2021 ANNUAL AGENCY PLAN

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GRAND RAPIDS

HOUSING COMMISSION

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Streamlined Annual

PHA Plan

(High Performer PHAs)

U.S. Department of Housing and Urban Development

Office of Public and Indian Housing

OMB No. 2577-0226

Expires: 02/29/2016

Purpose. The 5-Year and Annual PHA Plans provide a ready source for interested parties to locate basic PHA policies, rules, and requirements concerning the PHA’s operations, programs, and services, and informs HUD, families served by the PHA, and members of the public of the PHA’s mission, goals and objectives for serving the needs of low- income, very low- income, and extremely low- income families

Applicability. Form HUD-50075-HP is to be completed annually by High Performing PHAs. PHAs that meet the definition of a Standard PHA, Troubled PHA, HCV-Only PHA, Small PHA, or Qualified PHA do not need to submit this form.

Definitions.

(1) High-Performer PHA – A PHA that owns or manages more than 550 combined public housing units and housing choice vouchers, and was designated as a high performer on both of the most recent Public Housing Assessment System (PHAS) and Section Eight Management Assessment Program (SEMAP) assessments. (2) Small PHA - A PHA that is not designated as PHAS or SEMAP troubled, or at risk of being designated as troubled, and that owns or manages less than 250 public

housing units and any number of vouchers where the total combined units exceeds 550.

(3) Housing Choice Voucher (HCV) Only PHA - A PHA that administers more than 550 HCVs, was not designated as troubled in its most recent SEMAP assessment, and does not own or manage public housing.

(4) Standard PHA - A PHA that owns or manages 250 or more public housing units and any number of vouchers where the total combined units exceeds 550, and that was designated as a standard performer in the most recent PHAS or SEMAP assessments.

(5) Troubled PHA - A PHA that achieves an overall PHAS or SEMAP score of less than 60 percent.

(6) Qualified PHA - A PHA with 550 or fewer public housing dwelling units and/or housing choice vouchers combined, and is not PHAS or SEMAP troubled.

A.

PHA Information.

A.1 PHA Name: Grand Rapids Housing Commission PHA Code: mi073

PHA Type: Small High Performer

PHA Plan for Fiscal Year Beginning: July 1, 2021

PHA Inventory (Based on Annual Contributions Contract (ACC) units at time of FY beginning, above)

Number of Public Housing (PH) Units: 212 Number of Housing Choice Vouchers (HCVs): 3,556 Total Combined: 3768

PHA Plan Submission Type: High Performer Revised Annual Submission

Availability of Information. In addition to the items listed in this form, PHAs must have the elements listed below readily available to the public. A PHA must identify the specific location(s) where the proposed PHA Plan, PHA Plan Elements, and all information relevant to the public hearing and proposed PHA Plan are available for inspection by the public. Additionally, the PHA must provide information on how the public may reasonably obtain additional information of the PHA policies contained in the standard Annual Plan, but excluded from their streamlined submissions. At a minimum, PHAs must post PHA Plans, including updates, at each Asset Management Project (AMP) and main office or central office of the PHA. PHAs are strongly encouraged to post complete PHA Plans on their official website. PHAs are also encouraged to provide each resident council a copy of their PHA Plans.

Locations where the public may view and/or obtain copies of the proposed PHA Plan, PHA Plan Elements, and all information relevant to the public hearing and proposed PHA Plan:

1. GRHC Administrative Office, 1420 Fuller Ave. SE, Grand Rapids, MI 2. GRHC web site: www.grhousing.org

3. GRHC asset management project offices:

Adams Park Apartments, 1440 Fuller Ave. SE, Grand Rapids, MI

Campau Commons Apartments, 821 South Division Ave., Grand Rapids, MI Creston Plaza Apartments, 1080 Creston Plaza Dr. NE, Grand Rapids, MI Hope Community, 1024 Ionia SW, Grand Rapids, MI

Leonard Terrace Apartments, 1315 Leonard St. NE, Grand Rapids, MI Mount Mercy Apartments, 1425 Bridge St. NW, Grand Rapids, MI Ransom Tower Apartments, 50 Ransom Ave. NE, Grand Rapids, MI Sheldon Apartments, 1010 Sheldon SE, Grand Rapids, MI

PHA Consortia: (Check box if submitting a Joint PHA Plan and complete the table below)

Participating PHAs PHA Code Program(s) in the Consortia Program(s) not in the Consortia No. of Units in Each Program

PH HCV

Lead PHA:

B. Annual Plan Elements B.1 Revision of PHA Plan Elements.

(a) Have the following PHA Plan elements been revised by the PHA since its last Annual PHA Plan submission:

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B.1

(cont.) Y N_{Statement of Housing Needs and Strategy for Addressing Housing Needs.}

Deconcentration and Other Policies that Govern Eligibility, Selection and Admissions. Financial Resources.

Rent Determination. Homeownership Programs. Safety and Crime Prevention.

Pet Policy.

Substantial Deviation.

Significant Amendment/Modification

(b) The PHA must submit its Deconcentration Policy for Field Office Review. The GRHC’s Deconcentration Policy is provided as Attachment A.

Financial Resources

During 2020 the GRHC sold one three-bedroom Scattered Sites unit through de minimus reduction (431 Grant St. SW). The GRHC is in the process of selling an additional 8 properties from our Scattered Sites (MI073000004) inventory through de minimis reduction; these homes are being sold to low-income households. Proceeds from the sale of these units will be used to fund construction of Antoine Court, a 50-unit development currently under construction. The GRHC is in the process of converting 13 Scattered Sites home ownership units (MI073000004B) and 2 home ownership units that were originally earmarked for sale through a planned Section 32 Homeownership program via HUD’s Section 18-Scattered Sites Asset Repositioning initiative; these will be sold in compliance with that initiative (or similar program that allows for the sale of affordable home ownership units). The homes will be offered to eligible low-income households.

The GRHC plan to convert 188 units at Adams Park Apartments (MI073000001) to Section 8 housing via the Streamlined Voluntary Conversion process authorized under HUD’s Asset Repositioning initiative is proceeding. Resident meetings regarding the plan were held during spring 2019. Required environmental reviews are currently underway; the GRHC will submit an application to convert after the conversion of our Scattered Sites home ownership units is underway.

Capital Fund Program grants to the GRHC will be eliminated for our Scattered Sites and Adams Park Apartments developments. The remaining Capital Fund allocation for each affected development is approximated in the Capital Fund Program Five-Year Action Plan approved on July 1, 2019 (available in the HUD Energy and Performance Information Center (EPIC) Secure System and in this document as Attachment I).

We anticipate any reduction in Capital Fund grants will be offset by funds received through the Section 8 Project-Based program and gained through private investment in the affected developments. By providing the financial stability that will help us to attract private funding, these activities support a 2020-2024 Five-Year PHA Plan maintenance goal to “Maintain the Housing Commission real estate in good condition” as well as a specific community planning goal to “Address a community need cited in the Kent County, City of Grand Rapids and City of Wyoming Regional Consolidated Housing and Community Development Plan by making affordable housing opportunities more available to low-income and very low-income families.”

For more information about the GRHC’s financial resources, please reference the excerpt from the GRHC’s Operating Budget for the fiscal year ending 6/30/21 included as Attachment B.

Revisions to Policies that Govern Eligibility, Selection and Admissions

(Admissions) Section 8 Administrative Plan, Chapter 2, “Fair Housing and Equal Opportunity,” Part II: “Policies Related to Persons with Disabilities,” 2-II.E. “Approval/Denial of a Requested Accommodation” was amended to add the following:

“If the family is denied the accommodation or feels that the alternative suggestions are inadequate, they may request an informal hearing to review GRHC’s decision. If requested by the family, a designee will be allowed to provide information on behalf of the family after receiving written or verifiable permission from the family.

Reasonable accommodation requests will be reviewed by GRHC’s Reasonable Accommodations Committee (new). The committee will be composed of GRHC’s staff members from various GRHC departments. Upon review of the information, the committee may request additional supporting documents to substantiate the family’s request. The request for the additional information will be made in writing and will provide the requestor a ‘reasonable’ amount of time to submit the supporting documents. All decisions made by the committee will be provided to the family in writing.”

(Selection) Section 8 Administrative Plan, Chapter 4, “Applications, Waiting List and Tenant Selection,” Part III, “Selection for HCV Assistance,” 4-III.B. “Selection and HCV Funding Sources,” “Targeted Funding [24 CFR 982.204(e]” has been amended to add the following related to our Mainstream Voucher program:

“The GRHC will offer a preference to non-elderly persons with disabilities. The GRHC will maintain one waiting list for all tenant-based assistance, which includes Mainstream Voucher assistance. When issuing a Mainstream Voucher, the GRHC will choose the Mainstream-eligible family from its tenant-based waiting list first. When all Mainstream-eligible families are served from the GRHC main waiting list, the GRHC will accept referrals through established partnering service agencies that are identified by Memorandums of Understanding (MOUs) which are seeking to house Mainstream-eligible families.” (Eligibility) The GRHC has updated maximum annual income limits to reflect current HUD income limits.

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Grand Rapids Housing Commission Draft, 1/14/21, Page 3 of 6 form HUD-50075-HP (12/2014) B.1

(cont.) (Admissions) The GRHC has revised the Admissions and Continued Occupancy Policy (ACOP) that governs its agency-owned housing developments as follows: 1. Part 7.0 “Taking Applications”: Replaced “Applications are available and will be accepted during regular business hours at all Grand Rapids Housing Commission properties: [list of properties]” with “Online applications are available to the public at grhousing.org for the following properties: [list of properties].”

2. Part 7.0 “Taking Applications”: The following text has been removed from the policy: “Applications may be made in person at the Grand Rapids Housing Commission offices Monday through Friday 8:00 a.m. to 5:00 p.m. Applications will be mailed to interested families upon request.” The ACOP continues to offer a reasonable accommodation for persons with disabilities to receive staff help with completing the application form. (Admissions) During June 2020, the GRHC closed the waiting list for the following developments due to the length of the list and to prevent an untenable wait for housing assistance for applicant households:

Campau Commons Apartments (MI073000003), 92 units, located at 821 South Division Ave., Grand Rapids, MI 49507 (serves families, seniors and people with disabilities).

Creston Plaza Apartments (MI073000002), 100 units, located at 1080 Creston Plaza Dr. NE, Grand Rapids, MI 49505 (serves families, seniors and people with disabilities).

Scattered Sites Program (MI073000004), 20 units located throughout Grand Rapids (serves families, seniors and people with disabilities). We anticipate that the waiting list will continue to be closed throughout FY 2022.

Revisions to Policies that Govern Rent Determination

The GRHC updated the “Fair Market Rents” (FMRs) used in rent calculation to adhere to the rents provided through the HUD Fair Market Rent Documentation System for Federal Fiscal Year 2021. The GRHC updated the utility allowances used in the Section 8 Housing Choice Voucher and Low-Income Public Housing programs in compliance with 24 CFR part 982.517. Current FMR and utility allowance schedules are included as Attachment C. Revision to Policies that Govern Safety

The following section regarding tenant-owned wading pools has been added to the Operating Standards policies for Campau Commons Apartments, Creston Plaza Apartments and our Scattered Sites Program:

“Pools: Small pools are allowed during the daytime, but must be emptied each day by nightfall and whenever not in use. When not in use, pools must be stored properly. Pools are not to be stored on the porch or left in the yard. Pools are limited in size to a height not to exceed 14 inches at the sidewalls. Children in pools must be supervised at all times by an adult at least 18 yeas old.”

B.2 New Activities.

(a) Does the PHA intend to undertake any new activities related to the following in the PHA’s current Fiscal Year: Y N

Hope VI or Choice Neighborhoods. Mixed Finance Modernization or Development. Demolition and/or Disposition.

Conversion of Public Housing to Tenant-Based Assistance.

Conversion of Public Housing to Project-Based Assistance under RAD. Project-Based Vouchers.

Units with Approved Vacancies for Modernization.

Other Capital Grant Programs (i.e., Capital Lund Community Facilities Grants or Emergency Safety and Security Grants).

(b) If any of these activities are planned for the current Fiscal Year, describe the activities. For new demolition activities, describe any public housing development or portion thereof, owned by the PHA for which the PHA has applied or will apply for demolition and/or disposition approval under section 18 of the 1937 Act under the separate demolition/disposition approval process. If using Project-Based Vouchers (PBVs), provide the projected number of project based units and general locations, and describe how project basing would be consistent with the PHA Plan.

Disposition

Project-Based Vouchers Scattered Sites, 23 units:

During 2020 the GRHC sold one bedroom Scattered Sites unit through de minimus reduction (431 Grant St. SW); the GRHC currently has 18 three-bedroom and three 4-three-bedroom single-family Scattered Sites units as well as one vacant lot* that are included in an existing home ownership program. As stated in the “Financial Resources” section of B.1, during the year ahead the Housing Commission plans to dispose of an additional eight Scattered Sites units through de minimis reduction and plans to sell the remaining 15 units under a Section 18-Scattered Sites Asset Repositioning strategy (or similar program that allows for the sale of affordable home ownership units); all units will be sold to eligible low-income households.

*One three-bedroom home ownership unit at 333 Florence Court NE was destroyed by fire and will be sold as a vacant lot. Remaining unit addresses follow. All homes have three bedrooms with the exception of 1545 Broadway Ave. NW, 150 National Ave. NW and 716 Thomas St. SE, which have four bedrooms. Unit size of the homes will remain the same after conversion.

442 Adams St. SE 912 Dunham St. SE 610 Henry Ave. SE 461 Oakdale St. SE 831 Bates St. SE 1128 Fisk St. SE 650 Henry Ave. SE 465 Oakdale St. SE 1545 Broadway Ave. NW 2125 Francis Ave. SE 2144 Horton Ave. SE 21 Shelby St. SE 58 Caledonia St. NE 1659 Godwin Ave. SE 816 Innes St. NE 716 Thomas St. SE 500 Crawford St. SE 1247 Grandville Ave. SW 1127 Kalamazoo Ave. SE 808 Woolsey Ave. SW

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B.2 The units will be offered for sale as follows: 1. Sale to the existing tenant(s) (first right of refusal).

2. Sale to residents who are participants in the GRHC’s Family Self-Sufficiency program. 3. Sale to non-profit organizations that own and/or operate affordable housing programs.

Under the Section 18-Scattered Sites asset repositioning strategy, the current tenant is eligible to receive a Tenant Protection Voucher (TPV) as long as the tenant agrees to allow conversion of the TPV to a Section 8 Project-Based Voucher (PBV). Conversion of the TPV to PBV will make it possible for a resident who meets mortgage eligibility requirements to use the PBV amount toward mortgage payments. If the existing tenant declines to convert the TPV, the tenant will receive relocation assistance under the Uniform Relocation Act to help the tenant move to a comparable safe, sanitary and affordable dwelling unit.

The Conversion Plans that are part of our Asset Repositioning strategy are provided as Attachment D.

Capital Fund Program grants to the GRHC will be eliminated for our Scattered Sites and Adams Park developments. The remaining Capital Fund allocation for each affected development is approximated in the Capital Fund Program Five-Year Action Plan approved on July 1, 2019 (available

in the HUD Energy and Performance Information Center (EPIC) Secure System and here as Attachment I).

We anticipate any reduction in Capital Fund grants will be offset by funds received through the Section 8 Project-Based Program and gained through private investment in the affected developments.

By providing relatively stable funding that will allow the GRHC to attract private investment that would enhance our maintenance efforts, these conversions support the following specific goals in our 2020-2024 Five-Year PHA Plan:

Maintenance: “Maintain the Housing Commission real estate in good condition.”

Community Planning: “Address a community need cited in the Kent County, City of Grand Rapids and City of Wyoming Regional Consolidated Housing and Community Development Plan by making affordable housing opportunities more available to low-income and very low-income families.”

Disposition

Mixed-Finance Modernization or Development (LIHTC)

Conversion of Public Housing to Project-Based Assistance under RAD Project-Based Vouchers:

Adams Park Apartments, 188 units:

In October 2018 the GRHC received HUD RAD Program commitments to support the conversion of Adams Park Apartments (MI073000001). During 2019 an analysis of conversion options offered through the HUD Asset Repositioning initiative revealed that conversion through the Streamlined Voluntary Conversion program would afford a significant funding advantage and the Housing Commission is currently pursuing that option, with the goal of achieving a reliable funding stream that will enable us to attract private financing and undertake major renovation projects. Renovations will utilize both HUD grants and funds leveraged through federal Low-Income Housing Tax Credits.

Streamlined Voluntary Conversion will enable the GRHC to support the 188 units at Adams Park with Section 8 Project-Based Vouchers; current tenants will be offered a Tenant Protection Voucher they can use to relocate to alternate housing, or they will have the choice to remain at Adams Park under the Project-Based program. Tenant informational meetings were held during spring 2019 and the GRHC will submit an application for Streamlined Voluntary Conversion after the Section 18 conversion of our Scattered Sites home ownership units is underway. In the event the GRHC’s application to convert Adams Park through the Streamlined Voluntary Conversion process is denied, the Housing Commission will apply to reinstate the previously approved conversion through the HUD Rental Assistance Demonstration program.

In April 2020 (June 2020 funding round) the GRHC applied to the Low-Income Housing Tax Credit (LIHTC) program administered by MSHDA to obtain the financing needed to undertake required renovations; the GRHC did not receive an award for that funding round and during 2021 will reapply to the 4 percent LIHTC program.

Located at 1440 Fuller Ave. SE in Grand Rapids, Adams Park serves disabled adults and seniors ages 62 or older; Adams Park will continue to serve these populations after Streamlined Voluntary Conversion or conversion under the RAD program. Bedroom distribution at Adams Park is:

• One-bedroom units will remain the same (183 units). • Two-bedroom units will remain the same (5 units).

After conversion, current residents will receive a Tenant Protection Voucher (TPV) and will have the option of using that to rent privately owned property in accordance with regulations governing the TPV program or converting the voucher to the Section 8 Project-Based Voucher program and maintaining their unit at Adams Park. GRHC policies that govern eligibility, selection, admission and occupancy of Adams Park units will adhere to the regulations that govern the Section 8 Project-Based Voucher program.

Conversion will not require tenant relocation, and relocation is not a part of the conversion plan; the complete Adams Park Conversion Plan is included within Attachment D.

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B.2

(cont.) Mixed-Finance Modernization or DevelopmentProject-Based Vouchers: Antoine Court, 50 units:

During 2019 the GRHC was awarded $1.4 million in federal Low-Income Housing Tax Credits (LIHTC) we are leveraging to fund construction of Antoine Court, a $13.5 million Section 8 Project-Based program development tailored to meet the housing and supportive needs of veterans experiencing homelessness, adults who have a disability and seniors ages 62 and older. Additional funding for this development will come from the sale of 9 Scattered Sites units through de minimis reduction.

Currently under construction with a fall 2021 opening planned, the development will include 50 one-bedroom units and will have a preference for chronically homeless disabled veterans. The GRHC plans to provide Section 8 Project-Based Vouchers to support the planned development.

The Antoine Court development supports the following 2020-2024 Five-Year Plan community planning goal: “Address a community need cited in the Kent County, City of Grand Rapids and City of Wyoming Regional Consolidated Housing and Community Development Plan by making affordable housing opportunities more available to low-income and very low-income families.”

Hope Community Rapid Re-Housing Program, 24 units:

The GRHC will seek public and private funding and in-kind donations to support the renovation of our Hope Community Rapid Re-Housing program facilities. The GRHC may elect to seek funding through the LIHTC program.

Hope Community includes 24 units located at 1024 Ionia Avenue SW (12 units), 34/38 Albany St. SW (2 units), 35/37 Shelby St. SW (2 units), 43/47 Canton St. SW (2 units), 106/108 Putnam St. SW (2 units), 1043/1045 Ionia Ave. SW (2 units), and 1106/1108 Ionia Ave. SW (2 units). Hope Community serves homeless women and their minor children and will continue to serve this population after renovation. Bedroom distribution at Hope Community is (and will remain):

• 12 modular units that can be configured for one to three bedrooms. • Two-bedroom duplex units (6 units).

• Three-bedroom duplex units (6 units). Renovation will not require tenant relocation.

Renovation of Hope Community supports the following 2020-2024 Five-Year Plan goals:

Community Planning: “Address a community need cited in the Kent County, City of Grand Rapids and City of Wyoming Regional Consolidated Housing and Community Development Plan by making affordable housing opportunities more available to low-income and very low-income families.”

Maintenance: “Maintain the Housing Commission real estate in good condition.” Additional Activities:

During 2019 the GRHC submitted a letter of interest to HUD indicating our desire to participate in the Moving to Work (MTW) program’s Cohort #2, which focuses on rent reform; we have been invited to submit a full application to the program and plan to do so in the year ahead. The MTW program would afford our agency the flexibility to allocate resources in support of the following 2020-2024 Five-Year Plan community planning objective: “Address a community need cited in the Kent County, City of Grand Rapids and City of Wyoming Regional Consolidated Housing and Community Development Plan by making affordable housing opportunities more available to low-income and very low-income families.”

B.3 Progress Report.

Provide a description of the PHA’s progress in meeting its Mission and Goals in the PHA 5-Year Plan.

The Grand Rapids Housing Commission continues to make significant progress toward accomplishing its stated mission of providing housing assistance and affordable housing opportunities to lower income families, people with disabilities and senior citizens in a manner that is fiscally sound and in ways that support families, neighborhoods and economic self-sufficiency.

Some of the most significant accomplishments of the past year follow; these support Five-Year Plan community planning, maintenance, equal opportunity and resident services goals.

• Provided rental readiness services to low-income households through the Rental Assistance Center the GRHC administered in partnership with the City of Grand Rapids.

• Implemented administration of 57 of 63 Section 8 Project-Based Vouchers committed in support of development projects that are bringing a total of 351 units of affordable housing to our community; we anticipate that the remaining 6 committed vouchers will be put to use in the year ahead.

• Commenced construction of Antoine Court Apartments, a 50-unit development dedicated to serving the housing and supportive needs of veterans experiencing homelessness, people with disabilities and seniors ages 62 and older.

• Completed a total of $526,000 in improvements to 20 Scattered Sites units that were converted through the RAD program during fall 2019. • Made 6 home ownership units that are part of our de minimis reduction initiative available to low-income families; completed the sale of one unit. • Continued a partnership with the Grand Valley State University Kirkhof College of Nursing that provides an on-site health clinic at Mount Mercy Apartments and expanded this partnership to offer behavioral health services; Mount Mercy is a retirement community that serves ages 55 and older. • Continued a partnership with Meals On Wheels Western Michigan to host on-site Dining Centers at four GRHC developments that serve seniors. • Continued Resident Services and Family Self-Sufficiency programs that bring health care, educational, training, employment, social, and nutritional

programs and services to hundreds of low-income households.

• Partnered with Kids’ Food Basket and Grand Rapids Public Schools to provide children’s food services during periods when schools were closed and students did not have access to school meals.

• Partnered with local businesses and faith-based partners to meet resident needs for financial and food assistance during the COVID-19 pandemic.

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B.4 Most Recent Fiscal Year Audit.

(a) Were there any findings in the most recent FY Audit? Y N

Fiscal Year ended 6/30/20 (b) If yes, please describe:

(Unknown, will be updated when audit report is available.)

Other Document and/or Certification Requirements.

C.1 Certification Listing Policies and Programs that the PHA has Revised since Submission of its Last Annual Plan

Form 50077-ST-HCV-HP, Certification of Compliance with PHA Plans and Related Regulations, must be submitted by the PHA as an electronic attachment to the PHA Plan. See Attachment E.

C.2 Civil Rights Certification.

Form 50077-ST-HCV-HP, Certification of Compliance with PHA Plans and Related Regulations, must be submitted by the PHA as an electronic attachment to the PHA Plan. See Attachment F.

C.3 Resident Advisory Board (RAB) Comments.

(a) Did the RAB(s) provide comments to the PHA Plan? Y N

Resident Advisory Board meeting minutes are provided as Attachment G.

C.4 Certification by State or Local Officials.

Included as Attachment H.

D Statement of Capital Improvements._{the Capital Fund Program (CFP).} Required in all years for all PHAs completing this form that administer public housing and receive funding from D.1 Capital Improvements. Include a reference here to the most recent HUD-approved 5-Year Action Plan (HUD-50075.2) and the date that it was

approved by HUD.

Anticipated capital expenditures for fiscal year 2022 are included in the Capital Fund Program Five-Year Action Plan approved on July 1, 2019 (available in the HUD Energy and Performance Information Center (EPIC) Secure System and included here as Attachment I).

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ATTACHMENT A

GRAND RAPIDS HOUSING COMMISSION

DECONCENTRATION POLICY

It is the Grand Rapids Housing Commission’s policy to provide for deconcentration

of poverty and to encourage income mixing by bringing higher-income families into

lower-income developments and lower-income families into higher-income

developments. Toward this end, we will skip families on the waiting list to reach

other families that have a lower or higher income. We will accomplish this in a

uniform and nondiscriminatory manner.

The Grand Rapids Housing Commission will affirmatively market our housing to all

eligible income groups. Lower-income residents will not be steered toward housing

developments in which the average family income is below the median income in

our community, and higher-income residents will not be steered toward

developments in which the average family income is higher than the median income.

Prior to the beginning of each fiscal year, we will analyze the income levels of

families residing in each of our developments, the income levels of census tracts in

which our developments are located and the income levels of the families on the

waiting list. Based on this analysis, we will determine the marketing strategies and

deconcentration incentives to implement.

DECONCENTRATION INCENTIVES

The Grand Rapids Housing Commission may offer one or more incentives to

encourage applicant families whose income classification would help to meet the

deconcentration goals of a particular development.

Various incentives may be used at different times or under different conditions, but

will always be provided in a consistent and nondiscriminatory manner.

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All unit types

FMRs

Housing Choice Voucher Program

Rent Limit and Utility Allowance Chart

2020-2021

0BR tBR 2BR 3BR 4BR 5BR 6BR

739 817 994 1309 1501 1726 1951

Voucher Payment Standard{VPS)

FMR/Utility Allowance 2020

754 833 1014 1335 1531 1761 1990

FMRs: 11/01/2020

VPS (102% ofFMRs): 11/01/2020

Utility Allowance: 11/01/2020

A

TT

ACHM

E

N

T

C

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GRAND RAPIDS HOUSING COMMISSION

HUD ASSET REPOSITIONING INITATIVE

(CONVERSION PLANS)

The Grand Rapids Housing Commission (GRHC) will submit two applications for

conversion of its remaining Low-Income Public Housing (LIPH) developments from

Section 9 funding to Section 8 funding under the U.S. Department of Housing and Urban

Development (HUD) asset repositioning initiative.

The GRHC currently has a total 203 units remaining in its LIPH inventory. The

remaining units comprise two developments:

•

Adams Park Apartments – 188 total units consisting of 183 one-bedroom, and

5 two-bedroom units.

•

Scattered Sites (Homeownership) -15 total units all of which having three

bedrooms.

Actions to Date

The GHRC has initiated the asset repositioning application process with HUD. Initial

contact was made through the Detroit Field Office on July 2, 2019. Subsequent to the

initial contact on July 25, 2019 the GRHC submitted written communication to the HUD

Special Applications Center (SAC) requesting assignment of a Section 18 Expeditor.

Assignment of an Expeditor is a necessary first step in the asset repositioning application

process. The role of the Expeditor is to ensure that the conversion applications submitted

to SAC are complete and ready to be evaluated for approval.

Asset Repositioning Application Submissions

The HUD asset repositioning strategies listed above have differing requirements as it

pertains to the close-out of the GRHC’s remaining LIPH inventory. Therefore it is

necessary for the applications to be submitted in a particular order as the last application

must result in the removal of all remaining LIPH units form the GRHC’s inventory. The

GRHC will therefore submit their asset repositioning applications in the following order:

Development

Application Type

Target Submission

Date

Requires

Close-out

Scattered Sites

Section 18-Scattered Site February 15, 2020

No

Adams Park Apartments

Streamline Voluntary

Conversion

March 15, 2020

Yes

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Scattered Sites (Homeownership) Repositioning Initiative Using HUD’s Section

18-Scattered Sites Asset Strategy

The Grand Rapids Housing Commission (GRHC) will utilize HUD’s Section

18-Scattered Site asset strategy for the conversion of the 15 units which remain in its

Low-Income Public Housing (LIPH) Homeownership program. The Section 18-Scattered Site

strategy application is submitted to the Special Applications Center (SAC) as a

Demolition and Disposition Addendum on HUD Form 52860-A. The GRHC’s

justifications for disposition of these 15 units are:

A.

More Efficient/Effective Low-Income Housing as described in 24 CFR

97.17(b).

B.

Best Interest of PHA and Residents and Consistent with PHA Plan and 1937

Act as described in 24 CFR 970.17(c).

The units will be disposed of by means of “Negotiated Sale at Fair Market Value (FMV)”

to the Grand Rapids Scattered Site Corporation (GRSSC), and instrumentality of the

GRHC. The GRHC has initiated appraisals for each of the 15 units to determine their

FMV and will enter into an Agreement to Sell with GRSSC to purchase the units at

FMV. Subsequent to purchase of the units the GRSSC will begin the process of disposing

of the units through their sale. The GRSSC will undertake the following steps, in the

order presented, for sale of the 15 units:

1.

Sale to the existing tenant(s). The GRSSC will offer the current resident

the opportunity to purchase the unit. It will be the responsibility of the

tenant to obtain a mortgage to purchase the unit. The GRSSC will not

underwrite any of the costs to purchase the property on behalf of the

tenant.

2.

Sale to residents who are participants in the Family Self-Sufficiency (FSS)

Program. Homeownership is one of the end goals of the FSS Program,

therefore those FSS Program participants who have indicated their desire

to purchase a home will be notified of the opportunity to purchase any

available unit which is not purchased by the existing tenant.

3.

Sale to non-profit organizations which own and/or operate affordable

housing programs. (i.e. LINC, ICCF, Dwelling Place, New Development

Corporation, Habitat-for-Humanity, etc.).

Under the Section 18-Scattered Site asset repositioning strategy the current tenant is

eligible to receive a Tenant Protection Voucher (TPV), as long as that tenant is willing to

agree to allow conversion of the TPV to Section 8 Project-Base Voucher (PBV).

Conversion of the TPV to PBV will allow a resident who meets mortgage eligibility

requirements to use the PBV amount to assist in payment of a mortgage.

Should the existing tenant decline to convert the TPV that tenant would receive

relocation assistance under the Uniform Relocation Act (URA) to allow them to move to

a comparable safe, sanitary, and affordable dwelling unit.

(17)

The Section 18-Scattered Site application requires that the GRHC offer the sale of the 15

Scattered Site units to a Resident Organization as defined in 24 CFR 970.13. The GRHC

does not have a Resident Organization as defined by the regulations, but it does have a

Resident Advisory Board (RAB) which is made up of residents from each of its nine

developments. Discussion of the GRHC’s plan to proceed with this asset repositioning

Initiative will be had at the December 10, 2019 RAB meeting.

Additionally, a resolution of support from the Grand Rapids Housing Commission Board

must accompany the application submission package. Submission of this resolution is

contingent upon receipt of a letter of approval from the City of Grand Rapids which

indicates the City has discussed, reviewed and approves of the GRHC’s plan for the

disposition of the 15 units by means of the Section 18-Scattered Site asset repositioning

Strategy. The GRHC will present this resolution of support to the Housing Commission

Board at the first meeting following receipt of the City of Grand Rapids letter of support.

All proceeds realized from the sale of the 15 Scattered Site units will be utilized for the

acquisition of additional affordable housing units, construction of new affordable housing

units, or applied to GRHC programs which further the ability of Section 8 participants to

purchase affordable housing.

Adams Park Apartments Repositioning Initiative Using HUD’s Streamline

Voluntary Conversion Asset Strategy

The GRHC will utilize HUD’s Streamlined Voluntary Conversion (SVC) asset

repositioning strategy for the conversion of the 188 units at Adams Park Apartments

which will remain following approval of the Section 18-Scattered Sites application.

HUD’s SVC asset strategy

requires the GRHC to close-out its Low-Income Public

Housing

portfolio upon completion of this conversion. The SVC asset strategy

application is submitted to SAC on HUD Form 52860-E.

As part of the application process the GRHC must determine how the public housing

project will be used after conversion. Post conversion the GRHC will utilize Adams Park

Apartments as “assisted housing” with Section 8 Project-Based Voucher (PBV) subsidy.

Adams Park Apartments will be disposed of by means of sale to the Grand Rapids

Scattered Site Corporation (GRSSC), and instrumentality of the GRHC. The GRHC has

initiated an appraisal for Adams Park Apartments to determine the Current Value “As Is”,

and will enter into an Agreement to Sell with GRSSC to purchase the units at FMV.

Under the SVC asset repositioning strategy all current Adams Park Apartment tenants

will be eligible to receive a Tenant Protection Voucher (TPV). Unlike the Section

18-Scattered Site application where the tenant must convert the TPV to PBV, the tenant has

the option to keep the TPV and utilize it to find suitable safe, sanitary and affordable

housing outside of Adams Park Apartments. If the tenant desires to remain at Adams

Park Apartments they must voluntarily allow the GRHC to convert the TPV to Section 8

Project-Base Voucher (PBV).

(18)

Should the existing tenant decline to convert the TPV that tenant would receive

relocation assistance under the Uniform Relocation Act (URA) to allow them to move to

a comparable safe, sanitary, and affordable dwelling unit.

The GRHC is not required to offer to sell the development to the Resident Organization,

but a resolution of support from the Grand Rapids Housing Commission Board must

accompany the application submission package. It is the GRHC’s intent to submit this

resolution along with the Section 18-Scattered Site asset repositioning resolution.

Impact of HUD Asset Repositioning Imitatives on City of Grand Rapids Affordable

Housing Objectives

The HUD asset repositioning initiative will positively impact the availability of

Affordable (Workforce) Housing within the City of Grand Rapids as a result of the

change from Section 9 funding, which is subject to the annual congressional

appropriations process, to Section 8 program funding. Historically Congress has

appropriated less funding than what was requested by HUD for each annual fiscal year.

This consistent underfunding of Section 9 has resulted in a nationwide backlog of

deferred maintenance that is estimated to be $26 billion dollars as of October 30, 2019.

Congress, to date, has consistently provided full funding to the Section 8 program. Also

Section 8 Project Based Voucher (PBV) contracts are issued for twenty (20) year terms

thereby creating stability in funding over a long term period. This difference makes it

possible for the GRHC to leverage the Section 8 contract and thereby raise financial

capital which can be utilized to make repairs and improvements to the GRHC’s existing

affordable housing portfolio. This change in funding source will also result in long term

funding sustainability and thereby positively impact the GRHC’s ability to provide

affordable housing within the City of Grand Rapids.

Impact of HUD Asset Repositioning Imitatives on Tenants

The HUD asset repositioning initiatives include provisions for the GRHC to apply for

Tenant Protection Vouchers (TPVs) which give protection to the existing tenants and

provide them the ability to remain in their unit after the completion of the “disposition”

action or utilized the TPV to procure another affordable housing dwelling if they so

desire. In no case will the rent which the tenant pays exceed 30% of their eligible income.

Consistency with the Grand Rapids Housing Commission Annual and Five-Year

Plans

The HUD asset repositioning initiatives are consistent with and a part of the GRHC’s

Annual and Five-Year Plans. Additionally completion of the proposed HUD asset

repositioning objectives aligns with the GHRC’s long-term objective of becoming a

Moving-to-Work (MTW) Public Housing Authority (PHA). Transforming to a MTW

PHA will provide increased flexibility to the GRHC in the use of its funding and improve

the long term financial position of the organization.

(19)

GRHC Tenant Notification and Resident Advisory Board Consultation

The GRHC has held an initial meeting with the Adams Park Apartments and Scattered

Sites (Homeownership) tenants. There were two meetings held at the Adams Park

Apartments Community Room on Thursday November 7, 2019 at 10:00 am and 6:00 pm

respectively. At these meetings the attendees were informed of the GHRC’s intention to

submit both the Section 18-Scattered Site and Streamlined Voluntary Conversion asset

repositioning applications. Special emphasis was given to the discussion of Tenant

Protection Vouchers and their use, according to whether the tenant currently resides at

Adams Park Apartment or in Scattered Sites. Tenants were asked to provide feedback on

the GRHC’s asset repositioning plan. All of the tenant questions have been recorded in

writing, as well as the GRHC’s responses to the tenant’s questions. Copies of the meeting

agenda, sign-in sheets, questions, and answers will be included in the asset repositioning

applications.

On Tuesday December 10, 2019 the GRHC discussed the HUD asset repositioning plan

with the Resident Advisory Board (RAD).

Request for Letters of Support from the City of Grand Rapids

The Grand Rapids Housing Commission is requesting Letters of Support from the City of

Grand Rapids for the two asset repositioning initiatives which have been outlined above.

Because there are two separate and distinct repositioning initiatives which the Grand

Rapids Housing Commission will pursue, and because each initiative requires its own

application to the HUD Special Applications Center, and lastly because the Adams Park

repositioning initiative will require close-out of all of the remaining Low-Income Public

Housing operated by the Grand Rapids Housing Commission separate Letters of Support

are required.

(20)

Page 1 of 2 formHUD-50077-ST-HCV-HP(12/2014)

Certifications of Compliance with

PHA Plans and Related Regulations

(Standard, Troubled, HCV-Only, and

High Performer PHAs)

Office of Public and Indian Housing

OMB No. 2577-0226

Expires 02/29/2016

PHA Certifications of Compliance with the PHA Plan and Related Regulations including

Required Civil Rights Certifications

Acting on behalf of the Board of Commissioners of the Public Housing Agency (PHA) listed below, as its Chairman or other

authorized PHA official if there is no Board of Commissioners, I approve the submission of the___ 5-Year and/or___ Annual PHA

Plan for the PHA fiscal year beginning ________, hereinafter referred to as” the Plan”, of which this document is a part and make

the following certifications and agreements with the Department of Housing and Urban Development (HUD) in connection with the

submission of the Plan and implementation thereof:

1.

The Plan is consistent with the applicable comprehensive housing affordability strategy (or any plan incorporating such

strategy) for the jurisdiction in which the PHA is located.

2.

The Plan contains a certification by the appropriate State or local officials that the Plan is consistent with the applicable

Consolidated Plan, which includes a certification that requires the preparation of an Analysis of Impediments to Fair Housing

Choice, for the PHA's jurisdiction and a description of the manner in which the PHA Plan is consistent with the applicable

Consolidated Plan.

3.

The PHA has established a Resident Advisory Board or Boards, the membership of which represents the residents assisted by

the PHA, consulted with this Resident Advisory Board or Boards in developing the Plan, including any changes or revisions

to the policies and programs identified in the Plan before they were implemented, and considered the recommendations of the

RAB (24 CFR 903.13). The PHA has included in the Plan submission a copy of the recommendations made by the Resident

Advisory Board or Boards and a description of the manner in which the Plan addresses these recommendations.

4.

The PHA made the proposed Plan and all information relevant to the public hearing available for public inspection at least 45

days before the hearing, published a notice that a hearing would be held and conducted a hearing to discuss the Plan and

invited public comment.

5.

The PHA certifies that it will carry out the Plan in conformity with Title VI of the Civil Rights Act of 1964, the Fair Housing

Act, section 504 of the Rehabilitation Act of 1973, and title II of the Americans with Disabilities Act of 1990.

6.

The PHA will affirmatively further fair housing by examining their programs or proposed programs, identifying any

impediments to fair housing choice within those programs, addressing those impediments in a reasonable fashion in view of

the resources available and work with local jurisdictions to implement any of the jurisdiction's initiatives to affirmatively

further fair housing that require the PHA's involvement and by maintaining records reflecting these analyses and actions.

7.

For PHA Plans that includes a policy for site based waiting lists:



The PHA regularly submits required data to HUD's 50058 PIC/IMS Module in an accurate, complete and timely manner

(as specified in PIH Notice 2010-25);



The system of site-based waiting lists provides for full disclosure to each applicant in the selection of the development in

which to reside, including basic information about available sites; and an estimate of the period of time the applicant

would likely have to wait to be admitted to units of different sizes and types at each site;



Adoption of a site-based waiting list would not violate any court order or settlement agreement or be inconsistent with a

pending complaint brought by HUD;



The PHA shall take reasonable measures to assure that such a waiting list is consistent with affirmatively furthering fair

housing;



The PHA provides for review of its site-based waiting list policy to determine if it is consistent with civil rights laws and

certifications, as specified in 24 CFR part 903.7(c)(1).

8.

The PHA will comply with the prohibitions against discrimination on the basis of age pursuant to the Age Discrimination Act

of 1975.

9.

The PHA will comply with the Architectural Barriers Act of 1968 and 24 CFR Part 41, Policies and Procedures for the

Enforcement of Standards and Requirements for Accessibility by the Physically Handicapped.

10. The PHA will comply with the requirements of section 3 of the Housing and Urban Development Act of 1968, Employment

Opportunities for Low-or Very-Low Income Persons, and with its implementing regulation at 24 CFR Part 135.

11. The PHA will comply with acquisition and relocation requirements of the Uniform Relocation Assistance and Real Property

Acquisition Policies Act of 1970 and implementing regulations at 49 CFR Part 24 as applicable.

ATTACHMENT E

7/1/2021

(21)

___________________________________________________________________________________________________________

Page 2 of 2 formHUD-50077-ST-HCV-HP(12/2014)

12. The PHA will take appropriate affirmative action to award contracts to minority and women's business enterprises under 24

CFR 5.105(a).

13. The PHA will provide the responsible entity or HUD any documentation that the responsible entity or HUD needs to carry

out its review under the National Environmental Policy Act and other related authorities in accordance with 24 CFR Part 58

or Part 50, respectively.

14. With respect to public housing the PHA will comply with Davis-Bacon or HUD determined wage rate requirements under

Section 12 of the United States Housing Act of 1937 and the Contract Work Hours and Safety Standards Act.

15. The PHA will keep records in accordance with 24 CFR 85.20 and facilitate an effective audit to determine compliance with

program requirements.

16. The PHA will comply with the Lead-Based Paint Poisoning Prevention Act

,

the Residential Lead-Based Paint Hazard

Reduction Act of 1992, and 24 CFR Part 35.

17. The PHA will comply with the policies, guidelines, and requirements of OMB Circular No. A-87 (Cost Principles for State,

Local and Indian Tribal Governments), 2 CFR Part 225, and 24 CFR Part 85 (Administrative Requirements for Grants and

Cooperative Agreements to State, Local and Federally Recognized Indian Tribal Governments).

18. The PHA will undertake only activities and programs covered by the Plan in a manner consistent with its Plan and will utilize

covered grant funds only for activities that are approvable under the regulations and included in its Plan.

19. All attachments to the Plan have been and will continue to be available at all times and all locations that the PHA Plan is

available for public inspection. All required supporting documents have been made available for public inspection along with

the Plan and additional requirements at the primary business office of the PHA and at all other times and locations identified

by the PHA in its PHA Plan and will continue to be made available at least at the primary business office of the PHA.

22. The PHA certifies that it is in compliance with applicable Federal statutory and regulatory requirements, including the

Declaration of Trust(s).

_________________________________________

__________________________________________

PHA Name

PHA Number/HA Code

_____ Annual PHA Plan for Fiscal Year 20____

_____ 5-Year PHA Plan for Fiscal Years 20____ - 20____

I hereby certify that all the information stated herein, as well as any information provided in the accompaniment herewith, is true and accurate.Warning: HUD will prosecute false claims and statements. Conviction may result in criminal and/or civil penalties. (18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802).

_______________________________________________________________________________________________________________________________________

Name of Authorized Official Title

Signature Date

Grand Rapids Housing Commission

MI073

X

22

(22)

________________________________________________________________________________________________________________________ Previous version is obsolete Page 1 of 1 formHUD-50077-CR(2/2013)

Civil Rights Certification

(Qualified PHAs)

OMB Approval No. 2577-0226

Expires 02/29/2016

Civil Rights Certification

Annual Certification and Board Resolution

Acting on behalf of the Board of Commissioners of the Public Housing Agency (PHA) listed below, as its Chairman or other

authorized PHA official, I approve the submission of the 5-Year PHA Plan for the PHA of which this document is a part, and make the

following certification and agreements with the Department of Housing and Urban Development (HUD) in connection with the

submission of the public housing program of the agency and implementation thereof:

The PHA certifies that it will carry out the public housing program of the agency in conformity with title VI of

the Civil Rights Act of 1964, the Fair Housing Act, section 504 of the Rehabilitation Act of 1973, and title II of

the Americans with Disabilities Act of 1990, and will affirmatively further fair housing by examining their

programs or proposed programs, identifying any impediments to fair housing choice within those program,

addressing those impediments in a reasonable fashion in view of the resources available and working with local

jurisdictions to implement any of the jurisdiction’s initiatives to affirmatively further fair housing that require

the PHA’s involvement and by maintaining records reflecting these analyses and actions.

_________________________________________

__________________________________________

PHA Name

PHA Number/HA Code

I hereby certify that all the information stated herein, as well as any information provided in the accompaniment herewith, is true and accurate.Warning: HUD will prosecute false claims and statements. Conviction may result in criminal and/or civil penalties. (18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802)

Signature Date

ATTACHMENT F

Grand Rapids Housing Commission

MI073

(23)

ATTACHMENT G

RESIDENT ADVISORY BOARD

MEETING MINUTES

(24)

Page 1 of 1

form

HUD-50077-SL

(12/2014)

Certification by State or Local

U. S Department of Housing and Urban Development

Official of PHA Plans Consistency

with the Consolidated Plan or

OMB No. 2577-0226

State Consolidated Plan

Expires 2/29/2016

(All PHAs)

Certification by State or Local Official of PHA Plans

Consistency with the Consolidated Plan or State Consolidated Plan

I, _________________________________, the _____________________________________

Official’s Name

Official’s Title

certify that the 5-Year PHA Plan and/or Annual PHA Plan of the

_________________________________________________________________________________

PHA Name

is consistent with the Consolidated Plan or State Consolidated Plan and the Analysis of

Impediments (AI) to Fair Housing Choice of the

______________________________________________________________________________

Local Jurisdiction Name

pursuant to 24 CFR Part 91.

Provide a description of how the PHA Plan is consistent with the Consolidated Plan or State

Consolidated Plan and the AI.

I hereby certify that all the information stated herein, as well as any information provided in the accompaniment herewith, is true and accurate.Warning:HUD will prosecute false claims and statements. Conviction may result in criminal and/or civil penalties. (18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802)

__________________________________________________________________________________________________________________________________

Signature Date

Mark Washington

City Manager

Grand Rapids Housing Commission

City of Grand Rapids

The Grand Rapids Housing Commission 2021 Annual Agency Plan supports the affordable housing needs

detailed in the Kent County, City of Grand Rapids and City of Wyoming Regional Consolidated Housing and

Community Development Plan.

Bobbie Butler

City Manager

(25)

Capital Fund Program—Five-Year Action Plan

U.S. Department of Housing and Urban Development Office of Public and Indian Housing

OMB No. 2577-0226 Expires 08/30/2011

Page 1 of 4 form HUD-50075.2 (4/2008)

Part I: Summary

PHA Grand Rapids Housing Commission/MI073

Original 5-Year Plan

Revision No:

Locality (

Grand Rapids, MI

)

Original 5-Year Plan Revision No: _________

A. Development Number and Name: Work Statement for Year 1

FFY 2020

Work Statement for Year 2

FFY 2021 Work Statement for Year 3 FFY 2022 Work Statement for Year 4 FFY 2023 Work Statement for Year 5 FFY 2024 B. Physical Improvements

Subtotal Annual Statement

C. Management Improvements D. PHA-Wide Non-dwelling

Structures and Equipment

E. Administration

$91,864

$85,077

F. Other

G. Operations

$367,461

$340,308

H. Demolition I. Development

J. Capital Fund Financing – Debt Service

K. Total CFP Funds L. Total Non-CFP Funds

M. Grand Total

$459,325

$425,385

$0

ATTACHMENT I

(26)

OMB No. 2577-0226 Expires 4/30/2011

Page 2 of 4 form HUD-50075.2 (4/2008)

Part I: Summary (Continuation)

PHA Grand Rapids Housing Commission/MI073

Original 5-Year Plan

Revision No:

Locality (

Grand Rapids, MI

)

Original 5-Year Plan Revision No: _________

Development Number and

Name: Work Statement for Year 1 FFY 2020

FFY 2021 Work Statement for Year 3 FFY 2022 Work Statement for Year 4 FFY 2023 Work Statement for Year 5 FFY 2024 Annual Statement

(27)

Capital Fund Program—Five-Year Action Plan

OMB No. 2577-0226 Expires 4/30/2011

Page 3 of 4 form HUD-50075.2 (4/2008)

Part II: Supporting Pages – Physical Needs Work Statement(s)

Work

Statement for

Year 1 FFY

2020

FFY 2021

FFY 2022

Development Number/Name

General Description of Major Work

Part II: Supporting Pages – Physical Needs Work Statement(s)

Work

Statement for

Year 1 FFY

2020

FFY 2023

FFY 2024

General Description of Major Work Categories

Quantity Estimated Cost