1. FY 2023-2024 Annual Public Housing Agency (PHA) Plan — Anaheim City Council, March 28, 2023

Streamlined Annual
PHA Plan
(HCV Only PHAs)
U.S. Department of Housing and Urban Development
Office of Public and Indian Housing
OMB No. 2577-0226
Expires 03/31/2024

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

Applicability. The Form HUD-50075-HCV is to be completed annually by HCV-Only PHAs. PHAs that meet the definition of a Standard PHA, Troubled PHA, High Performer PHA, Small PHA, or Qualified PHA do not need to submit this form. Where applicable, separate Annual PHA Plan forms are available for each of these types of PHAs.

Definitions.

(1) High-Performer PHA – A PHA that owns or manages more than 550 combined public housing units and housing choice vouchers, and was designated as a high performer on both the most recent Public Housing Assessment System (PHAS) and Section Eight Management Assessment Program (SEMAP) assessments if administering both programs, or PHAS if only administering public housing. (2) Small PHA - A PHA that is not designated as PHAS or SEMAP troubled, that owns or manages less than 250 public housing units and any number of vouchers where the total combined units exceed 550.
(3) Housing Choice Voucher (HCV) Only PHA - A PHA that administers more than 550 HCVs, was not designated as troubled in its most recent SEMAP assessment and does not own or manage public housing.
(4) Standard PHA - A PHA that owns or manages 250 or more public housing units and any number of vouchers where the total combined units exceed 550, and that was designated as a standard performer in the most recent PHAS and SEMAP assessments. (5) Troubled PHA - A PHA that achieves an overall PHAS or SEMAP score of less than 60 percent. (6) Qualified PHA - A PHA with 550 or fewer public housing dwelling units and/or housing choice vouchers combined and is not PHAS or SEMAP troubled.

PHA Information.

A.1

PHA Name: _Anaheim Housing Authority ________________________________________ PHA Code: _CA104__________ PHA Plan for Fiscal Year Beginning: (MM/YYYY): _07/2023_________ PHA Inventory (Based on Annual Contributions Contract (ACC) units at time of FY beginning, above) Number of Housing Choice Vouchers (HCVs) __6,355_________ PHA Plan Submission Type: Annual Submission Revised Annual Submission

Availability of Information. In addition to the items listed in this form, PHAs must have the elements listed below readily available to the public.

A PHA must identify the specific location(s) where the proposed PHA Plan, PHA Plan Elements, and all information relevant to the public hearing and proposed PHA Plan are available for inspection by the public. Additionally, the PHA must provide information on how the public may reasonably obtain additional information of the PHA policies contained in the standard Annual Plan but excluded from their streamlined submissions. At a minimum, PHAs must post PHA Plans, including updates, at the main office or central office of the PHA. PHAs are strongly encouraged to post complete PHA Plans on their official website.

This PHA Plan and all relevant documentation is available at the Anaheim Housing Authority:
• Office: located at Anaheim City Hall – West Tower, 201 S. Anaheim Blvd., 10th Floor Anaheim, CA 92805 – Available Monday-Friday, between the hours of 8:00 a.m. and 5:00 p.m.; and • Website: www.anaheim.net/1947/Public-Documents

PHA Consortia: (Check box if submitting a joint Plan and complete table below) Participating PHAs PHA Code Program(s) in the Consortia Program(s) not in the Consortia No. of Units in Each Program
Lead HA:

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B. Plan Elements.

B.1
Revision of Existing PHA Plan Elements.
a
) H
ave the following PHA Plan elements been revised by the PHA since its last Annual Plan submission? Y N
Statement of Housing Needs and Strategy for Addressing Housing Needs.

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

Financial Resources.

Rent Determination.

Operation and Management.

Informal Review and Hearing Procedures.

Homeownership Programs.

Self Sufficiency Programs and Treatment of Income Changes Resulting from Welfare Program Requirements.

Substantial Deviation.

Significant Amendment/Modification.
(
b) I
f the PHA answered yes for any element, describe the revisions for each element(s):

Please see the following attachments:

Attachment 1 – Summary of Revisions to the Administrative Plan and Significant Amendment/Modification Attachment 2 – Deconcentration and Other Policies that Govern Eligibility, Selection, & Admissions Policies Attachment 3 – Financial Resources Table
Attachment 4 – Rent Determination Policies
Attachment 5 – Informal Review and Hearing Procedures
Attachment 5 – Self Sufficiency Programs
B.2 New Activities. – Not Applicable
B.3 Progress Report.

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

Please see Attachment 7 – Progress Report
B.4 Capital Improvements. – Not Applicable
B.5 Most Recent Fiscal Year Audit.
(a
) Were there any findings in the most recent FY Audit?
Y N
N/A
The AHA did not have any no findings in the FY 20-21 audit. FY 21-22 results pending. (b
) If yes, please describe:

C. Other Document and/or Certification Requirements.

C.1 Resident Advisory Board (RAB) Comments.
(a
) Did the RAB(s) have comments to the PHA Plan?
Y
N
Please see below
(b
) If yes, comments must be submitted by the PHA as an attachment to the PHA Plan. PHAs must also include a narrative describing their analysis of the RAB recommendations and the decisions made on these recommendations.

A
ttachment 8 of tshis Plan will be updated with the RAB member comments after the RAB meeting takes place.

C.2 Certification by State or Local Officials.

F
orm HUD 50077-SL, C ertification by State or Local Officials of PHA Plans Consistency with the Consolidated Plan , must be submitted by the PHA as an electronic attachment to the PHA Plan.

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C.3

Civil Rights Certification/ Certification Listing Policies and Programs that the PHA has Revised since Submission of its Last Annual Plan.

Form HUD-50077-ST-HCV-HP, PHA Certifications of Compliance with PHA Plan, Civil Rights, and Related Laws and Regulations Including PHA Plan Elements that Have Changed, must be submitted by the PHA as an electronic attachment to the PHA Plan.

C.4
Challenged Elements. If any element of the PHA Plan is challenged, a PHA must include such information as an attachment with a description of any challenges to Plan elements, the source of the challenge, and the PHA’s response to the public. (a) Did the public challenge any elements of the Plan?

Y N

If yes, include Challenged Elements.

This Plan is currently available for public comment from Monday January 9, 2023 through February 23, 2023.

Attachment 9 of this Plan will be continuously updated if any section is challenged during that time.

Affirmatively Furthering Fair Housing (AFFH).

D.1

Affirmatively Furthering Fair Housing (AFFH).

Provide a statement of the PHA’s strategies and actions to achieve fair housing goals outlined in an accepted Assessment of Fair Housing (AFH) consistent with 24 CFR § 5.154(d)(5). Use the chart provided below. (PHAs should add as many goals as necessary to overcome fair housing issues and contributing factors.) Until such time as the PHA is required to submit an AFH, the PHA is not obligated to complete this chart. The PHA will fulfill, nevertheless, the requirements at 24 CFR § 903.7(o) enacted prior to August 17, 2015. See Instructions for further detail on completing this item.

On August 6th, 2020, a consortium of more than 20 Orange County, CA cities released the Orange County’s Analysis of Impediments to Fair Housing Choice (AI). The AI is a thorough examination of structural barriers to fair housing choice and access to opportunity for members of historically marginalized groups protected from discrimination by the federal Fair Housing Act (FHA). The AI also outlines fair housing priorities and goals to overcome fair housing issues and lays out meaningful strategies that can be implemented to achieve progress towards the County’s obligation to affirmatively furthering fair housing.

The complete AI may be accessed through the following website:
http://www.anaheim.net/DocumentCenter/View/39608/Regional-AI_Final

Fair Housing Goal: 1. Increase the supply of affordable housing through the following strategies:

Describe fair housing strategies and actions to achieve the goal

The AHA’s housing strategies and actions:
a. Explore creative land use and zoning policies that facilitate the development of affordable housing, examples include a housing overlay zone or religious institutions amendment. b. Review Anaheim’s current Density Bonus and Accessory Dwelling Unit (ADU) Ordinances to ensure compliance with state requirements.
c. Support legislation that removes CEQA requirements for affordable housing. d. I dentify and explore allocating city-owned sites that may be well suited for housing for which there are no other development plans.
e. Continue to support tenant based rental assistance programs that facilitates additional affordable housing for homeless and low-income individuals.

Fair Housing Goal: 2. Preserve the existing stock of affordable rental housing and rent stabilized housing through the following strategies:

Describe fair housing strategies and actions to achieve the goal

The AHA’s housing strategies and actions:
a. Strengthen and expand education and outreach of tenants and owner of affordable rental housing at risk of conversion to market rents.
b. Extend affordability restrictions through loan extensions, workouts and buy-downs of affordability. c. Preserve at-risk housing through the issuance of Tax-Exempt Bond financing. d. Explore the development of a rental rehabilitation loan program.

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Fair Housing Goal:3. Expand the access to fair housing services and other housing services through the following strategies:

Describe fair housing strategies and actions to achieve the goal

The AHA’s housing strategies and actions:
a. Dedicate eligible entitlement dollars (CDBG, HOME, etc.) and explore local, state and federal resources to expand fair housing services.
b. Continue to support fair housing testing and investigation to look for evidence of differential treatment and disparate impact, including providing services to low income tenants reporting fair housing violations. c. Continue to support fair housing presentations, mass media communications, and multi-lingual literature distribution; conduct fair housing presentations at accessible locations and conduct fair housing presentations for housing providers.
d. Explore alternative formats for fair housing education workshops such as pre-taped videos and/ or recordings. Such formats could serve persons with one or more than one job, families with you children and other who find it difficult to attend meetings in person.

In addition,
• The City has allocated CDBG funds to the Fair Housing Foundation (FHF) to provide fair housing services to the Anaheim residents and operators of rental properties. These services include holding tenant and landlord workshops, counseling, and resolving any housing issues and allegations of discrimination . • In June of 2018, the City's Planning and Building Department amended its fee schedule and removed the reasonable accommodations application fee
• In June of 2018, the City's Planning and Building Department amended its fee schedule and removed the reasonable accommodations application fee

Fair Housing Goal: 4. Continue efforts to build complete communities through the following strategies:

Describe fair housing strategies and actions to achieve the goal

The AHA’s housing strategies and actions:
a. Maximize and secure funding from State of California’s Cap and Trade Program (Greenhouse Gas Reduction Fund), to improve housing opportunities, increase economic investments and address environmental factors in disadvantaged communities.
b. The City will continue to work with local transit agencies and other appropriate agencies to facilitate safe and efficient routes of transportation, including public transit, walking and biking. c. Explore development of a policy to encourage developers to provide residents with incentives to use non- auto means of transportation, including locating new developments near public transportation and providing benefits such as bus passes.
d. Prioritize workforce development resources in racially or ethnically concentrated areas of poverty to improve economic mobility

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Instructions for Preparation of Form HUD-50075-HCV
Annual PHA Plan for HCV-Only PHAs
___________________________________________________________________________

A. PHA Information. All PHAs must complete this section. (24 CFR §903.4)

A.1 Include the full PHA Name, PHA Code, PHA Type, PHA Fiscal Year Beginning (MM/YYYY), Number of Housing Choice Vouchers (HCVs), PHA Plan Submission Type, and the Availability of Information, specific location(s) of all information relevant to the public hearing and proposed PHA Plan.

PHA Consortia: Check box if submitting a Joint PHA Plan and complete the table. (24 CFR §943.128(a))

B. Plan Elements. All PHAs must complete this section. (24 CFR §903.11(c)(3) )

B.1 Revision of Existing PHA Plan Elements. PHAs must:

Identify specifically which plan elements listed below that have been revised by the PHA. To specify which elements have been revised, mark the “yes” box. If an element has not been revised, mark “no."

Statement of Housing Needs and Strategy for Addressing Housing Needs. Provide a statement addressing the housing needs of low-income, very low-income and extremely low-income families and a brief description of the PHA’s strategy for addressing the housing needs of families who reside in the jurisdiction served by the PHA and other families who are on the Section 8 tenant-based assistance waiting lists. The statement must identify the housing needs of (i) families with incomes below 30 percent of area median income (extremely low-income); (ii) elderly families (iii) households with individuals with disabilities, and households of various races and ethnic groups residing in the jurisdiction or on the public housing and Section 8 tenant- based assistance waiting lists. The statement of housing needs shall be based on information provided by the applicable Consolidated Plan, information provided by HUD, and generally available data. The identification of housing needs must address issues of affordability, supply, quality, accessibility, size of units, and location. Once the PHA has submitted an Assessment of Fair Housing (AFH), which includes an assessment of disproportionate housing needs in accordance with 24 CFR 5.154(d)(2)(iv), information on households with individuals with disabilities and households of various races and ethnic groups residing in the jurisdiction or on the waiting lists no longer needs to be included in the Statement of Housing Needs and Strategy for Addressing Housing Needs. (24 CFR § 903.7(a)).

The identification of housing needs must address issues of affordability, supply, quality, accessibility, size of units, and location. (24 CFR §903.7(a)(2) (i))
Provide a description of the ways in which the PHA intends, to the maximum extent practicable, to address those housing needs in the upcoming year and the PHA’s reasons for choosing its strategy. (24 CFR §903.7(a)(2)(ii))

Deconcentration and Other Policies that Govern Eligibility, Selection, and Admissions. A statement of the PHA’s policies that govern resident or tenant eligibility, selection and admission including admission preferences for HCV. (24 CFR §903.7(b))

Financial Resources. A statement of financial resources, including a listing by general categories, of the PHA’s anticipated resources, such as PHA HCV funding and other anticipated Federal resources available to the PHA, as well as tenant rents and other income available to support tenant-based assistance. The statement also should include the non-Federal sources of funds supporting each Federal program, and state the planned use for the resources. (24 CFR §903.7(c))

Rent Determination. A statement of the policies of the PHA governing rental contributions of families receiving tenant-based assistance, discretionary minimum tenant rents, and payment standard policies. (24 CFR §903.7(d))

Operation and Management. A statement that includes a description of PHA management organization, and a listing of the programs administered by the PHA. (24 CFR §903.7(e)).

Informal Review and Hearing Procedures. A description of the informal hearing and review procedures that the PHA makes available to its applicants. (24 CFR §903.7(f))

Homeownership Programs. A statement describing any homeownership programs (including project number and unit count) administered by the agency under section 8y of the 1937 Act, or for which the PHA has applied or will apply for approval. (24 CFR §903.7(k))

Self Sufficiency Programs and Treatment of Income Changes Resulting from Welfare Program Requirements. A description of any PHA programs relating to services and amenities coordinated, promoted, or provided by the PHA for assisted families, including those resulting from the PHA’s partnership with other entities, for the enhancement of the economic and social self-sufficiency of assisted families, including programs provided or offered as a result of the PHA’s partnerships with other entities, and activities subject to Section 3 of the Housing and Community Development Act of 1968 (24 CFR Part 135) and under requirements for the Family Self-Sufficiency Program and others. Include the program’s size (including required and actual size of the FSS program) and means of allocating assistance to households. (24 CFR §903.7(l)(i)) Describe how the PHA will comply with the requirements of section 12(c) and (d) of the 1937 Act that relate to treatment of income changes resulting from welfare program requirements. (24 CFR §903.7(l)(iii)).

Substantial Deviation. PHA must provide its criteria for determining a “substantial deviation” to its 5-Year Plan. (24 CFR §903.7(r)(2)(i))

Significant Amendment/Modification. PHA must provide its criteria for determining a “Significant Amendment or Modification” to its 5-Year and Annual Plan.

If any boxes are marked “yes”, describe the revision(s) to those element(s) in the space provided.

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B.2 New Activities. This section refers to new capital activities which is not applicable for HCV-Only PHAs.

B.3 Progress Report. For all Annual Plans following submission of the first Annual Plan, a PHA must include a brief statement of the PHA’s progress in meeting the mission and goals described in the 5-Year PHA Plan. (24 CFR §903.11(c)(3), 24 CFR §903.7(r)(1) )

B.4 Capital Improvements. This section refers to PHAs that receive funding from the Capital Fund Program (CFP) which is not applicable for HCV-Only PHAs

B.5 Most Recent Fiscal Year Audit. If the results of the most recent fiscal year audit for the PHA included any findings, mark “yes” and describe those findings in the space provided. (24 CFR §903.7(p)
)

C. Other Document and/or Certification Requirements.

C.1 Resident Advisory Board (RAB) comments. If the RAB had comments on the annual plan, mark “yes,” submit the comments as an attachment to the Plan and describe the analysis of the comments and the PHA’s decision made on these recommendations. (24 CFR §903.13(c), 24 CFR §903.19 )

C.2 Certification by State of Local Officials. Form HUD-50077-SL, Certification by State or Local Officials of PHA Plans Consistency with the Consolidated Plan, must be submitted by the PHA as an electronic attachment to the PHA Plan. (24 CFR §903.15). Note: A PHA may request to change its fiscal year to better coordinate its planning with planning done under the Consolidated Plan process by State or local officials as applicable.

C.3 Civil Rights Certification/ Certification Listing Policies and Programs that the PHA has Revised since Submission of its Last Annual Plan. Provide a certification that the following plan elements have been revised, provided to the RAB for comment before implementation, approved by the PHA board, and made available for review and inspection by the public. This requirement is satisfied by completing and submitting form HUD-50077 ST-HCV-HP, PHA Certifications of Compliance with PHA Plan, Civil Rights, and Related Laws and Regulations Including PHA Plan Elements that Have Changed.

Form HUD-50077-ST-HCV-HP, PHA Certifications of Compliance with PHA Plan, Civil Rights, and Related Laws and Regulations Including PHA Plan Elements that Have Changed must be submitted by the PHA as an electronic attachment to the PHA Plan. This includes all certifications relating to Civil Rights and related regulations. A PHA will be considered in compliance with the certification requirement to affirmatively further fair housing if the PHA fulfills the requirements of §§ 903.7(o)(1) and 903.15(d) and: (i) examines its programs or proposed programs; (ii) identifies any fair housing issues and contributing factors within those programs, in accordance with 24 CFR 5.154; or 24 CFR 5.160(a)(3) as applicable (iii) specifies actions and strategies designed to address contributing factors, related fair housing issues, and goals in the applicable Assessment of Fair Housing consistent with 24 CFR 5.154 in a reasonable manner in view of the resources available; (iv) works with jurisdictions to implement any of the jurisdiction's initiatives to affirmatively further fair housing that require the PHA's involvement; (v) operates programs in a manner consistent with any applicable consolidated plan under 24 CFR part 91, and with any order or agreement, to comply with the authorities specified in paragraph (o)(1) of this section; (vi) complies with any contribution or consultation requirement with respect to any applicable AFH, in accordance with 24 CFR 5.150 through 5.180; (vii) maintains records reflecting these analyses, actions, and the results of these actions; and (viii) takes steps acceptable to HUD to remedy known fair housing or civil rights violations. impediments to fair housing choice within those programs; addresses those impediments in a reasonable fashion in view of the resources available; works with the local jurisdiction to implement any of the jurisdiction’s initiatives to affirmatively further fair housing; and assures that the annual plan is consistent with any applicable Consolidated Plan for its jurisdiction. (24 CFR §903.7(o)).

C.4 Challenged Elements. If any element of the Annual PHA Plan or 5-Year PHA Plan is challenged, a PHA must include such information as an attachment to the Annual PHA Plan or 5-Year PHA Plan with a description of any challenges to Plan elements, the source of the challenge, and the PHA’s response to the public.

D. Affirmatively Furthering Fair Housing (AFFH).

D.1 Affirmatively Furthering Fair Housing. The PHA will use the answer blocks in item D.1 to provide a statement of its strategies and actions to implement each fair housing goal outlined in its accepted Assessment of Fair Housing (AFH) consistent with 24 CFR § 5.154(d)(5) that states, in relevant part: “To implement goals and priorities in an AFH, strategies and actions shall be included in program participants' … PHA Plans (including any plans incorporated therein) …. Strategies and actions must affirmatively further fair housing ….” Use the chart provided to specify each fair housing goal from the PHA’s AFH for which the PHA is the responsible program participant – whether the AFH was prepared solely by the PHA, jointly with one or more other PHAs, or in collaboration with a state or local jurisdiction – and specify the fair housing strategies and actions to be implemented by the PHA during the period covered by this PHA Plan. If there are more than three fair housing goals, add answer blocks as necessary.

Until such time as the PHA is required to submit an AFH, the PHA will not have to complete section D., nevertheless, the PHA will address its obligation to affirmatively further fair housing in part by fulfilling the requirements at 24 CFR 903.7(o)(3) enacted prior to August 17, 2015, which means that it examines its own programs or proposed programs; identifies any impediments to fair housing choice within those programs; addresses those impediments in a reasonable fashion in view of the resources available; works with local jurisdictions to implement any of the jurisdiction’s initiatives to affirmatively further fair housing that require the PHA’s involvement; and maintain records reflecting these analyses and actions. Furthermore, under Section 5A(d)(15) of the U.S. Housing Act of 1937, as amended, a PHA must submit a civil rights certification with its Annual PHA Plan, which is described at 24 CFR 903.7(o)(1) except for qualified PHAs who submit the Form HUD-50077-CR as a standalone document.

This information collection is authorized by Section 511 of the Quality Housing and Work Responsibility Act, which added a new section 5A to the U.S. Housing Act of 1937, as amended, which introduced the Annual PHA Plan. The Annual PHA Plan provides a ready source for interested parties to locate basic PHA policies, rules, and requirements concerning the PHA’s operations, programs, and services, and informs HUD, families served by the PHA, and member s of the public for serving the needs of low- income, very low- income, and extremely low- income families.

Public reporting burden for this information collection is estimated to average 6.02 hour per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. HUD may not collect this information, and respondents are not required to complete this form, unless it displays a cur rently valid OMB Control Number.

Privacy Act Notice. The United States Department of Housing and Urban Development is authorized to solicit the information requested in this form by virtue of Title 12, U.S. Code, Section 1701 et seq., and regulations promulgated thereunder at Title 12, Code of Federal Regulations. Responses to the collection of information are required to obtain a benefit or to retain a benefit. The information requested does not lend itself to confidentiality ATTACHMENT 1 Page 1 of 19

B.1 Revision of the PHA Plan Elements

Summary of Revisions to the FY 2023-2024 Section 8 Housing Choice Voucher Administrative Plan

The Anaheim Housing Authority (AHA) is required to maintain an Administrative Plan (Plan) that details the policies and procedures governing how its Section 8 Housing Choice Voucher (HCV) program will be administered. Since the last revisions that went into effect in 2022, some sections of the Plan are currently being updated with new or modified policies.

This attachment reflects the revisions made to the Administrative Plan regarding the Section 8 HCV, Project-Based Voucher (PBV), and special purpose voucher programs. Summaries of the changes being made are listed below. For your reference, the revisions are listed under “Modified Language.”

Significant Amendment/Modification
In the FY 2020-24 Five Year PHA Plan, the AHA defined a significant amendment or modification to the PHA Plan is as a change in program policy including changes to rent, admissions policies, and organization of the waiting list or terminations. Exceptions to this definition will be made for changes that are adopted to reflect changes in U.S. Department of Housing and Urban Development (HUD) regulatory requirements or if such changes are adopted in response to a significant reduction in funding.

ATTACHMENT 1 Page 2 of 19

B.1 Revision of the PHA Plan Elements

CHAPTER 3: ELIGIBILITY
Chapter Section: 3-I.N. LIVE-IN AIDE
Subsection (if any): n/a
Description of Change:

Under current PHA policy, a family is required to request AHA approval to add a live-in aide to their household. The PHA would like to amend its existing policy to clarify live-in aide must be someone that would not otherwise be living in the unit except to provide the necessary supportive services to the disabled individual. The PHA would also like to clarify that marriages or filing domestic partnerships must be reported within 10 business days in order to change the live-in aide’s relationship status to spouse or cohead.

PROPOSED PHA ADMIN PLAN LANGUAGE:

In addition, the family and live-in aide will be required to submit a certification stating that the live-in aide (1) is not obligated for the support of the person(s) needing the care, (2) would not be living in the unit except to provide the necessary supportive services, (3) and understands they do not have any right to the voucher.

Under limited circumstances, a relative, except for a spouse or registered domestic partner, may be approved to be a live-in aide but they must meet all the stipulations in the live-in aide definition described above. In particular, a relative who previously was living in the unit and wants to become a live-in aide must provide documentation that they would not be living in the unit except to provide the necessary supportive services and is not obligated for the support of the persons. Additionally, the previous

PREVIOUS PHA ADMIN PLAN LANGUAGE:

PHA Policy
A family’s request for a live-in aide must be made in writing. Written verification will be required from a reliable, knowledgeable professional, such as a doctor, social worker, or case worker, that the live-in aide is essential for the care and well-being of the elderly, near-elderly, or disabled family member. In addition, the family and live-in aide will be required to submit a certification stating that the live-in aide (1) is not obligated for the support of the person(s) needing the care, (2) would not be living in the unit except to provide the necessary supportive services, (3) and understands they do not have any right to the voucher.

The PHA will not approve a particular person as a live-in aide, and may withdraw such approval if [24 CFR 982.316(b)]:

The person commits fraud, bribery or any other corrupt or criminal act in connection with any federal housing program; The person commits drug-related criminal activity or violent criminal activity; or
The person currently owes rent or other amounts to the PHA or to another PHA in connection with Section 8 or public housing assistance under the 1937 Act.

ATTACHMENT 1 Page 3 of 19

B.1 Revision of the PHA Plan Elements

household member must have been residing elsewhere for at least twelve (12) months prior to being added to the household as a live-in aide. By definition, a current household member is not eligible to become a live-in aide.

A live-in aide may not become a member of the participant household unless a live-in aide marries, or files for a domestic partnership in the state of California with, the participant. At which time, the live-in aide will be given ten (10) business days to report the change to the PHA in order to be added to the household as a spouse or cohead. If the marriage or formal domestic partnership is not reported to the PHA within ten (10) business days, the family may be terminated.

An individual classified by the PHA as a live-in aide or guest when the sole family member passes away or vacates the unit is not entitled to the housing assistance voucher as a remaining member of the tenant family.

The PHA will not approve a particular person as a live-in aide, and may withdraw such approval if [24 CFR 982.316(b)]:

The person commits fraud, bribery or any other corrupt or criminal act in connection with any federal housing program;
The person commits drug-related criminal activity or violent criminal activity; or
The person currently owes rent or other amounts to the PHA or to another PHA in connection with Section 8 or public housing assistance under the 1937 Act.

Within 10 business days of receiving a request for a live-in aide, including all required documentation related to the request, the PHA will notify the family of its decision in writing.

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B.1 Revision of the PHA Plan Elements

CHAPTER 3: ELIGIBILITY
Chapter Section: 3-III.C. Other Permitted Reasons for Denial of Assistance Subsection (if any): Criminal Activity [24 CFR 982.553] Description of Change:

On June 10, 2022, HUD released the Implementation of the Office of General Counsel’s Guidance on Application of Fair Housing Act Standards to the Use of Criminal Records by Providers of Housing and Real Estate-Related Transactions Memorandum (“Memorandum”). The Memorandum provided recommendations on best practices for conducting investigations relating to criminal background screening information on applicants or tenants to prevent any violations of the Fair Housing Act. The PHA would like to amend its current policy to align with the best practices and suggestions stated in the Memorandum as its best effort to provide remove daunting barriers that individuals with a criminal history consistently face in obtaining and maintaining housing.

PROPOSED PHA ADMIN PLAN LANGUAGE:

HUD permits, but does not require, the PHA to deny assistance if the PHA determines that any household member is currently engaged in, or has engaged in during a reasonable time before the family would receive assistance, certain types of criminal activity.

PHA Policy
[…]
Evidence of such criminal activity includes, but is not limited to the following, during the respective lookback periods:

Criminal convictions
Police reports or witness statements
Any record of eviction from public or privately-owned
housing as a result of criminal activity

Completion of Parole/Probation - any adult family member convicted of a drug related, violent, and/or other applicable criminal activity within the defined lookback period, prior to the date of eligibility determination, must have completed all the terms

PREVIOUS PHA ADMIN PLAN LANGUAGE:

PHA Policy
[…]
Evidence of such criminal activity includes, but is not limited to the following, during the respective lookback periods:

Criminal convictions
Police reports or witness statements
Any record of eviction from public or privately-owned
housing as a result of criminal activity

B.1 Revision of the PHA Plan Elements

of any related sentence including completion of parole and/or probation to be eligible for admission. However, if by public record or other preponderance of evidence, a family member has completed the parole or probation terms, but appears to be currently engaged in other criminal activity, within the last twenty four months prior to determination of eligibility, the PHA may deny admission.

In making its decision to deny assistance, the PHA will consider the factors discussed in Section 3-III.E. Upon consideration of such factors, the PHA may, on a case-by-case basis, decide not to deny assistance.

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B.1 Revision of the PHA Plan Elements

CHAPTER 3: ELIGIBILITY
Chapter Section: 3-III.E. Criteria for Deciding to Deny Assistance Subsection (if any): Consideration of Circumstances [24 CFR 982.552(c)(2)] Description of Change:

On June 10, 2022, HUD released the Implementation of the Office of General Counsel’s Guidance on Application of Fair Housing Act Standards to the Use of Criminal Records by Providers of Housing and Real Estate-Related Transactions Memorandum (“Memorandum”). The Memorandum provided recommendations on best practices for conducting investigations relating to criminal background screening information on applicants or tenants to prevent any violations of the Fair Housing Act. The PHA would like to amend its current policy to align with the best practices and suggestions stated of the Memorandum as its best effort to provide remove daunting barriers that individuals with a criminal history consistently face in obtaining and maintaining housing.

PROPOSED PHA ADMIN PLAN LANGUAGE:

3-III.E. Criteria for Deciding to Deny Assistance
Consideration of Circumstances [24 CFR 982.552(c)(2) and PIH 2015-19]
HUD authorizes the PHA to consider all relevant circumstances when deciding whether to deny assistance based on a family’s past history except in the situations for which denial of assistance is mandated (see Section 3- III.B).

Policies or practices that deny housing based on an accurate record of convictions that indicate a demonstrable risk to resident safety and/or property may serve substantial, legitimate, nondiscriminatory interests (Implementation of the Office of General Counsel’s Guidance on Application of Fair Housing Act Standards to the Use of Criminal Records by Providers of Housing and Real Estate-Related Transactions Memorandum (June 10, 2022)).

PROPOSED PHA ADMIN PLAN LANGUAGE:

3-III.E. Criteria for Deciding to Deny Assistance
Consideration of Circumstances [24 CFR 982.552(c)(2)]
HUD authorizes the PHA to consider all relevant circumstances when deciding whether to deny assistance based on a family’s past history except in the situations for which denial of assistance is mandated (see Section 3- III.B).

PHA Policy
The PHA will consider the following factors prior to making its decision:

The seriousness of the case, especially with respect to how it would affect other residents
The extent of participation or culpability of individual family members, including whether the culpable family
member is a minor or a person with disabilities, or (as ATTACHMENT 1 Page 7 of 19

B.1 Revision of the PHA Plan Elements

PHA Policy
The PHA will consider the following factors prior to making its decision:

The nature and the seriousness severity of the case,
especially with respect to how it would affect other
residents
The extent of participation or culpability of individual family members, including whether the culpable family
member is a minor or a person with disabilities, or (as discussed further in section 3-III.G) a victim of domestic violence, dating violence, sexual assault or stalking
The length of time since the violation occurred, the
family’s recent history and the likelihood of favorable conduct in the future
In the case of drug or alcohol abuse, whether the culpable household member is participating in or has successfully completed a supervised drug or alcohol rehabilitation
program or has otherwise been rehabilitated successfully The PHA will require the applicant to submit
evidence of the household member’s current
participation in or successful completion of a
supervised drug or alcohol rehabilitation program,
or evidence of otherwise having been rehabilitated
successfully.

Before making an adverse decision related to an
applicant’s or participant’s criminal involvement, the PHA will provide the applicant or participant with the criminal record, indicate which specific part of the record may form the basis of an adverse decision, and give the applicant or tenant the opportunity to correct inaccurate information or explain extenuating circumstances related to that record. discussed further in section 3-III.G) a victim of domestic violence, dating violence, sexual assault or stalking
The length of time since the violation occurred, the
family’s recent history and the likelihood of favorable conduct in the future
In the case of drug or alcohol abuse, whether the culpable household member is participating in or has successfully completed a supervised drug or alcohol rehabilitation
program or has otherwise been rehabilitated successfully The PHA will require the applicant to submit evidence of the household member’s current participation in or
successful completion of a supervised drug or alcohol
rehabilitation program, or evidence of otherwise having been rehabilitated successfully.

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The PHA will conduct an individualized review that
considers relevant mitigating information beyond that
contained in an individual’s criminal record,
Relevant individualized evidence includes, but is not
limited, to the following, during the respective lookback periods:

The facts or circumstances surrounding the
criminal conduct
Whether the applicant’s offense bears a
relationship to the safety and security of other
residents
The age of the individual at the time of the conduct
How long ago the criminal conduct occurred
The number of convictions that appear on the
applicant’s criminal history
Evidence that the individual has maintained a good
tenant history before and/or after the conviction or
conduct
Evidence of rehabilitation efforts that the applicant
has undertaken since the time of conviction. If the
applicant is now in recovery for an addiction,
whether the applicant was under the influence of
alcohol or illegal drugs at the time of the offense
Criminal convictions
Police reports or witness statements
Any record of eviction from public or privately-
owned housing as a result of criminal activity
The PHA will consider all of the factors listed above in order to determine whether the individual threatens the safety, or right to peaceful enjoyment of the premises by other residents or persons residing in the immediate vicinity.

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B.1 Revision of the PHA Plan Elements

CHAPTER 4: APPLICATIONS, WAITING LIST AND TENANT SELECTION CHAPTER 5: BRIEFINGS AND VOUCHER ISSUANCE
CHAPTER 11: REEXAMINATIONS
Subsections (if any):
4-II.F. Reporting Changes in Family Circumstances
5-I.B. Briefing [24 CFR 982.301]
11-I.B. Scheduling Regular Reexaminations
Description of Change:

The PHA requires that all applicants and program participants provide the agency with their current address at all times so that AHA can notify them of information pertaining to their rental assistance. Otherwise, they are removed from the waiting list or terminated from the program (as applicable). These policies will stay in effect. The AHA would only like to modify the existing language so that they all contain uniform language.

PROPOSED PHA ADMIN PLAN LANGUAGE:
4-II.F. Reporting Changes in Family Circumstances
PHA Policy
[…]
The PHA uses the current mailing address to send notification when there are openings in the program. When mail is returned by the post office, the applicant’s name will be removed from the waiting list. A notice of denial (see Chapter 3) will not be sent to the family’s address of record as the address on record is will no longer be considered valid.

PREVIOUS PHA ADMIN PLAN LANGUAGE:
4-II.F. Reporting Changes in Family Circumstances
PHA Policy
[…]
The PHA uses the current mailing address to send notification when there are openings in the program. When mail is returned by the post office, the applicant’s name will be removed from the waiting list.

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B.1 Revision of the PHA Plan Elements

5-I.B. Briefing [24 CFR 982.301]
[…]
Notification and Attendance
PHA Policy
[…]
If the notice is returned by the post office, the family will be removed from the waiting list. A notice of denial (see Chapter 3) will not be sent to the family’s address of record as the address on record is will no longer be considered valid.
a notice of denial (see Chapter 3) will be sent to the family’s address of record. The PHA may also send a notice to an alternate address if provided on the initial application.

11-I.B. Scheduling Regular Reexaminations [24 CFR 982.516] […]
Notification of and Participation in the Regular Reexamination Process […]
PHA Policy
[…]
If a family fails to attend or respond to two scheduled interviews appointmentswithout PHA approval without prior notification to the PHA, the family may be terminated from the program in accordance with Chapter 12 of this Plan. A notice of termination (see Chapter 12) will be sent to the family’s address of record.

If correspondence to the family , or if the notice is returned by the post office and the PHA cannot verify they are in the unit, the PHA

5-I.B. Briefing [24 CFR 982.301]
[…]
Notification and Attendance
PHA Policy
[…]
If the notice is returned by the post office, a notice of denial (see Chapter 3) will be sent to the family’s address of record. The PHA may also send a notice to an alternate address if provided on the initial application.

11-I.B. Scheduling Regular Reexaminations [24 CFR 982.516] […]
Notification of and Participation in the Regular Reexamination Process […]
PHA Policy
[…]
If a family fails to attend two scheduled interviews without PHA approval , or if the notice is returned by the post office, a notice of termination (see Chapter 12) will be sent to the family’s address of record, and to any alternate address provided in the family’s file.

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B.1 Revision of the PHA Plan Elements

may propose termination in accordance with Chapter 12.I. of this Plan.
, a notice of termination (see Chapter 12) will be sent to the family’s address of record, and to any alternate address provided in the family’s file.

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B.1 Revision of the PHA Plan Elements

CHAPTER 5 | BRIEFINGS AND VOUCHER ISSUANCE
Chapter Section: 5-I.B. Briefing [24 CFR 982.301]
Subsection (if an): n/a
Description of Change:

When a family is admitted into the HCV program, the PHA must give the family an oral briefing and provide the family with a briefing packet containing written information about the program. The PHA would like to clarify the steps that it currently takes in order to ensure effective communication with disabled and LEP individuals.

PHA ADMIN PLAN LANGUAGE:

5-I.B. Briefing [24 CFR 982.301]

To ensure that applicants have an equal opportunity to participate in the program, the PHA must ensure that notices of and communications during all the briefing session and meetings are provided in a manner that is effective for persons with hearing, visual, and other disabilities consistent with Section 504, and the ADA [HCV Guidebook, Housing Search and Leasing Chapter, November 2020].

PHA Policy
Briefings will be conducted in group meetings.

Generally, the head of household is required to attend the briefing.

If the head of household is unable to attend, the PHA may approve another adult family member to attend the briefing.

Families that attend group briefings and still need individual assistance will be referred to an appropriate PHA staff person.

Briefings will be conducted in English. For limited English proficient (LEP) applicants that require other languages, the PHA

PREVIOUS PHA ADMIN PLAN LANGUAGE:

5-I.B. Briefing [24 CFR 982.301]

The PHA must give the family an oral briefing and provide the family with a briefing packet containing written information about the program.

Families may be briefed individually or in groups. At the briefing, the PHA must ensure effective communication in accordance with Section 504 requirements (Section 504 of the Rehabilitation Act of 1973), and ensure that the briefing site is accessible to individuals with disabilities. For a more thorough discussion of accessibility requirements, refer to Chapter 2.

PHA Policy
Briefings will be conducted in group meetings.

Generally, the head of household is required to attend the briefing.

If the head of household is unable to attend, the PHA may approve another adult family member to attend the briefing.

Families that attend group briefings and still need individual assistance will be referred to an appropriate PHA staff person.

ATTACHMENT 1 Page 13 of 19

B.1 Revision of the PHA Plan Elements

will provide translation services in accordance with the PHA’s LEP plan (Seein Chapter 2.III.).

The PHA will ensure effective communication with program accessibility to persons with disabilities by complying with the policies in Chapter 2.II.F.

Briefings will be conducted in English. For limited English proficient (LEP) applicants, the PHA will provide translation services in accordance with the PHA’s LEP plan (See Chapter 2).

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B.1 Revision of the PHA Plan Elements

CHAPTER 5: BRIEFINGS AND VOUCHER ISSUANCE
Chapter Section: 5-II.E. Voucher Term, Extensions, and Suspensions Subsection (if any): Extensions of Voucher Term [24 CFR 982.303(b)] Description of Change:

The PHA has the authority to grant extensions of the search time of a voucher, specify the length of a voucher extension period, and determine the circumstances under which extensions will be granted. These discretionary policies are required to be outlined in the PHA’s Plan. The PHA would like to clarify that voucher extension requests beyond 180 days (approx. 6 months) will only be considered as a reasonable accommodation.

PROPOSED PHA ADMIN PLAN LANGUAGE:

PHA Policy
The PHA will automatically approve one 60-day extension upon written request from the family, except in cases of incoming billable portability vouchers. For additional information regarding extensions of portability vouchers, please see Chapter 15.

The PHA will approve additional extensions, not to exceed a maximum of 180 days, only in the following circumstances:

The PHA has determined that additional search time is
necessary due to extraordinary market conditions, such as an extremely low vacancy rate.

It is necessary due to reasons beyond the family’s control, as determined by the PHA. Following is a list of
extenuating circumstances that the PHA may consider in
making its decision. The presence of these circumstances does not guarantee that an extension will be granted:

Serious illness or death in the family
Other family emergency

PREVIOUS PHA ADMIN PLAN LANGUAGE:

The PHA will approve additional extensions, not to exceed a maximum of 180 days, only in the following circumstances:

The PHA has determined that additional search time is
necessary due to extraordinary market conditions, such as an extremely low vacancy rate.

Serious illness or death in the family
Other family emergency
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B.1 Revision of the PHA Plan Elements

Extensions beyond 180 calendar days will only be considered as a reasonable accommodation for a person with disabilities. The PHA may approve up to 240 days when necessary as a reasonable accommodation. Any request for an additional extension beyond 180 days must include the reason(s) why an additional extension is necessary and comply with Chapter 2.II. of this Plan.

The PHA may require the family to provide documentation to support the any extension request.

All requests for extensions to the voucher term must be made in writing and submitted to the PHA prior to the expiration date of the voucher (or extended term of the voucher).

The PHA will decide whether to approve or deny an extension request within 15 business days of the date the request is received, and will immediately provide the family written notice of its decision.

The PHA may approve up to 240 days when necessary as a
reasonable accommodation.

Any request for an additional extension must include the reason(s) an additional extension is necessary. The PHA may require the family to provide documentation to support the request.

All requests for extensions to the voucher term must be made in writing and submitted to the PHA prior to the expiration date of the voucher (or extended term of the voucher).

ATTACHMENT 1 Page 16 of 19

B.1 Revision of the PHA Plan Elements

CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS
Chapter Section: 6-I.G. Assets [24 CFR 5.609(b)(3) and 24 CFR 5.603(b)] Subsection (if any): Types of Assets [24 CFR 5.659(e)]
Description of Change:

HUD regulations require that the PHA determine the value of each family member’s assets. The PHA would like to amend its existing policy so that it may request additional bank statements if the first two statements indicate discrepancies or possible unreported income. This policy would allow the PHA to accurately calculate a family’s income.

PHA ADMIN PLAN LANGUAGE:

Checking and Savings Accounts

For regular checking accounts and savings accounts, cash value has the same meaning as market value. If a checking account does not bear interest, the anticipated income from the account is zero.

PHA Policy
In determining the value of a checking account, the PHA will use, at minimum, the average monthly balance for the last two months.

The PHA may request additional bank statements if the statements indicate discrepancies or possible unreported income. If this occurs, the PHA will use the average monthly balance of all of the statements that were received.

In determining the value of a savings account, the PHA will use the current balance.

In determining the anticipated income from an interest-bearing checking or savings account, the PHA will multiply the value of the account by the current rate of interest paid on the account.

PREVIOUS PHA ADMIN PLAN LANGUAGE:

Checking and Savings Accounts

For regular checking accounts and savings accounts, cash value has the same meaning as market value. If a checking account does not bear interest, the anticipated income from the account is zero.

PHA Policy
In determining the value of a checking account, the PHA will use, at minimum, the average monthly balance for the last two months.

In determining the value of a savings account, the PHA will use the current balance.

In determining the anticipated income from an interest-bearing checking or savings account, the PHA will multiply the value of the account by the current rate of interest paid on the account.

ATTACHMENT 1 Page 17 of 19

B.1 Revision of the PHA Plan Elements

CHAPTER 8: HOUSING QUALITY STANDARDS AND RENT REASONABLENESS DETERMINATIONS Chapter Section: EXHIBIT 8-1: OVERVIEW OF HUD HOUSING QUALITY STANDARDS Subsection (if any): Smoke Detectors
Description of Change:

HUD requires that all units occupied by families receiving HCV assistance meet HUD's Housing Quality Standards (HQS) and permits the PHA to establish additional requirements. An HQS standard requires that every household must install smoke detectors. The PHA would like to clarify that smoke detectors must comply with both National Fire Protection Association Standard (NFPA) 74 (or its successor standards) and the California Health and Safety Code requirements and must be installed in every room.

PROPOSED PHA ADMIN PLAN LANGUAGE:

Smoke Detectors
Smoke detectors must be installed in accordance with and meet the requirements of the National Fire Protection Association Standard (NFPA) 74 (or its successor standards) and the California Health and Safety Code requirements. If the dwelling unit is occupied by any person with a hearing impairment, smoke detectors must have an appropriate alarm system as specified in NFPA 74 (or successor standards).

PHA Policy
Landlords must conform with local and/or state requirements by installing smoke detectors in each bedroom, other sleeping areas, and immediate vicinity outside of bedrooms (hallways).

The owner will be required to repair an inoperable smoke detector unless the PHA determines that the family has intentionally disconnected it (by removing batteries or other means). In this case, the family will be required to repair the smoke detector.

A smoke detector is required for each level of a dwelling.

PREVIOUS PHA ADMIN PLAN LANGUAGE:

Smoke Detectors
Smoke detectors must be installed in accordance with and meet the requirements of the National Fire Protection Association Standard (NFPA) 74 (or its successor standards). If the dwelling unit is occupied by any person with a hearing impairment, smoke detectors must have an appropriate alarm system as specified in NFPA 74 (or successor standards).

PHA Policy
The owner will be required to repair an inoperable smoke detector unless the PHA determines that the family has intentionally disconnected it (by removing batteries or other means). In this case, the family will be required to repair the smoke detector.

A smoke detector is required for each level of a dwelling.

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B.1 Revision of the PHA Plan Elements

CHAPTER 16 | PROGRAM ADMINISTRATION
Chapter Section: 16-III.B. Informal Reviews
Subsection (if any): Informal Review Decision [24 CFR 982.554(b)]

Description of Change:

When the PHA makes a decision that has an adverse impact on a family, the family is entitled to appeal the decision. For applicants, the appeal takes the form of an informal review. The PHA is required to outline the requirements and procedures for such informal reviews. The PHA would like to amend its current policy to acknowledge that it may not be administratively feasible to resume the processing of an application. The change would still revert the denial decision but would allow the PHA to collect updated verifications for a household in order to accurately redetermine their eligibility.

PHA ADMIN PLAN LANGUAGE:

PHA Policy

The PHA will notify the applicant of the final decision, including a statement explaining the reason(s) for the decision. The notice will be mailed within 15 business days of the informal review, to the applicant and his or her representative, if any.

If the decision to deny is overturned as a result of the informal review, processing for admission will resumethe decision to deny assistance will be reverted. In order to determine whether the application will be returned to the waiting list or whether processing for admission will resume, t.he PHA will take into consideration, at its discretion, whether the voucher funding is available, whether the application was selected within the current fiscal year, or any other relevant and pertinent factors.

PHA ADMIN PLAN LANGUAGE:

PHA Policy

If the decision to deny is overturned as a result of the informal review, processing for admission will resume.

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B.1 Revision of the PHA Plan Elements

CHAPTER 13: OWNERS
Chapter Section: 16-IV.B. Repayment Policy
Subsection (if any): Owner Debts to the PHA
Description of Change:

Current PHA policy states that the PHA may collect any owner debts to the PHA caused by their action or inaction which resulted in the overpayment of housing assistance. The PHA would like to clarify its existing policy that it will collect a debt by reducing the future HAP payments by the amount owed until the debt is paid in full when it is possible. In a situation where this is not possible, such as times when the owner is only receiving HAP payments from different funding and voucher program, then it will collect the debt from the owner directly and give them the opportunity to enter into a repayment agreement.

PROPOSED PHA ADMIN PLAN LANGUAGE:

Owner Debts to the PHA
PHA Policy
Any amount due to the PHA by an owner must be repaid by the owner within 30 days of the PHA determination of the debt.

If the owner fails to repay the debt within the required time frame and is entitled to future HAP payments, the PHA will reduce the future HAP payments by the amount owed until the debt is paid in full when possible.

If the owner is not entitled to future HAP payments the PHA may, in its sole discretion, offer to enter into a repayment agreement on terms prescribed by the PHA.

If the owner refuses to repay the debt, does not enter into a repayment agreement, or breaches a repayment agreement, the PHA will ban the owner from future participation in the program and pursue other modes of collection.

PREVIOUS PHA ADMIN PLAN LANGUAGE:

Owner Debts to the PHA
PHA Policy
Any amount due to the PHA by an owner must be repaid by the owner within 30 days of the PHA determination of the debt.

If the owner is not entitled to future HAP payments the PHA may, in its sole discretion, offer to enter into a repayment agreement on terms prescribed by the PHA.

ATTACHMENT 2 Page 1 of 1

Deconcentration and Other Policies that Govern Eligibility, Selection, and Admissions Policies

The Anaheim Housing Authority (AHA) does not own or manage any public housing units. The AHA only administers Housing Choice Vouchers and Project-Based Vouchers.

Deconcentration Policies
The AHA has existing policies consistent with the goal of deconcentrating poverty and to encourage the participation of landlords in the following sections of the AHA’s Administrative Plan:
- 5-I.B. Briefing [24 CFR 982.301]
- 13-I.A. Owner Recruitment and Retention [HCV GB, pp. 2-4 to 2-6] - 16-II.B. Payment Standards [24 CFR 982.503; HCV GB, Chapter 7] - 17-I.A. Overview [24 CFR 983.5 and FR Notice 01/18/17] - 17-V.B. HAP Contract Requirements
- 17-II.G. Site Selection Standards
Eligibility, Selection, and Admissions Policies
- Chapter 2 of AHA’s Administrative Plan, “Fair Housing and Equal Opportunity,” outlines the policies that the agency abides by in terms of discrimination, providing accessibility, reasonable accommodations, and services in other languages - Chapter 3 of AHA’s Administrative Plan, “Eligibility,” outlines the policies the agency abides by in terms of basic eligibility and denial criteria for the programs - Chapter 4 of AHA’s Administrative Plan, “Applications, Waiting List and Tenant Selection,” outlines policies the agency abides in terms of the application process, managing the wait list, and selection from the waiting list (including preferences) - Chapter 6 of AHA’s Administrative Plan, “Income and Subsidy Standards,” outlines policies the agency abides in terms of the income and assets calculations to determine eligibility for the program
- Chapter 7 of AHA’s Administrative Plan, “Verification,” outlines policies the agency abides in terms of the verifying the applicant and tenant information as required by the program

The FY 22-23 AHA Administrative Plan can be accessed on our website:
https://www.anaheim.net/DocumentCenter/View/44854/AHA-FY-22-23-Admin-Plan The FY 23-24 AHA Administrative Plan Draft can be accessed on our website:
https://www.anaheim.net/DocumentCenter/View/47540/Admin-Plan-Draft-010923-01

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B.1 Revision of the PHA Plan Elements

Financial Resources

Program Name Vouchers Allocated CY 2022 Total Funding
Housing Choice Voucher 6,397 $99,244,652
Mainstream 5 397 $4,997,702
Emergency Housing Voucher 278 $4,361,693
Family Self-Sufficiency N/A $125,710

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B.1 Revision of PHA Plan Elements

Rent Determination Policies

The Anaheim Housing Authority (AHA) does not own or manage any public housing units. The AHA only administers Housing Choice Vouchers and Project-Based Vouchers.

Chapter 6 of AHA’s Administrative Plan, “Income And Subsidy Determinations,” outlines the agency’s policies pertaining to participants’ annual income, adjusted income, and calculating their family share and PHA subsidy amounts to determine their ongoing eligibility for the program. The AHA has existing policies that governing rents charged for HCV dwelling units, including minimum rents, voucher family rent contributions, payment standard, and interim reexamination policies.
- Payment Standards:

AHA Admin Plan Section 6-III.C. “Applying Payment Standards” AHA Admin Plan Section 11-III.B. “Changes In Payment Standards and Utility Allowances”

- Minimum Rent Policies:

AHA Admin Plan 6-III.A. “Overview of Rent and Subsidy Calculations” and 6-III.B. “Financial Hardships Affecting Minimum Rent”
AHA has a $50 minimum rent policy and allows for families to request a financial hardship exemption.

- Voucher family rent contributions:

AHA Admin Plan Chapter 6 “Income And Subsidy Determinations”

- Interim Reexamination Policies:

AHA Admin Plan Chapter 11, Part II “Interim Reexaminations”

ATTACHMENT 5 Page 1 of 1

B.1 Revision of PHA Plan Elements

Informal Review and Hearing Procedures

Chapter 16, Part III of the AHA’s Administrative Plan contains policies and procedures pertaining to informal hearing and review procedures that the PHA makes available to its applicants and program participants. The applicable policies are listed below:
- 16-III.B. Informal Reviews
- 16-III.C. Informal Hearings for Participants [24 CFR 982.555, Pub.L. 109-162] - 16-III.D. Hearing and Appeal Provisions for Non-Citizens [24 CFR 5.514]

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B.1 Revision of PHA Plan Elements

Self Sufficiency Programs and Treatment of Income Changes Resulting from Welfare Program Requirements

The Anaheim Housing Authority’s Family Self-Sufficiency (FSS) program currently assists a grad total of 92 participants utilizing this resource. AHA continued strengthening its relationship with different partners in the FSS program to provide participants with a wide array of resources that can help them achieve their education and career goals. A HA worked closely with multiple local colleges to expand supportive services. Fullerton College’s Extended Opportunity Program & Service (EOP) office provided assistance with books that participants may need during their enrolled semesters. The North Orange County Community College District (NOCCCD) offers many classes to program participants that range from job seeking skills to specialized job and educational training. They also helped program participants with transportation by offering bus passes. Women Helping Women (WHW) offered participants job seeking and retaining skills and resources. AHA’s partnership with Boys Town helped provide supportive services to individuals who are suffering from abuse, addiction, abandonment or violence. Lastly, AHA also strengthened its relationship with NeighborWorks Orange County who specializes in realty services. They offer participants help with housing counseling and education regarding credit and home ownership.

The Anaheim Housing Authority’s strategies for assis ting participating families and their impact are included in its FSS Action Plan found in the following website:
https://www.anaheim.net/736/Family-Self-Sufficiency-Program

ATTACHMENT 7 Page 1 of 5
B.3 Progress Report

PHA Goal: Expand the supply of assisted housing
During FY 2022-2023, the U.S. Department of Housing and Urban Development (HUD) awarded the Anaheim Housing Authority (AHA) with 278 Emergency Housing Vouchers (EHVs), pursuant to the American Rescue Plan Act of 2021 (P.L. 117-2). AHA accepted the award and began administering the EHVs in May 2021 under the special set of operational requirements as provided in in HUD Notice PIH 2021-35. The AHA entered into Memorandums of Understanding with the Orange County Continuum of Care (CoC) and Interval House (a local victim services provider), to receive direct referrals of eligible families in July 2021. As if February 23, 2023, the AHA has received 332 EHV family referrals and has leased 227 EHVs.

Finamore Place Apartment project (Manchester/Orangewood) is 100% affordable 102-unit workforce rental housing project located at 2121 S. Manchester Avenue and 915 E. Orangewood Avenue. The project was successful in receiving a tax credit award in July of 2019. Twenty of the 102 units in the project will be made available to homeless families and the AHA awarded 20 Project-Based Section 8 Vouchers to assist the project. The project is currently under construction and is expected to be completed in January 2023.

Studio 6 Permanent Supportive Housing Apartment community (Studio 6 Motel) is a 100% affordable motel conversion project located at 1245 N. Harbor Boulevard. The Anaheim Housing Authority/City partnered with the Developer to submit an application for State of California Housing and Community Development (HCD) HOMEKEY Program funds and received an allocation in March of 2022. The Studio 6 currently provides interim housing for homeless individuals. The Anaheim Housing Authority is currently reviewing a Developer proposal to convert the interim housing project to an 89- unit Permanent Supportive Housing project for individuals and families who are exiting a chronically homeless condition. As part of the proposal, the Developer is requesting approval for 87 Project-Based Section 8 Vouchers to assist the project.

If approved, the Developer will submit an application for Tax Credit financing in March 2023. If awarded, the conversion can commence in December 2023.

In December of 2019, the AHA awarded 50 Project -Based Section 8 Vouchers and a $2 million dollar loan to the Salvation Army's Center of Hope Permanent Supportive Housing project . The Salvation Army's Center of Hope project consists of a total of 72-units and will provide long-term housing solutions for individuals who are exiting a chronically homeless condition. Center of Hope will include 70 studio units, all of which will be set aside for homeless individuals, with 50% being set aside for homeless individuals with disabilities, plus two one-bedroom Manager’s units.

Center of Hope will also include a 325-bed low barrier shelter as part of a future phase, which will serve as the entry point to exit homelessness and will provide a wide array of on- site supportive services. The Salvation Army received a funding award from State HCD, through the County of Orange No Place Like Home Program on June 23, 2021 and a Tax Credit award from the California Tax Credit Allocation Committee on August 11, 2021 to assist with development of the Center of Hope project. Center of Hope is currently underway and is expected to be completed in July 2023.

ATTACHMENT 7 Page 2 of 5
Miraflores Family Apartments (Anaheim/Midway) is a 100% affordable 86-unit workforce rental housing project located at 110 W. Midway Drive. Anaheim Midway Apartments was successful in receiving a tax credit award in December of 2021. Eight of the 86 units in the project will be made available to homeless families and the AHA awarded eight Project-Based Section 8 Vouchers to assist the project. Miraflores Apartments is currently underway and is expected to complete construction in December of 2023.

The AHA continues to actively acquire and assemble property in the City to seek opportunities for the creation of affordable housing. Below is an update for the year 2022-23:

The property located at 212 S. Beach Boulevard known as the Beach Boulavard (Silvermoon Site) is a Housing Authority-owned parcel of land currently being prepared for development. A Request for Proposals (RFP) is currently being prepared for developme nt of the property with a 100% affordable workforce rental project. The RFP is expected to be released in February of 2023 seeking development proposals.

The Anaheim Housing Authority is in the process of acquiring the Tampico Motel located at 120 S. State College Boulevard and will be releasing an RFP for the conversion of the Tampico Motel to a 100% affordable rental special needs housing project. The RFP process and Developer selection is expected to be completed by May of 2023.

The property known as the Karcher/UEI site is a n AHA-owned site recently assembled for the development of a multi-generational affordable housing project. The Karcher/UEI site is located on Harbor Boulevard and West Carl Karcher Way. Staff is currently assessing the development parameters of the site in preparation for an RFP process to seek development proposals and expecting to release and RFP in the Summer of 2023.

The site known as Lemon/Santa Ana is comprised of several AHA-owned properties assembled for the development of a workforce affordable rental housing and homeownership project. The Lemon/Santa Ana site (comprised of several non -contiguous parcels) is located on Lemon and Santa Ana Streets. Staff is currently assessing the development parameters of the site in preparation for an RFP process to seek development proposals.

PHA Goal: Improve the quality of assisted housing
The City of Anaheim has continued to seek opportunities to revitalize low-income neighborhoods characterized by substandard living conditions and high call for service, as evidenced in the Avon Dakota and Hermosa Village neighborhoods. Avon Dakota and Hermosa Village consist of multi- phased project s involving the acquisition and rehabilitation of apartment complexes and conversion of market rate units to long term affordable units.

The first phase of the Avon Dakota revitalization project was completed in 2013 and included the acquisition and rehabilitation of 16 units to provide affordable housing for low income families.

The second phase of the project, consisting of 21 units for low income families was completed in January of 2019. Since 2014, the City has acquired ten additional properties in the Avon Dakota Neighborhood, totaling 24 units. These properties will be rehabilitated or will be part of a new construction project to provide affordable housing as part of a future phase three project.

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The Hermosa Village Neighborhood Revitalization project consists of four phases completed between 2002 and 2008. The Phase I project consist ing of 294 units resyndicated in 2017, which included the rehabilitation of the units to meet current standards, improving on- site resident amenities and adding four units to the project for a total of 297 units. The Phase II project consisting of 112 units also resyndicated in November 2019 to provide the capital to rehabilitate the Project and extend the affordability for an additional 55 years. The Developer was successful in receiving a Tax Credit funding allocation from TCAC and Bonds from the California Debt Limit Allocation Committee (CDLAC) in April of 2020. The Phase II rehabilitation was completed in February 2022. All four phases in the Hermosa Village project consist of a total of 521 units.

As part of AHA’s neighborhood revitalization efforts, the AHA is utilizing its own land for the development of Finamore Place ( Manchester/Orangewood), Miraflores Apartments (Anaheim Midway), Beach Boulevard (Silvermoon Site) and the Tampico Motel affordable housing projects.

Finamore Place Apartments (Manch ester/Orangewood) is expected to be completed in January 2023 and Miraflores Apartments in December 2023. The Tampico Motel and the Beach Boulevard (Silvermoon Site) RFP’s will be released in January and February 2023, respectively, to seek development proposals for the creation of affordable housing.

The AHA does not own the land for Studio 6 Permanent Supportive Housing (PSH) project or the Salvation Army’s Center of Hope Permanent Supportive Housing sites, but provided funding for both projects to assist in the rehabilitation and conversion of the Studio 6 Motel to 87 PSH units and for the new construction of the 70 unit Center of Hope PSH project. The Studio 6 PSH project is expected to apply for financing in March 2023, and if awarded, would start the conversion in December 2023. The Center of Hope PSH) project is expected to be completed in July 2023.

The Center of Hope PSH and Studio 6 PSH projects will create 157 units for homeless individuals and Finamore Place (Manchester/Orangewood) and Miralflores Apartments (Anaheim/Midway) will create 186 new affordable housing units for working families and homeless families for a total of 343 new affordable rental units. The Tampico Motel conversion special needs project and the Beach Boulevard (Silvermoon Site) new construction workforce rental project are currently in the development pipe -line and will add approximately 131 affordable rental unit s to the AHA’s affordable housing inventory for a total of 474 affordable units.

PHA Goal: Increase assisted housing choices
The AHA continues its mobility agreement with three other PHA’s in Orange County, (the Garden Grove Housing Authority, the Orange County Housing Authority, and the Santa Ana Housing Authority), as an effort to increase housing choice s throughout the county. Additionally, AHA maintains its contract with Go Section 8, a property listing service providing free listing options for landlords that allows program participants to search rental units that accept AHA rental - assistance.

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PHA Goal: Promote self-sufficiency of assisted households During FY 2021-2022, AHA enrolled 21 new participant families into its Family Self-Sufficiency (FSS) program for a grand total of 92 participants utilizing this resource. AHA continued strengthening its relationship with different partners in the FSS program to provide participants with a wide array of resources that can help them achieve their education and career goals. AHA worked closely with multiple local colleges to expand supportive services. Fullerton College’s Extended Opportunity Program & Service (EOP) office provided assistance with books that participants may need during their enrolled semesters. The North Orange County Community College District (NOCCCD) offers many classes to program participants that range from job seeking skills to specialized job and educational training. They also helped program participants with transportation by offering bus passes. Women Helping Women (WHW) offered participants job seeking and retaining skills and resources. AHA’s partnership with Boys Town helped provide supportive services to individuals who are suffering from ab use, addi ction, abandonment or violence. Lastly, AHA also strengthened its relationship with NeighborWorks Orange County who specializes in realty services. They offer participants help with housing counseling and education regarding credit and home ownership.

PHA Goal: Ensure equal opportunity in housing
Fair housing and reasonable accommodation information is provided in AHA’s briefing packets and notices. Fair housing information is also provided in the lobby. In addition, program participants can utilize services from the Orange County Fair Housing Council , with whom the City has a contract with.

PHA Goal: Expand the Continuum of Care to assist the homeless population in Anaheim.

The AHA operates a homeless set aside program, which entails a preference for homeless families in Anaheim who are referred by a local homeless service provider. During FY 2021-2022, AHA accepted referrals of homeless families for up to 50% of its annual new admissions.

Throughout the past year, AHA continued to participate in several committees for the Continuum of Care and coordinated with other PHAs in Orange County to strategize on way to decrease homelessness.

During FY 2021-2022, the City allocated Emergency Shelter Grant funds (which are dedicated to preventing homelessness, reducing the number of homeless on the street and providing services to the sheltered and unsheltered) to two agencies that provided emergency shelter to the homeless.

The City spent a total of $95K in emergency shelter services. The two agencies provided emergency shelter to 171 homeless individuals.

With ESG Cares Act (ESG -CV) funds, the City has funded an additional five emergency shelter programs and expanded the capacity of one program to serve people experiencing homelessness.

The additional emergency shelter capacity served 217 homeless individuals in FY 2021. The City ATTACHMENT 7 Page 5 of 5
also operated two homeless shelters in FY 2021 funded by State resources and the City's General Fund. There were no ESG funds allocated towards homeless prevention in FY 2021-22. The reason for that was because the City allocated ESG -CV funding to ten agencies that provided homelessness prevention services. In FY 2021, all programs assisted 344 indi viduals with prevention services and continues to provide assistance through their contract term. The County of Orange assists people discharged from public funded institutions or systems of care (such as health care facilities, foster care or other youth facilities, or correction programs and institutions).

This assistance prevents homelessness resulting from discharge. The City will refer people discharged from public institutions to the County of Orange for additional resources.

The City also continued funding the Homeless Assistance Pilot Program (HAPP), which combines ESG and HOME funds to provide case management and rental assistance to program participants.

The program focuses on assisting homeless families that have children attending Anaheim schools.

During FY 2021- 2022, the HAPP program served families. Of the 40 families served, 15 completed the program and moved to permanent housing and the rest are still being assisted.

In addition, the City also continued funding the Chronically Homeless Individuals Pilot Program (CHIPP), operated by Mercy House Living Centers and the Illumination Foundation. The program provides individuals with case management services and tenant based rental assistance. During FY 2021-2022, the CHIPP program served 40 individuals. As of October 2020 the City expanded the CHIPP program to have capacity to provide homeless services for an additional 40 clients and as of August 2021, the City expanded the HAP program to have the capacity to provide tenant based rental assistance to 20 more families.

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C.1 Resident Advisory Board (RAB) Comments

The Anaheim Housing Authority (AHA) Resident Advisory Board (RAB) meeting was held on Thursday, February 23, 2023 at 1 p.m. to discuss the FY 2023-2024 PHA Annual Plan and changes to the Administrative Plan.

An invitation letter 76 current and prospective RAB members to attend and participate in the RAB meeting.

An invitation email was sent to all program participants that have an email address on file with AHA.

Fifteen program participants attended the RAB meeting.

The meeting began with an introduction of PHA Plan and the RAB. Next, the RAB discussed the proposed policy changes and then reviewed the entire PHA Plan draft.

Resident Advisory Board Members:

Linda Adair
Jesus Medina
Jacqueline Anne Mahrley
Anna Cruz
Pia S Edborg
Laura Ann Buonaugurio
Gilbert Luna
Martha Alicia Bullock
Elba Carrera
Antwan Charles Earl Frazier
Mark Higgins
Bashir Ahmad
Constance K Arnopoulos
Mustapha Traifi
Desiree M Drew

Below are the comments and questions from the RAB at the meeting:

Stance
• While discussing the proposed policy changes, all RAB members expressed support and did not object any proposed policy changes. There were no recommendations to add any additional policy changes.

Comments
• While discussing Section D. of the Proposed PHA Plan, a RAB member asked what entity can assist with Fair Housing related concerns should they have an issue arise with their landlord.

AHA staff expressed the city of Anaheim’s commitme nt to furthering fair housing efforts by promoting fair and equal housing opportunities for its residents . Staff shared that the city has engaged the services of the Fair Housing Council of Orange County to provide education, training, and legal services to its residents, and provided the contact information to the RAB:

Fair Housing Council of Orange County
2021 E. 4th Street, Ste. 122
ATTACHMENT 8

Santa Ana, California 92705-3912
Website - www.fairhousingoc.org
Phone - 714-569-0823
Fax - 714-835-0281
Staff also shared the goals that Anaheim set in the Orange County’s Analysis of Impediments to Fair Housing Choice (AI) to overcome fair housing issues and achieve progress towards affirmatively furthering fair housing.
• While discussing policy change under 3-I.N., a RAB member asked if someone coming over as a caretaker during the day needs to be requested as a live- in aide. They clarified that the caretaker does not permanently live in the home.

AHA staff clarified that a live-in aide refers to someone who permanently lives in the home who is approved to take care of a disabled individual full-time. If the disabled individual does not require the caretaker to permanently live in the home, then a reasonable accommodation is not required.

Staff also recapped the Reasonable Accommodation process with the agency and explained that a response on a request in granted by mail after the Reasonable Accommodation Committee makes a decision.

• While discussing policy changes under 3-III.C. and 3-III.E., the RAB expressed support in aligning current criminal background screening policies with best practices recommended by HUD and the Department of Justice. These recommendations are intended to remove disparate impact, or unintentional, discrimination toward communities of color and ensure criminal background policies only deny those whose presence at a housing site would cause a threat to the health and safety of others. A RAB member asked how program participants would be notified if this policy goes into effect.

AHA staff responded that all program participants would get a notification by either mail or email if the Board of Commissions approves the policy recommendations.

• A RAB member asked how they can report owner noncompliance their lease.

AHA staff recapped the triangular relationship with the Housing Authority, the owners, and the program participant in the Section 8 program . Staff clarified that AHA only has the authority to hold owners accountable to what is stated in the Housing Assistance Contract (HAP), but does not authority to act on issues that occur between program participants and property owners. Staff shared that a program participant may report if they suspect HAP Contract noncompliance to their Housing Specialist at any time. Staff reminded the RAB that they can Fair Housing Council of Orange County for any property owner related concerns.

• While discussing policy change under 3-I.N., a RAB member asked if someone coming over as a caretaker during the day needs to be requested as a live- in aide. They clarified that the caretaker does not permanently live in the home.

Staff also recapped the Reasonable Accommodation process with the agency and explained that a response on a request in granted by mail after the Reasonable Accommodation Committee makes a decision.

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• AHA policy 4.II.F., currently states that an applicant’s name will be removed from the waiting list if mail directed to them is returned by the post office as undeliverable. While discussing this policy, a RAB member asked if owners also have a similar policy. The RAB member shared that his current landlord has had trouble in the past receiving their mail.

AHA staff clarified that such policy does not exist as terminating the relationship with a landlord for undeliverable mail could adversely impact all the tenants that the landlord currently rents to under any AHA program. Staff shared with the RAB that an annual letter is sent to all the owne rs in the program asking them to update their information in needed. AHA staff stated they would check on that RAB member’s case to see if an update was received to ensure their owner’s information is saved correctly.

• A RAB member if any assistance is available for individuals that are disabled but not homeless.

AHA staff shared that Anaheim Housing Authority will be accepting pre -applications for the Housing Choice Voucher, also referred to as Section 8, program waiting list beginning Monday, March 6, 2023 at 10 a.m. PST through Thursday, April 6, 2023 at 4:59 p.m. PST and shared the anaeheim.net/ApplySection8 website.

• A RAB member commented that cost of living and utility expenses have gone up and asked if this is taken into account when determining their rent.

Staff explained that the utility allowance schedule is updated annual and directed RAB members to the Administrative Plan utility allowance methodology section. Staff explained that the Section 8 rent calculation formula does not account for a cost of living increase and is solely based on the household’s income at the time they are undergoing their annual reexamination.

• A RAB member asked where they can search for available units that accept Section 8 vouchers.

AHA staff shared the website AffordableHousing.com and noted that it is entirely managed by landlords itself and AHA cannot control the listings. Staff clarified that AHA only refers clients to the website to assist their search for a unit but does not own the website.

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C.4 Challenged Elements

If any element of the Annual PHA Plan or 5-Year PHA Plan is challenged, the Anaheim Housing Authority (AHA) must include such information as an attachment to the Annual PHA Plan or 5-Year PHA Plan with a description of any challenges to Plan elements, the source of the challenge, and the PHA’s response to the public.

The FY 23-24 AHA PHA Plan has been made available for public comment from January 9, 2023 through February 23, 2023.

As of February 23, 2023, there was not any challenged elements. No public comments were received during the public comment period.

Anaheim City CouncilMarch 28, 2023

Anaheim City Council
March 28, 2023