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City of Hoover, Alabama CONSOLIDATED PLAN PY 2007-2011 The City of Hoover through the submission of this document is providing its Consolidated Plan for years 2007-2011. The Consolidated Plan includes an Executive Summary, The Strategic Plan and the 2007 Action Plan. The Action Plan outlines specific expenditures proposed for the 2007 fiscal year. The information is provided to address CDBG Consolidated Plan regulatory requirements including those published in the February 9, 2006 Federal Register. EXECUTIVE SUMMARY Since its incorporation in 1967 the City of Hoover has grown at a tremendous pace in both population and commercial development. It has developed into one of the top retail centers for the Birmingham-Hoover Metropolitan Statistical Area and for the state as well. It also has a quality of life that is first tier with cultural and recreational facilities such as the Hoover Library/Theatre, Regions Metropolitan Stadium, and the Ross Bridge Golf Facility, to mention just a few. The City’s astounding growth led to a population of 62,742 as of 2000 and if Census Bureau estimates are correct the City had a population of 74,473 as of 2005. This is a growth rate of almost 20% for a five-year period which if maintained for the decade would lead to a truly remarkable growth rate of 40% for the decennial census period of 2000 to 2010. This type of growth obviously presents wonderful opportunities for the City but also presents many challenges, some of which can be addressed through the City’s Community Development Block Grant (CDBG) Program. Through its Consolidated Plan, Hoover has proposed the use of its CDBG funds during the period of FY 2007-2011. This Plan was prepared in accordance with all federal rules and regulations and entailed the involvement of citizens and lower income persons who would be served by the Program. The Plan reviewed extensive data on population, income, housing, homeless needs, special needs groups such as the elderly, disabled, chemically addicted, and persons with HIV/AIDS. The Plan used this information to help establish goals and objectives in the areas of housing and community development for the five year Plan period and for the upcoming Program Year. 1 In essence the Plan determined that public facilities projects such as the continuation of the Shades Mountain Park and the continuation of enrichment programs for lower income students and young people were the highest priorities and that housing needs and homeless facilities were not as high a priority for the CDBG Program at this point in time. The document contains a rather extensive analysis of housing and community development statistics and needs and concludes, based on review of the evidence, that the housing market is working relatively well and that, partially due to the recent construction of much of its housing stock, the condition of ---PAGE BREAK--- 2 housing is good, in fact much better than the majority of communities in Jefferson County and the state. Also based on review of pertinent evidence it was possible to determine that homeless cases were far less frequent in Hoover than in most other areas of the county and the greater Birmingham metropolitan area. Therefore, public facilities improvements to serve the needs of the rapidly growing population were deemed to be of primary importance. For the 2007 Program Year the Action Plan section of the document outlines activities for allocation of $290,680 in Community Development Block Grant funds. These funds are for improvements that will address the needs of lower income persons in the City as required by Program regulations. The following summary lists the activities proposed for funding during the 2007 Action Plan period. Planning and Administration $ 58,136 School Enrichment Programs $ 43,602 Shades Mountain Playground $ 25,000 Blue Ridge Boulevard Sidewalks $ 163,942 TOTAL $ 290,680 Report on Past Progress - The City has been an Entitlement City since 1997 and has generally performed well, in a timely manner, and without programmatic findings. The City has focused almost all funds on the national objective of addressing the needs of principally low- and moderate-income persons. A preponderance of funds have gone into the Lorna Road area, which is the heart of the City’s most highly concentrated Low and moderate Income Census Tract and Block Group. In the past couple of years more attention has also been focused on the Shades Mountain area which is also considered a qualifying income area based on HUD supplied census data. The City is committed to serving all qualifying areas in a fair and equitable manner as it plans for and carries out the Program. The City’s spending pace slowed briefly from 2004 to 2006 due to efforts to establish eligibility of a drainage project in the northern part of the City. Because projects planned to serve that need were ultimately determined to be of questionable eligibility, Hoover fell behind on its spending rate. However, expenditures on several projects (including the Shades Mountain Park, a sewer to serve lower income elderly and handicapped apartments, and sidewalks to serve severely disabled adults) in the winter and spring of 2007 have allowed the City to achieve a spending ratio acceptable to HUD. Such problems are not anticipated in the future. ---PAGE BREAK--- 3 MANAGING THE PROCESS LEAD AGENCY The City of Hoover’s Operations Department has primary responsibility for the planning and general administration of the City’s Community Development Block Grant program, in addition to development of the Consolidated Plan. Staff from this Department, with assistance from private consultants as needed, will implement the activities and carry out monitoring and reporting functions required by the Program. INSTITUTIONAL STRUCTURE With the responsibility for development of the Plan and administration of the CDBG program housed within the Operations Department, the organizational structure is ideal for coordinating departments and agencies as needed to implement the City of Hoover’s Consolidated Plan. With the CDBG Program being administered from an office reporting directly to the Mayor, the support and involvement of City officials demonstrates the level of leadership and attention the program receives. Coordination is evident in the manner that various departments and agencies in the City work together to support social services activities such as the American Hellenic Educational Progressive Association project and summer school enrichment programs. These projects also attest to the degree of “collaboration and partnership” involved in the Program. The “institutional structure and coordination” in the City has resulted in an effectively managed City, as well as an effective CDBG Program. The City works with public and private partners to provide services and adequate infrastructure for all its citizens. In doing so, it carries out anti- poverty and job creation activities. The City also works hard to address social needs as is witnessed by their support of educational opportunities for children of all social strata (CDBG assisted summer school program), and by their interest in aiding the construction of a 50 unit HUD Section 202 complex being developed by the American Hellenic Educational Progressive Association (AHEPA) adjacent to Oakhill Drive in Hoover. Although the City has spent no CDBG funds on economic development related projects in recent years, the City has a very robust economy that provides jobs for low and moderate-income persons living in Hoover and for many living outside the corporate limits of Hoover. In fact it is generally acknowledged that the Hoover economy is one of the most important driving forces for the entire Birmingham-Hoover metropolitan area. 1. Consultation with Public and Private Entities In preparation of the Consolidated Plan, the City contacted a wide range of social service and health agencies to obtain data and stay abreast of needs which may affect the planning process. Listed below are the organizations contacted. However, in its daily administration of the CDBG Program and other functions, the Operations Department routinely interacts with the widest possible array of organizations and individuals. • Jefferson County and Shelby County Health Departments • Metropolitan Birmingham Services for the Homeless • United Way ---PAGE BREAK--- 4 • Birmingham Works Workforce Development • Jefferson/Blount/St. Clair Mental Health and Retardation Authority • AIDS Alabama • Accessible Space, Inc. • Greater Birmingham Fair Housing • Hispanic Coalition • City of Hoover Building Inspection and Police Departments • Hoover School System. • Alabama Head Injury Foundation During the past year the City has worked very closely with the Hoover School System to make sure that the summer school program being carried out with CDBG funds is functioning effectively and is reaching the most appropriate clientele. The City has also worked closely with the American Hellenic Education Progressive Association (AHEPA) to assist their efforts to provide assisted housing for elderly and handicapped persons, and with the Alabama Head Injury Foundation to provide sidewalks that would greatly assist persons living in Patton Ridge Apartments. The Patton Ridge Apartments are for adults disabled by brain injuries or other physical disabilities and were developed by Accessible Space Incorporated with assistance from HUD. On June 15, 2007, the City contacted the Jefferson County Health Department concerning issues of health problems resulting from lead based paint in the City of Hoover. Ms. Addie Hightower, the Lead Programs Coordinator, indicated in her discussions that lead based paint poisonings and reports of elevated lead blood levels were exceedingly rare in this area and that lead poisoning cases in general were substantially down around the county due to sustained efforts to address the problems throughout the nineties. The Shelby County Health Department had also been contacted as part of the prior Consolidated Plan but was not interviewed in this effort since the homes in that area of Hoover were almost exclusively built in the last couple of decades after Lead Paint had been banned. Because of the recent vintage of the vast majority of housing in Hoover, the presence of lead is not a primary issue for the City. In May of 2007, the Metropolitan Birmingham Services for the Homeless was consulted with to gain perspective on homeless needs that may exist in the City. Information reported was integrated into the Consolidated Plan. Hoover works with the United Way of Central Alabama in assisting that agency to determine the priority of community needs. By providing access to the City’s available resources, Hoover ensured a mutual understanding of community needs. The City also works with the Jefferson County Center for Workforce Development to ascertain more information regarding how job training and job placement efforts can be coordinated more effectively. Hoover is a job center for the county. Unemployment in the City is extremely low and, in fact, many persons living in various parts of Jefferson, Shelby, Chilton, Saint Clair, and Bibb counties work in Hoover. The Jefferson/Blount/St. Clair Mental Health and Retardation offices were also used to help assess needs of the City for social services The Hispanic Interest Coalition of Alabama is also an active partner of the City as is the Fair Housing Center for Northern Alabama. In its efforts to serve all sectors of the community, and as part of a continual effort to address the needs of all citizens, the City works with Accessible ---PAGE BREAK--- 5 Space on a regular basis to determine how Hoover can further meet the needs of the physically and developmentally challenged population and, particularly, to make the facility on Rocky Ridge Road a success. The City also works with groups such as AIDS Alabama to stay abreast of and better utilize services available for HIV/AIDS victims. On June 1, 2007, Ms. Nicollette Harvey of AIDS Alabama was consulted to obtain further information on the HIV/AIDS needs and the services available within the county. The information obtained indicated there are approximately 4,000 HIV/AIDS cases in Jefferson County and numerous programs to address such needs. (See Table in Attachment One.) The City is committed to working with AIDS Alabama and Birmingham AIDS Outreach to be sure Hoover citizens can access facilities and programs they operate. During the course of Consolidated Plan development the City Building Inspection Department was consulted to obtain and confirm data compiled from other sources. The Department confirmed information regarding age and condition of the housing stock and the limited likelihood that lead based paint might be present in any significant number of homes. The City Public Safety Department was relied upon to assess the nature, extent and location of criminal activity. The Department was also helpful in gauging the degree and location of any non-sheltered homeless in the City. Results from Police indicated only four homeless persons were encountered in the last year and none of those indicated families were on the streets. This report, coupled with general Department observations throughout the course of the past several years, substantiates assessment by the City that homelessness in Hoover is almost non-existent and that chronic homelessness has not been observed. As is apparent from the information above, the agencies span the gamut of social services, health, housing, local and regional entities outlined in Sec. 91.100. 2. Citizen Participation Citizen Participation Plan - As part of the Consolidated Plan process for this year the City is revising its Citizen Participation Plan. The Plan was reviewed at the Public Hearing on June 27, 2007. The Plan addresses the following items outlined in the Guidelines for Preparing a Consolidated Plan. The Plan provides for and encourages citizens to participate in the development, implementation and review of the Consolidated Plan, Annual Action Plans, Substantial Amendments to the Plan, and the CAPER. The Plan encourages the participation of low and moderate-income residents as well as minorities, non-English speaking persons, and persons with disabilities. Citizens are provided opportunities to receive and review information and to comment on all proposed submissions. The Citizen Participation Plan requires a summary of the Consolidated Plan to be published for comments. It also requires public hearings at times and locations convenient to low and moderate-income persons which are adequately advertised. In addition the Plan provides for technical assistance to be provided and for citizen complaints to be addressed in a timely fashion. Input into Development of Plan - Hoover took all actions required by the Citizen Participation Plan to encourage citizen participation in development of this Consolidated Plan, including holding of public hearings and publication of the Plan Summary with a 30-day comment period. Advertisements, citizen comments, and City responses are found in attachments to this Plan. ---PAGE BREAK--- 6 Minorities and Non-English Speaking People - Minority and non-English speaking persons constitute a small but growing segment of Hoover’s population and they, too, are encouraged to participate by ads, public hearings and publication of the Action Plan summary. Ads offered the use of interpreters if requested by attendees. The largest concentrations of minority and non- English speaking persons in the City live in the area (CT 129.08 Block Group Persons with Disabilities - Input from disabled persons was sought as part of this process. Ads for public hearings offered special accommodations for disabled persons if notice was given prior to the meeting. As indicated above disabled persons and their representative organizations have had a very significant effect on the objectives and activities of the Hoover CDBG Program and will continue to do so. The City is very cognizant of its need to make facilities like its Shades Mountain Park accessible to the disabled, as well as other more fortunate citizens who are not challenged by mobility issues. LMI persons in Slums and Blighted Areas - Input from all persons in Hoover was sought as part of the process, although very few, if any, areas in Hoover would qualify as slums or blighted areas. LMI persons in Areas Where Funds are to be Used - As part of the process, input from residents of all areas where funds are to be used was requested. Public hearings for the program are usually held within the census tract block group (129.08 Block Group 8) having the highest concentration of lower income persons and minorities in the City. Proposed recreational activities will take place in CT 144.05 BG 8 which has one of the highest concentrations of African Americans in the City. Residents in Predominantly LMI Areas - Input from residents of predominantly low and moderate-income areas was critical to the development of this Plan. As indicated above public hearings are held in the area having the highest concentration of LMI persons in the City of Hoover. Also it is worthy to note that the preponderance of activities over the entire history of the program have occurred in this area. Residents of PHA Units - No PHA units exist in Hoover, although some Section 8 units administered by the Jefferson County Housing Authority are from time to time located in the City. Utilization of CDBG funded activities to benefit these units is not considered to be a high priority for the current Consolidated Plan time frame. Neighborhood Meetings - City officials attended a neighborhood meeting in the Shades Mountain area on June 19, 2007, to solicit input regarding neighborhood needs. Public Hearings. - A Public Hearing for this Plan was held on June 27, 2007, with ads for the Hearing appearing in the Birmingham News on June 13, 2007, and on June 20, 2007. See hearing minutes and comments attached. Public Notices and Comments 1. Notices - Minutes from the hearing, copies of Notices appearing in the Birmingham News, and summaries of comments are found in Attachment Six. 2. Comments - Thirty-Day Comment Period and Related Public Notices. From July 4, 2007, to August 3, 2007, the public was requested to comment on the proposed Amendment. Ads summarizing the proposed Plan and inviting comment were run in the Birmingham News on ---PAGE BREAK--- 7 July 4, 2007 and on July 11, 2007. Copies of these ads are presented as attachments. Reasonable public access was provided for review of the proposed Plan during the 30-day period. Summary of Public Comments. The comments received during the period stated above and responses to such comments are found in the Attachment Six. Summary of Responses or Actions in Regard to Comments. A summary of actions and responses to public comments during the 30-day period are found in Attachment Six noted above and enclosed as part of this submission. 3. Other - Announcements on Web Site. A draft of the Consolidated plan, 2007 Action Plan, Citizen Participation Plan, and Anti-displacement Plan were all made available on the Hoover website for a period of 30 days.. ---PAGE BREAK--- 8 ASSESSMENT OF HOUSING AND HOMELESS NEEDS HOUSING As part of the Hoover Consolidated Plan the housing needs for the five-year planning period have been estimated for the various family or household sizes. The review and estimates have taken into account the categories specified in Table 2A, Priority Housing Needs. Needs were estimated in terms of pertinent categories such as renter versus owner, elderly, small families, large families, disabled persons, and persons with HIV/AIDS, as well as by income categories of extremely low, low, moderate, and middle- income. The City’s housing needs were analyzed significantly in the City’s previous Consolidated Plan based primarily on 1990 Census data. Fortunately, since that time more 2000 Census Data and SOCDS CHAS data has become available. Updated information is presented and analyzed here along with limited data from the earlier Plan that is deemed to be useful or still pertinent to assessing the housing needs of the City of Hoover for the next five years. The primary statistical presentation of data is found in Attachment Three (Housing Needs and Market Analysis Tables), but highlights from that information are presented below. The 2000 Census showed that there are 25,052 housing units in Hoover, that 16,666 (66.53%) are owner units and 8,386 (33.47%) are rental units. CHAS data, used as the prime determinant of housing needs, varied due to rounding and statistical manipulation, but this data showed 8,438 renters and 16,652 owners. The CHAS data tables are presented at the beginning of Attachment Three, with separate needs tables presented for various racial groups and for Hispanic (ethnic) residents as well. As might be expected, more problems were found among rental households. CHAS data showed that 29% of renters had a cost burden of greater than 30% for gross rent, while only 21% of owners had this type of cost burden for gross mortgage cost. Fortunately, only 10.6% of renters and 7.4% of owners had a severe cost burden of 50% or more for gross housing costs. As is typical for low income and very low-income rental households, which constitute roughly 16% of the rental sector, the cost burden problems are more substantial. Among very low- income renters, those with cost burdens exceeding 30% stands at 78.3%. Among very low- income owners, the mortgage cost burden exceeds 30% for 72% of the 314 owners in this category. Fortunately, the percentage of very low-income owners is only 1.8% of the number of total owners and the percentage of very low-income renters is only 7.8% of the total number of renters. While it is to be expected that lower income households will almost always have a higher rent or mortgage cost burden than more affluent households, Hoover is fortunate that its median gross rent as a percentage of household income is 22.4%. This is lower than most nearby entitlement cities such as Bessemer Birmingham and Tuscaloosa Hoover is also fortunate that the housing stock is relatively new, with the median date of construction being 1985, and that most units are in good condition. Only 7 units out of 25,052 are lacking plumbing units, which is usually one of the barometers for judging physically substandard units. The City defines “standard housing” as housing that is not overcrowded and is ---PAGE BREAK--- 9 suitable for human habitation, subject to only routine maintenance such as painting, minor plumbing and electrical repairs, and is absent structural deterioration such as that caused by termites, rotting, water damage, or extreme age. The City considers units that can be repaired for $25,000 or less to be “suitable for rehabilitation.” Visual surveys have also indicated that physically substandard units are extremely rare in Hoover. The fact that the median value of a home in Hoover is $178,600, compared to $90,700 for Jefferson County and $56,500 and $62,100 for the adjacent entitlement cities of Bessemer and Birmingham, says a great deal about the physical quality of housing in the City. As indicated above, the median age of housing in Hoover was 15 years at the time of the 2000 Census, which is an additional indicator that the number or percentage of substandard housing is negligible. With such small numbers, it is almost impossible to subdivide them into categories of owner/renter, extremely low, low, or moderate. Almost assuredly, the few substandard units that do exist are more likely to be owned or rented by lower income persons; however, the physical housing needs in the City are indeed small in comparison to almost any area of the county or state except elite suburbs such as Mountain Brook or Vestavia. Assessment of Disproportionate Needs -In almost all categories of CHAS Data for minority groups other than African Americans and Hispanics, the numbers were too small to analyze or data was not available. Even among these minority groups the numbers were small enough to be skewed by a small number of cases or statistical anomalies, such as among African American households where three of the categories had only ten members in the category. In a City of approximately 63,000 people and 27,000 households that is a very small segment of the housing market. Among African American households (which comprise 6.9% of the City’s households), the housing needs in most categories shown in the CHAS Data were comparable to or within 10% of the needs of the population as a whole. In a few cases the population’s Black group needs were less than those of the population as a whole. In four categories the Black households had a higher need by more than 10%. However, in three of these categories (Elderly 1 and 2 member Rental Households with incomes of 50% to 80% of the median, Owner Family Households with incomes of 50% to 80% of the median, and Owner Other Households with 50% to 80% of the median) there were only 10 households, indicating that the needs involved were not very great and that, because of the very small numbers, the data could easily be skewed by a few unusual cases. In the other category where African American needs exceeded the overall needs by 10% or more (Other Owner Households with incomes exceeding 80% of MFI), the percentage of Black households with housing problems was 35%, compared with 19% for the total population. This indicates a somewhat disproportionate need. Again, the numbers are small, as there were only 54 households among Black families in that category, but 19 had at least one housing problem. Among the overall population, over 19% or 292 of the 1,517 households had at least one problem. The 19 African American households in this category comprised .07% of the households in Hoover, thereby constituting a very small portion of the overall housing market. Among Hispanic households there were more categories where disparities existed; but, again, the numbers were often small and in many categories not available since Hispanic Households total only 629 units or 2.5% of the City total. The absence of data was particularly true where owner units were involved. The most significant needs appeared to be among Rental Family ---PAGE BREAK--- 10 Households with incomes of 50% to 80% of MFI. Here, 74% of the 135 Hispanic Households had at least one housing problem (compared to 59% for the population as a whole); and, among the Rental Family Households with incomes of more than 80% of the MFI, 69% of the Hispanic Households had at least one problem compared to 49% for the overall population. These problems likely stem largely from the income levels of a large portion of the Hispanic population in Hoover, as over 50% of the Hispanic households earn under $40,000 annually. (See Attachment Five table entitled Household Income by Race and EthniCity.) HOMELESS NEEDS Homeless needs are concisely presented in Table 1A (Homeless and Other Special Needs Activities). This information is presented in a format prescribed by HUD and identifies the nature and extent of Homelessness to the extent possible. This table is located in Attachment One (Required Consolidated Plan Tables), and a brief narrative summary of the information is presented below. As indicated in the City’s 2002 Consolidated Plan, based on data and observations over a substantial number of years, the visible homeless population in Hoover is extremely small. The ratio of persons from Hoover utilizing the services of the homeless and spousal abuse facilities in the Birmingham metropolitan area is proportionally much lower than any other community. This fact was reestablished for the purposes of this Consolidated Plan by review and compilation of more recent data, including consultation with the Metropolitan Birmingham Services for the Homeless as well as by observations of the Hoover Department of Public Safety. According to observations and records of the Hoover Department of Public Safety the visible homeless population in Hoover is minimal, at most (4 persons in the last year), and typically involves temporary situations rather than chronic homelessness. The few incidents that do occur are primarily addressed through referral to homeless service agencies cooperating with the Metropolitan Birmingham Services for the Homeless. Because of the incredibly small number of observations of homeless persons in Hoover, it was impossible to categorize the observations into homeless veterans, families, etc. However, the City will continue to monitor homeless occurrences in Hoover to insure that housing and emergency care concerns are adequately addressed. Inventory - An inventory of Homeless and Other Special Needs groups was based on field observations of the Hoover Department of Public Safety over the past year and review of information from the Metropolitan Birmingham Services for the Homeless. The homeless population in Hoover is, at most, minimal (4 observations in the last year) and typically involves temporary situations rather than chronic homelessness. The few incidents that have occurred have been appropriately addressed through referral to homeless service agencies participating in the Metropolitan Birmingham Services for the Homeless. The City will continue to monitor homeless occurrences in Hoover to insure that housing and emergency care concerns are adequately addressed. Homeless Facilities and Services & Special Needs and Services - The City works with MBSH to remain abreast of all facilities in the area that provide housing or services for the homeless and special needs groups. See listing of Homeless organizations in Attachment Two (Homeless Organizations). Priority Homeless Needs - Priority needs for homeless groups have been reviewed and the applicable tables required by Consolidated Plan regulations (Tables 1A and 1B) are presented in ---PAGE BREAK--- 11 the Attachment One. However, due to the almost non-existent presence of homeless in Hoover, no numerical goals have been set at this time. Homeless Strategy and Continuum of Care Approach - A reasonable strategy for addressing the homeless needs of the City of Hoover involves the use of organizations throughout the Birmingham metropolitan area. This involves coordination with the Metropolitan Birmingham Services for the Homeless, as well as other organizations such as the Salvation Army, Bread and Roses, Aletheia House, and Safe House. This coordination represents an effective participation in the regional Continuum of Care and aids the prevention of homelessness. A listing of the Homeless service providers in the Birmingham Metropolitan Area can be found in Attachment Two to this Plan. The City’s strategy does not specifically address “chronic homelessness” as this problem has not been determined to exist in Hoover. However, as part of its implementation of the CDBG Program and essential program planning, the City remains vigilant for signs of this problem and will devise a strategy if needed. Specific Objectives - Objectives have been set to address the homeless needs of Hoover that take into account the extremely limited nature of homelessness at this point. Primarily the objectives consist of continuing to monitor homeless incidents that may occur in Hoover and coordinating with all relevant agencies in the Birmingham metro area to address the needs of Hoover’s homeless. At this point the occurrences are so few and sporadic that they are not considered a funding priority for the CDBG program and the City does not receive ESG, HOPWA, of HOME funds which might be applied to the needs of the homeless or domestic abuse cases. Discharge Coordination Policy - Hoover receives no ESG funds or other funds that would require a “Discharge Policy’. SPECIAL NEEDS POPULATIONS Hoover has estimated its Special Needs Populations and will address these as appropriate. An effort was made to determine how many Hoover residents fall into categories such as “frail elderly” or “developmentally disabled” through statistical review and data analysis, which is briefly described in the following paragraphs and in footnotes to Table 1B found in Attachment One. However, it is all but impossible to ascertain how many persons in these categories might be candidates for supportive housing and thereby indicate a need for housing goals. Therefore, at the present time, no additional goals are set in these areas for the CDBG program since CDBG funds were used during the past year to provide essential infrastructure to supportive housing facilities (sidewalks for the apartments on Rocky Ridge Road for adults with severe head injuries and sewer facilities for the HUD 202 apartments for lower income elderly and disabled persons located on Oakhill Drive). See Tables 1A and 1B in Attachment One for presentation of statistical information. Elderly and Frail Elderly - Estimates of the Elderly Population were obtained from SOCDS data entitled “Housing Problems for all Households.” The Elderly figure (869) is based on the elderly who were shown as elderly and low and moderate income. The Frail Elderly estimate is based on compilation of HUD supplied 2000 Census Data for Persons with Disabilities by Gender and Age. Data for persons age 65 and over with some type of disability were used as an approximation for Frail Elderly. There were 2,615 who fit this category. ---PAGE BREAK--- 12 Another way to approach this question would be to look at group quarters in Hoover and how many of these are occupied by institutionalized persons. A study performed by House Consultants indicated in 2000 revealed 657 spaces in group settings in the City of Hoover, with 491 of those occupied – 454 by institutionalized persons and 37 by non-institutionalized persons. This reflects a vacancy rate of roughly 25%. Therefore, there are likely to be 166 group quarters openings in Hoover to address the needs of persons requiring such facilities. With a vacancy rate this high, it would appear there is not a strong demand or need for this type of facility. Severe Mental Illness - The estimate of persons with severe mental illness was based on Table 41 of Census File SF3. The figure used (1,202) was based on a compilation of persons age 16 and older. Other studies show a composite figure in the same range as Census data. Data from the Alabama Department of Mental Health and Retardation have shown that there are approximately 28 individuals with mental retardation problems who are served in Hoover, while information from the Jefferson-Blount-St. Clair Mental Health/Mental Retardation Authority indicate approximately 1,450 residents of Hoover will either receive or be in need of services to treat severe and persistent mental illness such as schizophrenia, bipolar affective disorder, and major depression. The total of these figures is 1,478. The estimated in that study that approximately 10%, or 150 of those would need supportive housing during any given year. The housing needs of severely mentally ill in Hoover are able to be met through private resources and that should be the case for five year period of this Plan. Direct care services are provided to severely mentally ill in the Jefferson County portion of Hoover by the UAB Comprehensive Community Mental Health Center. Shelby County residents of Hoover are served by the Chilton-Shelby Mental Health Center. Developmentally Disabled - According to the United State Department of Health and Human Services statistics, approximately 3% of the U. S. population has developmental disabilities such as Down’s Cerebral Palsy, Epilepsy, etc. This figure was multiplied times the Hoover population to estimate that there are 2,000 persons in Hoover with a Developmental Disability. Physically Disabled - The figure for physical disabilities (2,760) came directly from Table 41 of Census File SF3. Alcohol or Other Drug Addictions - The national addiction rate according to HHS literature is estimated to be 22 million of 300 million in the United Sates. This factor was applied to the Hoover population to estimate 4,500 persons in the City have some level of substance addiction. Persons with HIV/AIDS - The HIV/AIDS rate of .03% was applied to the Hoover population and factored down based on the demographic patterns prevalent among AIDS victims to gauge that there are approximately 100 persons in that category in Hoover. This estimate may be high as earlier contacts with the Executive Director of AIDS Alabama revealed there are 10-15 clients in qualifying income ranges afflicted with HIV/AIDS in Hoover. AIDS Alabama believes the number of individuals with HIV/AIDS is higher that the 15 receiving services, but income levels in Hoover allow these people to receive services through other means. Victims of Domestic Violence - While Hoover is a more affluent community with lower levels of crime and violence than most in the region and state, it is not immune to the problem of domestic violence. The Hoover Department of Public Safety has reported 465 cases of Domestic violence during the past year. ---PAGE BREAK--- 13 Priority Needs of Special Needs Populations - The priority needs for Special Needs Populations are presented in Table 1B of Attachment One. At this time the City is not setting additional goals or objectives for such persons, given the limited CDBG funds available to the City. Specific Objectives - The City has addressed this issue as required at Section 24 CFR 91.1. However, no additional objectives are set for the five-year time period of the Strategic Plan due to the minimal and uncertain needs of subject populations that might need supportive housing. As indicated above the City has supported the needs of these groups at a substantial level, given the size of its CDBG entitlement amount. Lead Based Paint Hazards - It should be stressed that not all units with lead based paint pose a lead paint hazard. Lead paint presents a health hazard primarily to children under the age of seven and then mainly when lead paint is not in good condition and housekeeping skills and nutrition are poor. For these reasons the mere presence of lead based paint in all of the estimated units does not indicate a problem in and of itself. Still the City will continue to use available data and tools to weigh the risk and degree of lead based paint problems. Because there are no PHA units in Hoover, and because the majority of housing (65.5%) was constructed after 1978, lead based paint is less of a problem in Hoover than is found in many communities across Jefferson County, the State of Alabama, or even the nation, for that matter. Because of the recent vintage of the vast majority of housing in Hoover, the presence of lead based paint has not been an issue. Consultation with the Building Inspection Department as part of this planning effort revealed that no lead paint issues had come to their attention in the previous year. Consultation with the County Health Department also indicated that Hoover is regarded as a very low risk area for lead paint issues, with only one case of elevated lead blood levels reported in the last three years in a Hoover zip code. However, the City will remain vigilant to the possible problems that may arise in this area, particularly where children of less than seven years of age are concerned. ---PAGE BREAK--- 14 HOUSING NEEDS AND MARKET ANALYSIS GENERAL CHARACTERISTICS As part of the Hoover Consolidated Plan the housing needs for the five-year planning period have been estimated for the various family or household sizes. The review and estimates have taken into account the categories specified in Table 2A (Priority Housing Needs). Needs were estimated in terms of pertinent categories, such as renter versus owner, elderly, small families, large families, disabled persons, and persons with HIV/AIDS, as well as by income categories of extremely low, low, moderate, and middle income. The housing needs were analyzed significantly in the City’s 2002 Consolidated Plan based primarily on 1990 Census data. Fortunately, since that time more 2000 Census Data and SOCDS CHAS data has become available. Updated information is presented and analyzed here along with limited data from the earlier Plan deemed to be useful or still pertinent to assessing the housing needs of the City of Hoover for the next five years. The primary statistical presentation of data is found in Attachment Three (Housing Needs and Market Analysis Tables). Highlights from that information are presented below. The 2000 Census showed there are 25,052 occupied housing units in Hoover, of which 16,666 (66.53%) are owner units and 8,386 (33.47%) are rental units. CHAS data, used as the prime determinant of housing needs, varied due to rounding and statistical manipulation, but the data showed 8,438 renters and 16,652 owners. The CHAS data tables are presented at the beginning of Attachment Three, with separate needs tables presented for various racial groups and for Hispanic (ethnic) residents, as well. As might be expected more problems were found among rental households. CHAS data showed 29% of renters had a cost burden of greater than 30% for gross rent, while only 21% of owners had this type of cost burden for gross mortgage cost. Fortunately, only 10.6% of renters and 7.4% of owners had a severe cost burden of 50% or more for gross housing costs. As would be expected, among low income and very low-income rental households, which constitute roughly 16% of the rental sector, the cost burden problems are more substantial. Among very low-income renters, those with cost burdens exceeding 30% stands at 78.3%. Among very low-income owners, the mortgage cost burden exceeds 30% for 72% of the 314 owners in this category. Fortunately, the percentage of very low-income owners is only 1.8% of the number of total owners and the percentage of very low-income renters is only 7.8% of the total number of renters. While it is almost always the case that lower income households will have a higher rent or mortgage cost burden than more affluent households, Hoover is fortunate that its median gross rent, as a percent of household income, is 22.4%. This is lower than most nearby Entitlement Cities such as Bessemer Birmingham and Tuscaloosa Hoover is also fortunate that the housing stock is relatively new with the median date of construction being 1985, and that most units are in good condition. Only 7 units out of 25,052 are lacking plumbing units. The fact that the median value of a home in Hoover is $178,600, compared to $90,700 for Jefferson County and $56,500 and $62,100 for the adjacent Entitlement cities of Bessemer and Birmingham, says a great deal about the quality of housing in the City. ---PAGE BREAK--- 15 As part of this analysis it is worth noting that while no units in Hoover are specifically set aside for HIV/AIDS sufferers the City has been very instrumental in the development of units for handicapped persons in the last few years. The City rezoned property to allow for 18 units of low income handicapped housing to be built along Rocky Ridge Road and has recently installed a sidewalk from these units to Lorna Road, primarily to serve these units, through the use of CDBG funds. The City has also encouraged the development of 50 units of HUD 202 housing to serve lower income elderly and handicapped persons on Oakhill Drive. The City has also financed the extension of sewer lines to these units through the use of CDBG funds. AREAS OF LOWER INCOME AND MINORITY CONCENTRATION Hoover has relatively small minority populations, with the highest concentrations appearing to be in Census Tract 144.05 Block Group 3 and Census Tract 129.08 Block Group 8, where CDBG activities have been targeted, and in Census Tract 129.09 Block Group 9 which is very close to the majority of CDBG activities that have been undertaken in the Program to this point. According to the 2000 Census Hoover had an African American population percentage of 6.8%, Asian percentage of 2.9%, and Hispanic population percentage of 3.8%. In CT 129.08 BG 8 the African American percent of the population is 10.6%, the Hispanic percent is 10.9%, while the Asian percent is 3.8%. In CT 144.05 BG 3 the African American percent of the population is 18.0%, the Hispanic percent is 2.6%, while the Asian percent is 2.0%. In CT 129.08 BG 9 the African American per cent of the population is 10.5%, the Hispanic per cent is 13.9%, while the Asian percent is 4.9%. While Hoover is a generally affluent City with an overall Low and Moderate-Income (LMI) percentage of 18.1%, according to Department of Housing and Urban Development calculations shown in Attachment Five, the highest concentrations of LMI populations occur in the Block Groups noted above which have a higher concentration of minorities. Census Tract 129.08 Block Group 8 has an LMI percentage of 40.1%, CT 144.05 BG3 has an LMI percentage of 27.8%, and CT 129.09 BG 9 has an LMI percentage of 34%. All of these are the highest in Hoover for Block Groups that have substantially large population totals. As was noted above, the City has directed almost all of its CDBG funded activities to addressing needs in these areas. Please note Tables displaying lower income and minority concentrations in Attachment Four. ASSESSMENT OF DISPROPORTIONATE NEEDS CHAS Data for all minority groups other than African Americans and Hispanics were too small to analyze, as data in almost all areas was listed as not available. Even among these minority groups the numbers were small enough to be skewed by a small number of cases or statistical anomalies, such as among African American households where three of the categories that appeared to show disparities had only ten members in the category. In a City of approximately 63,000 people and 27,000 households that is a very small segment of the housing market. Among African American households (which comprise 6.9% of the City’s households) the housing needs in most categories shown in the CHAS Data were comparable to or within 10% of the needs of the population as a whole. In a few cases the population’s Black group needs were less than those of the population as a whole. In four categories the Black households had a higher need by more than 10%. However in three of these categories (Elderly 1 and 2 member Rental Households with incomes of 50% to 80% of the median, Owner Family Households with incomes of 50% to 80% of the median, and Owner Other Households with 50% to 80% of the median), there were only 10 households in the category, indicating that the needs involved were ---PAGE BREAK--- 16 not very great and that because of the very small numbers the data could easily be skewed by a few unusual cases. In the other category where African American needs exceeded the overall needs by 10% or more (Other Owner Households with incomes exceeding 80% of MFI), the percentage of Black households with housing problems was 35%, compared against 19% for the total population. This indicates a somewhat disproportionate need; but, again, the numbers are small as there were only 54 households among Black families in that category and 19 had at least one housing problem. Among the overall population, over 19% or 292 of the 1,517 households had at least one problem. The 19 African American households in this category comprise .07% of the households in Hoover and thus constitute a very small portion of the overall housing market in Hoover. Among Hispanic households, there were more categories where disparities existed. Again, the numbers were often small and in many categories not available since Hispanic Households total only 629 units or 2.5% of the City total. The absence of data was particularly true where owner units were involved. The most significant needs appeared to be among Rental Family Households with incomes of 50% to 80% of MFI. Here, 74% of the 135 Hispanic Households had at least one housing problem (compared to 59% for the population as a whole). And, in the Rental Family Households with incomes of more than 80% of the MFI, 69% of the Hispanic Households had at least one problem (compared to 49% for the overall population). These problems likely stem largely from the income levels of a large part of the Hispanic population in Hoover as over 50% of the Hispanic households earn under $40,000 annually. (See Attachment Five table entitled Household Income by Race and Ethnicity.) VACANT AND ABANDONED BUILDINGS The City of Hoover has determined that the number of vacant and abandoned buildings is negligible due to the continued steady development and redevelopment in the Hoover area and also due to the active code enforcement by the City of Hoover. In addition, the vast majority of homes and other structures in Hoover were built in the last 20 to 30 years, making the buildings generally useable without high maintenance and repair costs, and market factors in Hoover and southern Jefferson County and northern Shelby County keep most standard structures in high demand. PRIORITY HOUSING NEEDS Priority housing needs are presented in Table 2A (Priority Housing Needs/Investment Plan Table). An explanation of the derivation of these needs is presented below and in the Table 2A. Housing needs were derived primarily from review of the Census data presented in Attachment Three. Information for Owner and Renter housing needs was derived from the SOCDS CHAS Table entitled, “Housing Problems for All Households”. The total number of persons in a category, such as Small Related Families, was multiplied times the percent shown to have housing problems to obtain the unmet need figure. To derive Special Needs total, figures from Table 1B were multiplied times 40% (80% of MFI in normal Bell Curve distribution equals 40% of population), except for elderly who were already LMI based on HUD supplied data. HOMELESS FACILITIES AND SERVICES / SPECIAL NEEDS AND SERVICES The City works with Metropolitan Birmingham Services for the Homeless to remain abreast of all facilities in the area that provide housing or services for the homeless and special needs groups. See listing of homeless organizations in Attachment Two (Homeless Organizations). It is also worth noting that the City has been very instrumental in the development of units for ---PAGE BREAK--- 17 handicapped persons in the last few years. The City rezoned property to allow for 18 units of low income, handicapped housing to be built along Rocky Ridge Road and recently, through the use of CDBG funds, installed a sidewalk from these units to Lorna Road, primarily to serve these units. The City has also encouraged the development of 50 units of HUD 202 housing on Oakhill Drive to serve lower income elderly and handicapped persons. The City has also financed the extension of sewer lines to these units through the use of CDBG funds. BARRIERS TO AFFORDABLE HOUSING In general public policies such as tax policy, land use controls, zoning ordinances, building codes, and fees and charges for the City of Hoover have shown no significant effects on affordable housing. The City of Hoover does have zoning ordinances that apply to residential development, but no impediments to fair housing were identified during the review. The zoning regulations for residential districts are divided into eight different categories and the requirements of each category vary, including the minimum lot requirements. This information supports the existence of a wide array of housing opportunities being available in Hoover. The City has continually worked to make possible a variety of housing opportunities in Hoover. In recent years the City of Hoover amended its R-4 zoning to allow higher density housing for a group home for disabled persons with low incomes and changed its residential zoning code to allow mixed use developments within the City limits. The zoning change allows development of higher density residential developments, thus making housing more affordable and available to a wide range of income levels. The City has continued this trend by working with AHEPA to make possible the provision of 50 lower income HUD 202 units on property adjacent to Oakhill Drive. In fact the City is using CDBG funds to provide sewer to this facility. During recent years the City approved zoning requests for several hundred new apartments. Actions of this type continue to remove any impediments regarding housing within the City of Hoover. Analysis of Impediments to Fair Housing Choice - Review of statistics and public policies indicates that Hoover does not have public policies that constitute barriers to affordability. The City permits construction of a wide variety of unit sizes and types. Similarly, codes and minimum lot sizes are not excessively large so as to work against affordability. However, the City will remain vigilant in regard to such possibilities and will continually weigh data and public comments to detect areas where this might occur. The City Council on March 3, 1997, certified to affirmatively further fair housing and has prepared and maintains an Analysis of Impediments to Fair Housing Choice. The City also maintains records of its analysis and actions. The City will also remain alert to the validity and usefulness of this document and will update it when necessary. Fair Housing - The City Council on March 3, 1997 certified to affirmatively further fair housing and has prepared and maintains an Analysis of Impediments to Fair Housing Choice. The City also maintains records of its analysis and actions. The City will remain alert to the validity and usefulness of this document and will update it when necessary. The City has determined that it does not currently have public policies that constitute barriers to affordability. The City permits construction of a wide variety of unit sizes and types. Similarly, codes and minimum lot sizes are not excessively large so as to mitigate against affordability. However, the City will remain vigilant in regard to such possibilities and will continually weigh data and public comments to detect areas where this might occur. ---PAGE BREAK--- 18 MARKET ANALYSIS Presentation of the statistical data used for the Hoover Market Analyses can be found primarily in Attachment Three – “Housing Needs and Market Analysis,” but information in Attachment Four (“Demographic Data”) and Attachment Five (“Income and Economic Development Data”) are also useful in understanding the nature of the Hoover housing market. Included in this data is information on the percent of owner and renter occupied units, including the age of those units, the percent of housing units by type and school zone, the number of units that are occupied and vacant, the year structures were built, and the value of owner occupied units. Also included is data on the ability of households to afford a median priced house or the median level rent, the number of available rental units by age, the percent of costs for housing by income category, and the gross housing costs for owners and renters. Simply put ,the Hoover housing market appears to be superior to or equal to any in the state. The condition of the vast majority of units is very good and the supply and demand factors of the market appear to be working without any artificial barriers, such as large lot subdividing or restrictive zoning adversely affecting housing choice. There are no peculiar characteristics that can be seen to adversely affect protected groups such as minorities, the disabled, or victims of HIV/AIDS. A wide variety of housing choice exists within the City. The characteristics of the Hoover housing market influence the use of CDBG funds and Consolidated Plan housing priorities in many ways, but primarily by the fact that the quality of housing in Hoover is vastly superior to that in most of Jefferson County and in most of the State of Alabama. Comparative statistics readily support this assertion, and the reality of this fact has led the City to utilize CDBG funds largely for non-housing activities up to this point. However, the City maintains an open perspective regarding the use of funds for valid and eligible purposes and will continually assess available data and input from citizens that might alter the choice of program activities. Specific Housing Objectives - Because of a good quality housing stock, the relative affordability of housing in Hoover and a robust economy, the City of Hoover has, to this point, chosen to focus CDBG funds on public facilities and infrastructure needed to support the quality of life desired by its citizenry and has forgone the application of CDBG funds to housing development or economic development activities. Therefore no direct housing CDBG activities are programmed in this Plan. However, the City will remain vigilant for opportunities to use CDBG funds to support housing efforts when appropriate as it has done in the recent past such as sidewalks to serve apartment units built for lower income persons with severe head injuries and sewer lines to serve HUD 202 units. The City receives no HOME funds and thus cannot use these funds for housing actions. Needs of Public Housing - No public housing or PHA exists at the current time in the Hoover corporate limits. The City has no Public Housing Authority. Therefore, the physical condition of such units, the restoration and revitalization needs, and the Section 504 Needs Assessment of Public Housing projects are not applicable. Also, Hoover does not have any public housing units that receive funds through an approved HUD Comprehensive Grant Program. Public Housing Strategy - The City has no Public Housing and therefore views this item as not applicable at this time. ---PAGE BREAK--- 19 STRATEGIC PLAN GENERAL The City of Hoover used the information provided above and referenced in the attached tables, together input from the citizen participation process concerning priorities for the use of Program funds, as the basis for assigning priorities to goals, objectives, and projects. Based on historic trends (housing, population, and income) in the Hoover vicinity and after evaluating the relationship of the data in the previous Consolidated Plan to data collected for this Plan, it was adjudged that nothing is apparent that would severely impact the magnitude of the data collected or derived for the planning purposes of this document. Therefore, the City determined that the information assembled and presented herein was valid for establishing goals, objectives and funding priorities during the five-year planning period. The Tables in Attachment One show that the priorities for Hoover are Public Facilities and Public Services. Based on the information compiled in this document, it is evident that housing and homeless activities are not the serious problems in Hoover that they are in many communities across the state and, thus, should not be the primary focus of the City’s Program. This assessment is reflected in the priorities assigned in Table 2A. The City believes its clear priority is to continue targeting public facilities in census tracts and block groups identified as higher quartile areas for lower income persons. The City also views as a priority using funds to address the needs of individual lower income persons, particularly youth, who need assistance to become more productive citizens. The census tracts that are viewed by HUD as upper quartile tracts for low and moderate-income persons are listed in Attachment Five. These are generally found between U. S. Highway 31 and Interstate 65 north of Interstate 459 and between Alford Avenue and Tyler Road. These areas will be the primary focus of CDBG activities in the next five years, although nothing in this Plan should be seen as precluding activities in other eligible areas when certain important needs arise. The City deems the underserved needs to be the needs of lower and moderate-income persons for adequate public facilities and services. With its rapid growth, the City has been hard pressed to address all needs and CDBG funds has become an important asset to the City has for this purpose. The decline in entitlement amounts over the past several years has been an obstacle to fully addressing these needs. In Tables 1A, 1B, 1C, 2A, 2B and 2C the City has set forth the priorities and specific objectives for the coming years. The reasons for these choices, as described above are for providing an adequate quality of life for the lower income portions of an exploding population. In each of those tables the proposed accomplishments and outcomes desired over specific time frames are set forth. Usually these accomplishments are simply expressions of the numbers of people to be served and who will be provided a more suitable living environment. AFFORDABLE HOUSING The quality and availability of housing in Hoover is good. The City has a reasonable mix of owner and rental units and apartment unit complexes are spread generously through most of the City, although not as much in the Shelby County portions of Hoover. Approximately 25% of the ---PAGE BREAK--- 20 units in Hoover are multi-family units (apartments) and another 10% of the housing stock is comprised of patio homes and garden homes, which are also generally more affordable than large detached single family homes. Roughly 34% of the housing is comprised of rental units, which again gives moderate and lower income households a reasonable chance to reside in the City without paying exorbitant portions of their income for housing. The City’s 7% vacancy rate indicates there is ample flexibility in the market to allow the average or moderate working class family a chance to own or rent a home. According to the 2000 Census, 90% of the renters in Hoover had a gross housing cost of less than $1,000 and 70% of owners had a gross housing cost of less than $1,500, which indicates a reasonable degree of affordability for an affluent suburban area like Hoover. The Hoover housing market appears to be equal to any in the state in many respects. The condition of the vast majority of units is very good and the supply and demand factors of the market appear to be working without any artificial barriers, such as large lot subdividing or restrictive zoning adversely affecting housing choice. There are no peculiar characteristics evident that would adversely affect lower income persons, and a wide variety of housing choices exist within the City. In general public policies, such as tax policy, land use controls, zoning ordinances, building codes, and fees and charges for the City of Hoover, have shown no significant effects on affordable housing. The City of Hoover has a zoning ordinance that applies to residential development, but no impediments to fair housing were identified during the City’s review. The zoning regulations for residential districts are divided into eight different categories and the requirements of each category vary, including the minimum lot requirements. This information supports the existence of a wide array of housing opportunities being available in Hoover. The City has continually worked to make possible a variety of housing opportunities in Hoover. In recent years the City of Hoover amended its R-4 zoning to allow higher density housing for a group home for disabled persons with low incomes, and it changed its residential zoning code to allow mixed use developments within the City limits. The zoning change allows development of higher density residential developments, thus making housing more affordable and available to a wide range of income levels. The City has continued this trend by working with AHEPA to make possible the provision of 50 lower income HUD 202 units on property adjacent to Oakhill Drive. In fact the City is using CDBG funds to provide sewer to this facility in the current program year. During recent years, the City approved zoning requests for several hundred new apartments, including 18 units for severely brain injured adults. Actions like this continue to demonstrate the City’s commitment to providing housing choice for all citizens. The characteristics of the Hoover housing market influence the use of CDBG funds and Consolidated Plan housing priorities in many ways, but primarily by the fact that the quality of housing in Hoover is vastly superior to that in most of Jefferson County and in most of the State of Alabama. Comparative statistics readily support this assertion, but the reality of this fact has led the City to utilize CDBG funds largely for non-housing activities up to this point. However, the City maintains an open perspective regarding the use of funds for valid and eligible purposes and will continually assess available data and input from citizens that might alter the choice of program activities. ---PAGE BREAK--- 21 ADDRESSING HOMELESSNESS As indicated in the City’s 2002 Consolidated Plan, based on data and observations over a substantial number of years, the visible homeless population in Hoover is extremely small. Persons from Hoover who use the services of the homeless and spousal abuse facilities in the Birmingham metropolitan area is proportionally lower than the averages of most any other community. These facts were reestablished for the purposes of this Consolidated Plan by review and compilation of more recent data, consultation with the Metropolitan Birmingham Services for the Homeless, as well as by observations of the Hoover Department of Public Safety. According to observations and records of the Hoover Department of Public Safety the visible homeless population in Hoover is, at most, minimal (4 persons in the last year) and typically involves temporary situations rather than chronic homelessness. The few incidents that have occurred were primarily addressed through referral to homeless service agencies cooperating with the Metropolitan Birmingham Services for the Homeless. Because of the incredibly small number of observations of homeless persons in Hoover, it was impossible to identify or subdivide the statistics into homeless veterans, families, etc. However, the City will continue to monitor homeless occurrences in Hoover to insure that housing and emergency care concerns are adequately addressed. Strategy to Address Homelessness - A reasonable strategy for addressing the homeless needs of the City of Hoover involves the use of organizations throughout the Birmingham metropolitan area. This involves coordination with the Metropolitan Birmingham Services for the Homeless, as well as other organizations such as the Salvation Army, Bread and Roses, Aletheia House, and Safe House. This coordination represents an effective participation in the regional Continuum of Care which reaches out to the homeless and assesses their needs, helps low income families avoid homelessness, addresses the emergency shelter and transitional housing needs of the homeless, and helps the homeless and chronically homeless, make the transition to permanent housing and independent living. A listing of the Homeless service providers in the Birmingham Metropolitan Area can be found in Attachment Two to this Plan. The City’s strategy does not directly address “chronic homelessness” as this type of problem has not been determined to exist in Hoover. However, as part of its implementation of the CDBG Program and essential program planning, the City will remain vigilant for signs of this problem and will devise a strategy if needed. Objectives have been established to address the homeless needs of Hoover, taking into account the extremely limited nature of homelessness at this point. Primarily, the objectives consist of continuing to monitor homeless incidents in Hoover and coordinating with all relevant agencies in the metro area to address the needs of Hoover’s homeless. At this point the occurrences are so minor and sporadic as to not be considered a funding priority for the CDBG program; and, the City does not have ESG, HOPWA, of HOME funds which might be applied to the needs of the homeless or domestic abuse cases. Addressing Other Special Needs or Supportive Housing Needs - Hoover has estimated its Special Needs Populations and will address these as appropriate. An effort was made to determine how many Hoover residents fall into categories such as “frail elderly” or “developmentally disabled” through statistical review and data analysis, which is briefly described above and in footnotes to Table 1B found in Attachment One. However, it is all but ---PAGE BREAK--- 22 impossible to ascertain how many persons in these categories might be candidates for supportive housing, thereby indicating a need for housing goals. Therefore, at this point, no additional goals are set in these areas of the CDBG program since CDBG funds were used this past year to provide essential infrastructure to supportive housing efforts (such sidewalks to the apartments on Rocky Ridge Road for adults with severe head injuries and sewer to the HUD 202 apartments for lower income elderly and disabled persons located on Oakhill Drive). See Tables 1A and 1B in Attachment One for presentation of statistical information. NON-HOUSING COMMUNITY DEVELOPMENT PLAN The Tables in Attachment One (particularly Table 2B) show that the priorities for Hoover are Public Facilities and Public Services. These objectives were developed in accordance with the statutory goals described in 24CFR 91.1 and the primary objectives of the CDBG Program. Based on the information compiled in this document, it is evident that housing and homeless activities are not the serious problems in Hoover that they are in many communities and, thus, they should not be the primary focus of the City’s Program. The City’s long-term (five years) and short-term (1-3 years) objectives are to target public facilities to census tracts and block groups having been identified as higher quartile areas for lower income persons. The City also views as a priority using funds to address the needs of individual lower income persons, particularly youth who need assistance to become more productive citizens. The census tracts that are viewed by HUD as upper quartile tracts for low and moderate-income persons are listed in Attachment Five. These are generally found between U. S. Highway 31 and Interstate 65 north of Interstate 459 and between Alford Avenue and Tyler Road. These areas will be the primary focus of CDBG activities in the next five years, although nothing in this Plan should be seen as precluding activities in other eligible areas when certain important needs arise. ADDRESSING BARRIERS TO AFFORDABLE HOUSING In general, public policies such as tax policy, land use controls, zoning ordinances, building codes and fees, and charges by the City of Hoover have shown no significant effects on affordable housing. The City of Hoover does have zoning ordinances that apply to residential development, but no impediments to fair housing were identified during the review. The zoning regulations for residential districts are divided into eight different categories. The requirements of each category vary, including the minimum lot requirements. This information supports the existence of a wide array of housing opportunities being available in Hoover. The City has continually worked to make possible a variety of housing opportunities in Hoover. In recent years the City of Hoover amended its R-4 zoning to allow higher density housing for a group home for disabled persons with low incomes and changed its residential zoning code to allow mixed use developments within the City limits. The zoning change allows development of higher density residential developments, thus making housing more affordable and available to a wide range of income levels. The City has continued this trend by working with AHEPA to make possible the provision of 50 lower income HUD 202 units on property adjacent to Oakhill Drive. In fact the City is using CDBG funds to provide sewer to this facility. During recent years the City has approved zoning requests for several hundred new apartments. Actions like this continue to remove any impediments regarding housing within the City of Hoover. As described above no substantial barriers to affordable housing have been found to exist but Hoover will continue to work to be sure that all citizens have no artificial roadblocks to obtaining decent, safe, and affordable housing. ---PAGE BREAK--- 23 ADDRESSING LEAD BASED PAINT HAZARDS As indicated earlier in this Plan, research has indicated lead based paint risk is very minimal in the City of Hoover and in the respective portions of Jefferson and Shelby counties. Still, Hoover will continue to work with the state and county health departments to remain informed regarding lead based paint hazards in the community. The Building Inspection Department reported no problems in this area, and the extremely high percentage of recently constructed homes in the City indicates this is unlikely to be a problem. ADDRESSING POVERTY/ANTI-POVERTY STRATEGY Hoover’s anti-poverty strategy is to continue to cooperate with and support private sector efforts, which will continue to provide jobs to the area and, thus, assure unemployment levels stay at the approximately 3% level in the Birmingham-Hoover MSA. It will also continue to support and foster creative governmental and quasi-governmental ventures that stimulate the economy, such as the cyber-crime training center to be located in the Hoover Public Safety Center. This venture will train approximately 1,000 persons per year in Hoover and will result in the spending of roughly $7,000,000 by the Office of Homeland Security in the City on annual basis. The housing and feeding of the 1,000 annual participants will be a remarkable boon to the Hoover economy as well as to the entire MSA. ASSESSMENT OF INSTITUTIONAL STRUCTURE AND COORDINATION EFFORTS With the responsibility for development, management and monitoring of the CDBG program housed within the Operations Department, Hoover’s organizational structure is ideal for coordinating departmental and agency efforts needed to administer the City’s Consolidated Plan. Administering the program from an office reporting directly to the Mayor assures the support and involvement of the highest levels of City government. Coordination is evident in the manner the various departments and agencies work together to support social services activities, such as the American Hellenic Educational Progressive Association’s HUD-financed 202 apartment complex and the summer school enrichment programs. These projects also witness the degree of “collaboration and partnership” involved in the Program. Besides these collaborative efforts, the City works closely with agencies such as the Metropolitan Birmingham Services for the Homeless, private and public mental health agencies, the Alabama Head Injury Foundation, and Accessible Space to see that the needs of homeless persons and individuals with special needs are assisted. The “institutional structure and coordination” in the City has resulted in an effectively managed City and an effective CDBG Program. It is one that works with public and private partners to provide services and adequate infrastructure for all citizens, as it also carries out anti-poverty and job creation activities. The City’s efforts to address social needs is witnessed by their support of educational opportunities for children of all social strata (CDBG assisted summer school program), and by their interest in aiding the construction of a 50 unit HUD Section 202 complex being developed by the American Hellenic Educational Progressive Association (AHEPA) adjacent to Oakhill Drive in Hoover. Although the City has spent no CDBG funds on economic development related projects in recent years, the City has a very robust economy that provides jobs for low and moderate-income persons living in Hoover and for many living outside the corporate limits of Hoover. In fact it is ---PAGE BREAK--- 24 not a stretch to say that the Hoover economy is one of the most important driving forces in the entire Birmingham-Hoover MSA. STATUS OF PUBLIC HOUSING IN HOOVER No public housing or PHA exists at the current time in the Hoover corporate limits. The City has no Public Housing Authority. Therefore, the physical condition of such units, the restoration and revitalization needs, and the Section 504 Needs Assessment of Public Housing projects are not applicable. Also, Hoover does not have any public housing units that receive funds through an approved HUD Comprehensive Grant Program. The City has no Public Housing and, therefore, views this item as not applicable at this time. ---PAGE BREAK--- 25 ACTION PLAN FOR 2007 GENERAL INFORMATION AND RATIONALE FOR ALLOCATION PRIORITIES The City’s Form 424 and Program Certifications are found in Attachment Eight, and Hoover’s DUNS number is 07-897-5455. The presentation of geographic areas to be served is given in the maps provided in Attachment Seven. Hoover has elected to target funds to a continuation of activities in the Shades Mountain neighborhood in FY 2007. These activities are needed based on community input and are located in one of the highest percentage LMI block groups (Census Tract 144.05 Block Group 3, Group 9) in the City. Since Census Tract 129.08, Block Group 8, which also contains one of the highest concentration of lower-income persons in the City has received several million dollars of CDBG funded improvements over the past few years, the City feels that it is appropriate to address other needs in the jurisdiction where lower income concentrations are high. The City has always maintained its CDBG focus on serving high concentrations of low-income persons as the regulations intended. The primary focus is on public facilities projects that address the CDBG Objective of a Suitable Living Environment and the CDBG Outcome Category of Availability and Accessibility. It is expected that the activities in 2007 will serve a neighborhood of approximately 3,800 persons and a more suitable living environment for those persons would be the outcome. As a secondary focus Hoover has chosen to address the CDBG Objective of Economic Opportunity for lower income persons with the Outcome Category being Availability and Accessibility. This is being done through the public service activities of providing tuition for lower income students that are attending summer enrichment programs at the Hoover public schools. It is felt that these activities will enrich the lives of the participants and lead to the probability that those participating will grow up to be citizens that can engage more fully in the economy of the community. The outcome Measure for each of these activities is estimated to be 40 persons. RESOURCES/SOURCES OF FUNDS CDBG dollars are the only source of funds for the Hoover Program. The City receives no ESG, HOME, or HOPWA funds. The City’s CDBG Entitlement amount for FY 2007 is $290,680 and no program income has been received. STATEMENT OF SPECIFIC ANNUAL OBJECTIVES AND OUTCOME MEASURES See Attachment One Tables 3A and 3C for a presentation in suggested HUD format. The primary focus of Hoover’s program is on public facilities projects that address the CDBG Objective of a Suitable Living Environment and the CDBG Outcome Category of Availability and Accessibility. It is expected that the continuation of a neighborhood park in 2007 and the provision of sidewalks serving the same neighborhood of approximately 3,800 persons will result in a more suitable living environment. Availability and accessibility for those persons would be the outcome. As a secondary focus Hoover has chosen to address the CDBG Objective of Economic Opportunity for lower income persons with the Outcome Category being Availability and ---PAGE BREAK--- 26 Accessibility. This is being done through the public service activities of providing tuition for lower income students that are attending summer enrichment programs at the Hoover public schools. It is felt that these activities will enrich the lives of the participants and lead to the probability that those participating will grow up to be citizens that can engage more fully in the economy of the community. The Outcome Measure for each of these activities is estimated to be 40 persons. DESCRIPTION OF ACTIVITIES The City’s activities for FY 2007 are listed below. 1. Shades Mountain Park Improvements $ 25,000 The City will use these funds for the continued improvements to the Shades Mountain Park such as installation of attendant and necessary facilities like parking areas, restrooms, lighting, etc. The park will support the objective of a Suitable Living Environment and Outcome Category of Availability to approximately 3,800 persons. 2. School Enrichment Programs $ 43,602 This activity will continue the support of the City School Board’s Summer Enrichment Program by subsidizing the attendance of lower income children. The enrichment program will support the objective of a Suitable Living Environment and Outcome Category of Availability to approximately 40 persons. 3. Blue Ridge Boulevard Sidewalk Construction $ 163,942 The City will use these funds for the construction of a sidewalk along Blue Ridge Boulevard leading to the Shades Mountain Elementary School. The activity will support the objective of a Suitable Living Environment and Outcome Category of Availability to approximately 3,800 persons. 4. Administration $ 58,136 The City will use these funds for administration of CDBG program activities including payments for staff time, advertisements, legal fees, etc. GEOGRAPHIC DISTRIBUTION Priority needs for CDBG continue to fall in the area of improving public facilities and addressing certain public services needs such as upgrading educational opportunities for lower income children. Maps can be found in Attachment Seven that display the geographic location of proposed activities. The tuition assistance programs are based on specific lower income individuals and are not geographically targeted. The reasons for Hoover’s selection of the Shades Mountain neighborhood (Census Tract 144.05, BG 3) are addressed above under General Information and Rationale for Allocation Priorities. Approximately 65% of the FY 2007 CDBG funds are expected to be spent in this area which is, in addition to being an area with a higher concentration of lower income persons, a more racially diverse neighborhood than the City as a whole. The Shades Mountain area has a an African American population of 10.5% and the Shades Mountain School has an African American enrollment of 21% far exceeding the overall Hoover population percentage of approximately The average family size in the neighborhood is 2.88 and 93% of housing units are occupied. Almost 40% of the units are rental with roughly 22% of the people living in the Shades Mountain Elementary School district residing in apartments. ---PAGE BREAK--- 27 ANNUAL AFFORDABLE HOUSING GOALS Given the age and condition of Hoover’s housing stock production of new units and repair of existing units are not high priorities for use of the limited CDBG funds. Because of the relative recent age of most all housing in Hoover and its almost uniformly good to excellent condition, housing needs are capable of being addressed through the private market. See the Housing Needs and Market Analysis Section as well as Tables in Attachments One, Three and Five. HOMELESS AND OTHER SPECIAL POPULATIONS See Tables in Attachment One and discussions of Homeless and Special Needs groups in the Strategic Plan above. NEEDS OF PUBLIC HOUSING There are no public housing units in Hoover. ANTIPOVERTY STRATEGY Hoover’s economy is exceptional and income levels are well above state and regional averages. Because of the nature of the City’s economy no CDBG funds have been spent nor are they targeted this year for direct economic assistance to businesses. However, the City is using CDBG funds to enrich the lives and educational opportunities of lower income children by paying tuitions that allow them to attend summer school enrichment programs at the Hoover Public Schools. It is believed that this will enhance their ability to become adults who can more readily participate in the abundant economy of the City. This, in effect, would be the City’s Antipoverty Strategy. LEAD BASED PAINT HAZARDS Hoover will continue to work with the state and county health departments to remain informed regarding lead based paint hazards in the community. The Building Inspection Department has reported no problems in this area which, given the extremely high percentage of recently constructed homes in the City, it is unlikely to become a problem. OTHER ACTIONS No specific actions addressing Homeless problems are to be undertaken with CDBG funds in FY 2007.The FY 2007 Action Plan contains no activities to foster or maintain affordable housing or to address public housing improvements or PHA resident initiatives. The City’s School Enrichment Program should increase economic opportunities for lower income persons in Hoover and eventually affect the poverty status of residents in the City. The City’s Building Inspection Department will continue to monitor and report on any lead based paint issues that arise. No specific line items in the CDBG budget are for coordination with housing and service agencies but the City is completing projects that provide essential public facilities for apartment complexes that house lower income handicapped and elderly persons. MONITORING Each project supported by CDBG will be monitored closely to ensure compliance with regulations and appropriate use of the funds. The Operation Department will assume control of this function. OTHER REQUIREMENTS 1. HUD Required Tables - Required Tables are found in Attachment One. ---PAGE BREAK--- 28 2. Maps - Maps included as an attachment to this document identify the physical locations of the City’s planned CDBG projects and their relation to qualifying LMI Quartiles. These may be found at Attachment Seven. 3. Low and Moderate Income Benefit - It is estimated that 100% of the activities in this year’s Action Plan will be used to benefit persons qualifying as Low and Moderate Income based on Census data for the City of Hoover. This is based on their location in high LMI quartiles or because they benefit individual lower income persons such as LMI students attending summer enrichment programs. 4. Program Specific Requirements a. All CDBG funds anticipated to be available for FY 2007 have been budgeted. By virtue of this Plan the City is submitting its proposal the Department of Housing and Urban Development for review. No program income is anticipated. Surpluses from Urban Renewal settlements are not applicable. All previous grant amounts have been designated in prior plans. Income from Float-funded activities is not applicable. b. No program income is anticipated nor are there any surpluses from Urban Renewal Settlements or income from Float loans. c. No Urgent Need activities are included in this Action Plan. d. Information about all activities is included in this Action Plan, including the location of proposed activities. 5. Certifications and Form 424 - The 424 Form and the Certifications found at Attachment Eight address the fact that City is complying with applicable regulations. The following items have been produced by the City of Hoover and are an integral part of the City’s Program, or are used when necessary and appropriate by the City. All were adopted, if necessary, as part of the City’s Consolidated Planning process and have been updated as needed to address changing conditions or revised regulations. The Citizen Participation Plan received input for revision during the CDBG public hearing held on June 27, 2007. a. Analysis of Impediments b. Citizen Participation Plan 6. Consolidated Annual Performance Report (CAPER) - This document is on file and available for review at the Hoover City Hall.