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Home My WebLink About1988-04-19; Housing & Redevelopment Commission; 99; Revised Admin. & Equal Opportunity Housing PlanHOUSING AND ‘-f aDEVELOPMENT COMMISSI --V - AGENDA BILL w ic u -d AW gg TITLE: REVISED ADMINISTRATIVE AND EQUAL DEPT. HD. b MTG, 4119188 OPPORTUNITY HOUSING PLAN FOR DEPT. RED CARLSBAD HOUSING AUTHORITY RECOMMENDED ACTION: If Housing and Redevelopment Commission concurs, your action is to adopt Resolution No. 105 approving the revised Administrative Plan for the City of Carlsbad Housing Authority subject to the final approval of the U.S. Department of Housing and Urban Development in Los Angeles. ITEM EXPLANATION From time-to-time it becomes necessary to update the Housing Authority Administrative Plan because of changes received from the Federal Government regarding definitions, formulas, and policies to handle the Section 8 Existing Housing Program. Included in the last two years were several major changes which made it necessary to rewrite and expand the Administrative Plan: 1. Definition of family revised 2. Pilot program for Vouchers 3. Occupancy standards revised 4. Outreach to minorities revised 5. Portability The new Administrative Plan submitted to you, with the unanimous approval of the Housing and Redevelopment Advisory Committee at their January meeting, contains the needed changes and provisions to insure the adherence of the Carlsbad Housing Authority to the current HUD regulations. We are submitting the revised Administrative and Equal Opportunity Plans to be forwarded to HUD - Los Angeles. I FISCAL IMPACT: None EXHIBITS: l- Resolution No. 105 approving the Administrative Plan and Equal Opportunity Plan to be forwarded to HUD - LA 2- Copy of the Administrative Plan 3- Copy of the Equal Opportunity Plan a . . RESOLUTION NO. 105- A RESOLUTION OF THE HOUSING AND REDEVELOPMENT COMMISSION OF THE CITY OF CARLSBAD, CALIFORNIA, FORMALLY APPROVING THE REVISED ADMINISTRATIVE AND EQUAL OPPORTUNITY PLANS OF THE CARLSBAD HOUSING AUTHORITY. WBEREAS, the Housing and Redevelopment Advisory Committee recommends approval of the revised administrative and equal opportunity plans of the Carlsbad Housing Authority and the Housing and Redevelopment Commission concurs with that recommendation: and WHEREAS, the plans have been submitted in the current and revised versions incorporating the latest recommendations of the U. S. Department of Housing and Urban development. NOW, THEREFORE BE IT HEREBY RESOLVED, by the Housing and Redevelopment Commission of the City of Carlsbad, California, as follows: 1. That the above recitations are true and correct. 2. That the Housing and Redevelopment Commission approves the revised Administrative and Equal Opportunities Plans. 3. That the Commission directs the Housing and Redevelopment Director to forward the aforementioned plans to HUD for comment and approval. PASSED, APPROVED, AND ADOPTED at a regular meeting of the Housing and Redevelopment Commission held on the 19th day of April, 1988 by the following vote, to wit: AYES: Commissioners Lewis, Kulchin, Pettine, Mamaux and Larson NOES: None ABSENT: None ABSTAIN: None ATTEST: (SEAL) DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (HUD) SECTION 8 EXISTING HOUSING ADMINISTRATIVE PLAN CITY OF CARLSBAD HOUSING AUTHORITY 2965 Roosevelt Street, Suite B Carlsbad, California 92008 (619) 434-2810 1 l.Draft 9/87 TABLE OF CONTENTS Page SECTION I: PROGRAM FUNCTIONS A. Statement of Overall Approach B. Statement of Objectives C. Housing Stock SECTION II: PLANS FOR ADMINISTRATION OF PROGRAM FUNCTIONS A. B. C. D. E. F. G. H. I. J. K, L, M. N. 0. P. Q. Outreach to Families Outreach to Landlords and Owners Landlord Eligibility Suspension of Intake of Preliminary Applications Pre-applications Intake, Applicant Definitions, and Eligibility Determination Verification of Income and Determination of Total Tenant Payment Certificate or Voucher Issuance Housing Quality Standards and Inspection Lease Approval, Voucher and Housing Assistance Payments, HAP Contract Execution Payment to Owners Review of Family Circumstances, Rents, Utilities, and Housing Quality Termination and Family Moves Special Claims by Owner Re-admittance to the Housing Program by Formerly Assisted Tenants Portability of Certificates/Vouchers Complaints and Appeals Monetary and Program Performance SECTION III: BUDGETING AND STAFFING 26-27 APPENDICES: A. Organization Chart B, HAP Register Card C. Policy on Requests to Move, and Notices to Move D. Procedures to Move E. Appeals Procedures F. Carlsbad Housing Authority Budget 1 1 1 2 2 3 3 4 4 4-7 8 9-10 10-13 13 14 15- 17 17-21 21-24 24 24-25 25 25-26 SECTION I: PROGRAM FUNCTIONS A. STATEMENT OF OVERALL APPROACH The Carlsbad Housing /-\uthori.ty is committed to providing rentai assistance to very-low income families, the elderly, the hand- icapped and disabled, in order that they may obtain affordable7 decent. I ~.afe and sanitary housing in the City of Carlsbad. The Carlsbad Housing Acrthoritv (CH&) i.s guided by the Housing Assis- tance Plan of the Count.y of San Diego, and cooPerate with the San Diego Association of Governments and all the other titles of the region to encourage region-wide use of Federal and State housing funds and programs. ‘The CHA operates as a separate agency within ‘the structure of the municipal government of the City of Carlsbad. The governing body Of ‘tP163 CHA is the Carlsbad Housing and Redevelopment Commission C CHRC ) , and communit.y input is received through the Housing and Redevelopment Advisory Committee. e. SP’ATEMENT QF CIB JECTIVES The CHRC through the efforts of the CHA hss the foll.o,wi.ng ob,jcc- tives: 1. Provide rental assistance ‘to eligible households by adhering to this Udministt-ative Plan and the governlng Federal/St,ate laws and regula Lions. 3 *^* Improve Carlsbad’s housing stoc!< by using as a base the HUD Housing Guali ty Standards (HQS) to pr-omote more safe, decent and sanitary housing opportunities. 3. Promote the goals of Equal Housing Opportunity. I. Maintain at least a. 95 percent lease-up rate. 5” In a city: whose population is in a state of flux, promote household stabj li ty for Secti.on 8 participants. C. HOUSING STOCK Historically, the housing stock in the City of Carlsbad has been predominantly single-family residences. Mult.i-family rental units have been confined to limited areas within the city. Ther-e exists a shortage of affordable and acce&, ccible housincr for low and very- .~J Tow i.ncome famil3.cc, and senior ci. tizens. Presently ther-e is a surge of activity to construct senior housing which will tem- porarily relieve the latter- shortage. Ulso ~ the e~ty i.5 underta!i-- ing various projects, some with Federal assistance or municipal bond f undi. ng , which may increase the availabil.ity of housing for low-i ncome households. The scarcity of three and four bedroom rental. units in the ci.ty which rent a.t or below the Fair- Ma.rket Rent (FMR’s;) requires that the CHN work closely with owner-s and landlords in a,n attempt to maint.ain the availabiLity of such housing. This includes advising eligible property owners of resident i.al rehabil i tati.on programs a.nd other- .funding as it becomes available. Included in the city’s housing stock alWe sever-a.1 mobilehome parks which are mostly occupied by senior- cit.izens. SECTION II: PLANS FOR ADMINISTRATION OF PROGRAM FUNCTIONS ‘The Housing Authority will administer the prc.gra.m with Housing Author- ity staff and will comply with the Equal Opportunity Housing Plan (ECNIP) with regard to equal opportunity in hclusing and in the employ- ment 0.f staff, as detailed in the EOHF. The Housing Auth0rit.y will &tempt to comply with all. applicable state a.nd federal laws and regulations and administrative directives promulgated thereunder, in admi.ni stcri.ng the Set Lion 8 Rental Assistance Payments Program, the Rental Rehabilitation program and the Housing Voucher program. The Hnusl.ng Authority is committed to providing renta. assistance Lo ver-y-low income families in compliance with current U, 3. Department of Housing and Urban Development CHUD’, regulations and adminlstra.tlve 2 , practices. In the areas where the Housing Author-it#y has discretionary powers, the policy will be incorporated into the Administrative Pr-ac- tzces Handbook, 7420.7 and a copy provided 'to the HUD area office. A. OUTREACH TO FUMILIES In order to meet our- outreach goal the CHA sha.111 inform the public of the availability and nature of the Section 8 Housing program wi. th news releases and advertisements in the local newspapers and information releases to the local radio and television stations. We will also distribute information to all appropriate community organisations. Enrollment by acceptance of preliminary applica- t-ion5 normally exceeds the program's capacity to assist eligible households. In addition, special outreach programs are activated as community housing needs are identified. B. OUTREACH TO LHNDLQRDS HND OWNERS _. 'In order to promote participation by owners of rental units within all the geographic areas of Carlsbad, the CHU will make general announcements through the local press regardiny the availabi li ty of Section 8 Program assistance, will make available informational brochures, accept unit listings from landlords, and refer eligible families to landlords. Efforts will be made to ensure that landlord or owner inquiries receive an immediate response from the CHA. To keep the supply of rental units as large as possible, a continuing effort will be made to reach owners, realtor-s, and managers of units outside areas of low income tot+ minority con- centration. 3 !.~Lit-7dlQt-d5i are ineligible to par-tici.pate in the Section 8 Certifi- cate/Voucher- program if they have units constructed under the HUD 202 funding program, or if the landlord is guilty of .fr-aud in t;he Section 8 Program, as defined in the PWA contrC3ct. $QPEN$IoN OF INTAKE OF PRELIMINURY APPLICU'TIONS Application intake may be suspended if the waiting list, in the .judgement of the CtiA1 is so long that additional applicants would not be able to r-zceive a certificate during the following year. No ti.ce of suspension will. be placed in local newspapers or the intake announcement may specify a closing date. There ic; one exception to the suspenzsion, persons being di.splaced by government action, whether elderly or family, will be permitted to apply any time and will be issued the next available certificate in the category and number of bedrooms required. The PHA will monitor the outreach activities to assure that the applicant pocl. per bedroom size is adequate to i ssue unused Certificates, including those given up by participants leaving the program and that outreach activities are reaching targeted groups such 3% the elderly or low-income and minority families in a cost effective way I E - PRE-APPLI~ATIUN INTAKE ..,...... T!... _. . ..I u??.l-..rc?.eNT !Y?E.ElcJ4.T:T:$oPJs L.. Ar?D El ICIBILITY ..,.._.,. ._.. .._.... 7" ._..,. Y!....... ...,... ~~~~~~~~~~~~~~~~~~~~~~ g.ty ,....,...,-.., .,....,.,..,,,.,,,.,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,.,,,,,.., ,,,,,,. ,.,.,-,. ,,...,-.. .,...,_,..-. ,.,-,.., ,,..,,,,_, ,,,,, ,,,,,,,,,..,,,,.,,,._,,.,, ,,,, ,,,,. ,,,,,,..,,..,,, ,_,,.,, .., ....,. .,.. ., ,, ,,.,, ..,,. ,,,,,,,,,, ,, ., .,,,.,,.,,..,..,,, 1. Pi-e-application Intake: Acceptance of Preliminary Appllcatlons will be opened whenever the current waiting list does not provide enough applicants to meet the need o-f the CHA, When there is an open enrollment period, a news release as well as a legal notice will be published in the local newspaper-s. T he 1 eqa 1 notice2 will include the starting date of the enrollment period, identify the bedroom categories available ~ and give a 4 br-1e-f description of the program's requirements. The CHA will make every effort to receive and process preliminary applications in a manner which treats all applicants consistently. Preliminary applications may be requested by telephone or in person, c:omplet8d atr. the office or other intake site, or returned by mail or in pet-son later. All applications will be: a) time stamped and dated as received and b) registered and numbered in the Daily Journal. 2. Applici3nt Definitions Uny household is permitted to submit a preliminary applica- tion for the Section 8 programs. In order to be accepted for the waiting list, a household must. meet the following requirements: A ., FAMILY-two or more pet-sons sharing residency whose income and resources are available to meet the family's needs and who are related by blood, marriage or opera- tion of law (or who give evidence of a stable r-elat3.on- ship which has existed over a period of time).. 8. Persons displaced by government action, or federally recognized disaster. I'- rJ ., Elderly household, persons age 62 or over, disabled/- handicapped by definition of the Social Security Administration. Non-related elderly, handicapped, or disabled persons may be considered an elderly household, D. Single persclns-only single per-sons who are elderly (including disabled or handicapped), displaced, or a remaining member of an a r-;sic,ted family are eligible. Un applicant not maet.ing the criteria far being placed on the Waiting list will be sent a letter allowing them ten (10) days to furnish the CHA proof that they do meet the above mentioned requirements for participation in the program,. If 5 proof is not -submitted within ten days, then the preliminary application will be placed in the "Ineligible" file. Preliminary applications will be sorted into two categories: A. City residents and applicants with full-time jobs in the city of Car-lsbad, and 8, Non-resident app1icant.s. In addition all applicants will be sorted by priority and bedroom size, and if apparently qualified, then placed on the waiting list. Non-residents applications will be placed at the end of their respec- tive Waiting List and proce ssed when the resident applications are exhausted x If the non-resident applicant establishes residency, the application will be moved to the resident list accordxng to its date and time stamp. Changes in household st,ructure, whxch affect which bedroom size list the applicant is on, will also be placed on that list by using the date and time stamp. In order to e-,tabli.sh residency, an applicant must reside indepen- dently within the boundaries of the city of Cat-lsbad for at least one month. Non-residents who are employed within the boundaries of the city of Carlsbad at a full-time job will be placed on the Resident Waiting list.. RLl applicants will receive a ls%tet- acknowledging their applica- tion and giving them their category and priority. There are two types of priority applicants that will be recog- nized. The highest priority will be given to persons displaced by government action or federally recognized disasters. These applicants will be accepted regardless of enrollment period being open or closed. The second highest priority will. bE? granted to Veteran=/Ser-vicemen. This category is broken down into the foll.owing order of priority: 6 al Gold Star parents or spouse bj Service-connected Disabled Veterans or their wzdows. c) All other Veterans/Servicemen Cwomen) with Honorable Dis- c barges and active clu tv in excess of 90 days. All other preliminary applications are placed on the waiting list according to the date and time of application. Applications will. be reviewed by the CHA semi-annually to determi.ne if the applicant 1.5 still interested in the Secti.on S Programs. Applicants will. be instructed to check with the CHA intermittently, advise the office o-f changes in address, telephone, family structure, or income sources, and will be given ample opportunity to remain active on the preliminary application Wai.ti.ng list. 3. Eligibility Determination: When an applicant reaches the top five, on the Waiting list, an interview will be scheduled by the CHA staff. The applicant will be asked to provide proof of household composition and to sign third--party income verification forms. The CHA will strictly adhere to the third-party procedures to verify i.ncc+mE, assets, and medical/unusual expenses, No certificate or voucher will be issued until all third party verifications have been received and reviewed by the CHA, or one of the exceptions provided in Section 1I.F is used, When an applicant is found to be eligible ,for the Section 8 Program they will be promptly notified. Those Found ineligibl,e will be notified by letter, including an explanation the reason for their ineligibility, and informed of their right a hearing within ten (10) days of the notifioation. UpFLicants placed on the “Inactive” or "Ineligible" list have the right to informa. hearing. 0 f to an F 1 VEl?I~:~~&TION QF INCOME AND DETERMINUTION OF rwrm TENANT PAYNEI’JT 7 All income, assets, and medical/unusual expenses will be verified by the use of third-party verificat,i.ons. The applicant. will be notified of their eli.gibi.li.ty by letter and an interview for certification will be scheduled. The applrcant will be required to sign an “Uuthot-ization to Release Information” form which wi II. be forwarded to the providing agency with a self-addressed (CH&) stamped envelope - The only exception to thi”; third party verif ic- ation procedure will be when t-.here is: 1) Non-response by the provzder) or 2) when information is unobtainable due to cir- Curnstances beyond the participants or CHH’s control (fire, flood, etc...). In those i nskances I ,the CHA wi1.1 verify the information by viewing check stubs, bank statements, or other pertinent information provided by the appli.cant, or the CHA wi.l.l contact third parties by telephone or lett.er in an at.tempt to verify the information. The least desirable method of verification (except for imputed assets) will be by self-declaration. This last form of verifica- tion will be used only when all other options have been exhausted. Once all income, asc,ets, and medical/unusual expenses have been verified and the applicant is folrrid to be eligible, the proper calculations will be completed to determine the Total Tenant Payment (TTP! 1 For Certificates, the Total Tenant Payment will be the greater of 30% of the monthly adjusted income or 10% of the Unad,,just.ed Monthly Income I For Vouchers, the Total Tenant Payment will be the greater of 10% of the Unadjusted Monthly Income, or 30% of the Ad,]usted Monthly Income p.&,.~l~.::;.the amount of rent in excess of the applicable Payment, Standard for Vouchers. For mobilehome space rental assistance, a spec i al work-sheet. wi’l. 1 be used following HUD formulas to deterrnine the owners paymen’t. AlI. ca.lct~ln tions will be verified by another member- of the staff for accuracy. I (J _ CERTIFICUTE OR VOUCHER ISSUANCE 8 Certificate or Voucher-s that are available will be issued to the next applicant on the appropriate Waiting List by bedroom size. Neither Certificates nor Voucher-c, will bar! issued to an applicant until they have been found eligible and hhe Total Tenant Payment has been calculated. If an elig1bl.e applicant 1s offered a certificate due to the lack of an available alternative (a Voucher) and decli.nes the certificate, the applicant: wi.11 still retain their- position on the Waiting List. When an appropi-late Voucher becomes available that applicant will be offered the Voucher. If the Voucher is declined, then the Applicant will be placed on the Inactive list. Whenever possible, Certificates or Vouchers will be issued on an individual basis and the applicants briefed personally by a CHA staff member. THe applicant will be given an information packet including: 1. 2. 7 4). 4. 5, 6. 7 " 8. 52 * LO. Housing Discrimination Complaint Form Fair Housing USA and Lead Base Paint Warning Procedures Landlord Contact Sheet Certificate/Voucher Instructions Sample Lease and Contract Request for Lease Approval (RLA) Housing Quality Inspection (HGS) requirements Landlord Information Brochure Business Card of CH& staff membaer Informal Hearing Procedures The applicants will be briefed in detail on the Certificate/ Voucher requirements and limitations. The applicant will be informed in writing as to any applicable deadlines for submitting documents and how to obtain an extension on time on the Cer-- tificate/Voucher if they are unable to obtain housing during the initial 60 day life of the Certificate/Voucher. In order for the 3 applicant to receive an extension of time on their Certificate/ Voucher- they must submit a r-eques% for” extension one week prior to the expiration date,. This must. be done by submitting a completed Landlord Contact Sheet; which ~a.5 provided to the applicant in the Get-tifi.cate/Voucher packet a’t. his/her briefing. This docurnen t must. be presented to the CHA a. minimum of sever? ( ‘7) days or five (5) working days prior to the expirat.ion date of the Certificate/- Voucher along with the aforementioned request for an extension. H. !-jOUsING QLIALITY STANDARDS AND INSPECTIONS When an applicant finds a potential rental unit, the landlord/ow- ner will be asked to submit the Request for Lease Hpproval (RLA) form which was provided in the information packet given to the applicant.. Upon receipt of the RLU, the CHA will conduct an init.i.al. inspection of the rental unit. In the case of the applicant, thi.s unit. may be either their current place of reside-, nce or an entirely di.fferent unit. A Housing Assistance Payments Contract or Lease Chgrement may not. be execut.ed or renewed unless the rental unit passes the HQS inspecti,on (HUD Form 52580) I If t.he rent.al unit fails the HQS inspecti.on ,’ the property owner wil.l. be noti.fied and gi.ven thirty (30) days to correct all the deficiencies, If the owner refuses to make the necessary repairs the applicant or tenant will. be sent writ.ten notif icatzion t.hat the unit. is not accept.able for the applicant or that r-ental a ssistance will ter-mlnate within thirti/ (JO) days for an exist,ing Section 8 Tenant. In the latter case, the property owner will be glven written noti.fication that the Housing Assistance Payments contract will be terminated and rent payment;s wil.1 cease at the end of thirty (30) days, The tenant will be issued a current Cert.ificat.e/Voucher in order to locate suitable housrng. A tenant mav irelinquish, in writing to the CHA, their Certifi- cate/Voucher and pay the total rent if they chose not to move from a unit which did not pass the HQS inspection. Cinnual re-inspec- ti.on of units wi.1.3. be conducted approximately thirty days prior to t-he recertification date of the Section 8 tenant. During this initial contact period between the newly Certificated applicant and Lhe potential landlord, the CHA encourages the landlord to eJcre8n the applicant in the same imanner as any other applicant the landlord would consider-. The CHA considers the voluntary participation of the landlord to be basic to tha Section 8 program. 1. Occupancy Standards: The CHA will. apply the current occupancy standards for units of the following indicated bedroom size: BEDROOM SIZE _.. .,.__........_ -_,-_-._.- ___.._ -..- MINIMUM PERSONS MAXIMUM PERSONS -_.--...-_.- _......_ - ._._..........-... ._...._.._..._.._._..............~...~...,......,.,..,...~...,,., ” ._.......... O-BR 1 1 l-BR 1 4, Z-BR 2 6 3-RR 4 8 4-BR 7 LO NOTE: HQS standards allow two (2) persons per living/ sleeping room and would permit the above maximum occupancies, assuming a living room is used as a li.ving/sleepiny area. In issuing the certificate/voucher, the CHU will determine the appropriate size unit by applying the following criteria: a. The bedroom size assigned should not require more than two persons to occupy the same bedroom. b ., The bedroom size assigned should not require persons of the opposite sex, other than husband and wife, ‘to occupy the same bedroom other than infants and ver)/ young children. c. A couple expecting a chi1l.d will be given the largest bedroom sx ze posse ‘ble when that bedroom size is avail- ab1.e * The ,fact that they are expecting should be noted in the file with the expected deliver-v date. d, Children under the age of one ‘year shall occupy the same bedroom as their single parent. This arrangement. will. continue until the child reaches the age of three years. Nt the recertification following the third birthday of the child, a larger certificate wil.1 be issued when available. P .,d. Children under the age of four shall occupy the same bedroom as siblings of the opposite sex also under four, This arrangement will. continue until the sixth birthday of the eldest.. child. At the recert.if ication following the chil.d’s sixth birthday., a larger cer%ificate will be issued if available. f. Given the guidelines above, Certificates/Vouchers will be issued in the largest bedroom size to which the f am i 1. ‘y i s entitled when available. Y- Due to the limited number of S-bedroom Certificates, the CMB does not allow three persons to have a J-bedroom Certificate (i.e. a mother with a teenage son and 12 daughter kJould qua lify for a 2-bedroom Cer-t ificate because the mother and daughter could share a bedroom) I h. A maximum of ten (10) persons are allowed t.o have 4- bedroom certificate based on HUD standards a.llowing not more than two persons per 1 iving/sleeping rooms and assuming the living room of the unit to be used as such. The foregoing guidelines are set. forth solely for determining the bedroom sire to be designated on ,the Certifi.cates of Eligibility, The regulations provide that the family may rent a larger dwelling unit provided the rent to the owner plus any allowances for utilities and other services does not exceed the Fair Market Rent IFMR) for the bedroom size designated on the Certificate of Eligibility. The family ma.y rent a small. bedroom size unit provided the unit meets the standards of acceptabi1it.y regarding living/sleeping rooms. The CH& wi.1.1 grant excepti.ons from the standards if the Housing Authority determines the exception is justified by the relationship, age, sex, health or- handicap of family members or their individual circumstances. Other circumstan- ces may include, but will not be limited to large families who have difficulty locating large units, The CHA will notify the family that exceptions to the unit size standards may be granted and ,the circumstances under which the gra.nt of an exceptjon will be considered. I, LEASE APPROVAL ~ VCIUCHER .... Hl‘r,Q H\GlJSIN.G. .NS$.STUNCE PUYMENTS I. HAP c:QNTRACT EXECUTION ._ Reasonableness of contract rent on exis.ting units shall be det.ermined from data maintained by the CHA. Such data shall be based on survey information okatained by the CHA to determine that the contract rent for each unit for which a lease has been approved is reasonable in relation to rents currently being cha.rged for comparable units in the private sector, and not in excess of rents currently being charged by the owner for com- parable unassisted units. Staff will certify Rent Reasona.bleness for each individual. lea,se applicable to Section 8 (Existing) Housing #Assistance Program. Rent Reasonableness is not a criteria used in the Voucher program, Prospective landlords may be briefed on the Lease and Contract by telephone or i.n person. A follow-up letter is sent. If re- quested T a sample of the Lease, Contract, and related documents are also sent. All documents are annotated for easy reference. Once a prospective landlord submits a Request for Lease Approval, the unit is reviewed for Rent Reasonableness. An HQS inspection is scheduled. The Tenant is informed at the time of the inspec- tion if the unit passes.. If the unit meets HQS, the tenant is scheduled for a lease-briefing interview. The tenant is given a complete review of the lease provisions as well. as the conditions of the Certificate/Voucher. The tenant is told of his/her financial responsibility to the property owner for any pro-rated rent amounts. ,.J * PAYMENTS TO OWNERS A high priority for the CHA is the issuance of the HAP portion on time and in an accurate manner. ‘The control for HUP payments is the HAP Peqis,ter (Appendix B). The register is updated as needed and all changes are batched for entry into the computer. Each month the updated Request for Warrants are generated and the City of Carlsbad Finance department prepares the HAP checks and Financial Reports (as scheduled). 14 K. All tenant; files that are changed are routed through the HAP Register system prior to the execution of the change. UT1 monetary changes are noted on a Request for Warrant and for-Iwarded to the Finance Department for check issuance. Normal H&P payments ar-e mailed on or before the -first day of the month. "f'he Finance department is responsible to independently review and audit all HAP payments on a periodic basis. F?S'IEW OF FAMILY CIRCUMSTANCES ........... ....... .... ................... .............. .................. ..... 2 RENTS .................. ... . UTILITJES ......... .................. .... .L UND HOUSING ...................... ...... .......... QUALITY ..... ...... ................ All tenants are recertified annually. Interim r-ecertifications are made bJhf3t-i there are family composition or income changes which may affect Certificate/Voucher bedroom size or Gross Family Contribution. Nn annual recertification list is prepared 12 weeks in advance of the contr-act renewal date. The tenant is scheduled for an initial recertification inter-view, the case is reviewed, the appropriate Information Release forms are signed by the tenant, and they are advised of the recertification interview when all the Information Release forms are returned to the CHA by the appropriate agencies. An HQS inspection will be conducted prior to t,he Amendment of the Contract. The landlord and tenant are notified immediately if there are any deficiencies in the HQS inspection and the landlord is reminded of the impending recer- tification by mail and of the procedures for requesting an annual increase of rent. HQS deficiencies must be corrected in order for recertification to be completed. Special Review of Family Circumstances: icat ions wi 11 be conducted when one of the fo3 Interim recertif ing occurs: low- 1. U tenant reports changes in household income or composition, 2 x The CHA is made aware of changes in household income or- composition by a third party, or 3. The case fi.le is flagged for quarterly review due to unstable household income or composition, The determination of an in.ter-im recertifi.cation must make at least a $10 dollar difference in the Gross Family Contribution in order to warrant the executi.on of an Amendment to the Lease and Con- tract. The effective date of change due to an Inter-im Recer- ti.fication wil.l. be the first day of the following month, if the review ic, completed by the 15th of the current month. If it is determined that a tenant failed to report changes in household circumstances which warrant a change, in a timely manner, the change will be made retroactive to the first day of the month following the change. If the possibili.ty of tenant fraud is encountered, the tenant will be given the opportunity to r-equest and complete sn informal hear i ny I If the hearing determination is that ft-a[Jd was commit- tee. assistance to the tenant wi? 1 terminate immedia,tely. Simultaneously, a termination wi.l.l be issued to the landlord/own- er- I ‘If %he CHA has overpaid HAP payments due to a failure of the tenant to report a change in circumstances in a t.imelv ma.nner, the amount of the overpayment will. be recovEred by the CHN in one of the following ways: 1. If the overpayment is less than or equal to one montbl ‘c; HHP payment I the CH& may deduct the atmount from the following month’s HAP payment por-tion. 2. If the overpayment exceeds one month’s HAP payment, the tenant may make monthly payments until the overpayment is recovered. 16 If the tenant ic; to make payments, a record of the payments wi.11 be kept in the tenant file. The tenant will be asked to sign a note in a form approved by the City At.torney of Carlsbad. No payment schedule will exceed twenty-four (24) months. No interest will be charged on t,he overpayment, amount I The tenant has the right t;o appeal the overpayment recovery action. L, TERMINATIQN AND FAMILY MOVES Terminati.on of Tenanc,y is governed by the following requirements for the Section 8 Existing Housing Program: 1. Termination of tenancy by owners in accorda.nce with state and l.ocal laiws for the following rea5oncJ: a, Serious or repeated violations of the t.erms and coridi-- tioris of the lease by the tenants, b, Viol.atioi-35 of Federal) State. or local laws which directly relate to t.he occupancy or use of the unit or common areas, or c . Other good cause. Other good cause includes: a . Not accept.lng an offer of a new lease, b ,. U tenant history of disturbance t.o neighbars, destruc- tion of property or habitat which results in damage t.o the unit, c 2” Criminal activity by tenants physical violence, 17 i n v 0 1 v ing crimes of d ” The owner desires to use the unit for personal use (after the 1st year of the lease) ;, or e. A business Or economic reason such a5; a sale of the pt-operty , renovation, or the request, for a rent higher than the CHH can approve (after the 1st year of the lease ) I To terminate the lease the OliJner must give the tenant and the CHA wr-itten not.ice of the intent t.o terminate the lease, and comply with state a,nd local laws. 2. Termination of Tenancy by the Tenant The tenant may termina,te the tenancy after the firc,t year of the lease. Terminations during the first year of the lease are allowed only if the owner agrees to release the tenant from the lease, or if the lea,se provides for such termination with nctice. The tenant must give the owner notice in compliance with ‘the lease terms. The owner-‘% lease may not require more than 60 days noti.ce _ The tenant milst notify the CHA of its intent.ion to terminate and whether or not the tenant desire,5 assistance in another location, 3. HAP Cont,ract Terminations HAP contracts may end automatically or- be terminated by the CHA z. Once a HAP contract is terminated no WAP payments may be made and the CHA does not earn an admlnIstrative fee. A MAP contract ends automatically if the tenant moves frsm the unit or- the owner evicts the tenant. HAP Contracts may be terminated by the CHA for the following reasons: a. The ownei- is not in compliance with the terms of the HAP contact (before terminating tenanc:y for this reason the owner wi 1 I be given an opportcrni ty to take corrective actions), b. The owner has com~m i t ted f r au d i c I The CHA termi.nates assistance to the tenant., or d. The tenant is required to move from a. unit which is ei t.her underoccupied or over-crowded according to HUD occupancy standards ,, If the CHA terminates the HAP contract, the CHA will. give the owner and the tenant at least 30 days not:ice, and state in the notice the reason for the termination. the effectitde date, the deadline for submitt.ing special claims, and t.he tenan t.s responsibi.1.i.ty to pay the full amount of the rent, if staying in the unit. The CHA may termin8.t.e assistance to the tenant for reasons including: a ,. The tenant is guilty of program abuse or fraud - b. The t.enant. violates their oblxgations under the program I P 4” The tenant refuses to repay the CHA for amounts due under a signed agreement for special claims paid t.o t.he owner by the CHA on the tenant,‘5 behalf: or d, The tenant.‘5 TTP is suffi.cient t.o pay the full gross rent and one year ha.5 elapsed since t.he CHA’s last IlAP payment was made. (The unit remains under, t-l&P contract. for a full. year unless ‘the tenant moves). The CHU must give the ownet- and the tenant a 30-day wi-x tten notice of termination which states the re.asons for the t e r-m i n a t i 0 i-i , the effective date of the termination, t.he tenant.‘55 r i g PI t t 0 iC”f3CjlJESt a.n informal hearing, and the 13 tenant:~; responsibility to pay the full. rent to the owner if they remain in the unit. Terminatxon of assiskance does not automatical I.$,+ affect the tenant's right to remain in occupancy wxthout Section 8 assistance. The owner may offer a new lease to the tenant or continue the current lease. In cases w h d r-e no subsidy is being paid because the tenant's TIP covet"s the gross rent and the HAP contract. has not been terminated, the CWA Cl3 restart HAP payments if less than one year has elapsed since the date of the Last HAP payment ,3nd the tenant notifies the hO~J5it’~g office that thei.r income has been reduced (or- gross rent increased) to the point that the tenant's TTP no longer covers the gross rent. The CHA may issue a new Certifi.cate/Vouchcr to a current par- ticipant for bJhc>m no HAP payment is being made if the tenant meets the criteria described in the precedil>g paragraph, and the tenant qualifies as a very low income fami.l\! (or the CHR receives HUD approval to i ssue a new Certi-fIcate/Voucher- to 3 lower income family). If more than one year has elapsed since the last HAP payment 1 the family must reapply to receive further- assistance. Family Moves=,: Ut briefings, participants will be provided information regarding their responsibility to give the landlord and t. he CH{'? advance notice of any moves, The r-encal aqrcement includes a statement to that affect and information given to the tenar7t after the lease is executed reiterate5 th:~s obligation. The CHB requires a wri'trten notice SO-days in advance by the tenant or the landlord of anticipated changa in terms of t.he lease, or a signed statement. by the landlord /'tenant as to receipt of such noticz.. In order to request a move, tenants must foll.ow the pro- cedures &outlined in the "Policy Regarding Request for I*love Wi.thin Jut-isdictian" (See Appen3j.x C),. During the first 12 months of the term of the Lease and Contract, the tenant may only request to C[IOVE! for good cause ( i.e. , heal.th reasons, substandard conditions, discrimination, et.c...). After the ini ti.al 12 month5 of the laase, t he t e n d n 2, may t e r III i n a .t e t he lease by giving a 30-day notice. The ' ' p r- I:? c e d u r e 5 to move Within the Boundaries of the Ci.ty of Carlsbad" will be issusd to tenants requesting information on how t.0 move (see Appendix P). M * SPECIAL CLAIMS BY OWNER Owners participating in the Section 8 programs are not required to collect a securi try deposit 7 but are enc,oul-aged ta do 50, The maxlmum security deposit the owner may collect is the greater- of the tenant's TTP Or $50 dollars. The owner may retain the security deposit collected previously for a tenant who lea~ec, in place ~ even if the deposit is greater than the amount permitted by t h e Section 8 regulations, If the Owner dcss net cellect a security deposit, the CHA's liability for special claims is reduced by the amount the owner c0ul.d have collected j The HAP contract permits the Owner to bill the CHA for tenant damages and unpaid rent not covered by the 't e n a n t ' '3 5 ecu r i t:g deposit. Whet-l the tenant vacates the unit the owner must first apply the 5ecuritg deposit I PlUS any interest accrued, to t;he unpaid rent and damages, If the amount of the tEnant's securit;> deposit exceeds the charges, the owner must return the balance of t;he security deposit to the tenant in accordance with state and/or local law I 1f the securitp deposit is insufficient to eo\~er- the charges, tt1e owner- must atrtempt to collect any additional monies from the tenant. If the tenant fails to reimburse the oWner for unpaid rent. and/or darnages, the owner may c.1ai.m reimbursement from the CHA. The maximum CH& liability is the lesser of the amount owed to the owner or two month's contract rent minus the security deposit the owner actually collected or could have collected. If, after the owner receives a payment from the CHA, amounts are collected fron the tenant which would reduce the CHA's payment., the owner must repay the Cl-!&,. Vacancy Loss Payments, as provided in the HAP contract, allows the owner to bill the CHA for vacancy losses bJhet’I the family Vacates in viol.ation of the lease. An owner who evicts a tenant is also entitled to receive vacancy loss payments if the owner complies; with the terminations provisions of the HAP contract and state and local laws. When the tenant vacates, the owner may keep the housing assistance payment received for the month in which the tenant vacates, and bill the CHN for 80% of the contract rent for (a vacancy period not to exceed one additional month or the termination of the lease, whichever comes first (assuming the unit is not re-rented). If the rainily vacates in accordance with the lease (i-e, gives proper notice) ~ no vacancy loss claim can be made, To be eligible for a vacancy loss claim the owner must immediately notify the kCHA of the vacancy, take all feasible actIons to fi3.1. the vacancy, not reject eligible applicants except for gclod cause, and not be eligible for payments for the vacated unit from some other source (i.e. the tenant's security deposit, insurance, etc...). Processing C.laims for- Damages ,' Unpaid Rent and Vacancy Losses 22 Once a unit is vacated by the tenant and a. move-out inspection has been conducted, an Owner may submit a claim for unpaid rent, payment for a vacated unit, and/or %.enant-caused damages U A claim by the owner will be reviewed for compliance wit.h the HHP contract by at least twc; CHA staff members. ‘The tenant will be given the opport;uni ty to respond a.s to the vali.dity of the claim. Documen- tation f r-cm the owner which should accompany the claim includes: Vacancy lo ss--official notification ta the CHA of the vacancy and pr-onf Lhat- the owner has taken reasonable action to fil.l the vacancy and has not rejected eligible applicants except for- good cause. (Jnpaid rent and/or damages - should include proof that a security deposit was collected plus any interest accrued as required by state and/or local law. Invoices or other doc!.Imsntati.on should be presented to support the coasts of repairing tenants damages. A Rent Ledger or court judgement may be used to dccument unpaid rent I Non-payment by the tenant. may be documented with evidence of billing and non-payment. 1.f it is found that the claim by the owner is v,z.lid, the CHH will calculate the amount due using the Special Cla:Lm worksheet I and forward for paymerlt processing the fo’l..lowlng month. ‘I’ he te n:i n t i 5 responsible for reimbursing the CHU for any amounts paid on a damage claim. Failure by the ‘tenant to reimburse the CHf4 for the damage claim may provide grounds for the denial of issuance of a n e w c e r t I f I. c ,3 t e t c3 m c v e I if the tenant has an outstanding debt I If the tenant has signed an agreement. t,o pay money owed the CHA and they breach the agreement 1 the CHA may terminate assistance for ‘the breach of contract. 2pecia.E cl.aims by the owner under the l-i&P Contract must be sub- mi t.ted to t,he CH& in writing within 60 days of the date the 23 vacancy occurred. Industry standards will be used to determine reasonable repair/replacement costs. N. RE-ADMITTANCE TO THE HD!&It'lc; PR.C<;Rfii'l .g\, ,~,.~RMERC.Y,,.,A~S~S7E.D ,.-l"~,NUNTS When a tenant is found ineLigible for the program because the Total Tenant Payment (TTP) exceeds the gros rent at the annual re-examination, the tenant wil.1 be removed from the program.. “r he tenant may request. a re--evaluation within twelve months of being removed from the program. If the tenant circumstances change within twelve months of being removed from the program, and they are found ,to be eligible for assistance, the next available Certificate/Voucher of the correct bedroom size will be issued to them. If a tenant, requested termination of a ssistance and then requests re-admittance to the programs when less than sixty (60) days have elapsed, then the former tenant will be placed at the bottom of the Waiting List in the appropriate category. 0” PORTABILITY OF CERTIFICATES/VOUCHERS U key element of the Section 8 Existing Housing Programs is that the subsidy is tied to the family not to the particular unit. 'The intent of both Certificates and Vouchers is to give the tenant access to the widest range of housing resources. HLJD encourages mobility of participants through inter-jurisdictional agreements in both the Certificate and Voucher programs. Special portability provisions exist only for the Housing Voucher program. Voucher port.ability will be explained in the briefing session for the Voucher holders. The CHA will allow up to 15% of its l-lousing Voucher holder-s to move to other jurisdictions. Tenants who chose to move to other jurisdictions will be restricted to one (1) move in a twelve month period. 24 If a Housing Voucher holder from another jurisdiction moves within the Jurisdiction of the CHA, the housing authority will either- is;sue a tiousincl Voucher (if available) to the prospective tenant, or bill the PHA in the other Jurisdiction for the applicable ad- ministrative fees and the HUP payments. The CHA would hope in the reverse circumstances that the PHA in the other jurisdiction will work with the housing staff to obtain the same type of financial assistance program cooperation, P. QJ(YP,,-~J,r~,~.$.. (.‘iMQ ,,,,, (‘$.PEULS Complaints by tenants or owners 1wil1 be directed to senior staff members of the CHA for resolution. Such staff will either advise complainant or re-fer them to the other resources or agencies as appropriate,. In accordance with HUD regulations, applicants shall be given written notice of CHA decision or actions which result in the denial of listing on the CHA Waiting List, issuance of a Certificate/Voucher, or participation in ,the programs. Sur-h , notice shall also state the applicant may request. an informal review of the decision/acti,on and will instruct appl.icant on the procedure to obtain ,t.he review. Informal reviews shall be in conformance with procedures establrshed by the CHA (See Appendix E). All complaints that can be resolved without termination of assistance or adverse impact on the tenant will be resolved ir~formally, All complaints will be verified by sta,f,f, The tenant or owner will be advised of the complaint in wt-it.ing and a response requested within ten (10) days. If the complaint. carlno’t be resolved informally, ,formal procedures will be used and the tenant given the opportunity to r espond and/or appeal t,he acti on . . (See Appendix E for tippeals Procedure). MONITORING AND PROGRAM PERFCIRMAN’-‘E ..... ..... ....... ............. .............................. ................................................ ..?!. ...... Program monitoring will be done by a senior member of the CHA staff X Records will be kept on the following: 1. Total Number of leases compared to Total Allocation per month, 2. Number of Certificates/Vouchers available per month, 3. Number of Lease/Contracts which are 10% over FMR per month, 4. Total number of moves within jurisdiction per month. Staff will also maintain any other statistical data which may be needed to evaluate program performance for the City of Carlsbad or HUD - SEC’TION III: BUDGETING AND STUFFING The CHA budget is incorporated within the budget for the City of Carlsbad I Budgetary requests are prepared within the guidelines determined by the City of Carlsbad (See Appendix F). The Cit.y of Carlsbad hires employees who are then assigned to the CH&.. The present personnel assignment is a8 follows: 1. Housing and Redevelopment Manager I 10% 2. Housing Program Administrator, 100% 3. Housing Management Analyst 100% 4. Housing Specialist I, 100% cz J” Clerk Typist I, 100% Staffing will be adjusted as needs increase or decrease. The CHA will negotiate service agreements with the City of Carlsbad to provide services to the CH& as needed. The agreement includes expenses incurred by the City for processing HAP payments, professional services 26 provided the CWA, legal setvices, payment of utilities, rent, and costs incurred by the City to aid in the administration of the Section 8 programs, 27 I Equal Opportunity 1 CX-16-E077-001-009 C.~-16-~--0;;-001 Equal Opportunity Housing Plan Name of PHA: CARLSBAD HOUSISG AND REDEVELOPMENT CO~I?lISSION Address: 2965 RooseL-elt Street, Suite B, Carlsbad, CA 92008 -- Street O-BR Number of Units: Program Type: [Xl l-BR 169 City State Zipcode 2-BR 3-BR G-BR 90 44 27 Esisting Housing (Voucher) Moderate Rehabilitation Existing Housing and Moderate Rehabilitation Signature of Person Submitting Plan Ffike Brooks Name (Type or print) Housing Program Administrator Official Position City of Carlsbad I I Equal Opportunity Objective I - Outreach to Lower-Income Families Actions to be taken: The following items are applicable to the Existing Housing and Moderate Rehabilitation Programs 1. 2. 3. 4. 5. Media to be used (name and type): Radio - KKOS, Carlsbad, Community News Blade Tribune, Oceanside, Daily & Sunday Newspaper Carlsbad T.V., Cablevision, Carlsbad, Community Spots Other suitable means to be used to publicize program: Brochures, English and Spanish Posters - Social Service office bulletin boards Flyers - Social Service agencies Letters - Key people at Industrial Center, Flower growers, etc... Group or groups less likely to apply, if any: a) Persons from the black community, especially the elder or handicapped/disabled. b) White families, both parents employed but below income limits. Special outreach to groups identified in 3: a) Flyers, distributed at Food Commodity Distribution Center. Presentations at Senor Center. Article, Senior Newsletter. b) Poster, School nurses' office, Posters, 'employees room In- dustrial Center. Special outreach to persons expected to reside, if identified in HAP; -- -. City of Carlsbad [- Equal Opportunity 1 The CHRC will circulate information of its program through the follow- ing community organizations and offices: Women's Resource Center North County Centro de Information Community Action Council Oceanside Dept. of Public Welfare Social Security Office Carlsbad Senior Center Family Service Association Carlsbad Chamber of Commerce Lifeline Motor Vehicle Dept. Carlsbad School District Office Post Office, Carlsbad Boys and Girls Club Women's Club Mira Costa College Community Mental Health Carlsbad Library Carlsbad Police Dept. All Carlsbad Churches CLB Business Associates Objective II - Promoting Greater Housing Opportunities for Families Outside Areas of Low-Income and Minority Concentration Action to be Taken: The following items are applicable to the Existing Housing and Moderate Rehabilitation Program: 1. Media to be used to notify owners about the program(s): (name and type 1. Same as #l, page 1. Person to person contact, telephone contact. Luncheon presentations to Rotary, Kiwanis, Lions Club, Board of Realtors and Apt. Owners association. 2. Actions to encourage participation by owners of units outside low- income and minority areas (not applicable to Moderate Rehabilita- tion Programs if targeted to a specific neighborhood(s): Owners' information brochure mail-out to local Realtors, Brokers and property managers listed in telephone directory. The CHRC would also use the property owners list used by the water depart- ment. 3. Actions to explain program requirements including Equal Oppor- tunity to owners: Public presentations to large groups. The CHRC staff will be available to answer all inquiries made by owners in person by 3 -- I City of Carlsbad I Equal Opportunity telephone, in both English and Spanish, Article in Apt. Owners' association periodical. 4. Information on local, State and Federal Fair Housing laws and use of Form HUD-903 to be provided as follows: Poster in English and Spanish, posted on bulletin board in housing office, Fair Housing brochure included in each briefing packet. Discrimination complaint forms available in both English and Spanish at housing office. Staff available in Eng/Span to help individual complete form. Interpreter list available for those needing help in other languages. These items are applicable only to the Existing Housing Program: 5. Information on general locations and characteristics of neighbor- hoods and on listings, to be provided to Certificate Holders as follows: Locations of schools on map. Locations of churches on map.. Parks and recreation areas are identified on maps. Bus system schedules, and stop locations, available. 6. Actions to be taken to assist Certificate/Voucher Holders during housing, search, when requested: List of available housing posted on bulletin board. List of par- ticipating owners available. Printed owner's Brochure in both English and Spanish. Searcher given staff cards to present to owner. Staff will make telephone calls for searcher in English/ Spanish. Transportation available for disabled. 7. Actions taken to promote broadest geographical choice in selection of units by Certificate Holders, if any: Transportation system explained. School information available. If brochure of apartment complex available it will be given to searcher. Awareness of new shopping center location, also awareness of school locations. 8. Geographical areas in which PHA's Certificates may be used: City of Carlsbad is area of operation. Portability, (voucher holder) will be explained to the searcher. This is the ability for a Housing Voucher holder to move from the jurisdiction of its current PHA to the jurisdiction of another PHA. Objective III- Ensuring Equal Opportunity to Applicants for Participa- tion in the PHA's Existing Housing or Moderate Rehab- ilitation Program and in the Selection of Certificate Holders or Applicants to be Referred to Owners of Vacant -~ __ --____-. &diE.L P- 3s ha bi-1 i t a ted U n i t s l Actions to be taken: 1. System for taking, processing and filing applications; establish- ing waiting lists: a. b. c. d. e. f. 8. h. e. Application intake period announced. Pre-Application completed. All pre-applications date stamped, time stamped and numbered as received. Grouped into BR size as per date and number of application. Telephone inquiry card made for each applicant. Applicant notified in writing eligible or inel,igible. Applicant also notified he must keep application current and contact office at least every 60 days. Applicant made aware of current income limit changes. Veterans and families of veterans have preference. 2. Preference or pfiority categories in order, if any, for issuance of Certificates and method used for selection of Certificate Holders or applicants to be referred to owners of vacant moderate- ly rehabilitated units: CHRC Not in rehabilitation program In selecting applicants from the waiting list, the PHA shall use the Section 8 Certificate waiting list for the Housing Voucher program. A Family may not be penalized for refusing a Certificate if it desires to wait for a Voucher. However, if the Family then refuses the second form of assistance when it is offered, the Family shall be taken off the waiting list. If the Family requests, it will be reinstated on the waiting list in conformance with the PHA's approved Administrative Plan or Equal Opportunity Housing Plan. Objective IV - Provision of Services and Assistance to Families That Allege They Have Encountered Discrimination During Their Housing Search Actions to be taken: -___ 1. Services to be provided in finding a unit under the Existing Housing Program: a. b. c. d. e. f. ii: 1. Referral list of participating owners, Referral list of available units. Assistance in telephone calls, English/Spanish. Person to Person contact with owner. Letters, on behalf of family, written to owner. Explanation of program to owner. Fair housing brochure. Assistance in completion discrimination complaint. Assistance in documenting the encounter. 2. Assistance to be given to Certificate Holders or applicants referred to owners of vacant moderately rehabilitated units in the exercise o their rights under Federal, State and/or local law and name of persons responsible for giving assistance; training of these persons: CHRC not in Rehabilitation program. Objective V - Utilization of a Local Fair Housing Organization or Organization Serving the Handicapped The PHA will subcontract with a Fair Housing Organization or Organiza- tion serving the Handicapped in its Existing Housing or Moderate Rehabilitation Program(s). YES NO X Name of Organization Services to be provided by this Organization a. b. 6 City of Carlsbad 1 Equal Opportunity C. d. e. f. ObJective VI - Promoting Employment Opportunity in the PHA's Employment Practices - Existing Housing or Moderate Rehabilitation Programs 1, Existing or proposed staffing pattern by position, race/ethnicity, gender, and salary. (Asterisk staff members employed by PHA in other programs prior to making application for the Section 8 - Existing Housing and/or Moderate Rehabilitation Program.) 10% Housing Director White Ital/Amer Male $ 100% Housing Administrator White American Male $ 100% Management Analyst White Mex/Amer Female $ 100% Housing Specialist I White Mex/Amer Male $ 100% Temp. Clerk/Receptionist White Mex/Amer Female $ 25% Inspector White American Male $ 2. Actions to be taken to promote Equal Opportunity in employment practices. a) Copy of affirmative action plan available at your request. b) Affirmative action goals and timetables analysis monthly report made to monitor current equal opportunity status. Objective VII- Equal Opportunity for Participation in the Moderate Rehabilitation Program of Minority and Section 3 Businesses 1. Actions to be taken in developing and maintaining lists of local minority and Section 3 Businesses: Our Community Development Block Grant funded Rehabilitation programs maintain tracking systems for minority and low-income businesses and job generation respectively. Both Commercial and Residential Rehabilitation grant and loan programs update and verify this information. City does not participate in the Moderate Rehabilitation Program. 7