Sunday, May 8, 2016

Veteran Housing, Rental Assistance and HUD stuff



SHA's Southfair Apartments
The Salem Housing Advisory Committee recently recommended that the Salem Housing Authority (SHA) apply for an Oregon Health Authority grant of up to $1.25M in transitional housing rental assistance for homeless and at risk veterans.  This Housing Firstish program aims to assist as many as 30 veterans secure permanent rental assistance. 

SHA would take care of the housing aspects of the program, and Mid-Willamette Community Action Agency would provide direct services to clients.  The funding is available for nine months (October through June 2017), with extensions expected.  The SHA Board of Commissioners is expected to approve the idea at Monday's meeting.  Some details here.      

Also Monday, the City Council is expected to approve the 2016 Annual Action Plan after a public hearing.  Normally, the City's HUD-required plans receive no comment from the public (aside from that of interested parties) at the hearing, but this year might be different, owing to the submission of the following comment during the 30-day written comment period.   




COMMENT OF SARAH OWENS AND MICHAEL LIVINGSTON ON THE ANNUAL ACTION PLAN PROPOSED PURSUANT TO 24 CFR 92.220 

Introduction

This Comment is concerned with the narrative portion of the draft 2016 Annual Action Plan (The Plan), prepared for the City of Salem and issued March 31, 2016 for public comment.  It is concerned only with the narrative, and assumes, without endorsing, the appropriateness of the most recent funding recommendations, the accuracy of financial statements contained in The Plan, and the correct application of program-specific requirements.

It is understood that The Plan’s format is determined by 24 CFR 91.220.  It is further understood that most of The Plan narrative appeared in the 2015-19 Housing and Community Development Consolidated Plan (2015-19 Consolidated Plan), which was adopted by the Salem City Council on April 27, 2015. It’s understood that, mainly, all that’s “new” are the 2016-17 projects and available funding (“resources”).  Because most of the narrative has been approved previously, it is assumed and understood that The Plan as drafted probably meets the minimum requirements of the U.S. Housing and Urban Development Department (HUD).  

Notwithstanding the fact that The Plan may withstand federal and local governmental scrutiny, the concern expressed here, and below in greater detail, is that, with two exceptions, The Plan narrative contains errors, fails frequently to provide the required information, and makes  overly general and sometimes false assertions about the City’s actions and relationships, particularly its efforts to consult, collaborate and coordinate, such that the reader is both denied important information, and given a falsely positive impression of this community’s, and particularly the City’s, commitment to addressing its housing/homeless problems.   

The two exceptions are the portions of The Plan describing:  1) federal programs administration, and 2) Salem Housing Authority actions and administration, which seem to be accurate.

Those two exceptions aside, the average citizen reading The Plan narrative would be left with the impression that the City is an active participant in a functional regional (Marion and Polk Counties) “continuum of care”, but would not know what actions, specifically, the City had taken or plans to take to consult, collaborate and coordinate, what specific agencies those actions involve(d), and what the City’s role/relationship is/was with those other agencies.  We urge the City to correct these and the other deficiencies detailed below, before approving The Plan.

For example, if, as The Plan asserts, “City staff has been meeting with key community leaders to implement a ‘Housing First’ Model”, The Plan should identify the City agent/department involved, the community leaders involved, the name of the group and its charter/organizational structure, if any, the entity responsible for coordinating meetings and keeping records of any proceedings, how often they occur, whether they’re public, and so on.

If the City cannot describe its actions with greater accuracy and specificity than it has, its generalized, self-serving statements should be omitted from The Plan as unnecessary and misleading.  As The Plan itself states, all it really need do is “discuss the projects and programs taking place during the 2016-2017 Plan Year.”

Below, by way of illustration, are described some of the most problematic portions of the narrative.  The list is not meant to be exhaustive.   

Specific Features of The Plan

In the section “PR-05 Lead & Responsible Agencies”, The Plan contains this optional narrative: 

Activities and programs funded by both CDBG and HOME are carried out in cooperation with several partners: community based non-profit organizations, for-profit organizations, faith-based groups, private developers, and other City and State agencies and departments. The creation of this Annual Action Plan is a collective effort of City of Salem Urban Development staff, Salem Urban Devleopment [sic] Community Services and Housing Commission (CSHC), participating citizens, and community stakeholders.

CDBG- and HOME-funded activities and programs are carried out in cooperation with the City’s sub-grantees, which are named later in The Plan.  As discussed below, The Plan is basically the product of the City’s Urban Development Department.  To say that The Plan is the result of some kind of collective effort is greatly overstating the degree to which The Plan reflects outside inputs. 
The CSHC is responsible to review and rank grant applications, and make funding recommendations to the City Council.  At the end of that process, it is asked to recommend pro forma adoption of The Plan. 
 
Neither the CSHC, the citizenry, nor the “community stakeholders” (i.e., sub-grantees) were involved in any meaningful way in the creation of the plan, or, historically, have ever given it scrutiny, if they read it at all. 
 
In the section “AP-10 Consultation”, under “1. Introduction”, The Plan states “The development of this Annual Action Plan is guided by the effort of CSHC.”  As discussed above, the CSHC is responsible to review and rank grant applications, and make funding recommendations to the City Council.  At the end of that process, it is asked to recommend pro forma adoption of The Plan.  The CSHC does not “guide the development” of The Plan. 
 
Further on in this section, The Plan states, “Staff is working with…key agencies…to better coordinate housing, health, mental health, prevention of homelessness, and social services in the City of Salem.”  It is unclear from either this statement or the narrative that follows it what actions the City has taken or will take, and which agencies those actions involve.  If, indeed, “Staff” are working with “key agencies” in some way outside federal programs administrative activities, the narrative should describe that work in sufficient detail to allow the average citizen to understand and seek more information about it.

Under “Provide a concise summary of…activities to enhance coordination…”, The Plan states, “Activities to enhance coordination…are evident in the organizations listed in the Consultation section of this Consolidated Plan.”  However, no coordinating activities are evident in the section referred to, which is just a list of the most recent federal grant applications, discussed below in more detail. 
   
Under “Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons…and persons at risk of homelessness”, The Plan states that “The Continuum of Care is a community[-]based long-range planning organization…[that] is comprised of community stakeholders...”, that “Over the next year, the City’s strategy…is to support community agencies providing services…”, that “The City…will continue to advance the efforts of the Marion and Polk Counties Plan to End Homelessness through partnerships with members of the Continuum of Care”, and that “Gap analysis allows the City of Salem to leverage other viable and necessary resources for programs and projects.”  

The narrative that follows the latter statement fails to support or even make sense of it.  

The narrative does not discuss how the City will, beyond being a conduit for federal funds, “support” agencies or “advance the efforts” of the Marion and Polk Counties Plan to End Homelessness (10-Year Plan).  In fact, the City has never attempted to implement the 10-Year Plan, as discussed below.

The comparable 2015-19 Consolidated Plan narrative states that the City’s “strategy of reducing, preventing, and supporting the elimination of homelessness is to market CDBG and HOME funds.”  2015-19 Con Plan at 14.  (Emphasis added.)  If, as The Plan would seem to suggest, the City’s strategy consists of more than marketing CDBG and Home funds, The Plan should describe those elements specifically. 
  
The statement that the Continuum of Care for Marion and Polk Counties (CoC) constitutes a long-range planning organization comprised of community “stakeholders” is misleading.  According to the Mid-Willamette Community Action Agency, which is responsible for coordinating CoC meetings, the CoC consists only of the current funding cycle’s “sub-grantees”, which MWVCAA has, by its own admission, been unable to expand into an effective network, or engage in long-range planning.[i]  On information and belief, this fact is well known in the provider community.

If the City does have partnerships with (vs. favorites among) the CoC members (i.e., its sub-grantees) beyond monitoring compliance with funding requirements, then The Plan should describe the partnerships in sufficient detail to allow the average citizen to understand them, including which agencies of the City are involved, with which sub-grantee, and the nature of the partnership. 

Under “Describe consultation with the Continuum(s) of Care…in determining how to allocate ESG funds, develop performance standards and evaluate outcomes, and develop funding, policies and procedures for the administration of HMIS”, The Plan narrative makes no mention of ESG funds, performance standards, outcome evaluation, funding development or HMIS administration, all of which suggests that no such consultations/determinations occurred, consistent with the City’s limited involvement with CoC members, as described above.  If consultations did occur, The Plan should describe them specifically, and describe specifically what, if any, determinations were made as a result.  If they did not occur, The Plan should explain why they did not occur and what steps the City intends to take over the next year to remedy its failure. 

Under “2. Describe Agencies, groups, organizations and others who participated in the process and describe the jurisdiction[‘]s consultations with housing, social service agencies and other entities”, and for each agency/group/organization, discuss “How was the Agency/Group/ Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination?”, The Plan lists, with one exception, only agencies that applied for funds, what the funds were for, and whether the funds were awarded.  There is no discussion of anticipated outcomes or improving coordination. 
    
The one non-applicant agency listed in this section is the Emergency Housing Network (EHN), which is a group of “hundreds of community partners and stakeholders who want to network with, educate, or update other advocates and agencies serving the homeless and at-risk populations of greater Salem.”  Its monthly meetings follow a lunch/speaker/networking format and is facilitated by the Salem Housing Authority.[ii]  

The Plan states that EHN “was consulted through notification and distributed information at the March …2016 meeting.”  However, all that occurred at that meeting was that a federal programs employee made a 15-second announcement at the end of the meeting that The Plan’s public comment period would open at the end of the month, followed by the public hearing in May.  Announcements and accepting grant applications cannot reasonably be construed as the equivalent of a consultation.
      
Lastly, the narrative in this section omits one grant applicant: the Salvation Army.  The minutes of the CSHC, which reviews these funding applications and makes federal funding recommendations to the Salem City Council, indicate that the Salvation Army applied for, and was denied funds during the funding cycle covered by The Plan.  It is not, however, listed anywhere in The Plan.[iii]
Under “Identify any Agency Types not consulted and provide rationale for not consulting”, The Plan states, “A wide range of…[agency types was] consulted during this [sic] Consolidated Plan process and subsequently as listed above for the Annual Action Plan and public meetings. There were no known agency types not consulted.” 

However, the Consolidated Plan process took place last year.  The information requested concerns consultations made with respect to this year’s Plan.  If, as it appears, the City consulted only this year’s grant applicants “and public meetings”, then The Plan should so state, describing any “public meetings” with enough specificity for the average citizen to be able to identify them. 

The fact that the City consulted a wider range of agency types last year might, perhaps, be a rationale for not consulting them again during this year’s process.  However, if the City has the collaborative relationship with providers (other than its sub-grantees), consulting them during this year’s process should not have been difficult.   

Under “Other local/regional/state/federal planning efforts considered when preparing the Plan”, the CoC and its four assigned goals from the 10-Year Plan are listed.  They appear in bold print in the excerpt below: 

Create new permanent housing beds for the chronically homeless (60 beds in 10 years); increase the percentage of homeless persons staying in permanent housing over six months to at least 71 percent (increase from 80 percent to 85 percent?); increase the percentage of homeless persons moving from transitional housing to permanent housing; increase the percentage of homeless persons employed at completion of the self-sufficiency program (from 33 to 40 percent); decrease the number of homeless households with children (from 292 to at most 155). 

The source of the additional information (not in bold) cannot be identified by either the “Lead Organization” (MWCAA) or the City.  While some kind of performance metrics are certainly needed, they need to be understandable and tied to a reliable data source/method, which these presently are not.  If the source of additional text cannot be determined and its meaning clarified, it should be omitted.  

In that same list is a plan called “Housing First Model.”  The Plan states: 

City of Salem City staff has been meeting with key community leaders to implement a "Housing First" model that would mirror the prevalent permanent supportive housing best practices approach. This includes: Resource mapping to identify all community resources currently flowing into the housing and social service delivery system; leveraging Section 8 vouchers, SHA resources, local, and federal funds in a comprehensive way to provide maximum benefit to target populations; changing housing capital resource allocation processes to ensure integrated, outcome-based investment strategies; and creating new programs utilizing existing unrestricted, market housing units as the backbone for implementing a "Housing First" model. This includes creating financial and non-financial incentives to participate.
  
The same entry occurs in the 2015-19 Consolidated Plan, however, despite asking dozens of community providers what this entry might be referring to, its origin remains unknown.  It cannot be referring to the MWHI, as that entity was not even conceived until six months after the Consolidated Plan was adopted. 
In any event, as noted above, The Plan should identify which City staff have been meeting with which “key community leaders” and where more information about this effort can be found, or it should be omitted as lacking any factual basis.
 
Under “Describe cooperation and coordination with other public entities, including the State and any adjacent units of general local government, in the implementation of the Consolidated Plan”, The Plan refers to the Mid-Willamette Homeless Initiative, but does not describe how the MWHI Task Force is cooperating and coordinating in the implementation of the Consolidated Plan.  In fact, there is no mention of the Consolidated Plan anywhere in the MWHI Task Force charter, minutes or meeting materials.  Rather, those documents evince the MWHI Task Force’s intent to create its own plan, without reference to the Consolidated Plan.

Below the reference to the MWHI, The Plan states,

Other public entities coordinated with throughout the implementation of the Consolidated Plan include: the City of Salem Planning and Public Works Departments, Mid-Willamette Valley Council of Governments, Oregon Health Authority, etc. 
  
The Planning Division is in the Community Development Department.  Neither it, nor the Public Works Department, are “other public entities.”  They are parts of the same entity, namely the City of Salem, so their reference here is inapt.  Moreover, the narrative fails to describe the nature of the alleged cooperation/coordination with the MWV Council of Governments or the Oregon Health Authority or the entities meant to be included by “etc.” 

If there are indeed additional public entities with which the City has cooperated/coordinated, they should be identified and the cooperation/coordination described in sufficient detail to allow the average citizen to understand it.  The comparable section of the 2015-2019 Consolidated Plan is more, but not completely, responsive to the question. 

In the section “AP-12 Participation”, under “1. Summary of citizen participation process/Efforts made to broaden citizen participation [:] Summarize citizen participation process and how it impacted goal-setting”, The Plan describes the process used last year for the 2015-2019 Consolidated Plan.  But, as discussed above, that was last year’s process, so the narrative is not responsive to the question.

The Plan also restates that “The development of the 2015-2019 Consolidated Plan and the Annual Action Plan is guided by the effort of the Community Services and Housing Commission (CSHC)...”  Presumably, the City means by this to impart that CSHC is one form of citizen participation, which it is.
As discussed above, however, the CSHC (and up until fall of 2015, the CSHC’s predecessor board [SSAB] and commission [HUDAC]) is responsible to review and rank grant applications, and make funding recommendations to the City Council.  At the end of that process, CSHC is asked to recommend pro forma adoption of The Plan.  It did not, beyond executing those duties, “guide” the development of the Consolidated Plan or this Annual Action Plan, as shown by the CSHC minutes.  The Plan development is guided by staff, not CSHC.
The same is true of the repeated generic reference to the MWHI Task Force in this section.  The MWHI Task Force had no role in the citizen-participation process, and has had no impact on goal-setting for The Plan.  The fact of its formation is, rather, further evidence of the CoC’s irrelevance in this community, as discussed below. 

The MWHI was conceived as a response to pressure from local citizens and downtown businesses on the City Council, particularly the Mayor, arising from the long-unmet need for after-hours public toilets downtown, and concern over the lack of shelter for homeless youth, particularly minor females.  If the CoC were in fact the functional network that The Plan describes, Salem’s Mayor and City Council would have turned to it, rather than forming yet another quasi-government entity like the MWHI Task Force to create yet another strategic plan to address the problems of housing/homelessness in this community.

Also in this section, The Plan restates the paragraph, discussed above, from the Introduction:  “Staff is working with…key agencies…to better coordinate housing, health, mental health, prevention of homelessness, and social services in the City of Salem.”  As observed previously, it is unclear from either this statement or its context what coordinating actions the City has taken or plans to take, and which agencies those actions involve.  It is also unclear what, if anything, these actions have to do with The Plan’s citizen-participation process.
The City’s efforts to broaden citizen participation were and are inadequate, notwithstanding that they may, nominally, satisfy The Citizen Participation Plan.  In 2016, it is nothing short of a bureaucratic fiction that a one-day notice in a local paper of steadily diminishing circulation, a “media release”, and two 15-second announcements at monthly meeting of local providers somehow constitute outreach.  And it’s not a matter of resources or ability, as discussed below.  
   
The City does know how to encourage citizens to participate, as, for example, demonstrated by the many Facebook postings inviting citizens to attend the Mayor’s State of the City speech luncheon.  The City simply hasn’t made the same effort with respect to The Plan.

On request, the City did post, once, on its Facebook page, an announcement of the May 9 hearing on The Plan with an obscure link to something called, “bit.ly” (not what was requested, but technically correct).  A slightly more engaging notice and link went out in the April 15 Community Connection.  Much more could have been done.

Lastly, despite the fact that the City advertised that paper copies of The Plan would be available at two locations, at no time could we find paper copies of The Plan at the Library, or Library staff that knew anything about the Plan.  Urban Development Department staff, when asked, printed a copy of The Plan for us, but, obviously, we had to know to ask for it.  There were no copies with the other literature in the waiting area when we visited during the comment period.   
In the section “AP-15 Expected Resources”, The Plan states that “The City does not participate in a Section 108 loan guarantee program…”[iv]  However, in section “AP-35 Projects”, the name of Project 5 is “108 Loan Payments”, which is described in the section “AP-38 Projects Summary” as “This project is for the payment of 108 Loan Payments [sic].”  These apparently inconsistent statements need to be reconciled and the project explained in sufficient detail to permit the average citizen to understand Project 5.

In the section “AP-35 Projects”, is a table that lists Project 5 as “108 Loan Payments”, which is described in the section “AP-38 Projects Summary” as “This project is for the payment of 108 Loan Payments [sic].”  However, in section “AP-15 Expected Resources”, The Plan states that “The City does not participate in a Section 108 loan guarantee program…”  These apparently inconsistent statements need to be reconciled and the project explained in sufficient detail to permit the average citizen to understand Project 5.

Under “Describe the reasons for allocation priorities and any obstacles to addressing underserved needs”, The Plan states only that allocations are based on Consolidated Plan goals/priorities, which, of course, does not explain why some projects were funded and others were not, or why some received the full amount of the request and some received less.  (The standard explanation in section AP-10 that the unfunded projects were not funded “due to the number of applications and the limited amount of funding available” is bureaucratic nonsense and unacceptable.) 

It should be acknowledged that, as anyone who has participated in or witnessed the rating process knows, the process is highly political.  Therefore, giving true reasons for allocation priorities would be difficult, but not impossible. 
   
As for the obstacles, The Plan asserts that “[t]he largest obstacle to addressing the needs of underserved populations is that there is simply not enough money” and (in more bureaucratic language) that housing subsidies have not kept pace with rising rents.  This response is further proof, if any were needed, that The Plan is not the product of collaboration with the community, for the reasons discussed below. 

Everyone knows that there is not enough money.  There is never enough money.  That is precisely why coordination and collaboration are needed.  But, like a lot of things, it’s not likely to happen until the City recognizes it’s not happening, and resolves to do something about it.  Salem residents must face the fact that Salem is not the “collaboration capital” when it comes to addressing the problems of housing/homelessness.  Salem is, rather, the “everybody-does-their-own-thing capital” in this area. 

The City is asked in this section to analyze the way that services are provided – not just federally funded services, but all services – and determine what, besides “money”, is preventing those services from reaching the people who need them.  For instance, Salem’s only shelters are in Marion County.  The requirement of probation that one reside in the supervising county is an obstacle to serving the need for shelter of homeless West Salem residents on probation.  The analysis would be easy if the City had, in fact, engaged in the coordinating and collaborative activities it purports to have done, and more difficult if it has not. 
           
In the section “AP-65 Homeless”, under “Describe the jurisdiction’s one-year goals and actions for reducing and ending homelessness including [:] Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs”, the Plan describes only the annual Point-in-Time Count and the MWHI.  The Plan states:

The purpose of [the MWHI] is to address issues that cause and contribute to homelessness, to determine and address barriers to necessary housing, and to respond to needs identified in the Mid-Willamette Valley Community Action Agency’s 2015 Homeless Count Report, the Consolidated Plan, and Council Goals.

However, according to the MWHI’s Charter, the purpose of the MWHI is “to identify and launch proven strategies that will reduce homelessness in the Marion-Polk county region.  The MWHI Task Force includes no one from the homeless community, and it has never stated it intends to carry out the above purpose attributed to it.  The MWHI did not even come into existence until 2016.
Aside from administering federal grants, “the jurisdiction” has no one-year goals/actions for reducing ending homelessness or reaching out to homeless persons and assessing their individual needs.  That is because “the jurisdiction” is not coordinated, despite The Plan’s assertions to the contrary.  For years, segments of the community have engaged in uncoordinated, piecemeal efforts through loosely networked organizations, each doing their own thing, as they compete for funding.  They are not working in concert or individually to implement the 10-Year Plan, except insofar as their goals may overlap.  Their plans, if they have one, are their own, and they are not coordinated with others’ plans in any meaningful sense.

Under “Addressing the emergency shelter and transitional housing needs of homeless persons”,  Helping homeless persons”, and “Helping low-income individuals and families”, The Plan describes only those organizations and programs that recently received federal grants, and then states, under “Discussion”, 

As described above, the City will be continuing the effort to prevent and eliminate homelessness. The issue of homelessness will be addressed through multiple programs…”  

The failure to include in this section the “multiple programs” that did not receive funding is a further indication that the City’s goals and actions with respect to preventing and eliminating homelessness are limited to administering the grant process.   
  
There is, moreover, notably absent from this section of The Plan any mention of the annual Salem-Keizer Community Connect that occurs each March, for which the City of Salem provides two dental vans at a cost of about $2,000, or the fact that the Salem police officers have partnered with mental health and other social workers to assist them in encounters with people living on the streets and in encampments around the City, as opposed to arresting them, as was the practice previously.  Once again, had The Plan truly been the product of collaboration, these details, and many others, would have been included.               
In the section “AP-75 Barriers to Affordable Housing”, under “Actions it planned to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment” The Plan narrative describes the projects that received funding, the City’s requirement of reserve accounts, and system development charge waivers. 

Notably absent from this section is the fact that the Salem Housing Authority Board of Commissioners recently adopted the recommendation of the Salem Housing Advisory Committee’s recommendation 

That the City of Salem Housing Authority Board of Commissioners direct the Housing Administrator, in conjunction with the Executive Director, to address the growing deficit of affordable rental housing for low and moderate income Seniors, Disabled and Families by pursuing the development of mixed-income affordable housing on the North Campus of the State Hospital, and elsewhere within the City and the Housing Authority's area of operations. Further, to create an affordable housing committee that is responsible for developing affordable housing policies and strategies and reporting on progress on affordable housing development. 

Also absent is the fact that the City Council recently accepted the Housing Needs Analysis and directed staff to begin advancing the study's recommendations to address Salem's deficit of land for multifamily housing.[v]  Once again the point must be made: had The Plan truly been the product of collaboration, it would have included these details, and likely many others. 
             
Under “Discussion”, The Plan states
Below is a description of how the City intends to address the impediments listed in the Analysis of Impediments to Fair Housing for the City of Salem.  A full accounting of the impediments is also included in the attached hard copy of the Annual Action Plan.

First, The Plan is the Annual Action Plan, and it does not include a full accounting of the impediments to affordable housing, so the second sentence cannot be true.  

Second, under four categories of impediments, Fees and Charges, Limitations, Availability, and Other, The Plan describes (again) the projects that received funding.  However, without some explanation of each impediment, it is impossible to understand how they are addressed by the projects described.  This problem does not occur in the comparable section of the 2015-2019 Consolidated Plan (see page 179). 
 
In the section “AP-85 Other Actions”, under “Actions planned to address obstacles to meeting underserved needs”, The Plan states “Coordination between public and private housing and social services agencies is an extremely important activity”, which is true.  

Then it states, “The City participates in the CoC collaborative, which is comprised of various housing and social service agencies”, which is misleading, because, as discussed above, it gives the incorrect impression that the City is participating meaningfully in a functional group called the “CoC collaborative”, when neither is true.  As discussed above, the “CoC collaborative” consists of the current funding cycle’s “sub-grantees” who meet infrequently and have never managed to expand into an effective network.  The statement is, therefore, mostly false.

The same is true for the next sentence, “The collaboration of many local stakeholders provides better service to the underserved through many different projects and programs.”  It probably would, if it were occurring, but it isn’t.  At least not on the Marion County side.  Polk County is different, but not because of anything the City is doing.

Lastly, “Partnering with these institutions is vital to overcoming any gaps in institutional structure, and will continue in the next plan year.”  (Emphasis added.)  This statement is just false.  You cannot continue what you have not begun.  The City may claim as partners the participants in its grant application and administration process, but anything beyond that the City has yet to undertake.

The Plan then describes, again, the projects most recently funded.  The fact that the narrative in this section omits to mention any other agencies’ projects is a further indication that the City is not, in fact, collaborating with those agencies, and remains institutionally unaware of their activities. 

Under “Actions planned to reduce the number of poverty-level families” The Plan states, “Poverty reduction strategies in the City encompass a variety of processes that provide support to agencies assisting low and moderate-income households as they progress toward economic self-sufficiency.”  This statement is nonsense.  The City has no “poverty reduction strategies” apart from federal programs administration, and the 10-Year Plan, which it has never implemented or attempted to implement.  As noted previously, it was because the City had no “poverty reduction strategies” of its own that the MWHI Task Force came to be created in 2016.  

The Plan states “Section 3 guidelines are provided to every organization carrying out construction projects” without explaining what the Section 3 program is, or how providing Section 3 guidelines (presumably an administrative duty) is designed to reduce the number of poverty-level families.  Moreover, the inclusion of such bureaucratic minutiae into the narrative shows just how narrow a view the City takes of its role and responsibilities.  
 
Under “Actions planned to develop institutional structure”, and “Actions planned to enhance coordination between public and private housing and social service agencies”, The Plan narrative continues in this section in the same vein as described above, making false and misleading general statements designed to give the impression that the City is seriously engaged in developing institutional structure, planning, and enhancing coordination between housing and social service agencies, beyond what is needed to administer its federal programs.  That this is not the case is partly demonstrated by the fact that the only specific actions cited in this section are those of the most recently funded agencies.  The other housing and social service agencies apparently just do not exist, as far as the City is concerned, until they enter the sphere of federal programs.

If the City were seriously engaged in developing institutional structure, planning, and enhancing coordination between housing and social service agencies, beyond what is needed to administer its federal programs, this section would a) cite “other” actions (consistent with the title of the section), and b) show how those other actions develop institutional structure and enhance coordination.  The “monitor[ing]” activity of the City’s Urban Renewal Agency cited under “Discussion” in this section fails with regard to the latter, but, again, its inclusion illustrates rather well just how narrow a view the City takes of its role and responsibilities, not to mention its lack of vision in this area. 
  
Errata

Below are sections of the narrative that contain minor errors.  Followed by the section where the error occurs (e.g., AP-05).  (And in parentheses, if needed, an explanation.)

A more detailed account of the goals and the subset goals are identified in section SP-45.  AP-05. (That is a reference to the Consolidated Plan.  (The Plan does not contain a section SP-45.)  

[T]his Annual Action Plan is a collective effort of City of Salem Urban Development staff, Salem Urban Devleopment Community Services and Housing Commission (CSHC)… PR-05.

Activities to enhance coordination…are evident in the organizations listed in the Consultation section of this Consolidated Plan. AP-10.  (Should be “Annual Plan.”)

The City support’s the rehabilitation of existing homeless shelters and facilities… AP-10 

[EHN] was consulted…at the March 11, 2016 meeting.  AP 10. (Should be “March 10.”)

The development of the 2015-2019 Consolidated Plan and the Annual Action Plan is guided by the effort of the Community Services and Housing Commission (CSHC), and this draft will be made available to the public for review and comment beginning March 31, 2016.  AP-12.  (Should be “Salem Urban Development, Community Services and Housing Commission”.)

Presentation, review, and recommendation of the plan by CSHC. AP-12.  (Should be “Presentation of, review by, and approval of the plan…”)
…General Fund dollars for various social service programs and for the annual Homeless Connect.  AP-15. (Should be “Salem-Keizer Community Connect.”)
Expected Amount Available Reminder of ConPlan.  AP-15

The Continuum of Care (CoC) is a community based long-range plan… AP-15 (Should be “a community-based long range planning organization” to be consistent with The Plan’s statement in AP-10, Introduction.) 

SHA administers five homeless vouchers and three domestic violence vouchers… AP-15. (Effective February 2016, SHA administers 10 homeless vouchers and 5 domestic vouchers.)

The City's distribution of HOME and CDBG funds are based on the type of project… AP-35.

The City plans to dedicate $137,448 for CHDO set-aside projects… AP-35.  (Acronym only.)

Cooridated Access to Housing.  AP-38.

The punctuation was not corrected when the paragraph under section AP-65 Homeless… was converted to bullet points.  AP-65.

A colon is missing at the end of this and similar headings:  Describe the jurisdictions one-year goals and actions for reducing and ending homelessness including.  AP-65.  

A full accounting of the impediments is also included in the attached hard copy of the Annual Action Plan.  AP-75.   

Rena Peck, FP Manager
5/11/16 Update:  this response to the Comment appeared in the Council Additions and Deletions to the agenda.  At the hearing on 5/10, Federal Programs staff stated that the AAP would be amended in response to the comment.  As usual, the only public comment offered at the hearing was from representatives of programs awarded funds, including a member of the board of Shelley's House; Rick Gaupo of the Marion Polk Food Share; Adam Kohler, vice-chair of the Urban Development, Community Services and Housing Commission, which makes funding recommendations; T.J. Putman of Salem Interfaith Hospitality Network.  All expressed gratitude for funding expected or received, none made any attempt to address the substance of the Comment.


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