REPORT TO COUNCIL
SUBJECT
Title
Public Hearing: Opportunity for Public Comment on the Final version of the 2020-2025 Consolidated Action Plan and the final version of the 2020-2021 Annual Action Plan for U.S. Department of Housing and Urban Development Funds (CDBG & HOME) [Council Pillar: Promote and Enhance Economic and Housing Development]
Report
BACKGROUND
As an “entitlement jurisdiction,” the City of Santa Clara receives annual funding from the United States Department of Housing and Urban Development (HUD) in the form of Community Development Block Grant (CDBG) and Home Investment Partnerships Program (HOME) funds. CDBG funds are used to provide public services to Santa Clara’s low-income residents and funding for capital improvement projects. HOME funds are generally used for the development of affordable housing programs.
Entitlement jurisdictions are required by HUD to develop a Five-Year Consolidated Action Plan (ConPlan) that identifies goals and needs within the community that could be addressed using annual HUD funding allocations. The ConPlan is a five-year planning document that covers the period of fiscal year 2020-2021 through fiscal year 2024-2025. The City of Santa Clara worked collaboratively with the County of Santa Clara and other entitlement jurisdictions in the County to identify and prioritize housing-related needs across the region, and strategies to meet those needs through the ConPlan. The entitlement grantee jurisdictions involved in the collaborative outreach efforts included: City of Cupertino, City of Gilroy, City of Mountain View, City of Palo Alto, City of San José, City of Santa Clara, City of Morgan Hill, and City of Sunnyvale.
The City is also required each year to prepare an Annual Action Plan (AAP) to document how the City will use HUD funding consistent with the goals and needs identified in the current ConPlan. Preparation of both plans must allow for public input through a 30-day comment period (April 1, 2020 - May 5, 2020), and two public hearings: one during the drafting phase and one to present the final version prior to submission to HUD for approval. The first public hearing and opportunity for public comment was held at the March 31, 2020 City Council meeting. Tonight’s hearing serves as the second and final formal opportunity for public comment.
DISCUSSION
The City Council is being asked to take public input on both the ConPlan and AAP documents and adopt both Plans prior to submission to HUD on or before May 15, 2020.
Consolidated Plan (ConPlan)
The proposed 2020-2025 ConPlan was prepared through a regional collaborative effort undertaken by the County of Santa Clara and eight entitlement cities within the County. The County hired a consultant, Michael Baker International, to conduct a community engagement process to identify needs, priorities, goals, strategies, and activities for future housing and community development activities which the County should collectively address over the five-year ConPlan period. Engagement activities included a community survey, public outreach, stakeholder consultations, focus groups, and “pop-up” outreach events. City staff also held two public meetings on November 14, 2019. The results of this combined effort were synthesized and analyzed to identify goals and needs within the community that could be addressed by each participating jurisdiction using their annual HUD allocations of CDBG and HOME funds.
ConPlan Goals as identified through the collaborative outreach process:
Goal Name Goal Description
Affordable Housing Assist in creation and preservation of affordable housing for
low-income and special needs households through the
continuation of the Neighborhood and Community
Improvement Program (NCIP), rehab of rental units occupied
by low income tenants, tenant-based rental assistance
(TBRA) rental subsidies, and new construction.
Homelessness Support activities, consistent with Continuum of Care
strategies, to prevent and end homelessness. This includes
building affordable housing for people who are homeless or at
risk of homelessness as well as the provision of support
services.
Public Services Support activities that provide basic needs to lower income
households and special needs populations. Services would be
provided to low-income households, elderly individuals,
homeless persons, people with disabilities, and victims of
domestic violence.
Fair Housing Promote fair housing choice, through the following activities:
fair housing education, fair housing testing, housing
assistance hotline, and landlord-tenant mediation.
Public Facilities Improve accessibility for persons with physical disabilities by
identifying and repairing intersections for accessibility, mostly
through installation of sidewalk curb cuts.
The ConPlan also identifies Goal Outcome Indicators to evaluate the performance of the AAP activities.
Goals Summary for 5-Year ConPlan Cycle
Annual Action Plan (AAP)
The 2020-2021 AAP is a one-year Plan that directs how the HUD funds will be spent on projects and activities to address Goals identified in the ConPlan. The following table details the City’s Expected Resources for FY2020-2021 and the types of projects/activities that will be funded.
Expected Amounts Available
Annual Action Plan (AAP)
In addition to its normal annual entitlements for HOME and CDBG, the City anticipates receiving two one-time CDBG entitlements for 2020-2021 of approximately $1,500,000. These entitlements are part of the $2.2 trillion Coronavirus Aid, Relief, and Economic Security (CARES) stimulus package to help address the COVID-19 Crisis. In response, staff is developing an Emergency Rental Assistance Program (ERAP) to assist low-income Santa Clara residents affected by COVID-19. The program is meant to provide one-time emergency financial assistance to low-income families and individuals who incurred rental arrears beginning on April 1, 2020. Program applicants will be asked to verify that arrears were incurred due to substantial impacts to income caused by COVID-19. The City’s Eviction Moratorium allows tenants who are financially affected by COVID-19 to avoid eviction if they are not able to pay their rent; however, once the moratorium ends, many residents will have significant arrears and become at risk of homelessness. Staff is working with Bill Wilson Center as the proposed administrator of funds. The City anticipates assisting approximately 200 households with funds available starting July 1, 2020.
HUD has also waived several HOME requirements to help grantees address the COVID-19 crisis. One of the waivers the City requested - and HUD has granted - is the ability to use Community Housing Development Organization (CHDO) set aside funds from 2017-2020 for Tenant Based Rental Assistance (TBRA) activities. This will allow the City to invest approximately $220,000 of CHDO funds to expand the City’s TBRA program, which assists families at risk of homelessness. These CHDO funds have been a challenge to spend over the past Con Plan cycle, and this waiver allows the City to use these funds and avoid the risk of funds being recaptured by HUD.
As part of the AAP, the City also identifies a proposed distribution of CDBG funds to Public Service Agencies (PSAs). PSAs are local non-profits that provide services within the community which are eligible to receive CDBG funding. The City allows PSAs to apply for funding on a three or two-year cycle. HUD restricts the amount of funds that can be set aside for Public Service Agencies. Of the $1,850,000 for FY2020-2021 of CDBG funds, $252,006 is set aside for this purpose. Based upon the applications received for the current cycle, staff is recommending the following distribution of funds.
Proposed CDGB Funding Distribution to PSAs
Public Service Agency Funded Requested Funded Served
Bill Wilson Center - Family Therapy $50,000 $35,000 160
Bill Wilson Center - Family Advocacy $45,000 $35,000 107
The Health Trust - Meals on Wheels $40,645 $27,825 20
Santa Clara Senior Center Nutrition Program $24,000 $24,000 800
SVILC Housing for Persons with Disabilities $20,000 $18,000 57
Next Door Solutions Crisis & Support $20,000 $19,177 69
Senior Adult Legal Assistance $24,000 $16,500 90
Live Oak Adult Day Services $20,000 $15,000 11
Catholic Charities - Long Term Care Ombudsman $15,000 $10,000 375
Heart of the Valley Volunteer Coordinator $15,000 $15,000 249
HOPE Services - Educational Enrichment $74,904 $36,504 126
YWCA Domestic Violence Services $15,000 $0 n/a
IEP Collaborative - Assistance for Students w/IEPs $15,000 $0 n/a
TOTAL $378,549 $252,006
Attachment A (“Funding Proposals Summary”) provides a more detailed breakdown of the City’s FY20-21 Expected Resources and how staff proposes to spend said resources. Attachment A details the proposed Public Service Agencies and their funding levels as well as funds set aside for Capital Improvements (e.g., the City’s Neighborhood Conservation Improvement Program, Rebuilding Together Minor Home Repair program, and LifeMoves Generator Purchase project). Further, Attachment A details HOME fund resources and activities.
PSA submissions were ranked based on whether the proposed activity was deemed a high priority in the ConPlan, years of service, amount of funds leveraged, the majority of beneficiaries to be served that were extremely low and low income, and the agency’s history of drawing funds down. Other considerations were number of people served versus amount of funds granted, and whether other agencies provide similar services.
Staff is asking City Council to consider the recommendations and any public comment received in order to direct staff to approve these recommendations, or to make any necessary changes or adjustments as provided by City Council. Approved agencies will enter into one-year contracts with the option to renew for a second- and third-year subject to Federal appropriations.
ENVIRONMENTAL REVIEW
The action being considered does not constitute a “project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines section 15378(b)(5) in that it is a governmental organizational or administrative activity that will not result in direct or indirect changes in the environment.
FISCAL IMPACT
The estimated resources for FY20/21 are $1,850,000 in CDBG funds, $1,800,000 in HOME funds, $1,500,000 in CDBG COVID-19 funds, $95,000 in the General Fund, $275,697 in the City Affordable Housing Fund and $250,000 in the Housing Successor Agency Fund for a total investment of $5,770,697. This proposed allocation of the City’s available resources would be used to support the goals set forth in the City’s Consolidated Plan.
After approval of the FY 2020/21 Final Annual Action Plan, changes to the CDBG and HOME FY20/21 federal entitlement funds will be incorporated as part of the revised budget amendments to FY20/21 Operating Budget. The budget amendments currently align with the draft Annual Action Plan. No adjustments are necessary for the General Fund, City Affordable Housing Fund and Housing Successor Agency Fund.
COORDINATION
This report has been coordinated with the Finance Department and City Attorney’s Office.
PUBLIC CONTACT
Public contact was made by posting the Council agenda on the City’s official-notice bulletin board outside City Hall Council Chambers. A complete agenda packet is available on the City’s website and in the City Clerk’s Office at least 72 hours prior to a Regular Meeting and 24 hours prior to a Special Meeting. A hard copy of any agenda report may be requested by contacting the City Clerk’s Office at (408) 615-2220, email clerk@santaclaraca.gov <mailto:clerk@santaclaraca.gov> or at the public information desk at any City of Santa Clara public library.
Preparation of the ConPlan follows a procedure determined by HUD and has included two public hearings to identify community needs and objectives, and to review priorities for the City’s HUD funding allocations. The first public hearing was held at the March 31, 2020 Council Meeting, and the second will be held at the May 12, 2020 City Council meeting. Comments made at the two public hearings will be noted in the final ConPlan. At the first public hearing several non-profit agencies submitted public comment via email. A representative from Bill Wilson Center spoke on the need to have an emergency rental assistance program to assist tenants affected by the COVID-19 crisis. At the hearing staff recommended that such a program to be funded with CDBG-CV stimulus funds.
The ConPlan and Annual Action Plan were made available for public review and comment for a 30-day period from April 1 - May 5, 2020. Noticing of the 30-day public comment period was published on March 11, 2020 in The Santa Clara Weekly. Noticing was also e-blasted to community stakeholders and posted on the City Manager’s blog. The Plans were also made available on the City’s website, and at public locations including the City Clerk’s Office, the Housing and Community Services Division, and City libraries. Notification of the availability of both Plans were also emailed to interested parties which include local nonprofit agencies.
ALTERNATIVES
1. Note and File Public Comment on the 2020-2025 Consolidated Action Plan and FY2020-2021 Annual Action Plan for U.S. Department of Housing and Urban Development Funds (CDBG & HOME).
2. Approve the 2020-2025 Consolidated Plan and FY2020-2021 Annual Action Plan, and direct staff to incorporate all public comments to be submitted to HUD by or before May 15, 2020.
3. Any other Council direction.
RECOMMENDATION
Recommendation
1. Note and File Public Comment on the 2020-2025 Consolidated Action Plan and FY2020-2021 Annual Action Plan for U.S. Department of Housing and Urban Development Funds (CDBG & HOME); and
2. Approve the 2020-2025 Consolidated Plan and FY2020-2021 Annual Action Plan, and direct staff to incorporate all public comments to be submitted to HUD by or before May 15, 2020.
Staff
Reviewed by: Andrew Crabtree, Director of Community Development
Approved by: Deanna J. Santana, City Manager
ATTACHMENTS
1. 2020-2025 Consolidated Action Plan
2. 2020-2021 Annual Action Plan
3. FY20/21 HUD Funding Proposal - Attachment A
4. Public Comment for ConPlan & Action Plan (March 31, 2020)