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County of Hawai ` i
Office of the Mayor
25 Aupuni Street,Suite 2603 • Hilo, Hawaii 96720 • (808)961-8211 • Fax(808)961-6553
KONA 74-5044 Ane Keohokalole Hwy-,Bldg C • Kadua-Kona, Hawai'i 96740
(808)323-4444 • Fax(808)323-4440
December 3, 2019
Mr. Mark A. Chandler
Director, Office of Community Planning and Development
U.S. Department of Housing and Urban Development
Honolulu Field Office -- Region IX
1132 Bishop Street, Suite 1400
Honolulu, Hawai'i 96813
Dear Mr. Chandler,
RE: ANNUAL COMMUNITY ASSESSMENT REPORT (PY2418)
The County of Hawaii (County) has received HUD's Annual Community
Assessment Report for Program year 2018 which reflects the County's efforts in
ensuring compliance with HUD's program rules. There are many accomplishments to be
commended, including our Community Development Block Grants (CDBG) program for
meeting its program timeliness requirements and our Continuum of Care program with
opening its first Family Assessment Center, but there are several issues that the County
would like to address.
One of the issues was that the County did not include a discussion of the recent
lava flow disaster and the impact on the community in its annual Consolidated Annual
Performance and Evaluation Report (CAPER). The volcanic eruption began on May 3,
2018 and lasted for approximately 4 months resulting in 8,488 acres of land inundated
with lava and 875 acres of new land created along the shoreline. There were 716
structures destroyed with 3,000 residents being displaced. The County acknowledges
that the disaster wasn't addressed in its CAPER, however, the County continues to
work to identify resources and opportunities to assist communities that were affected by
the disaster.
The County was informed of the Community Planning Development (CPD) M19-
015 finding to the Continuum of Care (CoC) Coordinated Entry issued to the Bridging
the Gap (BTG) via Hawaii Island Home for Recovery (H1HR) program monitoring. As
County of Hawaii is an Equal Opportunity Provider and Employer
December 3, 2019
Page 2
required, the BTG provided a timely written response to CPD to document the updates
made to its policies and procedures manual for its Coordinated Entry System (CES) to
increase the capacity of its access points, to address the timely referral of persons
experiencing homelessness to available housing units and training of staff who are
required to comply with the CES. On November 22, 2019, the BTG was informed that
the CPD Finding M19-015 was closed and no further action needed to be taken. The
County is committed to ensure that appropriate and on-going training is conducted with
all program providers to ensure compliance with the written CES policies and
procedures.
Lastly, the County being identified as a High-Risk grantee is of great concern.
CDBG-DR funds are a critical resource to the recovery of Hawai'i Island after the
devastation caused by the 2018 volcanic eruption. The County acknowledges that any
appearance of misrepresentation was completely unintentional. As a potential grantee
for the CDBG-DR funds, the entire planning process, compounded by the uniqueness of
the volcanic disaster posed even greater challenges for the County to implement a grant
of such a substantial amount without prior experience. Since then, we have officially
organized a Disaster Recovery Team under the Planning Department. Key
departments include Research and Development, Planning, Office of Housing and
Community Development, Finance, Civil Defense, Consultant Tetra Tech, as well as my
office who are working together to develop plans and strategies for the use of the
CDBG-DR funds. The grant will be administered by Douglas Nam Le, who has prior
experience managing CDBG-DR funds on the East Coast with Hurricane Sandy.
Thank you for the opportunity to comment.
Sincerely,
Harry Kim
Mayor
c: Duane Hosaka, Administrator
Office of Housing & Community
Development
County of Hawaii is an Equal Opportunity Provider and Employer
'ptuEYr Or U.S.Department of Housing and Urban Development
zHonolulu Field Office-Region IX
IU 1132 Bishop Street.Suite 1400
A . Honolulu,Hawaii 96813
http.l/www.hud.gov
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December 16, 2019
The Honorable Harry Kim C-,
Mayor of the County of Hawaii rn
25 Aupuni Street
Hilo, HI 96720 co -71
Dear Mayor Kim:
LlSUBJECT: Final Response to Annual Community Assessment Report
w
Program Year 2018
The U.S. Department of Housing and Urban Development (HUD) received the County of
Hawaii's (County's) comments provided by letter, dated December 3, 2019, responding to
tl HUD's assessment of the County's 2018 Annual Community Assessment (ACA) Report.
HUD acknowledges the additional comments and clarifications provided by the County.
The ACA is considered final, with no changes being made to the original report. This letter
should he included as part of the County's ACA process for review of Program Year 2018.
Please consider the report final and slake it available to the public. It is recommended that you
make the report and correspondence available in the same way you handle your regular program
reports: by providing a notice in the newspaper, identifying the report contents and where it is
available for review.
If you have any questions, please call me at 808-457-4679.
Sincerely,
ark A. Chandler, Director
Office of Community Planning
and Development.
cc:
t/%lr. Duane Hosaka
Housing Administrator
Office of Housing and
Community Development
1990 Kino'ole Street, Suite 102
Hilo, HI 96720
LASERFICtaE I
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November 4, 2019
The Honorable Harry Kim
Mayor of the County of Hawaii
25 Aupuni Street
Hilo, HI 96720
Dear Mayor Kim- 1
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SUBJECT: Annual Community Assessment Report
Program Year 2018
This letter is to convey HUD's assessment of the County of Hawaii's (County's)
performance for its 2018 Community Planning and Development(CPD) Program Year. The report
reflects the County's efforts to ensure HUD program compliance. As part of HUD's annual review,
the Department wants to take this opportunity to address the Community Development Block Grant
(CDBG) program timeliness requirements,and the importance it plays in ensuring that the intent of
the CDBG program is achieved.
HUD CDBG regulations require recipients to carry out their CDBG activities in a timely
manner, thus ensuring low- and moderate-income persons are assisted. The standard requires
grantees to he at a 1.50 CDBG timeliness ratio 60 days prior to the end of their program year. HUD
is pleased that on the test date of May 2, 2019, the County had a CDBG timei inea, ratio of 1.47.
The enclosed Annual Community Assessment Report reflects HUD's assessment on the
County's implementation of its CPD programs. Please note that the report identifies the County as
a High-Risk grantee due to issues related to misrepresentations by the County in regards to HUD's
CPD programs. Of concern is that in the last three years the County has either mispresented a
situation or identified a regulatory loophole to allow misleading information to influence program
decisions. The first involved HUD's environmental review process on a major housing
development at the end of the last County administration, and the second involves the County's
current efforts to secure CDBG-DR funding directly to the County.
The County will have 30 days from the date of this letter to comment on the report. Should
the County not wish to comment on the report, or fails to comment within the above time period,
please consider the report final and make it available to the public using your standard notification
process. Should you have questions regarding our assessment, please call me at (808)457-4678.
Sincerely,
Mark A. Chandler, Director
Office of Community Planning
and Development
Enclosure
2
cc:
Duane T. Hosaka(w/enclosure)
Housing Administrator
Office of Housing and
Community Development
50 Wailuku Drive
Hilo, HI 96720
Enclosure
IV'
ANNUAL COMMUNITY ASSESSMENT REPORT
County of Hawaii
2018 Program Year: July 1,2018 to June 30, 2019
HUD Point of Contact: County Point of Contact:
Marsha Ito Mr. Duane T. Hosaka
Community Planning and Housing Administrator
Development Representative Office of Housing and
HUD Honolulu.Field Office Community Development
1132 Bishop Street, Suite 1400 County of Hawaii
Honolulu,HI 96813 50 Wailuku Drive
(808)457-4679 Hilo, HI 96720
(808) 961-8379
Introduction
The Housing and Community Development Act of 1974,as amended, and the National
Affordable Housing Act of 1990, require federal grant recipients receiving federal assistance
under the Act to submit an annual performance report disclosing the status of grant activities.
The Department of Housing and Urban Development(HUD) is required by 24 CFR 91.525 to
determine whether the grant recipient is in compliance with the statutes and has the continuing
capacity to implement and administer the programs for which assistance is received. In
accordance with 24 CFR 91.525, our comments below incorporate our assessment of the County
of Hawaii's (County's)Program Year 2018 (PY18) performance.
In assessing the County's performance, HUD relied primarily upon the County's PY18
Consolidated Annual Performance and Evaluation Report(CAPER), technical assistance, remote
monitoring, and communications with the County's federal programs staff. During this period,
HUD has determined that the County generally met the intent of the Community Planning and
Development(CPD)programs. Based on the County's accomplishments through the
Community Development Block Grant (CDBG), HOME Investment Partnerships Program
(HOME),and the Housing Trust Fund (HTF), the County has demonstrated its ability to carry
out various housing and community development programs. However, due to misrepresentations
by the County related to a pending Community Development Block Grant—Disaster Recovery
(CDBG-DR)award, HUD considers the County to be a High-Risk grantee as discussed under the
CDBG-DR section of this report.
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Significant Performance Conclusions
In general,the County effectively administers its annual/regular CDBG, HOME, and
HTF grant funds. In accordance with the CDBG regulations,the timeliness ratio benchmark
should be 1.50 sixty days prior to the end of the County's program year. The County's CDBG
timeliness ratio was 1.47 as of May 2, 2019. HUD congratulates the County on its
accomplishments and encourages the County to continue seeking ways for timely project
implementation. As a reminder, HUD has advised all CDBG grantees that failure to meet the
timeliness ratio of 1.50 may result in the loss of future grant funds. However, as noted above
and discussed below,HUD considers the County to be a High-Risk grantee due to
misrepresentations made by the County.
The County is a recipient of the State of Hawaii's (State's) HOME and HTF program
funds. While the primary source of HOME and HTF information is the State's CAPER, HUD
notes that the County's CAPER did include substantial data to inform the citizens about HOME-
and HTF-funded projects within the County.
Overall, the County has been successful in implementing activities in its Consolidated
Plan by utilizing its annual/regular CDBG, HOME, and HTF funding.
CPU Programs
CDBG
CDBG projects selected by the County for the PY18, when complete, will primarily
benefit low-and moderate-income persons. During this period, HUD noted that the County
completed several CDBG-funded projects, including the following:
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'rye • acquisition of an 8 passenger van for the Boys and Girls Club of the Big Island;
• acquisition of two refrigerated vans for the Food Basket for its emergency food
distribution;
• installation of Security Fencing at the Boys and Girls Club Facility;
• completion of accessibility im rovements at the Hilo Drag Strip.
The County reported it awarded and began design for the following projects:
• Kulaimano Elderly Housing Renovation Phase III, Kiheipua.Family Shelter(roof
and certified kitchen);
• Hale Maluhia Shelter(roof and accessibility improvements);
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• the Boys and Girls Club(gym and paving).
The County's Consolidated Plan describes the following four priority concerns that will
be addressed: housing and special needs housing,homelessness,community development, and
fair housing. HUD notes that during PY18, the County accomplished the following program
objectives:
• rehabilitated homes to address health and safety issues:
• provided housing through its TBRA program;
• conducted a total of 7 Fair Housing training/seminar sessions for property
managers,homeless programs and for the general public;
• launched, with the other state government entities, the Affordable Housing Study
for the upcoming 2020-2024 Consolidated Plan.
CDBG-DR
The County's CAPER did not include a discussion of its recent lava flow disaster or the
funds it anticipates from the CDBG-Disaster Recovery (CDBG-DR)program. Although not yet
awarded, much debate occurred within HUD on whether a CDBG-DR award should be granted
to the County. HUD's normal practice is to award CDBG-DR funds to State entities and allow
the State to coordinate with the disaster-affected communities regarding implementation of a
CDBG-DR program.
In assessing the Hawaii county disaster and with assurances by the County that its Office
of Housing and Community Development(011CD), the agency who administers the County's
annual/regular CDBG funds and has HUD program capacity,would administer a CDBG-DR
award, the local HUD Office recommended to HUD senior management that a CDBG-DR award
should be awarded directly to the County versus awarding the funds to the State of Hawaii. in
addition, Hawaii Congressional Leadership and the State of Hawaii made the same
recommendations. However, as the County continued disaster recovery planning efforts, HUD
became aware that the OHDC program staff was rarely involved in the recovery planning and
CDBG-DR discussions. Follow-up with the OHDC confirmed that OHCD program staff was not
actively involved with CDBG-DR planning and that essentially the County misrepresented the
involvement of OHCD as the CDBG-DR Administrator.
The County's misrepresentation, in order to gain a favorable recommendation for a
CDBG-DR award, raises significant questions about the integrity of the County. Of concern is
that this is the second time in approximately three years that the County has either mispresented
a situation or identified a regulatory loophole to allow misleading information to influence
program decisions. The first involved HUD's environmental review process on a major housing
development and the second involves the County's current efforts to secure CDBG-DR funding
directly to the County.
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The County is well within its rights to assign CDBG-DR management to whatever Office
it chooses and should assign CDBG-DR administration to the Office that the County plans to
have implement the program. However, misrepresentation to work around a regulation or gain a
favorable recommendation is a problem. The County's otherwise successful implementation of
its regular HUD funded programs by OHCD is directly impacted by the actions of internal
County influences and conflicts. As a result, HUD must question information presented by the
County and identify the County as a High-Risk grantee.
HOME and HTF
The State has the primary reporting responsibility for the HOME and HTF programs.
HUD will review the State's CAPER as the official report but commends the County for
including data in its CAPER to inform its citizens about HOME- and HTF-funded projects.
HUD encourages the County to seek leveraging of other federal, state,and private resources to
supplement its HOME allocations to further develop affordable rental housing in the county of
Hawaii.
Continuum of Care
During PY 18, the County has partnered with non-profit organizations and other
government agencies to help individuals and families from becoming homeless. It participates in
various community events where it provides information about homeless services and resources
available to the community.
The Kilauea Eruptions of 2018 placed over 600 individuals into temporary disaster
shelters. Under proclamations issued by the Governor and the Mayor of Hawaii County, non-
profit agencies built a total of 30 emergency shelter units, providing preference to individuals
and families who were impacted by the Kilauea Eruptions. The shelter also provided case
management services, referring program participants to appropriate permanent housing options.
HOPE Services Hawaii, Inc. (HOPE)was the key provider in assisting the homeless in
the county. HOPE provided outreach to 391 people experiencing unsheltered homelessness.
Those encountered were provided with necessities and were connected to various services and
emergency shelter as needed. Along with other partners, HOPE provided outreach services,
completed needs assessments,and connected families to financial and housing resources within
and/or outside the county's jurisdiction.
In FY18,the County notes several accomplishments, including the use of State funding to
open its first Family Assessment.Center in Hawaiian Paradise Park, and the completion and
implementation of its Coordinated Entry System(CES) which will facilitate the coordination and
management of resources and services to effectively connect people to interventions that aim to
rapidly resolve their housing crisis. HUD,however, would like to provide input on the
effectiveness of the CES in the County. HUD recently conducted on-site monitoring of a CoC
grantee receiving HUD funding. The monitoring review revealed weaknesses in the CES
process. In the case of Hawaii County, homeless placements were delayed because of a single
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accesspoint for the homeless was lackingstaff coverage that delegated clients to housing;g g g� thus,
CoC entities are not being provided with timely referrals to fill vacancies in order to house
persons experiencing homelessness. Bridging the Gap (BTG), the entity which addresses the
homeless needs of the neighbor islands, was consulted and has agreed to correct this deficiency.
HUD wishes the County continued success in its planning and implementing actions to
end homelessness.
Community Empowerment
The County provided opportunities for citizen participation during the development of
the CAPER through local newspaper publications and availability of the document at various
public facilities and libraries. Despite the opportunities available for public participation in the
reporting process, no public comments were received for the CAPER submission. HUD
encourages the County to continue to provide opportunities for citizen input to the planning and
reporting process.
Management of Funds
In accordance with the CDBG regulations,the timeliness ratio benchmark should be 1.50 or
below sixty days prior to the end of the County's program year. On the test date of May 2, 2019,
the County's timeliness ratio was 1.47. The staff responsible for the CPD programs works
diligently to ensure HUD funding is spent in accordance with program requirements. As timely
project implementation and expenditure of funds have become a priority with HUD, the Department
is pleased that the County has made it a priority to maintain a timeliness ratio of 1.50 or less. HUD
anticipates the County will continue to achieve the timeliness goals and that these efforts will
ensure future CDBG funding will not be compromised.
Areas for Improvement and Recommendations
The County needs to continue to monitor its ongoing regular CDBG, HOME, and HTF
projects to ensure timely implementation. In addition,the County needs to finalize its plans
regarding which County Office will be administering its future CDBG-DR award and move
i forward with its CDBG-DR planning process. HUD recommends that the County identify
project obstacles and develop plans to address these obstacles in order to strengthen its programs.
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Fair Housing & Equal Opportunity
i
The County continues to promote awareness and education of fair housing issues and
1 takes actions which help minimize and eliminate the unfair treatment of individuals in housing.
During PY18, the County conducted a total of 7 Fair Housing training/seminar sessions for
property managers, homeless programs and for the general public. It also continues to maintain
a fair housing website, which helps individuals who have fair housing inquiries. In PY2018,
y there were approximately 1,000 hits to the website for people seeking information. To keep
abreast of any changes in fair housing and to increase their knowledge,the County Fair Housing
Officer participated in 4 meetings with other fair housing officers and attended 2 fair housing
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training sessions.
The CAPER was provided to Mr.Jelani Madaraka, Lead Civil Rights Analyst, HUD
Honolulu Field Office, for compliance with Fair Housing and Equal Opportunity (FHEO)
requirements. He will forward any comments or questions he may have under separate cover.
Conclusion
Overall,except for the integrity questions noted above,of the County of Hawaii is
meeting its community needs by planning and executing a Consolidated PIan with a vision for
the future, and by implementing this Plan through its Annual Action Plan. As a result,the
County has assisted many communities and especially low- to moderate-income persons. HUD
encourages the County to continue its support of various housing and community development
programs, and especially wish to recognize the hard work of the OHCD County staff working on
the CPD programs for their dedication. The program staff is a credit to the County and its CPD
programs.
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