THIS IS A DRAFT DOCUMENT OF THE SUBSTANTIAL AMENDMENT THAT HCD WILL FORWARD TO HUD. IT IS OPEN FOR PUBLIC COMMENT FOR 15 DAYS FROM THE DATE OF PUBLICATION ON THE WEBSITE. HCD WILL BE TAKING ALL COMMENTS AT NSP@acgov.org. Ms. Maria F. Cremer, Acting Director of CPD U.S. Dept. of Housing and Urban Development Office of Community Planning and Development 600 Harrison Street, 3 rd Floor San Francisco, CA 94104 Dear Ms. Cremer: RE: Substantial Amendment The Alameda County Housing and Community Development Department (HCD) requests approval of a Substantial Amendment to the Action Plan for its Neighborhood Stabilization Program 2 (NSP2), Grant Agreement #B-09-CN-CA- 0052 to add 17 new census tracts to its NSP2 grant to allow for greater program impact. Substantial Amendment: Request to add the following seventeen (17) non NSP2 approved census tracts: 4503, 4425, 4419.22, 4411, 4377, 4383, 4376, 4312, 4515.03, 4331.01, 4324, 4326, 4306, 4402, 4403.06, 4516.01 and 4336, and remove fourteen (14) census tracts; 4504, 4501, 4419.01, 4431.01, 4415.03, 4351.01, 4363, 4352, 4517.02, 4511.01, 4507.01, 4301, 4357, 4362 Rationale: In late 2010, both of the NSP 2 Development Partners (Hallmark Community Solutions and Habitat for Humanity East Bay) requested that HCD seek to add the NSP 1 census tracts to the NSP2 program to provide more consistency between four overlapping NSP programs (Urban County NSP 1, City of Hayward NSP 1, City of Livermore NSP1 Consortium and Alameda County NSP 2 Consortium). The Development Partners and HCD staff believed that this would provide better access to foreclosed properties in all of the NSP 2 Consortium communities where foreclosures and vacant units were causing blight and depressing property values. HCD undertook a two-part analysis to better understand the
Page 2 foreclosure activity occurring in each of the NSP2 jurisdictions, inside and outside of the approved census tracts. First, in December 2010 using data collected from Foreclosure Radar HCD conducted a point in time study and looked at recent foreclosures in the Alameda County NSP2 Consortium. Using GIS software, HCD mapped: Bank absorbed properties in Alameda County in late 2010 Residential vacancies in Alameda County in late 2010 Recent REO counts for properties eligible for NSP2 funding broken down by Mid- County, South County and East County These maps were very useful in illustrating that while there were some foreclosures located in NSP1 census tracts, a great majority of the foreclosures in the County were not located in either NSP1 or NSP2 approved census tracts (see attached maps). For example, in Mid County, where the heaviest concentration of foreclosures in the County has occurred, of the 308 total foreclosures, 192 (over 60%) of them are located in unapproved census tracts. This is the same situation in East County, where 58% of the foreclosures were located in unapproved census tracts. In South County, almost 40% of the foreclosures were in unapproved census tracts. In order to further support our analysis, HCD then conducted a study of foreclosures over a six month period of time in the Alameda County NSP 2 Consortium Jurisdictions. Using data collected from the Neighborhood Stabilization Housing Trust which receives foreclosures per jurisdiction (not census tract), HCD analyzed 600 properties which had come from the Trust. We found that while many of our NSP 2 census tracts had significant numbers of eligible properties, some had almost none. As expected, there were also census tracts with many foreclosures that were not part of NSP1 or NSP2. HCD then looked at NSP2 and NSP3 scores for each census tract and used this information to determine an average score. Although the NSP2 mapping tool can no longer be used to submit NSP2 applications, HCD utilized the tool to determine the NSP2 census tract need score for the census tracts it is interested in adding to its program. HCD also utilized the NSP3 mapping tool, and noticed that many of the scores had dropped significantly from NSP2 to NSP3. Below is a snapshot of the scoring analysis HCD used in making this request for Substantial Amendment to its NSP2 grant.
Page 3 Add Jursidiction Cenus Trct # of Prop. High Score Hayw ard 4377 12 17 San Leandro 4331.01 11 15 Fremont 4425 10 17 Hayw ard/fairview 4312 10 17 Hayw ard 4383 9 16 San Leandro 4324 9 16 Union City 4402 9 16 Livermore 4515.03 8 17 San Leandro 4326 8 16 Fremont 4419.22 6 14 Hayw ard 4376 6 16 Union City 4403.06 6 17 Dublin 4503 5 17 Fremont 4411 5 13 Uninc/Castro Valley 4306 5 17 Livermore 4516.01 14 San Leandro 4336 15 Average of all Census Tracts 15.88 HCD took the higher of the scores when determining the average application score for the new census tracts in the above chart, which equals: 15.88. However, as illustrated by the chart below, when combined with the census tracts already in the NSP2 program the average score is: 15.38, which is significantly under the qualifying threshold for NSP2 eligibility. However, when the lower performing census tracts are removed, the average score increases to 17.57, which is just.43 under the qualifying threshold and our original application score. This data supports HCD s assertion that adding the requested census tracts and removing those lower scoring census tracts will strengthen its ability to implement and manage its NSP2 grant.
Page 4 City Census tract High Score Notes Dublin 4503 17 Add Fremont 4425 17 Add Fremont 4419.22 14 Add Fremont 4411 13 Add Hayward 4377 17 Add Hayward 4383 16 Add Hayward 4376 16 Add Hayward/Fairview 4312 17 Add Livermore 4515.03 17 Add Livermore 4516.01 14 Add San Leandro 4331.01 15 Add San Leandro 4324 16 Add San Leandro 4326 16 Add San Leandro 4336 15 Add Uninc/Castro Valley 4306 17 Add Union City 4402 16 Add Union City 4403.06 17 Add Dublin & Uninc. 4507.21 18 Keep Dublin & Uninc. 4505 18 Keep Emeryville 4251 19 Keep Fremont 4417 19 Keep Fremont 4416.02 18 Keep Fremont 4414.01 18 Keep Fremont 4426 18 Keep Hayward 4381 19 Keep Hayward 4382.02 20 Keep Hayward 4382.01 18 Keep Hayward 4364.01 19 Keep Hayward 4371 20 Keep Hayward/cherryland 4356 18 Keep Livermore 4516.02 18 Keep Livermore 4514.02 19 Keep Livermore/Uninc 4513 18 Keep Livermore 4515.02 18 Keep Livermore 4512.01 19 Keep Newark 4444 17 Keep Newark 4446 20 Keep Newark 4442 18 Keep Newark & Fremont 4443 18 Keep Newark 4441 18 Keep Pleasanton/Uninc 4507.03 18 Keep Pleasanton 4507.22 18 Keep Pleasanton 4506.02 18 Keep San Leandro 4334 18 Keep San Leandro 4325 18 Keep Uninc/Ashland 4338 18 Keep San Leandro 4339 18 Keep Uninc/Castro Valley 4302 18 Keep Uninc/El Portal Ridge 4305 18 Keep Uninc/San Lorenzo 4337 18 Keep Uninc/San Lorenzo 4358 18 Keep Union City 4403.09 19 Keep Union City 4403.01 18 Keep Union City 4403.02 19 Keep Dublin 4504 6 Remove Dublin 4501 1 Remove Fremont 4419.01 5 Remove Fremont 4431.01 2 Remove Fremont 4415.03 2 Remove Hayward/5 Canyons 4351.01 9 Remove Hayward/Fairview 4363 14 Remove Hayward/Fairview 4352 15 Remove Livermore 4517.02 3 Remove Livermore/Uninc 4511.01 3 Remove Pleasanton/Uninc 4507.01 2 Remove Uninc/Castro Valley 4301 4 Remove Uninc/San Lorenzo 4357 15 Remove Uninc 4362 16 remove Average of All 15.38 Average of Keep + add 17.57
Page 5 Alameda County Housing and Community Development Department (HCD) does not anticipate that the requested Substantial Amendment would negatively impact the original score received on our application. In fact, approving this amendment will increase our ability to obligate and expend NSP2 funds. Thank you in advance for your prompt consideration of this request. Should you have any questions or require additional information, please do not hesitate to contact me at (510) 670-5207, or by email at michelle.starratt@acgov.org. Sincerely, Linda M. Gardner Housing Director cc: Rebecca Blanco, HUD NSP Representative G:\HCD\NSP\NSP 2\taw substantial amendment re census tracts June 2011.doc