Louisville/Jefferson County Metro Government

2019 Action Plan - Amended July 1, 2019 – June 30, 2020

Amendment Submitted May 21, 2020 Original Submitted June 12, 2019

Prepared by Develop Louisville, Office of Housing and Community Development Jeff O’Brien, Director, Develop Louisville Louisville/Jefferson County Metro Government

Greg Fischer Mayor

Louisville Metro Council Members 2019

District 1 Jessica Green District 14 Cindi Fowler

District 2 Barbara Shanklin District 15 Kevin Triplett

District 3 Keisha Dorsey District 16 Scott Reed

District 4 Barbara Sexton-Smith District 17 Markus Winkler

District 5 Donna Purvis District 18 Marilyn Parker

District 6 David James District 19 Anthony Piagentini

District 7 Paula McCraney District 20 Stuart Benson

District 8 Brandon Coan District 21 Nicole George

District 9 Bill Hollander District 22 Robin Engel

District 10 Pat Mulvihill District 23 James Peden

District 11 Kevin Kramer District 24 Madonna Flood

District 12 Rick Blackwell District 25 David Yates

District 13 Mark Fox District 26 Brent Ackerson Louisville Metro Government Program Year 2019 Action Plan

Action Plan

AP-05 Executive Summary ...... 1 PR-05 Lead and Responsible Agencies ...... 6 AP-10 Consultation ...... 8 AP-12 Participation ...... 20 AP-15 Expected Resources ...... 26 AP-20 Annual Goals and Objectives ...... 39 AP-35 Projects ...... 45 AP-50 Geographic Distribution ...... 74 AP-55 Affordable Housing ...... 76 AP-60 Public Housing ...... 78 AP-65 Homeless and Other Special Needs Activities ...... 84 AP-70 HOPWA Goals ...... 90 AP-75 Barriers to Affordable Housing ...... 91 AP-85 Other Actions ...... 95 AP-90 Program Specific Requirements ...... 102

Appendices

Appendix A: Draft Program Year 2019 Action Plan Budgets ...... 112 Appendix B: Public Comments Received at Public Hearings Held February 25, 2019 and May 23, 2019 with Develop Louisville’s Response ...... 117 Appendix C: Affidavit of Publication of for Public Hearings Held February 25, 2019 and May 23, 2019 ...... 124 Appendix D: Summary of Louisville Metro Department of Resilience & Community Services 2018 Needs Assessment Survey Results ...... 129 Appendix E: Louisville Metro Department of Resilience & Community Services 2019 Subrecipient Awards ...... 136 Appendix F: Russell Neighborhood Revitalization Strategy Area (NRSA) Map ...... 143 2019 Action Plan Amendment: CARES Act COVID-19 Response ...... 153

Louisville-Jefferson County Metro Government Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

The purpose of this Substantial Amendment to Louisville Metro Government's PY19 Action Plan is to incorporate new Coronavirus Aid, Relied and Economic Security Act (CARES Act) funding. LMG received CARES Act entitlement funding under CDBG, ESG, and HOPWA. Several projects were added to the Projects section (AP-35) to reflect new activities to be undertaken with this funding, the Anticipated Resources section (AP-15) was amended to reflect the new entitlement amounts, and the Participation section (AP-12) describes public engagement. Additionally, all public comments received, as well as the updated Citizen Participation Plan, are included in the Public Comments attachment on this AP-26 Administration screen.

Executive Summary AP-05 Executive Summary - 24 CFR 91.200(c), 91.220(b) 1. Introduction

Louisville-Jefferson County Metro Government (Louisville Metro) is a consolidated city/county government with an estimated population of 759,724 (2016 American Community Survey 5-year estimate). Louisville Metro participates in four U.S. Department of Housing and Urban Development (HUD) entitlement grant programs: Community Development Block Grant (CDBG), HOME Investment Partnerships (HOME), Emergency Solutions Grant (ESG), and Housing Opportunities for Persons with AIDS (HOPWA).

Louisville-Jefferson County Metro Government 1 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended) • CDBG funds are used to contribute to the development of viable urban communities by providing decent housing, suitable living environments, and expanded economic opportunities, principally for low- and moderate-income persons. • HOME funds are used for a wide range of activities including acquiring, developing, and/or rehabilitating affordable housing for rent or homeownership or providing direct rental assistance to low-income people. • ESG funds are used to: engage homeless individuals and families living on the street; improve the number and quality of emergency shelters for homeless individuals and families; operate shelters; provide essential services to shelter residents; rapidly re-house homeless individuals and families; and prevent homelessness. • HOPWA funds provide housing assistance and related supportive services for low-income persons living with HIV/AIDS and their families.

HUD requires that local jurisdictions receiving entitlement funds complete a Consolidated Plan every three to five years that describes the jurisdiction’s affordable housing and community development priorities and multiyear goals, based on a needs assessment and market condition analysis. The purpose of the Consolidated Plan is to provide guidance for decisions regarding the use of these federal resources. Louisville Metro’s current Consolidated Plan was approved by HUD on July 22, 2015 and covers the period from July 1, 2015 to June 30, 2020.

The Consolidated Plan is implemented through annual Action Plans, which provide a summary of the actions, activities, and the specific federal and non-federal resources that will be used each year to address the priority needs and specific goals identified in the Consolidated Plan. The Program Year 2019 Action Plan covers the period from July 1, 2019 to June 30, 2020.

2. Summarize the objectives and outcomes identified in the Plan

This could be a restatement of items or a table listed elsewhere in the plan or a reference to another location. It may also contain any essential items from the housing and homeless needs assessment, the housing market analysis or the strategic plan.

Through community and stakeholder input and completion of a needs assessment and a market analysis, Louisville Metro identified five priority needs and eighteen goals for the five-year Consolidated Plan period. Goals and associated needs are listed below. Priority needs are described in detail in section SP-25 of the Consolidated Plan and goals, including expected 5-year outcomes, are described in detail in section SP-45 of the Consolidated Plan. Expected annual outcomes for Program Year 2019 are described in section AP-20 of this Action Plan.

Louisville-Jefferson County Metro Government 2 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Goal Associated Need Expand Homeownership Opportunities Increase and Retain Affordable Units Improve Existing Owner-Occupied Units Affordable Housing Provide Rental Assistance Provide Homeownership Counseling Services Clearance of Vacant or Abandoned Structures Non-Housing Community Provide Improvements to Public Facilities Development Provide Rapid Re-Housing for Diversion Provide Rental Assistance Provide Homeless Prevention Services Homeless Services Provide Street Outreach for Homeless Citizens Shelter Operations & Case Management for Homeless Citizens Micro-Enterprise Technical Assistance Small Business Micro-Enterprise Development Development Small Business Development Remove Barriers for Persons with Disabilities Provide TBRA to Persons with HIV/AIDS Non-Homeless Provide Supportive Services to Persons with HIV/AIDS Special Needs Provide STRMU to Persons with HIV/AIDS

3. Evaluation of past performance

This is an evaluation of past performance that helped lead the grantee to choose its goals or projects.

Louisville Metro’s most recently submitted Consolidated Annual Performance and Evaluation Report (CAPER) covered Program Year 2017 (the period from July 1, 2017 to June 30, 2018), the third year of the 2015-2019 Consolidated Plan period. Metro reported the following accomplishments:

Housing:

• 36 households received down payment assistance; • 879 persons received homeownership education and counseling services; • 308 households were provided with home repairs and/or rehabilitation; • The development of 12 new multi-family units are underway which will provide which will create 1552 units of affordable and safe housing.

Economic Development:

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• 4 businesses received loans through the Microenterprise Assistance Program; • 229 persons received business-related training or technical assistance.

Community Development:

• 156 blighted structures were demolished; • Streetscape improvements were begun on sidewalks and streets, including accessibility modifications and street paving; Continued progress was made on multiple park improvements. Park improvements in the Shawnee Outdoor Recreation Area, Russell Lee Park, Riverside Gardens Park, and Huston Quinn Park have since been completed; The expansion of YouthBuild Louisville’s campus continued and is near completion.

Homelessness:

• 12 programs at 10 non-profits (plus one administered through the Office of Resilience and Community Services) received ESG assistance for street outreach, prevention, shelter operations, and/or essential services and served 1662 persons. • 2658 homeless persons used CDBG supportive services

Non-Homeless Special Needs:

• 34 households received HOME TBRA • 41 households received HOPWA TBRA • 52 households received HOPWA STRMU assistance • 135 households received ramp construction or barrier removal services

4. Summary of Citizen Participation Process and consultation process

Summary from citizen participation section of plan.

HUD requires entitlement jurisdictions to provide opportunities for citizen participation in developing the annual Action Plan. Citizen participation efforts that have guided or will guide the development of the Program Year 2019 Action Plan include the annual Community Needs Assessment conducted by the Louisville Metro Office of Resilience and Community Services (a summary of which is found in Appendix D), stakeholder consultations, two public hearings (held on February 25, 2019 and May 23, 2019) and a 30-day public comment period for the draft Action Plan (May 8 to June 7, 2019). The consultation and citizen participation process is described in detail in sections AP-10 and AP-12 of this plan.

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5. Summary of public comments

This could be a brief narrative summary or reference an attached document from the Citizen Participation section of the Con Plan.

The public comment period for the draft Program Year 2019 Action Plan commenced on May 8, 2019 and ended on June 7, 2019. Two comments received at the first public hearing held on February 25, 2019, are included in this Program Year 2019 Action Plan as Appendix B, with Develop Louisville’s responses to each.

6. Summary of comments or views not accepted and the reasons for not accepting them

All comments received at public hearings or submitted during the comment period were accepted by Develop Louisville. All comments with Develop Louisville’s responses are included as an appendix to the Program Year 2019 Action Plan.

7. Summary

Louisville Metro’s Program Year 2019 Action Plan identifies goals, activities, and expected outcomes for the Program Year as well as financial resources that will be utilized. Louisville Metro received notification of its Program Year 2019 entitlement fund allocation amounts on April 12, 2019. They are as follows:

Louisville Metro Program Year 2019 Entitlement Fund Allocations

Totaling $15,930,258 Entitlement Fund Amount CDBG $11,190,723 HOME $2,932,633 ESG $950,821 HOPWA $856,081

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PR-05 Lead & Responsible Agencies – 91.200(b) 1. Agency/entity responsible for preparing/administering the Consolidated Plan

Describe the agency/entity responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source.

Agency Role Name Department/Agency

CDBG Administrator LOUISVILLE - JEFFERSON COUNTY METRO Develop Louisville GOVT HOPWA Administrator LOUISVILLE - JEFFERSON COUNTY METRO Office of Resilience and Community Services GOVT HOME Administrator LOUISVILLE - JEFFERSON COUNTY METRO Develop Louisville GOVT ESG Administrator LOUISVILLE - JEFFERSON COUNTY METRO Office of Resilience and Community Services GOVT Table 1 – Responsible Agencies

Narrative (optional)

Develop Louisville, through its Office of Housing and Community Development (OHCD), is the lead agency for preparing, administering, monitoring, and reporting on Louisville Metro Government’s Consolidated Plan and annual Action Plan. Develop Louisville was created in 2014 to focus on the full range of land development activities, including planning and design, vacant property initiatives, advanced planning, housing and community development programs, neighborhood redevelopment strategies, and clean and green sustainable development partnerships. Its mission is to lead an integrated approach to development that optimizes the vitality and the sustainability of the entire community.

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Consolidated Plan Public Contact Information

Questions or comments regarding the Program Year 2019 Action Plan may be directed to:

Michelle Rodgers, Grants Contract Coordinator Develop Louisville, Office of Housing and Community Development 444 S. 5th Street, 5th Floor [email protected], 502-574-4608

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AP-10 Consultation – 91.100, 91.200(b), 91.215(l) 1. Introduction

Louisville Metro considered input from various organizations, groups, and agencies in developing its Program Year 2019 Action Plan, including nonprofit service providers, Metro agencies, the Louisville Continuum of Care, neighborhood organizations, and others. In addition to these stakeholder consultations, Metro reviewed a variety of relevant plans when preparing the Action Plan in order to ensure alignment of proposed goals with existing plans where applicable.

Provide a concise summary of the jurisdiction’s activities to enhance coordination between public and assisted housing providers and private and governmental health, mental health and service agencies (91.215(l))

Many of Louisville's service agencies work in collaboration to address core issues surrounding poverty including financial security, education, job training, employment opportunities, safe and affordable housing, and access to medical and mental health services. As many service providers are struggling with diminishing funding, collaboration and collective impact models have and will likely continue to become increasingly important to meet the needs of Louisville’s low to moderate income residents. Louisville Metro’s Office of Resilience and Community Services (RCS) serves as the lead coordination agency for non-profit organization collaboration as it relates to local funding resources for homeless prevention, poverty reduction, and related services.

RCS awards nearly 3 million annually to local non-profits for homeless prevention, emergency shelter, street outreach, and case management services through ESG, HOPWA, CDBG, and Continuum of Care (CoC) funds. RCS awards additional non-federal funds to nonprofit service providers through Metro’s External Agency Fund.

RCS is heavily involved in the Louisville Continuum of Care, which is coordinated through the Coalition for the Homeless. RCS is represented on the CoC Board and Advisory Board, at monthly CoC meetings, and holds monthly coordination meetings with the Coalition. Additionally, Louisville Metro Housing Authority (LMHA) and the Develop Louisville Office of Housing & Community Development (OHCD) are represented on the CoC Board and Advisory Board.

RCS is the Community Action Agency for Louisville/Jefferson County. The Executive Director of the Louisville Metro Housing Authority (LMHA) serves on the Community Action Board due to the significant role LMHA plays in the lives of many Community Services clients. This allows better coordination of efforts between RCS and LMHA.

LMHA's position on the RCS Community Action Board also proves beneficial in relation to self-sufficiency programs. RCS goal is to be a one-stop shop for addressing multiple barriers to self-sufficiency by assessing a family or individual’s situation and linking them to departmental and community services Louisville-Jefferson County Metro Government 8 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

and resources. LMHA has a self-sufficiency program which provides intensive case management services to residents living in public or subsidized housing to help them accomplish long-term goals and develop job skills, parenting skills, and knowledge about income management and homeownership. RCS leverages LMHAs position on the RCS Community Action Board as a resource for knowledge, experience, and best practices for self-sufficiency services. RCS provides housing supports to agency clients engaged in case-managed programs as necessary to minimize this burden on households working towards self- sufficiency.

RCS supports the work of Family Health Centers Phoenix Health Care for the Homeless and Centerstone (formerly Seven Counties Services) to provide outreach, medical services, and mental health services to homeless individuals and families, and of Family Health Centers to provide medical care to patients regardless of their ability to pay for services.

Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans, and unaccompanied youth) and persons at risk of homelessness.

Louisville Metro Government is an integral partner in the Louisville/Jefferson County Continuum of Care (CoC). Metro works with the CoC by providing leadership in collaboration with the collaborative applicant, Louisville Coalition for the Homeless; by conducting a CoC-funded Permanent Supportive Housing program; and by supporting other CoC partner agencies through additional funding.

Metro’s ongoing collaboration with the CoC is primarily conducted through the Office of Resilience and Community Services (RCS). RCS has representation on the Louisville/Jefferson County CoC Advisory Board which operates as a steering committee for CoC, Chronic Homelessness Subcommittee, CoC Forms Development Committee, CoC Homeless Consumer Participation Task Force, and CoC Move-Up Voucher Committee.

RCS provides permanent supportive housing to over two-hundred and seventy-three households that are funded through the CoC collaborative application. RCS fully participates in HMIS, which is managed by the Coalition for the Homeless. Additionally, RCS supports the collaborative applicant and other CoC agencies through separate grant funding. In Program Year 2018, RCS provided CoC agencies with $2,478,691 in entitlement funds grants, including ESG, HOPWA, and CDBG funds. CoC agencies also received $525,500 in Metro general fund allocations in Program Year 2018. $80,000 of the CDBG funding supports the Coalition for the Homeless’ HMIS Administration and Continuum of Care coordination.

Louisville Metro Department of Corrections (LMDOC) has partnered with the CoC since early 2014. This partnership has brought an institutional discharge perspective to the Louisville/Jefferson County CoC’s decision-making process. LMDOC created “FACES”, a program that ensures that no homeless persons are released to the streets, that all discharged persons leave with a backpack of resources, and that all Louisville-Jefferson County Metro Government 9 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

discharged persons receive prescriptions for all medications they receive. LMDOC is also working with health care organizations, including Passport and WellCare, to identify homeless super-utilizers to target for supportive housing. In addition, Centerstone has created a program called the Living Room. Centerstone has partnered with Louisville Metro Police Department and Health Care providers to divert people from going to jail and away from emergency rooms or inpatient hospitalizations. It gives the person in crisis a safe space where they can connect to resources they need. The person can stay there for 23 hours. Since their inception in December 2017, they have served 2,500 guests.

In 2014, Louisville Mayor Greg Fischer signed the Mayor’s Challenge to End Veteran Homelessness pledge and appointed the Metro Community Services (now RCS) Director to oversee the ending veteran homelessness work group. Since fall 2014, Louisville has made steady progress in ending veteran homelessness by improving coordination between the CoC and Veterans’ Administration to utilize Veterans Affairs Supportive Housing (VASH), Housing Choice Vouchers, Supportive Services for Veteran Families (SSVF), and CoC resources. In November 2015, Mayor Fischer announced that the number of homeless veterans had been reduced to “functional zero,” meaning that the remaining number of homeless veterans is less than the average number of homeless veterans served each month. The Louisville/Jefferson County CoC continues to work with the Louisville Continuum of Care’s Rx: Housing initiative to end chronic homelessness.

In 2017, the Coalition for the Homeless and their CoC partners launched a new “Rx: Housing Young

Adults” initiative to end homelessness among unaccompanied young adults aged 18-24. The Coalition observed that for three consecutive years the number of homeless young adults in Louisville doubled annually, reaching a peak of 562 homeless young adults in 2013. In 2015, the CoC counted 418 young adults aged 18-24 living in adult emergency shelter or on the streets, plus an additional 450 youth below the age of 18 served at YMCA Safe Place, our partner agency that exclusively serves youth. On August 1, 2017, Louisville was one of five cities in the country to launch the 100-Day Challenge to accelerate our efforts to end homelessness among young adults. At the end of the challenge, the Rx: Housing Young Adults initiative had housed 112 young adults in just 100 days. Using the information gained during the 100-Day Challenge, the Coalition and its partners are collaborating in an effort to end homelessness for the remaining homeless young adults by 2020, including the launch of a “Host Homes” Pilot Project in 2018.

Louisville/Jefferson County CoC’s coordinated entry and referral team, called the Common Assessment Team, assesses homeless households across Louisville Metro and prioritizes referrals based on vulnerability. The Common Assessment Team began operating in May 2014. Veterans, the chronically homeless, and the most vulnerable homeless persons - particularly family and youth - are prioritized for available and appropriate housing slots.

Louisville Metro Housing Authority also serves as a valuable partner for the Louisville/Jefferson County

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CoC as it provides vouchers for initiatives such as Rx: Housing Veterans and has initiated a model move- up strategy aimed at making the best use of CoC housing vouchers.

Describe consultation with the Continuum(s) of Care that serves the jurisdiction's area in determining how to allocate ESG funds, develop performance standards for and evaluate outcomes of projects and activities assisted by ESG funds, and develop funding, policies and procedures for the operation and administration of HMIS

RCS staff meets with the Coalition for the Homeless, the collaborative applicant for the Louisville/Jefferson County CoC, on a monthly basis to prioritize and coordinate areas of funding to address homelessness. Additionally, the RCS ESG Coordinator sits on the Louisville CoC Advisory Board.

All ESG subrecipients are required to submit quarterly reports to the Office of Resilience and Community Services. RCS requires performance data from the Homeless Management Information System (HMIS) as well as data collected for CoC projects via the Annual Performance Report. As required by HUD, the RCS ESG-funded Rapid Re-Housing program follows the CoC housing referral model, which requires all new referrals to go through the Common Assessment Team. Of the $1,151,272 in ESG funding that was awarded in subrecipient grants in Program Year 2017, 93.4% ($1,141,272) went to agencies that are in the CoC.

2. Describe Agencies, groups, organizations and others who participated in the process and describe the jurisdiction’s consultations with housing, social service agencies and other entities

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Table 2 – Agencies, groups, organizations who participated 1 Agency/Group/Organization CENTER FOR ACCESSIBLE LIVING Agency/Group/Organization Type Services-Persons with Disabilities What section of the Plan was addressed by Homelessness Strategy Consultation? Non-Homeless Special Needs Briefly describe how the Agency/Group/Organization Center for Accessible Living ensures all people are able to achieve the goal of was consulted. What are the anticipated outcomes of independent living. Through their programs, they promote advocacy, self- the consultation or areas for improved coordination? sufficiency and independence for those with disabilities. Their partnership with Louisville Metro Government addresses physical barriers to accessibility. This includes ramp construction and room adaptions for those requiring assistance to live independently. 2 Agency/Group/Organization The Coalition for the Homeless, Inc. Agency/Group/Organization Type Services-homeless What section of the Plan was addressed by Homeless Needs - Chronically homeless Consultation? Homeless Needs - Families with children Homelessness Needs - Veterans Homelessness Needs - Unaccompanied youth Homelessness Strategy Anti-poverty Strategy Briefly describe how the Agency/Group/Organization The Coalition for the Homeless works in the Louisville, KY area to educate, was consulted. What are the anticipated outcomes of advocate and coordinate community for homeless individuals. Annually, they the consultation or areas for improved coordination? host a street count identifying a more accurate number of homeless in the Louisville, KY area. The ultimate goal is to reduce homelessness and or work to self sufficiency. 3 Agency/Group/Organization Louisville Metro Council Agency/Group/Organization Type Civic Leaders What section of the Plan was addressed by General Consultation?

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Briefly describe how the Agency/Group/Organization Louisville Metro Council is made up of 26 elected officials who represent the was consulted. What are the anticipated outcomes of citizens of Louisville-Jefferson County Metro. They serve as active partners the consultation or areas for improved coordination? working to meet the needs of the community by providing referrals while representing their assigned districts. 4 Agency/Group/Organization Louisville Urban League Agency/Group/Organization Type Services - Housing What section of the Plan was addressed by General Consultation? Briefly describe how the Agency/Group/Organization Louisville Urban League assists African Americans and other marginalized was consulted. What are the anticipated outcomes of populations in attaining social and economic equality through direct services the consultation or areas for improved coordination? and advocacy. Through their partnership with Louisville Metro Government, they provide a Homeownership Counseling program offered in a classroom style program. Participants learn about the process of selecting, financing, purchasing and maintaining a home. The Urban League is also exploring the provision of rental readiness training. 5 Agency/Group/Organization Louisville Metro Department of Community Services Agency/Group/Organization Type Grantee Department What section of the Plan was addressed by Homeless Needs - Chronically homeless Consultation? Homeless Needs - Families with children Homelessness Needs - Veterans Homelessness Strategy Non-Homeless Special Needs HOPWA Strategy Economic Development Anti-poverty Strategy

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Briefly describe how the Agency/Group/Organization Now known as the Office of Resilience and Community Services (RCS), the was consulted. What are the anticipated outcomes of department's mission is to fight poverty and promote compassion, stability, and the consultation or areas for improved coordination? the empowerment of residents and communities. Through their front line programs, they serve some of the most vulnerable populations in need with case management, emergency services, and social services. RCS also administers Metros Microbusiness development and loan program and manages Louisville Metro's Community Services Block Grant Funding. RCS also serves as Metro's lead agency for HOPWA and ESG. 6 Agency/Group/Organization Louisville Metro Department of Parks and Recreation Agency/Group/Organization Type Grantee Department Grantee Department What section of the Plan was addressed by Economic Development Consultation? General Briefly describe how the Agency/Group/Organization On February 22, 2005, former Mayor Jerry Abramson and Metro Parks was consulted. What are the anticipated outcomes of announced a multi-million dollar, multi-year initiative to add thousands of acres the consultation or areas for improved coordination? of park land and protected green space to Louisville Metro's "greenprint." Since this announcement, expansion efforts have increased greatly in areas including Jefferson Memorial Forest and a paved Louisville Loop to connect all of Louisville Metro through pedestrian and bicycle modes of transportation. Parks also operates community centers located throughout Jefferson County that offer varied programming to the public. 7 Agency/Group/Organization Louisville Metro Department of Public Works and Assets Agency/Group/Organization Type Grantee Department Grantee Department What section of the Plan was addressed by General Consultation?

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Briefly describe how the Agency/Group/Organization Louisville Metro Government's department that supports metro-wide was consulted. What are the anticipated outcomes of infrastructure including roadways, streets and sidewalks. Improvements include the consultation or areas for improved coordination? ADA sidewalk accessibility and streetscape improvements. 8 Agency/Group/Organization Louisville Metro Housing Authority Agency/Group/Organization Type PHA What section of the Plan was addressed by Public Housing Needs Consultation? Briefly describe how the Agency/Group/Organization The mission of the Louisville Metro Housing Authority is to provide quality, was consulted. What are the anticipated outcomes of affordable housing for those in need, assist residents in their efforts to achieve the consultation or areas for improved coordination? financial independence, and work with the community to strengthen neighborhoods. LMHA and Louisville Metro Government have partnered on the Vision Russell Choice Neighborhoods Redevelopment Initiative. 9 Agency/Group/Organization Louisville Metro Department of Economic Development Agency/Group/Organization Type Grantee Department Grantee Department What section of the Plan was addressed by Economic Development Consultation? General Briefly describe how the Agency/Group/Organization The department of Economic Development is responsible for working with large was consulted. What are the anticipated outcomes of and small businesses throughout Louisville Metro by promoting job creation the consultation or areas for improved coordination? and improved job skills. 10 Agency/Group/Organization Metropolitan Housing Coalition Agency/Group/Organization Type Services - Housing Service-Fair Housing Advocacy Organization What section of the Plan was addressed by Housing Need Assessment Consultation? Barriers to Affordable Housing

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Briefly describe how the Agency/Group/Organization The Metropolitan Housing Coalition has worked tirelessly for over 20 years on was consulted. What are the anticipated outcomes of behalf of fair, decent and affordable housing in the Louisville metropolitan the consultation or areas for improved coordination? region. MHC is a private, non-profit organization supported by over 300 individuals and organizations as coalition members that believe safe, decent housing is a basic human right. 11 Agency/Group/Organization NEW DIRECTIONS HOUSING CORP. Agency/Group/Organization Type Housing Services - Housing What section of the Plan was addressed by General Consultation? Briefly describe how the Agency/Group/Organization New Directions Housing Corporation develops and maintains affordable housing was consulted. What are the anticipated outcomes of and vital communities in partnership with neighborhoods and other the consultation or areas for improved coordination? stakeholders. 12 Agency/Group/Organization REBOUND, INC Agency/Group/Organization Type Housing Services - Housing CDHO What section of the Plan was addressed by General Consultation? Briefly describe how the Agency/Group/Organization A designated CHDO, Rebound uses federal dollars to turn abandoned and was consulted. What are the anticipated outcomes of vacant properties in Metro Louisville into homes for single families, and also the consultation or areas for improved coordination? provides new construction opportunities as well. 13 Agency/Group/Organization RIVER CITY HOUSING, INC. Agency/Group/Organization Type Housing Services - Housing What section of the Plan was addressed by General Consultation?

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Briefly describe how the Agency/Group/Organization A designated CHDO, River City Housing is a non-profit housing developer that was consulted. What are the anticipated outcomes of rehabilitates an average of 12-15 homes per year. the consultation or areas for improved coordination? 14 Agency/Group/Organization THE HOUSING PARTNERSHIP, INC Agency/Group/Organization Type Housing What section of the Plan was addressed by General Consultation? Briefly describe how the Agency/Group/Organization The Housing Partnership is a non-profit real estate development organization was consulted. What are the anticipated outcomes of that creates affordable housing opportunities to encourage family stability and the consultation or areas for improved coordination? support and empower our community through the development of both rental and home ownership opportunities.

Identify any Agency Types not consulted and provide rationale for not consulting

No agency types were intentionally omitted form this consultation.

Other local/regional/state/federal planning efforts considered when preparing the Plan

Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? The Coalition for the Homeless discusses and addresses the homeless needs Continuum of Care Coalition for the Homeless throughout Metro Louisville. These goals are met in collaboration with other agencies. Louisville Metro Louisville Metro Government's The strategic plan includes affordable housing, community development, and Strategic Plan Mayor's Office economic development goals. Develop Louisville, Office of Vision Louisville is a community driven plan to guide the look, feel, and flow of Vision Louisville Advanced Planning Louisville in 25 years, including its built environment.

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Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? The plan provides path to a healthy, connected and sustainable transportation Move Louisville 2035 Develop Louisville, Office of network that encourages investment, growth, and prosperity. Housing plays an Transportation Plan Advanced Planning integral role in our future transportation needs. Cornerstone 2040 Develop Louisville, Planning & Louisville Metro is currently updating its Comprehensive Plan. This effort includes Comprehensive Plan Design Services and Office of a Housing Work Group led by the Develop Louisville Office of Housing & Update Advanced Planning Community Development. Louisville Metro Kentucky State Data Center, Projections developed to guide the Cornerstone 2040 Comprehensive Plan Demographic University of Louisville Update, which will guide our built environment. Develop Louisville, Office of The VAP Study recommends strategies for eliminating blight and revitalizing Vacant and Vacant and Public Property neighborhoods by addressing the problem of vacant and abandoned properties in Abandoned Property Administration Louisville Metro. Making Louisville Louisville Metro Human The 20-Year Action Plan for Fair Housing outlines common problems affecting Home for Us All Relations Commission Louisville's protected classes and prescribes action steps to further fair housing. Develop Louisville, Office of 2015 Analysis of Housing and Community The AI discusses barriers to fair housing choice and recommends strategies to Impediments Development / Metropolitan overcome these barriers. Housing Coalition Louisville Metro Housing LMHA participates in the MTW Demonstration Program. LMHA's MTW activities Moving to Work Plan Authority and policies are outlined in the annual MTW plan. Choice Neighborhoods Louisville Metro Housing LMHA and co-applicant Louisville Metro Government received a $29,575,000 Initiative Authority Choice Neighborhoods Implementation grant in December 2016. Transformation Pln Develop Louisville, Office of Sustain Louisville outlines sustainability goals and initiatives related to energy, Sustain Louisville Sustainability environment, transportation, economy, community, and engagement. Louisville Urban Heat Develop Louisville, Office of Sustain Louisville outlines sustainability goals and initiatives related to energy, Management Sustainability environment, transportation, economy, community, and engagement.

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Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? Louisville Metro Department of Louisville Metro Health Highlights the socially-based health disparities and inequities evident within and Public Health and Wellness - Equity Report 2017 across Louisville Metro. Center for Health Equity A shared community health agenda for Louisville Metro that outlines measurable Louisville Metro Department of Healthy Louisville 2020 goals and objectives aimed to make us healthier by 2020, including mitigating Public Health and Wellness lead-based paint risk for children. State of Metropolitan Metropolitan Housing Coalition Assesses the need for affordable housing in Louisville Metro. Housing Report 2016-2020 Blueprint to Coalition for the Homeless The Blueprint plan outlines goals for addressing homelessness in Louisville Metro. End Homelessness Examines the mechanisms that perpetuate generational poverty. Issues ranging Poverty Beyond from household stability to food security compound to prevent poor families and Income-2017 Greater Louisville Project children from making achieving financial security. Finds that the barriers that keep Competitive City households in the cycle of poverty do not occur in isolation, and they cannot be Update addressed in isolation. Examines poverty beyond income both within Louisville and in comparison to its peer cities. The report also explores the connections between poverty and Louisville: A Focus on Greater Louisville Project Louisvilles Deep Drivers of Change: Education, 21st Century Jobs, Quality of Place, Poverty-2015 and Health. The report draws a clear connection between levels of concentrated poverty and the citys success and wellbeing. Table 3 – Other local / regional / federal planning efforts

Narrative (optional)

Louisville-Jefferson County Metro Government 19 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

AP-12 Participation – 91.105, 91.200(c) 1. Summary of citizen participation process/Efforts made to broaden citizen participation Summarize citizen participation process and how it impacted goal-setting

Public Hearings

A public hearing was held during the development of the Program Year 2019 Action Plan, and an additional hearing is scheduled during the draft comment period.

The first hearing was held on February 25, 2019 at 6:30 p.m. at the Newburg Central Library located at 4800 Exter Ave, Louisville, KY 40218. Its purpose was to explain the planning process and seek citizen and stakeholder input in developing Louisville Metro Government’s goals and priorities for the 2019 Action Plan.

Five members of the public, three Louisville Metro Government employees, and one representative of Metro Council Member Nicole George attended the hearing. The following organizations were represented at the first public hearing:

• Mattingly Edge • Noble Homes of Kentucky

Legal notice announcing the first public hearing was published in the Courier-Journal on February 15, 2019. A copy of this legal notice is included in Appendix Section C. A flyer advertising the hearing was sent to Louisville Metro Housing Authority, Metropolitan Housing Coalition, Louisville Metro Department of Community Services, Catholic Charities, the Anne Braden Institute for Social Justice Research, Kentuckians for the Commonwealth, the Coalition for the Homeless, Louisville Metro Council, and the offices of U.S. Congressman Yarmuth and U.S Senators McConnell and Paul for further distribution. Additionally, notice was posted on the Office of Housing and Community Development website and Develop Louisville social media.

Louisville Metro released the draft Program Year 2019 Action Plan for a 30-day Public Comment Period on May 8, 2019. Hard copies of the plan were made available for review beginning on May 8, 2019 at all branches of the Louisville Free Public Library, all Neighborhood Place sites, the Edison Center (701 W. Ormsby Avenue, Suite 201), and the Metro Development Center (444 S. 5th Street, 5th Floor). An electronic version of the Louisville-Jefferson County Metro Government 20 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

plan was posted for public review on the Develop Louisville OHCD webpage at https://louisvilleky.gov/government/housing-community- development/public-notices-federal-plans- and-project-compliance. Comments were accepted until the close of business on June 7, 2019.

Legal notice announcing the second public hearing, the release of the draft Program Year 2019 Action Plan, and the 30-day Public Comment Period was published in the Courier-Journal on May 8, 2019. A copy of this legal notice is included in Appendix C. A flyer advertising the hearing was sent to Louisville Metro Housing Authority, Metropolitan Housing Coalition, Louisville Metro Department of Community Services, Catholic Charities, the Anne Braden Institute for Social Justice Research, Kentuckians for the Commonwealth, the Coalition for the Homeless, Louisville Metro Council, and the offices of U.S. Congressman Yarmuth and U.S Senators McConnell and Paul for further distribution. Additionally, notice was posted on the Office of Housing and Community Development website and Develop Louisville social media.

Public Hearing - Amendment

A public hearing was held virtually on May 4, 2020 at 6:00pm to gather public comment on the Amendment to the 2019 Action Plan to include CARES Act funding. This meeting was held via WebEx and Facebook Live, and was streamed by approximately 200 people. The recording of the public meeting is available on Develop Louisville's Facebook Page. All comments received during this meeting are included in the updated Public Comment Appendices.

Louisville-Jefferson County Metro Government 21 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Citizen Participation Outreach

Sort Ord Mode of Outre Target of Outre Summary of Summary of Summary of comm URL (If er ach ach response/attendance comments recei ents not accepted applicabl ved and reasons e) Timeline 01.19.19-03.16.19. This 24- question assessment was distributed throughout Metro Louisville and A summary of translated into 4 languages. Links to the survey Community Non- the survey were shared on Develop results is 1 Needs targeted/broad Louisville & RCS websites and social N/A included in the Assessment community media. Printed copies were Appendix D of distributed among lead non-profit this Action Plan. agencies including Neighborhood House, Louisville Metro Housing Authority and Catholic Charities. A legal notice advertising the February Non- 25, 2019 public hearing was placed in 2 Newspaper Ad targeted/broad N/A N/A the Courier-Journal which circulates community Metro-wide, on February 15, 2019. Copies of the The hearing was held on Monday, comments and the February 25 at the Newburg Central Non- Two comments Develop Louisville Library. Five members of the public, 3 Public Hearing targeted/broad were presented responses are three Louisville Metro employees, one community at the hearing. included in Louisville Metro Council Person Appendix B of this attended the hearing. Action Plan

Louisville-Jefferson County Metro Government 22 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Sort Ord Mode of Outre Target of Outre Summary of Summary of Summary of comm URL (If er ach ach response/attendance comments recei ents not accepted applicabl ved and reasons e) A legal notice advertising the May 23, Non- 2019 public hearing, draft Action Plan 4 Newspaper Ad targeted/broad availability, and the public comment N/A N/A community period was placed in the Courier- Journal on May 8, 2019. A copy of the comment and the Non- Develop Louisville The hearing was held on May 23, 2019 5 Public Hearing targeted/broad response are at the Newburg Central Library. community included in Appendix Section B of this Action Plan

Louisville-Jefferson County Metro Government 23 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Sort Ord Mode of Outre Target of Outre Summary of Summary of Summary of comm URL (If er ach ach response/attendance comments recei ents not accepted applicabl ved and reasons e) Louisville Metro released the draft Program Year 2019 Action Plan for a 30-day Public Comment Period on May 8, 2019. Hard copies of the plan were made available for review beginning on May 8, 2019 at all branches of the Louisville Free Public Library, all Neighborhood Place sites, A copy of the the Edison Center (701 W. Ormsby comment and the Public Non- Avenue, Suite 201), and the Metro Develop Louisville 6 Comment targeted/broad Development Center (444 S. 5th response are Period community Street, 5th Floor). An electronic included in version of the plan was posted for Appendix B of this public review on the Develop Action Plan. Louisville OHCD webpage at https://louisvilleky.gov/government/h ousing-community- development/public-notices-federal- plans-and-project-compliance. Comments were accepted until the close of business on June 7, 2019

Louisville-Jefferson County Metro Government 24 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Sort Ord Mode of Outre Target of Outre Summary of Summary of Summary of comm URL (If er ach ach response/attendance comments recei ents not accepted applicabl ved and reasons e) A legal notice advertising the availability of the Draft Amendment to Non- the 2019 Action Plan and the virtual 7 Newspaper Ad targeted/broad public hearing held for comment on NA NA community the Amendment was placed in the Courier Journal, which circulates Metrowide, on May 1, 2020. A summary of comments received is included in the This meeting was held virtually on updated May 4, 2020, due to a restriction on All comments appendices of in-person meetings beginning March received were Non- this plan. More 16, 2020. This meeting was virtually accepted and 8 Public Meeting targeted/broad information attended by approximately 30 considered in community about the virtual community members and later developing the access and streamed by approximately 200 Amendment. accommodation community members. s for this meeting can be found in the appendices. Table 4 – Citizen Participation Outreach

Louisville-Jefferson County Metro Government 25 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Expected Resources AP-15 Expected Resources – 91.220(c)(1,2) Introduction All figures for entitlement funds are reflective of allocations released by HUD on April 12, 2019.

Anticipated Resources

Program Source Uses of Funds Expected Amount Available Year 1 Expected Narrative Description of Annual Program Prior Year Total: Amount Funds Allocation: Income: Resources: $ Available $ $ $ Remainder of ConPlan $ CDBG public - Acquisition Annual HUD entitlement federal Admin and Planning Economic Development Housing Public Improvements Public Services 11,190,723 200,000 335,267 11,725,990 11,190,723

Louisville-Jefferson County Metro Government 26 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Program Source Uses of Funds Expected Amount Available Year 1 Expected Narrative Description of Annual Program Prior Year Total: Amount Funds Allocation: Income: Resources: $ Available $ $ $ Remainder of ConPlan $ HOME public - Acquisition Annual HUD entitlement federal Homebuyer assistance Homeowner rehab Multifamily rental new construction Multifamily rental rehab New construction for ownership TBRA 2,932,633 150,000 163,900 3,246,533 2,932,600

Louisville-Jefferson County Metro Government 27 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Program Source Uses of Funds Expected Amount Available Year 1 Expected Narrative Description of Annual Program Prior Year Total: Amount Funds Allocation: Income: Resources: $ Available $ $ $ Remainder of ConPlan $ HOPWA public - Permanent Annual HUD entitlement federal housing in facilities Permanent housing placement Short term or transitional housing facilities STRMU Supportive services TBRA 856,081 0 0 856,081 856,081

Louisville-Jefferson County Metro Government 28 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Program Source Uses of Funds Expected Amount Available Year 1 Expected Narrative Description of Annual Program Prior Year Total: Amount Funds Allocation: Income: Resources: $ Available $ $ $ Remainder of ConPlan $ ESG public - Conversion and Annual HUD entitlement federal rehab for transitional housing Financial Assistance Overnight shelter Rapid re-housing (rental assistance) Rental Assistance Services Transitional housing 950,821 0 0 950,821 950,821

Louisville-Jefferson County Metro Government 29 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Program Source Uses of Funds Expected Amount Available Year 1 Expected Narrative Description of Annual Program Prior Year Total: Amount Funds Allocation: Income: Resources: $ Available $ $ $ Remainder of ConPlan $ Continuum of public - Overnight Continuum of Care (CoC) is a Care federal shelter HUD program designed to Rapid re-housing promote community-wide (rental commitment to the goal of assistance) ending homelessness. The Services coordinating agency for the Supportive Louisville CoC is the Coalition for services the Homeless. Transitional housing 9,910,618 0 0 9,910,618 9,910,618 Section 108 public - Economic federal Development Housing 0 0 0 0 0 Section 8 public - Rental Louisville Metro Housing federal Assistance Authority Housing Assistance 63,383,290 0 0 63,383,290 63,383,290 Payments

Louisville-Jefferson County Metro Government 30 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Program Source Uses of Funds Expected Amount Available Year 1 Expected Narrative Description of Annual Program Prior Year Total: Amount Funds Allocation: Income: Resources: $ Available $ $ $ Remainder of ConPlan $ Other – ESG private Financial Matching funds generated for Match Assistance ESG-supported programs. Overnight shelter Rapid re-housing (rental assistance) Rental Assistance Services Transitional housing 950,821 0 0 950,821 950,821

Louisville-Jefferson County Metro Government 31 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Program Source Uses of Funds Expected Amount Available Year 1 Expected Narrative Description of Annual Program Prior Year Total: Amount Funds Allocation: Income: Resources: $ Available $ $ $ Remainder of ConPlan $ Other – CNI public - Admin and Acquisition, homeowner rehab Grant federal Planning and new construction, Economic multifamily rental new Development construction, multifamily rental Homeowner rehab, economic development, rehab public facilities, infrastructure, Housing supportive services. Please Multifamily note: this total is for the entire rental new grant period. construction Multifamily rental rehab New construction for ownership Public Improvements Supportive services 29,575,000 0 0 29,575,000 29,575,000 Other – Lead public - Homeowner Homeowner rehab and multi- Based Paint federal rehab family rental rehab to remove Hazard Multifamily lead hazards from homes. Control Grant rental rehab 966,663 0 0 966,663 966,663

Louisville-Jefferson County Metro Government 32 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Program Source Uses of Funds Expected Amount Available Year 1 Expected Narrative Description of Annual Program Prior Year Total: Amount Funds Allocation: Income: Resources: $ Available $ $ $ Remainder of ConPlan $ Other - CSBG public - Public Services CSBG provides federal funding federal Supportive to Community Action Agencies services across the nation that addresses the causes and conditions of 1,655,887 0 0 1,655,887 1,655,887 poverty at the community level. Other – public - Acquisition Acquisition, homebuyer HOME Match local Homebuyer assistance, homeowner rehab, assistance multi-family rental new Homeowner construction, multi-family rental rehab rehab, new construction for Multifamily ownership TBRA. rental new construction Multifamily rental rehab New construction for ownership TBRA 733,158 0 0 733,158 733,158 Other – public - Public Services ESG funding received through CV-ESG federal Other the CARES Act, April 2020, for 3,390,700 0 0 3,390,700 0 COVID-19 Response.

Louisville-Jefferson County Metro Government 33 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Program Source Uses of Funds Expected Amount Available Year 1 Expected Narrative Description of Annual Program Prior Year Total: Amount Funds Allocation: Income: Resources: $ Available $ $ $ Remainder of ConPlan $ Other – public - Rental CDBG funding received through CV-CDBG federal Assistance the CARES Act, April 2020, for Other 6,745,161 0 0 6,745,161 0 COVID-19 Response. Other – public - STRMU HOPWA funding received CV-HOPWA federal Supportive through the CARES Act, April services 2020, for COVID-19 Response. TBRA Other 140,330 0 0 140,330 0 Table 5 - Expected Resources – Priority Table

Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied

Louisville Metro Government is committed to leveraging federal funds with the intent of maximizing the impact of its programs addressing the Priority Needs listed in section SP-25 of the Consolidated Plan, which include Affordable Housing, Non-Housing Community Development, Homeless Services, Small Business Development, and Non-Homeless Special Needs.

Local public funds are used to meet match requirements for ESG and HOME funds where applicable. Each ESG subrecipient is required to provide matching funds equal to its individual ESG allocation. The one-to-one ESG match requirement can be fulfilled using cash contributions, other agency grants, donated supplies to the agency, and so forth. The source of ESG match is required on all fully executed contracts between Louisville Metro Government and the awarded homeless service agency. Matching funds are documented by Louisville Metro Office of Resilience and Community Services (RCS).

Federal funds awarded to Louisville Metro through the Lead-Based Paint Hazard Control Grant program provide supplemental resources for

Louisville-Jefferson County Metro Government 34 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

home rehabilitation programs, which allows more entitlement funds to be directed toward other housing activities such as the development of new affordable units. Louisville Metro submitted an application for competitive lead grant funding March 2017 and received notification on June 30, 2017 of a three year allocation of Lead Hazard Control Grant funding with a Healthy Homes Supplement totaling $2,899,990.

In May 2015, Mayor Fischer announced the Louisville CARES initiative, a locally-funded $12 million revolving loan fund to provide gap financing for developers building affordable housing or incorporating affordable housing into market-rate developments. In Metro Fiscal Year 2018, Louisville Metro Council allocated an additional $4,828,500 in funding to CARES. As of May 1, 2019, CARES had committed $13,790,000 to developments that will create 727 CARES affordable units and 1,395 total units.

Additionally, Louisville Metro government demonstrated its continued commitment to affordable housing by allocating $2,350,000 in Metro Fiscal Year 2017 and $9,117,000 in Metro Fiscal Year 2018 to the non-profit Louisville Affordable Housing Trust Fund (LAHTF). At least 50% of these funds must support the construction or rehabilitation of housing units serving households at or below 50% of Area Median Income (AMI). As of May 1, 2019, the LAHTF had committed $20,303,511 to 70 projects that will create 2,248 LAHTF-assisted affordable units.

In December 2016 Louisville Metro Housing Authority received a Choice Neighborhoods Implementation Grant for $29,575,000. This grant will be used to: transform the Russell neighborhood into a neighborhood of opportunity and choice; revitalize the Beecher Terrace public housing development as part of an overall plan for improving the Russell neighborhood; and attract investments to Russell to improve quality of life for residents. Louisville Metro has committed $15 million in CDBG funds to support infrastructure investments for the project over five years as leverage for this effort. Louisville Metro has designated Russell as an NRSA and will continue to support targeted programming in the neighborhood in Program Year 2019.

Louisville-Jefferson County Metro Government 35 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

If appropriate, describe publically owned land or property located within the jurisdiction that may be used to address the needs identified in the plan

Louisville Metro Government has solicited proposals for the redevelopment of two large sites in Louisville: the former Urban Government Center (an 11.25 acre site located at 810 & 850 Barret Avenue in the Paristown Pointe neighborhood) and the Heritage West site, a 24-acre brownfield in the Russell neighborhood (located at 3029 West Muhammad Ali Boulevard) that was formerly the National Tobacco site. Additionally, redevelopment of the Beecher Terrace public housing site is the major component of the Choice Neighborhoods transformation plan for the Russell neighborhood.

Urban Government Center: Prospective developers’ proposals for the redevelopment of the Urban Government Center were submitted to Louisville Metro Government on March 15, 2017. After significant community engagement efforts to identify neighborhood goals for the site, the Solicitation of Interest for the site identified the following goals for proposed projects. “The development plan should model outstanding environmental values and incorporate current and future innovative development trends while: reflecting the historical character of the area; offering inclusive, mixed-income housing options and mixed-use spaces; providing green space and amenities for community and neighborhood activities; encouraging cross-generational interactions; and enhancing access and connectivity to surrounding commercial, educational and cultural resources.” A public comment period on submitted proposals was launched at an April 17, 2017 meeting and comment was accepted until May 17, 2017. At the conclusion of the public comment period, all comments were reviewed by a committee, which made recommendations on responses.

On December 20, 2017, Mayor Greg Fischer announced that Louisville Metro Government had chosen the Marian Group to redevelop the former Urban Government Center site. The Marian Group’s proposal aligned with community priorities expressed during an extensive public engagement period.

These priorities include the preservation of green space and an existing community garden, the creation of new housing choices at multiple price points, the ability of the site to support multi-modal transportation options, including transit and bicycles, the reuse of existing facilities and materials, the incorporation of community gathering spaces, and the use of innovative building and site management techniques to make the development a model of sustainability.

The development will feature such diverse housing options as townhomes, shotgun-style single family homes, multi-family rental units, and condo flats. Additionally, Marian plans to develop several types of affordable housing—including a Family Scholar House campus and housing for seniors. The development will include office and commercial space, and The Marian Group will also be exploring development of a boutique hotel.

Heritage West: Prospective developers’ proposals for the redevelopment of the Heritage West site were submitted to Metro Government on May 22, 2017. This site was to be re-developed as the Seed

Louisville-Jefferson County Metro Government 36 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Capital Kentucky “West Louisville FoodPort,” which was to house food and agriculture-related commercial tenants, including farmers, distributors, food processors, and retailers, as well as include a demonstration farm, classroom space, and public space. However, the FoodPort project was cancelled in August 2016 when a major tenant and crucial financial anchor pulled out of the project. As part of this project, a Community Council consisting of more than 100 neighborhood residents and community members was formed to ensure that the project has developed in a way that benefits the surrounding neighborhoods and residents. The input from this council helped identify priorities for the site following Metro’s re-acquisition of the property. Community stakeholders have identified the following as the top desired uses for the site: recreation/sports center; black/locally-owned small businesses; vocational training program for adults and/or youth; an entertainment center; a biotech research facility; a farmer's market and/or a cooperative urban farm; an upscale restaurant; parks/green space; or a veterans' hospital.

On September 19, 2017, Mayor Fischer announced that the Louisville Urban League had been selected to develop a state-of-the-art multi-sports complex anchored by an indoor track and field facility on the 24-acre Heritage West property. The complex will be designed to host a variety of sporting events potentially sponsored by organizations such as USA Track and Field (USATF), the National College Athletics Association (NCAA), colleges and universities, and local and regional public and private schools. The facility also will feature retail space and related amenities. The total project cost is expected to be approximately $30 million.

Beecher Terrace Redevelopment: The Choice Neighborhoods Initiative Vision Russell Transformation Plan (VRTP) includes the demolition of all 758 severely distressed Beecher Terrace public housing dwelling units and facilitates the construction in their place 640 mixed-income rental and homeownership units in a sustainably-designed, multigenerational community, reconnected to adjoining neighborhoods by a cohesive street grid. Anchored with higher density mixed-use buildings along Muhammad Ali Blvd., with a mix of 1-, 2- and 3-bedroom apartments in elevator, walk-up and townhome buildings, Beecher will be renowned for its unique urban architectural style that reflects both historic and contemporary elements. This walkable, amenity rich community will feature commercial businesses on the 1st floor of select buildings along 9th and Muhammad Ali, a renovated Art Deco community center flanking the Olmsted-designed Baxter Park, an on-site management building with a fitness center, pool for Beecher households and community space, as well as interactive green spaces on every block, including community gardens, tot lots and a gazebo next to the senior building. The new, on-site Ali Park will feature a playing field and courts for team sports, along with a community pool and a pavilion that will feature festivals and cultural events to foster community pride and civic engagement. Demolition for the project will begin once the Environmental Review is completed and a Request for Release of Funds is granted, which is anticipated to occur in Summer 2018.

Louisville-Jefferson County Metro Government 37 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Discussion

Narrative Descriptions of Funding Sources:

CoC: Continuum of Care (CoC) is a HUD program designed to promote communitywide commitment to the goal of ending homelessness. The coordinating agency for the Louisville CoC is the Coalition for the Homeless.

Lead-Based Paint Hazard Control Grant: The Lead-Based Paint Hazard Control (LPBHC) grant program is a competitive HUD grant used for the identification and control of lead-based paint hazards in eligible privately owned housing. Louisville Metro was awarded a new 3-year grant with Healthy Homes Supplement totaling $2,989,989 on June 30, 2017.

Choice Neighborhoods Action and Implementation Grants: To support transformation of the Russell Neighborhood, including redevelopment of the Beecher Terrace public housing project, LMHA received $1,000,000 in Choice Neighborhoods Action Grant funds in June 2016 and $29,575,000 in Choice Neighborhoods Implementation Grant funding in December 2016.

LMHA Housing Assistance Payments: The Housing Choice Voucher (Section 8) program administered through LMHA is the federal government's major program for assisting very low-income families, the elderly, and the disabled to afford decent, safe, and sanitary housing in the private market.

HOME Match: Louisville Metro Government provides cash match as required for HOME funds.

ESG Match: ESG subrecipients must provide 100% match, which is often in the form of in-kind rather than cash match. Louisville Metro provides match for administration and rapid re-housing funds when necessary.

CSBG: Federal funds dispersed by the U.S. Department of Health and Human Services intended to alleviate the causes and conditions of poverty in communities. Metro’s CSBG funds are administered by the Department of Community Services, which serves as Louisville’s Community Action Agency.

Louisville-Jefferson County Metro Government 38 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Annual Goals and Objectives

AP-20 Annual Goals and Objectives

Goals Summary Information

Sort Goal Name Start End Category Geographic Needs Addressed Funding Goal Outcome Indicator Order Year Year Area 1 Expand 2015 2019 Affordable Russell Affordable HOME: $100,000 Direct Financial Assistance homeownership Housing NRSA Housing to Homebuyers: 45 opportunities Metrowide Households Assisted 2 Clearance of vacant 2015 2019 Non-Housing Russell Non-Housing CDBG: $530,600 Buildings Demolished: 40 or abandoned Community NRSA Community Buildings structures Development Metrowide Development 3 Provide rapid re- 2015 2019 Homeless Metrowide Homeless CDBG: $38,400 Tenant-based rental housing for diversion Services ESG: $301,700 assistance / Rapid Rehousing: 303 Households Assisted 4 Increase and retain 2015 2019 Affordable Metrowide Affordable HOME: $2,187,000 Rental units constructed: affordable units Housing Housing 200 Household Housing Unit Rental units rehabilitated: 20 Household Housing Unit Homeowner Housing Added: 8 Household Housing Unit

Louisville-Jefferson County Metro Government 39 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Sort Goal Name Start End Category Geographic Needs Addressed Funding Goal Outcome Indicator Order Year Year Area 5 Improve existing 2015 2019 Affordable Shawnee Affordable CDBG: $2,818,000 Homeowner Housing owner-occupied Housing NRSA Housing Lead-Based Paint Rehabilitated: 350 units Russell Hazard Control Grant Household Housing Unit NRSA & Healthy Homes Metrowide Supplement: $996,663 6 Micro-enterprise 2015 2019 Economic Russell Small Business CDBG: $213,600 Businesses assisted: 230 technical assistance Development NRSA Development Businesses Assisted Metrowide 7 Micro-enterprise 2015 2019 Economic Russell Small Business CDBG: $75,000 Businesses assisted: 9 development Development NRSA Development Businesses Assisted Metrowide 8 Provide rental 2015 2019 Affordable Metrowide Affordable HOME: $298,100 Tenant-based rental assistance Housing Housing assistance / Rapid Homeless Homeless Rehousing: 34 Households Services Assisted 9 Provide 2015 2019 Affordable Russell Affordable CDBG: $103,100 Public service activities for homeownership Housing NRSA Housing Low/Moderate Income counseling services Metrowide Housing Benefit: 1000 Households Assisted 10 Provide 2015 2019 Non-Housing Russell Non-Housing CDBG: $3,125,000 Public Facility or improvements to Community NRSA Community Infrastructure Activities public facilities Development Development other than Low/Moderate Income Housing Benefit: 10000 Persons Assisted

Louisville-Jefferson County Metro Government 40 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Sort Goal Name Start End Category Geographic Needs Addressed Funding Goal Outcome Indicator Order Year Year Area 11 Remove barriers for 2015 2019 Non-Homeless Shawnee Non-Homeless CDBG: $200,000 Other: 80 Other persons with Special Needs NRSA Special Needs disabilities Russell NRSA Metrowide 12 Provide TBRA to 2015 2019 Non-Homeless Metrowide Non-Homeless HOPWA: $184,468 Housing for People with persons with Special Needs Special Needs HIV/AIDS added: 55 HIV/AIDS Household Housing Unit 13 Provide supportive 2015 2019 Non-Homeless Non-Homeless HOPWA: $124,250 Public service activities services to persons Special Needs Special Needs other than Low/Moderate with AIDS Income Housing Benefit: 750 Persons Assisted 14 Provide STRMU to 2015 2019 Non-Homeless Non-Homeless HOPWA: $102,744 Other: 300 Other persons with Special Needs Special Needs HIV/AIDS 15 Provide homeless 2015 2019 Homeless Metrowide Homeless CDBG: $116,400 Homelessness Prevention: prevention services Services ESG: $129,500 1065 Persons Assisted Other: 0 Other 16 Provide street 2015 2019 Homeless Metrowide Homeless CDBG: $74,900 Other: 163 Other outreach for Services ESG: $54,200 homeless citizens 17 Shelter operations & 2015 2019 Homeless Metrowide Homeless CDBG: $570,645 Public service activities case management Services ESG: $516,300 other than Low/Moderate for homeless Income Housing Benefit: 3867 Persons Assisted Table 6 – Goals Summary

Louisville-Jefferson County Metro Government 41 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Goal Descriptions

1 Goal Name Expand homeownership opportunities Goal Louisville Metro plans to expand opportunities for homeownership and deconcentrate poverty through its Russell NRSA Description Homeownership Incentive and HOME Down Payment Assistance Programs. NOTE: The Russell NRSA Homeownership Incentive Program and the HOME Down Payment Assistance program will also be supported by prior year carry forward and Program Income. The only Program Year 2019 Allocations for these programs will be $100,000 to support Down Payment Assistance. (It is estimated that $618,000 in HOME Funds will be carried forward into Program Year 2019.) 2 Goal Name Clearance of vacant or abandoned structures Goal Metro eliminates blight and encourages neighborhood stabilization through selective demolition of vacant or abandoned Description structures. Lots previously occupied by dilapidated structures can be returned to productive uses. 3 Goal Name Provide rapid re-housing for diversion Goal Metro provides rapid re-housing assistance to citizens who are at risk of homelessness or recently homeless to divert Description them from the shelter system and help them achieve housing stability. 4 Goal Name Increase and retain affordable units Goal Metro plans to increase the number of affordable rental and owner-occupied units and rehabiliate existing units through Description its HOME Affordable Housing Development Program, its support to CHDOs (at least 15% of Program Year 2019 HOME allocation), and its Russell NRSA Rental Rehabilitation program. NOTE: Production goals are estimates. Actual production goals will be established following the Fall 2019 Notice of Funding Availability once awards are conditionally committed.

5 Goal Name Improve existing owner-occupied units Goal Louisville Metro assists income-eligible owner-occupants of single family homes through its Office of Housing & Description Community Development Home Repair Progams. This includes the Lead Safe Louisville Program, funded through the Lead Hazard Control Grant with Healthy Homes Supplement. Additionally, Metro funds homeowner rehabilitation activities in the Russell neighborhood. Louisville-Jefferson County Metro Government 42 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

6 Goal Name Micro-enterprise technical assistance Goal Louisville Metro helps local micro-enterprises start, sustain, or grow through training, workshops, and technical Description assistance to income-eligible business owners. 7 Goal Name Micro-enterprise development Goal Metro recognizes that for many low to moderate-income entrepreneurs, starting a new business and securing traditional Description business financing is difficult. Metro provides loans to help create or expand micro-enterprise businesses through the Office of Reslience and Commmunity Services (RCS) Microbusiness Program. 8 Goal Name Provide rental assistance Goal Metro provides HOME Tenant-Based Rental Assistance to extremely low- and low-income households to prevent and Description end homelessness through the Department of Resilience and Community Services. 9 Goal Name Provide homeownership counseling services Goal Metro supports homeownership and foreclosure prevention counseling services to assist income-eligible persons in Description purchasing or retaining owner-occupied units. 10 Goal Name Provide improvements to public facilities Goal In program year 2019, Louisville Metro will support infrastructure and streetscape improvements in the Russell Description Neighborhood in support of Choice Neighborhoods Initiative transformation plan efforts. 11 Goal Name Remove barriers for persons with disabilities Goal Louisville Metro funds a ramp/accessibility program administered by the Center for Accessible Living to remove physical Description barriers that impede independent living for persons with disabilities. 12 Goal Name Provide TBRA to persons with HIV/AIDS Goal Metro provides Tenant-Based Rental Assistance (TBRA) (goal=58 households)and Permanent Housing Placement Description (PHP) (goal=21 households) to income-eligible persons with HIV/AIDS. 13 Goal Name Provide supportive services to persons with AIDS Goal Metro utilizes HOPWA funds to provide supportive services for persons with HIV/AIDS and their families. Description 14 Goal Name Provide STRMU to persons with HIV/AIDS Goal Metro provides Short-Term Rent, Mortgage, and Utility assistance and hotel vouchers to income-eligible persons with Description HIV/AIDS and their families. Louisville-Jefferson County Metro Government 43 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

15 Goal Name Provide homeless prevention services Goal Metro provides homeless prevention services, including eviction prevention assistance, and relocation services, to Description citizens who are at risk of homelessness. Metro’s Family Economic Success also program provides individuals at risk of homelessness with skills necessary to move toward self-sufficiency through referrals and case management. 16 Goal Name Provide street outreach for homeless citizens Goal Louisville Metro funds street outreach services targeted to youth and medically fragile homeless persons. Description 17 Goal Name Shelter operations & case management for homeless Goal Metro provides operational support for emergency shelters and case management services for homeless citizens. Description

Louisville-Jefferson County Metro Government 44 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Projects AP-35 Projects – 91.220(d) Introduction

Louisville Metro has identified the following projects for Program Year 2019, which are intended to address the goals described in the previous section.

Projects

# Project Name 1 Affordable Housing Homeowner Unit Preservation 2 Homeowner Accessibility Improvements 3 Residential Programs Delivery 4 Affordable Housing Development Program 5 Relocation 6 Vacant Properties Demolition 7 Homeless Services Support 8 Homeless Services External Agencies 9 Housing Counseling 10 Family Economic Success Program 11 LMHA Russell Choice Neighborhoods Infrastructure 12 HOME Tenant-Based Rental Assistance 13 HOME Homebuyer Assistance Program 14 RCS Microenterprise Activities 15 Russell NRSA Microenterprise Activities 16 RCS/DL Department Services 17 Urban Design/ Landmarks 18 Coalition for the Homeless 19 Indirect Cost 20 HOME Administration 21 ESG-Program Year 2019 22 2019 Louisville Metro- HOPWA Admin 23 2019 Hoosier Hills AIDS Coalition (HOPWA) 24 2019 House of Ruth (HOPWA) 25 2019 Keeping it Real Neighborhood Institute (HOPWA) 26 2019 Legal Aid Society HIV/ AIDS Legal Project (HOPWA) 27 2019 Volunteers of America Mid-States (HOPWA) 28 CARES Act - 2019 Eviction Prevention Program

Louisville-Jefferson County Metro Government 45 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

# Project Name 29 CARES Act - 2019 Housing Stabilization Program (TBRA) 30 CARES Act - 2019 Homeless Case Management and Operating Expenses 31 CARES Act - 2019 Community Land Trust 32 CARES Act - 2019 Small Business Loan Program 33 ESG - Program Year 2020 and CARES Act 34 2019 HOPWA Louisville Metro Admin: CARES Act 35 2019 HOPWA Project Sponsors: CARES Act PHP, STRMU, TBRA, Hotel/ Motel 36 2019 HOPWA Project Sponsors: CARES Act Supportive Services 37 2019 HOPWA Project Sponsors: CARES Act Phase Two Recovery Table 7 - Project Information

Describe the reasons for allocation priorities and any obstacles to addressing underserved needs

Louisville Metro’s Program Year 2019 proposed allocations align with its Consolidated Plan goals and priorities. Affordable housing was the utmost need identified in Metro’s most recent Consolidated Plan submission. This need was demonstrated repeatedly through the Needs Assessment, Market Analysis, and Strategic Plan portions of the Consolidated Plan. New data from the 2012-2016 American Community Survey (ACS) shows that 46.7% of renters and 20.0% of homeowners in Jefferson County spend more than 30% of their income on housing costs. Louisville Metro Housing Authority’s wait lists for Housing Choice Voucher 8 and public housing assistance of 25,074 households (as identified in its draft FY 2019 Moving to Work Plan released March 13, 2018) also demonstrate this demand.

For these reasons it is proposed that Louisville Metro will dedicate 60% of anticipated Program Year 2019 Entitlement Funding to housing activities, such as home repair, homeownership counseling, down payment assistance, rental rehabilitation, Affordable Housing Development, and assistance to Community Housing Development Organizations (CHDOs).

It is proposed that homeless services and housing activities receive 16.6% of anticipated Program Year 2019 Entitlement funds. Due to the great demand for these services, Louisville Metro utilizes approximately 14.8% of CDBG funds for eligible homeless public services activities in addition to ESG funds. The majority of these funds will be distributed to nonprofit subrecipients; however some programs are operated directly by Metro through the Department of Resilience and Community Services. Additionally, direct support to homeless individuals and families in securing housing will be provided through HOME-funded TBRA and ESG-funded Rapid Re-housing.

It is proposed that non-housing community development activities receive 19.62% of anticipated Program Year 2019 Entitlement funds. The great majority of these funds will support eligible

Louisville-Jefferson County Metro Government 46 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

infrastructure investments for the Russell Choice Neighborhoods Initiative transformation project.

It is proposed that Louisville Metro has allocate 1.8% of anticipated Program Year 2019 Entitlement funds for small business development through microbusiness assistance and loans as well as loans to businesses opening in or relocating to the Russell neighborhood. Louisville Metro residents demonstrate a strong need for improved job opportunities: the 2012-2016 American Community Survey (ACS) reports that 24.6% of Jefferson County households have incomes under $25,000 per year. This need is heightened disproportionately in particular neighborhoods. 53.3% of households in the Louisville West Census County Division (CCD) and 57.9% of households in the Louisville Central CCD earned less than $25,000 per year. Median household income is $22,398 in the Louisville West CCD and $20,653 in the Louisville Central CCD, while the median income in Jefferson County is more than twice those amounts at $50,099. Metro hopes to provide expanded economic opportunities by supporting economic development activities and targeting them to particularly distressed neighborhoods where possible.

Finally, Metro proposes an allocation of 5.2% of Program Year 2019 Entitlement funds for non- homeless special needs activities. The majority of these activities will be funded through HOPWA. HOPWA funding is distributed to subrecipients to provide supportive services, tenant-based rental assistance (TBRA), and short-term rent, mortgage, and utility (STRMU) assistance to individuals suffering from HIV/AIDS and their families. Additionally, Metro funds a ramp construction and barrier removal program through CDBG. This program serves to increase the mobility and self-sufficiency of individuals with physical disabilities, including elderly individuals.

Louisville-Jefferson County Metro Government 47 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

AP-38 Project Summary Project Summary Information

Louisville-Jefferson County Metro Government 48 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

1 Project Name Affordable Housing Homeowner Unit Preservation - Russell Target Area Russell NRSA Goals Supported Improve existing owner-occupied units Needs Addressed Affordable Housing Funding CDBG: $2,318,000 Lead-Based Paint Hazard Control Grant & Healthy Homes Supplement: $966,663 Description Funds allocated for homeowner unit preservation support the rehabilitation of owner-occupied homes through the Office of Housing and Community Development (OHCD) Home Repair Programs and the Lead Safe Louisville lead remediation program. Target Date 6/30/2020 Estimate the number 100 and type of families that will benefit from the proposed activities Location Description Russell Neighborhood - Home Repair Metrowide for Emergency and Lead Safe Louisville

Louisville-Jefferson County Metro Government 47 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Planned Activities OHCD Home Repair programs help low-and moderate-income homeowners who cannot afford necessary home repairs, including: emergency electrical issues; emergency plumbing issues; heating systems repair (in winter months); air conditioning repairs (during summer months for medical reasons); roof repairs; and/or emergency improvements needed to remedy building code violations. The purpose of the Lead-Safe Louisville (LSL) Program is to eliminate lead hazards that exist in both owner-occupied and rental units in the Metro Louisville area, especially those in which children under six years of age reside. Houses and apartments built before 1978 are most likely to have lead-based paint which can create a hazard to its inhabitants. Key risk factors are chipping or peeling paint on doors, windows, woodwork or exterior siding. Children are particularly prone to lead poisoning in such environments.

Lead Safe Louisville eligible units are based on the following: built prior to 1978; a child 5 years or younger or pregnant woman lives in the home or a child 5 years or younger visits a minimum of 6 hours a week; and occupant is low-income (80% AMI based on size of family).

To address lead-based paint hazards and mitigation through the Lead Safe Louisville program, Louisville Metro Office of Housing and Community Development has initiated a partnership with several health providers and community organizations, including the Family Health Centers, Louisville Metro Department of Public Health and Wellness (which organizes the Childhood Lead Poisoning Prevention Program (CLPPP)), and Shawnee Christian Health Center. The Family Health Centers assist the program by dispersing LSL educational information to clients, and assist in community outreach. Additionally, they assist by referring children and pregnant women into the LSL program. The Louisville Metro Department of Public Health and Wellness coordinates the Childhood Lead Poisoning Prevention Program (CLPPP) where staff member’s forward names and contact information for children with elevated blood lead levels to LSL within 7-10 days of receiving the data. The Shawnee Christian Health Center assists LSL by referring families with children and pregnant women to the program, asks LSL staff to speak at meetings, and provides educational and training manuals to clients who need information on the LSL program.

Louisville-Jefferson County Metro Government 48 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Specifics of the Lead Safe Louisville program can be found within AP-35 under Program 1: Affordable Housing Homeowner Unit Preservation under the Planned Activities tab. While consultations, programs, and educational information disbursements are all a part of the partnership, the majority of Lead Safe Louisville’s work is preventative and aims to address the problems before they arise. Note: Persons assisted through LSL can be homeowners (owner- occupied) or landlords, though the homeowners and tenants must meet the income qualifications. There is ongoing community outreach promoting these available services to residents. Louisville Metro Government partners with non- profit agencies to perform various community outreach endeavors. OHCD also provides program information to Metro Council members and other city departments for distribution via their e- newsletters. 2 Project Name Homeowner Accessibility Improvements Target Area Russell NRSA Metrowide Goals Supported Improve existing owner-occupied units Remove barriers for persons with disabilities Needs Addressed Non-Homeless Special Needs Funding CDBG: $200,000 Description Construction or repair of wheelchair ramps & barrier removal, or other repairs as needed to increase accessibility. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description

Louisville-Jefferson County Metro Government 49 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Planned Activities Louisville Metro Government provides funds for a ramp construction program operated by Center for Accessible Living. The program constructs access ramps and removes accessibility barriers for disabled residents in order to increase both mobility and self-sufficiency. This program is available for renter occupied homes in addition to owner occupied homes. The Center for Accessible Living promotes this program through individual outreach and through their website. 3 Project Name Residential Programs Delivery Target Area Russell NRSA Metrowide Goals Supported Increase and retain affordable units Improve existing owner-occupied units Needs Addressed Affordable Housing Funding CDBG: $950,300 Description Funds cover service delivery costs for residential repair programs. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Service delivery costs for Affordable Housing Homeowner Unit Preservation; Russell NRSA Rehabilitation, and Russell NRSA Homeowner Unit Preservation projects and part of the Lead Safe Louisville program staff costs. 4 Project Name Affordable Housing Development Program Target Area Russell NRSA Metrowide Goals Supported Expand homeownership opportunities Increase and retain affordable units Needs Addressed Affordable Housing Funding $2,187,000 Description Metro plans to increase the number of affordable rental and owner- occupied units and rehabilitate existing units through its Affordable Housing Development Program and support to CHDOs. The CHDO set- aside is $449,000. Funds will be awarded through a Fall 2019 NOFA.

Louisville-Jefferson County Metro Government 50 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Target Date 6/30/2020 Estimate the number 200 and type of families that will benefit from the proposed activities Location Description Russell Planned Activities New construction and rehabilitation of affordable rental units; new construction and rehabilitation of homeownership units. Goal outcome indicators in the Action Plan are rough estimates. Actual production goals will be established following the awarding of funds via a Fall 2019 NOFA. Project commitments will be in place by June 30, 2020. Construction completion dates will vary project to project. 5 Project Name Relocation Target Area Russell NRSA Metrowide Goals Supported Improve existing owner-occupied units Needs Addressed Affordable Housing Funding CDBG: $10,000 Description Relocation assistance as required under the Uniform Relocation Assistance and Real Property Acquisition Act (URA). Louisville Metro seeks to minimize displacement of persons resulting from acquisition, rehabilitation, and demolition activities and provides relocation assistance for involuntarily displaced persons. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Relocation assistance as required under the Uniform Relocation Assistance and Real Property Acquisition Act (URA). 6 Project Name Vacant Properties Demolition Target Area Russell NRSA Metrowide Goals Supported Clearance of vacant or abandoned structures Needs Addressed Non-Housing Community Development Louisville-Jefferson County Metro Government 51 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Funding CDBG: 530,600 Description Develop Louisville eliminates blight and encourages neighborhood revitalization through selective demolition of vacant or abandoned structures which have been determined to be cost-prohibitive to rehabilitate, so that lots previously occupied by dilapidated structures may be returned to productive uses. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Metro eliminates blight and encourages neighborhood stabilization through selective demolition of vacant or abandoned structures. Lots previously occupied by dilapidated structures can be returned to productive uses. Metro eliminates blight and encourages neighborhood stabilization through selective demolition of vacant or abandoned structures. Lots previously occupied by dilapidated structures can be returned to productive uses. Funding supports demolition activities and some of Metro Vacant and Public Property Administration's service delivery costs. 7 Project Name Homeless Services Support Target Area Metrowide Goals Supported Provide homeless prevention services Shelter operations & case management for homeless Needs Addressed Homeless Services Funding CDBG: $156,000 Description Funds cover program delivery costs for Metro Office of Resilience and Community Services (RCS) homeless services programs. Target Date 6/30/2020 Estimate the number and type of families that will benefit from the proposed activities Location Description

Louisville-Jefferson County Metro Government 52 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Planned Activities Funding supports the salaries of two RCS case managers in the Long- Term Housing and Support division. 8 Project Name Homeless Services External Agencies Target Area Metrowide Goals Supported Provide homeless prevention services Provide street outreach for homeless citizens Shelter operations & case management for homeless Needs Addressed Homeless Services Funding CDBG: $1,114,890 Description RCS competitively allocates funding to subrecipients. Louisville Metro proposes to fund 19 homeless services projects at 16 agencies with CDBG public service funds. Subrecipient projects and allocations are specified in Appendix Section E. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Metro provides operational support for emergency shelters, case management services for homeless citizens, and homeless prevention services. 9 Project Name Housing Counseling Target Area Russell NRSA Metrowide Goals Supported Provide homeownership counseling services Needs Addressed Affordable Housing Funding CDBG: $103,100 Description Louisville Metro proposes to fund homeownership counseling through the Legal Aid Society and the Louisville Urban League Homeownership, Foreclosure Prevention and Rental Readiness Counseling. Target Date Estimate the number and type of families that will benefit from the proposed activities Louisville-Jefferson County Metro Government 53 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Location Description Homeownership and foreclosure prevention counseling services to assist income-eligible persons in purchasing or retaining owner- occupied units. Rental readiness counseling to help income-eligible persons access and retain rental units. Planned Activities 10 Project Name Family Economic Success Program Target Area Metrowide Goals Supported Provide homeless prevention services Needs Addressed Affordable Housing Homeless Services Non-Homeless Special Needs Funding CDBG: $381,400 Description Through case management offered at Metro's Neighborhood Places, this program serves to help families build financial assets by: connecting families to job-readiness opportunities and skills to help them succeed at work; promoting financial education; expanding access to homeownership counseling and foreclosure intervention services; connecting families to mainstream financial services; linking families to free tax preparation assistance and the Federal Earned Income Tax Credit; identification and utilization of community based resources that provide additional financial supports; and linking bottom tiered AMI families to education and support groups that promote household stability. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities 11 Project Name LMHA Russell Choice Neighborhoods Infrastructure Target Area Russell NRSA Goals Supported Provide improvements to public facilities Needs Addressed Affordable Housing Non-Housing Community Development Funding CDBG: $3,125,000

Louisville-Jefferson County Metro Government 54 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Description The third year of funding for eligible infrastructure investments for the Russell Choice Neighborhoods Initiative transformation project to redevelop the Beecher Terrace public housing project site. Target Date Estimate the number 640 families will benefit from housing created at the newly constructed and type of families Beecher Terrace site, half of which will be available to low-income that will benefit from households. the proposed activities Location Description Beecher Terrace Public Housing site – borders consisting of: North – W. Jefferson St., South – W. Muhammad Ali Blvd, West – S. 13th Street, East – Roy Wilkins Ave (9th Street) Planned Activities Public facilities and infrastructure improvements at the Beecher Terrace site. 12 Project Name HOME Tenant-Based Rental Assistance Target Area Metrowide Goals Supported Provide rental assistance Needs Addressed Affordable Housing Homeless Services Funding HOME: 298,100 Description Direct rental support to homeless individuals and families that need to secure housing will be provided through a HOME-funded TBRA program. Target Date 6/30/2020 Estimate the number 25 households will receive rental assistance monthly and type of families that will benefit from the proposed activities Location Description Planned Activities Tenant-based Rental Assistance (TBRA) administered by the Metro Office of Resilience and Community Services (RCS). RCS’ HOME-TBRA program operates from a low-barrier Housing First modality with an overall program goal of assisting Program Participants with rapidly securing safe and stable housing and connecting families with the resources needed to maintain housing following the termination of RCS’ rental assistance. The HOME-TBRA Program offers in supportive services to all recipients.

Louisville-Jefferson County Metro Government 55 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

13 Project Name HOME Homebuyer Assistance Program Target Area Russell NRSA Metrowide Goals Supported Expand homeownership opportunities Needs Addressed Affordable Housing Funding HOME: 100,000 Description The OHCD Homebuyer Assistance Program is available to any homebuyer that is looking to purchase an existing or newly constructed home in the Louisville Metro. All homebuyers must be credit and income qualified. Homebuyer(s) gross income must be 80% or below of the area median income adjusted for family size. Target Date 6/30/2020 Estimate the number 50 and type of families that will benefit from the proposed activities Location Description Planned Activities Downpayment and closing cost assistance to income-eligible homebuyers. 14 Project Name RCS Microenterprise Activities Target Area Russell NRSA Metrowide Goals Supported Micro-enterprise technical assistance Micro-enterprise development Needs Addressed Small Business Development Funding CDBG: $213,600 Description Administered by the Department of Resilience and Community Services, this program assists in small economic development activities throughout Metro Louisville by supporting Micro-Enterprise technical assistance and loans. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Louisville-Jefferson County Metro Government 56 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Planned Activities Technical assistance and loans to Micro-Enterprises. 15 Project Name Russell NRSA Microenterprise Activities Target Area Russell NRSA Goals Supported Micro-enterprise development Needs Addressed Small Business Development Funding CDBG: $75,000 Description Administered by the Office of Resilience and Community Services, this program assists in small economic development activities in the Russell NRSA through Micro-Enterprise loans. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Loans to Micro-Enterprises created by Russell residents or serving the Russell neighborhood. 16 Project Name RCS/DL Department Services Target Area Russell NRSA Metrowide Goals Supported Expand homeownership opportunities Increase and retain affordable units Needs Addressed Affordable Housing Non-Housing Community Development Funding CDBG: $1,349,600 Description Funds support several functions within Develop Louisville and the Office of Resilience and Community Services to facilitate grants administration and management. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description

Louisville-Jefferson County Metro Government 57 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Planned Activities Funds support several functions within Develop Louisville and the Office of Resilience and Community Services to facilitate grants administration and management. 17 Project Name Urban Design/ Landmarks Target Area Metrowide Goals Supported Provide improvements to public facilities Needs Addressed Non-Housing Community Development Funding CDBG: $236,400 Description The Louisville Metro Office of Planning & Design Services provides planning services that enhance and protect the economic, environmental, cultural, and historical resources of the community. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Supports the Louisville Metro Office of Planning & Design Services in its provision of planning services that enhance and protect the economic, environmental, cultural, and historical resources of the community. 18 Project Name Coalition for the Homeless Target Area Metrowide Goals Supported Provide homeless prevention services Provide street outreach for homeless citizens Shelter operations & case management for homeless Needs Addressed Homeless Services Funding CDBG: $112,100 Description Supports HMIS administration, Continuum of Care coordination, and the White Flag severe weather shelter program implementation by the Coalition for the Homeless. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Louisville-Jefferson County Metro Government 58 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Planned Activities HMIS administration, Continuum of Care coordination, and the White Flag severe weather shelter program implementation. 19 Project Name Indirect Cost Target Area Metrowide Goals Supported Increase and retain affordable units Needs Addressed Affordable Housing Non-Housing Community Development Funding CDBG: $250,000 Description Louisville Metro Government Central Service Agencies provide assistance for CDBG, HOME, ESG, and HOPWA funded activities. Central Service Agencies are: Finance, Information Technology, Purchasing, Risk Management, Human Resources, Office of the County Attorney, and Office of the Internal Auditor. These agencies assist with budgeting, financial management, accounting, data processing, payroll, employment, benefits, legal, and purchasing activities. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Louisville Metro Government Central Service Agencies provide assistance for CDBG, HOME, ESG, and HOPWA funded activities. Central Service Agencies are: Finance, Information Technology, Purchasing, Risk Management, Human Resources, Office of the County Attorney, and Office of the Internal Auditor. These agencies assist with budgeting, financial management, accounting, data processing, payroll, employment, benefits, legal, and purchasing activities.

20 Project Name HOME Administration Target Area Metrowide Goals Supported Increase and retain affordable units Needs Addressed Affordable Housing Funding HOME: $221,100 Description The purpose of this activity is to administer all HOME projects to secure affordable housing for residents of Louisville Metro.

Louisville-Jefferson County Metro Government 59 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Target Date 6/30/20 Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities NA

21 Project Name ESG-Program Year 2019 Target Area Metrowide Goals Supported Provide homeless prevention services Provide street outreach for homeless citizens Shelter operations & case management for homeless Needs Addressed Homeless Services Funding ESG: $1,030,400 Description ESG funds support: emergency shelter; homelessness prevention services; street outreach; rapid-rehousing for persons experiencing or at risk of homelessness; and administrative costs. RCS competitively awards to ESG subrecipient agencies. Subrecipient allocations are specified in Appendix Section E. Target Date 6/30/20 Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Shelter operations & case management; street outreach; homeless prevention services; rapid re-housing. RCS administers the rapid re- housing program. RCS competitively awards to ESG subrecipient agencies. Subrecipient allocations are specified in Appendix Section E. 22 Project Name 2019 Louisville Metro- HOPWA Admin Target Area Metrowide Goals Supported Provide TBRA to persons with HIV/AIDS Provide supportive services to persons with AIDS Provide STRMU to persons with HIV/AIDS Needs Addressed Non-Homeless Special Needs Louisville-Jefferson County Metro Government 60 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Funding HOPWA: $830,399 Description HOPWA funds provide income-eligible persons with HIV/AIDS the following services: Tenant-Based Rental Assistance (TBRA) and permanent housing placement; Short-Term Rent, Mortgage, and Utility assistance and hotel vouchers; and supportive services. Three percent of funding supports Metro Administrative costs. Target Date 6/30/2020 Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities TBRA, STRMU, and supportive services for households where a member has HIV/AIDS. A breakdown of subrecipients and activities can be found in Appendix Section E. 23 Project Name 2019 Hoosier Hills AIDS Coalition (HOPWA) Target Area Metrowide Goals Supported Provide TBRA to persons with HIV/AIDS Provide STRMU to persons with HIV/AIDS Needs Addressed Non-Homeless Special Needs Funding HOPWA: $55,000 Description 2019 HOPWA Project Sponsor - STRMU, TBRA, and Admin Activities Target Date 6/30/2020 Estimate the number 16 persons benefitting from STRMU and type of families 8 persons benefitting from TBRA that will benefit from the proposed activities Location Description Metrowide Planned Activities Hoosier Hills AIDS Coalition will provide STRMU and TBRA assistance to persons with AIDS 24 Project Name 2019 House of Ruth (HOPWA) Target Area Metrowide

Louisville-Jefferson County Metro Government 61 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Goals Supported Provide TBRA to persons with HIV/AIDS Provide supportive services to persons with AIDS Provide STRMU to persons with HIV/AIDS Needs Addressed Non-Homeless Special Needs Funding HOPWA: $473,000 Description 2019 HOPWA Project Sponsor - STRMU, Supportive Services, TBRA, PHP, and Project Sponsor Admin Costs Target Date 6/30/2020 Estimate the number 15 persons benefitting from STRMU and type of families 735 benefitting from Supportive Services that will benefit from 47 benefitting from TBRA the proposed activities 21 benefitting from PHP Location Description Metrowide Planned Activities House of Ruth will provide STRMU, Support Services, TBRA and PHP to persons with AIDS 25 Project Name 2019 Keeping it Real Neighborhood Institute (HOPWA) Target Area Metrowide Goals Supported Provide supportive services to persons with AIDS Provide STRMU to persons with HIV/AIDS Needs Addressed Non-Homeless Special Needs Funding HOPWA: $114,386 Description 2019 HOPWA Project Sponsor - STRMU, Supportive Services Target Date 6/30/2020 Estimate the number 5 persons benefitting from STRMU and type of families 250 persons benefitting from Supportive Services that will benefit from the proposed activities Location Description Metrowide Planned Activities The Keeping It Real Neighborhood Institute will provide STRMU and Supportive Services to persons with AIDS

Louisville-Jefferson County Metro Government 62 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

26 Project Name 2019 Legal Aid Society HIV/ AIDS Legal Project (HOPWA) Target Area Metrowide Goals Supported Provide supportive services to persons with AIDS Needs Addressed Non-Homeless Special Needs Funding HOPWA: $38,000 Description 2019 HOPWA Project Sponsor - providing Legal Services to persons with AIDS Target Date 6/30/2020 Estimate the number 65 persons will receive legal assistance and type of families that will benefit from the proposed activities Location Description Metrowide Planned Activities The Legal Aids Society will provide legal advice and support to persons with HIV/AIDS through the HIV/AIDS Legal Project 27 Project Name 2019 Volunteers of America Mid-States (HOPWA) Target Area Metrowide Goals Supported Provide supportive services to persons with AIDS Provide STRMU to persons with HIV/AIDS Needs Addressed Non-Homeless Special Needs Funding HOPWA: $129,500 Description 2019 Project Sponsor - STRMU, Supportive Services, and Project Sponsor Administration Target Date 6/30/2020 Estimate the number 190 persons benefitting from STRMU and type of families 190 persons benefitting from Supportive Services that will benefit from the proposed activities Location Description Metrowide

Louisville-Jefferson County Metro Government 63 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Planned Activities Volunteers of America Midstates will provide STRMU and Supportive Services to persons with AIDS 28 Project Name CARES Act - 2019 Eviction Prevention Program Target Area Metrowide Goals Supported Provide rental assistance Provide homeless prevention services Needs Addressed Affordable Housing Funding CDBG-CV: $1,545,161 Description Support affordable housing by reducing cost burden and expand affordable housing choices for citizens. Target Date 6/30/2020 Estimate the number 625 renter households facing eviction and type of families that will benefit from the proposed activities Location Description Metrowide Planned Activities The goal of the program is to assist approximately 625 renter households facing eviction due to loss of income during COVID-19 pandemic by providing financial assistance for rent and/or utilities. This program will be administered by the Office of Resilience and Community Services (RCS) with staff support provided by Develop Louisville’s Office of Housing. These subsistence payments will be made on a short-term basis, for a period of no more than three months, as emergency rental assistance on behalf of individuals or families for the purpose of preventing homelessness. The program will help renters/households at less than 80% of area median income (AMI) who are facing eviction. Qualifying households must have a loss of income due to the COVID-19 virus. Qualified participants would be eligible for up to $2,500 of direct assistance to either the landlord or the utility company, on behalf the tenant. 29 Project Name CARES Act - 2019 Housing Stabilization Program (TBRA) Target Area Metrowide

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Goals Supported Provide rental assistance Provide homeless prevention services Needs Addressed Homeless Services Funding CDBG-CV: $170,000 Description Providing support through reducing housing cost burden and providing housing for homeless persons. Target Date 6/30/2020 Estimate the number Up to 170 homeless households, dependent on family size and and type of families additional costs, such as security deposits or moving costs. that will benefit from the proposed activities Location Description Metrowide Planned Activities CDBG-CV funds will be used in support of housing for the Emergency Solutions Grant Program to hire Housing Specialists. The program will be administered by the Office of Resilience and Community Services (RCS), including hiring three (3) new Housing Specialists and miscellaneous operating costs and supplies. Hiring will preference qualified Louisville Metro Government applicants who have been furloughed. 30 Project Name CARES Act - 2019 Homeless Case Management and Operating Expenses Target Area Metrowide Goals Supported Provide rental assistance Provide homeless prevention services Needs Addressed Homeless Services Funding CDBG-CV: $1,430,000 Description Addressing the issue of homelessness to provide housing and supportive services for homeless persons through homeless services, shelter operations, and grant coordinators. Target Date 6/30/2020

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Estimate the number Homeless Prevention – 480 families and type of families Homeless Services – 7,300 individuals that will benefit from the proposed activities Location Description Metrowide Planned Activities Competitive grants will be sought via a Notice of Funding Availability for Homeless Services. Services that will be requested include those focused throughout the community to assist those individuals experiencing homelessness and housing regardless of sheltered status to obtain and retain permanent housing. These services could include case management, housing navigation, transportation, storage, technology and devices that assist case managers perform tasks more efficiently & safely. However, Louisville Metro may, in lieu of a competitive notice of funding availability and in consultation with the local Continuum of Care, designate eligible subrecipient agencies for specific projects when appropriate in order to respond rapidly and/or ensure continuity of services. (It is estimated that this NOFA will be $356,000.) Additional operating expenses due to COVID-19 requirements incurred by shelters (day & night) not covered by FEMA reimbursement, One Louisville fund, or other sources. These funds will be awarded around the basis of demonstrated need to homeless providers that are members of the Continuum of Care. (It is estimated that this support allocation will be $743,000.) Funds will be used to pay salaries of two (2) Grant Contract Coordinators in the Office of Resilience and Community Services, plus miscellaneous operating costs such as office, supplies, local travel. ($331,000) 31 Project Name CARES Act - 2019 Community Land Trust Target Area Metrowide Goals Supported Increase and retain affordable units Needs Addressed Affordable Housing Funding CDBG: $2,100,000

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Description Transfer City Owned property to a Community Land Trust, thereby extending the period of affordability on multiple properties and creating more affordable units in perpetuity. Target Date 6/30/2021 Estimate the number Approximately 50 households and type of families that will benefit from the proposed activities Location Description Metrowide Planned Activities The goal of this program is to provide funding for up to two (2) local non-profit entities to start Community Land Trust(s). A Notice of Funding Opportunity (NOFO) would be released to select providers. A major challenge facing Louisville is the availability of for-sale, permanently affordable housing; this need was identified in the Housing Needs Assessment. A Community Land Trust (CLT) helps increase the number of permanently affordable units in the community and supports family wealth building. Both are problems that have been exacerbated by the pandemic. A CLT is a Community Based Development Organization (CBDO), similar to a CHDO under the federal HOME program; as such, a CLT can develop new housing as part of community economic development or as a part of an energy conservation or neighborhood revitalization project. Each CLT/CBDO would get $1,000,000, which could be paired with other funds available from the CLT/CBDO, stimulating economic impact by supporting the construction of houses and employment of skilled and non-skilled labor. This program would be administered by the Office of Housing in Develop Louisville. Additionally, operating funds are allocated to support staffing for CLTs. 32 Project Name CARES Act - 2019 Small Business Loan Program Target Area Metrowide Goals Supported Micro-enterprise development Small business development Needs Addressed Small Business Development

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Funding CDBG: $1,500,000 Description Work with partner organizations to provide microloans, and work with partners organizations to provide working capital loans. Target Date 6/30/2020 Estimate the number 60-75 businesses and type of families that will benefit from the proposed activities Location Description Metrowide Planned Activities The goal of the program is to provide small business loans in low- moderate-income census tracts Program will be administered by a third party chosen through a competitive Notice of Funding Availability (NOFA). Community Development Block Grant (CDBG) funding is available to one partner organization for the purpose of providing economic stabilization relief in the form of low- or no-interest loans or grants to small businesses affected by COVID-19 located in historically disinvested neighborhoods. The program is expected to provide financial relief in the form of low- or no-interest loans or grants to small businesses operating in and serving the following neighborhoods: Algonquin, Smoketown, Shelby Park, Russell, Parkland, Park DuValle, Park Hill, California, Portland, Shawnee, and Chickasaw. 33 Project Name ESG - Program Year 2020 and CARES Act Target Area Metrowide Goals Supported Provide rapid re-housing for diversion Provide homeless prevention services Provide street outreach for homeless citizens Shelter operations & case management for homeless Needs Addressed Homeless Services Funding ESG-CV: $3,390,700

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Description ESG funds support: emergency shelter; street outreach; rapid-rehousing and relocation for persons experiencing or at risk of homelessness; and administrative costs. RCS administers a rapid re-housing program directly and also competitively awards ESG funds to 11 subrecipient agencies conducting projects Subrecipient allocations are specified in the appendices.This ESG funding will support various COVID-19 Response programs undertaken through the CARES Act, including a NOFA to support Homeless Prevention and Support, Emergency Shelter Operating Expenses, and Phase Two Recovery Reserve.This project includes funding for both ESG PY 2020 programming ($1,043,500) and ESG-CV COVID-19 response programming ($3,390,700). Target Date 6/30/2020 Estimate the number 480 families will be served through activities undertaken by the and type of families Homeless Prevention NOFA that will benefit from 7,300 individuals will be served through activities undertaken by the the proposed Homeless Services NOFA activities 170 households receiving TBRA Location Description Metrowide

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Planned Activities CARES Act: Supplemental Program Support • Competitive grants via a Notice of Funding Availability for Homeless Prevention, to include Hotel/Motel, Temporary Housing, Rent & Mortgage Payments, Utility Assistance, Payee Services, Prevention of subsidized tenants from returning to homelessness, Eviction Court Case Manager incl. salary & benefits, services for youth (18-24) at-risk of homelessness, & other services specifically intended to prevent homelessness due to COVID-19 ($845,570) • Competitive grants via a Notice of Funding Availability for Homeless Services, to include temporary shelter not provided within the existing shelter system. i.e. Hotel/Motel Vouchers, college dormitories, etc. ($100,000) Note: In lieu of a competitive notice of funding availability, Louisville Metro in consultation with the local Continuum of Care may designate eligible subrecipient agencies for specific projects when appropriate in order to respond rapidly and/or ensure continuity of services. CARES Act: Tenant Based Rental Assistance • Provide rental assistance for a twelve (12) month period to eligible households in the Single Point of Entry (SPE) system that are precariously housed or homeless. (1,430,000) CARES Act: Technical Assistance • Additional HMIS licenses ($5,000) • HUD Training for COVID-19 Grants Administration, NEC ($10,097) CARES Act: Phase Two Recovery • Reserve to be allocated in collaboration with the Continuum of Care for post-shutdown recovery based on emerging requirements ($1,000,000) 34 Project Name 2019 HOPWA Louisville Metro Admin: CARES Act Target Area Metrowide Goals Supported Provide TBRA to persons with HIV/AIDS Provide supportive services to persons with AIDS Provide STRMU to persons with HIV/AIDS Louisville-Jefferson County Metro Government 70 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Needs Addressed Non-Homeless Special Needs Funding HOPWA-CV: $2,800 Description Support to Louisville Metro Administrative Costs for COVID-19 Response Target Date 6/30/2020 Estimate the number All beneficiaries and project sponsors of HOPWA programs will be and type of families eligible to receive benefit from LMG HOPWA technical assistance via that will benefit from LMG staff. the proposed activities Location Description Metrowide Planned Activities Funds to provide HUD Training for COVID-19 HOPWA Grants Administration for Office of Resilience and Community Services staff 35 Project Name 2019 HOPWA Project Sponsors: CARES Act PHP, STRMU, TBRA, Hotel/ Motel Target Area Metrowide Goals Supported Provide TBRA to persons with HIV/AIDS Provide STRMU to persons with HIV/AIDS Needs Addressed Non-Homeless Special Needs Funding HOPWA: $91,400 HOPWA-CV: $30,500 Description Permanent Housing Placement, Short-Term Rent, Mortgage and Utility Assistance, Tenant Based Rental Assistance, and Hotel/ Motel vouchers for persons with HIV/AIDS for COVID-19 Response Target Date 6/30/2020 Estimate the number 82 families and type of families that will benefit from the proposed activities Location Description Metrowide

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Planned Activities Competitive grants via a Notice of Funding Availability to HOPWA project sponsors, to be used for HOPWA COVID-19 Permanent housing placement, Short term housing, Rental, Mortgage & Utility assistance, Tenant Based Rental Assistance, Hotel/Motel 36 Project Name 2019 HOPWA Project Sponsors: CARES Act Supportive Services Target Area Metrowide Goals Supported Provide supportive services to persons with AIDS Needs Addressed Non-Homeless Special Needs Funding HOPWA: $91,222 HOPWA-CV: $47,000 Description Supportive Services for persons with HIV/AIDS for COVID-19 Response Target Date 6/30/2020 Estimate the number 590 individuals and type of families that will benefit from the proposed activities Location Description Metrowide Planned Activities Competitive grants via a Notice of Funding Availability to HOPWA project sponsors, to be used for HOPWA COVID-19 Supportive Services including legal and other auxiliary services. (An additional $98,778 of PY20 HOPWA funds will be used to support this NOFA and is included as a 2020 HOPWA Project in the 2020 Action Plan.) Note: In lieu of a competitive notice of funding availability, Louisville Metro in consultation with the local Continuum of Care may designate eligible subrecipient agencies for specific projects when appropriate in order to respond rapidly and/or ensure continuity of services. 37 Project Name 2019 HOPWA Project Sponsors: CARES Act Phase Two Recovery Target Area Metrowide Goals Supported Provide TBRA to persons with HIV/AIDS Provide supportive services to persons with AIDS Provide STRMU to persons with HIV/AIDS Needs Addressed Non-Homeless Special Needs Louisville-Jefferson County Metro Government 72 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Funding HOPWA-CV: $60,030 Description Permanent Housing Placement, Short-Term Rent, Mortgage and Utility Assistance, Tenant Based Rental Assistance, Hotel/ Motel vouchers, and Supportive Services for persons with HIV/AIDS for COVID-19 Response Phase 2 Target Date 6/30/2020 Estimate the number Goals will be determined during Phase 2 of the recovery and type of families that will benefit from the proposed activities Location Description Metrowide Planned Activities Reserve to be allocated in collaboration with the Continuum of Care for post-shutdown recovery based on emerging HOPWA requirements

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AP-50 Geographic Distribution – 91.220(f) Description of the geographic areas of the entitlement (including areas of low-income and minority concentration) where assistance will be directed

With the exception of funds set aside for NRSA activities, activities that provide direct client services will be available to qualifying individuals and families on a metro-wide basis. Activities that qualify on a low- and moderate-income area basis will be available in the qualifying census tracts.

Metro’s 2015-2019 Consolidated Plan indicated an intent to propose a Russell NRSA during the Consolidated Plan period. Metro submitted a Russell NRSA plan with the Program Year 2016 Action Plan and HUD approved the Russell NRSA designation on June 16, 2016. The Russell NRSA became active on July 1, 2016. The designation of Russell as an NRSA supports the Choice Neighborhoods/Vision Russell planning effort, which began in January 2015 with the award of a Choice Neighborhoods Planning Grant to Louisville Metro Housing Authority for the Russell neighborhood, including the Beecher Terrace public housing development. LMHA has since been awarded additional funds for this effort, including a $1,000,000 Choice Neighborhoods Action Grant in June 2016 and a $29,575,000 Choice Neighborhoods Implementation Grant in December 2016. A map of the Russell NRSA can be found in Appendix F of this Draft Action Plan.

All HOPWA funding, except for funds set aside for administration, is distributed to subrecipients. Potential HOPWA subrecipients submit proposals directly to the Louisville Metro Office of Resilience and Community Services (RCS), where the proposals are reviewed and recommended for funding. Eligible areas of service for HOPWA within the Louisville KY-IN Metropolitan Statistical Area (MSA) include Bullitt, Henry, Jefferson, Meade, Nelson, Oldham, Shelby, Spencer, and Trimble Counties in Kentucky and Clark, Floyd, Harrison, Scott, and Washington Counties in Indiana.

Geographic Distribution

Target Area Percentage of Funds Portland NRSA 0 Shawnee NRSA 0 Russell NRSA 23 Metrowide 77 Table 8 - Geographic Distribution

Rationale for the priorities for allocating investments geographically

The majority of funds will be used to support programs Metro-wide for qualifying LMI census tracts and persons. Louisville Metro uses NRSAs to target CDBG funds to particularly distressed neighborhoods and

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will continue to allocate funds to Russell NRSA in Program Year 2019. Third year Russell NRSA funds will be used for owner-occupied housing rehabilitation, vacant and abandoned property response, and economic development activities as described in the NRSA plan. Additionally, Russell will see a $3.125 million infrastructure investment in Program Year 2019 as part of Louisville Metro Government’s match commitment to the Choice Neighborhoods Initiative Transformation grant for the neighborhood.

It should be noted that funds identified as available on a Metro-wide basis are not excluded from use in the targeted areas and are in fact often utilized in these areas (e.g., homes located in target areas often receive priority consideration for Metro-wide rehabilitation programs).

Metro seeks to deconcentrate poverty in Jefferson County through programs such as Metro-wide HOME Homebuyer Assistance and the NRSA homeownership incentive program. Additionally, this is a consideration when selecting projects for the investment of HOME funds, CDBG rental rehabilitation funds, Louisville CARES funds, and Louisville Affordable Housing Trust Fund dollars.

Discussion

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Affordable Housing AP-55 Affordable Housing – 91.220(g) Introduction Expanding the supply of safe, decent, sanitary, and affordable housing was the primary goal identified in Louisville Metro’s 2015 - 2019 Consolidated Plan. Develop Louisville, Louisville Metro’s lead agency for utilizing HUD entitlement funds as well as its CDBG and HOME Administrator, undertakes a number of activities aimed at increasing the number of affordable housing units Metro-wide as well as stabilizing the existing housing stock. In 2012, Louisville Metro created a Strategic Plan which highlights affordable housing as one of its 21 goals as follows:

Increase and Preserve Affordable Housing Choices throughout Metro Louisville: Participate in the development and preservation of 5,000 new and/or rehabilitated quality and affordable housing units by FY18 and encourage public-private partnerships to dramatically increase the number of available quality and affordable housing units across the community. Having achieved and surpassed this goal, Louisville Metro Government hopes to achieve 5,000 additional units by 2022.

The tables below list the anticipated number of households that will be provided with housing assistance through programs outlined in this plan for Program Year 2019.

One Year Goals for the Number of Households to be Supported Homeless 73 Non-Homeless 591 Special-Needs 387 Total 1,051 Table 9 - One Year Goals for Affordable Housing by Support Requirement

One Year Goals for the Number of Households Supported Through Rental Assistance 538 The Production of New Units 200 Rehab of Existing Units 250 Acquisition of Existing Units 50 Total 1,038 Table 10 - One Year Goals for Affordable Housing by Support Type

Discussion

Anticipated outcomes for households supported through rental assistance include rapid re-housing (145), HOME TBRA (38), HOPWA TBRA (55), and HOPWA STRMU (300). Anticipated outcomes for Louisville-Jefferson County Metro Government 76 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

production of new units will be determined following the Fall 2019 NOFA for Affordable Housing Production (200 units as a temporary estimate). Anticipated outcomes for rehabilitation of existing units include improvements to existing owner-occupied units (236), improvements to NRSA rental units (25), and ramps and barrier removal (80). Anticipated outcomes for acquisition of existing units include down payment assistance (50).

Discussion- Broadband Infrastructure

Louisville Metro will comply with the December 26, 2016 Final Rule for Broadband Infrastructure in HUD-Funded New Construction and Substantial Rehabilitation of Multifamily Rental Housing. Metro will do so by requiring developers of multi-family housing assisted with CDBG and/or HOME funding to comply with the following telecommunications installation standards. This requirement will be implemented and enforced through funding agreements.

Developers of assisted housing will be required to:

• install a spare telecommunication 4-inch conduit from the right of way to the electrical room of any new multi-family development in addition to the telco (example: AT&T), cable TV (CATV) and electric feeds; • use split duct within the conduit to provide for access by multiple providers; • include with the conduit a stub up on the utility pole or intersect with underground cable path for telecommunications providers in the right of way. • install a tie-off at each end of the conduit; and • install a 12-inch pull box should be installed to allow for easier installation of fiber/cable in the future, if the duct makes more than three 90 degree turns.

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AP-60 Public Housing – 91.220(h) Introduction

As a participant in the Department of Housing and Urban Development’s (HUD) Moving to Work (MTW) Demonstration Program, the Louisville Metro Housing Authority (LMHA) prepares and submits an MTW Annual Plan to HUD each year, which outlines the agency’s short and long-term goals, as well as the strategies the agency intends to undertake in furtherance of these goals during the upcoming year.

Actions planned during the next year to address the needs to public housing

During FY 2020, LMHA will further its commitment to provide high-quality, affordable housing units throughout its public housing stock by engaging in the following initiatives:

• Housing Choice and Project Based Vouchers: LMHA projects that rental assistance and related services will be provided to 9,267 MTW households through the Housing Choice Voucher (HCV) program. An additional 372 households are projected to be served through the Veterans Administration Supportive Housing (VASH) program. Approximately 300 new units are also anticipated to be placed under contract in FY 2020 in conjunction with LMHA’s newly launched Project Based Voucher (PBV) program that is being utilized to fulfill the replacement housing component of the Beecher Terrace Choice Neighborhood Initiative Implementation grant. • Public Housing: In FY 2020, LMHA projects serving 3,640 public housing households. Additionally, LMHA plans to relocate the remaining families living on the Beecher Terrace site and demolish the 647 units (637 dwelling and 10 non-dwelling) remaining on the site as part of its Choice Neighborhoods Implementation grant initiative. While no new public housing units are planned for FY 2020, 114 new replacement units are expected to be created on the Beecher site during FY 2020 through a combination of PBVs and Low Income Housing Tax Credits.

• Russell Choice Neighborhoods Initiative (Vision Russell): The Choice Neighborhoods Initiative (CNI) is a HUD-funded grant program that began in 2010, replacing HUD’s HOPE VI program. There are currently two types of CNI funding available: Planning and Implementation.

o Planning Grant: LMHA was awarded a $425,000 Planning grant in January 2015. The Housing Authority, in collaboration with Louisville Metro Government, residents, and other community stakeholders, created a Transformation Plan for the Russell neighborhood, including the Beecher Terrace public housing development. The final Vision Russell Transformation Plan, submitted to HUD in January 2017, focuses on the following goals: transforming Russell into a neighborhood of opportunity and choice; revitalizing Beecher Terrace as part of an overall plan for improving the Russell neighborhood; and attracting investments to Russell to improve quality of life for residents. Louisville-Jefferson County Metro Government 78 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

o Planning Grant for Action Activities: In June 2016, LMHA was awarded $1 million in CNI Planning grant funds for Action Activities, which are being used to complete projects that enhance and accelerate the transformation of the Russell neighborhood. The projects include the creation of four neighborhood gateways (anticipated to be completed in mid 2019); construction of five SmART Stop bus shelters (two completed in 2018 and three by mid-2019); redevelopment of four vacant lots (2 completed in 2018 and two by mid-2019); and improvements to Sheppard Park (completed in 2018).

o Implementation Grant: LMHA and co-applicant Louisville Metro Government received a $29,575,000 CNI Implementation grant in December 2016, providing critical funding for the transformation of Beecher Terrace and select critical community improvements in the surrounding Russell neighborhood. All of the site’s original 758 dwelling units will be razed and replaced during the grant period, which runs through September 2023. The existing Beecher site will be redeveloped into a mixed-income, mixed-use community that includes 620 rental units (320 Beecher replacement units, 130 other affordable units and 170 market rate units), and 20 Homeownership units. A total of 442 Beecher Terrace replacement units will be created off-site. LMHA has also issued a Request For Proposals for off-site PBV units that is expected to attract the interest of several developers during FY2020.

As new units are completed, displaced residents will be able to return either on-site or to off-site replacement housing as long as they were lease-compliant at the time of departure from the original site and remained lease-compliant during their relocation period. Construction has begun on the first phase of redevelopment, a four story 117- unit building for persons age 55+. A second phase of construction, which will include 108 family units, is anticipated to begin during FY2020.

• Housing Options for Beecher Relocatees: As a large proportion of relocating Beecher families will need one bedroom units, LMHA sought to find a way to assist Beecher residents in finding LMHA anticipates that over 500 Housing Choice Vouchers will be utilized to assist these families in making strides toward self-sufficiency and increasing their housing choices. LMHA works with a number of partner agencies to assistant the Special Referral Program participants with services and supports in their efforts to achieve housing stability and economic self-sufficiency.

• Self-Sufficiency and Development Programs: Financial literacy, adult education, employment and training are among the supportive service programs that will continue to be provided by LMHA and a network of partners in FY 2019. Credit Building, Homeownership, Special Referral and the Family Self-Sufficiency programs are vehicles for LMHA participants to assist them in achieving economic self-sufficiency. These initiatives all leverage MTW Block Grant funding to

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secure additional public and private funding. A critical ongoing objective is for LMHA to maximize and leverage its MTW Block Grant investments through innovative partnerships with State, City, and non-profit agencies, universities, and social services organizations.

• Elderly/Disabled Housing: LMHA will continue to use MTW flexibility in FY 2019 to maximize leasing at elderly/disabled developments. Efforts include changing the definition of elderly from 62 to 55 and above and providing lease-up incentives. It is anticipated that these initiatives will continue to increase occupancy rates at these developments.

• Rent Policies: LMHA’s rent policies address both participant self-sufficiency and LMHA administrative efficiency. In FY 2019, LMHA anticipates that it will continue to apply the policies related to alternate year reexaminations, application of a standard medical deduction, earned income disregard for elderly HCV families and elimination of the mandatory earned income disregard.

• Owner Rent Increase Limit: In FY 2019, LMHA will modify its MTW policy on owner rent increases. While LMHA will continue to place a cap on rent increases, LMHA will conduct a reasonable rent determination on a sample of the units where increases in rents are requested. This change will ensure that rents are reasonable while maintaining the administrative efficiencies gained through this activity.

• HUD Rent Reform Demonstration: FY 2019 represents the fourth of six years of the HUD Rent Reform Demonstration. The Study sets forth alternative rent calculation and reexamination strategies that have been implemented at several public housing authorities across the country in order to fully test the policies nationally. In FY 2019, as a result of households leaving the program, it is anticipated that the Alternate Rent Group will have 664 households and the Control Group will have 871 households. The study is scheduled to end in 2021.

• Public Housing Development: As part of its goal to transform aging portions of LMHA’s physical housing stock while providing replacement units, LMHA developed and implemented two MTW Public Housing (PH) development activities. LMHA may use the Simplified PH Development Submittal and Acquisition of Mixed-Income Sites activities in FY 2019 as needed. These activities are designed to streamline the development process and reduce the time spent of development submittals. To date, LMHA has not used these flexibilities.

• Accessible Units: In 2010, LMHA conducted an assessment that demonstrated a 2.4% availability of accessible units within their portfolio. Since that time, LMHA has completed projects at Liberty Green and Sheppard Square, with each of these projects enjoying an increase of 8% in the total amount of accessible units at each respective property. With the completion of this, LMHA projects that 5% of their units are accessible, and plan to conduct an assessment of affordable units across their portfolio upon completion of their current re-development efforts Louisville-Jefferson County Metro Government 80 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

at Beecher Terrace. Additionally, in its efforts to provide fully accessible units to individuals with disabilities, LMHA, under its MTW Activity with Frazier Rehab Institute, provides transitional housing for up to six months per family. Frazier Rehab sub-lessees are also referred to an area service provider to assist them in leaving the program to obtain stable housing. This activity is anticipated to continue in FY 2019.

• Housing Needs Assessment: Louisville Metro Government's Office of Housing and Community Development (OHCD) has conducted a Metro-wide Housing Needs Assessment to gather data and provide analysis to determine housing supply and demand across price points, including rental and homeownership. This analysis includes accessibility unit availability across Louisville Metro.

• YouthBuild: Under this activity, LMHA provides temporary housing for low-income YouthBuild Louisville (YBL) participants who are experiencing homelessness. Up to three, 2 bedroom units are available for YBL participants who may stay in the unit as long as they are active in the YBL program. LMHA provides a PH preference to these individuals upon graduation from YBL. Due to the demolition at Beecher Terrace, temporary housing for Youthbuild participants is provided at 550 Apartments.

Along with its MTW implementation activities, LMHA will implement other initiatives in FY 2019 that do not specifically require MTW authority or Block Grant flexibility to administer. Highlights of LMHA’s planned Non-MTW activities include:

• ConnectHome USA: ConnectHome USA is a pilot initiative with communities, the private sector, and the federal government that seeks to accelerate the adoption and utilization of broadband technology by children and families living in assisted housing. In August, 2017, Louisville Metro Housing Authority (LMHA) was selected as one of these communities. In FY 2019 LMHA and partners will continue efforts to bridge the digital divide in LMHA communities and will be focusing on goals to assure LMHA public housing residents and Housing Choice Voucher Program participants have the opportunity to fully engage in the ever-evolving digital society. Through ConnectHome USA LMHA has a goal to connect 35% of HUD-assisted housing residents to a low-cost, in-home internet connection by January 2019.

• Smoke-Free Policy: As part of HUD’s Instituting Smoke-Free Public Housing Final Rule, LMHA will implement its No-Smoking Policy in July 2018. The new restrictions apply not just to residents, but also to visitors, service personnel, and LMHA employees. Per the Final Rule, Public Housing Agencies must ban cigarettes, cigars, pipes, and water pipes (hookahs) in no-smoking areas. LMHA has also opted to ban Electronic Nicotine Delivery Systems, such as e-cigarettes, e-cigars, e-pipes, and vape pens.

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Actions to encourage public housing residents to become more involved in management and participate in homeownership

Resident Councils: The Louisville Metro Housing Authority has Resident Councils at many of its housing developments to assist and serve as a resource for LMHA and the residents of the community. Resident Councils are charged with the responsibility of promoting programs and activities that improve the educational, recreational, cultural, and social opportunities for the residents of their respective community. The Resident Council Board members are also responsible for managing the affairs and conducting the business of the organization, as well as consulting with and keeping the residents informed.

HCV Homeownership Program: Homeownership is an important housing option for many low-income families, and it is an affordable and secure way for qualified LMHA families to achieve self-sufficiency. In fact, LMHA has been a pioneer in this area, completing the first HCV Homeownership Program closing in the nation in November 1997. The award-winning program offers a comprehensive route to self- sufficiency for low-income families through mortgage assistance, counseling, and maintenance support. To date, the HCV Homeownership option has helped 300 LMHA families make the transition from renting to owning by allowing them to utilize their voucher to pay a portion of their mortgage.

LMHA’s Homeownership Program is anticipated to continue in FY 2020 including the program enhancements designed to promote homeownership in areas of opportunity. LMHA increased the subsidy for one-bedroom eligible households, as well as increased the maximum subsidy in areas of opportunity. These MTW homeownership activities continue to result in increases to the number of households purchasing units in areas of opportunity.

In addition to financial assistance, the program provides intensive pre- and post-purchase counseling and requires homebuyer participation in Individual Development Accounts with a two-to-one match for repairs and maintenance to help families navigate the home-buying/home-owning process and increase their chances of success. LMHA will continue to recruit participants for this program.

If the PHA is designated as troubled, describe the manner in which financial assistance will be

Louisville-Jefferson County Metro Government 82 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended) provided or other assistance.

This section is not applicable to LMHA

Discussion

Louisville-Jefferson County Metro Government 83 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

AP-65 Homeless and Other Special Needs Activities – 91.220(i) Introduction

Louisville Metro Government is committed to providing safe and affordable housing opportunities and related supportive services throughout Louisville Metro to serve the homeless population. This includes and is not limited to rent assistance, transitional housing, and shelters.

Describe the jurisdictions one-year goals and actions for reducing and ending homelessness including:

Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs

Louisville has a homeless street outreach team funded in part by Continuum of Care (CoC) and Emergency Solutions Grant (ESG) dollars and historically operated by Centerstone (formerly Seven Counties Services), in addition to multiple privately-funded and volunteer outreach teams. The Centerstone team engages homeless persons sleeping outdoors or in places not meant for human habitation. The engagement primarily involves attempting to collect personal information for HMIS, making health referrals to the healthcare clinic for homeless persons (Phoenix Health Center), making referrals to shelters and other homeless services, and encouraging connection to the Common Assessment Team for coordinated assessment and potential housing program referral.

The Coalition for the Homeless began implementation of a single point of entry for homeless shelter in June of 2013, which removes the need for homeless people to wait in line in inclement weather, wait for a lottery to determine if they have a safe place to stay, or wander from place to place to find a bed for the night. Anyone can contact 637-BEDS to make a shelter reservation any day of the year. This process also ensures that shelter is reserved for those in greatest need, creates a way for institutions like hospitals and jails to prevent the release of homeless persons to the streets, and prevents people from becoming homeless in the first place by making referrals to homeless prevention services in the community. Because the system utilizes a scan card system, the length of time for check in has been greatly reduced at shelters and the data on homeless persons served is better than ever in the past.

In August of 2018, Louisville welcomed the addition of UP for Women and Children as Louisville’s first and only day shelter available to women and children. Of those homeless, nearly one-third are women. The day shelter provides a safe and healthy space for women to access to showers, laundry, case management and life skills training. Since the ribbon cutting, the shelter has had over 2,780 visits. Louisville Metro Government Office of Resilience and Community Services is pleased to have another referral source for participants to access.

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Additionally, Louisville has a coordinated assessment and referral team called the Common Assessment Team, which assesses each homeless household in Louisville and then determines the most appropriate housing referral based on vulnerability. A newly created medical outreach team goes on site to various locations once per week to address the medical needs of those living on the streets. On site assessments can diagnosis serious or potentially fatal illness Since May 2014, the Common Assessment Team has assessed more than 4,632 individuals and 1,066 families. Approximately 1,022 individuals and 430 families have been referred to permanent housing opportunities for persons experiencing homelessness.

The Coalition for the Homeless identifies improving crisis response as a goal in its 2016-2020 Blueprint to End Homelessness plan and intends to achieve this goal through short-term objectives such as continuing work with Neighborhood Place and Metro United Way’s 2-1-1 social service line to refer individuals and families to homeless prevention services, maintain the Bed One-Stop centralized intake system, maintaining a strong and coordinated outreach team, and working with technical assistance providers to identify gaps and funding priorities in order to move persons more quickly and successfully through the system. A new smart phone app, LouieConnect, was launched by several non-profits in 2018 that allows individuals with smart phone access to search for services for those in need of food, shelter and more. This app is free to download and was promoted across the city through bus ads, online campaigns and partner promotions.

In December 2017, Mayor Greg Fischer created the Homeless Encampment Task Force to review and develop city policies and procedures dealing with homeless encampments. The Homeless Encampment Task Force is a collaborative effort with more than 20 partner organizations and 60 participants from government, business, non-profits, religious leaders, and concerned citizens. Multiple departments of Metro Government are represented, including Resilience and Community Services, Metro Health and Wellness, the Louisville Metro Police Department, and Metro Solid Waste Management, as well as members of the Metro Council and many charitable and advocacy groups such as the Coalition for the Homeless.

The Task Force has been working to implement a new Metro Ordinance that requires 21 days of notice before clearing an occupied homeless encampment and other initiatives. The Task Force also provides a platform to facilitate conversation between service providers, homeless persons, outreach workers, and the broader community to understand challenges and develop a plan to improved services.

In December 2018, Metro Council approved an allocation from city government surplus funding totaling 546,741 to further address the needs of unsheltered homeless individuals in our community. The funds were for a short-term plan through June 30, 2019. The plan includes allocating funding to six external agencies servicing seven programs which will provide the following: a storage facility where homeless people can store their belongings when going into shelter; four options for low-barrier shelters; additional beds, cots and mats, and housing for homeless families; case management and outreach Louisville-Jefferson County Metro Government 85 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

workers to connect individuals to resources throughout the community; and options to house and care for homeless persons’ pets.

Addressing the emergency shelter and transitional housing needs of homeless persons

The emergency and transitional housing needs of homeless persons are assessed through the single point of entry and Common Assessment Team systems described above.

The Louisville Metro CoC’s 2019 Point in Time Count homeless census conducted on January 31, 2019, found 118 individuals sleeping outside. This represents a 23% decrease in the number of persons experiencing homelessness found in the 2018 Point in Time Count. Additionally, 161 people were counted sleeping indoors at the new low barrier shelter. This shelter opened in December of 2018 and immediately was nearly at capacity. With options for singles, families, and those with animals, this shelter has filled a vital need and reduced the number of those on the streets. As with each year, the count of unsheltered homeless is likely an undercount due to the difficulty in counting these individuals. The Coalition for the Homeless identifies increasing access to stable and affordable housing as a goal in its 2016-2020 Blueprint to End Homelessness plan and intends to achieve this goal through short-term objectives such as creating 200 new permanent supportive housing units by 2020, supporting efforts by partners to acquire additional VASH vouchers for homeless veterans, and working with LMHA to create a “move-up” strategy to allow those stabilized in permanent supportive housing for over two years to move to Section 8, freeing up permanent supportive housing for those with the greatest need. In program year 2018, RCS had 22 participants graduate through the Move-Up Program and 1 through the HUD VASH program.

Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again

Louisville’s Common Assessment Team prioritizes all housing program referrals based on HUD’s Notice CPD-14-012: “Prioritizing Persons Experiencing Chronic Homelessness and Other Vulnerable Homeless Persons in Permanent Supportive Housing and Recordkeeping Requirements for Documenting Chronic Homeless Status,” which establishes an order of priority for permanent supportive housing beds to ensure that persons with the most severe service needs are given first priority, rather than utilizing a first-come-first-served approach. Prioritization also takes into account local initiatives on ending

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homelessness.

In 2014-2015, Mayor Fischer announced a community campaign to end veteran homelessness in Louisville, in collaboration with the Continuum of Care and the Veterans’ Administration. The Louisville CoC worked successfully to reduce veteran homelessness to “functional zero” by the end of calendar year 2015. Metro government and the Coalition for the Homeless (the CoC Collaborative Applicant) have now shifted efforts to focus on ending family and youth homelessness in 2018.

In 2017, the Coalition for the Homeless and their CoC partners launched a new “Rx: Housing Young Adults” initiative to end homelessness among unaccompanied young adults aged 18-24. The Coalition observed for three consecutive years the number of homeless young adults in Louisville doubled annually, reaching a peak of 562 homeless young adults in 2013. In 2015, we counted 418 young adults aged 18-24 living in adult emergency shelter or on the streets, plus an additional 450 youth below the age of 18 served at YMCA Safe Place, our partner agency that exclusively serves youth. On August 1, 2017, Louisville was one of five cities in the country to launch the 100-Day Challenge to accelerate our efforts to end homelessness among young adults. At the end of the challenge, the Rx: Housing Young Adults initiative had housed 112 young adults in just 100 days. Using the information we gained and collaboration we employed during the 100-Day Challenge, the Coalition and its partners are pushing forward to end homelessness for the remaining homeless young adults by 2020, including launching a “Host Homes” Pilot Project in 2018.

In July of 2018, the U.S. Department of Housing and Urban Development awarded Louisville with a $3.45M grant to end Youth Homelessness. The Homeless Youth Demonstration Grant was awarded to a select number of communities to create comprehensive and innovative plans to address homelessness for unaccompanied youth age 24 and under. Louisville’s Youth Homeless Committee has been working for two years to understand the numbers and needs of homeless youth in the community and develop an extensive plan to address this need. A Youth Action Board made up solely of persons under 25 who have experienced homelessness has also been advising and engaging homeless youth throughout the effort.

Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); or, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs.

Louisville Metro’s Office of Resilience and Community Services (RCS) operates eight Neighborhood Place sites. Neighborhood Place serves as a community-based “one stop shop,” providing access to RCS Louisville-Jefferson County Metro Government 87 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

homeless prevention programming such as short term rental assistance and eviction prevention services, as well as to other RCS services and services from partner agencies such as the Kentucky Department for Community Based Services, Jefferson County Public Schools, and the local Community Mental Health Center.

The Association of Community Ministries (ACM) also offers eviction prevention and homeless prevention services, including emergency rent and utility assistance, at 15 sites Metro-wide serving residents from every zip code. Louisville Metro Government supports the emergency financial assistance programs of ACM with $1,124,300 in local taxpayer dollars in Metro Fiscal Year 2018. ACM is also supported by other local grants and private donations.

Emergency rent, mortgage, and utility assistance is also available through the Society St. Vincent de Paul, which provides person-to-person assistance through more than 30 volunteer groups based at faith-based institutions in Jefferson County. Volunteers of America – Mid-States offers an Eviction Prevention Program that provides immediate financial assistance and crisis intervention to families and individuals living in Louisville Metro Housing Authority properties who are facing eviction. Additionally, anyone facing potential eviction or homelessness in Louisville Metro can call Metro United Way’s 2-1-1 social service line to be directed to appropriate homeless prevention resources, as well as to a variety of other social service resources. In addition to Jefferson County, the 2-1-1 line is available to eight additional Kentucky counties and three Indiana counties. In 2014, Metro United Way expanded the service to include a mobile app, Kentuckiana 2-1-1.

Louisville Metro Government provides HUD-funded grants to support other providers of non-monetary services for Homeless Prevention. The Legal Aid Society, funded partly by an ESG sub-recipient grant from Metro Government, provides legal counsel and representation to low-income tenants facing eviction. In Program Year 2017, this program assisted 51 clients. Louisville Urban League also offers homeownership counseling and foreclosure prevention counseling. In Program Year 2017, they served 865 persons.

In 2019, Louisville Metro Government’s Office of Resilience and Community Services (RCS) continued to provide training and employment services for individuals living in emergency shelter for the third year of the ShelterWorks Program. ShelterWorks is a partnership between RCS and KentuckianaWorks, Kentucky Manufacturing Career Center, the Salvation Army, St. John Center, UP Louisville and others. The job training program focuses on increasing life skills and employability of participants through training in high-demand sectors in addition to personalized career coaching. Participants enter ShelterWorks while they are staying in emergency shelters throughout Louisville. During the first program year, participants came from only a handful of shelters. As ShelterWorks develops, more shelters are being included and more wrap-around services are added. Participants now can earn MTEC or call center certifications, are instructed in financial and digital literacy, are provided a nominal stipend Louisville-Jefferson County Metro Government 88 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

linked to training benchmarks to aid in program retention, are given interview-appropriate clothing, provided with free bus passes to get to work once hired, and graduates are aided in obtaining housing. Sixty-six (66) persons have completed ShelterWorks training to date, with participant counts growing each time a class is offered.

Discussion

Louisville Metro’s Department of Resilience and Community Services (RCS) carries out its goals related to homelessness and non-homeless special needs largely through grants of CDBG, ESG, and HOPWA funds to subrecipients through a competitive annual process. RCS has made recommendations of the sub recipients for the Fiscal Year beginning July 1, 2019, subject to approval from the Metro Council as part of the annual budget process. These subrecipient allocations are detailed in Appendix E.

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AP-70 HOPWA Goals– 91.220 (l)(3) One year goals for the number of households to be provided housing through the use of HOPWA for:

Short-term rent, mortgage, and utility assistance to prevent homelessness of the individual or family 150 Tenant-based rental assistance 50 Units provided in permanent housing facilities developed, leased, or operated with HOPWA funds 0 Units provided in transitional short-term housing facilities developed, leased, or operated with HOPWA funds 0 Total 200

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AP-75 Barriers to affordable housing – 91.220(j) Introduction:

Louisville Metro’s Consolidated Plan outlines regulatory barriers to affordable housing, including the following:

• Louisville Metro’s comprehensive plan, Cornerstone 2020, does not include an element that specifically addresses housing. While there are five goals (K1 through K5) related to housing in the Community Form element, with seven underlying objectives, the goals and objectives are broad in nature and do not provide detailed direction on how to modify to the existing policies and regulations that affect affordable housing. Further, the plan does not provide any estimates of current and anticipated affordable housing needs. • Few incentives have been adopted into Louisville Metro’s Land Development Code to address and encourage affordable housing. The most noteworthy existing incentive is the Alternative Development Incentives (ADI) program, which is voluntary and rarely used since its adoption in 2003. Another incentive is the Conservation Subdivision program, which encourages smaller single-family lots; however developers are not required to provide dedicated affordable housing as part of this program. • A majority of the county is zoned residential and thus provides sufficient land zoned for housing by right, however most of that residential zoning is single-family residential. While single-family residential lots are sometimes developed with affordable housing, affordable housing is often associated with attached housing and multi-family residential housing.

Actions it planned to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment

Louisville Metro is in the process of carrying out several ad hoc amendments to the Land Development Code that would incentivize fair and affordable housing. In 2012 and 2013, a Louisville Metro Fair & Affordable Housing Sub-Committee met 18 times, resulting in several recommendations to a Land Development Code Main Committee and the Planning Commission. The Planning Commission voted unanimously to approve 11 of the recommendations to Metro Council.

The following amendments have been approved by Metro Council:

• Mixed Residential Development Incentive (MRDI) – A new optional incentive would be Louisville-Jefferson County Metro Government 91 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended) established, designed to encourage developments with a mixture of housing types, styles and pricing. This incentive would allow multi-family residential development to occur in certain single-family zoning districts without requiring a zoning change. A density bonus would also be offered in exchange for a commitment to provide multi-family units and affordable units. • Multi-family residential development to be allowed in the OR Office Residential District at a density of 12 units per acre. • Attached housing to be allowed in the R-5A Multi-Family Residential District.

Discussion:

Additionally, Louisville Metro initiated the process of updating its comprehensive plan, Cornerstone 2020, in 2015. The updated plan will guide development in Louisville Metro from 2020 through 2040. In the new plan, policies regarding housing will be strengthened. The new plan will include a dedicated housing element which will provide specific and detailed goals, objectives, and policies related to housing, including those addressing fair and affordable housing. A housing work group was formed in November 2016 which met regularly through the end of 2017 to develop goals, objectives, and policies related to housing for the updated comprehensive plan. The housing work group is one of six topical work groups, which also included mobility, community form, community facilities, livability and environment, and marketplace. All meetings were open to the public and typically included representation from nonprofits, government, building industry and real estate professionals, and private citizens.

The recommended Comprehensive Plan goals, objectives and policies developed by the work groups have been incorporated into a revised Comprehensive Plan proposal approved by a Comprehensive Plan Advisory Committee. The current draft Comprehensive Plan is representative of the work of hundreds, including Metro staff, an advisory committee and citizen volunteers. The Advisory Committee, made up of diverse representatives from neighborhood and community organizations as well as development and business interests finalized its recommended goals, objectives and policies on February 21, 2018. The revised Comprehensive Plan went before the Planning Commission on April 16, 2018, and the Louisville Metro Council on June 14, 2018.

The Housing Element is Section 5.6 of the revised Comprehensive Plan (found at https://louisvilleky.gov/sites/default/files/planning_design/plan_2040_-_public_review_draft_3-12- 18_reduced.pdf). It “strives to enhance housing opportunities for all residents. This Plan Element provides the policy context to encourage a diverse range of affordable and accessible housing stock throughout the community.” The three goals established by the Housing Element are:

1. Expand and ensure a diverse range of housing choices. Louisville-Jefferson County Metro Government 92 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

2. Facilitate the development of connected, mixed use neighborhoods. 3. Ensure long-term affordability and livable options in all neighborhoods

Policies established by the proposed revisions Housing Element include, but are not limited to:

• Encourage inclusive communities, overcome disparities in access to Louisville Metro assets, and enhance housing choice for all residents throughout the Louisville Metro by coordinating plans and investments to affirmatively further fair and affordable housing.

• Encourage inter-generational, mixed income and mixed-use development that is connected to the neighborhood and surrounding area

• Encourage provision of fair and affordable housing by providing a variety of ownership options and unit costs throughout Louisville Metro. Expand opportunities for people to live in quality, variably priced housing in locations of their choice by encouraging affordable and accessible housing in dispersed locations throughout Louisville Metro.

• Encourage the use of innovative methods such as clustering, mixed-use developments, cohousing, and accessory apartments to increase the production of fair and affordable housing.

• Provide safe and affordable housing opportunities and related supportive services throughout Louisville Metro to serve the homeless population and those in need of housing, including but not limited to rent assistance, transitional housing, and shelters. Allow for supportive housing to be available for individuals entering or re-entering society upon their exit from residential care facilities, correctional facilities, foster case or similar institutions.

• Incentivize the development of fair, affordable and accessible housing. Such incentives may include but not be limited to density bonuses for projects that include low/moderate income housing, waiving local fees as appropriate, and encouraging mixed-use projects that include appropriate housing components.

• Provide incentives that allow for smaller lot sizes in single family residential zoning districts to increase opportunity and limit the burdens associated with housing costs.

• Support affordable housing initiatives such as the Louisville Affordable Housing Trust Fund and Louisville CARES. Pursue a variety of sources and mechanisms including new financial and regulatory tools to preserve and develop housing units and various assistance programs for households whose needs are not met by the private market.

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• Support programs that assist homeowners with housing costs such as mortgage and home improvement loans in formerly redlined neighborhoods.

• Encourage and incentivize developments with a residential component to provide affordable and accessible housing as part of their development plan.

• Where needed, as determined by a housing needs assessment, consider regulations for certain residential developments that receive public funding or financial incentives to provide affordable and accessible housing.

• Encourage energy-efficiency investments to reduce overall housing costs and increase long term affordability.

Louisville Metro, in partnership with the Louisville Affordable Housing Trust Fund, has also undertaken a Housing Needs Assessment project, launched in May 2018. This study has: examined demographic and housing market trends in 21 market areas encompassing Jefferson County; determined the need for affordable housing at various income levels; identified areas of opportunity across Louisville’s neighborhoods; Identified obstacles to housing development and preservation, especially affordable housing development; and provided implementation strategies to enhance the quality of housing and neighborhoods. The study, conducted by Mullin & Lonergan Associates, was completed February 2019.

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AP-85 Other Actions – 91.220(k) Introduction:

The biggest challenge to meeting the needs of underserved populations in Louisville Metro continues to be limited resources. The need for affordable housing in Louisville Metro is great. Louisville Metro Government, in partnership with the Louisville Affordable Housing Trust Fund, undertook a comprehensive Housing Needs Assessment. This HNA, released February 2019, identifies the need for 31,412 units of affordable housing for the lowest income households.

The lack of safe, clean, and affordable housing continues to impact families with children across Louisville Metro. The Kentucky Department of Education reported that 5,780 Jefferson County Public School students, or 5.7% of enrolled students, were homeless at some point during the 2016-17 academic year using the definitions set forth in the McKinney-Vento Homeless Education Assistance Act. The Louisville Metro CoC Point in Time Count homeless census conducted January 31, 2019, found 1071 unduplicated people experiencing homelessness, including 953 who stayed in emergency or transitional shelters and 118 who were unsheltered (who were found on the streets or in camps). This includes 138 persons who were residing in the new “low barrier” shelter which was recently opened by Wayside Christian Mission on December 24, 2018.

Louisville Metro residents demonstrate a strong need for improved job opportunities. The 2012-2016 American Community Survey (ACS) reports that 24.6% of Jefferson County households have incomes under $25,000 per year. This need is heightened disproportionately in particular neighborhoods. 53.3% of households in the Louisville West Census County Division (CCD) and 57.9% of households in the Louisville Central CCD earned less than $25,000 per year. Median household income is $22,398 in the Louisville West CCD and $20,653 in the Louisville Central CCD, while the median income in Jefferson County is more than twice those amounts at $50,099.

Vacant and abandoned properties negatively impact our city, and many of Louisville Metro’s vacant structures and lots are concentrated in Louisville’s western neighborhoods. A block-level analysis of blight in Louisville’s western neighborhoods, completed as part of the 2013 Vacant and Abandoned Property Neighborhood Revitalization Study, found that 30% of blocks in these neighborhoods require active intervention to become stable, while an additional 35% of blocks in these neighborhoods are on the verge of decline and are showing signs of disinvestment. Vacant properties and structures pose a threat to neighborhood stability, homeowner equity, health, and public safety.

Actions planned to address obstacles to meeting underserved needs

Housing activities such as emergency repair, homeownership counseling, rental rehabilitation, down payment assistance, Affordable Housing Development, and assistance to Community Housing

Louisville-Jefferson County Metro Government 95 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Development Organizations (CHDOs) assist low- and moderate-income populations in maintaining or securing safe and affordable housing. In Program Year 2018, OHCD’s Home Repair programs will have served over 450 households. As of May 6, 2019, the HOME Down Payment Assistance Program has provided 41 new homeowners with assistance totaling $753,400.00 in Program Year 2018. It is anticipated that another 2 clients will receive assistance by June 30, 2019. In partnership with the Louisville Urban League, 879 residents have received homeownership counseling.

Particularly vulnerable homeless and special needs populations will be assisted through programs within the department and through financial assistance to nonprofit subrecipients. A ramp construction and barrier removal program will increase the mobility and self-sufficiency of individuals with physical disabilities. Homeless individuals and families will be supported through CDBG and ESG funding distributed to nonprofit subrecipients. HOPWA funding will be distributed to subrecipients to provide supportive services, tenant-based rental assistance (TBRA), and short-term rent, mortgage, and utility assistance to individuals suffering from HIV/AIDS and their families. Direct support to homeless individuals and families that need to secure housing will be provided through a HOME-funded TBRA program and ESG-funded Rapid Re-Housing. Louisville’s Common Assessment Team (funded through the Continuum of Care) will continue to perform coordinated assessments for all homeless persons and households in Louisville.

Economic Development activities such as the micro-enterprise development and loan program will assist businesses seeking to expand, create and retain jobs for low- and moderate-income individuals, and provide assistance, training, and technical support to income-eligible individuals planning to start a business. Funding for activities such as the Family Economic Success program will provide financial literacy and skills training to low-income individuals at risk of homelessness that will put them on the path to self-sufficiency.

The strategic demolition program will increase the safety and livability of the community, particularly in low- and moderate-income areas.

Actions planned to foster and maintain affordable housing

Affordable Housing Development Program

The Affordable Housing Development Program (AHDP) provides the minimum financial assistance (gap financing) to projects from qualified developers which result in owner-occupied or rental units affordable to households with incomes at or below 80% of AMI. Assistance may be provided for acquisition, new construction, substantial rehabilitation, or adaptive reuse. The purpose of the AHDP is to offer housing choices to a range of homebuyers and renters by creating neighborhoods with a diverse

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blend of affordable housing types, supported by public facilities and other amenities.

Planned HOME Affordable Housing Development Activities

Louisville Metro Government, through the Develop Louisville Office of Housing & Community Development, plans to allocate Program Year 2019 HOME Funds for affordable housing development via competitive Notices of Funding Availability (NOFAs) for both Community Housing Development Organization (CHDO) set-aside funds ($440,00) and general Affordable Housing Development Program funding ($2,187,000), in which the CHDO funding is included. Develop Louisville anticipates that responses to these NOFAs will include both multi-family rental and single-family homeownership units. (This NOFA will also include $100,000 in CDBG funding for the Affordable Housing Renewable Energy Pilot Project, to incentivize multi-family rental unit developers to include renewable energy systems in their projects.)

In October 2017, OCHD issued a NOFA for the Affordable Housing Development Program using Program Year 2016 and Program Year 2017 HOME funds. The NOFA resulted in the conditional commitment of HOME funds to the following projects:

• Telesis Corporation - City View Park Rental Rehabilitation, $800,000 (150 total units, 11 HOME units) • River City Housing 2017-2018 (CHDO) – Homeownership Single-Family New Construction, $396,000 (4 HOME units) • REBOUND Russell Adopt-a-Block (CHDO) – Single-Family New Construction, $519,964 (5 HOME units)

In October 2018, OCHD issued a NOFA for the Affordable Housing Development Program. The NOFA resulted in the conditional commitment of HOME funds to the following projects in February 2019:

• River City Housing (CHDO) – Homeownership Single-Family New Construction, $800,000 (8 HOME units) • Housing Partnership, Inc. Chapel House – Rental Rehabilitation Units, $500,000 (203 total units) • REBOUND Scattered Site (CHDO) – Homeownership Single-Family New Construction, $1,200,000 (10 HOME units)

Community Housing Development Corporation (CHDO) Program

A Community Housing Development Organization (CHDO) is a private nonprofit, community-based service organization that has achieved a special designation as a developer of affordable housing. Louisville Metro Government must reserve no less than 15 percent of HOME funds for investment in

Louisville-Jefferson County Metro Government 97 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended) housing to be developed, sponsored, or owned by CHDOs. Develop Louisville will solicit CDHOs to submit project proposals as necessary to meet the set-aside requirements.

Eligible CHDO activities include:

• Acquisition and/or rehabilitation of rental housing or homebuyer properties • New construction of rental housing or homebuyer properties • Direct financial assistance to purchasers of HOME-assisted housing that has been developed with HOME funds by the CHDO

Louisville Metro currently provides support to two CHDOs, River City Housing, Inc. and REBOUND, Inc.

Affordable Rental Unit Rehabilitation

Develop Louisville supports eligible rental rehabilitation projects which will result in additional or improved rental units for income-eligible households. $300,000 in CDBG funding will be made available for rental rehabilitation projects in the Russell NRSA from Program Year 2018 funds.

Owner-Occupied Home Rehabilitation

Louisville Metro offers several programs intended to preserve homeownership among income-eligible households. Eligibility for specific home rehabilitation programs is dependent on household needs and home conditions. Programs include:

• Emergency Repair Program – assists with eligible electrical, heating and air conditioning, and plumbing replacements or repairs • Ramp Installation and Barrier Removal – removes accessibility barriers for disabled residents (this program is also available for renter-occupied units) • Lead-Based Paint Abatement – removal of lead-based paint hazards, particularly in units occupied by young children and/or pregnant women (this program is also available for renter- occupied units)

Certain geographic areas are sometimes targeted for more extensive exterior rehabilitation in order to further strategic investments into neighborhood revitalization. Improvements may include repair or replacement of windows, entry doors, roofs, paint, vinyl siding, stairs, shutters, security windows and doors, and gutters. Program Year 2019 funding will support targeted homeowner rehabilitation efforts in the Russell NRSA. Lead-based paint abatement is supported through Metro’s Lead-Based Paint Hazard Control Grant award.

Down Payment Assistance

Louisville Metro offers down payment assistance to income eligible homebuyers in the form of Louisville-Jefferson County Metro Government 98 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

forgivable loans. This program intends to: increase homeownership among low- and moderate- income households; facilitate the de-concentration of poverty by assisting homebuyers with purchases throughout Jefferson County: encourage homeownership in Metro’s Neighborhood Revitalization Strategy Areas (NRSA); and /or encourage reinvestment in Louisville Metro’s vacant and abandoned properties (VAPs).

Actions planned to reduce lead-based paint hazards

On June 30, 2017, Louisville Metro Government received notice from HUD that our application to receive a new 3-year grant under the 2017 NOFA for the Lead-Based Paint Hazard Control Program to allow continued operations of the Lead Safe Louisville program was awarded $2,499,990 in Lead Hazard Control Grant funding with a $400,000 Healthy Homes supplement. It is anticipated that the Lead Safe Louisville program will be able to make 120 homes lead safe during this grant period.

Actions planned to reduce the number of poverty-level families

Louisville Metro Office of Resilience and Community Services (RCS) maintains a comprehensive slate of anti-poverty programs meant to address a continuum of needs from crisis to self-sufficiency. RCS will continue to operate the following programs in Program Year 2019:

• College Scholarship — Provides scholarships to low-income college students to remove educational barriers to self-sufficiency. • Financial Empowerment Services — Provides financial education classes, trains frontline staff, and coordinates financial empowerment initiatives and events. • Financial Assistance — Provides financial assistance for housing and utility payments coupled with case management services to households with an employment history. • Foster Grandparent Program — Offers seniors with limited income the opportunity to serve as mentors to children with “exceptional or special needs.” Foster Grandparents lend their time, skill, and life experiences to assist children in reaching their academic, behavioral, and developmental potential. • Homelessness and Housing Services —Provides the homeless and disabled with on-going Permanent Supportive Housing. Program participants receive ongoing supportive service assistance and work with case managers to set annual service and financial goals. • Job Development and Workforce Training — Provides scholarships to low-income job seekers to obtain specialized skills (e.g., CDL, welding, etc.) needed for living-wage employment. • Low Income Home Energy Assistance Program (LIHEAP) — provides financial assistance to prevent utility disconnection during winter months for low-income residents. • Microbusiness Program — Provides low and moderate income business owners support with starting and growing a small business, including training, technical assistance, and low-interest

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loans. • Preschool Scholarship — Provides low-income families scholarships to send children to an accredited preschool to increase kindergarten readiness. • Senior Nutrition — Operates congregate meal sites providing lunch as well as educational and recreational activities throughout the city. Senior Nutrition also administers the Meals on Wheels program, which provides nutritious meals to homebound seniors. • Supportive Services — Provides clients enrolled in case-managed department programs assistance with removing common barriers to self-sufficiency, including childcare, transportation, housing, and expungement financial assistance.

RCS also operates eight Neighborhood Place sites. Neighborhood Place serves as a community-based “one stop shop,” providing access to RCS programming as well as to services from partner agencies such as the Kentucky Department for Community Based Services and Jefferson County Public Schools under one roof. In November 2016, RCS relocated its 810 Barret Neighborhood Place site to the East Government Center in Middletown following the closure of the Urban Government Center. Additionally, RCS maintains partnerships with a large number of nonprofit service providers in the following areas: employment; education; financial literacy, advocacy, and empowerment; housing and homelessness prevention; emergency services; nutrition; community and civic participation; long-term self-sufficiency programs; and emergency health services. These partnerships make it possible to provide the best service possible for low-income individuals seeking assistance.

Actions planned to develop institutional structure

Louisville Metro will continue to work with nonprofit partners to implement the goals identified in its Consolidated Plan and annual Action Plans.

Louisville Metro will continue to collaborate with Louisville Metro Housing Authority in targeted redevelopment areas. Metro has supported LMHA’s past HOPE VI redevelopment efforts and will continue to support LMHA’s work in the Russell neighborhood through the Choice Neighborhoods grants and Vision Russell project. A number of Louisville Metro Government agencies, including Develop Louisville, the Office for Safe and Healthy Neighborhoods, Louisville Metro Police Department, the Department of Economic Development, the Office of Resilience and Community Services, and the Department of Public Health and Wellness, are represented on the coordinating committee and task forces for the Choice Neighborhoods effort and will continue to be heavily involved in ongoing efforts in the neighborhood. Since the initial $425,000 Choice Neighborhoods Planning Grant award for Russell in January 2015, the extensive interagency collaboration and community involvement surrounding the initiative in Louisville resulted in successful applications for additional Action Grant funding ($1,000,000)

Louisville-Jefferson County Metro Government 100 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

and Implementation Grant funding ($29,575,000).

Develop Louisville intends to continue expanding and fostering partnerships, both within Metro Government and with external partners, to enhance coordination in targeting resources within the community.

Staff from Develop Louisville and the Office of Resilience and Community Services will attend professional development events and complete trainings as available to ensure continued compliance with federal regulations and knowledge of innovative housing, community development, homelessness, and anti-poverty programs.

Actions planned to enhance coordination between public and private housing and social service agencies

RCS’ extensive coordination and linkages with government and other social programs ensure effective delivery of services and reduce the risk of duplicating services. RCS collaborates with more than 100 agencies and/or forums, including Metro departments, state agencies, service providers, faith-based organizations, and others. Going forward, RCS plans to evaluate these linkages, focusing on creating quality, engaged relationships as well as identifying and eliminating gaps in order to better serve the low-income community.

RCS will continue to be heavily involved in the Louisville Continuum of Care, which is coordinated through the Coalition for the Homeless. RCS is represented on the CoC Board and Advisory Board, at monthly CoC meetings, and holds monthly coordination meetings with the Coalition.

Discussion:

Louisville-Jefferson County Metro Government 101 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Program Specific Requirements AP-90 Program Specific Requirements – 91.220(l)(1,2,4)

Introduction:

Louisville Metro has prepared program specific requirements for the use of CDBG program income, HOME recapture, and ESG performance standards.

Community Development Block Grant Program (CDBG) Reference 24 CFR 91.220(l)(1) Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in projects to be carried out.

1. The total amount of program income that will have been received before the start of the next program year and that has not yet been reprogrammed 0 2. The amount of proceeds from section 108 loan guarantees that will be used during the year to address the priority needs and specific objectives identified in the grantee's strategic plan. 0 3. The amount of surplus funds from urban renewal settlements 0 4. The amount of any grant funds returned to the line of credit for which the planned use has not been included in a prior statement or plan 0 5. The amount of income from float-funded activities 0 Total Program Income: 0

Other CDBG Requirements

1. The amount of urgent need activities 0

2. The estimated percentage of CDBG funds that will be used for activities that benefit persons of low and moderate income.Overall Benefit - A consecutive period of one, two or three years may be used to determine that a minimum overall benefit of 70% of CDBG funds is used to benefit persons of low and moderate income. Specify the years covered that include this Annual Action Plan. 76.00%

HOME Investment Partnership Program (HOME) Reference 24 CFR 91.220(l)(2) 1. A description of other forms of investment being used beyond those identified in Section 92.205 is

Louisville-Jefferson County Metro Government 102 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

as follows: Louisville Metro uses no other forms of investment beyond those identified in Section 92.205. Under 92.205, a participating jurisdiction may invest HOME funds as equity investments, interest-bearing loans or advances, non-interest-bearing loans or advances, interest subsidies consistent with the purposes of the HOME program, deferred payment loans, grants, or other forms of assistance that HUD determines to be consistent with the purposes of the program. Each participating jurisdiction has the right to establish the terms of assistance, subject to the requirements of this part.

2. A description of the guidelines that will be used for resale or recapture of HOME funds when used for homebuyer activities as required in 92.254, is as follows: For homebuyers and rental projects assisted with HOME funds the length of the affordability period depends on the amount of the HOME investment in the property and the nature of the activity funded. The table below provides the affordability periods:

HOME Investment per Unit Length of the Affordability Period Less than $15,000 5 years $15,000 - $39,999 10 years $40,000 or more 15 years New construction or Rental Projects 20 years

3. A description of the guidelines for resale or recapture that ensures the affordability of units acquired with HOME funds?

See 24 CFR 92.254(a)(4) are as follows: Sale Prior to Completion of the Period of Affordability

If the homeowner sells their property, whether voluntarily or involuntarily, during the Period of Affordability, then the property is subject to recapture provisions (as described in the following section) in compliance with HOME Regulations. If the current homebuyer is subjected to substantial unforeseen hardships which necessitate that the homebuyer sell his or her home, prior to the period of affordability term, and would like a designee to assume the mortgage, Metro, on a case by case basis, and in its sole but reasonable judgment, may exercise this right of assumption to an

Louisville-Jefferson County Metro Government 103 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

income-qualified designee.

Resale/Recapture Provisions 92.254 (a)(5)

Definitions

Resale: Under the resale provision, the period of affordability is based on the total HOME subsidy in the project. Under this provision, an assisted homebuyer is obligated to sell his/her property only to another HOME eligible buyer at a price that is deemed by the by Louisville Metro Government to be fair to both parties.

Recapture: Under the recapture provision, the period of affordability is based on the direct HOME subsidy to the homebuyer only. Under this provision, the homeowner repays all or some of the HOME subsidy and is able to sell his/her home to any buyer at any price.

Louisville Metro Government does not use the resale provision for any HOME-assisted properties. Louisville Metro Government places restrictions on all HOME-assisted homebuyer properties by electing to use the recapture provision for all of its Homebuyer Assistance Programs in an effort to help preserve affordable housing.

The recapture provision used by Louisville Metro Government is reduction during affordability period. Louisville Metro Government will require the direct HOME subsidy to be repaid if the client sells the home, voluntarily or involuntarily, before the period of affordability expires. This recapture provision will include a forgiveness schedule for homebuyer assistance loans with variable terms for five, ten, or fifteen-year periods of affordability as outlined below:

• Homebuyers receiving less than $15,000 are subject to a five (5) year period of affordability. If the homebuyer does not violate any terms of the mortgage agreement, 50% of the homebuyer assistance amount shall be forgiven on the fifth (5th) year from the date of the mortgage, with the remaining principal due at sale. • Homebuyers receiving $15,000 to $39,999 are subject to a ten (10) year period of affordability. If the homebuyer does not violate any terms of the mortgage agreement, then ten percent (10%) of the homebuyer assistance amount shall be forgiven for each full year beginning with the sixth (6th) year from the date of the mortgage, with 50% forgiven on the tenth (10th) year from the date of the mortgage and the remaining principal due at sale. • Homebuyers receiving $40,000 or more are subject to a fifteen (15) year period of affordability. If the homebuyer does not violate any terms of the mortgage agreement, then five percent (5%) of the homebuyer assistance amount shall be forgiven for each full year beginning with the sixth (6th) year from the date of the mortgage, with 50% forgiven on the fifteenth (15th) year from the date of the mortgage and the remaining principal due at sale.

Louisville-Jefferson County Metro Government 104 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

Example: Mr. John Doe purchases a home for $100,000 and receives $8,000 in HOME funded homebuyer assistance funds from Louisville Metro. This $8,000 loan is subject to recapture should Mr. Doe sell the property during the five year period of affordability. After three years, Mr. Doe sells the property. At this point, 0% of the homebuyer assistance amount has been forgiven and the entire loan balance of $8,000 must be repaid from the net proceeds of the sale.

Example: Ms. Jane Smith purchases a home for $120,000 and receives $20,000 in HOME funded homebuyer assistance funds from Louisville Metro. This $20,000 loan is subject to recapture should Ms. Smith sell the property during the ten year period of affordability. After seven years, Ms. Smith sells the property. At this point, 40% percent of the homebuyer assistance amount, or $8,000, is forgiven resulting in a loan balance of $12,000 to be repaid from the net proceeds of the sale.

If the net proceeds of the sale are inadequate to repay the direct HOME subsidy, the amount recaptured will be equal to the net proceeds available.

“Net Proceeds” are defined as the sale price (whether from a voluntary or involuntary sale) minus the repayment of any superior loans (other than HOME Funds) and any closing costs.

Sample net proceeds calculation: Net Proceeds $130,000

Home sale price -$110,000 Superior non-HOME debt Closing costs -$5,000

$15,000

Homebuyer investment outside of closing costs shall not be subtracted from net proceeds.

Louisville Metro Government shall impose recapture provisions through a HOME written agreement, as a separate legal document from any loan instrument. The HOME written agreement with the homebuyer shall make the period of affordability, principal residency requirements, and terms and conditions of the recapture requirements clear and detailed. The HOME note will also be used to impose the recapture requirements.

Louisville Metro Government shall perform ongoing monitoring of the principal residency requirement during the period of affordability.

4. Plans for using HOME funds to refinance existing debt secured by multifamily housing that is rehabilitated with HOME funds along with a description of the refinancing guidelines required that will

Louisville-Jefferson County Metro Government 105 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

be used under 24 CFR 92.206(b), are as follows: HOME funds will not be used to refinance existing debt secured by multifamily housing that is being rehabilitated with HOME funds.

Emergency Solutions Grant (ESG) Reference 91.220(l)(4)

1. Include written standards for providing ESG assistance (may include as attachment)

Standard Policies and Procedures for Evaluating Persons or Families Eligible for Assistance

In conjunction with Emergency Solutions Grant regulations at 24 CFR 576.400(d) homeless individuals and families must enter the homeless service provider system through the Single Point of Entry (SPE) established by the Coalition for the Homeless. The SPE is called the “Bed One-Stop.” Individuals and families who are not homeless but are seeking assistance are diverted to more appropriate community resources, such as Neighborhood Place and Metro United Way.

All persons seeking homeless shelter services should contact the Bed One-Stop at the Coalition for the Homeless for assessment and referral. This assessment begins with intake by phone or at the Coalition Bed One-Stop office. Intake staff will collect the HMIS universal data elements necessary to enter the client into the HMIS system and to make a referral to emergency shelter. After 14 days in shelter, each person will be assessed by the Common Assessment Team staffed by Family Health Centers to help make appropriate referrals to the best options including permanent housing, transitional housing, and rapid re-housing.

The types of ESG assistance available will fall into 4 categories: prevention, rapid re-housing, emergency shelter and homeless services. The intake staff will also evaluate ESG eligibility and a participant’s eligibility will be confirmed during the common assessment. The common assessment is an in-depth assessment of the client’s needs. An individual plan for that client will then be developed that includes a housing goal and an income goal. The plan will also include referrals to mainstream resources, such as Social Security Disability, food stamps, Section 8, or services for veterans. Program participants will then be referred to the most appropriate available program. Their individual plan will go with them. At the end of each common assessment, a checklist will be completed that will determine which programs may be appropriate for that participant. The agency staff will then go over the program options with the client to address questions, concerns and preferences. The staff will check the capacity of the best program for that client. If the first program choice is full and will be at capacity for more than 30 days, the agency staff will direct the client to the next best program.

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The Louisville Common Assessment Team (funded through the Louisville Continuum of Care) began performing coordinated assessments for all homeless persons and households in Louisville, KY in the spring of 2014. The actual Common Assessment survey tool is incorporated from the national 100,000 Homes survey tool [the Vulnerability Index/Service Prioritization Decision Assistance Tool (VI- SPDAT)] and will be used to prioritize those using Louisville’s homeless system by various vulnerabilities. The Common Assessment Team also maintains and refers from one community referral list for all HUD COC funded transitional and permanent supportive housing options in Louisville, KY. ESG Rapid Re- housing referrals are also coordinated through the Common Assessment Team. All referrals are made based on vulnerability ranking as determined by the VI-SPDAT.

Policies and procedures for coordination among providers

Coordination among providers will be attained through the Continuum of Care, the common assessment process, the White Flag program, HMIS, and monthly, board, advisory, and committee meetings. The common assessment process allows providers to refer clients to other providers as appropriate. All ESG providers are required to be active participants in our community’s Continuum of Care, which will serve as a vehicle to discuss system-wide issues and concerns. The White Flag program is the coordinated response to inclement weather that makes it unsafe for people to be on the streets White Flag served 1,593 unduplicated clients in Program Year 2017. ESG subrecipients are also able to participate in the ESG Interagency meetings which will be held as needed.

Policies and procedures for determining and prioritizing who will receive homeless prevention or rapid re- housing

Program placement will be based on need, eligibility, capacity of the programs, and the appropriateness of programs for participants. Program participants who are eligible for Continuum of Care-funded Permanent Supportive Housing programs or other subsidized permanent housing programs will be referred to those programs first. Program participants who are at-risk of homelessness but who will lose their housing before a prevention program can be of assistance will typically be referred to a rapid re- housing program. The placement of other participants in a rapid re-housing or prevention program will be determined during the in-depth assessment process and the development of an individualized plan. Participants who seem to be able to achieve housing stability with a short period of assistance will be prioritized for rapid re-housing programs.

ESG prevention assistance is currently limited to one program: Legal Aid Society’s eviction prevention program. The Legal Aid Eviction Prevention program provides legal counseling to help participants avoid eviction. Any individual or family who is eligible for prevention assistance and facing eviction can receive legal counseling through this program. The amount and type of services received is determined on a Louisville-Jefferson County Metro Government 107 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

case –by-case basis. In Program Year 2017, Legal Aid Society served 51 clients.

Louisville’s Common Assessment Team (funded through the Louisville Continuum of Care) began performing coordinated assessments for all homeless persons and households in the jurisdiction in May 2014. The Common Assessment Team will also maintain and refer from one community referral list for all permanent supportive housing options in Louisville, KY. The Common Assessment Team makes all referrals to the ESG Rapid Re-Housing Program. All emergency shelter referrals are made by Bed One- Stop.

Standards for determining the participant share of rent and utilities

The participant share of rent and utilities can be determined in one of two ways, either through a “shallow subsidy” model or a “lump sum” model. Louisville Metro’s Office of Resilience Community Services (RCS) and Revitalization department intends to do a “lump sum” payment standard for ESG direct client assistance. The payment standard will be based on household size (i.e. single-person household will receive up to $500 in monthly ESG assistance, two-person household will receive up to $550, etc.). Louisville HPRP had considerable success administering a lump sum payment standard for HPRP. The monthly payment will be for rent, but utility payments could be made on a case-by-case basis (provided that the lump sum assistance amount is not exceeded for the household size).

Standards for determining the length and level of assistance

Prevention assistance will be provided to eligible program participants in the amount necessary to stabilize their housing, as determined by the assessment process. The standards used to determine the amount to be provided will include: the level of available social supports (i.e. whether or not the person being assessed has exhausted supports from family, friends, churches or other potential supports) and the documentation of eligibility and need (i.e. the documentation of income and the threat to housing stability.)

Emergency Shelter will be provided to program participants who are homeless, as defined by HUD in 24 CFR 576.2.1. Emergency Shelter will be provided for no more than 180 days, with the expectation that program participants will have moved on to a housing solution. The exception to the 180 day length of stay will be made for those program participants who refuse other services in writing before they exceed 180 days in an emergency shelter in a program year. An exception can also be made if an individual plan calls for permanent housing or transitional housing, and those programs are at capacity and unable to be utilized for immediate housing placement. Essential Services will be available to any program participant utilizing Emergency Shelter. A case manager will provide an in-depth assessment and individualized plan for all program participants within the first 14 days of a participant’s stay in the shelter. Additional case management will be provided on an as needed basis and no-less than monthly Louisville-Jefferson County Metro Government 108 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

for program participants in emergency shelter until they are moved to a program providing them a housing solution.

Rapid re-housing rental assistance will be provided to program participants who are prioritized through Louisville’s coordinated assessment team (“Common Assessment Team”). Based on current national perspective, rapid re-housing seems to work best for homeless families and others who need shorter- term interventions. The goal is for rapid re-housing program participants to achieve housing stability in a relatively short amount of time. The current ESG rapid re-housing program is set-up as a flat 12 months of assistance, with the payment standard dependent upon the size of the program participants’ household. There is a declining payment standard starting with the tenth month of assistance. The ESG rental assistance drops $50 in the tenth month, another $50 in the eleventh month, and then another $50 in the twelfth month of assistance. Twelve months has been set for the program due to local landlord preferences. Many local landlords are hesitant to agree to program requirements if less than a standard 12-month lease is provided. Case management services are provided at least monthly for all ESG and CoC rapid re-housing program participants. In addition, housing placement services are provided on the front end of the program to ensure that qualifying program participants secure housing as soon as possible. In Program Year 2017, rapid re-housing rental assistance was provided to 131 clients in 52 households.

All ESG subrecipients will have a written termination procedure with the following minimum standards: written notice to the program participant containing a clear statement of the reasons for termination; a review of the decision, in which the program participant is given the opportunity to present written or oral objections to a person who is not the person who initiated the termination or a subordinate of that person; and prompt written notice of the final decision to the program participant. The termination of a client will not bar the program participant from receiving further assistance at a later date.

Standards for determining the type, amount and duration of housing stabilization services, including limits.

Housing stabilization services will be provided as needed to program participants receiving prevention and rapid re-housing assistance. Each ESG participant receiving housing stabilization services will have a unique and individualized case plan. Housing stability case management will be provided once a month to program participants. Except for housing case management, no participant may receive more than 24 months of assistance over 3 years.

Standards for Street Outreach

ESG subrecipients providing street outreach will work with service providers and other community Louisville-Jefferson County Metro Government 109 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

networks to identify, support, and stabilize the unique needs of those w h o a r e l i v i n g on t h e street. Street Outreach Teams will collect basic information in the attempt to add information into HMIS. Those who want to engage further will be screened through the coordinated assessment process. Appropriate referrals and resources will be identified based on this assessment.

Those living on the streets may be served by one of several street outreach teams currently active within the Louisville Continuum of Care (CoC). The Seven Counties Mental Health Outreach team is funded through the Louisville CoC and federal PATH funds and is the primary street outreach team for homeless adults with mental health concerns in Louisville. YMCA Safe Place Services is funded partially with Street Outreach Runaway and Homeless Youth funding through the Department of Health and Human Services (DHHS) and focuses on at-risk populations of 12 to 22 year olds, with primary education efforts to 12 to 17 year olds and street outreach and case management services to 18 to 22 year olds. They perform street outreach 5 days/nights a week in areas around Louisville, KY. In Program Year 2016, YMCA Safe Place Services provided assistance to 132 clients. Medical Street Outreach is provided by Family Health Centers – Phoenix. As Louisville’s only Healthcare for the Homeless program, FHC serves over 80% of those who are homeless. The street outreach team includes a physician or practitioner, medical assistant, and social worker and provides essential medical services. The team conducts medical outreach two days per week to area day shelters, community kitchens, homeless campsites, and other areas where homeless individuals congregate. Family Health Centers – Phoenix served 92 clients in Program Year 2017.

Centerstone Mental Health Outreach leads the annual homeless Street Count each January and coordinates three Assertive Community Treatment (ACT) teams that assist chronically homeless on the streets. Homeless street outreach is also performed in Louisville by the Wayside Christian Mission Samaritan Patrol, the River City Love Squad, and the Healing Place CAP Van outreach effort. These additional outreach teams do not receive Continuum of Care funding and operate on a more limited basis, but do perform consistent homeless street outreach efforts throughout the year.

Standards for Emergency Shelters

ESG Program Participants will be admitted to the shelter system through Bed One-Stop (Louisville’s Single-Point of Entry team maintained by the Coalition for the Homeless), where the capacity of each shelter, client preference and client eligibility will be assessed on a limited basis prior to shelter bed referral. Bed One-Stop will refer clients to a shelter with available beds and divert persons who are not eligible. If all participating shelters are at capacity the SPE will work with eligible participants to access alternate resources until they can access a bed. Bed One-Stop also coordinates referrals for the White Flag program, which allows three shelters to open additional space during inclement weather to ensure the safety of homeless persons.

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ESG regulations at 24 CFR 576.102(b) prohibits involuntary family separation. As such the age, of a child under age 18, must not be used as a basis for denying any families’ admission to a shelter that serves families with children under 18. For example, a shelter that serves families may not deny services to a family due to the presence of a teenage child of either gender.

Emergency shelters will discharge participants once participants have been referred and accepted into another program or have accessed permanent housing. Emergency shelters will follow the same termination policy outlined in the Standards for Determining the Length and Level of Assistance, if warranted.

All emergency shelters in Louisville are governed under Louisville Metro Government’s Land Development Code section 4.3.13 and licensed per Louisville Metro Code of Ordinances Chapter 115 Sections 001 through 010. Each shelter is subject to annual inspections for health and safety. Emergency Day Shelters are not subject to the licensing requirement and will be subject to an annual habitability inspection as part of their monitoring by Louisville Metro Government. In addition, all of Louisville’s emergency shelters undergo the Quality Assurance Standard (QAS) process administered by the Coalition for the Homeless. The QAS process reviews programmatic, policy and professional standards. Failure to comply with the QAS process and standards is reported by the Coalition for the Homeless to Louisville Metro Government. A lack of compliance will elevate a subrecipient’s risk assessment status (for program monitoring) and is a factor in future ESG funding decisions.

The needs of special populations will be addressed by identifying program participants (through the new common assessment process) who are affected by HIV/AIDS, mental health issues, domestic violence, sexual assault or other issues that require additional services besides those offered to the general population and referring those participants to appropriate services. The new VI-SPDAT coordinated assessment tool identifies participants with special needs during the assessment process. The new CAT will be trained on proper referral for those that identify with special needs. Additional HUD housing program options (i.e. non-CoC funded housing) are included as housing referral options for the new coordinated assessment system in Louisville (i.e. HOPWA, HOME TBRA, etc.). Emergency shelter staff will assist the Common Assessment Team in conducting VI-SPDATs over the course of the program year.

In addition to the tools provided through the common assessment and referral process, training will be provided to help deal with the sensitive issues of these vulnerable populations. The Center for Women and Families, House of Ruth, Wellspring, etc. may be involved in annual training efforts with Louisville’s Continuum of Care. The ESG program manager will work to coordinate other trainings related to serving vulnerable populations.

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Homeless Participation Policy

The Homeless Consumer Participation Task Force formed in June 2012 to address and encourage the participation of homeless and formerly homeless persons in the homeless services system. The Task Force was guided by the ESG written standards submitted as part of the second amendment to the 2011 Action Plan. This group organizes Consumer Participation research activities that serve to engage those who are homeless or who are formerly homeless. The Task Force is made up of mostly emergency shelter staff members who do outreach to potential group members and run the meetings. Formerly homeless individuals participate in the Task Force as well. The purpose of the Client Participation group is to engage those served by the homeless system, inform them of policy issues, and seek their input on these issues. A primary activity of the Task Force is engaging consumers through the annual Project Stand Down/Homeless Connect event to get feedback on needs, concerns, and experiences with homeless services in Louisville. At the 2014 Stand Down, University of Louisville social work students interviewed over 74 consumers on behalf of the Task Force. The Task Force also engages in research and outreach to targeted subpopulations. For example, the winter and spring 2015 project was to conduct interviews with transgender persons who are, or have, used the homeless services system. The goal was to learn about consumer experiences and to gauge both consumers’ and shelter staffs’ knowledge of the rights and responsibilities under the Equal Access to Housing final rule and HUD Notice 15-02, Appropriate Placement for Transgender Persons in Single-Sex Emergency Shelters and Other Facilities.

Insight and information gained from Task Force activities are sent to each participating agency’s board and to the board of the Coalition for the Homeless, and shared with the Continuum of Care. When appropriate, the Coalition for the Homeless and Louisville Metro will engage agencies in a wider conversation about how to address information that arises from the client participation group, including whether or not to change policies and procedures that all participating agencies are held to. ESG agencies who are actively engaged in this group will be able to meet the ESG rules and regulation requirement for participation from the homeless and/or formerly homeless persons. Agencies who don’t participate in this are expected to have a homeless or formerly homeless person on their respective board of directors, to perform regular client surveys that affect policies and procedures, to hold regular client participation meetings, or some combination of these activities. All ESG agencies should have a written Homeless Participation Policy and Louisville Metro monitors for this.

Participation in HMIS and Performance Standards to Evaluate ESG activities

In FY13, a common set of outcomes for ESG were developed in collaboration with the HMIS lead agency and CoC coordinator that will be measured through HMIS:

Louisville-Jefferson County Metro Government 112 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended)

ESG Outcomes and Benchmarks 1. 25% of those leaving emergency shelter will move into permanent housing. 2. The average length of stay in emergency shelter will be 30 days or less. 3. 25% of those leaving emergency shelter will leave with cash income. 4. 10% of those leaving emergency shelter will have employment. 5. 50% of those leaving emergency shelter will leave with non-cash benefits. 6. 85% of those leaving emergency shelter will have a known destination in HMIS. 7. 75% of those who receive prevention assistance will remain housed after 6 months. 8. 75% of those who receive street outreach assistance will move into shelter of some kind (emergency or permanent).

Louisville Metro Government requires that all ESG subrecipients participate in HMIS (except for those providing legal services, services to the victims of domestic violence or sexual assault and those serving HIV/AIDS affected participants); as applicable under ESG rules and regulations. Subrecipients serving these populations are required to use an equivocal system to provide the necessary summary reports to Louisville Metro Government. This requirement will be included in each subrecipient’s grant agreement and will be enforced through program monitoring.

Also, ESG Performance standards will be measured through HMIS. The standards that will be measured to evaluate ESG activities include: service provider’s ability to move persons from emergency/transitional/unstable housing to permanent housing; service provider’s ability to assist clients in increasing income from entry into the homeless provider system to exit; service provider’s ability to reduce the recidivism rate within the homeless provider system; and a service provider’s ability to reduce the length of people’s stay within the homeless provider system; as well as occupancy rates (average of four Point In Time counts) for overnight shelters and service delivery rates (how often/how much case management is being provided) for service providers.

Process for Making Subawards

Louisville Metro Government’s process for making subawards is a competitive application process. Each year, Louisville Metro Government announces to past ESG subrecipients and the larger CoC body that applications are being accepted. A panel scores and ranks applications in order to make a funding recommendation to the Mayor. The panel’s recommendation goes to Louisville Metro Council for review and approval, as part of the city’s larger budget process. Recommended ESG awards are included in Appendix Section F.

Consultation with Continuum of Care

The policies described above were developed in conjunction with the CoC in 2012 in response to

Louisville-Jefferson County Metro Government 113 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended) HEARTH Act changes to CoC activities and governance. The Louisville Metro Government ESG program manager consults and collaborates with the CoC through meetings, presentations and conversations as needed. The Louisville Metro Government ESG program manager is a CoC representative and also serves on the CoC advisory board. Through these roles, the ESG program manager is able to consult with the CoC about program goals, operations, and standards. ESG changes, updates and issues are regularly discussed at CoC meetings. All ESG subrecipients are members of the CoC.

To address the needs of special populations in the written standards, Louisville Metro Government consults and collaborates with agencies who serve those with mental illness, the chronically homeless, victims of domestic violence and sexual assault, transgender persons, and those who are affected by HIV/AIDS to provide input under the ESG Written Standards on how to best serve these vulnerable groups.

Louisville Metro Government maintains regular consultation with the CoC about program goals, operations, and standards, including common assessment implementation, single point of entry, and homeless participation.

Additionally, in March 2014, the CoC appointed a Board of Directors:

Louisville-Jefferson County Metro Government 114 Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended) Louisville/Jefferson Co. KY Continuum of Care KY-501 1300 S. 4th. St. Suite 250 Louisville, KY 40208

2019 Board of Directors

Louisville Continuum of Care Board of Directors-2019 Name Organization Term Ends Laura Albovias Wellspring Mental Wellness 12/31/20 Mark Bolton Louisville Metro Department of 12/31/19 Corrections, Director Gerry Gordon Brown Retired (Expert on state disability 12/31/20 programs) Jennifer Clark St. Vincent de Paul 12/31/19 Single male/chronically homeless Greg Conley Chair District Court 12/31/20 Giselle Danger-Mercaderes JCPS - Student Equity and Community 12/31/21 Engagement, Coordinator Kim Frierson National Safe Place 12/31/19 Unaccompanied Youth KiAndra Hilliard Youth Advisory Board Consumer 12/31/19

Ann Lanham Lanham Holdings Landlord 12/31/20

Rosemary Luckett Kentucky Housing Corporation 12/31/20 State Representative Epiphany McGruder Lou Metro Housing & Community 12/31/21 Development, Program Services Coordinator (ESG) Pat McKiernan Veterans/Substance Abuse 12/31/19 Michelle Neuhauser Consumer Representative 12/31/19 Lisa Osanka ( Louisville Metro Housing Authority 12/31/18 Stewart Pope Secretary Legal Aid Society 12/31/20 Heath Rico-Storey Lou. Metro Housing Authority 12/31/21

Andrea Scott UP 12/31/21

Donna Trabue Volunteers of America Families, DV, 12/31/19 HIV/AIDS Aaron Weathers LGBT Center HSC, UofL 12/31/20 Shameka Parrish- Wright Small business owner, consumer 12/31/21 representative Erin Rutherford ** Coalition for the Homeless

Mary Frances Schafer Coalition for the Homeless-CoC Lead n/a (Not a member of the CoC Board) ** Not a member of the CoC Board Updated: March 14, 2019

115 Louisville-Jefferson County Metro Government Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended) 2. If the Continuum of Care has established centralized or coordinated assessment system that meets HUD requirements, describe that centralized or coordinated assessment system.

Louisville Metro's Common Assessment Team is described in the written standards under "Policies and Procedures for Determining and Prioritizing Who Will Receive Homeless Prevention or Rapid Re- Housing.

3. Identify the process for making sub-awards and describe how the ESG allocation available to private nonprofit organizations (including community and faith-based organizations).

The process for making ESG subawards is described in the written standards under “Process for Making Subawards.”

4. If the jurisdiction is unable to meet the homeless participation requirement in 24 CFR 576.405(a), the jurisdiction must specify its plan for reaching out to and consulting with homeless or formerly homeless individuals in considering policies and funding decisions regarding facilities and services funded under ESG.

Homeless participation is addressed in the written standards under “Homeless Participation Policy.”

5. Describe performance standards for evaluating ESG.

Performance standards for evaluating ESG are described in the written standards under “Participation in HMIS and Performance Standards to Evaluate ESG Activities.”

HOPWA Project Sponsor Selection

The Office of RCS will solicit applications from any interested community organizations, including grassroot or faith-based entities to administer/sponsor HOPWA funds. The selected sponsors will be chosen via a competitive application process. The applications will be reviewed by a panel consisting of staff from the Office of Resilience and Community Service (RCS), the Office of Management and Budget (OMB), Develop Louisville and/or The Coalition for the Homeless. This panel will make grant recommendations for grant awards.

116

Louisville-Jefferson County Metro Government Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended) 117

Louisville-Jefferson County Metro Government Program Year 2019 Action Plan - Amended June 12, 2019 (Original); May 21, 2020 (Amended) Appendices 2019 Action Plan - Amended July 1, 2019 – June 30, 2020

118 APPENDICES Louisville Metro Government Program Year 2019 Action Plan

Appendix A: Program Year 2019 Action Plan Budgets...... 120

Appendix B: Public Comments Received at Public Hearings Held February 25, 2019 And May 23, 2019 with Develop Louisville’s Response ...... 125

Appendix C: Affidavit of Publication of for Public Hearings Held February 25, 2019 and May 23, 2019 ...... 132

Appendix D: Summary of Louisville Metro Department of Resilience & Community Services 2019 Needs Assessment Survey Results ...... 136

Appendix E: Louisville Metro Department of Resilience & Community Services 2019 Subrecipient Awards ...... 143

Appendix F: Russell Neighborhood Revitalization Strategy Area (NRSA) Map ...... 150

2019 Action Plan Amendment: CARES Act COVID-19 Response...... 153

Amendment Appendices and Supporting Documents...... 175

118 Louisville-Jefferson County Metro Government Program Year 2019 Action Plan June 12, 2019 119 Appendix A

Program Year 2019 Action Plan Budgets:

1. CDBG 2. HOME 3. ESG 4. HOPWA

Louisville-Jefferson County Metro Government 120 Program Year 2019 Annual Action Plan June 12, 2019 COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) - 2019 ACTION PLAN BUDGET CATEGORY ACTIVITY BUDGETED AMOUNT TOTALS

HOUSING RusselllAffordable Housing Homeowner Unit Preservation 2,318,000 Emergency Repair Program 600,000 Homeowner Accessibilty Improvements 200,000 Residential Programs Delivery 950,300 Total Housing 4,068,300

RELOCATION Relocation 10,000 Total Relocation 10,000

CLEARANCE Vacant Properties Demolition 530,600 Total Clearance 600,000

PUBLIC SERVICE Homeless Services Support 156,000 Homeless Services External Agencies 1,114,900 Homeownership Counseling 103,100 Family Economic Success Program 381,400 Total Public Service 1,755,400

PUBLIC FACILITIES AND IMPROVEMENTS LMHA Russell Choice Neighborhood Infrastructure 3,125,000 3,125,000 ECONOMIC DEVELOPMENT RCS Microenterprise Activities 213,600 *Russell NRSA Microenterprise Activities 75,000 Total Economic Development 288,600

ADMINISTRATION AND PLANNING RCS/DL Department Services 1,349,600 Urban Design/Landmarks 236,400 Coalition for the Homeless 112,100 Indirect Cost 250,000 Total Administration and Planning 1,948,100

TOTAL CDBG 2019 ACTION PLAN BUDGET 11,726,000

2019 ACTION PLAN CDBG FUNDS Louisville-Jefferson County Metro Government ROUNDED113 2019 Entitlement Funds Program Year 2019 Annual Action Plan 11,190,723 11,190,700 Prior Year Resources June 12, 2019 335,267 335,300 FY19 Estimated Program Income 200,000 200,000 TOTAL 2019 ACTION PLAN CDBG FUNDS 11,725,990 11,726,000 HOME INVESTMENT PARTNERSHIPS PROGRAM - 2019 ACTION PLAN BUDGET ACTIVITY BUDGETED AMOUNT Community Housing Development Organization (CHDO) $ 440,000 Affordable Housing Development $ 2,187,000 Homebuyer Assistance $ 100,000 Tenant Based Rental Assistance $ 298,100 HOME Administration $ 221,100 TOTAL HOME 2019 ACTION PLAN BUDGET $ 3,246,200

2019 ACTION PLAN HOME FUNDS ROUNDED 2019 Entitlement Funds $ 2,932,633 $ 2,932,600 Prior Year Resources $ 163,876 $ 163,900 FY 19 Estimated Program Income $ 149,691 $ 150,000 TOTAL 2019 ACTION PLAN HOME FUNDS $ 3,246,200 $ 3,246,500

Louisville-Jefferson County Metro Government 122 Program Year 2019 Annual Action Plan June 12, 2019 EMERGENCY SOLUTIONS GRANT - 2019 ACTION PLAN BUDGET ACTIVITY BUDGETED AMOUNT Emergency Shelter $ 516,300 Prevention $ 129,500 Street Outreach $ 54,200 Rapid Re-Housing $ 301,700 ESG Administration (7.5%) $ 28,700 TOTAL 2019 ACTION PLAN ESG FUNDS $ 1,030,400

2019 ACTION PLAN ESG FUNDS 2019 Entitlement Funds $ 950,821 Prior Year Resources $ 79,579 TOTAL 2019 ACTION PLAN ESG FUNDS $ 1,030,400

Louisville-Jefferson County Metro Government 123 Program Year 2019 Annual Action Plan June 12, 2019 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS (HOWPA) 2019 ACTION PLAN BUDGET ACTIVITY BUDGETED AMOUNT Housing Assistance and Supportive Services $ 830,399 HOPWA Administration (3%) $ 25,682 TOTAL 2019 ACTION PLAN HOPWA FUNDS $ 856,081

Louisville-Jefferson County Metro Government 124 Program Year 2019 Annual Action Plan June 12, 2019 Appendix B

Public Comments Received at Public Hearings Held February 25

and May 23, 2019 with Develop Louisville’s Response

Louisville-Jefferson County Metro Government 125 Program Year 2019 Annual Action Plan June 12, 2019 Hope Leet Dittmeier – Mattingly Edge

DEVELOP LOUISVILLE PUBLIC HEARING FOR CITIZEN PARTICIPATION IN DEVELOPING THE 2019 ACTION PLAN

February 25, 2019

Hello. Thank you for the opportunity to share my thoughts about housing needs. My name is Hope Leet Dittmeier. I am the Executive Director at Mattingly Edge. We are a nonprofit organization that cultivates partnerships that enable people with disabilities to thrive at work, at home and in relationship. This mission calls us to assist people with disabilities to find accessible, affordable housing that they can make their home. As you may know, accessible affordable housing is virtually non-existent in the Louisville area.

The good news is that most people we support, thanks to the Olmstead Decision, have access to Section 8 Choice vouchers. They also have access to Medicaid waiver resources that provide the individualized support they need to live safely and responsibly in their own home. The challenge is the lack of accessible, affordable housing.

Historically, housing resources, such as HUD and Community Development Block Grants, that are earmarked for people with disabilities has been invested in housing options that congregate people with disabilities together and segregate or separate them from the rest of community. Examples of this would be the Cain Center and Dayspring. The Federal government has issued the Home and Community Based Settings Final Rule stating that Medicaid will no longer fund waiver services that congregate people based on disability. Thus, what is already a crisis, is going to build as more people seek more normative options.

In the last year we assisted a woman to move into a home of her own near the University of Louisville. She was granted a Section 8 voucher that expired twice while we helped her search daily for housing that would meet her accessibility needs. In the end, it took us creating a housing option. Because of intensive networking, we identified a very nice man who agreed to turn the home he was moving from into a Section 8 property, specifically for this woman. He made this decision based on the relationship he built with the woman in need of housing. Over a period of more than six months, our organization raised funds and organized many volunteers to modify the home. We built a ramp, installed laminate flooring, and completely remodeled the bath to include a roll-in shower. While this woman is now living happily ever after in her own home, it simply is not feasible or sustainable to rely solely on the charity of a single landlord and donations of money and labor to solve this community’s issue of accessible affordable housing.

Louisville-Jefferson County Metro Government 126 Program Year 2019 Annual Action Plan June 12, 2019 Hope Leet Dittmeier – Mattingly Edge, continued

As a group, people with intellectual and developmental disabilities, including physical disabilities, are unique in their housing needs. For many, the home needs to be physically accessible. Not just a zero- clearance entrance, but with enough space to manage a wheelchair, and a bathroom and kitchen that is functional based on the person’s needs. Additionally, because of the heightened vulnerability of this group, their home needs to be in a safe neighborhood.

Because of transportation challenges, the home needs to be close to grocery store, pharmacy, faith community, and public bus stops. Another unique issue is that some people rely on live in support and need space that can functionally accommodate the privacy needs of unrelated adults sharing a home (e.g., ‘mother-in-law quarters’). Of course, actual needs vary from person to person, however, the solution for all of these can be accomplished with a one-time investment of funds into a housing unit that meets the unique needs of the person. Once the home is modified, other systems (often non-profit services) can provide the support and oversight needed for the person to live a long and fulfilling life as a full community member.

Mattingly Edge encourages Develop Louisville to invest in the development of dispersed housing suitable for people with accessibility needs. This could be accomplished in a variety of ways, including to incentivize Section 8 landlords to make accessibility modifications. Or, granting funds to develop new housing initiatives that integrate people with and without disabilities in the same housing development. At a minimum, every newly built affordable housing unit should include a percentage of units that are accessible for people who rely on a wheelchair and support staff to live.

We offer ourselves as a resource to anyone in the housing market that is interested in partnering to develop much needed single-family housing that is affordable and accessible. Please reach out to us.

Thank you.

Hope Leet Dittmeier

Louisville-Jefferson County Metro Government 127 Program Year 2019 Annual Action Plan June 12, 2019 Develop Louisville Response:

Develop Louisville would like to thank Ms. Dittmeier for her comments, and to recognize the dedication of Mattingly Edge to serving those members of our community with disabilities. Develop Louisville strongly supports the mission of this organization and similar organizations to create a more accessible and affordable community for all. Each year, Develop Louisville allocates $200,000 to the Center for Accessible Living, which is used on various projects to modify and install accommodations for persons with disabilities. Additionally, we require that all units constructed or rehabilitated with our funds throughout the community are built in accordance with ADA regulations.

Develop Louisville is c ommitted to extensive home repair throughout Louisville, and to date has committed over $2,000,000 to our Home Repair program. This program funds various home repairs, including adding accessibility features for persons with physical limitations throughout our community.

Finally, the Office of Housing and Community Development annually issues a competitive opportunity for funding. The HOME funds awarded in this NOFA, issued each fall, can be used for rental rehabilitation projects to increase affordable, accessible housing opportunities. We would encourage Mattingly Edge or any organization committed to increasing accessibility to consider applying for this funding. More information can be found at louisvilleky.gov/government/housing-community-development/affordable- housing-development-program.

Develop Louisville appreciates the work of Ms. Dittmeier, Mattingly Edge, and other organizations committed to accessibility. It is through partnerships with dedicated organizations such as these that Develop Louisville can maintain and grow our commitment to accessible, affordable communities.

Louisville-Jefferson County Metro Government 128 Program Year 2019 Annual Action Plan June 12, 2019 Cathy Hinko – Metro Housing Coalition

Metropolitan Housing Coalition

P.O. Box 4533

Louisville, Kentucky 40204

2019-2020 Action Plan for CDBG, ESG, HOME, HOPWA Comments by Metropolitan Housing Coalition Cathy Hinko February 25, 2019

A hard task, to guess what Louisville’s budget will be; MHC recognizes the difficulty of planning.

However two very large issues are ignored entirely in this plan.

The Louisville Metro Housing Authority is robbing the Section 8 voucher program of over $5,000,000. The stripping of these dollars from Section 8 means certainly over 500 households on the waiting list must live in misery because LMHA has turned their back on the people on the waiting list. This is at the same moment that hundreds of public housing units will be razed. This violates the federal law governing Moving to Work which mandates that the number served in Section 8 not be significantly less than that for which funding was given.

Demand these dollars be restored to rent assistance and DO NOT USE HOME dollars to put in Tenant Based Rental Assistance which is a thin assistance to those in need. Better to use the HOME funds to create housing that is affordable for many years than to pay someone’s rent for a month. Had this been the policy, all the millions of HOME dollars spent on vanishing rent payments could have produced hundreds of housing units that would still, today be affordable.

If the Louisville budget tanks, DO NOT ROB CDBG FUNDS TO DO BASIC CITY SERVICES. That is not the goal of CDBG and I know you will be tempted. But use CDBG as it was intended.

Louisville-Jefferson County Metro Government 129 Program Year 2019 Annual Action Plan June 12, 2019 Cathy Hinko – Metro Housing Coalition, continued

For instance, a problem is that there is no public plan by the city for the people in the center of the ring of investment who will be made homeless by the anticipated and much needed rising prosperity in the lowest cost neighborhoods. Attached is a comparison that shows that the 700 residents census block 24.1 residents (18th to 26th Streets and Muhammad Ali Boulevard to Main Street), already vulnerable, would be put in extreme jeopardy if rents went up by 10% or rental units taken off line or stricter adherence to code requirements were implemented on owner occupied units.

What is the plan for theses 700 people? They live in the middle of Choice Neighborhood replacement at 9th and Muhammad Ali, the national level track and field investment west of them on Muhammad Ali, the Cedar Street development and the Passport and YMCA development at 18th and Broadway.

All this investment is necessary, and in fact, if successful, will have an exponential effect because all of this at once can be a positive tipping point. But we still need to see the people who live in the ring who are racially and economically segregated to where rents are lowest (60% rent) and housing values are low (how to finance any improvements or pay for rising property taxes). What is the plan for them? It is not in this 2018 plan.

As this disproportionately affect black residents, MHC suggests a re-examination of the plan to not oust overwhelmingly black residents. Target the funds to improve the income of these residents, or to provide a buffer to help them as rising values change their ability to rent or own. This is not adhering the purported, but still not released to the public, Fair Housing Assessment. It is in violation of the Analysis of Impediments to Fair Housing Choice and may be in violation of the Fair Housing Act.

Use CDBG and HOME funds to accomplish the goal of housing the lowest income households in Louisville. This will have an exponential effect for good. Use the funds to halt deterioration of housing in neighborhoods where people are low-income home owners to keep those people as home owners.

Target raising the home ownership rate of black households, who have an ownership rate of 36% compared to the 70% home ownership rate of white households. Use funds to rectify clearly successful deliberate discrimination in wealth acquisition by black households.

Louisville-Jefferson County Metro Government 130 Program Year 2019 Annual Action Plan June 12, 2019 Develop Louisville Response:

Develop Louisville thanks Ms. Hinko for her comment and for Metropolitan Housing Coalition’s continued advocacy for affordable housing opportunities for low-income Louisvillians.

Develop Louisville acknowledges Ms. Hinko’s concerns about Louisville Metro Housing Authority (LMHA) budgetary decisions as a Moving to Work agency, but believes those comments would best be directed to LMHA during their Moving to Work Annual Plan development as Metro Government’s Program Year 2019 Action Plan has no authority over those funds.

Develop Louisville also understands Ms. Hinko’s criticism of the use of HOME funds for Tenant‐Based Rental Assistance (TBRA) but considers it a necessity due to current economic conditions and the high demand for affordable rental units, as she identified in her comments regarding LMHA. Metro’s HOME TBRA program, administered by the Department of Resilience and Community Services (RCS), employs a low-barrier Housing First modality with an overall program goal of assisting Program Participants with rapidly securing safe and stable housing and connecting families with the resources needed to maintain housing following the termination of RCS’ rental assistance.

The HOME TBRA resource serves persons experiencing homelessness as a part of the housing options provided through the Louisville Continuum of Care. All referrals for the HOME-TBRA program are generated from the Louisville Metro Continuum of Care (CoC) Common Assessment Team (CAT).

By offering targeted Neighborhood Redevelopment Strategy Areas programs to preserve both affordable rental and homeownership housing for low- and moderate –income Russell residents, Develop Louisville is working to serve those existing residents for whom Ms. Hinko expresses fear of displacement due to the significant public and private investment occurring in the neighborhood.

Louisville-Jefferson County Metro Government 131 Program Year 2019 Annual Action Plan June 12, 2019 Appendix C

Affidavit of Publication for Public Hearings Held

February 25, 2019 and May 23, 2019

Louisville-Jefferson County Metro Government 132 Program Year 2019 Annual Action Plan June 12, 2019 Affidavit of Legal Notice for First Public Hearing, Published February 15, 2019

Louisville-Jefferson County Metro Government 132 Program Year 2019 Annual Action Plan June 12, 2019 Copy of Legal Notice of First Public Hearing, Published February 15, 2019

Louisville-Jefferson County Metro Government 133 Program Year 2019 Annual Action Plan June 12, 2019 Affidavit of Legal Notice for First Public Hearing, Published May 8, 2019

Louisville-Jefferson County Metro Government 134 Program Year 2019 Annual Action Plan June 12, 2019 Copy of Legal Notice of First Public Hearing, Published May 8, 2019

Louisville-Jefferson County Metro Government 135 Program Year 2019 Annual Action Plan June 12, 2019 Appendix D

Summary of Louisville Metro Office of Resilience and Community Services 2019 Community Needs Assessment Survey Results

Louisville-Jefferson County Metro Government 136 Program Year 2019 Annual Action Plan June 12, 2019 Louisville-Jefferson County Metro Government 130 Program Year 2019 Annual Action Plan June 12, 2019 Louisville-Jefferson County Metro Government 131 Program Year 2019 Annual Action Plan June 12, 2019 Louisville-Jefferson County Metro Government 132 Program Year 2019 Annual Action Plan June 12, 2019 133 Louisville-Jefferson County Metro Government Program Year 2019 Annual Action Plan June 12, 2019 Louisville-Jefferson County Metro Government 135 Program Year 2019 Annual Action Plan June 12, 2019 Appendix E

Office of Resilience and Community Services 2019 Subrecipient Awards:

1. CDBG Homeless Services Awards 2. ESG Awards 3. HOPWA Subrecipient Awards

Louisville-Jefferson County Metro Government 143 Program Year 2019 Annual Action Plan June 12, 2019 1. CDBG Homeless Services Subrecipient Awards – Program Year 2019

PY 19 Service Delivery Organization Program CDBG Goal Award

Family Health Centers, Inc. 150 Phoenix Health Center - Case $109,200 Management

Fr. Maloney's Boys Haven, Inc. (DBA 100 Boys and Girls Haven $28,400 Independence Readiness

950 Jeff Street Baptist Community at $18,600 Liberty, Inc. At Liberty Hospitality Program

490 Kentucky Refugee Ministries, Inc. Refugee & Immigrant Housing $38,400 Coordination

Kept Inc Kept Inc's Organizational Payee Services $52,800 220

200 Legal Aid Society Increasing Tenant Stability $19,000

800 Legal Aid Society Tenant Assistance Program $19,000

600 Society of St. Vincent de Paul $57,000 Ozanam Inn

$115,600 1600 St. John Center, Inc. Emergency Day Shelter and Social Services Center

Louisville-Jefferson County Metro Government 144 Program Year 2019 Annual Action Plan June 12, 2019 PY 19 Service Delivery Organization Program CDBG Goal Award

The Center for Women and Families Crisis Response $43,800 4000

The Center for Women and Families Economic Success Program $35,800 100

The Louisville Continuum of Care 6344 (including Homeless Management $112,100 The Coalition for the Homeless, Inc. Information System and White Flag)

54 The Salvation Army Family Emergency Shelter Case $42,500 Management

800 The Young Mens Christian YMCA Safe Place Services - Shelter $35,000 Association of Greater Louisville House

Uniting Partners (UP) for Women and UP Case Management 600 Children $22,600

50 Volunteers of America Mid-States VoA Family Emergency Shelter $35,100

Volunteers of America Mid-States VoA Family Stabilization Program - $244,245 100 Shelter+Care

Wellspring Perkins Supportive Housing Program $35,745 65 (PuSHuP)

Louisville-Jefferson County Metro Government 145 Program Year 2019 Annual Action Plan June 12, 2019 PY 19 Service Delivery Organization Program CDBG Goal Award

Young Adult Development in Action, YBL Case Management Housing Services $50,000 20 Inc. DBA YouthBuild Louisville

Louisville-Jefferson County Metro Government 146 Program Year 2019 Annual Action Plan June 12, 2019 2. ESG Subrecipient Awards – Program Year 2019

Organization Category PY 19 ESG Service

Award Delivery Goal

The Home of the Innocents, Inc. Rapid Rehousing $42,500 100 Households

The Salvation Army Rapid Rehousing $99,520 65 Households

Volunteers of America Mid-States Rapid Rehousing $79,914 45 Households

Family Health Centers, Inc. Outreach $54,245 350 Persons

House of Ruth, Inc. Shelter Operations $18,360 6 Households

Jeff Street Baptist Community at Liberty, Shelter Operations $13,122 950 Persons Inc.

Society of St. Vincent de Paul Shelter Operations $67,070 600 Persons

St. John Center, Inc. Shelter Operations $119,163 1600 Persons

The Salvation Army Shelter Operations $115,183 2250 Persons

Volunteers of America Mid-States Shelter Operations $93,000 50 Households

Louisville-Jefferson County Metro Government 147 Program Year 2019 Annual Action Plan June 12, 2019 Organization Category PY 19 ESG Service

Award Delivery Goal

Legal Aid Prevention $30,000 240 Households

Wayside Family Shelter Shelter Operations $15,603 185 Households

UP Louisville Shelter Operations $33,722 600 Households

Kentuckiana Works Shelter Operations $41,000 50 Households

Louisville-Jefferson County Metro Government 148 Program Year 2019 Annual Action Plan June 12, 2019 3. HOPWA Subrecipient Awards – Program Year 2019

PY 19 HOPWA Service Organization Activity Award Delivery Goal

Short-Term Rent, Mortgage, and Utility 6,500 16 Hoosier Hills Assistance (STRMU) AIDS Coalition Tenant-Based Rental Assistance (TBRA) 45,000 8

Subrecipient’s HOPWA Administration 3,500

Short-Term Rent, Mortgage, and Utility 17,700 15 Assistance (STRMU)

House of Ruth Supportive Services 267,500 735

Tenant-Based Rental Assistance (TBRA) 142,000 47

Permanent Housing Placement (PHP) 12,800 21

Subrecipient’s HOPWA Administration 33,000

Keeping it Real Short-Term Rent, Mortgage, and Utility 40,493 5 Neighborhood Assistance (STRMU) Institute Supportive Services 73,893 250

Legal Aid Society HIV/AIDS Legal Project 38,000 65

Short-Term Rent, Mortgage, and Utility 100,500 190 Volunteers of America Assistance (STRMU) Mid-States Supportive Services 20,000 190

Subrecipient’s HOPWA Administration 9,000

Louisville-Jefferson County Metro Government 149 Program Year 2019 Annual Action Plan June 12, 2019 Appendix F

Russell Neighborhood Revitalization Strategy Area (NSRA) Map

Louisville-Jefferson County Metro Government 150 Program Year 2019 Annual Action Plan June 12, 2019 Louisville-Jefferson County Metro Government 151 Program Year 2019 Annual Action Plan June 12, 2019 Louisville-Jefferson County Metro Government 152 Program Year 2019 Annual Action Plan June 12, 2019 Louisville/Jefferson County Metro Government Program Year 2019 Action Plan 2015-2019 Citizen Participation Plan

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CARES Act Amendment May 21, 2020

Prepared by Develop Louisville Division of Compliance and Administration

Jeff O’Brien – Director, Develop Louisville 153 DEVELOP LOUISVILLE LOUISVILLE, KENTUCKY

GREG FISCHER JEFF O’BRIEN MAYOR DIRECTOR

DATE: May 21, 2020

RE: Amendment to the 2019 Annual Action Plan for HUD Entitlement Funds to Incorporate CARES Act funding for COVID-19 Relief Programming

This is a substantial amendment to Louisville/Jefferson County Metro Government’s 2019 Annual Action Plan. This amendment proposes new projects to be undertaken during Program Year 2019 (July 1, 2019 – June 30, 2020) with federal entitlement funds received through the Coronavirus Aid, Relied and Economic Security Act (CARES Act).

A 5-day public comment period was held for this amendment, as allowed by HUD’s waiver of requirement 24 CFR 91.105(c)(2). This public comment period began Friday, May 1, 2020 and concluded Thursday, May 7, 2020. A virtual public meeting was held on Monday, May 4, 2020 at 6:00pm to discuss the amendment and receive citizen comment. All comments received during this period, along with Louisville Metro Government’s response, are included in the appendices.

This amendment was submitted to the U.S. Department of Housing and Urban Development (HUD) on May 21, 2020.

Table of Contents Executive Summary ...... 155 Citizen Participation...... 158 Details of Proposed Projects ...... 159 CDBG Projects ...... 159 ESG Projects ...... 167 HOPWA Projects ...... 169

Appendices A: Written Comments Received ...... 177 B: Public Meeting: Questions and Comments ...... 207 C: Legal Notice appearing in the Courier Journal May 1, 2020 ...... 218 D: Amended Citizen Participation Plan ...... 221 E: Waiver Notifications Sent to HUD...... 231 F: Executive Order 2020-002 Mandating Public Meetings Held Virtually ...... 238

LOUISVILLE FORWARD 154 www.louisvilleky.gov OFFICE OF HOUSING & COMMUNITY DEVELOPMENT•DEVELOP LOUISVILLE• 444 S. 5TH STREET•SUITE 500•LOUISVILLE, KY 40202•502.574.5850•FAX-502.574.6215 Executive Summary

Substantial Amendments to the Annual Action Plan (24 CFR 91.505)

Louisville/Jefferson County Metro Government’s original 2019 Action Plan was submitted to the U.S. Department of Housing and Urban Development (HUD) on June 12, 2019 and was approved by HUD on September 17, 2019. The Annual Action Plan outlines projects and programs intended to address the goals identified in the 2015 - 2019 Consolidated Plan.

Louisville/Jefferson County Metro Government’s Citizen Participation Plan was designed to encourage active citizen participation in the development of Louisville Metro’s goals and strategies to address those needs. This plan, which provides guidelines for all phases of the consolidated planning process, including amendments to approved plans, states that a substantial amendment to the Action Plan is warranted upon: the addition of an activity not previously included in the Consolidated Plan; the deletion of an activity previously included in the Consolidated Plan; changes to the location of an activity which affect the original scope of the project; changes to the scope of an activity which affect the original beneficiaries; changes in the scope of an activity due to a modification in funding level totaling 30% or more in a Program Year Action Plan budget for the project; or a series of changes representing a cumulative total of more than 20% or more in a Program Year Action Plan budget.

This substantial amendment to Louisville/Jefferson County Metro Government’s 2019 Annual Action Plan proposes new projects to be undertaken during Program Year 2019 (July 1, 2019 – June 30, 2020) with federal entitlement funds received through the Coronavirus Aid, Relied and Economic Security Act (CARES Act). These funds will represent a change in funding level of greater than 30% of the 2019 Program Year Action Plan Budget, as well as the addition of new projects.

This amendment was submitted to the U.S. Department of Housing and Urban Development (HUD) on May 21, 2020.

Louisville-Jefferson County Metro Government 155 Amendment to the 2019 Action Plan May 21, 2020 Program Year 2019 Action Plan – CARES Act Amendment

This substantial amendment to the 2019 Action Plan is created in response to new federal funding received through the Coronavirus Aid, Relied and Economic Security Act (CARES Act). Louisville Metro Government has been awarded funding in the following amounts from the Office of Housing and Urban Development:

Community Development Block Grant (CDBG): $6,745,161 Emergency Solutions Grant (ESG): $3,390,700 Housing Opportunities for Persons with AIDS (HOPWA): $140,330

This amendment proposes several new projects to be undertaken with this funding during the 2019 Program Year (July 1, 2019 – June 30, 2020) in direct response to the COVID-19 pandemic crisis. Details of the new projects can be found in the following section(s) of this amendment. These additions are reflected in section AP-35 Projects – 91.220(d) of the 2019 Annual Action Plan.

Louisville-Jefferson County Metro Government 156 Amendment to the 2019 Action Plan May 21, 2020 Summary of Proposed Use of Funds

CDBG Proposed COVID-19 Response Programs $6,745,161 Expected CARES Allocation Housing Stability and Eviction Prevention: ...... $1,715,161 Eviction Prevention Program ...... $1,545,161 Housing Stabilization (TBRA) ...... $170,000 Case Management and Operating Expenses for Shelters: ...... $1,430,000 Homeless Services ...... $356,000 Operating Costs for Shelters ...... $743,000 Grant Coordinators ...... $331,000 Community Land Trust ...... $2,100,000 Small Business Loan NOFA ...... $1,500,000

ESG Proposed COVID-19 Response Programs $3,390,700 Expected CARES Allocation Supplemental Program Support ...... $945,570 NOFA: Homeless Prevention ...... $845,570 NOFA: Homeless Services ...... $100,000 Tenant Based Rental Assistance ...... $1,430,000 Technical Assistance ...... $15,097 Homeless Management Information System (HMIS) Licenses ...... $5,000 COVID-19 Grants Training ...... $10,097 Phase Two Recovery ...... $1,000,000

HOPWA Proposed COVID-19 Response Programs $140,330 Expected CARES Allocation $182,622 Reallocated Existing Funds $98,778 Program Year 2020 Funds* NOFA:PHP, STRMU, TBRA, and Hotel/ Motel vouchers for persons with HIV/AIDS ...... $121,900 NOFA: Supportive Services for persons with HIV/AIDS ...... $237,000 Technical Assistance ...... $2,800 Phase Two Recovery ...... $60,030

*Note: this funding is not included in Program Year 2019 Action Plan Amendment, as these are Program Year 2020 funds. Rather, these will be included as an adjustment to the 2020 Action Plan submitted to HUD on May 18, 2020.

Louisville-Jefferson County Metro Government 157 Amendment to the 2019 Action Plan May 21, 2020 Citizen Participation

2015 – 2019 Citizen Participation Plan Amendment

The 2015-2019 Citizen Participation Plan has been amended to include provisions for HUD waivers which may vary the public comment period requirements and allow for virtual public meetings. This amended plan can be found in the appendices.

Utilization of Federal Waiver

Pursuant to the memorandum Availability of Waivers of Community Planning and Development Grant Programs and Consolidate Plan Requirements to Prevent the Spread of COVID-19 and Mitigate Economic Impacts Caused by COVID-19, and in accordance with 24 CFR 5.110:

• Citizen Participation Public Comment Period for Consolidated Plan Amendment - 24 CFR 91.105(c)(2) and (k); 24 CFR 91.115(c)(2) and (i); 24 CFR 91.401 • Citizen Participation Reasonable Notice and Opportunity to Comment - 24 CFR 91.105(c)(2) and (k); 24 CFR 91.115(c)(2) and (i); 24 CFR 91.401

Requests for use of these waivers was submitted to the U.S. Department of Housing and Urban Development Kentucky Field Office, Region IV, on April 8, 2020. A copy of the Wavier Request is included in this amendment.

Public Comment Period

This waiver allows Louisville Metro Government to provide a public comment period of no less than 5 days on substantial amendments relating to CARES Act funding. The public comment period for the amendment proposed in this document began on Friday, May 1, 2020, and concluded on Thursday, May 7, 2020.

The public comment period also included a public meeting, held virtually per social distancing precautions as mandated by Executive Order 2020-002. This virtual public meeting was held on May 4, 2020 at 6:00pm via WebEx videoconference and Facebook Live stream. All comments received during this period, along with Louisville Metro Government’s response, are included in the appendices.

Louisville-Jefferson County Metro Government 158 Amendment to the 2019 Action Plan May 21, 2020 Details of Proposed Projects

CDBG Proposed Projects

COVID-19 Response Programs $6,745,161 Expected CARES Allocation

Housing Stability and Eviction Prevention: ...... $1,715,161 Eviction Prevention Program ...... $1,545,161 Housing Stabilization (TBRA) ...... $170,000

Case Management and Operating Expenses for Shelters: ...... $1,430,000 Homeless Services ...... $356,000 Operating Costs for Shelters ...... $743,000 Grant Coordinators ...... $331,000

Community Land Trust ...... $2,100,000

Small Business Loan NOFA ...... $1,500,000

Project Name Eviction Prevention Program Description Support affordable housing by reducing cost burden and expand affordable housing choices for citizens.

Consolidated Plan Affordable Housing Needs Addressed Consolidated Plan Provide rental assistance Goals Supported Provide homeless prevention services

Target Area Metrowide

Target Date 6/30/20

Funding CDBG $1,545,161 Costs: • $1,540,161 in rental subsistence payments to landlords • $5,000 for Miscellaneous operating costs and supplies

Louisville-Jefferson County Metro Government 159 Amendment to the 2019 Action Plan May 21, 2020 Estimated number 625 renter households facing eviction and type of families that will benefit Planned Activities The goal of the program is to assist approximately 625 renter households facing eviction due to loss of income during COVID-19 pandemic by providing financial assistance for rent and/or utilities. This program will be administered by the Office of Resilience and Community Services (RCS) with staff support provided by Develop Louisville’s Office of Housing. These subsistence payments will be made on a short-term basis, for a period of no more than three months, as emergency rental assistance on behalf of individuals or families for the purpose of preventing homelessness.

The program will help renters/households at less than 80% of area median income (AMI) who are facing eviction. Qualifying households must have a loss of income due to the COVID-19 virus. Qualified participants would be eligible for up to $2,500 of direct assistance to either the landlord or the utility company, on behalf the tenant.

Louisville-Jefferson County Metro Government 160 Amendment to the 2019 Action Plan May 21, 2020 Project Name Housing Stabilization Program Description Providing support through reducing housing cost burden and providing housing for homeless persons.

Consolidated Plan Homeless Services Needs Addressed Consolidated Plan Provide rental assistance Goals Supported Provide homeless prevention services

Target Area Metrowide

Target Date 6/30/20

Funding CDBG $170,000 Costs: • $165,000 for three (3) Housing Specialists at $55,000 average, including salary and fringe • $5,000 for Miscellaneous operating costs and supplies

Estimated number Up to 170 homeless households, dependent on family size and and type of families additional costs such as security deposits that will benefit Planned Activities CDBG-CV funds will be used in support of housing for the Emergency Solutions Grant Program. The program will be administered by the Office of Resilience and Community Services (RCS), including hiring three (3) new Housing Specialists and miscellaneous operating costs and supplies. Hiring will preference qualified Louisville Metro Government applicants who have been furloughed.

Louisville-Jefferson County Metro Government 161 Amendment to the 2019 Action Plan May 21, 2020 Project Name Homeless Case Management and Operating Expenses Description Addressing the issue of homelessness to provide housing and supportive services for homeless persons.

Consolidated Plan Homeless Services Needs Addressed Consolidated Plan Provide rental assistance Goals Supported Provide homeless prevention services

Target Area Metrowide

Target Date 6/30/20

Funding CDBG $1,430,000 Costs: • $356,000 in competitive grants for Homeless Services • $743,000 in Shelter Operating Expenses • $331,000 in Staff and Operating Costs for the Office of Resilience and Community Services

Estimated number Homeless Prevention – 480 families and type of families Homeless Services – 7,300 individuals that will benefit Planned Activities Competitive grants will be sought via a Notice of Funding Availability for Homeless Services. Services that will be requested include those focused throughout the community to assist those individuals experiencing homelessness and housing regardless of sheltered status to obtain and retain permanent housing. These services could include case management, housing navigation, transportation, storage, technology and devices that assist case managers perform tasks more efficiently & safely. However, Louisville Metro may, in lieu of a competitive notice of funding availability and in consultation with the local Continuum of Care, designate eligible subrecipient agencies for specific projects when appropriate in order to respond rapidly and/or ensure continuity of services. (It is estimated that this NOFA will be $356,000.)

Additional operating expenses due to COVID-19 requirements incurred by shelters (day & night) not covered by FEMA reimbursement, One Louisville fund, or other sources. These funds

Louisville-Jefferson County Metro Government 162 Amendment to the 2019 Action Plan May 21, 2020 will be awarded around the basis of demonstrated need to homeless providers that are members of the Continuum of Care. (It is estimated that this support allocation will be $743,000.)

Funds will be used to pay salaries of two (2) Grant Contract Coordinators in the Office of Resilience and Community Services, plus miscellaneous operating costs such as office, supplies, local travel. ($331,000)

Louisville-Jefferson County Metro Government 163 Amendment to the 2019 Action Plan May 21, 2020 Project Name Community Land Trust Description Transfer City Owned property to a Community Land Trust, thereby extending the period of affordability on multiple properties and creating more affordable units in perpetuity.

Consolidated Plan Affordable Housing Needs Addressed Consolidated Plan Increase and retain affordable units Goals Supported Target Area Metrowide

Target Date 6/30/20

Funding CDBG $2,100,000 Costs: • $2,000,000 for Development Funding (approximately 7-8 houses) for two CLTs • $100,000 in Public Service Funds

Estimated number Approximately 50 Households and type of families that will benefit Planned Activities The goal of this program is to provide funding for up to two (2) local non-profit entities to start Community Land Trust(s). A Notice of Funding Opportunity (NOFO) would be released to select providers.

A major challenge facing Louisville is the availability of for-sale, permanently affordable housing; this need was identified in the Housing Needs Assessment. A Community Land Trust (CLT) helps increase the number of permanently affordable units in the community and supports family wealth building. Both are problems that have been exacerbated by the pandemic. A CLT is a Community Based Development Organization (CBDO), similar to a CHDO under the federal HOME program; as such, a CLT can develop new housing as part of community economic development or as a part of an energy conservation or neighborhood revitalization project.

Each CLT/CBDO would get $1,000,000, which could be paired with other funds available from the CLT/CBDO, stimulating economic impact by supporting the construction of houses and employment of

Louisville-Jefferson County Metro Government 164 Amendment to the 2019 Action Plan May 21, 2020 skilled and non-skilled labor. This program would be administered by the Office of Housing in Develop Louisville.

Additionally, operating funds are allocated to support staffing for CLTs.

Louisville-Jefferson County Metro Government 165 Amendment to the 2019 Action Plan May 21, 2020 Project Name Small Business Loan Program Description Work with partner organizations to provide microloans, and work with partners organizations to provide working capital loans.

Consolidated Plan Small Business Development Needs Addressed Consolidated Plan Microenterprise development Goals Supported Small business development

Target Area Metrowide

Target Date 6/30/20

Funding CDBG $1,500,000

Estimated number 60-75 businesses and type of families that will benefit Planned Activities The goal of the program is to provide small business loans in low- moderate-income census tracts Program will be administered by a third party chosen through a competitive Notice of Funding Availability (NOFA). Community Development Block Grant (CDBG) funding is available to one partner organization for the purpose of providing economic stabilization relief in the form of low- or no-interest loans or grants to small businesses affected by COVID- 19 located in historically disinvested neighborhoods.

The program is expected to provide financial relief in the form of low- or no-interest loans or grants to small businesses operating in and serving the following neighborhoods: Algonquin, Smoketown, Shelby Park, Russell, Parkland, Park DuValle, Park Hill, California, Portland, Shawnee, and Chickasaw.

Louisville-Jefferson County Metro Government 166 Amendment to the 2019 Action Plan May 21, 2020 ESG Proposed Projects

COVID-19 Response Programs $3,390,700 Expected CARES Allocation

Supplemental Program Support ...... $945,570 NOFA: Homeless Prevention ...... $845,570 NOFA: Homeless Services ...... $100,000

Tenant Based Rental Assistance ...... $1,430,000

Technical Assistance ...... $15,097 Homeless Management Information System (HMIS) Licenses ...... $5,000 COVID-19 Grants Training ...... $10,097

Phase Two Recovery ...... $1,000,000

Project Name ESG – Program Year 2019 Description CARES Act Supplemental Funding for Admin, Prevention, Homeless Services, and Technical Assistance

Consolidated Plan Homeless Services Needs Addressed Consolidated Plan Provide homeless prevention services Goals Supported Provide rapid rehousing for homeless citizens Provide street outreach for homeless citizens Provide shelter operations for homeless citizens

Target Area Metrowide

Target Date 6/30/20

Funding ESG - $3,390,667

CARES Act: Supplemental Program Support ($945,570) • $845,570 in competitive grants for Homeless Prevention • $100,000 in competitive grants for Homeless Services

CARES Act: Tenant Based Rental Assistance ($1,430,000) • $1,430,000 in TBRA payments

Louisville-Jefferson County Metro Government 167 Amendment to the 2019 Action Plan May 21, 2020 CARES Act: Technical Assistance ($15,097) • $5,000 in additional HMIS licenses • $10,097 in COVID-19 Grants Training costs

CARES Act - Phase Two Recovery ($1,000,000) • $1,000,000 in reserve to be allocated to post-shutdown recovery based on future emerging requirements

Estimated number Homeless Prevention – 480 families and type of families Homeless Services – 7,300 individuals that will benefit Planned Activities CARES Act: Supplemental Program Support • Competitive grants via a Notice of Funding Availability for Homeless Prevention, to include Hotel/Motel, Temporary Housing, Rent & Mortgage Payments, Utility Assistance, Payee Services, Prevention of subsidized tenants from returning to homelessness, Eviction Court Case Manager incl. salary & benefits, services for youth (18-24) at-risk of homelessness, & other services specifically intended to prevent homelessness due to COVID-19 ($845,570) • Competitive grants via a Notice of Funding Availability for Homeless Services, to include temporary shelter not provided within the existing shelter system. i.e. Hotel/Motel Vouchers, college dormitories, etc. ($100,000) Note: In lieu of a competitive notice of funding availability, Louisville Metro in consultation with the local Continuum of Care may designate eligible subrecipient agencies for specific projects when appropriate in order to respond rapidly and/or ensure continuity of services.

CARES Act: Tenant Based Rental Assistance • Provide rental assistance for a twelve (12) month period to eligible households in the Single Point of Entry (SPE) system that are precariously housed or homeless. (1,430,000)

CARES Act: Technical Assistance • Additional HMIS licenses ($5,000) • HUD Training for COVID-19 Grants Administration, NEC ($10,097)

CARES Act: Phase Two Recovery • Reserve to be allocated in collaboration with the Continuum of Care for post-shutdown recovery based on emerging requirements ($1,000,000)

Louisville-Jefferson County Metro Government 168 Amendment to the 2019 Action Plan May 21, 2020 HOPWA Proposed Projects

COVID-19 Response Programs $140,330 Expected CARES Allocation $182,622 Reallocated Existing Funds $98,778 Program Year 2020 Funds*

*Note: This 2020 funding is not included in Program Year 2019 Action Plan Amendment, as these are Program Year 2020 funds. Rather, these will be included as an adjustment to the 2020 Action Plan to be submitted to HUD on or after May 13, 2020. Adjustments to the 2020 Action Plan are included in this 2019 Amendment proposal for reference.

NOFA: PHP, STRMU, TBRA, and Hotel/ Motel vouchers for persons with HIV/AIDS ...... $121,900

NOFA: Supportive Services for persons with HIV/AIDS ...... $237,000

Technical Assistance ...... $2,800

Phase Two Recovery ...... $60,030

Project Name 2019 HOPWA Project Sponsors: CARES Act PHP, STRMU, TBRA, Hotel/ Motel Description Permanent Housing Placement, Short-Term Rent, Mortgage and Utility Assistance, Tenant Based Rental Assistance, and Hotel/ Motel vouchers for persons with HIV/AIDS

Consolidated Plan Non-Homeless Special Needs Needs Addressed Consolidated Plan Provide STRMU to persons with HIV/ AIDS Goals Supported Provide TBRA to persons with HIV/ AIDS

Target Area Metrowide

Target Date 6/30/20

Funding HOPWA - $121,900

Competitive grants to HOPWA project sponsor agencies to provide PHP, STRMU, TBRA, and H/M vouchers • $30,500 of CARES Act supplemental funding • $91,400 of reallocated existing HOPWA funding

Louisville-Jefferson County Metro Government 169 Amendment to the 2019 Action Plan May 21, 2020 Estimated number 82 families and type of families that will benefit Planned Activities Competitive grants via a Notice of Funding Availability to HOPWA project sponsors, to be used for HOPWA COVID-19 Permanent housing placement, Short term housing, Rental, Mortgage & Utility assistance, Tenant Based Rental Assistance, Hotel/Motel

Louisville-Jefferson County Metro Government 170 Amendment to the 2019 Action Plan May 21, 2020 Project Name 2019 HOPWA Project Sponsors: CARES Act Supportive Services Description Supportive Services for persons with HIV/AIDS

Consolidated Plan Non-Homeless Special Needs Needs Addressed Consolidated Plan Provide Supportive Services to persons with HIV/ AIDS Goals Supported Target Area Metrowide

Target Date 6/30/20

Funding HOPWA - $138,222

Competitive grants to HOPWA project sponsor agencies to provide supportive services • $47,000 of CARES Act supplemental funding • $91,222 of reallocated existing HOPWA funding

Note: An additional $98,778 of PY20 HOPWA funds will be used to support this NOFA and is included as a 2020 HOPWA Project in the 2020 Action Plan.

Estimated number 590 individuals and type of families that will benefit Planned Activities Competitive grants via a Notice of Funding Availability to HOPWA project sponsors, to be used for HOPWA COVID-19 Supportive Services including legal and other auxiliary services.

Note: In lieu of a competitive notice of funding availability, Louisville Metro in consultation with the local Continuum of Care may designate eligible subrecipient agencies for specific projects when appropriate in order to respond rapidly and/or ensure continuity of services.

Louisville-Jefferson County Metro Government 171 Amendment to the 2019 Action Plan May 21, 2020 Project Name 2019 HOPWA Louisville Metro: CARES Act Technical Assistance Description Support to Louisville Metro Administrative Costs

Consolidated Plan Non-Homeless Special Needs Needs Addressed Consolidated Plan Provide STRMU to persons with HIV/ AIDS Goals Supported Provide Supportive Services to persons with HIV/AIDS Provide TBRA to persons with HIV/ AIDS

Target Area Metrowide

Target Date 6/30/20

Funding HOPWA - $2,800

Technical Assistance • $2,800 of CARES Act Supplemental Funding

Estimated number All families and individuals served by HOPWA programming will and type of families benefit from improved staff training that will benefit Planned Activities Funds to provide HUD Training for COVID-19 HOPWA Grants Administration for Office of Resilience and Community Services staff

Louisville-Jefferson County Metro Government 172 Amendment to the 2019 Action Plan May 21, 2020 Project Name 2019 HOPWA Project Sponsors: CARES Act Phase Two Recovery Description Permanent Housing Placement, Short-Term Rent, Mortgage and Utility Assistance, Tenant Based Rental Assistance, Hotel/ Motel vouchers, and Supportive Services for persons with HIV/AIDS

Consolidated Plan Non-Homeless Special Needs Needs Addressed Consolidated Plan Provide STRMU to persons with HIV/ AIDS Goals Supported Provide Supportive Services to persons with HIV/AIDS Provide TBRA to persons with HIV/ AIDS

Target Area Metrowide

Target Date 6/30/20

Funding HOPWA - $60,030

Phase Two Recovery Reserve • $60,030 of CARES Act Supplemental Funding

Estimated number Goals to be determined in Phase Two of Recovery and type of families that will benefit Planned Activities Reserve to be allocated in collaboration with the Continuum of Care for post-shutdown recovery based on emerging HOPWA requirements

Louisville-Jefferson County Metro Government 173 Amendment to the 2019 Action Plan May 21, 2020 Louisville-Jefferson County Metro Government 174 Amendment to the 2019 Action Plan May 21, 2020 Louisville/Jefferson County Metro Government Amendment Appendices

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Program Year 2019 Action Plan 2015-2019 Citizen Participation Plan May 21, 2020

175 0

Public Comments and Amendment Appendices

Appendix A: Written Comments Received during Amendment Public Comment Period with Develop Louisville’s Response ...... 177

Appendix B: Public Meeting on Amendment: Questions and Comment with Develop Louisville’s Response ...... 207

Appendix C: Legal Notice Appearing in the Courier Journal May 1, 2020 ...... 218

Appendix D: Amended Citizen Participation Plan ...... 221

Appendix E: Waiver Notifications Sent to HUD ...... 231

Appendix F: Executive Order 2020-002 ...... 238

Louisville-Jefferson County Metro Government 176 Appendices – Amendment to the 2019 Action Plan May 21, 2020 Appendix A

Written Comments Received During Amendment Public Engagement Period with Develop Louisville’s Response

1. Coalition for the Homeless (1)

2. Metropolitan Housing Coalition

3. Coalition for the Homeless (2)

4. Association of Christian Ministries

5. Metro United Way

6. Americana World Community Center

7. Louisville Urban League

8. Alltrade Property Management

9. resolve: Restorative Practices, LLC

10. Root Cause Research Center

11. Mattingly Edge

12. Russell Place of Promise

Louisville-Jefferson County Metro Government 177 Appendices – Amendment to the 2019 Action Plan May 21, 2020 Written Comments submitted by Mary Frances Schafer, on behalf of the Coalition for the Homeless

Received May 6, 2020

The CoC wishes to recommend that $130,000 be taken from the Homeless Prevention allocation and placed in the Homeless Services allocation. The amounts would then become:

Prevention Total: $792,000 Homeless Services (RRH) Total: $409,600

Please allocate $100,000 of the Homeless Services amount to Transportation and $30,000 to Technology and devices to assist street outreach workers and those experiencing homelessness.

Thank you.

Received May 7, 2020

Please move the funding for the Low Barrier Shelter, $205,000, out of the Homeless Prevention category and put it in Homeless Services. This would increase the Homeless Services category from $409,600 to $614,600 and reduce the Prevention category from $792,000 to $587,000. Please move the Low Barrier Shelter project from Prevention to Homeless Services as well. THANKS

Louisville Metro Response

Louisville Metro developed the original ESG category amounts in collaboration with the Coalition for the Homeless on behalf of the local Continuum of Care (CoC). Since the draft was published for public comment, the Coalition has received additional input from the CoC regarding specific proposed projects and has discussed these with staff in the Louisville Metro Office of Resilience and Community Services (RCS). RCS agrees with these recommendations from the Coalition for the Homeless and has revised the Amendment accordingly. Louisville Metro government values the advocacy of the Coalition for the Homeless and thanks them for their cooperation.

Louisville-Jefferson County Metro Government 178 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Written Comment submitted by Cathy Hinko, Metropolitan Housing Coalition

Received May 6, 2020

Thank you for a very clear presentation with a format that allowed for questions to be answered. As a follow up to that lively discussion, MHC would like to stress a few points for consideration.

The median income of black and Latinx households is about half of the median income of white households, with female-headed households with children also having a fraction of median income in general, and many of the jobs that are held by people in several fair housing protected classes are not ones covered by Unemployment Insurance. Therefore, any plan that does not give meaningful access to rent assistance to those at or below 30% of median income, competitive with those of incomes at 50% and above median income, would suffer bias. Recall that the new Analysis of Impediments to Fair Housing Choice includes a focus on creating opportunities for those below 50% and 30% of median.

One solution is to have the ESG funds allocated to those with lower incomes serve as a match in rent for access to the CDBG eviction diversion funds. Having half the rent is a burden on the lowest income people and if the ESG funds do not serve as a match, these lowest income people will be excluded from accessing the CDBG funds.

Please design the program for CDBG funds to encourage, not discourage, landlord participation. Partial payment is problematic for a landlord and changes the landlord's legal rights.

Not having utilities is a cause for eviction, so please include utility payment assistance and even set up a program with LG&E for repayment assistance and plans. This should also be true for the Louisville Water Company (city owned) and for MSD, although far fewer renters pay directly for those services.

As far as the renter's obligation to attend counseling or to simply have a plan for their match, there seemed to be some conflict between what was written and what was said. There is already forbearance in place for landlord's with mortgages and the elimination of required inspection further reduces landlord exposure. Yet the payment goes to the landlord, so do not treat this as if the only beneficiary is the renter. The direct beneficiary is the landlord and you do not obligate the landlord to pay or show how they will pay their mortgage. So go easy on the renter and the whole "deserving poor" concepts that seem baked into the CDBG portion.

Be sure, as in past rent assistance programs, that the landlord signs a statement to not evict the tenant for some specified term. In the wayback machine, I used those statements to throw out eviction cases where the city had helped with rent. It may shock you to know there are unscrupulous landlords. But violating such a statement while using federal funds- well, that could even be perjury.

For the Community Land Trust design, while Ms. Harris labeled it an economic program, the Analysis of Impediments to Fair Housing Choice as well as the Housing Needs Assessment show that the housing need and commitment is for those at 50% and 30% of median income. CLTs should be considered a housing program; if you want to spend that much capital on economic development , there are better ways to do so including support of small businesses. Do not try to "equivocate yourself to Heaven". Commit to using the CLT for ownership by those with lower incomes. You can set up a partnership with

Louisville-Jefferson County Metro Government 179 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Louisville Metro Housing Authority, you can set up matched savings plans for repair and maintenance- there is a lot you can do to support ownership by lower income households. Do not spend that large a portion of our emergency program just to tick off a box of having done a CLT- make it meaningful.

How will you evaluate the success? How will you evaluate for fair housing success? I suggest you build into the plan a way to know if you are reaching people in a fair manner and that the rules do not inadvertently exclude classes of persons. It is clear that the intentions are wonderful, but the short design time can bring flaws.

Thank you for the opportunity to comment.

Cathy Hinko Executive Director Metropolitan Housing Coalition [email protected] 502 291-4908

Louisville Metro Response

Develop Louisville would like to thank Ms. Hinko and Metropolitan Housing Coalition for the comments, and for the continued commitment to equity in our city.

As the finite details of the Eviction Prevention and Housing Stabilization programs are being determined LMG agrees that it is vitally important to ensure that citizens at both the 0-30% AMI range, as well as the 30-50% AMI range and the 50-80% AMI range can receive access to programming support. Develop Louisville is certainly aware of the systemic disadvantages faced by various populations in our city and will work to ensure access is extended to those populations. While no final determination has yet been made on whether ESG funds will be eligible as the 50% match for the CDBG Eviction Prevention program, Develop Louisville appreciates the input, and is carefully considering this option. Additionally, DL is closely scrutinizing the need for utility payments to be included in these funds, as DL is aware that lack of utility payment can also be grounds for eviction.

Additionally, DL recognizes the critical importance of encouraging positive participation from landlords as an essential element of this program’s success. DL recognizes that the rights of landlords may be compromised via certain payment structures. As landlords will also benefit from these programs, the role of the landlord in the tripartite agreement cannot be overlooked. As Develop Louisville moves forward in its partnership with the Jefferson County Attorney’s Office to draft the legal tripartite agreement, the rights of both landlords and tenants will be included in the final legal document language. This agreement will also set in place certain protections and obligations for both tenants and landlords throughout the lifetime of the agreement.

The Community Land Trust is a multifaceted program that not only provides additional affordable housing in perpetuity but can also be considered through the lens of an economic development program. In the immediate future, and as an emergency response to small business needs in the community at this time, this program will help jump start local businesses and

Louisville-Jefferson County Metro Government 180 Appendices - Amendment to the 2019 Action Plan May 21, 2020 support these grassroots, community driven organizations to increase their output and stimulate their hiring. The long-term goal of the program is to create 50 homes over the next few years, which will both provide affordable housing as well as continued funding to local developers. Inherent in the emergency issues that Louisville is now seeing with its low- to moderate-income residents is insufficient affordable housing. By ignoring this underlying issue, these kinds of emergency situations will continue to arise year after year, and emergency after emergency. By supporting the creation of a Community Land Trust now, DL ensures more affordable housing for the future, and reduces the impact of future economic burdens, while simultaneously stimulating the local economy with development funds in the immediate future.

Louisville-Jefferson County Metro Government 181 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Written Comments submitted by George Eklund, on behalf of the Coalition for the Homeless

Received May 7, 2020

Comment to the proposed amendment to the 2019 Action Plan Coalition for the Homeless 5.7.2020

Eviction Prevention Program We are excited to see that eviction prevention is on the radar of Louisville Forward and the city government. Before the Pandemic, Louisville’s eviction rate was twice the national average. We need a bold approach to prevent thousands of people from being evicted and turning Louisville's rental market into a landscape that is unpredictable, unstable, and that creates negative outcomes for families. However, we see several significant shortcomings with the plan laid out.

The Urban Institute released a study that identified the shortcomings of rental assistance programs that have already been implemented and we believe that the city needs to take into account. The first is that this program must target the lowest income renters and landlords. We suggest that these programs need to particularly target those at or below 50% AMI because these members of our community are already financially fragile and impacted by the shuttering of the economy. The second is that the programs should be created to be flexible. We are living in an unpredictable moment and we should design programs that are flexible and can deliver positive results while being adaptable to the moment we are in. The third is that we will need much more funding than what we think we will need. According to the US Department of Labor 591,500 people in Kentucky, more than a quarter of state’s workforce, have filed for unemployment insurance in Kentucky since mid-March. This should speak to the amount of need that we will see in our community. We ask that in creating and administering these programs you strongly consider these factors.

Scope of work We see a lack of clarity of what “facing eviction” means. To some, this could mean that they have a case filed against them while to others it means that they are significantly late on their rent payments. Each of these situations has a different set of intervention strategies. We ask for more clarity as to whom this program is meant to help and what are the anticipated outcomes.

Louisville-Jefferson County Metro Government 182 Appendices - Amendment to the 2019 Action Plan May 21, 2020 We also seek clarity and details about how a person will establish that they have lost income due to COVID-19. From our experience, we have heard many stories of people who were self-employed and cannot prove that they have lost income other than an empty bank account, people that are on a fixed income and were receiving other support from family to help cover bills and now that family member has lost their job, and people that were not working before COVID-19 due to health concerns and now are unable to find work. Additionally, would a person be disqualified from the program if they were trying to use other resources or had used other resources in the past year from the city? We propose that the threshold for receiving service through this program should remain low. We think that the priority of the program should be to assist people as quickly as possible with the least amount of barriers and exclusions as possible. We also advocate that this program needs to be especially geared to members of our community that are living at or below 50% AMI. These are the households that are already living with very thin margins, have a history of being locked out of assistance programs, and are the most likely to become homeless when some semblance of normalcy returns.

More Funding Needed $1.5M is a significant allocation but we fear that the need is going to be much greater than we can anticipate. Community Ministries and Neighborhood places are projected to spend 1.5 million on rental assistance by the end of June. We ask that more resources are dedicated to this program to deal with the influx of requests for assistance. With these additional resources, more staff can be allocated to this program and more people can be helped to result in better outcomes.

Timing Another shortcoming is the start date of June 30th. Eviction court has been closed for almost two months and is scheduled to reopen at the end of June. Based on our conversation with some landlord associations, there is a great amount of anxiety about getting rent payments to fulfill debt obligations. We believe that as soon as court opens there will be a rush of filings by landlords who are themselves behind on their payments. This program needs to begin before the court reopens to give landlords assurances that this program is the better, more financially viable option to eviction.

Speed of Payment to Landlords We also fear that this program is too slow for landlords. If the program is predicated on tenants making half of their late payments over the course of two months, that is an additional two months where landlords are waiting for their rent payments and not able to fulfill their debt obligations. This may become an obstacle for landlords and make the program the less advantageous alternative to eviction. We believe that these payments to Louisville-Jefferson County Metro Government 183 Appendices - Amendment to the 2019 Action Plan May 21, 2020 landlords should be made with urgency within 1-2 weeks.

It is paramount that Landlords are incentivized to buy into this program. Waiting for two months to be made whole is unworkable for many who have already been struggling with their debt obligations for two months. This program should prioritize quick payment to the landlord and explore ways to make some payment when the landlord and tenant enter into an agreement.

Caseworkers We also have many questions about the work that the caseworkers will take on while administering this program. The majority of participants will not need the traditional model of case management. We believe that these caseworkers will need to hold the role of mediator, trusted connector, and navigator. They should work closely with the courts and tenants before as well as during the eviction process. They should act as navigators that will help clients to communicate with their landlord, advocate during the eviction process, connect the client to funding options, and establish what option is best for the client. We strongly suggest that Louisville should emulate the best practices of a similar program operating in Cleveland, Ohio.

Financial Literacy Classes/Match Requirement/One Size Fits All Program We find that the requirement for participants to attend budgeting classes or speak with a financial advisor is a waste of resources and represents an undue burden for the participants and the case workers. We are in the midst of a dynamic environment because of the Covid-19 Pandemic. Many things are out of our control. Losing one’s job or getting one’s hours cut to maintain social distancing and stay healthy is not in our control. Requiring someone to attend a class on how to budget is based on the idea that if they made better decisions then they would not be asking for assistance. This pending eviction crisis is not because of everyone making a bad decision but because we are attempting to stunt the growth of an incredibly infectious virus.

We also question the use of financial literacy classes and budgeting classes as a requirement for any services and assistance. After working for years with a local eviction prevention committee to review best practices nationwide and speaking with local experts in the field, we believe that any program with a one size fits all format, is not a best practice and instead perpetuates the belief that poverty is the result of flaws in one's character and that if one shows more restraint and self-control then they would not be asking for help. The very nature of poverty means that the poor are often the savviest budgeters of us all. This is borne out of necessity. When one has limited income, the daily tradeoffs one faces prompt them to watch their finances more closely because there is little margin for error. Louisville-Jefferson County Metro Government 184 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Meanwhile, this same program provides a direct benefit to landlords who are also struggling during this time to make mortgage payments, but there is no similar requirement for them to attend budgeting classes or an assessment to determine if budgeting classes are needed. We find this discriminatory and suggest either everyone is required to attend these classes (including landlords) or an assessment is used to determine when it is an appropriate referral.

Through our research, we instead identified the Cleveland model of eviction prevention as the best practice and best fit for Louisville. It incorporates the HUD model of employing progressive engagement. This means working with the participants early in the eviction process to establish what their needs are and adapting the program to fit. The caseworker connects them with other services that are available to them in other departments of the city and social services sector which could include budget counseling when appropriate.

This same approach should be used in designing the amount of assistance. Some higher-income families that have acquired unemployment and/or returned to work may be able to pay 50% of their past due rent while others can never achieve that. This program would force those hardest hit to go to other limited resources like Neighborhood Place, Community Ministries, or churches to beg for other limited funds to maintain their housing and once again delay payments to landlords.

An alternative approach We propose an alternative approach, in conjunction with the suggestions above, to the administration of this program. We propose that the program should begin with a conference between the landlord, the tenant, and the city caseworker. During this conference, all parties work together to figure out a solution that will be workable to all involved. During this conference, the parties involved can negotiate what could be paid that day and what is owed at a future date, determine what the city can pay, waive late fees, and develop a plan of how the rent will be paid. From there, the tenant would be connected to a wide range of services and supports and the city could cut a check directly to the landlord. This would offer expediency and flexibility for the city to adjust the program to meet the needs of both people that have been able to return to work and those that are still waiting for employment or unemployment checks. This would offer a more expedited timeline that is a more advantageous option for landlords compared to the eviction process.

Housing Stabilization Program We support the Housing Stabilization Program to house and support individuals and Louisville-Jefferson County Metro Government 185 Appendices - Amendment to the 2019 Action Plan May 21, 2020 families experiencing homeless. We think this should be a priority of the city's work. We suggest that there is case management for these participants.

Moving from the waitlist to a housing unit is an opportunity to reset one’s life and as you noted in the plan to “gain stability and focus on more than the basic need of shelter”. We believe that in order to fully realize the potential of this program there needs to be an element of progressive engagement case management for the participants to ensure that when their rent subsidy ends, they are able to maintain housing. We believe that the progressive engagement model, A HUD best practice, offers maximum flexibility and utility for the clients and the case workers. A Way Home, a program already already managed by the city offers a template that this program could copy in employing Case Management.

Community Land Trusts We believe that Community Land Trusts are a viable option to secure affordable housing and that this is a tactic that should be put into practice here in Louisville. We do not, however, believe that this is the best use of funds targeted to address COVID-19. We are in a pandemic that is multiplying the need that already existed in Louisville and has placed an unprecedented strain on the thin safety net that we have. We believe that $2 Million spent on eviction prevention and diversion through the neighborhood places and community ministries would be a better return on investment than on a Community Land Trust that may produce 16 units of housing in two years. From the start of the pandemic to the end of June, the Community Ministries and Neighborhood Places are projected to spend $1.5 million on rental assistance alone. The moment that we are collectively experiencing requires the surging of resources to meet the needs of those that have been disproportionately impacted by the health and economic fallout from this crisis. Directing this additional $2 Million toward direct assistance is a necessity at this moment.

When Louisville does put Community Land trust into practice, we recommend that Louisville implements best practices to ensure that the trusts serve low-income individuals and families, that the Land Trust is led by the residents, and is supported with a nonprofit that is connected to and has a positive relationship with the community. We also believe that when a land trust is implemented here in Louisville special care needs to be taken to ensure that those units created can house families of all sizes and that there is funding for initial and ongoing training for residents as to how a land trust works, and other needs identified by those residents.

Louisville-Jefferson County Metro Government 186 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Louisville Metro Response

Thank you for your comments. Based on several comments Louisville Metro has altered the Eviction prevention program to remove the requirement for the applicant to contribute 50% of the past due rent, and the need for any client counseling including budgeting, and removing the case managers to keep the program flexible. We will continue to allow households up to 80% of area median. As for clarity on “facing eviction” applicants will be required to produce either a late rent notice, a Notice of Forcible Detainer, or a utility past due bill to document their situation. We intend on permitting minimal documentation for income loss due to Covid-19 for persons who were self- employed, which could include self-certification and/or prior year tax returns, to assist as many people as possible, as quickly as possible.

While we agree additional funds are needed, at this time, the $1.5M we are allocating is all we have available for this. We are working with city leaders to find other sources, specifically other Covid-19 funds from the federal government to address the great need.

We anticipate the roll out of this program toward the middle to end of May, not June 30th as listed originally. June 30th would be the very latest date we would roll it out, but we are on track to roll it out much earlier. As this program will be a continuation of the current Eviction Prevention Program being administered by the Office of Resilience and Community Services (RCS), we anticipate the payment to Landlords will continue at the same pace that we are currently making payments, which is approximately 2 weeks and if the landlord is already in our system, it could be much sooner.

RCS will continue to attempt to get landlords to waive all fees that they have not been charged by their financial institutions, but ultimately, the goal is to stave off eviction, therefore, if a landlord refuses to waive fees that are codified in their lease with the tenant, the funds would pay those fees.

Regarding the Stabilization Program, RCS plans to provide case management for the housing stabilization program participants with wrap-around services funded by CSBG (Community Services Block Grant) to overcome barriers to self-sufficiency. Support for the Housing Stabilization Program will be one of the major components of our CSBG annual plan.

In regard to the Community Land Trust (CLT), we believe that building housing, and in this case we anticipate 50 units over the next 4-6 years, would be a good investment in the housing infrastructure of these communities where the CLTs would be based. The basic tenet of a CLT is that it is led by the community, and the community runs the program, we full intend on ensuring the CLT follows this basic premise. The CLT would assist households at or below 80% of AMI, but in many cases, they would likely assist households far below that maximum

Louisville-Jefferson County Metro Government 187 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Written Comments submitted by Clare Rutz Wallace, on behalf of the Association of Christian Ministries

Received May 7, 2020

Hi Michelle,

On behalf of the Association of Community Ministries, we'd like to lift up the report that was submitted by the Coalition for the Homeless (attached). We are also aware of the comments the Metropolitan Housing Coalition submitted and agree with those statements as well. These are a few points we'd like to reiterate:

1) Landlords will not typically accept partial or late payments when they are able to move forward with the eviction process for their own financial security. The timeline and urgency in payment must be amended. Please note, the Community Ministries is able to provide payment to a landlord in a 24-48 hour timeframe for this reason.

2) The role of the Case Manager should be better defined. Traditionally, a "case manager" is someone that builds rapport, navigates resources, and advocates for their client. To do this work effectively, a case manager should have no more than 10 cases open at one time. With 3 employees and 1500 participants in a 10-week program, that's approximately 60-80 households a month. Landlord mediation and benefit navigation alone would not be possible with this case load. Our recommendation is to work with other, trained case managers to help with this work and to contract this work out.

3) A one-size-fits-all required budgeting class is both ineffective and condescending. It reinforces the notion that they are poor and in crisis because they have done something wrong. Especially now, this has little to do with their wealth management and everything to do with the fact that 78% of Americans are living paycheck to paycheck. This budgeting class and others should be offered, but not required.

4) $1.5 million is not enough. The Neighborhood Place and the Community Ministries have distributed approximately $1 million in 1.5 months and hundreds of people have still been turned away. We have seen the request for assistance increase by 40% compared to last year and we expect it to only continue to climb.

As always, the Association of Community Ministries is available to partner and support this program in whatever way we're able.

Gratefully, -- Clare Rutz Wallace Executive Director South Louisville Community Ministries 415 1/2 West Ashland Avenue Louisville, KY 40214

Louisville-Jefferson County Metro Government 188 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Louisville Metro Response

Thank you for your comments. Based on several comments Louisville Metro has altered the Eviction prevention program to remove the requirement for the applicant to contribute 50% of the past due rent, and the need for any client counseling, including budgeting, and removing the case managers, to keep the program flexible. We will continue to allow households up to 80% of area median.

As for clarity on “facing eviction” applicants will be required to produce either a late rent notice, a Notice of Forcible Detainer, or a utility past due bill to document their situation. We intend on permitting minimal documentation for income loss due to Covid-19 for persons who were self- employed, which could include self-certification and/or prior year tax returns, to assist as many people as possible, as quickly as possible.

While we agree additional funds are needed, at this time, the $1.5 million we are allocating is a step in the right direction. We are working with city leaders to find other sources, specifically other Covid-19 funds from the federal government to address the great need.

Louisville-Jefferson County Metro Government 189 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Written Comments submitted by Mandy Simpson, on behalf of the Metro United Way

Received May 7, 2020

Michelle,

We at Metro United Way are grateful for Develop Louisville’s dedicated and urgent efforts to design a proposal for amending the 2019 Action Plan to integrate newly allocated federal Coronavirus Aid, Relief and Economic Security Act (CARES Act) funding. Your commitment and leadership are invaluable to our community as we confront crisis.

As a part of our work to lift our community by mobilizing people and maximizing resources to advance opportunity and equity for all, we recognize the profound need for greater availability of safe, affordable housing opportunities in our region. The COVID-19 pandemic has compounded this need and placed us on the precipice of widespread housing loss. Our community must fully leverage CARES Act funding to stabilize the rental and home ownership landscapes and mitigate damages to individuals and families.

With this in mind, we stand by the unique expertise and frontline-experience of our Coalition for the Homeless partners and support their recommendations for improving the administration and increasing the impact of the proposed amendment. In this unprecedented moment of crisis, we must focus on accessible, large-scale solutions that are properly resourced and limit burdens on those they are designed to support.

We urge you to incorporate this guidance into the final Action Plan amendment and continue evaluating programmatic supports through an equity lens that prioritizes those who have experienced systemic inequities that exacerbate the effects of the COVID-19 crisis. We stand at the ready to support by sharing community research and lived realities. Please let us know how we can be helpful as you move forward.

Mandy Simpson (she/her/hers) Director of Public Policy

Metro United Way 334 E. Broadway | Louisville, KY 40202

Louisville Metro Response

Thank you for your comments. While we agree additional funds are needed, at this time, the $1.5 million we are allocating is a step in the right direction. We are working with city leaders to find other sources, specifically other federal funds to address the great need and stabilize the rental and home ownership landscapes and mitigate damages to individuals and families.

Louisville-Jefferson County Metro Government 190 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Written Comments submitted by Emilie Dyer, on behalf of Americana World Community Center

Received May 7, 2020

Good Morning Michelle,

I'm writing today to emphasize the important points of fellow community members about the spending plan proposal for the CARES Act. Please consider these issues when making decisions about this initiative:

1) Landlords will not typically accept partial or late payments when they are able to move forward with the eviction process for their own financial security. The timeline and urgency in payment must be amended. Please note, the Community Ministries is able to provide payment to a landlord in a 24-48 hour timeframe for this reason.

2) The role of the Case Manager should be better defined. Traditionally, a "case manager" is someone that builds rapport, navigates resources, and advocates for their client. To do this work effectively, a case manager should have no more than 10 cases open at one time. With 3 employees and 1500 participants in a 10-week program, that's approximately 60-80 households a month. Landlord mediation and benefit navigation alone would not be possible with this case load. Our recommendation is to work with other, trained case managers to help with this work and to contract this work out.

3) A one-size-fits-all required budgeting class is both ineffective and condescending. It reinforces the notion that they are poor and in crisis because they have done something wrong. Especially now, this has little to do with their wealth management and everything to do with the fact that 78% of Americans are living paycheck to paycheck. This budgeting class and others should be offered, but not required.

4) $1.5 million is not enough. The Neighborhood Place and the Community Ministries have distributed approximately $1 million in 1.5 months and hundreds of people have still been turned away. We have seen the request for assistance increase by 40% compared to last year and we expect it to only continue to climb.

Sincerely, Emilie Dyer Programs Director Americana World Community Center

Louisville Metro Response

Thank you for your comments. Based on several comments Louisville Metro has altered the Eviction prevention program to remove the requirement for the applicant to contribute 50% of the past due rent, and the need for any client counseling, including budgeting, and removing the case managers, to keep the program flexible. We will continue to allow households up to 80% of area median. While we agree additional funds are needed, at this time, the $1.5 million we are allocating is a step in the right direction. We are working with city leaders to find other sources, specifically other Covid-19 funds from the federal government to address the great need. Louisville-Jefferson County Metro Government 191 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Written Comments submitted by Lisa Thompson, on behalf of the Louisville Urban League

Received May 7, 2020

May 7, 2020

Michelle Rodgers, Louisville Forward Louisville Metro Government Louisville, KY 40202

Thank you for this opportunity to comment on proposed amendments to the Louisville/Jefferson County Metro Government Program Year 2019 Action Plan. The Louisville Urban League remains a committed partner to residents and to Louisville Metro Government. The COVID-19 crisis threatens everyone, but for the community’s most vulnerable who have already been negatively impacted by decades of disinvestment, redlining and inequity, the emergency has far greater danger.

We support the COVID-19 response to allocate $3,145,161 in Community Development Block Grant to support housing stability and eviction prevention. Louisville Urban League’s Center for Housing and Financial Empowerment is already engaged in the work of financial counseling aiding renters faced with enormous challenges due to COVID impact. The Eviction Prevention Plan, funded at $1,545,161 is needed but efficiencies must be identified to leverage existing counseling structures so that LUL clients and others similarly served can quickly access these CDBG resources as LMG establishes its operation.

We understand the goal to stretch funding by requiring that a tenant’s own resources or even community philanthropy match CDBG however family leaders of hundreds if not thousands of households cannot safely return to employment. The proposed $1:$1 match required from tenants in two months is too demanding to be successful for the hardest to serve. To avoid additional homelessness, quickly confirm that COVID-19 Response Emergency Shelter Grant resources allocated to homeless prevention will be used for this local match in extreme circumstances. If ESG or One Louisville COVID-19 Response Fund resources are not available for this match, we recommend that the match requirement be waived.

Challenges facing thousands of Louisville rental households was not of their making. Repayment plan counseling must be efficient, culturally competent and include trauma-informed practice. Evictions are the result of the pandemic and circumstances beyond the control of those harmed. Economic recovery of both the tenant and landlord is the highest goal however CDBG should favor the economic needs of the tenant. The match requirement and counseling plan, as outlined, imposes hardship upon the tenant and should be streamlined.

The Housing Stabilization Plan funded with $1,600,000 in CDBG funds is a well conceived 12-month rental assistance program and will enable service to more people experiencing homelessness due to this emergency.

Two additional CDBG-funded amendments are important. The establishment of Community Land Trusts is of extreme importance to equitable revitalization work. Future success in neighborhood revitalization should be measured by resident ownership of residential and commercial properties so that wealth generation is possible given Louisville’s highly discriminatory practices of the past. LUL supports the goal of a 50-unit production pipeline and community land trust control through nonprofit entities that have proven to be accessible to resident input and that prioritize resident asset-building and ownership.

Small business support using $1.5 million from COVID-19 Response Funds is a good start, but far more is needed to build resilience for businesses left out of other CARE Act support strategies. The NOFA must be quickly executed to get needed capital to resident-owned businesses.

Louisville-Jefferson County Metro Government 192 Appendices - Amendment to the 2019 Action Plan May 21, 2020 COVID-19 Response Emergency Shelter Grant funds used for homeless prevention services should include the LMG-desired match to CDBG for those hardest to serve. The three anticipated NOFAs are prescribed. Given Louisville’s disportionately large population of at-risk young adults and other high-need populations, we are concerned that grants are large enough to enable traction and nonprofit efficiencies given the HMIS compliance burden. We endorse ESG use to leverage other mortgage foreclosure and rent (eviction prevention) resources. The Louisville Urban League also supports the COVID-19 Response Plan for HOPWA.

Sincerely,

Lisa Thompson Chief Impact Officer cc: Marilyn Harris, Director, Office of Housing Sadiqa Reynolds, President and Chief Executive Officer, Louisville Urban League Lyndon Pryor, Chief Engagement Dena Elliott, Program Manager, LUL Center for Housing and Financial Empowerment

Louisville Metro Response

Thank you for your comments. Based on several comments Louisville Metro has altered the Eviction prevention program to remove the requirement for the applicant to contribute 50% of the past due rent, and the need for any client counseling including budgeting, and removing the case managers to keep the program flexible. We will continue to allow households up to 80% of area median.

While we agree additional funds are needed, at this time, the $1.5M we are allocating for the Eviction Prevention Program and to the Small Business Loan program is all we have available for these activities. We are however, working with city leaders to find other sources, specifically other Covid-19 funds from the federal government to address the great need.

Regarding the Stabilization Program, RCS plans to provide case management for the housing stabilization program participants with wrap-around services funded by CSBG (Community Services Block Grant) to overcome barriers to self-sufficiency. Support for the Housing Stabilization Program will be one of the major components of our CSBG annual plan.

In regard to the Community Land Trust (CLT), we believe that building housing, and in this case, we anticipate 50 units over the next 4-6 years, would be a good investment in the housing infrastructure of these communities where the CLTs would be based. The basic tenet of a CLT is that it is led by the community, and the community runs the program, we fully intend on ensuring the CLT follows this basic premise. The CLT would assist households at or below 80% of AMI, but in many cases, they would likely assist households far below that maximum

Louisville-Jefferson County Metro Government 193 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Written Comments submitted by Megan McGinn, on behalf of Alltrade Property Management

Received May 7, 2020

May 7, 2020

Develop Louisville ATTN: Michelle Rodgers 444 South 5th Street, Fifth Floor Louisville, KY 40202

To the Members of Louisville Metro Government:

Thank you for allowing me the opportunity to provide feedback on the proposed use of the Coronavirus Aid, Relief and Economic Security Act (CARES Act) funding. I am a former social worker and currently Chief Operating Officer at Alltrade Property Management, a property management company managing over 5,000 rental units in Louisville, Lexington, North Carolina and Alabama. Alltrade is a third party property management company which means we have two sets of clients – property owners and residents living in the units. We seek to balance the interests of both parties.

More than 5,000 households were evicted in Jefferson County in 2016, a rate that is two times the national average. Eviction displaces families, disrupts communities and creates further barriers to stable housing. In the wake of COVID-19, families are at an elevated risk of being evicted.

It is wonderful to see $1.5 million in CDBG funding for eviction prevention. Below are my recommendations for the best outcomes with those funds.

Start Sooner. The start date of June 30th coincides too closely with the date the courts are scheduled to reopen. This program needs to begin by June 15th (if not earlier) to allow for processing applicants so they can hopefully avoid going to eviction court all together. Eviction court is costly and already dockets and courtrooms are overcrowded. Getting residents assistance before even going to court will alleviate stress for residents, landlords and the courts.

Do not require 50% payment by the residents to qualify for matching assistance funds. The residents who are in need of assistance have likely already signed a payment plan with their landlord. They are already behind. We believe they would have paid already if they had the funds. Many will not have funds to pay the 50% required by this program. This is an unreasonable hurdle and delay. Many property owners do not have the patience or reserve funds to cover their mortgage obligations and will not allow their property manager to wait on filing an eviction.

Eliminate the requirement for participants to attend budgeting classes or speak with a financial advisor. This requirement creates additional barriers to stability and assistance for those who need it. Requiring someone to learn how to better budget conveys that they should have made better decisions to avoid losing their job or

Louisville-Jefferson County Metro Government 194 Appendices - Amendment to the 2019 Action Plan May 21, 2020 income due to a global pandemic. This element of blaming a victim is not helpful at this time. They need assistance to remain housed, not a budgeting class.

Thank you for your consideration of my feedback.

Sincerely,

Megan McGinn Chief Operating Officer Alltrade Property Management [email protected] 502-562-1985 x280

Louisville Metro Response

Thank you for your comments. Based on several comments Louisville Metro has altered the Eviction prevention program to remove the requirement for the applicant to contribute 50% of the past due rent, and the need for any client counseling including budgeting, and removing the case managers to keep the program flexible. We will continue to allow households up to 80% of area median.

We anticipate the roll out of this program toward the middle to end of May, not June 30th as listed originally. June 30th would be the very latest date we would roll it out, but we are on track to roll it out much earlier.

Louisville-Jefferson County Metro Government 195 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Written Comments submitted by Shannon Floyd on behalf of resolve: Restorative Practice, LLC

Received May 7, 2020

Good afternoon Ms. Rodgers,

In following-up to a recent email sent to Lisa Osanka and Monday’s (May 4th, 2020) public meeting concerning tentative plans for the allocation of federal funds (CARES Act) in response to COVID-19, please consider mediation as an alternative in eviction prevention services. resolve: Restorative Practices LLC MBE/WBE Certified is a mediation practice that empowers “disputing parties” to identify problems, form plausible solutions, establish goals and create desired change. The goal is to resolve disputes prior to the pursuit of costly legal representation and/or lengthy judicial processes. The mediation process consists of:

• Mediation is a process by which communication is facilitated between “disputing parties” by a “neutral third party” to reach mutually beneficial and/or agreeable terms.

• Per explanation of the mediation process, “all involved parties” (e.g. disputants, legal representatives, Mediator, etc.) voluntarily sign an Agreement to Mediate

• Disputants establish “rules of engagement” at the start of the mediation session

• Each disputant is allowed a set time to express their “point-of-view” of the dispute

• Disputants explore resolutions based on individual needs, desires, interests, options, values, etc. followed by a Mediator led facilitation of mutually beneficial resolutions

• Per reaching an agreement about specific mutually beneficial resolutions, a Mediation Settlement Agreement is completed by disputants and signed by “all involved parties”

• Failure to adhere to the Mediation Settlement Agreement, a legally binding written contract, by any and/or all disputants can result in the Mediation Settlement Agreement being enforced in a court of law pursuant to Code of Civil Procedure ‘664.6

Louisville-Jefferson County Metro Government 196 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Please afford resolve: Restorative Practices LLC an opportunity to bring a sense of “humanity” to increased tensions between property managers, landlords, residents, tenants, etc. during unprecedented times to decrease evictions and strengthen human relations one dispute at a time.

Every resolution begins with a conversation and I am bursting with excitement about the unlimited possibilities. I can be reached at: 502-442-9125 or [email protected] to schedule a Zoom meeting the week of May 18th to discuss how resolve: Restorative Practices LLC can be a solution to an increasingly complex social issue in Louisville Metro. Please see the attached resume vitae for your consideration.

Respectfully, Shannon Shannon R. Floyd, Principal Mediator Resolve: Restorative Practices LLC

Louisville Metro Response

Thank you for your comments, at this time mediation is not being considered as an alternative in the Eviction Prevention Program as the imminent evictions that we are addressing are related to loss of income due to Covid-19 and the pandemic.

Louisville-Jefferson County Metro Government 197 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Written Comments submitted by Joshua Poe, on behalf of the Root Cause Research Center

Received May 7, 2020

Develop Louisville ATTN: Michelle Rodgers 444 South 5th Street, Fifth Floor Louisville, KY 40202

Re: Root Cause Research Center comments on Proposed COVID-19 Response Programs

Eviction Prevention Program Comments: “Each participant would be required to work with a caseworker and attend a budgeting class or meet with a financial coach…” a. Requiring residents who receive eviction assistance to participate in budgeting classes is a racist and classist policy. There is no empirical evidence indicating that low income people lack the necessary knowledge, skill or responsibility to manage budgets, particularly as it relates to emergency funding for COVID relief efforts. This funding is designed for relief for those experiencing income loss due to COVID. Forcing those impacted to submit a budget is shaming and oppressive. This requirement should be removed and should be offered only as an option. “The program will help renters/households at less than 80% of area median income (AMI) who are facing eviction.” - The eviction prevention program should be used exclusively for households at less than 30% area median income. These funds are allocated for emergency relief from the COVID crisis and the households most at risk of being unhoused should be prioritized. The 2019 Louisville Metro Housing Needs Assessment found that our greatest housing needs are for those making 30% area median income or less, with very little housing need at the 80% area median income level. Allowing these funds to be used for higher incomes will limit the availability for those most at risk, particularly since this funding amount will only serve 1,500 households. Between 3/2/2020 and 3/26/2020, there were over 780 forcible detainer (eviction) cases filed in Jefferson County. These cases will be heard as soon as the eviction moratorium is lifted. We suggest that these funds be used for households who are covered under the CARES Act, to prioritize the most vulnerable populations. 3. “Landlords would have to agree to the structure for a tenant/participant to be able to participate, and all parties would be required to sign a tri-party agreement.” - In this program, landlords are being subsidized and should not have authority over the tenant’s payment structure or agreement. 4. This program should include an external evaluation at the end of the 10-week period and another evaluation 6 months later.

Louisville-Jefferson County Metro Government 198 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Housing Stabilization Programs Comments: Instead of rental assistance, we recommend that this funding be used for rapid rehousing programs and converting hotel/motel space for providing shelter for unhoused persons during the emergency.

Community Land Trusts Comments • Community Land Trusts (CLTs) do not address the needs of emergency housing during the COVID crisis. As Louisville Metro noted in the public meeting on Monday 5/4/2020, this program is designed to be an “economic development” project for 2 nonprofit housing developers. This program will only construct 50 housing units with income requirements set at 80% area median income. In the time it takes to construct 50 new homes, this funding could be used to provide shelter for thousands of families who are housing insecure. Additionally, having income requirements at 80% area median income negates the affordability benefits associated with CLTs, since prices at 80% area median income are comparable with those of market rate housing. This program essentially diverts emergency relief funds away from those most in need of housing assistance, to subsidize nonprofit housing developers in building market rate housing disguised as a CLT, with very little of the benefits that traditional CLTs offer, such as community control of land and perpetual affordability requirements for those with incomes below 30% area median income. There was no public participation process for this CLT program, which is an absolutely essential component of CLTs. We recommend that the funds for this program be put into the Eviction Prevention Program. If Metro continues with this CLT program, we recommend that it includes: a. A yearlong public engagement process that includes community organizing with the goal of establishing grassroots resident organizations b. Allowing resident-led organizations to apply and compete for funding in launching a CLT c. Income requirements for those making less than 30% area median income.

General Comments We recommend that these funds be allocated exclusively for crisis relief to coronavirus-related housing and homelessness needs that provide direct service to those most impacted by the pandemic. We do not believe that these funds should be used for economic development programs while the most vulnerable in our community suffer from the systemic patterns rooted in predatory extraction and oppression.

Our demands in the public comment process related to COVID emergency relief funding: • Emergency rental assistance for all tenants • Ensure moratoria on evictions do not lead to mass evictions after the emergency has passed • Extend funding for hotel/motel space until after the emergency passes • Facilitate transfer of unused/vacant housing to families who are unhoused -- Joshua Poe (he/him/his) Co-Principal Investigator - Root Cause Research Center https://www.rootcauseresearch.org [email protected]

Louisville-Jefferson County Metro Government 199 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Louisville Metro Response

Thank you for your comments. Based on several comments Louisville Metro has altered the Eviction prevention program to remove the requirement for the applicant to contribute 50% of the past due rent, and the need for any client counseling including budgeting, and removing the case managers to keep the program flexible. We will continue to allow households up to 80% of area median.

Regarding the Stabilization Program, RCS plans to provide case management for the housing stabilization program participants with wrap-around services funded by CSBG (Community Services Block Grant) to overcome barriers to self-sufficiency. Support for the Housing Stabilization Program will be one of the major components of our CSBG annual plan.

In regard to the Community Land Trust (CLT), LMG believes this investment in the permanent housing is vital to preventing illness and sustaining the health of the citizens. One key factor in preventing illness is sanitary living conditions; the construction of 50 new units will provide 50 families with good housing, while providing numerous tradespersons with steady income and opportunity.

In the last year Metro has worked diligently with a technical assistance provider, held multiple public meetings and trainings, and met with numerous grass roots organizations to discuss the possibility of one or more CLTs in the city. The program will include community control of the land and perpetual affordability; two of the basic tenets of a CLT. The CLT would assist households at or below 80% of AMI, but in many cases, they would likely assist households far below that maximum.

Any resident led organization that is intent on establishing a CLT are encouraged to apply through the NOFA for these funds.

Louisville-Jefferson County Metro Government 200 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Written Comments submitted by Mattingly Edge

Received May 7, 2020

Develop Louisville ATTN: Michelle Rodgers 444 South 5th Street, Fifth Floor Louisville, KY 40202

Proposed Amendment to the 2019 Annual Action Plan Comments by Mattingly Edge May 7, 2020

Thank you for the opportunity to comment on the Proposed Amendment to the 2019 Annual Action Plan. Mattingly Edge is a nonprofit organization that cultivates partnerships that enable people with disabilities to thrive at work, home, and in the community. As part of this work, Mattingly Edge has recently developed its Housing Solutions Project funded by the Commonwealth Council on Developmental Disabilities. The project’s mission is to assist individuals with developmental disabilities move out of the typical congregated housing model and into homes of their own with supportive services that allow them to live independently.

Mattingly Edge supports Louisville Metro Government’s proposed plan to use CARES Act funds to provide additional support to the most vulnerable populations during this pandemic. Increased funding for homeless populations, those on the verge of homelessness, and those with HIV/AIDS are critical. However, individuals with developmental disabilities are a sometimes forgotten population that is also especially vulnerable at this time.

As the COVID-19 pandemic unfolds, the need to move away from congregated and segregated living spaces has become ever more apparent. For many across the country it has become a matter of life or death. Hotspots for the pandemic like New York City exemplify the risks associated with group homes and similar facilities. Last month, the New York Times reported that, as of April 6th, 1,100 of the 140,000 developmentally disabled people monitored by the state had tested positive for the virus. One hundred and five had died—a rate much higher than the general population. A separate study found that residents of group homes in the New York area were 5.34 times more likely to contract the virus and 4.86 more times likely to die from it.

Louisville has also seen how quickly and tragically COVID-19 can spread through institutional settings with places like Treyton Oak Towers, Rivers Edge, and others reporting increasing numbers of cases. Long-term care facilities have become some of the biggest hotspots in our state. We are not aware of any specific studies at this point regarding how the virus has affected those living in group homes locally. However, we know that maintaining distance, our current best defense against COVID-19, is nearly impossible in these settings.

Louisville-Jefferson County Metro Government 201 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Many of the individuals with developmental disabilities that currently live in congregated settings could live independently in their own homes with proper supportive services. However, finding housing that is affordable and accessible is a major obstacle in this endeavor. For example, a low- income individual with a disability may be able to obtain a housing voucher, only to discover that there is no accessible housing available. This creates a timing issue in which the individual is unable to find suitable housing in the time allotted, even when provided an extension.

We are pleased that Louisville Metro Government has acknowledged these accessibility issues and made it a goal of the Consolidated Plan to remove barriers for persons with disabilities that prevent them from living in their own homes. Partnerships with agencies like the Center for Accessible Living that fund ramp construction and other adaptations are a valuable resource for those with disabilities who seek to live independently.

The efforts of these accessibility programs have never been more important. And with many experts predicting that we could be living in this new COVID-19 reality for one to two years or more, this is both an immediate and ongoing need. We respectfully submit this information in hopes that it will assist Louisville Metro Government as it allocates CARES Act funding.

Louisville Metro Response

Thank you for your comments. Individuals with developmental disabilities are one of the many populations we hope we can assist through this pandemic response. We will continue to work with partners like Center for Accessible Living to allow persons with disabilities the opportunity to remain in their homes and remove the barriers that would prohibit them from doing so.

Louisville-Jefferson County Metro Government 202 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Written Comments submitted by Theresa Zawacki, on behalf of Russell Place of Promise

Received May 7, 2020

Michelle, thank you for the opportunity to provide comments on the proposed amendments to the Consolidated Plan to accommodate additional funds coming to Louisville as part of the federal relief package. On behalf of Russell: A Place of Promise, I'd like to offer feedback on the proposal. In general, Russell: A Place of Promise is supportive of the intent to provide financial relief to keep residents in safe, stable housing, and to prevent cost burden for families. We have some general comments and some specific points on several of the proposed amendments.

General Comments:

Several of the line items in the proposed revisions indicate that there will be NOFA processes created to award funds to external partners to administer. Rather than creating new positions, we suggest adding more opportunities for funds, particularly those intended to reach residents in need of housing support, to be disbursed to external partners, particularly community-based organizations and, where possible, faith-based organizations, to administer. This reduces the need to hire additional staff to oversee programs and makes more of the dollars available to support residents.

Consider programs to support seniors in need of housing assistance, including eviction prevention and supports for senior home owners.

Eviction prevention:

1. Consider prohibiting landlords from reporting overdue rent to credit bureaus, raising rent or taking other financially punitive steps against tenants participating in this program 2. Consider increasing the amount of rent paid through this program from 50% to 80%. Many residents who need assistance are still waiting to receive federal stimulus checks and/or unemployment, and are not yet back to work. It is unclear when these circumstances will resolve, meaning that residents in the greatest need may not be able to commit to paying a full 50% of what is owed in rent by the time Metro's eviction diversion program becomes available. 3. Require landlords to waive all late fees 4. Many tenants are not finding themselves unable to pay rent as a result of bad budgeting habits or overspending, but are facing unemployment and lost wages that prevent them from covering these expenses. Consider requiring tenants to participate in alternatives to financial planning/budgeting such as career coaching/job training that can help them

Louisville-Jefferson County Metro Government 203 Appendices - Amendment to the 2019 Action Plan May 21, 2020 find more financial stability through higher income, possibly in addition to financial coaching/budgeting support to accompany career coaching/job training activities. 5. Right-size this program to serve as much as possible the estimated need among residents living at 80% or less of AMI rather than invest dollars to expand other programs that may serve fewer residents. The Kentucky Center for Investigative Reporting found that up to 25% of renters did not pay their April rent, a 5-fold increase compared to pre-COVID-19 data.

Housing stabilization program - consider using some or all of these dollars to right size the eviction prevention program.

Community land trusts- while this is a necessary and worthwhile investment, it does not seem to provide the kind of broad and immediate impact for existing residents that other proposed initiatives will offer. The total impact of 14-16 new homes will not be felt immediately, as it will take time to administer the NOFA to select host organizations, and additional time to acquire property and necessary permits to build homes. If the additional federal funds are intended to provide immediate or near-term relief to populations affected by COVID-19, this proposal may not achieve that intent. Consider diverting some or all of these funds to eviction prevention efforts. If there is a desire to support existing low/mod-income home owners, consider diverting these funds to support activities such as weatherization/energy efficiency, property tax payments or other methods of preserving home ownership, particularly in areas that are known to be experiencing rapid reinvestment (Smoketown, Shelby Park, Russell).

Small business lending. Consider adding criteria to lending program to recognize preexisting barriers to accessing capital or creating a set aside for businesses in target neighborhoods such as Russell to recognize redevelopment plans in addition to preexisting barriers.

Thank you for the opportunity to review the proposed amendments and for the work you're doing to support the community, and please let me know if you have questions about anything you see here.

Theresa

Theresa Zawacki Executive on Loan to Russell a Place of Promise [email protected] 502-593-4508 www.russellpromise.com

Louisville-Jefferson County Metro Government 204 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Louisville Metro Response

Thank you for your comments.

The Eviction Prevention programs will both be run by RCS with existing staff, no new staff will be hired. We have made that change in the final version that we will be submitting to HUD. Regarding the Stabilization Program, RCS plans to provide case management for the housing stabilization program participants with wrap-around services funded by CSBG (Community Services Block Grant) to overcome barriers to self-sufficiency. Support for the Housing Stabilization Program will be one of the major components of our CSBG annual plan.

Based on several comments Louisville Metro has altered the Eviction Prevention program to remove the requirement for the applicant to contribute 50% of the past due rent, and the need for any client counseling including budgeting, and removing the case managers to keep the program flexible. We will continue to allow households up to 80% of area median.

While we agree additional funds are needed, at this time, the $1.5M we are allocating is all we have available for this. We are working with city leaders to find other sources, specifically other Covid-19 funds from the federal government to address the great need.

We anticipate the roll out of this program toward the middle to end of May, not June 30th as listed originally. June 30th would be the very latest date we would roll it out, but we are on track to roll it out much earlier. As this program will be a continuation of the current Eviction Prevention Program being administered by the Office of Resilience and Community Services (RCS), we anticipate the payment to Landlords will continue at the same pace that we are currently making payments, which is approximately 2 weeks and if the landlord is already in our system, it could be much sooner. RCS will continue to attempt to get landlords to waive all fees or taking other punitive steps against the tenants, or charge fees that they have not been charged by their financial institutions, but ultimately, the goal is to stave off eviction, therefore, if a landlord refuses to waive fees or decides to report to the credit bureaus, we would still provide the funds. In regard to the Community Land Trust (CLT), LMG believes this investment in the permanent housing is vital to preventing illness and sustaining the health of the citizens. One key factor in preventing illness is sanitary living conditions; the construction of 50 new units will provide 50 families with good housing, while providing numerous tradespersons with steady income and opportunity. The program will include community control of the land and perpetual affordability; two of the basic tenets of a CLT. The CLT would assist households at or below 80% of AMI, but in many cases, they would likely assist households far below that maximum. Any resident led organization that is intent on establishing a CLT are encouraged to apply through the NOFA for these funds.

Louisville-Jefferson County Metro Government 205 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Finally, we will take into consideration adding criteria to the NOFA regarding pre-exisiting barriers to accessing capital and businesses in target areas.

Louisville-Jefferson County Metro Government 206 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Appendix B

Public Meeting on Amendment:

Questions and Comments with Develop Louisville’s Response

Public Meeting held virtually May 4, 2020 at 6:00pm

Louisville-Jefferson County Metro Government 207 Appendices – Amendment to the 2019 Action Plan May 21, 2020 Public Meeting on Proposed Amendment to 2019 Action Plan

• May 4, 2020 • Held virtually via WebEx and Facebook Livestream • Comments accepted via WebEx chat, Facebook comment, or email response • Approximately 200 participants viewed

Questions and comments received during the meeting, with responses from Develop Louisville (Director of the Office of Housing, Marilyn Harris [MH]) and the Office of Resilience and Community Services (Executive Administrator, Andrew Bates [AB]):

Question from WebEx user Arthur Crosby: Will there be any requirements that landlords make some concessions of the rent? Will you incentivize landlords that agree to waive some of their normal rent? Will you allow landlords to still collect late fees?

Louisville Metro Response: MH: Currently, Develop Louisville is not requiring landlords to make any waivers. DL understand that while tenants are facing difficulties paying rent, landlords are also facing difficulties paying mortgages. However, while DL will not require landlords to make concessions, we will require that there be a triparty agreement between the landlord, the tenant, and the Office of Resilience and Community Services, that lays out the terms of the agreement.

Question from WebEx user Cathy: So people who are so underemployed that they have no money to match are the gap that you are not reaching. Oh, until they become homeless.

Louisville Metro Response: MH: Those who are unemployed or underemployed due to the COVID-19 pandemic are eligible for both unemployment insurance and pandemic insurance. Unemployment insurance will pay a portion of the income that was earned before the individual was laid off. Pandemic insurance will pay an additional $600 every two weeks to supplement income. Develop Louisville has been persistent their recommendation that if an individual can pay their rent, they should, and that an individual should utilize the additional $600 received bi-monthly to help cover that expense. The amount of funding that Louisville Metro has to support COVID-19 response is not sufficient to cover 100% of the need. Therefore, these Amendment proposal projects have been designed to assist tenants get over the hurdle and pay their rent.

Question from WebEx user Cathy: I like CLTs but I fail to see how this is an emergency program.

Louisville-Jefferson County Metro Government 208 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Louisville Metro Response: MH: The Community Land Trust is a multifaceted program that can also be considered through the lens of an economic development program to help jump start local businesses and support local business to increase their hiring. The goal of the program is to create 50 homes over the next few years, which will both provide affordable housing as well as providing funding to local developers to create the housing. Inherent in the emergency issues that Louisville is now seeing with it’s low- to moderate-income residents is that there is not sufficient affordable housing for these income groups. By continuing to ignore this need, these kinds of emergency situations will continue to arise year after year, and emergency after emergency. By supporting the creation of a Community Land Trust now, DL ensures more affordable housing for the future, and reduces the impact of future economic burdens, while simultaneously stimulating the local economy with development funds.

Question from WebEx user Arthur Crosby: It also seems that if you want until the courts reopen to implement this plan, then you will have landlords who will have already started their evictions. That means additional court costs and late fees.

Louisville Metro Response: MH: DL’s intention is to roll out the program by the end of May 2020, well before the reopening of the courts on July 1st. While no progress can be made on individual cases until the courts reopen on July 1st, the intention is to enroll eligible participants in the program much earlier in the process, so that when the courts do open, DL is ready to advance the court cases of each participant. DL would prefer to work with eligible clients before they reach eviction court, so as to be more preventative and less reactive.

Question from WebEx user Resolve: Restorative Practices LLC: Will small business loans be forgivable?

Louisville Metro Response: MH: At this time, there is not an intention to make these loans to small businesses forgivable. They will be offered at very low interest rates to offer an opportunity to local, small businesses to get needed assistance at an affordable cost. While at this time there is no intention to make these loans forgivable, the NOFA is still in its development and may be revised to include this provision in the future.

Question from WebEx user Cathy: Can people use ESG as match for the eviction diversion money?

Louisville Metro Response: AB: Per the new waivers released by HUD in the month of April 2020, ESG subrecipients are not required to match ESG funds that are subgranted. Per standard ESG requirements, ESG subrecipients are required to provide a 1:1 match of all ESG funds received. However, there is not a requirement for subrecipients to provide a match to CARES Act funding. Therefore, the Office of Resilience and Community Services would encourage any organization for whom the

Louisville-Jefferson County Metro Government 209 Appendices - Amendment to the 2019 Action Plan May 21, 2020 match requirement has presented a barrier in the past to apply for these funds via the Notice of Funding Availability, as such a requirement does not apply here. Additionally, HUD has provided a waiver that allows the income limit for ESG services (usually capped at 30%) to be raised to accommodate more participants. Requirements for inspections have also been loosened to allow homeless prevention funding to be given to participants without their apartment requiring a pass inspection in advance of receiving assistance.

Question from WebEx user Cathy: Is there any movement to expand from AIDS alone to also people who have permanent disabilities due to COVID?

Louisville Metro Response: AB: While many of the requirements for the entitlement funds are being loosened per CARES Act waivers, HOPWA funding will still be designated for Housing Opportunities for Persons With AIDS and cannot at this time extend to support families experiencing other kinds of disabilities. However, much of the Emergency Solutions Grants (ESG) may be targeted to serve other populations, including those with disabilities resulting from complications with COVID.

Question from WebEx user Resolve: Restorative Practices LLC: Are new hires (Case Managers) responsible for mediating between property managers and residents?

Louisville Metro Response: MH: Develop Louisville and the Office of Resilience and Community Services are working together to outline these policies, and they are still under development. Currently, the drafted plan says that residents who are willing and able to contact their landlords and facilitate the agreements are able to do so. However, there will also be Case Managers hired through RCS who could advocate on behalf of the tenants in situations where an agreement cannot be immediately reached.

Question from WebEx user Lenovo: Are the match requirements the same as for the regular allocations?

Louisville Metro Response: AB: No, ESG requirements for CARES Act funding do not require a 1:1 match from subrecipients. Unlike regular entitlement ESG, there are no match requirements for CARES Act funding.

Question from WebEx user MGreenwell: In the ESG project funds designated for Homeless Prevention, the proposed amendment notes an "Eviction Court Case Manager". Is that an individual employed by RCS? How exactly will that individual be engaging with eligible clients?

Louisville-Jefferson County Metro Government 210 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Louisville Metro Response: AB: The Office of Resilience and Community Services is hopeful that one or more local agencies who has experience with management of court cases will apply for a portion of the ESG funding via the NOFA, and can act as the Eviction Court Case Manager in eviction cases directly related to hardship due to COVID-19. This designated liaison will coordinate eviction defense and help to triage the cases that come into eviction court and help to match the tenants who have pending evictions to instead divert them to one of the most appropriate programs to help them, such as the CDBG eviction prevention program or an ESG prevention program. Through this model, the client would work with the court and the landlord to receive assistance through one of those programs.

Question from WebEx user Cathy: So the person needs to HAVE the match but if you require that they give to the landlord, that alters the landlords legal rights. So landlords may refuse to take partial payment. This really narrows who will actually be able to use this program

Louisville Metro Response: MH: DL is in the process of drafting a tripartite agreement that would both protect the landlords rights as well as allowing the tenant to make partial payments. While final details are still being determined, DL is in full agreement that the rights of both the tenants and the landlords must be protected, and those priorities will be reflected in the legal document that DL will draft over the coming weeks.

Question from WebEx user Joe Hamilton: Just want to send kudos to Metro Gov for the amount of resources overall dedicated to rental assistance. When the eviction moratorium ends, I’m afraid we are all going to get slammed with folks needing emergency rental assistance. Anyway, kudos to you all for thinking this through! My one commentary is just about remembering the specific and unique needs of homeless young adults. Some dedicated rapid re-housing rental and support services could really help with this population. Thanks! Joe Hamilton

Louisville Metro Response: MH: Louisville Metro thanks Joe Hamilton for the comment. The needs of homeless youth are critical as both current and future uses of these funds are determined. Louisville Metro Government is committed to doing everything it can to disrupting the cycle of poverty, and nowhere is this impact more deeply felt than in work with our youth. LMG is grateful to community members like Mr. Hamilton for the work that they do to support homeless youth and will take into consideration the specific and unique needs of homeless young adults when coordinating this funding.

Question from WebEx user Cathy: I meant could a person use ESG as the match to get the Eviction Diversion money. But it was great to hear we do not have to match to get ESG

Louisville-Jefferson County Metro Government 211 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Louisville Metro Response: LMG appreciates the comment from Cathy. At this time, the specific details of what funding sources may or may not be used for the 50% match requirement for the Eviction Prevention Program are still being finalized. LMG will take this suggestion under consideration when creating final determinations.

Question from WebEx user Resolve: Restorative Practices LLC: Is unemployment insurance and pandemic unemployment "one in the same" or separate?

Louisville Metro Response: MH: Those who are unemployed or underemployed due to the COVID-19 pandemic are eligible for both unemployment insurance and pandemic insurance, which represent two different types of supplemental unemployment income. Unemployment insurance is funded by the State of Kentucky and is available to any eligible Kentuckian who has lost their job, regardless of whether or not this loss is related to the COVID-19 pandemic. The amount that a person would receive from this state-funded unemployment insurance is based on a percentage of that person’s previous income.

Pandemic insurance is a federally funded insurance program and will pay an additional $600 every two weeks to supplement income for those persons who lost employment specifically from COVID-19 related changes. This additional $600 received bi-monthly is intended to help cover living expenses or unforeseen expenses arising from this crisis. A person could receive both standard, state unemployment insurance and pandemic insurance every two weeks.

Question from Facebook user Josh Poe: Requiring residents who receive eviction assistance to participate in budgeting and financial literary classes is a racist and classist policy. There is no empirical evidence indicating that low income people lack the necessary knowledge, skill or responsibility to manage budgets. This policy is part of a long, harmful and paternalistic narrative that low income people don’t know how to supervise themselves. Louisville Metro should know better, having draped themselves in progressive rhetoric about racial equity and “acknowledging” the “history” of structural racism in our city. Why is this stipulation included and what analysis is the requirement based on? income people don’t know how to supervise themselves. Louisville Metro should know better, having draped themselves in progressive rhetoric about racial equity and “acknowledging” the “history” of structural racism in our city. Why is this stipulation included and what analysis is the requirement based on?

Louisville Metro Response: MH: DL is not necessarily requiring budgeting and financial literacy; Rather, the requirement will meet with a financial counselor to determine and ensure that clients are able to successfully pay their respective portion of the rent owed. This is considered a light touch program, and only requires tenants to meet a few times with a counselor to help determine a budgeting plan for the future.

Louisville-Jefferson County Metro Government 212 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Question from Facebook user Kelly Kinahan: Additionally, this situation is in no way associated with budgeting. We are in a public health crisis. Will landlords be required to participate in similar budgeting classes?

Louisville Metro Response: MH: To further clarify, DL is not requiring tenant to participate in budgeting classes, but rather to meet with a financial counselor to define a functional and successful repayment plan. At this time there is no plan to require landlords to also meet with a financial counselor.

Question from WebEx user Arthur Crosby: If you can’t meet 100% of the need, how are you going to prioritize who receives the funds? Will you prioritize affordable housing? Families with children? And how will you ensure that these all parts of the community is aware of this funding (i.e. non-English speakers, etc.)

Louisville Metro Response: MH: With regards to prioritization in the eviction prevention and stabilization programs, these programs will be operated on a first come-first served basis. We will assist families in the order that they apply. Develop Louisville plans to advertise these programs through the Louisvilleky.gov website, Develop Louisville’s Facebook page, and through connecting with all of the homeless service providers with whom RCS is connected. DL will also connect with the Louisville Apartment Association to connect with landlords. Non-English speaking persons can receive interpretive services from LMG.

AB: With regards to the NOFA for ESG and HOPWA, RCS strives to connect with as many agencies as possible. This is done through sharing the information on RCS’ website and social media, as well as with sharing the information with the Continuum of Care and service provider agencies, as well as the Association of Christian Ministries. RCS will also work to translate the application into Spanish and Arabic, the two languages most frequently spoken by participants.

Question from WebEx user Arthur Crosby: It does seem weird to require tenants to go through financial counseling before they qualify, but you're going to speed up the process so that landlords don't have to make sure their property meets basic Codes requirements.

Louisville Metro Response: MH: This program is still in the development phase. The allowance to loosed the requirements for inspections are based only on newly released waivers, and apply only to ESG funding.

AB: Additionally, landlords are still required to keep their units up to code. The wavier simply allows for the inspection from the assisting agency to come slightly later in the process so as not to impede clients’ ability to receive payments quickly and pay their rent. There is no amnesty allowing landlords to not meet code requirements.

Louisville-Jefferson County Metro Government 213 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Question from WebEx user Cathy: you can be evicted for not having utilities- so will this help with utilities?

Louisville Metro Response: MH: DL thanks Cathy for the comment. As the finite details of the program are created, LMG will include considerations of utility payment and how these, too, affect tenants ability to pay. Currently the program for eviction prevention does include utilities.

Question from Facebook user Josh Poe: Will landlords be required to go through racial equity training?

Louisville Metro Response: MH: At this time, there is no requirement for landlords to attend a racial equity training.

Question from WebEx user Arthur Crosby: Also, in your Eviction Program Plan you cite that "average eviction delinquency in Louisville is approximately $2000." Do you think that's realistic to use that past norm given the unprecedented nature of this pandemic?

Louisville Metro Response: MH: DL understands that this statistic is most likely no longer accurate, given all of the changes in average income over the past several weeks. However, it is the most recent statistic that DL has at its disposal, having been calculated in a review in February 2020 to assist eviction prevention measures that was already underway. This figure helps DL to determine an estimated number of people served.

Question from Facebook user Chester Hicks: Who administers the small business loan program?

Louisville Metro Response: MH: The work of the small business loan program administration will be released to the community at large in the form of a Notice of Funding Availability. Any organizations in the community who have experience monitoring these kinds of programs are encouraged to apply. DL anticipates releasing this NOFA on June 1st.

Question from Facebook user Josh Poe: From the proposal, "Each participant would be required to work with a caseworker and attend a budgeting class or meet with a financial coach; participants would be required to meet with the caseworker at least every four (4) weeks during the program to review their budgets and adherence to it. Landlords would have to agree to the structure for a tenant/participant to be able to participate, and all parties would be required to sign a tri-party agreement."

Louisville Metro Response: MH: DL is in the process of clarifying the language of the amendment. The true intention of this financial coaching is to ensure that tenants have a plan to meet the payment requirements, not to

Louisville-Jefferson County Metro Government 214 Appendices - Amendment to the 2019 Action Plan May 21, 2020 require tenants to go through lengthy budgeting classes. Landlords must also agree to the structure in order to be able to participate.

Question from WebEx user Arthur Crosby: Will there be online intake for all of these programs? What kind of documentation will people be required to present?

Louisville Metro Response: MH: DL plans to coordinate with RCS to follow the structure of their existing intake process. Applicants will be required to verify income, and further requirements will be based on requirements from the U.S. Department of Housing and Urban Development.

Question from Facebook user Robin Bray: How are you going to reach landlords?

Louisville Metro Response: MH: DL first plans to work with the Louisville Apartment Association and the Kentucky Landlord Association, and further will reach out to smaller landlords through local measures, including online postings and social media postings on Develop Louisville’s platforms.

Question from Facebook user Josh Poe: The CLT model proposed here seems less about being a movement for community control of land by historically impacted community members and more about providing subsidies to non- profit developers who are not connected to any grassroots organizing efforts. The most important aspect of CLTs is that residents are engaged and in control of the specific needs of their community. The model proposed here does not include any stipulations for resident control, resident leadership, or how community voices will be centered in this process. How are residents being engaged and how are those residents who are directly impacted being centered and given control in this process?

Louisville Metro Response: MH: The Community Land Trust, by definition, is land that is owned by the community. Resident panels and guidance will be built into the model, as well as administrative guidance from an organization. This administrative guidance will come from a local organization to be chosen and determined by a Notice of Funding Availability released in the coming weeks.

Question from Facebook user Kelly Kinahan: Can you clarify which city-owned properties would be transferred into the CLT(s) and what neighborhoods these properties are located in?

Louisville Metro Response: MH: At this time, DL does not know which properties will be transferred. This decision will be made by the Community Land Trust itself, and target areas will be determined once this group is established. Whether these properties will be a scattered site or closely laid out together is still to be determined. The recommendation from the Housing Needs Assessment is that the city transfer

Louisville-Jefferson County Metro Government 215 Appendices - Amendment to the 2019 Action Plan May 21, 2020 any city owned properties that a CLT is interested in, into that land trust, and DL would work with the CLT to ensure as smooth a process as possible with creating and transferring that city owned land.

Question from WebEx user Cathy: Will the city advocate that eviction court and LG&E make the address in a form compatible with census tracts and blocks so that researchers can compare census tract info of various kinds. Currently the best they do is zip codes which is not that useful. I realize this is not the program, but it would be useful for assessing the effectiveness of these programs.

Louisville Metro Response: MH: While Louisville Metro Government does not have authority to require the eviction courts and LG&E to maintain data compatible with census tracts, LMG will certainly advocate for that kind of data collection in its conversations with various agencies.

Question from WebEx user Resolve: Restorative Practices LLC: Who will be administering the "third party agreement"?

Louisville Metro Response: MH: The third-party agreement will be administered by the Office of Resilience and Community Services, as that office will be administering the Eviction Prevention and Stabilization programs.

Question from Facebook user Josh Poe: Why is the eviction prevention program targeting households under 80% AMI, when our greatest housing needs are below 30% AMI?

Louisville Metro Response: MH: Due to such significant economic changes resulting from COVID-19, many families who were previously at 80% of Area Median Income are now at or below 30% AMI. HUD’s program requirements stipulate that these funds go to families at or below 80% AMI. Therefore, so as to keep program opportunities open to as many people as possible who are experiencing COVID-19 related hardships, these proposed programs maintain that 80% AMI threshold.

AB: Furthermore, Louisville Metro Government is working to address the program from several angles. While the CDBG funding that will support the eviction prevention and stabilization programs is targeted toward 80% AMI and below, the Emergency Solutions Grant (ESG) is targeted toward individuals and families at much lower income thresholds. This funding is available to non-profits to design their own programs to assist low income individual.

Question from Facebook user Kelly Kinahan: How is affordability being defined in regards to the CLT proposal?

Louisville-Jefferson County Metro Government 216 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Louisville Metro Response: MH: Per HUD, a unit is considered affordable if a family’s mortgage payment does not exceed 30% of its income. Therefore, through the Community Land Trust model, homes must be sold at a price that would be “affordable” by this definition for a family at 80% of Area Median Income.

Question from Facebook user Robin Bray: Group that has 100's of landlords is Kentuckiana real estate investors Association

Louisville Metro Response: MH: Develop Louisville appreciates the resource, and will utilize several methods to connect with as many landlords as possible.

Louisville-Jefferson County Metro Government 217 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Appendix C

Affidavit and Legal Notice as published in the Courier Journal on May 1, 2020

Louisville-Jefferson County Metro Government 218 Appendices – Amendment to the 2019 Action Plan May 21, 2020 219 220 Appendix D

Amended Citizen Participation Plan, with narrative describing use during CARES Act funding period

Louisville-Jefferson County Metro Government 221 Appendices – Amendment to the 2019 Action Plan May 21, 2020 Citizen Participation

2015 – 2019 Citizen Participation Plan Amendment

The 2015-2019 Citizen Participation Plan has been amended to include provisions for HUD waivers which may vary the public comment period requirements and allow for virtual public meetings. This amended plan can be found in the appendices.

Utilization of Federal Waiver

Pursuant to the memorandum Availability of Waivers of Community Planning and Development Grant Programs and Consolidate Plan Requirements to Prevent the Spread of COVID-19 and Mitigate Economic Impacts Caused by COVID-19, and in accordance with 24 CFR 5.110:

• Citizen Participation Public Comment Period for Consolidated Plan Amendment - 24 CFR 91.105(c)(2) and (k); 24 CFR 91.115(c)(2) and (i); 24 CFR 91.401 • Citizen Participation Reasonable Notice and Opportunity to Comment - 24 CFR 91.105(c)(2) and (k); 24 CFR 91.115(c)(2) and (i); 24 CFR 91.401

Requests for use of these waivers was submitted to the U.S. Department of Housing and Urban Development Kentucky Field Office, Region IV, on April 8, 2020. A copy of the Wavier Request is included in this amendment.

Public Comment Period

This waiver allows Louisville Metro Government to provide a public comment period of no less than 5 days on substantial amendments relating to CARES Act funding. The public comment period for the amendment proposed in this document shall begin on Friday, May 1, 2020, and conclude on Thursday, May 7, 2020.

The public comment period will also include a public meeting, to be held virtually, to receive comments and questions on the proposed amendment. Monday, May 4th – 6:00pm • Join via WebEx Online o Call in: +1-415-655-0001 o Access Code: 476-523-073 o Web Access: Click Here o Meeting Password: 9ayMtBV63GN • Join via Develop Louisville Facebook Live stream Louisville-Jefferson County Metro Government 222 Appendices - Amendment to the 2019 Action Plan May 21, 2020 Per COVID-19 social distancing precautions as mandated by Executive Order 2020-002, these meetings will be held virtually and will be accessible via WebEx videoconference and Facebook Live stream. Information on how to access these meetings can be found at the webpage above. Persons who desire special accommodations, including limited English proficiency or sign language interpretation, may communicate their needs to (502) 574-6230 at least one week prior to these meetings. TDD users please use the Relay Service, 1-800-648-6056.

Louisville-Jefferson County Metro Government 223 Appendices - Amendment to the 2019 Action Plan May 21, 2020 LOUISVILLE METRO GOVERNMENT OFFICE OF HOUSING AND COMMUNITY DEVELOPMENT CITIZEN PARTICIPATION PLAN

To promote citizen participation, emphasizing the involvement of low-to-moderate, very low, and extremely low income residents, Louisville Metro has adopted the following Citizen Participation Plan. The Citizen Participation Plan is designed to give residents the opportunity to engage in the development of goals, strategies, and priorities for the Community Development Block Grant (CDBG), HOME Investment Partnership (HOME), Emergency Solutions Grant (ESG), and Housing Opportunities for Persons with AIDS (HOPWA) programs.

CITIZEN PARTICIPATION ACTIVITIES

Louisville Metro shall utilize a multifaceted approach to obtain citizens’ views. These approaches include, but are not limited to:

1. Public Hearings – A minimum of two public hearings shall be held during the development of the Consolidated Plan or Action Plan. Louisville Metro will utilize various notification methods to inform citizens of the public hearing, as outlined on Page 2. To stimulate the involvement of low, very low, and extremely low income residents, Louisville Metro will send notice of the public hearing to the Louisville Metro Housing Authority (LMHA), at least ten (10) to fourteen (14) days prior to the hearing. It is intended that LMHA will disseminate the information to its residents. Public hearings will be held during the week after 6:00 o’clock P.M. in an architecturally barrier free facility which is convenient to potential and actual beneficiaries. Notice will be made at least ten (10) to fourteen (14) days prior to the event. Included in the notification will be contact information for residents with mobility, visual, or hearing impairments and Limited English Proficient persons, so appropriate accommodations may be made. Recorded copies of the public hearing will be made available for those unable to attend and provisions will be made to accept their written comments.

2. Stakeholder Meetings – Louisville Metro shall engage various service providers and elected officials to aid in the development of the Consolidated Plan or Action Plan. Louisville Metro shall utilize standing meetings of key stakeholders (such as Continuum of Care meetings, board meeting or taskforces) as an opportunity to obtain feedback from these service providers. Particular emphasis will be placed on engaging stakeholder groups which represent low, very low, and extremely low income residents and/or represent predominately low and moderate income neighborhoods and/or represent minority groups (including non-English speaking and persons with disabilities) and/or represent homeless populations. Louisville Metro will announce stakeholder meetings on its website and send notice to community organizations, commissions, coalitions, and boards as well as to the Louisville Metro Housing Authority. Notice will be made at least ten (10) to fourteen (14) days prior to the event. Included in the notification will be contact information for residents with mobility, visual, or hearing impairments and Limited English Proficient persons, so appropriate accommodations may be made.

1 of 6 224 3. Public Comment – Citizens will have the opportunity to provide written comments regarding the proposed Consolidated Plan or Action Plan along with any amendments to the Plan. Citizens will have the opportunity to submit comments through the Louisville Metro website, Louisville Metro social media platforms, and/or via mail.

4. Surveys – Louisville Metro may choose to utilize a survey to obtain feedback from citizens in regards to community needs and funding priorities. Surveys can be administered during public hearings, stakeholder meetings, and/or online accessible from the Louisville Metro website.

NOTIFICATION TECHNIQUES

Louisville Metro may choose to utilize all or some of the notification techniques outlined below to provide citizens with the ability to participate in the citizen engagement process.

1. Legal Advertisement – Louisville Metro may publish notices as a legal advertisement in the Courier-Journal ten (10) to fourteen (14) days prior to the citizen participation activity (which complies with Chapter 424 of the Kentucky Revised Statutes). Contact information will be included in the notice for persons with disabilities or persons who are Limited English Proficient, so appropriate accommodations may be made. Any public hearings held during any phase of the Plan process, outlined on pages 3 to 5, MUST utilize legal advertisements as a means to notify the public.

2. Email Notification – Louisville Metro will make its best effort to inform past participants / attendees of the Consolidated Plan / Action Plan process aware of upcoming citizen participation activities. Louisville Metro will utilize meeting sign in sheets to obtain emails of participants. Louisville Metro can also utilize Metro email publications, such as newsletters and Mayor’s weekly report, to inform the public of citizen participation activities.

3. Metro TV- Louisville Metro can utilize Metro TV in order to inform citizens of citizen participation activities. Louisville Metro can utilize televised standing meetings, such as city council meetings, as an avenue to notify the public. Louisville Metro may choose to televise citizen participation activities as part of the Consolidated Plan / Action Plan process. This is a great method to reach citizens who are unable or unwilling to attend a meeting in person.

4. Website – Louisville Metro will post the Consolidated Plan, Action Plan, Amendments, the Annual Performance Report and this Citizen Participation Plan to the Louisville Metro website. Accommodations will be made to provide these materials to persons with disabilities or persons who are Limited English Proficient who are unable to access them via the Internet or in person at the locations outlined on page 3 – 4. Louisville Metro will also utilize the website to announce upcoming citizen participation activities.

5. Social Media – Louisville Metro can announce citizen participation activities via Louisville Metro social media platforms, such as Facebook and Twitter.

2 of 6 225 CONSOLIDATED/ACTION PLAN PROCESS

1. Community Needs Assessment – The first phase is the community needs assessment, which includes consulting with key stakeholders, service providers, and citizens to review community needs, issues, and strengths prior to preparing the Consolidated Plan or Action Plan. At least one public hearing will be incorporated into the community needs assessment phase to collect the views of citizens, service agencies, and other interested parties on community needs and priorities for addressing those needs. This will also be an opportunity for citizens to review prior program performance and comment publicly. Surveys may also be utilized during the community needs assessment phase to obtain information.

2. Publishing the Proposed Plan – Louisville Metro will take the comments received during the community needs assessment phase into consideration when developing the proposed Consolidated Plan or Action Plan. The Plan will indicate the amount of assistance Louisville Metro anticipates receiving, the range of activities that will be undertaken, including the amount to benefit persons of very low and low income status, and it will outline plans to minimize the displacement of persons, including how it will assist those persons who are displaced. After the proposed Consolidated Plan or Action Plan has been completed, Louisville Metro will prepare a summary of the Plan describing its contents and purpose. This summary will be published as a legal advertisement and will list the locations the proposed Plan may be reviewed in its entirety. In addition, the summary will provide information as to how citizens may submit written comments on the proposed Plan. For citizens to have access to the proposed Consolidated Plan or Action Plan, electronic or paper copies will be available at the main public library and all of its branch offices. Copies will also be available at the offices of Louisville Metro Office of Housing and Community Development (LMHCD), Louisville Metro Department of Community Services, and all Neighborhood Places. Additionally, the proposed Plan will be posted to the Louisville Metro website. Citizens may request a hard copy of the Plan from LMHCD. Free copies of the Plan will be available on a limited basis as citizens have the opportunity to review the Plan through the methods described. Citizens will be informed in the proposed Consolidated Plan or Action Plan of how to submit comments. The date, time, and location of the public hearing on the proposed Plan, as part of the public comment period as described below, will be included in the legal notice published in the Courier-Journal.

3. Public Comment on the Proposed Plan – Once the summary of the proposed Plan has been published and the entire document is available to the public, citizens and interested entities will have a period of not less than thirty (30) days to offer written comments. At least one public hearing will be incorporated into the public comment phase to collect the views of citizens, service agencies, and other interested parties on the proposed Plan. After the period for comment is over, comments received in writing or orally at a public hearing shall be considered in preparing the final Plan. A summary of these comments as well as Louisville Metro’s response to such comments and a summary of any comments not accepted along with the reasons shall be attached to the final Plan. Any complaints relating to the Plan, amendments, or performance reports, either written or verbal, will be substantially responded to within fifteen (15) business days from the receipt of the complaint.

3 of 6 226 4. Adoption and Submission of Plan – Once the final Consolidated Plan or Action Plan has been completed, including the summary of the comments, it will be forwarded to the U.S. Department of Housing and Urban Development. Louisville Metro will utilize at least one of the notification techniques outlined on page 2 announcing the locations where the public may review the final document. Copies will also be available in the offices of the Louisville Metro Office of Housing and Community Development, Louisville Metro Department of Community Services, and all Neighborhood Places. Additionally, the final Consolidated Plan or Action Plan will be posted on the Louisville Metro website linked to the Louisville Metro Office of Housing and Community Development homepage.

5. Amendments to the Plan - Should a substantial change occur in the planned or actual activities, Louisville Metro will formally amend the Consolidated Plan or Action Plan. Louisville Metro will utilize at least one of the citizen engagement activities outlined on pages 1-2 to provide the opportunity for the public to given comments on the amendment. Louisville Metro will utilize at least one of the notification techniques outlined on page 2 to inform the public of the amendment, where the amended Plan may be reviewed, and how to provide comments in regards to the amendment. The proposed amendment will also be posted on the Louisville Metro website. Citizens will have a period of not less than thirty (30) days after the proposed amendment is made available to the public to submit written comments. Louisville Metro will review and take into consideration all comments, views, or complaints before submitting the amended, final Consolidated Plan or Action Plan to the U.S. Department of Housing and Urban Development. Comments, views, or complaints must be submitted in writing, or orally at public hearings. A summary of the comments, views, and complaints will be attached to the amendment submitted to the U.S. Department of Housing and Urban Development along with an explanation of the reasons they were accepted or rejected, if applicable

The criteria Louisville Metro will use to determine what necessitates a substantial amendment are as follows: a. A significant change of project scope resulting in a funding adjustment totaling 30% or more in a program year Action Plan budget for the project; b. A series of changes representing a cumulative total of 20% or more in a program year Action Plan budget; c. The addition of a new activity not previously included in the Consolidated Plan; d. The deletion of an activity previously listed in the Consolidated Plan; e. Changing the location of an activity in such a way that it substantially affects the original scope of the project; or f. Altering the scope of an activity in such a way that it affects the original, intended beneficiaries. Carry-forward funds and funds remaining after a project is completed may be reallocated to another previously approved project without requiring a substantial amendment.

CDBG, ESG, and HOPWA sub-recipients and HOME funded projects will go through a competitive funding process(es). Any groups representing persons of low and moderate incomes

4 of 6 227 may request technical assistance from Louisville Metro to help in their preparation of an application for funding. The method with which to request technical assistance shall be included as part of the request for funding applications. The funding decision making process will also be outlined in the request for funding applications. Once sub-recipients and projects have been approved, Louisville Metro Government will review the list to determine if a technical correction of the information is needed or a substantial amendment is required.

6. Annual Performance Report - Within ninety (90) days of the close of the program year, Louisville Metro will submit a program report in the format prescribed by the U.S. Department of Housing and Urban Development. Prior to the submission to HUD, Louisville Metro will utilize at least one of the citizen engagement activities outlined on pages 1-2 to provide the opportunity for the public to given comments on the annual performance report. Louisville Metro will utilize at least one of the notification techniques outlined on page 2 to inform the public of the report, where the report may be reviewed, and how to provide comments in regards to the report. Citizens will have a period of not less than fifteen (15) days after the report is made available to the public to submit written comments. Louisville Metro will review and take into consideration any written comments, views, or complaints before submitting the report to the U.S. Department of Housing and Urban Development. A summary of the comments, views, and complaints will be attached to the report submitted to HUD.

7. Citizen Participation Plan - Citizens will have the opportunity to comment on this Citizen Participation Plan and any amendments made to this Plan in conjunction with the public comment periods associated with the Consolidated Plan or Action Plan. The Citizen Participation Plan will be available to the public via the Louisville Metro website. Accommodations will be made to provide the Citizen Participation Plan to persons with disabilities or persons who are Limited English Proficient who are unable to access them via the Internet.

MISCELLANEOUS PROVISIONS

Displacement

It is the policy of the Louisville Metro Government to minimize the displacement of persons resulting from programs and projects funded under the Consolidated Plan (CDBG, HOME, ESG, and HOPWA). If displacement occurs because of activities carried out in the Plan, Louisville Metro Government will follow its Residential Anti-displacement and Relocation Assistance Plan (RARAP) which follows the regulations set forth in the Uniform Relocation and Real Property Assistance Act of 1970 and HUD implementing regulations at 24CFR Part 42 and Section 104(d) of the Housing and Community Development Act of 1974 (as amended).

Access to Records

Louisville Metro Government will provide citizens, public agencies, and other interested parties reasonable and timely access to information and records relating to Louisville Metro Government’s Consolidated Plan

5 of 6 228 and Consolidated Plan programs for the prior five (5) year period. Louisville Metro Government reserves the right to charge a fee for copies to recoup the cost of providing the documents.

Emergency Funding

In response to a locally declared disaster, a situation may arise that requires immediate action to relieve emergency conditions in the community. These situations may result from storms or weather, natural disaster, terrorism, violence, or infectious disease. In the event of a disaster or local emergency, the Mayor, as the Chief Executive Officer for the entitlement jurisdiction, has the option to allocate CDBG funds to assist with the recovery effort.

To meet the citizen participation statutory requirements governing these funds, yet be able to act in an expedient manner, the review and comment period for funding received as a result of an emergency situation will be shortened to fifteen (15) days. In the event that such a local disaster or emergency prevents required public meetings from being held in person, virtual public meetings shall be acceptable. Such meetings should follow the same required notification techniques described on pages 2. Effort should be made to provide accommodations for residents with hearing impairments, such as closed captioning.

In all emergency situations, waivers from the U.S. Department of Housing and Urban Development (HUD) may take precedence and may be used to their full capacity to expedite and alleviate requirements for public participation in cases where such processes may delay the release of emergency funds. Record of such waivers should be kept on file and the public should be made aware of their use.

If funds are needed on an emergency basis and adherence to separate comment periods would prevent the giving of assistance during a Presidentially declared disaster, or during a local emergency that has been declared by the Mayor who has proclaimed there is an immediate need for public Action, the combined Notice of Finding of No Significant Impact (FONSI) and Notice of Intent to Request Release of Funds (NOI/RROF) may be disseminated and/or published simultaneously with the submission of the RROF. The combined Notice of FONSI and NOI/RROF shall state that funds are needed on an emergency basis due to a declared disaster and that comment periods have been combined. The Notice shall also invite citizens to submit their comments to both HUD and Louisville Metro Government.

Section 108 Loan Guarantee Program

Applications for assistance filed by Louisville Metro Government or its predecessors, the City of Louisville and Jefferson County, KY, for Section 108 loan guarantee assistance as authorized under HUD regulation 24 CFR Part 570, Subpart M, are subject to the provisions set forth within the Citizen Participation Plan. The citizen participation process for such applications mirrors that for developing or amending a Consolidated Plan or Action Plan and may be included as part of Consolidated Planning process or may be undertaken separately anytime during the program year.

6 of 6 229 7 of 6 230 Appendix E

Wavier Notifications Sent to HUD

Includes:

1. CDBG Waivers

2. ESG Waivers

3. HOPWA Waivers

4. HOME Waivers

Louisville-Jefferson County Metro Government 231 Appendices – Amendment to the 2019 Action Plan May 21, 2020 OFFICE OF HOUSING DEVELOP LOUISVILLE LOUISVILLE, KENTUCKY

GREG FISCHER MARILYN HARRIS MAYOR DIRECTOR

Ms. Renee Ryles U. S. Department of Housing and Urban Development Kentucky Field Office, Region IV 601 West Broadway, Room 110 Louisville, Kentucky 40202

Subject: CARES ACT Flexibility for CDBG Funds

Dear Ms. Ryles:

Pursuant to the Memorandum issued by Mr. John Gibbs, Assistant Secretary for Community Planning and Development on April 9, 2020, specifically the CARES Act Flexibility for CDBG Funds Used to Support Coronavirus Response and plan amendment waiver Louisville-Jefferson County Metro Government (LMG), qualifying under the Title IV of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), issued Disaster Number of DR4459, intends to implement the 5-Day comment period and uncap the percentage of CDBG funding for public services.

LMG is also asking to reserve the right to ask for additional waivers for any statute or regulations that the Secretary administers in connection with the CDBG-CV funds, FY2019 and FY2020 CDBG Funds, if we find that such waivers or alternative requirements are necessary to expedite or facilitate the use of such amounts to prevent, prepare for and respond to coronavirus.

If you have any questions, please do not hesitate to contact me at [email protected] or via the phone at 502-574-3737.

Sincerely,

Marilyn S. Harris Director

Copy: Ms. Anita Bowles Ms. Nicole Hayden

LOUISVILLE FORWARD www.louisvilleky.gov 232 OFFICE OF HOUSING & COMMUNITY DEVELOPMENTDEVELOP LOUISVILLE 444 S. 5TH STREETSUITE 500LOUISVILLE, KY 40202502.574.5850FAX-502.574.6215 233 234 April 8, 2020 Renee Ryles, Acting Director U.S. Department of Housing and Urban Development Louisville Field Office 601 West Broadway, Room 110 Louisville, KY 40202

Re: Availability of Waivers of Community Planning and Development (CPD) Grant Program and Consolidated Plan Requirements to Prevent the Spread of COVID-19 and Mitigate Economic Impacts Caused by COVID-19

Requestor: Tameka Laird, Director, Louisville-Jefferson County Metro Government Office of Resilience and Community Services, (502) 574-3929

Date Grantee Anticipates First Use of Waiver Flexibility: 04/08/2020

List of Waivers the Grantee Will Use: 1. Fair Market Rent for Individual Units and Leasing Costs 2. Program Disability Documentation for Permanent Supportive Housing 3. Limit on Eligible Housing Search and Counseling Service 4. Program Permanent Housing – Rapid Re-housing Monthly Case Management 5. Program Housing Quality Standards (HQS) – Initial Physical Inspection of Unit 6. Program HQS Annual Re-Inspection of Units 7. Program One-year Lease Requirement 8. Citizen Participation Public Comment Period for Consolidated Plan Amendment 9. Citizen Participation Reasonable Notice and Opportunity to Comment 11. Re-evaluations for Homelessness Prevention Assistance 12. Program Housing Stability Case Management 13. Program Restriction of Rental Assistance to Units with Rent at or Below FMR 14. HOPWA – Self-Certification of Income and Credible Information on HIV Status 15. HOPWA – FMR Rent Standard 16. HOPWA – Property Standards for TBRA Waiver 10 is not included because Louisville Metro Government is not the CoC HMIS lead. Thank you,

Tameka Laird, Director Office of Resilience and Community Services

235 OFFICE OF HOUSING DEVELOP LOUISVILLE LOUISVILLE, KENTUCKY

GREG FISCHER MARILYN HARRIS MAYOR DIRECTOR

Ms. Renee Ryles U. S. Department of Housing and Urban Development Kentucky Field Office, Region IV 601 West Broadway, Room 110 Louisville, Kentucky 40202

Subject: Waivers and Suspensions for the HOME Program

Dear Ms. Ryles:

Pursuant to the Memorandums issued by Mr. John Gibbs, Assistant Secretary for Community Planning and Development on April 10, 2020, specifically the Availability of Waivers and Suspension of the HOME Program Requirements in Response to COVID-19 Pandemic Louisville-Jefferson County Metro Government (LMG), qualifying under the Title IV of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), issued Disaster Number of DR4459, intends to implement one or more of the following waivers and suspensions in relation to the HOME Program:

1) 10% Administration and Planning Cap-Limitation on the Use of HOME Funds for Administrative Cost 2) CHDO Set-Aside Requirement-Set-Aside for Community Housing Development Organizations (CHDOs); 3) Limitations of Conditions of CHDO Operating Expense Assistance-Operating Assistance for Community Housing Development Organizations (CHDOs); 4) Matching Contribution Requirement-Reduction of Matching Contribution-Reductions of Matching Contributions; 5) Citizen Participation Reasonable Notice and opportunity to Comment; 6) Income Documentation-Source Documentation for Income Determinations; 7) On-sire Inspections of HOME-assisted Rental Housing- Ongoing Periodic Inspections of HOME- assisted Rental Housing; 8) Annual Inspection of Units Occupied by Recipients of HOME Tenant Based Rental Assistance- Annual Inspections of TBRA Units; 9) Four-Year Project Completion Requirement-Four Year Project Completion Deadline; 10) Nine Month Deadline for Sale of Homebuyer Units-Qualification as Affordable Housing- Homeownership; 11) Use of HOME Funds for Operating Reserve for Troubled HOME Projects; and

LOUISVILLE FORWARD www.louisvilleky.gov TH OFFICE OF HOUSING & COMMUNITY DEVELOPMENT•DEVELOP LOUISVILLE• 444 S. 5 STREET•SUITE 500•LOUISVILLE, KY 40202•502.574.5850•FAX-502.574.6215 236 12) Timeframe for a Participating Jurisdiction Response of Findings of Noncompliance-Corrective Remedial Actions

Regarding the Memorandum Suspension and Waivers to Facilitate Use of HOME-Assisted Tenant Based Rental Assistance (TBRA for Emergency and Short-term Assistance in Response to COVID-19 Pandemic LMG intends to implement one or more of the following waivers and suspensions for its HOME TBRA Program:

1) Consolidated Plan-HOME Certification, Analysis of Local Market Conditions and Citizen Participation; 2) Tenant Selection and Targeted Assistance; 3) Citizen Participation Reasonable Notice and Opportunity to Comment; 4) Rent Reasonableness: 5) Eligible Tenant-based Rental Assistance Costs and Maximum TBRA Subsidy; 6) Term of Rental Assistance Contract; 7) Tenant Protections-Lease; 8) Housing Quality Standards; 9) Annual Inspection of Units Occupied by Recipients of HOME TBRA; and 10) Income Determinations.

Utilization of these waivers and suspensions is appreciated, and will allow LMG to direct these federal dollars to address the immediate housing needs of our community, facilitate urgent housing assistance to our individual and families experiencing financial hardship, and to help prevent the spread of COVID-19

Sincerely,

Marilyn S. Harris Director

Copy: Ms. Anita Bowles Ms. Nicole Hayden

237 Appendix F

Louisville Executive Order 2020-002

Mandating that Public Hearings must be held virtually

Louisville-Jefferson County Metro Government 238 Appendices – Amendment to the 2019 Action Plan May 21, 2020 239 240 241 Louisville-Jefferson County Metro Government 242 Amendment to the 2019 Action Plan May 21, 2020