Approved NSP grant submission application to HUD

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					         STATE OF NEBRASKA

    DEPARTMENT OF ECONOMIC
         DEVELOPMENT
2008 HOUSING AND COMMUNITY DEVELOPMENT ANNUAL
                   ACTION PLAN
           SUBSTANTIAL PLAN AMENDMENT

   GRANT SUBMISSION FOR $19,600,000 COMMUNITY
   DEVELOPMENT BLOCK GRANT NEIGHBORHOOD
        STABILIZATION PROGRAM FUNDS

             SUBMITTED: DECEMBER 1, 2008
   REVISED PER HUD REQUIREMENTS: FEBRUARY 10, 2009
           THE NSP SUBSTANTIAL AMENDMENT
Jurisdiction(s): __State of Nebraska          NSP Contact Person: Lara Huskey
Department of Economic                        Address:              PO Box 94666
Development____                               Lincoln, NE 68509
                                              Telephone:      402-471-3759
Jurisdiction Web Address:                     Fax:         402-471-8405
        http://www.neded.org                  Email: lara.huskey@nebraska.gov

A. AREAS OF GREATEST NEED

Provide summary needs data identifying the geographic areas of greatest need in the
grantee’s jurisdiction.

Note: An NSP substantial amendment must include the needs of the entire jurisdiction(s)
covered by the program; states must include the needs of communities receiving their
own NSP allocation. To include the needs of an entitlement community, the State may
either incorporate an entitlement jurisdiction’s consolidated plan and NSP needs by
reference and hyperlink on the Internet, or state the needs for that jurisdiction in the
State’s own plan. The lead entity for a joint program may likewise incorporate the
consolidated plan and needs of other participating entitlement jurisdictions’ consolidated
plans by reference and hyperlink, or state the needs for each jurisdiction in the lead
entity’s own plan.

HUD has developed a foreclosure and abandonment risk score to assist grantees in
targeting the areas of greatest need within their jurisdictions. Grantees may wish to
consult this data in developing this section of the Substantial Amendment.

Response

The information from Realty Trac and HUD estimates were compared for all Nebraska
counties. Overall the areas of greatest need are determined to be counties that
demonstrate (a) there is at least one recorded foreclosure per Realty Trac and the HUD
foreclosure rate is 2.0% or greater or (b) the HUD estimated foreclosures are 30 or
greater and the HUD foreclosure rate is 5.0% or greater. Nebraska Department of
Economic Development (DED) Community Development Block Grant (CDBG)
Neighborhood Stabilization Program (NSP) funds are not available statewide. Funds
must be used in incorporated areas that are located in the Areas of Greatest Need counties
referenced below. This geographic distribution that is targeted is further substantiated in
Section G. NSP Information by Activity which clearly demonstrates that funds are not
proposed to be used statewide.

  (1) The area of greatest need for Community Development Block Grant (CDBG) NSP
      assistance is determined to be Douglas County and Sarpy County.



                                                                                         2
County          Realty Trac        HUD                Realty Trac      HUD estimated
                foreclosure rate   foreclosure rate   estimated        foreclosures
                                                      foreclosures
   Douglas           1.85%              3.5%               3,924            4,439
    Sarpy            1.83%              2.7%               1,059            1,137

  (2) The next area of greatest need for CDBG NSP assistance is determined to be
      Lancaster County.
County           Realty Trac        HUD            Realty Trac        HUD estimated
                 foreclosure rate foreclosure rate estimated          foreclosures
                                                   foreclosures
  Lancaster           0.73%               2.0%            848               1,391

  (3) The next area of greatest need for CDBG NSP assistance is determined to be the
      counties of Cass, Hall, and Washington.
County            Realty Trac       HUD             Realty Trac       HUD estimated
                  foreclosure rate foreclosure rate estimated         foreclosures
                                                    foreclosures
     Cass              1.46%              4.4%            163                309
     Hall              0.23%              7.0%             53                450
 Washington            1.75%              3.0%            141                141

  (4) The next area of greatest need for CDBG NSP assistance is determined to be the
      counties of Dakota, Red Willow, Saunders, and Scotts Bluff.

County          Realty Trac        HUD                Realty Trac      HUD estimated
                foreclosure rate   foreclosure rate   estimated        foreclosures
                                                      foreclosures
   Dakota            0.19%              4.7%                 15              144
 Red Willow          0.34%              3.8%                 18               35
  Saunders           0.76%              3.5%                 69              162
 Scotts Bluff        0.40%              5.9%                 65              257

  (5) The next area of greatest need for CDBG NSP assistance is determined to be the
      counties of Adams, Antelope, Buffalo, Burt, Chase, Cheyenne, Clay, Colfax,
      Cuming, Dawes, Dawson, Dixon, Dodge, Franklin, Gage, Garfield, Hamilton,
      Harlan, Holt, Howard, Jefferson, Johnson, Kearney, Keith, Kimball, Loup,
      Madison, Merrick, Nemaha, Nuckolls, Otoe, Perkins, Phelps, Pierce, Platte, Polk,
      Richardson, Saline, Seward, Stanton, Thayer, and Thurston.




                                                                                         3
County        Realty Trac        HUD                Realty Trac    HUD estimated
              foreclosure rate   foreclosure rate   estimated      foreclosures
                                                    foreclosures
   Adams          0.02%               5.1%                  3           167
  Antelope        0.03%               6.8%                  1            29
   Buffalo        0.01%               3.5%                  2           189
     Burt         0.16%               7.9%                  6            97
    Chase            -                8.8%                  -            30
 Cheyenne            -                5.8%                  -            77
     Clay            -                6.3%                  -            41
   Colfax         0.17%               6.1%                  7            57
   Cuming         0.30%               4.0%                 13            37
   Dawes          0.02%               3.1%                  1            19
   Dawson         0.02%               5.9%                  2           173
    Dixon         0.04%               4.6%                  1            34
   Dodge          0.09%               5.8%                 15           289
  Franklin        0.12%               6.9%                  2            11
    Gage          0.05%               5.0%                  5           176
  Garfield        0.10%               4.7%                  1             8
  Hamilton        0.03%               4.5%                 1             70
   Harlan         0.04%               3.8%                  1             9
     Holt         0.02%               5.6%                  1            62
   Howard            -                5.8%                  -            35
  Jefferson          -                6.4%                  -            56
  Johnson         0.14%               6.7%                  3            38
  Kearney         0.04%               6.0%                 1             46
    Keith            -                5.1%                  -            59
   Kimball        0.10%               8.1%                 2             31
    Loup          0.52%               7.7%                  2             3
  Madison         0.01%               5.0%                 1            170
   Merrick        0.03%               6.7%                 1            60
  Nemaha          0.11%               6.4%                 4             43
  Nuckolls        0.12%               5.2%                  3            13
     Otoe         0.09%               4.6%                  6           114
   Perkins        0.07%               7.5%                 1             23
   Phelps         0.12%               3.4%                  5            49
    Pierce           -                5.8%                  -            32
    Platte        0.01%               3.6%                  1           105
     Polk            -                5.7%                  -            30
 Richardson          -                5.3%                  -            34
    Saline        0.03%               5.0%                 2            105
   Seward         0.04%               3.5%                  3           122
   Stanton           -                6.8%                  -            40
   Thayer         0.03%               4.7%                  1            13
  Thurston        0.04%               9.0%                  1            19

                                                                               4
Projects in the following counties are not eligible for DED CDBG NSP funds because
these are determined to be areas that are not of greatest need.

Arthur, Banner, Blaine, Boone, Box Butte, Boyd, Brown, Butler, Cedar, Cherry, Custer,
Deuel, Dundy, Fillmore, Frontier, Furnas, Garden, Gosper, Grant, Greeley, Hayes,
Hitchcock, Hooker, Keya Paha, Knox, Lincoln, Logan, McPherson, Morrill, Nance,
Pawnee, Rock, Sheridan, Sherman, Sioux, Thomas, Valley, Wayne, Webster, Wheeler,
and York.

                                                       Realty Trac
                   Realty Trac           HUD                           HUD estimated
    County                                              estimated
                 foreclosure rate   foreclosure rate                    foreclosures
                                                       foreclosures
    Arthur               -               8.3%                -                 2
    Banner               -               4.2%                -                 1
    Blaine               -               4.2%                -                 1
    Boone                -               4.0%                -                14
  Box Butte              -               4.9%                -                63
     Boyd                -               5.4%                -                 2
    Brown                -               4.0%                -                10
    Butler               -               4.1%                -                49
    Cedar                -               2.7%                -                20
    Cherry               -               2.3%                -                12
    Custer               -               3.9%                -                34
    Deuel                -               9.0%                -                21
    Dundy                -               8.5%                -                10
   Fillmore              -               6.8%                -                29
   Frontier              -               5.3%                -                12
    Furnas               -               7.1%                -                27
    Garden               -               4.4%                -                 5
    Gosper               -               3.2%                -                 8
    Grant                -               9.1%                -                 2
   Greeley               -               5.7%                -                 5
    Hayes                -               8.1%                -                 3
  Hitchcock              -               4.8%                -                7
   Hooker                -               1.9%                -                 1
  Keya Paha              -                 -                 -                 -
     Knox                -               3.8%                -                22
   Lincoln               -               4.5%                -               225
    Logan                -               4.1%                -                 2
  McPherson              -               3.4%                -                1
    Morrill              -               5.4%                -                22
    Nance                -               5.7%                -                12
   Pawnee                -               6.9%                -                11
     Rock                -               1.6%                -                 1
   Sheridan              -               4.4%                -                15

                                                                                        5
                                                          Realty Trac
                     Realty Trac           HUD                             HUD estimated
    County                                                 estimated
                   foreclosure rate   foreclosure rate                      foreclosures
                                                          foreclosures
   Sherman                -               5.7%                  -                  9
    Sioux                 -               4.5%                  -                  3
   Thomas                 -               8.9%                  -                  5
    Valley                -               4.0%                  -                 15
    Wayne                 -               4.4%                  -                 32
   Webster                -               5.3%                  -                 10
   Wheeler                -               15.0%                 -                  3
    York                  -               4.4%                  -                 64

DED analyzed and compared data from each of the following sources to determine areas
of greatest need.
    1. First American Core Logic Data;
    2. Federal Reserve Bank of New York Sub-prime Mortgage Data;
    3. HUD provided Local Level Data; and
    4. Realty Trac
    5. DED CDBG NSP Pre-applications

First American Core Logic Data

Data Sources

Securities Data

Securities Data is a loan-level dataset with over 80 data fields of static and monthly
performance information. All the loans are collateral in non-agency, publicly-placed
mortgage backed securities. Historical data goes back to 1992. The data covers 95+% of
the non-agency market representing roughly $2 trillion in outstanding balances. Monthly
data includes delinquency, foreclosure, payoff, and dollar loss.

Servicing Data

Servicing Data is a cooperative loan-level dataset with over 40 data fields of static and
monthly performance information. All the loans are contributed by the nation’s largest
servicers. The data covers more than 75% of the nation’s active first mortgages, more
than 38 million, including all of the Fannie Mae and Freddie Mac portfolios.

Federal Reserve Bank of New York Sub-prime Mortgage Data

  SUBPRIME MORTGAGE CONDITIONS IN NEBRASKA COMPARED TO THE
                   OVERALL UNITED STATES
                         (JULY 2008)



                                                                                            6
        The table below indicates that the banking and housing industries in Nebraska are
generally less impacted by difficulties associated with subprime mortgage loans than in
the United States as a whole on most measures. The data in the table were released by
the Federal Reserve Bank of New York (www.newyorkfed.org). The data are apparently
for a period including 2007 and early 2008.
        Subprime loans per 1000 housing units. Nebraska had 14.5 percent owner-
occupied subprime loans per 1,000 housing units, compared to 23.4 percent for the total
United States. The Federal Reserve Bank of New York estimates these data cover 47
percent of subprime loans and assumes that the covered loans are representative of the
entire subprime market.
        In foreclosure per 1,000 housing units. Nebraska had 0.9 owner-occupied
subprime loans per 1,000 housing units where the lender has initiated the foreclosure
process but has not completed it. This was considerably less than a rate of 2.5 per 1,000
for the total U.S. This is a measure of the stock of loans in foreclosure at a particular
time, not the rate of completed foreclosures.
        Real estate-owned properties (REOs) per 1,000 housing units. With real estate-
owned properties (REOs), the lender has taken legal title to the property through
foreclosure or transference of title from the borrower. Nebraska had 0.5 REOs resulting
from subprime loans per 1,000 housing units, compared to 1.6 for the total U.S.
        Share adjustable rate mortgages (ARMs). This is the percent of owner-occupied
subprime loans that have a variable rate of interest that will be reset periodically in
contrast to loans with interest rates fixed to maturity. ARMs are given special
consideration because they traditionally have a higher likelihood of being delinquent or
foreclosed upon than fixed rate loans. This is true in both the prime and subprime
markets. Nebraska’s share of ARMs (62.6%) was only slightly below the U.S. figure
(63.1%).
        Share current. This is the percent of owner-occupied subprime loans for which
the borrower’s payments are up to date. Loans in this category may have at some time
been delinquent but were caught up at the end of the period measured. With 66.7% of
loans current, Nebraska compared favorably to a rate of 58.3% for the total U.S.
        Share 90 days delinquent. This is the percent of owner-occupied subprime loans
where the loan payment is 90 or more days overdue but the loan is not in foreclosure or
REO. Nebraska has a slightly lower percent (8.4%) on this measure than the overall
nation (9.2%).
        Share in foreclosure. For 6.3% of Nebraska’s owner-occupied subprime loans,
the lender had initiated the foreclosure process but not completed it. Again, this is a more
favorable share than for the total U.S. (10.7%).
        Median combined loan to value (LTV). The combined loan to value (LTV) is the
ratio of the loan amount to the value of property at origination, and the median, of course,
is the value at which half of LTVs are higher and half are lower. On this measure,
Nebraska was higher (90.0%) than the total U.S. (87.4%).
        Share low FICO & high combined loan to value (LTV). FICO is a credit bureau
risk score. The higher the FICO score, the lower the likelihood of delinquency or default
for a loan. Also, the lower the FICO score, generally the higher the cost of borrowing
(interest rate) will be. For this measure, the share of subprime loans was calculated that
had both FICO scores below 620 (the national average) and LTVs above 90%. Here

                                                                                          7
Nebraska did not score as well as the nation as a whole. The Nebraska share was 20%,
compared to 13.3% for the total U.S.
        Share low or no documentation. This measure is the percent of owner-occupied
subprime loans for which the borrower provided little or no verification of income and
assets in order to receive a mortgage. Tighter loan standards in Nebraska were indicated
by a significantly lower share (19.3%) of loans with low or no documentation compared
to the national figure (32.9%).
        Share adjustable rate mortgages (ARMs) resetting in 12 months. This measure
shows the percent of adjustable rate mortgages (ARMs) for which the rate of interest is
scheduled to undergo its first rate reset within the next 12 months. The Nebraska share
was 28.5%, compared to 33.1% for the total U.S.
        Share late payment last 12 months. Difficulties in paying on time often precede
more serious defaults. This measure shows the share of subprime owner-occupied loans
for which at least one payment has been late over the past 12 months. Nebraska’s share
was 50.3%, compared to a national figure of 56.6%.

      Subprime Mortgage Conditions in Nebraska and the Overall United States
             (Source: Federal Reserve Bank of New York, July 2008)

                                                                                   United
Measure                                                           Nebraska         States
Loans Per 1,000 Housing Units                                         14.5           23.4
In Foreclosure Per 1,000 Housing Units                                  0.9            2.5
Real Estate-Owned Properties (REOs) Per 1,000 Housing
Units                                                                    0.5           1.6
Share Adjustable Rate Mortgages (ARMs)                               62.6%         63.1%
Share Current                                                        66.7%         58.3%
Share 90 days Delinquent                                              8.4%          9.2%
Share in Foreclosure                                                  6.3%         10.7%
Median Combined Loan to Value (LTV)                                  90.0%         87.4%
Share Low FICO & High Combined Loan to Value (LTV)                   20.0%         13.3%
Share Low or No Documentation                                        19.3%         32.9%
Share Adjustable Rate Mortgages (ARMs) Resetting in 12
months                                                               28.5%         33.1%
Share Late Payment Last 12 Months                                    50.3%         56.6%


HUD provided Local Level Data
Neighborhood Stabilization Program - Revised 10-20-08
Methodology and Data Dictionary for HUD Provided Data
Background

Using data from the Mortgage Bankers Association National Delinquency Survey as of
June 2008, HUD has calculated the approximate number of foreclosure starts for all of
2007 and the first six months of 2008 (“Foreclosure Starts over 18 months”) at the
statewide level.

                                                                                           8
The Mortgage Bankers Association (MBA) data are not available for geographic areas
smaller than states. As such, HUD has identified data collected by other federal agencies
that prove to be good predictors of where foreclosures are likely. HUD has used those
data to “distribute” the statewide counts of foreclosure starts among the neighborhoods,
places, and counties within each state.

To test the reliability of HUD’s estimated foreclosure rate at the local level, HUD asked
the Federal Reserve to compare HUD’s estimate to data the Federal Reserve had from
Equifax showing the percent of households with credit scores that were delinquent on
their mortgage payments 90-days or longer. The Equifax data are based on a 5 percent
sample of all credit records in the United States. As such, they are more reliable for
counties with higher population counts (a larger sample size reduces sampling error) than
those with smaller population counts. At the statewide level, 90-day delinquencies from
Equifax and the MBA data on foreclosure starts are closely related, that is they have a
very high correlation with one another (0.90 where 1 is a perfect correlation).

Analysis by the Federal Reserve staff found that when comparing the HUD predicted
county foreclosure rates to the Equifax county level rates of delinquencies, HUD’s data
and the Equifax data had high intrastate correlations. For example, within the state of
California, the correlation was 0.835 (where 1 is a perfect correlation). The county level
intrastate correlations were higher when the analysis was restricted to counties with
greater than 15,000 households. There are reasons that either the HUD estimated
foreclosure rate or Equifax delinquency data could be wrong, but when they are very
similar to one another in a particular community, we have a greater confidence that
HUD’s estimated foreclosure rate and the Equifax delinquency data are accurately
targeting the problem.

HUD also obtains data from the United States Postal Service (USPS) on addresses that
have been vacant for 90-days or longer. The USPS collects these data to reduce delivery
of bulk mail to homes where no one is picking up the mail. While there are many reasons
for homes being vacant for 90-days or longer, HUD believes that if a Census Tract is
found to be estimated to have a higher rate of foreclosures and it has a high rate of homes
90-days or more vacant, abandonment risk associated with the foreclosure crisis is higher
in those neighborhoods.

HUD is providing its data on estimated foreclosures (based on risk) and vacancy data to
assist state and local governments in their efforts to target the communities and
neighborhoods with the greatest needs. HUD recommends that if states and local
governments have local data, such as county data on foreclosure filings, that those data
also be given serious consideration in identifying areas of greatest needs.

HUD has created data files at several areas of geography to assist local and state
governments:
   (1) County
   (2) County-Place

                                                                                             9
      (3) Census Tract
      (4) Block Group (part)

The County, County-Place, and Census Tract files contain the same data:
   • Estimated number and percent of foreclosure starts over the past 18 months
      through June 2008
   • Number and percent of vacant addresses in June 2008
   • Data used to calculated the estimated foreclosure rates
          o Federal Reserves Home Mortgage Disclosure Act Data on high cost loans
          o Office of Federal Housing Enterprise Oversight Data on falling home
             prices
          o Bureau of Labor Statistics data on place and county unemployment rates

The Block Group (part) file includes:
    • Number and percent of persons estimated at less than 120 percent of median
         income
    • A “foreclosure and abandonment risk score” that is a function of the estimated
         foreclosure rate and percent of addresses vacant
    • Percent of foreclosure starts over the past 18 months through June 2008
    • Percent of vacant addresses in June 2008
    • Data used to calculate the estimated foreclosure rates
             o Federal Reserves Home Mortgage Disclosure Act Data on high cost loans
             o Office of Federal Housing Enterprise Oversight Data on falling home
                 prices
             o Bureau of Labor Statistics data on place and county unemployment rates
Methodology
All of the files provide estimates of foreclosures based on a formula that calculates the
rate of foreclosure starts over the past 18 months as a function of:

      •   Metropolitan area decline in home values as of June 2008 against peak home
          values in June of any previous year between 2000 and 2008. If home values have
          not declined, it is zero. These data are from the Office of Federal Housing
          Enterprise Oversight (OFHEO) 1 Home Price Index. Data for non-metropolitan
          balances of states are from the March 2008 Home Price Index.

      •   County or Place Level unemployment rate as of June 2008 from the Bureau of
          Labor Statistics Local Area Unemployment Rate data.

      •   Census Tract Level Data on number of loans made between 2004 and 2006 from
          the Home Mortgage Disclosure Act (HMDA) data and the number of those loans
          that are high cost (where the rate spread is 3 percentage points above the Treasury
          security of comparable maturity).



1
    Now the Federal Housing Finance Agency (FHFA). Data available from www.ofheo.gov.

                                                                                          10
States with very high rates of correlation between HUD’s foreclosure rate estimates and
Equifax 90 day delinquencies (correlation of 0.80 or higher) are California, Connecticut,
Hawaii, Maryland, New Jersey, Rhode Island, and South Carolina. States with a
modestly high rate of correlation (correlation 0.60 to 0.79) are Arizona, Florida,
Massachusetts, Michigan, and South Dakota.

While most of the remaining states had correlations that were positive and significant, the
correlations were lower. The reason for the lower rate of correlations could be because
the model HUD is using to estimate foreclosure rates does not account for the factor or
factors most contributing to foreclosures in that state, the sampling errors in the Equifax
data makes the comparison data inaccurate, there is not enough variation between
counties on the data in the model to show significant variations in county foreclosure
rates, or some other reason. Notably, intrastate correlations between the HUD estimated
foreclosure rate and the Equifax data improve dramatically when only counties with more
than 15,000 households are included in the analysis. When making this restriction, 23
intrastate correlations are greater than 0.6 (see Appendix 1). Since the Equifax data are
sample data, their accuracy is improved by having a larger N while the HUD model is
also more accurate for communities within the metropolitan areas that OFHEO calculates
price change information.

All grantees are advised to look to other local data when considering their areas of
greatest need, particularly if they are not among the states listed as having high rates of
intrastate correlation between the HUD estimated foreclosure rate and the Equifax 90-day
delinquency data. Even in states with relatively low correlation, HUD believes that the
data it is providing are useful for identifying areas state and local governments should
review as possible candidates for targeting funds because they have underlying
characteristics that make them at significant risk for foreclosures and abandoned homes.

Data Dictionary for County, County-Place, and Tract Files
Geographic Identifiers in Each File Are As Follows:

County Level File
   • countycode - 5 character combination of state and county FIPS codes
   • state - 2 character state FIPS code
   • sta - 2 character state alphanumeric abbreviation
   • county - 3 character county FIPS code
   • countyname - county name




                                                                                        11
Appendix 1: Pearson Correlation Comparison of HUD County Foreclosure Rate Estimate to Equifax 90-
day mortgage delinquency sample data for Counties with over 15,000 Households
          Correlation                               Correlation                     Correlation
          when                                      when                            when
          restricted                                restricted                      restricted
          to counties N (counties                   to counties N (counties         to counties N (counties
          above         greater than                above          greater than     above        greater than
          15,000        15,000                      15,000         15,000           15,000       15,000
State     households households) State              households households) State    households households)
AK                 ***             4 KY                      ***             21 NY         0.545           55
AL                 ***            32 LA                      ***             27 OH         0.556           62
AR               0.606            18 MA                    0.779             12 OK           ***           22
AZ               0.823            11 MD                    0.874             18 OR         0.587           18
CA               0.862            45   ME                    ***             10 PA         0.632           55
CO               0.735            15 MI                    0.777             40 PR           ***            0
CT               0.840             8 MN                    0.466             22 RI         0.942            5
DC                 ***             1 MO                    0.587             25 SC         0.788           25
DE                 ***             3 MS                    0.625             16 SD         1.000            2
FL               0.799            43 MT                      ***               6 TN        0.570           37
GA               0.676            42 NC                    0.641             58 TX         0.428           63
HI               0.970              4 ND                     ***               4 UT          ***            6
IA               0.750            17 NE                    0.821               5 VA        0.531           40
ID               0.876              7 NH                  -0.678               9 VT          ***            6
IL               0.593            34 NJ                    0.920             21 WA         0.619           23
IN               0.591            37 NM                      ***             13 WI         0.468           35
KS               0.976            11 NV                    0.883               5 WV        0.594           14
***If data not shown, it was not statistically significant at the .05 level or
better                                                                           WY       -1.000            2
       States with correlations 0.6 or higher shown in bold.

      HUD provided Local Level Data on LMMI block groups (part) and foreclosure risk
      scores
      This information was found at
      http://www.huduser.org/publications/commdevl/nsp_target.html

      The data used to calculate the risk scores are also included in the file. The data used here
      are from different levels of geography, as noted below. That is, the data on home price
      change is for the whole metropolitan area, not just for the neighborhood and
      unemployment is for the place or county, not just the neighborhood. The high-risk loan
      rate and address vacancy data are at the neighborhood (Census Tract) level:

          •   Office of Federal Housing Enterprise Oversight (OFHEO) data on decline in
              home values as of June 2008 compared to peak home value since 2000 at the
              Metropolitan/Micropolitan/Non-Metropolitan level
              ("OFHEO_CBSA_home_price_decline_since_peak").


                                                                                                12
        •     Federal Reserve Home Mortgage Disclosure Act (HMDA) data on percent of all
              loans made between 2004 and 2006 that are high cost at the Census Tract Level
              ("HMDA_hi_cost_loan_rate").
        •     Labor Department data on unemployment rates in places and counties as of June
              2008 ("BLS_place_or_county_unempoloyment_rate_0608").
        •     USPS data on residential addresses identified as being vacant for 90 days or
              longer as of June 2008 at the Census Tract level
              ("USPS_residential_vacacancy_rate").

    B. DISTRIBUTION AND USES OF FUNDS

    Provide a narrative describing how the distribution and uses of the grantee’s NSP funds
    will meet the requirements of Section 2301(c)(2) of HERA that funds be distributed to
    the areas of greatest need, including those with the greatest percentage of home
    foreclosures, with the highest percentage of homes financed by a subprime mortgage
    related loan, and identified by the grantee as likely to face a significant rise in the rate of
    home foreclosures. Note: The grantee’s narrative must address these three stipulated
    need categories in the NSP statute, but the grantee may also consider other need
    categories.

    Response:

    The distribution and uses of funds are consistent with the requirements of Title III of
    Housing and Economic Recovery Act Section 2301(b)(3) by allocating funds according
    to the data provided in the Areas of Greatest Need section of this plan.

    DED proposes to use funds in each of the need areas starting with the area of greatest
    need level 1. DED recognizes that grantees will have limitations on the ability to
    administer the funds within the accelerated timeframe of the CDBG NSP. Therefore,
    funds distributed to each Level are limited by the capacity to expend funds within the
    CDBG NSP deadlines.

Need        Geographic Area                      Proposed amount of       Proposed uses
Level                                            NSP to be awarded
1           Douglas and Sarpy Counties           $6,432,000               (A) Establishing financing
2           Lancaster County                     $4,000,000                   mechanisms for
3           Cass, Hall, and Washington           $3,000,000                   purchase and
            counties                                                          redevelopment of
4           Dakota, Red Willow, Saunders,        $2,500,000                   foreclosed homes and
            and Scotts Bluff counties                                         residential properties;




                                                                                                  13
5        Adams, Antelope, Buffalo, Burt,        $2,100,000              (B) Purchasing and
         Chase, Cheyenne, Clay, Colfax,                                     rehabilitating homes and
         Cuming, Dawes, Dawson, Dixon,                                      residential properties
         Dodge, Franklin, Gage, Garfield,                                   abandoned or foreclosed;
         Hamilton, Harlan, Holt, Howard,                                (D) Demolishing blighted
         Jefferson, Johnson, Kearney,                                       structures; or
         Keith, Kimball, Loup, Madison,                                 (E) Redeveloping
         Merrick, Nemaha, Nuckolls, Otoe,                                   demolished or vacant
         Perkins, Phelps, Pierce, Platte,                                   properties
         Polk, Richardson, Saline, Seward,
         Stanton, Thayer, and Thurston
         counties
         Subrecipient (DED grantee)                $784,000        General Administration
         State Administration                      $784,000        General Administration
         Total                                  $19,600,000        Activities (A), (B), (D), (E),
                                                                   and General Administration
    Funds can be distributed from lower Need Levels to higher Need Levels using the
    Application Scoring Process outlined in the following section.

    Projects specified in the DED CDBG NSP Grant Submission for Section G.
    Section G. of the DED CDBG NSP Grant Submission was developed using the following
    method:

    Step 1: DED provided a pre-application form for potential Nebraska projects and held a
    DED CDBG NSP briefing to present the strategy and pre-application form. The pre-
    application form was available October 17, 2008 and due November 3, 2008. This pre-
    application was substantially equivalent to the NSP application and checklist required for
    the DED substantial plan amendment to receive the State allocation of CDBG NSP. DED
    did inform communities that the pre-application was required to have a potential project
    included in the DED grant submission.

    Step 2: Analyze “area of greatest need” information for the state – see Section A of this
    plan.

    Step 3: Determine general allocation of funds and eligible activities per “areas of greatest
    needs” data – See DED CDBG NSP allocation table in this section.

    Step 4: Pre-applications were reviewed and an Eligibility and Feasibility score was
    assigned. DED did not ask pre-applicants to address the Eligibility and Feasibility
    criteria in the pre-application. Instead, the criteria were more generally presented as (1)
    the project is eligible, (2) the project can be completed expeditiously, and (3) the project
    administrator and partners have the capacity to produce the intended results. The below
    score was developed as an objective measure of these three original criteria.
    All projects meet the goals of the NSP to stabilize neighborhoods.




                                                                                               14
10 = (a) project will contribute to meeting the state requirement that 25% of the funds
will be used to provide housing for families with incomes at or below 50% of the Area
Median Family Income, (b) the national objective can be met quickly, and the project
timeline is clearly feasible, and (c) the project was determined to be definitely eligible for
NSP.

9 = (a) project service area is targeted and the project meets a priority goal of the Housing
and Community Development Plans, (b) the national objective can be met quickly or the
project timeline is clearly feasible, and (c) the project was determined to be definitely
eligible for NSP.

8 = (a) project meets Housing and Community development plan goals, (b) the national
objective can be met quickly or the project timeline is clearly feasible, and (c) the project
was determined to be definitely eligible for NSP.

7 = (a) project activities are targeted or the project meets a priority goal of the Housing
and Community Development Plans, (b) the national objective can be met quickly, or the
project timeline is clearly feasible, and (c) the project was determined to have a high
likelihood for NSP eligibility.

6 = (a) project meets Housing and Community Development Plan goals, (b) the national
objective can be met quickly, or the project timeline is likely feasible, and (c) the project
was determined to have a high likelihood for NSP eligibility.

5 = (a) project activities are targeted or the project meets a priority goal of the Housing
and Community Development Plans, (b) the national objective can be met quickly, or the
project timeline is likely feasible, and (c) the likelihood of the project eligibility for NSP
is unknown.

4 = (a) project meets Housing and Community Development Plan goals, (b) the national
objective can be met quickly, or the project timeline is likely feasible, and (c) the
likelihood of the project eligibility for NSP is unknown.

3 = (a) project activities are targeted and does not meet Housing and Community
Development Plan goals, (b) the national objective can be met; however, timeliness is
uncertain, and (c) the project was determined to be definitely eligible for NSP.

2 = (a) project activities are targeted and does not meet Housing and Community
Development Plan goals, (b) the national objective can be met; however, timeliness is
uncertain, and (c) the project was determined to have a high likelihood for NSP
eligibility.

1 = (a) project activities are targeted and does not meet Housing and Community
Development Plan goals, (b) the national objective can be met; however, timeliness is
uncertain, and (c) the likelihood of the project eligibility for NSP is unknown.



                                                                                            15
0 = project is definitely ineligible for NSP.

Step 5: The pre-applications were reviewed for proposed changes per the HUD response
to the original DED plan submission and required changes. Pre-applicants were
responding based on the original allocation strategy; therefore, adjustments were needed.
This included a revision in budget, location, and narrative as needed to clearly
demonstrate the appropriate Area Need Level for the pre-application.

Step 6: The pre-application was sorted by (1) the Eligibility and Feasibility score
(highest to lowest), (2) the Area Need Level (first to fifth), and (3) the amount of NSP
investment proposed and potential impact on the neighborhood, (highest to lowest).
These projects still had to demonstrate a high likelihood that project activities could be
completed in an expeditious manner.

Step 7: Pre-applications were identified (in whole or in part) according to the Proposed
DED CDBG NSP Allocation Table in this section. Some projects are proposed to receive
a portion of the total requested to ensure eligibility and feasibility of the project. In
addition, funds can be redistributed per the Allocation table in this section from lower
Need Levels to higher Need Levels.

Step 8: In order to ensure that the requirement to award a minimum of 25% of the funds
for projects that include purchasing and rehabilitating homes and residential properties
abandoned or foreclosed upon that will result in housing very low-income persons, the
department proposes to set-aside funds for this activity within the two highest need areas.
City of Omaha - $4,000,000
City of Lincoln - $1,000,000
An application form will be provided for both grantees by March 18, 2009 due to the
department by May 6, 2009. The City in each case may designate an eligible non-profit
to be the direct grantee of funds in the application. If all application thresholds are met,
funds are anticipated to be conditionally awarded by June 30, 2009.

Step 9: Application Guidelines including all necessary information to determine project
eligibility and feasibility will be available March 18, 2009.

Step 10: Full applications are due (received) May 6, 2009. All eligible applicants and
projects may submit an application for DED CDBG NSP funds by May 6, 2009.

Step 11: Project applications will be selected using the following Feasibility and Priority
Score and cross-referenced with the Area Need Level as described in Step 7 of this
section. This application score is similar to the Eligibility and Feasibility Score;
however, eligibility will be determined prior to assigning a score since all projects will
have to be eligible to receive award and release of funds. In the case of a tie, the project
that is determined to have the highest likelihood to meet the aggressive timeline
requirements for implementation of the Neighborhood Stabilization program will be
selected. The track record of the administrator and the applicant with past DED program



                                                                                             16
awards will be reviewed. If the applicant is a non-profit in Lincoln or Omaha, DED may
consult with the City about the applicant and administrator capacity

The department contracted with First American Core Logic in 2008 to obtain detailed
data. A table was developed identifying Nebraska zip code areas with the highest ratios
of housing foreclosures to households. The foreclosures data are the monthly averages of
foreclosures shown for the January 2007-June 2008 period. The data on households are
from the 2000 census. A scoring procedure was developed to consider a combination of
the average number of foreclosures per month and the ratio of foreclosures to households
in each zip code area in the state. The table of zip codes that meet the below scoring
criteria will be available to applicants on the DED CDBG NSP web-page.

Category A zip code area –average per month foreclosure rate of 3 or higher or a
foreclosures/households ratio of 0.60% or higher

Category B zip code area –average per month foreclosure rate of 1.0 or higher or a
foreclosures/households ration of 0.40% or higher
(Category A zip code area also qualifies as a Category B zip code area for the purposes of
applying the below scoring criteria)

Feasibility and Priority Score for full applications

10 = (a) project is located entirely in Category A zip code area(s) and (b) the project
timeline is clearly feasible considering the capacity of the administrator and the grantee,
and the project was submitted in a pre-application in 2008.

9 = (a) project is located entirely in Category A zip code area(s), and (b) the project
timeline is likely feasible considering the capacity of the administrator and the grantee,
and the project was submitted in a pre-application in 2008.

8 = (a) project is located entirely in Category B zip code area(s) and (b) the project was
submitted as a pre-application in 2008, and the project timeline is clearly feasible
considering the capacity of the administrator and the grantee.

7 = (a) project is located entirely in Category B zip code area(s), and (b) the project was
submitted as a pre-application in 2008, and the project timeline and compliance are likely
feasible considering the capacity of the administrator and grantee.

6 = (a) project is located entirely in Category B zip code area(s), and (b) the project was
submitted in a pre-application in 2008, or the project timeline and compliance are likely
feasible considering the capacity of the administrator and grantee.

5 = (a) project does not meet the criteria for scores 6-10, and (b) the project was
submitted as a pre-application in 2008, and the project timeline is clearly feasible
considering the capacity of the administrator and the grantee.



                                                                                             17
4 = (a) project does not meet the criteria for scores 6-10, and (b) the project was
submitted as a pre-application in 2008, and the project timeline and compliance are likely
feasible considering the capacity of the administrator and grantee.

3 = (a) project is located entirely in Category B zip code area(s), and (b) the national
objective can be met, but timeliness and likelihood for compliance are uncertain
considering the capacity of the grantee and administrator.

2 = (a) project does not meet the criteria for scores 6-10, and (b) the project was
submitted in a pre-application in 2008, or the project timeline and compliance are likely
feasible considering the capacity of the administrator and grantee.

1 = (a) project does not meet the criteria for scores 6-10, and (b) the national objective
can be met, but timeliness and likelihood for compliance are uncertain considering the
capacity of the grantee and administrator.

0 = the project clearly cannot meet the proposed timeline considering the capacity of the
grantee and administrator.

C. DEFINITIONS AND DESCRIPTIONS

(1) Definition of “blighted structure” in context of state or local law.

Response:

Definition of blighted structure

The State of Nebraska definition of blighted structure for purposes of implementing the
Community Development Block Grant Neighborhood Stabilization Program is as
follows:

       Blighted structure includes, but is not limited to, any dwelling, garage,
       outbuilding, warehouse, commercial building, or any other structure or part of a
       structure, which:
               (a) because of the effects of fire, wind, flood, or other natural disaster;
               (b) because of physical deterioration; or,
               (c) because of demolition, or partial demolition, not carried out to
                   completion within a reasonable period of time;

       is no longer habitable as a dwelling or, in the case of a non-dwelling structure, is
       no longer useful for the purpose for which the non-dwelling structure was
       intended, and which has been designated by a State CDBG-recipient unit of local
       government or non-profit organization as detrimental to the public health or safety
       in its present condition and use.

Definition of blighted structure in the context of state law

                                                                                             18
A definition for “blighted structure” is not contained in Nebraska law. The above
definition was developed by incorporating frequently occurring elements from definitions
of blighted structure by other governmental entities with appropriate elements from the
definitions for substandard area and blighted area in the Nebraska Community
Development Law. The following definitions contained in Nebraska State Law are
related to defining blighted structures.

Nebraska Community Development Law - Nebraska Statute Section 18-2103 (10)

Substandard areas means an area in which there is a predominance of buildings or
improvements, whether nonresidential or residential in character, which, by reason of
dilapidation, deterioration, age or obsolescence, inadequate provision for ventilation,
light, air, sanitation, or open spaces, high density of population and overcrowding, or the
existence of conditions which endanger life or property by fire and other causes, or any
combination of such factors, is conducive to ill health, transmission of disease, infant
mortality, juvenile delinquency, and crime, (which cannot be remedied through
construction of prisons), and is detrimental to the public health, safety, morals, or
welfare;

Nebraska Community Development Law - Nebraska Statute Section 18-2103 (11)

Blighted area means an area, which (a) by reason of the presence of a substantial number
of deteriorated or deteriorating structures, existence of defective or inadequate street
layout, faulty lot layout in relation to size, adequacy, accessibility, or usefulness,
insanitary or unsafe conditions, deterioration of site or other improvements, diversity of
ownership, tax or special assessment delinquency exceeding the fair value of the land,
defective or unusual conditions of title, improper subdivision or obsolete platting, or the
existence of conditions which endanger life or property by fire and other causes, or any
combination of such factors, substantially impairs or arrests the sound growth of the
community, retards the provision of housing accommodations, or constitutes an economic
or social liability and is detrimental to the public health, safety, morals, or welfare in its
present condition and use and (b) in which there is at least one of the following
conditions: (i) Unemployment in the designated area is at least one hundred twenty
percent of the state or national average; (ii) the average age of the residential or
commercial units in the area is at least forty years; (iii) more than half of the plotted and
subdivided property in an area is unimproved land that has been within the city for forty
years and has remained unimproved during that time; (iv) the per capita income of the
area is lower than the average per capita income of the city or village in which the area is
designated; or (v) the area has had either stable or decreasing population based on the last
two decennial censuses. In no event shall a city of the metropolitan, primary, or first class
designate more than thirty-five percent of the city as blighted, a city of the second class
shall not designate an area larger than fifty percent of the city as blighted, and a village
shall not designate an area larger than one hundred percent of the village as blighted;

Nebraska Redevelopment Act - Nebraska Statute Section 58-503(6)

                                                                                           19
Blighted and substandard area means an area either within a city or cities or up to ten
miles outside of the area of operation of a city or cities of the metropolitan or primary
class, up to six miles outside of the area of operation of a city or cities of the first class,
and up to three miles outside of the area of operation of a city or cities of the second class
or village or villages, or any combination thereof, in which by reason of (a) the existence
of significant areas of unimproved or insufficiently developed land, (b) the lack of a
significant number of new and growing business enterprises, (c) the lack of sufficient
economic growth, (d) the dilapidation, deterioration, age, or obsolescence of buildings
and improvements, (e) the lack of a state, regional, or local redevelopment plan or
program, (f) the existence of significant conditions which prevent or do not promote
economic growth within such area, (g) the lack of medical and health care facilities, (h)
the lack of utilities and other government services infrastructure, or (i) any combination
of such factors, there exists (i) insufficient safe, sanitary, and available housing for low-
income and moderate-income families and persons, including, but not limited to, persons
displaced by clearing of slums or blighted areas or by other public programs, (ii) job
growth at less than the United States or midwest average job growth rates, (iii) average
wages at less than the United States or midwest average wage levels, (iv) a net emigration
of population, (v) population growth that is less than that of the United States or the
midwest, (vi) the failure to utilize substantial land areas at their highest and best uses in
comparison to other areas within such city or cities, (vii) an abundance of property that is
not on the tax rolls at levels at least equal to industrial and residential valuation levels, or
(viii) any combination of such results;

(2) Definition of “affordable rents.”

Response:

Definition of affordable rents

The State of Nebraska definition of affordable rents for purposes of implementing the
Community Development Block Grant Neighborhood Stabilization Program is as
follows:

Affordable Rents must meet the following qualifications:

a. Rent Limitation: NSP provides the following maximum NSP rent limits. The
   maximum NSP rents are the lesser of:

    1. The fair market rent for existing housing for comparable units in the area as
       established by HUD under 24 CFR 888.111; or

    2. A rent that does not exceed 30 percent of the adjusted income of a family whose
       annual income equals 65 percent of the median income for the area, as determined
       by HUD, with adjustments for number of bedrooms in the unit. The HOME rent
       limits provided by HUD will include average occupancy per unit and adjusted
       income assumptions.

                                                                                             20
b. Initial rent schedule and utility allowance:

   1. The participating jurisdiction must establish maximum monthly allowances for
      utilities and services (excluding telephone). The participating jurisdiction must
      review and approve rents proposed by the owner for units subject to the maximum
      rent limitations in paragraphs (a) or (b) of this section. For all units subject to the
      maximum rent limitations in paragraphs (a) or (b) of this section for which the
      tenant is paying utilities and services, the participating jurisdiction must ensure
      that the rents do not exceed the maximum rent minus the monthly allowances for
      utilities and services.

c. Subsequent rents during the affordability period:

   1. The maximum HOME rent limits are recalculated on a periodic basis after HUD
      determines fair market rents and median incomes. HUD then provides the new
      maximum HOME rent limits to participating jurisdictions. Regardless of changes
      in fair market rents and in median income over time, the NSP rents for a project
      are not required to be lower than the HOME rent limits for the project in effect at
      the time of project commitment.

   2. The Nebraska Department of Economic Development (DED) NSP grantee
      (subrecipient) must provide project owners with information on updated NSP rent
      limits so that rents may be adjusted (not to exceed the maximum HOME rent
      limits in paragraph (a) of this section) in accordance with the written agreement
      between the DED NSP grantee and the owner. Owners must annually provide the
      DED with information on rents and occupancy of NSP-assisted units to
      demonstrate compliance with this section.

   3. Any increase in rents for NSP-assisted units is subject to the provisions of
      outstanding leases, and in any event, the owner must provide tenants of those
      units not less than 30 days prior written notice before implementing any increase
      in rents.

This definition is an adoption of the HOME program standards at 24 CFR 92.252 (a), (c),
and (f).

(3) Describe how the grantee will ensure continued affordability for NSP assisted
housing.

Response:

Description of continued affordability

The State of Nebraska description of how the Nebraska Department of Economic
Development (DED) will ensure continued affordability for purposes of implementing

                                                                                          21
the Community Development Block Grant Neighborhood Stabilization Program is as
follows:

NSP-assisted housing must meet the following affordability requirements:
Rental Housing

a. Periods of Affordability. The NSP-assisted units must meet the affordability
   requirements for not less than the applicable period specified in the following table,
   beginning after project completion. The affordability requirements apply without
   regard to the term of any loan or mortgage or the transfer of ownership. They must be
   imposed by deed restrictions, covenants running with the land, or other mechanisms
   approved by the Nebraska Department of Economic Development (DED), except that
   the affordability restrictions may terminate upon foreclosure or transfer in lieu of
   foreclosure. The DED NSP grantee may use purchase options, rights of first refusal or
   other preemptive rights to purchase the housing before foreclosure or deed in lieu of
   foreclosure to preserve affordability. The affordability restrictions shall be revived
   according to the original terms if, during the original affordability period, the owner
   of record before the foreclosure, or deed in lieu of foreclosure, or any entity that
   includes the former owner or those with whom the former owner has or had family or
   business ties, obtains an ownership interest in the project or property.

            Rental Housing Activity              Minimum period of affordability in years
    Rehabilitation or acquisition of existing                      5
    housing per unit amount of NSP funds:
                 Under $15,000
            $15,000 to $40,000                                     10
   Over $40,000 or rehabilitation involving                        15
                refinancing
   New Construction or acquisition of newly                        20
            constructed housing

Homeownership

a. Acquisition with or without rehabilitation. Housing that is for acquisition by a family
   must meet the affordability requirements of this paragraph (a).

   1. The housing must be single-family housing.

   2. The housing must be modest housing as follows:

       i. In the case of acquisition of newly constructed housing or standard housing,
          the housing has a purchase price for the type of single family housing that
          does not exceed 95 percent of the median purchase price for the area, as
          described in paragraph (a)(2)(iii) of this section.


                                                                                            22
     ii. In the case of acquisition with rehabilitation, the housing has an estimated
         value after rehabilitation that does not exceed 95 percent of the median
         purchase price for the area, described in paragraph (a)(2)(iii) of this section.

     iii. If a DED NSP grantee intends to use NSP funds for homebuyer assistance or
          for rehabilitation of owner-occupied single-family properties, the DED NSP
          grantee must use the Single Family Mortgage Limits under Section 203(b) of
          the National Housing Act (12 U.S.C. 1709(b)) (which may be obtained from
          the HUD Field Office).

 3. The housing must be acquired by a homebuyer whose family qualifies as a
    income qualified family and the housing must be the principal residence of the
    family throughout the period described in paragraph (a)(4) of this section.

 4. Periods of affordability. The NSP-assisted housing must meet the affordability
    requirements for not less than the applicable period specified in the following
    table, beginning after project completion. The per unit amount of NSP funds and
    the affordability period that they trigger are described more fully in paragraphs
    (a)(5)(i) (resale) and (ii) (recapture) of this section.

Homeownership assistance NSP amount per-
                                                 Minimum period of affordability in years
                 unit
            Under $15,000                                          5
          $15,000 to $40,000                                       10
            Over $40,000                                           15

 5. Resale and recapture. To ensure affordability, the DED NSP-grantee must impose
    either resale or recapture requirements, at its option. The DED NSP-grantee must
    establish the resale or recapture requirements that comply with the standards of
    this section and set forth the requirements in its program guidelines. DED must
    determine that they are appropriate.

     i. Resale. Resale requirements must ensure, if the housing does not continue to
        be the principal residence of the family for the duration of the period of
        affordability, that the housing is made available for subsequent purchase only
        to a buyer who is an income-qualified family and will use the property as its
        principal residence. The resale requirement must also ensure that the price at
        resale provides the original NSP-assisted owner a fair return on investment
        (including the homeowner’s investment and any capital improvement) and
        ensure that the housing will remain affordable to a reasonable range of income
        eligible homebuyers as defined by the CDBG NSP. The period of affordability
        is based on the total amount of NSP funds invested in the housing.

        A. Except as provided in paragraph (a)(5)(i)(B) of this section, deed
           restrictions, covenants running with the land, or other similar mechanisms
           must be used as the mechanism to impose the resale requirements. The
                                                                                            23
   affordability restrictions may terminate upon occurrence of any of the
   following termination events: foreclosure, transfer in lieu of foreclosure or
   assignment of an FHA insured mortgage to HUD. The DED NSP-grantee
   may use purchase options, rights of first refusal or other preemptive rights
   to purchase the housing before foreclosure to preserve affordability. The
   affordability restrictions shall be revived according to the original terms if,
   during the original affordability period, the owner of record before the
   termination event, obtains an ownership interest in the housing.

B. Certain housing may be presumed to meet the resale restrictions (i.e., the
   housing will be available and affordable to a reasonable range of income-
   eligible homebuyers; an income-eligible homebuyers will occupy the
   housing as the family’s principal residence; and the original owner will be
   afforded a fair return on investment) during the period of affordability
   without the imposition of enforcement mechanisms by the DED NSP-
   grantee. The presumption must be based upon a market analysis of the
   neighborhood in which the housing is located. The market analysis must
   include an evaluation of the location and characteristics of the housing and
   residents in the neighborhood (e.g., sale prices, age and amenities of the
   housing stock, incomes of residents, percentage of owner-occupants) in
   relation to housing and incomes in the housing market area. An analysis of
   the current and projected incomes of neighborhood residents for an
   average period of affordability for homebuyers in the neighborhood must
   support the conclusion that a reasonable range of low-income families will
   continue to qualify for mortgage financing. For example, an analysis
   shows that the housing is modestly priced within the housing market area
   and that families with incomes of 65% to 120% of area median can afford
   monthly payments under average FHA terms without other government
   assistance and housing will remain affordable at least during the next five
   to seven years compared to other housing in the market area; the size and
   amenities of the housing are modest and substantial rehabilitation will not
   significantly increase the market value; the neighborhood has housing that
   is not currently owned by the occupants, but the DED-NSP grantee is
   encouraging homeownership in the neighborhood by providing
   homeownership assistance and by making improvements to the streets,
   sidewalks, and other public facilities and services. If a DED NSP-grantee
   in preparing a neighborhood revitalization strategy under 24 CFR Part
   91.215(e)(2) of its consolidated plan or Empowerment Zone or Enterprise
   Community application under 24 CFR part 597 has incorporated the type
   of market data described above, that submission may serve as the required
   analysis under this section. If the DED NSP-grantee continues to provide
   homeownership assistance for housing in the neighborhood, it must
   periodically update the market analysis to verify the original presumption
   of continued affordability.




                                                                               24
       ii. Recapture. Recapture provisions must ensure that the DED NSP-grantee
           recoups all or a portion of the NSP assistance to the homebuyers, if the
           housing does not continue to be the principal residence of the family for the
           duration of the period of affordability. The DED NSP-grantee may structure
           its recapture provisions based on its program design and market conditions.
           The period of affordability is based upon the total amount of NSP funds
           subject to recapture described in paragraph (a)(5)(ii)(A)(5) of this section.

           A. The following options for recapture requirements are acceptable to DED.
              The DED NSP-grantee may adopt, modify or develop its own recapture
              requirements for DED approval. In establishing its recapture requirements,
              the DED NSP-grantee is subject to the limitation that when the recapture
              requirement is triggered by a sale (voluntary or involuntary) of the
              housing unit, and there are no net proceeds or the net proceeds are
              insufficient to repay the NSP investment due, the DED NSP-grantee can
              only recapture the net proceeds, if any. The net proceeds are the sales
              price minus superior loan repayment (other than NSP funds) and any
              closing costs.

               1. Recapture entire amount. The DED NSP-grantee may recapture the
                  entire amount of the NSP investment from the homeowner.

               2. Reduction during affordability period. The DED NSP-grantee may
                  reduce the NSP investment amount to be recaptured on a prorata basis
                  for the time the homeowner has owned and occupied the housing
                  measured against the required affordability period.

              3. Shared net proceeds. If the net proceeds are not sufficient to recapture
                 the full NSP investment (or a reduced amount as provided for in
                 paragraph (a)(5)(ii)(A)(2) of this section) plus enable the homeowner
                 to recover the amount of the homeowner’s downpayment and any
                 capital improvement investment made by the owner since purchase,
                 the DED NSP-grantee may share the net proceeds. The net proceeds
                 are the sales price minus loan repayment (other than NSP funds) and
                 closing costs. The net proceeds may be divided proportionally as set
                 forth in the following mathematical formulas:
                                   
NSP Investment/NSP              X Net Proceeds =              NSP amount to be
Investment + homeowner                                        recaptured
investment
homeowner Investment /NSP X Net Proceeds =                    Amount to homeowner
Investment +
homeownerinvestment
            
              4. Owner investment returned first. The DED NSP-grantee may permit
                 the homebuyer to recover the homebuyer’s entire investment

                                                                                           25
   (downpayment and capital improvements made by the owner since
   purchase) before recapturing the NSP investment.

5. Amount subject to recapture. The NSP investment that is subject to
   recapture is based on the amount of NSP assistance that enabled the
   homebuyer to buy the dwelling unit. This includes any NSP assistance
   that reduced the purchase price from fair market value to an affordable
   price, but excludes the amount between the cost of producing the unit
   and the market value of the property (i.e., the development subsidy).
   The recaptured funds must be used to carry out NSP-eligible activities
   in accordance with the NSP requirements. If the NSP assistance is only
   used for the development subsidy and therefore not subject to
   recapture, the resale option must be used.

6. Special considerations for single-family properties with more than one
   unit. If the NSP funds are only used to assist an income qualified
   homebuyer to acquire one unit in single-family housing containing
   more than one unit and the assisted unit will be the principal residence
   of the homebuyer, the affordability requirements of this section apply
   only to the assisted unit. If NSP funds are also used to assist the
   income qualified homebuyer to acquire one or more of the rental units
   in the single-family housing, the affordability requirements of Rental
   Housing apply to assisted rental units, except that the DED NSP-
   grantee may impose resale or recapture restrictions on all assisted units
   (owner-occupied and rental units) in the single family housing. If
   resale restrictions are used, the affordability requirements on all
   assisted units continue for the period of affordability. If recapture
   restrictions are used, the affordability requirements on the assisted
   rental units may be terminated, at the discretion of the DED NSP-
   grantee, upon recapture of the NSP investment. (If NSP funds are used
   to assist only the rental units in such a property then the requirements
   of rental housing affordability requirements would apply and the
   owner-occupied unit would not be subject to the income targeting or
   affordability provisions of homeownership housing affordability
   requirements.)

7. Lease-purchase. NSP funds may be used to assist homebuyers through
   lease-purchase programs for existing housing and for housing to be
   constructed. The housing must be purchased by a homebuyer within
   36 months of signing the lease-purchase agreement. The homebuyer
   must be an income-qualified family at the time the lease-purchase
   agreement is signed. If NSP funds are used to acquire housing that will
   be resold to a homebuyer through a lease-purchase program, the NSP
   affordability requirements for rental housing shall apply if the housing
   is not transferred to a homebuyer within forty-two months after project
   completion.

                                                                         26
               8. Contract to purchase. If NSP funds are used to assist a homebuyer who
                  has entered into a contract to purchase housing to be constructed, the
                  homebuyer must be an income-qualified family at the time the contract
                  is signed.

b. Ownership interest. The ownership in the housing assisted under this section must
   meet the following definition of “homeownership”:

   1. homeownership means ownership in fee simple title or a 99 year leasehold
      interest in a one- to four-unit dwelling or in a condominium unit, or equivalent
      form of ownership approved by DED. The ownership interest may be subject only
      to the restrictions on resale required under homeownership (a) ; mortgages, deeds
      of trust, or other liens or instruments securing debt on the property as approved by
      the DED NSP-grantee; or any other restrictions or encumbrances that do not
      impair the good and marketable nature of title to the ownership interest. For
      purposes of the insular areas, homeownership includes leases of 40 years or more.
      For purposes of housing located on trust or restricted Indian lands,
      homeownership includes leases of 50 years. The DED NSP-grantee must
      determine whether or not ownership or membership in a cooperative or mutual
      housing project constitutes homeownership under State law.

c. New construction without acquisition. Newly constructed housing that is built on
   property currently owned by a family which will occupy the housing upon
   completion, qualifies as affordable housing if it meets the requirements under
   paragraph (a) of this section.

This description is an adoption of the HOME program standards applicable provisions at
24 CFR 92.252 (e) and 92.254.

(4) Describe housing rehabilitation standards that will apply to NSP assisted activities.

Response:

Description of housing rehabilitation standards

The State of Nebraska description of housing rehabilitation standards that will apply to
NSP-assisted activities for purposes of implementing the Community Development
Block Grant Neighborhood Stabilization Program is as follows:

NSP-assisted housing activities including rehabilitation of housing must meet the
following housing rehabilitation standards:
(1) All housing units rehabilitated as an NSP-assisted housing activity must meet local
codes that apply;
and
(2) All housing units rehabilitated as an NSP-assisted housing activity must meet the
Nebraska Department of Economic Development (DED) Rehabilitation Standards

                                                                                            27
required for the Nebraska HOME program, Nebraska CDBG program, and Nebraska
Affordable Housing Trust Fund. The current DED Rehabilitation Standards are
described below.

                  MINIMUM STANDARDS FOR REHABILITATION
                   Nebraska Department of Economic Development

A. MINIMUM STANDARDS FOR BASIC EQUIPMENT AND FACILITIES

1. KITCHENS – Every dwelling shall have a kitchen room or kitchenette equipped with
   a kitchen sink, properly connected to both hot and cold running water lines, under
   pressure, and in working order.

2. TOILET ROOM REQUIRED – Every dwelling unit, except as otherwise permitted
   for rooming houses, shall contain a room that is equipped with a flush water closet
   and properly installed lavatory. Said lavatory shall be properly connected to both hot
   and cold running water, under pressure, and shall be in working order. Fixtures shall
   be properly installed, free of hazards, leaks and defects, and in functional and sanitary
   order.
        
   Said flush water closet shall be properly connected to the water supply, under
   pressure, and shall be in working order.

3. SHARED TOILET FACILITIES – Shared toilet rooms shall be equipped with a flush
   water closet and lavatory basin, and shall be connected as provided in Section 2
   above. In rooming house type structures, at least 1 toilet and 1 lavatory basin,
   properly connected as set forth above, shall be supplied for each 8 persons or
   fractions thereof residing within a rooming house, including members of the
   operator’s family whenever they share the use of said facilities, provided that in
   rooming houses where rooms are let only to males, flush urinals may be substituted
   for not more than ½ of the required number of toilets.

4. BATH REQUIRED – Every dwelling unit shall contain a bathtub and/or shower.
   Fixtures shall be properly installed, free of hazards, leaks and defects, and shall be in
   functional and sanitary order.

   Potable water supply piping, water discharge outlets, backflow prevention devices or
   similar equipment shall not be so located as to make possible their submergence in
   any contaminated or polluted liquid or substance.

   Said bathtub and/or shower may be in the same room as the flush water closet and
   lavatory, or said bathtub and/or shower may be in a separate room. In all cases, these
   facilities shall be properly connected to both hot and cold running water lines, under
   pressure, and shall be in working order.




                                                                                          28
   In rooming house type structures, at least 1 bathtub and/or shower, properly
   connected as set forth above, shall be supplied for each 8 persons or fractions thereof,
   residing within a rooming house, including members of the operator’s family
   whenever they share the use of said facilities.

5. PRIVACY IN ROOM CONTAINING TOILET AND BATH – Every toilet and every
   bath shall be contained in a room or within separate rooms which affords privacy to a
   person within said room or rooms. Said rooms shall not be the only passageway to
   the exterior.

   Toilets and bathrooms shall have doors with a privacy type lock and such doors, locks
   and hardware shall be in working order.

6. LOCATION OF COMMUNAL TOILETS AND BATHS – Every communal bath
   required to be provided in accordance with other provisions, shall be located within a
   room or rooms accessible to the occupants of each dwelling unit sharing such
   facilities, without going through a dwelling unit of another occupant and without
   going outside of the dwelling.

   In rooming houses, said room or rooms shall be located on the same floor of the
   dwelling as, or on the floor immediately above or below, the dwelling unit whose
   occupants share the use of such facilities.

7. WATER SUPPLY – All fixture water supplies shall be properly connected to public
   or private water system.

   All water supply inlet orifices (mouth of an opening from any pipe or faucet
   supplying water) shall have an air gap (The unobstructed vertical distance through the
   free atmosphere between the lowest opening from any pipe or faucet supplying water
   to a tank, plumbing fixture or other device and the floor level rim of the receptacle.)
   or shall be protected by vacuum breakers (also known as backflow preventers).

8. HOT AND COLD WATER LINES TO BATH AND KITCHEN – Every dwelling
   shall have supplied water-heating facilities which are properly installed; in working
   condition and free of leaks; properly connected to hot water lines required; and are
   capable of supplying hot or tempered water at not less than 110°F to be drawn for
   every bath, as well as general usage.

   Hot water storage associated with water heating facilities shall not be less than the
   following minimum capacities:

       a.   1 dwelling unit                  30 gallons
       b.   2 dwelling units                 40 gallons
       c.   3 or more dwelling units         50 gallons or more
            and rooming houses



                                                                                           29
   Sizes and/or number of water heaters are to be based upon the number of units served.
   No water heaters shall be allowed in bathrooms or bedrooms. All hot water heaters
   shall be properly vented and sealed and equipped with a pressure relief valve and drip
   leg a maximum of 6” above the floor.

   The local rehabilitation division and/or building inspection division may adjust the
   above-required capacities upward or downward based on the type and recovery time
   of the hot water system.

9. CONNECTION OF SANITARY FACILITIES TO SEWAGE SYSTEM – Every
   kitchen sink, toilet, lavatory basin and bathtub/shower shall be in working condition
   and properly connected to an approved public or private sewage system.

   All sewers and vents shall function properly and be free of leaks and blockages.

10. EXITS – Every exit from every dwelling and/or dwelling unit shall comply with the
    following requirements:

   a. It shall be functional;

   b. It shall be unobstructed;

   c. All stairways and steps of 4 or more risers shall have at least 1 handrail, and all
      stairways and steps that are 5 feet or more in width or open on both sides shall
      have a handrail on each side where possible;

   d. Every dwelling unit shall have 2 independent ways of egress;

   e. All handrails shall be not less than 30” or more than 42” vertically above the nose
      of the stair treads and not less than 36” above the stairway platform;

   f. All balconies and platforms that are 30” or more above grade, shall have
      protective guards not less than 30” in height above the balcony or platform level;

   g. All multiple dwellings (1 & 2 family residences exempted) shall have a second
      exit stairway or approved fire escape available to all occupants of units located on
      second or higher stories;

   h. All stairs and steps shall have a riser height of no more than 8” and a tread depth
      of no less than 9”. This requirement may be waived on the programmatic level if
      in an existing structure, it would be impossible or cost prohibitive to meet this
      requirement. In such cases, new stairs could be put in having the same rise and
      run as the old;




                                                                                            30
   i. In basement units where one means of an exit shall be a window, it shall comply
      with the International Residential Code, Section 310 Emergency Escape and
      Rescue Openings.

11. FIRE PROTECTION AND SMOKE ALARMS – All fire protection systems and
    devices shall be in operable condition. When a dwelling is occupied by any hearing
    impaired person, smoke alarms shall have an alarm system designed for hearing
    impaired persons in accordance with NFPA 74 (or successor standards).

   Smoke alarms shall be installed:
    • On each story, including basement and cellar (Alarms are not required in
      unfinished attics and crawl spaces)
   • Outside of each bedroom
   • In each bedroom

B.  MINIMUM STANDARDS FOR LIGHT, VENTILATION AND HEATING 

1. REQUIRED WINDOW AREA – Every habitable room, provided such rooms are
   adequately lighted, shall have at least one open air space. The minimum total window
   area, measured between stops, for every habitable room shall be as follows:

   a. 1/12 of the floor area if two or more separate windows exist; or

   b. 1/10 of the floor area if only one window exists;

   c. a minimum of 12 square feet of window area is required in habitable rooms other
      than kitchens;

   d. a kitchen may pass without a window area, provided there is a mechanical means
      of ventilation in working order.

   Whenever the only window in a room is a skylight type window, the total window
   area of such skylight shall be equal to at least 15% of the total floor area of such
   room. Skylight type windows, if less than 15% of the total floor area shall be
   increased to 15% of the total floor area, unless another window is to be installed to
   provide adequate light and ventilation.

2. ADEQUATE VENTILATION REQUIRED - Every habitable room shall have at
   least one window or skylight which can easily be opened, or other such device as will
   adequately ventilate the room.

3. LIGHT AND VENTILATION REQUIREMENTS FOR BATHROOMS, TOILET
   ROOMS AND KITCHENS
    Every bathroom, toilet room, and kitchen shall comply with the light and ventilation
   requirements for habitable rooms contained above, except that no window shall be


                                                                                           31
   required in adequately ventilated bathrooms, toilet rooms, or kitchens equipped with a
   ventilation system that filters or exhausts to the exterior.

4. ALTERNATIVE LIGHT AND VENTILATION – Artificial light or mechanical
   ventilation complying with the International Building Code shall be permitted.

5. CLOTHES DRYER VENTING – Clothes dryer exhaust vent shall be a single
   purpose vent in compliance with the manufacturer’s instructions and vent to the
   exterior.

6. ELECTRIC OUTLETS AND SERVICE REQUIRED - Where there is suitable
   electricity available from supply lines no more than 300 feet away from a dwelling,
   including all existing dwellings now supplied with electrical services, every habitable
   room within such dwelling shall contain a minimum of two separate and remote wall
   type electric convenience outlets. Habitable rooms measuring more than 120 square
   feet shall contain a minimum of three separate and remote wall type electric
   convenience outlets. Temporary wiring, extension, or zip cords shall not be used as
   permanent wiring.

   Every habitable room shall have at least one ceiling or wall type electric light fixture,
   controlled by a wall switch, or a wall type grounded electric convenience outlet
   controlled by a remote switch.

   Every toilet room, bathroom, laundry room, furnace room, and hallway (hallway
   where applicable) shall contain at least 1 supplied ceiling or wall type electric light
   fixture, controlled by a wall switch, and at least one wall type grounded electric
   convenience outlet. Convenience outlets used in bathrooms shall be the GFI type.

   Each individual kitchen based on its size and layout shall be wired to meet the
   requirements of the National Electric Code (N.E.C.).

   Receptacle convenience outlets in or on open porches, breezeways or garages shall be
   of the GFI type with a weather proof receptacle box.

   All wall and/or ceiling type lighting fixtures shall be controlled by a wall switch,
   except porcelain type fixtures used in cellars and/or attics, which may be controlled
   with a proper pull chain.

   All electrical equipment, appliances and wiring shall be properly installed and in safe
   condition.

   All broken and/or missing switch and receptacle plates shall be replaced.

   All outlets and fixtures shall be properly installed, shall be in working condition and
   shall be connected to the source of electric power in a proper manner and in
   accordance with the electrical code of the city and/or the N.E.C., as applicable.

                                                                                             32
   Minimum electrical service for each dwelling and/or dwelling unit’s circuit breaker
   box shall be by a three wire 120/240 volt single phase service rated no less than 100
   amps, or as adjusted for size and usage of equipment and appliances in accordance
   with the ICC Electrical Code and approved, in writing, by the electrical inspector of
   the local jurisdiction or program.

7. HAZARDOUS ELECTRICAL CONDITIONS – Where any condition of the
   electrical system in the dwelling or structure is identified as, and constitutes a hazard,
   the hazardous conditions shall be corrected.

8. HEATING FACILITIES –Heating facilities shall be properly installed, be in working
   condition and be capable of adequately heating all habitable rooms, and toilet rooms
   contained therein, or intended for use by the occupants capable of maintaining a room
   temperature of 68°F (20°C) when the outdoor temperature is within the winter
   outdoor design temperature for the locality as cited in Appendix D of the
   International Plumbing Code. Space heaters shall not substitute for a central heating
   unit.

Every installed central heating system shall comply with the following requirements:

   a. The central heating unit shall be safe and in good working condition;

   b. Every heat duct, steam pipe and hot water pipe shall be free of leaks and
      obstructions and deliver an adequate amount of heat where intended;

   c. Every seal between any and all sections of a hot air furnace shall be air-tight so
      noxious gases and fumes will not escape into the heat ducts;

   d. Required clearance from combustible materials shall be maintained;

   e. All chimneys and vents shall have a flue liner intact and in safe working
      condition.

   Every existing space heater shall comply with the following requirements:
   a. No space heater burning solid, liquid or gaseous fuels shall be of a portable type;

   b. Every space heater burning solid, liquid or gaseous fuels shall be properly vented
      to a chimney or duct leading to outdoor space and be installed to provide proper
      draft;

   c. Every fuel burning space heater shall have a fire-resistant panel between it and the
      floor or floor covering as required by the unit’s manufacturer;




                                                                                           33
   d. Whenever a space heater is located within 2 feet of a wall, said wall shall be
      protected with insulation sufficient to prevent overheating of the wall as required
      by the unit’s manufacturer;

   e. Every space heater smoke pipe shall be equipped with approved thimbles or
      guards, properly constructed of non-flammable material, at the point where the
      pipe goes through any wall, ceiling or partition;
        
   f. Each dwelling and/or dwelling unit shall be supplied with its own heating
      systems. Local option may provide for one central forced air system to serve no
      more than two separate dwelling units.

9. LIGHTING OF PUBLIC HALLS AND STAIRWAYS

   a. Public halls and stairways in every dwelling containing 2 to 4 dwelling units shall
      be provided with convenient wall-mounted light switches controlling an adequate
      lighting system that will provide at least 2 foot candles of illumination on all parts
      thereof and be turned on when needed. An emergency circuit is not required for
      this lighting;

   b. Public halls and stairways in every dwelling containing 5 or more dwelling units
      shall be lighted at all times with an artificial lighting system. Said system shall
      provide at least 2 foot candles of illumination on all parts thereof at all times by
      means of properly located electric light fixtures, provided that such artificial
      lighting may be omitted from sunrise to sunset where an adequate natural lighting
      system is provided;

   c. Wherever the occupancy of the building exceeds 100 persons, the artificial
      lighting system as required herein, shall be on an emergency circuit;

   d. All basements and cellars shall be provided with a lighting system that permits
      safe occupancy and use of the space and contained equipment as intended, and
      which may be turned on when needed;

   e. The required intensity of illumination shall apply to both natural and artificial
      lighting.

10. SCREENS REQUIRED - For protection against flies, mosquitoes and other insects,
    every door opening directly from a dwelling unit or rooming unit, to the outdoor
    space where feasible, shall be supplied with a screen covering at least 50% of the
    window area of the door, and said door shall be equipped with a self-closing device.

   Every window or other opening to outdoor space used or intended to be used for
   ventilation shall likewise be supplied with screens covering the entire window areas
   required for ventilation. The material used for all such screens shall be no less than 16



                                                                                          34
   mesh per inch, properly installed, and repaired when necessary to prevent the
   entrance of flies, mosquitoes and other insects.

   Half-screens on windows may be allowed, provided they are properly installed and
   are bug and insect proof.

11. SCREENS FOR BASEMENT AND CELLAR WINDOWS - Every dwelling unit
    having operable basement or cellar windows shall be screened to prevent the entry of
    insects and rodents.

12. EXISTING HEATING TO DWELLINGS OR PARTS THEREOF - Every dwelling
   owner or operator who rents, leases or lets for human habitation any unit contained
   within such dwelling, on terms either expressed or implied, shall supply or furnish
   heat to the occupants.

   Whenever a dwelling is heated by means of a furnace, boiler or other heating
   apparatus under the control of the owner or operator, in the absence of a written
   contract or agreement to the contrary, said owner and/or operator shall be deemed
   to have contracted, undertaken, or bound to furnish heat in accordance with the
   provisions of this section to every unit that contains radiators, furnace heat duct
   outlets, or other heating apparatus outlets, and to every communal bathroom and
   communal toilet room located within such unit.

   a. Every central heating unit, space heater, water heater and cooking appliance shall
      be located and installed in a safe working manner to protect against involvement
      of egress facilities or egress routes in the event of uncontrolled fires in the
      structure;

   b. Every fuel burning heating unit or water heater shall be effectively vented in a
      safe manner to a chimney or duct leading to the exterior of the building. The
      chimney duct and vents shall be designed to assure proper draft, shall be
      adequately supported, and shall be clean;

   c. No fuel-burning furnace shall be located in any sleeping room or bathroom unless
      provided with adequate ducting for air supply from the exterior, and the
      combustion chamber for such heating unit is sealed from the room in an airtight
      manner. Water heaters are prohibited in bathrooms and sleeping rooms.

   d. Every steam or hot water boiler and every water heater shall be protected against
      overheating by appropriate temperature and pressure limit controls;

   e. Every gaseous or liquid fuel burning heating unit and water heater shall be
      equipped with electronic ignition or with a pilot light and an automatic control to
      interrupt the flow of fuel to the unit in the event of failure of the ignition device.
      All such heating units with plenum have a limit control to prevent overheating.



                                                                                          35
C. MINIMUM STRUCTURAL STANDARDS

1.    SIDEWALKS AND DRIVEWAYS – All sidewalks, driveways, stairs and similar
     areas shall be free of hazardous conditions and in proper repair.

2. PREMISE IDENTIFICATION NUMBERS – Address numbers easily visible and
   legible from the street or road shall be installed. Numbers shall contrast in color with
   their background and be at least 4 inches high with a minimum stroke width of one
   half inch.

3. FOUNDATIONS, EXTERIOR WALLS, ROOFS, SOFFITS AND FASCIA - Every
   foundation, exterior wall, roof, soffit, and fascia shall be structurally sound, weather-
   tight, and rodent/insect-proof.

     All exterior surface materials shall be protected by lead-free paint or other protective
     coating in accordance with acceptable standards. The exception is all types of exterior
     materials acceptable to weatherizing without deterioration.

4. INTERIOR WALLS, FLOORS, CEILINGS, DOORS, AND WINDOWS – Every
   interior partition, wall floor, ceiling, door and window shall be structurally sound.

     Holes in walls should be replastered before new paint is applied.

     All interior doors shall be capable of affording privacy for which they were intended.

5. GRADING AND RAINWATER DRAINAGE FROM ROOF - All rainwater shall be
   drained and conveyed from every roof so as not to cause dampness within the
   dwelling. All rainwater drainage devices, such as gutters, downspouts, leaders and
   splashblocks shall be in safe working order. Ground areas around the habitable unit
   shall be sloped or drain away from foundation walls to prevent standing water.

6. WINDOWS, EXTERIOR DOORS AND BASEMENT OR CELLAR HATCHWAYS
   - Every front, rear, side and basement or cellar door shall be no less than 2'4" in width
   and no less than 6' 6" in height. In existing structures, if replacement to meet these
   requirements would be impossible or cost-prohibitive, said requirement may be
   waived by the grantee.

     Every window, exterior door and basement or cellar hatchway shall be substantially
     tight and rodent-proof. In addition, the following requirements shall be met:

     a. All exterior doors to the outside or to a common public hall shall be equipped
        with adequate security locks. Means of egress door locks shall be easily opened
        from the egress side without a key or special knowledge. All windows accessible
        from ground level without the aid of mechanical devices shall have a security
        device. Emergency escape windows shall be openable from the inside without the
        use of a key, code or tool;

                                                                                           36
   b. Every window sash shall be fully equipped with windowpane glazing materials
      free of cracks or holes, and all panes shall be secured with retaining devices or an
      adequate amount of putty. Said putty shall not be cracked, broken or missing;

   c. Every window sash shall be in good condition and fit tightly within its frame;

   d. Every window, other than a fixed window, shall be easily opened and held in
      position by window hardware;

   e. Every exterior and interior door, door hinge, door latch, and/or lock shall be in
      good working condition;

   f. Every exterior and interior door, when closed, shall fit well within its frame;

   g. Every window, door and frame shall be constructed in relation to the adjacent
      wall construction, to exclude rain and wind as completely as possible from
      entering the dwelling or structure;

7. STAIRWAYS, DECKS, BALCONIES AND PORCHES - Every interior and exterior
   stairway, porch, deck, balcony and appurtenance thereto, including hand and guard
   rails, shall be constructed to be sound and safe to use and capable of supporting the
   load that normal use may place upon it.

8. SUPPLIED PLUMBING FIXTURES - Every plumbing fixture and water and waste
   pipe shall be properly installed in safe, sanitary working condition, free from leaks,
   defects, and obstructions.

9. BATHROOM, TOILET ROOM, KITCHEN AND UTILITY ROOM FLOORS -
   Every bathroom, toilet room, kitchen, and utility room floor surface shall be
   constructed to be impervious to water and to permit such floors to be easily kept clean
   and sanitary.

   Indoor-outdoor type carpeting, when properly installed, shall be allowed in
   bathrooms, toilet rooms, kitchens and utility rooms except when in conflict with
   required interim controls or standard treatments required to comply with the lead-
   based paint regulation.

10. CHIMNEYS AND SMOKE PIPES - Every chimney and smoke pipe shall be
    adequately supported, structurally sound, and clean.

11. TREES AND VEGETATION – Trees and vegetation endangering the unit and/or it
    occupants shall be eliminated.
        
12. INTERNATIONAL RESIDENTIAL CODE FOR ONE AND TWO-FAMILY
    DWELLINGS – All rehabilitation work must meet or exceed the requirements of the

                                                                                          37
   International Residential Code as promulgated by the International Code Council in
   its current edition or as adopted in ordinance by the local jurisdiction.

   a. Work must comply with the permitting and inspection requirements of the local
      jurisdiction.

   b. In the absence of local permitting and inspection services, the local recipient
      program shall engage qualified inspectors and document code inspection and
      compliance.

13. LEAD-BASED PAINT – As required under 24 CFR Part 35, the Final HUD
    Regulation on Lead-Based Paint Hazards in Federally Owned Housing and Housing
    Receiving Federal Assistance, all assisted dwelling units constructed before January
    1, 1978, will be evaluated for lead-based paint hazards or presumed to have lead-
    based paint present throughout the unit when paint is disturbed.

   a. Evaluation will be done by a qualified, certified or licensed person as required
      under the regulation.

   b. All lead-based paint hazards will be identified and reduced or eliminated through
      paint stabilization, interim controls or abatement with work being done by
      supervised, trained, qualified, certified or licensed persons as required under the
      regulation.

   c. Safe work practices will be followed at all times.

   d. Occupants shall be protected or temporarily relocated as required by the
      regulation. With some exceptions, as listed at 24 CFR 35.1345, occupants shall
      be temporarily relocated before and during hazard reduction activities to a
      suitable, decent, safe and similarly accessible dwelling unit that does not have
      lead hazards.

   e. The dwelling unit and worksite shall be secured. The worksite shall be prepared
      and warning signs shall be posted as required by the regulation.

   f. Clearance examinations will be performed by qualified personnel and final
      clearance shall be achieved as required by the regulations.
         
14. ENERGY CONSERVATION –

   a.       Equipment, appliances, windows, doors and appurtenances replaced during
            rehabilitation shall be replaced with Energy Star qualified products.

   b.       If feasible, attics should be insulated to R38 and walls to a minimum of R11.




                                                                                            38
   c.       Replacement heating and/or cooling systems shall be properly sized as evidenced
            by completion of ACCA/ANSI Manual J® or an equivalent sizing calculation
            tool.

   d.       All accessible air ducts shall be tightly sealed.

   e.       Heating or cooling supply running through unconditioned space should be
            avoided or rerouted, but when present and accessible, shall be insulated.
         
15. INDOOR AIR QUALITY – The scope and conduct of rehabilitation of each
    dwelling unit shall take into consideration the improvement and maintenance of
    satisfactory and healthy air quality within the unit.

   a.       A carbon monoxide detector installed per manufacturers’ recommendations shall
            be present in each unit, and receive primary power from the building wiring or
            battery. If the house is all electric a carbon monoxide detector is not required.
   b.       Devices and appurtenances identified to contain mercury shall be removed or
            replaced excluding CFL bulbs.
   c.       Materials and methods used in carrying out rehabilitation, shall to the extent
            feasible, minimize and prevent dust, outgassing, volatile organic compounds and
            other contaminants within the dwelling unit.
         
16. UNIVERSAL DESIGN AND ACCESSIBILITY – Rehabilitation of each unit shall
    be carried out with consideration for the needs of its occupants and to the maximum
    practical extent in accordance with the principles of universal design. For guidance in
    implementing universal design features, visit www.design.ncsu.edu/cud .

D. MINIMUM SPACE, USE AND LOCATION REQUIREMENTS

1. CEILING HEIGHT - Wherever possible, no habitable room in a dwelling or dwelling
   unit shall have a ceiling height of less than 7' 6". At least 1/2 of the floor area of every
   habitable room located above the first floor shall have a ceiling height of 7' 6", and
   the floor area of that part of any room where the ceiling height is less than 5' shall be
   considered as part of the floor area in computing the total floor area of the room for
   the purpose of determining maximum floor area.

2. ROOM WIDTH - All rooms, except kitchens and/or kitchenettes and baths, shall
   have a minimum width of 7'. Kitchens shall have a clear passage dimension of no less
   than 3 feet between walls, appliances and cabinets.

3. CELLAR SPACE NOT HABITABLE - No cellar space shall be converted or
   rehabilitated as habitable room or dwelling unit.
         
4. REQUIREMENTS FOR HABITABLE BASEMENT SPACE - No basement space
   shall be used as a habitable room or dwelling unit unless all of the following
   requirements are met:


                                                                                            39
   a. Such required minimum window area is located entirely above the grade of
      ground adjoining such window area, or an adequate window well of sufficient
      size as to allow escape of inhabitants residing within such basement apartment,
      has been constructed;
   b. Such basement dwelling unit or rooming unit shall be entirely sealed off from the
      central heating plant with a one hour fire separation. To assist grantees in
      evaluating existing building components, HUD has published the “Guideline on
      Fire Ratings of Archaic Materials and Assemblies”, February 2000, available at
      http://www.huduser.org/publications/destech/fire.html;
   c. Such basement dwelling unit or rooming unit provides two means of exit, with at
      least one means of opening directly to the outside;

5. MINIMUM STORAGE AREAS - Each dwelling unit shall have at least one closet
   with a minimum of 6 square feet of floor area and a minimum height of 6’, located
   within the dwelling unit. Dwelling units with 2 or more bedrooms shall have a storage
   floor area of at least 4 square feet per bedroom. This storage requirement does not
   necessarily have to be located in the bedrooms.

E. MINIMUM STANDARDS FOR GARAGES, FENCES AND PREMISES

   1. PROTECTION OF EXTERIOR WOOD SURFACES - All exterior wood
      surfaces shall be properly protected from the elements against decay and rot by
      lead-free paint, or other approved protective coating.

   2. FENCES - Every residential fence shall be in a state of maintenance and repair or
      shall be removed. Wood materials that are not decay resistant shall be protected
      against decay by use of lead-free paint or by other preservative material.

       If a fence is removed and replaced, said installation shall conform with all local
       requirements.

   3. CONDITION OF PREMISES - All areas and all parts of the premises upon which
      any dwelling or dwelling units are located and all areas adjacent thereto and a part
      of the premises shall be in a clean and sanitary condition. This shall include, but
      not be limited to, removal of abandoned and junked automobiles, automobile
      bodies, chassis, parts, and trailers; inoperable machines and appliances; lumber
      piles and building materials not used in actual construction; tin cans, broken glass,
      broken furniture, boxes, crates, and other debris, rubbish, junk and garbage.

   4. WATER SUPPLY - CONNECT TO WATER MAIN - Every owner of a dwelling
      situated on property that abuts any street or alley in which a water main is laid,
      shall be connected to such main to provide water service.
   5. ABANDONED WELLS AND CISTERNS - Every owner of a dwelling that
      contains an abandoned well or cistern on the premises shall permanently seal or
      fill it in a proper manner.



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   6. INFESTATION AND EXTERMINATION – Structures shall be free from rodent
      and insect infestation.

D. LOW INCOME TARGETING

Identify the estimated amount of funds appropriated or otherwise made available under
the NSP to be used to purchase and redevelop abandoned or foreclosed upon homes or
residential properties for housing individuals or families whose incomes do not exceed 50
percent of area median income: $_$5,000,000________.

Note: At least 25% of funds must be used for housing individuals and families whose
incomes do not exceed 50 percent of area median income.

Response:

DED proposes to award $4,000,000 to the City of Omaha and $1,000,000 to the City of
Lincoln for projects that include housing activities that will benefit households with
incomes at or below 50% of the Area Median Income (AMI).

E. ACQUISITIONS & RELOCATION

Indicate whether grantee intends to demolish or convert any low- and moderate-income
dwelling units (i.e., ≤ 80% of area median income).

If so, include:
     • The number of low- and moderate-income dwelling units—i.e., ≤ 80% of area
         median income—reasonably expected to be demolished or converted as a direct
         result of NSP-assisted activities.
     • The number of NSP affordable housing units made available to low- , moderate-,
         and middle-income households—i.e., ≤ 120% of area median income—
         reasonably expected to be produced by activity and income level as provided for
         in DRGR, by each NSP activity providing such housing (including a proposed time
         schedule for commencement and completion).
     • The number of dwelling units reasonably expected to be made available for
         households whose income does not exceed 50 percent of area median income.

Response:

The State of Nebraska intends to demolish 21 low- and moderate-income dwelling units
as a direct result of NSP-assisted activities.

The State of Nebraska intends to make available at least 70 dwelling units for low-
moderate – and middle income households.
       20 units made available through acquisition, rehabilitation, and resale of
foreclosed, abandoned, and vacant properties for households with incomes at or below
50% AMI.


                                                                                       41
       10 units made available through new construction of Habitat for Humanity homes
for households with incomes at or below 50% AMI.
       20 units made available through acquisition, rehabilitation, and resale of
foreclosed, abandoned, and vacant properties for households with incomes between 51%
and 80% AMI.
       5 units made available through acquisition, rehabilitation, and resale of
foreclosed, abandoned, and vacant properties for households with incomes between 81%
and 120% AMI.
       15 units made available through new construction for households with incomes
between 81% and 120% AMI.

The State of Nebraska intends to make at least 30 dwelling units available for households
whose incomes does not exceed 50 percent of area median income.

F. PUBLIC COMMENT

Provide a summary of public comments received to the proposed NSP Substantial
Amendment.

Note: proposed NSP Substantial Amendment must be published via the usual methods
and posted on the jurisdiction’s website for no less than 15 calendar days for public
comment.

Response:

Public comments were solicited via e-mail or letter to:

Lara Huskey
Director, Community and Rural Development Division
PO Box 94666
Lincoln, NE 68509

lara.huskey@nebraska.gov

Public comments were accepted from November 10, 2008 until close of business on
November 25, 2008.

The proposed CDBG NSP Substantial Amendment was posted on the web at
http://www.neded.org/content/view/818/156/ on November 10, 2008. In addition, an e-
mail notification of the availability of the Amendment and related public comment
procedures was sent via electronic mail the Nebraska Development List serve,
participants in the DED CDBG NSP briefing, and persons who prepared DED CDBG
NSP pre-applications.

63 public comments were received. Please find the text of each comment below.



                                                                                        42
Comment 1

I was disappointed to see that there were no projects in the list for award for the
Panhandle of Nebraska. We proposed doing virtually the same type of project as several
other applicants. We would have thought some of the projects would be reduced to
allow funding for all of the regions to do similar, much-needed projects. Our
community is in a very difficult position with Aurora Loan Services being the second
largest employer. Because they service mortgage loans and their parent company has
declared bankruptcy, we don't know what is going to happen with them in the future and
don't know what is going to happen with their 520 employees. We hope you will at least
consider a project for someone in the Panhandle prior to submitting this for the final
application. I don't care if it is the project for Panhandle Area Development District,
Gering, Scottsbluff, or Monument Family Connections, but please include a Panhandle
project. If you took a small percentage from each of the projects that are on the award
list, you'd have enough to do a project in the Panhandle region.

Comment 2

Due to the nature of the high foreclosure rates, lower median incomes, and the fact that
these counties encompass Indian Reservations, 20 percent of the NSP funds ($3.6
million) will also be designated for Indian Reservations.

Comment 3

Please consider including Habitat for Humanity of Omaha as part of the Neighborhood
Stabilization Plan for Nebraska – specifically because of the need in the area of North
Omaha and the capacity of Habitat as outlined below.

       Omaha has the highest foreclosure rate in our state – nearly double that of any
       other city in Nebraska. We expect many more additional foreclosures as investors
       are beginning to go under. North Omaha is an at-risk community. Every home
       that is boarded up creates more instability in this community in need.

       North Omaha is the area of our state with the greatest need for renovation and
       demolition of old housing stock. There are nearly 800 condemned homes in zip
       codes 68110 and 68111, over 250 on the demolition list, and the city is only
       demolishing 30 a year. Fifteen percent of all lots are vacant, and 15% of all
       homes are vacant.

       Habitat for Humanity is uniquely positioned to help in this housing crisis. We
       renovate old homes, build news ones and have the capacity to demolish existing
       structures very affordably through partially donated services. 100% of our
       families are below 50% of median income.

       Habitat does not need to wait for a buyer that is interested in the property AND
       able to qualify for a loan. Habitat does our own underwriting and mortgage

                                                                                           43
       lending and has a continuous list of 40 or more families that are waiting for a
       home.

       Habitat is fully supported by the community we serve. We have over 6000
       volunteers a year – eager to help with new or renovated construction. Our donor
       base consists of over 5000 donors.

       Habitat is successful. In Douglas & Washington Counties, we have over 240
       mortgages and have only foreclosed on 6 loans in 24 years. In 2008, Habitat will
       build or renovate 30 homes.

Please consider the needs in North & South Omaha and Habitat’s unique ability to
quickly renovate and sell homes to families in need. Habitat would be a good partner for
you in meeting the goals of NSP.

Comment 4

I think it is vital that Habitat for Humanity of Omaha (serving Douglas and Washington
County) be included to receive funds for the $19.5 million dollars for the following
reasons.

1) Omaha has the highest foreclosure rate in the state,
2) North Omaha is a blighted community that is most at-risk with foreclosure rates,
3) Habitat has the capacity to help meet the goals of the stabilization plan, and
4) Habitat rehabs houses and helps prevent neighborhoods from deteriorating.
5. These neighborhoods in Northeast and now starting in Southeast Omaha are being
TRANSFORMED, block by block. I invite you to come visit our organization and take a
tour of our good works in these neighborhoods. The way these streets now look will take
your breath away with their transformations from blighted to good, safe and stable
neighborhoods.
6. Our work benefits helps to increase tax revenues for our community by rehabilitating
and building new homes-increasing property values in areas where it has sunk to next to
nothing.
7. Through our partnership, we will help break the cycle of poverty by offering families a
“hand up”, not a hand out. Our homeowners BUY their homes through no-interest loans.
Between the time these families are approved for a loan and the completion of their home
they must attend classes on home ownership, fiscal responsibility and devote 350 hours
of “Sweat Equity,” volunteering their time to help build their own home as well as others.
8. In conclusion EVERYONE WINS when investing their funds in our organization in
the following ways:
    • Help break the cycle of poverty
    • Create safer and more stable neighborhoods in blighted areas
    • Increase tax revenues for our community
    • Instead of “giving a man a fish,” we “teach them how to fish,” figuratively
        speaking.


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   •   Offer hope to hard-working low-income families, by creating better futures
       through homeownership

Comment 5

 As a donor of Habitat for Humanity of Omaha , I really think that they need to be
included to receive funds for the $19.5 million dollar grant from HUD for the following
reasons.

   •   1) Omaha has the highest foreclosure rate in the state,
   •   2) North Omaha is a blighted community that is most at-risk with foreclosure
       rates, plummeted property values. These factors only increase the chance of
       more neighborhood destabilization by encouraging crime and gang activity.
   •   3) Habitat has the capacity to help meet the goals of the stabilization plan, and
   •   4) Habitat rehabs houses and helps prevent neighborhoods from deteriorating.
   •   5. These neighborhoods in Northeast and now starting in Southeast Omaha are
       being TRANSFORMED, block by block.As an example, all you need to do is
       drive down streets like 33rd and Manderson in Omaha to see for yourself-among
       others. The way these streets now look will take your breath away with their
       transformations from blighted to good, safe and stable neighborhoods.
   •   6. Our work benefits helps to increase tax revenues for our community by
       rehabilitating and building new homes-increasing property values in areas where
       it has sunk to next to nothing.
   •   7. Through our partnership, we will help break the cycle of poverty by offering
       families a “hand up”, not a hand out. Our homeowners BUY their homes through
       no-interest loans. Between the time these families are approved for a loan and the
       completion of their home they must attend classes on home ownership, fiscal
       responsibility and devote 350 hours of “Sweat Equity,” volunteering their time to
       help build their own home as well as others.
   •   8. In conclusion EVERYONE WINS when investing their funds in our
       organization in the following ways:
   •   Help break the cycle of poverty
   •   Create safer and more stable neighborhoods in bad ones
   •   Increase tax revenues for our community
   •   Instead of “giving a man a fish,” we “teach them how to fish,” figuratively
       speaking.
   •   Offer hope to hard-working low-income families, by creating better futures
       through homeownership

Thank you for your consideration. I know the director, Amanda Jedlicka, would be glad
to answer any questions and even give you a tour of our neighborhoods we have
transformed.

Comment 6




                                                                                       45
Please consider Habitat for Humanity for funding from this grant. They positively affect
the lives of the most in need.

Comment 7

Please consider including Habitat for Humanity of Omaha as part of the Neighborhood
Stabilization Plan for Nebraska. The reasons Habitat Omaha should be included are
many. for instance, Omaha has the highest foreclosure rate in the state. North Omaha in
particular is a blighted community that is most at-risk with foreclosure rates. Habitat for
Humanity has the capacity to help meet the goals of the stabilization plan because Habitat
rehabs houses and helps prevent neighborhoods from deteriorating.
I served a year of AmeriCorps National Service at Habitat Omaha, and their mission and
what they do is very close to my heart. The joy that Habitat brings to so many families in
Omaha could certainly be increased exponentially with their inclusion in the
Neighborhood Stabilization Plan. Thank you for your time, and again, please do not
exclude Habitat Omaha and all of the good things that they do.

Comment 8

In support of Habitat for Humanity receiving funding, I can attest first hand the changes
that Habitat makes in a new home owner's life. I've been to a ceremony called a
dedication where Habitat for Humanity hands the keys to the new homeowner. The
sacredness of that moment is priceless. The home owner's Pastor or Spiritual Leader will
come out and say a prayer for the new family and I've felt the love in that house when
that's happening among, once strangers, now a team who finished building a home! The
home is more than just wood framing and carpet. It's a stake in the community that needs
that kind of support and commitment from it's constituents. Please include Habitat for
Humanity for this year's, or should I say, next year's funding. Thank you,

Comment 9

Hello, my name is Steven Beck and I am a Community Development Advisory
Committee member in Grand Island. I am writing to you as I am concerned that the State
is proposing to allow everyone who didn’t submit a pre-app to apply in the open round
against everyone who submitted a pre-app. By doing this you are basically
demonstrating that is doesn’t matter if you submitted all of the paper work in the correct
manner and by the correct time as you still have the same chance as those who chose to
do nothing.

They are using other cities information as their plan which they will submit to HUD. At
this time there is not an allowance, or priority given to those who qualified in the pre-
app. I am asking you to set aside the amount currently allocated for those who submitted
pre-apps and then split the rest of the grant funds among those who apply in the open
round.

Comment 10

                                                                                        46
I would like Habitat Omaha to be included in the Neighborhood Stabilization Plan. I am
on the Board of Directors for Habitat for Humanity.

   1) Omaha has the highest foreclosure rate in the state, 2) North Omaha is a blighted
      community that is most at-risk with foreclosure rates, 3) Habitat has the capacity
      to help meet the goals of the stabilization plan, and 4) Habitat rehabs houses and
      helps prevent neighborhoods from deteriorating.

Please support Habitat.

Comment 11

As a board member of Habitat Omaha, I have seen first hand the benefits of this valuable
organization. Please consider Habitat Omaha to be included in the Neighborhood
Stabilization Plan. There is a great need for affordable house in area of North Omaha.
Omaha has the highest foreclosure rate in the state of Nebraska - nearly double that of
any other city in our state. We fully expect many more foreclosures as investors are
beginning to go under. North Omaha is an at-risk community. Every home that is
boarded up creates more instability in this community.

The capacity of Habitat as outlined below:

 Habitat for Humanity is uniquely positioned to help in this housing
 crisis. They renovate old homes, build new ones and have the capacity
 to demolish existing structures very affordably through partially
 donated services. 100% of their families are below 50% of median
 income.

 Habitat is fully supported by the Omaha community. They have over 6,000
 volunteers a year - eager to help with new or renovated construction.
 The donor base consists of over 5,000 individuals/organizations.

 Habitat does not need to wait for a buyer that is interested in the
 property AND able to qualify for a loan. Habitat does their
 underwriting and mortgage lending and has a continuous list of 40 or
 more families that are waiting for a home.

 Habitat is successful. In Douglas & Washington Counties, they have over
 240 mortgages and have only foreclosed on 6 loans in 24 years. In 2008,
 Habitat will have built or renovated 30 homes.

Please take these points into consideration. Habitat would be an excellent partner for you
in meeting the goals of NSP.

Comment 12

                                                                                       47
Regarding comments to the Annual Action Plan, especially the NSP funding our county
has concerns that while other parts of the United States may already be feeling the effects
of foreclosures, we in this area have only begun to feel the impact, and with several
closures announced in Nebraska and one significant in limbo for Dawson County
concerning a large number of households, we may not be aware of how deeply we will be
impacted. The NSP funding should allow for some flexibility to address future events
that will have significant impact on the number of foreclosures that could occur in the
future due to these plant closures.

Thank You!

Comment 13
I am a member of the Grand Island Community Development Advisory Committee and
would like to provide a comment in regard to the proposed 2008 Housing and
Community Development Substantial Plan Amendment for the Neighborhood
Stabilization Program. I am a real estate broker in Grand Island and support the City’s
plan to demolish substandard housing to rebuild safe, affordable housing as a
replacement. These funds are crucial to moving demolition of substandard housing
forward in this community.

In the first part of November, the Community Development Division submitted a pre-
application to the state for the Neighborhood Stabilization Program. We are pleased to
have been identified in one of the six levels as an appropriate, eligible program that
qualifies for grant funding based on your scoring criteria.

Joni Kuzma, Community Development Administrator, provided a copy of the State’s
proposed plan to the Advisory Committee. As a member of that Committee, I would ask
that the pre-applicants noted in the plan receive an allocation that is set aside for them
pending their completion of the larger application that is due in March. The pre-
applicants showed initiative, organization, and foresight in their ability to complete that
grant in a small window of time. It is good that other communities will have the chance to
apply for these funds even though they did not submit a pre-application, but I feel they
should have to compete against one another.

The Department of Economic Development has awarded thousands of dollars to Grand
Island over the years for housing projects. Each of those grants enabled our community to
make improvements in housing. This is a most unique program that will allow the City to
address substandard and vacant housing in a concentrated way that has not been done
before.

I appreciate having the opportunity to share my thoughts on this plan.

Comment 14




                                                                                         48
As a current Habitat for Humanity volunteer and advocate, I ask for you to
please consider including Habitat in your Neighborhood Stabilization Plan. You and your
plan would benefit greatly for several reasons. First off, Habitat has been both influential
and supportive of the North and South Omaha communities. If you include Habitat you
would be including a well established non-profit organization capable of achieving your
plan. Second, Habitat has a long history of bringing positive to both the community and
the city. The community benefits from new or refurbished houses in dilapidated
neighborhoods and the city benefits from the increase in tax revenue. Please take a
moment to consider all the benefits Habitat has to offer. Thank you

Comment 15

My name is Mike Klauer and I Chair the Finance Committee for Habitat for Humanity of
Omaha. I am emailing to request that Habitat be considered in the funds allocated to the
Neighborhood Stabilization Plan. For the reasons stated in the attached letter to you from
the Executive Committee, I believe the funds attained would be used appropriately to
assist in curbing the housing downturn by providing homes to qualified and committed
owners, consistent with our mission and history serving the Omaha area.

Comment 16

I would like Habitat for Humanity Omaha to be included in the Neighborhood
Stabilization Plan. North and South Omaha, areas that Habitat Omaha serves have a high
crime rate. Additional empty homes will increase the crime in those neighborhoods.
Homeownership has been proven to cut down crime and improve neighborhoods.

Comment 17

Habitat Omaha should be included in the Neighborhood Stabilization Plan.

Comment 18

Please consider including Habitat for Humanity of OMaha in your funds for the
Neighborhood Stabilization Plan. THis worthy and well run organization is basically
already in this business!.
 They currently serve this community and certainly can expand those efforts with
additional support. They renovate homes and sell them to those in need now- please let
them serve out their mission further by designating additional funds to help the
people of Nebraska ( with the work they already know how to do!).

Comment 19

Please include Habitat Omaha in the Neighborhood Stabilization Plan. Omaha has the
highest foreclosure rate in the state; moreover, North Omaha is a blighted community that
is most at-risk with foreclosure rates. Habitat has demonstrated its ability and the



                                                                                         49
capacity to help meet the goals of the stabilization plan. The homes rehabilitated by
Habitat prevent neighborhoods from deteriorating.

Comment 20

I am familiar with the work of Habitat for Humanity of Omaha and understand that they
are not currently a part of the Neighborhood Stabilization Plan for Nebraska. I would
like to ask that the Nebraska Department of Economic Development include Habitat for
Humanity of Omaha in that Neighborhood Stabilization Plan.

I believe that not only is there a great need in Omaha, but the Habitat for Humanity of
Omaha is well equipped to renovate old homes affordably and to sell these homes to low
income families that can make use of them.

Comment 21

I work for Habitat for Humanity of Omaha, Inc. so I may be a little bias. However, our
stabilization plan is something that addresses and embraces the needs of the community
during this critical housing crisis. Please consider including our organization as we
would appreciate the opportunity to serve the community through this special partnership.

Comment 22

The city of South Sioux City concurs with the plan for Neighborhood Stabilization
Community Development Block Grant funds. We recognize and appreciate the
tremendous effort made by the State of Nebraska to meet the needs of citizens of the
State with the parameters of the funds.

Comment 23

May we first compliment the Nebraska Department of Economic Development for the
great job of putting together the Neighborhood Stabilization Program Application in such
a short period of time. We are aware of the large volumes of information, federal
regulations, and project requests you had to process and greatly appreciate the
professional presentation of your Federal grant submission.

PADD also greatly appreciates all the effort the DED has made to address the housing
and community development issues facing all of rural Nebraska.

Even though we are aware that there will be a second opportunity to submit project
requests for the NSP, It is our understanding that this is our only opportunity to comment
on the Nebraska NSP program.

We thus would like to make a comment and a request for the DED to consider regarding
the impact the National housing crisis has had on the Panhandle region. As you are
aware, Aurora Loan Services is a subsidiary of Lehman Brothers that specializes in

                                                                                        50
originating and servicing home mortgages and employees over 500 persons in our
region. With the bankruptcy of Lehman Brothers, it puts their local loan servicing center
in a very precarious situation.

Given this unique impact the housing crisis is directly creating in the Panhandle region,
we hope the DED will consider granting at least one NSP project in the Nebraska
Panhandle.

Comment 24

I am writing to ask you to please include Habitat for Humanity of Omaha in the
Neighborhood Stabilization Plan. My husband and I moved to Omaha three years ago,
and since then I have gotten involved with Habitat for Humanity of Omaha Friends. I see
such a need for help in this area. My hope would be that if more funds are put into this
area, we might prevent neighborhoods in north Omaha from deteriorating any further.
Hopefully, in turn we will see a turn for the better in the crime rate, as we give hope for a
brighter future to the less forturnate. Also, when we give folks "ownership" in the
process of building their homes, as Habitat does, we evoke more of an attitude of pride in
their community. I feel it is such a worthy cause, and hope you will also, in your
decision making.

Comment 25

I understand that you are accepting public comments of the NSP Substantial Amendment
pre-applications. Joni Kuzma, our Grand Island Community Development
Administrator, has indicated to me that the pre-application of level 5 designation of need
indicates an order of approval. However, I’ve noticed on page 13 that this pre-
application was not a requirement and that some communities did not submit one.

Due to the extra effort that Joni and her staff went through, I would like you to consider
that the, allocations of need, that you listed on pages 2-4 be given priority when your
decision is made in March, 09.

Comment 26

I am on the Advisory Board of the Habitat for Humanity-Omaha organization and would
like to petition to have our Habitat group be part of the Neighborhood Stabilization Plan
grant from HUD. I am certain our Habitat organization has the capacity to meet the goals
of the stabilization plan and the staff of Habitat is exceptional in their diligence to the
cause of affordable housing for the Omaha community. The office is located in north
Omaha which is a blighted community and subject to high risk of foreclosures. Over the
years our Habitat office has worked very hard to keep neighborhoods from deteriorating
by filling empty lots with Habitat homes and conscientious home owners. It would seem
to me to be a perfect fit for the HUD dollars and an opportunity to have Nebraska be a
point of light in having great impact for the Neighborhood Stabilization Plan.



                                                                                            51
I sincerely hope the Department will give consideration to partnering with Habitat for
Humanity-Omaha.

Comment 27

As a personal supporter of Habitat for Humanity of Omaha and an employee of the
company that partners with the homebuilder, I submit this public comment in support of
including Habitat of Omaha in the state’s Neighborhood Stabilization Plan.
I formerly served as an AmeriCorps member and construction site supervisor with
Habitat of Omaha. I saw how the organization united the resources of local government,
philanthropies, and volunteers to build quality, affordable homes. But we built more than
homes – we built a conduit to savings and wealth for low-income families. These
families who earn between 30 and 50% of median income for the area, would otherwise
have no such path. Through 30-year, no-interest mortgages, Habitat of Omaha offers
American Dream to hardworking, underpaid families.
Furthermore, the organization transformed by life by engaging me in service to my
community. During my term of service , I learned marketable skills for my own career
and learned the value of helping the less fortunate. Each year, Habitat Omaha helps
hundreds of individual volunteers and AmeriCorps members make that same personal
transformation.
Currently, Goodwill’s YouthBuild program partners with Habitat Omaha to offer a
construction training program for youth ages 16 to 24 who have dropped out of high
school. Good will provides academic instruction and vocational training, and Habitat
provides a real-world training environment. This a comprehensive approach to
neighborhood revitalization – building and renovating homes, preparing young people for
college and careers, and developing tomorrow’s leaders. Habitat Omaha is critical to this
revitalization.
The number of foreclosed homes in Omaha is frightening. According to NSP data, more
than 105,000 people – one in seven Omaha residents – live in an area with an estimated
foreclosure abandonment risk score of 10 on HUD’s 10-point scale. And recently, the
NIFA first-time homebuyers program ceased making new loans as a result of the credit
crisis. Clearly, current economic conditions will only increase the need for affordable
housing, and Habitat Omaha’s no-interest model is uniquely positioned to serve the
families most in need.
Thank you for considering this public comment in support of including Habitat Omaha in
the Neighborhood Stabilization Plan.

Comment 28

I would like Habitat for Humanity of Omaha included in the Neighborhood Stabilization
plan.

Habit has build on over 200 vacant lots in Northeast Omaha and has done a gread deal to
change neighborhoods from weeds to houses, where a family can have a home of their
own.



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Omaha has over 400 houses that are boarded up and not occupied. Habitat, with financial
help, can rehab a number of these houses and provide a home for another family

Comment 29

I am writing today to request your consideration of including Habitat for Humanity of
Omaha as part of the Neighborhood Stabilization Plan for Nebraska. As a supporter and
former employee of Habitat Omaha I know first hand the success the agency has had in
rebuilding the North and South Omaha communities.

Habitat for Humanity makes homeownership a reality to families that would otherwise
never have the possibility or the hope for a home of their own. They stimulate progress
and re-development in neighborhoods otherwise left to deterioration. They inspire and
reinvigorate neighborhoods to step up and reinvest in their own homes and streets. They
provide thousands of volunteers with a meaningful and tangible way to help other
families in our city.

Please consider the needs in North & South Omaha and Habitat’s unique ability to
quickly renovate and sell homes to families in need. They would make and excellent
partner in obtaining the goals of the NSP.

Comment 30

I represent a rural county in central Nebraska with 5 communities. I am a certified
CDBG administrator with over 10 years experience in this field. I submitted a grant pre-
application to the NE Dept of Economic Development within time frame requested.

My application request was NOT included as a high priority project in the NE plan
submitted to HUD. We are assuming that we did not meet the major criteria outlined in
the Federal NSP priorities?

Although the communities in Sherman County have seen a 75 percent increase in
foreclosures over the last 2 years, we feel that we are being “penalized” because our local
banks have been more diligent than our urban counterparts and have NOT provided “sub-
prime” loans to unqualified applicants.

Our communities’ average over 60% area LMI and we are experiencing serious
population decline due to the lack of quality affordable housing available. Our
communities’ have very low unemployment rates leading to a very competitive labor
market. This makes the availability of quality affordable housing that much more
important to attract and retain our population.

We are confident about our housing needs because Loup City undergone two
professionally prepared blight/redevelopment studies, one comprehensive housing
plan/study, one comprehensive plan, and one comprehensive economy development



                                                                                        53
strategy within the last 10 years. Based on our history of preparation and planning, we
feel that we are more than prepared to administer an NSP project.

We simply propose the acquisition and demolition of 21 “blighted or foreclosed”
structures/properties.

Acquisition and demolition of these properties will create opportunities:
   • For developers and individual homeowners to build what our market demands,
       thereby
   • Increasing the local property tax base and subsequently providing better services
       and living standards for everyone

Housing is our primary economic development strategy as we have very few large
employers but we are in close proximity to two larger cities and one of Nebraska’s largest
Lakes/recreation areas.

It our recommendation that the activity of acquisition and demolition of “blighted or
foreclosed” structures/properties be placed as a higher priority in the best interest of our
nation and impoverished rural America in general.

Comment 31

I want to thank you in advance for considering Habitat for Humanity of Omaha as a
partner in the Neighborhood Stabilization Plan for Nebraska. Habitat has unique
capabilities that can help mitigate the severity of the housing crisis immediately. Our
capabilities include:
    • Flexibility - We both build and renovate homes. In addition we are able to
        demolish existing structures at low cost.
    • Responsiveness - We are not reliant on banks to approve potential home buyers.
         Through our own underwriting process we can approve buyers and we maintain a
        list of families waiting to buy.
    • Human Resources - We have over 6000 working volunteers.
    • History and Reputation - We have over 240 outstanding mortgages and will build
        or renovate 30 homes in 2008.

As you know the North Omaha area is faced with significant housing challenges.
 Between condemned homes and foreclosures it is the most at risk part of our community
and perhaps the entire State. We are active in this community today and we can
accomplish much more by partnering with the State through the Neighborhood
Stabilization Plan.

Comment 32

My name is Norma Fletcher and I would like to support the efforts of Omaha Habitat for
Humanity to be included in the Neighborhood Stabilization Plan. As a long time
volunteer builder with Omaha Habitat I can testify to their efforts to provide well built,

                                                                                           54
functional homes for the low income members of Omaha's community. Habitat is the
perfect organization to take foreclosed homes, make sure they are remodeled for future
occupants and get these homes to the working poor of Omaha. Omaha Habitat has a stong
volunteer base and is well equiped to handle more homes.
Please consider Habitat for Humanity of Omaha to carry out the goals of the
Neighborhood Stabilization Plan.

Comment 33

I am writing this in support of the application from Buffalo County for the NSP funds.
As a local banker and a member for the Buffalo County housing work group I feel the
NSP funds would be a wonderful opportunity for Buffalo County to grow and revitalize
their communities.
I attend the monthly housing senate meetings and I see how the communities have really
come together and are working diligently and putting their hearts into on how they can
revitalize their communities and make them a welcoming place to live and raise a family.
I am a native to Buffalo County and have seen what the communities can provide and I
really feel that the funds would be a great opportunity to give the towns a way of getting
rid of the structures that are not livable and provide new, affordable, safe homes to be
purchased and help the communities grow.
Thank you for your time in reading this and please consider Buffalo County’s application
to NDED.

Comment 34

I am the Buffalo County Housing Senate Representative for the Village/City of Kearney.
I feel this Housing Senate has assisted all of the Buffalo County communities to
recognize the needs of the County as a whole and that all communities are working
toward a common goal. The Housing Senate has been working toward improving the
available housing in Buffalo County. We have looked at improving our neighborhoods
by removal of deteriorating buildings in each of our communities. We are appreciative
of the opportunity to submit a pre-application to NDED for the NSP program. We had a
planning meeting with the Housing Senate members to discuss the opportunity and all of
the communities in Buffalo County gathered data for submittal into the grant application.
The Housing Senate members talked to local bankers, realtors, the County Treasurer, and
city officials to gather the most accurate information they could for the pre-application.
We would appreciate it if NDED considered the Buffalo County application to help us
realize our goals for the county.

Comment 35

Buffalo County Economic Development Council is diligently working to offset a
shortage of a skilled, educated workforce by recruiting area alumni back to Buffalo
County. While we hope that these efforts are successful in attracting our alumni back to
their roots, we are also concerned with the limited availability of housing in many of our



                                                                                        55
county communities. Should a graduate choose to return to and live in their hometown,
they may face challenges in locating adequate housing for their families.

The opportunity that the NSP program offers to these communities to improve their
available housing inventories would be very advantageous. For this reason, please
consider the Buffalo County application for the NSP program to put our best foot forward
to attract new residents and improve on the neighborhoods we already have. Buffalo
County is very progressive and we would put the NSP funds to good use. We are
thorough and have the capacity to attain the outcomes we develop for the program. We
would appreciate your consideration of our application.

Comment 36

I serve on the Buffalo County Community Partners Board and their work group Positive
Pressure. In addition, I am also the President of the Board of Directors for RAFT
(Residential Assistance to Families in Transition). Our goal is to assist Buffalo County in
accomplishing the goals of the 2008 Buffalo County Housing Study. In particular, the
Buffalo County Attorney's Juvenile Services Office recognizes the needs of the County
as a whole and to insure that all communities are on the same vision, working toward a
common goal. As a group we have been working for months toward the common goal of
improving housing in Buffalo County. As a part of this goal, demolition of dilapidated
structures was deemed a priority in each of our communities. Because of this priority we
were very excited at the opportunity to submit a pre-application to NDED for the NSP
program. We had a planning meeting with the Housing Senate members to discuss the
opportunity and all of the communities gathered data for submittal into the grant
application. The Housing Senate members talked to local bankers, realtors, the County
Treasurer, and municipal elected officials to glean the most accurate information for the
pre-application. We would appreciate it if NDED considered the Buffalo County
application in all aspects to help us attain our goal.

Comment 37

I serve on the Buffalo County Community Partners Board. One of our goals is to assist
Buffalo County in accomplishing the goals of the 2008 Buffalo County Housing Study.
This organization recognizes the needs of the County as a whole and is working to ensure
that all communities are working toward a common goal. As a group we have
been collaborating for months toward the common goal of improving the housing in
Buffalo County. As a part of this goal, demolition of dilapidated structures was deemed a
priority in each of our communities. Because of this priority we were very excited at the
opportunity to submit a pre-application to NDED for the NSP program. We had a
planning meeting with the Housing Senate members to discuss the opportunity and all of
the communities gathered data for submittal into the grant application. The Housing
Senate members talked to local bankers, realtors, the County Treasurer, and municipal
elected officials to glean the most accurate information for the pre-application.
We believe this opportunity is crucial for continued growth in our communities and



                                                                                        56
would appreciate it if NDED considered the Buffalo County application in all aspects to
help us attain our goal.

Comment 38

I’m writing to urge that Habitat of Humanity Omaha to be included in the Neighborhood
Stabilization Plan.

Comment 39

The City of Scottsbluff is concerned with the direction of funding under the
Neighborhood Stabilization Program (NSP). While we understand certain criteria help
define the targets for funding it is very difficult to understand how some jurisdictions in
the State were fully funded for projects identical to those the panhandle submitted. If one
looks objectively at the need to stabilize neighborhoods our need is at the very least equal
if not greater than others who appear to be in line for funding. It appears application of
the criteria has been somewhat oversimplified.

The impact of these difficult national economic conditions are in fact shared by the
panhandle. One only needs to look at how recent economic stress has added to stress' of
the panhandle's already low income levels. We have struggled for decades with higher
than average levels of low income households. Thus we do not accept the apparent view
that somehow the panhandle is an isolated area free from national economic problems
sited in criteria for the NSP. What is true is that a poor national economy sinks the
disproportionately high number of low income households to even lower standards of
living, much lower than the State of Nebraska as a whole thus destabilizing our
neighborhoods further.

We applaud past funding for important projects that have served to stabilize our
neighborhoods and will continue to strongly support the DED and others at the State level
who recognize the panhandle's unique economic conditions. We are concerned that in
this case a careful second look at sharing the wealth is in order. We would love to see a
Scottsbluff project funded but urge additional consideration for the panhandle as a
whole. We look at the health of this region of the State as our first priority and consider
our contributions to the welfare of the entire State as our primary goal.

Comment 40

I am the director of the Buffalo County Community Partners. I hope that you are
receiving a few emails today from our many partners in Buffalo County expressing their
interest in the investment of housing dollars in our communities. Our organization
started in 1995 with the express intent to define community goals. We have 10 goals to
achieve by 2010. One of those goals has always been to increase affordable housing in
Buffalo County.
Our organization has organized multiple work groups in the community since 1994. We
coordinate between homeless programs, near homeless, mental health, substance abuse,

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business engagement, and youth engagement and many others. One of our indicators
requires us to decrease homelessness and many of the members of the Homeless
Coalition maybe connecting with you to share their support of this funding. One of our
goals addresses mental health housing, so we are working with many organizations to
determine need for this type of funding. Our workgroup has conducted the past 2
housing studies and most recently conducted the first Buffalo County wide housing
study.
The study outlines that we should develop a county wide Housing Senate, which has been
completed and I hope you are hearing from some of the Senate people. And we also are
working toward attainment of another housing study recommendation to remove vacant
and dilapidated structures in Buffalo County. I made many of the calls to each Buffalo
County community. Each community is very excited for this type of funding. They see a
great need in each of the community which is also outlined as our greatest need in the
Buffalo County housing study. We also received great response from bankers who are
sitting on repossessed homes in Buffalo County. Our hardest hit area is in the south east
side of the county in Gibbon and Shelton.
We encourage you to consider investing funds in Buffalo County. We have a tremendous
need in this area for rehabbing homes, removing vacant homes and providing affordable
housing for our communities. These needs match very nicely with your grant funding.
Please let me know if we can provide any other information. We look forward to hearing
from you and your office.

Comment 41

I am writing in support of the Neighborhood Stabilization Program (NSP) pre-application
submitted for Buffalo County, excluding the City of Kearney and including Sumner in
Dawson County. The Buffalo County Housing Work Group and the Housing Senate
have worked diligently to obtain specific data for this pre-application. Personnel
throughout the County are prepared to begin the project, including individuals with the
capacity to administer the program in a timely manner. I urge NDED to give full
consideration to this pre-application.

The Housing Senate was formed as an outcome of the 2008 Buffalo County Housing
Study conducted by Western Economic Services, LLC. Representatives of the nine
communities in the county, plus one rural representative, have organized to address the
needs of the County as a whole and insure that all communities are working toward the
common goal of addressing affordable housing in Buffalo County. During the needs
identification process, demolition of dilapidated structures was deemed a priority by each
of the community representatives. Therefore, the opportunity to submit a pre-application
to NDED for the NSP program was identified as an exciting avenue to accomplishing this
goal. At a recent planning meeting, the Housing Senate members discussed the prospect
and each of the community representatives gathered data for inclusion in the grant pre-
application. The Housing Senate members discussed the potential project with lenders,
Realtors, the County Treasurer, and municipal elected officials to obtain the most
accurate information for the pre-application.



                                                                                       58
I would appreciate NDED’s consideration of the Buffalo County NSP application as an
avenue to address the revitalization of communities in Buffalo County. Thank you for
the opportunity to submit input on the funding of future NSP projects.

Comment 42

My name is Tom Hunter and I am the Victim/Witness Assistance Director for Scotts
Bluff County. My office is located in the county attorney’s office. I have held this
position for the past 18 years. During this time I have worked with many needy families
and battered women that have been displaced from their homes. Our local domestic
violence staff is doing an incredible job of assisting domestic violence victims and often
with children. All too often crime victims are forced into personal financial problems that
are not of their creation. Some victims loose their employment through extended medical
recovery. Many people are victimized by the crime and then they are re-victimized with
an avalanche of medical bills that get sent to collection agencies because of their failure
to pay. These financial situations often lead to utility disconnects, inability to provide
basic necessities for their children and homelessness.

For the past several years I have served on the board of directors for Monument Family
Connection. MFC goal is to provide emergency housing for homeless people. At the
present time we located property in a blighted area of Scottsbluff. All of the buildings on
the property are abandoned and need to be demolished. None of the buildings (and old
motel with multiple units and a liquor lounge) is suitable to inhabit as they are asbestos
and rodent contaminated. At the present time the board is negotiating with the property
owner to purchase the property. We have polled the residents and businesses in the area
and have their support. We also have the support and encouragement to build emergency
homeless shelter from our area churches. .Twin City Development in Scottsbluff desires
to collaborate with us on the project.

Monument Family Connections needs financial assistance for development and
maintenance of this community betterment project.

Thank you for this opportunity of voicing my comments and opinions regarding our
homeless emergency housing project.

Comment 43

The Buffalo County Community Partners was the applicant for the Nebraska
Stabilization Program to 1) remove vacant and dilapidated homes and 2) assist in
rehabilating repossessed homes in Buffalo County. The letter of intent was submitted to
the Nebraska Department of Economic Development (NDED). We recently found out
that Buffalo County was not inserted into the plan the NDED sent to HUD.

I serve on the Buffalo County Community Partners Board. Our goal is to assist Buffalo
County in accomplishing the goals of the 2008 Buffalo County Housing Study. In
particular, Kearney Housing Agency recognizes the needs of the County as a whole and

                                                                                         59
ensures that all communities are on the same vision, working toward a common goal. As
a group we have been working for months toward the common goal of improving the
housing stock in Buffalo County. As a part of this goal, demolition of dilapidated
structures was deemed a priority in each of our communities. Because of this priority we
were very excited at the opportunity to submit a pre-application to NDED for the NSP
program. We had a planning meeting with the Housing Senate members to discuss the
opportunity and all of the communities gathered data for submittal into the grant
application. The Housing Senate members talked to local bankers, realtors, the County
Treasurer, and municipal elected officials to glean the most accurate information for the
pre-application. We would appreciate it if NDED considered the Buffalo County
application in all aspects to help us attain our goal.

Kearney Housing Agency has a Management Contract with Gibbon and Shelton and as
the Director for Public Housing these 3 communities in Buffalo County, I can assure
there is a tremendous need to address the worn out housing no longer meeting the needs
of the community. This housing provides substandard living conditions, creating social
issues, is an eyesore, invites vandalism and an increase need for law enforcement.
Communities need to be able to move forward to address the issues of decent, safe and
affordable housing and the NSP program is a step in the right direction.

Please reconsider and include Buffalo County for the NSP program.

Comment 44

It is my understanding Tribes/Native Americans are considered eligible participants in
the Neighborhood Stabilization Program (NSP). I made some local inquiries about any
meeting notices that would have been received regarding this program. Unfortunately,
none of the mail logs hold any reference to any NSP public meeting notice.

Regarding the State's proposed NSP, the only reference to Native Americans I found in
the amendment to the 2008 Housing and Community Development Annual Action Plan
was regarding leases on trust properties.

The wording in the paragraph that relates to Native Americans is such that it precludes
many of the group. What is asked is that all Native American Homebuyers/Owners
living on trust properties need to amend there homesite leases to fifty years. According
to a USDI/BIA Realty Officer, they would require a Tribal Resolution to change
a homesite lease to 50 years to comply with 25 CFR. There is just not enough time to
accomplish this task for every potential applicant. We find this unreasonable.

The majority of Native Americans reside on trust properties within Reservations. These
areas have the highest rates of overcrowding, unemployment and are
economically distressed. These areas also have the lowest median incomes in the State
and are therefore the most needy population.




                                                                                         60
A simple solution to the problem would be similar to the neighboring States which have
set-aside up to 25 percent of the Neighborhood Stabilization Program Funds for Native
Americans living on Reservations.

We respectfully request the State of Nebraska Department of Economic Development to
make a similar set-aside of 20 percent or 3.6 million dollars. These funds would be used
in accordance with the national program objectives for use on all the Indian
Reservations located in the State of Nebraska.

This would enhance the quality of life on the Reservations by providing safe and
affordable housing, creating employment, and helping the local economy.

Comment 45

Goodwill has been working with the Buffalo County Housing work group for many years
and we have a strong interest in housing throughout our entire area.

Please consider the Buffalo County NSP application, as the Buffalo County Housing
Work Group and the Housing Senate have worked hard on obtaining precise data for the
pre-application. We have the persons ready to start the program and persons who have
the capacity to administer the program timely and correctly. Your consideration of our
application would be greatly appreciated and we know you won’t be disappointed in the
completion of the project.

Comment 46

My comment and support for a similar provision as found in South Dakota would be an
excellent leveraging strategy. And, would be a good way for tribes to work in
collaboration with local governments in areas where there are tribal members residing in
fee land. Perhaps like Walthill in Thurston county as an example. The Ponca Tribe of
Nebraska actually has technical service areas established by the Congressional
Restoration Act that includes 14 counties to include Douglas and Lancaster. I’m sure the
Santee Tribe, Omaha Tribe, and Winnebago tribe would like to find ways to expand
housing in adjacent or contiguous areas or areas “on or near” their reservations.

The South Dakota 20% could definitely be a model for Nebraska in the area of
addressing state-tribal relations development in areas involving rural economic
development and housing needs.

The Northern Ponca Housing Authority would like to see a 20% set aside for the 4
nebraska Indian tribes similar to the South Dakota plan.

Comment 47

In reviewing the recommendations for the use of NSP funds, I have a need for the
department to consider. I believe there is a great need for funds to be allocated to the

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panhandle of Nebraska for the purpose of addressing emergency shelter needs for
homeless individuals and families.

The Region I Continuum of Care for Housing and Homelessness formed a sub committee
to work on this effort several years ago. This sub committee formed a
501 C3 which is managed by it’s own independent board of directors. This non – profit,
Monument Family Connections, has been working diligently to obtain funding to open an
emergency shelter. Our first effort was to partner with the Housing Authority to convert a
GSA building which had been given to them, into shelter and transitional housing. The
Housing Authority received grant funds from DED to help with this project As the
department is aware, there was much controversy over the location which ultimately
ended in DED rescinding the grant until a more equitable location could be found.

The department has been very supportive of this effort and has looked at several of the
locations we have considered. Monument Family Connections has continued to seek a
suitable site and community support for such a project and we believe we are close. The
NSP funds would fit perfect with our venture. We have located an old hotel and bar
which is an eye soar and safety issue for the community. Homeless people have been
found sleeping in the hotel rooms which have raw sewer water standing, the fire
department has been called to the location and the outside of the building is covered in
graffiti.

Having the opportunity to write a grant which offers funding for demolishing and/or
rehabilitating abandoned properties is exactly what Monument Family Connections has
been waiting for. The project will house households at 50% AMI or less. As board chair
of MFC and the Operations Manager for Cirrus House, I have been actively involved in
the Region I CoC and see the magnitude of the homeless problem in our area on a daily
basis. At the present time MFC and Cirrus House use vouchers from NHAP and State
PATH grant funds to assist homeless referrals. These funds are minimal and only help a
small percentage of those referred. Having a shelter would stretch our resources and
would fill a gap for agencies through out the panhandle.

Monument Family has a design committee which is researching green build as well as
other energy efficient construction. We have included local engineers, architects and city
staff in the development of our plan. We intend on utilizing community volunteers as
well as employing homeless individuals during the construction and/or redevelopment
and beyond. MFC has networked with other agencies in the panhandle to provide case
management/support services to help families transition from homelessness to permanent
housing. We have listened to our community and believe the location and the plan we
have for constructing a shelter answer concerns expressed by neighbors and business
leaders.

We are hopeful the Nebraska Department of Economic Development will give us the
opportunity to apply for these funds by allocating an proportionate amount of NSP funds
to the panhandle for the purpose of demolishing blighted structures and the
redevelopment of demolished or vacant properties.

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Comment 48

Please accept this public comment regarding the NSP program. These funds are
desperately needed in the Panhandle to build an emergency shelter in a blighted area of
our community. Community Members have been working together for several years to
find a suitable location and determine the safest and most empowering shelter model.
NSP funds would assist our community in improving a blighted area of our community
and encouraging additional beautification projects while establishing a green-build
emergency shelter.

I strongly encourage you to consider the Panhandle (especially the Scottsbluff/Gering
area) for use of these funds.

Comment 49

I am writing to ask you that Habitat for Humanity of Omaha, Inc. be included in the
Neighborhood Stabilization Plan. I presently serve as Board President and can tell you
that we are in a unique position to serve a blighted neighborhood is on the brink of
disaster. Market forces are driving foreclosures at a rate higher than anywhere else in the
state of Nebraska. We can help meet the goals of the Stabilization Plan and we hope that
HFHO will be considered for funding.

Comment 50

Family Monument Connection in Scottsbuff, NE’s goal is to build a sustainable
emergency shelter in Scottsbluff using blighted property on the East side of the city. We
are currently negotiating for one of two sites. We will have on site management and a
social support caseworker, charged with helping residents obtain food, clothing,
employment and health care.

We have considerable community support, but always need more. We are networking
with agencies who refer homeless people to us and others. We are currently working
with vouchers using rooms at motels and empty apartments for short term housing. Our
limited funds come from local and state grants and future funding is in the form of Bricks
and Mortar Grant Pledges from local banks, state, and community sources.

As you well know, in these times there is a great need for a facility of this type, especially
in a community of our size in Western Nebraska. The largest communities near us our at
least one hundred miles in any direction. A recent paper has stated the homeless
population has risen 30% since the summer. Combined with job loss and home
foreclosures, these matters will certainly worsen.

I am co-chair of the design committee and we are dedicated to a totally green technology
for this facility. I have proposed the idea of building the facility of adobe brick design,
using the latest in solar technology, as well as passive solar architecture and landscaping.
This idea would help us in several ways:

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1) Historically, being on the Oregon Trail, pioneers often built their homes using local
resources such as mud, sand, and hay using less sophisticated building skills. Skills
which could employ homeless and unemployed persons and community volunteers. A
structure of this nature can save as much as 50% in building costs. Many fine and
enduring buildings have in the past and continue to be built with these materials.
2) This process and over all design could be used as an educational tool in our local
schools and college.
3) A project of this nature could open up possibilities for grant and loan monies directed
at organizations promoting alternative and sustainable energy sources as well as
humanitarian organizations.
4) I believe if we can realize all of these goals that such a facility would be a "showcase"
and a model for the community, the state, and perhaps the nation.

I hope that you and your program will keep this western end of Nebraska in mind, and
will lend any assistance you can. As you know, the need is dire.


Comment 51

It is great to hear about HUD’s new Neighborhood Stabilization Program that will
provide emergency assistance to state and local governments to acquire and redevelop
foreclosed properties that might otherwise become sources of abandonment and blight
within their communities. Before the mortgage and foreclosure crisis even happened we
have been dealing with this issue locally for several years. I am afraid it will only get
worse now.
I understand that Omaha and Lincoln are always going to be at the top of the list for
funding like this - if for no other reason because of their size and population compared to
the rest of the state. However I would like to urge you to consider some of the dire needs
in the Panhandle of Nebraska especially Scotts Bluff County.
I have an extensive background in working with homeless youth (ages 22 and younger) in
the Panhandle. Through my experience of working with Monument Family Connections
and now at Cirrus House, Inc. I can testify that the homeless problems span across ages
and most often affect families and parents with children. As you may know Panhandle
Community Services has a Transitional Living Program for homeless youth ages 16 to
21. These are youth who are NOT part of the foster care system or part of any other
system of care – they are on their own - out in the streets and living in substandard
housing such as run down abandoned houses, trailers with no heat or running water and
living out of their cars. The following chart shows how many youth were turned away
because the TLP program was at maximum capacity.
Year Number of Youth Turned Away from the Transitional Living Program because
the program was at maximum capacity.
Note: These are all youth that filled out an application and met the FYSB definition of
homelessness.
2002-2003        31 youth turned away
2003-2004        59 youth turned away

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2004-2005        60 youth turned away
2005-2006        81 youth turned away
2006-2007        66 youth turned away
2008 update All TLP apartment slots (16) are currently full and they continue to
receive referrals of homeless youth.
That is 297 unduplicated homeless people in a specific age range since 2002. Last month
Cirrus House, Inc had 21 referrals (in 24 days) of homeless people of various ages
seeking us out for housing. Scotts Bluff County has a housing crisis right now. We do not
have an Emergency Shelter option for people who are already homeless and we have
blighted areas with land lords that are grossly taking advantage of low income, homeless
and vulnerable populations of people.
Next time you are in the city of Scottsbluff please take a drive through the Wagon Wheel
Trailer Court. The owners of this property live in Colorado and rent rundown trailers to
anyone with cash in hand. You will find 1 and 2 bedroom trailers with no furniture that
have 10 to 15 people living there sleeping on blankets on the floor. You will find trailers
with broken windows and some with no electricity some with no running water. Yet these
trailers are being “rented” legally. This is just one example – there are others just like it.
Every winter in Scottsbluff people engage in survival sex just to have a warm place to
sleep at night. I have personally worked with an 18 year old mother who was sleeping in
an unheated garage with her 6 week old baby, a 21 year old man who lives in his car in
the Wal-Mart parking lot (where he works full time but has no place to live), a young
married couple who bum places to sleep from couch to couch and sleep in their car when
no other option is available, two homeless girls that are cousins and sleep where ever they
can at night yet they still make it to school each day and are getting B’s and C’s for
grades.
I can go on and on but my point is this: Scotts Bluff County may not be able to ever
compete with the numbers and statistics that Omaha and Lincoln can put up but people
(human beings) are more than a group of numbers. Our end of the state has dire needs
that go unmet year after year. On paper, 297 homeless youth in 5 years might look like a
drop in the bucket compared to Omaha and Lincoln but when you have to look that one
person in the face and say “I’m sorry I don’t have any place for you to stay tonight.” the
numbers take on a whole different meaning.
I would urge you to consider the Region I, Panhandle area for this and future funding
opportunities that can address our very real housing crisis and need for emergency
shelter.

Comment 52

As Mayor of the City of Ravenna I would encourage you and the DED to consider the
Buffalo County NSP Program Application. Having worked with the Buffalo County
Housing Senate and having attended some of the Buffalo County Housing meetings;
along with offering input from the City of Ravenna’s Housing Listening Sessions and
Surveys, I believe we have put together a workable application that addresses many of
the common housing needs seen throughout the County that would help to revitalize our
communities. The communities in Buffalo County are very progressive and would



                                                                                           65
benefit greatly from the NSP Program funds. Thank you again for your consideration on
the Buffalo County NSP Program Application.

Comment 53

 I am so pleased to see that Nebraska has a plan for full utilization of the
NSP funding. You have expressed accurately the areas of greatest need and
have opportunities for the entire state to benefit from this most needed funding
appropriation.
In Western Nebraska, our issues of homelessness and blighted, substandard,
vacant buildings are still of foremost concern as I mentioned to you on the phone.
Our local banks and USDA offices were very conservative in their loans and have
not had the high exposure to foreclosures that many experienced in Eastern Ne.
This is a unique opportunity for collaboration between the Housing Authority, PADD,
TCD, realtors and communities to make a difference in their housing and economic
development communities. Please consider an allocation for Western Nebraska,
particularly Scotts Bluff County, but not forgetting the other Panhandle counties, where
vacant buildings can be demolished and new rental housing established or new
storefronts
with housing attached to create sustainable neighborhoods. I am pleased to see
many applications from persons who are assisting the homeless and hope that
your efforts will reflect a statewide effort to assist those who may find themselves
in the less than 50% and indeed, less than 30% of AMI.

Comment 54

I am the Chairperson for the Buffalo County Community Partners Housing Goal Work
Group as well as the coordinator for the Buffalo County Housing Senate. The Housing
Work Group goal was to raise funds and obtain a grant to complete the first ever county-
wide Housing Study. This goal was accomplished and the finished product was
presented to the public in June 2008.

One of the recommendations from the study was to create a Housing Senate comprised of
a member from each Buffalo County community. This group has been formed and has
been meeting monthly since June 2008. As a Senate group they felt the NSP program
was a wonderful opportunity to accomplish one of their goals, which was to remove
dilapidated structures from the communities in Buffalo County. They were very excited
at the opportunity and spent time researching the structures which needed to be included
in the pre-application.

As the work group leader I have been impressed by the commitment these volunteer
Housing Senate members have shown. They have attended meetings, obtained pertinent
data for the application and have served as a liaison to their respective communities to
help spread the word about the importance of safe, affordable housing in Buffalo
County. They are working toward a common goal and it is very rewarding to be a part
of.

                                                                                       66
With all of this said, I would urge DED to give the Buffalo County NSP application the
attention it deserves and consider investing funds in Buffalo County. There is a need;
capacity and readiness to proceed have been reflected in the partners at the table and the
persons working to make this a reality.

Thank you for your consideration and I am sure that if you invest in Buffalo County you
will not be disappointed with the outcome.

Comment 55

I have a comment regarding the funding distribution in the NSP plan. I suggest that any
leftover funds from the pool of money for the communities over 20,000 population (if
there is any) be added to the rest of the Nebraska area which was only allocated $3.6
million. This money for removal of dilapidated structures would be very important to the
rural Nebraska communities and would make a huge impact in their communities. For
example, Arthur County is one of the smallest counties in Nebraska and would utilize the
funds to demolish two dilapidated structures from their downtown area which would
make way for a much needed new senior/community center and fire station. Since the
community is so small they don’t have a large population to draw from to obtain
donations, however those facilities are vital to the community’s existence. It is stories
and examples like this that make the NSP program a great thing for rural Nebraska.

Comment 56

I am writing in support of the Buffalo County application to the Nebraska Stabilization
Program for funding to remove vacant and dilapidated homes and assist in rehabilitating
homes in Buffalo County. I am a member of the Buffalo County Community Coalition
Board and was in attendance when the findings of the 2008 Housing Survey were shared
with the constituents in Buffalo County. These are definitely needs that were identified
in the process that was sponsored by the Partners Housing Coalition.

Buffalo County is a hub for a lot of economic development activity and housing goes
hand in hand with those activities. For this reason, please consider our application for the
NAP program to put our best foot forward to attract new residents and improve on the
neighborhoods we already have. Buffalo County is very progressive and we would put
the NSP funds to good use. We are thorough and have the capacity to attain the
outcomes we develop for the program. We would appreciate your consideration of our
application.

Comment 57

I am the Chairman of the Buffalo County Board of Supervisors and am a member of the
Buffalo Housing Senate. I also sit on other boards and committees in the area dealing
with economic development. We, (members of these boards and committees) are always
looking for things that help promote our communities to make them more desirable to

                                                                                         67
both live in and work in. The NSP Grant is a great opportunity for our small
communities to do just that. It will be an immediate, tangible way for people of these
communities to see that things are getting done to further promote what we have to offer
those that might be looking to move into these communities. Your consideration of our
application would be greatly appreciated.

Comment 58

I received a copy of the proposed 2008 Housing and Community Development
Substantial Plan Amendment for the Neighborhood Stabilization Program this week from
the Community Development staff for the city of Grand Island. I am a Realtor in Grand
Island, and serve as a member of our Community Development Advisory Committee,
because I recognize the need to make improvements in the availability of affordable,
decent housing and adequate infrastructure for the residents of Grand Island.

Our community submitted a request for funding during the pre-application phase,
primarily as a result of the tremendous efforts of Joni Kuzma and Barb Quaundt. I
believe that one of the important criteria for any grant funding is the amount of
commitment and priority that a community shows in support of their proposed use.
Without such commitment up front, the chances for success for the project are weakened.
When a project is critical to successfully meeting the goals and objectives of a
community, they will put forth the effort necessary to make it happen. I believe that Joni
and Barb’s efforts showed that our community is committed to the success of our
proposal.

I would like you to consider giving priority to those communities and organizations that
met the requirements of a granting organization during the pre-application phase. Thank
you for your consideration of my request.

Comment 59

I have been a member of the Grand Island Community Development Advisory
Committee for more than 10 years and am familiar with the amount of time and effort
required to complete a grant application to carry out the activities of the grant. Based on
that experience, I am submitting a public comment to your Department regarding the
State Plan for the Neighborhood Stabilization Program.

I was pleased to hear that the Grand Island preapplication met the funding requirements
of the grant program and was in one of the qualifying levels of allocation for grant
funding. I believe that the extra effort invested by our Community Development staff
and staff from the other organizations that submitted preapplications merits priority
selection when the grant is awarded.

I understand that a full application will be required of each preapplicant and that grant
funds will be made available to all the other towns and agencies in Nebraska that did not
initially apply. Please consider awarding grant funds to the preapplicants as a type of

                                                                                         68
entitlement and not require them to compete with applicants who did not participate in
the first round.

Thank you for allowing me to provide this comment on behalf of the City and the
Neighborhood Stabilization Program.

Comment 60

Please accept the following comments from the City of Grand Island as input into the
2008 Housing and Community Development Substantial Plan Amendment for the
Neighborhood Stabilization Program.

The City submitted a pre-application to the Department, which is noted on page 12 of the
Plan in the Proposed DED CDBG NSP Allocation Table. We would suggest that it
would be consistent with HUD regulations and Public Law 110-289 to allow those
counties/communities identified in the table to move forward as set aside projects. Grant
approval could be contingent on submission of a full application in March that meets the
thresholds set by HUD and DED. It is our suggestion that all new applications submitted
in the open cycle be considered for funding with the moneys not already allocated to set
aside projects.

It was further noted that HUD set an allowable administration fee of 10% Housing and
Economic Recovery Act of 2008 and that the State has proposed a 4% administration fee
for grantees in this program. The City contends that the administrative fee be set between
8 to 10% due to a limited grant time frame, the complexity of projects to be completed,
and the high degree of oversight and management required to meet both HUD and DED
regulations.

We appreciate the opportunity to provide input into the 2008 Housing and Community
Development Substantial Amendment for the Neighborhood Stabilization Program.

Comment 61

I would appreciate it if you would consider the following comments and suggestions as
input into the 2008 Housing and Community Development Substantial Amendment for
the Neighborhood Stabilization Program.

The City of Grand Island Community Development Division submitted a pre-application
to the Department, which is noted on page 12 of the Plan in the Proposed DED CDBG
NSP Allocation Table. It appears that would be consistent with the HUD regulations and
Public Law 110-289 to allow those counties/communities identified in the table to move
forward as set aside projects. Grant approval could be contingent on submission of a full
application in March that meets the thresholds set by HUD and DED. I would suggest
that all new applications submitted in the open cycle be considered for funding with the
moneys not already allocated to set aside projects. The process, timeline and procedure



                                                                                         69
for completing the pre-application was understandably short but, those of us that
complied with the procedure should get consideration for our work.

The State has proposed a 4% administration fee for grantees in this program. HUD set an
allowable administration fee of 10% Housing and Economic Recovery Act of 2008.
Looking at the budget for my department and divisions; and the upcoming City budget
process, City participation in the future may be limited if we have to subsidize the
administrative costs associated with the programs. It is not possible to meet NEDED and
HUD guidelines without certified, paid professional staff.

Thank you for giving me the opportunity to provide input into the 2008 Housing and
Community Development Substantial Plan Amendment for the Neighborhood
Stabilization Program.

Comment 62

I write in support of the State of Nebraska’s 2008 Housing and Community Development
Substantial Plan Amendment grant submission for Neighborhood Stabilization Program
funds. The proposed program meets the needs of Nebraskans and Omahans within the
objectives of the Neighborhood Stabilization Program to acquire and redevelop
foreclosed properties that might otherwise become sources of abandonment and blight.

The elements of the substantial plan amendment for the City of Omaha will assist our
efforts to provide housing opportunities for lower income citizens, remove blighted
structures for redevelopment, turn vacant and foreclosed properties into safe and sanitary
housing, stimulate the housing market and rebuild property value. Overall, the
Neighborhood Stabilization Program and I am confident the plan will improve the quality
of life in our community. Thank you for including our proposed activities in your grant
submission. Please let me know how the City of Omaha can assist you in making the
Neighborhood Stabilization Program a success.

Comment 63

I am writing to ensure that you are aware of a new funding opportunity for our
community, and to make a recommendation for developing your plans for that
opportunity.

HUD’s new Neighborhood Stabilization Program (NSP) will provide emergency
assistance to state and local governments to acquire and redevelop foreclosed properties
that might otherwise become sources of abandonment and blight within their
communities.

NSP provides grants to every state and certain local communities to purchase foreclosed
and abandoned homes to rehabilitate, resell, or redevelop those homes in order to
stabilize neighborhoods and stem the decline of house values of neighboring homes. The



                                                                                       70
program is authorized under Title III of the recently passed Housing and Economic
Recovery Act.

Under the law, local authorities must submit their budget plans for acquisition of
foreclosed homes by December 1, 2008.

1. I am sure I join many who would ask that you submit plans for acquisition by the
December 1 deadline and bring our fair share of the funds to our community.

2. In addition, I request that you strongly encourage/recommend/require home
inspections for the houses that your office will acquire under the NSP program.

While a home inspection is always a good idea, it is especially important in cases of
abandonment and foreclosure. Such distressed properties often suffer from a lack of
maintenance and repair.

A home inspection may be indispensable to your efforts. Clearly, your office will need to
respond to taxpayers who wish to know the physical condition of the homes that will
come under your management with NSP funds.

Further, future homebuyers whom we hope will eventually purchase these homes will
need some reassurance that they will be buying – and your office will be selling – houses
that have been inspected for their technical condition. An independent, professional
home inspection is the best available means to meet this need.

Thank you for your kind attention to these issues. I would appreciate knowing your plans
to proceed. If I may be of help, I would be happy to answer questions about home
inspections or provide other resource information that may assist you in this regard.




                                                                                        71
  The following table is a summary of responses to comments.

Comment Number Response
1, 23, 39      The plan was revised based on the data for Scotts Bluff County and now
               includes projects in the Panhandle.

2, 46                  Foreclosure data utilized to develop the plan, which includes data provided by
                       HUD, does not support the conclusion that Nebraska Indian Reservations are
                       areas of greatest need. Thurston County, which includes the Winnebago and
                       Omaha Indian Reservations and is part of the Northern Ponca Tribe service
                       area, is a designated area for NSP. Knox County, which includes the Santee
                       Sioux Indian Reservation, is not a designated area for NSP because the Realty
                       Trac data source recorded no foreclosures and the HUD data demonstrated a
                       foreclosure rate less than 5% and less than 30 total foreclosures. The Northern
                       Ponca Tribe serves many of the counties that were determined to be areas of
                       greatest need.
44                     The State of Nebraska NSP plan was made available for public comment and
                       the required public comment process was followed to which you have
                       responded with this comment. We are unable to determine the paragraph and
                       related information to which you are referring regarding Native Americans in
                       the Nebraska NSP plan. Foreclosure data utilized to develop the plan, which
                       includes data provided by HUD, does not support the conclusion that Nebraska
                       Indian Reservations are areas of greatest need. Thurston County, which
                       includes the Winnebago and Omaha Indian Reservations and is part of the
                       Northern Ponca Tribe service area, is a designated area for NSP. Knox County,
                       which includes the Santee Sioux Indian Reservation is not a designated area for
                       NSP because the Realty Trac data source recorded no foreclosures and the
                       HUD data demonstrated a foreclosure rate less than 5% and less than 30 total
                       foreclosures. The Northern Ponca Tribe serves many of the counties that were
                       determined to be areas of greatest need.
3, 4,5, 7, 10, 11, 14, The Nebraska CDBG NSP plan has been revised and Habitat for Humanity
15, 16, 17, 18, 19,    Omaha is identified as a project partner with the City of Omaha to serve
20, 21, 24, 26, 27,    households that are very low-income to meet their housing needs. Habitat for
28, 29, 31, 32, 38,    Humanity Omaha is encouraged to work with the City of Omaha in
49                     development of the City's set-aside for CDBG NSP.
6, 8                   The Nebraska CDBG NSP plan includes many projects identifying the local
                       Habitat for Humanity as a potential project partner.
9, 13, 25, 58, 59, 60 The scoring for full applications was revised and now includes an advantage for
                       projects that were submitted as part of a pre-application during the October-
                       November 2008 DED CDBG NSP pre-application round. This was determined
                       to be one measure, among others, of readiness to proceed.
12                     The Nebraska CDBG NSP funds must be expended in an expeditious manner;
                       therefore, funds can not be distributed based on anticipated needs. The
                       program; however, does allow for programs that will be available for up to two
                       years within a community and could be responsive to some future need.


                                                                                         72
Comment Number Response
22, 62              Thank you for supporting the State of Nebraska Department of Economic
                    Development's plan for use of the CDBG NSP funds.
30                  The federal program parameters for CDBG NSP do not allow for an
                    acquisition/demolition of blighted structure activity. In addition, the data used
                    to develop the plan does not identify Sherman County as an "area of greatest
                    need" based on foreclosure rates and subprime mortgage rates. The
                    communities in your area may very well have a great need for resources,
                    however, unfortunately the requirements for CDBG NSP distribution do not
                    allow for use of these funds in your area.
33, 34, 35, 36, 37, Buffalo County is identified as an "area of greatest need" county in the CDBG
40, 43, 45, 52, 54, NSP plan. We encourage you work with an eligible applicant to submit the
56, 57              project you are supportive of for funding addressing the full application scoring
                    criteria.
41                  Buffalo County and Dawson County are identified as "area of greatest need"
                    counties in the CDBG NSP plan. We encourage you work with an eligible
                    applicant to submit the project you are supportive of for funding addressing the
                    full application scoring criteria.
42, 47, 48, 50, 51, The plan was revised based on the data for Scotts Bluff County and now
53                  includes projects in the Panhandle. We encourage you to work with an eligible
                    applicant to submit the project that you support for funding addressing the full
                    application scoring criteria.
55                  The Distribution and Uses of funds section of the plan has been revised. There
                    are no funds reflected in the plan that are not targeted toward an "area of
                    greatest need" that would be available for general distribution. All available
                    funds, excluding $5 million set-aside to meet the 25% to serve very low-income
                    households with housing, will be available through the application cycle
                    outlined in the plan which could include the types of projects that you are
                    referencing in your comment.
61                  The administration fee for grantees is capped at 4% to ensure that the total
                    administration fee for the state and grantees of 10% can be met. Additional
                    funds may be provided for project delivery costs.
63                  Rehabilitated homes in the Nebraska CDBG NSP will be required to meet the
                    Rehabilitation standards outlined in the plan. This process includes a proper
                    review and clearance inspection that the home meets these standards. In
                    addition, newly constructed homes will be required to meet codes and the 2003
                    International Energy Conservation Code. The use of an additional home
                    inspection is not required, but an eligible cost of the program. 




                                                                                        73
G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

THE STATUS OF PROJECTS LISTED IS DETAILED IN SECTION B DISTRIBUTION AND USES OF
FUNDS

DED provided a pre-application form for potential Nebraska projects and held a DED
CDBG NSP briefing to present the strategy and pre-application form. The pre-
application form was available October 17, 2008 due November 3, 2008. This pre-
application was substantially equivalent to the NSP application and checklist required for
the DED substantial plan amendment to receive the State allocation of CDBG NSP.
DED informed communities that the pre-application was needed to have a potential
project included in the DED grant submission.

A comprehensive spreadsheet with a listing of all pre-applications submitted and details
is available for reference on the DED NSP web page.
Pre-applicant           Activity                                   NSP         Area
                                                                   Amount      Level of
                                                                               Need
Omaha                   Acquisition, rehabilitation, and resale of $3,000,000 1
                        foreclosed and abandoned properties.
                        Serving very low-income families
Bellevue                Demolish 8 blighted structures             $1,182,000 1
                        preparing lots for industrial park
                        redevelopment
Omaha                   Redevelopment of vacant property to        $1,250,000 1
                        housing. Open Door Mission
                        Permanent Supportive Housing for
                        homeless men.
Omaha                   Redevelop vacant property to provide       $325,968    1*
                                                               th
                        housing for low-income seniors at 18
                        and Locust Streets
Omaha (to Habitat       Purchase, rehabilitate and resell          $1,000,000 1
for Humanity            foreclosed properties to very low-
Omaha)                  income families.
Lincoln                 Acquisition, rehabilitation, and resale of $1,000,000 2
                        foreclosed and abandoned homes to
                        provide homeownership housing for
                        very low-income homebuyers
Lincoln                 Acquire foreclosed and vacant homes        $2,000,000 2
                        which were split into apartments,
                        rehabilitate/deconvert/reconstruct for
                        homeownership housing in the Everett
                        and Near South neighborhoods




                                                                                        74
Pre-applicant     Activity                                    NSP          Area
                                                              Amount       Level of
                                                                           Need
Lincoln           NeighborWorks Lincoln will acquire,         $1,000,000   2
                  rehabilitate and resell abandoned,
                  foreclosed, and vacant homes for
                  homebuyers in the Malone
                  neighborhood
Housing           Acquire, rehabilitate, resell foreclosed,   $1,032,000   3
Development       abandoned and vacant homes. Counties
Corporation       of Adams, Clay, Nuckolls, and at least
                  50% of the funds will be used in Hall
                  county.
Grand Island      Acquire foreclosed homes, demolish          $967,032     3
                  blighted structures, redevelop
                  demolished and vacant property and
                  partner with Habitat for Humanity and
                  the North Central Continuum of Care
                  for future development
Union             Demolish blighted structures to             $500,000     3
                  redevelop for community center and
                  emergency shelter
Plattsmouth       Demolish blighted residential structures    $175,000     3
Indianola         Demolish a blighted structure in the        $182,000     4
                  downtown and redevelop for a tornado
                  shelter
West Central      Demolish blighted structures in the         $500,000     4
Nebraska          counties of Keith, Dawson, Perkins,
Development       Chase, and at least 50% of the funds to
District          be used in Red Willow county.
Gering            Demolish blighted structure, vacant         $705,000     4
                  McKinley School. Demolish vacant
                  HHS building. Demolish 10 houses.
                  Redevelop for housing
McCook            Demolish 5 blighted structures              $182,000     4
Panhandle Area    Demolish 20 dilapidated structures on       $130,000     4
Development       developable lots in communities that
District          enforce nuisance ordinances or building
                  codes. Counties of Cheyenne, Dawes,
                  Kimball, and at least 50% of the funds
                  will be used in Scotts Bluff county.
McCook Economic   Redevelop demolished and vacant             $801,000     4
Development       structures for housing including vacant
Corporation       downtown second story units, St.
                  Catherine’s apartments and demolition
                  of a blighted commercial building.

                                                                                  75
Pre-applicant         Activity                                    NSP           Area
                                                                  Amount        Level of
                                                                                Need
Northeast Nebraska     Demolish blighted structure on lots that   $400,000      5
Economic               can feasibly be redeveloped and in
Development            communities enforcing local building
District               codes and nuisance ordinances.
                       Counties of Antelope, Colfax, Cuming,
                       Dixon, Dodge, Madison, Pierce, Platte,
                       Stanton, and Thurston.
Dawson Area            Demolish blighted structures in Dawson     $200,000      5
Development            county.
Wilcox                 Demolish a blighted structure in the       $500,000      5
                       downtown and redevelop the property
                       for a community center.
Central City           Acquisition and demolition of structures   $450,000      5
                       to redevelop into housing. Demolish
                       abandoned school building
NeighborWorks          Purchase, rehabilitate, and resell 5       $395,200      5
Northeast Nebraska foreclosed or abandoned homes.
                       Counties of Colfax, Cuming, Madison,
                       Pierce, Platte, and Stanton.
Fremont                Acquire, demolish and deed properties      $154,800      5
                       to Habitat for Humanity to redevelop for
                       homebuyers
*funds redistributed from Area Level of Need 3
Projects for demolition of blighted structures only – total does not exceed 30% of funds
allocated to subrecipients ($5,409,600).
Pre-applicant           Activity                                   NSP         Area
                                                                   Amount      Level of
                                                                               Need
Bellevue                Demolish 8 blighted structures             $1,182,000 1
                        preparing lots for industrial park
                        redevelopment
Plattsmouth             Demolish blighted residential              $175,000    3
                        structures
West Central            Demolish blighted structures in the        $500,000    4
Nebraska                counties of Keith, Dawson, Perkins,
Development             Chase, and at least 50% of the funds to
District                be used in Red Willow county
McCook                  Demolish 5 blighted structures             $182,000    4
Panhandle Area          Demolish 20 dilapidated structures on $130,000         4
Development             developable lots in communities that
District                enforce nuisance ordinances or
                        building codes. Counties of Cheyenne,

                                                                                       76
Pre-applicant        Activity                               NSP           Area
                                                            Amount        Level of
                                                                          Need
                     Dawes, Kimball, and at least 50% of
                     the funds will be used in Scotts Bluff
                     county.
Northeast Nebraska   Demolish blighted structure on lots     $400,000     5
Economic             that can feasibly be redeveloped and in
Development          communities enforcing local building
District             codes and nuisance ordinances.
                     Counties of Antelope, Colfax, Cuming,
                     Dixon, Dodge, Madison, Pierce, Platte,
                     Stanton, and Thurston.
Dawson Area          Demolish blighted structures in         $200,000     5
Development          Dawson county.
Total                15% of funds allocated to projects      $2,769,000




                                                                                     77
PROJECT 1 – City of Omaha - Acquisition, rehabilitation and resale of foreclosed and
abandoned properties and redevelopment of vacant property for housing serving very
low-income families.

(1) Activity Name: Single Family CROWN Rent-to-Own Program

(2) Activity Type:     (include NSP eligible use & CDBG eligible activity)

NSP eligible uses
  • §2301(c) Administration and Planning Costs (see activity 26)
  • §2301(c)(3)(B) purchase and rehabilitate homes and residential properties that
       have been abandoned or foreclosed upon, in order to sell, rent, or redevelop such
       homes and properties;

CDBG eligible uses
  • Administration and planning costs (see activity 26)
  • 24 CFR 570.201
         (a) Acquisition
         (b) Disposition
  • 24 CFR 570.202 Eligible rehabilitation and preservation activities for homes and
     other residential properties.
  • New housing construction

(3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).

LMMH - Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
Units

LMMH - All Units must be occupied by those meeting the very low-income requirement.

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 1 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is housing.


                                                                                            78
3. The project will be used to meet the low-income housing requirement for those
   below 50% of area median income.

The Single-Family CROWN Rent-to-Own Program addresses several important needs of
the NSP grant. First, the geographical focus of the program is in an area already
established to have a need for stabilization, the North NRSA. The Single-Family
CROWN Rent-to-Own Program will acquire abandoned/foreclosed upon properties and
return them to the occupied housing stock. Not acting on abandoned/foreclosed upon
property through the Single-Family CROWN Rent-to-Own Program not only puts these
units at great risk further deterioration but threatens the area around each house. The units
would be rented exclusively to low-income households, households at or below 50% the
Area Median Income (AMI).

The program is also designed to provide decent affordable housing to qualified renters
interested in homeownership. The rent-to-own feature of the program requires that
households participating make progress towards homeownership by: 1) Taking
homeownership training/counseling services, and 2) Setting aside a portion from each
monthly rent payment to be used for the downpayment and related cost when the
household eventually buys a home.

The City of Omaha will use the approach to maintaining housing affordable with the
Single-Family CROWN Rent-to-Own Program it uses with the HOME Investment
Partnerships Program (HOME). One significant difference is the level of affordability.
Unlike the HOME program, the household income level for participation in the Single-
Family CROWN Rent-to-Own Program will be at or below 50% AMI. This legally-
binding requirement will be incorporated into an agreement with the developer and will
be monitored by the City of Omaha during the 20-year affordability period.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

The Single-Family CROWN Rent-to-Own Program will take place primarily in the North
NRSA. The North NRSA is in a part of Omaha determined to be one of the most
economically distressed areas of the city. The North NRSA not only defines the area of
greatest need, but approval of the area as an NRSA by HUD offers enhanced flexibility
for the use of CDBG funds in a manner that promotes innovative programs. This
additional flexibility in using annual/regular CDBG funds with the Single-Family
CROWN Rent-to-Own Program and other Neighborhood Stabilization Program (NSP)
activities will enhance the impact of all efforts to stabilize and revitalize the North
NRSA.

As previously described, the North NRSA is the targeted area for the Single-Family
CROWN Rent-to-Own Program; however, any Census Block Group qualifying as a Low
Moderate and Middle Income (LMMI) area could receive Single-Family CROWN Rent-
to-Own Program funding. Still, only households meeting NSP income limits of at or
below 50% of AMI would qualify.

                                                                                          79
                      Targeted Census Block Groups 

                                   Block                     Block
                      Tract        Group        Tract        Group
                      3            1, 2, 3      42           1, 2
                      4            1, 2         51           1, 2, 3
                      5            1            52           1, 2
                      6            1, 2         53           1, 2, 3
                      7            1            54           1, 2, 3, 4
                      8            1, 3         58           2, 3
                      11           1, 2, 3      59.01        1, 2, 3
                      12           1, 2, 3      59.02        1, 2
                      19           1, 2         60           1, 2, 3, 4, 5
                      39           1, 2         61.02        5
                      40           1, 2, 3


(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

50 foreclosed, abandoned, or vacant properties will be acquired and rehabilitated.

50 households with incomes at or below 50% of the Area Median Income will benefit
from the rent-to-own housing.

(7) Total Budget: (Include public and private components)



Single­Family CROWN Rent­to­Own Program Budget 

                         NSP          50 %       Low/Mod        Other         Private     Total Project
                        Budget        Low-        Income        Public        Funds           Cost
                                    Income        Benefit       Funds
                                    Benefit
Project Cost          $3,000,000   $3,000,000   $3,000,000     $100,000      $3,186,268     $6,286,268

Total                 $3,000,000   $3,000,000   $3,000,000     $100,000      $3,186,268     $6,286,268




                                                                                                 80
(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

The City of Omaha Planning Department Housing and Community Development
Division serves as the responsible organization for the development and administration of
the Single-family CROWN Rent-to-Own Program. The Omaha Planning Department is
located at:

1819 Farnam Street, Suite 1111,
Omaha NE 68183.

The administrator of the Single-family CROWN Rent-to-Own Program is:

James R. Thele, Assistant Planning Director
(402) 444-5206
jthele@ci.omaha.ne.us

(9) Projected Start Date: September 1, 2009

(10) Projected End Date: August 31, 2012

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased will have a purchase discount of 15% or greater than the Current
Market Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

NSP financing provided will be at a 0% interest rate

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

Duration or term of assistance: 20 years conditional grant.

Tenure of beneficiaries: tenants to eventually become homeowners

Description of how the design of the activity will ensure continued affordability:

Upon sale to a homebuyer, at the end of the initial 20-year rental affordability period, the

                                                                                          81
City of Omaha will use its resale/recapture provisions for the HOME Program for
homebuyers receiving NSP assistance, if any.

If the City does not select the resale option for projects within the Area of Presumed
Affordability before NSP assistance is provided to the initial homebuyer, the Recapture
Requirements described above shall be used. This resale provision applies only to the
affordability requirements of the project and does not nullify any terms of the
mortgage/deed of trust securing the NSP-funded assistance.

The project will meet the affordability requirements detailed in Section C (3) of this plan.




                                                                                         82
PROJECT 2 – City of Bellevue - Demolition of blighted structures to prepare site to be
“shovel-ready” for business development and job creation.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Coreslab Demolition and Redevelopment

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses:
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;

CDBG Eligible Activity:
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201 (d) Clearance, for blighted structures only

(3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).
    • Demolition

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 1 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is removal of a blighted structure
   (demolition).

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

The area of greatest need addressed by this project is the former Coreslab industrial
property located on the northwest corner of Fort Crook Road and Cornhusker Road and
the surrounding residential neighborhoods north and west of the property. The expected
benefit to income qualified persons in the area will be removal of a series of blighted
structures and redevelopment leading to job creation activities benefiting LMMI persons.
Due to the presence of active rail service on the property, residential redevelopment

                                                                                            83
using HUD funds would be challenging given considerations for noise and current land
use at the site. However, the property is ideal for mixed commercial/industrial use, or
could have benefits serving a public use for the area, and clearance of the blighted
buildings is a critical first step in redevelopment.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

The project location is in Bellevue Nebraska at the location known as the Coreslab
property and is located on the northwest corner of the intersection of Fort Crook Road
and Cornhusker Road.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

8 blighted structures will be demolished.

(7) Total Budget: (Include public and private components)

Note :These are Cost Estimates
Activity                         Cost         NSP Amount              Local Share
Demolition & Clearance           $1,400,000   $1,182,000              $218,000 (TIF)
Construction Mgmt                  $100,000   $0                      $100,000 (City)
Totals                           $1,500,000   $1,182,000              $318,000

The cost estimates above represent gross costs associated with clearance of the site to the
point where it is “shovel ready” for redevelopment.

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

The project will be implemented by the City of Bellevue and led by the Public Works
Director. The administrator for the project will be Jake Hansen of MAPA. 402-444-6866
x226 jhansen@mapacog.org

(9) Projected Start Date: August 1, 2009

(10) Projected End Date: February 1, 2010

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

This project does not include NSP acquisition activities.


                                                                                         84
For financing activities, include:
   • range of interest rates

This project does not include NSP financing activities.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

This project is not a housing related activity.




                                                                                      85
PROJECT 3 – City of Omaha - Redevelopment of vacant property to housing. Open
Door Mission Permanent Supportive Housing for homeless men.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Open Door Mission Permanent Supportive Housing Redevelopment
Project

(2) Activity Type:    (include NSP eligible use & CDBG eligible activity)

NSP eligible uses

   •   §2301(c) Administration and Planning Costs (see project 26)
   •   §2301(c)(3)(A) establish financing mechanisms for purchase and redevelopment
       of foreclosed upon homes and residential properties, including such mechanisms
       as soft-seconds, loan loss reserves, and shared-equity loans for low- and
       moderate- income homebuyers
   •   §2301(c)(3)(E) redevelop demolished or vacant properties

CDBG eligible uses
  • Administration and planning costs (see project 26)
  • As part of an activity delivery cost for an eligible activity as defined in 24 CFR
     570.206.
  • Financing mechanisms used to carry out CDBG eligible activities listed below.
  • 24 CFR 570.201
             (a) Acquisition
             (b) Disposition
              (e) Public services for housing counseling, but only to the extent that
             counseling beneficiaries are limited to prospective purchasers or tenants of
             the redeveloped properties
  • New housing construction

(3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).

LMMH - Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
Units

LMMH - All Units must be occupied by people with incomes at or below 120% AMI.

(4) Activity Description:


                                                                                      86
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 1 referenced in Section A of this
   plan.
2. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

The Open Door Mission Permanent Supportive Housing Redevelopment Project
addresses several important needs of the NSP grant. The Open Door Mission Permanent
Supportive Housing Redevelopment Project will construct 41 units of rental housing for
homeless people on a site that is abandoned, foreclosed upon, or has had a recently
demolished structure on it.. Providing permanent supportive housing for homeless people
provides stable housing circumstances. Not providing it may prevent homeless people
from achieving stable housing circumstance for themselves and stable households make
for stable neighborhoods. The 41 units will be rented exclusively to low-income
households, households at or below 50% the Area Median Income (AMI).

The City of Omaha will use the approach to maintaining housing affordable with the
Open Door Mission Permanent Supportive Housing Redevelopment Project it uses with
the HOME Investment Partnerships Program (HOME). One significant difference is the
level of affordability. Unlike the HOME program, the household income level for
participation in the Open Door Mission Permanent Supportive Housing Redevelopment
Project will be at or below 120% AMI. This legally-binding requirement will be
incorporated into an agreement with the developer and will be monitored by the City of
Omaha during the 20-year affordability period.

The project includes the use of Low-Income Housing Tax credits, with rental limited to
households at or below 60% LMI, having an initial 15-year affordability period followed
by another 15-year period.

Financing includes LIHTC equity, FHLB-AHP funds, City HOME funds, tax increment
financing, private contributions and NSP funds and private debt financing. No private
debt financing is used. NSP funds will be at no interest.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

The Open Door Mission Permanent Supportive Housing Redevelopment Project will take
place at the southeast corner of Locust Street and 23rd Street East. The Open Door
Mission considers the location of this project, near its existing facilities, critical to the
overall effectiveness of this project and to its existing programs/facilities. The project is
also just three blocks from the North NRSA. The North NRSA is in a part of Omaha
determined to be one of the most economically distressed areas of the city. The North

                                                                                            87
NRSA not only defines the area of greatest need, but approval of the area as an NRSA by
HUD offers enhanced flexibility for the use of CDBG funds in a manner that promotes
innovative programs. These factors are obvious advantages for the Open Door Mission
Permanent Supportive Housing Redevelopment Project.

As previously described, the North NRSA is near the Open Door Mission Permanent
Supportive Housing Redevelopment Project. Only households meeting NSP income
limits would qualify.



                      Targeted Census Block Groups 

                                 Block                  Block
                      Tract      Group      Tract       Group
                      3          1, 2, 3    42          1, 2
                      4          1, 2       51          1, 2, 3
                      5          1          52          1, 2
                      6          1, 2       53          1, 2, 3
                      7          1          54          1, 2, 3, 4
                      8          1, 3       58          2, 3
                      11         1, 2, 3    59.01       1, 2, 3
                      12         1, 2, 3    59.02       1, 2
                      19         1, 2       60          1, 2, 3, 4, 5
                      39         1, 2       61.02       5
                      40         1, 2, 3


(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

41 households with incomes at or below 50% of the Area Median Income will benefit
from the permanent supportive housing.

(7) Total Budget: (Include public and private components)




                                                                                     88
 

Open Door Mission Permanent Supportive Housing Redevelopment 
Project Budget 

                         NSP          50 %      Low/Mod      Other       Private        Total
                        Budget        Low-       Income      Public      Funds         Project
                                     Income      Benefit     Funds                      Cost
                                     Benefit
Project Cost          $1,250,000           $0   $1,250,000   $663,000   $8,545,000   $10,458,000

Total                 $1,250,000          $0    $1,250,000   $663,000   $8,545,000   $10,458,000

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

The City of Omaha Planning Department Housing and Community Development
Division serves as the responsible organization for the development and administration of
the Single-family CROWN Rent-to-Own Program. The Omaha Planning Department is
located at:

1819 Farnam Street, Suite 1111,
Omaha NE 68183.

The administrator of the Single-family CROWN Rent-to-Own Program is:

James R. Thele, Assistant Planning Director
(402) 444-5206
jthele@ci.omaha.ne.us

(9) Projected Start Date: September 1, 2009

(10) Projected End Date: August 31, 2012

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased with a purchase discount of 15% or greater than the Current Market
Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

NSP financing provided will be at a 0% interest rate

                                                                                             89
For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

duration or term of assistance: conditional grant for 20 years.

Tenure of beneficiaries: tenants

Description of how the design of the activity will ensure continued affordability period:
See Section C (3) of this plan for the description of how DED will ensure the continued
affordability period for a new construction rental property.

The project will meet the affordability requirements detailed in Section C (3) of this plan.




                                                                                         90
PROJECT 4 – City of Omaha - Redevelop vacant property to provide housing for very
low-income seniors at 18th & Locust Streets

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: New construction of senior housing rental units

(2) Activity Type:     (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses:

   •   §2301(c) Administration and Planning Costs (see project 26)
   •   §2301(c)(3)(A) establish financing mechanisms for purchase and redevelopment
       of foreclosed upon homes and residential properties, including such mechanisms
       as soft-seconds, loan loss reserves, and shared-equity loans for low- and
       moderate- income homebuyers;
   •   §2301(c)(3)(E) redevelop demolished or vacant properties

CDBG Eligible Activities:
  • Administration and planning costs (see project 26)
  • As part of an activity delivery cost for an eligible activity as defined in 24 CFR
     570.206.
  • Financing mechanisms used to carry out CDBG eligible activities listed below.
  • 24 CFR 570.201
              (b) Disposition
              (e) Public services for housing counseling, but only to the extent that
             counseling beneficiaries are limited to prospective purchasers or tenants of
             the redeveloped properties
  • New housing construction


(3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).

LMMH - Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
Units

LMMH - All Units must be occupied by those meeting very low-income requirement.

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity

                                                                                            91
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 1 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is housing.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

The proposed project will be a twenty-eight (28) unit affordable rental housing project for
seniors 55+. The proposed site is a comprised of approximately 3 acres located between
Locust and Corby Streets and 18th and 19th streets in Omaha, Nebraska. The project will
consist of seven 4-plexes, for a total of 28 units. Twenty-four of the total units will be 2-
bedroom units, while the remaining 4 units will be 3 bedrooms. The units will be rented
to households with an income up to 50% of the Area Median Income. The proposed
rents will not exceed the fair market rents for a 2 bedroom and 3 bedroom units that are in
effect at the time of lease agreement. The project will be 100% visitable and adaptable
and would include at least one handicap accessible unit. The project includes the use of
Low-Income Housing Tax credits, with rental limited to households at or below 50%
LMI, having an initial 15 year affordability period followed by another 15 year period.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

The new construction senior rental housing units will be built in the North NRSA. The
North NRSA is in a part of Omaha determined to be one of the most economically
distressed areas of the city. The North NRSA not only defines the area of greatest need,
but approval of the area as an NRSA by HUD offers enhanced flexibility for the use of
CDBG funds in a manner that promotes innovative programs. This additional flexibility
in using annual/regular CDBG funds with the senior rental housing units and other
Neighborhood Stabilization Program (NSP) activities will enhance the impact of all
efforts to stabilize and revitalize the North NRSA.

Only households meeting NSP income limits of at or below 50% of AMI would qualify
for these units.




                                                                                          92
                      Targeted Census Block Groups 

                                  Block                     Block
                      Tract       Group        Tract        Group
                      3           1, 2, 3      42           1, 2
                      4           1, 2         51           1, 2, 3
                      5           1            52           1, 2
                      6           1, 2         53           1, 2, 3
                      7           1            54           1, 2, 3, 4
                      8           1, 3         58           2, 3
                      11          1, 2, 3      59.01        1, 2, 3
                      12          1, 2, 3      59.02        1, 2
                      19          1, 2         60           1, 2, 3, 4, 5
                      39          1, 2         61.02        5
                      40          1, 2, 3

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

28 seniors with incomes at or below 50% of the Area Median Income will benefit from
the newly constructed rental housing.

(7) Total Budget: (Include public and private components)



                 New Construction Senior Housing Rental Units Budget 

                    NSP         50 %      Low/Mod       Private       Total
                   Budget       Low-       Income       Funds        Project
                               Income      Benefit                    Costs
                               Benefit
                  $325,968     $325,968     $325,968   $3,992,003   $4,317,971

Total             $325,968     $325,968     $325,968   $3,992,003   $4,317,971

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

Project Administrator
James R. Thele, Assistant Planning Director
(402) 444-5206

                                                                                      93
jthele@ci.omaha.ne.us

The City of Omaha Planning Department Housing and Community Development
Division serves as the responsible organization for the development of the new
construction senior rental housing units. The Omaha Planning Department is located at:

1819 Farnam Street, Suite 1111,
Omaha NE 68183.
(9) Projected Start Date: September 1, 2009

(10) Projected End Date: August 31, 2012

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased with a purchase discount of 15% or greater than the Current Market
Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

NSP financing provided will be at a 0% interest rate.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

Duration or term of assistance – NSP will be provided as a conditional grant with a 20
year affordability period

Tenure of beneficiaries – rental

Description of how the design of the activity will ensure continued affordability – the
project will be subject to the affordability requirements for newly constructed rental
housing detailed in Section C (3) of this plan.

The project will meet the affordability requirements detailed in Section C (3) of this plan.




                                                                                          94
PROJECT 5 – City of Omaha- Omaha Habitat for Humanity – Purchase, rehabilitate,
and resell abandoned and foreclosed homes that are financed by Habitat for Humanity.

(1) Activity Name: Redevelopment of foreclosed homes for Habitat for Humanity
assisted homebuyers.

(2) Activity Type:    (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(A) establish financing mechanisms for purchase and redevelopment
      of foreclosed upon homes and residential properties, including such mechanisms
      as soft-seconds, loan loss reserves, and shared-equity loans for low- and
      moderate- income homebuyers
  • §2301(c)(3)(B) purchase and rehabilitate homes and residential properties that
      have been abandoned or foreclosed upon, in order to sell, rent, or redevelop such
      homes and properties

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • As part of an activity delivery cost for an eligible activity as defined in 24 CFR
     570.206.
  • Financing mechanisms used to carry out CDBG eligible activities listed below.
  • 24 CFR 570.201
         (a) Acquisition
         (b) Disposition
         (i) Relocation
         (n) Direct homeownership assistance to persons whose incomes do not
         exceed 120% of median income.

   •   24 CFR 570.202 Eligible rehabilitation and preservation activities for homes and
       other residential properties. Note that rehabilitation may include counseling for
       those seeking to take part in the activity

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
   • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
   • Homeownership Assistance
   • Infrastructure for housing as part of redevelopment
   • All Units must be occupied by those meeting the very low-income requirement.


                                                                                         95
(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 1 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is housing.

3. The project will be used to meet the low-income housing requirement for those
   below 50% of area median income.

The Purchase and Rehabilitation of Foreclosed Properties program will renovate 40
homes and will address the area of the greatest need in Omaha – focusing on zip codes
68110, 68111, 68104, 68105, and 68107. These areas have been most affected by
foreclosures. In addition:
    • Beneficiaries will be homeowners at 30-50% of median income
    • Financing will be provided so the duration of service is 30 years or more
    • Affordability will be ensured through requirements in the warranty deed and
       mortgage documents – Habitat will follow guidelines set forth by the NE-DED

For acquisition activities (not limited to housing):
   • All home acquisition discounts will be greater than 15% of appraised value

For financing activities (not limited to housing):
   • Interest rates will all be at 0% interest financing

This activity will be used to meet the low income housing requirement for those below
50% below area median income.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

Primarily in the areas of North & South Omaha – zip codes 68110, 68111, 68104, 68105,
68107

Other areas of Omaha may be included.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

20 foreclosed and abandoned homes will be acquired and rehabilitated.


                                                                                            96
20 households with incomes at or below 50% of the Area Median Income will benefit
from the housing.

(7) Total Budget: (Include public and private components)

 Funding for 200 Houses
         NSP                                    1,000,000
         Private Funding                        1,000,000
 Total Project Funding                          2,000,000

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

Project Administrator
James R. Thele, Assistant Planning Director
(402) 444-5206
jthele@ci.omaha.ne.us

The City of Omaha Planning Department Housing and Community Development
Division serves as the responsible organization for the development of the new
construction senior rental housing units. The Omaha Planning Department is located at:

1819 Farnam Street, Suite 1111,
Omaha NE 68183.


(9) Projected Start Date: September 2009

(10) Projected End Date: October 2012

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased with a purchase discount of 15% or greater than the Current Market
Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

NSP financing provided will be at a 0% interest rate.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;


                                                                                      97
   •   a description of how the design of the activity will ensure continued affordability

Duration or term of assistance – NSP will be provided as a conditional grant with an
affordability period consistent with the affordability period requirements.

Tenure of beneficiaries – homeownership

Description of how the design of the activity will ensure continued affordability – the
project will be subject to the affordability requirements for homebuyer housing detailed
in Section C (3) of this plan.




                                                                                        98
PROJECT 6– City of Lincoln - Acquisition, rehabilitation, and resale of foreclosed and
abandoned homes to provide homeownership housing for very low-income homebuyers.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Purchase, rehabilitation(or demo/build new), resale.

(2) Activity Type:    (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses:
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(A) establish financing mechanisms for purchase and redevelopment
      of foreclosed upon homes and residential properties, including such mechanisms
      as soft-seconds, loan loss reserves, and shared-equity loans for low- and
      moderate- income homebuyers;
  • §2301(c)(3)(B) purchase and rehabilitate homes and residential properties that
      have been abandoned or foreclosed upon, in order to sell, rent, or redevelop such
      homes and properties;
  • §2301(c)(3)(D) demolish blighted structures;
  • §2301(c)(3)(E) redevelop demolished or vacant properties

CDBG Eligible Activities:
  • Administration and planning costs (see project 26)
  • As part of an activity delivery cost for an eligible activity as defined in 24 CFR
     570.206.
  • Financing mechanisms used to carry out CDBG eligible activities listed below.
  • 24 CFR 570.201
         (a) Acquisition
         (b) Disposition
         (d) Clearance, for blighted structures only
         (e) Public services for housing counseling, but only to the extent that
         counseling beneficiaries are limited to prospective purchasers or tenants of the
         redeveloped properties
         (i) Relocation
         (n) Direct homeownership assistance to persons whose incomes do not
         exceed 120% of median income.
  • 24 CFR 570.202 Eligible rehabilitation and preservation activities for homes and
     other residential properties.
  • 24 CFR 570.204 Community based development organizations
  • New housing construction




                                                                                      99
(3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).
Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
    • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
    • Homeownership Assistance
    • All Units must be occupied by those meeting the low- and moderate-income
       requirement.

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of need level 2 referenced in Section A of this plan.

2. The project benefit to income-qualified persons is housing.

3. The project will be used to meet the low-income housing requirement for those
   below 50% of area median income.

The project will address the preservation of home ownership in neighborhoods with low
ownership rates while still keeping the houses affordable to lower income buyers. The
benefit to income-qualified persons will be a first mortgage payment within their housing
cost ratios. All funds will be used to benefit those below 50% of AMI.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

City of Lincoln

Priority will be given to the Neighborhood Revitalization Strategy Areas (NRSA) to
preserve home ownership but balanced by some economic integration in the non-LMI
areas.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

2 blighted structures will be demolished

7 houses will be acquired and rehabilitated


                                                                                        100
9 households with incomes at or below 50% of the Area Median Income will benefit
from the homeownership opportunities provided.


(7) Total Budget: (Include public and private components)

$1,000,000 of NSP funds for the acquisition, rehabilitation and resale to 50% AMI
buyers.
This should result in nine first mortgages carried by a private lender or Habitat. Each
mortgage in order to be affordable to a 50% AMI owner will need to be in the range of
$50,000 to $70,000 in private mortgage funds.
This will leave in each project $30,000 to $40,000 in NSP 0% deferred payment second
mortgage.
We also need to anticipate that after rehabilitation the appraised value may be less than
what we have in the project but with that being said;
The project should result in $540,000 of private mortgage money and $225,000 of NSP
funds left in the project.

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

City of Lincoln, Urban Development, 808 P Street, Suite 400, Lincoln, NE. 68508, Steve
Werthmann 441-8621, swerthmann@lincoln.ne.gov

(9) Projected Start Date: August 1, 2009

(10) Projected End Date: August 1, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

   Properties purchased will have a purchase discount of 15% or greater than the Current
   Market Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

The soft seconds will carry a 0% deferred payment. The first mortgage will be market
rate fixed through a private lender except for Habitat which carries a below market rate
first mortgage.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;

                                                                                       101
   •   a description of how the design of the activity will ensure continued affordability

Duration or term of assistance: the homebuyers will carry a soft second mortgage which
the function will be to make the first mortgage affordable to someone at 50% AMI. The
soft second will also prevent a “windfall” profit to the owner because the below market
first mortgage amount will not create instant equity for the buyer without the second
being in place.

Tenure of beneficiaries: will be homeowners unless part of the funds are used for a
Special Need project then the tenure will be permanent supportive housing tenant.

A description of how the design of the activity will ensure continued affordability:
       Once the acquisition and rehabilitation has taken place, the house will be sold so
       the first mortgage payment will be affordable to a 50% AMI buyer. This will be
       accomplished by moving the remaining balance of the purchase price determined
       by an appraisal to a 0%, deferred payment second mortgage. The second
       mortgage will serve as the affordability mechanism for recapture of the funds if
       the owner sells or no longer occupies the home.

       The project will meet the affordability requirements detailed in Section C (3) of
       this plan.




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PROJECTS 7 & 8 (Combined) – Lincoln

Everett and Near South - Acquire foreclosed and vacant houses which were split into
apartments, rehabilitate/deconvert/reconstruct for homeownership housing for low-
moderate-middle income households in the Everett and Near South neighborhoods.

Malone - NeighborWorks Lincoln will acquire, rehabilitate and resell abandoned,
foreclosed, and vacant homes to provide housing for low-moderate-middle income
homebuyers in the Malone neighborhood.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Purchase, rehabilitation (or demolish/build new), resale

(2) Activity Type:    (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(A) establish financing mechanisms for purchase and redevelopment
      of foreclosed upon homes and residential properties, including such mechanisms
      as soft-seconds, loan loss reserves, and shared-equity loans for low- and
      moderate- income homebuyers;
  • §2301(c)(3)(B) purchase and rehabilitate homes and residential properties that
      have been abandoned or foreclosed upon, in order to sell, rent, or redevelop such
      homes and properties;
  • §2301(c)(3)(D) demolish blighted structures;
  • §2301(c)(3)(E) redevelop demolished or vacant properties

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • As part of an activity delivery cost for an eligible activity as defined in 24 CFR
     570.206.
  • Financing mechanisms used to carry out CDBG eligible activities listed below.
  • 24 CFR 570.201
         (a) Acquisition
         (b) Disposition
         (d) Clearance, for blighted structures only
         (e) Public services for housing counseling, but only to the extent that
         counseling beneficiaries are limited to prospective purchasers or tenants of the
         redeveloped properties
         (i) Relocation
         (n) Direct homeownership assistance to persons whose incomes do not
         exceed 120% of median income.




                                                                                      103
   •   24 CFR 570.202 Eligible rehabilitation and preservation activities for homes and
       other residential properties. Note that rehabilitation may include counseling for
       those seeking to take part in the activity.
   •   24 CFR 570.204 Community based development organizations
   •   New housing construction

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
   • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
   • Homeownership Assistance
   • All Units must be occupied by those meeting the low- and moderate- middle-
       income requirement.

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 2 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is housing.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

Everett and Near South:
The activity will address the need to increase home ownership in the Everett and Near
South neighborhoods and in doing so provide a neighborhood revitalization benefit. The
top priority is to target houses that were split into apartments and deconvert. The benefit
to income-qualified persons will be a first mortgage payment within their housing cost
ratios. The funds will be used to benefit those below 120% of AMI which will
economically integrate this low income neighborhood.

Malone:
The activity will address a need to increase in home ownership in neighborhoods with
low ownership rates while still keeping the houses affordable to lower income buyers.
The benefit to income-qualified persons will be a first mortgage payment within their
housing cost ratios. All funds will be used to benefit those below 120% of AMI.


                                                                                         104
(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

Everett and Near South:
The Everett and Near South neighborhoods including distressed property on 11th & C,
15th & D, Goodhue Blvd., S 16th and 17th.
Census Tracts: 17, 18, 20 and 22.

Malone:
Activities will be conducted in the Malone Neighborhood of Lincoln.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

10 units of housing will be acquired, rehabilitated and sold to homebuyers.

3 blighted structures will be demolished.

4 moderate-income homebuyers will benefit from the homeownership activity

21 middle-income homebuyers will benefit from the homeownership activity

(7) Total Budget: (Include public and private components)

Uses                                               Amount    Source
Acquisition&Rehabilitation                       2,455,500   NSP
Demolition                                          60,000   NSP
Rehabilitation                                     600,000   Other/NWL Line of Credit
1st Mortgages                                    2,900,000   Local lenders
Soft Seconds                                       484,500   NSP
Total                                            6,500,000
Total NSP                                        3,000,000   NSP


(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

City of Lincoln, Urban Development, 808 P Street, Suite 400, Lincoln, NE. 68508, Steve
Werthmann 441-8621, swerthmann@lincoln.ne.gov

Malone: City of Lincoln will partner with NeighborWorks Lincoln, Michael Snodgrass,
2121 N 27th Street, Lincoln, Nebraska (402) 477-7181, msnodgrass@nwlincoln.org

(9) Projected Start Date: August 1, 2009

                                                                                      105
(10) Projected End Date: August 1, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased will have a purchase discount of 15% or greater than the Current
Market Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

NSP financing provided will be at a 0% interest rate

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

Tenure of beneficiaries will be homeowners.

Duration or term of assistance; the homebuyers will carry a soft second mortgage whose
function will be to make the first mortgage affordable to someone between 80% and
120% AMI. The soft second will also prevent a “windfall” profit to the owner because
the below market first mortgage amount will create instant equity for the buyer without
the second being in place.

A description of how the design of the activity will ensure continued affordability:
       Once the acquisition and rehabilitation has taken place, the house will be sold so
       the first mortgage payment will be affordable to the income range of the buyer.
       This will be accomplished by moving the remaining balance of the purchase price
       determined by an appraisal to a 0%, deferred payment second mortgage. The
       second mortgage will serve as the affordability mechanism for recapture of the
       funds if the owner sells or no longer occupies the home.

Project will meet affordability requirements for homeownership housing in Section C. (3)
of this plan.




                                                                                        106
9 – Housing Development Corporation - Acquire, rehabilitate, resell foreclosed,
abandoned and vacant homes for low-moderate-middle income homebuyers.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Purchase, Rehabilitation, Resale of Foreclosed and Abandoned
Property

(2) Activity Type:    (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(A) establish financing mechanisms for purchase and redevelopment
      of foreclosed upon homes and residential properties, including such mechanisms
      as soft-seconds, loan loss reserves, and shared-equity loans for low- and
      moderate- income homebuyers;
  • §2301(c)(3)(B) purchase and rehabilitate homes and residential properties that
      have been abandoned or foreclosed upon, in order to sell, rent, or redevelop such
      homes and properties;


CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • As part of an activity delivery cost for an eligible activity as defined in 24 CFR
     570.206.
  • Financing mechanisms used to carry out CDBG eligible activities listed below.
  • 24 CFR 570.201
         (a) Acquisition
         (b) Disposition
         (i) Relocation
         (n) Direct homeownership assistance to persons whose incomes do not
         exceed 120% of median income.
  • 24 CFR 570.202 Eligible rehabilitation and preservation activities for homes and
     other residential properties. Note that rehabilitation may include counseling for
     those seeking to take part in the activity.

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
   • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
   • Homeownership Assistance


                                                                                      107
   •   All Units must be occupied by those meeting the low- moderate- and middle-
       income requirement.

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 3 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is housing.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.


(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

Grand Island, Nebraska; Hastings, Nebraska; and additional communities in the
following Nebraska counties: Adams, Clay, Nuckolls, and Hall Counties. At least 50%
of the funds will be used in Hall County.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

28 foreclosed or abandoned houses will be purchased, rehabilitated, and sold to low-
moderate- middle income households.

7 households with incomes below 50% AMI will benefit from the homeownership
activity.

7 households with incomes between 51% and 80% AMI will benefit from the
homeownership activities.

14 households with incomes between 81% and 120% AMI will benefit from the
homeownership activities.

(7) Total Budget: (Include public and private components)

NSP FUNDS
Purchase 8 homes at an average cost of $75,000.                          600,000
Complete Rehabilitation at an average cost of $20,000.                  160,000.

                                                                                         108
Pay closing costs, holding costs during construction and marketing,
insurance, utilities, maintenance – Approximate holding time
is based on 6 months- 8 units at 1,500.                               12,000.
Down Payment Assistance 8 X Average of 32,500 per homebuyer          260,000.
Total NSP Funds                                                 $1,032,000.00

Resell homes for the purchase price plus repairs less DPA of up to $20,032,500.00 per
household at and average cost of $95,000.00 per home
Continue purchasing homes with the funds generated from the sale of homes, complete
rehabilitation, and provide DPA until funds are exhausted

Potential units 28
Private funds
Homeowner contribution 28 X $500.00 minimum                        $14,000.00
First Mortgages 28 X average of $70,000.00                      $1,960,000.00

Total Project
NSP FUNDS                            $1,032,000.00
Private Funds                        $1,970,000.00

TOTAL                                $3,006,000.00

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

Responsible Organization – Housing Development Corporation
                           PO Box 1005
                           Hastings, Nebraska 68902
Administrator Contact      Linda Addison, Executive Director
                           402 461 8407
                           lahdc@hastingschamber.com

(9) Projected Start Date: September 1, 2009

(10) Projected End Date: August 31, 2010

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased will have a purchase discount of 15% or greater than the Current
Market Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

                                                                                        109
   range of interest rates: NSP funds will be provided as deferred forgiveable loans at
   0% interest rate

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

Duration or term of assistance: The down payment assistance is a one time principle
reduction payment at closing that will be used for closing costs and to reduce the amount
of the mortgage loan. Direct homebuyer assistance will be provided as a deferred
forgiveable loan at 0% interest.

Tenure of beneficiaries: homeownership

A description of how the design of the activity will ensure continued affordability:

HDC has assisted 126 homeowners purchase homes since 1995. Of the126 families only
2 households have had mortgages foreclosed. This represents 2 % of the total. The
majority of these households are at or below 80% of median income and all are below
100% median income. This population group represents families that are more likely to
lose their home through foreclosure due to job loss, illness, or a change in the household
due to divorce or death.
HDC’s Program Design limits the household to spending 25% or less of the gross income
for housing costs and requires that homebuyers are dredit worthy or willing to work
towards cbeing credit worthy. Lenders have traditionally been allowing up to 32% and if
there is little or no debt, as much as 41%. This type of lending practices has caused some
of the foreclosure problems. Housing costs include: Principle, Interest, Taxes and
Insurance (PITI). Lenders will allow up to 32%. Homes that are rehabbed by HDC meet
the minimum standards as required by NDED. In addition HDC makes sure that the life
expectancy of all mechanicals, roof, structure and other inspected areas of the home is at
least 5 years. This ensures that the homeowner will not face expensive repairs within the
first five years of purchase which is when the risk of foreclosure in highest.

All homeownership activities will meet the affordability requirements for
homeownership detailed in Section C. (3) of this plan.




                                                                                       110
PROJECT 10 – City of Grand Island - Acquire foreclosed homes, demolish blighted
structures, redevelop demolished and vacant property and partner with Habitat for
Humanity and the North Central Continuum of Care for future development.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Grand Island Neighborhood Stabilization Project

(2) Activity Type:     (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;
  • §2301(c)(3)(E) redevelop demolished or vacant properties

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201
             (a) Acquisition
             (b) Disposition
              (d) Clearance, for blighted structures only
             (e) Public services for housing counseling, but only to the extent that
             counseling beneficiaries are limited to prospective purchasers or tenants of
             the redeveloped properties
             (i) Relocation
             (n) Direct homeownership assistance (for persons whose income does not
             exceed 120% of median income)
  • 24 CFR 570.204 Community based development organizations
  • New housing construction

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
   • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
   • Homeownership Assistance
   • All Units must be occupied by those meeting the low- moderate- and middle-
       income requirement.

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity


                                                                                            111
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 3 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is housing.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

There is a need in Grand Island to develop housing for very low income residents and for
quality, affordable housing for low-to-moderate income persons. Habitat for Humanity
serves residents at 50% of medial income and report receiving an average of 100
applications for each home that they build in Grand Island. The Hall County Housing
Authority has a 3-year waiting list for 2-3 bedroom homes and stated at a recent
Affordable Housing Market Study Steering Committee meeting that “if their families do
find housing that is available for rent, it is often poor quality or unsafe.” Director Rick
Ruzicka also noted that houses with 4 or more bedrooms are needed due to an increase in
large families in the last few years. Unfortunately, larger, existing homes in Grand Island
were generally built prior to 1940 and need significant and costly improvements.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

The properties with the greatest need for demolition or redevelopment will be selected
from Hall County Census Tracts/Block Groups 000200-1; 000200-2; 000200-4; 000100-
3; 000400-2; 000400-4; 000400-5; 000700-1; 000700-3; 000700-2; 000300-5; 000300-1;
000300-2; 000300-3; 000300-4; 000600-2; 000600-1; 000900-1; 001000-1; 000900-2;
000900-4; 001100-1; 001100-3; and 000800-1. Many of these areas have 1) a
neighborhood school, 2) one or more mobile home parks, 3) undeveloped property, or 4)
are in an area that has been declared substandard or blighted. Other Census Tracts/Block
Groups outside of the City limits but within the 2-mile jurisdiction may be eligible.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

12 blighted structures will be demolished and redeveloped.

4 very low-income households will benefit from redeveloped housing.

4 moderate-income households will benefit from redeveloped housing.

4 middle-income households will benefit from redeveloped housing.



                                                                                         112
(7) Total Budget: (Include public and private components)
Activity              # of  Budget per   NSP         Other         NSP       Other
                      units unit         Request     Funds         Funding   sources of
                                                                             funding
Acquisition           12    $45,000      $528,400                  NSP
Closing Costs         12    $1,000       $ 12,000                  NSP
Property taxes, lot   12    $1,500       $ 18,000                  NSP
upkeep
Phase 1               12    $500         $   6,000                 NSP
Environmental
Review;
publications,
filings, Building
Dept. housing
inspections
Lead Based Paint      12    $1,000       $ 12,000                  NSP
assessment/removal
Asbestos              12    $3,000       $ 36,000                  NSP
assessment/removal
Demolition            12    $7,000 per   $ 77,000          -       NSP
                            structure                                        City of Grand
                                                     $7,000                  Island
                                                                             Building
                                                                             Department
Construction          12    $500         $ 6,000          -        NSP
Development (RFP,
public notices,
advertising)
Home Construction     4     $60,000                  $240,000                Habitat
Habitat
Home Construction     4     $95,000                  $380,000                HDC
HDC
Home Construction     4     $110,000                 $440,000                Contractors
Market
Down payment          12    $20,000 or   $200,000             -    NSP       City of Grand
assistance                  20% of                                           Island
                            purchase                 $ 40,000                Program
                            price/unit                                       Income
New construction      12                             $1,200,000              Habitat
of housing                                                                   HDC
                                                                             Contractors
Sidewalks, curb       12    $800 per                     $ 8,400             Habitat
repair                      unit                     -                       HDC
                                                                             Contractors
TOTAL:                                   $895,400    $1,107,000
Housing Admin.              8%           $ 71,632                  NSP
(project delivery
costs)
Total Grant request                      $967,032    $ 967,032
Total Project cost:                                  $2,074,032

                                                                                       113
(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

        Applicant: The City of Grand Island
        Physical Location: 100 E. 1st St.
        Mailing Address: P.O. Box 1968
                          Grand Island, NE 68802

        Administrator Contact: Joni Kuzma, Community Development Administrator
                               Community Development
                               P.O. Box 1068
                               Grand Island, NE 68802
                               Phone: 308-385-5444, ext. 248
                               Fax: 308-385-5423
                               Email: jkuzma@grand-island.com


(9) Projected Start Date: August 1, 2009

(10) Projected End Date: July 31, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased will have a purchase discount of 15% or greater than the Current
Market Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

NSP financing provided will be at a 0% interest rate


For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

    •   duration or term of assistance;

   Existing guidelines for duration or term of assistance are as follows but may be amended to
meet the restrictions or modifications recommended by the Department. For persons at 80% -
120% of median income, down payment assistance from the City of Grand Island will be
secured by a second mortgage in the form of a lien for a period of 10 years. This lien will

                                                                                            114
be secured by a Deed of Trust and a Note to Secure the Deed of Trust to be signed by the
applicant(s) and filed with the Hall County Register of Deeds. If the homebuyer lives in
the house for the duration of the affordability period, the second mortgage will decrease
10% annually on the origination date, be forgiven at the end of the 10-year period, and no
repayment will be required.

For persons at 50% of median income, down payment assistance from the City of Grand
Island will be secured by a second mortgage in the form of a lien for a period of 5 years.
This lien will be secured by a Deed of Trust and a Note to Secure the Deed of Trust to be
signed by the applicant(s) and filed with the Hall County Register of Deeds. If the
homebuyer lives in the house for the duration of the affordability period, the second
mortgage will decrease 20% annually on the origination date, be forgiven at the end of
the 5-year period, and no repayment will be required.

A third lien will be executed on the housing unit if rehabilitation funds are utilized. The
lien will be for a five-year period in the amount of the funds used and decrease 20%
annually on the anniversary date of the loan. This lien will be secured by a Deed of Trust
and a Note to Secure the Deed of Trust to be signed by the applicant(s) and filed with the
Hall County Register of Deeds. If the homebuyer lives in the house for the duration of the
affordability period, the third mortgage will be forgiven and no repayment will be
required.

    • tenure of beneficiaries--renters or homeowners?;
    Existing City housing programs provide for tenures of either 5 or 10 years in the
clients’ home of residence, for both owner-occupied rehabilitation and the first time
homebuyer program. Very low Income clients are at 50 – 80% of median income and
have a 5-year tenure requirement. Low income clients can be at 80% median income and
have a 10-year tenure requirement. Tenure guidelines may be amended if there are other
restrictions or modifications recommended by the Department. Tenure guidelines for
Habitat for Humanity will apply.

   •   a description of how the design of the activity will ensure continued
       affordability

    Current guidelines for use of recaptured CDBG funds are outlined in a 1994 Reuse
Plan. These funds are reinvested into housing for families that meet low-to-moderate
income guidelines to ensure affordability of housing. At this time, all recaptured funds
are prorated and the amount repaid is directly dependent upon the established
affordability period (5 years - 20% per year forgiven; 10 years - 10% per year forgiven).
Recaptured funds are placed in an interest bearing account and used as program income
for future housing activities that benefit low-to moderate income person.
        Recaptured funds from NSP will follow HUD requirements for reuse or returned
to the Department of Economic Development or HUD. The City has a policy in place for
recaptured funds, but it may be modified if NSP funding is awarded.




                                                                                       115
    Housing will meet affordability requirements detailed for homeownership in Section
C. (3) of this plan.




                                                                                   116
PROJECT 11– Village of Union – Demolish main street building and redevelop into a
community building with emergency shelter.

(1) Activity Name: Demolition of Main Street building and redevelopment for
community building.

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;
  • §2301(c)(3)(E) redevelop demolished or vacant properties


CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201 (d) Clearance, for blighted structures only
  • 24 CFR 570.201
             (a) Acquisition
             (b) Disposition
             (c) Public facilities and improvements
              (i) Relocation

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).
    • Demolition, Acquisition, Lank Banks if maintenance and demolition also take
       place

Serving a limited clientele whose incomes are at or below 120 % of area median income
(LMMC).
   • Public facilities such as emergency shelters, group homes

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

The project is located in the Area of Greatest Need Level 3. The benefit is to the area
that is primarily households with incomes at or below 120% Area Median Income. The
funds used for this activity will not be used to meet the low income housing requirement
for those below 50% of area median income.

                                                                                            117
(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

Several lots on the corner of US Hwy 34 (Main Street) and 2nd St. in Union. Lots 2, 3
and 4, Block 2, South Union Addition, Union, Cass County, Nebraska.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

The activity will have an area benefit to 226 people with incomes at or below 120% area
median income in an area with 272 total population.

(7) Total Budget: (Include public and private components)

Inspections, removal of hazardous materials
Demolition and site Clearance ……………
Construction of facility for community center and Emergency Shelter…..
______________________________________________________________

       Total NSP for above items……………………………………… $500,000
       Total other funds for above items………………………………… $250,000

__________________________________________________________________
Total project costs……………………………………………….                      $750,000

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

The Board of Trustees: Village of Union, PO Box 127, Union, NE 68455

CDBG Certified Administrator through Southeast Nebraska Development District:
David R. Taladay, SENDD, 2631 “O” St., Lincoln, NE, 68510-1398, 402.475.2560

(9) Projected Start Date: August 1, 2009

(10) Projected End Date: July 30, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

This project does not include NSP acquisition activities.




                                                                                        118
For financing activities, include:
   • range of interest rates

This project does not include NSP financing activities.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability


This project is not a housing related activity.




                                                                                     119
PROJECT 12– City of Plattsmouth – Demolition of blighted residential structures.

(1) Activity Name: Demolition of blighted structures.

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201 (d) Clearance, for blighted structures only


 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).
    • Demolition, Acquisition, Lank Banks if maintenance and demolition also take
       place

 (4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

The activity is located in area need level 3. The project will provide an area benefit to
low income persons with incomes at or below 120% area median income. The funds
used for this activity will not be used to meet the low income housing requirement for
those below 50% of area median income.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

Plattsmouth, Nebraska

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

The activity will have an area benefit where 51% of the people will live in households
with incomes at or below 120% area median income.

                                                                                            120
(7) Total Budget: (Include public and private components)

Estimated costs for the following activities to acquire properties and to
Complete demolition and clearance……

Coordination of Acquisition process, appraisal, legal, inspections
Purchase costs
Environmental Review of each property prior to demolition
Removal of identified hazardous materials
Demolition costs
Lot clearance costs

       Total cost for above items………………………………………                            $175,000

___________________________________________________________________
Total project costs……………………………………………….                      $175,000


(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

Responsible organization: City of Plattsmouth, 136 No. 5th St., Plattsmouth, NE, 68048

CDBG Certified Administrator through Southeast Nebraska Development District:
David R. Taladay, SENDD, 2631 “O” St., Lincoln, NE, 68510, 402.475.2560.

(9) Projected Start Date: August 1, 2009

(10) Projected End Date: July 30, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

This project does not include NSP acquisition activities.

For financing activities, include:
   • range of interest rates

This project does not include NSP financing activities.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

                                                                                       121
This project is not a housing related activity.




                                                  122
PROJECT 13 – City of Indianola - Demolish a blighted downtown structure and
redevelop for a community tornado shelter to serve tenants of public housing built slab on
grade and mobile home occupants.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Indianola Community Redevelopment Project

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;
  • §2301(c)(3)(E) redevelop demolished or vacant properties

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201
             (a) Acquisition
             (b) Disposition
             (c) Public facilities and improvements
             (d) Clearance, for blighted structures only

(3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
   • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
   • Homeownership Assistance
   • Infrastructure for housing as part of redevelopment
   • All Units must be occupied by those meeting the low- moderate- and middle-
       income requirement.

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).
    • Demolition
    • Community tornado Shelter (community is approximately 75% LMMI)

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

                                                                                            123
1. The project meets the area of greatest need level 4 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is for safety from inclement weather
   in a centrally-located tornado shelter.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

The proposed project for the City of Indianola is to demolish a blighted structure in the
downtown area that is a definite health and safety hazard. After the demolition of the
building, the City is planning to construct a tornado shelter for citizens in Indianola who
do not have basements. The City of Indianola has HUD housing on the east side of town.
The properties are built slab on grade. They also have approximately 15-20 trailer homes
on scattered sites throughout the community which do not have any place to go in a
tornado. The shelter would serve a void in the City’s Hazard Mitigation plan as research
has shown the community needs a place for persons to go for safety during a storm. The
project would benefit the entire community of which there are approximately 75% of
households at or below 120% AMI. The City has been trying to rid the main street of the
dilapidated structure for several years; however the lack of City funds has deterred them
from completing the demolition. The NSP program will enable them to demolish this
structure and redevelop the area so to service the entire community with a safe place to
go during inclement weather.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

The location of the property to be demolished is 120 North Main Street, Indianola, NE
(Legal Description is All of Lots 3 &4 and the North 8’9” of Lot 5 in Block 33 of
Original Town, Indianola, Nebraska). This would be the same location of the storm
shelter construction as well.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

One blighted structure will be demolished.

One tornado shelter will be constructed benefit 491 income-eligible households.

(7) Total Budget: (Include public and private components)

Demolition of Blighted Structure on Main Street                             $ 75,000
Construction of Storm Shelter (including Phase I, architectural
  Fees, and construction costs)                                             $107,000



                                                                                         124
TOTAL PROJECT COST                                                 $182,000

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

Miller & Associates, 1111 Central Avenue, Kearney, NE 68847 will be the responsible
organization implementing the NSP activities for the City of Indianola. Miller &
Associates has two certified administrators on staff, Candy Kuntz and Jacque Haupt.
Candy Kuntz will handle the day-to-day administration of the project. Her contact
information is 308/234-6456 (telephone) 308/234-1146 (fax) and candy@miller-
engineers.com (e-mail) Candy has been a certified administrator since 2003 and the firm
of Miller & Associates is currently completing the administration of the City of
Indianola’s joint water system improvement grant project with the communities of
Bartley and Cambridge as well as Indianola’s Wastewater project.

(9) Projected Start Date: August 1, 2009

(10) Projected End Date: July 31, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

No acquisition is planned for the project.

For financing activities, include:
   • range of interest rates

NSP financing will be provided as a conditional grant.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

No housing activities are planned for the project.




                                                                                      125
PROJECT 14 – West Central Nebraska Development District - Demolish blighted
structures in communities enforcing nuisance ordinances or building codes.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Regional Demolition Plan

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201 (d) Clearance, for blighted structures only

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).
    • Demolition


(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 4 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons by demolishing blighted structures.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

Any blighted structure that is to be demolished in the DED CDBG NSP must be located
in an identified census block group as provided for by HUD DED and the area should be
defined by DED as having a likelihood of a higher than average percent of houses that are
dilapidated.



                                                                                            126
WCNDD has visited all communities within the District in the past twelve (12) months.
And through visual assessment and personal visits with business owners, staff has
determined that in many areas throughout the District there is a need for clean-up of old
dilapidated structures (including mobile homes) not only in residential areas but in
business districts as well.

As a result of a regional Strategic Planning Process in meeting with community leaders
and residents in a town hall setting to determine the needs of municipalities as defined by
the citizens. In a tally of priorities identified by participating municipalities, community
clean-up was the highest priority at 23% of the total activities identified.

Municipalities within the District have determined the need for community clean up and
are beginning to access the services of the WCNDD Nuisance Abatement Program. A
Nuisance Abatement Ordinance, formulated by Creighton Law College in collaboration
with WCNDD, has been made available and adoption will be required by all communities
who participate in the NSP program.

In a regional report developed for the Economic Development Administration, the 2008
Comprehensive Economic Development Strategy, clearly shows that over one-half of the
homes (59%) in the District were built prior to 1960 and those not receiving any repair
and maintenance are showing severe decline. This information is in line with DED’s
assumption of targeted areas having a likelihood of a higher than average percent of
houses that are dilapidated

Any blighted structure that is to be demolished in the DED CDBG NSP must be located
in an identified census block group as provided for by HUD. The area must be defined
by DED as having a likelihood of a higher than average percent of houses that are
dilapidated.

In order for the process to be fair and equitable to all communities within the District,
WCNDD will establish a priority ranking system to determine highest need for
demolition, and will collaborate with local units of government in order establish a
greater need scale. This plan will also serve an area in which at least 51% of the residents
have incomes at or below 120 percent of the area median income (LMMH).

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

The Regional Demolition Plan will cover the counties of Keith, Dawson, Perkins, Chase,
and Red Willow. 50% or more of the funds will be used in Red Willow County.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).




                                                                                        127
32 blighted structures will be demolished benefitting low- moderate- middle income
persons.

(7) Total Budget: (Include public and private components)

         Activity                                        Budget
Demolition & Land Fill                                  $320,000
Costs

Lead and asbestos                                       $180,000
abatement

PROJECT TOTAL                                           $500,000
BUDGET


(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

Responsible Organization: West Central Nebraska Development District at PO Box 599
Ogallala, NE 69153

Administrator: CJ Poltack, same address, 308-284-6077, cjpoltack@wcndd.org

(9) Projected Start Date: August 1, 2009

(10) Projected End Date: July 31, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Project does not include acquisition activities.

For financing activities, include:
   • range of interest rates
NSP funds will be provided as conditional grants with no interest rate.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

Project does not include housing or housing related activities.


                                                                                      128
PROJECT 15– City of Gering – Demolish blighted structures and redevelop for
housing.

(1) Activity Name: Demolition of blighted structures and redevelopment for affordable
housing.

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;
  • §2301(c)(3)(E) redevelop demolished or vacant properties

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201 (d) Clearance, for blighted structures only
  • 24 CFR 570.201
             (a) Acquisition
             (b) Disposition
              (e) Public services for housing counseling, but only to the extent that
             counseling beneficiaries are limited to prospective purchasers or tenants of
             the redeveloped properties
             (i) Relocation
             (n) Direct homeownership assistance (for persons whose income does not
             exceed 120% of median income)

   •   24 CFR 570.204 Community based development organizations

   •   New housing construction

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
   • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
   • Homeownership Assistance
   • Infrastructure for housing as part of redevelopment
   • All Units must be occupied by those meeting the low- moderate- and middle-
       income requirement.

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).


                                                                                            129
   •   Demolition, Acquisition, Lank Banks if maintenance and demolition also take
       place

 (4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

The activity is located in area need level 4. The project will provide an area benefit to
low income persons with incomes at or below 120% area median income. The project
will also provide a direct benefit to income-qualified households to become homebuyers.
The funds used for this activity will not be used to meet the low income housing
requirement for those below 50% of area median income.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

McKinley School --- 1430 6th Street Gering, NE 69341

HHS Building -- 1030 N Street Gering, NE 69341

Demo of 10 structures – within the city limits of Gering in the allowable census tracts,
but focusing on the housing districts east and southeast of the central business district.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

The activity will have an area benefit where 51% of the people will live in households
with incomes at or below 120% area median income.

The activity will assist 8 very low-income households and 2 households with incomes
between 50% AMI and 120% AMI.

(7) Total Budget: (Include public and private components)

McKinley School -- $275,000

HHS Building --     $125,000

10 Structures demolished $105,000

Redevelop 2 houses at an average of $100,000 per year = $200,000




                                                                                         130
Total Budget $705,000


(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

City of Gering and Twin Cities Development Assoc., Inc.

(9) Projected Start Date: September 1, 2009

(10) Projected End Date: August 31, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased with a purchase discount of 15% or greater than the Current Market
Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

NSP financing provided will be at a 0% interest rate.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

Duration or term of assistance – NSP will be provided as a conditional grant with an
affordability period consistent with the affordability period requirements.

Tenure of beneficiaries – homeownership

Description of how the design of the activity will ensure continued affordability – the
project will be subject to the affordability requirements for homebuyer housing detailed
in Section C (3) of this plan.




                                                                                       131
PROJECT 16– City of McCook – Demolish five blighted structures.

(1) Activity Name: Demolition of blighted structures.

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;


CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201 (d) Clearance, for blighted structures only

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).
    • Demolition, Acquisition, Lank Banks if maintenance and demolition also take
       place

 (4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

The activity is located in area need level 4. The project will provide an area benefit to
low income persons with incomes at or below 120% area median income. The funds
used for this activity will not be used to meet the low income housing requirement for
those below 50% of area median income.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

McCook, Nebraska.

206 West 7th
511 East 6th
1303 East B
301 East 2nd
304 West 4th Street


                                                                                            132
(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

The activity will have an area benefit where 51% of the people will live in households
with incomes at or below 120% area median income.

(7) Total Budget: (Include public and private components)

Demolition of Blighted Structures                                         $175,000
(1@ $100,000; 3 @ $15,000 each; and 1 @ $30,000)
Total Demolition Cost                                                     $182,000

TOTAL PROJECT COSTS WITH ADMINISTRATION                                   $182,000


(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

Miller & Associates, 1111 Central Avenue, Kearney, NE 68847 will be the responsible
organization implementing the NSP activities for the City of McCook. Miller &
Associates has two certified administrators on staff, Candy Kuntz and Jacque Haupt.
Candy Kuntz will handle the day-to-day administration of the project. Her contact
information is 308/234-6456 (telephone) 308/234-1146 (fax) and candy@miller-
engineers.com (e-mail) Candy has been a certified administrator since 2003.

(9) Projected Start Date: September 1, 2009

(10) Projected End Date: August 31, 2010

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

This project does not include NSP acquisition activities.

For financing activities, include:
   • range of interest rates

This project does not include NSP financing activities.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

                                                                                         133
This project is not a housing related activity.




                                                  134
PROJECT 17– Panhandle Area Development District– Demolish blighted structures.

(1) Activity Name: Demolition of blighted structures.

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201 (d) Clearance, for blighted structures only

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Area Benefit Activity

# ___34,294 (68.9%) people with household incomes at or below 120% AMI

 (4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

The activity is located in area need level 4. The project will provide an area benefit to
low income persons with incomes at or below 120% area median income. The funds
used for this activity will not be used to meet the low income housing requirement for
those below 50% of area median income.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

The project will include project eligible areas in incorporated communities in the
Nebraska Panhandle region which includes Cheyenne, Dawes, Kimball, Scotts Bluff
counties. At least 50% of the funds will be used in Scotts Bluff county.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

The activity will have an area benefit where 51% of the people will live in households
with incomes at or below 120% area median income.

                                                                                            135
Area Benefit Activity

# ___34,294 (68.9%) people with household incomes at or below 120% AMI

(7) Total Budget: (Include public and private components)

PADD proposes to demolish at least 20 dilapidated structures on developable lots.

The total cost of the program is $130,000

The cost of physical demolition, capping, proper disposal of materials and restoration of
lot for development will total $130,000.

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

The Panhandle Area Development District will implement the activity by utilizing private
sector contractors to perform demolition activities.

Panhandle Area Development District
1432 10th Street
Gering NE 69341
Jeff Kelley, Project Administrator

(9) Projected Start Date: September 1, 2009

(10) Projected End Date: February 28, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

This project does not include NSP acquisition activities.

For financing activities, include:
   • range of interest rates

This project does not include NSP financing activities.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability



                                                                                       136
PROJECT 18– McCook Economic Development Corporation – Demolish blighted
structures and redevelop to housing.

(1) Activity Name: Demolition of blighted structures and redevelop to housing.

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;
  • §2301(c)(3)(E) redevelop demolished or vacant properties

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201 (d) Clearance, for blighted structures only
  • 24 CFR 570.201
             (a) Acquisition
             (b) Disposition
              (e) Public services for housing counseling, but only to the extent that
             counseling beneficiaries are limited to prospective purchasers or tenants of
             the redeveloped properties
             (i) Relocation
             (n) Direct homeownership assistance (for persons whose income does not
             exceed 120% of median income)

   •   24 CFR 570.204 Community based development organizations

   •   New housing construction

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
   • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
   • Homeownership Assistance
   • Infrastructure for housing as part of redevelopment
   • All Units must be occupied by those meeting the low- moderate- and middle-
       income requirement.

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).
    • Demolition, Acquisition, Lank Banks if maintenance and demolition also take
       place

                                                                                            137
 (4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

The activity is located in area need level 4. The project will provide an area benefit to
low income persons with incomes at or below 120% area median income. The project
will also provide a direct benefit to income-qualified households to become homebuyers.
The funds used for this activity will not be used to meet the low income housing
requirement for those below 50% of area median income.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

McCook, Nebraska.

An Area bounded by: A Street to J Street between West 2nd Street to East 13th

An area bounded by: A Street to E Street between West 2nd and East 1st Streets.

1200 West 4th Street, Red Willow Realty First Addition McCook Blk 1,
Lot 1 and Pt Lot 3

204 Norris Avenue, McCook Nebraska.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

The activity will have an area benefit where 376, 51% of the people will live in
households with incomes at or below 120% area median income.

The activity will assist 10 very low-income households and 2 households with incomes
between 50% AMI and 120% AMI.

(7) Total Budget: (Include public and private components)

Engineering study                                     $ 10,000
Asbestos abatement                                    $ 35,000
Demolition                                             $96,000
Landfill                                              $ 10,000
Infill                                                $ 10,000
Paving and green space                                $ 15,000

Demolition of the existing structure                  $532,500

                                                                                        138
Soft costs for developing project                    $150,000
Rehab Grants                                         $137,500
Total                                                $801,000

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

McCook Economic Development Corporation
301 Norris Avenue, Suite, 200
PO Box 626
McCook, NE 69001

Mary Seybold, CDBG Program Administrator
Housing Development Director
308-345-1200
308-345-2152-fax
mary@mccookne.org

(9) Projected Start Date: August 1, 2009

(10) Projected End Date: June 30, 2010

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased with a purchase discount of 15% or greater than the Current Market
Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

NSP financing provided will be at a 0% interest rate.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

Duration or term of assistance – NSP will be provided as a conditional grant with an
affordability period consistent with the affordability period requirements.

Tenure of beneficiaries – homeownership and rental



                                                                                       139
Description of how the design of the activity will ensure continued affordability – the
project will be subject to the affordability requirements for homebuyer and rental housing
as appropriate detailed in Section C (3) of this plan.




                                                                                      140
PROJECT 19 – Northeast Nebraska Economic Development District (NENEDD) -
Demolish blighted structures on lots that can feasibly be redeveloped and in communities
enforcing local building codes and nuisance ordinances.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Demolition and Clearance for Northeast Nebraska

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201 (d) Clearance, for blighted structures only

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).
    • Demolition

 (4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 5 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is demolition and clearance of
   blighted structures.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

Northeast Nebraska Economic Development District (NENEDD) is proposing to use
$400,000 CDBG NSP funds for demolition/clearance of blighted structures in their 17
County service area. NENEDD will work with local governments and economic
developers in identifying the properties that if redeveloped would best stabilize
neighborhoods and communities. Communities believe if lots were cleared and available,

                                                                                            141
        that they would be redeveloped. Some of the properties on the potential listing already
        are targeted for redevelopment once cleared. Most properties are truly a safety issue and
        will benefit the entire community both by removing a hazard and by improving
        appearance to those looking at the community to relocate or start a business.

        (5) Location Description: (Description may include specific addresses, blocks or
        neighborhoods to the extent known.)

        The demolition funding will be available in the following Counties: Antelope, Colfax,
        Cuming, Dixon, Dodge, Madison, Pierce, Platte, Stanton, and Thurston.
       List of Blighted Structures
Community       Address/Location                            Property Type         Redevelopment Target
Beemer          3rd and Main (old grocery store)            Commercial            Commercial
                Trailers                                    Trailer
Clarkson        414 Elm Street                              House                 Residential
                310 Pine Street                             Apartment Building    Commercial
                218 Elm Street                              House                 Residential
                314 East 3rd                                Garage                Residential
                314 Bryan                                   House                 Residential
                422 Oak                                     House                 Residential
                515 Maple Street                            House                 Residential
                517 Maple St.                               House                 Residential
                310 Oak St                                  House                 Clarkson Motor’s would
                                                                                  probably enlarge parking
                                                                                  lot for business
                119 E. 8th St.                              House                 Residential
                518 Bryan St.                               House                 Residential
Clearwater      Utah St.                                    House
                Utah St. and Nebraska                       House
                Colorado & Reno, S.W. Corner                House
                Montana St. & Reno St. N.W. Corner          Commercial
                Montana St.                                 House
                Custer St.                                  House
                Downtown, Nebraska St.                      Former Town         Commercial
                                                            building
                Custer & Colorado St.                       House
Howells         West Main Street                            House
                North 3rd Street                            House, building and
                                                            trailer
                South 2nd Street by Legion Club             House
                South 1st Street                            House
                South 2nd Street                            House
                North 8th Street                            Trailer
                North 6th Street                            House
                South 3rd Street                            House

                                                                                               142
Community   Address/Location       Property Type         Redevelopment Target
            Josephine Street       House
            South 3rd Street       House
            North 3rd Street       Shed by Hegemann
                                   Hardware
            East Center Street     Humlick Funeral
                                   Home
Madison                            Condemned –           Residential
            606 S. Ingram          Residential
                                   Condemned –           Residential
                     nd
            305 W. 2               Residential
                                   Condemned –           Residential
            102 S. Ruby            Residential
                                   Condemned –           Residential
            307 W. 4th             Residential
                                   Condemned –           Residential
            202 E. 1st             Residential
            307 S. Lincoln         Residential           Residential
            508 N. Main            Residential           Residential
            408 W. Third           Residential           Residential
            602 S. Hamilton        Residential           Residential
            102 S. Orchard         Residential           Residential
            104 E. 1st             Residential           Residential
            110 E. 1st             Residential           Residential
            408 E. 1st             Residential           Residential
            410 E. 1st             Residential           Residential
            1006 S. Orchard        Residential           Residential
            1005 S. Main           Residential           Residential
Neligh      210 M Street           Commercial
            214 M Street           Commercial
            414 M Street           Commercial
            205 K St.              House
Newman                             Bob’s Motel –
Grove       503 Boardwell Avenue   Commercial
                                   Old Reporter Office
            605 Hale Avenue        – Commercial
            504 Hale Avenue        Commercial
            310 Hale Avenue        Nazarene Church
            308 Hale Avenue        House
            215 N 1st Street       House
            106 N 4th Street       House
            108 S 4th Street       House
            206 County Line        House
            113 N 4th Street       House
            106 N 5th Street       House

                                                                       143
Community       Address/Location                         Property Type        Redevelopment Target
                207 N 5th Street                         House
                208 N 6th Street                         House
                202 N 7th Street                         House
                114 N 9th Street                         House
                108 N 10th Street                        House
                601 County Line                          House
                615 County Line                          House
                308 Hale Avenue                          House
Pilger          210 N. Main Street                       Commercial           Commercial
                245 N. Main Street                       Commercial           Commercial
                305 E 2nd Street                         Residential          Residential
                200 E. 2nd Street                        Residential          Residential
                130 E. 4th Street                        Residential          Residential
                250 E. 4th Street                        Residential          Residential
                250 W. Elm Street                        Residential          Residential
                215 S. Main Street                       Residential          Residential
Platte Center                                            House
                                                         House
                                                         House
Schuyler        Great Northern Warehouse Property        Multiple buildings
                (located immediately on the north side   and silos
                of the UP railroad @ corner of Adam &
                13th St.
                Corner of B & 12 Street                  Old Coast-to-
                                                         Coast/Aztec
                                                         Building
Scribner        511 Main Street                          Residential          Expansion; Funeral
                                                                              Home
                612 Main Street                          Residential          Single Family Housing
                125 Neff Street                          Residential          Single Family Housing
                500 5th Street                           Residential (old     Multi-Family Housing
                                                         manor)
                617 Main Street                          Residential          Single Family Housing
                308 6th Street                           Residential          Single Family Housing
                508 6th Street                           Residential          Single Family Housing
                404 6th Street                           Residential          Single Family Housing
                408 6th Street                           Residential          Single Family Housing
                700 Main Street                          Residential          Single Family Housing
                201 9th Street                           Residential          Single Family Housing
                705 Main Street                          Residential          Single Family Housing
Tilden          Antelope County side of Center Street    50’ x 100’, zoned
                                                         commercially
Wakefield       Condemned old school.                                         Community Resource
                                                                              Center/ Daycare

                                                                                        144
Community      Address/Location                              Property Type      Redevelopment Target
Wisner         On Ave. D between 10th and 11th Streets       2 Commercial       Proposed site for fire hall
                                                             buildings


       (6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
       demolished for the income levels of households that are 50 percent of area median
       income and below, 51-80 percent, and 81-120 percent).

       21 blighted structures will be demolished.

       (7) Total Budget: (Include public and private components)

Activity Description                CDBG                Local Match       Non CDBG or       Total
                                                                          Local Match
0030 Clearance/Demolition
         Clearance/Demolition        $        352,870    $            -   $         -       $       352,870
         Lead Paint                  $         27,723    $            -   $         -        $       27,723
         Testing/Abatement
         Asbestos                    $         19,407    $            -                      $         19,407
         Testing/Abatement
            Activity Subtotals       $     400,000       $            -   $             -    $      400,000
         Total Project               $     400,000       $            -   $             -    $      400,000


       (8) Responsible Organization: (Describe the responsible organization that will
       implement the NSP activity, including its name, location, and administrator contact
       information)

       Northeast Nebraska Economic Development, Inc. is the responsible organization.
       NENEDD is located at 111 S. 1st Street, Norfolk, NE 68701.

       Administrator name: Thomas L. Higginbotham
       Administrator location: same as above
       Administrator phone: 402-379-1150
       Administrator e-mail: thomash@nenedd.org

       (9) Projected Start Date: September 1, 2009

       (10) Projected End Date: August 31, 2011

       (11) Specific Activity Requirements:
       For acquisition activities, include:
           • discount rate

                                                                                                 145
No acquisition activities


For financing activities, include:
   • range of interest rates

No financing activities.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

No housing activities.




                                                                                     146
PROJECT 20 – Dawson Area Development- Demolish blighted structures.
Communities have planned and maintained prioritize lists for substandard buildings

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: The Dawson Demolition Project

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;


CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201 (d) Clearance, for blighted structures only

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).
    • Demolition

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 5 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is demolition of a blighted structure.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

The immediate neighborhood and the city/village would benefit by the demolition of an
unsafe structure that stands in their way of protecting the health of their residents. The
unit has been vacated because of the condition. Cities, and most especially the small
villages in our area, cannot afford to demolish these uninhabitable structures. In order to
clean up their towns, they must try all other options of ridding the area of the housing


                                                                                            147
unit, short of paying for demolition themselves and then trying to recoup the cost from
the owner of the property.

This program would allow for cleanup of unsafe housing units in our area and pave the
way for the original owner or someone else to redevelop the property and provide safer,
healthier, and affordable housing unit(s).

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

Locations for demolition of housing structures will be in Dawson County communities.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

13 blighted structures will be demolished.

(7) Total Budget: (Include public and private components)

Dawson Area Development, with the help of their members, would propose to demolish
13 units of substandard/blighted housing stock over a two-year period. At an
approximate cost of approximately $15,000 per property, the total cost would be
$200,000.

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)


Dawson Area Development 
209 W. 8th Street
Cozad, NE 69130

PHONE: 308 784-3902

Executive Director:     Jennifer Wolf                        jwdad@cozadtel.net
Community Development Coordinator/Administrator : Deb Jensen djdad@cozadtel.net

(9) Projected Start Date: August 1, 2009

(10) Projected End Date: July 31, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

                                                                                      148
Project does not include acquisition activities.

For financing activities, include:
   • range of interest rates

Project does not include financing activities.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

Project does not include housing activities.




                                                                                     149
PROJECT 21 – Village of Wilcox - Demolish a blighted structure in the downtown and
redevelop the property for a community center that serves low-moderate-middle income
families.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Wilcox Community Redevelopment Project

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;
  • §2301(c)(3)(E) redevelop demolished or vacant properties

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201
             (a) Acquisition
             (b) Disposition
             (c) Public facilities and improvements
             (d) Clearance, for blighted structures only
              (i) Relocation

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).
    • Demolition, Community Center

 (4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 5 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is access to a community center.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.


                                                                                            150
The proposed project for the Village of Wilcox is to demolish a blighted structure in the
downtown area that is a definite health and safety hazard. After the demolition of the
building, the Village is planning to construct a senior/community center on the lot which
will benefit the entire community that has 76.9% of households at or below 120% AMI.
The Village has been trying to rid their main street of the dilapidated structure for several
years; however the lack of Village funds has deterred them from completing the
demolition. The NSP program will enable them to demolish this structure and redevelop
the area so to service the entire community with a place they can gather for senior and
community events.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

The location of the property to be demolished is 101 South Main Street, Wilcox, NE
(Legal Description is Lot 1, Block 1 of Original Town, Wilcox, Nebraska). This would
be the same location of the senior/community center construction as well.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

One blighted structure will be demolished and redeveloped to serve low- moderate- and
middle –income persons needs for a senior/community center.

279 people with incomes at or below 120% AMI will benefit from the senior/community
center.

(7) Total Budget: (Include public and private components)

Demolition of Blighted Structure on Main Street                               $ 30,000
Construction of Community Center (including Phase I, architectural
  Fees, and building costs)                                                   $470,000


Total Demolition and Construction                                             $500,000

TOTAL PROJECT COSTS                                                           $500,000


(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

Miller & Associates, 1111 Central Avenue, Kearney, NE 68847 will be the responsible
organization implementing the NSP activities for the Village of Wilcox. Miller &
Associates has two certified administrators on staff, Candy Kuntz and Jacque Haupt.

                                                                                         151
Candy Kuntz will handle the day-to-day administration of the project. Her contact
information is 308/234-6456 (telephone) 308/234-1146 (fax) and candy@miller-
engineers.com (e-mail). Candy has been a certified administrator since 2003 and the firm
of Miller & Associates is currently completing the administration of the Village of
Wilcox’s water system improvement grant project.

(9) Projected Start Date: August 1, 2009

(10) Projected End Date: July 31, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

This project does not include acquisition activities.

For financing activities, include:
   • range of interest rates

The NSP for the community center is a conditional grant with no interest rate.


For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

This project does not include housing or housing related activities.




                                                                                     152
PROJECT 22 – Central City - Demolish blighted structures, redevelop vacant
demolished properties to housing for low-moderate-middle income families. The
community has an established inventory and analysis for dilapidated and substandard
houses.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Dilapidated Structure Demolition and Redevelopment

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;
  • §2301(c)(3)(E) redevelop demolished or vacant properties


CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201
             (a) Acquisition
             (b) Disposition
             (d) Clearance, for blighted structures only
             (e) Public services for housing counseling, but only to the extent that
             counseling beneficiaries are limited to prospective purchasers or tenants of
             the redeveloped properties
             (i) Relocation
             (n) Direct homeownership assistance (for persons whose income does not
             exceed 120% of median income)
  • 24 CFR 570.204 Community based development organizations
  • New housing construction

(3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
   • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
   • Homeownership Assistance
   • All Units must be occupied by those meeting the low- moderate- and middle-
       income requirement.

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).

                                                                                            153
   •   Demolition

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 5 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is housing and demolition of
   blighted structures.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

Currently, the City is administering a “free lot program”. This program provides a free
lot to persons desiring to build a home in Central City. The City is getting low on lots
available for its “free lot program”.

With the acquisition and redevelopment of currently vacant and unsightly structures the
City could replenish its inventory of free lots by demolishing and clearing the structures
from the lots it acquires. The city would then make empty lots available at no cost to
persons interested in using them to build a personal residence on. The lots could also be
offered for sale to investors wanting to provide affordable rental property within the City
of Central City.

In addition, the Merrick County Development Corporation (MCDC) has a history of
home construction and could be the vehicle for developing, reselling, and applying down
payment assistance to provide five (5) new, affordable homes to area residents.

Whereas, NSP can not be used for acquisition with only a demolition activity, NSP funds
will not be used to acquire lots where redevelopment of the 5 homes will not be built.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

Abandoned school property on A street in City of Central City between “E” Avenue and
“D” Avenue.

Dilapidated structures currently under review in Central City, Nebraska.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

                                                                                         154
21 blighted structures will be demolished. 5 will be redeveloped into housing for low-
moderate- middle-income households.

5 households with incomes above 80% AMI and below 120% AMI will benefit from the
new homebuyer units.

(7) Total Budget: (Include public and private components)

Sources                      NSP                    Other funds             Total
Uses
Acquisition of blighted
                                           25,000                 100,000             125,000
structures
Demolition and clearance
of blighted residential                   250,000                                     250,000
structures
Demolition of vacant
school, asbestos removal,                  50,000                                      50,000
disposal
Down payment assistance                   100,000                                    100,000
Relocation                                  2,500                                      2,500
Housing administration                     22,500                                     22,500
TOTAL                                    $450,000             $100,000              $550,000

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

Responsible Organization: City of Central City; Central City, Nebraska
Administrator: Chris Anderson, City Administrator
PO Box 418
Central City, NE 68826

Phone: 308-946-3806
Fax: 308-946-3334
Email: ctyadm@cconline.net

(9) Projected Start Date: June 1, 2009

(10) Projected End Date: May 31, 2010

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased will have a purchase discount of 15% or greater than the Current
Market Appraised Value for each property purchased with NSP funds.

                                                                                         155
For financing activities, include:
   • range of interest rates

NSP financial assistance will be provided as deferred forgiveable loans with no interest.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

Duration or term of assistance: Assistance will be provided as a conditional grant, or in
the case of homebuyer assistance, deferred forgiveable loan with no interest with an
affordability period of at least 5 years. The project is subject to affordability
requirements detailed in Section C. (3) of this plan.




                                                                                       156
PROJECT 23 – NeighborWorks Northeast Nebraska - Acquire, rehabilitate, resell
foreclosed, abandoned and vacant homes for low-moderate-middle income homebuyers.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: NSP Purchase/Rehab/Resell

(2) Activity Type:    (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(A) establish financing mechanisms for purchase and redevelopment
      of foreclosed upon homes and residential properties, including such mechanisms
      as soft-seconds, loan loss reserves, and shared-equity loans for low- and
      moderate- income homebuyers;
  • §2301(c)(3)(B) purchase and rehabilitate homes and residential properties that
      have been abandoned or foreclosed upon, in order to sell, rent, or redevelop such
      homes and properties;

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • As part of an activity delivery cost for an eligible activity as defined in 24 CFR
     570.206.
  • Financing mechanisms used to carry out CDBG eligible activities listed below.
  • 24 CFR 570.201
         (a) Acquisition
         (b) Disposition
         (i) Relocation
         (n) Direct homeownership assistance to persons whose incomes do not
         exceed 120% of median income.
  • 24 CFR 570.202 Eligible rehabilitation and preservation activities for homes and
     other residential properties. Note that rehabilitation may include counseling for
     those seeking to take part in the activity.

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
   • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
   • Homeownership Assistance
   • All Units must be occupied by those meeting the low- moderate- and middle-
       income requirement.


                                                                                      157
 (4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.

1. The project meets the area of greatest need level 5 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is housing.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

NeighborWorks® Northeast Nebraska intends to utilize NDED CDBG NSP funds to
purchase, rehabilitate and resell 5 foreclosed upon or abandoned homes which will be
located within the communities situated in Colfax, Cuming, Madison, Pierce, Platte, or
Stanton counties. All five homes will be sold to beneficiaries with up to 120% of the area
median income per the most recent HUD income limits for the county of residence.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

Various sites located within communities situated in the Colfax, Cuming, Madison,
Pierce, Platte, or Stanton counties.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

5 foreclosed or abandoned homes will be purchased, rehabilitated and sold to qualified
homebuyers.

1 household with an income at or below 50% AMI will benefit from the homeownership
activity.

2 households with incomes between 51% and 80% AMI will benefit from the
homeownership activity.

2 households with incomes between 81% AMI and 120% AMI will benefit from the
homeownership activity.

(7) Total Budget: (Include public and private components)




                                                                                         158
Single Family Purchase/Rehab/Resale 
                                                                     CDBG         OTHER
   Acquisition                 (5 x $60,000)                       $200,000
                               $100,000
   Rehabilitation              (5 x $20,000)                       $100,000
   10% Resale Discount         (5 x $ 8,000)                       $ 40,000
   Development Fee             (5 x $ 11,040)                      $ 55,200




   TOTAL PROJECT COST:                                             $395,200      $100,000


(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

NeighborWorks® Northeast Nebraska
Leslie Coleman, CDBG Administrator
213 South 1st Street, Suite D
Norfolk, NE 68701
(402) 379-3377

(9) Projected Start Date: September 1, 2009

(10) Projected End Date: August 31, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased will have a purchase discount of 15% or greater than the Current
Market Appraised Value for each property purchased with NSP funds.


For financing activities, include:
   • range of interest rates

NSP financing will have an interest rate range of 0% to 2%.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability


                                                                                        159
Duration or term of assistance: The term of assistance will be for the time the
homeowner owns and occupies the home acquired through the NSP
Purchase/Rehab/Resell program.

Tenure of beneficiaries – homeownership.

A description of how the design of the activity will ensure continued affordability:
NeighborWorks® Northeast Nebraska intends to purchase the foreclosed or abandoned
properties at a minimum of a 15% discount of the appraised value. Upon ownership
NeighborWorks® Northeast Nebraska will coordinate the necessary rehabilitation work
to the property and resell it to the income-qualified homebuyer at a 10% discount.

The affordability requirements for the project are affordability requirements for
homeownership detailed in Section C. (3) of this plan.




                                                                                    160
PROJECT 24 – City of Fremont - Demolish blighted structures and donate property to
Habitat for Humanity for future housing projects.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: Acquisition, Demolition, Clearance, Redevelopment

(2) Activity Type:     (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs (see project 26)
  • §2301(c)(3)(D) demolish blighted structures;
  • §2301(c)(3)(E) redevelop demolished or vacant properties

CDBG Eligible Activities
  • Administration and planning costs (see project 26)
  • 24 CFR 570.201
             (a) Acquisition
             (b) Disposition
              (d) Clearance, for blighted structures only
             (e) Public services for housing counseling, but only to the extent that
             counseling beneficiaries are limited to prospective purchasers or tenants of
             the redeveloped properties
             (i) Relocation
  • 24 CFR 570.204 Community based development organizations
  • New housing construction

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
   • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
   • Homeownership Assistance
   • All Units must be occupied by those meeting the low- and moderate- middle-
       income requirement.

(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.



                                                                                        161
1. The project meets the area of greatest need level 5 referenced in Section A of this
   plan.

2. The project benefit to income-qualified persons is housing.

3. The project will not be used to meet the low-income housing requirement for those
   below 50% of area median income.

The project will result cleared, available lots for Habitat for Humanity to build upon.
Habitat for Humanity currently has approximately 70 families on their waiting list. It is
anticipated that 40 of these families will qualify for Habitat’s assistance. The expected
benefit to income-qualified families will be quality, affordable housing and an increase in
quality homes for the City of Fremont’s housing stock. Through the proposed activities,
these funds will be utilized to meet the low income housing requirement for those below
120% of the area median income.

(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

The City of Fremont will focus on the targeted area within the City of Fremont as
identified by HUD where the household incomes are 51% or more at 120% of the area
median income.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

2 blighted structures will be demolished and redeveloped to housing.

1 very low-income family will benefit from the homebuyer housing.

1 moderate-income families will benefit from the homebuyer housing.

1 middle-income families will benefit from the homebuyer housing.

(3) Total Budget: (Include public and private components)

Description                                                 Total
      Acquisition                                                   $104,800         NSP
      Demolition/Clearance                                            50,000         NSP
      New construction and homebuyer assistance                      312,500         H4H
      Total Project Costs                                            467,300




                                                                                         162
(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

Organization responsible: City of Fremont; Fremont, Nebraska

Administrator: Tina M. Engelbart, Deputy Director
Address:
Northeast Nebraska Economic Development District
111 South 1st Street
Norfolk, NE 68701
Telephone:          402.379.1150 Ext. 108
Fax:                402.379.9927
Email:               tina@nenedd.org

The City of Fremont will be the responsible organization. The city has a committed,
experienced staff that have the history and capacity to implement the project in a timely
manner. The City of Fremont is willing and able to partner with NDED during the
application and implementation process of this program.

The City will contract with the Northeast Nebraska Economic Development District
(NENEDD) for administration of this project and NENEDD will play a major role in the
implementation of this project. NENEDD is located in Norfolk, Nebraska and serves a
16 County area. NENEDD has a staff of thirteen (13) full-time professionals who have a
combined experience in community development, economic and housing development,
finance, construction, and planning which exceeds 40 years. Eleven of professionals are
Certified Community Development Block Grant (CDBG) Grant Administrators who
regularly attend CDBG and other training sessions each year. On staff is a Certified
Economic Development Finance Professional, a Master Consultant in Business Retention
and Expansion, and one graduate of the Economic Development Institute.

In the past thirteen years NENEDD assisted members in obtaining more than $80 million
in grants and loans being awarded to members for various community and economic
development projects throughout the region. These grants and loans leveraged over three
times that amount in local and private funds.

(9) Projected Start Date: September 1, 2009

(10) Projected End Date: August 31, 2011

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate



                                                                                       163
Properties purchased will have a purchase discount of 15% or greater than the Current
Market Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

NSP financing provided will be at a 0% interest rate

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability
Duration or term of assistance: NSP funds will be provided as a conditional forgiveable
grant with 0% interest for 5 years.

Tenure of beneficiaries: homeownership

A description of how the design of the activity will ensure continued affordability: The
project will follow the affordability requirements detailed in Section C. (3) of this plan.




                                                                                         164
 Projects 25 & 26 (combined) GENERAL ADMINISTRATION AND PLANNING
COSTS –
Nebraska Department of Economic Development – Administration and planning for
the State of Nebraska CDBG NSP.
NDED CDBG NSP Grantees (subrecipients) – Administration and planning costs.

G. NSP INFORMATION BY ACTIVITY (COMPLETE FOR EACH ACTIVITY)

(1) Activity Name: State Administration and Grantee (subrecipient) Administration

(2) Activity Type:      (include NSP eligible use & CDBG eligible activity)

NSP Eligible Uses
  • §2301(c) Administration and Planning Costs

CDBG Eligible Activities
  • Administration and planning costs

 (3) National Objective: (Must be a national objective benefiting low, moderate and
middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median
income).

Providing or improving permanent residential structures that will be occupied by a
household whose income is at or below 120% of area median income (LMMH).
   • Acquisition, Rehabilitation, Rental, Sale, Conversion, Construction of Housing
       Units
   • Homeownership Assistance
   • All Units must be occupied by those meeting the low- moderate- and middle-
       income requirement.

Benefiting all the residents of a primarily residential area in which at least 51% of the
residents have incomes at or below 120% of area median income (LMMA).
    • Demolition, Community Facilities

Serving a limited clientele whose incomes are at or below 120 % of area median income
(LMMC).
   • Public facilities such as emergency shelters, group homes


(4) Activity Description:
Include a narrative describing the area of greatest need that the activity addresses; the
expected benefit to income-qualified persons; and whether funds used for this activity
will be used to meet the low income housing requirement for those below 50% of area
median income.



                                                                                            165
1. The activity address area of greatest need levels 1-5 referenced in Section A of this
   plan.

2. The activity benefit to income-qualified persons is housing, demolition of blighted
   structures, community facilities, and commercial development to create jobs for low-
   moderate- middle-income persons.

3. The State administration and Grantee (subrecipient) administration will not be used
   to meet the low-income housing requirement for those below 50% of area median
   income.


(5) Location Description: (Description may include specific addresses, blocks or
neighborhoods to the extent known.)

Location of projects listed in Section G of the plan Projects 1-24.

(6) Performance Measures (e.g., units of housing to be acquired, rehabilitated, or
demolished for the income levels of households that are 50 percent of area median
income and below, 51-80 percent, and 81-120 percent).

Performance measures listed by project in Section G of the Plan

(7) Total Budget: (Include public and private components)

Source-                          Neighborhood Stabilization    Total
                                 Program
Use
State: General                   $784,000                      $784,000
administration costs that
can not be attributed to
specific project activities
Grantees (subrecipients)         $784,000                      $784,000
General administration
costs that can not be
attributed to specific project
activities
Total General                    $1,568,000                    $1,568,000
Administration

(8) Responsible Organization: (Describe the responsible organization that will
implement the NSP activity, including its name, location, and administrator contact
information)

Responsible organization: Nebraska Department of Economic Development, PO Box
94666, Lincoln, NE 68509

                                                                                      166
Administrator: Lara Huskey, same address, (402) 471-3759, lara.huskey@nebraska.gov

(9) Projected Start Date: September 29, 2008 Pre-award
                          March 10, 2009

(10) Projected End Date: February 12, 2013

(11) Specific Activity Requirements:
For acquisition activities, include:
    • discount rate

Properties purchased will have a purchase discount of 15% or greater than the Current
Market Appraised Value for each property purchased with NSP funds.

For financing activities, include:
   • range of interest rates

General administration is not a financing activity.

For housing related activities, include:
   • duration or term of assistance;
   • tenure of beneficiaries--rental or homeownership;
   • a description of how the design of the activity will ensure continued affordability

General administration is not a housing or housing related activity.




                                                                                        167
                              CERTIFICATIONS
(1) Affirmatively furthering fair housing. The jurisdiction will affirmatively further fair
housing, which means that it will conduct an analysis to identify impediments to fair housing
choice within the jurisdiction, take appropriate actions to overcome the effects of any
impediments identified through that analysis, and maintain records reflecting the analysis and
actions in this regard.

(2) Anti-lobbying. The jurisdiction will comply with restrictions on lobbying required by
24 CFR part 87, together with disclosure forms, if required by that part.

(3) Authority of Jurisdiction. The jurisdiction possesses the legal authority to carry out
the programs for which it is seeking funding, in accordance with applicable HUD regulations
and other program requirements.

(4) Consistency with Plan. The housing activities to be undertaken with NSP funds are
consistent with its consolidated plan, which means that NSP funds will be used to meet the
congressionally identified needs of abandoned and foreclosed homes in the targeted area set
forth in the grantee’s substantial amendment.

(5) Acquisition and relocation. The jurisdiction will comply with the acquisition and
relocation requirements of the Uniform Relocation Assistance and Real Property Acquisition
Policies Act of 1970, as amended (42 U.S.C. 4601), and implementing regulations at 49 CFR
part 24, except as those provisions are modified by the Notice for the NSP program published
by HUD.

(6) Section 3. The jurisdiction will comply with section 3 of the Housing and Urban
Development Act of 1968 (12 U.S.C. 1701u), and implementing regulations at 24 CFR part
135.

(7) Citizen Participation. The jurisdiction is in full compliance and following a detailed
citizen participation plan that satisfies the requirements of Sections 24 CFR 91.105 or 91.115,
as modified by NSP requirements.

(8) Following Plan. The jurisdiction is following a current consolidated plan (or
Comprehensive Housing Affordability Strategy) that has been approved by HUD.

(9) Use of funds in 18 months. The jurisdiction will comply with Title III of Division B
of the Housing and Economic Recovery Act of 2008 by using, as defined in the NSP Notice,
all of its grant funds within 18 months of receipt of the grant.

(10) Use NSP funds ≤ 120 of AMI. The jurisdiction will comply with the requirement that
all of the NSP funds made available to it will be used with respect to individuals and families
whose incomes do not exceed 120 percent of area median income.

(11) Assessments. The jurisdiction will not attempt to recover any capital costs of public
improvements assisted with CDBG funds, including Section 108 loan guaranteed funds, by

                                                                                           168
assessing any amount against properties owned and occupied by persons of low- and
moderate-income, including any fee charged or assessment made as a condition of obtaining
access to such public improvements. However, if NSP funds are used to pay the proportion of
a fee or assessment attributable to the capital costs of public improvements (assisted in part
with NSP funds) financed from other revenue sources, an assessment or charge may be made
against the property with respect to the public improvements financed by a source other than
CDBG funds. In addition, with respect to properties owned and occupied by moderate-
income (but not low-income) families, an assessment or charge may be made against the
property with respect to the public improvements financed by a source other than NSP funds
if the jurisdiction certifies that it lacks NSP or CDBG funds to cover the assessment.

(12) Excessive Force. The jurisdiction certifies that it has adopted and is enforcing: (1) a
policy prohibiting the use of excessive force by law enforcement agencies within its
jurisdiction against any individuals engaged in non-violent civil rights demonstrations; and
(2) a policy of enforcing applicable State and local laws against physically barring entrance
to or exit from, a facility or location that is the subject of such non-violent civil rights
demonstrations within its jurisdiction.

(13) Compliance with anti-discrimination laws. The NSP grant will be conducted and
administered in conformity with title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d),
the Fair Housing Act (42 U.S.C. 3601-3619), and implementing regulations.

(14) Compliance with lead-based paint procedures. The activities concerning lead-
based paint will comply with the requirements of part 35, subparts A, B, J, K, and R of this
title.

(15) Compliance with laws. The jurisdiction will comply with applicable laws.

_________________________________                                      _____________
Signature/Authorized Official                                          Date

___________________
Title

PLEASE SEE ATTACHMENT FOR SIGNED CERTIFICATIONS AND SF - 424




                                                                                           169
        NSP Substantial Amendment Checklist
For the purposes of expediting review, HUD asks that applicants submit the following
checklist along with the NSP Substantial Amendment and SF-424.

                Contents of an NSP Action Plan Substantial Amendment
Jurisdiction(s): ____State of               NSP Contact Person: Lara Huskey
Nebraska___________                         Address:            PO Box 94666
Lead Agency Nebraska Department of          Telephone:           402-471-3759
Economic Development                        Fax:                 402-471-8405
Jurisdiction Web Address:                   Email:     lara.huskey@nebraska.gov
http://www.neded.org
(URL where NSP Substantial Amendment
materials are posted)

The elements in the substantial amendment required for the Neighborhood Stabilization
Program are:

A. AREAS OF GREATEST NEED
Does the submission include summary needs data identifying the geographic areas of
greatest need in the grantee’s jurisdiction?
        Yes X No .             Verification found on pages _2-11____.

B. DISTRIBUTION AND USES OF FUNDS
Does the submission contain a narrative describing how the distribution and uses of the
grantee’s NSP funds will meet the requirements of Section 2301(c)(2) of HERA that
funds be distributed to the areas of greatest need, including those with the greatest
percentage of home foreclosures, with the highest percentage of homes financed by a
subprime mortgage related loan, and identified by the grantee as likely to face a
significant rise in the rate of home foreclosures?
        Yes X No .               Verification found on pages ___11-_16_.

Note: The grantee’s narrative must address the three stipulated need categories in the
NSP statute, but the grantee may also consider other need categories.

C. DEFINITIONS AND DESCRIPTIONS
For the purposes of the NSP, do the narratives include:

   •   a definition of “blighted structure” in the context of state or local law,
       Yes X No . Verification found on page _16-18____.

   •   a definition of “affordable rents,”
       Yes X No .             Verification found on page _18-19____.




                                                                                         170
   •   a description of how the grantee will ensure continued affordability for NSP
       assisted housing,
       Yes X No . Verification found on pages _19-25____.

   •   a description of housing rehabilitation standards that will apply to NSP assisted
       activities?
       Yes X No .             Verification found on pages __25-39___.

D. LOW INCOME TARGETING
   • Has the grantee described how it will meet the statutory requirement that at least
      25% of funds must be used to purchase and redevelop abandoned or foreclosed
      upon homes or residential properties for housing individuals and families whose
      incomes do not exceed 50% of area median income?
      Yes X     No .       Verification found on page _39____.

   •   Has the grantee identified how the estimated amount of funds appropriated or
       otherwise made available will be used to purchase and redevelop abandoned or
       foreclosed upon homes or residential properties for housing individuals or
       families whose incomes do not exceed 50% of area median income?
       Yes X      No .        Verification found on page _39____.
                               Amount budgeted = $_5,000,000____.

E. ACQUISITIONS & RELOCATION
Does grantee plan to demolish or convert any low- and moderate-income dwelling units?
       Yes X       No . (If no, continue to next heading)
                              Verification found on page __40___.

If so, does the substantial amendment include:
     • The number of low- and moderate-income dwelling units—i.e., ≤ 80% of area
         median income—reasonably expected to be demolished or converted as a direct
         result of NSP-assisted activities?
         Yes X      No .        Verification found on page _40____.

   •   The number of NSP affordable housing units made available to low- , moderate-,
       and middle-income households—i.e., ≤ 120% of area median income—
       reasonably expected to be produced by activity and income level as provided for
       in DRGR, by each NSP activity providing such housing (including a proposed time
       schedule for commencement and completion)?
       Yes X      No .       Verification found on page _40____.

   •   The number of dwelling units reasonably expected to be made available for
       households whose income does not exceed 50 percent of area median income?
       Yes X     No .       Verification found on page __40___.




                                                                                        171
F. PUBLIC COMMENT PERIOD
Was the proposed action plan amendment published via the grantee jurisdiction’s usual
methods and on the Internet for no less than 15 calendar days of public comment?
      Yes X      No .        Verification found on page __41___.

Is there a summary of citizen comments included in the final amendment?
        Yes X    No           Verification found on pages _41-_70___.

G. INFORMATION BY ACTIVITY
Does the submission contain information by activity describing how the grantee will use the
funds, identifying:

   •   eligible use of funds under NSP,
       Yes X No . Verification found on pages _71-173____.

   •   correlated eligible activity under CDBG,
       Yes X No . Verification found on page __71-173___.

   •   the areas of greatest need addressed by the activity or activities,
       Yes X No . Verification found on page _71-173____.

   •   expected benefit to income-qualified persons or households or areas,
       Yes X No . Verification found on page _71-173____.

   •   does the applicant indicate which activities will count toward the statutory
       requirement that at least 25% of funds must be used to purchase and redevelop
       abandoned or foreclosed upon homes or residential properties for housing
       individuals and families whose incomes do not exceed 50% of area median
       income?
       Yes X      No .        Verification found on page _71-173____.

   •   appropriate performance measures for the activity,
       Yes X No . Verification found on page _71-173____.

   •   amount of funds budgeted for the activity,
       Yes X No .          Verification found on page _71-173____.

   •   the name, location and contact information for the entity that will carry out the activity,
       Yes X No .            Verification found on page _71-173____.

   •   expected start and end dates of the activity?
       Yes X No . Verification found on page _71-173____.

   •   If the activity includes acquisition of real property, the discount required for
       acquisition of foreclosed upon properties,
       Yes X No . Verification found on page _71-173____.

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   •   If the activity provides financing, the range of interest rates (if any),
       Yes X No . Verification found on page _71-173____.

   •   If the activity provides housing, duration or term of assistance,

       Yes X No      . Verification found on page _71-173____.

   •   tenure of beneficiaries (e.g., rental or homeownership),
       Yes X No . Verification found on page _71-173___.

   •   does it ensure continued affordability?
       Yes X      No .        Verification found on page _71-173____.


H. CERTIFICATIONS
The following certifications are complete and accurate:

(1) Affirmatively furthering fair housing                              Yes X       No
(2) Anti-lobbying                                                      Yes X       No
(3) Authority of Jurisdiction                                          Yes X       No
(4) Consistency with Plan                                              Yes X       No
(5) Acquisition and relocation                                         Yes X       No
(6) Section 3                                                          Yes X        No
(7) Citizen Participation                                              Yes X        No
(8) Following Plan                                                     Yes X        No
(9) Use of funds in 18 months                                          Yes X        No
(10) Use NSP funds ≤ 120 of AMI                                        Yes X        No
(11) No recovery of capital costs thru special assessments             Yes X        No
(12) Excessive Force                                                   Yes X        No
(13) Compliance with anti-discrimination laws                          Yes X       No
(14) Compliance with lead-based paint procedures                       Yes X        No
(15) Compliance with laws                                              Yes X       No




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