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What Is HOME?
Becoming a HOME Player
Before considering the use of HOME funds, LHAs or other agencies should--
Defining and Achieving Shared GoalsBefore even considering the possibility of using HOME funds, any agency must know what is possible and permissible under the HOME regulations. For example, Public Housing modernization is not an eligible use of HOME funds. Thus, even if an LHA and a local PJ agree that funds are needed for the modernization of a public housing development, they should not view HOME as a potential vehicle for meeting that need. On the other hand, an LHA may wish to provide homeownership opportunities for tenants of public or assisted housing. The jurisdiction may also wish to increase homeownership opportunities generally or in a particular geographic area. Thus, the two entities may jointly develop a HOME-funded homeownership program to achieve a shared goal. Any organization considering the effective use of HOME funds must know what it can and wishes to achieve with HOME. For example, an LHA may want to undertake any of the following activities using HOME funds:
The jurisdiction's goals for using HOME should be clearly stated in the Consolidated Plan. Ideally, a variety of state and local agencies will have had a substantive role in shaping those goals through the required planning process that leads to the development of the Consolidated Plan.
Planning--Getting A Handle On The ProcessThe National Affordable Housing Act of 1990, which created HOME, mandated a HUD-approved planning document for all jurisdictions that receive HOME funds. Beginning in FY 1995, all jurisdictions--states, cities, counties and consortia--were required to have an approved Consolidated Plan in order to receive HOME funds as well as Community Development Block Grant (CDBG), Emergency Shelter Grant (ESG) and Housing Opportunities for Persons With AIDS (HOPWA) funds. The Consolidated Plan should result from a comprehensive, inclusive planning process on either the state or local level. Local jurisdictions must consult with the local housing authority concerning public housing needs and Comprehensive Grant funded activities to ensure that these endeavors are fully coordinated with those covered by the Consolidated Plan. They are required to provide information to housing agencies about activities related to public and assisted housing developments and surrounding communities. In conjunction with LHAs, local jurisdictions must encourage participation by public and assisted housing residents in the process of developing and implementing the Consolidated Plan. Although states are not subject to the same requirements regarding consultation with local housing authorities and public housing residents, the process of developing a state Consolidated Plan should also be inclusive. All jurisdictions must hold at least two public hearings per year related to the development of the Plan and must provide a 30-day comment period after a draft plan has been made available. Because of the mandated linkages between housing authority activities and those administered by the jurisdiction, the establishment of the Consolidated Planning process offers an important opportunity for local housing authorities to impact the determination of priority needs and how resources--especially HOME--will be used in their communities. However, these mandates do not apply to the many local housing authorities located in smaller communities not required to submit a Consolidated Plan. In order for these agencies to impact priorities for spending millions in Federal housing and community development funds, they must actively track the planning process in their state. In any case, most local housing authorities should aggressively involve themselves in the process as it has been established in their community or state.
Consolidated Plan Requirements
Identifying the Players and What They Have to OfferFor a Local Housing Authority or other agency considering how they can use HOME to benefit their community, the most significant actor is the participating jurisdiction, the state or the unit of local government that is the official recipient of HOME funds. All PJs must designate a department or agency to administer the program. States typically designate either their housing and community development departments or their state housing finance agencies for this purpose. In most local participating jurisdictions, the community development department is responsible for administering HOME. The local community development department may also be responsible for developing the Consolidated Plan, or may do so in conjunction with the planning department. When the housing authority or other agency is located in a jurisdiction that is part of a HOME consortium, the situation is more complicated but the same rules apply. The consortium must submit a Consolidated Plan and there must be a designated lead agency primarily responsible for seeing that the goals of the program are carried out. The HUD Field Office can provide information on consortia and lead agencies. LHAs should be aware that the HUD Office of Community Planning and Development (CPD) is responsible for HOME and Consolidated Planning and the CPD field staff is not always housed in the same location as the Public and Indian Housing staff. Another group of significant actors are CHDOs--Community Housing Development Organizations. All participating jurisdictions must set aside at least 15 percent of their HOME allocation for use by these nonprofit organizations. Local Housing Authorities should be particularly aware of the existence and activities of CHDOs or other nonprofits utilizing HOME funds. Local housing authorities have been involved in establishing CHDOs and some are currently providing consulting services as well as long-term housing management services to CHDOs and other nonprofits that have developed HOME-assisted projects. The Consolidated Plan process offers LHAs and other agencies the opportunity for a more substantial role in establishing priorities and planning for the use of HOME funds and potentially in implementing those plans. In order to fulfill that role, each agency must critically examine the skills and expertise it brings to the table. These skills and expertise may include the following:
From the perspective of the participating jurisdiction, given the monitoring and affordability requirements for HOME-assisted housing, the most significant advantage enjoyed by local housing authorities may be their long-term involvement in providing low- and moderate-income housing. Secondarily, unlike many other potential development partners, LHAs are able to assure the participating jurisdiction that any financial return derived from a project will be devoted to further affordable housing efforts. Participation in HOME-assisted activities may present LHAs and other agencies with a variety of important opportunities including:
There are many ways in which Local Housing Authorities and other agencies can participate cooperatively with PJs to implement HOME-assisted activities and achieve commonly established goals. Each agency must determine how its expertise can best be developed and used to realize those goals and identify opportunities to effectively use HOME to meet the affordable housing needs of the community.
Becoming A HOME Player: Advice from Successful LHAs
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