Loading...
HomeMy WebLinkAboutMINUTES - 12052006 - D.7 t 4 • 1- 7 �O: BOARD OF COMMISSIONERS i Housing FROM: Rudy Tamayorift Authority of Executive DirectorContra Costa County DATE: December 5, 2006 SUBJECT: Report to the Board; Section 8 Program and the City of Antioch SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION RECOMMENDATION: ACCEPT report of the Section 8 Housing Choice Voucher Program and the City of Antioch. FINANCIAL IMPACT: This report is for informational purposes only and has no fiscal impact. BACKGROUND On September 26, 2006 the Board of Commissioners accepted the report on Section 8 Housing Choice Voucher(NCV) issues in the City of Antioch (City). The Board further directed a follow-up report to respond to their queries regarding the Section 8 program and address those concerns and issues raised by the various city council members of the City of Antioch. Your Board directed that a follow up report take into consideration the distribution of the HCV throughout the County, portability component of the HCV program, and, the process for ending participation of residents from the HCV program. The City Council and some citizens had concerns that the Housing Authority was not responsive to the Antioch citizenry; there is a disproportionate number of HCV households in the City; some Section 8 recipients are renting in affluent neighborhoods; their behavior patterns are disruptive; and, they bring crime, drugs, and disorder to the neighborhood. Furthermore, they shouldn't be allowed to rent in neighborhoods with high home values. The Section 8 Experience. The Quality Housing and Work Responsibility Act(QHWRA) enacted the Section 8 Housing Choice Voucher Program (HCV) in 1998, which was a merger of the Section 8 Certificate and Voucher programs. Title 24 of the Code of Federal Regulations Parts 982 et al (24CFR)is the current regulations for the Section 8 HCV. The Housing Authority has a contract with the U. S. Department of Housing and Urban Development (HUD)to administer 6,781 vouchers. Within Contra Costa County the Section 8 HCV Program has a history of successful program implementation. Housing choice is at the core of the mission of the Section 8 HCV Program. It expands opportunities for participants, especially working households, to make real choices and decisions about where to live, improve their quality of life, and to avail themselves of other socio-economic opportunities in other communities. HUD encourages housing authorities to promote mobility and deconcentration of poverty among Section 8 recipients. Minority households, families with children, the elderly and disabled have been successful in the private market over the past few years in finding a home or apartment to qualify for the program, however Section 8 clustering is still prevalent within the County. In Contra Costa County mobility and deconcentration becomes extremely difficult given contradictory HUD program requirements and the market conditions of the various communities. Recent3EXEWCUTIVE ms, e.g., CONTINUED ON ATTACHMENT: X YES SIGNATURE: T M 0, DIR OR RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF WARD COMMITTEE APPROVE OTHER SIGNATURE(S): ACTION OF BOARD ON 1 1 Q �Q�g APPROVED AS RECOMMENDED IV OTHER X 522. 6 l�✓� VOTE OF COMMISSIONERS I HEREBY CERTIFY THAT THIS IS A TRUE AND CORREC' COPY OF AN ACTION TAKEN AND ENTERED ON MINUTES Of THE BOARD OF COMMISSIONERS ON THE DATE SHOWN. UNANIMOUS(ABSENT — ) AYES: NOES: ABSENT: ABSTAIN: Contact: Judy Hayes,957-8028 ve,00T : 371$C• Cc: County Administration 'ATTESTED J©� Auditor-Controller JOHN ULL N K OF THE BOARD OF COMMISSIONERS BY: 4 DEPUTY l�oaM of Commissioners November 14, 2006 Page 2 of 5 QHWRA, require housing authorities to target 75%of their Section 8 assistance to households with incomes below 30%of area median and prohibit recipients from contributing more than 40%of their income toward rent. The Fair Market Rent(FMR) level, which is discussed later in the report, coupled with the above reforms do not provide the flexibility to expand access to desirable neighborhoods. Market conditions may have expanded opportunity housing in some communities but have also limited affordable housing opportunities in others. The FMRs are low relative to market rents in more affluent or desirable neighborhoods, Section 8 recipients are excluded from those neighborhoods since they cannot contribute more than 40%of their income to make the difference; and/or they are effectively excluded by the absence of moderate cost rental housing. Within the City of Antioch the market rents provide opportunity housing for many Section 8 recipients not available in other communities. The Section 8 Program and Deconcentration. The federal regulations, 24CFR 982.54(d)(5)are specifically tailored to further HUD's policy of poverty deconcentration. These policies provide Section 8 HCV households the ability to move from neighborhoods of concentrated poor households to more affluent communities with low concentrations of poverty. In addition, the portability or mobility feature of a Section 8 voucher allows a participating household from another housing authority the ability to rent a unit within our jurisdiction. This Housing Authority then administers the incoming portability voucher. Under the portability feature a voucher holder or participating family has the right to receive tenant-based voucher assistance to lease a unit outside the initial PHA jurisdiction. They can go anywhere in the United States within a jurisdiction that administers the Section 8 HCV Program. It should be noted that the report provided on September 26'x' to your Board stated that the 1,470 vouchers within the City of Antioch included portable vouchers from other jurisdictions. Attachment 1 provides a brief outline of the HCV Program portability feature. Deconcentration of poverty has also fueled the debate centering on modestly priced housing which is a function of HUD's Fair Market Rents (FMRs) by bedroom size for this metropolitan statistical area (MSA). The Housing Authority's payment standards, as reported on September 26"'to your Board, are based on these FMRs. Currently HUD's formula for calculating FMRs is set at the 40w percentile of units in the market. HUD reflects changes in market conditions by adjusting this calculation each year. A Section 8 household can live anywhere in the County or country if the rent is within the FMRs and it is reasonable for the area as determined by the rental market conditions. Market selling value is not part of the equation for calculating modest priced rental housing. Current rental market conditions exist within the City of Antioch that provide opportunity housing to Section 8 recipients to reside within communities that have low concentrations of poverty, a primary goal of the Section 8 HCV Program. How does the number of Section 8 households in the City, 1,470, compare to the number of Section 8 households in other cities or communities within the County?The following table indicates that the City of Antioch has the third largest percentage of Section 8 participants to total number of household units as compared to some other cities in the County. The growth of about 4,000 multi-family and single-family units in a five-year period provided a significant change to the housing market conditions within the City. These housing market conditions coupled with the lower rents have made rental housing, especially for single-family homes, more accessible to Section 8 recipients. In over two and a half years about 400 Section 8 recipients relocated to the City. Section 8 Vouchers In Other Areas of the County City #Housing #Sec 8 %of Hsng Units Vouchers Units TIOCH 33,633 1,470 4.37% BRENTWOOD 15,494 246 1.59% CLAYTON 3,988 4 0.10% CONCORD 46,289 1,252 2.70% ANVILLE 15,637 16 0.10% EL CERRITO 10,610 67 0.63% HERCULES 8,017 229 2.86% LAFAYETTE 9,455 57 0.60% MARTINEZ 14,922 345 2.31% ORAGA 5,765 61 0.10% OAKLEY 9,030 1501 1.66% ORINDA 6,788 2 0.03% PINOLE 6,990 190 2.72% PITTSBURG 20,342 948 4.66% Board of Commissioners November 14, 2006 Page 3of5 PLEASANT HILL 14,320 220 1.54% RICHMOND 37,656 1,5601 4.14% SAN PABLO 9,666 7571 7.83% SAN RAMON 20,903 82 0.39% ALNUT CREEK 32,267 301 0.93% UNINCORPORATED 62,896 1,206 *Pittsburg and Richmond have own housing authority. It should be noted that those areas with low Section 8 participation have a limited number of affordable rental housing units available and/or rents for the area exceed the FMR or Housing Payment Standard rent structure. The Housing Authority is researching and gathering available data to determine this number. Terminatinq Family Participation from the Section 8 Program. Termination of Family Assistance is a result of a family's action or failure to act in accordance with the federal regulations. Attachment 2 outlines the Housing Authority's responsibilities for the Section 8 HCV program. The Housing Authority is mandated to terminate assistance to a family for any of the following reasons: ❑ If the family has been evicted for serious violations of the lease.(See Attachment 3) ❑ If any member of the family fails to sign and submit consent forms for obtaining information in accordance with program regulations. ❑ If a family member does not establish citizenship or eligible immigration status. ❑ If the Housing Authority determines that any member of the household has ever been convicted of drug related criminal activity, or for the manufacture or production of methamphetamine. (24CFR 982(b)(0(ir) The Housing Authority may terminate assistance to a family for other reasons including if a family or any member violates any family obligation or if the family or any member has been engaged in drug related or criminal activity. Attachment 4 is a listing of the family obligations. Termination of tenancy is a result of the property owner evicting the tenant or terminating the lease for lease violations. The property owner completes evictions for lease violations. Upon notification that a Section 8 participant's tenancy is terminated for lease violations the Housing Authority also terminates the family assistance. Attachment 5 is listing of obligations of the property owner. Since the Housing Authority is not a party to the lease, there is no legal requirement for the Housing Authority to terminate tenancy for serious lease violations. However, the Housing Authority will provide assistance to property owners to assist in the termination of tenancy if requested by the property owner. In terminations from the Section 8 HCV Program the Housing Authority must provide program participants with the opportunity for an informal hearing to consider whether certain Housing Authority decisions are in accordance with the law, HUD regulations, and Housing Authority Policies. Attachment 6 is the Informal Hearing process outlined in the Housing Authority's Section 8 Administrative Plan as approved by HUD. Terminations can take from thirty days to three months or longer depending on the tenacity of the participants' attorney. In many cases involving drug related or violent criminal activity the Section 8 recipient does not request a hearing. In some cases they do go to hearing and are later appealed to the court system for adjudication. Housina Authority Actions Within The City of Antioch. The Housing Authority met with City officials on October 25, 2006 to develop a stronger working partnership to mitigate blight, crime, and other quality of life issues related to Section 8 participants. The City has created a Community Action Team (C.A.T.)that consists of four officers. As explained by the City: o These are specially trained patrol officers who report concerns encountered while on duty. ❑ Carry"door hangers"that are used in problem areas asking neighbors to report neighborhood concerns. ❑ The C.A.T. takes the lead on all Section 8 cases and investigates issues including criminal activity and disregard of Section 8 criteria. Cases are developed, documented and turned over to the Housing Authority for follow through and disposition. ❑ The City stated that approximately 60% of C.A.T. caseload is Section 8 housing issues. The Housing Authority is making every effort to work with the City staff to assist in addressing their major concerns as it relates to the Section 8 HCV program and its impact on the City's quality of life issues. The efforts expected by the City include: • Follow through is needed on all cases referred to the Housing Authority. The Housing Authority does investigate all referrals made by the City and its residents. Board of Commissioners November 14, 2006 Page 4 of 5 However, most referrals are made by the C.A.T. and follow-up reports on Housing Authority action are generally handled by an exchange of monthly reports between the Antioch Chief of Police and the Housing Authority Director of Assisted Housing. The Housing Manager and various members of the City's Police Department do collaborate and exchange documents that support any termination of participation for drug related or violent criminal activity. With the recent documentation provided by police, the Housing Authority has terminated three participants and scheduled ten informal hearings over the next four weeks. • Section 8 recipients should be monitored and screened and told they will be held accountable for their behavior. The Housing Authority qualifies income eligible participants when they first enter the program and once annually through credit checks and third party verifications. Criminal background checks are conducted for all adult family members at initial entry into the program and for any adult member that may be subsequently added to the household. The Housing Authority is modifying its participant briefing to emphasize their responsibility to consistently comply with the landlord lease requirements, especially as it relates to the quiet, peaceful enjoyment of the neighborhood. Monitoring participants to ensure consistent compliance with lease requirements is a function of landlord responsibilities. The Housing Authority has counseled landlords and tenants to encourage enforcement and compliance with the lease when deemed appropriate. • Education is needed for landlords regarding what the Housing Authority does or does not do in the screening process. Landlord workshops are scheduled within the City of Antioch. The first was November 4`h from 9:00 a.m. to noon at the Antioch Senior Center on 2nd Street. Additional workshops are planned for January 2007 and a regional workshop is planned to coincide with Affordable Housing Week in May 2007. The Housing Authority attended and participated in the City's Quality of Life forum on November 18-2006. • Develop standards of conduct for Section 8 participants. The Housing Authority referred this to HUD, San Francisco regional office since this may have implications related to discriminatory practices contrary to the Fair Housing Act. • One employee is handling all East County revocations, which is simply not enough. The Housing Authority relies predominately upon the documentation provided by law enforcement for terminations of assistance for drug related or criminal activity. Recently, the Antioch Police Department has provided more detailed documentation; as a result, terminations of participation and scheduling of fair hearings are processed quicker. Staff reorganization is planned once the current office is enlarged. In the interim, if a backlog occurs more staff and contracted hearing officers will be assigned. Desist from promoting a disproportionate share of Section 8 housing in the City of Antioch. The Housing Authority does not promote or encourage Section 8 recipients to live in any particular area of the County. As stated earlier, the Section 8 recipient is free to make housing choice decisions that best meets their household needs. Market conditions and household needs, not the Housing Authority, generally dictate the movement of any renter to affordable housing units available anywhere in the County. • Reconsideration of the rent structure stipends issued in the City of Antioch. Any change beyond what is allowed by regulation will require HUD approval. The Housing Authority must refrain from any action that may be construed as violating the Fair Housing Act or contributing to the concentration of poverty. The Housing Authority is working diligently to do its share to assist in addressing the quality of life concerns in Antioch and within the County. In addition to those actions stated on September 26`h and those mentioned above the Housing Authority is working toward, participated, or conducted the following: ➢ Working with Community Action Team and Chief of Police to address crime and blight issues. ➢ Committed Housing Authority Inspectors to work with City Code enforcement to alert City staff of code violations and/or blight conditions. ➢ Will add more staff to the Antioch Section 8 office in January 2007. ➢ Conducted Landlord Eviction Workshop on November 4, 2006 at the Antioch Senior Center and follow-up workshops will be conducted in January and May 2007. ➢ Housing Authority participation and presentation at the City's Quality of Life Forum on November 18, 2006. ➢ Met with HUD, City, County and Congressional staff on November 22, 2006 ➢ Modifying Section 8 participants' briefing orientation to emphasize good neighbor conduct and good housekeeping practices. ➢ Assist the City in a training and certification program for rental property owners. Board of Commissioners November 14, 2006 Page 5 of 5 ➢ Develop a pilot program with the City for the Housing Authority to review police reports to determine involvement of Section 8 recipient family members and assist in fraud investigation. Other efforts by the Housing Authority with direct impact upon the City of Antioch include: ➢ Reallocation of resources to: o Strengthen fraud investigation, o Initiate a community ombudsman program, and, o Increase workshops for renters and landlords. ➢ Develop cooperative agreements with the City of Antioch Police Department for exchange of arrest and criminal information without violating federal and state laws. The Housing Authority efforts at the state and federal level includes: ➢ Working with legislators and juvenile court to allow access to juvenile criminal records or reports to document this criminal activity by Section 8 recipient family members. ➢ Working with federal legislators to promote dedicated federal funding for fraud investigation by Housing Authorities. The Housing Authority is fully utilizing all its available resources to assist the City of Antioch in its endeavors to aggressively meet its crime, blight and neighborhood growth challenges. We will do our part, within the federal program regulations, to ensure those Section 8 recipients that are committing fraud or involved in criminal activity are terminated from the program. Individuals making complaints about the renters cannot be told whether or not a particular household participates in the program. The Housing Authority is also prohibited from steering or barring Section 8 recipients from choosing particular neighborhoods. The Housing Authority is exploring opportunities to partner with community organizations to resolve disputes between Section 8 recipients and neighbors; and, to dispel myths and stereotypes about Section 8 landlords and tenants. Attachment 1 PORTABILITY [24 CFR 982.3531 Portability applies to families moving out of or into the HA's jurisdiction within the United States and its territories. OUTGOING PORTABILITY [24 CFR 982.353, 982.355] Within the limitations of the regulations and this policy, a participant family has the right to receive tenant-based voucher assistance to lease a unit outside the HA's jurisdiction, anywhere in the United States, in the jurisdiction of a HA with a tenant-based program. When a family requests to move outside of the HA's jurisdiction, the request must specify the area to which the family wants to move. If there is more than one HA in the area in which the family has selected a unit, the HA will choose the receiving HA. Restrictions on Portability Participants After an applicant has leased-up in the jurisdiction of the initial housing agency, they cannot exercise portability during the first year of assisted occupancy, except in the following circumstances. The receiving HA and the initial HA agree to allow the move. The receiving HA agrees to absorb the voucher. This requirement is dependant upon available funding. The HA will not permit families to exercise portability: 1. If the family is in violation of a family obligation, or 2. If the family owes money to the HA, or I If the family has moved out of its assisted unit in violation of the lease. rHousing Authority of the County of Contra Costa 4/2004-05 Admin Plan 13-1 INCOMING PORTABILITY [24 CFR 982.354, 982.355] Absorption or Administration The HA will accept a family with a valid Voucher from another jurisdiction and administer or absorb the Voucher. If administering, the family will be issued a "Portable" Voucher by the HA. The term of the voucher will not expire before the expiration date of any initial HA voucher. The family must submit a request for approval of tenancy for an eligible unit to the receiving HA during the term of the receiving HA voucher. The receiving HA may grant extensions in accordance with this Administrative Plan. However, if the Family decides not to lease-up in the HA's jurisdiction, they must contact the initial HA to request an extension. The HA may absorb all incoming portable families provided that there is funding available. When the HA does not absorb the incoming Voucher, it will administer the Initial HA's Voucher and the receiving HA's policies will prevail. The HA may absorb all incoming portable families affected by a federally declared disaster area, provided that there is funding available. When the HA does not absorb the incoming voucher, it will administer the initial HA's voucher and the receiving HA's policies will prevail. For admission to the program a family must be income eligible in the area where the family initially leases a unit with assistance under the program. The receiving HA does not re-determine eligibility for a portable family that was already receiving assistance in the initial HA Section 8 tenant-based program. The HA will issue a "Portability Voucher" according to its own Subsidy Standards. If the Family has a change in family composition which would change the voucher size, the HA will change to the proper size based on its own Subsidy Standards. Incoming portability applicants/all adult members over the age 18 will be screened by National Tenant Network for drug-related activity and other criminal activity. Income and Total Tenant Payment of Incoming Portables [982.353(d)] As receiving HA, the HA will conduct a re-certification interview to verify the information provided. If the HA conducts a re-certification of the family it will not cause a delay in the issuance of a voucher. Housing Authority of the County of Contra Costa 4/2004-05 Admin Plan 13-2 If the family's income is such that a $0 subsidy amount is determined prior to lease-up in the HA's jurisdiction, the HA will refuse to enter into a contract on behalf of the family at $0 assistance. Requests for Approval of Tenancy A briefing will be mandatory for all portability families. When the Family submits a Request for Tenancy Approval, it will be processed using the HA's policies. If the Family does not submit a Request for Tenancy Approval or does not execute a lease, the Initial HA will be notified within 30 days by the HA. If the Family leases up successfully, the HA will notify the Initial HA within 30 days, and the billing process will commence. The HA will notify the initial HA if the family fails to submit a request for approval of tenancy for an eligible unit within the term of the voucher. If the HA denies assistance to the family, the HA will notify the Initial HA within 30 days and the family will be offered a review or hearing. The HA will notify the family of its responsibility to contact the Initial HA if the Family wishes to move outside the HA's jurisdiction under continued portability. Regular Program Functions The HA will perform all program functions applicable the tenant-based assistance program, such as: 1. Annual reexaminations of family income and composition; 2. Annual inspection of the unit; and 3. Interim Examinations when requested or deemed necessary by the HA Terminations The HA will notify the Initial HA in writing of any termination of assistance within 30 days of the termination. If an Administrative Hearing is required and requested by the Family, the hearing will be conducted by the HA, using the regular hearing procedures included in this Plan. A copy of the hearing decision will be furnished to the Initial HA. The Initial HA will be responsible for collecting amounts owed by the Family for claims paid and for monitoring repayment. If the Initial HA notifies the HA that Housing Authority of the County of Contra Costa 4/2004-05 Admin Plan 13-3 the'Family is in arrears or the Family has refused to sign a Payment Agreement, the HA will term inate.assistance to the family. Required Documents As Receiving HA, the HA will require the documents listed on the HUD Portability Billing Form from the Initial HA. Billing Procedures As Receiving HA, the HA will bill the Initial HA initially and when changes occur for Housing Assistance Payments, and other amounts, including Administrative Fees and Special Claims. The HA will bill 100% of the Housing Assistance Payment, 100% of Special Claims and 80% of the Administrative Fee (at the Initial HA's rate) for each "Portability" Voucher leased as of the first day of the month. The HA will notify the Initial HA of changes in subsidy amounts and will expect the Initial HA to notify the HA of changes in the Administrative Fee amount to be billed. Housing Authority of the County of Contra Costa 4/2004-05 Admin Plan 13-4 ATTACHMENT 2 HOUSING AUTHORITY'S RESPONSIBILITIES Source: 24 CFR§ 982.153 Housing Authority's Responsibilities: The PHA administers the voucher program locally. The PHA provides a family with the housing assistance that enables the family to seek out suitable housing. Review all applications to determine if they are eligible for the program. Explain all the rules of the program to all families who qualify. Approve the family, unit and landlord. PHA enters into a contract with the landlord to provide housing assistance payments on behalf of the family. If the landlord fails to meet the owner's obligations under the lease, the PHA has the right to terminate assistance payments. The PHA must reexamine the family's income and composition at least annually and must inspect each unit at least annually to ensure that it meets minimum housing quality standards. Ensure that both the family and the unit continue to qualify under the program. Ensure that landlords and families comply with the program rules. 1 t ATTACHMENT 3 TERMINATION OF TENANCY BY OWNER Soprce: Excerpts from the HUD Tenancy Addendum HUD-52641-A Form Termination of Tenancy by Owner a. Requirements. The owner may only terminate the tenancy in accordance with the lease and HUD requirements. b. Grounds. During the term of the lease (the initial term of the lease or any extension term), the owner may only terminate the tenancy because of: (1) Serious or repeated violation of the lease; (2) Violation of Federal, State, or local law that imposes obligations on the tenant in connection with the occupancy or use of the unit and the premises; (3) Criminal activity or alcohol abuse (as provided in paragraph c); or (4) Other good cause(as provided in paragraph d). c. Criminal activity or alcohol abuse. (1) The owner may terminate the tenancy during the term of the lease if ally member of the household, a guest or another person under a resident's control commits any of the following types of criminal activity: (a) Any criminal activity that threatens the health or safety of, or the right to peaceful enjoyment of the premises by, other residents (including property management staff residing on the premises); (b) Any criminal activity that threatens the health or safety of, or the right to peaceful enjoyment of their residences by, persons residing in the immediate vicinity of the premises; (c) Any violent criminal activity on or near the premises; or (d) Any drug-related criminal activity on or near the premises. (2) The owner may terminate the tenancy during the term of the lease if any member of the household is: (a) Fleeing to avoid prosecution, or custody or confinement after conviction, for a crime, or attempt to commit a crime, that is a felony under the laws of the place from which the individual flees, or that, in the case of the State of New Jersey, is a high misdemeanor; or (b) Violating a condition of probation or parole under Federal or State law. (3) The owner may terminate the tenancy for criminal activity by a household member in accordance with this section if the owner determines that the household member has committed the criminal activity, regard-less of whether 1 the -household member has The owner may terminate the tenancy during the term of the lease if any member of the household has engaged in abuse of alcohol that threatens the health, safety or right to peaceful enjoyment of the premises by other residents. d. Other good cause for termination of tenancy (1) During the initial lease term, other good cause for termination of tenancy must be something the family did or failed to do. (2) During the initial lease term or during any extension term, other good cause includes: (a) Disturbance of neighbors, (b) Destruction of property, or (c)Living or housekeeping habits that cause damage to the unit or premises. (3) After the initial lease term, such good cause includes: (a) The tenant's failure to accept the owner's offer of a new lease or revision; (b) The owner's desire to use the unit for personal or family use or for a purpose other than use as a residential rental unit; or (c) A business or economic reason for termination of the tenancy (such as sale of the property, renovation of the unit, the owner's desire to rent the unit for a higher rent). e. Eviction by court action. The owner may only evict the tenant by a court action. f. Owner notice of grounds (1) At or before the beginning of a court action to evict the tenant, the owner must give the tenant a notice that specifies the grounds for termination of tenancy. The notice may be included in or combined with any owner eviction notice. (2) The owner must give the PHA a copy of any owner eviction notice at the same time the owner notifies the tenant. Eviction notice means a notice to vacate, or a complaint or other initial pleading used to begin an eviction action under State of local law. 2 ATTACHMENT 4 SOURCE: 24 CFR § 982.551 § 982.551 Obligations of participant. (a) Purpose. This section states the obligations of a participant family under the program. (b) Supplying required information—(1) The family must supply any information that the PHA or HUD determines is necessary in the administration of the program, including submission of required evidence of citizenship or eligible immigration status (as provided by 24 CFR part 5). "Information" includes any requested certification, release or other documentation. (2) The family must supply any information requested by the PHA or HUD for use in a regularly scheduled reexamination or interim reexamination of family income and composition in accordance with HUD requirements. (3) The family must disclose and verify social security numbers (as provided by part 5, subpart B, of this title) and must sign and submit consent forms for obtaining information in accordance with part 5, subpart B, of this title. (4) Any information supplied by the family must be true and complete. (c) HQS breach caused by family. The family is responsible for an HQS breach caused by the family as described in §982.404(b). (d) Allowing PHA inspection. The family must allow the PHA to inspect the unit at reasonable times and after reasonable notice. (e) Violation of lease. The family may not commit any serious or repeated violation of the lease. (f) Family notice of move or lease termination. The family must notify the PHA and the owner before the family moves out of the unit, or terminates the lease on notice to the owner. See §982.314(d). (g) Owner eviction notice. The family must promptly give the PHA a copy of any owner eviction notice. (h) Use and occupancy of unit.—(1) The family must use the assisted unit for residence by the family. The unit must be the family's only residence. (2) The composition of the assisted family residing in the unit must be approved by the PHA. The family must promptly inform the PHA of the birth, adoption or 1 court-awarded custody of a child. The family must request PHA approval to add any other family member as an occupant of the unit. No other person [i.e., nobody but members of the assisted family] may reside in the unit (except for a foster child or live-in aide as provided in paragraph (h)(4) of this section): (3) The family'must promptly notify the PHA if any family member no longer resides in the unit. (4) If the PHA has given approval, a foster child or a live-in-aide may reside in the unit. The PHA has the discretion to adopt reasonable policies concerning residence by a foster child or a live-in-aide, and defining when PHA consent may be given or denied. (5) Members of the household may engage in legal profitmaking activities in the unit, but only if such activities are incidental to primary use of the unit for residence by members of the family. (6) The family most not sublease or let the unit. (7) The family must not assign the lease or transfer the unit. (i) Absence from unit. The family must supply any information or certification requested by the PHA to verify that the family is living in the unit, or relating to family absence from the unit, including any PHA-requested information or certification on the purposes of family absences. The family must cooperate with the PHA for this purpose. The family must promptly notify the PHA of absence from the unit. Q) Interest in unit. The family must not own or have any interest in the unit. (k) Fraud and other program violation. The members of the family must not commit fraud, bribery or any other corrupt or criminal act in connection with the programs. (1) Crime by household members. The members of the household may not engage in drug-related criminal activity or violent criminal activity or other criminal activity that threatens the health, safety or right to peaceful enjoyment of other residents and persons residing in the immediate vicinity of the premises (see §982.553). (m) Alcohol abuse by household members. The members of the household must not abuse alcohol in a way that threatens the health, safety or right to peaceful enjoyment of other residents and persons residing in the immediate vicinity of the .premises. 2 y (n) Other housing assistance. An assisted family, or members of the family, may not receive Section 8 tenant-based assistance while receiving another housing subsidy, for the same unit or for a different unit, under any duplicative (as determined by HUD or in accordance with HUD requirements) federal, State or local housing assistance program. 3 ATTACHMENT 5 SOURCE: 24 CFR § 982.452 §982.452 Owner responsibilities. (a) The owner is responsible for performing all of the owner's obligations under the HAP contract and the lease. (b) The owner is responsible for: (1) Performing all management and rental functions for the assisted unit, including selecting a voucher-holder to lease the unit, and deciding if the family is suitable for tenancy of the unit. (2) Maintaining the unit in accordance with HQS, including performance of ordinary andextraordinary maintenance. For provisions on family maintenance responsibilities, see §982.404(a)(4). (3) Complying with equal opportunity requirements. (4) Preparing and furnishing to the PHA information required under the HAP contract. (5) Collecting from the family: (1) Any security deposit. (ii) The tenant contribution (the part of rent to owner not covered by the housing assistance payment). (iii) Any charges for unit damage by the family. (6) Enforcing tenant obligations under the lease. (7) Paying for utilities and services (unless paid by the family under the lease). (c) For provisions on modifications to a dwelling unit occupied or to be occupied by a disabled person, see 24 CFR 100.203. I Attachment 6 A. INFORMAL HEARING PROCEDURES [24 CFR 982.555 (a-f), 982.54(d)(13)] The HA will provide a copy of the hearing procedures in the family briefing packet. When the HA makes a decision regarding the eligibility and/or the amount of assistance, applicants and participants must be notified in writing. The HA will give the family prompt notice of such determinations which will include: The proposed action or decision of the HA, which must be in writing stating that the applicant/participant has ten calendar days by which to respond; The date the proposed action or decision will take place; The family's right to an explanation of the basis for the HA's decision. The procedures for requesting a hearing if the family disputes the action or decision; The time limit for requesting the hearing. To whom the hearing request should be addressed; A copy of the HA's Hearing Procedures. The HA must provide participants with the opportunity for an Informal Hearing for decisions related to any of the following HA determinations: 1. Determination of the family's annual or adjusted income and the computation of the housing assistance payment; 2. Appropriate utility allowance used from schedule; 3. Family unit size determination under HA subsidy standards; 4. Determination that family is under occupied in its current unit and a request for exception is denied; 5. Determination to terminate assistance for any reason; Housing Authority of the County of Contra Costa 4/2004-05 Admin Plan 18-1 a 6. Determination to terminate a family's FSS Contract, withhold supportive services, or propose forfeiture of the family's escrow account; . 7. Determination to pay an owner claim for damages, unpaid rent or vacancy loss. The HA must always provide the opportunity for an informal hearing before termination of assistance. Informal Hearings are not required for established policies and procedures and HA determinations such as: 1. Discretionary administrative determinations by the HA; 2. General policy issues or class grievances; 3. Establishment of the HA schedule of utility allowances for families in the program; 4. An HA determination not to approve an extension or suspension of a voucher term; 5. An HA determination not to approve a unit or lease; 6. An HA determination that an assisted unit is not in compliance with HQS (HA must provide hearing for family breach of HQS because that is a family obligation determination); 7. An HA determination that the unit is not in accordance with HQS because of the family size; 8. An HA determination to exercise or not exercise any right or remedy against the owner under a HAP contract. Notification of Hearing It is the HA's objective to resolve disputes at the lowest level possible, and to make every effort to avoid the most severe remedies. However, if this is not possible, the HA will ensure that applicants and participants will receive all of the protections and rights afforded by the law and the regulations. When the HA receives a request for an informal hearing, a hearing shall be scheduled within 15 (fifteen) days. The notification of hearing will contain: Housing Authority of the County of Contra Costa 4/2004-05 Admin Plan 18-2 1. The date and time of the hearing; 2. The location where the hearing will be held; 3. The family's right to bring evidence, witnesses, legal or other representation, at the family's expense; 4. The right to view any documents or evidence in the possession of the HA upon which the HA based the proposed action and, at the family's expense, to obtain a copy of such documents prior to the hearing. The HA's Hearing Procedures After a hearing date is set, the family may request to reschedule only upon showing "good cause," which is defined as an unavoidable conflict which seriously affects the health, safety or welfare of the family. If the family does not appear at the scheduled time, and did not make arrangements in advance to reschedule, the HA will automatically deny the appeal unless the family contacts the HA within 48 hours (excluding weekends and HA holidays) and presents evidence of extenuating circumstances. The HA may reschedule a second hearing date of the evidence is determined credible and the circumstances surrounding the failure to appear are acceptable. Families have the right to: 1. Present written or oral objections to the HA's determination. 2. Examine the documents in the file which are the basis for the HA's action, and all documents submitted to the Hearing Officer; 3. Copy any relevant documents, at their prepaid expense; 4. Present any information or witnesses pertinent to the issue of the hearing; 5. Request that HA staff be available or present at the hearing to answer questions pertinent to the case; and 6. Be represented by legal counsel, advocate, or other designated representative, at their own expense. Housing Authority of the County of Contra Costa 4/2004-05 Admin Plan 18-3 Y If the family requests copies of documents relevant to the hearing, the HA may make the copies for the family and assess a reasonable charge per copy. In no case will the family be allowed to remove the file from the HA's office. The Informal Hearing shall be conducted by the Hearing Officer appointed by the HA who is neither the person who made or approved the decision, nor a subordinate of that person. The HA appoints hearing officers who: Are HA commissioners/ HA management; Are managers from other departments in the government of the jurisdiction; Are managers from another HA; Are professional mediators or arbitrators. Are otherwise qualified to serve. The hearing shall concern only the issues for which the family has received the opportunity for hearing. Evidence presented at the hearing may be considered without regard to admissibility under the rules of evidence applicable to judicial proceedings. No documents may be presented which have not been provided to the other party before the hearing if requested by the other party. "Documents includes records and regulations. The family may request in writing an audio recording of the hearing, if desired, at least 5 (five) days prior to the hearing date. The Hearing Officer may ask the family for additional information and/or might adjourn the Hearing in order to reconvene at a later date, before reaching a decision. If the family misses an appointment or deadline ordered by the Hearing Officer, the action of the HA shall take effect and another hearing will not be granted. '-'� Housing Authority of the County of Contra Costa 4/2004-05 Admin Plan 18-4 Y� s The Hearing Officer will determine whether the action, inaction or decision of the HA is legal in accordance with HUD regulations and this Administrative Plan based upon the evidence and testimony provided at the hearing. Factual determinations relating to the individual circumstances of the family will be based on a preponderance of the evidence presented at the hearing. A notice of the Hearing Findings shall be provided in writing to the HA and the family within 10 (ten) days and shall include: A clear summary of the decision and reasons for the decision; If the decision involves money owed, the amount owed; and The date the decision goes into effect. The HA is not bound by hearing decisions: Which concern matters in which the HA is not required to provide an opportunity for a hearing; Which conflict with or contradict to HUD regulations or requirements; Which conflict with or contradict Federal, State or local laws; or Which exceed the authority of the person conducting the hearing. The HA shall send a letter to the participant within 10 (ten) days if it determines the HA is not bound by the Hearing Officer's determination. The letter shall include the HA's reasons for the decision. All requests for a hearing, supporting documentation, and a copy of the final decision will be retained in the family's file. -" Housing Authority of the County of Contra Costa 4/2004-05 Admin Plan 18-5 3IA16: ,¢cam'`, REQUEST TO SPEAK FORM (3 Minute Limit) I wish to s eak on Agenda Item#1a Corqlete this form and place it in the upright box near the Date: speaker's podium, and wait to be called by the Chair. Jz Personal information is optional. This speaker's card will be My comments will be: ''General incorporated into the public record of this meeting. ❑ For Name: �f/��� '� , - El Against � � /�i� �? ❑ Address: I wish to speak on the subject of: � �7-�� � � � City: Phone: / � z z —g f I am speaking for: ❑ Myself Oghrg /ktftanization: �2;OVP!S ❑ I do not want to speak but would like to leave comments for the Board to consider (use the back of this form) Editor/Letters To The Editor-Guest Commentary: Antioch's Mayor,Don Freitas,and the rest of the Council Members should be ashamed of themselves!Using the County's Section 8 Program and its participants as their most recent political propaganda, for their own ends and hoped for upwards mobility in Elective Office, is disgraceful and repugnant. This includes their patronizing some Antioch residents and getting them riled up into an unjust lather.The alleged"problems"are NOT with the County Housing Authority's management of the Program but rather Mayor Freitas,Council Members and the City staff. Their alleged"cure" is to lean towards taking over the Housing Assistance Program within Antioch via creating Antioews own. Don Freitas is quoted and reported as saying"we're paralyzed because it's a county housing authority process", and "we are looking for anything that will give us some power, some authority to really get the bad characters out- either the renters or the landlord". Councilman Jim Davis(who hopes to eventually replace Freitas as Mayor), and Councilman Arne Simonsen (who hopes to beat Mark Desaulnier for Assembly),both beat the drum with equal animated fervor,aided by the rest of the Council and uninformed small group of residents. What hogwash! Mayor Don Freitas goes on to say "....I see garbage and I see problems with vector control and cars that don't work, a run- down house. It becomes substandard housing.We don't have anything to get through the bureaucracy."And,last but not the least of their wrongs,is referring to the tenants as"those people"is obviously elitist,discriminatory,and seems to be latently slanderous. What Mayor Don Freitas,Council Members,and the rest of those involved,do not admit is that they are being rather coy about their own lack of accountability and individual responsibility in these issues. It is NOT the County Housing Authority nor the Executive Director Rudy Tamayo's fault for the perceived incompetence of Mayor Freitas,Council Members, etc. The issues and matters loudly complained about by them have always been enforceable within Antioch by them and/or their personnel via Federal and State laws,as well as Antioch's own City Codes and Ordinances. Their failure to do something about it is NOT the County's or Mr. Tamayo's fault, it is Mayor Freitas',et al, fault. But, it appears,they will not admit it or tell the complaining residents whose real fault it is. All one has to do is know/read the Federal and State laws, as well as know/read the City's Codes and Ordinances, and apply them accordingly. Antioch has a number of"nuisance laws",health&safety codes,etc.,that they could've and should've used all along to attempt to resolve the alleged problems.In fact,nothing prevents them from doing so even today! The question(s) then surface as to what these claimed "experienced" Officials vote on when they budget Code Enforcement and Police personnel,and resources,plus the related City Codes,Ordinances,etc.,involved. Oh, and let's not forget the much ballyhooed citizen volunteers(referred to as VIPs)who have been picking and choosing whom they will pursue,cite,harass,etc.,regarding the very same things Don Freitas and company want to "correct" by forming its own Antioch Housing Authority. What hogwash, irresponsible,incompetent, and unjust political propaganda by them. In my last 17 years in Law Enforcement,as a C.C. County D.A.'s Inspector(1986 thru 2003),1 additionally dealt with the Housing Assistance Programs.Using the knowledge,available laws,Housing Assistance rules &regulations, etc.,I never had a problem in rule breaking enforcement against Section 8 tenants,Landlords,others involved, properties, etc. Both the County Housing Authority and HUD responded admirably and efficiently, all within the various involved legal frameworks. So, Antioch's Mayor Freitas,et al,are instigating our Antioch community needlessly.Instead,they should enforce what they already have available to them, and quit deceiving our citizenry by blaming the County for their own lack of competence or action. I also recommend that working with the CCCHA and its Executive Director will bear more positive results than the legal "swamp"they are intent on pursuing. Your newspapers too can verify what I say by mere inquiry and/or research. People,Don Freitas'unofficial campaign to replace County Supervisor Federal Glover has begun. This is a tactic he is well known for, as when he unofficially campaigned for Antioch City Council in 1997 &early 1998-before the Candidacy period even opened up in July 1998. And,Jim Davis'unofficial campaign to replace Freitas as Mayor is no secret either.Nor is Arne Simonsen's unofficial campaign to beat Mark Desaulnier for Assembly. Our community and the County is unnecessarily being "used" in their political gamesmanship and propaganda. The real problem is Antioch's elected officials,NOT the County or the Section 8 Housing Assistance Programs. Ralph A. Hernandez, Chairperson-Citizens For Democracy c/o 2718 Barcelona Cr., Antioch,Ca.,94509 #(925) 757-8943 REQUEST TO SPEAK FORM (3 Minute Limit) I wish to speak on Agenda Item #: Complete this form and place it in the upright box near the Date: 2 5 0 (a speaker's podium, and wait to be called by the Chair. My comments will be: ❑ General Personal information is optional. This speaker's card will be incorporated into the public record of this meeting. ❑ For ❑ Against Name: D � G X l Z�c 42'11 wish to speak on the subject of: Address: 3 City: Phone: S� I am speaking for: ❑ Myself Organization: ❑ Ido not want to speak but would like to leave comments for the Board to consider ° (use the back of this form) REQUEST TO SPEAK FORM 3,y(THREE (3) MINUTE LIMIT) Complete this form and place it in the box near the speakers' rostrum before addressing the Board. Name: -JJk Phone: C f Address: �T � � t"-'� City: (Address and phone number are ptiorral;please note that this card will become a public record kept on file with the Clerk of the Board in association with this meeting) I am speaking for myself_� or organization: -612 CHECK ONE: ❑ I wish to speak on Agenda Item # -7 Date: r My comments will be: ❑ General ❑ For ❑ Against . ❑ 1 wish to speak on the subject of: ❑ I do not wish to speak but would like to leave these comments for the Board to consider: I Please see reverse for instructions and important information REQUEST TO SPEAK FORM (3 Minute Limit) I wish to speak on Agenda Item #: Complete this form and place it in the upright box near the Date: 'C 2cpo,�, speaker's podium, and wait to be called by the Chair. My comments will be: 2� General .Personal information is optional. This speaker's card will be incorporated into the public record of this meeting. ❑ For 111 ' [— Against Name: R cG k- `��✓` l I wish to speak on the subject of. Address: Z Z AYY\'( to R0524 City: C&,n V l �. a.��asr� kips messy-E�et' w Phone: 7 — I am speaking for: Myself "C4;- e✓`• ❑ Organization: ❑ I do not want to speak but would like to leave comments for the Board to consider (use the back of this form) REQUEST TO SPEAK FORM (THREE (3) MINUTE LIMIT) Complete this form and place it in the bo �r the speakers' rostrum before addressing the Board. Name: i PhoneQ/: r/ �+, Address: 102.5- /,924'l Q City:/`/ 7 d �,2I (Address and phone number are optional;please note that this card will become a public record kept on file with the Clerk of the Board in association with this meeting) I am speaking for myself or organization: 44 47 Lev Z-Pidp 9472 CHECK ONE: ❑ I wish to speak on Agenda Item # Date: My comments will be: ❑ General ❑ For ❑ Against P" wish to speak on the subject of: 11 ❑ I do not wish to speak but would like to leave these comments for the Board to consider: Please see reverse for instructions and important information REQUEST TO SPEAK FORM (THREE (3) MINUTE LIMIT) Complete this form and place it in the box near the speakers' rostrum before addressing the Board. Name: '�� �"t �o�l�-C- 7' / Phone: 7S-e , 3 28'47 Address: ���2 `�+�e�t (�[r°Y City: /�J7e,oe 14 (Address and phone number are optional;please note that this card will become a public record kept on file with the Clerk of the Board in association with this meeting) I am speaking for myself ✓ or organization: CHECK ONE: ❑ 1 wish to speak on Agenda Item # "D - 7 Date: My comments will be: WGeneral ❑ For ❑ Against ❑ I wish to speak on the subject of: I ❑ I do not wish to speak but would like to leave these comments for the Board to consider: Please see reverse for instructions and important information ADDENDUM to D.7 December 5, 2006 On this day,the Board of Supervisors, acting as the Housing Authority Board of Commissioners, considered accepting a report from the Housing Authority Executive Director on the Section 8 Housing Choice Voucher Program and the City of Antioch. Rudy Tamayo, Housing Authority Executive Director,presented the report. In his presentation he provided the Board with information that included the countywide distribution of Section 8 housing vouchers, noting that disproportionate numbers may be due to the disproportionate availability of affordable housing. He also covered the Housing Authority's responsibilities, participating families' obligations to the Housing Authority, and eligibility requirements.He further commented on landlord responsibilities and causes for termination. Supervisor Uilkema asked about the issue of portability,asking in what way vouchers issued in other states are honored in our County. Mr. Tamayo responded that, in accordance with federal regulations,the portable voucher is administered here and,while local Housing Authorities have the choice to conduct their own background check,they cannot hold up the use of that voucher to do so. He added that if a criminal record were to be found in a background check,the Housing Authority would terminate the voucher and notify the issuing agency of fraud. Supervisor Uilkema asked if that is the procedure being used here for portable vouchers. Mr.Tamayo responded that in the past,the Housing Authority has accepted vouchers granted by other authorizing agencies without doing additional background checks. Chair Gioia called for public comment, and the following people spoke: Councilmember Jim Conley, City of Antioch, said the fact that the City has become involved in this process speaks volumes as the City should not have to be involved.He stipulated that background checks are not being done for either the portable or the locally issued vouchers. He noted a study done where the findings indicated that two-thirds of Antioch's crime is tied to Section 8 participants. He suggested that proper management of the Housing Authority could alleviate these problems. He commented that today's report is lacking any"next steps."He also noted there is a problem with friends and relatives moving in with program participants without background checks. Chair Gioia said there are also public perceptions about Section 8 participants that may unfairly categorize all participants because of the awareness of the failings of some. He suggested focusing on how to enforce the rules of the program. Supervisor Glover said he would like information about anything that is within the authority of the local Housing Authority that is not being done. Rick Hatton,Danville resident, said he is a landlord who partners with the Housing Authority. He suggested that he is in the business of being a good asset manager, and said the Housing Authority helps landlords take care of their assets because of the regular inspections and property maintenance requirements, in addition to ensuring that money ADDENDUM to D.7 December 5, 2006 Page 2 of 3 comes in reliably.He mentioned that often it is not the tenants who fail to live up to certain standards but the environment itself in which they live. Julie Medina, Concord resident, agreed that crime is a problem in certain areas but said she does not agree that Section 8 is the problem. She said Section 8 participants want to make sure they do not lose their benefits. She said that having been a personal recipient of Section 8 housing benefits, she could comment to the value of the program. She said it enabled her to go back to school and be involved in the lives of her children after her husband's death. She said she would like to see people have a more open mind about the Section 8 program. Ralph Hernandez, Chairperson, Citizens for Democracy and Antioch resident, challenged Gary Gilbert and other involved parties to a public debate on the real problems of Antioch. He said there seems to be a racial and financial bias. (Handout provided to the Board) Monique Dorylan, Staff Attorney for Bay Area Legal Aid, said she could assure the Board that the Housing Authority vigorously pursues Section 8 violations and seeks terminations. She noted the code of federal regulations has very specific procedures for these processes. She commented that a landlord can go through the eviction process if a tenant violates the terms of the lease whether that tenant is a Section 8 participant or not. Chair Gioia noted that whether it is Section 8 housing or not,the cities have a responsibility to inspect and follow code enforcement procedures. Wanda Remmers, Housing Rights,Inc., said the current upheaval about Section 8 in Antioch is disturbing. She offered the services of Housing Rights to the City and the County to help educate tenants and landlords on their responsibilities. Chair Gioia suggested being careful not to use the Section 8 program as a scapegoat for larger social issues. He said that if there is a problem with the program,the focus should be on how to solve it. Supervisor Piepho suggested identifying ways to do annual criminal and background checks on program participants, examining whether such background checks would be a good and financially inexpensive way to keep a check on the program. She suggested reviewing the program with the following questions in mind: How are we checking the system? Who has the extra pair of eyes that can make sure the program is meeting federal guidelines? She said she would like continued discussion on how to improve the program. Diana Tenes,Housing Authority Board Member, said that a lack of understanding about how the program works breeds discrimination against the program. Supervisor Uilkema suggested that landlords have a responsibility to find responsible tenants. She said she would like to see recommendations come back to the Board to show how there is a measurable cooperative plan between the City and the County that, at the end of a period of time, could be reviewed to see if things are getting better and would show the standards by which those things are measured. She suggested that conducting a future hearing where all people could give their thoughts about the Housing Authority would be appropriate. ADDEND UM to D.7 December 5, 2006 Page 3 of 3 Supervisor Glover noted that Mr. Tamayo and the Housing Authority staff have been meeting with law enforcement and with the City of Antioch to look a the process of dealing with people who violate the program. He said we have got to stop having discussions where all the City's problems are blamed on Section 8. He said that many problems also exist with renters and with homeowners. He suggested that rather than spending resources on annual background checks for people who have already qualified for the program,those resources could be better used to deal with code violations. He suggested that whether it be renters, homeowners, or Section 8 participants, problems need to be dealt with as code violations. He encouraged Mr. Tamayo to continue to meet with the City of Antioch and various departments to see how we can all be better partners. He said that at the end of the process, he'd like to see a model that would be good for the County as a whole. Chair Gioia asked what the law requires regarding background checks for Section 8. Mr. Tamayo responded that different states have different regulations, and that Federal law allows local Housing Authorities to set the timeframe from which no criminal activity is allowed to be on the record, which he said for most is usually between one to three years depending on the type of crime. Chair Gioia said he would like to see a copy of Contra Costa's policy on this. He noted the issue of a criminal record can be a complex one, as studies show that recidivism goes up when a person does not have access to jobs or housing. By a unanimous vote—with none absent, Commissioner Diana Tenes present, and the District IV seat vacant—the Board of Supervisors acting as the Housing Authority Board took the following action: ACCEPTED the report from the Housing Authority Executive Director on the Section 8 Housing Choice Voucher Program and the City of Antioch; DIRECTED the Housing Authority Executive Director to continue to work with the City of Antioch to create a plan outlining how to work cooperatively on Section 8 issues,to include a review of a similar cooperative procedure used by the Community Services Department and law enforcement for child abuse issues; DIRECTED the Housing Authority Executive Director to research the possibility of annual criminal background checks on Section 8 program participants and subsequent co-inhabitants;DIRECTED the Housing Authority Executive Director to bring back to the Board in 60 days a report on the outcome of these directions.