On January 5, 1995, the U.S. Department of Housing and Urban Development (HUD) issued the Consolidated Submission for Community Planning and Development Programs Final Rule. The rule requires a Consolidated Submission (24 CFR Parts 91,92,570,574,576 and 968) for Community Planning and Development Programs, beginning with Fiscal Year 1995. Requirements for the State Government Consolidated Plan are found at 24 CFR Part 91, Subpart D (91.300 - 91.330).
The consolidated submission/plan will replace the current planning and application aspects for HUD's Community Development Block Grant (CDBG), Emergency Shelter Grant (ESG), HOME Investment Partnerships (HOME), and Housing Opportunities for Persons with AIDS (HOPWA) formula funded programs. The consolidated plan submission will replace the current Comprehensive Housing Affordability Strategy (CHAS), the HOME program description, the Community Development Plan and the CDBG Final Statement, and the ESG and HOPWA applications. The new rule also consolidates the reporting requirements for these programs, replacing the individual performance reports with one performance report.
The State's FY'95 CDBG allocation of $58,607,000 (an increase of slightly less than 2% over 1994) also reflects HUD's use of updated census and housing data to determine funding levels. The HOME Program is being funded at $24,122,000, an increase of 14% more than in 1994. The McKinney Program provided funding of $3,081,000 for the ESG Program and of $1,400,000 for HOPWA, an increase of approximately 36% and a decrease of approximately 13%, respectively.
On August 8, September 15 and 27, and December 20, 1994, the Office of Housing and Community Partnerships (OHCP) convened eight advisory groups representing the following programmatic activities: the HOPWA program, Formula Allocation Program, Community Housing Improvement Program (CHIP), Economic Development Program, Water and Sanitary Sewer Competitive Program, Downtown Revitalization Competitive Program, New Horizons Fair Housing Assistance Program, and the NonProfit Housing Development Program. Members of these advisory groups include local elected officials, program administrators, practitioners, service providers, and regional and statewide organizations involved in housing, economic and community development activities at the local level. Each group has a minimum of ten (10) members. In addition, each advisory group meeting was open to any interested party.
The program advisory groups were convened mainly for the following reasons:
In addition, both the Ohio Empowerment Zone/Enterprise Community Program
Committee and the Ohio Conference of Community Development (OCCD) State Programs
Committee met in the fall of 1994 to discuss Ohio's needs in the areas of
housing, infrastructure and economic and community development.
In 1993, the State of Ohio completed a thorough analysis of Ohio's housing and homeless needs. The results of this analysis was included in the State of Ohio's FY 1994-1998 Comprehensive Housing Affordability Strategy (CHAS) and submitted to HUD in December 1993. Therefore, the Consolidated Submission highlights some of the areas previously analyzed by the state and, in many instances, refers readers to the complete CHAS for more information.
More than one out of five Ohio households (23 percent) experience some type of housing need, with cost burden being the greatest housing need facing Ohioans. Nearly 40 percent of Ohio renters and 16 percent of Ohio owners experience a housing need. For renters, cost burden affects 99 percent of those households experiencing a need.
The biggest obstacle to homeownership for first-time homebuyers remains the up-front cash required to purchase a home. Other obstacles to home purchase, especially for lower income renters, are the price of homes and the low-income of renters.
The Coalition on Housing and Homelessness in Ohio (COHHIO), formerly the Ohio Coalition for the Homeless, estimated that approximately 106,000 Ohioans experienced a period of homelessness during 1991.
As Ohio's homeless population has continued to increase, several easily identifiable subpopulations with special needs have emerged. The populations identified include the mentally disabled, alcohol and drug abusers, school-age children and youth, victims of domestic violence, persons with AIDS, the elderly, families with children, veterans, and individuals and families at risk for homelessness.
According to a report prepared by the Legislative Subcommittee of the Ohio Childhood Lead Poisoning Prevention Program Advisory Committee, "lead poisoning is the most common childhood environmental health issue in the State of Ohio." In June 1994, Governor George V. Voinovich signed Senate Bill 162, which became Ohio's lead poisoning prevention law, taking effect on July 1, 1994. This legislation addressed the licensure of abatement workers, manufacture of lead-abatement systems and products, required approval of environmental and lead analytical laboratories and clinical laboratories for lead testing, established a child lead poisoning prevention program, and created the Lead Program Fund and the Legislative Advisory Committee.
However, one of the major impediments to the abatement of lead-based paint is the potential cost. The HUD Lead-Based Paint Abatement Demonstration (Federal Housing Administration -- FHA) estimated that the cost of abatement involving complete removal of lead-based paint would average about $7,700 per unit, although others involved in housing rehabilitation have estimated the per unit cost at between $8,000 to $15,000 per unit. Using the Ohio Department of Health's estimate of 1.8 million affected units and an average of $10,000 per unit, the total cost of abatement would be $18 billion for Ohio alone.
Although the Ohio Department of Development is the primary agency responsible for assisting and directing housing development in the state, five other agencies administer programs dedicated to creating affordable housing: the Ohio Departments of Aging, Human Services, Mental Health, and Mental Retardation and Developmental Disabilities.
Major barriers to affordable housing in Ohio include:
The State of Ohio determined the following priorities for housing and homelessness and strategies to address those priorities through the CHAS preparation process and the Consolidated Submission citizen participation process:
Priority #1
Low-Income Renter Households (0-80 Percent of Median Income)
Priority #2
Low- and Moderate-Income Owners (0-80 Percent of Median Income)
Priority #3
Homeless Families and Individuals
Priority #4
Non-Homeless Special Needs Persons (0-80 Percent of Median Income)
The most important cause of Ohio's recent poverty growth is a major shift in the state's economy. Blue collar job losses associated with economic recessions of the early 1980s and 1990s were the main engine of this process. Nearly one-fourth of Ohio's manufacturing jobs have disappeared since 1979, including a six percent manufacturing job loss during the 1990-1992 recession.
Ohio's anti-poverty strategies focus on two key areas:
Unlike housing, which received extensive needs analysis in Ohio's FY 1994-1998 CHAS, the consolidated plan provides the opportunity to assess statewide, non-housing community development needs. HUD defines community development as a broad area of activities encompassing public improvements (infrastructure), public facilities, public services, and economic development. Of the data available for the assessment, most information concerned public improvements and economic development.
Since the assessment was statewide, the information was sorted and data analyzed according to the Governor's twelve economic development regions. With the assistance of ODOD staff, each region produced a ?white paper' that detailed community development needs and priorities. A summary of the white papers provided the framework for the needs assessment.
Another major contributor of information for the assessment was the Capital Improvements Report (CIR) maintained by the Ohio Public Works Commission. CIR is perhaps the most extensive database available for infrastructure needs. The CIR database was summarized, on a regional basis, and charts and maps are provided of these results.
In order to understand trends in resource availability and unmet needs, funding information for infrastructure construction and maintenance was provided by several state or federal agencies. Resource allocations and unfunded requests, for the last three years, were studied and a regional summary provided.
The community development needs assessment yielded no surprises. The white papers documented a host of planned or pending projects for all regions. The CIR contained approximately $17.2 billion of repairs for infrastructure in the reporting jurisdictions. With known repairs, pending projects, and local plans for new construction, the infrastructure needs are astronomical.
Historically, resources for public improvements and economic development have been concentrated where Ohio's population was located, i.e., in urban metropolitan areas. Rural areas are more challenged to acquire funding for infrastructure improvements, as well as other resources for community development.
Although differing needs emerged from the assessment for urban and rural
areas, the white papers documented well that each community has its own needs
and priorities that need to be understood in a local context.
During the Ohio Consolidated Plan Advisory Committee meeting on January 13, 1995, the following three community development concerns were discussed: housing; economic development; and infrastructure finance.
After reviewing a variety of information regarding Ohio's housing and community development needs, the Ohio Consolidated Plan Advisory Committee suggested that Ohio, through its housing and economic development programs, focus on the following areas:
A. CDBG PROGRAM ALLOCATIONS
The following program allocations for FY'95 are based on a $58,607,000 funding level assumption from HUD (a 2% increase over the FY'94 funding):
| State Program Administration (2% allowed and matched, plus $100,000 not matched) | $ 1,272,140 |
| State Technical Assistance (1% allowed) | 136,070 |
| Community Housing Improvement Program (CHIP) | 12,000,000 |
| Emergency Shelter Grant Program | 500,000 |
| Formula Allocation Program | 23,000,000 |
| Water and Sanitary Sewer Competitive Program | 8,500,000 |
| Economic Development Program | 9,150,000 |
| CDBG Discretionary Fund | 700,000 |
| Microenterprise Business Development Program | 300,000 |
| Imminent Threat Set-Aside Fund | 300,000 |
| Downtown Revitalization Competitive Program | 2,300,000 |
| New Horizons/Fair Housing Assistance Program | 150,000 |
| Training and Technical Assistance Program* | 300,000 |
| Total: | $58,607,000 |
* This is a set-aside of the state's 1% allowance for technical assistance, which totals $586,070.
B. HOME PROGRAM ALLOCATIONS
| State Program Administration -- 10% allowed: (approximately 60% distributed to state recipients and other local grantees) | $2,412,200 |
| Community Housing Improvement Program (CHIP) | 10,850,000 |
| Non-Profit Housing Development Program | 10,350,000 |
| Community Housing Development Organization (CHDO) Competitive Operating Grant Program | 509,800 |
| Total: | $24,122,000 |
C. EMERGENCY SHELTER GRANT (ESG) PROGRAM ALLOCATION
| State Program Administration (5% allowed) | | $ 154,050
| Emergency Shelter Grant Formula Program | 1,799,000
| Emergency Shelter Grant Competitive Program | 550,000
| Discretionary Fund/Homeless Prevention | 150,950
| Supportive Housing for the Homeless (SHH) | 427,000
| Total: | $3,081,000
| |
D. HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS (HOPWA) PROGRAM ALLOCATION
| State Program Administration -- 10% allowed: (approximately 70% distributed to local grantees) | $ 140,000 |
| Housing Opportunities for Persons with AIDS (HOPWA) | 1,185,000 |
| Training and Technical Assistance Grant Program | 75,000 |
| Total: | $1,400,000 |
E. SUPPORTIVE HOUSING FOR THE HOMELESS PROGRAM ALLOCATION
The total allocation for this program will be determined in the State Fisca7l Year 1996 budget.
A. CDBG
- Formula Allocation Program
The $23 million Formula Allocation funding will be enhanced by available FYs 1989-1994 recaptured Formula funds. The "direct" and "acquired" cities status will be determined based on the Formula allocation in FY'95. The determination of "direct" city grantees will remain in effect for three program years (1995, 1996, and 1997), regardless of a city's annual allocation level. Direct cities are those whose 1995 allocation amount is $50,000 or more and who will receive and administer their own Formula allocation.
Starting with FY'95, county Formula grantees may undertake a maximum of six (6) projects, and cities a maximum of three (3) projects. Counties will be allowed an additional three (3) projects for each "acquired" city allocation they administer. Administration and Fair Housing will not count toward the allowable number of projects. It is hoped that by concentrating their limited resources on fewer projects, Formula grantees will be able to produce a better impact in local target areas and neighborhoods. The smaller number of projects should also reduce workload and paperwork requirements for local and state program administration.
In 1995, Formula set-aside funds will be distributed to eligible cities and counties as follows: 100% of the set-aside will be distributed based on local low- and moderate-income population.
In the past, CDBG Formula dollars were allocated on a per capita basis with the per capita amount adjusted for degree of distress as determined via a jurisdiction's per capita income and unemployment rate. Since the U.S. Census Bureau no longer provides data on per capita income, the development of a new methodology was necessary.
- Community Housing Improvement Program (CHIP)
The CDBG set-aside of approximately $12 million will be combined with approximately $10.8 million of HOME funds and available resources from the Ohio Low- and Moderate-Income Housing Trust Fund. A maximum of $500,000 of the CDBG-CHIP set-aside may be awarded for special housing projects through the Nonprofit Housing Development Funding Program. Current CHIP grantees will also be evaluated in the commitment and expenditure of CHIP funds. Therefore, current CHIP grantees are expected, at the time of application submittal, to have at least 50% of the current grant funds committed and at least 30 percent of the current grant funds expended. Applicants that do not meet the 50/30 rule requirement will be subject to rating point reductions. Eligible applicants may complete public residential rehabilitation in shelters for special needs populations; however, the cost of such activity can not exceed $75,000.
- Economic Development Program
The demand for CDBG economic development funds has greatly increased during the last couple of years. For FY'94, the demand for economic development funds will exceeded the funding allocation. The increased demand can be mainly attributed to numerous requests for large grants to provide off-site infrastructure improvements in connection with business expansion and retention activities. The 1995 set-aside of $9,150,000 attempts to make adequate funding available to meet anticipated demand. To help ensure that the funding will be adequate, the following changes are proposed: 1) maximum award for direct loans will be kept at $500,000, while the maximum award for off-site infrastructure will be reduced to $400,000; 2) the CDBG cost per full-time equivalent job created/retained will be kept at $15,000 for direct loans and reduced to $10,000 for off-site infrastructure projects; 3) funding for the off-site infrastructure portion of projects will be scaled according to local distress; therefore, the CDBG participation in the cost of a local economic development project's infrastructure may range from 50% to 75%; and 4) the maximum allowed for general administration and implementation will be 10% of the grant, not to exceed $10,000.
In FY'95, OHCP will also evaluate Economic Development Program grantees' ability to effectively administer a local Revolving Loan Fund at the time of application approval. If it is determined that the local Revolving Loan Fund is not being satisfactorily administered, collateral effectuation, promissory notes and loan repayments must be provided to the State. A determination on whatconstitutes a "satisfactorily administered" economic development Revolving Loan Fund is the sole discretion of the State.
- Water and Sanitary Sewer Competitive Program
The set-aside for this program will be approximately $8.5 million, which hopefully will leverage other State and Federal resources to assist distressed communities address water and sanitary sewer needs. The funding requests received last year far exceeded available funds, resulting in several deserving projects not receiving a grant award.
- Downtown Revitalization Competitive Program
The application deadline will be moved to October 27, 1995. Program grantees are required to be a member of Downtown Ohio, Inc., a statewide nonprofit organization encouraging the development, redevelopment and improvement of downtown areas throughout Ohio. Funding will remain at the $2.3 million level.
- CDBG Discretionary Fund
This set-aside of $700,000 continues to serve the purpose of providing financial assistance for local projects that do not meet the specific requirements of other funding categories. Projects funded are generally in the area of economic development.
- Microenterprise Business Development Program
This $300,000 set-aside will be combined with other non-federal financial resources to assist local counties and cities in their effort to offer microenterprise business development programs.
- Training and Technical Assistance (T/TA) Grant Program
Approximately $300,000 will be awarded on a competitive basis to nonprofit organizations that will assist local governments and other organizations improve their capacity to apply for and administer various state and federal funds by providing training and technical assistance. These funds will be combined with other federal and state resources.
- Emergency Shelter Grant (ESG) Program
Approximately $500,000 will be awarded to local units of government in non-entitlement areas of the State to assist shelters. The funds will be distributed through existing application systems and review criteria currently used by OHCP.
- Imminent Threat Set-Aside Fund
No changes are contemplated for this program. The funding for FY'95 will be $300,000, along with undistributed funds carried over from previous years.
- New Horizons/Fair Housing Assistance Program
Approximately $150,000 will be set aside for distribution through this program. There are no changes in program guidelines expected for this year.
- HUD-Section 108 Loan Guarantee Program
The HUD-Section 108 Loan Guarantee Program does not require a set-aside of CDBG funds. The State will continue to offer this additional resource to local counties and cities that wish to undertake eligible housing and economic development projects.
B. HOME
- Community Housing Improvement Program (CHIP)
The HOME set-aside of approximately $10.8 million will be combined with approximately $11.8 million of CDBG funds and available resources from the Ohio Low- and Moderate-Income Housing Trust Fund.
- Nonprofit Housing Development Program (NPHDP)
The HOME set-aside of approximately $10.3 million will be combined with other available state resources including the Community Development Corporation (CDC) Grant Program and the Ohio Low- and Moderate-Income Housing Trust Fund.
- Community Housing Development Organization (CHDO) Competitive Operating Grant Program
Approximately $509,800 in HOME funds will be awarded to eligible nonprofit organizations to assist with operating costs incurred while undertaking housing development activities.
C. ESG
- Emergency Shelter Grant (ESG) Formula Program
Approximately $1,799,000 in McKinney funds will be combined with state funds and CDBG dollars to provide funding on a formula basis to homeless shelters throughout the state. Eligible grantees are those organizations that received formula allocations or operating grants through the previous year's ESG Competitive Program.
- Emergency Shelter Grant (ESG) Competitive Program
Approximately $550,000 will be available on a competitive basis for units of local government and nonprofit organizations for new homeless or daytime shelters, essential services and/or shelter rehabilitation. Daytime shelters are ineligible for rehabilitation grants.
- Discretionary Fund/Homelessness Prevention
Approximately $150,950 is being held in reserve to fund critical activities at existing shelter locations. These dollars may also be used to assist with homeless prevention activities.
- Supportive Housing for the Homeless (SHH) Program
Approximately $427,000 may be used in conjunction with the state-funded Supportive Housing for the Homeless (SHH) Program to provide supplemental funding.
D. HOPWA
- Housing Opportunities for Persons with AIDS (HOPWA) Program
Approximately $1,185,000 will be awarded to nonprofit organizations or units of local government on a competitive basis to meet the housing and supportive service needs of persons infected with AIDS.
- Training and Technical Assistance (T/TA) Grant Program
Approximately $75,000 will be used in conjunction with other state and federal resources to fund, on a competitive basis, nonprofit organizations that will in turn assist in building the capacity of communities and organizations to apply for and administer state and federal funds (see CDBG program description).
E. SHH (state funded)
- Supportive Housing for the Homeless (SHH) Program
The goal of this program is to provide long-term solutions to end homelessness. There are no changes in the program guidelines expected for this year.