Loading...
HomeMy WebLinkAbout06/15/2021 07 Public input meeting to consider citizen comments on the proposed Draft 2021 Annual Action Plan for Community Development Block Grant (CDBG), HOME Fund Programs, and Cares Act CDBG-CV3 funds 1 ti i..asxntntj kd d g$Ag aY ae.. x°'naa.x,,4n BUSINESS OF THE CITY COUNCIL YAKIMA, WASHINGTON AGENDA STATEMENT Item No. 7. For Meeting of: June 15, 2021 ITEM TITLE: Public input meeting to consider citizen comments on the proposed Draft 2021 Annual Action Plan for Community Development Block Grant(CDBG), HOME Fund Programs, and Cares Act C D B G- CV3 funds SUBMITTED BY: Joan Davenport,AI CP, Community Development Director Archie Matthews, O N DS Manager(509) 576-6761 SUMMARY EXPLANATION: Every year the City of Yakima is required by the Federal Housing and Urban Development Department (HUD)to provide an Annual Action Plan that outlines the City of Yakima's Budget plans for using Community Development Block Grant (CDBG) entitlements funds, HOME Investment funds and Cares Act CDBG-CV3 funds to meet the needs of it's low to moderate income citizens with "eligible activities". The CDBG program has three primary objectives; to benefit low and moderate income persons, to assist with problems relating to slum and blight, and to assist with urgent health and welfare needs. The program can thus provide assistance in a broad range of activities and services, but at least 70% of all funds must be spent on assisting people with issues related to low income. The HOME program can only assist low/moderate income person with issues relating to housing; which can range from new construction of single family to rental housing and down payment assistance for first time homebuyers. The Cares Act CDBG-CV3 funds must be utilized to prepare, prevent and respond to the Covid 19 pandemic and must follow the same eligible activity criteria as the CDBG program. In keeping with HUD regulations, the City of Yakima must allow a thirty day written comment period and two public hearings in order to give the citizens of Yakima an opportunity to comment and provide input on the proposed 2021 Annual Action Plan "DRAFT". This is the first of two public input meetings and within the thirty day written comment period that began May 31, 2021. The proposed 2021 Annual Action Plan DRAFT is available at the Office of Neighborhood Development Services, City Clerk's Office and on the City of Yakima website 2 at: www.yakimawa.gov/services/neighborhood-development-services/ ITEM BUDGETED: NA STRATEGIC PRIORITY: Neighborhood and Community Building APPROVED FOR SUBMITTAL BY THE CITY MANAGER RECOMMENDATION: ATTACHMENTS: Description Upload Date Type 0 DRAFT 2021 Annual Action Ran &'3/2021 Backup Material 3 City of Yakima Office of Neighborhood Development Services Community Development Block Grant HOME Investment Partnership 1)RAFT 2021 Annual Action Plan w •• • is x ti •• w. . Yu; "` pu 't•:ikta .y eta' •...'i ,5k. vxa ...X'ttt***a' •••:'. n v.:'..t ••y. 4 Executive Summary AP-05 Executive Summary - 24 CFR 91.200(c), 91.220(b) 1. Introduction As the annual recipient of federal Community Development Block Grant (CDBG), HOME Investment Partnership(HOME) funds, and CDBG-CV funds to prepare, prevent and respond to the Covid 19 pandemic.The City of Yakima is required to engage in a careful planning process. This process involves a long-term five-year strategy,which is detailed in a document called the Consolidated Plan, and a subset of this document known as the Annual Action Plan. Each Action plan specifies the things the City will do during the coming year to implement those steps it feels will lead to the accomplishment of the goals set forth in the Consolidated Plan. A key component of serving the needs of local residents is to meet with them,and listen to them as they express their thoughts. ONDS follows a Yakima City Council adopted "Citizen Participation Plan" as approved by HUD. This plan dictates how the Office of Neighborhood Development Services conducts citizen participation input meetings for both the Consolidated Plan and the Annual Action Plan. Information is collected from City residents and others in a variety of ways.There are regular surveys conducted of local citizens to ask about their needs and challenges. Meetings are held to provide the opportunity for people to speak. And as required by HUD City staff meet with other providers of services for low-income persons to hear about the things they feel are important. By the time the 2021 Action Plan is completed, City staff will have met with local residents on at least two occasions to share information on the possible activities and hear their ideas as is outlined in the HUD mandated "Citizen Participation Plan" as well as held a "Thirty Day Written Comment Period" on the proposed 2021 Annual Action Plan draft. This document is the 2021 Annual Action Plan for the City of Yakima's 2020-2024 Consolidated Plan. The format and content of the document is largely dictated by the US Department of Housing and Urban Development(HUD) regulations. These regulations provide a framework that helps ensure that each dollar invested meets local priorities and complies with Federal law. Congress implemented the CDBG program in order to provide assistance to communities such as Yakima as they work to provide various forms of assistance to low and moderate-income individuals and families. According to law,the CDBG program has three primary objectives; to benefit low and moderate income persons, to assist with problems relating to slum and blight, and to assist with urgent health and welfare needs. The HOME program is of more recent origin. It can only assist low/moderate income persons with issues relating to housing. These services can range from new construction of single family or rental housing and down payment assistance to assistance with rents. While lacking the flexibility of the Block Grant Annual Action Plan 1 2021 OMB Control No:2506-0117(exp.09/30/2021) 5 program, the HOME program has provided valuable services to hundreds of families here in Yakima. By combining both programs under on strategy, the City of Yakima has provided a broad-spectrum approach to helping the many local residents these programs serve. The CDBG-CV program is emergency funding that can only assist to prepare, prevent and respond to the Covid 19 pandemic.This funding follows the same program guidelines as the CDBG program. 2. Summarize the objectives and outcomes identified in the Plan This could be a restatement of items or a table listed elsewhere in the plan or a reference to another location. It may also contain any essential items from the housing and homeless needs assessment, the housing market analysis or the strategic plan. This information is contained in the "AP-38 Project Summary contained within this 2021 Annual Action Plan. 3. Evaluation of past performance This is an evaluation of past performance that helped lead the grantee to choose its goals or projects. The 2021 Annual Action Plan will be the second of 2020-2024 Consolidated Plan. The Annual Action Plans will report progress on addressing priority housing and non-housing community development needs each year from 2020-2024 as Yakima ONDS has annually reported progress for previous 2015- 2019 Consolidated Plan. A detailed breakdown report of prior year uses and performances has also been provided in the yearly Consolidated Annual Performance & Evaluation Report(CAPER) which is available at the City of Yakima's Office of Neighborhood Development Office or online at Yakima's webpage https://www.yakimawa.gov/services/neighborhood-development-services/) 4. Summary of Citizen Participation Process and consultation process Annual Action Plan 2 2021 OMB Control No:2506-0117(exp.09/30/2021) 6 Summary from citizen participation section of plan. As required by the adopted City of Yakima's Citizen Participation Plan; A thirty day written comment period will be observed with addition of any written comments received during that period being added within the Annual Action Plan as submitted to HUD. Two Public Hearings will be held at the Yakima City Council Chambers as advertised. 5. Summary of public comments This could be a brief narrative summary or reference an attached document from the Citizen Participation section of the Con Plan. To Be Determined. 6. Summary of comments or views not accepted and the reasons for not accepting them To Be Determined. 7. Summary To Be Determined. Annual Action Plan 3 2021 OMB Control No:2506-0117(exp.09/30/2021) PR-05 Lead & Responsible Agencies —91.200(b) 1. Agency/entity responsible for preparing/administering the Consolidated Plan Describe the agency/entity responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source. Agency Role Name Department/Agency CDBG Administrator YAKIMA Office of Neighborhood Development Services HOME Administrator YAKIMA Office of Neighborhood Development Services Table 1—Responsible Agencies Narrative (optional) The City of Yakima's Office of Neighborhood Development Services (ONDS) is the lead agency for preparing Yakima's Consolidated Plan and Annual Action Plans, and has been designated to be responsible for the planning,development,and implementation of its CDBG, HOME and CDBG-CV programs by the Yakima City Council. Consolidated Plan Public Contact Information Annual Action Plan 4 2021 OMB Control No:2506-0117(exp.09/30/2021) 8 AP-10 Consultation —91.100, 91.200(b), 91.215(1) 1. Introduction Consultation for the Consolidated Plan includes the use of consultants generating statistical information needed to establish needs,gaps and barriers. ONDS consults with public and private agencies and citizens, including a Housing Advisory Committee composed of the Yakima Housing Authority,Catholic Charities, as well as Yakima County,this is also known as the Community Development Advisory Board providing review and feedback. Provide a concise summary of the jurisdiction's activities to enhance coordination between public and assisted housing providers and private and governmental health, mental health and service agencies (91.215(I)) ONDS consults with public and private agencies that provide assisted housing, health services, and social and fair housing services-especially those focusing on services to children,the elderly, persons with disabilities, persons with HIV/AIDS and their families, and homeless persons through Neighborhood Health. ONDS also consults with Washington State Department of Commerce (CED) &Yakima Housing Authority (YHA) to assure that the Yakima Consolidated Plan is inclusive and addresses statutory purposes. Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans, and unaccompanied youth)and persons at risk of homelessness. The Yakima Valley Council of Governments (YVCOG) is the coordinator of the Yakima County Continuum of Care. The Yakima Valley Council of Governments is composed of a broad group of Yakima County public, non-profit,and private human services agencies including many of the groups listed above. YVCOG conducts regular meetings and agendas, updated the Yakima County Continuum of Care Plan,and organized the annual Point-In Time Homeless Persons Count.The City of Yakima continues to coordinate and assist YVCOG with its efforts to assist persons at risk of homelessness and chronically homeless individuals and family. The City of Yakima works with YVCOG to strategize, plan and assist with Emergency Winter Shelters for the Homeless on a year by year basis, in order to ensure safe, decent, emergency winter shelters that are both suitable for the homeless but also suitable for the residents and businesses within those neighborhoods. Annual Action Plan 5 2021 OMB Control No:2506-0117(exp.09/30/2021) 9 Describe consultation with the Continuum(s) of Care that serves the jurisdiction's area in determining how to allocate ESG funds, develop performance standards for and evaluate outcomes of projects and activities assisted by ESG funds, and develop funding, policies and procedures for the operation and administration of HMIS The City of Yakima has consulted with Yakima Valley Council of Governments (YVCOG) and other Continuum of Care providers through joint affordable housing committee meetings, through email as well as reviewing individual service provider websites.Yakima Valley Council of Governments (YVCOG) hold scheduled meetings as well as request input from agencies as well as citizens on a regular basis.The City of Yakima works in partnership with YVCOG throughout the Strategic Planning process for both Yakima County and the City of Yakima to develop program performance standards and evaluate and adjust outcomes and develop funding, policies and procedures for a wide variety of programs and funding, including the administration of the HMIS. 2. Describe Agencies, groups, organizations and others who participated in the process and describe the jurisdiction's consultations with housing, social service agencies and other entities Annual Action Plan 6 2021 OMB Control No:2506-0117(exp.09/30/2021) Table 2—Agencies,groups,organizations who participated 1 Agency/Group/Organization Catholic Charities Housing Services Agency/Group/Organization Type Housing Services- Housing Services-Children Services-Elderly Persons Services-Persons with Disabilities Service-Fair Housing What section of the Plan was addressed by Housing Need Assessment Consultation? Public Housing Needs Homeless Needs-Chronically homeless Homeless Needs- Families with children Homelessness Needs- Veterans Homelessness Needs- Unaccompanied youth Homelessness Strategy Non-Homeless Special Needs Market Analysis Anti-poverty Strategy Briefly describe how the Agency/Group/Organization ONDS conducted meetings of the Community Development Advisory Board was consulted.What are the anticipated outcomes of providing review and feedback of which Catholic Charities Housing Services the consultation or areas for improved coordination? (CCHS) was an integral part of. As in the past CCHS has assisted ONDS with developing housing market strategies as well as developing affordable housing projects within the City of Yakima for First Time Homebuyers,as well as affordable housing opportunities for low to moderate income Elderly and disabled. Annual Action Plan 7 2021 OMB Control No:2506-0117(exp.09/30/2021) 2 Agency/Group/Organization Yakima County Department of Human Services Agency/Group/Organization Type Housing Services- Housing Services-Children Services-Elderly Persons Services-Persons with Disabilities Services-Victims of Domestic Violence Services-homeless Services-Employment Service-Fair Housing Services-Victims Other government-County What section of the Plan was addressed by Housing Need Assessment Consultation? Public Housing Needs Homeless Needs-Chronically homeless Homeless Needs- Families with children Homelessness Needs- Veterans Homelessness Needs- Unaccompanied youth Homelessness Strategy Non-Homeless Special Needs Market Analysis Anti-poverty Strategy Lead-based Paint Strategy Briefly describe how the Agency/Group/Organization Meetings with the Yakima County in consultation about affordable housing and was consulted.What are the anticipated outcomes of homelessness issues within the City of Yakima. Continued coordination in the consultation or areas for improved coordination? developing and maintaining affordable housing as well as continued cooperation in dealing with the Yakima Valley Council of Governments. Annual Action Plan 8 2021 OMB Control No:2506-0117(exp.09/30/2021) 3 Agency/Group/Organization Yakima Housing Authority Agency/Group/Organization Type Housing PHA Services- Housing Publicly Funded Institution/System of Care What section of the Plan was addressed by Housing Need Assessment Consultation? Public Housing Needs Homeless Needs-Chronically homeless Homeless Needs- Families with children Homelessness Needs- Veterans Homelessness Needs- Unaccompanied youth Homelessness Strategy Market Analysis Anti-poverty Strategy Briefly describe how the Agency/Group/Organization The Director towel Krueger is a member of the Community Development was consulted.What are the anticipated outcomes of Advisory Board and attended meetings as well as consulted via telephone and the consultation or areas for improved coordination? email. The City of Yakima continues to work closely with the Yakima Housing Authority to develop and maintain affordable housing. Identify any Agency Types not consulted and provide rationale for not consulting No specific Agency was intentionally excluded from the consultation process as a 30 day written comment period will advertise and open to any citizen or agency to give additional written comment, plus two advertised Public Hearings to give ample opportunity for input from individuals, groups, departments and/or agencies. Annual Action Plan 9 2021 OMB Control No:2506-0117(exp.09/30/2021) Other local/regional/state/federal planning efforts considered when preparing the Plan Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? Yakima County The City of Yakima works hand in hand with YVCOG in assisting the local community with a Continuum of Care Council of variety of programs and goals, such as affordable housing,Yakima County Economic Government Development and Assisting the Homeless The Urban Area Comprehensive Plan (UACP) was developed in accordance with the Growth Management Act(GMA) to address growth issues in the City of Yakima and adjacent Urban City of Yakima Growth Area. It represents the community's policy plan for growth over the next 20 years. It will Yakima Urban Area Planning assist the management of the City by providing policies to guide decision-making for growth, Comprehensive Plan Department development and public services. Cities are required to update their plans every ten years.The original Yakima GMA Plan was adopted in 1997 and Planned through the year 2015 and has been updated and will carry the community forward through 2025 Table 3—Other local/regional/federal planning efforts Narrative (optional) Annual Action Plan 10 2021 OMB Control No:2506-0117(exp.09/30/2021) AP-12 Participation —91.105, 91.200(c) 1. Summary of citizen participation process/Efforts made to broaden citizen participation Summarize citizen participation process and how it impacted goal-setting To be determined after the mandatory public notices,a thirty day written comment period and two public hearings Citizen Participation Outreach Sort Order Mode of Outreach Target of Outreach Summary of Summary of Summary of comments URL(If response/attendance comments received not accepted applicable) and reasons Table 4—Citizen Participation Outreach Annual Action Plan 11 2021 OMB Control No:2506-0117(exp.09/30/2021) Expected Resources AP-15 Expected Resources —91.220(c)(1,2) Introduction After ten years of slow steady entitlement reduction the City of Yakima received an increase in 2021 from the preceding year of an additional $15,293.00 in CDBG for a total of$1,039,004.00 and a reduction of$4,042.00 in HOME Investment dollars for a total of$503,424.00. Additionally, due to the Covid 19 pandemic the City of Yakima received CDBG-CV3 funds in the amount of$618,993.00 that will be used to prepare, prevent and or respond to the Covid 19 pandemic. Despite the reductions of years past at the federal funding level and the recent increase,the City of Yakima is continually challenged to continue programs with the fluctuation of funding, in order to continue to serve it's low to moderate income citizens to the best of its ability. Furthermore,any decision to change CDBG funding greater than 10% increase or decrease in any program funding line after the public comment period received by the City of Yakima ONDS will trigger an amendment as per the adopted citizen participation plan. Although any increase or decrease in funding directly attributed to the Federal Allocation will be added or subtracted to the largest funded program as currently funded through those federal entitlement allocations. (CDBG would be either added or subtracted from the Single Family Rehabilitation program and HOME funds would be added or subtracted from the New Construction program line. Any addition or subtraction to or from either of these program lines equaling more than 10%would trigger a substantial amendment to the Annual Action plan per the currently adopted Citizen Annual Action Plan 12 2021 OMB Control No:2506-0117(exp.09/30/2021) Participation Plan.) Anticipated Resources Program Source of Uses of Funds Expected Amount Available Year 1 Expected Narrative Description Funds Annual Program Prior Year Total: Amount Allocation: Income:$ Resources: $ Available $ $ Remainder of ConPlan CDBG public- Acquisition federal Admin and Planning Economic Development Housing Public Improvements Public Services 1,039,004 21,368 1,145,974 2,206,346 595,974 HOME public- Acquisition federal Homebuyer assistance Homeowner rehab Multifamily rental new construction Multifamily rental rehab New construction for ownership TBRA 503,424 58,322 1,849,878 2,411,624 326,280 Annual Action Plan 13 2021 OMB Control No:2506-0117(exp.09/30/2021) Program Source of Uses of Funds Expected Amount Available Year 1 Expected Narrative Description Funds Annual Program Prior Year Total: Amount Allocation: Income:$ Resources: $ Available $ $ Remainder of ConPlan Other public- Admin and Planning CDBB-CV Funds will be used federal Economic for Public Services and Public Development Facilities Public Services Other 618,993 0 0 618,993 0 Table 5-Expected Resources—Priority Table Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied CDBG funds are leveraged with partnerships with non-profits such as OIC of Washington in the continued operation of the Henry Beauchamp Center (formerly known as the South East Community Center) to provide community service programs to low and moderate income citizens. HOME Investment funds are leveraged by assisting housing investment partners within our community through developers, to construct single family homes to be sold to qualified low to moderate income homebuyers and/or the construction of affordable housing units through multi- family housing to be rented to qualified low to moderate income tenants. The city uses these funds as local participation funding to assist with gap financing and in assisting affordable housing developers through the application process of the Washington State Housing Trust fund as well as the application process in securing affordable housing tax credits for each development. Match requirements are set by HUD, imposed upon the City of Yakima which are met on an annual basis. Depending upon the Match requirements imposed,the City of Yakima has an accumulated "Match amount" that has been banked through the years through the use of volunteers and local non-federal funds. Thus,depending upon Match requirement,the City will draw upon that match reserve to fulfill any match requirements HUD sets. In years past the City of Yakima has been 100% match exempt to 25% match contribution as set by HUD,thus allowing the city to build up a match reserve account. Annual Action Plan 14 2021 OMB Control No:2506-0117(exp.09/30/2021) 18 If appropriate, describe publically owned land or property located within the jurisdiction that may be used to address the needs identified in the plan Currently there is no publically owned land or property under consideration for use that isn't already addressed in other parts of the plan. Discussion The City of Yakima has been notified of actual "FY 2021 Allocations" which have been inputted within this draft document as per HUD's notification. Annual Action Plan 15 2021 OMB Control No:2506-0117(exp.09/30/2021) Annual Goals and Objectives AP-20 Annual Goals and Objectives Goals Summary Information Sort Order Goal Name Start End Category Geographic Needs Funding Goal Outcome Indicator Year Year Area Addressed Table 6—Goals Summary Goal Descriptions Annual Action Plan 16 2021 OMB Control No:2506-0117(exp.09/30/2021) 20 Projects AP-35 Projects —91.220(d) Introduction The City of Yakima does its best to allocate funding for eligible activities, meeting national objectives through individual programs to assist the citizens of Yakima with specific projects to meet a wide variety of needs. Many of the specific locations are to be determined throughout the year as need arises through the Senior/Disabled Emergency Home Repair program. Also, in partnership with many HOME Investment projects the specific addresses are unavailable until the design and layout of the site has gone through the planning and zoning process prior to site preparation. Many of the HOME Investment projects take years of development through many types of funding grant rounds to include state and local funding, environmental reviews, planning and zoning reviews before a specific address can be allocated. Also, be aware that many of the program numbers served are listed here as an "Approximate number" due to the ever changing nature of many of the development criteria as listed above. These numbers are subject to change depending upon the need,cost associated with the development as it goes through the many reviews, as well as the subject of the development and construction costs that can rise due to inflation over a long development and construction period. Projects Project Name 1 P4: CDBG:SEN/DISABLED S/F REHAB PROG-2021 2 P9: CDBG PUBLIC/COMMUNITY SERVICE PROG-2021 3 P10: CDBG ADMINISTRATION 2021 4 P13:HOME ADMINISTATION 2021 5 P14: CHDO PROGRAM 2021 6 P18: HOME: NEW/REHABILITATED HOME UNITS IN 2021 7 P19: FIRST TIME HOMEOWNER ASSISTANCE PROG-2021 8 P20: CDBG-CV INFRASTRUCTURE/PUBLIC FACILITIES 2021 9 P24: CDBG: CODE COMPLIANCE 2021 10 CDBG-CV3 Admin Table 7-Project Information Annual Action Plan 17 2021 OMB Control No:2506-0117(exp.09/30/2021) 21 Describe the reasons for allocation priorities and any obstacles to addressing underserved needs The City of Yakima tries its best to help as many of its citizens with the limited entitlement funding it receives through federal grant awards. The increased need for decent, safe,affordable housing continues to grow within the city limits of Yakima as population increases have far surpassed the supply of affordable housing opportunities within Yakima. Allocation priorities are set by the elected representatives of the people that sit on the City of Yakima Council. Public input meetings and public comment periods are observed through the adopted "Citizen Participation" process as overseen by HUD regulations. Obstacles to addressing underserved needs is in direct correlation to the limited funding through the entitlement funding as supplied to the City of Yakima by the Federal Government as set by Congress and overseen by the department of Housing and Urban Development. Annual Action Plan 18 2021 OMB Control No:2506-0117(exp.09/30/2021) AP-38 Project Summary Project Summary Information Annual Action Plan 19 2021 OMB Control No:2506-0117(exp.09/30/2021) 23 1 Project Name P4: CDBG:SEN/DISABLED S/F REHAB PROG-2021 Target Area Goals Supported Needs Addressed Funding CDBG: $639,499 Description THIS PROJECT PROVIDES ASSISTANCE TO LOW-MOD INCOME FAMILIES, SENIOR AND OR DISABLED PERSONS TO REHAB THEIR PRIMARY RESIDENCE LOCATED IN THE CITY LIMITS OFYAKIMA.FUNDING AVAILABLE INCLUDES ENTITLEMENT DOLLARS IN THE AMOUNT OF $618,131 AND ESTIMATED PI IN THE AMOUNT OF$21,368. Target Date 12/31/2021 Estimate the number Approximately 75 qualified low to moderate Senior and/or disabled and type of families homeowners will be assisted. that will benefit from the proposed activities Location Description Qualified applicants will be determined throughout the year by application and limited to within the City Limits of Yakima. Planned Activities Emergency repairs to include, no heat, no water, no electricity,water leaks,frozen pipes, leaking roofs, no hot water. Installation and maintenance of aluminum wheel chair ramps to qualified homeowners. Exterior paint as applied by local volunteers and/or contractors to qualified low to moderate income homeowners (as funding allows). 2 Project Name P9: CDBG PUBLIC/COMMUNITY SERVICE PROG-2021 Target Area Goals Supported Needs Addressed Funding CDBG: $126,000 CDBG-CV3: $235,000 Annual Action Plan 20 2021 OMB Control No:2506-0117(exp.09/30/2021) 24 Description This activity will provide Community Service Programs through public facilities operated by local non-profits.The Henry Beauchamp Community Center located at 1211 S. 7th Street,Yakima, WA 98901 and the Washington Fruit Community Center located at 602 N 4th St, Yakima,WA 98901. As well as an energy assistance program to assist senior and or disabled individuals in the City Limits of Yakima operated by grantee staff. Additionally,CDBG-CV funds will be provided to People for People for the Meals on Wheels program within the City Limits of Yakima. Target Date 12/31/2021 Estimate the number Henry Beauchamp will assist an estimate of 3300 low income families and type of families within the City limits of Yakima. that will benefit from Washington Fruit Community Center will activities will be determined at the proposed a later date. activities The City of Yakima will assist an estimate of 2 low income senior/disabled individuals with emergency energy assistance. People for People will provide an estimate of 29,000 meals for low income senior/disabled individuals within the City limits of Yakima. Location Description Henry Beauchamp Community Center-1211 S. 7th Street,Yakima,WA 98901 Washington Fruit Community Center- 602 N 4th St,Yakima,WA 98901 People for People- 304 W Lincoln Ave,Yakima,WA 98902 Annual Action Plan 21 2021 OMB Control No:2506-0117(exp.09/30/2021) 25 Planned Activities Henry Beauchamp Community Center: • After school tutoring including literacy, math,and recreation for approximately 50 elementary through high school students. • Summer Enrichment Program serving approximately 125 elementary and middle school youth. • "100 Jobs for 100 Kids" which this summer will provide summer employment educational opportunities to approximately 50 high school youth. Due to the COVID-19 pandemic these youth may,or may not, also be placed in summer employment opportunities. The focus this year, however, is on job skills and employment education. • Computer Lab and STEM activities for approximately 50 elementary and middle school youth. Washington Fruit Community Center-TBD People for People- Meals on Wheels program for senior/disabled individuals within the City limits of Yakima. 3 Project Name P10: CDBG ADMINISTRATION 2021 Target Area Goals Supported Needs Addressed Funding CDBG: $207,801 Description This project is for the Administration,salaries and benefits for managing CDBG programs in 2021 Target Date 12/31/2021 Estimate the number Approximately 10,000 low to moderate income families will directly and type of families benefit from activities conducted through the City of Yakima's Office of that will benefit from Neighborhood Development Services supported by the CDBG the proposed Administration funds. activities Location Description Administration of the CDBG funds is conducted through the Office of Neighborhood Development Services located at 112 S. 8th Street within the city limits of Yakima. Annual Action Plan 22 2021 OMB Control No:2506-0117(exp.09/30/2021) 26 Planned Activities Single Family Rehabilitation program. Public Facility or infrastructure activities. Code Compliance. Public Service. 4 Project Name P13:HOME ADMINISTATION 2021 Target Area Goals Supported Needs Addressed Funding HOME: $50,342 Description THIS PROJECT IS FOR THE ADMINISTRATION OF HOME FUNDS FOR PROGRAM/SALARIES FOR 2021 Target Date 12/31/2021 Estimate the number An estimate of 41 low to moderate income families will be direct and type of families recipients to HOME Investment activities in the 2021 program year. that will benefit from the proposed activities Location Description Administration of the HOME funds is conducted through the Office of Neighborhood Development Services located at 112 S. 8th Street within the city limits of Yakima. Planned Activities The development and construction of a 41 units Multifamily project. 5 Project Name P14: CHDO PROGRAM 2021 Target Area Goals Supported Needs Addressed Funding HOME: $98,807 Description THIS PROJECT IS FOR HOME CHDO'S FOR 2021 Target Date 12/31/2022 Annual Action Plan 23 2021 OMB Control No:2506-0117(exp.09/30/2021) 27 Estimate the number Approximately 2 low to moderate income families will be provided and type of families housing in partnership with a qualified Community Housing that will benefit from Development Organization (CHDO). the proposed activities Location Description To be determined but within the city limits of Yakima. Planned Activities Construction of two single family dwellings to be sold to qualified low to moderate first time homebuyers. 6 Project Name P18: HOME: NEW/REHABILITATED HOME UNITS IN 2021 Target Area Goals Supported Needs Addressed Funding HOME: $402,597 Description THIS PROJECT CONSISTS OF THE REHABILITATION AND NEW CONSTRUCTION OF HOME UNITS WITHIN THE CITY LIMITS OF YAKIMA FOR 2021.TFUNDING AVAILABLE INCLUDES ENTITLEMENT DOLLARS IN THE AMOUNT OF$344275.00 AND ESTIMATED PI IN THE AMOUNT OF $58322.00 Target Date 12/31/2022 Estimate the number Approximately 16 low to moderate income families will benefit from the and type of families construction of new rental housing units constructed with HOME that will benefit from Investment funds in partnership with a local housing organization. the proposed activities Location Description THIS PROJECT CONSISTS OF THE NEW CONSTRUCTION OF HOME UNITS WITHIN THE CITY LIMITS OF YAKIMA FOR 2021. Planned Activities The development and construction of a 16 unit multifamily rental project. 7 Project Name P19: FIRST TIME HOMEOWNER ASSISTANCE PROG-2021 Target Area Goals Supported Needs Addressed Annual Action Plan 24 2021 OMB Control No:2506-0117(exp.09/30/2021) 28 Funding HOME: $10,000 Description THIS ACTIVITY FUNDS FIRST TIME HOMEOWNER ASSISTANCE IN THE CITY LIMITS OF YAKIMA. Target Date 12/31/2021 Estimate the number Two low to moderate income families are expected to receive direct and type of families benefit. that will benefit from the proposed activities Location Description Qualified applicants will be determined through application and located within the city limits of Yakima. Planned Activities First time Homebuyer assistance to qualified first time homebuyers in the City Limits of Yakima. 8 Project Name P20: CDBG-CV INFRASTRUCTURE/PUBLIC FACILITIES 2021 Target Area Goals Supported Needs Addressed Funding CDBG-CV3: $260,000 Description CDBG-CV INFRASTRUCTURE/PUBLIC FACILITIES 2021 WITHIN THE CITY OF YAKIMA 2021. Target Date 12/31/2021 Estimate the number This activity will help and estimate of 3300 low income families in the and type of families City limits of Yakima. that will benefit from the proposed activities Location Description Henry Beauchamp Community Center- 1211 S 7th Street,Yakima, WA 98901 Washington Fruit Community Center- 602 N. 4th Street,Yakima,WA 98901 Planned Activities Install HVAC air scrubbers in both Henry Beauchamp Community Center and Washington Fruit Community Center as approved by Yakima City Council. Project Name P24: CDBG: CODE COMPLIANCE 2021 Annual Action Plan 25 2021 OMB Control No:2506-0117(exp.09/30/2021) 29 9 Target Area Goals Supported Needs Addressed Funding CDBG: $87,072 Description THIS PROJECT IS FOR THE CODE COMPLIANCE IN THE CITY OF YAKIMA 2021. Target Date 12/31/2021 Estimate the number Approximately 350 low to moderate income families located within the and type of families low to moderate income census tracts will be directly assisted with code that will benefit from compliance by the individual staff member paid with CDBG Code the proposed Compliance funding. activities Location Description Within the low to moderate income census tracts within the city limits of Yakima. Planned Activities The salary of an individual Code Compliance officer to conduct code compliance activities serving low to moderate areas. 10 Project Name CDBG-CV3 Admin Target Area City Wide Goals Supported Needs Addressed Funding CDBG-CV3: $123,798 Description This project is for the Administration,salaries and benefits for managing CDBG-CV3 programs in 2021 Target Date 12/31/2021 Estimate the number People for people will provided an estimate of 29,000 meals to low and type of families income senior/disabled individuals. Henry Beauchamp will provide that will benefit from services to an estimate of 3300 low income individuals. Washington the proposed Fruit is TBD. activities Location Description Administration of the CDBG funds is conducted through the Office of Neighborhood Development Services located at 112 S. 8th Street within the city limits of Yakima. Annual Action Plan 26 2021 OMB Control No:2506-0117(exp.09/30/2021) 30 Planned Activities Administration for the following activities: Public Services- People for People Meal on Wheels Public Facilities- Henry Beauchamp Community Center and Washington Fruit Community Center Annual Action Plan 27 2021 OMB Control No:2506-0117(exp.09/30/2021) 31 AP-50 Geographic Distribution —91.220(f) Description of the geographic areas of the entitlement (including areas of low-income and minority concentration)where assistance will be directed ONDS programs are designed to be application driven and City Wide,to enable the City of Yakima to help as many low to moderate income applicants as possible within the entire city limits of Yakima. Geographic Distribution Target Area Percentage of Funds City Wide 100 Table 8-Geographic Distribution Rationale for the priorities for allocating investments geographically Low to Moderate income citizens are located city wide and it is not the wish or design by the City of Yakima to directly or indirectly "steer" people of any race, creed,color or financial level, be it low to moderate or otherwise into any designated area, real or otherwise. Therefore, the programs are offered city wide, to qualified applicants. Discussion The City of Yakima does not limit any CDBG or HOME Investment funding to any specific geographical area and all programs are designed to assist eligible applicants and funding within the entire city limits of Yakima as appropriate. Annual Action Plan 28 2021 OMB Control No:2506-0117(exp.09/30/2021) 32 Affordable Housing AP-55 Affordable Housing—91.220(g) Introduction The main focus of the City of Yakima through ONDS in using both CDBG and HOME Investment funds is "Affordable housing". The Single Family Rehabilitation program is focused on rehabilitation of existing housing to enable the homeowners to continue to reside in their affordable housing, through the Senior/Disabled Emergency Home Repair Program to include; the Senior/Disabled Wheel Chair ramp program, the Exterior Paint Program. ONDS also supports and encourages Affordable housing through the use of HOME funds for; the First Time Homebuyers Program, the New Construction Program and the use of a minimum of 15%of yearly entitlement HOME funds in supporting Affordable housing though partnerships with certified CHDO's. One Year Goals for the Number of Households to be Supported Homeless 41 Non-Homeless 93 Special-Needs 0 Total 134 Table 9-One Year Goals for Affordable Housing by Support Requirement One Year Goals for the Number of Households Supported Through Rental Assistance 0 The Production of New Units 59 Rehab of Existing Units 75 Acquisition of Existing Units 0 Total 134 Table 10-One Year Goals for Affordable Housing by Support Type Discussion The City of Yakima continues to serve a growing number of Senior/Disabled homeowners with severe Emergency repairs such as; no heat, no power, no water, no sewer, deteriorated roofs that have become insurance concerns that may lead to cancellation with limited Federal Entitlement funds from HUD. The City of Yakima through partnerships with a qualified Community Housing Development Organizations expect to construct two single family homes to be sold to qualified low to moderate income first time homebuyers, as well as assist with land acquisition and development of a 16 unit multifamily low to moderate income apartment complex within the city limits of Yakima. Additionally, Annual Action Plan 29 2021 OMB Control No:2506-0117(exp.09/30/2021) 33 construction completion of a 41 unit homeless veteran multifamily housing development. Annual Action Plan 30 2021 OMB Control No:2506-0117(exp.09/30/2021) 34 AP-60 Public Housing— 91 .220(h) Introduction The City of Yakima continues to support the Yakima Housing Authority (YHA), although indirectly. In the past, the City of Yakima has support specific facilities through various ways and even though budget restrictions severely limit the City's participation in current projects, each request of the YHA is reviewed individually and participation is given consideration through the Yakima City Council as are other funding requests. The Office of Neighborhood Development Services (ONDS) as the local environmental representative for HUD projects has worked with the YHA to enable projects to have the proper documentation in order to meet the HUD regulation criteria needed for those specific projects as requested by the YHA. Actions planned during the next year to address the needs to public housing The City of Yakima ONDS expects to continue to partner and support the YHA as our limited federal budget will allow. Specific projects and funding requests will be analyzed and given consideration by due process regarding the most beneficial use of entitlement funds. ONDS expects to continue to support the YHA with environmental review and documentation as requested by the YHA. Actions to encourage public housing residents to become more involved in management and participate in homeownership The Yakima Housing Authority encourages resident involvement with programs like the Resident Advisory Board (RAB).The RAB provides the YHA and the residents with a forum for sharing information about the agency's Annual Action Plan. RAB membership is comprised of individuals who reflect and represent the residents assisted by the public housing agency (PHA).The role of the RAB is to assist the PHA in developing the PHA Plan and in making any significant amendment or modification to the Plan. In addition, the Yakima Housing Authority is an active participant in crime-free rental housing which allows the residents to be a part of the local block watch which ONDS participates in every year, inviting the residents and local organizations to partake in National Night Out. The YHA also participates in the Yakima County Asset Building Coalition,and they are establishing a partnership with YVOCAN for the Union Gap and Yakima area. YHA is also in the process of collaborating with the AmeriCorps VISTA Education Award with the goal of every eligible resident signing up for the Annual Action Plan 31 2021 OMB Control No:2506-0117(exp.09/30/2021) 35 College-Bound Scholarship. Lastly,YHA is administering the Family Self-Sufficiency (FSS) Program. This program enables families assisted through the HCV program to increase their earned income and reduce their dependency on welfare assistance and rental subsidies. If the PHA is designated as troubled, describe the manner in which financial assistance will be provided or other assistance The Yakima Housing Authority is not designated as "troubled". Discussion The Yakima Housing Authority continues to do an extraordinary job in assisting Yakima residents with decent,safe,and affordable housing though its many diverse housing programs.The City of Yakima looks forward to continuing its partnership with the YHA to provide this type of housing to its residents. Annual Action Plan 32 2021 OMB Control No:2506-0117(exp.09/30/2021) 36 AP-65 Homeless and Other Special Needs Activities —91.220(i) Introduction The Department of Commerce is the Collaborative Applicant for the Washington Balance of State Continuum of Care (BoS CoC). The BoS CoC's 34 small and medium-sized counties receive about$8 million annually for 50 permanent and temporary housing projects funded by the Department of Housing and Urban Development Continuum of Care Program in which Yakima County including the City of Yakima are included. The City of Yakima recognizes homelessness as the most severe housing problem and strives to prevent the most at-risk populations from becoming homeless by using CDBG funds for the Single Family Rehabilitation Program.These programs are designated to help the high-risk senior and disabled groups with emergency rehabilitation, wheelchair ramps and exterior painting in the hopes that this will allow them to continue to occupy their current affordable housing units. ONDS also strives to support affordable housing with its homeownership programs,the First Time Homeownership Program,the New Construction Program and the direct and indirect support of certified Community Housing Development Organizations(CHDOs) in creating new single family housing that is decent,safe,and affordable.This directly affects the homeless by giving them the opportunity to own their first home, or by indirectly allowing someone in either a rental situation or a public housing situation to buy their first home and thereby indirectly allow another affordable rental or public housing unit to be occupied by an otherwise homeless individual or family. Describe the jurisdictions one-year goals and actions for reducing and ending homelessness including Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs The City of Yakima continues to support the Department of Commerce's Continuum of Care Plan . The first priority of Continuum of Care is to maintain existing resources that serve the ends of the homeless within the community.The plan identifies new projects and services that fill critical gaps in prevention services,outreach, emergency and transitional housing,support services, and long-term affordable Annual Action Plan 33 2021 OMB Control No:2506-0117(exp.09/30/2021) 37 housing. Addressing the emergency shelter and transitional housing needs of homeless persons The City of Yakima continues to work with the multitude of local agencies through Continuum of Care in addressing emergency shelters and transitional housing opportunities on an individual project basis. 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 Due to the severely limited Federal funds received by the City of Yakima through reduced entitlements, the City is unable to address this particular need until additional funding becomes available. Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: 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); or, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs. The City of Yakima, though the Senior/Disabled Emergency Home Repair Program, is often contacted by local hospital and nursing care facilities about seniors and/or disabled homeowners that need emergency repairs or wheelchair ramps in order to be allowed to be returned to their homes after being released from these care facilities. Discussion Due to severely limited resources,the City of Yakima continues to direct its attention to assisting senior/disabled homeowners through its Emergency Home Repair Program to enable the elderly, frail Annual Action Plan 34 2021 OMB Control No:2506-0117(exp.09/30/2021) 38 and disabled to remain in their homes and thereby not becoming homeless and adding to the Continuum of Care's burden with additional homelessness. Annual Action Plan 35 2021 OMB Control No:2506-0117(exp.09/30/2021) 39 AP-75 Barriers to affordable housing—91.220(j) Introduction: Yakima's Comprehensive Plan identifies several areas affecting the development of affordable housing including zoning, land use,subdivision requirements, impact fees, licensing and permits, and extension of transportation and utility services.The Yakima Planning Division monitors available land, zoning, and land use in order to ensure projected population increase can be accommodated with new housing construction available to all income groups. Actions it planned to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment The City of Yakima continues to work with expanding economic development activities to bolster the local economy and spur building investment toward the construction of more affordable residential developments and units.The Community Development Department through its Planning Division continues to research and recommend new zoning policies to allow a more diverse range of housing types and make it easier to develop housing in certain areas. Discussion: The effective use of Federal allocations to the responsible local entities with a measured reserve of responsible recording and reporting is the only way of effectively reducing the barrier to affordable housing at the local level. Increasing the benefit to the low and moderate income workforce that has so effectively made our great county what it is, is the only way of increasing affordable housing and will not only effectively raise the entire nations living standard but also serves it well economically. Annual Action Plan 36 2021 OMB Control No:2506-0117(exp.09/30/2021) 40 AP-85 Other Actions —91.220(k) Introduction: The City of Yakima continues to assist its citizens with the use of Community Development Block Grant (CDBG) and HOME Investment funds to the best of its ability through the Office of Neighborhood Development Services by continuing to assist qualified low to moderate applicants with rehabilitation of their existing homes, providing new single family dwellings to qualified First Time Homeowners, Economic Development, Public Services, and Neighborhood development. Actions planned to address obstacles to meeting underserved needs The City of Yakima will continue to seek federal funding as well as other available funding to overcome the lack of sufficient funds to address all of the underserved needs. The City of Yakima Office of Neighborhood Development Services(ONDS) continues to partner with many non-profits, local service organizations,and other government and non-governmental agencies to assist in meeting underserved needs. Actions planned to foster and maintain affordable housing As discussed throughout the Consolidated Plan and elsewhere in this Annual Action Plan,the City of Yakima has a wide variety of programs directed at maintaining affordable existing housing through rehabilitation, as well as new single family dwellings through its homeownership program. The City of Yakima continues to partner with local affordable housing agencies. Actions planned to reduce lead-based paint hazards As discussed in the Five-Year Consolidated Plan, ONDS aligns all of its rehabilitation programs with the Washington State lead-based paint regulations and continues to presume any disturbed paint surfaces are "Possible lead hazards" and thus are treated according to the state's regulations and HUD's lead- based paint policy. ONDS has both certified supervisors and staff on hand to assess and address lead-based paint as well as Annual Action Plan 37 2021 OMB Control No:2506-0117(exp.09/30/2021) 41 hires certified state lead-based paint professionals to deal with all projects with potential lead-based paint disturbed surfaces. Actions planned to reduce the number of poverty-level families The City of Yakima continues to address economic development opportunities to bring more businesses and jobs to Yakima that pay decent living wages,as well as encourage growth and development of existing opportunities to assist poverty-level families. Actions planned to develop institutional structure The City of Yakima continues to work with existing agencies and departments within Yakima as well as consultants and other governmental bodies outside Yakima to strengthen and enhance the current institutional structure. We will continue to seek out partnerships with organizations as well as private enterprises to further develop the institutional structure Actions planned to enhance coordination between public and private housing and social service agencies The City of Yakima through the Office of Neighborhood Development Services (ONDS) will continue to coordinate with public and private housing and social service agencies through committee meetings and consultation to coordinate services to the residents of Yakima. Discussion: ONDS has served its community for over 40 years through its vast and varied programs,administering all kinds of Federal and State funds over the years,towards the betterment of the community and with a focus on affordable housing. Partnerships with other organizations have been instrumental in continuing affordable housing within Yakima with every agency struggling with funding from the past several years of economic struggle. The City of Yakima has focused on being a good steward of both CDBG and HOME Investment funds and stretching those dwindling resources to the best of its ability in serving the community. The City of Yakima continues to strive for affordable housing with the assistance of the community, Annual Action Plan 38 2021 OMB Control No:2506-0117(exp.09/30/2021) 42 neighborhoods and partners in effectively using its entitlement funds. Annual Action Plan 39 2021 OMB Control No:2506-0117(exp.09/30/2021) 43 Program Specific Requirements AP-90 Program Specific Requirements —91.220(I)(1,2,4) Introduction: Due to limited HUD funding, the City of Yakima expends every dollar as effectively and efficiently as possible to benefit its residents within its ONDS programs per HUD's requirements. This means that any program income,float-funded activities,or Section 108 loan guarantee funds are infused within appropriate programs and the funding utilized per HUD regulations concerning eligible activities to meet HUD-approved national objectives. HOME Investment Partnership Program (HOME) Reference 24 CFR 91.220(1)(2) 1. A description of other forms of investment being used beyond those identified in Section 92.205 is as follows: ONDS uses two "Non-Federal" funding sources to administer ongoing"affordability periods" of past HOME Investment projects in compliance with HUD program regulations. ONDS has obligated HOME Investment program income to the construction of two Multi-family affordable rental projects; • One project is to construct a 16 unit low income rental complex that will serve extremely low, low and moderate income individuals and families. • Another project is a 41 unit rehabilitation of an existing building and newly constructed multi-family housing units to provide rental units for low to moderate income veterans. 2. A description of the guidelines that will be used for resale or recapture of HOME funds when used for homebuyer activities as required in 92.254, is as follows: When the City of Yakima makes a loan of HOME Investment funds,that loan is secured by a promissory note and deed of trust. Within those documents is language that specifies the Annual Action Plan 40 2021 OMB Control No:2506-0117(exp.09/30/2021) 44 disposition of funds in the event of a sale. The City of Yakima uses the"Full Recapture" provision in the following manner; If the Homebuyer decides to sell, rent or dispose of the property at any time before the expiration of the affordability period "Full Recapture" provision goes into effect, and in the event of a sale, foreclosure,will trigger repayment of the entire HOME direct subsidy loan amount(Recapture). The Recapture amount is based on net proceeds from the voluntary sale or foreclosure.The net proceeds of a sale are the sales proceeds minus non-Home loan repayments and any closing costs. As per regulation 92.545(ii)(A) says in establishing the PJ's recapture requirements,the Pi is subject to the limitation that when the recapture requirement is triggered by a sale (voluntary or involuntary) of the housing unit, the amount recaptured cannot exceed the net proceeds, if any. The net proceeds are the sales price minus superior loan repayment(other than the direct subsidy HOME funds) and any closing costs. Furthermore, if there are no net proceeds-the amount to be recaptured would be zero given that the City of Yakima may not recapture more than the amount of the net proceeds. If the net proceeds are some portion but do not fully equal your HOME direct subsidy investment amount that would be the amount to recapture. To clarify, the recapture amount is based on the direct HOME subsidy as per HUD requirements. 3. A description of the guidelines for resale or recapture that ensures the affordability of units acquired with HOME funds?See 24 CFR 92.254(a)(4) are as follows: When the City of Yakima makes a loan of HOME funds, that loan is secured by a promissory note and deed of trust. Within those documents is language that specifies the disposition of funds in the event of a sale. The City of Yakima uses the"Full Recapture" provision in the following manner; If the Homebuyer decides to sell, rent or dispose of the property at any time before the expiration of the affordability period "Full Recapture" provision goes into effect, and in the event of a sale, foreclosure,will trigger repayment of the entire HOME direct subsidy loan amount. (Recapture). The Recapture amount is based on net proceeds from the voluntary sale or foreclosure.The net proceeds of a sale are the sales price minus non-HOME loan repayments and any closing costs. As per regulation 92.545 (ii)(A) says in establishing the PJ's recapture requirements,the Pi is subject to the limitation that when the recapture requirement is triggered by a sale (voluntary or Annual Action Plan 41 2021 OMB Control No:2506-0117(exp.09/30/2021) 45 involuntary) of the housing unit, the amount recaptured cannot exceed the net proceeds, if any. The net proceeds are the sales price minus superior loan repayment(other than the direct subsidy HOME funds) and any closing costs. Furthermore, if there are no net proceeds-the amount to be recaptured would be zero given that the City of Yakima may not recapture more than the amount of net proceeds. If the net proceeds are some portion but do not fully equal the HOME direct subsidy investment amount that would be the amount to recapture. 4. Plans for using HOME funds to refinance existing debt secured by multifamily housing that is rehabilitated with HOME funds along with a description of the refinancing guidelines required that will be used under 24 CFR 92.206(b),are as follows: The City of Yakima currently has no plans for refinancing any existing debt secured by multifamily housing that is rehabilitated with HOME funds. If such actions are decided by the Yakima City Council and amendment will be sought and the required refinancing guidelines will be defined at that time as part of the Amendment. The City of Yakima chooses to use the Overall Benefit in the following manner-As a consecutive period of one year, used to determine that a minimum overall benefit of 100%CDBG funds is to be used to benefit persons of low to moderate income. The year specified is this Annual Action Plan of 2021, Annual Action Plan 42 2021 OMB Control No:2506-0117(exp.09/30/2021) 46 Annual Action Plan 43 2021 OMB Control No:2506-0117(exp.09/30/2021)