Tuesday, September 8, 2009

ANNUAL REPORT Update: Don’t Forget Certification Forms

Annual report certification forms are crucial, and no annual report is complete without them. There are two certification forms, and both may be downloaded from the ‘References’ tab, the rightmost tab on the web annual report. Since the certification forms must be signed by your chief elected official, you must mail them to Florida Housing to supplement your web-based annual reports.

The first certification form is very straight forward. It certifies the accuracy of the annual report. The second certification form addresses the implementation of regulatory reform activities. This form is one main method that Florida Housing uses to document a jurisdiction’s compliance with the requirement to implement a minimum of two “incentive strategies”.

Section 67-37.019 (5) of the SHIP Rule outlines the incentive strategy requirements for all SHIP jurisdictions:
The local government staff or entity with administrative authority for a local housing assistance plan shall provide documented evidence to the Corporation or its designated monitoring agent, that:
(a) Permits, as defined in Sections 163.3164(7) and (8), F.S., for affordable housing projects are expedited to a greater degree than other projects; and
(b) There is an ongoing process for review of local policies, ordinances, regulations, and plan provisions that increase the cost of housing prior to their adoption.

These two incentive strategies are often referred to as (a) Expedited Permitting and (b) Ongoing Review. Sections 1 and 2 of the regulatory reform certification are statements to evidence that the jurisdiction has implemented these two incentive strategies.

Section 3 asks for details resulting from your jurisdiction’s ongoing review process. You must report the estimated per unit cost increases for housing construction that have resulted from the creation of any new policies, ordinances, regulations, fees or plans during the most recently completed state fiscal year. In order to complete this form with accurate information, talk with the group or individual in your jurisdiction that performs the “Ongoing Review” responsibility. Ask them about their review process during the 12 months of this last fiscal year. If there have been no new policies to increase costs, enter $0.

Section 4 is very similar to Section 3. Provide the per unit estimated cost increases for rehabilitation activities that have resulted from new local policies, ordinances, regulations and more that were considered during the state fiscal year.

How should your jurisdiction go about estimating how much a particular policy will increase the cost of housing? The SHIP Statute and Rule provide no guidance or method by which a local jurisdiction must determine the cost increase. Such estimates are a local determination, and the jurisdiction should retain back up material to justify the dollar amounts reported on this certification form.

Every jurisdiction must submit their reports by next Tuesday, September 15th. The Coalition is available to help you ‘cross the finish line’ and submit your annual reports. This year, the Coalition is available on Tuesdays and Thursdays to provide this assistance through its technical assistance line: 800 677-4548. In addition, a full and updated collection of frequently asked questions about annual reports is available at http://faqannualreports.blogspot.com/.

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