Just when Minnesota Housing's 2012 Affordable Housing Plan has been put to rest, the state housing agency joined by DEED and DHS brings us the Consolidated Plan for review and comment. But there isn't much time.
The Consolidated Plan is a federally mandated, five-year plan laying out priorities for spending federal block grant funds for housing and community development needs. Distribution of funding under CDBG, HOME, Emergency Solutions Grant, and Housing for Persons with AIDS (HOPWA) block grants all must conform to the Consolidated Plan, so it's an important document.
MHP hopes that the overview and analysis below will help enable readers to provide their own comments to the state on Minnesota's 2012-16 Con Plan draft before the January 1, 2012 deadline.
Note also that other block grant jurisdictions in Minnesota such as Bloomington, Dakota County, and Minneapolis must submit their own Con Plans: see the HUD website for a full list.
As you might guess, to provide a plan meeting all the federal requirements requires a lot of paper. You can examine the various documents comprising the 2012-16 plan draft, all 300+ pages, on a DEED webpage.
This draft plan (which is split between volume 1 and volume 2) provides a statement of needs and then identifies measurable objectives and a timeline for addressing housing and community development priorities. The plan is released with the Annual Action Plan identifying priorities for the coming year, in this case 2012. Finally, there is a related draft document called Analysis to Impediments to Fair Housing Choice, which is not officially part of the Con Plan, but is being released at the same time.
In addition to analysis of numerous demographic and housing trends for Minnesota, covering much of the same ground in the Affordable Housing Plan, the Consolidated Plan includes the results of community meetings and surveys the state undertook as part of the planning process.
The state received 550 responses to its survey on various housing and community development priorities. Here are some examples of the type of input the state received:
- For the statewide response, in selecting from 18 options for "high housing need", the top 5 all concerned housing for renters, with "rental assistance" and "rental housing for very low income households" tying for the top response.
- Another question asked about the top barriers to affordable housing. The top three responses among 17 options, in order, were "Not in my back yard mentality," then "cost of land or lot," and "cost of materials."
- When asked how the state should distribute resources, the responses were a near tie between housing (25%) and human services (24%), followed by economic development (21%) and infrastructure (18%), then public facilities (11%) and other (1%).
Priorities of the Strategic Plan
In the strategy section of the plan, the state identifies its top priorities for assisting renters, homeowners, and special needs populations.
- Receiving a "high" priority rating were renter households with incomes from 50% of median and below, and owner households at 51-80% of median income.
- Renter and owner households in other income categories received a "moderate" rating.
- Among the non-homeless population with special needs, "high" priority rates were given to people with severe mental illness, HIV/AIDS, and victims of domestic abuse.
The plan then provides separate goals under three categories: housing, non-housing community development, and homeless and special needs populations. The goals and related strategies are all pretty generic, allowing for a wide range of funding possibilities for the state agencies to pursue while still adhering to the strategic plan.
For instance, the goals for housing are: 1) financing new affordable housing opportunities (this is the homeownership goal), 2) mitigate foreclosures through prevention and remediation, 3) preserve exiting affordable housing stock, and 4) increase the availability of affordable rental housing.
The goals for homeless and special needs populations reflect the new federal structure for homeless funding, with a greater emphasis on prevention of homelessness.
Action Plan: Distribution of Federal Funds in 2012
The one-year action plan, a separate document to be submitted with the 2012-16 plan, provides specifics on distribution of federal funds in 2012.
Community Development Block Grant (CDBG)
DEED is responsible for distributing Minnesota's federal CDBG funds, which amount to about $16 million for 2012. This money goes for housing rehab, economic development, and public infrastructure. DEED must adhere not only to federal rules for CDBG program structure and formula, but also to state statute for this program.
Under the action plan, DEED may distribute $250,000 in microenterprise assistance. In 2011 DEED allocated this same amount, although only $227,000 was actually awarded by the state. Yet as of November 1, 2011, the plan notes, only $25,642 had actually been disbursed, with no jobs yet created. DEED will wait for further results on 2011 funds before committing any additional dollars.
Minnesota Housing will distribute $5.2 million in HOME program funds through three of its programs. The action plan notes that Congress recently reduced HOME funding by 38% from 2011, and that the draft Con Plan includes that same level of reduction for each type of HOME program from the amounts stated in the agency's 2012 Affordable Housing Plan (AHP). While an overall reduction of 38% is certain, Minnesota Housing's board will determine in January how to distribute this cut amongst the three HOME programs.
Assuming a proportionate cut from each of the HOME funded programs, funding would be split between Affordable Rental Housing Preservation ($4.3 million), HOME HELP (homebuyer assistance, $623,500), CHDO (nonprofit operating support, $290,000), with the remainder to be retained by Minnesota Housing for administration of HOME ($580,000). In addition, while no funds are allocated, Disaster Response and Tenant-Based Rental Assistance are identified in the plan as contingent activities eligible to receive HOME funds.
Housing Opportunities for Persons With AIDS (HOPWA)
Regarding $140,000 in HOPWA funds, also administered by Minnesota Housing, the plan states that since almost all persons with HIV/AIDS in Greater MN are already housed the funds will be used to help people stay in their homes.
Emergency Solutions Grant (ESG)
$1.2 million in ESG (homeless) funds administered by DHS will be distributed under the rules of the 2009-passed HEARTH act. This act caps the amount of ESG funds to 60% of the grant or the amount used for emergency shelter in 2010. Under the 2012 action plan, the state intends to allocate the maximum allowed to emergency shelters. Other amounts will go for homeless prevention and re-housing programs. The plan notes that the state will "use the flexibility of ESG funds to create the most appropriate balance of prevention, shelter, transitional housing and supportive service resources depending on what resources are available in the state as a whole."
As required by federal law, the fair housing portion of the Action Plan includes a certification that the state is affirmatively furthering fair housing. To be able to make this statement, by law, the state must complete a document called the Analysis to Impediments to Fair Housing Choice (AI), which has also just been released, take action to remedy any impediments, and keep records of the analysis and actions taken. In the 2012-16 Consolidated Plan, the state is putting forth the most significant rewrite of the fair housing analysis and action steps since 2003, says a DEED staffer. Changes were in part based upon a survey of housing and human rights groups to identify impediments to fair housing.
The plan identifies eight private sector impediments and four public sector impediments to fair housing. An example of a private sector impediment is a "discriminatory refusal to rent." A related remedial action step is to "periodically review occupancy of tax credit developments and evaluate whether households of color and disabled persons are under-represented and consult with owners." A public sector impediment is "zoning decisions that affect placement of multifamily housing," with the related action step being to "continue to encourage local communities to reevaluate decisions that may adversely affect housing place[ment]." Minnesota Housing staff expects that work on fair housing impediments will continue after the Consolidated Plan is adopted.
Comments are not being soliticed per se on the Analysis to Impediments to Fair Housing Choice, but comments on the fair housing portions of the Con Plan and Action Plan are welcome.