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Consolidated Plan and Analysis of Impediments to Fair Housing Choice

 
2013-2018 Consolidated Plan, 2013 Action Plan, and Substantial Amendment

Metro Nashville is an entitlement community eligible to receive direct assistance under the U.S. Department of Housing and Urban Development (HUD) Community Development Block Grant (CDBG) program. Metro Nashville is a participating jurisdiction under the HOME Investment Partnerships Program (HOME) and a formula grantee under the Emergency Solutions Grant (ESG). Funds for these programs must be expended within Nashville-Davidson County for participants who meet applicable eligibility criteria and for eligible activities as outlined by program regulations. In addition, Metro Nashville is a formula grantee under the Housing Opportunities for Persons with AIDS (HOPWA) program; these funds target needs of persons living with HIV/AIDS and their families in the metropolitan area.
 
The Metropolitan Development and Housing Agency (MDHA) is the lead agency responsible for the development and administration of the Consolidated Plan for Metro Nashville. Within MDHA, the Community Development Department is responsible for administering the Consolidated Plan programs listed below.
 
Purpose of the Consolidated Plan:
 
As a recipient of federal grant funds, MDHA is required by HUD to produce a Consolidated Plan and Annual Action Plan on behalf of Metro Nashville. In 2012, MDHA contracted with WFN Consulting for the production of these planning documents. These plans serve as the application for funding for the following federal programs: 
 
The Five-Year Consolidated Plan identifies the community’s affordable housing, community development and economic development needs and outlines a comprehensive and coordinated strategy for addressing them. This document includes narrative responses to specific questions that grantees must answer in order to be compliant with the Consolidated Planning Regulations.
 
The previous Consolidated Plan covered the period from April 1, 2010 to March 31, 2015, and Metro Nashville was in program year three of the five-year plan when the planning process began for a new plan. Although there were two remaining years under the previous five-year plan, MDHA elected to undertake a new Consolidated Plan due to significant changes in Metro Nashville since 2009: the May 2010 Flood, reduced federal funding, and new federal laws and regulations. These drastic events, combined with the economic crisis of recent years, have changed housing and community needs throughout the county. A new Consolidated Plan allowed the City to identify the most pressing needs and develop the most effective strategies to meet those needs for the next five years (April 1, 2013 – March 31, 2018).

MDHA submitted the 2013–2018 Consolidated Plan and 2013 Annual Action Plan to HUD for approval on March 25, 2013. At the time of submission, anticipated funding amounts for the 2013 Program Year were estimated, as the actual allocation amounts were not released until May 29, 2013. The actual 2013 allocations included increases of 10% in CDBG funding and 4% in HOME funding and decreases of 20% in ESG funding and 5% in HOPWA funding than had been estimated. The Plan was updated in June 2013 to reflect the actual allocations.
 
During the 2013 Program Year, MDHA undertook a review of expenditures through the use of HUD’s Integrated Disbursement and Information System (IDIS), which provides tracking and reporting for the CPD grants.  Through this process, MDHA identified previously funded projects/activities with unspent funding and recaptured these funds. Additionally, some previously funded projects have since been completed below budget; and higher than anticipated receipts from program income allowed some projects to be funded completely from program income rather than from grant funds.  As a result, $2,802,098.50 in prior year CDBG funds and $1,291,620.15 in prior year HOME funds can be re-allocated to activities in the 2013 Annual Action Plan. These additional funds require budget revisions and enable MDHA to add new activities not previously described in the Consolidated Plan and 2013 Annual Action Plan submitted to HUD in March 2013.
 
The Plan submitted to HUD stated that MDHA would develop and implement a Place-Based Strategy to target community development efforts and resources to specific “priority neighborhood(s)” in order to have a more comprehensive and lasting impact on residents. The Plan, as submitted, provided general criteria on how MDHA would identify priority neighborhood(s) and a general description of activities to be undertaken. As stated in the Plan, MDHA has worked with a HUD-approved technical assistance provider to formalize the strategy and develop more specific details. The Substantial Amendment describes the methodology for selecting “priority neighborhoods”, activities to be undertaken, and funding allocated to eligible activities.  The Substantial Amendment was approved by HUD on September 25, 2013.
 
Draft 2014 Action Plan

MDHA has prepared a draft 2014-2015 Annual Update to the 2013-2018 Consolidated Plan (2014 Action Plan). The public comment period began on December 9, 2013 and concluded on January 31, 2014. Two public hearings were held on December 19, 2013 and January 28, 2014. In accordance with CPD Notice 13-010, MDHA will not submit the Plan to HUD until the 2014 allocation amounts have been announced.
 





Citizen Participation Plan


Introduction
 
The Citizen Participation Plan is designed to provide for and encourage citizen involvement in the development, implementation and evaluation of housing and community development programs in Metropolitan Nashville-Davidson County, Tennessee. While the processes contained in this Citizen Participation Plan may be used to address a broad range of public and private resources, this Plan is specifically designed to meet the citizen participation requirements for the Consolidated Plan for housing and community development needs of Metropolitan Nashville-Davidson County. Completion of the Consolidated Plan is required by the U.S. Department of Housing and Urban Development in order for Metropolitan Nashville-Davidson County to receive federal funds allocated through the Community Development Block Grant (CDBG), the HOME Investment Partnerships Program (HOME), the Emergency Solutions Grant (ESG), and the Housing Opportunities for Persons with AIDS (HOPWA) Program.
 
As the lead agency responsible for the preparation and administration of the Consolidated Plan, the Metropolitan Development and Housing Agency (MDHA) has the primary responsibility for developing and implementing the Citizen Participation Plan. Per the federal regulations found at 24 CFR 91, the citizen participation plan must provide for and encourage citizens to participate in the development of the Consolidated Plan, the annual action plan, any substantial amendments to the Consolidated Plan, and the annual performance report. The plan is designed especially to encourage participation by low- and moderate-income persons, particularly:
 
         those living in slum and blighted areas,
         in areas where CDBG funds are proposed to be used,
         residents of predominantly low- and moderate-income neighborhoods,
         residents of public and assisted housing developments, and
         residents of targeted revitalization areas in which the developments are located.
 
MDHA will follow its citizen participation plan to the greatest extent possible. The requirements for citizen participation do not restrict the responsibility or authority of MDHA for the development and execution of its Consolidated Plan. MDHA will provide citizens with a reasonable opportunity to comment on amendments to the citizen participation plan and will make the citizen participation plan public. The citizen participation plan must be in a format accessible to persons with disabilities, upon request.
 
The Community Development Department of MDHA is the point of contact for all questions, comments, complaints, and requests for technical assistance. The Community Development Department can be contacted by telephone at 615-252-8505 or by e-mail at comments@nashville-mdha.org. Please address all correspondence to:
 
MDHA Development Department
Attn: Consolidated Plan
P.O. Box 846
Nashville, TN 37202
 
MDHA will maintain a mailing list to keep interested parties informed with updates regarding the Consolidated Plan. To be added to the mailing list call 615-252-8505.
 
The Consolidated Plan & Annual Action Plan
 
Every five years MDHA develops a long-term strategic plan called the Consolidated Plan. The Consolidated Plan guides the programs that MDHA will undertake each year. In addition to the Consolidated Plan, MDHA must prepare an annual action plan that describes the actions to be taken in a specific program year. To ensure public participation in the development of the Consolidated Plan and annual action plan, MDHA will hold a public hearing, accept public comment, and issue public notices for the Consolidated Plan and for each annual action plan.
 
·         Public Notice & Publication
 
MDHA will publish a public notice in a non-legal section of The Tennessean and at least one weekly minority newspaper prior to the beginning of the public comment period and a minimum of two weeks before a public hearing. MDHA will also publish a notice on its website. The notice will include a general summary and the location where copies of the entire plan may be obtained. MDHA will also send the notice to all members of the Consolidated Plan mailing list. Notices will also be distributed to all active affordable housing forums/groups, public housing Resident Associations, HUD gaps group and other homeless advocacy groups, and interested parties and groups.
 
MDHA is required to publish each proposed plan in a manner that affords citizens, public agencies, and other interested parties a reasonable opportunity to examine its contents and to submit comments. MDHA will provide a reasonable number of free copies of the plan to citizens and groups that request it. The Consolidated Plan will be provided in alternate formats. Copies of each plan will be available for review at MDHA and on the MDHA website at: http://www.nashville-mdha.org/reports-consolidated.php.
 
·         Public Hearings
MDHA will hold at least one public hearing per year during the development of the Annual Action plan. The purpose of the public hearing is to obtain citizens' views, respond to proposals, and answer questions. The hearings will address housing and community development needs, proposed activities, and review of program performance. These hearings are held while the proposed plan is published for comment.
 
Upon request, MDHA will provide for translation services to meet the needs of non-English speaking residents. MDHA will also take whatever actions are appropriate to serve the needs of persons with disabilities.
 
·         Public Comments
 
MDHA will provide a period of at least 30 days to receive comments from citizens on each proposed plan. MDHA will consider any comments or views of citizens received orally at the public hearings or in writing during the public comment period, in preparing the final adopted plan. A summary of these comments or views and MDHA’s responses shall be attached to the final adopted plan.
 
Plan Amendments
 
In the course of administering the four federal programs, MDHA may need to amend the Consolidated Plan or an annual action plan. When the amendment is significant and meets the criteria set forth below, the change will be considered a substantial amendment and MDHA will undertake additional actions to ensure citizens have an opportunity to comment. Records of all amendments will be maintained at MDHA for public review and will be fully described in the annual performance report submitted to HUD.
 
·         Criteria for Substantial Amendments
 
If a plan amendment meets any of the following criteria, MDHA will consider the amendment to be substantial and undertake the additional steps described in this section to ensure public participation:
 
o   a change in funding allocation priorities described in the Consolidated Plan,
o   a new program not previously described in an annual action plan,
o   the deletion of an activity described in the Consolidated Plan,
o   a budget amendment for any program of more than twenty-five percent (25%), or
o   a substantial amendment is required by HUD.
 
·         Public Notice & Publication
 
In the case of any proposed substantial amendment, MDHA will publish a public notice in The Tennessean and at least one weekly minority newspaper a prior to the beginning of the public comment period and a minimum of two weeks before a public hearing. The notice will include a summary of the amendment and a list of the locations where copies of the amendment may be examined. MDHA will also maintain a mailing list of interested parties and send information regarding the amendment to all members of the mailing list.
 
·         Public Comments
 
MDHA will provide a period of at least 30 days to receive comments from citizens on each proposed plan. MDHA will consider any comments or views of citizens received orally at the public hearings or in writing during the public comment period, in preparing the final adopted plan. A summary of these comments or views and MDHA’s responses shall be attached to the final adopted plan.
 
 
Each year MDHA must submit a Consolidated Annual Performance and Evaluation Report (CAPER) to HUD. This report is due 90 days after the close of the program year. To ensure public participation in the review of the performance report, MDHA will hold a public hearing, accept public comment, and issue public notices.
 
·         Public Notice & Publication
 
MDHA will publish a public notice in The Tennessean and at least one weekly minority newspaper prior to the beginning of the public comment period and a minimum of two weeks before a hearing. MDHA will also maintain a mailing list of interested parties and send information to all members of the mailing list. MDHA will provide a reasonable number of free copies of the performance report to citizens and groups that request it. Copies of each report will be available for review at MDHA and on the MDHA website at: http://www.nashville-mdha.org/reports-caper.php.
 
·         Public Hearings
 
MDHA will hold at least one public hearing per year during the preparation of the annual report. The purpose of the public hearing is to obtain citizens' views, answer questions, address housing and community development needs, and review program performance.
 
Upon request, MDHA will provide for translation services to meet the needs of non-English speaking residents. MDHA will also take whatever actions are appropriate to serve the needs of persons with disabilities.
 
·         Public Comments
 
MDHA will provide a period of at least 15 days to receive comments on the annual report before the report is submitted to HUD. MDHA will consider any comments or views of citizens received orally at public hearings or in writing during the public comment period, when preparing the final report. MDHA will attach a summary of these comments and MDHA’s response to the final annual report.
 
Information
 
In addition to providing participation in the development of plans and the review of the annual report, MDHA will provide citizens, public agencies, and other interested parties with reasonable and timely access to information and records relating to the Consolidated Plan and the use of federal funds. MDHA will provide access to records for the current program year and previous five program years. This information includes, but is not limited to, the citizen participation plan, the Consolidated Plan as adopted, annual action plans, performance reports, and any substantial amendments. MDHA will make these records available in a form accessible to persons with disabilities, upon request. Most records are maintained at MDHA in the Community Development Department, located at 712 South Sixth Street.
 
Records may be reviewed by appointment during regular business hours.
 
MDHA will also provide citizens with reasonable and timely access to local meetings held in regard to the Consolidated Plan and the activities undertaken as part of the Consolidated Plan.
 
Technical Assistance
 
MDHA must provide for technical assistance to groups representative of persons of low- and moderate-income that request such assistance in developing proposals for funding assistance under any of the programs covered by the Consolidated Plan. To request technical assistance, contact the Community Development Department using the contact information listed in the Introduction. MDHA hosts pre-proposal conferences when an Request for Proposal is issued to award funding for a project. The purpose of the pre-proposal conference is to answer questions from potential respondents.