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second challenge is the willingness of some property owners to undertake lead -paint <br />removal after it has been identified through testing. Several property owners have <br />dropped out of the City's housing rehabilitation programs after lead had been <br />identified in their home. Reasons given included an unwillingness to endure the <br />added time (and possible temporary displacement) needed to undertake lead -paint <br />removal or to borrow more money to undertake lead -paint removal work. <br />Nonetheless, all owner occupied housing units rehabilitated during the report period <br />were tested for lead paint hazards (average cost per test - $250). Program staff <br />estimates that procedures implemented to comply with Title X have added a <br />minimum of 30 days to the typical housing rehabilitation project. <br />7. ACTIONS TAKEN TO ENSURE COMPLIANCE WITH PROGRAM AND COMPREHENSIVE PLANNING <br />REQUIREMENTS AND MONITORING: HUD has established specific requirements for <br />implementation of the Consolidated Plan. Santa Ana has made every effort to <br />ensure compliance with these comprehensive planning requirements. <br />Requirements include holding public hearings, public comment periods, and <br />ensuring adequate public notification of these and other actions. The City also has <br />made every effort to comply with all regulations for respective programs. As <br />necessary, the assistance of HUD's Los Angeles office has been sought. During the <br />2003 -2004 report period, HUD's Los Angeles office conducted an on -site monitoring <br />of the City's CDBG program. HUD staff provided several constructive <br />recommendations. One significant finding was the use of CDBG resources to fund <br />the Code Enforcement PREP program. It was HUD's finding that the PREP <br />program had been created by the City with its own independent funding sources that <br />was sufficient to sustain it over the course of several years, yet CDBG was still <br />allocated to the program. HUD directed the City to discontinue the use of CDBG for <br />the PREP program. This recommendation was implemented in the 2004-2005 - <br />report period. <br />8. ACTIONS TO REDUCE THE NUMBER OF PERSONS LIVING BELOW THE POVERTY LEVEL: Santa <br />Ana's anti - poverty strategy includes the identification of low- income residents <br />needing housing and support service assistance, and coordinating public and <br />private resources to address these needs. Services and activities that were <br />supported by the City during the report period included: <br />■ Affordable housing programs including rehabilitation, rental assistance, and <br />creation of new affordable housing units via acquisition /rehabilitation activities. <br />■ Homeless assistance including prevention activities, emergency shelter, <br />transitional housing, and access to permanent housing opportunities. <br />Appropriate support services were blended with these activities. <br />■ Public safety activities to prevent criminals from victimizing the poor. <br />■ Public facility improvements to improve the overall infrastructure of the City, but <br />more specifically for older neighborhoods. <br />22 <br />19E -25 <br />9/9/04 <br />