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Staff Report 4485
City of Palo Alto (ID # 4485) Finance Committee Staff Report Report Type: Action Items Meeting Date: 4/15/2014 City of Palo Alto Page 1 Summary Title: Fiscal Year 2015 CDBG Allocations Title: Recommendations On Proposed Fiscal Year 2015 Community Development Block Grant Funding Allocations and the Draft Fiscal Year 2015 Annual Action Plan From: City Manager Lead Department: Planning and Co mmunity Environment Recommendation Staff recommends that the Finance Committee recommend that the City Council take the following actions: 1. Allocate CDBG funding as recommended in the draft 2015 Action Plan and as described in this report; 2. Authorize the City Manager to execute the 2015 CDBG application and 2015 Action Plan for CDBG funds, any other necessary documents concerning the application, and to otherwise bind the City with respect to the applications and commitment of funds; and 3. Authorize staff to submit the 2015 Action Plan to HUD by the May 15, 2014 deadline. Executive Summary The City of Palo Alto receives funds annually from the U.S. Department of Housing and Urban Development (HUD) as an entitlement city under the Community Development Block Grant (CDBG) Program. CDBG is the principal Federal program providing localities with grants to devise innovative and constructive neighborhood approaches to improve the physical, economic, and social conditions in their communities through “the developm ent of viable urban communities, by providing decent housing and a suitable living environment and expanding economic opportunities, principally for persons of low and moderate income.” HUD requirements include preparation of a five-year strategic plan of action, referred to as a Consolidated Plan, to address priority housing and community development needs and to set goals for attaining identified objectives. On May 3, 2010, the City Council adopted the City’s City of Palo Alto Page 2 2010-2015 Consolidated Plan. An Action Plan is prepared annually to identify specific projects to be funded in that year that implement the strategies identified in the Consolidated Plan. The draft 2015 Action Plan (Attachment C) has been made available for Public review from March 17, 2014 through April 18, 2014. The Finance Committee is being asked to review the draft Action Plan and funding recommendations. Upon review of the draft plan and funding recommendations, it is requested the Finance Committee make recommendations to the City Coun cil. The City Council will review the recommendations of the Finance Committee at a public hearing scheduled for May 5, 2014. Staff will then submit the Action Plan to HUD in order to meet the May 15, 2014 deadline. Background The CDBG program is authorized under Title I of the Housing and Community Development Act of 1974, as amended. As an entitlement city under the CDBG program, the City of Palo Alto receives funds annually on a formula grant basis. Over the past three years the City has received approximately $443,000 annually in entitlement funds. Palo Alto has historically expended all of its CDBG funds on projects benefiting low- and very-low-income persons. HUD regulations require all CDBG funded activities meet one of the three national o bjectives: Benefit low-and very-low-income persons; Aid in the prevention or elimination of slums or blight; or Meet other community development needs having a particular urgency, or posing a serious and immediate threat to the health or welfare of the com munity. All of the funded projects in Palo Alto meet the first objective of benefiting low -and very-low- income persons. Palo Alto has five primary CDBG program activity a reas in which to allocate funds: Public Services, Planning and Administration, Econo mic Development, Housing, and Public Facilities. Federal regulations limit the amount that can be spent on Administration and Public Services. The allocations for administrative activities and public services are both proposed to be at the maximum spending cap in FY 2015. No more than 20 percent of the City’s entitlement grant and estimated program income for the following year can be spent on Administration. It is estimated that $113,996 will be available for administration activities for Fiscal Year 2015. Similarly, Federal law places a maximum spending cap of 15 percent of the grant allocation and 15 percent of any program income received during the previous fiscal year on public services. It is estimated that $95,320 will be available for public service activities for Fiscal Year 2015. Public service activities include services for homeless persons, housing and emergency services to low income individuals with disabilities, and services to victims of domestic violence. City of Palo Alto Page 3 The City received its final funding allocation amount of $433,993 from HUD on March 19, 2014. Action Plan HUD requires submittal of an Annual Action Plan no later than 45 days prior to the start of the program year, or May 15th of every year, that identifies the specific projects to be funded to implement strategies identified in the Consolidated Plan. On May 3, 2010, the City Council adopted the 2010-2015 Consolidated Plan, a five-year strategic plan of action that addresses priority housing and community development needs. CDBG Applications Currently, the CDBG program operates under a two-year funding request cycle. Applications for Fiscal Years 2014 and 2015 were made available in November 2012. A notice of CDBG funding availability was published in the Palo Alto Weekly on November 9, 2012 with completed applications due January 8, 2013. Mandatory proposal -writing workshops were conducted on November 28, 2012 and December 20, 2012 to assist applicants with program regulations and project eligibility questions. The CDBG applications considered for funding for Fiscal Year 2015 are identified on the attached chart (Attachment A). During this funding cycle the City did not receive any funding applications for housing or public facilities improvement projects. Fiscal Year 2015 is the second year in the funding cycle and allocation of funds is now required. Citizen Participation A Citizen Participation Plan is a required component of the CDBG Program. HUD regulations require CDBG recipient agencies to prepare and implement a plan that provides adequate opportunity for citizens to participate in an advisory role in the planning, implementation, and assessment of the CDBG program. On October 18, 2010, the City adopted an amended Citizen Participation Plan and shifted the CDBG advisory role from a separate Citizens Advisory Committee to the established Human Relations Commission (HRC). In summary, the intention of the new plan was to provide a collaborative link between the CDBG funding process and the Human Service Resource Allocation Process (HSRAP). The HRC is now charged with reviewing funding recommendations for the City’s two human service funding sources. A sub -committee comprised of staff and two members of the HRC was established to review both the CDBG and HSRAP funding applications and to provide recommendations to the full commission. While both CDBG and HSRAP are operating on a two-year funding cycle, final CDBG funding recommendations need to be reviewed annually since the budget is contingent upon funding allocations received from HUD. The sub-committee met on March 3, 2014 at City Hall to City of Palo Alto Page 4 discuss the Fiscal Year 2015 CDBG budget, identify a contingency plan as recommended by HUD, and recommend funding amounts based on the estimated funds available. On March 13, 2014 the HRC considered the funding recommendations of the s ubcommittee and voted to recommend that the City Council Finance Committee and the City Council approved the funding allocation amounts. A total of four public service providers spoke abo ut the services they provide through the CDBG Program and thanked the City for their continued support. Commitment of Funds HUD regulations require that CDBG funds be expended in a timely manner. Specifically, the regulatory requirement is that no more than 1.5 times a jurisdiction’s annual entitlement grant amount remain in the City’s Letter of Credit 60 days prior to the end of the program year. In an effort to reduce the backlog of unspent CDBG funds, HUD employs monetary sanctions against jurisdictions that exceed this timeliness requirement. For this reason, all funding a pplications are scrutinized to ensure the readiness of the program or project to move forward and expend funds in a timely manner. Discussion Palo Alto’s CDBG program continues to be directed towards expanding and maintaining existing affordable housing supply, promoting housing opportunities and choices, maintaining and improving community facilities, and providing supportive services for targeted low -income groups including persons who are homeless, persons with disabilities, the elderly, and other special needs groups. Moreover, the CDBG program places a high priority to expand the goal of creating economic opportunities for low-income persons. All of the proposed projects for CDBG funding for Fiscal Year 2015, as presented in the draft 2015 Action Plan, address the priority housing and community development needs identified in the Consolidated Plan. Fiscal Year 2015 Funds Available for Allocation On March 19, 2014 the City received its final funding allocation amount from HUD. The amount represents a reduction of $23,551 from the projections used by staff for planning purposes. This year HUD asked grantees to include contingency provision language in their action plan that explains how it will adjust its proposed plan to match its actual allocation amounts once they are known. The selection committee was charged with reviewing the following two contingency provision options: Option 1 – All proposed activities’ budgets will be proportionally increased or decreased from the estimated funding levels to match actual allocation amounts. City of Palo Alto Page 5 Option 2 – Each grantee will receive an amount which represents a proportional share of funds as the amount originally allocated for each funding category, up to the amount requested with the balance of funds distributed amongst the remaining agencies. The Selection Committee agreed that “Option 2” reflects the priority in funding that was placed on the Opportunity Services Center and the SRO Resident Support Program that was set by the Selection Committee during the Fiscal Year 2014 funding allocations. Under this option, regardless of what the final allocation amounts are, each agency w ill receive the same percentage of the allocation to be budgeted to each activity. For instance, the Opportunity Services Center will receive approximately 47% of the public service dollars regardl ess of the funding allocation. The HRC reviewed the two contingency provisions at a public hearing on March 13, 2014 and concurred with the Selection Committee’s recommendation. Staff has applied the selected contingency provision to update the recommendations made by the HRC based on the final allocation amounts and funding limitations placed on two fundin g categories. As part of the contingency plan, staff recommended that not all of the funding available for allocation be programmed for this year. Instead, staff asked the selection committee to consider deferring the allocation of un-programmed funds to mitigate the impact from a potential significant reduction in the final allocation amounts from HUD. Specifically, staff recommended that the $72,787 balance from two prior year projects be retained as contingency funds. The selection committee agreed with Staff’s recommendation. Since then, CDBG staff has received information on additional program income and there is now an additional $73,491 of unanticipated program income expected during Fiscal Year 2014 that has not been allocated. In total there is $213,651 in unallocated CDBG funds available for allocation. Based on the foregoing, the total amount available for allocation in Fiscal Year 2015 is estimated to be $783,633 as summarized below: $433,933 Estimated Fiscal Year 2015 Entitlement Grant $136,049 Estimated FY 2015 Program Income from Palo Alto Housing Corporation that is generated from rental income in excess of expenses on specific properties acquired or rehabilitated with CDBG funds. $72,787 Reallocated Funds from Previous Years: $46,998 – Palo Alto Housing Corp. California Park Rehab (FY2013) $25,789 – Community Working Group Alma Garden Rehab (FY2012) $140,866 Estimated excess FY 2014 Program Income $65,375 –rental income City of Palo Alto Page 6 $ 7,000 – Loan Repayments from Housing Improvement Program $68,491 – Sheridan Loan Repayment $783,635 ESTIMATED TOTAL AVAILABLE FOR ALLOCATION As discussed above, these totals have been updated to reflect the final allocation amount and to provide a more detailed illustration of the funds available f or allocation. Of the $783,633 of CDBG funds available, $673,416 is proposed to be used during Fiscal Year 2015. This includes $433,933 in FY 2015 entitlement funds, $136,049 in estimated program income, and $103,434 in excess program income received during Fiscal Year 2014. The balance, or $110,217, will be allocated as part of the 2016 CDBG Fiscal Year Budget. The funding caps have also been adjusted based on the final allocation amount provided by HUD and updated information on program income. The following summarizes calculations for funding limitations that are placed on two funding categories: Maximum Available for Public Services Fiscal Year 2015 CDBG Entitlement Grant $433,933 2014 Actual Program Income Received1 $201,535 $635,468 Public Service Cap (15%) $ 95,320 Maximum Available for Planning/Administration Fiscal Year 2015 CDBG Entitlement Grant $433,933 Estimated 2015 Program Income $136,049 $569,982 Planning/Admin Cap (20%) $113,996 The difference between the funding caps and the amount to be allocated during Fiscal Year 2015, or $464,100, yields the amount that can used to fund projects within the other three 1 Actual Program Income expected in Fiscal Year 2014 includes $194,536 from Palo Alto Housing Corporation and $7,000 in HIP loan repayments. City of Palo Alto Page 7 funding categories: Economic Development, Housing, and Public Facilities. Additional funding can be made available for these activities if less is provided for administration or public services. Fiscal Year 2015 – Funding Requests and Recommendations Palo Alto’s CDBG program is operating under a two -year funding cycle. Funding for Fiscal Year 2015 is contingent upon the CDBG allocation, program income, and any available funds for reallocation. Public Service and Administration Caps have been recalculated in accordance with available funds. All of the agencies remain eligible and meet prog ram goals and objectives. A list of the final funding allocations for Fiscal Year 2014 as well as the funding recommendations for Fiscal Year 2015 is identified in Attachment A. Table 1, Fiscal Year 2015 Funding Recommendations, identifies the applications recommended for funding and the allocation amounts prepared by staff and the HRC. Table 1: Fiscal Year 2015 Funding Recommendations Applicant Agency FY2014 Final Allocation FY 2015 Funding Request Revised HRC Recommendations Public Services Palo Alto Housing Corporation – SRO Hotels Supportive Services $32,413 $ 43,166 $29,913 Catholic Charities of Santa Clara County – Long Term Care Ombudsman $6,500 $ 6,500 $ 5,897 InnVision Shelter Network- Opportunity Services Center $48,852 $ 50,000 $45,149 YWCA/Support Network – Domestic Violence Services $10,000 $ 10,000 $ 9,141 Silicon Valley Independent Living Center – Housing and Emergency Services $5,770 $ 5,770 $ 5,221 Sub-total $103,535 $115,436 $ 95,320 Admin/Fair Housing Services Project Sentinel – Fair Housing Services $31,950 $ 32,808 $ 32,016 City of Palo Alto - $74,010 $ 84,010 $ 81,981 City of Palo Alto Page 8 Over the past three years Staff has actively taken measures to introduce efficiency in program administration that will result in a less staff intensive program. This includes streamlining the administrative procedures to reduce staffing needs, operating under a two -year funding cycle, and revised monitoring guidelines to improve efficiency and reduce on-site monitoring visists. Moreover, staff has identified ways to recover certain personnel costs associated with individual projects that require administration beyond the basic CDBG program administration requirements. These are referred to as project delivery costs and are typically associated with capital outlay projects that require staff to assist with the development of bid documents and assistance with federal procurement requirements. Staff is requesting additional funding ($7,971) in the Administration budget to cover the cost associated with the preparation of the required 2015-2020 Consolidated Plan and the required Assessment of Impediments to Fair Housing Choice. Both of the documents are required in order for the City to be eligible for CDBG funds. Staff is working in collaboration with the County of Santa Clara’s Affordable Housing Department and the entitlement jurisdictions in the county on procuring one consulting firm to prepare the necessary documents . This approach is consistent with prior years and once again serves as an opportunity for a collaborative process whereby participating jurisdictions establish a unified vision for some regional activities. Staff is also proposing to continue with the Microenterprise Assistance Program and requests the same funding amount provided in the current year. An update of the program to date is appended to this report as Attachment B. An informational report will be provided to the full City Council in May with more details on the achievements of the program. The budgeted allocation also funds a 0.25 position to support the program. Timeline CDBG Administration Sub-total $105,960 $116,818 $113,996 Economic Development City of Palo Alto – Microenterprise Assistance Program $150,000 $150,000 $150,000 Downtown Streets Inc. – Workforce Development Program $280,353 $314,100 $314,100 Sub-total $430,353 $464,100 $464,100 Grand Total $639,848 $696,354 $673,416 City of Palo Alto Page 9 Funding recommendation made by the Finance Committee will be forwarded to the City Council for review and approval at a public hearing scheduled for May 5, 2014. Subsequently, the adopted Action Plan will be submitted to HUD by May 15, 2014. Resource Impact Several measures have been taken to ensure there is no direct General Fund subsidy for the administration of the CDBG Program. This includes streamlining the program to reduce staffing needs and revised monitoring guidelines to improve efficiency of the program. However, internal support departments such as ASD, PSO, or the City Manager’s Office do not recuperate the cost for support of the program. Additionally, the Planning Department’s Administrative Division does not charge the cost for guiding and directing the program. Policy Implications All of the applications recommended for funding in Fiscal Year 2015 are consistent with the priorities established in the City’s adopted 2010-2015 Consolidated Plan. Moreover, they are consistent with the housing programs and policies in the adopted Comprehensive Plan. Environmental Review For purposes of the National Environmental Policy Act (NEPA) and the California Environmental Quality Act (CEQA), budgeting in itself is not a project. Prior to commitment or release of funds for each of the proposed projects, staff will carry out the required environmental reviews or assessments and certify that the review procedures under CEQA, HUD and NEPA regulations have been satisfied for each particular project. Attachments: Attachment A: Fiscal Year 2015 Funding Recommendations (PDF) Attachment B: Pilot Microenterprise Assistance Program Update (PDF) Attachment C: Draft FY 2015 Action Plan (PDF) CI T Y O F P A L O A L T O C D B G A P P L I C A T I O N S FIS C A L Y E A R 2 0 1 5 AG E N C Y PR O G R A M N A M E FY 2 0 1 4 F I N A L FY 2 0 1 5 RE Q U E S T RE V I S E D H R C RE C O M M E N D A T I O N S Pu b l i c S e r v i c e s ( 1 5 % C A P = $95 , 3 2 0 ) Pa l o A l t o H o u s i n g C o r p . SR O R e s i d e n t S u p p o r t Pr o g r a m $ 32 , 4 1 3 $ 4 3 , 1 6 6 $ 29 , 9 1 3 Ca t h o l i c C h a r i t i e s of S a n t a C l a r a C o u n t y Lo n g -Te r m C a r e O m b u d s m a n Pr o g r a m $ 6,50 0 $ 6,5 0 0 $ 5,8 9 7 Inn V i s i o n Sh e l t e r N e t w o r k Op p o r t u n i t y Se r v i c e s Ce n t e r $ 48 , 85 2 $ 50 , 0 0 0 $ 45 , 1 4 9 YW C A / S u p p o r t N e t w o r k Do m e s t i c V i o l e n c e S e r v i c e s $ 10 , 0 0 0 $ 10 , 0 0 0 $ 9,1 4 1 Sil i c o n V a l l e y I n d e p e n d e n t L i v i n g C e n t e r Ho u s i n g a n d E m e r g e n c y S e r v i c e s $ 5,7 7 0 $ 5,7 7 0 $ 5,2 2 1 Pu b l i c S e r v i c e T o t a l $ 10 3 , 5 3 5 $ 11 6 , 8 1 8 $ 95 , 3 2 0 Pla n n i n g & A d m i n i s t r a t i o n ( 2 0 % C A P = $11 3 , 9 9 6 ) Pr o j e c t S e n t i n e l Fa i r H o u s i n g S e r v i c e s $ 3 1 , 9 5 0 $ 32 , 8 0 8 $ 32 , 0 1 5 Cit y o f P a l o A l t o CD B G A d m i n i s t r a t i o n $ 74 , 0 1 0 $ 84 , 0 1 0 $ 81 , 9 8 1 Pla n n i n g & A d m i n i s t r a t i o n T o t a l $ 10 5 , 9 6 0 $ 11 6 , 8 1 8 $ 11 3 , 9 9 6 Ec o n o m i c D e v e l o p m e n t Cit y o f P a l o A l t o , P l a n n i n g M i c r o e n t e r p r i s e A s s i s t a n c e P r o g r a m $ 1 5 0 , 0 0 0 $ 1 5 0 , 0 0 0 $ 1 5 0 , 0 0 0 Do w n t o w n S t r e e t s W o r k f o r c e D e v e l o p m e n t P r o g r a m $ 28 0 , 3 5 3 $ 31 4 , 1 0 0 $ 31 4 , 1 0 0 Ec o n o m i c D e v e l o p m e n t T o t a l $ 43 0 , 3 5 3 $ 46 4 , 1 0 0 $ 46 4 , 1 0 0 GR A N D T O T A L $ 63 9 , 8 4 8 $ 69 6 , 3 5 4 $ 67 3 , 4 1 6 Fu n d s A v a i l a b l e $ 67 3 , 4 1 6 Av a i l a b l e f o r P u b l i c S e r v i c e ( 1 5 % C a p ) $ 95 , 3 2 0 Av a i l a b l e f o r P l a n n i n g / A d m i n ( 2 0 % C a p ) $ 11 3 , 9 9 6 Av a i l a b l e f o r E c o n o m i c D e v e l o p m e n t $ 46 4 , 1 0 0 ATTACHMENT A - FY 2015 FUNDING RECOMMENDATIONS COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM Planning and Community Environment Department PILOT MICROENTERPRISE ASSISTANCE PROGRAM UPDATE Planning Staff, in conjunction with the City’s Economic Development Manager, conducted research on best practices around the country to develop a Pilot Microenterprise Assistance Program (MAP) tailored to the Palo Alto community. Staff’s overall strategy in developing the Pilot MAP was to leverage existing community and business networks to create a system of support for microenterprise businesses owned primarily by very-low to moderate income persons. We pursued a number of partnerships with community organizations, and outreached to the business community. The following serves to provide a brief update of the Pilot Microenterprise Assistance Program and the activities staff has undertaken during the fiscal year. MAP Vision Statement “Empower and improve the economic well-being of low-moderate income families and individuals by providing local aspiring entrepreneurs with systems of support to start and grow their own business that will increase their self-sufficiency.” MAP Grant Review Committee Planning Staff worked with the City’s Economic Development Manager to engage the business community to both review applications for funding and to serve as business mentors for MAP applicants. We held our first meeting on November 7, 2013 with approximately ten (10) members from the business community. Since our first meeting the committee members have provided invaluable support to the MAP program and have helped shape the application process. MAP Cohort In collaboration with Downtown Streets and PAHC Resident Support Services, Planning staff created a MAP cohort for our target population. On December 20, 2013 an orientation meeting was held with approximately seventeen (17) individuals to go over the parameters of the program. The orientation included a presentation from a small business owner and materials about existing services in the county for small business owners. Since then staff has held several workshops with Cohort members including business plan writing, budgeting and credit, and business idea development. Grant Application Process In order to be eligible for MAP funds applicants were required to submit a pre-application by January 15, 2014. The City received twenty-six (26) pre-applications from MAP Cohort members and the general public. Planning Staff and the MAP Grant Review subcommittee reviewed all applications and established an eligibility list. Only those placed on the eligibility list qualified to apply for MAP funds. Of these twenty-six (26) applications, eleven (11) were placed on the eligibility list and were provided with a formal application for MAP funds. Staff has received seven (7) formal applications for funding ranging from $1,000 to $15,000 from those placed on the eligibility list. Next Steps The applications have been reviewed by the MAP Grant Review subcommittee and staff. Preliminary funding recommendations have been made and we anticipate the formal announcement will take place the first week of April 2014. ATTACHMENT B -PILOT MAP UPDATE DRAFT FISCAL YEAR 2015 ONE-YEAR ACTION PLAN Annual Update of the City’s Consolidated Plan for the Period July 1, 2014 to June 30, 2015 Public Review and Comment Period: March 17, 2014 – April 15, 2014 Updated March 24, 2014 Prepared by the Department of Planning & Community Environment 250 Hamilton Avenue Palo Alto, CA 94301 Director Hillary Gitelman Consuelo Hernandez, Senior Planner (650) 329-2428 T: 650-329-2428 E: Consuelo.hernandez@cityofpaloalto.org ATTACHMENT C - DRAFT FY2015 ACTION PLAN City of Palo Alto - New Consolidated Plan Template In May 2012, the Federal Department of Housing and Urban Development’s Office of Community Planning and Development introduced the eCon Planning Suite, a collection of new online tools to assist grantees in creating market‐driven, leveraged housing and community development plans. One of these tools, the Consolidated Plan Template, allows grantees to develop and submit their Five Year Consolidated Plans and Annual Action Plans online. While Palo Alto is not required to use the eCon Planning Suite until the next Consolidate Planning cycle, staff has elected to use the online tool for planning purposes. The following document is an exported version of the Annual Action Plan entered in HUD’s Integrated Disbursement and Information System (IDIS). OMB Control No: 2506-0117 (exp. 07/31/2015) PAGE INTENTIONALLY LEFT BLANK OMB Control No: 2506-0117 (exp. 07/31/2015) DRAFT FISCAL YEAR 2015 ACTION PLAN TABLE OF CONTENTS Executive Summary….……………………………..………………………………………………………………………......1 Objectives…….………..………………………………………………………………………………….………....................................2 Outcomes.…………………………………………………………………………………………………………………………………………….2 Public Participation.................................................................................................................5 Expected Resource..................................................................................................................6 Anticipated Resources………………………………………………………..…………………………………………...………………….6 Maximum Spending Caps………………………………………………..……………………………………………………….………….6 Annual Goals and Objectives……………………………………….………………………………………………………..8 Projects………………………………………………………………………………………………………………………………….9 Geographic Distributions…………………………………………….……………………………………………………….12 Affordable Housing……………………………………………………………………….…………………………………….13 Homeless and Special needs…..……….….…………………………………………………………………………………………….14 Barriers to Affordable Housing..……………….………………………………………………………………………………………..17 Other Actions........................................................................................................................19 Program Specific Requirements.............................................................................................21 APPENDICES Appendix A: Application for Federal Assistance Form SF-424 Appendix B: Certifications Appendix C: Public and Private Resources Appendix D: Proposed Projects Appendix E: Public Hearing Advertisement Appendix F: Map Appendix G: Public Comment EXECUTIVE SUMMARY ES-05 Executive Summary 1. Introduction The Draft Fiscal Year 2015 Action Plan is a one-year plan describing the eligible activities the City of Palo Alto intends to undertake to address the needs and implement the strategies identified in the adopted 2010-2015 Consolidated Plan. It is the fifth Action Plan in the implementation of the five-year plan covering the period from July 1, 2014 to June 30, 2015 and serves as the City’s application for federal funds under the U.S. Department of Housing and Urban Development (HUD) formula grant programs. Both the Consolidated Plan and the Action Plan are implemented by the City’s Planning and Community Environment Department. A total of $673,416 is available for funding projects and programs during the 2014 Program Year which correlates with the City’s Fiscal Year 2015. The City anticipates receiving $433,933 from the federal Community Development Block Grant (CDBG) program. In addition, the City will also reprogram $103,434 in previous year resources, and $136,049 in anticipated program income. Palo Alto has access to a variety of federal, state, and local resources to achieve its housing and community development priorities. Table 1, Fiscal Year 2015 CDBG Budget, summarizes the uses of the funds proposed during Fiscal Year 2015. Specific funding resources will be utilized based on the opportunities and constraints of each particular project or program. TABLE 1: FISCAL YEAR 2015 DRAFT BUDGET Applicant Agency Budget Public Services Palo Alto Housing Corporation - SRO Hotels Supportive Services $29,913 Catholic Charities of Santa Clara County – Long Term Care Ombudsman Program` $ 5,897 InnVision Shelter Network - Opportunity Center - Drop-In Center $45,149 YWCA/Support Network - Domestic Violence Services $ 9,141 Silicon Valley Independent Living Center – Housing and Emergency Services $ 5,221 Sub-total $95,320 Planning and Administration Project Sentinel – Fair Housing Services $ 32,016 City of Palo Alto Administration $ 81,981 Sub-total $113,996 Economic Development City of Palo Alto – Microenterprise Assistance Program $150,000 Downtown Streets – Workforce Development Program $314,100 Sub-total $464,100 Grand Total $673,416 The estimated amounts are based on the Federal Fiscal Year 2014 Omnibus Appropriations Bill which reduced CDBG funding by two (2) percent. With changes to the allocation method that took place last year, there is a possibility the actual allocation amount will be lower than the amount projected. Pursuant to CPD Notice number CPD-13-010, the City has adopted the following contingency provision OMB Control No: 2506-0117 (exp. 07/31/2015) language to illustrate how final allocations will be adjusted once the actual allocation amounts are known. “Each grantee will receive an amount which represents a proportional share of funds as the amount originally allocated, up to the amount requested with the balance of funds distributed amongst the remaining agencies.” Under this option, regardless of what the final allocation amounts are, each agency will receive the same percentages of the allocation to be budgeted to each activity. For instance, the Opportunity Services Center will receive approximately 47% of the public service dollars regardless of the funding allocation. On March 19, 2014 the City received its final funding allocation amount from HUD and the Annual Action Plan has been updated to reflect updated 2. Summary of the objectives and outcomes identified in the Plan Needs Assessment Overview O BJECTIVES The City intends to provide funding for various activities which are consistent with the adopted Consolidated Plan. Key objectives for Fiscal Year 2015 include the following: Support efforts to help homeless or low-income Palo Alto residents at risk of homelessness receive necessary supportive services; Affirmatively further Fair Housing; and Improve employment opportunities for low-income persons. O UTCOMES The City’s outcomes for this planning period are directed at expanding public services and economic opportunities for low-income persons. Specifically, the City anticipates the following outcomes from its 2015 activities: 131 persons will have improved accessibility to a suitable living environment. 250 persons residing in long term care facilities will have improved access to a suitable living environment 800 homeless persons will be provided with supportive services and have improved accessibility to a suitable living environment. 45 unduplicated adults and children will be provided emergency safety net supportive services and emergency shelter as needed. 25 households will have improved accessibility to decent affordable housing. 27 individuals will be placed in jobs through job training/employment readiness classes 7 Microbusinesses will be provided with resources 3. Evaluation of past performance The City has historically allocated CDBG funds to activities that benefit low and moderate income persons, with a top priority to increase affordable housing opportunities within the City. Palo Alto has one of the most expensive housing markets in the country due in part to the lack of available OMB Control No: 2506-0117 (exp. 07/31/2015) land. Notwithstanding, 140 new affordable rental housing units have been created during the 2010- 2015 Consolidated Planning Period. This includes the project at 801-841 Alma Street that opened during this program year and created 50 additional new affordable rental units funded in part through the City’s Affordable Housing Fund. 4. Summary of citizen participation process and consultation process Palo Alto encourages citizen participation through the Action Plan process. This includes consulting local organizations, holding public meetings, and encouraging public comment during the public review period. A total of three public hearings have been planned in order to allow for public input. The City actively reached out to all applicants and posted updates on the CDBG website. A 30-day comment period from March 17, 2014 through April 15, 2014 will give citizens an opportunity to offer comments on the draft Action Plan. This draft will be posted on the City’s CDBG website and presented at a public hearing to the Finance Committee on April 15, 2014. 5. Summary of public comments A summary of all written comments received during the public comment period will be inserted before the Action Plan is submitted to HUD. 6. Summary of comments or views not accepted and the reasons for not accepting them The City accepts and responds to all comments that are submitted. OMB Control No: 2506-0117 (exp. 07/31/2015) PR-05 Lead & Responsible Agencies 1. Agency/entity responsible for preparing/administering the Consolidated Plan The following are the agencies/entities responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source. TABLE 2: RESPONSIBLE AGENCY Agency Role Name Department/Agency Lead Agency PALO ALTO Planning and Community Environment Consolidated Plan Public Contact Information Consuelo Hernandez, Senior Planner City of Palo Alto Department of Planning and Community Environment 250 Hamilton Avenue, 5th Floor Palo Alto, CA 94301 Consuelo.hernandez@cityofpaloalto.org (650) 329-2428 OMB Control No: 2506-0117 (exp. 07/31/2015) PUBLIC PARTICIPATION AP-12 Participation 1. Summary of citizen participation process/Efforts made to broaden citizen participation Summarize citizen participation process and how it impacted goal-setting Citizen Participation Outreach: On October 18, 2010, the Palo Alto City Council adopted an amended Citizen Participation Plan that utilizes the Human Relations Commission (HRC), rather than a separate Citizen Advisory Committee, to promote and encourage citizen participation in the planning, implementation and assessment of the CDBG Program. The HRC is uniquely positioned to understand and consider the needs of low and very low income persons, members of minority groups, the elderly, persons with disabilities, and residents of neighborhoods where CDBG activities may be undertaken. Thus far the revisions to the Citizen Participation Plan have promoted a more coordinate and effective response by the City to the human service needs in the community. A summary of public participation is outlined in Table 3, Citizen Participation Outreach. This Draft Action Plan is being made available for a 30-day comment period to give citizens an opportunity to offer comments. A summary of comments received will be added to Appendix G. TABLE 3: CITIZEN PARTICIPATION OUTREACH Mode of Outreach Target of Outreach Summary of response/attendance Summary of comments received Public Meeting Non- targeted/broad community The Finance Committee is scheduled to hold a public hearing on April 15, 2014. A summary will be added after the meeting. Public Meeting Non- targeted/broad community The City Council is scheduled to hold a public hearing on May 5, 2014. A summary will be added after the meeting. Public Meeting Non- targeted/broad community CDBG Applicants The Human Relations Commission met on March 13, 2014 to discuss the applications for funding. Representatives from agencies requesting CDBG funds for Fiscal Year 2015 were present. Non-profit agencies discussed their funding request and thanked the City for its continued support. Newspaper Ad Non- targeted/broad community OMB Control No: 2506-0117 (exp. 07/31/2015) EXPECTED RESOURCES AP-15 Expected Resources Introduction In Fiscal Year 2015, Palo Alto will allocate approximately $673,416 to eligible activities that address the needs identified in the Consolidated Plan. The City received is final allocation amount from HUD on March 19, 2014. Anticipated Resources Planning Staff originally used the estimated 2% reduction over FY 2014 funding levels for planning purposes with final adjustments pending the City’s official allocation from HUD. The funds available for allocation have been updated. Based on the foregoing, the total amount available for allocation in Fiscal Year 2015 is estimated to be $673,416. The funding available for allocation includes $433,933 in CDBG entitlement funds, $103 of prior year CDBG resources, and $136,049 in estimated program income as summarized in Table 4, Funding Available for Allocation. Program income is income directly generated from the use of CDBG funds that is returned to the CDBG program for allocation to new activities. The program income anticipated below is from various loan repayments from Palo Alto Housing Corporation. TABLE 4: FUNDING AVAILABLE FOR ALLOCATION $433,933 Estimated Fiscal Year 2015 Entitlement Grant $103,434 Prior Year Resources – Excess Program Income: $ 65,375 - rental income in excess of expenses on specific properties acquired or rehabilitated with CDBG funds. $ 38,059 – portion of Sheridan Loan Repayment $136,049 Estimated Program Income from Palo Alto Housing Corporation (PAHC) that is generated from loan repayments. $673,416 ESTIMATED TOTAL AVAILABLE FOR ALLOCATION The following summarizes calculations for funding limitations that are placed on two funding categories: Maximum Available for Public Services Fiscal Year 2015 CDBG Entitlement Grant $433,933 2014 Actual Program Income Received1 $201,535 Public Service Cap (15% of $635,468) $ 95,320 Maximum Available for Planning/Administration Fiscal Year 2015 CDBG Entitlement Grant $433,933 Estimated 2015 Program Income $136,049 Planning/Admin Cap (20% of $569,982) $113,996 1 Actual Program Income received in Fiscal Year 2014 includes $194,536 from Palo Alto Housing Corporation and $7,000 in HIP loan repayments. OMB Control No: 2506-0117 (exp. 07/31/2015) The difference between the funding caps and the estimated total available, or $464,100, yields the amount that can used to fund projects within the other three funding categories; Economic Development, Housing, and Public Facilities. Additional funding can be made available for these activities if less is provided for administration or public services. Contingency Provisions The estimated amounts were based on the Federal Fiscal Year 2014 Omnibus Appropriations Bill which reduced CDBG funding by two (2) percent. With changes to the allocation method that took place last year, there is a possibility the actual allocation amount will be lower than the amount projected. Pursuant to CPD Notice number CPD-13-010, the City has adopted the following contingency provision language to illustrate how final allocations will be adjusted once the actual allocation amounts are known. Each grantee will receive an amount which represents a proportional share of funds as the amount originally allocated, up to the amount requested with the balance of funds distributed amongst the remaining agencies. Under this option, regardless of what the final allocation amounts are, each agency will receive the same percentages of the allocation to be budgeted to each activity. For instance, the Opportunity Services Center will receive approximately 47% of the public service dollars regardless of the funding allocation. Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied In order to comprehensively address community needs and the goals identified in the Consolidated Plan, the City will augment CDBG funds utilizing a variety of additional funding sources. These funding sources include other federal funds, state, and local funds. A full listing of potential funding sources is appended to this Action Plan as Appendix C – Public and Private Resources. If appropriate, describe publically owned land or property located within the jurisdiction that may be used to address the needs identified in the plan Not applicable. OMB Control No: 2506-0117 (exp. 07/31/2015) ANNUAL GOALS AND OBJECTIVES AP-20 Annual Goals and Objectives Goals Summary Information TABLE 5: GOALS SUMMARY Goal Name Category Needs Addressed Funding Goal Outcome Indicator Support Activities to end homelessness Affordable Housing Homeless Supportive services CDBG: $75,062 Public service activities other than Low/Moderate Income Housing Benefit: 931 Persons Public Service Activities Homeless Non-Homeless Special Needs Community services CDBG: $20,259 Public service activities other than Low/Moderate Income Housing Benefit: 319 Persons Promote Fair Housing Choice Fair Housing Fair Housing CDBG: $32,016 Other: 27 Economic Opportunities Homeless Non-Homeless Special Needs Non-Housing Community Development Economic Development Employment Opportunities CDBG: $464,100 Jobs created/retained: 30 Jobs Businesses assisted: 5 Estimate the number of extremely low-income, low-income, and moderate-income families to whom the jurisdiction will provide affordable housing as defined by HOME 91.215(b) Not applicable. OMB Control No: 2506-0117 (exp. 07/31/2015) PROJECTS AP-38 Project Summary Project Summary Information Introduction Table 6, Project Summary, provides a list of the activities with the specific priority need identified in the Consolidated Plan the City will fund with CDBG funds during Fiscal Year 2015. Complete project descriptions are located in Appendix D – Proposed Projects (HUD Table 3Cs). TABLE 6: PROJECT SUMMARY No. Project Goals Supported Needs Addressed Funding 1 SRO Resident Support Program Activities to end homelessness supportive services CDBG: $29,913 Description Resident support services program at two SRO properties in Palo Alto Planned Activities One-on-one consultations for information and referral, support counseling 2 Long-Term Care Ombudsman Program Public Service Activities supportive services CDBG: $5,897 Description Advocates for the rights of residents of long term care facilities in Palo Alto. Planned Activities Assists with problem resolution 3 Opportunity Services Center (OSC) Activities to end homelessness supportive services CDBG: $45,149 Description The OSC is a comprehensive one-stop multiservice drop-in day center Planned Activities Access to nutritious food, receive mail, and case management 4 Domestic Violence Services Public Service Activities community services CDBG: $9,141 Description Addresses issues of domestic violence for Palo Alto residents Planned Activities Emergency shelter and essential services to victims of domestic violence 5 Housing and Emergency Services Public Service Activities supportive services CDBG: $5,221 Description Assistance for individuals with disabilities and their families Planned Activities Administrative support of the housing program and emergency info & referral 6 Project Sentinel Promote Fair Housing Choice fair housing education CDBG: $32,016 Description Fair Housing services aim to protect the fundamental rights of housing Planned Activities Community outreach, education, and investigations of complaints 7 Microenterprise Assistance Program Economic Opportunities employment growth CDBG: $150,000 Description Access to new opportunities and builds foundations of entrepreneurship Planned Activities Grants to support microenterprise businesses 8 Workforce Development Program Economic Opportunities workforce training CDBG: $314,100 Description Provides homeless and/or extremely low-income individuals workforce dev. Planned Activities Employment development outreach to local businesses and job search skills OMB Control No: 2506-0117 (exp. 07/31/2015) Describe the reasons for allocation priorities and any obstacles to addressing underserved needs Fiscal Year 2015 is the fifth year of the City’s five year Consolidated Plan for the period 2010-2015. Table 7, Summary of Specific Housing/Community Development Objectives, below sets forth five year goals of the Plan and the one-year goals of the Action Plan for Fiscal Year 2015. TABLE 7: PROJECT SUMMARY Goal # Specific Objectives Performance Measure 5 Year Goal FY 2015 Goal Rental Housing Objectives 1A.1 &1C.1 Increase the Supply of Rental Housing Units 125 0 1A.2 &1C.1 Preserve Existing Affordable Rental Housing Units 72 0 1A.2 &1C.1 Conserve the Condition of Existing Rental Housing Units 150 0 Owner Housing Objectives 1B.1 Continue Below market Rate Program Units 34 10 1B.3 Rehabilitation Loans to L/M Income Owners Units Emergency Only As Needed 1B.3 Minor Home Repairs and Accessibility Upgrades Units 150 0 Public Service Objectives 3A.1 Assist Seniors in Long-Term Care Individuals 400 250 2A.1 - 5 Services to Prevent Homelessness Individuals 2,000 931 3A.1 Food and Meal Programs Individuals 2,000 400 Public Facilities Objectives 3B.1 & 3B.2 Promote Community-Based Services through Public Facilities Facilities 2 0 OMB Control No: 2506-0117 (exp. 07/31/2015) AP-35 Projects Project Summary Information Introduction Table 8, Summary of Specific Annual Objectives (HUD Table 3A), provides a list of the activities with the specific priority need identified in the Consolidated Plan the City will fund with CDBG funds during Fiscal Year 2015. TABLE 8: SUMMARY OF SPECIFIC ANNUAL OBJECTIVES (HUD TABLE 3A) Specific Objective Priority Need Source of Funds Performance Measure Goal Achieved Outcome/ Objective* Public Service SRO Tenant Support Program $29,913 CDBG People 131 TBD** SL-1 Long-Term Care Ombudsman Program $5,897 CDBG People 250 TBD SL-1 Opportunity Center $45,149 CDBG People 800 TBD SL-1 Domestic Violence Services $9,141 CDBG People 45 TBD SL-1 Housing and Emergency Services $5,221 CDBG People 24 TBD SL-1 Fair Housing Services $32,016 CDBG Households 27 TBD DH-1 Economic Development Microenterprise Assistance Program $150,000 CDBG Businesses 7 TBD E0-1 Workforce Development Program $314,100 CDBG Jobs 30 TBD E0-1 * HUD’s National Outcome/Objectives Codes Availability/ Accessibility Affordability Sustainability Decent Housing DH-1 DH-2 DH-3 Suitable Living Environment SL-1 SL-2 SL-3 Economic Opportunity EO-1 EO-2 EO-3 ** TBD: To be determined at the end of the Program Year OMB Control No: 2506-0117 (exp. 07/31/2015) GEOGRAPHIC DISTRIBUTION AP-50 Geographic Distribution Description of the geographic areas of the entitlement (including areas of low -income and minority concentration) where assistance will be directed The City considers the provisions of all types of housing assistance on a citywide basis consistent with the policies of the Comprehensive Plan. Palo Alto does not have specific target areas for housing activities, instead the City attempts to provide housing affordable to lower-income persons throughout the City. Minority concentration includes areas in the City where the concentration of racial and ethnic minority population is 10% or higher than their total citywide representation. There are only a few areas that are considered to have a concentration of minority populations or low-income residents in Palo Alto. The CDBG Program defines low-income concentration as any census block group where 51% or more residents earn 80% of MFI or less. An exception exists for a jurisdiction that does not have any areas meeting this definition, such as Palo Alto, which includes the highest quartile of all areas in the City in terms of degree of concentration is used. However, Palo Alto does not qualify activities under the LMI area benefit category. OMB Control No: 2506-0117 (exp. 07/31/2015) AFFORDABLE HOUSING AP-55 Affordable Housing Introduction Palo Alto has identified affordable housing as the primary objective for the expenditure of CDBG funds in the Consolidated Plan. It will continue to allocate the maximum funding available to activities and projects that meet this objective. Several of the projects being proposed for Fiscal Year 2015 provide essential affordable housing services to homeless, non-homeless, and special needs populations. Table 9, One-Year Goals for the Number of Households to be supported, summarizes the number of households to be served through the SRO Resident Support Program, services received at the Opportunity Services Center, emergency shelter to victims of domestic violence, and new proposed services provided through the Housing and Emergency Services Program. TABLE 9: ONE-YEAR GOALS FOR AFFORDABLE HOUSING BY SUPPORT REQUIREMENT One Year Goals for the Number of Households to be Supported Homeless 931 Non-Homeless 5 Special-Needs 24 Total 979 Over the past three Fiscal Years Palo Alto has funded a number of projects that have resulted in the production of new affordable housing units, rehabilitation of existing multi-family rental units, and acquisition of existing units. During the current funding cycle the City did not receive any applications for affordable housing supported through the production of new units or rehabilitation of existing units as summarized in Table 10, One-Year goals for Affordable Housing by Support Type. TABLE 10: ONE-YEAR GOALS FOR AFFORDABLE HOUSING BY SUPPORT TYPE Grantee Name: City of Palo Alto Program Year: 2014 5-Year Goal Fiscal Year 2015 Goal Resources Used RENTAL GO ALS (Sec. 215 Only) Production of new units 125 0 CDBG Rehabilitation of existing units 150 0 CDBG Total Sec. 215 Affordable Rental 275 0 HOME OWNER GOALS (Sec. 215 Only) Below Market Rate Program 34 10 Housing Rehabilitation of existing units 150 0 CDBG Total Sec. 215 Affordable Owner 184 10 OMB Control No: 2506-0117 (exp. 07/31/2015) AP-60 Public Housing There are no public housing facilities in the City of Palo Alto. AP-65 Homeless and Other Special Needs Activities Introduction The City of Palo Alto plans to use its CDBG funds to promote the local provision of services for low- income Palo Alto residents. A number of the City’s proposed Fiscal Year 2015 programs will directly benefit special needs groups. Moreover, through the City’s Human Services Resource Allocation Process (HSRAP), funding is provided to support services and resources targeted to Homeless and Special Needs populations. Describe the jurisdictions one-year goals and actions for reducing and ending homelessness including: Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs: In January 2013, a Point‐In‐Time (PIT) count was conducted for Santa Clara County by the City of San Jose in conjunction with the County of Santa Clara. The PIT is an intense survey used to count the number of homeless living throughout Santa Clara County on the streets, in shelters, safe havens or in transitional housing, or in areas not meant for human habitation. The survey was conducted by hundreds of volunteers who asked those living on the streets, as well as the residents of shelters, safe havens and transitional housing, to respond to questions related to their needs. A portion of the survey addresses the needs of those surveyed. Addressing the emergency shelter and transitional housing needs of homeless persons: In addressing the Consolidated Plan and the Continuum of Care strategic plans, Palo Alto will provide funding for essential services and operations to local emergency shelters and transitional housing facilities. The facilities provide shelter and services to homeless families with children, single parents with children, single men and women, victims of domestic violence and sexual abuse, homeless veterans, and the population living on the street. Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again: The City of Palo Alto plans to use its CDBG funds to promote the local provision of services for low- income Palo Alto residents. A number of the City’s proposed Fiscal Year 2015 programs will directly benefit special needs groups. Moreover, through the City’s Human Services Resource Allocation Process (HSRAP), funding is provided to support services and resources targeted to Homeless and Special Needs populations. CDBG Funded InnVision Shelter Network - Opportunity Center: The Opportunity Center facility in Palo Alto provides a clean, safe environment and resources for very- low income or homeless persons including bagged groceries, hot meals, a rotating church shelter OMB Control No: 2506-0117 (exp. 07/31/2015) program, information and referral, shower and laundry facilities, case-management, and money management (payee) programs, clothing and health services. A daily hot meal is provided at a different location each day and bagged groceries are distributed daily at the Downtown Food Closet. The Hotel de Zink rotating church shelter program is housed at a different location each month. Downtown Streets Team – Workforce Development Program: This economic development program will help motivated graduates of the Downtown Streets Team programs move on to stable employment. The program will include mentoring, counseling, job readiness, job training, and assistance. HSRAP Funded Abilities United – Disability Services: This organization provides services and activities for adults and children with mental and physical disabilities. Community Technology Alliance – Shared Technical Infrastracture: Provides shelter hotline and voicemail services for homeless individuals and families. The voicemail service helps case-managed clients attain individual goals such as securing health care, housing or employment. A countywide housing information and referral website and tracking system is maintained to assist service providers and those seeking shelter. Downtown Streets Team – Downtown Streets: Identifies motivated homeless individuals and provides them with jobs cleaning and beautifying the downtown area in exchange for housing and food vouchers. The program includes counseling, coaching and training to help program participants build self-esteem, confidence and connections in the community. Momentum for Mental Health – Homeless Outreach Program: Mental health outreach program that provides emergency on-call services to assist local mentally ill homeless persons. The agency provides services to City departments, libraries, community centers and local homeless service providers. Helping low-income individuals and families avoid becoming homeless, especially extremely low - income individuals and families and those who are: being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); or, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs. Palo Alto Housing Corporation – SRO Tenant Counseling: Provides counseling and case-management services for the low-income residents and prospective residents of single room occupancy hotels in Palo Alto. Many SRO residents have a history of homelessness and special needs. The program plays a vital role in helping residents maintain their stability and housing. Avenidas – Senior Services: Agency is the main provider of senior services in the Mid-Peninsula area. OMB Control No: 2506-0117 (exp. 07/31/2015) La Comida de California – Hot Meals for The Elderly: Daily meal program for the elderly. May View Health Center – Health Care for Low Income & Homeless Palo Alto residents: Basic primary health care services and health education and referral services for uninsured low-income and homeless individuals from the Palo Alto area. Peninsula HealthCare Connection – Project Downtown Connect: Provider of health care services at the Opportunity Center of Palo Alto. Project Downtown Connect provides Section 8 vouchers to eligible homeless individuals and families. SALA – Legal Assistance to Elders: Senior Adults Legal Assistance (SALA) provides affordable legal assistance to elders. OMB Control No: 2506-0117 (exp. 07/31/2015) AP-75 Barriers to affordable housing Introduction A barrier of affordable housing is defined in the Consolidated Plan as a public policy such as land use controls, property taxes, zoning ordinances, building codes, fees, growth limits, and other similar policies. Palo Alto faces a number of obstacles in meeting its affordable housing strategies including governmental and non-governmental constraints that may act as barriers. Governmental constraints can include land use policies governed by local general plans and zoning ordinances. The largest non- governmental constraints are market-related factors, such as land, construction costs, and the availability of financing. For instance, during the economic downturn and slumped housing market almost all of the for-sale and most rental properties in Palo Alto remained out of reach for all but households with above moderate income. Moreover, there continues to be a low vacancy rate for rental housing. According to the 2010 U.S. Census the rental vacancy rate in the City was 5.6%. Some of the barriers to building more housing are the result of decisions and priorities set by the State or the Federal Government that must decide how to best allocate limited funding. Policies and priorities set by these agencies often do not favor high cost areas, and most federal housing resources are not readily available to the City of Palo Alto. Actions it planned to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment: The City of Palo Alto takes a number of actions to eliminate barriers to the development of affordable housing including participation in a county-wide effort to provide additional affordable housing units, programs in the 2007-2014 Housing Element Update to increase the supply of affordable housing, and Development Impact fees for Housing. Housing Trust Fund of Santa Clara County (HTSCC) The HTSCC was created to provide additional financial resources to address the County’s affordable housing deficit. HTSCC’s mission is to make Silicon Valley a more affordable place to live. Loans and grants are issued to increase the supply of affordable housing, assist first-time home buyers, prevent homelessness and stabilize neighborhoods. Palo Alto was among the contributors during its founding and has continued to allocate funding. A provision was added to ensure the City’s funds be used exclusively for qualifying affordable housing projects within the City of Palo Alto. The most recent included $200,000 from the City’s Residential Housing Fund for Fiscal Year 2012. Participation in the HTSCC has increased the available housing funding for a number of Palo Alto Projects as summarized in table 2.4. In addition, HTSCC has invested over $100,000 assisting 16 households to purchase homes in Palo Alto through its first-time homebuyer program. Adjustments or Improvements to Affordable Housing Strategies 2007-2014 Housing Element Update Palo Alto’s Housing Element of the City’s Comprehensive Plan is the chief policy document describing the City’s housing needs and the policies and programs the City will use to meet those needs. The 2007- 2014 Housing Element Update was certified by the State Department of Housing and Community Development in August 2013. Planning Staff is currently working on the 2015-2023 planning period and plans to submit a draft Housing Element Update by mid-July 2014. OMB Control No: 2506-0117 (exp. 07/31/2015) Development Impact Fees for Housing Palo Alto’s impact fees are comprised of four categories: Housing, traffic, community facilities, and Parkland dedication. The housing fee to non-residential development increased from $18.44 to $18.89 per square foot, effective May 8, 2013. The fee rate applies to all net new commercial square footage on a site. Full payment is required at building permit issuance with some exemptions including hospitals and convalescent facilities, private education facilities, public facilities and private clubs, lodges and fraternal organizations. AFFIRMATIVELY FURTHERING FAIR HOUSING Fair Housing is crucial to ensuring persons of like income levels have equal access to housing. HUD requires that jurisdictions receiving federal funds commit to affirmatively further fair housing. A fair housing impediment, according to HUD, is considered to be “any actions, omissions, or decisions which have the effect of restricting housing choices or the availability of housing choices because of race, color, religion, sex, disability, familial status, or national origin.” A key part of affirmatively furthering fair housing includes the preparation of an Analysis of Impediments to Fair Housing Choice (AI). The City’s 2015-2020 Consolidated Plan will include an update to the AI. ACTIVITIES TO AFFIRMATIVELY FURTHER FAIR HOUSING Palo Alto is committed to fair housing practices and places a priority on promoting and ensuring an atmosphere of non-discrimination in housing choice. In Fiscal Year 2015 the City of Palo Alto will provide $32,016 in CDBG funds to Project Sentinel for the provision of fair housing complaint investigations, public education and information, and referral services. The following actions to foster and maintain affordable housing to address housing: Provide tenant/landlord counseling and mediation services for Palo Alto residents through the Palo Alto Mediation Program (Project Sentinel). Support the Human Relations Commission in their documentation and investigation of hate crimes, and in their support of diversity, disability and affordable housing issues. Continue to monitor the provision of fair housing services to ensure that adequate services are being provided and are cost effective. Continue to participate in the Santa Clara County Fair Housing Task Force. Provide funding to Project sentinel to reduce discrimination in housing by: 1. Investigating cased of housing discrimination in Palo Alto 2. Conducting consultation with persons who believe they have been discriminated against 3. Maintaining a pool of trained testers for investigations and conducting trainings 4. Maintaining a panel of participating attorneys for referral 5. Running fair housing ads in the Palo Alto Weekly, San Jose Mercury News and other media outlets 6. Distributing fair housing brochures 7. Running public service announcements for local radio/TV broadcasters 8. Making educational presentations to the community 9. Monitoring and testing rental housing sites for fair housing compliance 10. Organizing an event for National Fair Housing Month OMB Control No: 2506-0117 (exp. 07/31/2015) OTHER ACTIONS AP-85 Other Actions Actions planned to address obstacles to meeting underserved needs The City’s CDBG program diligently works with other purveyors of funding to provide the most value per dollar. This is actualized by partnering with other City resources such as HSRAP and leveraging dollars invested in site acquisition for low-income housing with a multitude of other funding sources. However, Palo Alto is at a disadvantage in removing or eliminating obstacles to meeting underserved needs due to the consistently shrinking amount of CDBG funds available in recent years. During the next program year the City will continue to support applications by service providers to expand affordable housing opportunities, homeless assistance, and supportive services consistent with the Consolidated Plan. Actions planned to foster and maintain affordable housing The City will continue to foster the development of affordable housing through its affordable housing program. Housing Staff recently finalized the Density Bonus Ordinance and was adopted by the City Council in January 2014. Actions planned to reduce lead-based paint hazards Lead poising can cause permanent damage to the brain and many other organs, and can result in reduced intelligence and behavioral problems in young children. More than 80,000 children younger than 6 years old living in the United States have lead in their blood that is above the level of concern set by the Centers for Disease Control and Prevention (CDC). A significant number of these children are in families of low income and are living in old homes with heavy concentration of lead-based paint and lead-contaminated dust and soil in the environment. The City’s housing and CDBG staff provide information and referral to property owners, developers, and non-profit organizations rehabilitating older housing about lead-based paint hazards. There is no information that indicates lower income households are more likely to be exposed to lead paint hazards in Palo Alto than are families in the general population. The City’s 2010-15 Consolidated Plan has a more detailed discussion of lead based paint in the City. Any house to be rehabilitated with City financial assistance is required to be inspected for the existence of lead paint and lead paint hazards. The City will provide financial assistance for the abatement of such hazards in units rehabilitated with City funding. Actions planned to reduce the number of poverty-level families The City of Palo Alto provided either CDBG or HSRAP funding to several services for persons within the community who are very low-income, homeless, or at-risk of becoming homeless. In summary, the goal of all of the services listed in the section above is to prevent homelessness, help people move out of homelessness and to reduce the number of persons below the poverty line. Actions planned to develop institutional structure Implementation of CDBG funds is overseen by the Department of Planning and Community Environment. Human Services and social service delivery in Palo Alto by non-profit agencies is coordinated through the Human Services Resource Allocation Program (HSRAP). The City Council approves projects and programs that meet the City’s goals. Collectively, the programs funded under CDBG and HSRAP provide essential services to the community. Applications are received and reviewed congruently which allows for internal administrative efficiencies, creates a visible public forum for the OMB Control No: 2506-0117 (exp. 07/31/2015) CDBG program, and provides a more coordinated and effective approach at addressing the City’s human service needs. CDBG entitlement cities, including Palo Alto, Sunnyvale, Mountain View, Santa Clara, Cupertino, Gilroy, Milpitas, and San Jose, along with the Urban County of Santa Clara continue to meet on a regular schedule to discuss issues of mutual concern and to share information and strategies for addressing a variety of issues of common concern. These meetings have helped participants better understand the County and nonprofit social service structure within the County, and provide input to the Santa Clara County Office of Affordable Housing. Finally, the meeting serves as a forum for HUD representatives to share information and answer questions from entitlement jurisdictions regarding issues of mutual importance. OMB Control No: 2506-0117 (exp. 07/31/2015) PROGRAM SPECIFIC REQUIREMENTS AP-90 Program Specific Requirements Introduction Community Development Block Grant Program (CDBG) Reference 24 CFR 91.220.(I)(1) Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in projects to be carried out. TABLE 11: PROGRAM INCOME SUMMARY 1. The total amount of program income that will have been received before the start of the next program year and that has not yet been reprogrammed $37,432 2. The amount of proceeds from section 108 loan guarantees that will be used during the year to address the priority needs and specific objectives identified in the grantee's strategic plan. 0 3. The amount of surplus funds from urban renewal settlements 0 4. The amount of any grant funds returned to the line of credit for which the planned use has not been included in a prior statement or plan 0 5. The amount of income from float-funded activities 0 Total Program Income: $37,432 TABLE 12: OTHER CDBG REQUIREMENTS 1. The amount of urgent need activities 0 2. The estimated percentage of CDBG funds that will be used for activities that benefit persons of low and moderate income. Overall Benefit - A consecutive period of one, two or three years may be used to determine that a minimum overall benefit of 70% of CDBG funds is used to benefit persons of low and moderate income. Specify the years covered that include this Annual Action Plan. 100% OMB Control No: 2506-0117 (exp. 07/31/2015) Appendix A: Application for Federal Assistance Form SF -424 APPLICATION FOR Version 7/03 FEDERAL ASSISTANCE 2. DATE SUBMITTED Applicant Identifier 1. TYPE OF SUBMISSION: Application Pre-application 3. DATE RECEIVED BY STATE State Application Identifier Construction Construction Non-Construction Non-Construction 4. DATE RECEIVED BY FEDERAL AGENCY Federal Identifier 5. APPLICANT INFORMATION Organizational Unit: Legal Name: Department: Organizational DUNS: Division: Address: Street: Name and telephone number of person to be contacted on matters involving this application (give area code) Prefix:First Name: City: Middle Name County: Last Name State:Zip Code Suffix: Country: Email: 6. EMPLOYER IDENTIFICATION NUMBER (EIN): - Phone Number (give area code) Fax Number (give area code) 8. TYPE OF APPLICATION: New Continuation Revision 7. TYPE OF APPLICANT: (See back of form for Application Types) If Revision, enter appropriate letter(s) in box(es) (See back of form for description of letters.) Other (specify) Other (specify)9. NAME OF FEDERAL AGENCY: 10. CATALOG OF FEDERAL DOMESTIC ASSISTANCE NUMBER: - TITLE (Name of Program): 12. AREAS AFFECTED BY PROJECT (Cities, Counties, States, etc.): 11. DESCRIPTIVE TITLE OF APPLICANT’S PROJECT: 13. PROPOSED PROJECT 14. CONGRESSIONAL DISTRICTS OF: Start Date:Ending Date:a. Applicant b. Project 15. ESTIMATED FUNDING:16. IS APPLICATION SUBJECT TO REVIEW BY STATE EXECUTIVE ORDER 12372 PROCESS? a. Federal $.00 b. Applicant $.00 a. Yes.THIS PREAPPLICATION/APPLICATION WAS MADE AVAILABLE TO THE STATE EXECUTIVE ORDER 12372 PROCESS FOR REVIEW ON c. State $.00 DATE: d. Local $.00 b. No.PROGRAM IS NOT COVERED BY E. O. 12372 e. Other $.00 OR PROGRAM HAS NOT BEEN SELECTED BY STATE FOR REVIEW f. Program Income $.00 17. IS THE APPLICANT DELINQUENT ON ANY FEDERAL DEBT? g. TOTAL $.00 Yes If “Yes” attach an explanation. No 18. TO THE BEST OF MY KNOWLEDGE AND BELIEF, ALL DATA IN THIS APPLICATION/PREAPPLICATION ARE TRUE AND CORRECT. THE DOCUMENT HAS BEEN DULY AUTHORIZED BY THE GOVERNING BODY OF THE APPLICANT AND THE APPLICANT WILL COMPLY WITH THE ATTACHED ASSURANCES IF THE ASSISTANCE IS AWARDED. a. Authorized Representative Prefix First Name Middle Name Last Name Suffix b. Title c. Telephone Number (give area code) d. Signature of Authorized Representative e. Date Signed Previous Edition Usable Authorized for Local Reproduction Standard Form 424 (Rev.9-2003) Prescribed by OMB Circular A-102 B-14-MC-06-0020 B-14-MC-06-0020 City of Palo Alto Planning and Community Environment 050520782 Planning P.O. BOX 10250 Miss Consuelo Palo Alto Santa Clara Hernandez CA 94303 9 (650) 329-2428 consuelo.hernandez@cityofpaloalto.org (650) 329-2154 D. Township Government U.S. Department of Housing and Urban Development The City of Palo Alto's Community Development Block Grant (CDBG) Program for Fiscal Year 2015. Community Development Block Grant (CDBG) City of Palo Alto, County of Santa Clara, State of California 07/01/2013 06/30/2014 14th Congressional District 14th Congressional District 457,484 67,375 136,049 660,908 Mr.James Keene City Manager (650) 329-2563 ✔ ✔ 4 6 983000 1 8124 OMB Approved No. 3076-0006 OMB Control No: 2506-0117 (exp. 07/31/2015) Appendix B: Certifications CPMP Non-State Grantee Certifications 1 Version 2.0 CPMP Non-State Grantee Certifications Many elements of this document may be completed electronically, however a signature must be manually applied and the document must be submitted in paper form to the Field Office. This certification does not apply. This certification is applicable. NON-STATE GOVERNMENT CERTIFICATIONS In accordance with the applicable statutes and the regulations governing the consolidated plan regulations, the jurisdiction certifies that: Affirmatively Further Fair Housing -- The jurisdiction will affirmatively further fair housing, which means it will conduct an analysis of impediments to fair housing choice within the jurisdiction, take appropriate actions to overcome the effects of any impediments identified through that analysis, and maintain records reflecting that analysis and actions in this regard. Anti-displacement and Relocation Plan -- It will comply with the acquisition and relocation requirements of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended, and implementing regulations at 49 CFR 24; and it has in effect and is following a residential antidisplacement and relocation assistance plan required under section 104(d) of the Housing and Community Development Act of 1974, as amended, in connection with any activity assisted with funding under the CDBG or HOME programs. Drug Free Workplace -- It will or will continue to provide a drug-free workplace by: 1. Publishing a statement notifying employees that the unlawful manufacture, distribution, dispensing, possession, or use of a controlled substance is prohibited in the grantee's workplace and specifying the actions that will be taken against employees for violation of such prohibition; 2. Establishing an ongoing drug-free awareness program to inform employees about – a. The dangers of drug abuse in the workplace; b. The grantee's policy of maintaining a drug-free workplace; c. Any available drug counseling, rehabilitation, and employee assistance programs; and d. The penalties that may be imposed upon employees for drug abuse violations occurring in the workplace; 3. Making it a requirement that each employee to be engaged in the performance of the grant be given a copy of the statement required by paragraph 1; 4. Notifying the employee in the statement required by paragraph 1 that, as a condition of employment under the grant, the employee will – a. Abide by the terms of the statement; and b. Notify the employer in writing of his or her conviction for a violation of a criminal drug statute occurring in the workplace no later than five calendar days after such conviction; 5. Notifying the agency in writing, within ten calendar days after receiving notice under subparagraph 4(b) from an employee or otherwise receiving actual notice of such conviction. Employers of convicted employees must provide notice, including position title, to every grant officer or other designee on whose grant activity the convicted employee was working, unless the Federal agency has designated a central point for the receipt of such notices. Notice shall include the identification number(s) of each affected grant; 6. Taking one of the following actions, within 30 calendar days of receiving notice under subparagraph 4(b), with respect to any employee who is so convicted – a. Taking appropriate personnel action against such an employee, up to and including termination, consistent with the requirements of the Rehabilitation Act of 1973, as amended; or b. Requiring such employee to participate satisfactorily in a drug abuse assistance or rehabilitation program approved for such purposes by a Federal, State, or local health, law enforcement, or other appropriate agency; 7. Making a good faith effort to continue to maintain a drug-free workplace through implementation of paragraphs 1, 2, 3, 4, 5 and 6. Palo Alto CPMP Non-State Grantee Certifications 2 Version 2.0 Anti-Lobbying -- To the best of the jurisdiction's knowledge and belief: 8. No Federal appropriated funds have been paid or will be paid, by or on behalf of it, to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement; 9. If any funds other than Federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with this Federal contract, grant, loan, or cooperative agreement, it will complete and submit Standard Form-LLL, "Disclosure Form to Report Lobbying," in accordance with its instructions; and 10. It will require that the language of paragraph 1 and 2 of this anti-lobbying certification be included in the award documents for all subawards at all tiers (including subcontracts, subgrants, and contracts under grants, loans, and cooperative agreements) and that all subrecipients shall certify and disclose accordingly. Authority of Jurisdiction -- The consolidated plan is authorized under State and local law (as applicable) and the jurisdiction possesses the legal authority to carry out the programs for which it is seeking funding, in accordance with applicable HUD regulations. Consistency with plan -- The housing activities to be undertaken with CDBG, HOME, ESG, and HOPWA funds are consistent with the strategic plan. Section 3 -- It will comply with section 3 of the Housing and Urban Development Act of 1968, and implementing regulations at 24 CFR Part 135. Signature/Authorized Official Date Name Title Address City/State/Zip Telephone Number James Keene City Manager 250 Hamilton Avenue Palo Alto, CA 94301 650-329-2563 Palo Alto CPMP Non-State Grantee Certifications 3 Version 2.0 This certification does not apply. This certification is applicable. Specific CDBG Certifications The Entitlement Community certifies that: Citizen Participation -- It is in full compliance and following a detailed citizen participation plan that satisfies the requirements of 24 CFR 91.105. Community Development Plan -- Its consolidated housing and community development plan identifies community development and housing needs and specifies both short-term and long-term community development objectives that provide decent housing, expand economic opportunities primarily for persons of low and moderate income. (See CFR 24 570.2 and CFR 24 part 570) Following a Plan -- It is following a current consolidated plan (or Comprehensive Housing Affordability Strategy) that has been approved by HUD. Use of Funds -- It has complied with the following criteria: 11. Maximum Feasible Priority - With respect to activities expected to be assisted with CDBG funds, it certifies that it has developed its Action Plan so as to give maximum feasible priority to activities which benefit low and moderate income families or aid in the prevention or elimination of slums or blight. The Action Plan may also include activities which the grantee certifies are designed to meet other community development needs having a particular urgency because existing conditions pose a serious and immediate threat to the health or welfare of the community, and other financial resources are not available); 12. Overall Benefit - The aggregate use of CDBG funds including section 108 guaranteed loans during program year(s) 2011, 2012, 2013, (a period specified by the grantee consisting of one, two, or three specific consecutive program years), shall principally benefit persons of low and moderate income in a manner that ensures that at least 70 percent of the amount is expended for activities that benefit such persons during the designated period; 13. Special Assessments - It will not attempt to recover any capital costs of public improvements assisted with CDBG funds including Section 108 loan guaranteed funds by assessing any amount against properties owned and occupied by persons of low and moderate income, including any fee charged or assessment made as a condition of obtaining access to such public improvements. However, if CDBG funds are used to pay the proportion of a fee or assessment that relates to the capital costs of public improvements (assisted in part with CDBG funds) financed from other revenue sources, an assessment or charge may be made against the property with respect to the public improvements financed by a source other than CDBG funds. The jurisdiction will not attempt to recover any capital costs of public improvements assisted with CDBG funds, including Section 108, unless CDBG funds are used to pay the proportion of fee or assessment attributable to the capital costs of public improvements financed from other revenue sources. In this case, an assessment or charge may be made against the property with respect to the public improvements financed by a source other than CDBG funds. Also, in the case of properties owned and occupied by moderate-income (not low-income) families, an assessment or charge may be made against the property for public improvements financed by a source other than CDBG funds if the jurisdiction certifies that it lacks CDBG funds to cover the assessment. Excessive Force -- It has adopted and is enforcing: 14. A policy prohibiting the use of excessive force by law enforcement agencies within its jurisdiction against any individuals engaged in non-violent civil rights demonstrations; and 15. A policy of enforcing applicable State and local laws against physically barring entrance to or exit from a facility or location which is the subject of such non-violent civil rights demonstrations within its jurisdiction; Palo Alto CPMP Non-State Grantee Certifications 4 Version 2.0 Compliance With Anti-discrimination laws -- The grant will be conducted and administered in conformity with title VI of the Civil Rights Act of 1964 (42 USC 2000d), the Fair Housing Act (42 USC 3601-3619), and implementing regulations. Lead-Based Paint -- Its activities concerning lead-based paint will comply with the requirements of part 35, subparts A, B, J, K and R, of title 24; Compliance with Laws -- It will comply with applicable laws. Signature/Authorized Official Date Name Title Address City/State/Zip Telephone Number James Keene City Manager 250 Hamilton Avenue Palo Alto, CA 94301 650-329-2563 Palo Alto CPMP Non-State Grantee Certifications 10 Version 2.0 This certification does not apply. This certification is applicable. APPENDIX TO CERTIFICATIONS Instructions Concerning Lobbying and Drug-Free Workplace Requirements Lobbying Certification This certification is a material representation of fact upon which reliance was placed when this transaction was made or entered into. Submission of this certification is a prerequisite for making or entering into this transaction imposed by section 1352, title 31, U.S. Code. Any person who fails to file the required certification shall be subject to a civil penalty of not less than $10,000 and not more than $100,000 for each such failure. Drug-Free Workplace Certification 1. By signing and/or submitting this application or grant agreement, the grantee is providing the certification. 2. The certification is a material representation of fact upon which reliance is placed when the agency awards the grant. If it is later determined that the grantee knowingly rendered a false certification, or otherwise violates the requirements of the Drug-Free Workplace Act, HUD, in addition to any other remedies available to the Federal Government, may take action authorized under the Drug-Free Workplace Act. 3. Workplaces under grants, for grantees other than individuals, need not be identified on the certification. If known, they may be identified in the grant application. If the grantee does not identify the workplaces at the time of application, or upon award, if there is no application, the grantee must keep the identity of the workplace(s) on file in its office and make the information available for Federal inspection. Failure to identify all known workplaces constitutes a violation of the grantee's drug-free workplace requirements. 4. Workplace identifications must include the actual address of buildings (or parts of buildings) or other sites where work under the grant takes place. Categorical descriptions may be used (e.g., all vehicles of a mass transit authority or State highway department while in operation, State employees in each local unemployment office, performers in concert halls or radio stations). 5. If the workplace identified to the agency changes during the performance of the grant, the grantee shall inform the agency of the change(s), if it previously identified the workplaces in question (see paragraph three). 6. The grantee may insert in the space provided below the site(s) for the performance of work done in connection with the specific grant: Place of Performance (Street address, city, county, state, zip code) Check if there are workplaces on file that are not identified here. The certification with regard to the drug-free workplace is required by 24 CFR part 21. Place Name Street City County State Zip Palo Alto City Hall 250 Hamilton Ave. Palo Alto Santa Clara CA 94301 7. Definitions of terms in the Nonprocurement Suspension and Debarment common rule and Drug-Free Workplace common rule apply to this certification. Grantees' attention is called, in particular, to the following definitions from these rules: "Controlled substance" means a controlled substance in Schedules I through V of the Controlled Substances Act (21 U.S.C. 812) and as further defined by regulation (21 CFR 1308.11 through 1308.15); "Conviction" means a finding of guilt (including a plea of nolo contendere) or imposition of sentence, or both, by any judicial body charged with the responsibility to determine violations of the Federal or State criminal drug statutes; "Criminal drug statute" means a Federal or non-Federal criminal statute involving the manufacture, distribution, dispensing, use, or possession of any Palo Alto CPMP Non-State Grantee Certifications 11 Version 2.0 controlled substance; "Employee" means the employee of a grantee directly engaged in the performance of work under a grant, including: a. All "direct charge" employees; b. all "indirect charge" employees unless their impact or involvement is insignificant to the performance of the grant; and c. temporary personnel and consultants who are directly engaged in the performance of work under the grant and who are on the grantee's payroll. This definition does not include workers not on the payroll of the grantee (e.g., volunteers, even if used to meet a matching requirement; consultants or independent contractors not on the grantee's payroll; or employees of subrecipients or subcontractors in covered workplaces). Note that by signing these certifications, certain documents must completed, in use, and on file for verification. These documents include: 1. Analysis of Impediments to Fair Housing 2. Citizen Participation Plan 3. Anti-displacement and Relocation Plan Signature/Authorized Official Date Name Title Address City/State/Zip Telephone Number James Keene City Manager 250 Hamilton Avenue Palo Alto, CA 94301 650-329-2563 OMB Control No: 2506-0117 (exp. 07/31/2015) Appendix C: Public and Private Resources PUBLIC AND PRIVATE RESOURCES Palo Alto has access to a variety of federal, state, and local resources to achieve its housing and community development priorities. The table below identifies potential sources of funding available to carry out housing and community development activities in Palo Alto. To the extent possible, the City will seek to leverage funding from other public and private entities to strengthen programs and activities established in the Consolidated Plan and this Action Plan. PROGRAM NAME DESCRIPTION ELIGIBLE ACTIVITIES FEDERAL PROGRAMS Community Development Block Grant (CDBG) Grants awarded to the City on a formula basis for Housing and Community Development Activities. The City’s CDBG Budget for Fiscal Year 2015 is $673,416. This includes an entitlement grant of $433,933, $103,434 of prior year resources, and $136,049 in estimated Program Income. Acquisition Rehabilitation Home buyer assistance Economic Dev. Homeless assistance Public services HOME Program The City of Palo Alto is not an entitlement grantee under the federal HOME program and thus does not receive a direct grant of HOME Program funds from HUD. HOME funds are available on an annual competitive basis through the State of California HOME program. Acquisition Rehabilitation Home buyer assistance Rental Assistance Section 8 Housing Vouchers The Housing Authority of the County of Santa Clara administers the federal Section 8 program countywide. The City anticipates that Section 8 vouchers will continue to be available to Palo Alto residents in Fiscal Year 2015 through the Moderate Rehabilitation Program, and the Housing Choice Voucher Program. Rental Assistance Homeless Assistance Support Services McKinney – Vento Homeless Assistance Funds Santa Clara County distributes federal McKinney Homeless Assistance funds to organizations in the County that provide services to homeless persons and persons at-risk of homelessness. None of the funding is currently targeted directly to shelter or supportive services in Palo Alto. Supportive Housing Shelter Plus Care Section 8 SRO STATE PROGRAMS State of California’s Multifamily Housing Program (MHP) MHP has been a major source of funding for affordable housing since 2002. The purpose of this program is to provide low-interest loans to developers of affordable rental housing. The Fabian Way Senior Housing received an award of $5.25 million in permanent MHP funding in 2008. New construction Rehabilitation Preservation of low-income permanent and transitional rental housing PROGRAM NAME DESCRIPTION ELIGIBLE ACTIVITIES State of California’s Local Housing Trust Fund Grant Program Another component of Proposition 46 was funding for new and existing local housing trust funds. A local housing trust fund is a public or private partnership created to receive on-going revenues for affordable housing production such as Palo Alto’s Commercial and Residential Housing Funds. Rental Housing Projects (deed restricted) Down payment assistance Low-Income Housing Tax Credits The California Tax Credit Allocation Committee (CTCAC) holds two application cycles each year. Typically, the first cycle is held in March and the second is held in July. Local non-profits apply directly to the CTCAC for these funds when they have identified a project. New Construction Acquisition and rehabilitation of eligible projects LOCAL PROGRAMS Human Service Resource Allocation Process (HSRAP) In addition to the CDBG public service funds, the City will provide $1,099,347 million dollars from the General Fund in support of human services through HSRAP. The HSRAP funds, in conjunction with the CDBG public service funds, are distributed to local non-profit agencies. Public service activities serving the needs of seniors, children, youth and families, persons with disabilities, and those who are homeless or at risk of homelessness Palo Alto Commercial Housing Fund The Commercial Housing fund is used primarily to increase the number of new affordable housing units for Palo Alto’s work force. It is funded with mitigation fees required from developers of commercial and industrial projects. As of March 6, 2013 the Commercial Fund had an available balance of approximately $1,972,000. New construction Palo Alto Residential Housing Fund The Residential Housing Fund is funded with mitigation fees provided under Palo Alto’s Below Market Rate (BMR) housing program from residential developers and money from other miscellaneous sources, such as proceeds from the sale or lease of City property. As of December 31, 2013 the Residential Fund had a balance of approximately $3,787,000 Acquisition Rehabilitation New construction Pre-development costs Below Market Rate Emergency Fund This fund was authorized by council in September 2002 in order to provide funding on an ongoing basis for loans to BMR owners for special assessment loans and for rehabilitation and preservation of the City’s stock of BMR ownership units. As of March 13, 2014 the BMR Emergency Fund had a balance of approximately $450,000. Special Assessment Loans Rehabilitation PROGRAM NAME DESCRIPTION ELIGIBLE ACTIVITIES The Housing Trust Fund of Santa Clara County (HTSCC) HTSCC is a non-profit organization that combines private and public funds to support affordable housing activities in the County, including assistance to developers and homebuyers. The HTSCC is a public/private initiative, dedicated to creating more affordable housing in Santa Clara County, using a revolving loan fund and grant- making program to complement and leverage other housing resources. New Construction First time homebuyers program Developer Loans Homelessness Prevention Programs Santa Clara County Affordable Housing Fund (AHF) The Santa Clara County Board of Supervisors established the Affordable Housing Fund with initial funding of $18.6 million in 2002. The main purpose of the AHF was to assist in the development of affordable housing especially for extremely low income and special needs people throughout Santa Clara County. $960,000 was awarded to the Tree House project developed by the Palo Alto Housing Corporation. The County has awarded over $10 million from the AHF to date. Construction Permanent Financing OMB Control No: 2506-0117 (exp. 07/31/2015) Appendix D: Proposed Projects U.S. Department of Housing OMB Approval No. 2506-0117 and Urban Development Exp. 8/31/2014) Table 3C Consolidated Plan Listing of Projects Jurisdiction’s Name City of Palo Alto Priority Need Public Services Project Title SRO Resident Support Services Description Palo Alto Housing Corporation will provide counseling and supportive case management services for low- income residents of single room occupancy facilities in order to help them maintain housing stability. Activities include financial counseling, health maintenance, information and referral, problem solving, employment assistance, crisis intervention and case management. Objective category: Suitable Living Environment Decent Housing Economic Opportunity Outcome category: Availability/Accessibility Affordability Sustainability Location/Target Area Street Address: 439 Emerson Street and 753 Alma Street City, State, Zipcode: Palo Alto, CA 94301 Objective Number SL-1 Project ID 1 HUD Matrix Code 05 Public Services CDBG Citation 570.201 (e) Type of Recipient LMC CDBG National Objective 570.208(a)(2) Start Date (mm/dd/yyyy) 07/01/2014 Completion Date (mm/dd/yyyy) 06/30/2015 Performance Indicator People Annual Units 131 Local ID SR-01048-999 Units Upon Completion 131 Funding Sources: CDBG $29,913 ESG HOME HOPWA Total Formula Prior Year Funds Assisted Housing PHA Other Funding Total $29,913 The primary purpose of the project is to help: the Homeless Persons with HIV/AIDS Persons with Disabilities Public Housing Needs U.S. Department of Housing OMB Approval No. 2506-0117 and Urban Development Exp. 8/31/2014) Table 3C Consolidated Plan Listing of Projects Jurisdiction’s Name City of Palo Alto Priority Need Public Services Project Title Long Term Care Ombudsman Program Description Catholic Charities assists in problem resolution and advocates for the rights of residents of long term care facilities in Palo Alto. The majority of the clients assisted are low-income, frail, elderly, and chronically ill. This program assists these vulnerable, dependent and socially isolated residents receive the care and placement to which they are entitled. Objective category: Suitable Living Environment Decent Housing Economic Opportunity Outcome category: Availability/Accessibility Affordability Sustainability Location/Target Area Community - wide Street Address: City, State, Zipcode: Objective Number SL-1 Project ID 2 HUD Matrix Code 05A Senior Services CDBG Citation 570.201 (e) Type of Recipient LMC CDBG National Objective 570.208(a)(2) Start Date (mm/dd/yyyy) 07/01/2014 Completion Date (mm/dd/yyyy) 06/30/2015 Performance Indicator People Annual Units 260 Local ID SR-01025-999 Units Upon Completion Funding Sources: CDBG $5,897 ESG HOME HOPWA Total Formula Prior Year Funds Assisted Housing PHA Other Funding Total $5,897 The primary purpose of the project is to help: the Homeless Persons with HIV/AIDS Persons with Disabilities Public Housing Needs . U.S. Department of Housing OMB Approval No. 2506-0117 and Urban Development Exp. 8/31/2014) Table 3C Consolidated Plan Listing of Projects Jurisdiction’s Name City of Palo Alto Priority Need Public Services Project Title Opportunity Service Center Description InnVision Shelter Network provides basic necessities for persons who are homeless or at-risk of becoming homeless. The Opportunity Services Center is a comprehensive, one-stop, multi-service, day drop-in center that provides critical services for homeless Palo Alto residents. Specifically, the facility provides showers, laundry, clothing, snacks, case management, and shelter/housing referral services. Objective category: Suitable Living Environment Decent Housing Economic Opportunity Outcome category: Availability/Accessibility Affordability Sustainability Location/Target Area Street Address: 33 Encina Way City, State, Zipcode: Palo Alto, CA 94301 Objective Number SL-1 Project ID 3 HUD Matrix Code 05 Public Services CDBG Citation 570.201 (e) Type of Recipient LMC CDBG National Objective 570.208(a)(2) Start Date (mm/dd/yyyy) 07/01/2014 Completion Date (mm/dd/yyyy) 06/30/2015 Performance Indicator People Annual Units 800 Local ID SR-01082-999 Units Upon Completion 800 Funding Sources: CDBG $45,149 ESG HOME HOPWA Total Formula Prior Year Funds Assisted Housing PHA Other Funding Total $45,149 The primary purpose of the project is to help: the Homeless Persons with HIV/AIDS Persons with Disabilities Public Housing Needs . U.S. Department of Housing OMB Approval No. 2506-0117 and Urban Development Exp. 8/31/2014) Table 3C Consolidated Plan Listing of Projects Jurisdiction’s Name City of Palo Alto Priority Need Public Services Project Title Domestic Violence Services Description Support Network for Battered Women, a Division of YWCA will provide individuals and families experiencing domestic violence, the program provides a bilingual domestic violence hotline, an emergency shelter, crisis counseling, legal assistance, court accompaniment, individual and group therapy, support groups, children’s therapy groups, preventative education, safety planning and community referrals. Objective category: Suitable Living Environment Decent Housing Economic Opportunity Outcome category: Availability/Accessibility Affordability Sustainability Location/Target Area Community-wide Street Address: City, State, Zipcode: Objective Number SL-1 Project ID 4 HUD Matrix Code 05G CDBG Citation 570.201(e) Type of Recipient LMC CDBG National Objective 570.208(a)(2) Start Date (mm/dd/yyyy) 07/01/2014 Completion Date (mm/dd/yyyy) 06/30/2015 Performance Indicator People Annual Units 45 Local ID SR-01105-999 Units Upon Completion 45 Funding Sources: CDBG $9,141 ESG HOME HOPWA Total Formula Prior Year Funds Assisted Housing PHA Other Funding Total $9,141 The primary purpose of the project is to help: the Homeless Persons with HIV/AIDS Persons with Disabilities Public Housing Needs . U.S. Department of Housing OMB Approval No. 2506-0117 and Urban Development Exp. 8/31/2014) Table 3C Consolidated Plan Listing of Projects Jurisdiction’s Name City of Palo Alto Priority Need Public Services Project Title Housing and Emergency Services for Persons with Disabilities Description Silicon Valley Independent Living Center provides assistance for individuals with disabilities and their families to transition from homelessness, health care facilities, unstable or temporary housing to permanent affordable, accessible, integrated housing with emergency assistance, security deposits, rent, information & referral, and other basic essentials. Objective category: Suitable Living Environment Decent Housing Economic Opportunity Outcome category: Availability/Accessibility Affordability Sustainability Location/Target Area Community-wide Street Address: City, State, Zipcode: Objective Number SL-1 Project ID 5 HUD Matrix Code 5B CDBG Citation 570.201(e) Type of Recipient LMC CDBG National Objective 570.208(a)(2) Start Date (mm/dd/yyyy) 07/01/2014 Completion Date (mm/dd/yyyy) 06/30/2015 Performance Indicator People Annual Units 24 Local ID SR-01124-999 Units Upon Completion 24 Funding Sources: CDBG $5,221 ESG HOME HOPWA Total Formula Prior Year Funds Assisted Housing PHA Other Funding Total $5,221 The primary purpose of the project is to help: the Homeless Persons with HIV/AIDS Persons with Disabilities Public Housing Needs . U.S. Department of Housing OMB Approval No. 2506-0117 and Urban Development Exp. 8/31/2014) Table 3C Consolidated Plan Listing of Projects Jurisdiction’s Name City of Palo Alto Priority Need Public Services Project Title Fair Housing Services Description Project Sentinel will provide community education and outreach regarding fair housing law and practices, investigation, counseling and legal referral for victims of housing discrimination, and analyses for City staff and officials regarding fair housing practices. California and federal fair housing laws assure specific protected classes the right to be treated in terms of their individual merits and qualifications in seeking housing. Unfortunately, some people are not aware of the law or their rights. Objective category: Suitable Living Environment Decent Housing Economic Opportunity Outcome category: Availability/Accessibility Affordability Sustainability Location/Target Area Community-wide Street Address: City, State, Zipcode: Objective Number DH-1 Project ID 6 HUD Matrix Code 21D CDBG Citation 570.206 Type of Recipient LMC CDBG National Objective 570.208(a)(2) Start Date (mm/dd/yyyy) 07/01/2014 Completion Date (mm/dd/yyyy) 06/30/2015 Performance Indicator People Annual Units 27 Local ID SR-01087-999 Units Upon Completion 27 Funding Sources: CDBG $32,016 ESG HOME HOPWA Total Formula Prior Year Funds Assisted Housing PHA Other Funding Total $32,016 The primary purpose of the project is to help: the Homeless Persons with HIV/AIDS Persons with Disabilities Public Housing Needs . U.S. Department of Housing OMB Approval No. 2506-0117 and Urban Development Exp. 8/31/2014) Table 3C Consolidated Plan Listing of Projects Jurisdiction’s Name City of Palo Alto Priority Need Planning and Administration Project Title City of Palo Alto Description Administer the Administrative costs for the overall management, coordination, and evaluation of the CDBG program, and the project delivery costs associated with bringing projects to completion. Objective category: Suitable Living Environment Decent Housing Economic Opportunity Outcome category: Availability/Accessibility Affordability Sustainability Location/Target Area City of Palo Alto Street Address: 250 Hamilton Avenue City, State, Zipcode: Palo Alto, CA 94301 Objective Number Project ID 7 HUD Matrix Code 21 CDBG Citation 570.206 Type of Recipient N/A CDBG National Objective N/A Start Date (mm/dd/yyyy) 07/01/2014 Completion Date (mm/dd/yyyy) 06/30/2015 Performance Indicator N/A Annual Units N/A Local ID SR-01003-999 Units Upon Completion N/A Funding Sources: CDBG $81,981 ESG HOME HOPWA Total Formula Prior Year Funds Assisted Housing PHA Other Funding Total $81,981 The primary purpose of the project is to help: the Homeless Persons with HIV/AIDS Persons with Disabilities Public Housing Needs U.S. Department of Housing OMB Approval No. 2506-0117 and Urban Development Exp. 8/31/2014) Table 3C Consolidated Plan Listing of Projects Jurisdiction’s Name City of Palo Alto Priority Need Job creation and replacement Project Title Pilot Microenterprise Assistance Program Description The Pilot Microenterprise Assistance Program will provide resources to support and foster the development of microbusinesses by providing grants to eligible low-to moderate income families in conjunction with capacity building and entrepreneurial assistance. Objective category: Suitable Living Environment Decent Housing Economic Opportunity Outcome category: Availability/Accessibility Affordability Sustainability Location/Target Area Community-wide Street Address: City, State, Zipcode: Objective Number E0-1 Project ID 8 HUD Matrix Code 18C CDBG Citation 570.201(o) Type of Recipient LMCMC CDBG National Objective 570.208(a)(2)(iii) Start Date (mm/dd/yyyy) 07/01/2014 Completion Date (mm/dd/yyyy) 06/30/2015 Performance Indicator Jobs Annual Units 5 Local ID SR-01121-999 Units Upon Completion 5 Funding Sources: CDBG $150,000 ESG HOME HOPWA Total Formula Prior Year Funds Assisted Housing PHA Other Funding Total $150,000 The primary purpose of the project is to help: the Homeless Persons with HIV/AIDS Persons with Disabilities Public Housing Needs . U.S. Department of Housing OMB Approval No. 2506-0117 and Urban Development Exp. 8/31/2014) Table 3C Consolidated Plan Listing of Projects Jurisdiction’s Name City of Palo Alto Priority Need Job creation and replacement Project Title Workforce Development Program Description The Workforce Development Program will provide a transition from unemployment and homelessness to regular employment and housing through case management, job training, mentoring, housing, and transportation assistance. Downtown Streets Team will screen and prepare applicants and will use their community connections to provide training and job opportunities. Objective category: Suitable Living Environment Decent Housing Economic Opportunity Outcome category: Availability/Accessibility Affordability Sustainability Location/Target Area Community-wide Street Address: City, State, Zipcode: Objective Number E0-1 Project ID 9 HUD Matrix Code 05H CDBG Citation 570.204(a)(2) Type of Recipient LMC CDBG National Objective 570.208(a)(2)(A) Start Date (mm/dd/yyyy) 07/01/2014 Completion Date (mm/dd/yyyy) 06/30/2015 Performance Indicator Jobs Annual Units 30 Local ID SR-01121-999 Units Upon Completion 30 Funding Sources: CDBG $314,100 ESG HOME HOPWA Total Formula Prior Year Funds Assisted Housing PHA Other Funding Total $314,100 The primary purpose of the project is to help: the Homeless Persons with HIV/AIDS Persons with Disabilities Public Housing Needs OMB Control No: 2506-0117 (exp. 07/31/2015) Appendix E: Public Hearing Advertisement NOTICE OF PUBLIC REVIEW PERIOD AND PUBLIC HEARINGS ON PALO ALTO’S COMMUNITY DEVELOPMENT BLOCKGRANT (CDBG) PROGRAM This is to notify the general public and other interested parties that a 30-day public review period of the Draft Annual Action Plan for the allocation of Fiscal Year 2015 Community Development Block Grant (CDBG) funds, will begin on March 17, 2014 and end on April 15, 2014. The Draft Annual Action Plan describes the activities the City may fund under the 2015 CDBG Program. Collectively these activities are intended to meet Palo Alto’s affordable housing and community development objectives described in the 2010-2015 Consolidated Plan. Copies of the Draft Annual Action Plan will be available on March 17, 2014 at the Department of Planning and Community Environment, 250 Hamilton Avenue, 5th Floor, Palo Alto, CA 94301, on the City’s website http://www.cityofpaloalto.org/depts/pln/advance_planning/cdbg.asp or by calling Consuelo Hernandez, Planner – CDBG, at (650) 329-2428. Interested parties are encouraged to submit written comments on the proposed Draft Annual Action Plan during the public review period, or to comment at the public hearings and meetings described below. PUBLIC HEARINGS AND MEETINGS The City of Palo Alto Human Relations Commission will hold a Public Hearing on March 13, 2014 to review the Fiscal Year 2015 CDBG funding allocations recommended by the CDBG Human Relations Selection Committee. The Public Hearing will be held at 7:00 p.m., or as soon as possible thereafter, in City Hall Council Conference Room, 250 Hamilton Avenue, Palo Alto. The City of Palo Alto Finance Committee will hold a Public Hearing on April 15, 2014 to review the proposed Fiscal Year 2015 CDBG funding allocations identified in the Draft Annual Action Plan. The Public Hearing will be held at 6:00 p.m., or as soon as possible thereafter, in City Hall Council Conference Room, 250 Hamilton Avenue, Palo Alto. The Palo Alto City Council will hold a Public Hearing on May 5, 2014 to adopt the Annual Action Plan and the associated Fiscal Year 2015 CDBG allocations. The Public Hearing will be held at 7:00p.m., or as soon as possible thereafter, in City Hall Council Chambers, 250 Hamilton Avenue, Palo Alto. Persons with disabilities who require auxiliary aids or services in using City facilities, services or programs, or who would like information on the City’s compliance with the Americans with Disabilities Act (ADA) of 1990, may contact: ADA Coordinator, City of Palo Alto, 650-329-2550 (Voice) ada@cityofpaloalto.org OMB Control No: 2506-0117 (exp. 07/31/2015) Appendix F: Map ElCaminoReal ElCaminoReal AlmaStreet AlmaStreet AlmaSt UniversityAvenue UniversityAve JuniperoSerraBlvdJuniperoSerraBlvd WestPortolaAvenue MarichWay S.RengstorffAvenue CaliforniaStreet LathamStreet DelMedioAvenue ShowersDrive LosAltosAvenue IndependenceAvenue GarciaAvenue ont Road WestridgeDrive DuranzoWay EricaWay SharonParkDrive RosaDrive AltschulAvenue ElenaAvenue TuscaloosaAvenue ColemanRoad LaurelStreet SantaMonicaAvenue GilbertAvenue MenaltoAvenue WoodlandAvenue BellStreet Co o le y A v e n u e O'ConnerStreet RunnymedeStr eet ClarkAvenue WoodlandAvenue PulgasAvenue O'ConnerStreet Beach Street JasmineWay BrannerDrive CampbellLane ShoronRoad LemonStreet OliveAvenue SantaCruzAvenue BayLaurelDrive MiddleAvenue BayLaurelDrive WindsorDrive PeterCouttsCircle LasuenStreet PanamaDr GovernorsAve ElectioneerAve N.LemonAvenue CottonStreetValparaisoAvenue FremontStreet UniversityDrive CambridgeAvenue MiddleAvenue ArborRoad CreekDrive WillowRoad OakGroveAvenue SantaCruzAvenue IsabellaAvenue BrittonAlejandraAvenue EscondidoRoad OlmsteadRoad RingwoodAvenue MiddlefieldRoad MiddlefieldRoad MiddlefieldRd BayshoreFwy BayshoreFwy EmbarcaderoRoad CharlestonRd SantaCruzAvenue SandHillRoad GlenwoodAvenue LomaVerdeAve LyttonAve HomerAve ChanningAve CowperSt EmersonSt AddisonAve EMeadowDr WMeadowDr MaybellAve StanfordAve CaliforniaAve ChimalusDr HeatherLn NewellRd ChurchillAve ParkBlvd Raim undo W ay BryantSt CollegeAve LouisRd GreerRd ColoradoAve RossRd ArastraderoRd ArastraderoRd LosRoblesAve GeorgiaAve LaDonnaSt LagunaAve AmarantaAve BarronAve MataderoAve SealeAve SouthCt ParkBlvd LaParaAve BirchSt LincolnAve PageMillRd ElVeranoAve ElDoradoAve EmersonSt AmarilloAve NCaliforniaAve HawthorneAve AshSt OliveAve VenturaAve AlmaSt WilkieWay FerneAve AlvaradoAvenue LinariaWay LaCuestaDrive CloudAvenue AlmaStreet ClarkAvenue AthertonAvenue AthertonAvenue WatkinsAvenue SanMateoDrive SanAntonioAve JuniperoS erraBlvd tsa E otl A o l a P dro f n a t S ytis r e v i n U A not r e h t oln e M kra P doo w d e R ytiC Mountain View otl A o l a P Road e l as Pul gas d HillRoad Jun iper o Ser r a Boul evar d PageMillRoad ArastraderoRoadE l a mi n o R e a l SanAntonioAvenue Chra l eston Road rO e o g n Exp e r ss w ay Mi d d l e f i e l d Road ersity Ave Bay s ho r e Fr eeway 1 0 1 A l m S r ee t ElCaminoReal MiddlefieldRoad pi neRoad Foothi l l Expres s w a y Road UniversityAve. Hillview East B ya s o h re West Baysh roe Fabian CentralExpressw SandHillRoad EmbarcaderoRoad MarshRoad Bay Expressway Willow eht f o t c u d o r p a s i p a m s i h T SI G o t l A o l a P f o y t i C .se c r u o s e l b a l i a v a t s e b f o y l n o n o i t a t n e s e r p e r c i h p a r g a s i t n e m u c o d s i h T dn e g e L yra d n u o B y t i C o t l A o l a P '0 0 5 4 '0 FY 2014 - 2015 CDBG Projects Location map CITYOF PALOALTO INC O R P O R A T E D CALIFORNIA ot l A o l a P fo y t i C e h T A P R I L 1 6 1894 otl A o l a P f o y t i C 7 0 0 2 o t 9 8 9 1 © . s r o r r e y n a r o f y t i l i b i s n o p s e r ons e m u s s a o t l A o l a P f o y t i C e h T 23: 7 1 : 4 1 5 0 - 5 0 - 1 0 0 2 , a r e v i r r )b d m . a r e v i r r \ l a n o s r e P \ n i m d a \ s i g\$ s i g \ s p a m - cc\\ ( p a m n o i t a c o l g b d c OR S e c a l P a m l A ) 4 OR S l e t o H r e k r a B ) 3 ret n e C y t i n u t r o p p O ) 2 Uivn )1 t C a Fiscaly Year 2014 - Draft Action Plan DUNS No. 050520782 46 City of Palo Alto March 2013 OMB Control No: 2506-0117 (exp. 07/31/2015) Appendix G: Public Comments