City Policies Grant Assistance Policy - 12/9/86

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                            Rehabilitation Assistance Program Policies
                                 REPETITIVE ASSISTANCE




Problem Statement

       Since no formal policy exists, grant assistance has traditionally been awarded on a

‘lifetime basis’, meaning once completed, clients must then seek other sources.

Traditionally also, clients have been allowed loan assistance only, when a grant has been

awarded in the past. While there are no apparent abuses on the policy recorded, certain

cases may exist where loan assistance is not feasible due to extenuating circumstances.



Policy Statement

       A policy shall be established to support the ‘lifetime’ limitations for grant

assistance. This shall be a general policy, however, the City reserves the right to extend

additional assistance under the following conditions:

           Grant assistance may not have been received within the past seven (7) year

           period:



           Consideration shall be given on a case-by-case basis;



           Age of the applicant must be over S5years;or physically or mentally

           handicapped;



           Applicant must demonstrate a clear financial inability to repay a loan

           obligation; i.e. fixed income, etc.



           Amount of repairs must not be excessive; the structure must be economically

           feasible under normal program standards;



           All of the above conditions must be met, and the level of assistance shall be

           limited to those in effect at the time of the review.
                                  ASSISTANCE LEVELS



Problem Statement

        The levels of grant and loan assistance have remained constant for a number of

years, as $6,500 and $17,450 respectively. The ratio of assistance offered by the program

to increased construction costs has restricted the feasibility of assistance to clients, while

the rate of housing deterioration continues to accelerate.

        The current grant assistance limit of $6,500 in many cases, hinders assurance of

quality construction for those clients with greater financial handicaps. Further, one

method used to compute eligibility (i.e. monthly housing expenses in excess of 25% of

gross household income) has not kept pace with comparable programs.

        The current loan limit of $17,450 is available at interest rates of 3, 5-1/2, or 8%

depending upon the client income. Loans are available for clients ineligible for grant

assistance or combined with grant assistance when costs exceed grant limits. Some

eligible clients cannot be served because their properties need greater repairs than present

limitation offer.



Policy Statement

        Tn order to mitigate the adversity of inadequate financial resources, grant and loan

assistance levels shall be appropriately increased. Increases in these levels are expected

to enhance client services, contractor participation and the City’s long-term commitment

to housing preservation.

        Grants assistance shall be increased to an amount not to exceed $8,000 for eligible

recipients. Eligibility criteria shall demonstrate that more than 30% of gross monthly

income is being spent towards monthly housing costs. Monthly housing costs are defined

as mortgage taxes, insurance, utilities and maintenance.

       Loan assistance shall be increased to an amount not to exceed $20,000 for

eligible recipients. Loan assistance shall be available at interest rates of 3,5-1/2, and 8%,

depending upon income,      Repayment periods shall be computed to the benefit of the

City’s security position and affordability of clients at 5-, 10-, 15-, or 20 years periods.
                                                            6
                                                       &7~-10

                                              COMPLAINT        PROCEDURE




 Problem Statement

        No     formal           complaint,           grievance       or    appeal process      has    ever been

 developed           in        the     program.          Traditionally,            complaints        have   been

 handled           on case-by-case bases.                    Some decisions have raised compliance

 questions,              avoided        the     issues        and    generally       served     to quiet the

 complainants                 without regard for legal repercussions, public relations
 or     impact           on     the     program.             The    lack     of    formal     procedure      has

 contributed              to     poor public perceptions                  of program administration and

 merits       the    following          policy       statement.




        A     written           grievance        procedure          shall     be    available        for public

 viewing           and        be ‘delivered to each program participant upon initiation

 of    case    processing.


        A      Review            Committee           shall     be    created       for    formal     grievance

 hearings.                This        group will be comprised of persons from the CDC and

 staff.


        Jts        purpose           shall be    limited to rendering opinions                 in accordance

 with        established grievance procedure.                         It shall have the authority to

 recommend           appropriate disposition or that a grievance be forwarded to

-the        next     higher           phase     of     the     procedure.           Its purpose is not to

 consider           all        applications,           but     rather, review only those that have
 exhausted           remedy through the formal grievance procedure.                                Staff shall

 compile           all necessary              information for presentation and an aggrieved
 person shall have the opportunity to attend any formal hearing.
        The        procedure will be set into three phases:                              verbal, written and

 appeal.            All pertinent facts shall be weighed to insure that both the

 aggrieved party’s and the City’s best interests are protected.
                                                GRIEVANCE            PROCEDURE




          In     accordance        with          the        objectives            of    the       National       Housing       Act,


the            Department         of        Housing               and          Urban         Development              rules       and

implementing               regulations,                   and     the      City         of     Muskegon's              Community

Development               Block        Grant               Progran,             the         following           policies          and


procedures            are         established                   to        resolve             disputes            related           tuo


eligibility,               processing                 or        other           elements               of       the        housing


rehabilitation              assistance                program.                 Said    procedures              shail      apply    to


participants              involved         in    active         processing            for    housing           rehabilitation


assistance.




      -    Each      participant                 shall          be      provided            information              about        the


           availability           of       grievance            policies        set     herein,          how    to     use    then,

           including           rights           of        appeal     and    the    right          to   be     represented          by

           legal    counsel,          at    the       participant’s             expense.

      ~    Each     participant                 shall        be      given        the        opportunity             to    make    an

           informal,           oral        presentation              of    his/her          grievance          before        filing

           @    written    complaint,                if    desired.


      -    Each     participant              shall         be     provided        assistance             by    City       staff    in

           preparing       a   formal       written             complaint,         if       desired.


      -    Each     written       complaint               shall      be    reviewed          by    the      Department        Head

           or     designee,           other          than         the      official/employee                    who    made       the

           original       determination.


      -    Each     aggrieved          person         shall        be     given    the       opportunity          to      inspect

           his/her        files        or       records           pursuant             to     his/her          clain,      except

           those     exempt           under      the       Freedom        of    Information              Act    and    job    cost

           ~    related    documents.
    -   Complete        records              and    documentation                    pertaining                  to    a    written


        complaint           shall       be    retained         by    the       City       and    prompt           notification


        shall    be    given       to    each      aggrieved             person       of    any       actions          taken.




Il. Procedures
   -    Each     aggrieved              person          shall       first       express          a    complaint.                 Staff

        shall     respond           within          a     reasonable             time       and       document             the    file

        concerning           the    nature         of    the    complaint,                dates,          parties          involved

        and     suggested           resolution.                 If       no    resolution             is       reached,          staff


        shall     assist           the        aggrieved             person       with       completion                of   written


        complaint,          if    necessary.


   -    All     written           complaints             must       be    on    forms       provided             by    staff       and

        must     specifically                identify      the       nature          of    the       problem,          dates       and

        factual        background.                  Upon       completion,                staff       shall       present          the


        written        complaint             to     the        Department                 Head       or    designee.             Said


        person         shall            resolve           the            complaint              after           allowing          for


        consultation              with       the    aggrieved             person          and    staff          involved.           If


        no    solution       is    reached,         the    aggrieved             person          may       appeal.


   ~    An     appeal        may     be       made        to    a    committee             of    the       City’s       Citizens


        District        Council.                  Said     committee             shall          review          the    complaint

        history        and    make       recommendations                  for    alternative                   administrative


        remedy         on         whether           the        complaints             merit               further          action.


        Following            reasonable             notice           of        hearing           to        all        interested


        parties        and        after       hearing,              the        CDC    shall           (1)       concur      in    the

        proposed        resolution                submitted           by       City   staff,              or    (2)   recommend


        to    staff    any    alternate            resolution             to    the   complaint.

        Under     no        circumstances                shall        the       committee             have       authority         to


        implement       or    change         policy       administration                  by    City Staff.
-   Any     person       not    satisfied            with       the      City’s    determination            after   a


    formal       appeal        is    conducted.             in           accordance         with     established

    grievance        procedures,              may    make       a    request      to   the    HUD    Area   Office


    serving       this     community                for     a        HUD   Review      of    his    appeal.      The

    determination          made          by    HUD    will          be   communicated         to    the   City   and

    to    the   complainant         in    writing.




                                                                                       Ai dapti           1-27-&7
                                       S7-19       «&

                              APPLICABLE CODE STANDARDS


_KGROUND

    Municipal Code Standards are established to provide reasonable protection of
    health, safety and welfare in buildings used for human habitation. These Code
    Standards are defined in three ordinances, namely, the Housing Code, the
    Piumbing Code and the Electrical Code.    The Rehab Program has traditionally
    provided assistance beyond these categories, under what are referred to as
    “Rehab Standards".   Generally speaking, these standards are what makes the
    program a "substantial rehab” program as distinct from “minimum code"
    programs. Won-code work items are often included, but in determining economic
    feasibility, Code requirements are not sacrificed.

    PROBLEM STATEMENT

    Written Rehab Standards are of paramount importance to successful rehab
      ygrams. The absence of these standards of reference creates confusion for
    all parties including rehab staff, contractors, inspectors and clients. The
    Muskegon program has operated under the premise that the formal Housing,
    Plumbing and Electrical Codes are the mandate. However, as various complaints
    over time have shown, written standards specific to the rehab program are a
    grave necessity that must be addressed.

    OPTIONS/RECOMMENDATIONS

    The adoption of a firm Code standard to be applied to rehab inspections wil]
    help to define priorities in the writeup and the appropriateness of items.
    Further, such action wil) aid contractors, inspectors, clients and staff in
    determining the basis for decision evolving from disputes, etc.
    The adoption of City's Ordinance entitled “Article V Housing Code" provides
                                                                        by the
    “ne foundation for “substantial rehab". The standards outlined
(
                                     -                   ~2~
 “dinance     establish        minimum         standards       for   interior   and exterior        structural

needs.

In    addition,     a    standard        policy        has   been     developed      to   address       areas   not

contained in the City’s Ordinance.                           This policy (copy attached) should be
construed as an addendum to the Ordinance, in that it provides an overview of

certain     requirements        by       MSHDA    or    existing       CDBG   standards         which    are    not

necessarily a local Code Requirement.


IMPACT/SUMMARY

Tne   adoption      of   the   City's          Ordinance     and     policy   addendum     as    offical    Rehab

Standards    will    formalize what             have been operating guidelines for the program.

These points of reference will firmly establish mandated compliance objectives

for   all   parties      involved         in    the    program       and   thereby    eliminate     or     reduce

uncertainties and confusion.
                                  STANDARD AND PROCEDURE POLICY
                       FOR MECHANICAL INSPECTIONS ON MSHDA, CDBG, AND GRANTS
                    .                     CITY OF MUSKEGON


A. ELECTRICAL —

               If, at the time of on-s      ite inspection, the Elecir,trical Inspector
     1.
                                                         in good repa and the
                                     60 amp entrance is volt
               determines that the not                                                total
               connected loan does       exceed 11,000        amp, or appr   oxim atel y 50
                                              any major electrical inappl ianc es   (ran ge,
               amp, and if there arethe not
                                          service entrance may rema at     the pres 60
                                                                                     ent
               dryer, water heater),          ired number of circuits for the dwelling,
               amp size. To acqu   ire the requ to a new 12 or 16 circuit panel with a
               the changing  of  the old fuse box
               60 amp main  brea ker will suffice. If ali the above cannot be met, then
                                         be required.
               a new 100 amp service will-
                                                                                 rooms.
               Ground Fault Interruptor receptacles will be required in all bath
               Smoke detectors will be hard wired.
                                        , if there is only one
               As in the Housing Codeting                           light fixture in the
                                   exis
               laundry area on the new      laundry circuit, and only     one outlet, this
               will not require a new20 20ampamplaun dry circuit.   If  thes e requirements
               cannot be met, then a              laundry circuit  must  be  installed.
               Flourescent light fixt  ures will be required      in kitchens and bathirs
               uniess, in the case of a grant, the present fixtures are in good repa
               (complete) and safe operating condition.
                                                                                  .
               All other wiring shall conform to Section 4-65 of the Housing Code
B.    PLUMBING

                If, at the time of toinspection, the Plumbing   Inspector can determineme
      i.
                that the water flow more                                     if the syst
                                              than one fixture is low, ifor the
                                     materials, or leaking
                has bandages, rusty aced                    pipes, or            system has
                been partially repl ,onethen     the entire system  shou  ld  be  replaced.
                Low water pressure to                               all   wate r
                                            fixture does not meani.e. bibb, wash  piping is
                                                   et or valve;
                          It could be in the fauc ly                                 er, or
                bad.                                       tube.
                sediment in the valve body or supp
                                                                 ctive, in bad repair,
                                           determined to be defethe                      or
                 If the sewer systemor ismore restricted, then      buil ding sewe r syst em
                 appears to be 40% aced totally.
                 shall also be repl
                                                                      .
                 All other plumbing shall conform to the Housing Code
          STRUCTURAL

          1.     The roof shal l be in good repair. Any evidence of leakage would
                 justify replacment..
                                                       l be in excs.ellent                     and
                                                                              repair. Stormsof the
                 All. doors and bewinreqdowuirs edshal
                                                    for all window                       is
                                                                         If the windowonly a storm
                 screens shal]
          2.

                 non~opening type,. and      not required to    be  ope nab le, then
                 shall be required
                                         -2-




     All   other structural   items shal] meet the requirements set forth in the
     Housing Code.

     ENERGY.

     1,    For MSHDA - assisted projects,     the insulation requirements   set forth
           by the MSHDA shall pertain.

E.   INCIPIENT VIOLATIONS

     For certain high cost items such as furnaces and       roof replacement, where
     the item is deemed an incipient violation solely on the basis of age, and
     not on the basis of condition or performance, and where inclusion of such
     item makes the project infeasible or unapprovable by the City, the City
     May at its discretion eliminate the item from the writeup.

     GRANTS

     The   requirements   for a grant shall    be based wholly on the Housing Code,
     addressing only health and safety problems, and the roof covering to
     assure that the building is well protected and weather resistant.     What
     are commonly known as "cosmetic" items are not to be included except under
     the following conditions:   (1) Failure to include the item perpetuates a
     blighting condition; (2)     The item is needed for purposes of weather
     resistance or to eliminate unsanitary or unsafe conditions.   It should be
     noted, however, that often a good cleaning and some repair would fulfill
     requirements of the Housing Code and significantly decrease project costs.
                                                         e7-17 2@




      Basic        eligibility                for     participation               in    CDBG rehab programs is

generally          left           to    the discretion of the local progren, with primary

focus        (in   Muskegon’s                 cease) on benefit to low-mod income persons and
elimination             of        blighting influences in targeted neighborhoods.                           This

is,     of     course, based upon the national objectives of the Block Grant
program.


      The      City          reviews          eligibility            from       the      standpoint of both the

applicant          and        the       property.              Programs           ere evailable both for the

owner-occupant                and        the investor—owner.                    The latter, however, is most

likely        to    be        served          by     one       or    more        of     the   NSHDA-adwinistered

prograns, where eligibility criteria are not within the purview of
the City.                Considerable local discretion does exist for the regular
CD    homeownership                    program,          and    that       is     the     focus    of this policy

review.




      Preliminary eligibility hes for years been established on the
basis        of    a)        ownership             and     occupancy for one year prior to project
approval;          b)        property              insurance in force; c) no delinquent taxes or

water        bills;          d)        conformance with local soning.                         Loans or grants can

be made to individuals or families.

      Once basic eligibility is established, the primary concern is
household          income                 household members) from the standpoint of a)
                                       (all
eligibility             for        assistance; and b) ability to undertake any loan
obligations             required              to     ensure         that    the property is brought up to
code.

      Applicants                  are         screened         through          a verification        process   to

determine the source and amount of monthly income, housing expenses
such        as mortgage,            taxes,          insurance            and utilities,             and    credit      history,

etc.          Theoretically,                   the       City        could also include                   consideration of

liquid sssets in its                  review,            although this             is not          routine.

       Tfraditionslly,               if        an     applicant’s            income has             fallen below            80% of

the     aren        median         income,          that      applicant          automatically qualifies                     for e


grant.             If     income          is    higher              than 80%       (the benchmark for “low and

moderate           income"),          an       applicant                 could still qualify for @ grant if
housing          expenses           exceed          25%        of monthly          income.           Finally,       if      in   the


course        of        loan       packaging             it    becomes       clear          that    rehab    loan      payments


will        cause       an     increase             in        monthly housing expenzes                      beyond       the 25%

mark,        grant        assistance            has           been        given        to    the    extent      necessary        to


bring those monthly expenses                             below the 25%             cap.

       Problems          with       the    current            policy       are    as    follows.          First,       the City


has     relied          upon        outdated         income          statistics             in screening applicants.

This        is      easily          remedied             through           adoption          cof     Section       8        income

Suidelines           for       the Muskegon               Area.           Second,       no   upper     limit     on     incomes


has     ever       been        imposed          for           either        straight           loans       or    houscholds

qualifying           for       a     grant          on        the        basis    of monthly          housing      expenses.


Finally,          the      25%      benchmark            has       not    kept    pace with          increases         in   other


housing          assistance           programs                or     with        conventional          mortgage         lending


practices.          Thirty          percent         is    probably          more       realistic.


       Based       upon        revised         housebold             income       limits       (attached)        four       tiers


or    eligibility          are      proposed,            as    follows:


       1)        Very      __Low     Income:                  Straight           Processing          of Grants.             These

                 households,              falling             roughly        into        the        "50% of area median

                 income"           group,       qualify              automatically                 for a grant of up to

                 $8,000,       assuming other eligibility requirements are met.
    2)      Low__Income:____3%_Loan/Adjusted
                                Processing of Grants. These
            households           heve      incomes          equating              to     50-80%    of    the srea

            sedian.          If     their       monthly            housing expenses exceed 30% of

            their        income,         they would qualify automatically for a grant.

           rd      monthly        rehab        payments           on        a     3% loan produces housing

            expenses        in     excess        of     30%        of           income,       they would become

            eligible        for     oe    grant        in     an        amount          sufficient to reduce

            monthly housing expenses to the 30% cap.

    3)      Below Median Income: __5_1/2%_Loan.                                        Households at or below
            the         median     income        (80-100%              of       median)       would     generally

            qualify for a 5 1/2% loan if other criteria are met.

    4)      Above        Median Income:               8% Loan.              Households earning 100-120%

            of     the    median         income would qualify for an 8% loan,                             if they

            can     provide        two        letters        of        rejection           from    local banks.

            Rejection            must     be     related           to       the        property       offered    as

            security,       and not to such factors as credit history.

    Loan     applications           are        reviewed           not       only        for    the applicants’

ability     to     repay,    but also for the City’s security in the loan.                                      The

latter     relates        closely        to     the     question                of     property eligibility,

discussed below.




    There        sre numerous guestions tangentially related to the property

proposed     for        rehabilitation.               These include whether or not there ia

clear     title     and     adequate           insurance,           whether             use    of the property

conforms     to     local        rzoning,       as    well as whether the cost of required

repairs     can     be     accommodated by the Program through a grant, loan or
combination.


    Apart        from     these     tangential              issues              is the central question of

whether rehabilitation of the structure makes good economic sense.
Where     e     loan        is        being     considered,    the    cost   of rehabilitation      is

excessive        if        total        indebtedness     exceeds      the    market   value of the

property        after        rehab.             fhe City would have inadequate security for
its     loan,     and        the        property     owner would be making an         investment    of

dubious value.
       Even     where collateral is not a factor,                    rehab assistance should be

considered        a        public        investment     requiring      an    economic return.       In

theory,       units are considered unsuitable for rehab                       (and candidates for

clearance),           if     the        cost of reheb exceeds 75% of the market value of

the     property.                In     fact,    however,     the    City sometimes does extend

assistance        under           those       circumstances.         Structurally sound housing

unit     is     extremely              costly to replace.      Muskegon’s housing units have

an     unusually           low        sarket value in relation        to replacement costs,        and

in     many     cases        a 75% cap accommodates only a small amount of repair.

However,        most often a practical limit                  is placed on assistance through

grant limits and the ability of the property owner to take on debt.
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                            "INVUD
                                                          TARGET       ABEAS

                                                               S7-/79 &

        fhe       benefits           of       targeting housing rehabilitation occur at three
 levels.               (1)     targeting             demonstrates                 compliance with the             intent of

 federal.         law;        (2) target areas support local planning objectives;                                            (3)
 by     concentrating                public          investment              at        the neighborhood level,               the

 individual property owners                          are protected.

       From        the       standpoint              of        the    federal       legislation,       the drawing of

target         area boundaries                can       demonstrate          a    locnlity’s       commitment          to    the

principle              objective         of   the Block Grant                Program:          service     to    people of

low      and       moderate          income.             In the City of Muskegon,                   the "Block Grant

Neighborhoods"                are        those with             the    highest         percentage    of    lower       incorne

people        -     over       650% in all cases,                     and as high as 75%.              These are also

the     neighborhoods                with       the            highest       percentages           of minorities             and

female-headed                households             -     ae    factor which HUD            also    considers          in    its

review        of       the     progras.                 The         second        principle        objective           is    the

elimination             of     slums          and       blight.             If housing rehabilitation                   is   to.

serve        this       objective,             some        sort of delineation of those areas must
also occur.

       While        Federal          regulations                do     not        prohibit     Citywide,         or    "spot"

rehabilitation,                each        instance             of     assistance           must     meet       one of the

national          objectives.                  Compliance             could       be    demonstrated       on    the    basis

of     the     lower          income status               of the       applicants being             assisted,          or the

fact     that          the     housing          unit           is    substandard.          However,        to    date,      the

City     has       chosen           to   concentrate                rehab    activity for          reasons       discussed

below.


       From       the        time    the City           embarked        on    its      Rehabilitation           Assistance


Progras,          it     has        been      used      to support           local      land use     and   development

objectives.             Those       objectives            are expressed in               the   local   zoning
erdinance,           which      defines which neighborhoods ere to be preserved for
single         femily     use.          Residentiel structures which do not conform to

local        xzoning     are     not    eligible       for     rehab.        At the outset of: the

Progran,           Community      Development         objectives        were also set out in the

Keighborhood Development Plan which first defined target areas for
concentrated activities. Although HUD no longer requires an NDP, the
concept            is still an underlying principle of the CD Program.                   Wot only

is      neighborhood housing stock to be improved, but infrastructure as
well.                                                                    .
        More        recently,     the    City’s       land     use and development objectives
heave     been              in the Citywide Master Plan and proposed
                      elaborated        upon
zoning ordinance, as well as the 1982 Housing Policy. The proposed
zoning ordinance would encourage the conversion of many current R-2
neighborhoods back to k&-1, or single-family.     fhe City has tried
wherever            possible     to     discourage      the     use of rehab funds to support

higher         densities.         Neighborhoods most affected are Nims, Froebel and
McLaughlin.

        The        Housing     Policy     presented apn analysis of neighborhood trends
over         the     tumultuous        decade from 1970 to 1980. The neighborhoods
perceived            as having the greatest need for housing rehabilitation were
Angell,            McLaughlin,        Nelson    and    Nims.       Rental rehabilitation is a
pressing need in Angell, NcLeughlin and Nelson.
        Of     equal     or     greaterhowever, is the need for code
                                               importance,
enforcement  not only in conjunction with rental rebabilitation
efforts but also in stable but older neighborboods such as East
Muskegon, Nims and Lakeside. The concept of linking code enforcement
with rehabilitation strategies,                        proposed in the Housing Policy, has
never been fully implemented.
          The     effectiveness                of     the     Rehabilitation                   Assistence Program             in
 addressing            neighborhood                deterioration               can    be   limited by a number of

 factors.              Participation                 is at the discretion of the property
                                                                                          owner.
 Sometines§           substantial             investment            in     a       property does          not make good

 econonic         sense,           or   the    owner       cannot        afford      a   loan        necessary    to    bring
 the    unit          into        compliance.               In     still           other        cases     the     City    is
confronted            with the          question       of whether             to    extend assistance             a second
time.            In   time,        then,      the City may          find       it    appropriate          to    scale back
or        otherwise               alter       the     Program,           perhaps           by        making     assistance

available         Citywide         for       eligible       properties.

       Decisions             of    this        order       should be based upon a                     careful    analysis

of     program         impact           at     the     neighborhood level,                     and an assessment of
continuing            public       interest.           Until       that    time,         the    current       target    area
Concept      seems       a    workable         one.


Targeting Policies

1)     The      designation of rehabilitation targ
                                                   et                                arenas as well as program

       administration               itself          will,     to    the       extent       possible,          support   the

       City’s         planning          and        development          objectives,             as    expressed in the

     Master       Plan,       the    roning         ordinance,          and    the    Housing          Policy.

     Specifically,


     a)         Prograz           expenditures               will         not         be        used       to    support

                perpetuation            of    nonconforming             uses;

     b)         Rental        rehabilitation               assistance will be used judiciously
                                                                                               to

             elizinate                  blighting             influences                 and         expand      housing

             opportunities                   for     low    and    moderate          income      households.           Care

             will            be     taken           not       to         undermine              the     stability        of

             peighborhoods              characterized              by    owner       occupancy.
2)   Target    areas will     be   defined    at   three yesr intervals, in
     conjunction    with    preparation      for submission of the Grantee
     Performance Report.

3)   Target aress will not be changed until the objective of visible
      impact within the neighborhood has been achieved, and/or there
      has been a marked decrease in the interest level in the prograr.
4)   Within defined target areas, the program approach will be
                                                                       s,
      tailored to neighborhood conditions. Deteriorated neighborhood
                                                                 ctures,
      i.e., those with «a high percentage of substandard stru
                                                                     on,
      will be targeted for a combination of substential rehabilitati
      clearance,    and code enforcement directed at blighting
      influences.       Those neighborhoods experiencing destabilization of
      housing values, due to deferred maintenance or isolated instances ‘
      of blight,    will be treated with code enforcement and spot
      rehabilitation.
                                                                 the
4)    The Rehabilitation Assistance program will be supported to
                                                                  to
      extent feasible by infrastructure improvements necessary
      stimulate neighborhood reinvestment.
                                                          B7-179 &
                                               PRIORITY WORK CATEGORIES


     BACKGROUND ;

     The    need    for prioritizing rehab work item
                                                     s parallels the need for written
     Standards. _        Such priorities and objectives have
                                                             been debated for many years
     and have been, for the most Part
                                      , the center of many complaints.


     PROBLEM STATEMENT

 Debates over work priorities have rise
                                        n from clients, staff and inspectors
                                                                             and
 resulted in many disagreements over
                                     what can vs.                                 cannot be addressed by rehab,

 required Code items vs. cosmetic
                                  work, etc.                               While mechanical      items      (plumbing,
 electrical         and heating)           are consistently mandated for rehab
                                                                               assistance, other

 areas       are    in        need    of     formal    definition.              These   areas     include      roofs,

 storm/screens,               cabinets,      panelling       vs.    painting,       etc.      with    the    proposed
adoption       of       the    City's      Housing    Code    for    rehab, many of these areas will               be
addressed;          however,          firm    priorities       must        be     developed    and     consistently
applied.           No    specific         policy   exists    at     this    time; most areas addressed -are

matters of staff judgement and
                               client endorsement.


OPTIONS /RECOMMENDATIONS


An     orderly      method        for      identifying       rehab    priorities        must     be   established.
Generally speaking, this may occur in
                                      two phases:

1.     General      priorities address             very   basic concerns about housing preservation

       and other objectives of the program.

       A)    Health 2 Safety/Code - Deals with plumbing, electr
                                                                ical,                                 heating and
             Structural defects which may pose immediate
                                                         hazards to occupants.

       B)    Visual      Impact/Energy Conservation - Measures the visual
                                                                          impact of the

            blighting            influence         upon      surrounding            properties        and/or     the

            neighborhood             in    general.         This     may     be     characterized      as    broken
                                          -2-


                                                                                    ances of a
   door/windows, collapsing porches or other general appear
       uct ure .    Ene rgy   con  ser vat ion  mea sur es   are    tho se  dea ling with the
   str
       ent   nee  d  for   sto  rm  win dow s/d oor s,   roo fin g,    ins ula tio n, etc. An
   urg
             sho  uld  be    mad e  to   mak e   the   bui ldi ng    ene rgy -ef fic ient. An
   effort
                                                                                riteup.
   energy audit may be required at the time of inspection/w                                h the
                 Fac ail iti es   ~  Bat h   and   kit che n  fac  ili tie s   dea ls  wit
C) Interior                                                                           aus e both
                       ade qua  cy  of   the se   two  are as   as   pri ori ty,  bec
   condition and
     have a direct impact on the health and welfare of theersocc upants.
Specific priorities have been developed for use and und      tanding of which
            ms    are   nec ess ary    and   whi ch   are    sup erf ici al.       Specific
reh ab  ite
          ons   are  ran ked  bel ow  and  a cor rec tio n Cod e  fol low s.   Att ached is
designati
                                                                    designation.
a listing of common work items used and their proposed                        pli ance with
           y   app lie s to  ite ms  tha t are req  uir ed to  ach iev e  com
A) Primar                                                                     sing. This
      Jocal Codes, i.e., electrical, heating, plumbingexporectedhou to increase
      designation may also apply to items which are                                  addition,
                 ici enc y, “by  acc  ept ed  con ser vat ion  sta nda  rds .    In
      energy eff                                                                  con sidered.
                of  ite ms   in ter  ms of   nei ghb orh ood  imp act   wil l  be
      the value                                                                   on  pro perty
                      whi ch   hav e  @  not ice abl e   ben efi cia l  imp  act
      Those items                                                                  ,  wil l be
                     and    whi ch    ten d   to   enc our age    rei  nve stm ent
      appearance,
      considered priorities.
    Pri mar y /Op tio nal   des ign ati on  app lie s   to   ite ms  tha  t  are primary when
 B)                                                                          cor  rec tive action
    the con   dit ion   of  the   exi sti ng  ite m  is  def ect  ive  and
                ary .     The se  ite ms  are  con  sid ere d  opt ion al   whe n  the  condition
    is necess                                                                        action will
       of the existing item ig reasonably good and corrective
       extend its usefulness only.
                                                                 -3-



            C)     Optional designation applie
                                               s to items which are not
                                                                        primary but which
                   hevertheless      enhance          the   livability   of a      structure.       These   items    may
                  be addressed according to
                                                             the rate of deterioration,
                                                                                                     tho not at the
                  expense of the primar
                                        y objecti ves,                 nor    for cosmetic purposes
                                                                                                    only.

  CORRECTION CODE

  A.    Install        new    applies       to    the need       for   installation        of new materials,           of
        acceptable quality
                           to               correct an existing
                                                                defect.

 B.     Repair applies              to ‘the       need      to restore,       refurbish      or repair existing
        deteriorated materials
                               and/or defects.

 Cc.    Replace applies to the need
                                    to replace existing deteriora
                                                                  ted materials
        with the same or better
                                type and quality materi
                                                        als.
D.     Remove applies to the existenc
                                      e of a defect or condition tha
                                                                     t must be
       removed;       no other action            is necessary,

IMPACT/SUMMARY


It     is    expected        that    upon     the      establishment         of   firm,    consistent     and    fair
policy,          debates   over rehab Standards
                                                              vs.    cosmetic     work    will   be minimized,      if
not eliminated,              Further,   the       formulation of priority
                                                                          work               items will     clearly
State       the     program's       intent       as    health,      safety   and   housing       preservation,    as
Opposed      to    cosmetic    redecorating.
                                  PRIMARY



EXTERIOR                               I.     Interior


A.    Masonry                                 A. Structure


      sidewalk                                         ceiling structure
      driveway                                         wal] structure-bearing
      exterior flooring-masonry                        wall structure-partition
      masonry walls                                    floor structure
      foundation                                       trim structure
      ‘chimney                                         step structure
      footings                                         railing structure
      exterior steps-masonry                           closet wall structure
                                                       beams & supports
B.    Carpentry                                        door
                                                       door frame
       ext. decking wood                               door hardware
     - deck superstructure-wood                        hardware misc.
       ext. steps-wood
       ext. railings & supports       Il.     Code
       ext. trim
       ext. cornices                          A.       Electrical-Rough
       ext moulding
       ext. ceiling                                    new service
      window complete                                  wiring
                                                   1




      window sash                                      outlets
      window screen                                    switches
      window-basement
      window hardware                                  Piumbing-Rough
      window glass
      ext. door complete                               gas service lines
      ext. door screens                                water service lines
      ext. door hardware                               water tap
      rodent screen opening                            water meter
                                                       drain lines
C.    Roofing                                          water lines
                                                       vent lines
      roof structure                                   hot water heat lines
      roof sheathing                                   gas lines
      roof covering                                    radiators
      flashing-valleys/ridge                           toilet bend
      flashing-roof openings
      flashing roof edge                      C.       Heating


D. Insulation                                          hot water boiler
                                                       gas~forced boiler
       sidewall                                        gas gravity
      ceiling                                          electrical panels
      crawl space                                      gas space heaters
      heating duct .                                   elec. space heaters
      water systems
                                        IV.   Environmental

                                                       exterminate roaches
                                                       exterminate termites
                                                       exterminate rodents
                                                       rubbish/gargage storate unit
                                              PRIMARY /OPTIONAL


    -    Interior                                                 - paint steps
                                                                  ~ paint railing
         A.        Structure-Pre-Finish                           - paint closet
                    .                                             - paint cabinet
              -    plaster   ceiling                              -   paint shelving
              -    plaster   walls                                -   waterproof floor cover
              -    plaster   closet                               ~   waterproof step cover
              -    drywall   ceiling                              -   sand floor & finish
              -    drywall   ceiling                              ~   sand steps & finish
              ~ recover ceiling
              - recover walls                              B.     Features
        Be        Electrical-Finish
                                                                  ~   cabinets upper
             -    ceiling fixtures        .                       ~   cabinets lower
             -    wall fixtures                                   -   panel walls
             -    bath fixtures                                   ~   fabric floor cover
             ~    outside fixtures                                -   fabric step cover
             ~    appliance                                       >   sink top covering
             ~    utility fans

        C.        Piumbing Finish


             - water heater
             - kitchen sink
             - lavatory
             - toilet
             ~ tub

                        OPTIONAL

.       Exterior


        A,        Siding

                  exterior siding

        B.        Exterior Paint


               ext. paint openings
               ext. paint trim
               ext. paint sidewalls
             - ext. paint masonry
             - ext. paint ceilings & decks

        Interior

        A.        Structure-Finish

             - paint ceiling
             - paint walls
             - paint trim

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