers of affordable housing to assist in the
permit process.
• Affordable housing projects are stamped "EXPEDITED."
Other Actions 91.220(k)
17. Describe the actions that will take place during the next year to address obstacles to meeting
underserved needs, foster and maintain affordable housing, evaluate and reduce the number
of housing units containing lead -based paint hazards, reduce the number of poverty -level
families develop institutional structure, enhance coordination between public and private
agencies (see 91.215(a), (b), (i), (j), (k), and (l)).
The City has been working with Broward County to create an Affordable Housing
Policy. This policy will lay out the City's plans to foster and maintain affordable
housing, ensure future housing needs are met and development is in coordination
with the City's Comprehensive and Consolidated Plans. In addition to the long-term
goals of the policy, the Housing Division will continue to provide lead -based paint
assessments and abatement on properties identified and containing hazards.
The City participated as a member of an "Affordable Housing Website Users Group"
committee initiated by Broward County Housing Finance to create a website
incorporating all local, regional, state and federal resources. The website is
intended to give residents a starting point to identify resources including but not
limited to: grant programs, housing counseling agencies, foreclosure prevention
programs, tenant based rental programs and projects, and education and outreach
events. The website is a work in progress and the City intends to continue as a
member to offer feedback and ideas to improve the availability of resources to the
residents of Tamarac as well as the local community.
24
18. Describe the actions to coordinate its housing strategy with local and regional
transportation planning strategies to ensure to the extent practicable that residents of
affordable housing have access to public transportation.
Throughout the year, City staff participate in several community events, outreach
efforts, educational workshops, public service announcements, and invitational guest
speaking opportunities at various communities, boards, organizations, non -profits,
and for -profits to assess the needs of the community and share information with the
residents of Tamarac as to the availability of funds
Several members of City staff are members of general local government planning
boards, committees and sub -committees at which county -wide coordination is
reached on issues pertaining to planning, transportation, housing, community
development and neighborhood revitalization.
CDBG 91.220(l) (1)
1. Identify program income expected to be received during the program year, including:
• amount expected to be generated by and deposited to revolving loan funds;
• total amount expected to be received from each new float funded activity included in this
plan; and
• amount expected to be received during the current program year from a float funded
activity described in a prior statement or plan.
Program Income is only generated when a previous recipient of CDBG funds breaks
the terms of their deferred loan and repayment is due to the City. The City's Home
Rehabilitation activity is the only activity in which funds are issued as a deferred
loan.
Recapture Terms/Affordability Period for the Housing activities are as such:
Deferred loan secured by a lien against the property for a period of ten (10) years
with zero (0) percent interest with a principal reduction of twenty (20) percent
beginning in year six. At the end of the tenth year, the loan is forgiven. The pro-
rated repayment is due upon the sale or transfer of the property or if cash equity
is taken out within the ten (10) year loan term.
The City's loan documents provide that the obligation for repayment shall
continue for the entire recapture terms even in the event of the death of the
homeowner. The obligation to repay funds during the recapture period in the
event of the sale of the property, or due to failure to comply with the obligations
as stated in the loan document shall transfer to any heir or beneficiary of the
deceased property owner.
25
The sale, transfer of ownership of the Property, refinancing of the Property with a
cash payment to the Owner -Occupant, or the Owner -Occupant's vacation of the
property as a primary residence during the ten (10) year term of the Agreement
shall constitute a default. The prorated amount of the principal balance of the
Deferred Payment Loan that is remaining to be paid at the time of the default
shall be payable, in full, to the City of Tamarac.
2. Program income received in the preceding program year that has not been included in a
statement or plan.
No CDBG Program Income has been received over the past year.
3. Proceeds from Section 108 loan guarantees that will be used during the year to address the
priority needs and specific objectives identified in its strategic plan.
4. Surplus funds from any urban renewal settlement for community development and housing
activities.
5. Any grant funds returned to the line of credit for which the planned use has not been
included in a prior statement or plan.
6. Income from float funded activities.
7. Urgent need activities, only if the jurisdiction certifies.
8. Estimated amount of CDBG funds that will be used for activities that benefit persons of low -
and moderate income.
All CDBG funds will benefit low -moderate income persons, households or areas.
It is proposed that $226,628.00 will be allocated to Home Rehabilitation for low -
moderate income households, and $53,385 will be allocated to Public Service
activities for low -moderate income persons.
HOME 91.220(l) (2)
In FY 2002, the City of Tamarac became a member of the Broward County HOME
Consortium along with the Entitlement Cities of Tamarac, Margate, Deerfield Beach,
Sunrise, Lauderhill, Plantation, Davie, Pembroke Pines, Miramar and Coconut Creek
which recently joined the Consortium. The United States Congress passed the
National Affordable Housing Act In 1990. This Act created a variety of affordable
housing programs, including the Home Investment Partnerships Act (HOME).
26
With the additional HOME funds, the City can increase the resources available for
home rehabilitation. An additional three to four homeowners can be assisted
because of fiscal year 2014/2015 HOME funds.
Participation in the Broward County HOME Consortium also provides advantages
beyond additional funding. The consortium allows the cities to collaborate on best
practices, share knowledge, leverage resources, and exchange technology on the
provision of affordable housing. The ultimate and cumulative advantage of
participating in the consortium is the enhanced capacity of the consortium members
to provide their residents with affordable housing. The added values of quality
housing in these cities include the ability to attract new businesses and working
families and a reduction in code compliance issues that can translate into reduced
crime and vandalism. In May 2009, the City of Tamarac renewed their commitment
to the Broward County HOME Consortium by entering into a new three years
Interlocal Agreement.
City Staff is able to provide the residents with direct access and assistance in the
applying for, and processing of HOME funds.
Describe other forms of investment. (See Section 92.205)
If grantee (PJ) plans to use HOME funds for homebuyers, did they state the guidelines of
resale or recapture, as required in 92.254.
HOME funds are typically allocated to Home Rehabilitation; however, with the
receipt of NSP3 funds, the City may re -allocate a portion of its HOME funds to
homebuyers in the form of Down Payment Assistance. Should this occur, the City
will incorporate resale or recapture guidelines similar to those outline in the City's
Local Housing Assistance Plan (LHAP).
2. If grantee (PJ) plans to use HOME funds to refinance existing debt secured by multifamily
housing that is being rehabilitated with HOME funds, state its refinancing guidelines
required under 24 CFR 92.206(b).
3. Resale Provisions -- For homeownership activities, describe its resale or recapture
guidelines that ensure the affordability of units acquired with HOME funds? See 24 CFR
92.254(a)(4).
Should HOME funds be allocated to homeownership activities, the recapture
guidelines will be as follows:
Terms of the award; Recapture and Default.
Include pay back terms in the event of default (failure to make required payments
on a loan secured by a first mortgage which leads to foreclosure and/or loss of
property ownership).
27
Deferred loan secured by a lien against the property for a period of ten (10) years
with zero (0) percent interest with a principal reduction of twenty (20) percent
beginning in year six. At the end of the tenth year, the loan is forgiven. The pro-
rated repayment is due upon the sale or transfer of the property or if cash equity
is taken out within the ten (10) year loan term
The City's loan documents provide that the obligation for repayment shall
continue for the entire recapture terms even in the event of the death of the
homeowner. The obligation to repay funds during the recapture period in the
event of the sale of the property, or due to failure to comply with the obligations
as stated in the loan document shall transfer to any heir or beneficiary of the
deceased property owner.
The sale, transfer of ownership of the Property, refinancing of the Property with a
cash payment to the Owner -Occupant, or the Owner -Occupant's vacation of the
property as a primary residence during the ten (10) year term of the Agreement
shall constitute a default. The prorated amount of the principal balance of the
Deferred Payment Loan that is remaining to be paid at the time of the default
shall be payable, in full, to the City of Tamarac HOME program.
4. HOME Tenant -Based Rental Assistance -- Describe the local market conditions that led to
the use of HOME funds for tenant based rental assistance program.
If the tenant based rental assistance program is targeted to or provides a preference for a
special needs group, that group must be identified in the Consolidated Plan as having an
unmet need and show the preference is needed to narrow the gap in benefits and services
received by this population.
5. If a participating jurisdiction intends to use forms of investment other than those described in
24 CFR 92.205(b), describe these forms of investment.
6. Describe the policy and procedures it will follow to affirmatively market housing containing
five or more HOME -assisted units.
7. Describe actions taken to establish and oversee a minority outreach program within its
jurisdiction to ensure inclusion, to the maximum extent possible, of minority and women, and
entities owned by minorities and women, including without limitation, real estate firms,
construction farms, appraisal firms, management farms, financial institutions, investment
banking firms, underwriters, accountants, and providers of legal services, in all contracts,
entered into by the participating jurisdiction with such persons or entities, public and
private, in order to facilitate the activities of the participating jurisdiction to provide
affordable housing under the HOME program or any other Federal housing law applicable
to such jurisdiction.
8. If a jurisdiction intends to use HOME funds to refinance existing debt secured by multifamily
housing that is rehabilitated with HOME funds, state its financing guidelines required under
24 CFR 92.206(b).
28
HOPWA 91.220(l) (3)
The City of Tamarac is not a recipient of HOPWA funds.
1. One year goals for the number of households to be provided housing through the use of
HOPWA activities for: short-term rent, mortgage, and utility assistance to prevent
homelessness of the individual or family, tenant -based rental assistance, units provided in
housing facilities that are being developed, leased, or operated.
Include any action plan information that was not covered by a narrative in any other section. If
optional tables are not used, provide comparable information that is required by consolidated
plan regulations.
Section 3
The City has a Section 3 Plan which is included in all solicitations utilizing federal funds
incorporated Section 3 language.
Under the Home Rehabilitation Program in 2014, with the next General Contractors
solicitation, Section 3 determination will be made a part of the award process. General
Contractors will be asked to complete the Section 3 Business and/or Resident
certifications.
Additionally, the City has consultants under the Neighborhood Stabilization Program —
Round 3 within the "vicinity hiring" guidelines. A realtor located in the City of Tamarac
was selected to assist with acquisition, property management and disposition of NSP3
properties. A local lawn maintenance company was also selected to maintain the lawns
at NSP3 properties while owned by the City.
City staff will continue to attend local Section 3 training improving the incorporation of
Section 3 into grant funded projects.
Davis Bacon
In addition to creating the above Section 3 Plan, the City recently completed its Davis
Bacon Plan. All solicitations incorporate Davis Bacon requirements when federally
funded. CDBG funds have been allocated to the installation of sidewalks over the past
3-5 years. Davis Bacon activities took place ensuring compliance on these jobs. Staff
attends the award conference notifying the contractor of its Davis Bacon obligations and
conducts on -site interviews with labor personnel confirming labor standards are being
met.
29
Fair Housing
Fair Housing in the City of Tamarac is promoted during community events, workshops,
and as part of the one-on-one housing counseling at the staff level through Broward
County Housing Authority and other local counseling agencies.
The Fair Housing Plan consists of updating the City's Analysis of Impediments,
conducting Fair Housing educational outreach sessions, distributing Fair Housing and
Predatory Lending educational materials, and publishes several Public Service
Announcements. The City continues to be an annual sponsor of the local Fair Housing
event sponsored by H.O.P.E. Inc.
Additionally, the H.O.P.E. Inc. Discrimination Hotline phone number has been added the
City's website and it published in the City's Tam -A -Gram newsletter once per year.
The City maintains an annual Scope of Work Agreement with H.O.P.E. Inc. for all its
Fair Housing initiatives and needs. Tamarac has an updated Analysis of Impediments
on record which was reviewed and approved by HUD's Fair Housing and Equal
Opportunity office. During FY 14/15 the City will contract with H.O.P.E. Inc to prepare a
new Analysis of Impediments. This Analysis will be completed prior to the submission
of the City's next Five -Year Consolidated Plan.
30