Loading...
HomeMy WebLinkAboutStaff Report 2302-098010.Adoption of the Community Development Block Grant (CDBG) FY2023-24 Annual Action Plan and the Adoption of a Resolution Approving Use of CDBG Funds for FY 2023-24 1 7 2 6 City Council Staff Report From: City Manager Report Type: ACTION ITEM Lead Department: Planning and Development Services Meeting Date: May 1, 2023 Report #:2302-0980 TITLE Adoption of the Community Development Block Grant (CDBG) FY 2023-24 Annual Action Plan and the Adoption of a Resolution Approving Use of CDBG Funds for FY 2023-24 RECOMMENDATION The Human Relations Commission (HRC) and staff recommend City Council take the following actions: 1. Adopt the draft Fiscal Year 2023-2024 Annual Action Plan (Attachment A) and the associated resolution (Attachment B) allocating Community Development Block Grant (CDBG) funding for Fiscal Year 2023-24; 2. Authorize the City Manager to execute the Fiscal Year 2023-24 CDBG application to fund the Fiscal Year 2023-24 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 2023-24 Annual Action Plan (Attachment A) to U.S. Department of Housing and Urban Development (HUD) by the May 15, 2023, deadline. EXECUTIVE SUMMARY The City is preparing for its first year of a two-year CDBG funding cycle for FY 2024. On February 9, 2023, the HRC reviewed the eligible programs and recommended the funding allocations for each project as reflected in the draft FY 2024 Annual Action Plan (AAP; Attachment A). Staff requests that Council review the draft FY 2024 AAP and approve the recommended funding allocations identified in the document. Council’s approval of the AAP will be recorded by Resolution (Attachment B). 1 7 2 6 The CDBG federal appropriations for FY 2024 were released by the U.S. Department of Housing and Urban Development (HUD) on February 27, 2023. The total amount available for allocation in FY 2024 is $614,242, which includes the City’s entitlement grant ($514,242) and estimated program income ($100,000). These funds have been allocated to fund nine programs and projects as well as the program administration. Please see Table 3 for a summary of the projects and respective allocations. BACKGROUND The CDBG program, administered by HUD, provides annual grants on a formula basis to states, cities, and counties to develop viable urban communities by providing decent housing and a suitable living environment, and by expanding economic opportunities, principally for low- and moderate-income persons. The program is authorized under Title 1 of the Housing and Community Development Act of 1974. The HUD regulations require all CDBG-funded activities to meet one of the three national objectives: 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 urgency or posing a serious and immediate threat to the health or welfare of the community. For general information on the CDBG program, please visit: https://www.hudexchange.info/programs/cdbg-entitlement/. Palo Alto’s CDBG program has primarily been focused on meeting the first objective of benefiting low-and very-low-income persons. 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. FY 2024 Application Review Process Funding applications for “Public Services, Housing, Economic Development and Public Facilities Rehabilitation” projects were made available on October 21, 2022. A notice of CDBG funding availability was published in the Palo Alto Weekly on October 21, 2022, with completed 1 2020-2025 Consolidated Plan: https://www.cityofpaloalto.org/civicax/filebank/blobdload.aspx?t=49340.42&BlobID=79655 1 7 2 6 applications due November 29, 2022. A pre-proposal conference was conducted on November 10, 2022 to assist applicants with program regulations and project eligibility questions. For FY 2024, the City received applications from two agencies (Peninsula Healthcare Connection & WeeCare) that have not been previously funded by the City’s CDBG program. For any new applications, 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 FY 2024 (year one of funding cycle), the City received nine funding applications in addition to funding a public facilities project. These applications were reviewed on December 23, 2022 by the HRC Selection Committee. The committee made the initial project funding recommendations for eight of the nine applications to the full HRC. At the public hearing on February 9, 2023, 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 (May 15, 2023) as the last step in the process. Annual Action Plan (AAP) Citizen Participation 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. Refer to the Stakeholder Engagement report section below for specific details on required meetings and comment periods. HRC Review - Recommended Allocation for FY 2024 When the HRC reviewed the allocations on February 9, 2023, the CDBG federal appropriations for FY 2024 was not known. For budgeting purposes, staff estimated the City’s HUD Entitlement Grant for FY 2024 based on an 8% reduction from the previous year’s entitlement grant. The estimated total amount available for allocation in FY 2023-24 is $610,000, which includes the estimated entitlement grant ($510,000) and program income ($100,000). 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 4Citizen Participation Plan 2022: https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/cdbg-general- information/plans-and-reports/amended-citizen-participation-plan-2022-approved-by-city-council-9-12-22- final.pdf 1 7 2 6 On February 9, 2023, the HRC considered the funding recommendations of the HRC Selection Committee and voted unanimously to recommend Council approve the draft FY 2024 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 WeeCare, one of the new program applicants in the economic development funding category. A representative of WeeCare described how the company would be using CDBG funds and activity eligibility. Additionally, since the City’s CDBG grant amount was not known at the time, the HRC recommended a funding contingency plan as follows: •If more funds are received than estimated, allocate additional funds to the LifeMoves program; and •If less funds are received than estimated, evenly reduce all programs. Since the City received $4,242 more than what was estimated for the entitlement grant, staff adjusted the allocation amounts based on funding caps and the HRC’s contingency plan above. DISCUSSION This section includes information on the CDBG funds available for allocation and funding categories for FY 2023-24 funding cycle. The final funding recommendations are documented in the AAP that is required to be submitted to HUD. Funds Available for Allocation for FY 2024 The CDBG federal appropriations for FY 2024 was received on February 27, 2023. The total amount available for allocation in FY 2024 is $614,242, which includes the entitlement grant and estimated program income, as summarized below in Table 1. This amount is $4,242 more than esimated. The recommended allocations continue to address the preservation of affordable housing, housing-insecure individuals and households, strengthen neighborhoods, fair housing, and economic development. Table 1: FY 2024 CDBG Funding Summary FY 2023-2024 Entitlement Grant $514,242 Estimated Program Income in FY 2023-24 from Alta Housing generated from loan repayments and rental income in excess of expenses on specific properties acquired or rehabilitate with CDBG funds $100,000 Total Available for Allocations $614,242 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) 1 7 2 6 Public Facility Improvements. 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 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 in Table 2. Table 2: FY 2024 CDBG Funding Categories and Allocation Amounts Funding Categories Allowed Allocations Public Services (15% cap)$92,136 Planning and Administration (20% cap)$122,848 Economic Development, Housing Rehabilitation, and Public Improvements and Facilities (un-capped)$399,258 Total Available for Allocation $614,242 “Planning and Administration” Funding Category As of November 2021, the City has been primarily relying on consultant services to administer the CDBG program. The City is currently in the process of reviewing proposals to secure a new contract for consultant assistance for CDBG program management by July 2023. With the use of consultants, sufficient CDBG budget must be set aside to cover the program administration and, therefore, 100% of the administration funds is recommended to be set aside for this purpose. Allocations There are 10 activities recommended for FY 2024 allocations that are summarized below in Table 3. Detailed descriptions of the funding recommendations and agencies are provided in Attachment A. Table 3: FY 2024 Summary of Applications and Funding Recommendations Agency/Program Name FY 2023 Funded Amount Recommended FY 2024 Amount Public Services (15% Cap = $92,136) Alta Housing – SRO Resident Supportive Care $20,113 $14,000 Catholic Charities of Santa Clara County - Long Term Care Ombudsman Program $10,000 $10,000 LifeMoves – Case Management at Opportunity Center $23,616 $23,636 Peninsula Healthcare Connection (PHC) - Harm Reduction Materials n/a $10,000 Silicon Valley Independent Living Center (SVILC) – Case Management Services $14,021 $16,500 1 7 2 6 Project Sentinel - Fair Housing Services $23,615 $18,000 Subtotal $92,136 Economic Development (No Cap) WeeCare - Training for Family Child Care Home (FCCH)n/a $114,000 Subtotal $114,000 Housing (No Cap) Rebuilding Together Peninsula – Home Repair Program $73,135 $73,585 Subtotal $73,585 Public Facilities (No Cap) City of Palo Alto Sidewalk Repairs Capital Project (PO-89003)n/a*$211,673 Subtotal $211,673 Planning & Administration (20% Cap = $122,848) City of Palo Alto/CDBG Administation $121,816 $122,848 Subtotal $122,848 GRAND TOTAL $614,242 *This project received $300,000 in FY 2023 via a Substantial Amendment to the FY 2021-2022 action plan (CMR 2302-0991), which reallocated funding from the Ravenswood Family Health Network ADA ramp improvements project. Downtown Streets Team: Workforce Development Program The Downtown Streets Team (DST) was one of the nine applications submitted for FY 2024 funding with a request of $278,174.5 The HRC did not recommend funding for this project. Due to the more recent circumstances regarding DST’s Community Business Development Organization (CBDO) status, DST is not eligible to be funded under the Economic Development uncapped funding category; historically, this was how CDBG funded the program. DST could be eligible for funding under the Public Services category where six other applications were considered. The City recognizes the valuable contribution DST provides to the community, but the HRC did not recommend funding the program this year. The DST funding request exceeded the total amount available to allocate under Public Services and diverted funds away from the other programs, potentially impacting the assistance to several hundred City residents in need. As the City continues to evaluate the transition of Downtown Streets Team, staff will include funding for this program in the FY 2024 proposed budget for City Council consideration. 5 DST: The project activities included securing paid employment opportunities for unemployed and homeless individuals and building an extensive network of local employers willing to hire Downtown Streets Team workforce development program participants. Goal: assist 44 individuals and 15 businesses. 1 7 2 6 POLICY IMPLICATIONS The projects recommended for funding for the FY 2024 AAP are consistent with the priorities established in the City’s adopted FY 2020-2025 Consolidated Plan. FISCAL/RESOURCE IMPACT 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 support the program administration. These funds are needed to pay for consultant services to manage the program. There are no anticipated impacts to the General Fund budget with the requested action. TIMELINE The funding recommendations made by the Council will be incorporated into the FY 2024 AAP. Subsequently, the adopted FY 2024 AAP will be submitted to HUD by the May 15, 2023 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 FY 2024 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 February 9, 2023, served as the first public hearing, the City published a notice of the HRC meeting on January 25, 2023 in the Daily Post; this constituted the required 14-day public review period prior to first public hearing. After the presentation of the draft FY 2024 AAP to the HRC, the FY 2024 AAP was posted to the City’s webpage for public review and comments for are required 30-day period that began on March 28, 2023 through April 27, 2023; information was also posted on the City’s CDBG webpage and via email blasts to stakeholders. At the time of this report, staff did not receive any public comments on the draft AAP. The public Council meeting on May 1, 2023 will serve as the second public hearing to review and approve the FY 2024 AAP. The City published a public notice of the Council public hearing on March 27, 2023 advertised in the Daily Post. This advertisement complies with the City’s required 14-day public notice period prior to the second public hearing. ENVIRONMENTAL REVIEW 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 1 7 2 6 assessments and certify that the review procedures under CEQA, HUD and NEPA regulations have been satisfied for each project. ATTACHMENTS Attachment A: FY 2023-24 Draft Palo Alto Annual Action Plan Attachment B: FY 2023-24 Draft CDBG Resolution APPROVED BY: Jonathan Lait, Planning and Development Services Director ANNUAL ACTION PLAN FISCAL YEAR 2023-2024 DRAFT ADMINISTERED BY: PLANNING AND DEVELOPMENT SERVICES Page | 2 Table of Contents Executive Summary 3 AP-05 Executive Summary - 91.200(c), 91.220(b) 3 Introduction 3 The Process 6 PR-05 Lead and Responsible Agencies - 91.200(b) 6 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 Goals Summary Information – FY2023-24 23 AP-35 Projects - 91.420, 91.220(d) 25 Introduction 25 AP-38 Project Summary 26 AP-50 Geographic Distribution - 91.420, 91.220(f) 33 AP-75 Barriers to affordable housing -91.420, 91.220(j) 34 AP-85 Other Actions - 91.420, 91.220(k) 36 Program Specific Requirements 39 AP-90 Program Specific Requirements - 91.420, 91.220(l)(1,2,4) 39 APPENDIX A 40 PUBLIC COMMENTS 40 APPENDIX B 41 PUBLIC HEARING NOTIFICATIONS 41 APPENDIX C 45 CDBG APPLICATION FORMS 45 Page | 3 Executive Summary AP-05 Executive Summary - 91.200(c), 91.220(b) Introduction The City of Palo Alto (City) Fiscal Year (FY) 2023-24 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. 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. This Action Plan covers the fourth 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 FY2023-24 were released by HUD on February 27, 2023 and the City received $514,242 for CDBG programming. With the entitlement grant and $100,000 in estimated project income, the total of available for funding projects and programs during FY2023-24 is $614,242. The City’s Action Plan covers the time period from July 1, 2023, to June 30, 2024, (HUD Program Year 2023). The City’s FY 2023-24 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 According to Quick facts data provided by the U.S. Census Bureau 1, the City's total resident population is 66,680, per the Census on July 1, 2022. The City has the most educated residents in the country and is Page | 4 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. Additionally, according to the 2022 Point in Time Homeless Census 2, in Palo Alto, there were 299 unsheltered homeless in 2019 and 263 in 2022. The PIT count revealed there were 14 individuals sheltered in 2019 and 11 in 2022. This number represents decrease of 12% from 2019 to 2022. The Action Plan provides a summary of how the City will utilize its CDBG allocation to 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. As mentioned previously, a total of $614,242 is available for funding projects and programs during FY2023-24. In FY 202 3 -202 4 , t he City was allocated $514,242 from the federal CDBG program plus an additional $100,000 in program income. Table 1, “Fiscal Year 2023-2024 CDBG Budget” below summarizes the uses of the funds proposed during FY 2023-24. Table 1: Fiscal Year 2023-2024 CDBG Budget Applicant Agency Allocation Public Services Alta Housing - SRO Resident Supportive Services $14,000 Catholic Charities of Santa Clara County – Long Term Care Ombudsman $10,000 LifeMoves – Case Management at Opportunity Center $23,636 Silicon Valley Independent Living Center – Case Management Services $16,500 Project Sentinel – Fair Housing Services $18,000 Peninsula Healthcare Connection – Harm Reduction Services $10,000 Sub-total $92,136 Planning and Administration City of Palo Alto Administration $122,848 Public Facilities ADA curb ramp project $211,673 Economic Development WeeCare $114,000 Housing Rebuilding Together Peninsula $73,585 GRAND TOTAL $614,242 Evaluation of past performance This is an evaluation of past performance that helped lead the grantee (the City) to choose its goals or projects. 2 Santa Clara County Point-in-Time Report on Homelessness: 2022 PIT Report Santa Clara County.pdf (sccgov.org) Page | 5 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 the FY 2021-22 CAPERs reveals: • LMI elderly were assisted: 262 • Residents that received counseling services: 151 • Homeless individuals received shelter: 56 • Individual that received housing complaint services: 24 • Persons with disabilities receiving assistance: 26 • LMI homeowners receiving home improvements: 6 • Workforce development program assistance: 14 employers and 7 individuals 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 2023-24 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 stakeholders. The City held two advertised public hearings on February 9, 2023, and May 1, 2023. The Action Plan 30-day public review period occurred from March 28, 2023, through April 27, 2023. Summary of public comments [To be updated after close of comment period] There were no public comments received during the public review period. 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 FY2023-24 Action Plan. Page | 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. 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 2023-24 Annual Action Plan represents the fourth year of CDBG funding of the 2020-2025 Consolidated Plan. 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 Page | 7 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 2023-24 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 2023-24, 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 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 continues to attend regular 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-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 in identifying community needs. Page | 8 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 data from the County of Santa Clara PIT count is used to plan, fund, and implement actions for reducing chronic homelessness and circumstances that bring about homelessness. In 2023 the PIT count was conducted on January 26. 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 Consolidated Planning process and describe the jurisdictions consultations with housing, social service agencies and other entities Table 3: Agencies, Groups, and 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 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 Page | 9 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 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 Page | 10 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 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 Page | 11 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 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 Page | 12 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 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 Page | 13 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 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 Page | 14 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 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 Page | 15 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 (2023-2031) 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. 2019&2020 STD/HIV Annual Report Santa Clara County HIV Planning Council for Prevention and Care This report provides a summary findings for Santa Clara County HIV surveillance data. Page | 16 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. Accessibility Summary 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. Page | 17 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 hold two advertised public hearings on February 9, 2023, and May 1, 2023. The Action Plan 30-day public review period was from March 28, 2023, through April 27, 2023. The City did not receive 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/ broad community The Human Relations Commission met on Feb 9, 2023 to discuss: • FY2023-24 Applications • Annual allocation • Draft AAP There were no public comments Refer to the Engagement Summary. The HRC provided comments over WeeCare application. Public Hearing Nontargeted/ broad community The City Council met on May 1, 2023 to discuss: • FY2023-24 Projects, annual allocation • Draft AAP approval TBD TBD Page | 18 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 Draft FY2023-24 AAP and FY2023-24 CDBG Funding Allocations was published in the Daily Post on January 25, 2023. Update if comments received There were no public comments received. Email Blast Nontargeted/ broad community Email blast of HRC Public Hearing emailed Feb 3, 2023 to approximately 65 stakeholders Update if comments received There were not comments received from interested stakeholders Website Post Nontargeted/ broad community Website posting: https://www.cityof paloalto.org/CDBG Update if comments received Newspaper Ad Nontargeted/ broad community Notice of Public Hearing and Public Comment Period on the Draft AAP was published in the Daily Post on March 27, 2023 Update if comments received TBD Page | 19 Email Blast Nontargeted/ broad community Notice of City Council Public Hearing was published March 27, 2023) emailed to approximately 65 stakeholders Update if comments received TBD Website Post Nontargeted/ broad community Website posting: https://www.cityof paloalto.org/CDBG Update if comments received TBD Page | 20 Expected Resources AP-15 Expected Resources - 91.420(b), 91.220(c)(1,2) Introduction In FY2023-24, the City will allocate $614,242 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 years of the City’s 5-Year Consolidated Plan. Anticipated Resources Table 6: Expected Resources FY2023-24 – Priority Table Source of Funds Uses of Funds Expected Amount Available Year 2024 Narrative Description Program: CDBG Annual Allocation: $ Program Income: $ Prior Year: $ Total: $ Public – Federal CDGB Admin and Planning/ Economic Development / Housing Public Improvement / Public Services $514,242 $100,000 $0 $614,242 This is the 4th year of the 2020-2025 ConPlan. CDBG funds will be used for the preservation of owner-occupied homes, ADA street improvements, and public services that benefit low income and special needs households Page | 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 are 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 California Department of Housing and Community Development (HCD) for housing projects located within Palo Alto. The City has only received one HOME grant from 1992 HOME funding for the Barker Hotel project. Proceeds from HOME loan repayments are 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. In September 2022, multiple State bills were signed, including SB 6 (Middle-Class Housing Act) and AB 2011 to advance housing development progress. These two bills streamline the regulatory process and ensure that workers building homes are being paid a fair wage. The bill helps generate new housing units plus general thousands of jobs. The California Housing Accelerator provided funding for shovel-ready projects in 2022 whose financing was stalled because of the difficulty in receiving tax credits. 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, provides assistance for the development of below market rate (BMR) housing units which are, in part, funded by mitigation fees obtained from commercial and industrial Page | 22 development projects. • ADA coordinator and city-wide ADA capital improvement listing. • Housing Element Update provides the city with detailed housing priorities and needs. • Rebuilding Together Peninsula assists 5-7 low-to moderate income homeowners with home improvements. 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. Discussion Please see information provided in previous sections. Page | 23 Annual Goals and Objectives AP-20 Annual Goals and Objectives - 91.420, 91.220(c)(3) and(e) Goals Summary Information – FY2023-24 Table 7: Goals Summary Goal Name Start End Category Area Needs Addressed Fund Goal Outcome Indicator Affordable Housing 2020 2025 Affordable Housing Citywide Affordabl e Housing CDBG: $73,585 Homeowner Housing Rehabilitated: 5 Household Housing Units Homelessness 2020 2025 Homeless Citywide Homelessness CDBG: $23,636 Public service activities other than Low/Moderate Income Housing Benefit: 350 Persons Assisted Strengthen Neighborhoods 2020 2025 Non-Homeless Special Needs Non-Housing Community Development Citywide Community Services and Public Improvement s CDBG: $262,173 Public service activities other than Low/Moderate Income Housing Benefit: 1,711 Persons Assisted Fair Housing 2020 2025 Non-Housing Community Development Citywide Fair Housing CDBG: $18,000 Public service activities other than Low/ Moderate Income Housing Benefit: 177 Persons Assisted Economic Development 2020 2025 Non-Housing Community Development Citywide Economic Developmen t CDBG: $114,000 Jobs created/ retained: 19 Jobs Page | 24 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. Page | 25 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. 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. Peninsula Healthcare Connection – Harm Reduction 7. City of Palo Alto - Planning and Administration 8. WeeCare – Assist Daycare Providers 9. Rebuilding Together Peninsula – Safe at Home 10. ADA curb cuts 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. Page | 26 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: 570.208(a)(2). CDBG Citation:570.201(e). Recipient Type: LMC Target Date 6/30/2024 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: $23,636 Description Opportunity Services Center Eligible Activity (Matrix Code):03TCDBG National Objective: 570.208(a)(2). CDBG Citation:570.201(e). Recipient Type: LMC Target Date 6/30/2024 Page | 27 Estimate the number and type of families that will benefit from the proposed activities 350 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: $14,000 Description SRO Resident Support Program. Eligible Activity (Matrix Code):05OCDBG National Objective:570.208(a)(2). CDBG Citation:570.201(e). Recipient Type: LMC Target Date 6/30/2024 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 of 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. Page | 28 4 Project Name Silicon Valley Independent Living Center: Housing and Emergency Housing Services. Target Area Citywide Goals Supported Strengthen Neighborhoods Needs Addressed Community Services and Public Improvements Funding CDBG: $16,500 Description Housing and Emergency Housing Services. Eligible Activity (Matrix Code):05B. CDBG National Objective:570.208(a)(2). CDBG Citation:570.201(e). Recipient Type: LMC Target Date 6/30/2024 Estimate the number and type of families that will benefit from the proposed activities 115 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: $18,000 Description Fair Housing Services. Eligible Activity (Matrix Code):21D. CDBG National Objective:570.208(a)(2). CDBG Citation: 570.206(c). Recipient Type: LMC Target Date 6/30/2024 Page | 29 Estimate the number and type of families that will benefit from the proposed activities 177 unduplicated individuals will be provided with fair housing services of complaint counseling, investigation, and where appropriate enforcement referral. 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 Peninsula Healthcare Connection Target Area Citywide Goals Supported Strengthen Neighborhoods Needs Addressed Community Services and Public Improvements Funding CDBG: $10,000 Description PHC will deliver Harm Reduction materials to referral families. Substance Abuse Services 05F. 570.208(a)(2) 570.483(b)(2) LMC Target Date 6/30/2024 Estimate the number and type of families that will benefit from the proposed activities 400 referred households Location Description City-wide Planned Activities Harm Reduction materials will be delivered to referral families. Materials include: substance use treatment recommendations such as rehab center options, AA/NA meeting referrals, harm reduction kits designed for safe needle use and storage, and basic needs resources, such as Narcan. This is in response to the prevalent use of controlled substances and subsequent overdose-related deaths in the City. Page | 30 7 Project Name 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 $122,848 Description Planning and Administration: CDBG Citation: 570.206(a) Target Date 6/30/2024 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. 8 Project Name WeeCare Target Area Citywide Goals Supported Economic Development Needs Addressed Economic Development Funding CDBG: $114,000 Description WeeCare, a microenterprise business, will provide business improvement services to the City’s daycares. Eligible Activity (Matrix Code): 18C.CDBG National Objective: 570.483(b)(2)(iv). CDBG Citation: 570.208(a)(2)(iii). Recipient Type: LMCMC Target Date 6/30/2023 Estimate the number and type of families that will benefit from the proposed activities 19 daycare businesses will benefit from this project. Plus, new full-time jobs will be created by WeeCare. Page | 31 Location Description Citywide Planned Activities WeeCare intends to work with FCCH providers in Palo Alto who are already on the wait list for the BOOST program. These providers will receive staff training-learning best practices on how to grow and sustain their organization and how to better support LMI families they serve. Funds are requested will pay for WeeCare staff salaries for training providers on how to use Child Management System (CCMS) software. CCMS was developed for providers to create work plans, goals, capacity, and revenue empowering them to reach service and operations goals. 9 Project Name Rebuilding Together Peninsula – Safe at Home Target Area Citywide Goals Supported Affordable Housing Needs Addressed Affordable Housing Funding CDBG: $73,585 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. 24 CFR 570.202(a)(1) or 42 USC 5305(a)(4) LMH Target Date 6/30/2024 Estimate the number and type of families that will benefit from the proposed activities 5 LMI households will benefit from home improvements. 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. Page | 32 10 Project Name ADA curb cut-City of Palo Alto Target Area Citywide Goals Supported Strengthen Neighborhoods Needs Addressed Community Services and Public Improvements Funding CDBG: $211,673 Description The City intends to fund a major curb ramp improvement project that will bring an estimated 70 curb ramps up to current ADA accessibility standards. 03K, 24 CFR 570.201(c) or 42 USC 5305(a)(2) LMJFI Target Date 10/30/2024 Estimate the number and type of families that will benefit from the proposed activities 2,090 Location Description Street intersection locations TBD Planned Activities Provide safe ADA-accessible curb-cut intersections. The city will bid and award the project competitively. Page | 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. Page | 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 investments that provide housing for much of the region’s workforce – for example, salesclerks, 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 has historically used in- lieu fees and 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 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 resolves 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, the HIP was enacted as an alternative to the State Density Bonus law and provides development incentives including no housing density restrictions, increased Page | 35 floor area ratios and increased lot coverage. The HIP is available to specific areas of the City where higher density development is encouraged. • 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. Page | 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, from July 2021-2022, approximately $37,000 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. • In 2022, the City funded Downtown Streets Team 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 foster and maintain affordable housing The City will foster and maintain affordable housing by continuing the following programs and ordinances: • A Business Tax was approved in late 2022 to fund affordable housing, public safety, homeless services, rail crossing safety, and general city services. • 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. • 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. Page | 37 • The Density Bonus Ordinance 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 2023-2024, 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 provides 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. • WeeCare provides business services and best management practices for small daycare businesses in the City. Many of which provide childcare for LMI families. 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: • Regular 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. Page | 38 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. Page | 39 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 $100,000 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: $ 100,000 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 City held two advertised public hearings on February 9, 2023, and May 1, 2023. The Draft FY2023-24 Annual Action Plan was circulated for public comments and review from March 28, 2023, through April 27, 2023. During the 30 days public comment and review period time, no comments were received. APPENDIX B PUBLIC HEARING NOTIFICATIONS PLACE HOLDER FOR AD PUBLISHED ON March 27, 2023 RE: City Council meeting on May 1, 2023 APPENDIX C CDBG APPLICATION FORMS TO BE COMPLETED AND SIGNED AFTER AAP APPROVAL *NOT YET APPROVED* 1 0160102_20230417_AY16 Resolution No. _______ Resolution of the City Council of the City of Palo Alto Approving The Use of Community Development Block Grant Funds for Fiscal Year 2023-2024 A. On May 1, 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 2023-2024 Annual Action Plan, the annual funding update to the Consolidated Plan, was subjected to public review and commentary during the period from March 28, 2023 through April 27, 2023. 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 2023-2024. F. CDBG funds allocated to the City for Fiscal Year 2023-2024 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 2023-2024 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. $14,000 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 *NOT YET APPROVED* 2 0160102_20230417_AY16 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. $23,636 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. $16,500 5. Project Sentinel – Fair Housing Services. Provide fair housing services including complaint investigation, counseling, advocacy and community education $18,000 6. Peninsula Healthcare Connections – deliver Harm Reduction materials to referral families. $10,000 7. ADA curb cut-City of Palo Alto – major curb ramp improvement project that will bring many ramps up to current ADA accessibility standards. $211,673 8. WeeCare - a microenterprise business that will provide Palo Alto childcare business improvement services. $114,000 9. Rebuilding Together Peninsula – Safe at Home. Provision of critical health and safety related home repair needs for low-income Palo Alto homeowners. $73,585 10. CDBG Program Planning and Administration. $122,848 $614,242 SECTION 2. The total amount set forth under Section 1 of this resolution represents the proposed allocation of $514,242, in CDBG funds from the United States Department of Housing and Urban Development (HUD) for Fiscal Year 2023-2024, and $100,000, in anticipated program income for Fiscal Year 2023-2024 from Palo Alto Housing Corporation. SECTION 3. The City staff is hereby authorized to submit the Fiscal Year 2023-2024 Annual Action Plan, update and appropriate funding to HUD for the Fiscal Year 2023-2024 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 2023-24 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. *NOT YET APPROVED* 3 0160102_20230417_AY16 SECTION 5. The City Council hereby finds that the Fiscal Year 2023-2024 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 2023-2024 CDBG program prior to the release of funds for any such project. INTRODUCED AND PASSED: AYES: NOES: ABSTENTIONS: ABSENT: ATTEST: ____________________________ ____________________________ City Clerk Mayor APPROVED AS TO FORM: APPROVED: ____________________________ ____________________________ Assistant City Attorney City Manager ____________________________ Director of Planning and Development Services ____________________________ Director of Administrative Services CDBG Coordinator