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2023-034 HUD CAPER 2021-22 Date: April 21,2023 Report No. 2023-034 INFORMAL STAFF REPORT TO MAYOR AND CITY COUNCIL SUBJECT: U.S. Department of Housing and Urban Development, Consolidated Annual Performance and Evaluation Report, 2021-22 Program Year DISCUSSION: The Consolidated Annual Performance and Evaluation Report(CAPER)is the year-end report that evaluates the progress made towards the activities identified in Denton's 2020-2023 Consolidated Plan for Housing and Community Development (Consolidated Plan) and the 2021-22 Program Year Annual Action Plan (AP). The CAPER is submitted annually to the U.S. Department of Housing and Urban Development (HUD). The City of Denton uses the CAPER to inform the public of how federal Community Development Block Grant (CDBG), HOME Investment Partnerships (HOME), and Community Development Block Grant(CDBG-CV)entitlement funds have been expended and to highlight successes in addressing the 3-year Consolidated Plan priorities and objectives. The 2021-22 CAPER reports on the second year of the Consolidated Plan. The CAPER provides data on housing units completed, the number and type of individuals assisted, dollars expended, sources of funds used, and other relevant performance data. 2021-22 CAPER REPORT The City of Denton 2021-22 program year for the federal grants runs from October 1, 2021, through September 30, 2022. While the CAPER focuses on federally funded activities, the City of Denton recognizes the importance of local funding in the provision of community development activities, especially in social services and homelessness. Accomplishments reported in the CAPER include resources leveraged, homeless and homeless prevention narratives, and a summary of households and/or persons assisted by both local and federal funds (Exhibit 1). HUD is required to conduct an annual review of grant recipient performance according to the provisions of the Housing and Community Development Act and the National Affordable Housing Act. The assessment includes performance data based on the federal funding sources related to Community Development—CDBG, HOME, and CDBG-CV(Exhibit 2). CITIZEN PARTICIPATION Citizens have a variety of ways to provide comments on all Community Development programs and projects throughout the year. To ensure citizen participation in the 2021-22 PY performance report process, the City followed its 2020-2023 Citizen Participation Plan. Citizen participation strategies deployed included: • Newspaper-A notice was placed in the Denton Record-Chronicle on December 10,2022, requesting public comments on the draft 2021-22 PY CAPER between December 12 through 26. The advertisement also included a link to the draft report online. • Online - The draft 2021-22 CAPER report was available on the City's website at www.cityofdenton.com/communitydevelopment beginning December 12. Date: April 21,2023 Report No. 2023-034 • Public Comment-Community Development accepted comments on the draft report from December 12 through 26 by phone at(940) 349-7726, at Community Development at 401 N. Elm St., Denton, TX 76201, by email at CommunityDevelopment@cityofdenton.com • Social media outreach - Staff coordinated with Public Affairs to post information on the City's social media channels including Facebook and Twitter. • Email - Staff sent out information through Constant Contact to interested citizens, previous clients, committee members, local churches, participating lenders and realtors, neighborhood associations, and social services agencies. Despite significant outreach utilizing the Citizen Participation Plan, no comments were received. SUMMARY OF EXPENDITURES IN 2021-22 PROGRAM YEAR: The CAPER outlines expenditures by funding source and the number of persons assisted by priority and activity. A total of$5,354,188 in federal, state, local funds were expended to meet the following priorities within Denton's 2020-2023 Consolidated Plan: • Affordable Housing • Making Homelessness Rare, Brief, and Non-Recurring • Public Services • Public Facilities, Improvements, and Infrastructure The chart below provides a breakdown of the total expenditures of$5,354,188 by funding source and total percentage. CDBG, HOME, and CDBG-CV federal expenditures totaled $1,302,878 (24%), $865,581 (16%), and $620,041 (12%), respectively. General Funds expenditures totaled $2,565,688 (48%). Total Expenditures General Fund(Local) CDBG-CV(Federal) HOME(Federal) CDBG(Federal) 0% 10% 20% 30% 40% 50% 60% The chart below provides a breakdown of expenditures by priority category. Affordable Housing expenditures totaled $1,185,190 (22%); Making Homelessness Rare, Brief, and Non-Recurring expenditures totaled $1,138,485 (21%); Public Services expenditures totaled $645,408 (12%), Public Facilities and Improvements, and Infrastructure and Administration expenditures totaled $689,452 (13%) and$1,695,652 (32%), respectively. Date: April 21,2023 Report No. 2023-034 $1,400,000 $1,200,000 $1,000,000 $800,000 $600,000 $400,000 $200,000 $0 — Affordable Housing Making Homelessness Public Services Public Facilities, Rare,Brief,and Non- Improvements,and Recurring Infrastructure SUMMARY OF PERSONS ASSISTED IN 2021-22 PROGRAM YEAR A total of 36,034 persons were beneficiaries of programs or services: • Affordable Housing: A total of 103 persons were assisted through the Affordable Development Fee Grant Program, Minor Repair Program, Home Improvement Program, and Homebuyer Assistance Program. • Making Homelessness Rare, Brief, and Non-Recurring: A total of 4,788 persons were assisted by funding provided to local non-profits such as Denton County Friends of the Family, Giving HOPE, Inc., Grace Like Rain, Hotel Voucher Program, Our Daily Bread, The Salvation Army, and United Way of Denton County. • Public Services: A total of 4,788 persons were assisted by funding provided to local non- profits for an array of services including daycare, health care, mental health, senior services, and afterschool care. • Public Facilities,Improvements,and Infrastructure: A total of 8,123 people benefited from the completion of the Carl Young Park, Fred Moore Park, Quakertown Park, and Sequoia Park Projects. Persons Assisted Affordable Housing 103 Public Facilities,Improvements,and Infrastructure 8,123 Public Service 4 4,78 aking Homelessness Rare,Brief,and Non-Recurring 23,020 Date: April 21,2023 Report No. 2023-034 A One-Page Summary of the CAPER and HUD's Annual Community Assessment for the 2021- 22 Program Year is attached(Exhibit 3). ATTACHMENTS: 1. 2021-22 CAPER HUD Approved 2. 2021-22 HUD Assessment Letter 3. 2021-22 CAPER One-Page Summary STAFF CONTACT: Luisa Garcia, Community Development Manager (940) 349-7238 Luisa.Garciag cityofdenton.com REQUESTOR: Staff Initiated STAFF TIME TO COMPLETE REPORT: 4 hours 2021/22 PY CONSOLIDATED ANNUAL PERFORMANCE AND EVALUATION REPORT (CAPER) 2nd year of the 2020-23 CONSOLIDATED PLAN ...for housing and community development _ 1 f 7 i i i i OI DENTON A REPORT FOR THE U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Community Development Block Grant (CDBG) HOME Investment Partnership Grant (HOME) Community Development Block Grant—CARES Act (CDBG-CV) CAPER 1 OMB Control No:2506-0117(exp.06/30/2018) CAPER REPORT PREPARED BY: City of Denton Community Services 401 N. Elm Street Denton, Texas 76201 Primary Phone Number: (940) 349-7726 Email: CommunityDevelopment@cityofdenton.com Website: www.cityofdenton.com CAPER 2 OMB Control No:2506-0117(exp.06/30/2018) CR-05 - Goals and Outcomes Progress the jurisdiction has made in carrying out its strategic plan and its action plan. 91.520(a) This document serves as the City of Denton's 2021/22 PY Consolidated Annual Performance and Evaluation Report (CAPER) for the Community Development Block Grant, HOME Investment Partnership Grant, and the Community Development Block Grant — CARES funding programs. This report meets the performance requirements described in the Consolidated Plan (ConPlan) regulations at 24 CFR 91.520. The performance report meets the following three purposes: 1) it provides HUD with the necessary information for the Department to meet its regulatory requirement to assess Denton's ability to carry out the CDBG and HOME grants in compliance with all applicable rules and regulations; 2) it provides information necessary for HUD's Annual Report to Congress; and 3) it provides Denton an opportunity to describe to its citizens the successes in meeting the strategies stated in the three-year Consolidated Plan. The City of Denton is currently an entitlement city for the Community Development Block Grant and a participating jurisdiction under the HOME Investment Partnership Program. During the 2021/22 PY, the funding detailed in Table 1 was available to the City of Denton to further the objectives of the Consolidated Plan. These amounts include unexpended funds from the previous PY. HUD Funding Funding • Community Development Block Grant Funds $2,227,259.25 HOME Investment Partnership Grant Funds $1,430,904.92 Community Development Block Grant Funds—CARES Act* $956,080.68 Total funds available for PY ,- I Table 1 Total HUD funds Available for 2021/22 PY During the 2021/22 PY, the City of Denton expended a total of $5,208,404 in CDBG, HOME, CDBG-CV, and General Funds to support the 2020-23 Consolidated Plan priorities and to assist a total of 56,379 persons. Below is a breakdown of funds expended by priority areas outlined in the City's ConPlan (Table 2). *CARES Act provide CDBG funding for one-time projects. CAPER 3 OMB Control No:2506-0117(exp.06/30/2018) EXPENDITURES 2020-23 CONPLAN PERSON PRIORITYD: • CDBG-CV Funds Total % Affordable Housing 103 $357,790 $803,334 $24,066 $1,118,190 23% Making Homelessness Rare, Brief, and Nonrecurring 4788 $62,856 $0 $331,098 $743,531 $827,733 22% Public Services 8,123 $88,999 $0 $185,500 $370,909 $503,458 10% Public Facilities, Improvements, and Infrastructure 23,020 $586,009 $0 $103,443 $0 $689,452 13% Planning and Administration 0 $2071223 $62,247 $0 $1,426,182 $1,695,652 33% Table 2 Annual Performance—2020-23 ConPlan Priorities CAPER 4 OMB Control No:2506-0117(exp.06/30/2018) Assess how the jurisdiction's use of funds, particularly CDBG, addresses the priorities and specific objectives identified in the plan, giving special attention to the highest priority activities identified. The 2021/22 PY is the second year of Denton's 2020-23 Consolidated Plan. Staff focused on housing and public services with an emphasis on homeless assistance and public facility improvements. Below is a summary of accomplishments and goals. Affordable Housing: The City has a completion rate of 97.6% at the end of Year 2 and aims to meet the 3-year goal of 123 units in affordable housing. One (1) households received down payment and closing costs assistance through the Homebuyer Assistance Program. The City assisted 46 homeowners with minor, substantial rehabilitation or reconstruction to their homes for a total of 47 housing units. Homeless Assistance and Prevention: The City has a completion rate of 79.8% at the end of Year 2 and is on target to meet the 3-year goals of assisting 7,560 people. Denton County Friends of the Family, the Temporary Shelter Hotel Voucher Program, and The Salvation Army of North Texas helped a total of 2,977 people during the 2021/22 PY with homeless assistance and prevention activities. Public Services: The City has a completion rate of 43.1% at the end of Year 2. The City is behind meeting the 3-year goal of assisting 4,500 people. Funding was available to Denton City County Day School, SPAN, Inc., and City's Summer Kids Camp to assist 1422 people during the 2021/22 PY. The pandemic affected the number of people assisted during the program year, as in- person services remained limited during this program year. It is expected that the City will meet the Public Services goals by the next program year due to the additional persons that will be assisted with CDBG-CV funds. Public Facilities and Infrastructure Improvements: The City has a completion rate of 136.4% at the end of Year 2. The City is ahead of schedule on its 3-year goal of assisting 24,000 people. During the 2021/22 PY, the following projects were completed: Quakertown Restroom/Playground/Trail Lighting Projects, Carl Young Park Lighting Project, Sequoia Park Playground Phase 1, and Fred Moore Park Improvements for a total of 23,020 people. CAPER 5 OMB Control No:2506-0117(exp.06/30/2018) CR-10 - Racial and Ethnic composition of families assisted Describe the families assisted (including the racial and ethnic status of families assisted). 91.520(a) CDBG White 2795 15 Black or African American 1414 2 Asian 34 0 American Indian or American Native 23 0 Native Hawaiian or Other Pacific Islander 35 0 Hispanic 380 3 Non-Hispanic 4109 14 Table 3—Table of assistance . racial and ethnic populations by sourceof funds Narrative The data shown in the table show that city programs and activities assisted minority populations. However, the chart does not provide information on multi-racial families assisted. CDBG assisted an additional 188 persons for a total of 4489 people. In the CDBG program, 31 percent were African American, and 8 percent were Hispanics. In the HOME program, 12% were African American, and 18 percent were Hispanics. The above table does not include all persons or households assisted during the 2021/22 PY, especially with CDBG funds. Attachment 1 — Summary of Households/Persons Assisted provides a comprehensive summary of all persons assisted by funding type and race and ethnic categories. CAPER 6 OMB Control No:2506-0117(exp.06/30/2018) CR-15 - Resources and Investments 91.52O(a) Identify the resources made available Source of Funds Source Resources Made Available Amount Expended During Program Year CDBG Public - Federal $2,227,259.25 $1,302,877.50 HOME Public - Federal $1,430,904.92 $865,580.94 CDBG-CV Public - Federal $956,080.68 $620,041.00 Table 4- Resources Made Available Narrative The above resources and expenditures include funds from prior years and program income received during the year. Projects such as public facilities or affordable housing development, can take more than one year to complete. Identify the geographic distribution and location of investments Target Area Planned Percentage Actual Percentage of Narrative Description of Allocation Allocation N/A Table 5— Identify the geographic distribution and location of investments Narrative The City of Denton provides the majority of its HUD-funded community development programs city-wide to ensure access by all citizens at low- and moderate-income levels. At 80% of Area Median Income, Household income is considered low- and moderate-income. Geographic distribution of some capital improvement projects is based on citizen comments and City staff input regarding significant needs in the low-income community, specifically public facility improvements. Below is an overview of the programs provided city-wide. The Minor Repair Program (MRP) assists with minor repairs of up to $10,000 on single-family homes and mobile homes. Households at or below 80% of the area median income within Denton's city limits are eligible for the minor repair program. While eligible households may live anywhere in the city, most homes completed during the 2021/22 PY were in Southeast and Northeast Denton, as shown on the map in Attachment 2. These areas have higher concentrations of older housing stock in need of rehabilitation and eligible low- and moderate- income homeowners. CAPER 7 OMB Control No:2506-0117(exp.06/30/2018) The Homebuyer Assistance Program (HAP) provides down payment and closing cost assistance to eligible low- and moderate-income homebuyers city-wide. The map in Attachment 2 shows the geographic distribution of the HAP-assisted home purchased during the 2021/22 PY. Public Service activities provide services to eligible low- and moderate-income households throughout the Denton community through local nonprofits in the form of a grant. The Home Improvement Program (HIP) assists with substantial rehabilitation or reconstruction of single-family homes. Assistance is provided to households at or below 80% of the area median income within the city limits of Denton. While eligible households may live anywhere in the city, the homes completed during the 2021/22 PY were in Southeast Denton, as shown on the map in Attachment 2. This area has higher concentrations of older housing stock in need of rehabilitation and eligible low- and moderate-income homeowners. CAPER 8 OMB Control No:2506-0117(exp.06/30/2018) Leveraging Explain how federal funds leveraged additional resources (private, state and local funds), including a description of how matching requirements were satisfied, as well as how any publicly owned land or property located within the jurisdiction that were used to address the needs identified in the plan. The Community Development Division works with other City departments and nonprofit agencies to leverage resources for projects and activities such as capital improvement, housing, social services, and other projects to help low-income neighborhoods and citizens. Attachment 3 includes a table of additional federal, state or local resources available during the program year to the City of Denton and local agencies to meet community development priorities. The City of Denton leveraged for match a total of $85,236,828 during the 2021/22 PY funds, as outlined below in Table 6. The table below provides an overview of the HOME match requirement. All HOME expenditures except for administration require a 25% match from a variety of eligible sources. During the 2021/22 program year. Fiscal Year Summary— HOME Match 1. Excess match from prior Federal fiscal year—Adjusted from the 2020 Balance $66,900.00 2. Match contributed during current Federal fiscal year $24,106.92 3. Total match available for current Federal fiscal year (Line 1 plus Line 2) $91,006.92 4. Match liability for current Federal fiscal year $78,782.36 5. Excess match carried over to next Federal fiscal year (Line 3 minus Line 4) $12,224.56 Table 6— Fiscal Year Summary- HOME Match Report CAPER 9 OMB Control No:2506-0117(exp.06/30/2018) Match Contribution for the Federal Fiscal Year Project No. or Date of Cash Foregone Appraised Required Site Bond Total Match Other ID Contributi Taxes, Land/Real Infrastructure Preparation, Financing on (non- Fees, Property Construction Federal Charges Materials, sources) Donated labor DFG — HOME HIP projects 9/30/2022 $7,379.42 0 0 0 0 0 $7,379.42 DFG — HOME HAP projects 9/30/2022 $4,727.50 0 0 0 0 0 $4,727.50 DFG — HOME Habitat Projects 9/30/2022 $12,000 0 0 0 0 0 $12,000 Table 7— Match Contribution for the Federal Fiscal Year HOME MBE/WBE report Program Income— Enter the program amounts for the reporting period Balance on hand at Amount received Total amount expended Amount expended for Balance on hand at end begin-ning of reporting during reporting period during reporting period TBRA of reporting period period $196,640 $68,355.93 $196,640 $0.00 $68,355.93 Table 8—Program Income CAPER 10 OMB Control No:2506-0117(exp.06/30/2018) Minority Business Enterprises and Women Business Enterprises — Indicate the number and dollar value of contracts for HOME projects completed during the reporting period Total Minority Business Enterprises White Alaskan Asian or Black Non- Hispanic Non- Native or Pacific Hispanic Hispanic American Islander Indian Contracts Dollar Amount $1,067,425.06 $320,556.26 $174,997.00 $570,649.00 Number 7 2 1 4 Sub-Contracts Number 15 15 Dollar Amount $152,470.00 $152,470.00 Total Women Male Business Enterprises Contracts Dollar Amount 7 2 5 Number $1,066,202.26 $320,556.26 $745,646.00 Sub-Contracts Number 15 0 7 Dollar Amount $152,470.00 $0.00 $152,470.00 Table 9 - Minority Business and Women Business Enterprises CAPER 11 OMB Control No:2506-0117(exp.06/30/2018) Minority Owners of Rental Property — Indicate the number of HOME assisted rental property owners and the total amount of HOME funds in these rental properties assisted Total Minority Property Owners White Non- Alaskan Asian or Black Non- Hispanic Hispanic Native or Pacific Hispanic American Islander Indian Number 0 0 0 0 0 0 Dollar Amount 0 0 0 0 0 0 Table 10— Minority Owners of Rental Property Relocation and Real Property Acquisition — Indicate the number of persons displaced, the cost of relocation payments, the number of parcels acquired, and the cost of acquisition Parcels Acquired 0 0 Businesses Displaced 0 0 Nonprofit Organizations Displaced 0 0 Households Temporarily Relocated, not Displaced 0 0 Households Total Minority Property Enterprises White Non- Displaced Alaskan Asian or Black Non- Hispanic Hispanic Native or Pacific Hispanic American Islander Indian Number 0 0 0 0 0 0 Cost 0 0 0 0 0 0 Table 11— Relocation and Real Property Acquisition CAPER 12 OMB Control No:2506-0117(exp.06/30/2018) CR-20 - Affordable Housing 91.520(b) Evaluation of the jurisdiction's progress in providing affordable housing, including the number and types of families served, the number of extremely low-income, low-income, moderate-income, and middle-income persons served. One-Year Goal Actual Number of Homeless households to be provided affordable housing units 0 0 Number of Non-Homeless households to be provided affordable housing units 41 47 Number of Special-Needs households to be provided affordable housing units 0 0 Total 41 47 Table 12— Number of Households One-Year Goal Actual Number of households supported through Rental Assistance 4 0 Number of households supported through The Production of New Units 0 0 Number of households supported through Rehab of Existing Units 34 46 Number of households supported through Acquisition of Existing Units 3 1 Total 41 47 Table 13— Number of Households Supported CAPER 13 OMB Control No:2506-0117(exp.06/30/2018) Discuss the difference between goals and outcomes and problems encountered in meeting these goals. The 2021/22 PY is the second year of Denton's 2020-23 Consolidated Plan. Staff focused on housing and public services with an emphasis on homeless assistance and public facility improvements. Below is a summary of accomplishments and goals. Affordable Housing: The City has a completion rate of 97.6% at the end of Year 2 and aims to meet the 3-year goal of 123 units in affordable housing. One (1) households received down payment and closing costs assistance through the Homebuyer Assistance Program. The City assisted 46 homeowners with minor, substantial rehabilitation or reconstruction to their homes for a total of 47 housing units. Homeless Assistance and Prevention: The City has a completion rate of 79.8% at the end of Year 2 and is on target to meet the 3-year goals of assisting 7,560 people. Denton County Friends of the Family, the Temporary Shelter Hotel Voucher Program, and The Salvation Army of North Texas helped a total of 2,977 people during the 2021/22 PY with homeless assistance and prevention activities. Discuss how these outcomes will impact future annual action plans. Public Services: The City has a completion rate of 43.1% at the end of Year 2. The City is behind meeting the 3-year goal of assisting 4,500 people. Funding was available to Denton City County Day School, SPAN, Inc., and City's Summer Kids Camp to assist 1422 people during the 2021/22 PY. The pandemic affected the number of people assisted during the program year, as in- person services remained limited during this program year. It is expected that the City will meet the Public Services goals by the next program year due to the additional persons that will be assisted with CDBG-CV funds. Public Facilities and Infrastructure Improvements: The City has a completion rate of 136.4% at the end of Year 2. The City is ahead of schedule on its 3-year goal of assisting 24,000 people. During the 2021/22 PY, the following projects were completed: Quakertown Restroom/Playground/Trail Lighting Projects, Carl Young Park Lighting Project, Sequoia Park Playground Phase 1, and Fred Moore Park Improvements for a total of 23,020 people. CAPER 14 OMB Control No:2506-0117(exp.06/30/2018) Include the number of extremely low-income, low-income, and moderate-income persons served by each activity where information on income by family size is required to determine the eligibility of the activity. Number of Households Served CDBG Actual HOME Actual Extremely Low-income 11 1 Low-income 16 6 Moderate-income 20 1 Total 47 8 Table 14— Number of Households Served Narrative Information This table reflects the breakdown of the number of households by income served in programs funded with HOME and CDBG and CDBG-CV funds. The City of Denton assisted a total of 55 households through the Hotel Voucher Program (CDBG-CV) Minor Repair (CDBG), Home Improvement (CDBG/HOME), and Homebuyer Assistance programs (CDBG/HOME). The table below provides a breakdown of income based on funding sources. Please note that the Home Improvement Program and the Homebuyer Asisstance Programs are funded with both CDBG and HOME funds and the accomplishements are reported in both funding sources as required by HUD. House Funding hold Moderate Very Low Ext. Low HOME Home Improvement Program CDBG/HOME 7 5 1 1 Homebuyer Assistance Program CDBG/HOME 1 1 HOME TOTAL 8 6 1 1 CDBG Minor Repair Program CDBG 39 14 15 10 Home Improvement Program CDBG/HOME 7 5 1 1 Homebuyer Assistance Program CDBG/HOME 1 1 CDBG TOTAL 47 20 16 11 TOTALS TOTAL HOUSEHOLDS 55 26 17 12 CAPER 15 OMB Control No:2506-0117(exp.06/30/2018) CR-25 - Homeless and Other Special Needs 91.220(d, e); 91.320(d, e); 91.520(c) Evaluate the jurisdiction's progress in meeting its specific objectives for reducing and ending homelessness through: Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs Through collaborative efforts, our Housing Crisis Response System plan includes goals for reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs through the following collaborative efforts. Annually, the City participates in the Point-In-Time (PIT) Count with the collaborative partner (and Balance of State CoC lead agency), the Texas Homeless Network, reaching out to assess the needs of persons experiencing homelessness. City staff supported efforts to produce and distribute a report, including PIT Count results and data collected in real-time year-round throughout the City, including the City website and community presentations. The report was presented at multiple community-wide meetings and for the community at large. Data from the 2022 PIT Count indicated 395 households were experiencing sheltered and unsheltered homelessness in Denton County. This is an increase from 2020 PIT count results of 191 and can be attributed to additional funding for emergency shelter hotel stays due to COVID 19. PIT Count data for 2021 was not compared due to the data only including sheltered households because of COVID 19 concerns. In 2022, the City supported a Street Outreach (SO) program and a Rapid Rehousing (RRH) programs. City general fund dollars were provided for staffing to reach out to sheltered and unsheltered people experiencing homelessness, document and prioritize them for housing through Coordinated Entry, and offer them permanent housing opportunities. Coordinated Entry affords us the key data for individual housing needs for local housing programs providers to receive referrals, reach out, and pull people off the Housing Priority List (HPL) as housing units and funding for housing assistance is available The City deploys a collaborative approach to homeless street outreach including law enforcement and nonprofit partners. The Denton Police Department's Homeless Outreach Team (HOT) employs two full-time officers who engage with people living unsheltered. In 2022, HOT partnered with Giving Grace, a local nonprofit, to connect people living unsheltered to housing, mental health, substance use treatment and other resources. HOT responds to community requests and proactively connects with people living unsheltered to address any health and safety concerns and help people move from homeless to housed. Denton continues to implement Coordinated Entry (CE), a uniform process designed to identify quickly, assess, refer and connect people in crisis to housing assistance and services. Households that complete the CE assessment process are then included in the Housing Priority CAPER 16 OMB Control No:2506-0117(exp.06/30/2018) List (HPL) and referred to the most appropriate housing solution. Households are pulled off the HPL in order of priority status as housing assistance becomes available. Rapid Re-Housing (RRH) is a permanent housing solution that provides short to medium term rental assistance. RRH provides housing relocation and stabilization services to help an individual or family experiencing homelessness move as quickly as possible into permanent housing and supports them with wrap-around services to gain stability in that housing. Rapid Re-Housing (RRH) provides a permanent housing opportunity for those on the Housing Priority List (HPL) to be referred. The City awarded $100,000 of general funding to Our Daily Bread, a local nonprofit, to provide Rapid Re-Housing assistance to sheltered and unsheltered persons in need of housing. Rapid Re-Housing assists with application fees, security deposits, and rental assistance. During the 2021/22 PY, the City awarded $18,850 of general funding to the United Way of Denton County to provide HMIS licenses to community partners for data collection, data quality, data analysis, and data reporting for our Coordinated Entry (CE) system; $64,600 to Giving Grace for dedicated Street Outreach; and $80,000 to the United Way of Denton County for coordination of the Homelessness Leadership Team and its workgroups that support the Housing Crisis Response System. Addressing the emergency shelter and transitional housing needs of homeless persons In Denton, through collaborative efforts, our Housing Crisis Response System plan includes goals for addressing the emergency shelter and transitional housing needs of homeless persons through the following collaborative efforts. Diversion and Prevention are the most cost effective of all solutions. Diversion and prevention are critical components of our Housing Crisis Response System by reducing the number of people who become homeless. Homeless prevention helps households stay in their current housing situation. Diversion prevents homelessness for people seeking shelter by helping them identify immediate alternate housing arrangements and, when necessary, connecting them with services. Emergency shelter and temporary housing assist people experiencing a housing crisis or fleeing an unsafe situation to quickly find a safe place to stay. Emergency and temporary housing are a part of a continuum of services that aligns with the larger goals of moving people from homelessness to housing. The City of Denton addressed the emergency shelter (ES) and transitional housing (TH) needs of persons experiencing homelessness through supporting HMIS data systems and providing funding for programs. Specifically, $90,000 in general funds were allocated for ES to Our Daily Bread (ODB). along with $40,000 in CDBG funds to Denton County Friends of the Family (DCFOF) and $35,000 in CDBG for the Salvation Army (TSA) in the amount of$35,000. CAPER 17 OMB Control No:2506-0117(exp.06/30/2018) Four-hundred thousand ($400,000) was allocated to Our Daily Bread (ODB) for emergency shelter to continue increased accessibility 7-nights a week and implement an Enhanced Shelter program with a housing focus and supported case management. In March 2020, Denton City Council approved CARES funding to temporarily house individuals and families experiencing homelessness in local hotels to implement COVID-19 safety protocol. This transition was deemed necessary by staff to prevent potential breakouts and allow individuals and families experiencing homelessness to have a safe place to sleep in non- congregate settings. Collaboration with local organizations has allowed for meals and supplies to be readily available to people staying in the hotels and reduced the need for people staying in shelters to venture into large group settings. Additionally, the hotel setting has allowed people experiencing homelessness who test positive for the virus to safely quarantine until they are without symptoms and no longer considered contagious. Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: likely to become homeless after being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); and, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs Diversion and Prevention are critical, cost-effective components for reducing the number of people who become homeless in our Housing Crisis Response System. Homeless prevention helps households stay in their current housing situation. Diversion prevents homelessness for people seeking shelter by helping them identify immediate alternate housing arrangements and, when necessary, connecting them with services. Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again Better data in HMIS and better processes through Coordinated Entry (CE) continue to improve the overall housing crisis response system. In 2021/22 PY, the City continued to support the housing needs of homeless persons by providing $18,850 to fund licenses for the Homeless Management Information System (HMIS) and $80,000 to the United Way of Denton County (UWDC) to support the ongoing implementation and improvement of CE. UWDC coordinates the housing crisis response system, CE, data collection, data quality, and data reporting locally. There are twelve (12) agencies now reporting critical system performance data. This reporting provides vital data for the community to complete a comprehensive analysis of the homeless system to identify needs, gaps in housing and to use the data to inform housing, programming and funding decisions. CAPER 18 OMB Control No:2506-0117(exp.06/30/2018) As part of the development of the City's CE process, partner agencies under the support of UWDC meet every week in case conferencing to manage the Housing Priority List (HPL). The meetings typically review the general list of individuals on the HPL, and one week a month focus on veterans. Those ranked as the most vulnerable are prioritized for HUD-funded permanent supportive housing programs and other housing assistance services. Investment in CE has reduced the time that it takes to identify housing needs and refer to the most appropriate housing option. While we still have a long way to go because of the availability of housing units, we are seeing shorter wait times for housing for first-time homeless. Other programs described in previous sections also shorten the length of time individuals and families experience homelessness. Street Outreach (SO) connects the unsheltered to City- funded emergency shelters, Denton County Friends of the Family (DCFOF), Our Daily Bread (ODB), and The Salvation Army, Denton (TSA). Outreach directly connects to emergency shelter and CE and the HPL services result in referral to housing assistance programs like Rapid Rehousing (RRH); Permanent Supportive Housing (PSH) funded through the CoC grant; and referrals to the Denton Housing Authority for Housing Choice Vouchers. CAPER 19 OMB Control No:2506-0117(exp.06/30/2018) CR-30 - Public Housing 91.220(h); 91.320(j) Actions taken to address the needs of public housing The City of Denton has no public housing units. However, City staff will continue to work with the Denton Housing Authority to promote City programs for those currently receiving Housing Choice Vouchers. Actions taken to encourage public housing residents to become more involved in management and participate in homeownership The City of Denton has no public housing units. However, City staff will continue to work with the Denton Housing Authority to promote the City's Homebuyer Assistance Program that provides down payment and closing costs assistance. Actions taken to provide assistance to troubled PHAs The City of Denton has no public housing units. CAPER 20 OMB Control No:2506-0117(exp.06/30/2018) CR-35 - Other Actions 91.220(j)-(k); 91.320(i)-(j) Actions taken 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. 91.220 (j); 91.320 (i) The City's Affordable Housing Needs & Market Value Analysis identified various housing development and preservation tools that can support Denton's unique housing needs. Collaborative, cross-sector strategies are vital. Public sector incentives and investments must balance the value of neighborhood characteristics with the cost of land acquisition and development to meet production volume goals while still facilitating economic mobility. To an extent, policies can address impediments such as the availability of affordable units in a range of sizes and source-of-income discrimination. Action taken in 2021/22 PY that served to reduce barriers to affordable housing through public policy and programs supported by public policy: CDBG/HOME • Increased housing choice by increasing down payment assistance from $15,000 to $50,000 in the Homebuyer Assistance Program to bring down the overall home cost and make it affordable to lower AMI households. One (1) Households were assisted. • Continued high-performing housing programs designed to ensure that affordable, accessible housing is created and preserved in Denton. The majority of homes completed during the 2021/22 PY were in Southeast and Northeast Denton, as shown on the map in Attachment 2. These areas have higher concentrations of older housing stock in need of rehabilitation and eligible low- and moderate-income homeowners. To leverage other federal resources: • The City provides a Housing Tax Credit Policy and Application supporting of the development and preservation of affordable rental housing for low-income households. Developers request Housing Tax Credits (HTC) through the Texas Department of Housing and Community Affairs. The City provided seven (7) Resolution of Support for a developer's 9% HTC Application and Resolutions of No Objection for six (6) 4% HTC applications. The City also leverages human resources and policy-driven grant programs an outlined below. • The City preserved affordable housing units throughout Denton through the Development Fee Grant Program, waiving development fees for projects that provide affordable housing or community services. Projects supported by this grant in PY 21/22 CAPER 21 OMB Control No:2506-0117(exp.06/30/2018) include one (1) nonprofit developer and four (4) homeowner in the City's Home Improvement Program. • The City completed the City's Affordable Housing assessment, and the City is utilizing the assessment in Phase Two to enhance Denton's zoning and development codes, prioritize investment, and incentive strategies to increase the supply of affordable housing, especially in high opportunity areas. • The City participated in four (4) quarterly round table meetings with (DCTA) to improve access to transit resources (bus stops, route locations, and schedules, and covered bus stops to provide shelter in inclement weather). • The City collaborated with Denton Housing Authority, Balance of State CoC, Denton County Friends of the Family, Denton Affordable Housing Corporation and the Denton County Homeless Coalition on determining the priorities for the HOME-ARP Allocation Plan. Actions taken to address obstacles to meeting underserved needs. 91.220(k); 91.320(j) The City of Denton has several tools to identify obstacles to meeting underserved needs. To understand gaps and barriers in Denton, the City analyzes Community Needs Assessments from community partners such as the Denton County Health Department, Texas Health Presbyterian, and the United Way of Denton County. Guided by the Citizen Participation Plan, City staff also review activities with the public. The City utilizes real-time data on community needs to inform underserved needs through the following activities: • Holding public meetings; • Utilizing public comment periods; • Gathering community surveys accessible online for citizens and nonprofit agencies; • Participating actively in coalitions and committees; • Maintaining ongoing consultation with various city departments; and • Consulting with housing providers, including nonprofits and the Denton Housing Authority. In addition, the City analyzes homeless data collected during the annual PIT Count and ongoing HMIS data to understand obstacles to meeting underserved needs. While demand far exceeds available resources, existing resources support actions to address obstacles to meeting underserved needs. CAPER 22 OMB Control No:2506-0117(exp.06/30/2018) Highlights of resulting actions in 2021/22 PY include: CDBG/HOME $50,000 in CDBG funds was awarded to Denton County Friends of the Family Emergency Shelter to increase the number of short-term supportive and long-term permanent affordable housing units. In effort to leverage other federal resources in meeting underserved needs for specialized housing for those in need of Permanent Supportive Housing (PSH), the City collaborates with TX Balance of State Continuum of Care Programs, including providing Certificates of Consistency for funded PSH programs at Giving Hope, Inc., and Denton County MHMR. The City also leverages human resources and grant programs. • The City provided $362,250 in General Funds supporting the Human Services Grant Program. • Through the Development Fee Grant Program, the City provides $75,000 in grant funds to cover the cost of development fees for the renovation, reconstruction, and creation of affordable housing units and $150,000 for nonprofit facility development/improvements. • Staff support annual Point in Time Count • The City continued to strengthen the Housing Crisis Response System and various homeless and at-risk initiatives by providing $703,100 of funding along with other funding for staff(described below) o Backbone support of the Denton County Homelessness Leadership Team (DCHLT) Collective Impact Project. o Increase Street Outreach efforts to connect with people experiencing homelessness living unsheltered. Increase the number of short-term supportive and long-term permanent affordable housing units for both individuals and families with children. o Increase funding for Rapid Re-Housing for families and individuals, including housing location and stabilization resources. o Making the transition to permanent housing and independent living. o Increase funding for Diversion (rapid resolution for diverting people from homelessness quickly). o Shortening the length of time that individuals and families experience homelessness. o Facilitating Access. • The City worked with community partners to secure other funding sources. CAPER 23 OMB Control No:2506-0117(exp.06/30/2018) Actions taken to reduce lead-based paint hazards. 91.220(k); 91.320(j) In the 2021/22 PY, Denton Affordable Housing Corporation did not undertake any rehabilitations of any pre-1978 units in 2021/22. Re-inspections for virtually all DAHC units were performed including pre-1978 units. All pre-1978 units passed a Visual Assessment for deteriorated paint. Homebuyers Assistance Program: One (1) HAP was completed in 2021/22 and it was constructed in 1986. Minor Repair Program: In 2021/22 the project limit was raised to $10,000, potentially bringing some pre-1978 MRPs into the Identify and Control Lead Hazards range. Delivery of both HUD/EPA lead-based paint pamphlets was continued to all potential Minor Repair clients. In one (1) pre-1978 house an area of greater than two (2) interior square feet had to be disturbed in a project of under $5,000, and Clearance was achieved. The remainders were either post- 1978 or no painted surface greater than de minimis had to be disturbed. Home Improvement Program: Seven (7) HIP projects were completed and all exceeded $25,000 in Federal assistance. Three (3) were Reconstructions in which the existing pre-1978 structures were demolished. Of the four (4) Rehabilitations one was post-1978. The remaining three (3) were inspected and/or Lead Risk Assessments were completed. One (1) testing found no lead-based paint, and in the other two (2) Abatement was carried out and Clearance achieved. Actions taken to reduce the number of poverty-level families. 91.220(k); 91.320(j) The City of Denton utilizes Community Development Block Grant (CDBG), HOME, and General Revenue Funds awarded to local nonprofit agencies to reduce the number of poverty-level families. Community Development also administers the grant programs awarded through other City departments, including the Police Department's Fair Share Fund and the Denton Municipal Electric P-L-U-S One Utility Assistance Program. These programs further the amount of funding in the community in support of resident needs. This year, Community Development managed multiple funding sources for Housing Stability; Food Security; Health & Well-Being, Making Homelessness Rare, Brief, and Nonrecurring; Early Childhood Education; and Economic Security projects. During 2021/22 PY, the City actions were: • Affordable housing assistance programs: o Allocated funds to Implement or provide grants for Preserving Affordable housing through Repair, Renovation, Reconstruction, and Rental Rehabilitation projects. CAPER 24 OMB Control No:2506-0117(exp.06/30/2018) o Allocated funds to the Development Fee Grant to projects in support the creation of Affordable Housing units (GF — Affordable Housing Grant). Fourteen (14) people were assisted in five (5) projects. o Funds awarded for utility assistance programs that increase Housing Stability and Prevent Homelessness. o Public Services Grants for rental assistance increase Housing Stability and Prevent Homelessness. ■ Completion January 2021 (GF) ■ Started Phase 2— Building the Strategies Toolkit • Public Services, Facility, and/or Infrastructure Grants to combat Food Insecurity through the Human Services Grant (CDBG/GF - Public Services Grant) • Public Services, Facility, and/or Infrastructure Grants to increase availability and access to Health, Mental Health, and Behavioral Health Care through the Human Services Grant (CDBG/GF - Public Services Grant). • Public Services, Facility, and/or Infrastructure Grants to improve Family Stability by improving safety, support, and opportunity, including access to affordable childcare through the Human Services Grant (CDBG/GF - Public Services Grant). • Public Services, Facility, and/or Infrastructure Grants to increase availability and access to services for special needs populations (seniors, disabled, veterans, abused and neglected children, and victims of domestic violence) through the Human Services Grant (CDBG/GF - Public Services Grant) • Public Services, Facility and/or Infrastructure Grants to make homelessness rare, brief, and nonrecurring through Utilities Grant (GF - Budget) • Intergovernmental collaboration and Public Services, Facility and/or Infrastructure Grants to increase access to Transportation increasing housing and workforce stability through Participation in DCTA Community Meetings to discuss solutions that increase access to Transportation and Participation in the Denton County Workforce Success Leadership Team Public Services Grants to increase access to mobility, educational programs, and workforce development for Economic security through the Human Services Grant (GF - Public Services Grant) Actions taken to develop institutional structure. 91.220(k); 91.320(j) Through financial and human resources in support of public services programs, special projects, and system planning, the City is taking actions to ensure a coordinated response to complex social issues, including support for and improvement of institutional structures. The City has defined overall institutional structure strategies to: 1. Develop and maintain a coordinated system across service sectors and cultivate systems to better match services to needs; CAPER 25 OMB Control No:2506-0117(exp.06/30/2018) 2. Identify and continuously evaluate the strengths and gaps in housing and supportive services, including improving systems to share best practices information across sectors; 3. Collect and utilize data that inform system-wide decision-making for prioritizing and selecting high-performing projects. A City priority is a coordinated systems approach to identifying those experiencing homelessness, preventing homelessness when possible, and quickly connecting people with housing and services. This Housing Crisis Response System (HCRS) is the City's collaboration with community partners to develop institutional structures. The HCRS increases the availability of Affordable Housing, strengthens the goal to Make Homelessness Rare, Brief, and Nonrecurring, enhances collaboration among governments and community partners for the provision of Public Services, and improves neighborhoods by facilitating Public Facilities, Public Improvements, and Infrastructure projects. Action taken in 2021/22 PY to develop institutional structure: • Completed Affordable Housing Strategic Toolkit, Phase 2 of an Affordable Housing Assessment to housing solutions (Affordable Housing Goal). • Provided general funds to support the Denton County Homelessness Leadership Team, a public-private partnership with the United Way for staff who provide technical support for joint agency bi-weekly case conferencing, management of the housing priority list, housing navigation, and mobilization of support services necessary to secure housing and maintain housing stability. (Make Homelessness Rare, Brief, and Nonrecurring). • Provided general funds to United Way for staff who provide technical support of Coordinated Entry and Homeless Management Information System (HMIS), including general funds for HMIS licenses to support increase the number of organizations participating in and contributing data to our HCRS. (Make Homelessness Rare, Brief, and Nonrecurring). • Provided CBDG and general funds for street outreach, diversion, emergency shelter, and Rapid Rehousing, including utility assistance programs (Make Homelessness Rare, Brief, and Nonrecurring). • Provided funding to local nonprofits through grants and other programs (Public Services). • Participated in Intergovernmental groups, local Coalitions, and Community Meetings to discuss solutions for improved community response systems to complex social issues (Public Services). • Provided funding for Public Facilities, Public Improvements and Infrastructure projects to improve neighborhoods (Public Facilities, Public Improvements and Infrastructure). Actions taken to enhance coordination between public and private housing and social service agencies. 91.220(k); 91.320(j) The City of Denton has a solid network of service providers, including housing and supportive services. The City has a partnership with the United Way of Denton County in three Collective CAPER 26 OMB Control No:2506-0117(exp.06/30/2018) Impact projects: the Denton County Behavioral Health Leadership Team, Denton County Homelessness Leadership Team, and the Denton County Workforce Success Leadership Team. These projects bring public and private sectors together to review and discuss services in the Denton area, to improve systems and maximize the benefits derived from available resources. In addition, Denton has several workgroups, committees, collaborations, and coalitions developed to enhance coordination between public and private housing and social service agencies. The City of Denton staff, including Community Development, continued to participate in the below committees during the 2021/22 PY. • Denton County Homeless Coalition • Committee on Persons with Disabilities • Denton Hunger Coalition • Healthy Communities Coalition (specific issues discussed including mental health) Identify actions taken to overcome the effects of any impediments identified in the jurisdictions analysis of impediments to fair housing choice. 91.520(a) Details regarding the actions to overcome the effects of any impediments are in the City's Fair Housing Plan and Analysis of Impediments (FHP-AI). The work plan (and Action Plan goals) includes six (6) goals with proposed actions to remove or ameliorate barriers to affordable housing: Increase access to affordable housing in high-opportunity areas 1. Increase supply of affordable housing units 2. Increase supply of accessible, affordable housing for persons with disabilities 3. Make investments in targeted neighborhoods to improve access to opportunity 4. Increase access to information and resources on fair and affordable housing 5. Increase supports and services for residents with housing assistance The City of Denton's analysis of impediments to fair housing choice indicated no overt barriers to fair housing. The actions taken over the past year to support fair housing include the following: • Weekly advertisements in the local Denton Record-Chronicle newsletter providing information regarding how to get assistance in filing a fair housing complaint; • Community Development works with local lenders and real estate professionals to support fair lending and fair housing practices. Homebuyer Assistance Program assisted one (1) households in becoming homeowners; • Provision of assistance to those with housing problems through both Community Improvement Services (code enforcement) and Community Development housing assistance; • Program information, legal documents, newsletters provided in English/Spanish; CAPER 27 OMB Control No:2506-0117(exp.06/30/2018) • The City provides a Housing Tax Credit Policy and Application supporting of the development and preservation of affordable rental housing for low-income households. Developers request Housing Tax Credits (HTC) through the Texas Department of Housing and Community Affairs. The City provided seven (7) Resolution of Support for a developer's 9% HTC Application and Resolutions of No Objection for six (6) 4% HTC applications. • The City preserved affordable housing units throughout Denton through the Development Fee Grant Program, including one (1) nonprofit developer and four (4) homeowners in the City's Home Improvement Program. CAPER 28 OMB Control No:2506-0117(exp.06/30/2018) CR-40- Monitoring 91.220 and 91.230 Describe the standards and procedures used to monitor activities carried out in furtherance of the plan and used to ensure long-term compliance with requirements of the programs involved, including minority business outreach and the comprehensive planning requirements City of Denton is responsible for collecting pertinent qualifying and performance data from subrecipients for the CDBG and HOME program reporting, and project monitoring purposes. Subrecipients must keep accurate records that conform to City of Denton and federal requirements and regulations. Subrecipients must be able to fully document their CDBG and HOME projects to demonstrate compliance with all applicable regulations. Agencies receiving funding are required to report on various items throughout the program year, including board meeting notices and minutes, financial reports, quarterly beneficiary and performance reports and year-end beneficiary reports. The City provides information and training to subrecipients, distributing information on program requirements. City of Denton staff conducted mandatory contract implementation training for all subrecipients. Technical assistance is provided to subrecipients as needed. The City completes programmatic and financial monitoring of CDBG subrecipients and documents those reviews with a checklist and monitoring reports. Below is an overview of the 2021/22 monitoring compliance for the CDBG and HOME grants: CDBG Program Monitoring In 2021/22 FY, the City of Denton conducted ongoing desk monitoring and a risk analyses for all CDBG funded subrecipients. The City completed site visits of the following CDBG and CDBG-CV funded subrecipients: Denton County Friends of the Family, City of Denton Parks department, Health Services of North Texas, Span Denton County (Span Transportation & Meals on Wheels of Denton County), Denton City County Day School, The Salvation Army and Children's Advocacy Center of Denton County. The City also completed site visits to the following funded General Fund funded subrecipients: Solutions of North Texas and Giving Grace. During these visits, staff observed the operations and management of projects. Other activities conducted on these visits included: inspection of accounting systems, client records, file organization, goal and objectives review, contract compliance, budget status/review and program performance. The details of on-site monitoring visits were documented, including: persons contacted, records reviewed, concerns or problems discussed, and any applicable conclusions or recommendations. No deficiencies were found, but various items were noted. The City of Denton continues to work with all subrecipients to ensure that self-certification forms are completed on a yearly basis for all clients. Subrecipients have been advised that they are required to collect information to determine income. Due to comments received, the City of Denton has revised the self-certification form. CAPER 29 OMB Control No:2506-0117(exp.06/30/2018) HOME Program Monitoring During the 2021/22 FY, the City of Denton conducted monitoring of the Denton Affordable Housing Corporation, Cumberland Youth and Family Services (formerly Cumberland Presbyterian Children's Home, and Fairoaks of Denton, Inc. 1. Denton Affordable Housing Corp, a local Community Housing Development Organization (CHDO). DAHC is recertified as a CHDO prior to the start of every project. DAHC is required to submit quarterly financial, beneficiary reports, yearly audits, and income applications for all HOME rental units. City staff provides DAHC with technical assistance with HOME construction projects and monitors projects from start to finish. Technical assistance includes initial inspections, assisting with work write-ups, in-progress inspections, reimbursements, and final inspections. City staff complete inspections of each unit with DAHC staff present to ensure that the rehabilitation or new construction specifications include all items required to bring the unit into compliance with the City of Denton building codes. Upon completion and before the release of any payment to DAHC, the unit is inspected to confirm that all required items have been completed. The Denton Affordable Housing Corporation is monitored on an annual basis and was monitored on August 25, and September 1, 2022. Individual files were reviewed for compliance with special attention to annual inspections on rental units, tenant leases on rental units, and other items related to HOME program rehabilitation requirements. The City also reviewed fair housing compliance, reporting requirements, policy items (records/retention, conflict of interest, nepotism, political activity and lobbying, equal opportunity and nondiscrimination, financial policy: procurement, financial policy: separation of duties/internal controls), bank reconciliations and general ledgers for August, September, and October 2021, bank card signatures and proof of pay tax payments for 2021/22 FY. One recommendation was noted as a result of the 2021/22 monitoring visit. Staff recommended that DAHC's Policies and Procedures be revised and resubmitted for review. Staff recommended that the following policies be revised or developed: Revised income eligibility policy to ensure all applicants are reviewed in the same manner using the same type of income documentation; Develop a policy to determine when self-certification and full recertifications are needed to ensure consistency; Develop a policy to notify the City of rent increases; Develop a fair housing policy to maintain a list of denied applicants with the reason for denial or reasons why the households were not assisted. The information collected should include ethnicity, household size, type of household, and reason for denial CAPER 30 OMB Control No:2506-0117(exp.06/30/2018) or if they obtained other housing. The log of all denied applicants that completed the application process must be maintained and available for review upon request. The list should be developed and maintained and will be reviewed at the next monitoring visit. 2. A desk monitoring was completed on Cumberland Youth and Family Services (formerly Cumberland Presbyterian Children's Home) with a site monitoring on a bi-annual basis. Cumberland submitted quarterly financial and beneficiary reports. No issues were noted in the annual desk monitoring. 3. Fairoaks was monitored on August 31, 2022. Fairoaks provides quarterly tenant and financial reports. These reports include the income information for each of the tenants currently residing in the facility. Fairoaks staff also provides information on the most recent tenant income evaluation dates and the rent amount paid by each tenant. All tenants in the Fairhaven apartments receive a HUD 202 PRAC subsidy. In addition, annual independent audits are submitted for review by City CD staff. Over the past year, CD has been working with the Fairoaks staff to complete a HOME Investment Partnership Program. As part of the project, CD has visited and inspected the areas to be renovated and determined that no additional improvements were necessary. The following was reviewed and completed: inspection of all units, review of internal inspections of all units, current tenant leases, Fair Housing compliance that includes affirmatively market units, tenant selection policy, and proof of pay tax payments for 2021/22 FY. No findings were noted. Fairoaks is required to submit quarterly financial and beneficiary reports. In addition, City staff completes an inspection of each unit with Fairoaks staff present to ensure that the rehabilitation or new construction specifications include all items required to bring the unit to City of Denton building codes. CAPER 31 OMB Control No:2506-0117(exp.06/30/2018) Citizen Participation Plan 91.105(d); 91.115(d) Describe the efforts to provide citizens with reasonable notice and an opportunity to comment on performance reports. Citizens have a variety of opportunities to provide comments on all Community Development programs and projects throughout the year. To ensure citizen participation in the 2021/22 PY performance report process, the City followed its 2020-23 Citizen Participation Plan. A notice was placed in the Denton Record Chronicle on December 11, 2022, requesting public comments on the draft 2021/22 PY CAPER. The advertisement stated that the City of Denton accepts comments on the performance report from December 12 through 26 on the status of community development projects. The advertisement also included the website location of the draft report. The affidavit of publication for the advertisement is in Attachment 4. The draft CAPER report was available at www.citvofdenton.com/communitVdevelopment beginning December 11. Citizen participation strategies include: • Public Comment. Community Development accepted comments on the draft report from December 12 through 26 by phone at (940) 349-7726, at Community Development at 401 N. Elm St., Denton, TX 76201, by email at CommunityDevelopment@cityofdenton.com • Social media outreach. Staff coordinated with Public Affairs to post information on the City's social media channels. • Email. Staff send out information through Constant Contact to interested citizens, previous clients, committee members, local churches, participating lenders and realtors, neighborhood associations and social services agencies. No comments were received during the 1S-day comment period. CAPER 32 OMB Control No:2506-0117(exp.06/30/2018) CR-45 - CDBG 91.520(c) Specify the nature of, and reasons for, any changes in the jurisdiction's program objectives and indications of how the jurisdiction would change its programs as a result of its experiences. The City of Denton completed the following amendment during the 2021/22 PY: PurposeAction Plan Completed Quakertown Park Restroom Project 2016 Residual Funds Minor $6,432.94 Completed Homebuyer Assistance Program 2017 Residual Funds Minor $22,473.55 Completed Fairoaks Sr. Housing Project Residual 2019 Funds Minor $109.77 Completed Denton City Council Day School Project 2020 Residual Funds Minor $5,359.00 Completed Denton County Friends of the Family 2020 Residual Funds Minor $66.23 Completed Sequoia Park Playground Residual 2021 Funds Minor $55,809.79 Table 3 -Amendments Does this Jurisdiction have any open Brownfields Economic Development Initiative (BEDI) grants? No [BEDI grantees] Describe accomplishments and program outcomes during the last year. CAPER 33 OMB Control No:2506-0117(exp.06/30/2018) CR-50- HOME 91.520(d) Include the results of on-site inspections of affordable rental housing assisted under the program to determine compliance with housing codes and other applicable regulations Please list those projects that should have been inspected on-site this program year based upon the schedule in §92.504(d). Indicate which of these were inspected and a summary of issues that were detected during the inspection. For those that were not inspected, please indicate the reason and how you will remedy the situation. Between one (1) and four (4) rental units are inspected every three (3) years; between five (5) and twenty-five (25) units are inspected every two (2) years, and more than twenty-five (25) units are inspected yearly. The HOME waiver included a waiver of on-site inspections for HOME-assisted Rental Housing due to the COVID-19 Pandemic to ensure tenants' safety. The HOME waivers and extentions were effective until December 31, 2021. The waiver impacted units that were scheduled to be inspected in the 2019/20 and 2020/21 PY. At the end of the waiver period, the HOME PJ had 180 days to physically inspect units. All seventy-six (76) rental units, were inspected during the 2021/22 PY. The Rental Inspection Schedule located in Attachment 5 for the 2021/22 PY includes results of the on-site inspections of affordable rental housing assisted under the HOME program. During on-site inspections, any minor issues that were identified by the Community Development Inspector were corrected. Provide an assessment of the jurisdiction's affirmative marketing actions for HOME units. 92.351(b) The City of Denton housing programs were affirmatively marketed to low-income and minority households throughout the City. The following is a list of actions taken to affirmatively market to low-income and minority households during the 2021/22 PY: • Program information is available in English and Spanish, with bilingual Spanish-speaking staff available to applicants when needed. • Inspector carries a supply of housing program information brochures in his vehicle and distributes them to residents of substandard properties. • Community Improvement Services (Code Enforcement) officers carry our brochures and provide them to residents of substandard properties. • The City of Denton Cable Channel (DTV) advertises CD housing assistance programs regularly. City produced a project video with DTV to market housing programs using CDBG and HOME funds in support of affordable housing and a suitable living environment for Denton residents. • Denton nonprofit agencies refer households to City when housing repairs are needed. • The City's website includes program descriptions, requirements, and information needed to apply for assistance. CAPER 34 OMB Control No:2506-0117(exp.06/30/2018) • Home Improvement Program (HIP) applicants are given an option to allow a yard sign to be placed in their yard during rehab or reconstruction that advertises the City's home repair programs. • Information on all programs is provided at the Participating Lenders and Real Estate Buyer's Agents Training. Describe other actions taken to foster and maintain affordable housing. 91.220(k) (STATES ONLY: Including the coordination of LIHTC with the development of affordable housing). 91.320(j) As more low-income households struggle to find affordable housing, preserving existing housing is essential. Preservation supplements new developments, prevents displacement, is generally cheaper than building new housing, and it conforms to existing land-use patterns. During the 2021/22 PY, the City prioritized the use of its HOME funding for the preservation of affordable housing that serves low-to moderate-income households. The goal of preserving affordable housing is to allow homeowners and renters who might not otherwise afford necessary repairs to maintain a safe and healthy living environment. The Home Improvement Program, DAHC Rental Rehabilitation Program, and the Fairoaks Senior Housing Project use HOME funding for preservation activities. The programs help low-to moderate-income homeowners make much-needed repairs, enabling them to preserve and prevent the displacement of low-income households who otherwise may struggle to keep their homes in livable condition. During the PY the City also prioritized Denton Affordable Housing Corp with funding to rehabilitate rental units. Staff provided assistance to DAHC to complete work write ups for five (5) rental units that were completed at the beginning of the 2022/23 program year. Also, during the PY the City funded the Home Improvement Program to complete substantial rehabilitation and reconstruction of homes that were not feasible to rehabilitation. Home Improvement Projects allows ADA repairs or additions to assist a household with accessibilities. CAPER 35 OMB Control No:2506-0117(exp.06/30/2018) �CM�N70c U.S.DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Fort Worth Regional Office,Region VI o Office of Community Planning and Development a IIIIIIII miz 301 W.7'Street,Suite 1000 �9 Fort Worth,TX 76102 eqN oEJE`A cpdd generalcorr-ftw(&hud.gov March 1, 2023 Luisa Garcia, Community Development Manager Community Services Department City of Denton 401 North Elm Street Denton, TX 76201 Sent via email to: (Luisa.Garcia&cityofdenton.com) Dear Mrs. Garcia: SUBJECT: Annual Community Assessment for the 2021 Program Year HUD is required to conduct an annual review of performance by grant recipients according to the provisions of the Housing and Community Development Act and the National Affordable Housing Act. We must determine that each recipient is in compliance with the statutes and has the continuing capacity to implement and administer the programs for which assistance is received. This is to report the results of our review of the City's performance during the 2021 program year: 10/01/2021 —09/30/2022. Report Our review is based on an evaluation of your consolidated planning process and progress in carrying out the programs; the management of funds by the City and your subrecipients; information provided in the Consolidated Annual Performance and Evaluation Report (CAPER), Integrated Disbursement and Information System(IDIS), and SAGE HMIS Reporting Repository; results of on-site and remote monitoring; and your achievement of program objectives. We congratulate you on the City's accomplishments during the 2021 program year and your performance in the following areas: Community Development Block Grant (CDBG) Program Providing Suitable Living Environments. According to information provided in IDIS,the city assisted 2,977 people during the 2021/22 program year with homeless assistance and prevention activities with the help of Denton County Friends of the Family, the Temporary Shelter Hotel Voucher Program, and The Salvation Army of North. According to information provided in IDIS, the city assisted with public services funding for Denton City County Day School, SPAN, Inc., and City's Summer Kids Camp to assist 1422 people during the 2021/22 program year. Providing Decent Housing. According to information provided in IDIS, the City used CDBG funds to assisted forty-six (46)homeowners with minor, substantial rehabilitation or reconstruction and one (1)households received down payment and closing costs assistance through the Homebuyer Assistance Program. Primary Objective. According to the 2021 Action Plan, the city designated program year 2021 as the overall program benefit period. According to information provided in the CDBG Financial Summary Report for Program Year 2021, the City expended 100 percent of its CDBG funds for activities which principally benefit low- and moderate-income persons, which is greater than the 70 percent minimum standard for overall program benefit. Timeliness. According to information provided in IDIS, the city is implementing its program in a timely manner. The timeliness standard is that 60 days before the end of the program year, a grantee must not have more than 1.5 program years of grant funds in its line of credit. As of August 2, 2022, the City's unadjusted and adjusted for program income line of credit balances were both 1.39. This rate of progress assures that the benefits of the program are reaching the intended beneficiaries within a reasonable period of time after grant approval. Program Year Obligation Caps. According to information provided in the CDBG Financial Summary Report for Program Year 2021, the amount of funds obligated for planning and administration during the program year was 20 percent, which is not above the 20 percent cap for such activities; and the amount of funds obligated for public service activities during the program year was 14.58 percent,which is below the 15 percent cap for such activities. Origin Year Grant Expenditure Standard. The origin year grant expenditure standard is that no more than 20 percent of any origin year grant shall be expended for planning and administration costs. Funds from origin year grants 2021 and 2020 were expended during the program year. According to information provided in the PR 26 CDBG Activity Summary Report for Grant Years 2021 and 2020 the amount of funds expended on planning and administration was 20 percent and 20 percent respectively, which is not above the 20 percent planning and administration cap for each grant. Primary Objective— CDBG-CV Grant. According to information provided in the CDBG- CV Financial Summary Report, the City expended 100 percent of its CDBG-CV funds for activities which principally benefit low- and moderate-income persons, which is greater than the 70 percent minimum standard for overall program benefit. Program Cap— CDBG-CV Grant. According to information provided in the CDBG-CV Financial Summary Report, the amount of funds expended on planning and administration was 0 percent, which is below the 20 percent cap for such activities. HOME Investment Partnership (HOME) Program Providing Affordable Housing. According to information provided in IDIS, the city provided 47 low-income and very-low-income households with decent affordable housing. Program Caps. According to information provided in IDIS, the amount of 2021 grant funds disbursed for administration and planning costs was 10 percent,which is not above the 10 percent cap for such activities. Areas Needing Improvement and Recommendations We provide the following comments for your consideration as you continue to improve performance, develop and refine your Consolidated Planning process, and carry out your programs. CDBG Program— CDBG has eligibility categories related to providing social services, such as health care, day care, substance abuse services, education, or safety services. CDBG can be used to assist the rehabilitation and development of these facilities, as well as the services themselves. These services can be combined with housing programs to offer a more complete package of assistance to low-income persons and communities. CDBG-CV Program—Eligible Activities. The City may use CDBG-CV funds only for those activities carried out to prevent,prepare for, and respond to coronavirus. By law,use of funds for any other purpose is unallowable. To satisfy these purposes, City may assist activities that respond to direct effects, such as the need to rehabilitate a building to add isolation rooms for recovering coronavirus patients. City may also undertake activities to address indirect effects of the virus, such as the economic and housing market disruptions caused by social distancing measures and stay at home orders implemented to prevent the spread of coronavirus. CDBG-CV Program—Period of Performance. The City is reminded that, per FR-6218-N-01, grantees must expend all CDBG-CV funds within the 6-year period of performance established in its CDBG-CV grant agreement. Additionally, HUD is imposing an alternative requirement that each grantee must expend at least 80 percent of all CDBG-CV funds no later than the end of the third year of the period of performance established by the CDBG-CV grant agreement. It is noted that,per FR- 6218-N-01, HUD may authorize an extension of the three-year expenditure requirement or the overall period of performance if the grantee provides evidence of such extenuating circumstances that would warrant the extension and that they could demonstrate they would meet all program requirements within the extended expenditure period and period of performance. CDBG-CV Program—Substantial Amendments and Citizen Participation. The City is reminded that it should follow the requirements described in FR-6218-N-01 should it need to carry out a substantial amendment to its PY 2021 Action Plan to reprogram CDBG-CV funds. The City should contact the field office as needed for additional policy guidance relative to this process. CDBG-CV Program— Training and Policy Guidance. The City is encouraged to review the policy guidance and materials available in the CDBG-CV Toolkit as it considers eligible activities, the "prepare for, prevent, and respond to coronavirus" (PPR) tieback, and other program requirements. HOME Program Objective -HOME program intention is to operate in ways that will help participating jurisdictions (PJs) develop the skills, institutions, relationships, and vision they need to undertake their own affordable housing strategies. HOME was designed explicitly to expand the supply of decent and affordable housing for low- and very low-income Americans. HOME assisted rental and owner-occupied housing is to guarantee that Federal assistance reaches the families that most urgently need it. HUD Training. The City should be aware that HUD training for grantees is provided during the fiscal year. Courses often available include CDBG and HOME grants, as well as tools and resources to assist grantees in implementing CARES Act and American Rescue Plan grants. You may contact this office for information on which courses are currently available. Conclusion As a result of our evaluation, we have determined that the City has carried out its programs substantially as described in its Consolidated Plan; the Consolidated Plan as implemented complies with the requirements of the Housing and Community Development Act and other applicable laws and regulations; and the City has the continuing capacity to carry out its approved programs in a timely manner. We are providing the City with 30 days from the date of this letter to comment on this report. Should the City wish to comment or request changes to it we will take them into consideration and provide a written response. If no comments are received within the period allowed, then this report will be considered to be in final form. Once it is in final form, it will be made available to the public upon request. Public Access This report is intended to be shared with the public. You may provide copies to interested persons such as the news media, members of local advisory committees, and citizens attending public hearings. We request that you provide a copy of this letter to the Independent Public Accountant who performs the single audit of the city in accordance with 2 CFR part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. If you have any questions about this report,please contact Tracy E. Holmes, CPD Representative, at(817) 978-5870 or tracy.e.holmes&hud.gov. Sincerely, �ewQld le, �KseK� Pwo�wa�r /�a7a�ew for Shirley J. Henley Director Consolidated Annual Performance • Evaluation Report DENT • 2021-22 ProgramYear The Consolidated Annual Performance and During the 2021-23 program year from Evaluation Report (CAPER) is the year-end October 1,2021 through September 30,2022, report that evaluates the progress made the following funds were expended by towards community development programs funding source to assist a total of 36,034 and activities with funding from the federal people as detailed below. Community Development Block Grant (CDBG), HOME Investment Partnerships unding Source T (HOME), and Community Development CDBG(Federal) $1,302,878 Block Grant (CDBG-CV) programs. The CAPER is completed annually and submitted HOME (Federal) $865,581 to the U.S.Department of Housing and Urban CDBG-CV(Federal) $620,041 Development (HUD). While the CAPER General Fund* (Local) $2,565,688 focuses on federally funded activities, the City of Denton recognizes the importance of Total Expenditures $5,354,188 local funding in the provision of community *General Funds includes funding for public services,council initiatives,and administration development activities, especially in social for Community Development and Community services and homelessness. Improvements Divisions. SOCIAL NEIGHBORHOOD HOUSING HOMELESSNESS SERVICES SERVICES SERVICES SERVICES 8,123 Persons 23,020 Persons 103 Persons 4,788 Persons assisted through assisted through assisted through assisted through Public Services Public Facilities Affordable Homelessness activities & Infrastructure Housing Initiatives activities activities CommunityServices Department 401Denton Texas 76201 • - 941 4• •