HomeMy WebLinkAboutAgenda Report - April 2, 2014 G-01 PHAGENDA ITEM � W I
ta CITY OF LODI
COUNCIL COMMUNICATION
TM
AGENDA TITLE: Public Hearing to Consider Adopting a Resolution Approving the Draft 2014-2018
Consolidated Plan for the Community Development Block Grant Program (CD)
MEETING DATE: April 2, 2014
PREPARED BY: Interim Community Development Director
RECOMMENDED ACTION: Conduct a Public Hearing to consider a Resolution approving the
draft 2014-2018 Consolidated Plan for the Community Development
Block Grant (CDBG) Program.
BACKGROUND INFORMATION: The Consolidated Plan (Con Plan) is one of the three documents
required to receive federal housing and community development
funding through the Community Development Block Grant (CDBG)
program. The overall goal of these housing and community
development programs is to serve low- and moderate -income persons by developing viable urban
communities through the following actions:
* Providing decent housing;
* Providing a suitable living environment; and
* Expanding economic opportunities.
The Con Plan is the five-year plan for identifying and addressing community needs in the areas of
Housing, Homelessness, Special Needs and Community Development. The process of developing the
Con Plan has involved a significant amount of community outreach and involvement. A total of six
outreach workshops have been held between September 2013 and January 2014 that involved the
general public, focused minority groups, community-based organizations, and the local development
community. The information gathered through that outreach process is then combined with a review of
demographic and economic data sets and a housing market analysis. Once completed, the needs
assessment portion of the Con Plan forms the basis of the Strategic Plan, which will detail how CDBG
funding or any federal housing and community development funding will be used to address priority
needs over the next five years.
The 2014/15 CDBG Annual Action Plan is incorporated into the Con Plan document in this first year of
the five-year document. Lodi's annual allocation for 2014/15 will be $602,302 In 2007, the City Council
established a policy of allocating 40 percent of the annual CDBG award (net of administrative costs) to
community-based organizations (CBOs), with the remainder going to City projects. HUD regulations also
place a 15 -percent cap on the amount of funding that can be allocated to Public Service activities,
whether that is by the City or by a CBO.
2014-2018 CDBG Consolidated Plan
April 2, 2014
Page 2 of 3
Based upon the estimated allocation, the distribution of funds will be as follows:
City projects $289,105
CBO projects $192,737
Administration $120,460
TOTAL $602,302
15% Service Cap $90,345
At the completion of an application period that ran from January 8 to February 12, 2014, the City received
a total of eight applications from community-based organizations (CBO's) requesting a total of $234,450.
Those 8 applications were then evaluated with a grading/scoring matrix that is intended to provide a
standard of measurement to allow for an empirical rating of applicants. Each application is rated on a
grading scale that allows a maximum of 108 points.
The review of the applications centered on the rating criteria that focuses on the following areas:
• Serving Priority Population Bonus. Programs and projects were evaluated on whether they serve
any or all of the following targeted priority populations: Hispanics, Female Head of Household with
Children, Disabled.
• Activity Need and Justification. Activities were evaluated on their ability to address a significant
community need and their benefit to very low-income persons.
• Readiness to Proceed. Programs and projects were evaluated based on their feasibility of
implementation, overall and within the allotted time frame.
• Cost Reasonableness and Effectiveness. Budgets were reviewed to determine completeness
and reasonableness of all costs related to the request for CDBG funding. Organizations applying
for service funding were also evaluated on their ability to become self-sustaining.
• Activity Management and Implementation. Applicants were evaluated on experience,
administrative capacity, and financial management.
• Past Performance. Applicants previously receiving CDBG funds from the City were evaluated on
their reporting and timely expenditure of funds.
• Matching Contributions. Consideration was given to the amount of non-CDBG/HOME funds
committed to the project.
CDBG Funding Recommendations
For planning and administrative activities, an allocation of $120,460 (20 percent of the CDBG allocation)
is recommended to cover the costs of managing the CDBG Program. Remaining funding
recommendations are grouped into the following categories: City projects, City service programs, CBO
projects, and CBO service programs.
Funding recommendations for these categories are listed as follows, with additional detail on applicants
and recommendations in Exhibit A (Summary/Ranking of Applications Received), Exhibit B (Internal
Applications Received) and Exhibit C (City Manager's Recommendations).
2014-2018 CDBG Consolidated Plan
April 2, 2014
Page 3 of 3
While CDBG funding has not been recommended for the City's Spay and Neuter Program, staff is
working to assist them in securing grant funding from the PetSmart Foundation as an alternative. Award
announcements for that grant process are expected as early as May.
PROGRAM ADMINISTRATION $120,460
CITY CAPITAL PROJECTS ($247,105)
• Alley Drainage Improvements ($125,000)
• Hutchins Street Square — North Entrance ADA Improvements — Phase 1 ($106,105)
• Lodi Library Patio Awning ($16,000)
CITY SERVICE PROGRAMS ($42,000)
• Graffiti Abatement ($42,000)
CBO CAPITAL PROJECTS ($144,737)
• LOEL Center —125 S. Washington Project— Phase III ($144,737)
CBO SERVICE PROGRAMS ($48,000)
• San Joaquin Fair Housing — Fair Housing Services ($18,000)
• Salvation Army — Tutoring and Mentoring Program ($20,000)
• Second Harvest Food Bank -Food Assistance Programs ($10,000)
Next Steps
Upon completion of the initial public hearing, the Draft Consolidated Plan will be available for public
review and comment and will be brought back for final approval at a public hearing on May 7, 2014. The
adopted Consolidated Plan document must be submitted to HUD no later than May 15, 2014 in order to
receive funding beginning July 1, 2014.
FISCAL IMPACT: CDBG are federal funds. Capital improvements allow for maintenance
costs to be reduced. Administration costs are paid via a 20 percent set-
aside of the grant funds.
FUNDING AVAILABLE: $602,302 — Estimated 2014/15 Community Development Block Grant
Allocation.
A_a4 V1
or an Ayers, Deputy Cit nag r
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Step chwaba
Interim Community Development Director
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2
RESOLUTION NO. 2014-51
A RESOLUTION OF THE LODI CITY COUNCIL APPROVING THE
DRAFT 2014-2018 CONSOLIDATED PLAN FOR THE FEDERAL
COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM
WHEREAS, the Department of Housing and Urban Development (HUD) has determined that the
City of Lodi, California, is entitled to Community Development Block Grant (CDBG) as an entitlement
community for fiscal year 2014/15 Federal allocation; and
WHEREAS, the City of Lodi has been notified that the 2014/15 CDBG allocation is $602,302; and
WHEREAS, the City of Lodi has held, with proper notification, a public hearing at the City Council
meeting of April 2, 2014, to receive comments and proposals from the public regarding the projected use
of CDBG funds and provided the public with adequate information concerning the amount of funds
available for community development activities, the range of eligible activities, and other important
requirements; and
WHEREAS, the City of Lodi, California, has received public input regarding the proposed use of
CDBG funds; and
WHEREAS, staff therefore recommends the following allocations:
PROGRAM ADMINISTRATION $120,460
CITY CAPITAL PROJECTS ($247,105)
• Alley Drainage Improvements ($125,000)
• Hutchins Street Square — North Entrance ADA Improvements — Phase 1 ($106,105)
• Lodi Library Patio Awning ($16,000)
CITY SERVICE PROGRAMS ($42,000)
• Graffiti Abatement ($42,000)
CBO CAPITAL PROJECTS ($144,737)
• LOEL Center —125 S. Washington Project — Phase III ($144,737)
CBO SERVICE PROGRAMS ($48,000)
• San Joaquin Fair Housing — Fair Housing Services ($18,000)
• Salvation Army — Tutoring and Mentoring Program ($20,000)
• Second Harvest Food Bank - Food Assistance Programs ($8,500)
• Emergency Food Bank — Mobile Farmer's Market ($1,500)
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Lodi does hereby
approve the draft Consolidated Plan, which includes the recommended 2014/15 Federal allocations of
CDBG funds to the projects recommended by staff in the amount of $602,302 as indicated above.
Dated: April 2, 2014
I hereby certify that Resolution No. 2014-51 was passed and adopted by the City Council of the
City of Lodi in a regular meeting held April 2, 2014, by the following vote:
AYES: COUNCIL MEMBERS — Hansen, Johnson, Mounce, Nakanishi, and
Mayor Katzakian
NOES: COUNCIL MEMBERS — None
ABSENT: COUNCIL MEMBERS — None
ABSTAIN: COUNCIL MEMBERS — None
4ANDI JOHL-OLSON
City Clerk
2014-51
2014 - 2018 CDBG
Consolidated Plan
Presented by
Community Development Department
April 2014
2014/18 CDBG Consolidated Plan
■ Consolidated Plan Process
❑ Five-year Plan Identifying and Addressing Community
Needs
■ Six Community Workshops
❑ September 2013 — January 2014
■ Needs Analysis
❑ Using information gathered from community outreach and
additional demographic and economic data.
■ Strategic Plan
❑ Details how federal community development funding will be used
to address priority needs over next five years.
Needs Assessment
■ The Needs Assessment identified several target
populations:
❑ Extremely low-income and very low-income households;
❑ Seniors;
❑ Youth, primarily ages 6 — 17;
❑ Persons with disabilities;
❑ Foster youth; and
❑ Limited English Proficient (LEP) persons.
Needs Assessment
■ The Needs Assessment also identified the following
types of projects and services that are needed in the
community:
o Public facilities (either new or upgrades/expansions to existing facilities), including
community centers, youth facilities, community gardens and one-stop service centers;
o Affordable housing programs for new housing construction, the preservation and
rehabilitation of existing rental housing, emergency housing repairs, down -payment
assistance and tenant -based rental assistance;
o Crime prevention activities to provide resources to support law enforcement and crime
prevention programming in designated neighborhoods;
o Public improvements, especially those focused on increasing accessibility, such as
ADA curbs ramps and sidewalk infill, and storm drainage and flooding improvements;
o Public services for a wide range of populations, including seniors, youth, disabled
persons, homeless households, foster youth, displaced workers, and households with
fair housing issues;
o Employment development services to provide training and to support job creation.
o Transitional housing for young adults coming out of foster care system.
2014/18 CDBG Consolidated Plan
■ 2014/15 Annual Allocation Process
Li Allocation amount - $602,302.
8 Applications from Community Based
Organizations
■ Total Amount Requested $234,450
❑ 6 Public Services Requests: $69,500
Li Public Services Cap
■ $90,345
2014/15 CDBG Funding Availability
2014/15 CDBG Allocation
$602,302
Program Administration
($120,460)
Balance Available for Distribution
$481,842
60% Set-aside for City Projects/Services
$289,105
40% Set-aside for CBO Projects/Services
$192,737
2014/15 Public Service Funding
■ Public Service Cap $90,345
■ Graffiti Abatement $42,000
■ Spay/Neuter Program $20,000
■ Fair Housing $18,000
■ Second Harvest $10,000
■ Mobile Farmer's Market $1,500
■ SJC — Human Services $5,000
■ Salvation Army $20,000
■ Grace & Mercy Foundation $15,000
❑ Total $131,500
2014/15 CDBG Funding
■ Public Hearing — April 2nd.
Li 2014/18 Consolidated Plan.
■ Draft Consolidated Plan Document.
30 Day Public Review/Comment Period.
April 7 —May 7
■ Final Document to Council on May 7th.
■ Submittal to HUD by May 15th.
■ Questions or Comments?
HUD Fair Housing and Equal Opportunity (FHEO) Concern — Spay/Neuter Program Funding
24 CFR 1.4(b)(6)(i), 24 CFR 6.4(a)(1)(viii) states that a recipient in determining the types of services which
will be provided under any such program may not utilize criteria or methods of administration which
have the effect of defeating or substantially impairing accomplishment of the objectives of the program
as respect to persons of a particular race, color, national origin, and sex.
Facts: The objective of the CDBG program is to improve communities by providing decent housing, a
suitable living environment, and expanding economic opportunities, all principally for persons of low
and moderate income. In FY 2009, 2010, and 2011, the City allocated CDBG funds to a city -administered
Spay/Neuter program which was not noted as a Con Plan need, nor did it appear to address any
impediment to the City's Al (Analysis of Impediments to Fair Housing). During that same time period,
the City rejected two programs that were noted as Con Plan priority needs: job creation and ESL for
Limited -English Proficient (LEP) Hispanics. During the Council meeting on 3/17/10, two citizens spoke in
opposition to funding the spay/neuter program in light of other community needs, particularly job
creation. The city's response, if any, was not included in the Council minutes and the program was
continually funded.
The Al and FHEO's analysis revealed that eight percent of the city's population is LEP-Spanish speaking.
Hispanics and female -headed households with children are the groups with the greatest need for both
housing and community services due to low income/poverty. Therefore, these groups would appear to
benefit more from job creation and/or ESL services than they would from a spay/neuter program. In
fact, Hispanics are not benefiting from the spay/neuter program as this group was under -represented in
the program from 40-45% during each of the three years under review.
Corrective Action: The city's rating/ranking procedure for selection of CGBE-funded activities shall
ensure that priority points are awarded to programs that address Al and Con Plan "unmet needs" and
are likely to benefit the lowest -income members of the community (identified as Hispanics, female
headed households with children, and possibly persons with disabilities).
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OCT 20113
PQtVearaFy U.S. Department of Housing and Urban Development
0-4 , °c� Office of Pair Housing and Equal Opportunity
San Francisco tt Regional Once - Region IX g 600 Harrison Street, Yd Floor
San Francisco, California 94107-1387
Office: 800.347.3739 Far. 415.489-6560
Office: 41 SA89-6524 1TY: 415.489-6554
«'ebsilc: http://wNw.had.gov
R'ebsite: espaniol.hud.gov
SEI' 2 12013
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
City of Lodi
Mr. Konradt Bartlam, City Manager
PO Box 3006
Lodi, CA 95241-1910
Dear Mr. Bartlam:
SUBJECT, Letter of Preliminary Findings
Section 109, Title VI, Title VIII (AFFH), Section 3, Section 504
City of Lodi, Community Development Block Grant Program (CDBG)
Program Years: 2008-2009,2009-2010, and 2010-2011
Case Numbers: 09-13-R-003-9 (Section 109)
09-13-R-003-6 (Title VI)
09 -13 -R -002-F (Title VIII/AFFH)
09-13-R-003-4 (Section 504)
The Department's Office of Fair Housing and Equal Opportunity has completed a review
of the city's CDBG-fhnded program. The purpose of the review was to determine whether the
program was administered in compliance with the nondiscrimination provisions of Section 109,
Title VI, Title VIII/AFFH, and Section 504.
Section 109 of the Housing and Community Development Act of 1974(Section 109), 42
U.S.C. Section 5301 et seq., and the Department's implementing regulations at 24 CFR Parts 6
and 570.602, which prohibit discrimination based on race, color, national.origin, religion, and
sex; Title VI of the Civil Rights Act of 1964 (Title VI), 42 U.S.C. Section 2000, and the
Department's implementing regulations at 24 CFR Part I which prohibit discrimination based on
race, color, and national origin; Title VIII of the Civil Rights Act of 1968, as amended by the
Fair Housing Amendments Act of 1988 (Title VIIUAFFH), 42 U.S.C. 3608, Section 808(e)(5),
and the Department's regulations at 24 CFR 570.601 which require the recipient to certify that it
will affirmatively further fair housing by (1) conducting an Analysis of Impediments to fair
housing choice, (2) taking appropriate actions to overcome the identified impediments, and (3)
maintaining records reflecting the analysis and actions; Section 504 of the Rehabilitation Act of
1973 (Section 504),42 U.S.C. Section 794, and the Department's implementing regulations at 24
CFR Part 8 which prohibit discrimination based oil disability.
. The onsite review was conducted oil December 3-6, 2012. The review included an
examination of the following processes: Citizen Participation; Benefits, Services and Methods of
Administration; Affirmatively Furthering Fair Housing, and Section 504 Program Requirements,
including a limited accessibility survey of City Hall and various ADA improvements.)
The review identified areas in which the recipient failed to fully comply with provisions
of Title VIII (including the requirement to Affirmatively Further Fair Housing choice), and Title
VI, Section 109, and Section 504 implementing regulations (42 USC 3608(4), and 24 CFR Parts
6, 1, and 8 respectively) and concerns which may result in findings of non-compliance if left
uncorrected. The findings and concerns are detailed below:
Preliminary Findings of Non -Compliance
1. Preliminaiy Finding of Non -Compliance- (Title VIIUAFFH): Section 808(e)(5) of the Fail-
Housing
airHousing Act requires HUD to administer the programs and activities relating to housing and
urban development in a manner to affirmatively further fair housing (the policies of the Fair
Housing Act). 24 CFR 570.601 of the Department's CPD regulations require the grantee to
certify that it will affirmatively further fair housing by (1) conducting an analysis to identify
impediments to fair housing choice within its jurisdiction, (2) taking appropriate actions to
overcome the effects of any impediments identified through that analysis, and (3) maintaining
records reflecting the analysis and actions in this regard.
Facts: FHBO reviewed the AT and noted the following analytical deficiencies:
A: The AT failed to analyze the degree of discrimination against persons with disabilities and
female-headed-housel€olds with children along with the housing patterns of each group in order to
determine whether these groups face high levels of discrimination and segregation. The Al states
that the disabled and female -headed families with children "may" face discrimination due to
lower-income and various other factors. Additionally, the AT noted the most common basis of
discrimination among complaints filed with HUD and DFEH was disability. San Joaquin County
Fair Housing (SJCFC) reported that 100% of the fair housing complaints it accepted during the
period of review (4 complaints) were based on disability, and citizens taking the AT survey
reported discrimination based on familial status. However, the AT did not analyze this data nor
did it analyze the housing patterns of each group.
B: The Al failed to analyze the relationship between lack of affordable housing, the prevalence of
substandard rental housing on the east side of the city, and the high concentration of ELINLI
Hispanics on the East side of the city to determine whether these factors present an impediment to
fair housing choice. For example, in the AI survey, residents commented that due to the lack of
affordable housing, some ELIIVLI Hispanics are living in substandard housing at the mercy of
landlords who know that their tcoants have limited housing choices. Additionally, although the
AI identified lack of affordable housing as an impediment, it did not connect it to any particular
protected class, nor did it analyze the impact of substandard housing. The Al simply stated that
64% of the city's housing stock is 30 years old or older and housing of that age is typically in
need of rehabilitation.
C: The AT failed to analyze the supply, demand, locations, and availability of affordable
accessible housing to determine whether these factors present an impediment to fair housing
choice. The AT states that 23% of the city's population is disabled and, due to lower incomes, this
group "may" have a challenge finding affordable and accessible housing. However, these factors
were not analyzed.
D: The AI failed to analyze the relationship between housing, employment, and transportation
for lower income persons to determine whether these factors present an impediment to fair
housing choice. For example, although the Al lists six major employers in the city, it was unclear
whether these employers offered jobs at the lower-income levels of the wage/salary scale and
there was no analysis of the geographic relationship between lower income employers and
proximity to lower income housing. Additionally, the Al discusses the city's Grape Line bus
set -vice but does not link bus routes/schedules with low income housing or employment
opportunities to determine if lack of accessible public transportation was an impediment to fair
housing choice.
Corrective Action: The city must analyze the following issues to determine whether they
present impediments to fair housing choice: (1) the degree of discrimination faced by the disabled
and female -headed -households with children along with each group's housing patterns, (2) the
relationship between affordable housing, substandard housing, and Hispanic concentration on the
east side of the city, (3) the supply, demand, locations, and availability of affordable physically
accessible housing, and (4) the relationship between housing, employment, and transportation for
lower income persons. If the analyses reveal that any of these issues impede fair housing choice,
the Al must identify them as impediments, explain what caused them, and develop actions to
overcome them during the current and successive ConPlan cycles.
2. Preliminary Finding of Non -Compliance- (Title VIII/AFFH): Section 808(e)(5) of the Fair
Housing Act requires HUD to administer the programs and activities relating to housing and
urban development in a manner to affirmatively further fair housing (tine policies of the Fair
Housing Act). 24 CFR 570.601 of the Department's CPD regulations require the grantee to
certify that it will affirmatively further fair housing by (1) conducting an analysis to identify
impediments to fair housing choice within its jurisdiction, (2) taking appropriate actions to
overcome the effects of any impediments identified through that analysis, and (3) maintaining
records reflecting the analysis and actions in this regard.
Facts: FHEO reviewed the city's identified impediments, actions needed, and actions taken and
noted the following deficiencies:
A: The AI failed to identify the pattern of Hispanic -ethnicity concentration in three adjoining
census tracts (CT 44.03 (69% Hispanic), 44.04 (69% Hispanic), and 45.02 (80% Hispanic) as an
impediment, explain what caused it, and develop actions to address it.
B. The Al identified the "Lack of Affordable Housing Supply" as an impediment based on a
limited analysis of income/affordability. The limited analysis concluded that affordable rental
housing was needed by ELI/VLI female -headed households with children. However, the Al did
not link the tenure type (rental), household type (family) and protected class (female -headed -
households with children) to the impediment. Moreover, the AI failed to analyze disproportionate
need by any of the other protected classes, namely- race, ethnicity (See footnote)', and disability.
The city took action on the impediment by supporting the county in constructing four single-
family ownership homes and pre -developing a senior project. However, these actions were
I FHEO analyzed disproportionate need by race and ethnicity using CDBG area demographics (area of lowest
Income) and found that Hispanics had the lowest per -capita incomes in the city. This conclusion was supported by:
http•//Nk,ww city -data cont/iticome/income-Lodi-Colifornia.html. Therefore, the data reveals that the city lacks family
rental housing which is affordable to ELINLI female -headed -households with children, Hispanics, and possibly the
disabled.
inappropriate to address the impediment of an unmet need for rental housing and housing for
female -headed households with children. .
C: The Al attributes the "Loss of affordable units" impediment to a loss of HCWs; however, the
Al indicates that the city does not know the number of HCV's used in Lodi. Therefore, the city's
Al lacks the analysis necessary to conclude that there was a loss of HCVs. (FHEO's independent
research found a slight increase in HCV utilization in Lodi over the past 3 years). Additionally,
FHEO independently reviewed conversion of subsidized units to market rate and the prevalence
of affordable substandard units to determine whether these factors created a "loss of affordable
units." The Al states that Bethel Apartments, 28 affordable units, converted to market rate;
however, Bethel is a "senior" project so the "loss" of these units has no impact on the type of
housing for families that was identified in the city's Al as critical need. Further, the Al citizen
survey indicates that the city's substandard housing stock did not result in a "loss of affordable
units" as the units are still being rented despite their poor condition, which undermines the
credibility of this impediment as identified by the city.
D: In order to overcome the "Need for subsidies for LI HH" (Low income Households)
impediment, the city indicted that it would "support" the PHA in administering its HCV program
by displaying/distributing HCV materials during code enforcement activity, creating a link to the
local PHA's website, and encouraging greater participation in the HCV program by property
owners during code enforcement activities. Not only did city staff provide no evidence to FHEO
through this review that any of the actions had been taken, the actions listed had no nexus to the
impediment.
E: The Al identified "Differential origination/approval rates based on CT and ethnicity" as an
impediment to fair housing choice. The Al reports a 45% Hispanic loan denial in CTs 44.03,
44.04, 45.02, and 45.01 and the city's actions to address this involved "supporting" home
purchase by Hispanics in the noted census tracts, although all tracts, aside from 45.01, are already
Hispanic -concentrated areas. The county constructed four new homes in CT 45.02 but did not
evaluate site demographics prior to construction, nor did its developer appear to market the
homes outside the concentrated area. Ultimately, the county sold the 4 homes to Hispanics which,
though addressing the impediment to promote successful homeownership among under-
represented Hispanics, also had the effect of perpetuating Hispanic concentration in census tract
45.02, and limiting the range of housing choices to low-income Hispanic buyers and applicants to
this program.
r: The "Lack of knowledge of fair housing rights" was identified as an impediment based on the
AI online survey. The Al survey reports that although 6 (83%) city staff felt that residents
understand their fair housing rights somewhat poorly or not at all, 31 (70%) residents, 1 (1001/0)
provider, and 3 (67%) real-estate professionals felt that they, or their clients, understood their fair
housing rights very well or somewhat well. Additionally, 77% of residents declined the offer to
receive additional fair housing information, Further, San Joaquin County Fair Housing (SJCFH)
staff maintained a presence at the Lodi Public Library once/week for 7 months. However, despite
attempts to generate interest with a .Lodi Alews Sentinel advertisement and a presentation at a
disability rights fair, the library services were ultimately discontinued due to lack of interest.
Therefore, this does not appear to be a substantiated impediment, at least without some further
analysis to demonstrate that lack of knowledge of fair housing rights/obligations was limiting
housing choice in the city.
G: The Al identified "Lack of information on discrimination" as an impediment and listed "fair
housing testing" as a means of addressing it. The Al noted the most common basis of
4
discrimination among complaints filed with HUD and DFEH was disability, and SJCFH reported
that all the fair housing complaints it accepted during the period of review (4 complaints) were
based on disability. In addition, citizens taking the Al survey reported discrimination based on
Hispanic ethnicity and familial and marital status. Although the city contracted with SJCFH to
conduct fair housing testing, SJCFH stated that the agency lacked the capacity to do so.
Therefore, the city must identify other means of addressing the "testing" action.
H: The Al identified "Unequal distribution of low income households and minority households"
as an impediment. Low-income households are concentrated in the CDBG area (CT's 42.03,
44,03, 44.04, 4S.0 1, 45.02) and minority households are concentrated in CT's 44.03, 44,04,
45.02) .The city's actions to address this involved encouraging a mix of incomes in new
developments. The city's new development during this period consisted of four homes
constructed by the county in CT 45.02, a low-income, Hispanic concentrated area. As part of its
marketing efforts, the county provided the developer with flyers which stated that low-income
(<!= 501/o AMI) was a qualifying factor to purchase the homes. The county did not evaluate site
demographics prior to construction and its developer did not appear to market the hones outside
the low-income concentrated area. Ultimately, the homes were sold to low-income Hispanics
which, as also noted within paragraph 2.E above, perpetuated low-income concentration and
Hispanic concentration in the area.
Corrective Action A: The AI must identify the pattern of Hispanic concentration in three
adjoining low-income census tracts ( CT 44.03, 44.04, and 45.02) as an impediment, analyze it,
explain what caused it, and develop actions to overcome it during the current and upcoming
ConPlan cycles (see also corrective actions for items E and H, below).
Corrective Action B: In order to overcome the "Lack of affordable housing supply", the city
must: (1) analyze disproportionate need for affordable housing by race, ethnicity, and disability
(2) link household type (family, elderly, disabled), tenure type (rental, ownership), and the
protected classes that have the greatest need for affordable housing (by race, ethnicity, sex,
disability) to the impediment and (3) take appropriate action to overcome the impediment by
providing family rental housing affordable to ELINLI female -headed -households with children,
Hispanics, and possibly the disabled during the current and upcoming ConPlan cycles.
Corrective Action C: The "Loss of affordable units" was not firmly grounded through
presentation of a justifying factual analysis. Therefore, the city must remove this item from the Al
impediments pending further analysis.
Corrective Action D: The actions listed as needed to overcome the "Need for subsidies" are
inappropriate as a means of addressing the impediment. Therefore, the city must amend the Al
"actions needed" during the current Con Plan cycle. As discussed during the onsite, FHEO
suggests that the city pursue HOME funding for tenant -based rental subsidies for the groups with
the greatest need.
Corrective Action E: The city must take an active role in the siting and marketing of affordable
housing within its jurisdiction or risk the loss of federal funding due to failure to affirmatively
further fair housing. The actions taken to overcome the "Differential origin/approval rates based
on CT and Hispanic ethnicity" are inappropriate as they resulted in the perpetuation of Hispanic
z Census tracts were renumbered in Census 2010 and the numbers do not necessarily correspond with the
Census 2000 data used in the Al. However, the locations identified as "low-income" and "minority" are the
same.
5
concentration in CT 45.02. Therefore, the city must amend the AI "actions needed" during the
current and successive ConPlan cycles, to include an analysis of census tract demographics of the
prospective sites for development of new affordable housing units, and to ensure that the city's
future affordable housing development reflects a wide range of housing choices, including units
outside of areas of existing racial or ethnic concentration.
Corrective Action F: The "Lack of knowledge of fair housing rights" was not firmly grounded
in the Al conclusion. Therefore, the city must remove this item from the Al impediments pending
further analysis and presentation of facts to support that this continues to be an actual
impediment.
Corrective Action G: Although "fair housing testing" is an appropriate action to address the
"Lack of information on discrimination," the city's contracted provider (S3CFH) stated that it
lacks the capacity to perform this service. Therefore, the city inust amend the AT "actions needed"
to reflect new actions to analyze the prevalence of housing discrimination within its jurisdiction,
and/or to identify a new fair housing provider that can degree provide testing services or work
with its existing provider to develop this capacity.
Corrective Action H: The city must take an active role in the siting and marketing of affordable
housing within its jurisdiction or risk the loss of federal funding due to failure to affirmatively
further fair housing. The actions taken to overcome the "Unequal distribution of low-income
households and minority households" are inappropriate as they resulted in the perpetuation of
low-income concentration and Hispanic concentration in CT 45.02. Therefore, the city must
amend the AT "actions needed" during the current ConPlan cycle. FHEO strongly suggests that
the city pursue HOME funding for mixed -income housing as a means of addressing this
impediment, as is also sought as a corrective action for item D, above.
3. Preliminary Finding of Non -Compliance- (Title VIIUAFFH): Section 808(e)(5) of the Fair
Housing Act requires HUD to administer the programs and activities relating to housing and
urban development in a manner to affirmatively further fair housing (the policies of the Fair
Housing Act). 24 CFR 570.601 of the Department's CPD regulations require the grantee to
certify that it will affirmatively further fair housing by (1) conducting all analysis to identify
impediments to fair housing choice within its jurisdiction, (2) taking appropriate actions to
overcome the effects of any impediments identified through that analysis, and (3) maintaining
records reflecting the analysis and actions in this regard.
Facts: FHEO reviewed the city's AFFH records and noted the following deficiencies:
A: A review of county (city supported) "[HOME] Gap Loan Program" and "NSP Gap Loan
Program" marketing flyers revealed that the flyers did not contain equal opportunity provisions
for persons with disabilities. Specifically, (1) the flyers posted a telephone number but did not
post an equivalent method of communication for the deaf; (2) flyers did not include a "Non-
discrimination on the basis of disability" clause along with the Section 504 coordinator's narne
and contact information; (3) flyers did not inform beneficiaries that the HOME and NSP funded
homes could be made accessible upon request.
B: A review of county (city supported) HOME and NSP beneficiary files revealed no data oil
disability status. City staff confirmed that the county did not collect disability data on the
beneficiaries of its HOME and NSP programs. Absence of procedures for collecting data from
applicants and beneficiaries prevented an analysis of the degree to which people with disabilities
6
participated in the funded programs, or would have indicated a need for affirmative marketing to
promote increased participation by this group.
Corrective Actions A -B: The city is obligated to AFFH in all housing and housing -related
activities within its jurisdiction. Therefote, the city must adopt and implement a procedure to
ensure that materials used to market affordable housing activities contain communication, non-
discrimination, and housing accessibility provisions that afford the disabled an equal opportunity
to participate in housing programs within its jurisdiction. Additionally, the city must adopt and
implement a procedure to ensure that disability data is collected on applicants and beneficiaries of
all affordable housing programs.
4. Preliminary Finding of Non-conipliance (Title VI, Section 109, Section 504).24 CFR
1.4(b)(6)(1), 24 CFR 6.4(a)(1)(viii) and 24 CFR 8.4(b)(1)(viii) prohibit recipients of federal
financial assistance from employing methods of administration which have the effect of limiting
participation by persons on the basis of race, color, national origin, sex, or disability.
Facts: FHEO's demographic analysis revealed a significant under -representation of Hispanic
beneficiaries in all direct -benefit programs during the three years of review compared to their
representation in the 'income -qualified population. For example, in the SJCFH, Second Harvest
Food Bank, and Spay/Neuter activities, Hispanic beneficiaries were significantly
underrepresented from 20%-45% relative to their numbers among the general population of the
city's jurisdiction. Additionally, disabled beneficiaries were significantly underrepresented in the
Second Harvest Food Bank by 10%-20%. City staff acknowledged that they did not analyze
beneficiary demographic data, nor did they extend affirmative marketing to the underrepresented
groups.
Corrective Action: The city shall adopt and implement a procedure requiring analysis of the
race, ethnicity, female -headed householder, and disability status of applicants and beneficiaries in
CDBG funded programs to determine whether any protected groups are underrepresented. If
underrepresentation is found, the city shall engage in affirmative marketing to the
underrepresented group.
5. Preliminary Finding of Non-compliance (Section 504). (24 CFR 8.53(a) requires recipients
that employ fifteen or more persons to designate at least one person to coordinate its efforts to
comply with Section 504. ) 24 CFR 8.53(b) requires a recipient that employs fifteen or more
persons to adopt grievance procedures that incorporate appropriate due process standards and that
provide for the prompt and equitable resolution of complaints alleging any action prohibited by
Section 504.
Facts: FHEO found that the city's Building Official coordinates compliance with Section 504
physical accessibility (Transition flan) but the city does not have an employee that coordinates
efforts to comply with Section 504 program accessibility throughout all city departments.
Moreover, the city has not adopted a formal grievance procedure that incorporates due process
and provides for the prompt and equitable resolution of complaints based on disability
Corrective Action: The city shall officially designate at least one person to effectively
coordinate efforts to comply with Section 504. In order to effectively coordinate compliance
efforts, the person, or persons, must have knowledge and/or training in Section 504 physical and
program accessibility, including conducting a self-assessment to identify policies and practices
7
that present barriers to accessibility and implementing a plan to correct the deficiencies.
Additionally, the city shall adopt and implement a written grievance procedure that incorporates
due process and provides for the prompt and equitable resolution of complaints based on
disability.
6. Preliminary Finding of Non-compliance (Section 504). 24 CFR 8.54(a) requires recipients
that employ fifteen or more persons to take ...continuing steps to notify applicants, participants,
and beneficiaries ... that it does not discriminate on the basis of handicap. The notification shall
state that the recipient does not discriminate in admission or access to, or treatment or
employment in, its federally assisted programs and activities oil the basis of disability and shall
include the identification of the designated Section 504 Coordinator. Methods of notification may
include the posting of notices, publication in newspapers and magazines, and distribution of
memoranda or other written communication. 24 CFR 8.54(c) requires the recipient to ensure that
persons with visual or hearing impairments that are likely to be directly affected by a federally
assisted program are provided with the information necessary to understand and participate in the
program. Methods for ensuring participation may include qualified sign language and oral
interpreters, readers, or the use of taped and Braille materials.
Facts: FHEO reviewed 17 Lodi --News Sentinel notices announcing ConPlan, Al, AAP, and
CAPER public meeting and hearings and found that none of them contained continuing notice of
non-discrimination on the basis of disability which included the identification of the designated
Section 504 Coordinator. Additionally, 59% of the notices (10 of 17) did not inform persons with
visual or hearing impairments that they could request reasonable accommodations in order to
participate in the meetings or hearings. Further, the city did not consistently notify federally
funded program applicants and beneficiaries of the opportunity to request reasonable
accommodations.
Corrective Action. The city shall take continuing steps to notify applicants, participants, and
beneficiaries that it does not discriminate on the basis of disability by posting a "Notice of Non -
Discrimination" oil ConPlan, Al, AAP and CAPER newspaper notices and federally funded
program marketing materials (e.g., SJCFH, Second Harvest Food Bank, Spay/Neuter program).
The notice shall state that the city does not discriminate in admission or access to, or treatment or
employment in, federally assisted programs and activities on the basis of disability and shall
include the identification of the designated Section 504 Coordinator. Additional methods of
notification may include posting notices at City Hall, placing notices in newspapers or city
publications, or distributing memoranda or other written communication to interested parties.
Additionally, the city shall notify persons with disabilities that reasonable accommodations (i.e.,
auxiliary aids such as ASL interpreters, amplifiers, Braille materials, etc) are available upon
request by posting such notice on ConPlan, Al, AAP, and CAPER newspaper notices and
federally funded program marketing materials.
7. Preliminary Finding of Non-compliance (Section 504). 24 CFR 8.6(a)(2) requires that
where a recipient communicates with applicants and beneficiaries by telephone, TDDs or equally
effective communication systems for the deaf shall be used.
Facts: FHEO reviewed 17 Lodi-Neivs Sentinel notices announcing ConPlan, Al, AAP, and
CAPER public meeting and hearings and although all notices posted the city's telephone number,
none of them posted a TDD or equally effective communication method for the deaf.
8
Corrective Action. The city shall post a TDD number or equally effective communication
method for the deaf on all city publications that display a telephone number (i.e newspaper
notices, federally funded program flyers, city stationery, etc.) .
Concerns
1. Concern: (Title V111/ATFH): Section 808(e)(5) of the Fair Housing Act requires HUD to
administer the programs and activities relating to housing and urban development in a manner to
affirmatively further fair housing (the policies of the Fair Housing Act), 24 CFR 570.601 of the
Department's CPD regulations require the grantee to certify that it will affirmatively further fair
housing by (1) conducting an analysis to identify impediments to fair housing choice within its
jurisdiction, (2) taking appropriate actions to overcome the effects of any impediments identified
through that analysis, and (3) maintaining records reflecting the analysis and actions in this
regard.
Facts: FHEO noted the following Al errors and omissions: (1) the AI/24 Table 14- "Affordable
Mortgage/Rent Amounts" appears erroneous as it pairs an INCREASE in income with a
DECREASE (as opposed to an increase) in affordable rent in the "low income" column; (2) the
AV26 identifies "Creeks:de,"as a family project; however, it is a HUD subsidized project for the
elderly. The city has no HUD subsidized family housing projects; (3) the Al should use more -
recent Census 2010 or American Community Survey data; (4) the Al must include milestones and
timetables for amelioration of each impediment as the sole measure of success for fair housing
planning is the achievement of results.
Corrective Action: The city shall correct the above Al data errors and omissions during the
current ConPlan cycle.
2. Concern: (Title VI, Section 109). 24 CFR 1.4(b)(3) and 24 CFR 6.4(a)(2) prohibit the
recipient from making housing site or location selections with the purpose or effect of .
..subjecting individuals to discrimination on the basis of race, color, or national origin. .
Facts: The city is pre -developing a new HOME -funded rental project for seniors in CT 43.03, a
racially/ethnically mixed area. City staff acknowledged that they did not analyze the racial and
ethnic demographics of the site prior to selecting it to determine whether it could significantly
increase the ratio of minorities to non -minorities in the area. In this case, new construction in CT
43.03 will not significantly alter the ratio of minorities to non -minorities due to the population of
the tract (4,610) and the small number of units being constructed (80). However, the city is
required to conduct a demographic analysis of proposed new rental sites located in "mixed" areas
to ensure that site selection does not contribute to minority concentration.
Corrective Action: The city shall adopt and implement a procedure to ensure that proposed sites
of new HOME -funded rental housing comply with HOME program site and neighborhood
standards at 24 CFR 92.202(b)/983.6(b). These standards prohibit construction of new rental
housing in a "mixed" area if the housing will significantly increase the ratio of minorities to non -
minorities in the area and they include additional stipulations for housing sited in minority
concentrated areas.
E
3. Concern (Title VI, Section 109). 24 CFR 1.6(b) and 24 CFR 6.10(c) require each recipient
of HUD assistance to keep timely, complete, and accurate records to enable HUD to ascertain
whether the recipient has complied with Title VI and Section 109. In general, recipients should
have data available on race and ethnicity. HUD issued guidelines implementing the Office of
Management and Budget's (OMB) standards for collecting and reporting race and ethnicity,
effective 1/1/03. HUD's guidelines require recipients to collect race and ethnicity data by asking
applicants and beneficiaries to choose one of two ethnicity groups (Hispanic or Not -Hispanic)
AND one or more of five racial groups(American Indian/AK Native, Asian, Black/African
American, Native Hawaiian/Pacific Islander, White). If the applicant or beneficiary fails to self -
identify race and ethnicity, the city should use "observer identification" to collect and report this
data.
Facts: FHEO's analysis revealed that the Second Harvest Food Bank did not collect the race of
its Hispanic ethnicity beneficiaries. However, the city reported the race of these persons to
HUD/IDIS as "Other /Multi -Racial" or "White" Additionally, out of 37 FTHB applicants, seven
applicants did not self -identify race and three applicants did not self -identify ethnicity. Although
-the city met with these applicants face-to-face, it did not use "observer identification" to collect
the unidentified demographic data where the applicants declined to self -identify.
Corrective Action. The city shall collect race and etlinicity data from all applicants and
beneficiaries of federally funded activities and accurately report the applicable data to HUD.
Additionally, the city shall adopt and implement a procedure requiring the use of "observer
identification" to identify ethnicity and race when applicants and beneficiaries are seen face-to-
face and they decline to self -identify.
4. Concern (Title VI, Section 109).24 CFR 1.4(b)(6)(i), 24 CFR 6.4(a)(1)(viii) prohibit
recipients of federal financial assistance from employing methods of administration which
have the effect of limiting participation by persons on the basis of race, color, or national
origin. HUD's guidance regarding Title VI's prohibition against National Origin Discrimination
affecting Limited English Proficient Persons (LEP), effective on March 7, 2007, states that ill
certain situations, failure to ensure that LEP persons can effectively participate in, or benefit
from, federally assisted programs may violate Title VI's prohibition against national origin
discrimination.
Facts: The US Census reports that 8% of the city's population is LEP-Spanish speaking;
however, the city has not performed the four -factor analysis of language needs, developed a
Language Access Plan, and implemented it. Although the city employs bilingual English/Spanish
staff members that have provided interpretation, it does not affirmatively inform the public that
this service is available. For example, FHEO reviewed 17 English language Lodi -Neils Sentinel
notices soliciting citizen participation in the ConPlan, AI, AAPS, and CAPERs and found that
94% (16 of 17) did not offer oral language interpreters during meetings and hearings upon
request, nor did they offer Spanish-language translation of the aforementioned planning
documents. Additionally, although the city translated FTHB marketing materials into Spanish,
vital documents such as activity applications appeared only in English. Moreover, the city does
not have a procedure to assist LEP persons who speak languages other than Spanish.
Corrective Action: The city shall adopt and implement a Language Access Plan to facilitate
communication with LEA persons by offering oral language interpretation for any language and
by identifying vital documents and translating them into Spanish. Additionally, the city must
ensure that notices announcing the ConPlan, Al, AAP, and CAPER and flyers advertising
10
federally funded programs (i.e. SJCFH, Second Harvest Food Bank, Spay/Neuter, etc.) state that
language interpreters can be made available upon request and that the planning documents can be
translated into Spanish upon request.
5. Concern (Section 504). 24 CFR 8.4(b)(1)(i) A recipient in providing any ...benefit or
service in a program or activity that receives federal financial assistance may not, directly or
through contractual arrangements, solely on the basis of disability, deny a qualified individual
with handicaps the opportunity to participate in, or benefit from the benefit or service. 24 CFR
8.20 requires that no qualified individual with handicaps shall, because a recipient's facilities are
inaccessible to or unusable by individuals with handicaps, be denied the benefits of, be excluded
from participation in, or otherwise be subjected to discrimination under any program or activity
that receives HUD financial assistance. 24 CFR 8.21(b) requires that alterations to existing non-
housing facilities shall, to the maximum extent feasible, be made to be readily accessible to and
usable by individuals with handicaps,
Facts: In 2010/11 the city awarded the "l 80'Teen Center"CDBG funds and entered into a
contract with the facility for "expansion." City staff was aware that the Teen Center was not
physically accessible to the disabled at the time of the award, the Teen Center did not have a plan
to provide alternate access to the disabled, and there was no evidence that the alteration
("expansion") resulted in accessibility. Therefore, mobility impaired persons were not afforded all
equal opportunity to participate in Teen Center activities.
Corrective Action: The city's shall adopt and implement a procedure to ensure that programs
requesting CDBG funding are screened to determine if services will be delivered in facilities that
are accessible to the disabled (or the program offers alternate accessibility provisions) or the
funding requested is for the purpose of making the facility accessible. If the facility does not meet
these criteria, the program should not be funded until physical accessibility has been achieved.
6. Concern: (Title VI, Section 109) 24 CFR 1.4(b)(6)(i), 24 CFR 6.4(a)(1)(viii) states that a
recipient in determining the types of services which will be provided under any such program
may not utilize criteria or methods of administration which have the effect of defeating or
substantially impairing accomplishment of the objectives of the program as respect to persons of
a particular race, color, national origin, and sex.
Facts: The objective of the CDBG program is to improve communities by providing decent
housing, a suitable living environment, and expanding economic opportunities, all principally for
persons of low and moderate income. In FY 2009, 2010, and 2011, the city allocated CDBG
funds to a city -administered Spay/Neuter program which was not noted as a Con Plan need, nor
did it appear to address any impediment in the city's Al. During the same time -period, the city
rejected two programs that were noted as Con Plan priority needs: job geation and ESL for LEP
Hispanics. During a City Council meeting on 3/17/10, two citizens spoke in opposition to funding
the spay/neuter program in light of other community needs, particularly job creation. The city's
response, if any, was not included in the council minutes and the program Nvas continually
funded.
The Al and FHEO's analysis revealed that eight percent of the city's population is LEP- Spanish
speaking. Hispanics and female -headed households with children are the groups with the greatest
need for both housing and community services due to low income/poverty. Therefore, these
groups would appear to benefit more from job creation and/or ESL set -vices than they would from
11
a spay/neuter program. In fact, Hispanics are not benefiting from the spay/neuter program as this
group was underrepresented in the program from 40-45% during each of the three years under
review.
Corrective Action: The city's rating/ranking procedure for selection of CDBG-fronded activities
shall ensure that priority points are awarded to programs that address Al and ConPlan "unmet
needs" and are likely to benefit the lowest -income members of the community (identified as
Hispanics, female headed households with children, and possibly persons with disabilities).
7. Concern. (Section 504)24.CFR8.21(e)(4) requires that if structural changes to non -housing
facilities will be undertaken to achieve program accessibility, a recipient shall develop a transition
plan setting forth the steps necessary to complete such changes within six months of 7/11/88 (i.e.,
by 1/11/89). The plan shall be developed with the assistance of interested persons, including
individuals with handicaps or organizations representing these individuals. A copy of the plan
shall be made available for public inspection. The plan shall (1) identify physical obstacles in
facilities that limit accessibility of programs or activities to individuals with handicaps, (2)
describe in detail the methods used to make the facilities accessible, (3) specify the schedule for
taking the steps necessary to achieve cotnpl iance and, if the time period of the transition plan is
longer than one year, identify steps that will be taken during each year of the transition period.
Facts: FHEO reviewed the city's Transition Plan (updated in 2005 and 2011) and found that it
noted barriers to accessibility in city facilities, all of which had been remediated from 1992-2011
aside from the Grape Bowl. The Transition Plan notes that the "Grape Bowl and all of its
facilities are out of compliance" but the plan does not include a schedule for taking the steps
necessary to achieve compliance. Additionally, FHEO noted that the ramp in front of City Hall,
shown as remediated in 1996, was still inaccessible. Further, FHEO's limited survey identified
barriers to accessibility in other city facilities. City staff acknowledged the issues and explained
that the Transition Plan was being updated but did not provide a date of completion.
Corrective Action: The city must develop a new Transition Plan with the assistance of
interested persons, including persons with disabilities or agencies representing this group,
within eight months of the date of issuance of this Letter of Findings (i.e., May 31,
10 14). The revised Transition Plan shall identify a comprehensive listing of barriers to
accessibility in city facilities (including the barriers identified in FHEO's limited survey),
methods to remediate them, and timetables for remediation.
Observation (i). A review of the PY 2011 locations of graffiti abatement revealed that 29%
(263 of 914 instances) were not in the CDBG area. The city's CAPER should report the degree to
which CDBG-funded activities including indirect -benefit programs such as graffiti abatement
activities are occurring within the CDBG target areas, This observation is also being referred to
the Regional CPD Director for possible program compliance follow by her staff.
COMPLIANCE REVIEW CONCLUSION
Pursuant to 24 CFR Part §8.56(h), you may request a complete review of the Section 504
Preliminary Findings of Nan -Compliance in this Letter of Preliminary Findings within thirty (30)
days of receipt by contacting:
12
Bryan Greene, General Deputy Assistant Secretary
Office of Fair Housing and Equal Opportunity
4517'" Street S.W.
Washington, D.C. 20410
Additionally, please send a copy of your request to:
Anne Quesada, Director
Office of Fair Housing and Equal Opportunity (Correspondence Code 9AEH)
600 Harrison Street, 3"i Floor
San Francisco, California 94107
The Department of Housing and Urban Development would like to resolve these matters
by reducing the findings and concerns to a written Voluntary Compliance Agreement (VCA) with
timetables for implementation (See 24 CFR H6.41(e), 1.7(d) (1) and 8.560) (2)). A DRAFT copy
of a VCA has been attached for your consideration. The department will contact you shortly to
arrange a mutually convenient time to discuss remedies to the findings and concerns noted above.
In the interim, please contact me at (415) 489-6536 or Program Compliance Branch Chief Jeff
Jackson at (415) 489-6538, if you have any questions or wish to pursue resolution of the findings
and concerns noted herein through a VCA.
Iir conclusion, this office would like to express our gratitude to you and your staff for the
cooperation and assistance extended to us throughout our review.
Very Sincerely Yours,
Anhe Quesada, Director
Office of Fair Housing and Equal Opportunity
Under the Freedom of Information Act, it may be necessary to release this document and related
correspondence and records to a third party, upon request. In tine event that the department
receives such a request, we will protect, to the extent provided by law, personal information,
which would constitute an unwarranted invasion of privacy if released.
Attachments:
1. "OMB Standards for Federal Data on Race and Ethnicity: HUD Policy Statement and
Implementing Guidelines", HUD policy memo dated 8/13/02
2. "Final Guidance to Federal Financial Assistance Recipients Regarding Title VI
Prohibition Against National Origin Discrimination Affecting Limited English Proficient
Persons; Notice" dated January 22, 2007yj07
cc:
Ophelia Basgal, Regional Administrator, Region IX
Maria Cremer, Director, HUD -Region IX, Office of Community Planning and Development
13
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MEMORANDUM, City of Lodi, Community Development Department
To: Rad Bartlam, City Manager
From: Joseph Wood, Neighborhood Services Manager
Date: October 25, 2013
Subject: Summary of HUD Letter of Preliminary Findings dated September 27, 2013
In December of 2012, HUD's Office of Fair Housing and Equal Opportunity (FHEO) conducted
an onsite review to examine the following processes of our CDBG Program: Citizen
Participation; Benefits, Services and Methods of Administration; Affirmatively Furthering Fair
Housing; and Section 504 Program Requirements. Their review focused on programs and
activities in the 2008/09, 2009/10 and 2010/11 Program years, which include Urban County
CDBG, HOME and NSP, State HOME, and our Entitlement CDBG. Over the course of four
days, FHEO staff reviewed our CDBG files and met with City staff including myself, the Building
Official, and the City Clerk. During that time they also reviewed files and met with staff at San
Joaquin County Neighborhood Preservation and San Joaquin Fair Housing.
On October 21, 2013, we finally received a Letter of Preliminary Findings which outlines
potential issues of non-compliance, the regulatory basis of the issue, the facts found during
their visit that substantiate the determination of non-compliance, and the corrective action
necessary to address the non-compliance. In total, they identified ten (10) findings and
fourteen (14) recommended corrective actions. In addition, they noted seven (7) lesser
concerns and a recommended corrective action for each.
Attached to the Letter of Preliminary Findings was a draft Voluntary Compliance Agreement
(VCA) that lists each corrective action that we will take in order to address the findings. HUD's
desire is to reduce the findings and concerns to a written VCA with timetables for
implementation. The draft VCA provides 180 days for implementation of most of these actions.
I've contacted the HUD-FHEO office already for clarification on a few issues and they
commented that they consider these to be minor issues and that the field notes indicate that
we've been doing a good job administering the program.
What follows is a summary of the issues and what action we need to take.
aly is sof;,ImOediments to Fair Housing (AD
For some background on this, when Lodi became an Entitlement in 2009, HUD required that we
do an Al and that was completed by Sarah Bontrager through our contract with PMC for CDBG
administration. We submitted the Al to HUD-FHEO in 2010 and did not hear anything further.
Our first feedback on the AI has come from their review during the onsite visit.
What they have found and called out in their Notice is that there were some analytical
deficiencies in the Al in relation to determining impediments that will need to be addressed. In
addition, they noted that some of the impediments that we identified in the Al were not
adequately substantiated. These issues will need to be addressed in the next Al document. In
my recent contact with FHEO, I made them aware that we are in the process of developing a
Fair Housing Equity Assessment (FHEA) through the HUD -funded Sustainable Communities
grant with Smart Valley Places and that the FHEA document will be the used as the
groundwork for a subsequent Al, likely in 2014/15. They acknowledged that and stated that
the VCA could be revised to reflect that.
Fair Housing Act
We will need to add additional disclaimer language on our notices and on printed materials to
cover non-discrimination, communication and accessibility requirements.
In addition, we will need to do a more thorough job of collecting and analyzing our beneficiary
demographic data and follow up with our subrecipients to make sure that they do the same.
This relates back to our ability to identify impediments, determine the cause and develop
actions to overcome them.
Through the analysis of demographic data from our applicants and beneficiaries accessing
funded programs, we will also need to identify whether any protected groups are
underrepresented relative to the general population and actively engage marketing to the
underrepresented group to resolve that.
Section 504
While the Building Official coordinates compliance with Section 504 for physical accessibility
(Transition Plan), we are required to have at least one person designated to coordinate
compliance with Section 504 program accessibility through all departments. A Section 504
Policy Manual is required, as well as a formal grievance procedure for complaints based on
both program and physical accessibility. This also touches on the need for additional language
in our notices and printed materials addressing non-discrimination and reasonable
accommodation, including TDD access.
They are calling for the review of the updated Transition Plan, which was underway at the time
of their onsite visit, to verify that it identifies barriers in all facilities, methods to remediate and
timetables for remediation. They made specific reference to the Grape Bowl facility and the
front ramps at City Hall that are out of compliance.
Along those same lines, we will need to ensure that any (subrecipient's) facilities assisted with
CDBG funding or where CDBG funded programs and activities are carried out are accessible.
I have found Section 504 Coordinator training/certification on-line, as well as the Policy Manual.
Site Selection for Affordable Housing
In the future, we will need to be sure that we conduct racial and ethnic demographic analysis
when selecting a site for affordable housing development in order to avoid the creation or
perpetuation of minority concentration.
FHEO noted that when we developed the four new SFD units on Oak and Garfield, while we did
promote homeownership opportunities for an underrepresented minority population, we
perpetuated the over -concentration of Hispanic population within that census tract.
Furthermore, we failed to meet the greater need of providing affordable family housing in that
area.
Limited English Proficient Persons (LEP)
To address concerns related to limiting participation of LEP persons, we will need to adopt and
implement a Language Access Plan. We will need to make sure that our notices and printed
materials are available in other languages and make sure that our subrecipients do the same.
I've already downloaded and am looking through the Language Access Assessment and
Planning Tool for Federally Conducted and Federally Assisted Programs. Much of the outreach
for the development of Language Access Plan can be incorporated into the Consolidated Plan
process.
Spay/Neuter Program
FHEO has taken issue with our funding of the spay/neuter program over programs or activities
that serve priority needs listed in the Consolidated Plan: job creation and ESL for LEP
Hispanics. They are calling for our rating and ranking system to provide priority points for
activities that address unmet Al and Con Plan needs, and are likely to benefit the lowest income
members of the community: Hispanics, Female Head of Household with Children, and Disabled
Persons.
In Conclusion
I believe that all of these issues can be addressed with appropriate changes in our operational
policies and procedures. With my initial follow up call with them, HUD-FHEO is aware that we
are working on a number of these issues already. The next step is to schedule a conference
call or meeting with them. I'm attaching a copy of both the Notice and the VCA for your review.
Let me know how you want me to proceed and if you need me to prepare anything for the City
Council's review.
Joseph Wood, Manager
Neighborhood Services Division
Community Development Department
0
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MEMORANDUM, Lodi Improvement Committee
0: Mayor Nakanishi and Lodi City Councilmembers
rom: Sunil Yadav, Lodi Improvement Committee Chairman
• September 11, 2013
ect: Cherokee Lane Corridor Improvements
onorable Mayor and Council Members,
June 11"', 2013, the Lodi Improvement Committee held a Special Meeting out in the
stside community to hear from the residents and business owners along the Cherokee Lane
ridor. The issues and concerns that they expressed regarding the general conditions along
erokee Lane and the lack of adequate sidewalks and accessibility accommodations are
led out in the attached letter from them.
e Lodi Improvement Committee has established a goal of promoting the development of
autification and improvement projects for the Cherokee Lane corridor. On behalf of the
tire Lodi Improvement Committee, I ask that the City work with us and the local business and
)perty owners in this effort to improve one of the City's oldest commercial corridors and one
the Eastside's main thoroughfares.
ncerely,
nil Yadav, Chair
9i Improvement Committee
City Manager
Public Works Director
City Engineer
ity Clerk
ity of Lodi
.0. Box 3006
odi, CA 95241-1910
RE: Condition of Cherokee Lane -Hotel & other Property Owner Concerns
Mayor, City Council Members, & City Manager:
he undersigned write this letter to voice our concerns for the continued deterioration of
herokee Lane, and the difficulty that hotel and motel owners face with missing and broken
dewalks as well as the street's general appearance.
.o rernind you, the vast majority of.Cherokee Lane property owners volunteered to assess
iemselves for improvernents to Cherokee Lane in 1995. We are specifically referring to the
Lodi Central City Revitalization District No. 95-1, Zone B AS -018". We as property owners
ave been paying these assessments for over 15 years, but our street has long been forgotten.
pink about what other streets in Lodi that have portions with no curb and no sidewalk -we're not
ure there are any. Though some improvements were made, I think you all would agree that this
nportant gateway to Lodi has long since been neglected, while at the same time, other streets
ave enjoyed the benefits of revitalization. Unlike Cherokee Lane, however, these other streets
o not welcome out of town visitors and passers-by with needed lodging facilities, restaurants,
teres, and gas stations. The current economic conditions make it even more difficult for our
irgely family-owned businesses to generate incomes. Unlike Cherokee Lane, the owners of
roperty fronting these other streets that have been revitalized pay no assessments. To be
andicapped by the conditions found in the public rights of way makes business survival even
lore difficult. The absence of any effort on the part of the City to improve the appearance of
'herokee Lane quite frankly puzzles us, as either we or our tenants generate significant amounts
f transient occupancy taxes, sales taxes, fuel taxes, and property taxes, not to mention many
esperately-needed jobs.
undersigned respectfully ask that Cherokee Lane be given the attention it deserves as Lodi's
gateway to Highway 99 and East Highway 12.
incerely,
owners of Cherokee Lane:
S T�CZ."r G-) t *--h 2i
Cherokee Lane Property/Business Owners: o " r far I, S 4 1-4 C- t4^ e -42,e-3 V --
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® MEMORANDUM, Lodi Improvement Committee
To: Mayor Nakanishi and Lodi City Councilmembers
From: Sunil Yadav, Lodi Improvement Committee Chairman
Date: September 11, 2013
Subject: Cherokee Lane Corridor Improvements
Honorable Mayor and Council Members,
On June 11th, 2013, the Lodi Improvement Committee held a Special Meeting out in the
Eastside community to hear from the residents and business owners along the Cherokee Lane
corridor. The issues and concerns that they expressed regarding the general conditions along
Cherokee Lane and the lack of adequate sidewalks and accessibility accommodations are
called out in the attached letter from them.
The Lodi Improvement Committee has established a goal of promoting the development of
beautification and improvement projects for the Cherokee Lane corridor. On behalf of the
entire Lodi Improvement Committee, I ask that the City work with us and the local business and
property owners in this effort to improve one of the City's oldest commercial corridors and one
of the Eastside's main thoroughfares.
Sincerely,
Sunil Yadav, Chair
Lodi Improvement Committee
cc: City Manager
Public Works Director
City Engineer
G-1
-Record
April 2, 2014
To: Lodi City Council
From: Committee for a Better Life in Lodi (Comite Para Una Vida Mejor en Lodi)
Re: Letter from the Community to the Lodi City Council
Dear City Council Members,
Thank you very much for the opportunity to present this letter to you. We hope that this
brings about an improved connection with our City Government. We authorized Mrs Maria
Rosado of California Human Development to bring and read this letter to you in our name.
We would also like to express our gratitude to Mr. Joseph Wood from the City of Lodi for his
time and effort in meeting with us. At these meetings we expressed the following needs of
our community:
1) Community Center — Our community wants and needs a place where we can share our
talents and learn new skills and abilities. We would like to have sewing, cooking,
dancing, and other classes to enrich our community;, share our Mexican heritage with
our children, and practice and learn new things about the culture of the place that is
now our home — Lodi. The community recommends that we also use this center to
provide English classes, parenting classes, and nutrition classes.
We ask that the City consider building a community center on the East side of Lodi.
2) Cleaning of Streets and alleys — Our community wants and needs to live in a
neighborhood where the streets and alleys are cleaned regularly. We look towards
the West and see beautiful houses and clean streets. We want to cooperate with the
City and help maintain our streets and alleys clean on the days that cleaning is not
scheduled. We make that commitment and
We ask that our streets and alleyways are cleaned more often and on a regular basis
on the East of Lodi.
3) Community Garden — Our community wants and needs a community garden to
enhance our neighborhood and provide healthy foods for our families. We believe
that a community garden will give us the opportunity to engage our youth in safe and
healthy activities. It will be a good way to keep our youth busy and keep them away
from crime and gang involvement.
We ask that the City approve the creation of a community garden located on the East
side of Lodi.
4) Housing — Our community wants and needs housing that is comfortable, in good
condition, and affordable for all. It is very difficult for us to find housing in good
condition and affordable. Many of us do not qualify to live in good housing because
we lack money or good credit. We are not able to purchase a home. We know that
there are programs that assist low income individuals with purchasing their first home
or retrofitting the current home to make it more comfortable and energy efficient.
We ask that the City consider creating programs that help improve housing conditions
and help those that wish to purchase their first home.
5) Protection and Security — Our community wants and needs to live in a place where
crime is reduced and people feel secure and able to count on the protection from their
Police. Department. We feel unsafe in our parks and are fearful that something will
happen to our kids when they walk to school.
We ask that the City consider providing more protection for our neighborhoods on the
East side of Lodi.
6) Health Services and Other Community Services — Our community wants and needs
better access to community services. The hospital and medical clinics are located
outside of our neighborhoods. We know that community services are very necessary
in our neighborhoods. We recommend that the City plan for a community center and
consider using it to bring more community services and health services there also.
We ask that the City consider bringing more health services and community services
to a community center located closer to our neighborhoods on the East of Lodi.
We, the community of the East side of Lodi, want to cooperate with the City and be of
assistance any time you need us so that we can start on the path and be able to reach our
goal of a Better Life in Lodi for All.
Respectfully,
(signatures attached)
El Comite Para Una Vida Mejor en Lodi
Committe For a Better Life in Lodi
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CITY OF LODI
LEGAL ADVERTISEMENT
ADVERTISING INSTRUCTIONS
SUBJECT: NOTICE OF PUBLIC HEARING FOR DISCUSSION OF POSSIBLE
CDBG APPLICATIONS
PUBLISH (DATES): March 13, 2014
ACCT#: 20104930
TEAR SHEETS WANTED: 1 EXTRA (ONLY) DELIVER TO: Community
Development Dept.
AFFIDAVIT &BILL TO: Community Development - CDBG
City of Lodi
221 W. Pine Street
Lodi, CA 95241
DATE: March 11, 2014 ORDERED BY: Joseph Wood
TITLE: Neighborhood Services Division Manager
JACommunity Development\Neighborhood Services Division\CDBG\2014-2015\Notices\Public Hearing Notice Con Plan 3-13-
14.doc
DECLARATION OF POSTING
PUBLIC HEARING TO CONSIDER DRAFT 2014-2018 CONSOLIDATED
PLAN FOR THE COMMUNITY DEVELOPMENT BLOCK GRANT
PROGRAM
On Thursday, March 20, 2014, in the City of Lodi, San Joaquin County, California, a
Notice of Public Hearing to consider draft 2014-2018 Consolidated Plan for the
Community Development Block Grant Program (attached and marked as Exhibit A) was
posted at the following locations:
Lodi City Clerk's Office
Lodi City Hall Lobby
Lodi Carnegie Forum
I declare under penalty of perjury that the foregoing is true and correct.
Executed on March 20, 2014, at Lodi, California.
.f ROBISON,
CITY CLERK
.►
N:\Administration\CLERK\Forms\DECPOSTCD.DOC
ORDERED BY:
RANDI JOHL-OLSON
CITY CLERK
MARIA DITMORE
ADMINISTRATIVE CLERK
�y OFA
DECLARATION OF MAILING
PUBLIC HEARING TO CONSIDER DRAFT 2014-2018 CONSOLIDATED PLAN FOR THE
COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM
On Thursday, March 20, 2014, in the City of Lodi, San Joaquin County, California, I deposited
in the United States mail, envelopes with first-class postage prepaid thereon, containing a
Notice of Public Hearing to consider draft 2014-2018 Consolidated Plan for the Community
Development Block Grant Program, attached hereto marked Exhibit A. The mailing list for said
matter is attached hereto marked Exhibit B.
There is a regular daily communication by mail between the City of Lodi, California, and the
places to which said envelopes were addressed.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on March 20, 2014, at Lodi, California.
J IFER M. OBISON, CMC
A ISTANT CITY CLERK
Forms/decmail.doc
RANDIJOHL
CITY CLERK, CITY OF LODI
MARIA DITMORE
ADMINISTRATIVE CLERK
a.
LEGAL NOTICE
NOTICE OF PUBLIC HEARING FOR DISCUSSION OF THE COMMUNITY
DEVELOPMENT BLOCK GRANT PROGRAM
NOTICE IS HEREBY GIVEN that a public hearing will be held on Wednesday, April 2, 2014 at 7:00
p.m. or as soon thereafter as the matter may be heard, in the Lodi City Council Chambers, 305 West Pine
Street, Lodi, CA 95241 in order to consider the Community Development Block Grant (CDBG) Program
Consolidated Plan development process and to receive input regarding community needs and funding
priorities. The City expects to receive $650,000 in CDBG funds for 2014/15.
The CDBG program provides funding for activities that benefit low-income persons, eliminate slum or
blight, or serve an urgent need. Eligible activities include property acquisition, public improvements,
housing rehabilitation, economic development, and public services.
The Consolidated Plan (Con Plan) is one of the three documents required to receive federal housing and
community development funding through the Community Development Block Grant (CDBG) program.
The overall goal of these housing and community development programs is to serve low- and moderate -
income persons by developing viable urban communities through the following actions:
* Providing decent housing;
* Providing a suitable living environment; and
* Expanding economic opportunities.
The Consolidated Plan is the five-year plan for identifying and addressing community needs in
the areas of Housing, Homelessness, Special Needs and Community Development. This
Consolidated Plan will cover activities to be funded from 2014 through 2018. Incorporated into
the proposed Consolidated Plan is the 2014/15 Annual Action Plan. The Action Plan generally
describes how the City will utilize program funds for eligible activities during the fiscal year. The Action
Plan can be amended as needed to reallocate funds to housing and community development activities.
Planning documents will be made available to the public for at least 30 days before adoption by the City
Council. The documents are anticipated to be released on April 7, 2014 for public review and comment.
An additional public hearing will be held on Wednesday, May 7, 2014 for review and adoption of the
Consolidated Plan.
The purpose of this public hearing will be to give citizens an opportunity to make their comments known
regarding community needs and potential activities to be funded under the CDBG Program. If you are
unable to attend the public hearing, you may direct written comments to the City Clerk, City of Lodi, PO
Box 3006, Lodi, CA 95241, or you may telephone (209) 333-6711. In addition, information is available
for review at Lodi City Hall (221 West Pine Street) between the hours of 8:00 a.m. and 5:00 p.m. on
weekdays.
Notice of Non -Discrimination on the Basis of Disability and Reasonable Accommodation
The City promotes fair housing and makes all its programs available to low- and moderate -income
families regardless of age, race, color, religion, sex, national origin, sexual preference, marital status or
handicap.
JACommunity Development\Neighborhood Services Division\CDBG\2014-2015\Notices\Public Hearing Notice Con Plan 3-13-
14.doc
The City of Lodi does not discriminate in admission or access to, or treatment or employment in,
its federally assisted programs and activities on the basis of disability. Reasonable
accommodations will be made available to the disabled, upon request. Translators/Translation
services are also available upon request. Any questions, concerns or requests related to these
Notices should be directed to the following person:
Joseph Wood, (209) 333-6800 x2467.
Neighborhood Services Manager
Joseph Wood
Dated: March 11, 2014
JACommunity Development\Neighborhood Services Division\CDBG\2014-2015\Notices\Public Hearing Notice Con Plan 3-13-
14.doc
2014/15 CDBG Mailing List
Captains Tory and Martin Ross
c/o Salvation Army, Lodi Corps
PO Box 1388
Lodi, CA 95241
martin.rossgusw. salvationarmy.or..
209-369-5896 x107
Mike Mallory
c/o Second Harvest Food Bank
704 E. Industrial Park Drive
Manteca, CA 95337-6116
ktapia feedinaamerica.ortr
209-239-2091
Rebeca Knodt
c/o Emergency Food Bank of Stockton/San Joaquin
7 W. Scotts Avenue
Stockton, CA 95202
rknodt ,stocktonfoodbank.org
209-464-7369
Peggy Wagner
c/o San Joaquin County Fair Housing Association
247 E. Miner Ave
Stockton, CA 95202
PeggyWgsjfaii•hous.ing com
(209) 451-3471
Tracy Williams
c/o LOEL Foundation, Inc.
105 S. Washington Street
Lodi, CA 95240
tracy@loelcenter.net
209-368-2050
Dean Fujimoto
c/o SJC Human Services Agency
PO Box 201056
Stockton, CA 95201
Nate McBride
c/o Small Business Development Center
56 S. Lincoln Street
Stockton, CA 95203
Cheryl Francis
c/o Grace and Mercy Charitable Foundation
PO Box 2236
Lodi, CA 95242
cherylp_gracenmerc ylodi. com
925-864-0183
EXHOT
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