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regional Alameda County HOME Consortium Analysis of Impediments zo Fair Housing (AI). The City will also continue to implement its fair housing action plan through ECHO Housing, a fair housing counseling agency which provides services to very low- and moderate-income clients. The HUD Office of Fair Housing and Equal Opportunity (FHEO) conducted an on-site compliance review of the CDBG and other City housing/community development programs in November 2007 to determine whether the CDBG program is administered in compliance with the nondiscrimination provisions of Section 109, Title VI, and Section 504. The City has executed an Agreement for Voluntary Compliance (VCA) with HUD FHEO to update and/or revise its policies and procedures to ensure compliance with federal equal opportunity and fair housing regulations. PUBLIC HOUSING IMPROVEMENTS AND RESIDENT INITIATIVES San Leandro is under the jurisdiction of the Alameda County Housing Authority and has no public housing. HUD Section The HUD Section 108 Loan Guarantee Program is a debt financing program through the CDBG Program to help communities leverage CDBG dollars for community development or revitalization activities such as economic development, capital improvements, housing rehabilitation. Local governments which utilize the Section 108 loans must pledge current and future CDBG allocations (or other local funding sources) as security for the loan. HUD's formula far calculating how much a local government may borrow under Section 108 is five times its latest CDBG entitlement grant minus any outstanding Section 108 principal loan balances. The City has currently has an outstanding Section 108 loan for the land acquisition relating to the Broadmoor Plaza affordable senior rental housing development. HUD recently calculated that the City currently has the capacity to apply for up to $2.85 million in Section 108 loan funds. The City is preparing a Section ] 08 loan application for $2.5 million, which is needed to complete the construction of the City's new senior center in FY 09-10. The senior center is a high priority in the City's current Five Year HUD Consolidated Plan and furthers the CDBG national objective of benefitting low- and moderate income persons, particularly seniors. The City will pledge future CDBG funds to repay the $2.5 million loan over 20 years. City staff estimates that the annual average loan repayment (principal plus interest) will be $173,500 with the interest payments declining over time as the principal balance is paid down. The City does not project any program income from the senior center. The draft Section 108 loan application will be available for public review and comment on the City website and at City Hall and the Main Library fora 30 day period (March 20 -April 20, 2009) and Council will review the final application on Apri120, 2009. . Draft Action Plan - FY2D09-10 City of San Leandro Page 17