HomeMy WebLinkAbout2019-03-07; Housing Commission; ; CARLSBAD PUBLIC HOUSING AGENCY ANNUAL PLANThe City of Carlsbad Housing & Neighborhood Services
A REPORT TO THE HOUSING COMMISSION
DATE: February 21, 2019
SUBJECT: CARLSBAD PUBLIC HOUSING AGENCY ANNUAL PLAN
I. RECOMMENDATION
Staff: Bobbi Nunn
Housing Program Manager
Item No.1
That the Housing Commission ADOPT Resolution No. 2019-001, RECOMMENDING that the Community
Development Commission APPROVE the Carlsbad Public Housing Agency (PHA) Annual Plan for Fiscal Year
2019 for submission to the U.S. Department of Housing and Urban Development.
II. BACKGROUND
Housing & Neighborhood Services administers the federally funded Section 8 Rental Assistance Program
for the Public Housing Agency in Carlsbad, which is more specifically known as the Carlsbad Housing
Agency. Pursuant to code of federal regulations (CFR) 24 Part 903, a Public Housing Authority (PHA) is
required to submit a 5-Year and Annual Plan. The 5-Year and Annual PHA Plan provide a basic guide to
PHA policies, rules, and requirements concerning the PHA's operations, programs, and services. In
addition, the Plan advises HUD and members of the public the PHA' s mission and strategies for serving the
needs of low-income and very low-income families for the next five years. The 5-Year Plan covering fiscal
years 2015 -2019 was approved by the Community Development Commission on April 7, 2015.
The PHA Plan and any revisions of the plan must be formally adopted by the PHA Board of Commissioners
or other PHA officials. The Community pevelopment Commission is the governing board for the Carlsbad
Housing Agency.
III. DISCUSSION
The Draft PHA Annual Plan is available for public review and comment prior to the Public Hearing and
adoption by the Community Development Commission. The public review period will end on April 9, 2019,
and the Public Hearing is tentatively scheduled for April 9, 2019. All public comments received on the draft
PHA Annual Plan will be addressed and included in the final documents that will be submitted to HUD.
CARLSBAD PUBLIC HOUSING AGENCY ANNUAL PLAN
FEBRUARY 21, 2019
The PHA is required to identify any PHA Plan elements that have been revised since the last Annual Plan
submission. The following areas are addressed:
• Deconcentration and Other Policies that Govern Eligibility, Selection, and Admissions; and
• Financial Resources.
Further, the PHA needs to indicate the progress in meeting the goals and objectives identified in the last 5-
Year PHA Plan that was adopted on April 7, 2015. The purpose of the 5-Year PHA Plan is to identify goals
and objectives to serve the needs of low-income (under 80% of the area median income -AMI}, very low-
income (under 50% of the AMI}, and extremely low-income (under 30% ofthe AMI} families for the next 5
years.
The goals are:
1. Expand the supply of assisted housing;
2. Improve the quality of assisted housing;
3. Increase assisted housing choices;
4. Promote self-sufficiency and asset development of families and individuals; and
5. Ensure equal opportunity and affirmatively further fair housing.
Once the Plan is approved, the following documents are required to be submitted with the PHA Plan
template (Form HUD-50075-HP):
IV.
• Form HUD-50077-ST-HCV-HP, PHA Certifications of Compliance with the PHA Plans and Related
Regulations (which includes all certifications relating to Civil Rights);
• Form HUD-50077-SL, Certification by State or Local Official of PHA Plans Consistency with the
Consolidated Plan or State Consolidated Plan; and
• Resident Advisory Board (RAB) comments and a narrative describing the analysis of any
recommendations and decisions made regarding the recommendations.
STAFF RECOMMENDATION
Staff recommends that the Housing Commission adopt Resolution No. 2019-001, recommending that
the Community Development Commission approve the Annual PHA Plan for Fiscal Year 2019 for
submission to the U.S. Department of Housing and Urban Development.
V. EXHIBITS
1. Housing Commission Resolution No. 2019-001
2. Annual PHA Plan (Form HUD-50075-HP) for Fiscal Vear 2019
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HOUSING COMMISSION RESOLUTION NO. 2019-001
A RESOLUTION OF THE HOUSING COMMISSION OF THE CITY OF
CARLSBAD, CALIFORNIA, RECOMMENDING APPROVAL OF THE
CARLSBAD ANNUAL PUBLIC HOUSING AGENCY (PHA) PLAN FOR
FISCAL YEAR 2019 AND AUTHORIZATION TO SUBMIT TO THE U.S.
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
WHEREAS, the Housing & Neighborhood Services Department administers the Section 8
Rental Assistance Program for the City of Carlsbad's Public Housing Agency (PHA); and
WHEREAS, the U.S. Department of Housing and Urban Development (HUD) has issued
regulations requiring PHAs to submit 5-Y ear and Annual Plans consistent with the City of Carlsbad's
Consolidated Plan and local objectives; and
WHEREAS, federal regulations provide that the 5-Y ear and Annual Plans must be adopted
by the Board of Commissioners of the Housing Agency and submitted to the U.S. Department of
Housing and Urban Development.
NOW, THEREFORE, BE IT HEREBY RESOLVED by the Housing Commission of the
City of Carlsbad, California, as follows:
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1. The above recitations are true and correct.
2. That based on the information provided within the Housing Commission Staff Report,
the Housing Commission ADOPTS Resolution No. 2019-001, recommending to the
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HC RESOLUTION NO. 2019-00 I
PAGE2
II
Community Development Commission APPROVAL of the Carlsbad Annual PHA Plan for
Fiscal Year 2019 and authorization to submit to the U.S. Department of Housing and Urban
Development.
The Housing Commission hereby recommends that the Housing & Neighborhood Services
Director be authorized to execute all appropriate documents required for the submittal of said
Annual PHA Plan.
PASSED, APPROVED, AND ADOPTED at a regular meeting of the Housing Commission
of the City of Carlsbad, California, held on the 21 st day of February 2019, by the following vote, to
wit:
AYES:
NOES:
ABSENT:
ABSTAIN:
ALAN NEWMAN, CHAIRPERSON
CARLSBAD HOUSING COMMISSION
DEBBIE FOUNTAIN
COMMUNITYANDECONOMICDIRECTOR
( City of
Carlsbad
,•• . .
Annual Plan for Fi s cal Year 2019
Purpose. The 5-Ycar and Annual Pl-IA Plans provide a ready source for interested parties to locate basic PH/\ policies, rules, and requirements concerning the
1'1-IA's operations, programs, and services, and informs HUD, families served by the Pl IA, and members of the public of the Pl IA 's mission, goals and
objectives for serving the needs of low-income, very low-income, and extremely low-income fam ilies
Applicability. Form I-IUD-50075-1-IP is to be completed annually by lligh Performing PIIAs. PHAs that meet the definition of a Standard l'HA, Troubled
Pl-IA, I-ICY-Only Pl-IA, Small PI-IA, or Qualified PH/\ do not need to submit this form.
A. PHA Information.
A.I PHA Name: CARLSBAD HOUSING AGENCY -HOUSING & NEIGHBORHOOD SERVICES
PHA Code: CA077
PHA Type: 0 Small [8] High Performer
PHA Plan for Fiscal Year Beginning: (MM/YYYY): 07 /2019
PHA Inventory (Based on Annual Contributions Contract (ACC) units at time of FY beginning, above)
Number of Public Housing (PH) Units not applicable Number of Housin g C hoice Vouchers (HCVs) 726 baseline
Total Combined 726 units
PHA Plan Submission Type: IZ] Annual Submission □Revised Annual Submission
Availability of Information. In addition to the items li sted in this form, PHAs must have the elements listed below readily
available to the public. A PHA must identify the specific location(s) where the proposed PHA Plan, PHA Plan Elements, and all
information relevant to the public hearing and proposed PHA Plan are available for inspection by the public. Additionally, the
PHA must provide in formation on how the public may reasonably obtain additional information of the PHA policies contained in
the standard Annual Plan, but excluded from their streamlined submjssious. At a minimum, PHAs must post PHA Plans,
including updates, at each Asset ManagementProject(AMP) and main office or central office of the PHA. PHAs are strongly
encouraged to post complete PHA Plans on their official website. PHAs are also encouraged to provide each resident council a
copy of their PHA Plans.
Location(s) where the public may obtain copies of the 5-Year and Annual PHA Plan:
Main administrative office of the PHA:
• City of Carlsbad
Housing & Neighborhood Services
1200 Carlsbad Village Drive
Carlsbad,CA 92008
Main administrative office of the local, county or State government:
• City of Carlsbad -City Hall
City Clerk
1200 Carlsbad Village Drive
Carlsbad, CA 92008
Public libraries:
• City of Carlsbad
Main Library
1775 Dove Lane
Carlsbad, CA 92011
• City of Carlsbad
Georgina Cole Library
1250 Carlsbad Village Drive
Carlsbad, CA 92008
Other:
• City of Carlsbad
Senior Center
799 Pine Avenue
Carlsbad, CA 92008
PHA Plan Supporting Documents are available for inspection at:
Main business office of the PHA:
• City of Carlsbad
Housing & Neighborhood Services
1200 Carlsbad Vil lage Drive
Carlsbad, CA 92008
D PHA Consortia: Check box ifsubmittin° a Joint PHA Plan and com lete table below
Participating PIIAs Pl-IA Code Progrnm(s) in the Consortia
Lead Pl-IA:
B. Annual Plan Elements
B.t Revision of PHA Plan Elements.
Program(s) not in the
Consortia
'o. or Units in Each Program
Pl-I IICV
(a) Have the following PHA Plan elements been revised by the PHA since its last Annual PHA Plan submission?
y N
D [gl Statement of Housing Needs and Strategy for Addressing Housing Needs.
D [gl Deconcentration and Other Policies that Govern Eligibility, Selection, and Admissions.
[gl D Financial Resources.
D [gl Rent Determination.
D [gl Homeownership Programs.
D [gl Safety and Crime Prevention.
D [gl Pet Po licy.
D [gl Substantial Deviation. D [gl Significant Amendment/Modification
(b) The PHA must submit its Deconcentration Policy for Field Office Review.
DECONCENTRATION POLICY (Excerpt from PHA Administrative Plan)
Local Objectives
Mission of Housing & Neighborhood Services:
Enhance the quality of life and sense of community for those who live in Carlsbad by providing better
connections to city information and services and through focused program development and
implementation, community engagement and outreach services and provision of affordable housing
opportunities.
The Section 8 Rental Assistance Program is designed to achieve three major objectives:
1. To provide affordable decent, safe and sanitary rental housing, of a modest (non-luxury)
nature, for very low-income families.
2. To promote freedom of rental housing choice and spatial deconcentration of very low-income
families of all racial and ethnic backgrounds.
3. To provide an incentive to private property owners to rent to very low-income families by
offering timely assistance payments and annual inspections.
Owner Outreach
The PHA encourages owners of decent, safe, and sanitary rentaJ#ni.ts to rent to Section 8 participants. The
PHA maintains an ongoing list of available rental units and p~~(¢Jiiting owners/property managers. The list is
available in the lobby and is updated on a monthly basis. V~(fi~ijJi~tings from owners/property managers are
received, they will be compiled by the PHA staff by bedriiijiif~Mf~m:I date of availability.
Actions to encourage participation by owners of ~1:!ff~~'j~';:ntal u·:;f~ff~ted outside areas of low-income and
minority areas: {JjjJj!''·· ''%J:I)i,=\,
1. The PHA maintains communication with th~j§~,i Dieg9J~9~.mty AparirnijbtAssociation and local
property management comp~-:ni:~;~· These res8ijf~~~::~@fi~ used to makl:ijwners aware of the
benefits of the Section 8 Rent~tA~!~tance Prograqif(. --
2. In order to expand participati~N'.~{iiJ~~t9.wners whK~htinterested in the program or are unfamiliar
with the program, the Housing P't&graJfM~o~ger wili"'tMhhe prospective owner to explain the
benefits of the S~g,!9ft~._program Mit~nc~~i~s.t:t!t~ir pirt(ij!J:?,~tion.
3. Housing repre~-~6ll·HvJ~wm. attend 16:~~1. ag_~,deyjjW,ji~.Q,mmuHfi:y fairs to increase awareness of the
program and ~inifits for·'.JWb~rs. Ho~sfogfipt~sentatiJgs:wm also participate in Owner
seminars/worki~$.P..~, which:l~f:~ organizdaji{coordination of with other local housing agencies, San
Diego ~9lfflty Ap~rtM~.IJ.t ~$~'.¢j~lic;>_a:,, NortW~9unty Apartment Managers Association, and local
.. •~.;•:•:•:~~:•:•;.;.. .... ~ . ··~❖:-:-;~ ... ~~:-:•:•:•:•:~:•:•:•~,: .. :-:-~:•:❖:/-.. ~=❖=<•: p rop·e:ay::fffafi:agement:c-ompiin ies:=:::::::::~:::;:... ·::::t\
4. _:9w,Jt:n~i~;M~tlijn_:packM~}f:~scribi~lit:~ft?.~.riJfits of the rental assistance program will be available
\,p~nreq u est. ·•:::{:\ltt.. "-'.\\~!\:;., . ·-:'.:::-:-
5. ThEfRBh. will market thl:$..ectio'fqfprogram by conducting Rental Owner workshops for prospective
owneit~~r..iodically to ~f~J~in th~::~ft>gram benefits, especially during periods of low voucher
utilizatiollijhf low vacan'cyfrates.
6. The PHA wifitmn~.e the n:jijij;ia, including newspapers, magazines, internet, television, and radio to
market the Secliqfo~. p_r.9gf:a'm as determined necessary.
The PHA will periodically ;J~/J!f: the distribution of assisted families to identify areas within the jurisdiction
where owner outreach should be targeted.
Family Outreach
Outreach will inform all eligible segments of Carlsbad's population of the availability of the Section 8 Rental
Assistance program. If applicant groups are not reflective of the eligible population, additional outreach
aimed at targeted groups will be increased. The PHA will publicize the availability of rental assistance for very
low-income families in newspapers of general circulation, minority media, and by other suitable means.
Notices will also be provided in Spanish.
In addition, the PHA will distribute fact sheets to the broadcasting media, and initiate personal contact with
members of the news media and community service agencies to utilize public service announcements.
Liaisons have been established with a variety of city and county agencies, private social service agencies, non-
profit agencies and special interest groups. The PHA will communicate the status of rental assistance
availability to the service providers in the community, advising them of eligibility factors and guidelines so
that they can make appropriate referrals.
Payment Standards
Payment Standards are currently set between 90% and 110% of the Small Area Fair Market Rents (SAFMR).
The new Payment Standards calculated based on the SAFMRs vy:~nt into effect on April 1, 2018. The higher
payment standards reflect the higher rents in Carlsbad and indMise the housing options for families in
Carlsbad; therefore, furthering the PHA's efforts for fair tJ~?.:G:@}t~nd deconcentration.
( c) If the PHA answered yes for any element, describe the revision{{J)l~:~Jili~m~nt below:
Financial Resources -CY 2018 (CY 2019 FunJgi :-ot det;:mf'lled)
.-:::=:=:::::::~?:•· ··=::~===~::::::.
Annual Contributions for HCV Program -\(: }$ 6,590,187.
Housing Assistance Payments (HAP) ·•: \\\:;. .-:J:::-,
~::~:~sc;::i~:;~:;::~~!~~:;~=f JW½,-$'':{~t~;:3
·1:~;:;_~.,'._::_:::::;:~_'_:::;:,;·.
1
_:_~_:\?'
Operations ·\\(?tl):::::'.•· _
Total Resources \@t. ····::::tlil$7.,.170,S!li}\;.
B.2 New Activitie_~-::::::::::::::::::;.;-.-. ·-::'.'.::j)\: ... J\)\:\//]:}:;... ·::\},;
(a) Does th~::P:ff'A)mt~~:tJJ~::1;1ndertak~:~fnew actiyifi.~.xelateqJq the following in the PHA's current Fiscal Year?
v N t@Jf tv ---",~'"fi) > ''{f)i:j,\ _ -''''\W{:t, -w
□ ~ Hopi{V:t.or Choice NeigiM~moods.· '.?\\ ..
0 ~ MixecfF;~~ce Modemizatifu.{~r Devefop:fu~t.
□ ~ Demoliti6tilnd/or Dispositiottl\ ·'.((? □ ~ Conversio~'.:w~h:~lic Housing Wi[enant Based Assistance. D ~ Conversion of'P@.U~ Housing f9::J?.roject-Based Assistance under RAD. □ ~ Project Based V oiifh~~-/I? □ 181 Units with Approvecf V~~¢j~J6r Modernization. D ~ Other Capital Grant Prd~~ffif({e., Capital Fund Community Facilities Grants or Emergency Safety and Security Grants). ~-;~:~::=-·
(b) If any of these activities are planned for the current Fiscal Year, describe the activities. For new demolition activities, describe
any public housing development or portion thereof, owned by the PHA for which the PHA has applied or will apply for demolition
and/or disposition approval under section 18 of the 1937 Act under the separate demolition/disposition approval process. Ifusing
Project-Based Vouchers (PBVs), provide the projected number of project based units and general locations, and describe how
project basing would be consistent with the PHA Plan.
B.3 Progress Report.
Provide a description of the PHA's progress in meeting its Mission and Goals described in the PHA 5-Year Plan.
PHA ANNUAL PLAN -FY 2019
PROGRESS IN MEETING MISSION AND GOALS STATEMENT
PROGRESS OF 5-YEAR PLAN GOALS AND OBJECTIVES: FY 2015 -2019
PHA Goal: Expand the supply of assisted housing
O~jective: 1) Leverage private or other public funds to create additional housing opportunities; and
2) Collaborate with private develop ers and non-profit agencies.
• Affordable Housing Construction Assistance -Carlsbad's affordable housing program allows t he City
to assi st in t he development of new affordable housing units; resulting in an increase of the
ava ilability of affordable rental housing that is decent and safe.
PHA 5-YEAR PLAN GOALS AND 2015 2016 2017
OBJECTIVES
Assist in construction of new 0 0 affordable housing.
Juniper at The Preserve
Portola Senior Apartments
Pending Developments:
PHA Goal: Improve the quality of assisted housing
Objective: Improve voucher management (SEMAP score).
64
2018
101
• Designated by HUD as a high-performer for FY 2015, 2016 and 2017.
• Maintained and utilized HAP costs within t he HUD funding allocation.
• Maintained a 100% PIC reporting rate.
• Continually seeking ways to stream line process ing functions.
2019
• Section 8 software conversion is in process to provide a paper-less/hosted product.
Total Units
2015-2019
64
101
PHA Goal: Increase assisted housing choices
• Continue to reach out to owners to increase awareness of the benefits of renting through the rental
assistance program. In addition, contact owners monthly to document any current or upcoming
vacancies. Participate in community events and provide information about the Section 8 Program
and other affordable housing options in Carlsbad.
• Maintain payment standards between 90% and 110% of the SAFMRs for zip codes 92008, 92009,
92010, and 92011 to allow for a broader range of rental opportunities in Carlsbad.
• Worked with non-profit agencies and developers to collaboratively provide affordable housing
options, as outlined in the above table.
• April 17, 2018 hosted a Q&A booth on Section 8 Rental Assistance benefits for property owners at
the San Diego County Apartment Association {SDCAA) E~PO .
. ,Ji~if=~
PHA Goal: Promote self-sufficiency and asset developm~rit:anamilies and individuals .. -✓,i",/'~',/'.,"•/,.",,f,1
• PHA continues to administer the Family Self-SufftiieH~f{fSS) Program for the clients who port in as
an FSS participant. ..::}::,:;.?;:J:-1/· ·•.:\f;~h>
• PHA staff meet with non-profit organiz~.W{1~]ihd support ~~,t~~s agencies to obtain information
about programs and benefits that will m~tft"bte self-sufficienc\l=WN~articipant families. In addition, ,:.•,, ••••• , •• .❖ ..... ,, ..
information is made available in the loBlif;f.o.r the community and=:~,tb.ers seeking resources. ~;~-: .. !<">. ,.,-;? ❖; .. : .. ;}.;.•.
• Staff maintains a Community Resource Direqtg_,:y thc;t~~ijf~aks down se~{:~~s by subject matter, gives -=x·•····· , .. .,, ••. ,,, •• ,,. ....... :-:. •,·.
a brief description of serviceiffJJ_ach organiii~!~iflia provides conta~}nformation.
• Carlsbad Service Center provfeJlifiij!tlt~ining, erifpJJ!ir~1ent preparedness, food distribution, Cal
Fresh application assistance, arfifa'tfffifr.ig:Genter. ·•::t~t\/ .. ?~it\ ·•'.·,..1Wt~i~1t:-::, ·•:\1\tt>.
PHA Goal: Ensure equ~t:9-'~p,;ijtlY,nity and··~ffi,rmati~iM!9.f.~er fa1f:t:~ousing .,·❖"' ..:•:.,:-;-:--:-: .. ·-·l'~:-;,,:.i:,.; .. :~=1/. · ,: .. ~/ .. "..;.. .t .. ; .. ~:-;❖: .. ~:•' .~ .. :.?:❖:,--;~.. "./'
• Fair housing t?.~J~·ual 'op~girunit~ in'.f:~f1wi,~:~•,is pr:(W}~f:.d !n pro~ram a~d move br~efing packets
• Have a contra~t~J!.h Legal '1t~; Society o.fif~h Diego; to provide Fair Housing counseling and
landlord/tenant ··mtdiation .for, residents of.t~rlsbad. ·-:~:=::~:::-.. >:=:::~:::~:=:=:~:.,~ .. -··~~:::::.-.
• Leg~,k:N~i~tsi@.~Y pr6V:~~~%!)]:f.:air::!tlgH~!ng wq;~~~hop for staff and tenants on July 11, 2018.
• ~~ttifkrils=c%t~fY:::W.ill prtia~ an adJitJ#,Q~t.FJi'PHousing and new housing laws workshop on ,,.:;;:; .. :•:-:x· .......... -= .. =-~=~-~ ·.i:•::=-::-:~-.. • .... _.: ..... :•:•:~-:,~ :-E~e6ruary 27 2019•:❖:-. '·,:•Z•Z·. '•'.❖;.'.❖:•· ';¾fit,.. ' . ,,,ft,. ·•:eyltb,,. .,,.,.,
PHA Goal: En~ri~ the_needs ·a:itret of:~\Wd ~nd ~dult victims of domestic violence, dating violence,
sexual assault otJ!~.lkmg per V'lflt/: A Reauthor1zat1on Act of 2005
• Staff adviseqjf@Jputside r;@9urces available to child or adult victims of domestic violence, dating
violence, ancf'§~~l;,l.~I as~.iWf or stalking.
• Staff has been cfffJ?t~~iWprovide referrals to outside agencies that provide such services, such as
the Women's Reso'i:if~f'c:enter, which is located in Oceanside and provides domestic violence
services in the PHA service area.
• Brochure titled: Violence Against Women Act-What Applicants, Tenants, Owners and Landlords
Need to Know is available in the lobby of the housing department and is included in the Briefing
Packets, Recertification Packets, and Portability Packets. Brochure is also available in Spanish.
• HUD form 5380 Notice of Occupancy Rights under the Violence Against Women Act (VAWA) and
HUD form 5382 Certification of Domestic Violence, Dating Violence, Sexual Assault, or Stalking, and
Alternative Documentation are now included in the Briefing Packets, Recertification Packets, Intake
Packets, Move Packets, Port In Packets and are also included with any Notice of Intended Action to
terminate or deny Rental Assistance.
• Emergency Transfer Plan implemented and incorporated into the Administrative Plan
Most Recent Fiscal Year Audit.
(a)Were there any findings in the most recent FY Audit?
y N
□t8:I
Fiscal Year Audit:
Yea r ended June 30, 2018 -The single audit report on expenditures of federal awards disclosed no audit
findings required by the auditors to be reported under paragraph .Sl0(a) of 0MB Circular A-133.
(b) If yes, please describe:
C. Other Document and/or Certification Re uirements.
C.1 Certification Listing Policies and Programs that the PHA has Revised since Submission of its Last Annual Plan
Form 50077-ST-HCV-HP, Certification of Compliance with PHA Plans and Related Regulations, must be submitted by the PHA
as an electronic attachment to the PHA Plan.
C.2 Civil Rights Certification.
Form 50077-ST-HCV-HP, Certification of Compliance with PHA Plans and Related Regulations, must be submitted by the PHA
as an electronic attachment to the PHA Plan.
C.3 Resident Advisory Board (RAB) Comments.
(a) Did the RAB(s) provide comments to the PHA Plan?
y N
□□ If yes, comments must be submitted by the PHA as an attachment to the PHA Plan. PHAs must also include a narrative describing
their analysis of the RAB recommendations and the decisions made on these recommendations.
C.4 Certification by State or Local Officials.
Form HUD 50077-SL, Certification by State or l ocal Officials of PHA Plans Consistency with !he Consolidated Plan, must be
submitted by the PAA as an electronic attachment to the PHA Plan.
D Statement of Capital lmprovements. Required in all years for all PHAs completing this form that adminfater public housing and
receive funding from the Capital Fund Program (CFP). -NOT APPLICABLE
D.1 Capital [mprovements. Include a reference here to the most recent HUD-approved 5-Year Action Plan (HU D-50075.2) and the
date that it was approved by HUD.
PUBLIC COMMENTS AND CHALLENGES