2017-06-28 Housing Authority Item H1 Commentsvvmt S l I\J C-r- Z( rq f �'� T(- � G M 1 1 S
Kathy Noel
DFrom: Diane Langager
ent: Monday, June 26, 2017 6:17 PM
To: Parisa Ijadi - Maghsoodi
Cc: Kathy Noel; Nikki Photinos; Jessica Porter Oporter @quadel.com); Nicole Piano
Subject: RE: Public Comment Section 8 Admin Plan and Request for LEP Analysis
Attachments: Household Language by Limited English (ACS 2011- 2015).pdf
Dear Ms. Parisa Ijadi- Maghsoodi, Esq.:
The LEP dated November 2011, available at the following link:
http: / /www.encinitasca.gov /Portals /0/ City %2ODocuments / Documents / Planning /CommunitV ° /o2OServicesO,,,2ODo
cuments /Housing /LEP°620Plan.pdf is the current LEP that is utilized by the Encinitas Housing Authority
(EHA).
Based on the revised wording proposed for Section 3.7, the EHA will periodically review the need for an update
(no less often than concurrently with the Five Year PHA Plan process). The next update to the PHA is due in
2020; it is anticipated that we will assess the language needs of the City in more detail starting in summer of
2019. However, it should be noted that to date it has been EHA staff experience that the only request for
language assistance has been for Spanish. Bi- lingual staff is available to provide assistance to the EHA staff
from other departments located in the same facility (Encinitas City Hall) as the EHA staff. Additionally, based
on your comments we reviewed data in the 2011 -2015 American Community Survey (ACS) regarding
Household Language by Household Limited English Speaking Status and it appears that English and Spanish
is the primary language spoken in Encinitas. Based on staff experience and the ACS data it does not appear
that there have been any significant changes in the composition or language needs of the LEP population that
warrants an update to the LEP.
Owe thank you for your comments and interest in the update to the EHA Administrative Plan.
Sincerely,
Diane S. Langager
Principal Planner
City of Encinitas
505 S. Vulcan Avenue
Encinitas, CA 92024
P 760 633 -2714
F 760 633 -2818
dlangag CC7 encinitasca.c�ov
From: Parisa Ijadi- Maghsoodi [ mailto: parisa .ijadi.maghsoodi @gmail.com]
Sent: Thursday, June 22, 2017 3:03 PM
To: Diane Langager
Cc: Kathy Noel; Nikki Photinos; Jessica Porter (jporter@quadel.com); Nicole Piano
Subject: Re: Public Comment Section 8 Admin Plan and Request for LEP Analysis
Dear Ms. Langager,
Many thanks for this information and for the timely response.
Onfortunately, I was unsuccessful in locating the LEP Plan referenced in EHA's response to my second
comment.
The only LEP Plan available on the Encinitas relies on data from 10 years ago (2008 -2010 U.S. Census), I trust
that your office has a more updated LEP Plan and analysis.
Would you please provide me with the link to the current LEP Plan?
Thank you.
Sincerely,
Parisa
On Thu, Jun 22, 2017 at 1:52 PM, Diane Langager <DLan�ager@encinitasca.gov> wrote:
Dear Ms. Parisa Ijadi - Maghsoodi, Esq.:
The Encinitas Housing Authority (EHA) thanks you for your comments regarding the proposed amendments to
the Section 8 Housing Choice Voucher Program Administrative Plan. A response to your comments is
attached; in the attached your comments are noted followed by staff response.
Thanks for your interest in the Administrative Plan of the Housing Choice Voucher Program of the EHA.
sincerely,
Diane S. Langager
Principal Planner
City of Encinitas
505 S. Vulcan Avenue
Encinitas, CA 92024
P 760 633 -2714
F 760 633 -2818
dlangag(d )encinitasca.gov
2
From: Kathy Noel
Sent: Thursday, June 22, 2017 1:33 PM
To: Diane Langager
Oubject: FW: Public Comment Section 8 Admin Plan and Request for LEP Analysis
From: Parisa Ijadi- Maghsoodi [ mailto: parisa .ijadi.maghsoodiCabgmail.com]
Sent: Friday, June 16, 2017 4:16 PM
To: Nikki Photinos
Subject: Public Comment Section 8 Admin Plan and Request for LEP Analysis
Dear Nikki Photinos.
I am writing to express concerns with the proposed changes to the Section 8 HCVP Administrative Plan pursuant to the attached
Public Comment Notice.
The Payment Standard section is vague and misleading. It fails to notify potential program applicants. program applicants.
program participants, and the general public about one's right to request an Exception Payment Standard beyond 120 '10 of the
FMR. Ensuring that EHA's Exception Payment Standard language is simple to understand and not misleading ensures the
above mentioned individuals can understand and request Exception Payment Standards, which can significantly improve the
0conomic health of low- income families.
The Exemption Payment Standard information is clearly stated in HUD's HCVP Guidebook and EHA can simply use the
language from the Guidebook. As written, the Administrative Plan does not state that EHA can request HUD approval to adopt
Exception Payment Standards above 120% FMR. Given the high cost of living in Encinitas, the lack of rent control, and the
current housing and homelessness crisis low- income San Diego County residents are experiencing, the Exception Payment
Standard section should not be vague and misleading, but clear and easy to understand.
EHA's Language Access Plan and Limited English Proficiency section does not reference the LEP analysis EHA conducted in
determining that no written translation would be provided and no LEP plan written.
Given that EHA's Proposed Plan cites the Federal Register guidance about the LEP analysis, it only makes sense that such an
analysis was conducted. The data EHA collected to conduct the analysis (the current total population within EHA's jurisdiction.
the current total population of LEP individuals within ERA's jurisdiction, and the current total population of Spanish speaking LEP
individuals within ERA's jurisdiction) and EHA's analysis of the data that demonstrated to EHA its ability to avoid having an LEP
plan or written translation of vital documents needs to be provided to the general public.
The City should provide the data and analysis on the website where the Proposed Plan is located before the end of the Public
0omment period as specified in the Public Comment Notice.
Thank you.
Sincerely,
Oarisa Ijadi - Maghsoodi, E,y.
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