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HomeMy WebLinkAboutStaff Report 2401-2562CITY OF PALO ALTO CITY COUNCIL Special Meeting Tuesday, June 18, 2024 Council Chambers & Hybrid 4:00 PM     Agenda Item     9.Adoption of the Community Development Block Grant (CDBG) FY 2024-25 Annual Action Plan and the Adoption of a Resolution Approving Use of CDBG and CDBG CARES Act (CDBG-CV) Funds for FY 2024-25, and Approval of a Budget Amendment in the Community Development Block Grant Fund. Presentation 3 9 1 1 City Council Staff Report From: City Manager Report Type: ACTION ITEMS Lead Department: Planning and Development Services Meeting Date: June 18, 2024 Report #:2401-2562 TITLE Adoption of the Community Development Block Grant (CDBG) FY 2024-25 Annual Action Plan and the Adoption of a Resolution Approving Use of CDBG and CDBG CARES Act (CDBG-CV) Funds for FY 2024-25, and Approval of a Budget Amendment in the Community Development Block Grant Fund. RECOMMENDATION The Human Relations Commission (HRC) and staff recommend City Council take the following actions: 1. Adopt the draft Fiscal Year (FY) 2024-25 Annual Action Plan (AAP, Attachment A) and the associated CDBG FY 2024-25 Annual Action Plan Resolution (Attachment B) allocating Community Development Block Grant (CDBG) and CDBG CARES Act (CDBG-CV) funding for FY 2024-25; and 2. Authorize the City Manager to execute the FY 2024-25 CDBG application to fund the FY 2024-25 Annual Action Plan and associated 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 2024-25 AAP (Attachment A) to the U.S. Department of Housing and Urban Development (HUD) by the July 6, 2024, deadline; and 4. Authorize the City Manager or designee to draft and execute a loan agreement, regulatory agreement, and related documents necessary to implement City Council direction on the Alma Garden Rehabilitation Project in a form consistent with the City’s affordable housing loan documents and approved by the City Attorney. 5. Amend the Fiscal Year 2025 Budget Appropriation for the Community Development Block Grant Fund (2/3 vote needed) by: a. Increasing Revenue from Other Agencies by $1,157,286 b. Increasing General Expenses by $1,157,286 EXECUTIVE SUMMARY The City is preparing for its second year of a two-year CDBG funding cycle for FY 2024-25. On February 8, 2024, the HRC made funding recommendations for the CDBG FY 2024-25 funding cycle and CDBG-CV funds. Given that the City’s CDBG grant entitlement amount for FY 2024-25 3 9 1 1 was unknown at the time, the HRC also recommended the implementation of a contingency plan to be used if CDBG FY 2024-25 funds were different than the amount estimated by staff. On May 7, 2024, the City received HUD’s formal notification of the City’s CDBG FY 2024-25 entitlement grant amount. Subsequently, staff updated the draft FY 2024-25 AAP to: •Include two specific Public Facilities projects; the applications for these projects were submitted in February 2024 and funding for these projects came from the HRC’s recommended funding in the CDBG Public Facilities category; •Reflect updated calculations of unspent funds from past program years and associated CDBG funding category cap amounts; •Incorporate the City’s CDBG FY 2024-25 entitlement grant amount; and •Update the CDBG FY 2024-25 funding allocation amounts through implementing the HRC’s recommended contingency plan.1 The draft FY 2024-25 AAP contains proposed funding allocations to spend all available CDBG and CDBG-CV funds. CDBG funds available for allocation in FY 2024-25 total $1,037,807.61, including the City’s FY 2024-25 entitlement grant, estimated program income to be received in FY 2024- 25, and unspent funds from prior years. CDBG-CV funds available for allocation in FY 2024-25 total $119,478.74, including unspent funds from the canceled LifeMoves-COVID-19 Testing project and unspent CDBG-CV Planning & Administration funds. It is not possible to fully fund all CDBG applications at the levels requested by applicants requesting funding in the CDBG Public Services and Planning & Administration categories, but the City is able to fully fund applications in the CDBG Economic Development and Housing Rehabilitation categories. The proposed recommendations: •Allocate all available CDBG and CDBG-CV funds; •Are consistent with the City’s CDBG Consolidated Plan; •Are consistent with the City’s 6th Cycle Housing Element goals, projects, and activities as they pertain to CDBG; and •Will result in funding key programs, projects, and activities that benefit many low- and very low-income Palo Alto residents. Staff recommends that Council review and approve the draft FY 2024-25 AAP (Attachment A), the associated draft CDBG FY 2024-25 Resolution (Attachment B), and authorize staff to submit and execute associated documents necessary to implement the CDBG FY 2024-25 AAP. BACKGROUND The CDBG program, administered by HUD, provides annual grants on a formula basis. Jurisdictions use the funds to develop viable urban communities by providing decent housing and a suitable living environment and by expanding economic opportunities, principally for low- and 1 The City did not receive any public comments on the draft FY 2024-25 AAP. Consequently, no edits to the draft FY 2024-25 AAP were necessary due to public comment. 3 9 1 1 moderate-income persons. The CDBG program is authorized under Title 1 of the Housing and Community Development Act of 1974. HUD regulations require all CDBG-funded projects and activities to meet at least 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 that have urgency or pose a serious and immediate threat to the health or welfare of the community. The City's CDBG program has primarily focused on meeting the first objective to benefiting low- and very-low-income persons.2 Consolidated Plan & Annual Action Plan Programs, projects, and activities funded through the City’s CDBG program must be consistent with the goals outlined in the City’s 2020-2025 Consolidated Plan,3 a five-year strategic plan of action that addresses priority housing and community development needs. Each year, HUD requires the submittal of an Annual Action Plan (AAP) that identifies the specific programs, projects, and activities to be funded to implement strategies identified in the Consolidated Plan. Following the City Council's final approval of the City’s proposed funding allocations, the specific programs, projects, and activities are reported to HUD through the submittal of the AAP. Citizen Participation for the Annual Action Plan Per HUD's regulations and the City's adopted "Citizen Participation Plan"4 the City must ensure adequate citizen participation in the CDBG funding allocation process. Prior to submittal of the AAP each year to HUD, the City must follow the following process: hold a public hearing on the draft AAP, subsequently hold a 30-day circulation and public comment period, and lastly hold another public hearing on the draft AAP. The February 8, 2024, HRC meeting served as the first public hearing, while the June 18, 2024 City Council meeting will serve as the second public hearing required for the FY 2024-25 AAP. Annual Action Plan Application Review and Allocation Process CDBG funding applications were made available on October 2, 2023. A notice of CDBG funding availability was published in the Daily Post on October 2, 2023, with completed applications due November 17, 2023. The City hosted a pre-proposal conference on October 26, 2023. 2 For general information on the HUD CDBG program, please visit: https://www.hudexchange.info/programs/cdbg- entitlement/. For general information on the Palo Alto’s CDBG program, please visit: https://www.cityofpaloalto.org/Departments/Planning-Development-Services/Housing-Policies- Projects/Community-Development-Block-Grant. 3 2020-2025 Consolidated Plan: https://www.cityofpaloalto.org/files/assets/public/v/3/planning-amp- development-services/cdbg-general-information/plans-and-reports/consolidated-plans/2020-2025-palo-alto- consolidated-plan-2020-21-aap-minor-amend1.pdf 4 Adopted Citizen Participation Plan 2022: https://www.cityofpaloalto.org/files/assets/public/v/1/planning-amp- development-services/cdbg-general-information/plans-and-reports/amended-citizen-participation-plan-2022- approved-by-city-council-9-12-22-final.pdf 3 9 1 1 Additionally, staff provided technical assistance to applicants during the open application period regarding program regulations and project eligibility questions. During this application cycle, the Notice of Funding Availability (NOFA) specified that funding would be available for projects in the CDBG Economic Development, Public Facilities and Improvements, and Housing Rehabilitation categories. The NOFA noted that new CDBG Public Services category applications were not being accepted in this second-year funding cycle, as two- year Public Services category applications were already received in the prior fiscal year. However, the NOFA specified that the City could accept new CDBG-CV applications in the Public Services category. All applications were reviewed to determine HUD compliance in accordance with eligible activities5 and National Objectives6. Human Relations Commission Review The HRC is involved in the preparation of the draft CDBG AAP each year. On January 17, 2024, the HRC Selection Committee reviewed the applications received for FY 2024-25. The HRC Selection Committee’s recommendations were then presented at a public hearing to the full HRC on February 8, 2024 (Attachment C). The HRC unanimously approved a motion to recommend that Council approve the draft FY 2024-25 AAP. Given that the City’s CDBG grant entitlement amount for FY 2024-25 was unknown at the time, the HRC also recommended the implementation of a contingency plan to be used if CDBG FY 2024-25 funds were different than the amount estimated by staff. ANALYSIS The City received its CDBG FY 2024-25 entitlement grant amount on May 7, 2024, which is a later date than anticipated, resulting from the overall delays in the FY 2024-25 federal budgeting process. While the amount of CDBG-CV funds remained unchanged, the amount of CDBG funds available for allocation in FY 2024-25 is less than the amount estimated and presented to the HRC in February 2024. This is largely due to reconciliation of the amounts of program income received in past program years, which has experienced declines relative to formerly estimated amounts. Upon receipt of the CDBG FY 2024-25 entitlement grant amount, staff adjusted the proposed funding allocations using the HRC’s contingency plan (Table 1). The updated proposed funding allocations are also documented in the FY 2024-25 AAP (Attachment A). CDBG funds available for allocation in FY 2024-25 total $1,037,807.61, including the City’s FY 2024-25 entitlement grant, estimated program income to be receipted in FY 2024-25, and unspent funds from prior years. CDBG-CV funds available for allocation in FY 2024-25 total $119,478.74, including unspent funds from the canceled LifeMoves-COVID-19 Testing project and unspent CDBG-CV Planning & Administration funds (Table 1). 5 CDBG Matrix Codes: https://files.hudexchange.info/resources/documents/Matrix-Code-Definitions.pdf 6 CDBG National Objectives: https://www.hudexchange.info/sites/onecpd/assets/File/CDBG-National-Objectives-Eligible-Activities-Chapter- 3.pdf 3 9 1 1 Table 1: FY 2025 CDBG and CDBG-CV Funding Summary FY 2024-25 Entitlement Grant $513,653 Program Income to be receipted in FY 2024-25 (Estimated) $60,000 Prior Year Unspent Funds $461,154.61 FY 2021-22 ($191,018.05)1 FY 2022-23 ($269,435.96)2 FY 2023-24 ($ 3,700.60)3 Estimated Total CDBG Funds Available for Allocation $1,037,807.61 Unspent Canceled Project: LifeMoves-COVID-19 Testing $34,200.50 Unspent Planning & Administration funds $85,278.24 Estimated Total CDBG-CV Funds Available for Allocation $119,478.74 1 The City has a total of $191,018.05 in unspent CDBG funds from FY 2021-22 that is available for reprogramming. 2 The City originally had $376,736.96 in unspent CDBG funds from FY 2022-23 that was available for reprogramming. Of this amount, $107,301 was reallocated to the FY 2023-34 program budget due to lower than estimated program income (PI) from FY 2023-24 ($107,301 had been estimated; $0 will be received by the conclusion of FY 2023-24). Consequently, the City has a total of $269,435.96 in unspent CDBG funds from FY 2022-23 that is available for reprogramming. 3 Due to program income (PI) reconciliation, adjustments in the FY 2023-24 Planning & Administration budget were made to meet the Planning & Administration category 20% Cap. Staying within the 20% Cap leaves a $3,700.60 surplus. CDBG Funding Categories and Funding Caps The CDBG program has five primary activity areas in which to allocate funds: (1) Public Services, (2) Economic Development, (3) Housing Rehabilitation, (4) Public Facilities & Improvement, and (5) Planning & Administration. Federal regulations cap the amount of CDBG funds that can be spent on Public Services and Planning & Administration as follows (Table 2): •Public Services (15% Cap) — The amount of any CDBG funds that may be obligated toward Public Services during a program year is capped at 15% of the sum of the grant allocation plus the total amount of program income received during the prior program year. •Planning & Administration (20% Cap) — The amount of any CDBG funds that may be obligated toward Planning & Administration during a program year is capped at 20% of the sum of the grant allocation plus the total amount of program income received during the current program year. 3 9 1 1 Table 2: FY 2025 CDBG and CDBG-CV Funding Categories and Allowed Allocations Funding Categories Allowed Allocations CDBG Funds Public Services 15% Maximum 15% x [entitlement grant allocation ($513,653) + prior year FY 2023-24 program income ($0.00)] $77,047.95 Planning and Administration 20% Maximum 20% x [entitlement grant allocation ($513,653) + current year FY 2024-25 anticipated program income ($60,000)] $114,730.60 Un-capped Funds $846,029.06 Total Available for CDBG Allocation $1,037,807.61 CDBG-CV Funds Public Services (No Cap)$88,623.75 Planning and Administration 20% Maximum $149,228.60 Program Income Program Income is received from Alta Housing for loan repayments and rental income in excess of expenses on specific properties acquired or rehabilitated with CDBG funds. Municipalities are required to estimate anticipated program income for the activity budget for the upcoming year. In past years, program income was estimated around $100,000. However, due to consistent declines in actual program income received in recent years, staff reduced the estimated program income for FY 2024-25 to $60,000 to align with historic trends. CDBG and CDBG-CV FY 2024-25 Funding Allocations Thirteen (13) applicants are recommended for CDBG and CDBG-CV FY 2024-25 funding allocations (Table 3) in the in the draft FY 2024-25 AAP (Attachment A). It is not possible to fully fund all CDBG applications at the levels requested by applicants requesting funding in the CDBG Public Services and Planning & Administration categories (Table 3), however, the City is able to fully fund applications in the CDBG Economic Development and Housing Rehabilitation categories. The draft FY 2024-25 AAP reflects the HRC’s funding recommendations. Staff was also able to include the following two new Public Facilities projects received by the City during February 2024: •Fire Station Sidewalk Improvement Project •Homekey Palo Alto Recreation Project Staff is able to include these Public Facilities projects because they were eligible, and the draft FY 2024-25 AAP reviewed by the HRC had already earmarked a large pool of CDBG funds to be used in the Public Facilities and Improvements funding category. The largest funding recommendation is for rehabilitation at the Alma Garden affordable housing project. This funding will be structured as an affordable housing loan and will include a regulatory agreement extending the term of affordability for the property. Staff is therefore seeking authority to draft and execute the necessary loan documents in a form substantially similar to the City’s past affordable housing loans. 3 9 1 1 Table 3: Summary of FY 2024-25 CDBG and CDBG-CV Applicants and Funding Recommendations Agency/Program Name FY 2023-24 Funded Amount FY 2024-25 Recommended Amount FY 2024-25 Applicant Requested Amount CDBG Applicants Public Services (15% Cap = $77,047.95) Alta Housing - SRO Resident Supportive Services $14,000 $11,575 $24,343 Catholic Charities of Santa Clara County – Long Term Care Ombudsman Program $10,000 $7,575 $10,000 LifeMoves – Case Management $23,636 $28,247 $69,919 Silicon Valley Independent Living Center (SVILC) – Case Management $16,500 $14,075 $28,127 Project Sentinel – Fair Housing Services $18,000 $15,575 $36,393 Subtotal $77,047 $168,782 Economic Development (No Cap) WeeCare/Upwards $114,000 $120,000 $120,000 Subtotal $120,000 $120,000 Housing Rehabilitation (No Cap) Rebuilding Together Peninsula (RTP) – Safe at Home $73,585 $73,585 $73,585 Community Work Group/Abode – Alma Garden N/A $404,800 $404,800 Subtotal $478,385 $478,385 Public Facilities & Improvements (No Cap) Fire Station – Sidewalk Improvement Project N/A $62,645.61 $65,000 Homekey Palo Alto – Recreation Project N/A $185,000 $185,000 Subtotal $247,645.61 $250,000 Planning & Administration (20% Cap = $114,730.60) City of Palo Alto Administration $119,013 $114,730 $116,060 Subtotal $114,730 $116,060 GRAND TOTAL for CDBG N/A $1,037,807.61 N/A CDBG-CV Applicants Public Services CDBG-CV MOVE Mountain View - Safe Parking Program $110,000.00 $110,000.00 $110,000.00 Planning & Administration CDBG-CV Planning and Administration – CV N/A $9,478.74 N/A GRAND TOTAL for CDBG-CV N/A $119,478.74 N/A 3 9 1 1 Should the FY 2024-25 AAP be adopted by City Council, it would be submitted to HUD prior to the July 6, 2024 deadline. POLICY IMPLICATIONS The programs, projects, and activities recommended for funding in the draft FY 2024-25 AAP are consistent with the priorities established in the City’s adopted CDBG FY 2020-2025 Consolidated Plan. FISCAL/RESOURCE IMPACT There is no fiscal impact associated with this action as CDBG and CDBG-CV funding is provided by HUD. Associated grant funding is also used to support program administration for consultant services and liability insurance. STAKEHOLDER ENGAGEMENT Prior to the submission of the FY 2024-2025 AAP to HUD, the City must follow the following process: hold a public hearing on the draft AAP, hold a 30-day circulation and public comment period, and hold an additional public hearing on the draft AAP. The HRC meeting on February 8, 2024 served as the first public hearing. The City published a notice of the HRC meeting on January 24, 2024, in the Daily Post; this constituted the required 14-day public review period for the first public hearing. The 30-day circulation, public review, and comment period on the draft FY 2024-25 AAP began on March 13, 2024 and ended on April 12, 2024; notice of funding availability was published in the Daily Post on March 13, 2024, on the City’s CDBG webpage, and via email notification to stakeholders. At the time of this report, staff did not receive public comment on the draft FY 2024-25 AAP. The City Council public hearing on June 18, 2024 will serve as the second public hearing for review and approval of the FY 2024-25 AAP. The City published a public notice of the City Council public hearing on June 3, 2024, in the Daily Post. This advertisement complies with the City’s required 14-day public notice period for the second public hearing. ENVIRONMENTAL REVIEW For the purposes of the National Environmental Policy Act (NEPA) and the California Environmental Quality Act (CEQA), budgeting by itself is not a project. Prior to the commitment or release of funds for each of the proposed programs, projects, and activities, staff will carry out the required environmental reviews or assessments and certify that the review procedures under HUD, NEPA, and CEQA regulations have been satisfied for each activity. 3 9 1 1 ATTACHMENTS Attachment A: Draft FY 2024-25 CDBG Annual Action Plan, dated June 3, 2024 Attachment B: Draft Resolution CDBG FY 2024-25 Annual Action Plan Attachment C: Human Relations Commission Review Summary APPROVED BY: Jonathan Lait, Planning and Development Services Director ANNUAL ACTION PLAN FISCAL YEAR 2024-2025 DRAFT (June 6, 2024) for City Council Public Meeting: June 18, 2024 ADMINISTERED BY: PLANNING & DEVELOPMENT SERVICES FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 1 Table of Contents Executive Summary .................................................................................................................................................. 2 AP-05 Executive Summary - 91.200(c), 91.220(b) ................................................................. 2 The Process ............................................................................................................................................................... 6 PR-05 Lead and Responsible Agencies - 91.200(b) ................................................................ 6 AP-10 Consultation - 91.100, 91.200(b), 91.215(l) ............................................................... 8 AP-12 Participation - 91.401, 91.105, 91.200(c) ................................................................ 16 Expected Resources ................................................................................................................................................ 20 AP-15 Expected Resources - 91.420(b), 91.220(c)(1,2) ......................................................... 20 Annual Goals and Objectives .................................................................................................................................. 24 AP-20 Annual Goals and Objectives - 91.420, 91.220(c)(3)&(e) ............................................... 24 AP-35 Projects - 91.420, 91.220(d) ................................................................................ 27 AP-38 Project Summary ............................................................................................. 28 AP-50 Geographic Distribution - 91.420, 91.220(f) ............................................................. 34 AP-75 Barriers to affordable housing -91.420, 91.220(j) ...................................................... 35 AP-85 Other Actions - 91.420, 91.220(k) ......................................................................... 38 Program Specific Requirements .............................................................................................................................. 42 AP-90 Program Specific Requirements - 91.420, 91.220(l)(1,2,4) ............................................ 42 Appendices ............................................................................................................................................................. 43 APPENDIX A ........................................................................................................... 43 Public Comments ................................................................................................. 43 APPENDIX B ........................................................................................................... 44 Public Notices ..................................................................................................... 44 APPENDIX C ........................................................................................................... 49 Application for Federal Assistance SF-424 Forms and Certifications ...................................... 49 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 2 Executive Summary AP-05 Executive Summary - 91.200(c), 91.220(b) 1. Introduction The City of Palo Alto (City) Fiscal Year (FY) 2024-25 Annual Action Plan (AAP) contains the City’s 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 fifth and final year of the City’s five-year 2020-2025 Consolidated Plan, which was adopted by the Palo Alto City Council on June 15, 2020. The Planning and Development Services Department is the lead agency for the Consolidated Plan and subsequent 5 Annual Action Plans for the City’s CDBG program. HUD requires entitlement jurisdictions to submit a Consolidated Annual Performance and Evaluation Report (CAPER) that describes the distribution of federal entitlement grant funds over the Consolidated Plan’s five-year planning period and identifies how funding allocations help meet the goals covered in the Consolidated Plan. The City received its CDBG FY 2024-25 entitlement grant amount on May 7, 2024,CDBG funds available for allocation in FY 2024-25 total $1,037,807.61, which includes the entitlement grant ($513,653), anticipated program income ($60,000) to be receipted in FY 2024-25, and unspent funds from prior years ($461,154.61). The City is aware that program income receipts can be inconsistent and makes its best effort to estimate future income and execute ongoing program budget adjustments as necessary. The City is also reallocating $119,478.74 in CDBG CARES Act (CDBG-CV) funds, including unspent funds from the canceled LifeMoves- COVID-19 Testing project ($34,200.50) and unspent CDBG-CV Planning & Administration funds ($85,278.24) The City’s FY 2024-25 AAP covers the time period from July 1, 2024, to June 30, 2025. The FY 2024-25 AAP contains the accomplishments the City expects to achieve in FY 2024-25. All the projects, programs, and activities in the FY 2024-25 AAP reflect the 2020-2025 Consolidated Plan goals. CDBG-funded programs and activities principally benefit City residents that have extremely low, low, and moderate- incomes and/or populations that have special needs, such as the elderly, disabled, and homeless. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 3 Fiscal Year 2024-25 CDBG and CDBG-CV Budget Summary Applicant Agency Allocation Public Services (15% Cap = $77,047.95) Alta Housing - SRO Resident Support Services $11,575 Catholic Charities of Santa Clara County – Long Term Care Ombudsman Program $7,575 LifeMoves – Case Management $28,247 Silicon Valley Independent Living Center (SVILC) – Case Management $14,075 Project Sentinel – Fair Housing Services $15,575 Subtotal $77,047 Economic Development (No Cap) WeeCare/Upwards $120,000 Subtotal $120,000 Housing Rehabilitation (No Cap) Rebuilding Together Peninsula (RTP) – Safe at Home $73,585 Community Work Group/Abode – Alma Garden $404,800 Subtotal $478,385 Public Facilities & Improvements (No Cap) Fire Station – Sidewalk Improvements Project $62,645.61 Homekey Palo Alto – Recreation Project $185,000 Subtotal $247,645.61 Planning & Administration (20% Cap = $114,730.60) City of Palo Alto Planning & Administration $114,730 Subtotal $114,730 Grand Total for CDBG Budget $1,037,807.61 Public Services CDBG-CV CDBG-CV MOVE Mountain View - Safe Parking Program $110,000 Planning & Administration CDBG-CV (20% Cap) CDBG-CV City of Palo Alto Planning & Administration $9,478.74 Grand Total for CDBG-CV Budget $119,478.74 2. Summarize the objectives and outcomes identified in the Plan This could be a restatement of items or a table listed elsewhere in the plan or a reference to another location. It may also contain any essential items from the housing and homeless needs assessment, the housing market analysis or the strategic plan FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 4 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 space. According to the U.S. Census Bureau, 2022 ACS Census, the City's total resident population is 66,021 and has a density of 2,745 persons per square mile. Between 2020 and 2021 the City’s median household income grew from $174,003 to $194,782, a 11.9% increase. According to the U.S. Census data, 6.1% of all residents within the City had incomes below the federal poverty level. The City has the most educated residents in the country and is one of the most expensive cities to live in. According to the 2020 Palo Alto Business & Economic Activity Report in 2020, the City has between 4,100 and 7,000 for-profit and not for profit businesses and 92,000 to 114,000 employees. Additionally, according to the 2023 Point in Time (PIT) homeless count, there were 187 unsheltered homeless individuals and 19 sheltered. The 2022 PIT homeless count revealed there were 263 unsheltered homeless individuals and 11 sheltered homeless individuals in Palo Alto in 2022. This reflects an overall estimated 24.5% decrease in homelessness in Palo Alto. The FY 2024-25 Annual Action Plan provides a summary of how the City will utilize its CDBG allocation to meet the needs of the City’s lower-income and special-needs populations. In FY 2023-24, the City received $514,242 from the federal CDBG program and utilized $80,825 of program income. In FY 2024-25, they City has available a total of $1,037,807.61 CDBG funds. This higher amount is largely due to activities identified in past AAPs that were canceled and previously unspent funds from completed activities. Canceled CDBG activities included Downtown Streets Inc. and Mitchell Park Place. Completed activities with remaining FY2021-22 funds were Catholic Charities, Rebuilding Together Peninsula, and City of Palo Alto Planning and Administration; remaining FY2022-22 funds were Catholic Charities, Life Moves, Project Sentinel, and City of Palo Alto Planning and Administration; remaining FY2023-24 funds were City of Palo Alto Planning and Administration. The City also intends to reallocate $119,478.74 in CDBG-CV funds. The canceled CDBG-CV was LifeMoves-COVID-19 Testing. 3. Evaluation of past performance An evaluation of past performance helps City leaders allocate funds to priority activities, as well as select projects that are more aligned with its priority needs and goals. The City is responsible for ensuring compliance with all rules and regulations associated with the CDBG entitlement grant program. Prior Annual Action Plans (AAPs) and Consolidated Annual Performance and Evaluation Reports (CAPERs) provide many details about the accomplishment goals, projects, and programs completed by the City and its subrecipients. A review of the FY 2022-23 CAPER reveals that 310 persons and/or employers were assisted. Specifically: • LMI elderly were assisted: 62 • Residents that received counseling services: 148 • Homeless individuals received shelter: 49 • Individual that received housing complaint services: 22 • Persons with disabilities receiving assistance: 24 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 5 • LMI homeowners receiving home improvements: 5 • Workforce development program assistance: 0 The City evaluates the performance of subrecipients on a quarterly basis. Subrecipients submit required quarterly progress reports that include client data, performance objectives, and data on outcome measures. Prior to the start of the program year, subrecipients and the City collaboratively develop program objectives, ensuring that they are aligned with the City's overall goals and strategies. The City then utilizes the quarterly reports to review progress toward achievement of annual goals. 4. Summary of Citizen Participation Process and consultation process The City solicited input throughout the development of the FY 2024-25 Annual Action Plan (AAP). As required by HUD, the City provides multiple opportunities for public review and comment on the AAP, as well as any substantial amendments. Per the City’s adopted Citizen Participation Plan, the City holds a 30- day public review comment period for the AAP. The City also publishes the required notification 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 the AAP, HRC meeting on February 8, 2024, and the City Council meeting on June 18, 2024. The AAP 30-day public review period began on March 13, 2024 and ran through April 12, 2024. 5. Summary of public comments This could be a brief narrative summary or reference an attached document from the Citizen Participation section of the Con Plan. Public comments received by the City will be reported here. 6. Summary of comments or views not accepted and the reasons for not accepting them The City accepts and responds to all submitted public comments. As noted above, all public comments were reported and addressed as part of this FY 2024-25 Annual Action Plan. 7. Summary No further discussion FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 6 The Process PR-05 Lead and Responsible Agencies - 91.200(b) 1. Agency/entity responsible for preparing/administering the Consolidated Plan The following are the agencies/entities responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source. Agency Role Name Department/Agency Lead Agency PALO ALTO CDBG Administrator PALO ALTO Department of Planning & Development Services Table 1 – Responsible Agencies 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 (PDS) 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. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 7 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 2024-25 AAP represents the fifth year of CDBG funding of the 2020-2025 Consolidated Plan. Consolidated Plan Public Contact Information Rebecca Atkinson, Planner City of Palo Alto Department of Planning and Development Services 250 Hamilton Avenue, 5th Floor Palo Alto, CA 94301 E-mail: rebecca.atkinson@cityofpaloalto.org Phone: (650) 329-2596 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 8 AP-10 Consultation - 91.100, 91.200(b), 91.215(l) 1. Introduction The Annual Action Plan is a one-year plan that describes the eligible projects, programs, and activities to be undertaken with funds expected during FY 2024-25 and their relationship to the priority housing, homeless, and community development needs outlined in the 2020-25 Consolidated Plan. Consultation with the City and region’s social services, Human Relations Commission (HRC), Santa Clara Housing Coordinators group, City Departments, and City Council occurred in the development of the AAP. 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(l)). The projects, programs, and activities identified in the Annual Action Plan were shaped through a detailed collaborative process. The City CDBG program administrators performed technical assistance, as well as interviewed and monitored subrecipients. They also conducted consultations with the City’s Public Works, Planning, Housing, Human Services, and Economic Development staff. The City continues to work with and consult with city departments, non-profit organizations that provide programs and services for low- income households, private industry, homeless providers, and housing development groups. The City supports the development of affordable housing opportunities both regionally and within the City. City staff provides technical assistance to awarded public service subrecipients and new CDBG applicants, as well as attends monthly Santa Clara County Continuum of Care and 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 monthly CoC Housing Coordinator meetings. The CoC plans and prepares significant reports supported by its CDBG entitlements and cities. Reports adopted by the CoC strive to improve conditions for the homeless, record data related to homelessness, develop a system for volunteer assistance that helps identify gaps in homeless services, establish funding priorities, and pursue a systematic approach to addressing homelessness. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 9 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 Reports and Publications - Office of Supportive Housing - County of Santa Clara (sccgov.org). As part of the development of the 2020-25 Consolidated Plan, the City directly consulted both the CoC and County Office of Supportive Housing for their expertise and experience in 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 for and evaluate outcomes of projects and activities assisted by ESG funds, and develop funding, policies and procedures for the operation and 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 uses its CDBG-CV funds to support safe parking lots that house non-sheltered homeless persons and families. Annually the City funds its homeless shelter for its supportive case management services. Over the last several years the City has developed funding and building plans for its new Homekey Shelter. Homekey Palo Alto is a planned modular interim housing shelter with the capacity to serve over 200 individuals annually with on-site support services. This project will be constructed by 2025. The City provides local funds for the County to conduct its annual Point in Time (PIT) count, an annual regional collaborative effort to count and survey sheltered and unsheltered 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. For 2023, the PIT count was conducted on January 26, 2023. The CoC reported there were 275 persons placed in transitional housing, 1,480 persons sheltered, and 5,904 persons unsheltered. There were 187 unsheltered homeless individuals and 19 sheltered in the City of Palo Alto. The City’s 2022 PIT homeless count was 263 unsheltered homeless individuals and 11 sheltered homeless individuals. This reflects an overall estimated 24.5% decrease in homelessness in Palo Alto. 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 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 10 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. 2. Agencies, groups, organizations and others who participated in the process and consultations FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 11 Agencies, groups, organizations who participated 1 Agency/Group/Organization REBUILDING TOGETHER PENINSULA Agency/Group/Organization Type Housing What section of the Plan was addressed by Consultation? Affordable Housing Preservation Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Attended pre-application workshop. Stakeholder communications and application submission and project selection. 2 Agency/Group/Organization SILICON VALLEY INDEPENDENT LIVING CENTER Agency/Group/Organization Type Services - Housing Services-Elderly Persons Services-Persons with Disabilities What section of the Plan was addressed by Consultation? Non-Homeless Special Needs Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Attended pre-application workshop. Stakeholder communications and application submission and project selection. 3 Agency/Group/Organization PROJECT SENTINEL Agency/Group/Organization Type Services - Housing Fair Housing and mediation services What section of the Plan was addressed by Consultation? Fair Housing Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Attended pre-application workshop. Stakeholder communications and application submission and project selection. 4 Agency/Group/Organization ALTA HOUSING Agency/Group/Organization Type Services - Housing FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 12 What section of the Plan was addressed by Consultation? Non-Homeless Special Needs Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Attended pre-application workshop. Stakeholder communications and application submission and project selection. 5 Agency/Group/Organization LIFEMOVES Agency/Group/Organization Type Services-homeless What section of the Plan was addressed by Consultation? Homeless Needs - Chronically homeless Homeless Needs - Families with children Homelessness Needs – Veterans Strengthening Neighborhoods – Public Facilities Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Attended pre-application workshop. Stakeholder communications and application submission and project selection. 6 Agency/Group/Organization CATHOLIC CHARITIES Agency/Group/Organization Type Services-Housing What section of the Plan was addressed by Consultation? Non-Homeless Special Needs Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Attended pre-application workshop. Stakeholder communications and application submission and project selection. 7 Agency/Group/Organization WEECARE/UPWARDS Agency/Group/Organization Type Business and Civic Leaders What section of the Plan was addressed by Consultation? Economic Development FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 13 Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Attended pre-application workshop. Stakeholder communications and application submission and project selection. 8 Agency/Group/Organization COMMUNINITY WORK GROUP/ABODE Agency/Group/Organization Type Housing What section of the Plan was addressed by Consultation? Affordable Housing Preservation Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Attended pre-application workshop. Stakeholder communications and application submission and project selection. 9 Agency/Group/Organization MOVE MOUNTAIN VIEW Agency/Group/Organization Type Services-homeless What section of the Plan was addressed by Consultation? Homeless Needs - Chronically homeless Homeless Needs - Families with children Homelessness Needs - Veterans Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Attended pre-application workshop. Stakeholder communications and application submission and project selection. 10 Agency/Group/Organization PEARL TRANSIT CORP. Agency/Group/Organization Type Business and Civic Leaders What section of the Plan was addressed by Consultation? Non-Homeless Special Needs FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 14 Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Stakeholder communications and application submission and project not selected. Table 2 - Agencies, groups, organizations who participated Identify any Agency Types not consulted and provide rationale for not consulting There were no gaps in the consultation process. Other local/regional/state/federal planning efforts considered when preparing the Plan 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. Housing Element 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 Clare County This report provides a summary of findings for Santa Clara County HIV surveillance data. 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 A 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. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 15 Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? Palo Alto's Infrastructure: Catching Up, Keeping Up 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. Table 2 - Other local / regional / federal planning efforts Narrative No additional content needed. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 16 AP-12 Participation - 91.401, 91.105, 91.200(c) 1. 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 published notifications of 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 February 8, 2024, and June 18, 2024. The Action Plan 30-day public review period began on March 13, 2024 and ran through April 12, 2024. The City has not received any public comments to date. (Any comments to be inserted here once public hearings are completed) Citizen Participation Outreach Sort Or der Mode of Outr each Target of Outre ach Summary of response/attenda nce Summary of comments received Summary of comments not accepted and reasons URL (If applicable) 1 Newspaper Ad & Internet Outreach Non- targeted/broad community Email Blast to interested organizations, persons Accepted NOFA application between October 3 – November 17, 2023. 4 new CDBG applications were received; 6 applications were received in Program Year 1 and applied to Year 2 of the two-year funding cycle. And 2 new CDBG-CV applications. All comments accepted https://www.cityofpaloalto.org/files /assets/public/v/1/planning-amp- development-services/cdbg-general- information/py-2024-2025-cdbg- nofa-application-package- 10.02.23.pdf. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 17 Sort Or der Mode of Outr each Target of Outre ach Summary of response/attenda nce Summary of comments received Summary of comments not accepted and reasons URL (If applicable) 2 Consultation Listing Social Service, City Departments, Area Housing developers Pre-Application Conference on October 26, 2023 Application description, stakeholder consultation All comments accepted https://cityofpaloalto.zoom.us/rec/s hare/OEnSZX1HwWN6fKv2PHYowU myEheUO0GEkAA3_grogQrkP0mzJn EB9x4C6eVDipHo.zOLaGzGCkZuWtP SE https://www.cityofpaloalto.org/files /assets/public/v/1/planning-amp- development-services/cdbg-general- information/plans-and- reports/action-plans/py-2024-25- pre-proposal-conf-pres-10-26-23.pdf 3 Newspaper Ad Non- targeted/broad community Notice of Human Relations Commission & City Council Public Hearings announced FY2024-25 CDBG Funding Allocations, published in the Daily Post on January 24, 2024. No comments received All comments accepted https://www.cityofpaloalto.org/Dep artments/Planning-Development- Services/Housing-Policies- Projects/Community-Development- Block-Grant 4 Public Hearing Non- targeted/broad community HRC met on Feb 8, 2024, to discuss FY2024-25 Applications and AAP activities. No comments received All comments will be accepted https://www.cityofpaloalto.org/City- Hall/Boards-Commissions/Human- Relations-Commission FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 18 Sort Or der Mode of Outr each Target of Outre ach Summary of response/attenda nce Summary of comments received Summary of comments not accepted and reasons URL (If applicable) 5 Newspaper Ad Non- targeted/broad community Notice of City Council Public Hearing announcing FY2024- 25 CDBG Funding Allocations, published in the Daily Post on March 13, 2024. CORRECTION NOTICE of City Council Public Hearing Date published in Daily Post on June 3, 2024. Not yet completed All comments will be accepted 6 Public Hearing Non- targeted/broad community The City Council held its second public hearing on June 18, 2024, to discuss Draft AAP. Council members recommended approval. Not yet completed All comments will be accepted 7 Internet Outreach Non- targeted/broad community Webpage postings for both hearings Jan 24th No comments received March 13th No comments received All comments will be accepted https://www.cityofpaloalto.org/Dep artments/Planning-Development- Services/Housing-Policies- Projects/Community-Development- Block-Grant FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 19 Sort Or der Mode of Outr each Target of Outre ach Summary of response/attenda nce Summary of comments received Summary of comments not accepted and reasons URL (If applicable) 8 Internet Outreach Non- targeted/broad community Email Blast to interested organizations, persons 3 Email Blasts were sent on January 24 and March 13, 2024, and June 3, 2024, to all documented contacts, interested agencies, and individuals. Jan 24th No comments received March 13th No comments received June 3rd No comments received All comments will be accepted Table 3 – Citizen Participation Outreach FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 20 Expected Resources AP-15 Expected Resources - 91.420(b), 91.220(c)(1,2) Introduction In FY 2024-25, the City will allocate a total of $1,037,807.61 CDBG funds to eligible activities that address the needs identified in the Consolidated Plan. These CDBG funds reflect the sum of a $513,653 FY 2024-25 Entitlement Grant, $60,000 Program Income (estimated) to be receipted in FY 2024-25, and $464,154.61 in unspent funds from prior years that are reallocated. The City acknowledges that program income receipts may vary and endeavors to forecast future income while implementing necessary adjustments to the ongoing program budget. In FY 2024-25, the City reallocated a total of $119,478.74 in CDBG CV funds to eligible activities to prevent and respond to the spread of coronavirus. The total reallocated CDBG-CV funds is the sum of $34,200.50 unspent funds from the canceled LifeMoves-COVID-19 Testing Project and $85,278.24 unspent funds from Planning & Administration funds. 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 efforts include leveraging local county, regional, state and federal funds estimating $5.3 million, that align with goals outlined in the Consolidated Plan. The City continues to leverage additional resources, as described below, to provide support and services to the communities' populations in need. The following section discusses the anticipated resources available for community development activities during the remaining year of the City’s 5-Year Consolidated Plan. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 21 Anticipated Resources Program Source of Funds Uses of Funds Expected Amount Available Year 5 Expected Amount Available Remainder of ConPlan $ Narrative Description Annual Allocation : $ Program Income: $ Prior Year Resources: $ Total: $ CDBG public - federal Admin and Planning Economic Development Housing Public Improvements Public Services 513,653 60,000 (estimate d) 464,154.61 CDBG $119,478.74 CDBG-CV 1,037,807.61 CDBG $119,478.74 CDBG-CV 1,037,807.61 CDBG $119,478.74 CDBG-CV This is the 5th year of the 2020-2025 ConPlan. CDBG funds are used for public services that benefit low income and special needs households, economic development, housing rehabilitation through preservation of owner- occupied homes, and public facilities & improvement projects. A total of $464,154.61 in unspent funds from prior years are reprogrammed in the FY2024-25 AAP. The following canceled projects required a substantial amendment for their corresponding program years: -PY 2021-22 Downtown Streets Inc. - Workforce Development Program project $133,068.07. In total, $191,018.05 of unspent funds from PY2021-22 are available for reprogramming. -PY 2022-23 Mitchell Park Place project $356,330. Reconciliation of PI receipted resulted in total $269,435.96 unspent funds from PY2022-23 are available for reprogramming. In total, $3,700.60 of unspent funds from PY2021-22 are available for reprogramming. All prior years’ resources were reallocated to PY2024-25 Housing Rehabilitation projects. Table 4 - Expected Resources – Priority Table FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 22 Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied 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 funds only projects 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 projects funded leverage private, HSPAP, and County funds estimated 1.6 million to support their programs. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 23 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 continues to track and look for opportunities to leverage State resources for the City. 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 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 development projects. • ADA coordinator and city-wide ADA capital improvement listing. • The Housing Element outlines the City’s detailed housing priorities and needs. • Rebuilding Together Peninsula assists 4-6 low-to moderate income homeowners with home improvements. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 24 Annual Goals and Objectives AP-20 Annual Goals and Objectives - 91.420, 91.220(c)(3)&(e) Goals Summary Information Sort Order Goal Name Start Year End Year Category Geographic Area Needs Addressed Funding Goal Outcome Indicator 1 Affordable Housing 2020 2025 Affordable Housing Affordable Housing CDBG: $478,385 Homeowner Housing Rehabilitated: 5 Households Rehabilitating rental housing units for extremely low income households: 10 2 Homelessness 2020 2025 Homeless Homelessness CDBG: $28,247 CDBG-CV: $110,000 Public service activities other than Low/Moderate Income Housing CDBG Benefit: 158 Persons Assisted CDBG-CV Benefit: 150 Persons Assisted FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 25 Sort Order Goal Name Start Year End Year Category Geographic Area Needs Addressed Funding Goal Outcome Indicator 3 Strengthen Neighborhoods 2020 2025 Non-Homeless Special Needs Non-Housing Community Development Community Services and Public Improvements CDBG: $ $252,717.61 Public Facility or Infrastructure Activities other than Low/Moderate Income Housing Benefit: 435 households Assisted Public service activities other than Low/Moderate Income Housing Benefit: 75 Persons Assisted 4 Fair Housing 2020 2025 Non-Housing Community Development Fair Housing CDBG: $15,575 Public service activities other than Low/Moderate Income Housing Benefit: 12 Persons Assisted 5 Economic Development 2015 2020 Non-Housing Community Development Economic Development CDBG: $120,000 Jobs created/retained: 0 Jobs Businesses assisted: 15 Businesses Assisted Table 5 – Goals Summary FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 26 Goal Descriptions The goal of the City of Palo Alto, with funding from CDBG, is to increase self-sufficiency, housing opportunities and economic opportunity for lower-income residents and individuals so that they can achieve a higher quality of life. In 2020, the City has established the following goals as a guide for allocating CDBG funding during the 5-year consolidated planning period: 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 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. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 27 AP-35 Projects - 91.420, 91.220(d) Introduction The Consolidated Plan goals represent high priority needs for the City of Palo Alto (City) and serve as the basis for the strategic actions the City undertakes to meet these needs. The projects, listed in no particular order are: # Project Name CDBG and CDBG-CV 1 2024 Alta Housing SRO Resident Support Services 2 2024 Catholic Charities of Santa Clara County: Long Term Care Ombudsman Program 3 2024 LifeMoves: Case Management 4 2024 Silicon Valley Independent Living Center (SVILC): Case Management 5 2024 Project Sentinel – Fair Housing Services 6 2024 WeeCare/Upwards 7 2024 Rebuilding Together Peninsula (RTP) – Safe at Home 8 2024 Community Work Group/Abode – Alma Garden 9 2024 Fire Station – Sidewalk Improvements Project 10 2024 HomeKey Palo Alto – Recreation Project 11 2024 Planning & Administration 12 2024 CDBG-CV MOVE Mountain View - Safe Parking Program 13 2024 CDBG-CV Planning & Administration Table 6 – Project Information CDBG Describe the reasons for allocation priorities and any obstacles to addressing underserved needs The City awards CDBG funding to projects and programs that primarily benefits 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. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 28 AP-38 Project Summary Project Summary Information 1 Project Name 2024 Alta Housing SRO Resident Support Services Program Target Area Citywide Goals Supported Homelessness Needs Addressed Homelessness Funding CDBG: $11,575 Description SRO Resident Support Services Program. Eligible Activity (Matrix Code): 05O, Mental Health Services CDBG National Objective: LMC Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities Case management and support counseling services will be provided to an estimated 131 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’s Resident Support Services program project activities include case management and counseling services to residents at the Barker Hotel (25 units) and at Alma Place (106 units). Funding would support a SRO Service Coordinator services to assist residents with managing daily living skills, maintaining their mental and physical health, one-on-one support counseling, and crisis intervention. 2 Project Name 2024 Catholic Charities of Santa Clara County: Long Term Care Ombudsman Program Target Area Citywide Goals Supported Strengthen Neighborhoods Needs Addressed Community Services Funding CDBG: $7,575 Description Long-Term Care Ombudsman Program. Eligible Activity (Matrix Code): 05A, Senior Services CDBG National Objective: LMC Target Date 6/30/2025 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 Catholic Charities' Long-Term Care Ombudsman Program (LTCOP) project activities include regular contact with Palo Alto Residential Care Facilities to observe and monitor conditions of care and handle and resolve issues regarding residents' rights, unmet needs, allegations of abuse, and complaints effectively, thus promoting resident well-being. Funding would support Program services. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 29 3 Project Name 2024 LifeMoves: Case Management Target Area Citywide Goals Supported Homelessness Needs Addressed Homelessness Funding CDBG: $28,247 Description Opportunity Services Center/Hotel De Zink Eligible Activity (Matrix Code):- 03T, Operating Costs of Homeless/AIDS Patients Programs CDBG National Objective: LMC Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 27 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 LifeMoves project activities include case management services to Opportunity Services Center and Hotel De Zink clients in locating housing and/or employment and be connected to benefits. Additionally, activities include provision of services at the Opportunity Services Center, such as showers, restrooms, laundry facilities, benefits enrollment assistance, transportation vouchers, and referrals for medical and dental care for residents of Palo Alto and surrounding areas who are homeless or at risk of homelessness. 4 Project Name 2024 Silicon Valley Independent Living Center (SVILC): Case Management Target Area Citywide Goals Supported Strengthen Neighborhoods Needs Addressed Community Services and Public Improvements Funding CDBG: $14,075 Description Case Management. Eligible Activity (Matrix Code): 05B, Handicapped Services CDBG National Objective: LMC Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 25 unduplicated Palo Alto residents will benefit from one-on-one housing assistance. Location Description Citywide FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 30 Planned Activities Silicon Valley Independent Living Center (SVILC) project activities assist very low income Palo Alto residents with disabilities and their families with their housing search for affordable, accessible housing. Funding would support the Housing and Emergency Services for Persons with Disabilities Program and case management services. The Program provides education & training on all aspects of how to conduct a housing search to transition from homelessness, health care facilities, or unstable, temporary housing into safe, long-term community-based housing. It includes group workshops, one-on-one service training, and access to IL (Independent Living) services, including emergency food assistance, security deposits/rent (as funding allows), information & referral to ensure the long-term sustainability of housing. 5 Project Name 2024 Project Sentinel – Fair Housing Services Target Area Citywide Goals Supported Fair Housing Needs Addressed Fair Housing Funding CDBG: $15,575 Description Fair Housing Services. Eligible Activity (Matrix Code): O5J, Fair Housing Activities CDBG National Objective: LMC 24 CFR 570.208(a)(2) Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 12 unduplicated low and moderate income individuals will be provided with fair housing services of complaint counseling, investigation, and where appropriate enforcement referral. Location Description Citywide Planned Activities Project Sentinel’s project activities include fair housing counseling and investigative services for Palo Alto residents through casework, increase knowledge of fair housing laws and individual counseling on the fair housing laws to improve understanding of residents' and housing providers' rights or obligations. Funding would provide operating expenses for these fair housing services. 6 Project Name 2024 WeeCare/Upwards Target Area Citywide Goals Supported Economic Development Needs Addressed Economic Development Funding CDBG: $120,000 Description WeeCare/Upwards assists Family Childcare Home microenterprise businesses and will provide business improvement services to such businesses in the City. Eligible Activity (Matrix Code): 18B Economic Development-Technical Assistance. CDBG National Objective LMCSV Target Date 6/30/2025 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 31 Estimate the number and type of families that will benefit from the proposed activities 15 daycare microenterprises will benefit from this project. Plus, the possibility of new full-time jobs will be created by WeeCare/Upwards. Location Description Citywide Planned Activities WeeCare/Upwards, a for-profit organization, project activities support their BOOST program for low-income Family Child Care Home (FCCH) providers in Palo Alto. The BOOST program provides specialized technical assistance and business support for income qualifying FCCH’s. 7 Project Name 2024 Rebuilding Together Peninsula (RTP)– Safe at Home Target Area Citywide Goals Supported Affordable Housing Needs Addressed Affordable Housing Funding CDBG: $73,585 Description Eligible Activity (Matrix Code): 14A National Objective LMH 24 CFR 570.202(a)(1) Target Date 6/30/2025 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 RTP project activities preserve affordable housing by transforming homes 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 or financially unable to maintain safe living conditions for themselves and their families. Funding covers the costs of home repair, such as construction materials and payment of subcontractors. 8 Project Name 2024 Community Work Group/Abode – Alma Garden Target Area 2024 Alma Garden Apartments 2507-2533 Alma Street, Palo Alto, CA 94306 Goals Supported Affordable Housing Needs Addressed Affordable Housing Funding CDBG: $404,800 Description Eligible Activity (Matrix Code): 14B National Objective LMH 24 CFR 570.202(a)(1) Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 10 LMI households will benefit from apartment unit improvements. Location Description Citywide FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 32 Planned Activities Community Work Group/Abode project activities include rehabilitating rental housing units in Alma Garden, an affordable multi-family housing complex for extremely low income households, to address existing health and safety concerns. Funding would be spent on a project manager, bathroom upgrades, exterior repairs, and electrical and water utility upgrades. 9 Project Name 2024 Fire Station – Sidewalk Improvements Project Target Area City-Wide Goals Supported Strengthen Neighborhoods Needs Addressed Community Services and Public Improvements Funding CDBG: $62,645.61 Description This project will focus on renovations of sidewalks, curbs, and curb ramps located at 3600 Middlefield Road. Eligible Activity (Matrix Code): 03L, Sidewalks National Objective LMC Target Date 9/30/2025 Estimate the number and type of families that will benefit from the proposed activities 331 LMI households Location Description 3600 Middlefield Rd, Palo Alto, CA 94303, Fire Station No.4 Planned Activities Plan, design and reconstruct the sidewalk, curbs and curb ramps at the intersection area of Meadow Drive and Middlefield Road. The anticipated project requires a contractor bidding process and has an estimated completion timeframe of 18 months. 10 Project Name 2024 Homekey Palo Alto – Recreation Project Target Area City-Wide Goals Supported Homelessness Needs Addressed Homeless Funding CDBG: $185,000 Description This project will provide an on-site play structure and area at the HomeKey Palo Alto shelter. Eligible Activity (Matrix Code): 03C, Homeless Facilities National Objective LMC Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 104 households annually Location Description 1237 San Antonio Road Planned Activities LifeMoves, this homeless service provider will manage the design and construction of recreation area and recreation equipment within the Homekey Palo Alto shelter property. The anticipated project completion timeframe is 12 months. 11 Project Name 2024 Planning & Administration FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 33 Target Area Citywide Goals Supported Strengthen Neighborhoods Needs Addressed Community Services and Public Improvements Funding CDBG: $114,730 Description Eligible Activity (Matrix Code): 21A, General Program Administration Planning and Administration: CDBG Citation: 570.206(a) Target Date 6/30/2025 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. 12 Project Name 2024 CDBG-CV MOVE Mountain View – Safe Parking Program Target Area City-Wide Goals Supported Homelessness Needs Addressed Homelessness Funding CDBG: $110,000 Description MMW operates and provides homeless services at multiple approved Safe Parking Lots in Palo Alto. Case managers helping assist homeless individuals staying on approved parking lots. Eligible Activity (Matrix Code): 03T, National Objective LMC Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 150 individuals will be assisted through the safe parking program. Location Description Citywide Planned Activities CDBG funds will be used for case management staff salaries working with the MMV Safe Parking Program. Establishing housing partnership with property owners and landlords. Rather than solely referring clients to existing housing opportunities, MOVE MV case managers and or housing specialists forge direct connections by facilitating client sponsorship in rental placement. Beneficiaries include vehicle dwellers and other homeless persons living in Palo Alto parking lots. 13 Project Name 2024 CDBG-CV Planning & Administration Target Area City-Wide Goals Supported Strengthen Neighborhoods Needs Addressed Community Services and Public Improvements Funding CDBG: $9,478.74 Description Planning and Administration: CDBG Citation: 570.206(a) Target Date 6/30/2025 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 34 Estimate the number and type of families that will benefit from the proposed activities The City will provide general administrative support to the CDBG-CV program. Location Description Citywide Planned Activities Administer the administrative costs for the overall management, coordination, and evaluation of the CDBG-CV program, and the project delivery costs associated with bringing projects to completion. 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 any designated target areas. Instead, the City focuses CDBG funds on public services, housing preservation, economic development-business assistance, and capital improvements across the City as a whole. Geographic Distribution Target Area Percentage of Funds Citywide 100% Table 7 - Geographic Distribution Rationale for the priorities for allocating investments geographically This question is not applicable to Palo Alto’s program. Discussion See discussion above. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 35 AP-75 Barriers to affordable housing -91.420, 91.220(j) Introduction The City of Palo Alto is committed to providing equitable opportunities to all residents of Palo Alto in order to expand access to housing and increase housing mobility. The City will take action to overcome patterns of segregation, address disparities in housing needs and access to opportunity, and foster inclusive communities. The City’s Housing Element contains a listing of actions established to reduce the barriers to affordable housing, including but not limited to racial inequities, high housing and land costs, regulatory constraints, and public resistance. Currently the City is experiencing a constrained housing supply market, so when housing developments produce housing units that are considered “relatively” affordable, higher- income buyers and renters outbid lower-income households. Subsequently, a home’s final sale or rental price may exceed the projected sales or rental costs. Public subsidies are often needed to guarantee affordable homes for low- and moderate-income households. The City wants to ensure adequate planning is undertaken to provide its “fair share” of affordable and market-rate housing, demonstrating a strategy for removing barriers to increase housing production that addresses today’s housing shortage. To address the requirements of AB 686, the City participated in the 2020-2025 Santa Clara County Consolidated Plan (ConPlan). The County’s ConPlan identifies eight housing goals for the County and each of its participating jurisdictions, including Palo Alto. Additionally, the ConPlan identifies regional and local barriers to fair housing around the region, with heavy emphasis on racial and economic disparity, land use and zoning, and lack of assistance and resources. Programs were identified to reduce barriers in the City, including adjusting zoning amendments to expand affordable and alternative housing opportunities and increasing accessibility to information. 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% and provided more exceptions to applicable zoning and development standards. One significant update is if a 100% affordable development is located within half a mile of a major transit stop, the City cannot impose any density limits and is entitled to a maximum height increase of three additional stories or 33 feet. • Remove Density requirements in certain zoning districts. • 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 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 36 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 making changes to its BMR program and adopted a new fee structure. The ordinances became effective on June 19, 2017. • Fair Housing: Protect tenants from displacement through more robust tenant protections and better access to legal services. The City annually provides CDBG funding to Project Sentinel, a non- profit entity that provides expertise in fair housing law and tenant-landlord disputes. Program 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. • Fair Housing: Increase access to lending opportunities for residents of historically low-income communities of color. • 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 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 commercially 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. • The average Palo Alto home, as of February 1, 2023, costs about 8 times the national average home price, and the monthly rent is about 2.5 times the national average. • Title 18 (Zoning) Relating to Accessory Dwelling Units and Junior Accessory Dwelling Units: The City recently updated amended its Ordinance Title 18, which included “the development of a single-family home, ADU, and/or a JADU on a lot that allows for single-family development shall not be considered a multifamily development pursuant to PAMC Section 18.04.030, nor shall they require Architectural Review pursuant to other sections of Chapter 18. In addition to addressing the square footage height restrictions, 18.09.040 • The City Amended Chapter 9.68 (Rental Housing Stabilization) of the Municipal Code to expand just cause eviction protections to Palo Alto renters, including reducing the minimum time period FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 37 required for renters to qualify for just cause eviction protections. Discussion Please see above. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 38 AP-85 Other Actions - 91.420, 91.220(k) Introduction The following provides a description of today's obstacles and or barriers to meeting LMI or underserved populations, including vulnerable populations, housing preservation needs, lead-paint issues, increased earning capacity for LMI households, city delivery structure for supporting needed services, and regional approaches to serving and helping the homeless populations. Actions planned to address obstacles to meeting underserved needs The City collaborative works with social service providers, affordable housing developers, housing preservation entities, fair housing and homeless assistance agencies to address obstacles to permanent housing for all residents. To address this, the City supplements its CDBG funding with other resources and funds, such as: • Support social services entities including Alta Housing and Catholic Charities that provide needed supportive services for extremely low-income and or elderly residents. • In FY 2022-23, the City’s Human Service Resource Allocation Process (HSRAP) provided $622,377 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. • Support low income persons with disabilities. Provide CDBG funds to Silicon Valley Independent Living Center (SVILC) with case management needs. • Support the city’s homeless population through CDBG awards and other funding sources to: LifeMoves Shelter and proposed Homekey Palo Alto shelter development project. • 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. • Continue to locally support, through General City Funds, the 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: • Support low income homeowners through annual CDBG allocations for housing rehabilitation. Provide CDBG funds to Rebuilding Together Peninsula to preserve existing affordable housing stock. The City is also planning an affordable housing rehabilitation and replacement project, Buena Vista Mobile Home Park that will benefit approximately 270 residents. • Support Community Work Group (Abode) with CDBG funds to preserve 10 affordable housing FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 39 units. • Annual CDBG allocations to Rebuilding Together Peninsula to preserve existing affordable housing stock. • 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. • Apply to both the State of California HOME program, and the County’s HOME Consortium to fund supported affordable housing projects. • The Commercial Housing Fund and Residential Housing Fund are used by the City to assist new housing development or the acquisition, rehabilitation, or the preservation of existing housing for affordable housing. • 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. • The City is collaborating with Santa Clara County and Eden Housing in the development of Michell Park Place, a new affordable housing development project providing 50 affordable units located in one of the City’s LMI census tracts. Actions planned to reduce lead-based paint hazards The City’s housing and CDBG staff provides technical assistance, information, and referrals 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 be 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. Rebuilding Together Peninsula, through its housing rehabilitation program, ensures each rehab includes lead-based paint assessment and mitigation on impacted areas for each housing case. 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 2024-25, these programs will include the following: • LifeMoves provides basic necessities for persons who are homeless or at risk of becoming FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 40 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. • Homekey Palo Alto, although not CDBG funded, is supported by the City and other state and federal resources to build a new interim housing shelter that will serve over 200 individuals annually. This new facility includes 88 rooms with interior shows and restrooms. • 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. • Buena Vista Mobile Home Park development project, although not CDBG funded, is supported by the City to replace, and increase the number of residential units in the development. Plus improve neighborhood amenities include walking trails, bulk trash removal, new water/sewer infrastructure. Actions planned to develop institutional structure The administration of the City’s CDBG program requires collaboration between several departments including the finance department, administration, Human Services, and Planning and Development Services Department staff. The Planning and Development Services Department assigns critical staff to manage project development, subrecipient contracting and technical assistance, consultant management, collaboration with public works department staff, and fund draws and activity spending. The Finance Department assists in the process by reconciling CDBG and City budget accounts and draw approvals. The Human Relations Commission and Council hold public hearings and recommend recommendations and final approvals of annual CDBG project activities and projects. The City strives to improve intergovernmental and private sector cooperation to synergize efforts and resources and develop new revenues for community service needs and affordable housing production. Collaborative efforts include: • Regular meetings between entitlement jurisdictions at the CDBG Housing Coordinators meetings and Regional Housing Working Group. • Joint jurisdiction Request for Proposals and project review committees. • Collaborations between the City’s housing and public works departments. • 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 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 41 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 continues to participate with other local jurisdictions and developers in sharing information and resources. In FY 2024-25, the City awarded CDBG funds to the Alma Garden project for the preservation of 10 residential very low income rental units. The City is collaborating with Santa Clara County and Eden Housing in the development of Michell Park Place, a new affordable housing development project providing 50 affordable units located in one of the City’s LMI census tracts. In addition to the actions listed above, the City continues to coordinate with the City’s Human Relations Commission on funding efforts to address community needs comprehensively. Discussion Please see discussions above. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 42 Program Specific Requirements AP-90 Program Specific Requirements - 91.420, 91.220(l)(1,2,4) Introduction 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 completed. 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 60,000 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: 60,000 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. Specify the years covered that include this Annual Action Plan. 100.00% Discussion Please see the discussion above. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 43 Appendices APPENDIX A Public Comments The City held two Advertised public hearing on February 8, 2024, and June 18, 2024. The draft CDBG FY2024-25 Annual Action Plan dated February 1, 2024 was circulated for public comments and reviewed from March 13, 2024, through April 12, 2024. No public comments were received during this 30-day public comment and review period time. No public comments were received to date, June 3, 2024. All comments will be accepted and recorded once received. Any written comments received will be in the public participation document. FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 44 APPENDIX B Public Notices • Publication October 2, 2023: Notice of CDBG and CDBG-CV Funding Availability (NOFA) • Publication January 24, 2024: Notice of Public Review, Comment Period, and Public Hearing for the FY 2024-25 Community Development Block Grant (CDBG) Annual Action Plan • Publication March 13, 2024: Notice of Public Review, Comment Period, and Public Hearing for the Fiscal Year (FY) 2024-25 Community Development Block Grant (CDBG) Annual Action Plan • Publication June 3, 2024: Correction Notice - Public Hearing Date Change, Notice of Public Review and Public Hearing for the Fiscal Year (FY) 2024-25 Community Development Block Grant (CDBG) Annual Action Plan • FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 45 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 46 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 47 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 48 FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 49 APPENDIX C Application for Federal Assistance SF-424 Forms and Certifications (to be completed and signed after City Council action on the CDBG FY 2024-25 Annual Action Plan) *NOT YET ADOPTED* ATTACHMENT B 0160144_KB2_20240529_AY16 Resolution No. _______________ Resolution of the City Council of the City of Palo Alto Approving the Use of Community Development Block Grant for Fiscal Year 2024-25 and Substantial Amendments for the Use of Community Development Block Grant Fiscal Year 2021-22, Fiscal Year 2022-23 & CDBG CARES Act Funds for Fiscal Year 2020-21 R E C I T A L S 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 2024-2025 Annual Action Plan, Substantial Amendments, and the annual funding update to the Consolidated Plan, was subjected to public review and commentary during the period from March 13, 2024 through April 12, 2024. C. The potential uses of Community Development Block Grant (CDBG) and CDBG CARES Act (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 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. As an extension, under the CDBG-CV program, the highest priority is given to activities which prevent, prepare for, and respond to coronavirus. E. The City Council and the Human Relations Commission held publicly noticed public hearings on the proposed uses of the CDBG and CDBG-CV funds for Fiscal Year 2024-25, as well as the proposed Substantial Amendments for the proposed reprogramming of Community Development Block Grant funds from Fiscal Year 2021-22, Fiscal Year 2022- 23 funds & CDBG-CV funds for Fiscal Year 2020-21. F. CDBG and CDBG-CV funds allocated to the City for Fiscal Year 2024-2025 are proposed to implement the programs described in this resolution. *NOT YET ADOPTED* ATTACHMENT B 0160144_KB2_20240529_AY16 NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF PALO ALTO RESOLVES AS FOLLOWS: SECTION 1. The uses of CDBG funds for Fiscal Years: 2024-25, 2021-22, 2022-23, 2023-24, and CDBG-CV funds for Fiscal Year 2020-21 are hereby approved and authorized for the following programs: Name of Program Amount 1. Alta Housing – SRO Resident Support Services Program. Provide in- house case management and counseling services to residents at Barker Hotel and Alma Place. $11,575 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. $7,575 3. LifeMoves – Case Management. Provide case management services to Opportunity Services Center and Hotel De Zink clients in locating housing and/or employment and be connected to benefits. $28,847 4. Silicon Valley Independent Living Center – Case Management. Provide case management services to low-income individuals with disabilities to secure affordable and accessible housing. $14,075 5. Project Sentinel – Fair Housing Services. Provide fair housing services including complaint investigation, counseling, advocacy, and community education $15,575 6. WeeCare/Upwards - a microenterprise business that will provide Palo Alto childcare business improvement services. $120,000 7. Rebuilding Together Peninsula – Safe at Home. Provision of critical health and safety related home repair needs for low-income Palo Alto homeowners. $73,585 8. Community Work Group/Abode – Alma Garden. 10 LMI households will benefit from apartment unit improvements. $404,800 9. Fire Station – Sidewalk Improvements Project. Reconstruct the sidewalk, curbs, and curb ramps to current ADA accessibility standards at the intersection area of Meadow Drive and Middlefield Road. $62,645.61 10. Homekey Palo Alto – Recreation Project. This project will provide a recreation area and recreation equipment at the HomeKey Palo Alto shelter. $185,000 *NOT YET ADOPTED* ATTACHMENT B 0160144_KB2_20240529_AY16 11. CDBG Program Planning and Administration $114,730 Total CDBG Funds $1,037,807.61 12. CDBG-CV MOVE Mountain View – Safe Parking Program $110,000.00 13. CDBG-CV Program Planning and Administration $9,478.74 Total CDBG-CV Funds $119,478.74 SECTION 2. The total amount set forth under Section 1 of this resolution represents the proposed allocation of $513,653 in CDBG funds from the United States Department of Housing and Urban Development (HUD) for Fiscal Year 2024-2025, $60,000 in anticipated program income to be receipted in Fiscal Year 2024-25 from Alta Housing (previously known as Palo Alto Housing Corporation), and a total of $464,154.61 in prior years' resources (FY 2021-22 $191,018.05, FY 2022-23 $269,435.96, FY 2023-24 $3,700.60) from canceled projects and remaining unspent funds of closed completed projects. Substantial Amendments are required for FY 2021-22 CDBG, FY 2022-23 CDBG, and CDBG-CV Funds. Available CDBG-CV funds total amount of $119,478.74, including unspent funds from the canceled LifeMoves-COVID-19 Testing project ($34,200.50) and unspent CDBG-CV Planning & Administration funds ($85,278.24). SECTION 3. The City staff is hereby authorized to submit the Annual Action Plan to Fiscal Year 2024-2025, CDBG Substantial Amendment to Fiscal Year 2021-22 & CDBG Substantial Amendment to Fiscal Year 2022-23 and CDBG-CV Substantial Amendment to Fiscal Year 2020-21 Annual Action Plan, update and appropriate funding to HUD, 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 City staff is hereby authorized to draft and execute loan documents and a regulatory agreement to secure a $404,800 loan to Community Working Group/Abode for the Alma Gardens Rehabilitation project. SECTION 5. The funding amounts set forth in Section 1 of this resolution are based on final allocation amounts from the Federal Fiscal Year 2024-25, Fiscal Year 2021-22, Fiscal Year 2022-23 & Fiscal Year 2023-24 & CARES Act (CDBG-CV) Fiscal Year 2020-21, 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 ADOPTED* ATTACHMENT B 0160144_KB2_20240529_AY16 SECTION 6. The City Council hereby finds that the Fiscal Year 2024-25, Fiscal Year 2021- 22, Fiscal Year 2022-23 & Fiscal Year 2023-24 & CARES Act (CDBG-CV) Fiscal Year 2020-21, CDBG & CDBG-CV 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 2024-25 CDBG & CDBG- CV program prior to the release of funds for any such project. INTRODUCED: 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 1 Attachment C: Human Relations Commission Review Summary The CDBG federal allocations for FY 2024-25 were not known at the time of the HRC public hearing on February 8, 2024. For budgeting purposes, staff estimated the City’s HUD entitlement grant for FY 2025 as a 0.8% reduction from the entitlement grant amount from previous year FY 2023-2024. Therefore, the total amount considered by the HRC as available for CDBG allocation FY 2024-25 was $1,122,415.01, including the estimated FY 2024-25 entitlement grant ($510,000), estimated program income ($60,000), and estimated unspent funds from prior years ($552,415.01). The estimated total available in CDBG-CV funding for FY 2024-25 is $119,478.74, including unspent funds from the canceled LifeMoves-COVID-19 Testing project ($34,200.50) and unspent CDBG-CV Planning & Administration funds ($85,278.24). The HRC considered the funding recommendations of the HRC Selection Committee1 and voted unanimously to recommend Council approval of the draft FY 2024-25 AAP. The HRC discussed proposed funding allocations based on the program budget, availability of additional resources, HUD spending caps, and the total available CDBG and CDBG-CV funds. Key points of the HRC discussion included: •A summary of the application selection process, reasons for selection, and agency capacity; •A summary of HRC Selection Committee deliberations; •A summary of the HRC Selection Committee’s recommended Contingency Plan and clarification of the desire to support LifeMoves at a level closer to half their requested amount, if feasible; •Information on the definitions of income levels and income limits, which are influenced by family size, varying by county (Palo Alto uses HUD’s FY 2023 Income Limits Area for Santa Clara County Metropolitan area2, effective May 15, 2023, with HUD's acronym for low-income limits being LMI); •Consideration of increasing funding toward homelessness services in future funding years if it could be learned if CDBG funds directly resulted in the reported 25% decrease in homelessness in Palo Alto in 2023 year; •Clarifications on unspent funds, which are the result of applicants cancelling approved projects, not using all of their available allocation, no longer needing their available allocation, or remaining funds being left due to the lifting of COVID-19 mandates; and •Clarifications on the reduction of funds to CDBG Program Administration resulting from the interplay of the 20% spending cap on this funding category combined with a forthcoming reduction in program income receipts for FY 2024-25. 1 February 8, 2024 Human Relations Commission staff report: https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=d37a6bbc-0569-4d6b-91db-05b16a3dabc0 2 Source: https://www.huduser.gov/portal/datasets/il/il2023/2023summary.odn 2 The HRC’s recommended contingency plan is as follows: A. If more funds are received than estimated: 1.Ensure funding caps are met for Public Services and Planning & Administration categories; 2.Increase LifeMoves' FY 2024-25 allocation to $34,960, or as near as feasible; 3.Retain the currently recommended funding for Project Sentinel; 4.If there are surplus funds available, allocate additional funding proportionally to other Public Services applications based on their recommended shares, provided they are not fully funded; 5.Allocate any remaining un-capped funds to the Public Facilities project(s). B. If less funds are received than estimated: 1.Ensure funding caps are met for Public Services and Planning & Administration categories; 2.Decrease funding across each of the Public Services applications proportionate to the overall decrease in funding; 3.If possible, maintain full funding for both Housing Rehabilitation projects and the Economic Development project; and 4.Decrease un-capped funds from the Public Facilities project(s). FY 2024-25 Community Development Block Grant Annual Funding Allocations Public Hearing #2 City Council –June 18, 2024 www.cityofpaloalto.org1 Presenters: Rebecca Atkinson, Planner, City of Palo Alto Tina Roseberry, Manager, Michael Baker International 2 Meeting Purpose Hold a Public Hearing on the draft Community Development Block Grant (CDBG) FY 2024-25 Annual Action Plan City Council review and approval of the CDBG FY 2024-25 Annual Action Plan 3 Funding Categories & Proposed Subrecipients •Alta Housing -SRO Resident Support Services $11,575 •Catholic Charities of Santa Clara County –Long Term Care Ombudsman Program $7,575 •LifeMoves –Case Management $28,247 •Silicon Valley Independent Living Center (SVILC)–Case Management $14,075 •Project Sentinel –Fair Housing Services $15,575 CDBG Public Services –15% Cap •WeeCare/Upwards $120,000 CDBG Economic Development •Rebuilding Together Peninsula (RTP) –Safe at Home $73,585 •Community Work Group/Abode –Alma Garden $404,800 CDBG Housing Rehabilitation •Fire Station –Sidewalk Improvement Project $62,645.61 •Homekey Palo Alto –Recreation Project $185,000 CDBG Public Facilities and Improvements •City of Palo Alto $114,730 CDBG Planning & Administration –20% Cap •MOVE Mountain View –Safe Parking Program $110,000 CDBG-CV Public Services –No Cap •City of Palo Alto $9,478.74 CDBG-CV Planning & Administration –20% Cap 4 Recommendations The Human Relations Commission (HRC) and staff recommend that the City Council: 1.Adopt the draft Fiscal Year (FY) 2024-25 Annual Action Plan (AAP, Attachment A) and the associated CDBG FY 2024-25 Annual Action Plan Resolution (Attachment B) allocating Community Development Block Grant (CDBG) and CDBG CARES Act (CDBG- CV) funding for FY 2024-25, as amended to include funding for Life Moves at $28,247; 2.Authorize the City Manager to execute the FY 2024-25 CDBG Application to fund the FY 2024-25 Annual Action Plan and associated documents concerning the application, and to otherwise bind the City with respect to the applications and commitment of funds; 3.Authorize staff to submit the Fiscal Year 2024-25 AAP (Attachment A) to the U.S. Department of Housing and Urban Development (HUD) by the July 6, 2024, deadline; 4.Authorize the City Manager or designee to draft and execute a loan agreement, regulatory agreement, and related documents necessary to implement City Council direction on the Alma Garden Rehabilitation Project in a form consistent with the City’s affordable housing loan documents and approved by the City Attorney; and 5.Amend the Fiscal Year 2025 Budget Appropriation for the Community Development Block Grant Fund (2/3 vote needed) by: a.Increasing Revenue from Other Agencies by $1,157,286 b.Increasing General Expenses by $1,157,286.