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HomeMy WebLinkAboutStaff Report 14143 City of Palo Alto (ID # 14143) City Council Staff Report Report Type: Action Items Meeting Date: 6/20/2022 City of Palo Alto Page 1 Summary Title: CDBG FY 2023 Annual Action Plan & Substantial Amendment to FY2021 Annual Action Plan Title: PUBLIC HEARING: Adoption of the Community Development Block Grant Funds (CDBG) Fiscal Year 2022-23 Annual Action Plan and Adoption of a Resolution Approving Use of CDBG Funds for FY 2022-23; Approval of a Substantial Amendment to the CDBG Fiscal Year 2020-21 Annual Action Plan and Adoption of an Associated Resolution; and Budget Amendment in the FY 2023 Operating Budget in the CDBG Fund From: City Manager Lead Department: Planning and Development Services Recommendation: A. The Human Relations Commission (HRC) and staff recommend City Council take the following actions: 1. Adopt the draft Fiscal Year 2022-23 Annual Action Plan (Attachment A) and the associated resolution (Attachment B) allocating Community Development Block Grant (CDBG) funding for Fiscal Year 2022-23; 2. Authorize the City Manager to execute the Fiscal Year 2022-23 CDBG application to fund the Fiscal Year 2022-23 Annual Action Plan and 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 Fiscal Year 2022-23 Annual Action Plan (Attachment A) to U.S. Department of Housing and Urban Development (HUD) by the July 12, 2022 deadline. B. Staff recommend City Council take the following actions: City of Palo Alto Page 2 1. Approve CDBG Substantial Amendment to the Fiscal Year 2020-21 Annual Action Plan to reallocate $194,501 of CDBG-CV funding to two new projects; 2. Adopt a Resolution (Attachment C) reallocating CDBG-CV funding as recommended in the above action and as described in this report; and 3. Authorize staff to submit CDBG Substantial Amendment to the Fiscal Year 2020-2021 Annual Action Plan to HUD. 4. Approve and authorize the City Manager to accept $653,168 in grant funding from the U.S. Department of Housing and Urban Development (HUD) 5. Approve an amendment to the Fiscal Year 2023 Operating Budget Appropriation for the Community Development Block Grant Fund (requires 2/3 approval) by: a. Increasing the revenue estimate by $847,669; and b. Increase expense appropriations by $761,307; and c. Increase estimated ending fund balance by $86,362. Executive Summary: This report discusses two distinct actions for the CDBG program, one for the adoption for the FY2023 Annual Action Plan and one for the approval of a Substantial Amendment to the FY2021 Annual Action Plan (AAP). FY2023 Annual Action Plan The City is preparing for its second year of a two-year CDBG funding cycle for FY2023. On March 10, 2022, the HRC reviewed the eligible programs and recommended the funding allocations for each project as reflected in the draft AAP (Attachment A). The Council is requested to review the draft FY2023 AAP and approve the recommended funding allocations identified in the document. Council’s approval of the AAP will be recorded by Resolution, see Attachment B. The CDBG federal appropriations for FY2023 were released by the U.S. Department of Housing and Urban Development (HUD) on May 13, 2022. The total amount available for allocation in FY2023 is $653,168, which includes the City’s entitlement grant ($513,168) and estimated program income ($140,000). FY2021 Annual Action Plan Substantial Amendment The City was informed by the CDBG subrecipient LifeMoves that they no longer needed the remaining funds allocated to them in fiscal year 2020-21. These funds supported a Rental Assistance Program and specifically came from CDBG-Coronavirus (CDBG-CV) grants. The remaining funds total $194,501 Staff investigated other funding opportunities for eligible City of Palo Alto Page 3 CDBG-CV activities for the reallocation of the $194,501. The staff recommendation is to fund $160,300 for Move Mountain View to support a safe parking program and $34,201for LifeMoves to administer a COVID-19 testing program. Background: The CDBG program, administered by HUD, provides annual grants on a formula basis to states, cities, and counties. These grants are allocated to develop viable urban communities by providing decent housing, a suitable living environment, and by expanding economic opportunities, principally for low- and moderate-income persons. The HUD regulations require all CDBG funded activities to meet one of the three national objectives listed below: 1. Benefit low-and very-low-income persons; 2. Aid in the prevention or elimination of slums or blight; or 3. Meet other community development needs having particular urgency or posing a serious and immediate threat to the health or welfare of the community. The Palo Alto CDBG program has primarily been focused on meeting the first objective of benefiting low- and very-low-income persons. The applications recommended for funding are consistent with this objective. For general information on the CDBG program, please visit: https://www.hudexchange.info/programs/cdbg-entitlement/. Consolidated Plan & Annual Action Plan HUD requirements include the preparation of a five-year strategic plan of action, referred to as a Consolidated Plan. This plan addresses priority housing and community development needs and sets goals for attaining identified objectives. Currently, Palo Alto’s CDBG program is guided by the 2020-2025 Consolidated Plan1 adopted by Council in 2020. Every year, an AAP is prepared to identify the specific projects to be funded by the CDBG program; these projects must further the implementation of the Consolidated Plan strategies. As Council reviews the proposed projects and recommends funding allocations, consistency with the Consolidated Plan goals is a primary consideration. Annual Action Plan Amendments Under specific circumstances, when the City’s CDBG funding situation changes, amendments to the AAP may be required. There are two types of amendments: 1. Minor Amendments: Changes to a previously adopted Consolidated Plan or Annual Action Plan that does not meet the thresholds to qualify as a Substantial Amendment. Minor amendments are typically processed at a staff level. 12020-2025 Consolidated Plan: https://www.cityofpaloalto.org/civicax/filebank/blobdload.aspx?t=49340.42&BlobID=79655 City of Palo Alto Page 4 2. Substantial Amendments: (a) A change in the use of CDBG funds from one eligible activity to another; (b) The implementation of an activity not previously identified in sufficient detail to provide affected citizens an opportunity to submit comments; or (c) A change in an activity’s program budget which exceeds ten percent of the City’s latest annual entitlement grant; and (d) Staff seeks Council approval for substantial amendments. The recommendations for the reallocation of $194,501CDBG-CV funds require a Substantial Amendment, which is explained in more detail in the Discussion section below. FY2023 Application Review Process Funding applications for “Public Improvements and Facilities” projects were made available on December 13, 2021. A notice of funding availability (NOFA) was published in the Palo Alto Weekly on December 13, 2021, with completed applications due by January 14, 2022. A mandatory pre-proposal conference was conducted on January 7, 2022, to assist applicants with program regulations and project eligibility questions. For FY2023, the second year of a two-year funding cycle, the City did not receive any new funding applications for Public Improvements and Facilities projects. Typically, when new applications are received, the initial step in the review process is the determination that the applications are compliant with HUD’s eligible activities2 and National Objectives.3 This process involves staff reviewing the application materials and communicating with the applicant as needed to clarify details in the application. For FY2022 (year one of funding cycle), the City approved eight funding applications. Seven of those projects were carried over into the 2022-23 CDBG program year. These seven projects were reviewed on February 24, 2022, by the HRC Selection Committee who made the initial project funding recommendations to the full HRC. At the regularly scheduled public hearing on March 10, 2022, the HRC made the funding recommendations reflected in the draft AAP for Council consideration. Once adopted, the AAP will be submitted to HUD by the deadline (July 12, 2022) as the last step in the process. Annual Action Plan Citizen Participation 2 CDBG Matrix Codes: https://files.hudexchange.info/resources/documents/Matrix-Code-Definitions.pdf 3 CDBG National Objectives: https://www.hudexchange.info/sites/onecpd/assets/File/CDBG-National-Objectives-Eligible-Activities-Chapter- 3.pdf City of Palo Alto Page 5 As per HUD’s regulations and the City’s adopted Citizen Participation Plan4, the City must ensure adequate citizen participation in the CDBG funding process. Prior to the submission of the AAP to HUD, the City must hold two public hearings; one hearing, followed by a 30-day circulation and public comment period, followed by one more public hearing. The HRC meeting on March 10, 2022 served as the first public hearing, and the City Council meeting on June 20, 2022 will serve as the second public hearing. After the presentation of the draft FY2023 AAP (Attachment A) to the HRC, the AAP was circulated for public review and comments for a required 30-day period that began on April 2, 2022, and concluded on May 2, 2022. Due to unforeseen changes in circumstance with one subrecipient (i.e. Downtown Streets Team), the AAP was modified and recirculated for public comment from May 20, 2022 through June 20, 2022. At the time of this report, staff did not receive any public comments on the draft AAP. HRC Review - Recommended Allocation for FY2023 At the time of the HRC review, the CDBG federal appropriations for FY2023 was not known. For budgeting purposes, staff estimated the City’s HUD Entitlement Grant for FY2023 based on a 10% reduction from the FY2022 entitlement grant. The estimated total amount available for allocation in FY2023 was $665,459, which included the entitlement grant, program income, and previous year’s resources. The recommended allocations continue to address housing and the needs of housing-insecure individuals and households. For more information, please review the associated report for the meeting. On March 10, 2022, the HRC considered the funding recommendations of the HRC Selection Committee and voted 4-1 to recommend Council approve the draft FY2023 AAP. The HRC discussed the estimated funding allocations based on program budget, availability of additional resources, the federal spending caps, and total available CDBG funds. The HRC inquired about the criteria that was used by the Selection Committee for funding recommendations. Additionally, since the City’s CDBG grant amount was not known at the time of the meeting, HRC recommendations were based on estimated allocations and a funding contingency plan as follows: If the City receives additional funds beyond the estimated allocation, the HRC supports the funding contingency plan to (1) allocate additional funds to projects within the Public Services to match what was funded this year (FY2022), and (2) allocate 4 Adopted Citizen Participation Plan 2020: https://www.cityofpaloalto.org/civicax/filebank/blobdload.aspx?t=51199.36&BlobID=79447 City of Palo Alto Page 6 additional un-capped funds to the 50-unit low-income housing project at 525 E. Charleston Road, with the following modifications: a. For the programs in the Public Services category, Project Sentinel shall be given first priority for full funding to match FY2022 allocation, and b. Staff shall consider additional funding for Rebuilding Together Peninsula. The FY2023 allocation amounts have been updated based on the HRC’s recommendations and updated funding sources and are summarized in the Discussion section of this report. At the time of this report no minutes were available online but a video recording is available for viewing: HRC Meeting - March 10, 2022 - YouTube. Discussion: This report section is divided into the two topics, one for the FY2023 AAP and the other for the FY2021 AAP Substantial Amendment. FY2023 Annual Action Plan Summaries of the FY2023 CDBG grant amount, project funding categories, and proposed allocations are provided below. Funds Available for Allocation in FY2023 The CDBG federal appropriations for FY2023 was received on May 13, 2022. The total amount available for allocation in FY2023 is $653,168, which includes the entitlement grant and estimated program income, as summarized below in Table 1. The recommended allocations continue to address housing and the needs of housing-insecure individuals and households. Table 1: Summary of FY2023 CDBG Funding FY2022-2023 Entitlement Grant $513,168 Estimated Program Income in FY2022-23 from Alta Housing generated from loan repayments and rental income in excess of expenses on specific properties acquired or rehabilitated with CDBG funds $140,000 Total Available for Allocation $653,168 CDBG Funding Categories and Funding Applications The CDBG program has five primary activity areas to allocate funds to: (1) Public Services, (2) Planning and Administration, (3) Economic Development, (4) Housing Rehabilitation, and (5) Public Improvements and Facilities. Federal regulations limit the amount that can be spent on two categories: planning and administration and public services. No more than 20% of the City’s entitlement grant and estimated program income for the following year can be spent on planning and administration. Similarly, there is a maximum spending cap of 15% of the grant City of Palo Alto Page 7 allocation and 15% of any program income received during the previous fiscal year on the public services category. The amount available to allocate in each of the activity area is summarized below. Table 2: CDBG Funding Categories and Allocation Amounts Funding Categories Allowed Allocation Public Services (15% cap) $97,975 Planning and Administration (20% cap) $130,633 Economic Development, Housing Rehabilitation, and Public Improvements and Facilities (un-capped) $424,560 Total Available for Allocation $653,168 Recommended Changes to “Public Services” and “Planning and Administration” Categories In past years, the Planning and Administration funding category was used to cover both the City’s administration cost (part-time staff and consultants) and fund Project Sentinel (Fair Housing Services). In November 2021, the part-time CDBG position became vacant, and City began using consultant services (Michael Baker International) to fully manage the program for the City. With this staffing change, and because the program administration is fully funded by the CDBG grant, additional budget is needed to maintain the program administration. In past years, the City’s administration allocation has been approximately $99,000. For this coming fiscal year, staff is requesting $121,816for the City’s program administration. $86,362 dollars is programmed in the FY 2023 budget, which is subject to City Council approval through the annual budget process. With the City’s administration role requiring more funding, the level of funding for Project Sentinel must be reduced from the Planning and Administration category. Because of Project Sentinel’s program activity, fair housing services, they are also eligible to be funded from the Public Services category, which is what is recommended. Adding Project Sentinel to the Public Services category does, however, impact the funding for the other service providers; allocations must be split between five providers instead of four. Downtown Streets Team/Workforce Development Program Since the HRC meeting and recommendation on the allocations, some concerns have arisen about the eligibility of the Downtown Streets Team (DST) program for program funding. To qualify for the recommended $160,477 allocation in the Economic Development category, DST must maintain a Community Based Development Organization (CBDO) status – this is a HUD requirement for funding in the un-capped Economic Development category (otherwise the program could be funded from Public Services). In order to qualify as a CBDO, Downtown Streets must meet specific characteristics required by HUD: City of Palo Alto Page 8 1. Is an association or corporation organized under State or local law to engage in community development activities (which may include housing and economic development activities) primarily within an identified geographic area of operation within the jurisdiction of the recipient; and 2. Has as its primary purpose the improvement of the physical, economic, or social environment of its geographic area of operation by addressing one or more critical problems of the area, with particular attention to the needs of persons of low and moderate income; and 3. May be either non-profit or for-profit, provided any monetary profits to its shareholders or members must be only incidental to its operations; and 4. Maintains at least 51 percent of its governing body's membership for low- and moderate- income residents of its geographic area of operation, owners or senior officers of private establishments and other institutions located in and serving its geographic area of operation, or representatives of low- and moderate-income neighborhood organizations located in its geographic area of operation; and 5. Is not an agency or instrumentality of the recipient and does not permit more than one- third of the membership of its governing body to be appointed by, or to consist of, elected or other public officials or employees or officials of an ineligible entity; and 6. Requires the members of its governing body to be nominated and approved by the general membership of the organization, or by its permanent governing body; and 7. Is not subject to requirements under which its assets revert to the recipient upon dissolution; and 8. Is free to contract for goods and services from vendors of its own choosing. However, if an organization does not meet one of the criteria set forth by HUD, the organization along with the City can file for an exemption. The exemption would describe how the organization can still undertake the activities but may not meet one or more of the requirements of a CBDO. Downtown Streets requested for the City to support an exemption. This process takes time and based on staff’s engagement with HUD on the matter, approval is uncertain. The proposed FY2023 allocations still include the DST program with the provision that DST’s CBDO status is confirmed by August 31, 2022. There is some risk to the City in making this allocation if the CBDO status is not assured or the exemption is not granted. The risk to the City is a potential reduction in future CBDG funding if the City is not able to disburse a specified percentage of federal funds within a certain timeframe. For this reason, staff recommends a deadline to DST to either comply with the CBDO program requirements or obtain an exemption (which the City is working with DST to obtain). In the event resolution is not provided by the deadline, staff will seek another eligible program to fund. City of Palo Alto Page 9 In any event, staff will not provide any CBDG reimbursement payments until the CBDO status has been validated by HUD. Allocations With the changes described above about the administration allocation, the strategy for funding for the Public Service providers was to allocate funds to match the FY2022 allocations (or get as close as possible). As recommended in the HRC motion above, priority was given to funding Project Sentinel first. Of the five programs, with the recommendation provided in the AAP, three would match the FY2022 allocation amounts, while two would receive a reduction. See Table 3 for details. The HRC included in their motion to consider additional funds for the Rebuilding Together Peninsula program. Staff reviewed the programs existing progress and checked in with the program representatives; additional funding for this program does not seem warranted at this time. The program can work with the proposed allocation amount to meet their goals. There are seven programs recommended for FY2023 allocations that are summarized in the Table 3 below. Detailed descriptions of the funding recommendations and agencies are provided in Attachments A and B. Please note that the City does have to apply for the administration funding to manage the program. Table 3: Summary of Applications and Funding Recommendations Agency/Program Name FY 2022 Funded Amount FY 2023 Recommended Amount Public Services Alta Housing – SRO Resident Support $24,535 $22,413 Catholic Charities/ Ombudsman Program for the rights of seniors in long term care facilities. $10,000 $10,000 LifeMoves (formerly Inn Vision)/Opportunity Services Center $31,545 $26,660 Silicon Valley Independent Living Center/Housing and Emergency Services $14,020 $14,021 Project Sentinel/Fair Housing Services n/a $24,881 Public Services Total (Not to Exceed $97,975) $80,100 $97,975 Planning & Administration City of Palo Alto/CDBG Administration $99,304 $121,816* Project Sentinel/Fair Housing Services $33,698 $8,817 City of Palo Alto Page 10 Planning & Administration Total (Not to Exceed $130,633) $133,002 $130,633 Economic Development Downtown Streets Team/Workforce Development Program $160,477 $160,477 Economic Development Total $160,477 $160,477 Rehabilitation Rebuilding Together Peninsula/ Critical health and safety related home repair needs for low-income homeowners. $73,135 $73,135 Mitchell Park – 525 E. Charleston – Affordable Housing (Construction) n/a $190,948 Rehabilitation Total $73,135 $264,083 New CDBG-CV Allocation MOVE Mountain View – Safe Parking Program n/a $160,300 LifeMoves – COVID-19 Testing Program n/a $34,201 New CDBG-CV Allocation Total n/a $194,501 GRAND TOTAL $847,669 *Of the total FY 2023 administration expenses, $86,362 is already programmed as salary and benefit and allocated charge expenses in the CDBG Fund, subject to the approval of the FY 2023 Operating Budget by the City Council. Substantial Amendment to FY2021 Annual Action Plan This section includes information on the CARES Act, AAP amendments, and recommended CDBG-CV funding allocations. CARES Act The United States Congress passed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) on March 27, 2020. The CARES Act expedites the use of CDBG funds to prevent and respond to COVID-19. Through the CARES Act, the City received a total of $746,413 in two separate grant allocations. These funds are to be used specifically for responding to the COVID- 19 pandemic. On June 15, 2020, Council allocated a portion of the first allocation of CARES Act funding (CDBG-CV1) in the amount of $294,900 to LifeMoves to provide rental assistance to eligible City of Palo Alto Page 11 low-income Palo Alto families (i.e. 80% Area Media Income and below) who have suffered documented income loss due to COVID-19. Of this amount, LifeMoves was able to spend $99,499.50, and is now giving the remaining $194,501back to the City to reallocate. To ensure the expedited use of the CARES Act funds, HUD requires all grantees to expend at least 80% of all the CDBG-CV funds by October 27, 2023; the remaining 20% funds are available to use through FY2026. The City anticipates meeting the 80% expenditure requirement with the funding of the two projects noted below. The City received separate CARES Act funding from the State of California that was allocated to areas of public safety and other department responses to the pandemic (CMR 11596). AAP Substantial Amendments There are two activities noted below that trigger a Substantial Amendment to the FY2021 AAP. Project Cancelled/Funds Returned The approved FY2021 AAP included funding of $294,000 for a project by LifeMoves. This project was for their Rental Assistance Program that provided households that have been financially affected by the COVID-19 pandemic with direct monetary assistance to pay for rent in order to keep them housed. In a letter dated May 3, 2022, LifeMoves informed the City that they were returning the funds because of a decrease in the need for COVID related rental assistance and the inability to expend the funds in a timely manner. This project was part of Resolution No. 9893 adopted by the Council on June 15th, 2020. In accordance with the CDBG guidelines and City’s adopted Citizen Participation Plan, the withdrawal of a project as described above requires a Substantial Amendment to the AAP to show that the funds have been returned on a certain project and reallocated. See Table 4 for the recommended reallocation. Recommended Funding Allocations Staff communicated with two organizations under the public services category to develop new programs to fund with CDBG-CV, MOVE Mountain View for their Safe Parking Program and LifeMoves for their COVID-19 Testing Program. Based on the available funding and proposed programs, staff has prepared funding recommendations described below and identified in Table 4. MOVE Mountain View - Safe Parking Program Staff Recommendation: Fund $160,300 MOVE Mountain View (MMV) is the lead agency operating Safe Parking Programs in Palo Alto and Mountain View. They have been serving the homeless and marginalized vehicle-dwellers in City of Palo Alto Page 12 the area since June 2018. The program provides reserved off-street parking for participants, as well as permanent housing solutions through intensive case management. MMV operates four 24/7 RV Safe Parking lots and three Congregational Safe Parking locations. The total capacity of these lots in Palo Alto and Mountain View is 109 vehicles. The Palo Alto site associated with this funding is the Geng Road Safe Parking Lot. There are 12 RV safe parking spaces with eight spaces for client commuter car parking. A unique resource on this lot is the presence of two buildings housing a library, laundry, kitchen, showers, and office spaces. These services provide great benefits for the clients in the program. MMV would like CDBG-CV funding to add staffing and help pay for utilities. The Safe Parking Program will assist at least 100 persons over a course of a year. The expansion of services made possible by Palo Alto CDBG-CV funding will serve clients referred to Safe Parking in Palo Alto. The estimated 40+ client caseload will be managed by a full-time Case Manager dedicated to Palo Alto clients. In addition, the Case Manager will be the liaison between the Palo Alto Unified School District (PAUSD) and safe parking resources for unhoused families. The Case Manager will also reinforce street outreach efforts to unhoused persons in Palo Alto. The free laundry and showers supported by this grant add to available direct services to Safe Parking clients. This increased use of the facility will require a Lot Manager dedicated to Palo Alto clients to supervise, organize, and monitor the Safe Parking Program at that site. Additionally, a Coordinator for Volunteers is needed to help manage and carry out the volunteer program. MOVE Mountain View is requesting CDBG-CV funds from the City of Palo Alto in the amount of $160,300 to cover the following costs: Case Manager: $79,061 Facilities Manager: $32,895 Coordinator for Volunteers: $24,172 Utilities: $24,172 Total $160,300 LifeMoves - COVID-19 Testing Program (at the Opportunity Services Center) Funding Recommended: $34,201 LifeMoves needs an effective way to test clients in a drop-in setting effectively and quickly for COVID-19. They are requesting $34,201in CDBG-CV funding to purchase approximately 450 Cue Health Tests that test for COVID-19 and deliver accurate results in 20 minutes. Tests can be administered to qualifying residents at any time that the Opportunity Services Center is open, whether the client is symptomatic or asymptomatic. City of Palo Alto Page 13 In general, Cue’s test is the most accurate COVID-19 self-test on the market. In a clinical study with lay users, the Cue COVID-19 Test for Home and Over The Counter (OTC) Use demonstrated sensitivity of 97% (% positive agreement) and specificity of 99% (% negative agreement). Importantly, the study showed the test was 100% accurate in people infected with the virus who were asymptomatic. LifeMoves is requesting CDBG-CV funds from the City of Palo Alto in the amount of $34,200.50 to cover the following costs: • Purchase of CUE Tests: $34,201 Table 4: CDBG-CV Reallocation Funding Recommendations1 Agency Old CDBG- CV Allocation New CDBG- CV Allocation Total Funding Allocation Public Services MOVE Mountain View - Safe Parking Program $0 $160,300 $160,300 LifeMoves - COVID-19 Testing Program $0 $34,201 $34,201 Total $0 $194,501 $194,501 Policy Implications: All programs recommended for funding for the FY2023 AAP and FY2021 AAP Substantial Amendment are consistent with the priorities established in the City’s adopted 2020-2025 Consolidated Plan. Resource Impact: FY2023 AAP - As per HUD’s regulations, up to 20% of the total CDBG funding can be used for the CDBG program administration. The City relies on the annual grant funding to pay for the staff that administers the CDBG program. As described above, for FY2023 staff is requesting additional funding within the HUD allocation to support the program administration. These additional funds are needed to pay for a consultant to manage the program. If the City does not have enough CDBG funding to cover all of the administrative costs necessary to properly run the program, it may require assistance from the General Fund to make up the difference and staff would return to City Council with that request. Additionally, staff is requesting City Council approval of a cost neutral budget amendment to increase both revenue and expense to support FY 2023 CDBG activity of $847,669. This action increases revenues by $847,669, which includes FY 2023 program revenue of $653,168 and City of Palo Alto Page 14 $194,501 from FY 2020-21 allocation which was not spent. This action also increases expenses by $761,307, which will augment $86,362 of expenses already programmed in the FY 2023 budget, which is subject to City Council approval through the annual budget process, for a total expense appropriation in the CDBG Fund of $847,669. The actions recommended in this report will allow for the distribution of this grant funding. FY2021 AAP Substantial Amendment - Staff is requesting City Council reallocate existing CDBG- CV funding from one project to two new projects to allow for the distribution of this grant funding. There are no anticipated resource impacts associated with this action. Timeline: The funding recommendations made by the City Council will be incorporated into the FY2023 AAP. Subsequently, the adopted FY2023 AAP will be submitted to HUD by the July 12, 2022, deadline. The consequence of submitting the AAP late to HUD is a delay in City receiving funds for reimbursement to the programs. Stakeholder Engagement: Prior to the submission of the FY2023 AAP to HUD, the City must hold two public hearings; one hearing, followed by a 30-day circulation and public comment period, followed by one more public hearing. The HRC meeting on March 10, 2022, served as the first public hearing, and the City Council meeting on June 20, 2022 will serve as the second public hearing. After the presentation of the draft FY2023 AAP to the HRC, the AAP was posted on the City’s webpage for public review and comments for a required 30-day period that began on April 2, 2022 and concluded on May 2, 2022. Due to unforeseen changes in circumstances with one subrecipient (i.e. Downtown Streets Team), the AAP was modified and reposted for public comment from May 20, 2022 through June 20, 2022. At the time of this report, staff did not receive any public comments on the draft AAP. The FY2021 AAP Substantial Amendment was also posted for a 30-day public comment period from May 20 through June 20, 2022. The City Council meeting on June 20, 2022 is the respective public hearing for this item. For both the FY2023 AAP and the FY2021 AAP Substantial Amendment, the City published a notice on May 2, 2022 in the Daily Post. The notice informed the public of the June 20 public hearing and the 30-day public review comment period; information was also posted on the City’s CDBG webpage and via email blasts to stakeholders. Environmental Review: City of Palo Alto Page 15 For purposes of the National Environmental Policy Act (NEPA) and the California Environmental Quality Act (CEQA), budgeting by 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 project. Attachments: Attachment A - Draft Fiscal Year 2022-23 Annual Action Plan (DOCX) Attachment B - Fiscal Year 2022-23 CDBG Resolution (DOCX) Attachment C - FY 2020-21 CDBG-CV Substantial Amendment Resolution (DOCX) Attachment D - MOVE Mountain View Safe Parking Program Project Details (DOCX) Attachment E - LifeMoves COVID-19 Testing Program Project Details (DOCX) Attachment F - Draft FY2021 CDBG-CV Substantial Amendment (DOCX) PUBLIC COMMENT PERIOD May 20, 2022 – June 20, 2022 ADMINISTERED BY: PLANNING AND DEVELOPMENT SERVICES FISCAL YEAR 2022-23 ANNUAL ACTION PLAN DRAFT 05/27/2022 1 Table of Contents Executive Summary ...........................................................................................................................2 AP-05 Executive Summary - 91.200(c), 91.220(b) .................................................................................... 2 The Process ................................................................................................................................................... 5 PR-05 Lead and Responsible Agencies - 91.200(b) ................................................................................... 5 AP-10 Consultation - 91.100, 91.110, 91.200(b), 91.300(b), 91.215(l) and 91.315(I) ............................... 7 AP-12 Citizen Participation - 91.105, 91.115, 91.200(c) and 91.300(c) .................................................. 17 Expected Resources .................................................................................................................................... 20 AP-15 Expected Resources - 91.420(b), 91.220(c)(1,2) ........................................................................... 20 Annual Goals and Objectives ...................................................................................................................... 23 AP-20 Annual Goals and Objectives - 91.420, 91.220(c)(3)and(e) .......................................................... 23 AP-35 Projects - 91.420, 91.220(d) ......................................................................................................... 25 AP-38 Project Summary .......................................................................................................................... 26 AP-50 Geographic Distribution - 91.420, 91.220(f) ................................................................................. 32 P-75 Barriers to affordable housing -91.420, 91.220(j) .......................................................................... 33 AP-85 Other Actions - 91.420, 91.220(k) ................................................................................................ 35 Program Specific Requirements .................................................................................................................. 38 AP-90 Program Specific Requirements - 91.420, 91.220(l)(1,2,4) .......................................................... 38 Appendices Appendix A Appendix B Appendix C 2 Executive Summary AP-05 Executive Summary - 91.200(c), 91.220(b) Introduction The City of Palo Alto (City) Fiscal Year (FY) 2022-23 One Year Action Plan contains the City’s one- year plan to carry out housing and community development activities funded by Federal formula grant funds received from the U.S. Department of Housing and Urban Development (HUD), Community Development Block Grant (CDBG) program. This Action Plan covers the third of five program years covered by the City’s 2020-2025 Consolidated Plan which was adopted by the Palo Alto City Council on June 15, 2020. The Department of Planning and Development Services is the lead agency for the Consolidated Plan and submits the Annual Action Plan for the City’s CDBG program. HUD requires entitlement jurisdictions to submit an Annual Action Plan to report the distribution of federal entitlement grant funds over the Consolidated Plan’s five-year period identifying how funding allocations help meet the goals covered in the Consolidated Plan. The CDBG federal appropriations for FY2022-2023 were released by HUD on May 13, 2022. The total amount available for allocation in FY2022-2023 is $653,168, which includes the entitlement grant ($513,168) and program income ($140,000), and is available for funding projects and programs during the 2022 Program Year. The City’s Action Plan covers the time period from July 1, 2022, to June 30, 2023, (HUD Program Year 2022). The City’s FY 2022-23 Action Plan reports on the status of needs and outcomes the City expects to achieve in the coming year. All of the activities mentioned in this Action Plan are based on current priorities. By addressing these priorities, the City hopes to meet those objectives stated in the 2020-2025 Consolidated Plan. All the proposed projects and activities are intended to principally benefit residents of the City who have extremely low-, low- and moderate- income, and populations that have special needs, such as the elderly, disabled, and homeless. Summary of the objectives and outcomes identified in the Plan The City is part of the San Francisco Metropolitan Bay Area, located 35 miles south of San Francisco and 14 miles north of San José. The City is located within the County of Santa Clara, borders San Mateo County, and encompasses an area of approximately 26 square miles, one- third of which consists of open space1. ________________________ 1 U.S. Census Bureau: https://www.census.gov/quickfacts/fact/table/paloaltocity 3 According to Quick facts data provided by the U.S. Census Bureau1, the City's total resident population is 68,572, per the Census on April 1, 2020. The City has the most educated residents in the country and is one of the most expensive cities to live in. In Silicon Valley, the City is considered a central economic focal point and is home to over 9,483 businesses. The Action Plan provides a summary of how the City will utilize its CDBG allocation to the meet the needs of the City’s lower income population. According to the U.S. census data, 6.1% of all residents within the City had incomes below the federal poverty level. Additionally, according to the 2019 Point in Time Homeless Census2, there are 299 unsheltered homeless individuals living within the City of Palo Alto. This number represents an increase of 17% from the 256 individuals that were counted in 2017. As mentioned previously, a total of $653,168 is available for funding projects and programs during FY2022-23. In FY 2022-23 the City received $513,168 from the federal CDBG program and approximately $140,000 in program income. Table 1, “Fiscal Year 2023 CDBG Budget” below summarizes the uses of the funds proposed during FY 2022-23. Table 1: Fiscal Year 2023 CDBG Budget Applicant Agency Allocation Public Services Alta Housing - SRO Resident Supportive Services $22,413 Catholic Charities of Santa Clara County – Long Term Care Ombudsman $10,000 LifeMoves – Case Management at Opportunity Center $26,660 Silicon Valley Independent Living Center – Case Management Services $14,021 Project Sentinel – Fair Housing Services $24,881 Sub-total $97,975 Planning and Administration City of Palo Alto Administration $121,816 Project Sentinel/Fair Housing Services $8,817 Sub-total $130,633 Economic Development Downtown Streets – Workforce Development Program $160,477 Sub-total $160,477 2 South County Homeless Census and Survey Comprehensive Report: https://www.sccgov.org/sites/osh/ContinuumofCare/ReportsandPublications/Documents/2015%20Santa%20Clara%20County%20 Homeless%2 0Census%20and%20Survey/2019%20SCC%20Homeless%20Census%20and%20Survey%20Report.pdf 4 Public Facilities and Improvement Mitchell Park – 525 East Charleston Project $190,948 Sub-total $190,948 Housing Rehabilitation Rebuilding Together Peninsula $73,135 Sub-total $73,135 Grand Total $653,168 Evaluation of past performance This is an evaluation of past performance that helped lead the grantee (the City) to choose its goals or projects. The City is responsible for ensuring compliance with all rules and regulations associated with the CDBG entitlement grant program. The City’s Annual Action Plans and Consolidated Annual Performance and Evaluation Reports (CAPER) have provided many details about the goals, projects and programs completed by the City. A review of past CAPERs reveals a strong record of performance in the use of CDBG funds. For example, during the 2015-2020 Consolidated Plan period, 244 affordable rental units were rehabilitated, 130 jobs were created or retained, and nearly 2,600 households were assisted through public service activities for low- and moderate- income housing. The City evaluates the performance of subrecipients on a semiannual basis. Subrecipients are required to submit semiannual progress reports, which include client data, performance objectives, as well as data on outcome measures. Prior to the start of the program year, program objectives are developed collaboratively by the subrecipient and the City, ensuring that they are aligned with the City's overall goals and strategies. The City utilizes the semiannual reports to review progress towards annual goals. Summary of citizen participation process and consultation process The City solicited input throughout the development of the FY 2022-23 Annual Action Plan. As required by HUD, the City provides multiple opportunities for public review and comment on the Action Plan and on any substantial amendments to it. Per the City’s adopted Citizen Participation Plan, the City held a 30-day public review comment period for the Action Plan. The City published notifications of upcoming public hearings and the 30-day public review comment period in a local newspaper of general circulation, on the City’s CDBG webpage and via email blasts to stake holders. The City held two advertised public hearings on March 10, 2022, and May 20, 2022. The Action Plan 30-day public review period occurred from May 20, 2022, through June 20, 2022. Summary of public comments [To be updated after close of comment period] There were no public comments received during the public review period. 5 Summary of comments or views not accepted and the reasons for not accepting them [To be updated after close of comment period] There were no public comments received during the public review period. The City accepts and responds to all comments that are submitted. As mentioned above, no public comments were received regarding the FY2022-23 Action Plan. Summary Please see above. 6 The Process PR-05 Lead and Responsible Agencies - 91.200(b) Describe agency/entity responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source 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 Agencies Agency Role Name Department/Agency CDBG Administrator Palo Alto City of Palo Alto: Department of Planning and Development Services Narrative The City is the Lead and Responsible Agency for the United States Department of Housing and Urban Development’s (HUD) entitlement programs in Palo Alto. The Department of Planning and Development Services is responsible for administering the City’s CDBG program. The City joined the HOME Consortium in 2015 and receives federal HOME Investment Partnership (HOME) funds through the County. Entitlement jurisdictions receive entitlement funding (i.e., non-competitive, formula funds) from HUD. HUD requires the City to submit a five-year Consolidated Plan and Annual Action Plan to HUD listing priorities and strategies for the use of its federal funds. The Consolidated Plan helps local jurisdictions to assess their affordable housing and community development needs and market conditions to meet the housing and community development needs of its populations. As a part of the Consolidated Plan process for 2020-2025, the City collaborated with the County of Santa Clara (County) as the Urban County representing the cities of Campbell, Los Altos, Los Altos Hills, Los Gatos, Monte Sereno, Morgan Hill, and Saratoga; the cities of Cupertino, Gilroy, Mountain View, Sunnyvale, San José, and Santa Clara; and the Santa Clara County Housing Authority (SCCHA) to identify and prioritize housing and community development needs across the region, and to develop strategies to meet those needs. The FY 2022-23 Annual Action Plan represents the third year of CDBG funding of the 2020-2025 Consolidated Plan. 7 Consolidated Plan Public Contact Information Clare Campbell, Manager of Long Range Planning City of Palo Alto Department of Planning and Development Services 250 Hamilton Avenue, 5th Floor Palo Alto, CA 94301 E-mail: clare.campbell@cityofpaloalto.org Phone: (650) 617-3191 8 AP-10 Consultation - 91.100, 91.110, 91.200(b), 91.300(b), 91.215(l) and 91.315(I) Introduction The Action Plan is a one-year plan which describes the eligible programs, projects, and activities to be undertaken with funds expected during FY 2022-23 and their relationship to the priority housing, homeless and community development needs outlined in the 2020-25 Consolidated Plan. Provide a concise summary of the jurisdiction’s activities to enhance coordination between public and assisted housing providers and private and governmental health, mental health, and service agencies (91.215(I)). During Fiscal Year 2022-23, the City will continue to work with non-profit organizations to provide programs and services for low-income households; private industry, including financial and housing development groups, to encourage the development of affordable housing opportunities regionally and within the City; and other local jurisdictions, including the County of Santa Clara, in carrying out and monitoring regional projects in a coordinated and cost-effective manner. The City will provide technical assistance to the public service agencies it funds with CDBG dollars and will continue to attend the biweekly Regional CDBG/Housing Coordinators meetings. Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans, and unaccompanied youth) and persons at risk of homelessness The Santa Clara County Office of Supportive Housing is the administrator of the regional Continuum of Care (CoC). The City’s Office of Human Services Manager is in contact with the Santa Clara County Office of Supportive Housing and Destination Home regarding issues of homelessness in the community. The Santa Clara County CoC is a group comprising of stakeholders throughout the County, including governmental agencies, homeless service and shelter providers, homeless population, housing advocates, affordable housing developers, and various private parties, including businesses and foundations. City staff attend a bi-weekly CDBG/Housing Coordinator meeting. Members of the CoC meet monthly to plan CoC programs, identify gaps in homeless services, establish funding priorities, and pursue a systematic approach to addressing homelessness. The CoC is governed by the CoC Board, which takes a systems-change approach to preventing and ending homelessness. This same CoC Board is comprised of the same individuals who serve on the Destination: Home (Destination Home) Leadership Board. Destination Home is a public- 9 private partnership that is committed to collective impact strategies to end chronic homelessness. Regional efforts of the CoC include the development of The Community Plan to End Homelessness, which identifies strategies to address the needs of people experiencing homelessness in the County, including chronically homeless individuals and families, families with children, veterans, and unaccompanied youth. The plan also addresses the needs of persons at risk of homelessness. The new community plan to end homelessness can be viewed at https://destinationhomesv.org/community-plan. Also, during the development of the 2020-25 Consolidated Plan, the City consulted both the CoC and County Office of Supportive Housing for their expertise and experience for identifying community needs. Describe consultation with the Continuum(s) of Care that serves the jurisdiction's area in determining how to allocate ESG funds, develop performance standards and evaluate outcomes, and develop funding, policies, and procedures for the administration of HMIS The City is not an ESG entitlement jurisdiction and therefore does not receive ESG funds. However, the City does administer federal grant programs that help homeless and low-income families in Santa Clara County. The City also helps fund and conduct the Point in Time (PIT) count, the biennial regional collaborative effort to count and survey people experiencing homelessness. The latest count and survey were conducted on February 24, 2022. The data from the 2022 County of Santa Clara PIT count is used to plan, fund, and implement actions for reducing chronic homelessness and circumstances that bring about homelessness. The Santa Clara County Office of Supportive Services takes the role of Homeless Management Information System (HMIS) administration. The County, and its consultant Bitfocus, work jointly to operate and oversee HMIS. Both software and HMIS system administration are now provided by Bitfocus. Funding for HMIS in Santa Clara County comes from HUD, the County of Santa Clara, and the City of San Jose. The County’s HMIS is used by many City service providers across the region to record information and report outcomes. Describe Agencies, groups, organizations, and others who participated in the process and describe the jurisdictions consultations with housing, social service agencies and other entities Table 3: Agencies, Groups, Organizations Who Participated 1 Agency/Group/Organization Boys and Girls Clubs of Silicon Valley Agency/Group/Organization Type Services-Children What section of the Plan was addressed by Consultation? Needs Assessment and Strategic Plan 10 How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended Santa Clara focus group meeting on 11/7/19 as part of the 2020-25 Consolidated Plan process. 2 Agency/Group/Organization Healthier Kids Foundation Santa Clara County Agency/Group/Organization Type Services-Children What section of the Plan was addressed by Consultation? Needs Assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended Santa Clara focus group meeting on 11/7/19 as part of the 2020-25 Consolidated Plan process 3 Agency/Group/Organization Community Services Agency Agency/Group/Organization Type Services-Elderly Persons What section of the Plan was addressed by Consultation? Needs Assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended stakeholder consultation conference call on 11/15/19 as part of the 2020-25 Consolidated Plan process 4 Agency/Group/Organization San Jose Conservation Corps Charter Agency/Group/Organization Type Services-Education What section of the Plan was addressed by Consultation? Needs Assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended Gilroy focus group meeting on 11/18/19 as part of the 2020-25 Consolidated Plan process 11 5 Agency/Group/Organization CommUniverCity San Jose Agency/Group/Organization Type Services-Education What section of the Plan was addressed by Consultation? Needs assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended stakeholder consultation conference call on 11/25/19 and regional forum meeting in San Jose on 11/20/19 as part of the 2020-25 Consolidated Plan process. 6 Agency/Group/Organization The Health Trust Agency/Group/Organization Type Services-Persons with Disabilities Services-Persons with HIV/AIDS Services-Health What section of the Plan was addressed by Consultation? Needs Assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended stakeholder consultation on 11/21/19 as part of the 2020-25 Consolidated Plan process 7 Agency/Group/Organization Rebuilding Together, Silicon Valley Agency/Group/Organization Type Housing What section of the Plan was addressed by Consultation? Strategic plan and needs assessment How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended stakeholder consultation conference call on 11/21/19 and San Jose regional forum on 11/20/19 as part of the 2020-25 Consolidated Plan process 8 Agency/Group/Organization City of Cupertino Agency/Group/Organization Type Other government - Local What section of the Plan was addressed by Consultation? Needs assessment and strategic plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency was contacted for consultation as a partner in addressing the needs of the County as part of the 2020-25 Consolidated Plan process 12 9 Agency/Group/Organization City of Gilroy Agency/Group/Organization Type Other government - Local What section of the Plan was addressed by Consultation? Needs assessment and strategic plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency was consulted and provided emailed feedback as part of the 2020-25 Consolidated Plan process 10 Agency/Group/Organization City of Mountain View Agency/Group/Organization Type Other government - Local What section of the Plan was addressed by Consultation? Needs assessment and strategic plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended regional forum meeting at Palo Alto on 11/7/19 as part of the 2020-25 Consolidated Plan process 11 Agency/Group/Organization Bill Wilson Center Agency/Group/Organization Type Services-Children What section of the Plan was addressed by Consultation? Needs Assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended Santa Clara focus group meeting on 11/7/19, community meetings on 11/4/19 at Morgan Hill and 11/20/19 at Roosevelt as part of the 2020-25 Consolidated Plan process 12 Agency/Group/Organization Heart of the Valley Agency/Group/Organization Type Services-Elderly Persons What section of the Plan was addressed by Consultation? Needs Assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency was consulted through interview questions. Agency provided emailed feedback as part of the 2020-25 Consolidated Plan process 13 13 Agency/Group/Organization City of San Jose Agency/Group/Organization Type Other government - Local What section of the Plan was addressed by Consultation? Needs assessment and strategic plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency was contacted for consultation as a partner in addressing the needs of the County as part of the 2020-25 Consolidated Plan process 14 Agency/Group/Organization City of Morgan Hill Agency/Group/Organization Type Other government - Local What section of the Plan was addressed by Consultation? Needs assessment and strategic plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended regional forum meeting at Morgan Hill on 11/4/19 as part of the 2020-25 Consolidated Plan process 15 Agency/Group/Organization City of Sunnyvale Agency/Group/Organization Type Other government - Local What section of the Plan was addressed by Consultation? Needs assessment and strategic plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended regional forum meeting at Palo Alto on 11/7/19 and provided emailed feedback as part of the 2020-25 Consolidated Plan process 16 Agency/Group/Organization Servant Partners Agency/Group/Organization Type Neighborhood Organization Neighborhood Organization What section of the Plan was addressed by Consultation? Needs Assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Attended community meeting on 11/13/19 at Hillview library as part of the 2020-25 Consolidated Plan process 14 17 Agency/Group/Organization Senior Adults Legal Assistance (SALA) Agency/Group/Organization Type Service-Fair Housing Legal What section of the Plan was addressed by Consultation? Needs assessment and strategic plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended Palo Alto and San Jose public engagement meeting on 11/17/19 and 11/19/19, regional forum meeting on 11/4/19 at Morgan Hill and 11/7/19 at Palo Alto as part of the 2020-25 Consolidated Plan process 18 Agency/Group/Organization HomeFirst Agency/Group/Organization Type Services-homeless What section of the Plan was addressed by Consultation? Needs assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended regional forum meeting at Morgan Hill on 11/4/19 as part of the 2020-25 Consolidated Plan process 19 Agency/Group/Organization Santa Clara County Office of Supportive Housing Agency/Group/Organization Type Other government - County Continuum of Care What section of the Plan was addressed by Consultation? Needs assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended regional forum meeting at Morgan Hill on 11/4/19 and at Palo Alto on 11/7/19 as part of the 2020-25 Consolidated Plan process 20 Agency/Group/Organization City of Santa Clara Agency/Group/Organization Type Other government - Local What section of the Plan was addressed by Consultation? Needs assessment and Strategic Plan 15 How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended regional forum meeting at Morgan Hill on 11/4/19 and provided emailed feedback as part of the 2020-25 Consolidated Plan process 21 Agency/Group/Organization Vista Center for the Blind and Visually Impaired Agency/Group/Organization Type Services-Persons with Disabilities What section of the Plan was addressed by Consultation? Needs assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended stakeholder consultation on 12/9/19 as part of the 2020-25 Consolidated Plan process 22 Agency/Group/Organization Destination: Home Agency/Group/Organization Type Services-homeless What section of the Plan was addressed by Consultation? Needs assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended stakeholder consultation on 11/11/19 as part of the 2020-25 Consolidated Plan process 23 Agency/Group/Organization Community Solutions Agency/Group/Organization Type Services-Victims of Domestic Violence What section of the Plan was addressed by Consultation? Needs assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended the AFH and ConPlan joint meeting on 12/11/19 at the Gilroy Council Chambers as part of the 2020-25 Consolidated Plan process 24 Agency/Group/Organization St Mary Parish Agency/Group/Organization Type Neighborhood Organization Neighborhood Organization What section of the Plan was addressed by Consultation? Needs assessment and Strategic Plan 16 How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency attended the AFH and ConPlan joint meeting on 12/11/19 at the Gilroy Council Chambers as part of the 2020-25 Consolidated Plan process 25 Agency/Group/Organization Community and Neighborhood Revitalization Committee - Gilroy Agency/Group/Organization Type Community Organization What section of the Plan was addressed by Consultation? Needs assessment and Strategic Plan How was the Agency/Group/Organization consulted and what are the anticipated outcomes of the consultation or areas for improved coordination? Agency co-hosted the AFH and ConPlan joint meeting on 12/11/18 at the Gilroy Council Chambers as part of the 2020-25 Consolidated Plan process Identify any Agency Types not consulted and provide rationale for not consulting Not applicable. Other local/regional/state/federal planning efforts considered when preparing the Plan Table 4: Other Local / Regional / Federal Planning Efforts Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? Continuum of Care Regional Continuum of Care Council Identifies housing inventory count to facilitate the provision of housing services to those experiencing homelessness. City of Palo Alto Housing Element (2015-2023) City of Palo Alto Identifies barriers to affordable housing, such as land- use controls, inefficiencies of the development review process, and strategies to alleviate such barriers. 2012-2014 Comprehensive HIV Prevention and Care Plan Santa Clara County HIV Planning Council for Prevention and Care This plan provides a roadmap for the Santa Clara County HIV Planning Council for Prevention and Care to provide a comprehensive and compassionate system of HIV prevention and care services for the County. This effort aligns with the Strategic Plan's goal to support activities that strengthen neighborhoods through the provision of community services and public improvements. 17 Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? SCCHA Moving to Work Annual Plan Santa Clara County Housing Authority Addresses housing authority updates and strategies pertaining to public housing and vouchers. Regional Housing Need Plan for San Francisco Bay Area Association of Bay Area Governments This plan analyzes the total regional housing need for the County and all of the Bay Area. This effort aligns with the Strategic Plan's goal to assist in the creation and preservation of affordable housing. Community Plan to End Homelessness in Santa Clara Destination: Home The Community Plan to End Homelessness in the County is a five-year plan to guide governmental actors, nonprofits, and other community members as they make decisions about funding, programs, priorities and needs. This effort aligns with the Strategic Plan's goal to support activities to end homelessness Palo Alto's Infrastructure: Catching Up, Keeping Up, and Moving Ahead City of Palo Alto Infrastructure Blue Ribbon Plan This plan details recommendations for infrastructure maintenance and replace, as well as identifies potential sources of funding. This effort aligns with the Strategic Plan's goal to support activities that strengthen neighborhoods through the provision of community services and public improvements City of Palo Alto Comprehensive Plan (2030) City of Palo Alto This plan is the primary tool for guiding future development in Palo Alto. It provides a guide for long- term choices and goals for the City future. This effort aligns with the Strategic Plan's goal to support activities that strengthen neighborhoods through the provision of community services and public improvements Narrative Please see above. 18 AP-12 Citizen Participation - 91.105, 91.115, 91.200(c) and 91.300(c) Summary of citizen participation process/Efforts made to broaden citizen participation. Summarize citizen participation process and how it impacted goal-setting The Planning and Development Services Department is the lead agency for overseeing the development of the Consolidated Plan and Action Plan. Per the City’s adopted Citizen Participation Plan, the City is to allow a 30-day public review and comment period for the Action Plan. The City has published notifications of upcoming public hearings and the 30-day public review comment period in the local newspaper of general circulation, on its CDBG webpage and via email blasts. The City held two advertised public hearings on March 10, 2022, and June 20, 2022. The Action Plan 30-day public review comment period occurred from May 20, 2022, through June 20, 2022. The City has not received any public comments to-date. Citizen Participation Outreach Table 5: Citizen Participation Outreach Mode of Outreach Target of Outreach Summary of response Summary of comments received Summary of comments not accepted/reason Public Hearing Nontargeted/ The Human Two members of All comments broad Relations the public were accepted. community Commission met provided on March 10, comments on the 2022 to discuss funding the FY2022-23 allocation. Three funding members allocations and representing three review the draft funding FY2022-23 applicants Annual Action provided Plan comments at the meeting. Public Hearing Nontargeted/ broad community The City Council met on June 20, 2022, to discuss the FY2022-23 funding allocations and adopt the draft FY2022-23 AAP. Update After Meeting Update After Meeting 19 Mode of Outreach Target of Outreach Summary of response Summary of comments received Summary of comments not accepted/reason Newspaper Ad Nontargeted/ broad community Notice of Human Relations Commission Public Hearing and Public Comment period on the First Draft FY2022-23 CDBG Funding Allocations was published in the Daily Post on February 24, 2022. Two members of the public provided comments on the programs being funded. Newspaper Ad Nontargeted/ broad community Notice of Public Hearing and Public comment period on the Second Draft AAP was published in the Daily post on April 2, 2022 and May 20, 2022 Update if comments received Website Nontargeted/ broad community Draft AAP FY2022-23 posted at: Update if comments received https://www.cityofp aloalto.org/CDBG 20 Expected Resources AP-15 Expected Resources - 91.420(b), 91.220(c)(1,2) Introduction In FY2022-23, the City will allocate $653,168 to eligible activities that address the needs identified in the Consolidated Plan. It should be noted that while the HUD CDBG allocations are critical, the allocations are not sufficient to overcome barriers and address all needs that low- income individuals and families face in attaining self-sufficiency. The City will continue to leverage additional resources as described below to provide support and services to the populations in need within the community. The following section discusses the anticipated resources available for community development activities during the next remaining three years of the City’s 5-Year Consolidated Plan. Anticipated Resources Table 6: Expected Resources FY2022-23 – Priority Table Source of Funds Uses of Funds Expected Amount Available Year 2 Narrative Description Program: CDBG Annual $ Program Income: $ Prior Year: $ Total: $ Public - Federal Admin and Planning Economic Development Housing Public Improvement Public Services 513,168 140,000 0 653,168 CDBG funds will be used for the creation and preservation of affordable rental units, improvements in lower income neighborhoods, and public services that benefit low income and special needs households 21 Explain how federal funds will leverage those additional resources (private, state, and local funds), including a description of how matching requirements will be satisfied Entitlement Funds Leverage, in the context of the CDBG and HOME Investment Partnerships Program (HOME), means bringing other local, state, and federal financial resources to maximize the reach and impact of the City’s HUD Programs. HUD, like many other federal agencies, encourages the recipients of federal monies to demonstrate that efforts are being made to strategically leverage additional funds in order to achieve greater results. The City joined the Santa Clara County's HOME Consortium in 2015 and does not receive federal HOME funds on an entitlement basis from HUD. The HOME Consortia consists of the cities of Cupertino, Gilroy, Palo Alto, and the Urban County. HOME funds can be used to fund eligible affordable housing projects for acquisition, construction, and rehabilitation. Starting in FY 2015- 16 developers of affordable housing projects were eligible to competitively apply through an annual RFP process directly to the County for HOME funds to help subsidize affordable housing projects in Palo Alto. Applications will be directly submitted through the County's request for proposal process for available HOME funds. Certain nonprofit organizations known as Community Housing Development Organizations (CHDOs) may also apply for funding from State HCD for housing projects located within Palo Alto. The City received one HOME grant from 1992 HOME funding for the Barker Hotel project. Proceeds from HOME loan repayments must be deposited into a HOME Program Income Fund and used in accordance with the HOME program regulations. In addition, the County will only fund a project that has the local support of the City. If the City receives HOME dollars from its participation in the HOME consortium, the required 25% matching funds will be provided from the City’s Affordable Housing Fund, which is comprised of two sub-funds: The Commercial Housing Fund and the Residential Housing Fund. To date, no projects within the City have been funded through the HOME Consortium. Moving forward, the City plans to increase outreach to developers in the City to provide additional information on the HOME Consortium and available funding. Other State and Federal Grant Programs In addition to the CDBG entitlement dollars, the federal government has several other funding programs for community development and affordable housing activities. These include Section 8 Housing Choice Voucher Program, Section 202, Section 811, the Federal Home Loan Bank Affordable Housing Program (AHP), and others. It should be noted that in most cases the City would not be the applicant for these funding sources as many of these programs offer assistance to affordable housing developers rather than local jurisdictions. The State of California has recently passed approximately 20 bills with the intent of increasing or preserving affordable housing with the State. According to the Governor’s State of the State 22 address, bills that help increase housing production, both market-rate and affordable, will be a priority in 2020. The City will continue to track and look for opportunities to leverage State resources for the City. Local Housing and Community Development Sources Other local resources that support housing and community development programs include: • Palo Alto Commercial Housing Fund, which is for the development of below market rate (BMR) housing units and paid by mitigation fees on commercial and industrial projects; and • Palo Alto Residential Housing Fund, which is for the development of below market rate (BMR) housing units and paid by miscellaneous funding sources. The City will continue to seek opportunities for projects that meet local bond requirements in order to bring additional resources to help the City’s affordable housing shortage. If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan The City has no surplus public land. However, in 2019, the Governor Newsome signed Executive Order N-06-19 that ordered the California Department of General Services (DGS) and the California Department of Housing and Community Development (HCD) to identify and prioritize excess state-owned property and aggressively pursue sustainable, innovative, cost-effective housing projects. There is no excess state property in the City of Palo Alto. Discussion Please see information provided in previous sections. 23 Annual Goals and Objectives AP-20 Annual Goals and Objectives - 91.420, 91.220(c)(3) and(e) Goals Summary Information – FY2022-23 Table 7: Goals Summary Goal Name Start End Category Area Needs Addressed Fund Goal Outcome Indicator Affordable Housing 2020 2025 Affordable Housing Citywide Affordable Housing CDBG: $264,083 Homeowner Housing Rehabilitated: 6 Household Housing Units Low/Moderate Income Housing Benefit: 2077 Persons Assisted Homelessness 2020 2025 Homeless Citywide Homelessness CDBG: $49,073 Public service activities other than Low/Moderate Income Housing Benefit: 119 Persons Assisted Strengthen Neighborhoods 2020 2025 Non- Homeless Special Needs Non-Housing Community Development Citywide Community Services and Public Improvements CDBG: $24,021 Public service activities other than Low/Moderate Income Housing Benefit: 50 Persons Assisted 24 Fair Housing 2020 2025 Non-Housing Community Development Citywide Fair Housing CDBG: $33,698 Public service activities other than Low/Moderate Income Housing Benefit: 15 Persons Assisted Economic Development 2020 2025 Non-Housing Community Development Citywide Economic Development CDBG: $160,477 Jobs created/retained: 14 Jobs 25 Goal Descriptions 1 Goal Name Affordable Housing Goal Description Assist in the creation and preservation of affordable housing for low income and special needs households. 2 Goal Name Homelessness Goal Description Support activities to prevent and end homelessness, such as funding affordable housing opportunities, resource centers for homeless individuals, and support for tenants of single-room occupancy units. 3 Goal Name Strengthen Neighborhoods Goal Description Provide community services and public improvements to benefit low-income and special needs households. This includes assisting those with disabilities to transition from unstable housing to permanent housing, supporting residents of long-term care facilities, and supporting individuals experiencing domestic violence. 4 Goal Name Fair Housing Goal Description Promote fair housing choice by funding fair housing organizations to provide fair housing services, such as education, tenant-landlord mediation, and testing. 5 Goal Name Economic Development Goal Description Support economic development activities that promote employment growth and help lower-income people secure and maintain jobs. This includes funding nonprofits working toward developing the skills of low-income and homeless individuals. 26 AP-35 Projects - 91.420, 91.220(d) Introduction The Consolidated Plan goals below represent high priority needs for the City of Palo Alto (City) and serve as the basis for the strategic actions the City will use to meet these needs. The goals, listed in no particular order, are: 1. Assist in the creation and preservation of affordable housing for low income and special needs households. 2. Support activities to end homelessness. 3. Support activities that strengthen neighborhoods through the provision of community services and public improvements to benefit low income and special needs households. 4. Promote fair housing choice. 5. Expand economic opportunities for low-income households. It is important to note, Project Sentinel, whom will be providing fair housing services will be under two categories, Planning and Administration and Public Services. Table 8: Project Information No. Project Name 1. Catholic Charities of Santa Clara County - Long Term Care Ombudsman 2. LifeMoves - Opportunity Services Center and Hotel De Zink (HDZ): Case Management 3. Alta Housing - Single Room Occupancy (SRO) Support Services 4. Silicon Valley Independent Living Center- Housing and Emergency Services for Persons with Disabilities 5. Project Sentinel - Fair Housing Services 6. City of Palo Alto - Planning and Administration 7. Downtown Streets Inc. - Workforce Development Program. 8. Rebuilding Together Peninsula – Safe at Home 9. Mitchell Park Place – 525 E. Charleston – 50 Unit Development of Affordable Housing Describe the reasons for allocation priorities and any obstacles to addressing underserved needs The City awards CDBG funding to projects and programs that will primarily benefit low-income, homeless, and special needs households. The City operates on a two-year grant funding cycle for CDBG public service grants and a one-year cycle for CDBG capital housing rehabilitation and public facilities and improvement projects. Projects are only considered for funding within the Consolidated Plan period if they address the goals discussed above. 27 AP-38 Project Summary Project Summary Information 1 Project Name Catholic Charities of Santa Clara County: Long Term Care Ombudsman Target Area Citywide Goals Supported Strengthen Neighborhoods Needs Addressed Community Services and Public Improvements Funding CDBG: $10,000 Description Long-Term Care Ombudsman Program. Eligible Activity (Matrix Code):05A. CDBG National Objective: LMC Target Date 6/30/2023 Estimate the number and type of families that will benefit from the proposed activities The program will provide advocacy and complaint investigation for 50 elderly residents of long-term care facilities in Palo Alto. Location Description Long-term care and skilled nursing facilities throughout the City. Planned Activities Regular contact with Palo Alto Residential Care Facilities to observe and monitor conditions of care. 2 Project Name LifeMoves - Opportunity Services Center and Hotel De Zink (HDZ): Case Management Target Area Citywide Goals Supported Homelessness Needs Addressed Homelessness Funding CDBG: $26,660 Description Opportunity Services Center Eligible Activity (Matrix Code):03T CDBG National Objective: LMC Target Date 6/30/2023 28 Estimate the number and type of families that will benefit from the proposed activities 30 unduplicated individuals (homeless and/or very low-income individuals per year) will receive case management services including assistance with housing/job searches, referrals and mentoring at the Opportunity Services Center and Hotel De Zink. Location Description 33 Encina Way, Palo Alto, CA 94301 Planned Activities Case management services will be provided to Opportunity Services Center and Hotel De Zink clients in locating housing and/or employment and be connected to benefits. 3 Project Name Alta Housing Target Area Residents of Barker Hotel (25 units) and Alma Place (106 units) Goals Supported Homelessness Needs Addressed Homelessness Funding CDBG: $22,413 Description SRO Resident Support Program. Eligible Activity (Matrix Code):05O CDBG National Objective: LMC Target Date 6/30/2023 Estimate the number and type of families that will benefit from the proposed activities Case management and support counseling services will be provided to residents of Barker Hotel and Alma Place Location Description 439 Emerson Street, Palo Alto, CA 94301 735 Alma Street Palo Alto, CA 94301 Planned Activities Alta Housing engages a service coordinator to provide 40 hours weekly services to provide case management and support counseling services to residents at Alma Place and Barker Hotel to help them maintain housing stability. Activities include financial counseling, health maintenance, information and referral, problem solving, employment assistance, crisis intervention and case management. Both Alma Place and Barker Hotel are single-room occupancy facilities. 4 Project Name Silicon Valley Independent Living Center: Housing and Emergency Housing Services Target Area Citywide 29 Goals Supported Strengthen Neighborhoods Needs Addressed Community Services and Public Improvements Funding CDBG: $14,021 Description Housing and Emergency Housing Services. Eligible Activity (Matrix Code):05B. CDBG National Objective: LMC Target Date 6/30/2023 Estimate the number and type of families that will benefit from the proposed activities 27 unduplicated Palo Alto residents will benefit from one-on-one housing assistance. Location Description Citywide Planned Activities 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, and referral, and other basic essentials. 5 Project Name Project Sentinel - Fair Housing Services Target Area Citywide Goals Supported Fair Housing Needs Addressed Fair Housing Funding CDBG: $33,698 ($24,881 Public Services & $8,817 Planning & Administration) Description Planning & Administration - Fair Housing Services. Eligible Activity (Matrix Code):21D. CDBG National Objective: LMC . Public Service - Fair Housing Services. Eligible Activity (Matrix Code):05J. CDBG National Objective: LMC. Target Date 6/30/2023 Estimate the number and type of families that will benefit from the proposed activities 15 unduplicated individuals will be provided with fair housing services of complaint counseling, investigation, and where appropriate enforcement referral. 30 Location Description Citywide Planned Activities 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. 6 Project Name City of Palo Alto - Planning and Administration Target Area Citywide Goals Supported Affordable Housing Homelessness Strengthen Neighborhoods Fair Housing Economic Development Needs Addressed Affordable Housing Homelessness Community Services and Public Improvements Fair Housing Economic Development Funding CDBG: $121,816 Description Planning and Administration: CDBG Citation: 570.206(a) Target Date 6/30/2023 Estimate the number and type of families that will benefit from the proposed activities The City will provide general administrative support to the CDBG program. Location Description Citywide Planned Activities 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. 7 Project Name Downtown Streets Inc. - Workforce Development Program. Target Area Citywide Goals Supported Economic Development 31 Needs Addressed Economic Development Funding CDBG: $160,477 Description Workforce Development Program. Eligible Activity (Matrix Code): 05H. CDBG National Objective: LMC Target Date 6/30/2023 Estimate the number and type of families that will benefit from the proposed activities 14 unduplicated homeless and unemployed persons will be placed in jobs through job training/employment readiness classes and outreach to local employers. Location Description Citywide Planned Activities 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. 8 Project Name Rebuilding Together Peninsula – Safe at Home Target Area Citywide Goals Supported Affordable Housing Needs Addressed Affordable Housing Funding CDBG: $73,135 Description Preserves affordable housing by transforming homes through critical repairs and accessibility modifications, at no cost to the service recipient. The majority of the low-income homeowners served will be elderly seniors and/or people with disabilities, who are physically and financially unable to maintain safe living conditions for themselves and their families Eligible Activity (Matrix Code):14A. CDBG National Objective: LMC Target Date 6/30/2023 Estimate the number and type of families that will benefit from the proposed activities 4 households 32 Location Description Citywide Planned Activities Provide home safety repairs, mobility, and accessibility improvements for low- income households in Palo Alto with the primary consideration being the correction of safety hazards. 9 Project Name Mitchell Park Place – 525 E. Charleston Road Target Area N/A Goals Supported Affordable Housing Needs Addressed Affordable Housing Funding CDBG: $190,948 Description Eden Housing is developing 50 units of affordable housing. Approximately half the units are for persons with disabilities. The parcel is owned by the County and will be a long-term lease with the developer. The City intends to use CDBG funding for predevelopment costs as per HUD regulations. Eligible Activity (Matrix Code):12. CDBG National Objective: LMC Target Date 6/30/2023 Estimate the number and type of families that will benefit from the proposed activities 50 Low-Income Households Location Description 525 E. Charleston Road Planned Activities Provide affordable housing for persons with disabilities. 33 AP-50 Geographic Distribution - 91.420, 91.220(f) Description of the geographic areas of the entitlement (including areas of low-income and minority concentration) where assistance will be directed The City allocates CDBG funds to benefit low-moderate income (LMI) households and does not have target areas. Instead, the City focuses its services and capital improvements across the City as a whole. Geographic Distribution Table 9: Geographic Distribution Target Area Percentage of Funds Citywide 100% Rationale for the priorities for allocating investments geographically Not applicable. Discussion Please see discussion above. 34 AP-75 Barriers to affordable housing -91.420, 91.220(j) Introduction The incorporated and unincorporated jurisdictions within the County face barriers to affordable housing that are common throughout the Bay Area. High on the list of market barriers is the lack of developable land, which increases the cost of available lands and increases housing development costs. Local opposition is another common obstacle as many neighbors have strong reactions to infill and affordable housing developments. Their opposition is often based on misconceptions, such as a perceived increase in crime; erosion of property values; increase in parking and traffic congestion; and overwhelmed schools. However, to ensure a healthy economy the region must focus on strategies and investment that provide housing for much of the region’s workforce – for example, sales clerks, secretaries, waiters, baristas, teachers, and health service workers – whose incomes significantly limit their housing choices. It should be noted that in a constrained housing supply market, when housing developments produce housing that is relatively affordable, higher income buyers and renters generally outbid lower income households. A home’s final sale or rental price will typically exceed the projected sales or rental costs. Public subsidies are often needed to guarantee affordable homes for low- and moderate-income households. 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 Palo Alto is addressing the barriers to affordable housing through: • Density Bonus Ordinance: The City recently updated its Density Bonus ordinance which lowered the eligibility requirements to qualify for a higher density bonus percentage up to 80% as well as providing more exceptions to applicable zoning and development standards. One significant update is if a 100% affordable development is located within a half a mile of a major transit stop, the City cannot impose any density limits and entitled to a maximum height increase of three additional stories or 33 feet. • Below Market Rate (BMR) Housing Program: Established in 1974, the City’s BMR requires developers to provide a certain percentage of units as BMR in every approved project of three units or more. The program originally required that for developments on sites of less than five acres, the developer must provide 15 percent of the total housing units as BMR housing units. If the site was larger than five acres, the developer was required to provide 20 percent of the units as BMR housing. The City of Palo Alto have historically used in-lieu fees and the use of development impact fees charged on new, market-rate housing and/or commercial development to finance 100% affordable developments. The City updated its Commercial and Residential Impact Fee Nexus Studies 35 and adopted two ordinances to make changes to its BMR program and adopted a new fee structure. The ordinances became effective on June 19, 2017. • Fair Housing: The City provides funding to Project Sentinel. Project Sentinel provides expertise in fair housing law and tenant-landlord disputes. Services include information, referrals, community outreach and education. In addition, Project Sentinel resolve fair housing complaints via investigation, mediation, education and outreach to both property owners and tenants about fair housing policies. • Housing Incentive Program (HIP): Effective May 2, 2019, this Ordinance adopted changes to the following zoning districts: Citywide – where multifamily uses are permitted, Multifamily Residential Districts (RM), Downtown (CD-C), California Avenue (CC ((2)), and El Camino Real (CS and CN). • Affordable Housing (AH) Combining District: In 2018, The City Council adopted the Affordable Housing Combining District to provide flexible development standards beyond the State Density Bonus Law to allow 100% affordable housing projects located in a commercial zoned area. • Workforce Housing (WH) Combining District: The City Council also adopted in 2018 the Workforce Housing Combining District to encourage the development of housing within half-mile of major fixed rail transit by modifying flexible development standards for the public facilities (PF) zoning district. Discussion Please see above. 36 AP-85 Other Actions - 91.420, 91.220(k) Introduction This section discusses the City’s efforts in addressing the underserved needs, expanding, and preserving affordable housing, reducing lead-based paint hazards, and developing institutional structure for delivering housing and community development activities. Actions planned to address obstacles to meeting underserved needs The diminishing amount of funds continues to be the most significant obstacle to addressing the needs of underserved populations. To address this, the City supplements its CDBG funding with other resources and funds, such as: • In FY2020-21, The City’s Human Service Resource Allocation Process (HSRAP) provided $549,306 from the General Fund in support of human services. The HSRAP funds, in conjunction with the CDBG public service funds, are distributed to local non-profit agencies. Additionally, approximately $50,000 was provided to nonprofit organizations serving Palo Alto residents with short-term and/or urgent funding to address emergency, critical or emerging human services needs through the Emerging Needs Fund. • The Palo Alto Commercial Housing Fund is funded with mitigation fees provided under Palo Alto’s BMR housing program from developers of commercial and industrial projects and used to assist new housing development or the acquisition, rehabilitation, or the preservation of existing housing for affordable housing • The Palo Alto Residential Housing Fund is funded with mitigation fees provided under Palo Alto’s BMR housing program from residential developers and money from other miscellaneous sources, such as proceeds from the sale or lease of City property. The Residential Housing Fund is used to assist new housing development or the acquisition, rehabilitation, or the preservation of existing housing for affordable housing. • The City’s Below Market Rate Emergency Fund was authorized in 2002 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. • HOME Program funds are available on an annual competitive basis through the State of California HOME program, and the County’s HOME Consortium. • The Housing Authority of the County of Santa Clara (HACSC) administers the federal Section 8 program countywide. The program provides rental subsidies and develops affordable housing for low-income households, seniors and persons with disabilities living within the County. Actions planned to foster and maintain affordable housing The City will foster and maintain affordable housing by continuing the following programs and ordinances: • The Below Market Rate Emergency Fund which provides 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. 37 • The Commercial Housing Fund and Residential Housing Fund are used to assist new housing development or the acquisition, rehabilitation, or the preservation of existing housing for affordable housing. • The Density Bonus Ordinance adopted by the City Council in January 2014. The density bonus regulations allow for bonuses of 20 to 35 percent, depending on the amount and type of affordable housing provided. • The City’s participation in the County's HOME Consortium will allow developers of affordable housing projects to be eligible to competitively apply through an annual RFP process directly to the County for HOME funds to help subsidize affordable housing projects in Palo Alto, including acquisition, construction, and rehabilitation. Actions planned to reduce lead-based paint hazards The City’s housing and CDBG staff provides information and referral to property owners, developers, and non-profit organizations rehabilitating older housing about lead-based paint (LBP) hazards. Any house to be rehabilitated with City financial assistance is required to be inspected for the existence of LBP and LBP hazards. The City will provide financial assistance for the abatement of LBP hazards in units rehabilitated with City funding. The City also requires that contractors are trained and certified in an effort to decrease the risk of potential use of LBP in new units. All development and rehabilitation projects must be evaluated according to HUD’s Lead Safe Housing Rule 24 CFR Part 35. Actions planned to reduce the number of poverty-level families The City, in its continuing effort to reduce poverty, will prioritize funding agencies that provide direct assistance to the homeless and those in danger of becoming homeless. In FY 2022-2023, these programs will include the following: • LifeMoves 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. • Alta Housing will provide counseling and supportive case management services for low- income residents of single-room occupancy facilities to help them maintain housing stability. Activities include financial counseling, health maintenance, information and referral, problem solving, employment assistance, crisis intervention, and case management. • Downtown Streets Team works to reduce homelessness through a “work first” model. Downtown Streets Team uses its community connections to provide training and job opportunities to homeless people, specifically in the downtown area. Actions planned to develop institutional structure The City is striving to improve intergovernmental and private sector cooperation to synergize efforts and resources and develop new revenues for community service needs and the production of affordable housing. Collaborative efforts include: 38 • Regular bi-weekly meetings between entitlement jurisdictions at the CDBG Coordinators Meeting and Regional Housing Working Group. • Joint jurisdiction Request for Proposals and project review committees. • Coordination on project management for projects funded by multiple jurisdictions. • HOME Consortium meetings between member jurisdictions for affordable housing projects. Actions planned to enhance coordination between public and private housing and social service agencies The City benefits from a strong jurisdiction and region-wide network of housing and community development partners, such as the County and the Continuum of Care. To improve intergovernmental and private sector cooperation, the City will continue to participate with other local jurisdictions and developers in sharing information and resources. In addition to the actions listed above, the City will continue to coordinate with the City’s human services funding efforts to comprehensively address community needs. Discussion Please see discussions above. Program Specific Requirements AP-90 Program Specific Requirements - 91.420, 91.220(l)(1,2,4) Introduction The following provides additional information about the CDBG program income and program requirements. Community Development Block Grant Program (CDBG) Reference 24 CFR 91.220(l)(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. 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 $140,000 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: $ 140,000 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. 100 % Discussion Please see discussion above. APPENDIX A PUBLIC COMMENTS The Draft FY2022-23 Annual Action Plan was circulated for Public Comments and Review from May 20, 2022, through June 20, 2022. During the 30 days public comment and review period time, no comments were received APPENDIX B PUBLIC HEARING NOTIFICATIONS APPENDIX C CDBG APPLICATION FORMS SF-424 and SF-424D Certifications Resolution No. XXXX Resolution of the City Council of the City of Palo Alto Approving The Use of Community Development Block Grant Funds for Fiscal Year 2022-2023 A. On June 15, 2020, the Palo Alto City Council approved and adopted a document entitled “Consolidated Plan” which identified and established the Palo Alto housing and non-housing community development needs, objectives and priorities for the period July 1, 2020, to June 30, 2025. B. The Fiscal Year 2022-2023 Annual Action Plan, the annual funding update to the Consolidated Plan, was subjected to public review and commentary during the period from May 20, 2022, through June 20, 2022. C. The potential uses of Community Development Block Grant (CDBG) funds were evaluated in light of the needs and objectives identified in the Consolidated Plan and reflected in the recommendations and comments of the Human Relations Commission Selection Committee, Human Relations Commission and other interested citizens. D. Under the CDBG program, the highest priority is given to activities which will benefit persons with low and moderate incomes. E. The City Council and the Human Relations Commission have held publicly noticed public hearings on the proposed uses of the CDBG funds for Fiscal Year 2022-2023. F. CDBG funds allocated to the City for Fiscal Year 2022-2023 are proposed to implement the programs described in this resolution. NOW, THEREFORE, the Council of the City of Palo Alto does RESOLVE as follows: SECTION 1. The uses of CDBG funds for Fiscal Year 2022-2023 are hereby approved and authorized for the following programs: Name of Program Amount 1. Alta Housing – SRO Resident Support. Provide in-house case management and counseling services to residents at Barker Hotel and Alma Place. $22,413 2. Catholic Charities of Santa Clara County – Long Term Care Ombudsman Program. Advocate for the rights of seniors and disabled residents in long term care facilities. $10,000 3. LifeMoves – Opportunity Services Center. Provide case management services to Opportunity Services Center and Hotel De Zink clients in locating housing and/or employment and be connected to benefits. $26,660 4. Silicon Valley Independent Living Center – Housing and Emergency Services. Provide case management services to low-income individuals with disabilities to secure affordable and accessible housing. $14,021 5. Project Sentinel – Fair Housing Services. Provide fair housing services including complaint investigation, counseling, advocacy and community education $33,698 6. City of Palo Alto Department of Planning and Development Services– CDBG Program Administration. $121,816 7. Downtown Streets – Workforce Development Program. Provide comprehensive support services for homeless/ unemployed to secure employment. $160,477 8. Rebuilding Together Peninsula – Safe at Home. Provision of critical health and safety related home repair needs for low-income Palo Alto homeowners. 9. Mitchell Park Place – 525 E. Charleston Road – Funds are requested for predevelopment costs for a 50-unit affordable housing complex. Approximately half of the units are for persons with disabilities. The parcel is owned by the County and will be a long-term lease with the developer, Eden Housing. $73,135 $190,948 TOTAL $653,168 SECTION 2. The total amount set forth under Section 1 of this resolution represents the proposed allocation of $513,168, in CDBG funds from the United States Department of Housing and Urban Development (HUD) for Fiscal Year 2022-2023, and $140,000 in anticipated program income for Fiscal Year 2022-2023 from Palo Alto Housing Corporation. SECTION 3. The City staff is hereby authorized to submit the Fiscal Year 2022-2023 Annual Action Plan, update and appropriate funding to HUD for the Fiscal Year 2022-2023 CDBG funds, and such money shall be spent as set forth in this resolution. The Mayor, City Manager and any other designated City staff or officials are hereby authorized to execute such application forms and any other necessary documents to secure these funds. The City Manager or designee is authorized to sign all necessary grant agreements with the program providers set forth in Section 1. SECTION 4. The funding amounts set forth in Section 1 of this resolution are based on final allocation amounts from the Federal Fiscal Year 2022-23 HUD appropriations; City Staff is authorized to adjust increasing or decreasing the funding amounts set forth herein as consistent with the adopted Citizen Participation Plan. SECTION 5. The City Council hereby finds that the Fiscal Year 2022-2023 CDBG program authorized under Section 1 of this resolution is not a project under the California Environmental Quality Act (CEQA). However, the Council further authorizes and directs City staff to prepare certifications that may be required, under CEQA and the National Environmental Policy Act (NEPA), for each project under the Fiscal Year 2022-2023 CDBG program prior to the release of funds for any such project. // // // // // INTRODUCED AND PASSED: AYES: NOES: ABSTENTIONS: ABSENT: ATTEST: APPROVED: City Clerk Mayor APPROVED AS TO FORM: City Manager Sr. Assistant City Attorney Director of Planning and Development Services APPROVED AS TO CONTENT: Director of Administrative Services CDBG Coordinator Resolution No. XXXX Resolution of the Council of the City of Palo Alto Approving the Substantial Amendment for the use of Community Development Block Grant Coronavirus Funds for Fiscal Year 2020-2021 A. On June 15, 2020, the Palo Alto City Council approved and adopted a document entitled “Consolidated Plan” which identified and established the Palo Alto housing and non-housing community development needs, objectives, and priorities for the period July 1, 2020 to June 30, 2025. B. The Substantial Amendment to Fiscal Year 2020-2021 Action Plan, was subjected to public review and commentary during the period from May 20, 2022 through June 20, 2022. C. The potential uses of Community Development Block Grant Coronavirus Funds (CDBG- CV) funds were evaluated in light of the needs and objectives identified in the Consolidated Plan and reflected in the recommendations and comments of interested citizens. D. Under the CDBG-CV program, the highest priority is given to activities which will benefit persons with low and moderate incomes. E. The City Council have held a publicly noticed public hearing on the proposed uses of the CDBG-CV funds for Fiscal Year 2020-2021. F. CDBG-CV funds allocated to the City for Fiscal Year 2020-2021 are proposed to implement the programs described in this resolution. NOW, THEREFORE, the Council of the City of Palo Alto does RESOLVE as follows: SECTION 1. The uses of CDBG and CDBG-CV funds for Fiscal Year 2020-2021 are hereby approved and authorized for the following programs: Name of Program Amount 1. MOVE Mountain View Safe Parking Program $160,300 2. LifeMoves COVID-19 Testing Program $34,200.50 TOTAL $194,500.50 SECTION 2. The total amount set forth under Section 1 of this resolution represents the proposed reallocation of $194,500.50 in CDBG-CV (Coronavirus) funds from the United States Department of Housing and Urban Development (HUD) for Fiscal Year 2020-2021. SECTION 3. The City staff is hereby authorized to submit the CDBG-CV Substantial Amendment to the Fiscal Year 2020-2021 Annual Action Plan, and such money shall be spent as set forth in this resolution. The Mayor, City Manager and any other designated City staff or officials are hereby authorized to execute such application forms and any other necessary documents to secure these funds. The City Manager or designee is authorized to sign all necessary grant agreements with the program providers set forth in Section 1. SECTION 4. The funding amounts set forth in Section 1 of this resolution are based on final allocation amounts from the CARES Act (CDBG-CV) HUD appropriations; City Staff is authorized to make adjustments increasing or decreasing the funding amounts set forth herein as consistent with the adopted Citizen Participation Plan. SECTION 5. The City Council hereby finds that the Fiscal Year 2020-2021 CDBG program authorized under Section 1 of this resolution is not a project under the California Environmental Quality Act (CEQA). However, the Council further authorizes and directs City staff to prepare certifications that may be required, under CEQA and the National Environmental Policy Act (NEPA), for each project under the Fiscal Year 2020-2021 CDBG and CDBG-CV program prior to the release of funds for any such project. // // // // // INTRODUCED AND PASSED: AYES: NOES: ABSTENTI ONS: ABSENT: ATTEST: APPROVED: City Clerk Mayor APPROVED AS TO FORM: City Manager Sr. Assistant City Attorney Director of Planning and Development Services APPROVED AS TO CONTENT: Director of Administrative Services CDBG Coordinator MOVE Mountain View Safe Parking Program at Geng Road Lot Overview of MOVE Mountain View MOVE Mountain View (MMV) is the lead agency operating Safe Parking Programs in Palo Alto and Mountain View , California. We have been serving the homeless and marginalized vehicle-dwellers in the area since June 2018. MMV collaborates with local municipalities, the Office of Supportive Housing Santa Clara County, local faith communities, and other area social services providers. The program provides reserved off-street parking for participants, as well as permanent housing solutions through intensive case management. MMV operates four 24/7 RV Safe Parking lots and 3 Congregational Safe Parking locations. The total capacity of these lots in Palo Alto and Mountain View is 109 vehicles. 159 vehicle dwellers are currently enrolled in the program. Since the Geng Road lot in Palo Alto opened in February of 2021, 50% of client households have been placed in safe housing or other interim housing. MMV expects this percentage to rise as more safe housing options are developed by the state of California. The Geng Road Safe Parking Lot is where MMV will utilize the grant. There are 12 RV safe parking spaces with 8 spaces for client commuter car parking. A unique resource on this lot is the presence of two buildings. A library, laundry, kitchen, showers, and office spaces will create many options for service to the clients in the program. Congregations in Palo Alto have been enthusiastic about collaborating with MMV in the safe parking program. Since the Geng Road lot opened, the Highway Community Church and the Unitarian Universalist Church in Palo Alto have opened their lots to provide safe parking for 4 cars each. Currently, two more Palo Alto congregations are in process for permits to provide safe parking. The Impact of this Grant The expansion of services made possible by this grant will serve clients referred to Safe Parking in Palo Alto. The estimated 40+ client caseload will be managed by a full-time Caseworker dedicated to Palo Alto clients. In addition, the caseworker will be the liaison between PAUSD and safe parking resources for unhoused families. The Caseworker will also reinforce street outreach efforts to unhoused persons in Palo Alto. The free laundry and showers supported by this grant add to available direct services to Safe Parking clients. This increased use of the facility will require a Lot Manager dedicated to Palo Alto clients to supervise, organize, and monitor the Safe Parking Program at that site. MOVE Mountain View plans to assist at least 100 Palo Alto persons through the Safe Parking Program. Metrics MMV’s goals for the upcoming program year are to continue to place clients into safe permanent housing. MMV projects a 10% increase in the number of placements. MMV will report client demographic data such as age, ethnic self-identification, income level, language preference, number of shelter nights provided, and statistics about placement outcomes. In addition, MMV tracks and will continue to record the impact of COVID-19 on the clients we serve. Vehicle dwellers in our community are impacted by reduced access to PPEs, inadequate sanitation, and infrequent medical care. Many vehicle dwellers have lost employment due to COVID shutdowns of businesses. Their school-aged children have been challenged by lack of internet access and special needs resources. All MMV programs are administered under the COVID protocols for shelters as directed by the Santa Clara Health Department. As a result, there is low incidence of COVID-19 infections among the clients on the lots. Budget MOVE Mountain View will use CDBG-CV funds from the City of Palo Alto in the amount of $160,300 to cover the following costs: • Case Manager: $79,061 • Facilities Manager: $32,895 • Volunteer Coordinator: $24,172 • Utilities: $24,172 Total $160,300 LifeMoves COVID-19 Testing Program at their Opportunity Services Center LifeMoves needs an effective way to test clients and staff that work in a drop-in setting effectively and quickly for COVID-19. They are requesting $34,200.50 in CDBG-CV funding to purchase approximately 450 CUE Health Tests that test for COVID-19 and deliver accurate results in 20 minutes. They can be administered to anyone at any time that the Opportunity Services Center is open, whether the client is symptomatic or asymptomatic. In general, Cue’s test is the most accurate COVID-19 self-test on the market. In a clinical study with lay users, the Cue COVID-19 Test for Home and Over The Counter (OTC) Use demonstrated sensitivity of 97% (% positive agreement) and specificity of 99% (% negative agreement). Importantly, the study showed the test was 100% accurate in people infected with the virus who were asymptomatic. LifeMoves will use CDBG-CV funds from the City of Palo Alto in the amount of $34,200.50 to cover the following costs: • Purchase of CUE Tests: $34,200.50 Page 1 of 3 CITY OF PALO ALTO - CDBG ANNUAL ACTION PLAN FY2020-21: CDBG-CV SUBSTANTIAL AMENDMENT City Council Approved Date, 2022 INTRODUCTION: The City of Palo Alto’s Annual Action Plan details the funding strategy for the Community Development Block Grant (CDBG) program each year. Through the Annual Action Plan, the City implement its Five-Year Consolidated Plan. The City’s Citizen Participation Plan (CPP) describes the efforts that the City will take to encourage its residents to participate in developing these plans. It also provides requirements for public process when a “substantial amendment” to the Annual Action Plan is proposed. The following changes constitute a substantial amendment and require public notice as described in the CPP: • A change in the use of CDBG funds from one eligible activity to another; • The implementation of an activity not previously identified in sufficient detail to provide affected citizens an opportunity to submit comments; or • A change in an activity’s program budget which exceeds ten percent of the City’s latest annual entitlement grant. The information provided in this attachment qualifies as a substantial amendment because it meets all three criteria of a substantial amendment as described in the City’s CPP. BACKGROUND: The United States Congress passed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) on March 27, 2020. The CARES Act expedites the use of CDBG funds to prevent and respond to COVID-19. Through the CARES Act, the City received a total of $746,413 in two separate grant allocations. These funds are to be used specifically for responding to the COVID- 19 pandemic. On June 15, 2020, Council allocated a portion of the first allocation of CARES Act funding (CDBG-CV1) in the amount of $294,900 to LifeMoves to provide rental assistance to eligible low-income Palo Alto families (i.e. 80% Area Media Income and below) who have suffered documented income loss due to COVID-19. Of this amount, LifeMoves was able to spend $99,499.50, and is now giving the remaining $194,500.50 back to the City to reallocate. The purpose of this substantial amendment to the City of Palo Alto’s FY 2020-21 Annual Action Plan is to reallocate a portion of the CDBG-CV funds that was returned by a subrecipient to two new COVID-19 related projects and provide a summary of the recommended projects/activities. DISCUSSION: The City will re-allocate $194,500.50 in CDBG-CV funds that was returned from LifeMoves Rental Assistance Program. The LifeMoves Rental Assistance Program was funded in FY 2020- Page 2 of 3 21 under the CDBG public services category to provide eligible households who are unable to meet their monthly financial obligations as a result of the COVID-19 emergency with rental assistance. Individuals and families in danger of becoming homeless or losing their homes, will be able to remain in their homes. LifeMoves informed the City that they would be unable to spend the remaining funds that they received for this program and are therefore returning the funds to the City to be reallocated towards different COVID-related activities. Table 1 provides an overview of the recommended re-allocation of the $194,500.50 from the FY 20/21 program year. Table 1. Staff Recommendation for the Reallocation of CDBG-CV Funds Agency – Name of Program Amount 1. MOVE Mountain View – Safe Parking Program $160,300 2. LifeMoves – COVID-19 Testing Program $34,200.50 TOTAL $194,500.50 Public Outreach Process for the Reallocation of CDBG-CV Funds The City circulated the amendment to the FY 2020-21 Annual Action Plan for a 30-day public comment period from May 20, 2022 through June 20, 2022. After the public comment period concludes, the City Council will hold a public hearing on June 20, 2022. A brief description of programs that will be funded with the City’s reallocated CDBG-CV funds is provided below. The CDBG-CV funds will provide a valuable funding source for the City and its non-profit partners to address the community needs in the wake of the COVID-19 pandemic. Project Name MOVE Mountain View – Safe Parking Program Goals Supported and Needs Addressed COVID-19 Response Funding Amount CDBG-CV: $160,300 Description The program provides reserved off-street parking for participants, as well as permanent housing solutions through intensive case management. The Geng Road Safe Parking Lot is where MMV will utilize the grant. There are 12 RV safe parking spaces with eight spaces for client commuter car parking. A unique resource on this lot is the presence of two buildings. A library, laundry, kitchen, showers, and office spaces will create many options for service to the clients in the program. Page 3 of 3 Estimate the number and type of families that will benefit from the proposed activities Approximately eight Palo Alto residents will be served. Location Description Citywide (Palo Alto) Project Name LifeMoves – COVID-19 Testing Program Goals Supported and Needs Addressed: COVID-19 Response Funding Amount CDBG-CV: $34,200.50 Description LifeMoves will use this funding to purchase CUE Health Tests that test for COVID-19 and deliver accurate results in 20 minutes. They can be administered to anyone at any time that the Opportunity Services Center is open, whether the client is symptomatic or asymptomatic. Estimate the number and type of families that will benefit from the proposed activities Approximately 450 Palo Alto residents will be served. Location Description Citywide (Palo Alto)