Valerie F.

Leonard
4111 West 21st Place
Chicago, IL 60623
Phone: 773-521-3137 Fax: 773-521-3137
E-mail: valeriefleonard@msn.com

November 23, 2008

Ms. Ellisa Johnson, Grants Manager

Cook County Department of Planning and Development
69 W. Washington St. Suite 2900
Chicago, IL 60602-3007

Re: Public Comment-Neighborhood Stabilization Program Substantial Amendment

Dear Ms. Johnson:

It gives me great pleasure to provide public comment for the Cook County, Illinois Substantial Amendment to the
2008 Annual Action Plan. Please find my comments below.

B. Distribution and Uses of Funds

The Amendment indicates that all Cook County municipalities and current CDBG and HOME affordable housing
partners including non-profits and pre-qualified developers are eligible to participate in the NSP program. While I
believe it is important to provide funds to organizations that already have contracts with the County, I would strongly
encourage the County to broaden the base of delegate agencies.

We have seen situations in the past where ownership of a large concentration of public housing units or project
based Section 8 housing has proven to be unmanageable over time. One such example is the Chicago Housing
Authority, which had over 250,000 units of public housing at its peak. As a result of years of delayed maintenance
and high crime, the CHA decided to reinvent public housing under its Plan for Transformation. Another example is
the Lawndale Restoration project comprised of over 1,500 affordable rental units. Years of delayed maintenance,
building code violations and lack of access to capital resulted in the seizure of the properties by the federal
government. (This single action impacted 8% of North Lawndale’s housing stock, and 12% of the population.) These
units have been sold to several developers who have rehabbed them for mixed income for-sale and rental units.

Wherever possible, the County should encourage churches, local community based organizations and entrepreneurs
to purchase properties. To the extent that capacity is an issue, I recommend that NSP funds be leveraged with
programs such as HOME, and others, to build the capacity of churches and other community based entrepreneurs
and nonprofits to take advantage of the program.

The Amendment indicates that one of the NSP eligible uses is to establish financing mechanisms for the 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 homeowners. However, there
are no provisions to work with homeowners who are in danger of losing their homes.

If one of the criteria for targeting an area for NSP is the prevalence of subprime lending, then it makes sense to use
some of the funds to assist homeowners to refinance their homes at more favorable rates. Another option would be
to create a fund to purchase homes from persons who are in danger of foreclosure, and allowing them to rent them,
with an option to repurchase the homes at a later date. The accumulated rents could be used for a down payment.
Hopefully, this would help to stem the tide of displacement of local residents, while ensuring cash flow for the
investor.

G. Information by Activity

The Amendment indicates that the NSP program will provide a number of financing mechanisms. NSP funds will be
used to offer soft seconds. Cook County funds will include funding from the County Acquisition Loan Fund, gap
funding and County- supported specialized bank loan product for homebuyers. There is also provision for a revolving
loan fund for economic development. There are no amounts given for any of these mechanisms. Although the plan
calls for the use of some of the NSP allocation to be used for soft seconds, the entire $28,156,321 NSP allocation
has been allocated to other activities. There is no dollar amount allocated to the “Financing Mechanisms” line item,
either for NSP funds or other County funds.

I like the structure of the NSP Homebuyer Purchase and Rehabilitation Program. The County provides counseling
for homebuyers and engages CDBG and HOME delegate agencies to provide counseling technical assistance to
homebuyers on all aspects of the process, including site selection, rehab and financing.

Another potential strength of the program is the County’s use of NSP funds to address issues other than conventional
rental or for sale housing. For example, the plan calls for $2,000,000 to acquire and/or redevelop demolished or
vacant properties for public facilities, such as open space, hospitals, group homes for the mentally retarded, shelters
for battered spouses, and halfway homes for ex-offenders, etc. While these are all noble uses, these programs
should be coupled with robust supportive services in order to make the maximum positive impact to the local
community. The Department of Planning and Development should implement these activities in strong partnership
with other County agencies as applicable, including the President’s Office of Employment and Training, Chicago
Botanic Garden, Juvenile Temporary Detention Center, Health Services Bureau, Veterans Assistance Commission,
etc. The County should also engage its extensive network of nonprofit organizations to provide specific services as
needed.

The most innovative aspect of the plan is the leveraging of Cook County’s Green Manufacturing Assistance Initiative.
Cook County has already allocated $300,000 to assist the development of five (5) new business ventures and build
their capacity to incorporate “green” and energy efficient approaches to building construction and land development
in all NSP-funded homeownership and rental housing rehabilitation and redevelopment projects. An additional
$1,000,000 NSP funding will be used for the five microenterprises to work with the development and general
construction contractors and separately bid, compete, contract and implement green initiatives in NSP-funded
rehabilitation and redevelopment projects including public facilities. Over 150 housing units are candidates for “green”
initiatives at an average cost of $5,000 - $6,000 per unit. This activity is expected to create 5 new jobs. I believe this
initiative may be further strengthened by leveraging resources of the President’s Office for Employment and Training,
local colleges, and nonprofit organizations to source cutting edge opportunities for people who feel a need to learn
new job skills. This would be particularly critical in the South Suburban areas, which have been devastated by job
losses in manufacturing.

Community Participation

The excerpt from the Cook County Code regarding blighted areas could also be applicable to TIF districts and
conservation areas. If one of the implicit uses of the NSP is to leverage TIF dollars, I recommend that, where
applicable, a local TIF oversight panel comprised of a broad cross-section of community stakeholders provide advice
into the use of the NSP funds. This body should include local residents, business leaders, community based
organizations, representatives from the public sector and philanthropic community. Ideally, there should be a clear
separation of the planning, development, investment and advisory functions, with no conflicts of interest between the
members of this body, local planners and developers.
If such bodies do not exist in the NSP target area, then the community advisory committee that provides advice into
the use of the County’s CDBG funds should perform this function. The advantage is the countywide advisory group
would not be closely tied to the politics of the local community, and can be more objective in its advice. This could
also be a weakness, as the countywide body may not be as familiar with the nuances that are specific to an individual
community.

At a very minimum, the County should host public meetings periodically informing the public of the program, its goals
and objectives, and progress towards those goals. Because the County is so large, it may be helpful to have these
meetings digitally recorded for CAN TV and for your website.

Marketing Considerations

I had an opportunity to attend a housing symposium sponsored by the (City of Chicago) Mayor’s Office for People
with Disabilities on November 17, 2008. One of the developers in attendance lamented that he built a development
financed by New Homes for Chicago, and complied with the requirement to make 25% of the units accessible for
people with disabilities. He has been unsuccessful in selling the units, and program guidelines won’t allow him to rent
them. Apparently there is a significant gap between the price of the homes which were reportedly selling in the
$250,000 range and the ability of low income people with disabilities to purchase them.

To the best of my recollection, the moderator indicated that many people with disabilities are living below the poverty
line. Many of the housing options have issues with accessibility, affordability, and crime. These issues should be
addressed as the program is developed more fully. I did note that the County’s plan already provides for the rental of
for sale housing units that cannot be sold within a reasonable timeframe.

Also, the NSP program could create opportunities to address the growing need for affordable, accessible senior
housing in Cook County by retrofitting units for seniors who would like to “age in place”, as opposed to moving to
senior living facilities or nursing homes.

In closing, I would like to thank you for your time and consideration of my comments. It is my sincerest hope that you
might be able to incorporate some of these ideas into the final NSP design. If you have any questions, please feel
free to call me at 773-521-3137, or e-mail me at valeriefleonard@msn.com.

Sincerely,

Valerie F. Leonard