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01-27-75 agenda:,...: ra .~ - CITY OF RICHFIELD, .MINNESOTA Office of $xecutive~ Director _ HR.A' Letter No . 3 January 27,• 1975 'Housing and Redevelopment Authority' Commissioners Gty of Richfie d Gentlemen: Subject:' HRA: Staff Report At the, November. 18; L975, Housing and Redevelopment Authority special meeting, staff gave a report. on: 1 . -Responsibility and duties of the HRA . 2. Community' T~evelopment Act Title II. 3. Tentative~Work Program. -At that time, the Housing and-Redevelopment Authority asked <staff toupdate ahe report to allow-for new developments and present to the Housing and'Redevelopment Authority at a .later date. ,The information .contai,~~d;~iri the staff report; is most. currents .However, some caution should be exercised .in .that the final regulations .:for "Lease Existng:Housing" have-not been published. ,Also this is a new federal government program and some :changes. will probably be made throughout the year. Respectfully submitte ~~ ~~~ raaff Wayn . gg Executive: Director WSB/blj cc:: Planning: Director THE HRA 1. Summary of Responsibilities 2. Community Development Act Title II • 3. Tentative Work Program • Staff Report December 26, 1974 '~ c The need for low income family and senior citizen housing has been established, The Housing and Redevelopment Authority has been organized and the 1975 budget • has been certified to the Hennepin County Auditor. Where do we go from here? To help answer this question the following Three Major Issues are addressed. 1. The future role of the HRA~ 2. The housing and development tools available to the HRA. 3. The proposed schedule for accomplishment, The Housing and Redevelopment Authority (HRA) is a public corporation. In general, the HRA has three primary purposes:(1~ to To protect and enhance the financial stability of the City of Richfield: a.o by encouraging and assisting the production of well planned low and moderate income housing, bo by encouraging, assisting and providing incentives to private enterprise • to invest funds in development and improvement of commercial areas, c. by the prevention and elimination of deterioration and blight. 2~ To protect and promote the welfare of the Richfield citizen: a® by reconstruction, rehabilitation and modernization of deteriorating areas, b. by providing decent, safe and sanitary housing for low income families, including handicapped and elderly persons. c. by providing public improvement in areas where deterioration is taking place. 3. To assist and encourage citizens to eliminate blighting conditions and existing deterioration: a. by conservation and rehabilitation of existing neighborhoods, and bo by development and improvement of commercial areas. Source:- innesota tatute ~~ • -2- • PROGRAM PLANNING ~ MANAGII~IFFNT Specifically the Richfield HRA is a housing management development corporation which will be involved with action planning for commercial improvement, housing and development. These Program Planning and Management responsibilities include: 1. Developing plans and programs. 2. Review Plan developed by a Development Group or Development Corporation. 3. Federal Grants. 4. Management Policy Planning. Developing Plans ~ Programs With the assistance of staff and existing advisory groups, the HRA should develop beoth a "Housing Assitance Plan" and a "Community Development Program". The Housing Assistance Plan • This management tool will be completed under Contract with the Metropolitan Council. In general, the plan is (1) to accurately. survey .the. coridtions of the local housing stock; (2) to assess the housing needs of lower income ~.~ persons residing or expected to reside in the community; (3) to specify a realistic annual goal for assisted housing, including new development, rehabilitated, and existing units; (4) to identify general locations of proposed housing for lower income persons with the objectives of (a) revitalizing the community, (b) restoring or rehabilitating stable neighborhoods, (c) promoting greater choice of housing opportunities, (d) avoiding undue concentrations of assisted persons, and (e) to assure availability of public facilities and services to serve proposed housing project. (2) Overall, the function of this plan is to tie together local housing activities closely with the community development activities and to put new emphasis on local housing services. If the Richfield HRA takes advantage of Community Development Program Funds, Community Deve opment Fun s re er to ale o t e Community eve opment Act of 1974. _3_ the 1974 Community Development Act makes the linkage between Community Development (CD) and Housing in the statement of "Findings and Purposes". These purposes include: 1. Addressing critical problems arising from inadequate public and - private investment and reinvestment in housing. 2. Suggesting "the conservation and expansion of the Nation's housing A , ~ stock in order to provide a decent home and a suitable living environment for all pexsons, but principally those of low and moderate income." 3. "Purusing the reduction of the isolation of income groups within communities and geographical areas, and the promotion of an increase in the diversity and vitality of neighborhoods." Once the Housing Assistance Plans is built into the functioning of the HRA and City, there are implications that new, ongoing local housing services will be added, such as technical services to insure quality in the design and development, as well as the-long-term management of assisted. housing and the gearing of the municipal service structure to assure the maintenance of sound residential developments and neighborhoods over the long run. Community Development (CD) Plan ..and Program The Community Development plan is a three year plan which identifies development needs, specifies strategies to satisfy the needs, and provides both-short and long range objectives. The Community Development Plan is similar to the City's Capital Improvement Program. The CD plan must be specifically designed with the goal to prevent blight and deterioration and to provide improved. community development facilities and services and public works improvements. The Community Development Program is similar to the City's Capital Budget. • The,CD program indenitifies all the funds to be used in any fiscal year. ...Appropriate environmental factors and social factors must be taken into account -4- in preparing the CD program,.,; Review Development Group Plans The HRA-will actively review Plan developed by Development groups, e.g. Lyndale/Hub/Nicollet Commercial Improvement Committee. The HRA will be reviewing and approving for submission to the federal government, the state government and foundation grant applications for housing related services, and commercial improvement and development. Management Policy Planning The HRA will be developing management policies for such things as site selection, and selection of developers. Also, construction management will all be the responsibility of the HRA and its staff. • HOUSING MANAGEMENT The HRA will also be involved in housing management and policy development. For example, the HRA will be responsible among other things for the development of the following housing management areas: 1. Developing procedures for determining the amounts of family gross contributions and housing assistance payments. 2. Development of tenant selection criteria and preparation of an affirmative marketing program, This includes the advertisement of availability of housing and inviting owners to make housing units available for lease. 3. Determination of tenant eligibility guidelines in accord with fair market rent schedules as established by HUD. 4. Development of policies for housing quality standards and certificate holders packets, This includes training sessions for tenants on their responsibilities and the owners responsibilities and sessions on housing quality standards. 5. Procedure for the approval of leases and maintenance of relations with owners. 6. Determining procedures for: a. Contract enforcement. -5- b. Authorizations for evictions. • c. Compliance with equal opportunity requirements. d. Executing bills and receiving funds. e. Contracting with the city and other groups for services. 7. Carrying out a performance report to HUD. REHABILITATION/NEW HOME PROGRAM (SPO'T'RENEWAL) In the area of rehabilitation the HRA will be responsible for developing policies and receiving plans for the rehabilitation of existing housing units. A related area is the new home program. The HRA will develop policies and monitor the new home program on a continuing basis. CONIl~.RCIAL Il~IPROVEMENT AND DEVELOPMENT In the area of commercial development, the HRA works with and assists the: Commercial Improvement Committee • The HRA will not only participate in planning but be directly involved in the following.,: 1, Establishing and managing public funds for tax increment financing within a development district or project area. 2. Relocation and displacement of businesses-and people and insuring that these groups are equitably treated., including relocation payments. 3. Securing investors; developers, new businesses rela~iYe to the market and-the site assembly available for redevelopment and improvements. The I-IRA also is responsiile to help existing business, and to develop implementation methods which increases the city's financial resources. 4. Providing Capital Improvement in the Commercial Area through Community Development ,Funds and Revenue Bonds. There are four areas where the HRA should be developing the ability to deliver ° .. _6_ subsidized housing.3 These-areas are: 1. Traditional public housing. 2. Housing Assitance Payments (HAP, Section 8). 3. Moderate Income Housing (Section 207). and, 4. Rehabilitation. TRADITIONAL HOUSING Subsidized low income housing or traditional public housing can be delivered to very low income seniors and families.4 .The method of delivery can vary. e.g. financing a private developer, building a new structure and turning it over to a housing management agency, purchasing or leasing an existing structure or housing units within a structure. Under this traditional public housing arrangement, HUD (Department of Housing and Urban Development) will pay both the principal and interest up to a 40 year mortgage. In addition, the following costs ..are paid by tenant z°ents: 1. Operating costs, .including HRA staff, utilities. 2. Maintenance of the project, e.g. repair of light fixtures. 3. Special program costs, e.g. Christmas party for seniors. 4. Payment of 100 of the rent in lieu of taxes to taxing jurisdiction. e.g. the Austin, Minnesota HRA pays $11,000 annually in lieu of taxes to the taxing jurisdiction for its senior citizen housing project. The $11,000 comes 1000 from rents receivable. SUBSIDIZED HOUSING ASSISTANCE PA1'MEIVTS (HAP) is for lower income families including the elderly. Under this program the HRA may lease existing units or may contract with a developer or encourage a developer to build a new apartment or single family structure. This type of program also allows for the substantial rehabilitation of existing apartment structures, Title I Community Deve opment ct o 4. The Department. of housing ~ Urban Development does not intend to establish any new Traditional Public I-ioizsing Pro~;raJ~t, unless MAP fails to meet the needs. However, it is impori.ant to understand tn~~ ~.:raditional program as it will con-trast faith I?AP . -7- Lease Existing Relative to leasing existing housing units some of the particulars are: 1. An Annual Contributions Contract (ACC) is entered into with HUD. 2. Assistance payments to prospective tenants for occupied housing units (leases) are made for not less than one month or more than 15 years. The landlord is guaranteed a vacant 70% lease arrangement of 60 days provided he actively seeks a tenant. 3o Selection of the .tenants is the function of the landlord subject to Ii;J])-II':A established eligibility and selection criteria. 4. The housing units are 100% taxable. New Construction Relative to new construction, some of the particulars are: 1. HUD may deal directly with private developers or with the HRA. The • latter being more likely because of the existing financing market. The HRA may pledge the Annual Contribution Contract amount to finance Construction Revenue Bonds. The private developer may not pledge Annual ;C~ntribution Contract for financing. 2. Anew apartment structure may contain all ranges of income. However, only the ].over income units are subs~_dized. This accomplsh'~°goal of not concentrating low income people in any given axes. 3. The HUD contract for payments to the owner can be for one month to twenty years.- If the owner is the HRA the contract can be for 40 years. This contract period along with the ability to pledge ACC makes it more feasible for the HRA to build and manage the project. 4. All ownership, management and maintenance responsibilities including tenant __ .. selection and eviction are assumed by the owner. Evictions must be revie~ by the HRA. 5. The developer, or HRA, may use the mortgage insurance under 22I(d)`(3) of :~ , _g_ the National Housing Act to finance the housing project. 6. The housing structure is 100a taxable from a real estate tax point. Who would qualify for low income traditional housing, and Housing Assistance Payments, and how does the process work? The Office of the Assistant Secretary for Housing (HUD) has not as of this writing promolgated the rules for these existing housing programs. However, some cautious insite can be gained by looking at the old Section 23 rules and how other cities determined low income eligibility. Eligibility Income The eligibility limits (upper gross income limits) for individual living in subisidized housing is determined by the HRA within a maximum set by HUD for Hennepin County. Each tenant's gross income is reviewed annually, (biannually for elderly) to determine if the tenant is still eligible for._subsidized housing. The HRA must also establish an upper net income limit. This is done by first deducting military disability payments and last summer's increased social security benefits. The HRA may also establish other deductions, beside military disability and increased social security to arrive at net income limits, Example: Applicants gross income $6,000 (2 person family) Less: military disability payment 2,000 Increased social security payment 1,000 Child support (optional) 400 Net Income $3,600 It is the perogative of the HRA, within HUD maximums, to establish income limits. There are no' asset Limits on the new housing program. The HRA is also responsible to set "continued occupancy income limits". The purpose of the continued occupancy is to provide incentive for the tenants to increase their income and yet not be evicted from the subsidized housing units. The "continued occupancy" income limit is usually set at approximately 1250 of "initial occupancy income limit." -9- Example: (St. Louis Park) Eligibility Income Limits ` One Person Initial occupancy $3,400 Continued occupancy 4,300 Selection of tenants Two People $4,700: 5,700 Etc. The policy for'selection of tenants is established by the HRA. However, the preference criteria policy must include in any priority order: 1. Families including elderly displaced by public action. 2. Veterans and servicemen's families. The HRA should develdp additional preference criteria. For example: 1. Rent paying ability of the applicants 2. Applicant's age, disability or handicap. 3. Urgency of housing needs, e.g. being evicted tomorrow. 4. Richfield resident. Note: Although residency can be part of • preference selection criteria policy, it can not be made a ree{uirement for occupancy. Detertftning Rent Eligibility income limits were discussed above. Eligibility income and rent paying .income are different. Each eligible tenant must pay not more than 25% nose less than 5% of his/her income toward gross rent. Gross rent is determined by 25% of adjusted incomeo To determine adjusted income (rent paying income) the previously arrived at eligibility figure is adjusted with the following deductions: 1. 5% gross income for families. 2. 10% gross income for elderly and handicapped. 3. $300 deduction for each secondary wage earner. _4. Medical expenses in excess of 30 of income. 5, Unusual occupation expenses. ~~ -10- Example: Elderly tenant gross income- $3,000 (no military disability income payments) Less loo gross $300.00 Wife is secondary wage earner 300x00 Medical expenses in excess of 3% 310.00 Unusual occupational expenses 30.00 Total deduction $940,00 Rent is calculated on this income $2,060 Gross Annual Rent (includes utilities) $515.00 (Not more than 25% net nor less than 50 of gross.) Gross monthly rent (includes utilities) 42.95 Determining Rent Payments (Fair i~iarket Rents) Fair Market Rent (FMR) is the scheduled amount which HUD will pay for a given S housing unit size. Example: two bedroom unit $135 - FMR (250 of occupants income assuming a monthly income of $250) 62.50 HUD contribution FMR minus 250 tenants contribution 72.50 plus HUD administrative contribution 7.00 Total HUD Contribution $ 79.50 per unit/per month The present Fair Market Rents (FMR) for Hennepin County are less than the open market rents, However, HUD has indicated that an increase adjustment of up to 80o will probably occur in 1975. The strategy in maximizing the ACC (Annual Contribution Contract )5 is developed in the Affirmative Marketing Plan, Given a FMR and also given eligible tenants with a range of income, a . cc is t e grant to t e o is is one on an annua asis or years, -11- balance point of high, low income and low, low income should be reached. • This type of balancing is known as income range stirategy. For example, one tenant may have an income of $250 per month, another an income of $125 per month and still another an income of $375 per month. Assuming the HRA approves leases for only the people with $125 per month income, the result will be, given the FMR, an expenditure of funds with little production of units or placement of people. Now, assume the HRA balances the approval of leases relative to income ranges. The ranges may be twenty five. percent to people with incomes of $125, 25% to people with incomes of $375 and 50a to people with incomes of $250, and the result would be getting as many people housed who need subsidized housing and at the same time maximizing the Annual Contributions Contract. INCOME RANGE STRATEGY - Example only Fair Market Rent (FMR) for a 2 bedroom housing unit is $135. Annual Contribution Contract (ACC) 1. Person with $125 monthly income FMR 25o inc. HUD Contribution Plus HUD Cont.-Adm. Total Contribution $135.00 31.25 103.75 :$200,.000 7.00. $110.75 per month x 12 = 1,329 per year Number of units possible to lease (Acc - total contribution per units) - 150 units 2. Persons with $250 monthly income FMR 25o inc. HUD Contribution Plus HUD Cont. Adm. Total Contribution $135.00 62.50 72.50 7.00 79.5D-per month x 12 = $954 per year. ~1 , '. -12- Number of units possible to lease (ACC-total contribtuions per unit) - 209 units 3. Person with $375 monthly income. FMR $135.00 25% into 93.75 HUD Contribution 41.25 HUD Administration 7.00 Total Contribution 48.25 per month x 12 = $579 per year Number of units possible to lease (ACC-total contribution per unit) - 345 units The purpose of the Housing Program is to house low income people. The income range of maximizing different incomes allows the HRA to maximize this principle and yet create income mixes (Nonconcentration). .: $125 income person 250 of units = 38 units (25% of ACC - total contribution) ($50,000-$1,329) $375 income person 250 of units = 86 units (250 of ACC - total contribution) ($50,000-$579) $250 income person 50a of units = 104 units (50% of ACC - total contribution) ($100,000 - $954) Total units leased 228 Units DIRECT LOANS TO DEVELOP MODERATE INCOME ELDERLY HOUSING (Section 202) This is an interest subsidy program much like Section 236. The program is for moderate income elderly and handicapped persons. The income limits of the program are established by HUD and are based on 135% of the Housing Assistance Payments. There-:;are no any asset limitations. Example: • Assuming Housing Assitance Payment income limit $6,000 Section 202 income l~.mit -($-6,000 x 135%) 8,100 The tenant. in this situation (Section 202 pays rent equal to the open market rent less whatever savings are available to the owner due to the interest subsidy and -13- the 50o tax reduction.` UPPER MODERATE INCOME PROGRAM (22143) offers advantages gained through mortgage insurance and-the 50% tax reductions on units financed by 221 d program. REHABILITATION PROGRAM is offered by both the State of Minnesota (Housing Finance Agency) and HUD. The program provides low interest loans and grants for the rehabilitation of existing housing. -14- • Can be used for: 1, Public improvementsin development district or project area. 2, Land assembly of small parcels and demolition of structures for resale. 3, Write down of land price to make it more marketable. Who can use it• City Council in a development district .(development districts are limited in size) City Council through HRA (in project area) A. More flexible than development district. B. Not covered by fiscal disparities act. How it works• The idea is to use increased taxes which are stimulated by new development to promote continued economic development and improvement. This is a financial tool use and • controlled locally. What does it do: 1. Provides a means to make existing land marketable in a competitive system. 2. Provides a means to create a cash flow from redevelopment to provide public improvement and improve the business climate (parking, landscaping, theme for mass marketing) 3. It is a tool to change any obsolete characteristic of the shopping area - redo old buildings. 4. It provides a means to offer a developer or businessman an incentive to improve property or redevelop property. What is needed: 1. The establishment of a development district or HRA project area, 2. A redevelopment plan/improvement plan. 3. Approval by the City Council -15- ~, TAX INCREMII~IT FINANCING EXAMPLE • 1. Original taxes on original taxable valuation of $51,500-are $1,590. Tax increment procedure freezes the $51,500 value. 2. Tax implement procedure: Acquisition cost $51,50Q Clearance cost 10,500 Administrative costs 9,300 Gross total cost $71,300 Ld`written down and sold to developer for 27,300 Net project cost $44,000 3. New development has taxable value of $133,000 which produces $6,500 in total property taxes. 4. Tax increment amounts to $4,910 ($6,500 less $1,59b = $4,910). 5. The net project cost of $44,000 is divided by tax increment of $4,910 plus • interest cost to determine number of years required for write-off. • -16-, EFFECTS OF TAX INCREMENT FINANCING USING EXAMPLE ON PREVIOUS PAGE Given Valuation Frozen Effects on School District (Largest taxing unit) Annual tax yield to School District on $51,500 value (54.50) $ 867 Total tax yield 1,590 Note: Taxes on parcel of land are not frozen, but vary with incrases and decreases in the mill levy. Annual inflation, appreciation 1,060 $51,500 at ~o annual Annual tax yield on $2,060 (due to inflation) 88 . Lost tax yield on inflation ($2,060 value) ($88 x 5.45) 1%3 recovered by state aid Total shifted temporarily to taxing district (which includes Southdale) Effects on City County Special Units Annual tax yield from frozen value City (15.20 of $1,590) County (30.30 of $1,590) Special units Annual tax yield on appreciated value City (15.2% of $88) County (30a3o of $88) Special Units (less than $1.00) $51,500 48 16 32 $ 242 480 1 13 27 County tax yield of inflation value ($27) is spread over entire .county City tax yield on inflation vale ($13) is spread over entire city. -17> Gains Short Range New development value New development stimulated (7% private investment stimulation by investment 'of $133,000 new .development) Short range gains Less $88 inflation value Less frozen value original tax. Net annual short range gains Long Range New development stimulated Inflation value on new development at end of payback period on tax increment ($.202,.000 annual tax Net total annual tax yield (Long range gain) $133,000 9,310 9,310 T~;xed X5'30 430 $2,020 88 $1,932 1,590 $ 342 $ 430 8,605 $9,035 • • • 1 ~ ~ TENTATIVE RICHFIELD HOUSING AND REDEVELOPMF.,I`i`I' AL"~'HORITY WORD PROGRAM Objective 1, February, 1975 Develop a Richfield Housing Assistance Plan. After this is completed the remaining work program should be re-evaluated and preliminary staffing arrangements should be made by this time. Objective 2, Marcy, 1975 Formulate housing assistance payment grant applicatior. and submit it to the City Council for approval and to HUD for funding. Objective 3, April, 1975 Develop housing management policies. .Objective 4, April, 1975 Arrange leases with existing owners. Begin to take applications for Housing Assistance Payments. Objective 5, November, 1975 Apply for preconstruction loan, select site, preliminary architecture, start to take tenant applications. • Objective 6, December, 1975 Start to implement housing rehabilitation program with various neighborhood committees. Objective 7, February, 1976 Apply for construction grant and reapply for Housing Assistance Payments (annual contribution contract). Objective 8, October, 1976 Site acquisition, final architecture, select developer, and relocation. Begin Construction. Objective 9, February,. 1977- April, 1977 finish Construction. Objective 10, June, 1977 Develop activity program with "tenant council". {' ;t_.1~,~ ~~.,,~ ~'G(„(/jJ !1 /L~/ti/~.d'~v /~J~/r+....-w- /T " v ~ +.~.t~ ~...A- ~ ~~/ ,,. Minneapolis-St. Paul: Metropolitan Area. Thee rent limits are considerably lower for existing. units han for newly-constructed or rehabilitated units. They are designed to reflect the "going rate" for standard, but modest, rental units . Revisions in the. fair. market rents for existing housing are expected soon, and are likely to involve increases in the fair market rents.. The newly-revised fair market rents for new construction and substantial rehabilitation are listed below: - Number of Bedrooms 0 1 2 3 4 or more Structure Type` Detached _ 34.8 420 471 Semi-detached/row' - ..298 344 39.7 420 . Walkup 216 246 289 394 - Elevator 225 258. 319 - - Thn -fair market rents for' existing housing, not yet revised, are. as follows: Size of Unit Fair 1Vlarket.Rent 0 -Bedroom $ 126. 1 -Bedroom 7.43 2 -Bedroom . 368 ~ , 3 -Bedroom 193 4 -Bedroom 218 Eligible Recipients of Assistance `(Moderate) {Low) Lower Income ..Very Low Income 7?amity Size 80% of Median 50% of Median 1 $ 7,800 $ 4,700 2 _ 10,000_ 6,250 11,250: 7,050 4 12,500 7,800 . 5 13,250 8,450 6 14,050: 9,050 7 , _ _ 14,850 9 , 7.00 .. 8 or more 15, 600 10,:300 Both fam.iaies -and the elderly are eligible for assistance. This program may be able to serve up to 40 per cent of the Area`s population, including persons ineligible because of income under previous subsidized housing programs An example of rental assistance follows: Adjusted gross income $200/month, Amount to be spent by tenant on rent (2 5 % of income) 5 0/month Normal: fair .market rent of unit 150/month >HUD rent assistance payment 100/month • CITY OF RICHFIELD, MINNESOTA Office of Executive Director HRA Letter No . 2 January 27, 1975 Housing and Redevelopment Authority Commissioners City of Richfield Gentlemen: Subject: Formation of Ad Hoc Housing Committee At the November I8, 1974 meeting of the Housing and Redevelopment Authority there was informal discussion concerning desirability of a group of individuals to advise the HRA on housing matters'. .The. staff recommended at tha t time that it would not be advisable to create another full fledged advisory commission for this. purpose. There was a so some consideration of an ad hoc committee with repres- entatives from various city commissions and public interest groups. • Since that time there have been o r pportunities fo_ representatives _of the.. city staff. to discuss the housing capabili*.ies of the HRA with the Senior Citizens Advisory Commission, the Human Rights Commission, and the Planning Commission. ....This subject has also been discussed with representatives of the League of Women Voters, the Chamber of Commerce and the Commercial Improvement Committee. .While it does not at this time appear to be desirable to create a formal advisory commission, it is the recommendation of the executive .director that the authority support the creation of an ad hec committee to review the housing assistance plan now being developed. and to provide the HRA with informal advice in the area of housing programs . It' is suggested that the membership of the ad hoc committee be limited to representatives from the three city commissions mentioned previously with each of the commissions designating their representative(s) to serve on the ad hoc comm- ittee. It would also seem i~:~gical that the ad hoc committee might wish to meet with representatives of the League of .Women Voters, the : Chamber of Commerce and the Commercial Improvement Committee in their review of the housing assistance plan and formulating advice and recommendations on the subject of housing for the Housing and Redevelopment Authority. . - Respectfully submitt~' (, ,, ~ ~~ o Wa n /~5. Bur raaff (.~- Y 9' gg Executive Director cc: Planning Director