sr-032310-1eBoard Meeting: March 23, 2010
Agenda Item: ~ -
To: Housing Authority Board Chair and Members
From: Andy Agle, Director of Housing and Economic Development
Subject: City of Santa Monica Housing Authority Draft Administrative Plan
Recommended Action
Staff recommends that the Housing Authority Board approve all proposed revisions to
the Santa Monica Housing Authority's (SMHA) Draft Administrative Plan and adopt the
Draft Administrative Plan.
Executive Summary
The Administrative Plan (Plan) establishes policies and procedures for operational
oversight of the SMHA's rental subsidy programs in a manner consistent with mandated
U.S. Department of Housing and Urban Development (HUD) regulations. HUD provides
federal funds to the SMHA to administer seven distinct rental assistance programs for
approximately 1,300 very-low and low-income households who reside in Santa Monica.
While programs are strictly governed by HUD policy and regulations, HUD does permit
jurisdictions to tailor discretionary policies that address .local needs to the extent that
they do not conflict with HUD regulations. 24 CFR 982.54 requires the SMHA Plan to
develop and publish policies that address 24 distinct subjects that provide guidance to
program applicants and participants,. as well as members of the public and staff.
Background
The Administrative Plan is not a strategic or planning document, rather an operations
manual of policies and procedures. Its purposes include:
® It informs the Housing Authority Board regarding the policies of the SMHA on all
aspects of program operations.
® It serves as a policy and procedures manual for staff to adhere to uniformly and
consistently in their daily work.
® It provides a standard by which the participants and the public can determine if
program applicants and participants are treated equitably.
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® It notifies HUD of the policies the SMHA has adopted in conformity with the
regulations.
HUD develops regulations and notices to interpret, clarify, and define the laws that
Congress enacts. SMHA subsequently develops policies and procedures that are
consistent with the regulations and creates the Plan. For example, HUD regulations
define that a Section 8 program applicant has a finite period of time during which to
locate a unit to lease and that this period is from 60 to no more than 120 days. The
Administrative Plan states the circumstances under which SMHA will extend the time
period beyond 60 days.
HUD also expects the SMHA to revise the Plan as needed to comply with frequent
changes in HUD regulations and statutes. Since 2003, when the Plan was last revised
and adopted, there have been significant non-discretionary changes that govern the
Section 8 program. A summary of policy changes is identified in Attachment B.
Discussion
The Draft Administrative Plan and its policies reflect and comply with changes in HUD
regulations and SMHA operations. The Plan changes are primarily made to reflect
mandated federal requirements and are not discretionary. A major formatting change to
the Plan embeds the specific Code of Federal Regulations citations within each policy
instead of referencing them in an Appendix. This change provides a better
understanding of the regulations and how the SMHA applies them. Staff has worked
with the Legal Aid Foundation of Los Angeles in the development of the Plan, as Legal
Aid serves the same target population as the Housing Authority. The Plan reflects green
text for discretionary policies that HUD permits, and since the Plan was made available
for public comment, HUD has made non-discretionary regulatory changes and those
have been integrated into the Plan to keep it current. The Plan reflects those recent
changes in blue text. Public commerits and the relevant responses are included in the
Plan.
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Commission Action
The Housing Commission reviewed and discussed the Draft Administrative Plan at its
September, November, and December 2009 meetings. At the December 2009 meeting,
the Housing Commission approved. the SMHA Draft Administrative Plan and
recommended City Council/Housing Authority Board adoption.
Public Comment
The Draft plan was made available fora 45 day public review period, as required by
HUD, from December 23, 2009 to February 8, 2010. The public review period was
noticed in the Santa Monica Daily Press. All comments have been reviewed by staff and
have been integrated into the public comment section ofthe Draft Plan.
Financial Impacts ~ Budget Actions
No fiscal or budgetary impacts will result from approval of the Plan.
Prepared By: Julie Lansing, Housing Authority Administrator
Housing and
Attachments:
Forwarded to Council:
Rod Gould
Executive Director
A. City of Santa Monica Housing Authority Administrative Draft Plan
B. Summary of Policy Changes and Clarifications
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Additional documentation
available in City Clerk's
Office.