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Resolution 2022-31979RESOLUTION NO. 2022-31979 A RESOLUTION OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, APPROVING A "SUBSTANTIAL AMENDMENT" TO THE CITY'S ONE-YEAR ACTION PLAN FOR FEDERAL FUNDS FOR FY 21, IN ACCORDANCE WITH APPLICABLE FEDERAL REQUIREMENTS, TO INCLUDE THE HOME INVESTMENT PARTNERSHIPS PROGRAM AMERICAN RESCUE PLAN (HOME -ARP) FUNDS IN THE AMOUNT OF $2,245,387; AND AUTHORIZING THE CITY MANAGER TO: (1) EXECUTE ALL APPLICABLE DOCUMENTS RELATED TO THE APPROPRIATION AND ALLOCATION OF THE HOME -ARP PROGRAM FUNDS; (2) SUBMIT THE ONE-YEAR ACTION PLAN TO HUD; (3) MAKE SUBSTANTIAL CHANGES TO THE ONE-YEAR ACTION PLAN; AND (4) SUBMIT THE REVISED ACTION PLAN; AND FURTHER AUTHORIZING THE CITY MANAGER AND CITY CLERK TO EXECUTE AGREEMENTS FOR SUB -RECIPIENTS OF HOME -ARP PROGRAM FUNDS AND INTERDEPARTMENTAL AGREEMENTS FOR RECIPIENTS OF HOME -ARP PROGRAM FUNDS. WHEREAS, the City is an entitlement recipient of U.S. Department of Housing and Urban Development (HUD) formula grant programs as follows: Community Development Block Grant (CDBG) funds and HOME Investment Partnerships (HOME) funds; and WHEREAS, the City expects to continue to receive entitlement funds from these grant programs to operate the City's housing and community development activities; and WHEREAS, the One -Year Action Plan for Federal funds is a requirement under the HUD formula grant programs, including the CDBG and HOME Programs; and WHEREAS, the- One -Year Action Plan for FY 2021 is based upon the City's Federal entitlement of $991,531.00 in CDBG funds and $619,533.00 in HOME funds; and WHEREAS, On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 for the HOME Investment Partnerships Program ("HOME -ARP") into law, which provides funding to address the continued impact of the COVID-19 pandemic on the economy, public health, State and local governments, individuals, and businesses; and WHEREAS, on September 22, 2021, the local US HUD field office notified the City of its HOME -ARP allocation of $2,245,387, which must be expended by September 30, 2030 on eligible activities, to address the need for homelessness and supportive services, as described in the One - Year Action Plan for FY 21; and WHEREAS, disbursement,of funds is contingent upon the City's submission of the HOME - ARP allocation plan, included as part of the amended One -Year Action Plan for FY 21 and the execution of the HOME -ARP grant agreement, and WHEREAS, the City advertised a Notice of a 30 -day public comment period (November 8, 2021 — December 8, 2021), with a public hearing on November 16, 2021 for the substantial amendment to the One -Year Action Plan for FY 21, including the HOME -ARP funds; and WHEREAS, HOME -ARP funds must be used to primarily benefit qualifying populations through four eligible activities: (1) development and support of affordable housing, (2) tenant -based rental assistance (TBRA), (3) provision of supportive services; and (4) acquisition and development of non -congregate shelter units; and WHEREAS, the HOME -ARP allocation plan must describe how the City intends to distribute HOME -ARP funds, including how it will use these funds to address the needs of qualifying populations, as determined in the consultation process; a community needs assessment; and the gap analysis of current housing and shelter inventory; and WHEREAS, 15 percent (15%) of the City's allocation ($336,808.05) can be allocated to the planning and administration of the HOME -ARP Program and up to five percent (5%) of funds can be allocated to a non-profit capacity building; and WHEREAS, the City plans to allocate the remaining HOME -ARP funds to the following activities: 1) Rental Housing ($1,400,000), 2) Supportive Services ($396,309.25), and 3) Non-profit capacity building ($112,269.35); and WHEREAS, the Administration will issue a Request for Proposals in February 2022 to obtain applications from qualified providers interested in providing services aligned with the HOME -ARP Allocation Plan; and WHEREAS, the City Manager is the HUD -designated agent for all formula grants, and executes the grant applications, agreements, and other applicable HUD documents on behalf of the City. NOW, THEREFORE, BE IT DULY RESOLVED BY THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, that the Mayor and City Commission hereby approve a "substantial amendment" to the City's One-YearAction Plan for federal funds for FY 21, in accordance with applicable federal requirements, to include the Home Investment Partnerships Program American Rescue Plan (HOME -ARP) funds in the amount of $2,245,387; and authorize the City Manager to: (1) execute all applicable documents related to the appropriation and allocation of the HOME -ARP program funds; (2) submit the One-YearAction Plan to HUD; (3) make substantial changes to the One-YearAction Plan; and (4) submit the revised action plan; and further authorize the City Manager and City Clerk to execute agreements for sub -recipients of HOME -ARP program funds and interdepartmental agreements for recipients of HOME -ARP program funds. PASSED and ADOPTED this oto ATTEST: day of 70,F7 k 4 r V , 2022. C ._. k'�oro.rro ban Gelber, Mayor Rafael E. Granado, City Clerk J AN 2 5 2022. APPROVED AS TO FORM & LANGUAGE & FOR EXECUTION (_>_� f o 2� City Attorney * Date C7 -Resolutions M MIAMI BEACH COMMISSION MEMORANDUM TO: Honorable Mayor and Members of the City Commission FROM: Alina T. Hudak, City Manager DATE: January 20, 2022 SUBJECT:A RESOLUTION OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, APPROVING A "SUBSTANTIAL AMENDMENT" TO THE CIT'rS ONE-YEAR ACTION PLAN FOR FEDERAL FUNDS FOR FY 21, IN ACCORDANCE WITH APPLICABLE FEDERAL REQUIREMENTS, TO INCLUDE THE HOME INVESTMENT PARTNERSHIPS PROGRAM AMERICAN RESCUE PLAN (HOME -ARP) FUNDS IN THE AMOUNT OF $2,245,387; AND AUTHORIZING THE CITY MANAGER TO: (1) EXECUTE ALL APPLICABLE DOCUMENTS RELATED TO THE APPROPRIATION AND ALLOCATION OF THE HOME -ARP PROGRAM FUNDS; (2) SUBMIT THE ONE-YEAR ACTION PLAN TO HUD; (3) MAKE SUBSTANTIAL CHANGES TO THE ONE-YEAR ACTION PLAN; AND (4) SUBMIT THE REVISED ACTION PLAN; AND FURTHER AUTHORIZING THE CITY MANAGER AND CITY CLERK TO EXECUTE AGREEMENTS FOR SUB -RECIPIENTS OF HOME -ARP PROGRAM FUNDS AND INTERDEPARTMENTAL AGREEMENTS FOR RECIPIENTS OF HOME -ARP PROGRAM FUNDS. RECOMMENDATION The Administration recommends approving the Resolution. BACKGROUND/HISTORY The Five -Year Consolidated Plan is a federal requirement for all U.S. Department of Housing and Urban Development (HUD) entitlement cities. The City of Miami Beach is a HUD - designated entitlement city as determined by the decennial census information on population growth lag, over -crowding, age of housing stock, and poverty. The City of Miami Beach has been a Community Development Block Grant (CDBG) entitlement community since 1975. The HOME Program was started in 1992 to provide funding specifically for affordable housing. As an entitlement community, the City automatically qualifies for an annual allocation of federal funding under HUD's grant programs. HUD requires each entitlement community to submit an annual One -Year Action Plan describing how it will utilize funding and resources to address priority needs identified in the City's Consolidated Plan. The One -Year Action Plan is a component of the Five -Year Consolidated Plan filed with HUD. Page 325 of 1313 On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 for the HOME Investment Partnerships Program ("HOME -ARP") into law, which provides funding to address the continued impact of the COVID-19 pandemic on the economy, public health, State and local governments, individuals, and businesses. On September 22, 2021, the local HUD field office notified the City of its HOME -ARP allocation of $2,245,387. The funds must be expended by September 30, 2030 on eligible activities to address the need for homelessness and supportive services, as described in the One -Year Action Plan for FY 21. The disbursement of funds is contingent upon the City's submission of the HOME -ARP allocation plan and part of the amended One -Year Action Plan for FY 21 and the execution of the HOME - ARP grant agreement. The City advertised a Notice of a 30 -day public comment period (November 8, 2021 — December 8, 2021) with,a public hearing on November 16, 2021, for the substantial amendment to the One -Year Action Plan for FY 21 including the HOME -ARP funds. HOME -ARP funds must be used to primarily benefit qualifying populations through four eligible activities: (1) development and support of affordable housing; (2) tenant -based rental assistance (TBRA); (3) provision of supportive services; and (4) acquisition and development of non - congregate shelter units. The HOME -ARP allocation plan must describe how the City intends to distribute HOME -ARP funds, including how it will use these funds to address the needs of qualifying populations as determined in the consultation process, a community needs assessment, and the gap analysis of current housing and shelter inventory. ANALYSIS The City conducted a consultation process with various providers within the Miami -Dade County Homeless Continuum of Care Program, designed to assist individuals (including unaccompanied youth) and families experiencing homelessness and to provide the services needed to help such individuals move into transitional and permanent housing, with the goal of long-term stability. The City's main goal of the consultation process was to obtain information on the current service gaps and needs for the qualifying populations defined in HOME -ARP guidelines. Exhibit A demonstrates the data gathered during the consultation process and the needs analysis. Based on the information obtained, the City formulated a proposal for funding activities. Below is a summary of the proposed Allocation Plan: HOME -ARP Allocation Plan Recommendations Program Administration $336,808.05 15% Rental Housing (acquisition, construction' $1,400,000 62% and rehabilitation) Supportive Services $396,309.60 18% Non -Profit $112,269.35 5% Capacity Building TOTAL $2,245,387.00 100% HOME -ARP funds allow Participating Jurisdictions to allocate fifteen (15) percent of the award amount to planning and administration. Up to five (5) percent of funds can be allocated to non- profit capacity building. Page 326 of 1313 The Administration will issue a Request for Proposals on January 24, 2022, to obtain applications from qualified providers interested in providing services aligned with the HOME - ARP Allocation Plan. SUPPORTING SURVEY DATA Not applicable. CONCLUSION The Administration recommends approval of a substantial amendment to the One -Year Action Plan for FY21/22 and the approval of the HOME -ARP Allocation Plan. Applicable Area Not Applicable Is this a "Residents Right Does this item utilize G.O. to Know" item, pursuant to Bond Funds? City Code Section 2-14? No No Strategic Connection Mobility - Support affordable, compatible workforce housing. Legislative Tracking Housing and Community Services ATTACHMENTS: Description ❑ Resolution ❑ Exhibit A- HOME ARPAIIocation Plan Page 327 of 1313 HOME -ARP Allocation Plan Template Guidance • To receive its HOME -ARP allocation, a PJ must: o Engage in consultation with at least the required organizations; o Provide for public participation including a 15 -day public comment period and one public hearing, at a minimum; and, o Develop a plan that meets the requirements in the HOME -ARP Notice. • To submit: a PJ must upload a Microsoft Word or PDF version of the plan in IDIS as an attachment next to the "HOME -ARP allocation plan" option on either the AD -26 screen (for PJs whose FY 2021 annual action plan is a Year 2-5 annual action plan) or the AD -25 screen (for PJs whose FY 2021 annual action plan is a Year 1 annual action plan that is part of the 2021 consolidated plan). • PJs must also submit an SF -424, SF -424B, and SF -424D, and the following certifications as an attachment on either the AD -26 or AD -25 screen, as applicable: o Affirmatively Further Fair Housing; o Uniform Relocation Assistance and Real Property Acquisition Policies Act and Anti -displacement and Relocation Assistance Plan; o Anti -Lobbying; o Authority of Jurisdiction; o Section 3; and, o HOME -ARP specific certification. Participating Jurisdiction: City of Miami Beach Date: Click to enter a date. Consultation Before developing its plan, a PJ must consult with the CoC(s) serving the jurisdiction's geographic area, homeless and domestic violence service providers, veterans' groups, public housing agencies (PHAs), public agencies that address the needs of the qualifying populations, and public or private organizations that address fair housing, civil rights, and the needs of persons with disabilities, at a minimum. State PJs are not required to consult with every PHA or CoC within the state's boundaries; however, local PJs must consult with all PHAs (including statewide or regional PHAs) and CoCs serving the jurisdiction. Summarize the consultation process: The City held various meetings with service providers in the Continuum of Care, to determine the current service needs in the community and the approximate funding required. The City also held a meeting with the Housing Authority of the City of Miami Beach to discuss the service gaps in voucher programs and subsidized housing programs. Page 330 of 1313 List the organizations consulted, and summarize the feedback received from these entities. Agency/Org Type: of Consulted Agency/Org Method of-,-..,. Consultation 'Feedback Homeless Trust ; Continuum of Virtual Meeting The Homeless Trust informed the Care City of their pending housing projects Legal Services of Legal Services Virtual Meeting for qualif_ying populations. i Legal Services of Greater Miami Greater Miami I provided a proposal for supportive services to address the service gaps for households at -risk of } homelessness. I j Miami Beach j Non-profit Virtual Meeting Miami Beach Community Community housing Development Corporation provided a j Development provider Corporation request for funding to preserve the agency's capacity as a housing —TDomestic provider. Lotus House Virtual Meeting ; The Lotus House expressed interest j Shelter Violence I in submitting a proposal for funds. Provider The organization provided information on the need for services for the population served by their eriNy' — — — -- Housing Public Housing Virtual Meeting I The organization is interested in Authority of Authority submitting an application for City of Miami I acquisition and rehabilitation of Beach housing for low-income residents. A needs analysis was also provided to I explain the current funding gaps. I Agency Name. �` Type of I Agency/Org. Method of Consultation. Feedback. j Agency Name. of Method of Feedback. Agency/Org. Agency Name. Type ' Consultation. Method Feedback. of Agency/Org. of Consultation. If additional space is needed, insert image of table here: Public Participation Page 331 of 1313 PJs must provide for and encourage citizen participation in the development of the HOME -ARP allocation plan. Before submission of the plan, PJs must provide residents with reasonable notice and an opportunity to comment on the proposed HOME -ARP allocation plan of no less than 15 calendar days. The PJ must follow its adopted requirements for "reasonable notice and an opportunity to comment" for plan amendments in its current citizen participation plan. In addition, PJs must hold at least one public hearing during the development of the HOME -ARP allocation plan and prior to submission. For the purposes of HOME -ARP, PJs are required to make the following information available to the public: • The amount of HOME -ARP the PJ will receive, • The range of activities the PJ may undertake. Describe the public participation process, including information about and the dates of the public comment period and public hearings) held during the development of the plan: • Public comment period: start date -11/812021 end date — 12/8120 21 • Public hearing: 11/16/2021 The City did not receive public comments regarding the allocation of HOME -ARP funds. Describe any efforts to -broaden public participation: The public hearing was held on November 16 during the Affordable Housing Advisory Committee meeting, which is advertised by the Office of the City Clerk. The public hearing was also advertised in the Miami Herald and the City's website. A PJ must consider any comments or views of residents received in writing, or orally at a public hearing, when preparing the HOME -ARP allocation plan. Summarize the comments and recommendations received through the public participation process: The City did not receive comments or recommendations throughout the public participation process. Summarize any comments or recommendations not accepted and state the reasons why: Not applicable. Needs Assessment and Gaps Analysis PJs must evaluate the size and demographic composition of qualifying populations within its boundaries and assess the unmet needs of those populations. In addition, a PJ must identify any gaps within its current shelter and housing inventory as well as the service delivery system. A PJ should use current data, including point in time count, housing inventory count, or other data 3 Page 332 of 1313 available through CoCs, and consultations with service providers to quantify the individuals and families in the qualifying populations and their need for additional housing, shelter, or services. The PJ may use the optional tables provided below and/or attach additional data tables to this template. 4 Page 333 of 1313 OPTIONAL Homeless Needs Inventory and Gap Analysis Table Suggested Data Sources: 1. Point in Time Count (PIT); 2. Continuum of Care Housing Inventory Count (HIC); 3. Consultation Suggested Data Sources: 1. American Community Survey (ACS); 2. Comprehensive Housing Affordability Strategy (CHAS) 5 Page 334 of 1313 Homeless Current IOveutory Homeless Population Gap Analysis` Family Adults Only vets Family Adult Family Adults Only HH (at HH victims # of # of. # of. #.of; # of•. least, (w/o' vetsof D,# of # of. # of , # of . Beds Units Beds Units Bedschild child Beds Units Beds Units Emergency 47 # 47 # # Shelter 0 # 22 # # Transitional Housing Permanent Supportive 0 # 48 # # Housing Other Permanent Housin # # # # Sheltered Homeless # # # # Unsheltered Homeless # 183 # # Current Gap # # # # Suggested Data Sources: 1. Point in Time Count (PIT); 2. Continuum of Care Housing Inventory Count (HIC); 3. Consultation Suggested Data Sources: 1. American Community Survey (ACS); 2. Comprehensive Housing Affordability Strategy (CHAS) 5 Page 334 of 1313 Describe the size and demographic composition of qualifying populations within the PJ's boundaries: The City's overall population is 90,108. According to the Shimberg Center for Housing Studies, 9.5% of the population are renters that are severely cost -burdened. The City's overall vision of providing neighborhoods with affordable, safe and decent housing continues to be the long-term goal that requires a diverse collaboration with local CHDOs, community partners, foundations and others. Barriers that continue to inhibit our ability to complete our long-term goals include: • Limited funding and the high cost of real estate values in the City of Miami Beach; • The average sales price for a single-family home was $3,769,336 in 2020. The median sales price that year was $1,769,250, compared to a median sales price of $402,000 in Miami -Dade County (Produced by Florida REALTORS® with data provided by Florida's multiple listing services). The median sales price for condominiums in 2020 was $329,000, compared to $264,000 in Miami -Dade County (Produced by Florida REALTORS® with data provided by Florida's multiple listing services.); • Limited long-term, community-based residential options with supportive services for those who need help with daily living activities, housekeeping, self-care, social services and other assistance; • An absence of community development partners and CHDOs with the capacity to develop affordable housing in the City within defined timeframes; • Inability of program recipients to acquire gap funding from additional financial sources for construction and rehabilitation projects; and • Limited number of properties with multiple bedrooms to serve larger families. Based on the limitations listed above, the access to affordable units continues to become increasingly challenging. Describe the unmet housing and service needs of qualifying populations, including but not limited to: • Sheltered and unsheltered homeless populations; • Those currently housed populations at risk of homelessness; • Other families requiring services or housing assistance or to prevent homelessness; and, • Those at greatest risk of housing instability or in unstable housing situations: The City has calculated that renter 6,333 households are cost -burdened and at -risk of homelessness. In 2020 and 2021, there was a considerable loss of affordable units throughout the City, forcing residents to relocate outside of City limits. There are an estimated 3,073 Housing Choice Vouchers available throughout the City, however, only 2,566 are being utilized. Voucher P. Page 335 of 1313 recipients are experiencing great difficulties locating units within the voucher's price range and are forced to look outside of city limits. The 2021 Miami -Dade County Community Homeless Plan, prioritizes Seniors and persons identified by the CDC at high risk of death during a pandemic for permanent housing, in addition to persons fleeing domestic violence; human and sex trafficking; youth, families and veterans. Identify and consider the current resources available to assist qualifying populations, including congregate and non -congregate shelter units, supportive services, TBRA, and affordable and permanent supportive rental housing: Currently, the City provides funding for the following service activities: Congregate Shelter Units: 47 beds contracted through various shelter providers Supportive Services: CDBG currently funds public services for elderly and households at -risk of homelessness TBRA: CDBG and General funds for a maximum six months for rent/mortgage and utility assistance Affordable and Permanent Supportive Rental Housing: FY 21 HOME and CDBG funds have been allocated to affordable housing capital projects and homeowner assistance. Identify any gaps within the current shelter and housing inventory as well as the service delivery system: Currently, there is only one zero -bedroom apartment available for fair market rent. The City is continuously trying to assess resources to fund the rehabilitation or development of affordable housing. Identify the characteristics of housing associated with instability and an increased risk of homelessness if the PJ will include such conditions in its definition of "other populations" as established in the HOME ARP Notice: The following characteristics of housing associated with instability, as defined in Section W.A.4.2A.G. of the Notice, will be utilized when assisting "other populations": (ii)has annual income that is less than or equal to 50% of the area median income, as determined by HUD, AND meets one of the following conditions from paragraph (iii) of the "At risk of homelessness" definition established at 24 CFR 91.5: (A)Has moved because of economic reasons two or more times during the 60 days immediately preceding the application for homelessness prevention assistance; (B) Is living in the home of another because of economic hardship; (C) Has been notified in writing that their right to occupy their current housing or living situation will be terminated within 21 days after the date of application for assistance. Identify priority needs for qualifying populations: Elderly and disabled. Page 336 of 1313 Explain how the level of need and gaps in its shelter and housing inventory and service delivery systems based on the data presented in the plan were determined: Various service agencies within the Continuum of Care provided data. HOME -ARP Activities Describe the method for soliciting applications for funding and/or selecting developers, service providers, subrecipients and/or contractors and whether the PJ will administer eligible activities directly: The City will be issuing a Request for Proposal on January 24, 2022 to receive solicitations from providers. If any portion of the PJ's HOME -ARP administrative funds were provided to a subrecipient or contractor prior to HUD's acceptance of the HOME ARP allocation plan because the subrecipient or contractor is responsible for the administration of the PJ's entire HOME ARP grant, identify the subrecipient or contractor and describe its role and responsibilities in administering all of the PJ's HOME ARP program: Not applicable. PJs must indicate the amount of HOME -ARP funding that is planned for each eligible HOME - ARP activity type and demonstrate that any planned funding for nonprofit organization operating assistance, nonprofit capacity building, and administrative costs is within HOME -ARP limits. The following table may be used to meet this requirement. Use of HOME -ARP Funding Additional narrative, if applicable: Enter narrative response here. Page 337 of 1313 Funding Amount percent of the Statutory Grant Limit Supportive Services $ 396,309.60 Acquisition and Development of Non- $ 0 Congregate Shelters Tenant Based Rental Assistance (TBRA) $ 0 Development of Affordable Rental Housing $ 1,400,000 Non -Profit Operating $ 0 # % 5% Non -Profit Capacity Building $ 112,269.35 5% 5% Administration and Planning 1 $ 336,808.05 15% 15% Total HOME ARP Allocation $ 2,245,387.00 Additional narrative, if applicable: Enter narrative response here. Page 337 of 1313 Describe how the characteristics of the shelter and housing inventory, service delivery system, and the needs identified in the gap analysis provided a rationale for the plan to fund eligible activities: Although the development of affordable rental housing is the greatest need in the community, the City also recognizes that service providers are struggling with capacity building and service delivery to qualifying populations. Therefore, the City is proposing the allocation mentioned above to supportive services and non-profit capacity building. The service categories will be finalized once the City reviews all solicitations and proposals to determine the most viable methods of expending funds. HOME -ARP Production Housing Goals Estimate the number of affordable rental housing units for qualifying populations that the PJ will produce or support with its HOME ARP allocation: The City estimates that 20 affordable housing units will be acquired and/or preserved. Describe the specific affordable rental housing production goal that the PJ hopes to achieve and describe how it will address the PJ's priority needs: The City hopes to continue allocate all available resources to the creation, retention and development of affordable housing for qualifying populations. Preferences Identify whether the PJ intends to give preference to one or more qualifying populations or a subpopulation within one or more qualifying populations for any eligible activity or project: • Preferences cannot violate any applicable fair housing, civil rights, and nondiscrimination requirements, including but not limited to those requirements listed in 24 CFR 5.105(a). • PJs are not required to describe specific projects to which the preferences will apply. The City will not give preference to a specific qualifying population. If a preference was identified, explain how the use of a preference or method of prioritization will address the unmet need or gap in benefits and services received by individuals and families in the qualifying population or category of qualifying population, consistent with the PJ's needs assessment and gap analysis: Not applicable. If a preference was identified, describe how the PJ will use HOME ARP funds to address the unmet needs or gaps in benefits and services of the other qualifying populations that are not included in the preference: Not applicable. 0 Page 338 of 1313 HOME -ARP Refinancing Guidelines If the PJ intends to use HOME -ARP funds to refinance existing debt secured by multifamily rental housing that is being rehabilitated with HOME -ARP funds, the PJ must state its HOME - ARP refinancing guidelines in accordance with 24 CFR 92.206(b). The guidelines must describe the conditions under with the PJ will refinance existing debt for a HOME -ARP rental project, including: • Establish a minimum level of rehabilitation per unit or a required ratio between rehabilitation and refinancing to demonstrate that rehabilitation of HOME ARP rental housing is the primary eligible activity The City does not plan to use HOME -ARP funds to refinance existing debt. • Require a review of management practices to demonstrate that disinvestment in the property has not occurred, that the long-term needs of the project can be met; and that the feasibility of serving qualified populations for the minimum compliance period can be demonstrated Not Applicable. • State whether the new investment is being made to maintain current affordable units, create additional affordable units, or both. The City seeks proposals to acquire, construct or rehabilitate existing affordable housing units. • Specify the required compliance period, whether it is the minimum 15 years or longer. The required compliance period will be 30 years for rental housing. • State that HOMEARP funds cannot be used to refinance multifamily loans made or insured by any federal program, including CDBG. HOME -ARP funds cannot be used to refinance multifamily loans. This has been stipulated in the Program Policies and Procedures. • Other requirements in the PJ's guidelines, if applicable: Enter narrative response here. 10 Page 339 of 1313