HomeMy WebLinkAboutStaff Report 2601-5797CITY OF PALO ALTO
CITY COUNCIL
Special Meeting
Monday, March 16, 2026
Council Chambers & Hybrid
4:30 PM
Agenda Item
A.Summary of Fiscal Year 2024-2025 Community Development Block Grant (CDBG) Program
Accomplishments — Review of the CDBG Consolidated Annual Performance and
Evaluation Report (CAPER). CEQA Status: Not a Project.
City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: Planning and Development Services
Meeting Date: March 16, 2026
Report #:2601-5797
TITLE
Summary of Fiscal Year 2024-2025 Community Development Block Grant (CDBG) Program
Accomplishments — Review of the CDBG Consolidated Annual Performance and Evaluation
Report (CAPER). CEQA Status: Not a Project.
RECOMMENDATION
This is an informational report and no action is required.
EXECUTIVE SUMMARY
The City is required to annually report its accomplishments achieved through its Community
Development Block Grant (CDBG) program to the U.S. Department of Housing and Urban
Development (HUD). This annual report to HUD is called the Consolidated Annual Performance
and Evaluation Report (CAPER). In accordance with the City’s CDBG Citizen Participation Plan,
the City’s Human Relations Commission (HRC) conducts a public hearing on the draft CAPER to
allow for public review and discussion. The City then submits the draft CAPER to HUD by the
annual September deadline. Afterwards, staff typically provides City Council with an
informational report disseminating the draft CAPER submitted to HUD. Rather than providing a
copy of the draft CAPER to City Council in November, this year staff is providing City Council
with a copy of the final CAPER for CDBG Fiscal Year (FY) 2024-2025 (Attachment A). This
updated process ensures that City Council has the opportunity to view the HUD-approved
version of the document.
The CAPER was accepted by HUD on January 13, 2026. No action is required by City Council to
receive the CAPER.
During FY 2024-2025, the City’s CDBG subrecipients provided projects, programs, and activities
that benefited extremely low-, very low-, low-, and moderate-income individuals and
households in Palo Alto. Through CDBG and CDBG-CV funds, 7,320 persons and 15
microenterprises were assisted in FY 2024-2025. Of the 7,320 persons and microenterprises
assisted by CDBG, 447 were extremely low-income and 6,918 were low-income. CDBG-CV
funds, in 2020, were awarded to entitlement jurisdictions to prevent, prepare for and respond
to the spread of COVID-19.
BACKGROUND
ANALYSIS
Catholic Charities of Santa Clara County – Long Term Care Ombudsman Program [Goal:
Assist 37 individuals; Actual: 37 individuals]. The program provided advocacy and
complaint investigation for elderly residents of long-term care facilities in Palo Alto,
which included regular contact with Palo Alto Residential Care Facilities to observe and
monitor conditions of care.
Alta Housing – SRO Resident Supportive Services [Goal: Assist 131 individuals; Actual:
516 individuals]. Alta Housing engaged a service coordinator to provide 40 hours of
weekly services to provide case management and support counseling services to
residents at Alma Place and Barker Hotel to help them maintain housing stability.
Activities included financial counseling, health maintenance, information, and referral
problem-solving, employment assistance, crisis intervention, and case management.
Both Alma Place and Barker Hotel are single-room occupancy facilities.
LifeMoves – Case Management [Goal: Assist 32 individuals; Actual: 47 individuals].
LifeMoves provided case management services to Opportunity Services Center and
Hotel De Zink clients for locating housing and/or employment and be connecting clients
to benefits.
Project Sentinel – Fair Housing Services [Goal: Assist 10 individuals; Actual: 7
individuals]. Project Sentinel provided fair housing services to City residents including
community education and outreach regarding fair housing law and practices,
investigation, counseling, and legal referral for victims of housing discrimination.
Silicon Valley Independent Living Center (SVILC) – Case Management Services [Goal:
Assist 21 individuals; Actual: 12 individuals]. SVLIC provided assistance for individuals
with disabilities and their families. This assistance helped these persons to transition
from homelessness, health care facilities, unstable or temporary housing to permanent
affordable, accessible, integrated housing involving emergency assistance, security
deposits, rent, information, and referrals.
Rebuilding Together Peninsula – Safe at Home Program [Goal: Assist 5 households;
Actual: 2 households]. Program preserved affordable housing by transforming homes
through critical repairs and accessibility modifications, at no cost to the service
recipient. The majority of the low-income homeowners served were elderly seniors
and/or people with disabilities, who are physically and financially unable to maintain
safe living conditions for themselves and their families. The program did not meet its
anticipated goal due to program outreach and recruitment challenges. The City is
working with Rebuilding Together Peninsula to determine new outreach methods.
Palo Alto Public Works Department – 2023 ADA Curb Ramp Improvements [Goal:
2,090 individuals; Actual: 6,681 individuals]. The City intends to fund a major curb ramp
improvement project that will bring an estimated 70 curb ramps up to current ADA
accessibility standards.
Abode/Community Work Group – Alma Garden Rehabilitation [Goal: 10 individuals;
Actual: 0 individuals]. Project activities include rehabilitating rental housing units in
Alma Garden, an affordable multi-family housing complex for very low and low-income
households, to address existing health and safety concerns. Funding is being spent on a
project manager, bathroom upgrades, exterior repairs, and electrical and water utility
upgrades. Construction continues with interior work as exterior work has concluded.
Rehabilitation is anticipated to be complete by May 2026, at which point the City will
close the project out and update the outcomes to reflect 10 individuals served.
LifeMoves – HomeKey Recreation Project [Goal: 100 individuals; Actual: 0 individuals].
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. The Homekey interim shelter project has
experienced construction delays. The City plans to complete the recreation project by
July 2026 - then update the program outcomes to reflect 100 individuals.
WeeCare/Upwards – BOOST Program [Goal: 15 microenterprises; Actual: 15
microenterprises]. WeeCare worked with Family Child Care Home (FCCH) providers in
Palo Alto who are already on the wait list for the BOOST program. These providers
received staff training-learning best practices on how to grow and sustain their
organization and how to better support the families they serve. Funds requested to pay
WeeCare staff salaries for training providers on how to use Child Management System
(CCMS) software. CCMS was developed for providers to create work plans, goals,
capacity, and revenue, empowering them to reach service and operations goals.
Move Mountain View (MMV) [Goal: 37 individuals; Actual: 6 individuals]. The program
provides reserved off-street parking for participants, as well as permanent housing
solutions through intensive case management. MMV operates four 24/7 RV Safe Parking
lots and three Congregational Safe Parking locations. The total capacity of these lots in
Palo Alto and Mountain View is 109 vehicles. A total of 159 vehicle dwellers are
currently enrolled in the program. One of locations is located in Palo Alto at the Geng
Road Safe Parking Lot. The Geng Road Safe Parking Lot is where MMV utilizes Palo Alto’s
CDBG-CV funds. Funding pays for the salary of one full-time Client Counseling Case
Manager and one full-time Client Case Manager Housing Specialist. The program has an
ongoing vacancy at the Case Manager level. Despite active recruitment efforts, this
vacancy has limited the programs ability to meet its anticipated goals.
If a subrecipient does not meet the anticipated performance outcomes identified in the
funding agreement, the City may require corrective actions, modify the scope of services,
or reallocate unspent funds to other eligible activities. Continued underperformance may
be considered in future funding recommendations.
As required by HUD, the FY 2024-2025 draft CAPER was submitted by the September 30, 2025,
deadline.
FISCAL/RESOURCE IMPACT
This informational report has no fiscal impact. However, leveraging CDBG funds enables the
City to support essential public services, capital improvements, and housing-related activities
without reliance on the General Fund. The use of CDBG funds represents an effective strategy
to secure and deploy outside resources to accomplish local goals and priorities.
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
2024-2025
Consolidated Annual Performance
and Evaluation Report
(CAPER)
COMMUNITY DEVELOPMENT BLOCK
GRANT (CDBG)
ADMINISTERED BY:
PLANNING AND DEVELOPMENT SERVICES
1
2
CR-05 - Goals and Outcomes
Progress the jurisdiction has made in carrying out its strategic plan and its action plan.
91.520(a)
This could be an overview that includes major initiatives and highlights that were proposed and
executed throughout the program year.
The Consolidated Annual Performance and Evaluation Report (CAPER) is a report that
demonstrates the overall progress realized through the City’s priorities and specific objectives as
identified in the Fiscal Year (FY) 2024-2025 Annual Action Plan and the 2020-2025 Consolidated
Plan. The CAPER highlights accomplishments that occurred between July 1, 2024, to June 30,
2025. This is the final year-end report of the 2020-2025 Consolidated Plan.
As shown in Table 1, the City of Palo Alto has accomplished immense success in FY2024-2025
(PY2024-2025, Program Year 2024-2025, PY2024) while meeting identified goals. The City has
used Community Development Block Grant (CDBG) funds to support their community’s residents.
The City does not receive HOME Investment Partnership (HOME), Emergency Shelter Grant (ESG),
or Housing Opportunities for Persons with AIDS (HOPWA) and thus these funds are not reflected
in this report.
A total of $1,107,757 in CDBG funds was available for projects and programs during the 2024-
2025 Program Year (PY). The City received $513,653 from the federal CDBG program and
$129,950 in program income and had $464,154.61 available in unspent funds from previous
years. In FY2024-2025, the City reallocated CDBG-CV funds in the sum of $34,200.50 unspent
funds from the canceled LifeMoves’ COVID-19 Testing Project and $85,278.24 unspent funds
from Planning and Administration.
In PY2024, 7,320 persons and 15 microenterprise businesses were assisted through CDBG
allocations.
Major accomplishments for FY2024-2025 include the following:
Planning and Administration.
•Catholic Charities of Santa Clara County – Long Term Care Ombudsman Program
•Alta Housing – SRO Resident Supportive Services
3
services to provide case management and support counseling services to residents at
Alma Place and Barker Hotel to help them maintain housing stability. Activities included
financial counseling, health maintenance, information, and referral problem-solving,
employment assistance, crisis intervention, and case management. Both Alma Place and
Barker Hotel are single-room occupancy facilities;
•LifeMoves – Case Management [Goal: Assist 32 individuals; Actual: 47 individuals].
LifeMoves provided case management services to Opportunity Services Center and Hotel
De Zink clients for locating housing and/or employment and be connecting clients to
benefits;
•Project Sentinel – Fair Housing Services [Goal: Assist 10 individuals; Actual: 7 individuals].
Project Sentinel provided fair housing services to City residents including community
education and outreach regarding fair housing law and practices, investigation,
counseling, and legal referral for victims of housing discrimination;
•Silicon Valley Independent Living Center (SVILC) – Case Management Services [Goal:
Assist 21 individuals; Actual: 24 individuals]. SVLIC provided assistance for individuals with
disabilities and their families. This assistance helped these persons to transition from
homelessness, health care facilities, unstable or temporary housing to permanent
affordable, accessible, integrated housing involving emergency assistance, security
deposits, rent, information, and referrals;
•Rebuilding Together Peninsula – Safe at Home Program [Goal: Assist 5 households;
Actual: 2 households]. Program preserved affordable housing by transforming homes
through critical repairs and accessibility modifications, at no cost to the service recipient.
The majority of the low-income homeowners served were elderly seniors and/or people
with disabilities, who are physically and financially unable to maintain safe living
conditions for themselves and their families;
•Public Works Department (PW) – 2023 ADA Curb Ramp Improvements [Goal: 2,090
individuals; Actual: 6,681 individuals]. The City intends to fund a major curb ramp
improvement project that will bring an estimated 70 curb ramps up to current ADA
accessibility standards;
•Abode/Community Work Group – Alma Garden Rehabilitation [Goal: 10 individuals;
Actual: 0 individuals]. Project activities include rehabilitating rental housing units in Alma
Garden, an affordable multi-family housing complex for very low and 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
4
upgrades. Construction continues with interior work as exterior work has concluded;
•LifeMoves – HomeKey Recreation Project [Goal: 100 individuals; Actual: 0 individuals].
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. Environmental review reaching conclusion with
construction to begin shortly thereafter.
•WeeCare/Upwards – BOOST Program [Goal: 15 microenterprises; Actual: 15
microenterprises]. WeeCare worked with Family Child Care Home (FCCH) providers in
Palo Alto who are already on the wait list for the BOOST program. These providers
received staff training-learning best practices on how to grow and sustain their
organization and how to better support the families they serve. Funds requested to pay
WeeCare staff salaries for training providers on how to use Child Management System
(CCMS) software. CCMS was developed for providers to create work plans, goals, capacity,
and revenue, empowering them to reach service and operations goals; and
•Move Mountain View (MMV) [Goal: 37 individuals; Actual: 6 individuals]. The program
provides reserved off-street parking for participants, as well as permanent housing
solutions through intensive case management. MMV operates four 24/7 RV Safe Parking
lots and three Congregational Safe Parking locations. The total capacity of these lots in
Palo Alto and Mountain View is 109 vehicles. A total of 159 vehicle dwellers are currently
enrolled in the program. One of locations is located in Palo Alto at the Geng Road Safe
Parking lot. The Geng Road Safe Parking Lot is where MMV utilizes Palo Alto’s CDBG -CV
funds. Funding pays for the salary of one full-time Client Counseling Case Manager and
one full-time Client Case Manager Housing Specialist. MMV continues to look to fill these
positions.
Comparison of the proposed versus actual outcomes for each outcome measure submitted
with the consolidated plan and explain, if applicable, why progress was not made toward
meeting goals and objectives. 91.520(g)
Categories, priority levels, funding sources and amounts, outcomes/objectives, goal outcome
indicators, units of measure, targets, actual outcomes/outputs, and percentage completed for
each of the grantee’s program year goals
Goal Category
Source
/
Amount
Indicator Unit of
Measure
Expected
–
Strategic
Plan
Actual –
Strategic
Plan
*Percent
Complete
Expected
–
Program
Year
Actual –
Program
Year
Percent
Complete
Affordable
Housing
Affordable
Housing CDBG: $ Rental units
rehabilitated
Household
Housing
Unit
107 0 0.00% 0 0 -
Affordable
Housing
Affordable
Housing CDBG: $
Homeowner
Housing
Rehabilitated
Household
Housing
Unit
40 19 47.50% 15 2 13.33%
Economic
Development
Non-Housing
Community
Development
CDBG: $ Jobs
created/retained Jobs 150 28 18.67% 0 0 -
Economic
Development
Non-Housing
Community
Development
CDBG: $ Businesses
assisted
Businesses
Assisted 0 34 - 15 15 100.00%
Fair Housing
Non-Housing
Community
Development
CDBG: $
Public service
activities other
than
Low/Moderate
Income Housing
Benefit
Persons
Assisted 75 89 118.67% 10 7 70.00%
Homelessness Homeless
CDBG: $
/ CDBG-
CV: $
Public service
activities other
than
Low/Moderate
Income Housing
Benefit
Persons
Assisted 800 1,546 193.25% 304 569 187.17%
1
Goal Category
Source
/
Amount
Indicator Unit of
Measure
Expected
–
Strategic
Plan
Actual –
Strategic
Plan
*Percent
Complete
Expected
–
Program
Year
Actual –
Program
Year
Percent
Complete
Homelessness Homeless
CDBG: $
/ CDBG-
CV: $
Tenant-based
rental assistance
/ Rapid
Rehousing
Households
Assisted 60 92 153.33% 0 0 -
Homelessness Homeless
CDBG: $
/ CDBG-
CV: $
Homeless
Person
Overnight
Shelter
Persons
Assisted 100 0 0.00% 0 0 -
Homelessness Homeless
CDBG: $
/ CDBG-
CV: $
Overnight /
Emergency
Shelter /
Transitional
Housing Beds
Beds 0 0 0 0 0 -
Strengthen
Neighborhoods
Non-
Homeless
Special
Needs
Non-Housing
Community
Development
CDBG: $
Public Facility or
Infrastructure
Activities other
than
Low/Moderate
Income Housing
Benefit
Persons
Assisted 2,190 6,681 305.07% 2,090 6,681 319.67%
2
Goal Category
Source
/
Amount
Indicator Unit of
Measure
Expected
–
Strategic
Plan
Actual –
Strategic
Plan
*Percent
Complete
Expected
–
Program
Year
Actual –
Program
Year
Percent
Complete
Strengthen
Neighborhoods
Non-
Homeless
Special
Needs
Non-Housing
Community
Development
CDBG: $
Public service
activities other
than
Low/Moderate
Income Housing
Benefit
Persons
Assisted 3,600 1,886 52.39% 59 62 105.08%
Table 1 - Accomplishments – Program Year & Strategic Plan to Date
*IDIS (Integrated Disbursement and Information System) automatically rounds percentages to the nearest whole number: rounding up if the decimal portion is
greater than 0.50 and rounding down if the decimal portion is less than 0.50. Table 1 reports on precise percentages.
Assess how the jurisdiction’s use of funds, particularly CDBG, addresses the priorities and specific objectives identified in the plan,
giving special attention to the highest priority activities identified.
Throughout FY2024-25 (Program Year 2024), the subrecipients of the City’s CDBG program persistently delivered essential services to
households belonging to the extremely low-, very low-, low-, and moderate-income brackets. Simultaneously, they tackled the
priorities and needs of the community, as outlined in the City’s officially adopted 2020 -2025 Consolidated Plan.
The City achieved numerous goals as outlined in the FY2024 -2025 Annual Action Plan (AAP) through CDBG funding. A total of
$1,107,757 was available for funding projects and programs during the 2024 Program Year. The City received $513,653 from the
federal CDBG program and $129,950 in program income and had $464,154.61 in previous year unspent CDBG funds. At the time of
this CAPER, the City has spent approximately $793,516.08. In FY2024-2025, the City reallocated CDBG-CV funds in the sum of
$34,200.50 unspent funds from the canceled LifeMoves’ COVID-19 Testing Project and $85,278.24 unspent funds from Planning and
3
Administration.
Goals established through the 2020-2025 Consolidated Plan include:
•Affordable Housing: Assist in the creation and preservation of affordable housing for low -income and special needs
households.
•Homelessness: Support activities to prevent and end homelessness.
•Community Services and Public Improvements: Support provision of essential human services, particularly for special needs
populations, and maintain/expand community facilities and infrastructure.
•Fair Housing: Promote fair housing choice.
•Economic Development: Support economic development activities that promote employment growth and help lower income
people secure and maintain jobs.
Through the CDBG annual formula grant, activities such as the following were undertaken and accomplished to contribute toward
meeting the 2020-2025 Consolidated Plan’s goals:
•Catholic Charities, Ombudsman Program: Assisted 37 senior residents through visitation, resolved complaints, completed
phone outreach at local long-term facilities.
•LifeMoves, Opportunity Services Center: Assisted 47 homeless and very low-income individuals through case management
services, including housing and job searches.
•Project Sentinel: Assisted 7 low-income individuals with tenant and landlord mediation services.
•Alta Housing: Assisted 516 individuals in the Single-Room Occupancy (SRO) Residents Support Program through onsite
counseling services.
•Rebuilding Together Peninsula: Assisted 2 households with home rehabilitation.
•Move Mountain View: Assisted 6 individuals with intensive case management services through the reserved off-street
parking program.
•WeeCareUpwards: Assisted 15 family childcare home businesses with business improvement services.
•SVILC: assisted 24 persons through case management services.
•Alma Garden: construction underway with completion scheduled for PY2025 .
4
•Homekey Recreation Project: environmental review to completed with construction to commence shortly there after .
•43 ADA Curb Ramps were installed, benefiting the City of Palo Alto’s 6,681 residents with disabilities.
5
CR-10 - Racial and Ethnic composition of families assisted
Describe the families assisted (including the racial and ethnic status of families assisted).
91.520(a)
CDBG
White 5,527
Black or African American 318
Asian 996
American Indian or American Native 65
Native Hawaiian or Other Pacific Islander 12
Total 6,918
Hispanic 572
Not Hispanic 6,346
Table 2 – Table of assistance to racial and ethnic populations by source of funds
Narrative
During FY2024-2025, the City was successful in collecting demographic data for 7,335 persons
who were served with CDBG funds. Table 2 above outlines the racial and ethnic populations
served by CDBG funds in FY2024-2025 (PY 2024) for a variety of races, although this HUD IDIS
formatted reporting table does not track persons identifying as multi -racial. Not reflected in
Table 2 above is an additional 417 identified as multi-racial individuals. Further, 584 of the total
individuals assisted identified as Hispanic.
A portion of services provided included:
•Alta Housing SRO Resident Support Services Program: Case management and support
counseling services provided to 516 residents of Barker Hotel and Alma Place.
•Catholic Charities of Santa Clara County Long Term Care Ombudsman Program: Advocacy
and compliant investigation provided to 37 elderly residents of long-term care facilities in
the City.
•LifeMoves at Opportunity Services Center and Hotel De Zink: Case management services
provided to 47 homeless and/or very low-income individuals, including assistance with
housing/job searches, referrals, and mentoring.
•Silicon Valley Independent Living Center: Case management services provided to 24 very
low-income residents with disabilities and their families, including group workshops, one-
on-one service training, and access to independent living services, including emergency
food assistance, security deposits/rent (as funding allows), information and referral to
ensure the long-term sustainability of affordable and accessible housing.
6
•Project Sentinel Fair Housing Services: Fair housing services, including complaint
counseling, investigation, and (where appropriate) enforcement referral was provided to
7 LMI individuals.
•WeeCare/Upwards Family Childcare Home Microenterprises: 15 microenterprise daycare
businesses in the City of Palo Alto received assistance. WeeCare/Upwards’ BOOST
Program supports low-income family-child care home providers in Palo Alto.
•Rebuilding Together Peninsula, Safe at Home: 2 LMI households including seniors and/or
persons with disabilities received home improvement assistance for critical home repairs.
7
CR-15 - Resources and Investments 91.520(a)
Identify the resources made available
Source of Funds Source Resources Made
Available
Amount Expended
During Program Year
CDBG public - federal 1,107,757 793,516.08
Table 3 - Resources Made Available
Narrative
Identify the geographic distribution and location of investments
Target Area Planned Percentage
of Allocation
Actual Percentage of
Allocation
Narrative Description
Citywide 100% 100% Community Services
and Public
Improvements,
Economic
Development,
Housing
Rehabilitation,
Sidewalk
Improvements
Table 4 – Identify the geographic distribution and location of investments
Narrative
The City’s approach to housing assistance encompasses all forms of housing support, aligning
with the principles outlined in the City’s Comprehensive Plan. CDBG-funded public service and
housing activities are not confined to specific target areas. The City strives to offer affordable
housing options and community services to individuals with lower incomes across the entire
municipality.
8
Leveraging
Explain how federal funds leveraged additional resources (private, state and local funds),
including a description of how matching requirements were satisfied, as well as how any
publicly owned land or property located within the jurisdiction that were us ed to address the
needs identified in the plan.
The City of Palo Alto does not receive HOME, ESG, or any other federal grants that require
matching requirements. However, the City is consistently maximizing their use of available
resources while simultaneously looking out for additional funding opportunities. In addition, the
City actively encourages nonprofit organizations to pursue various avenues of funding, including
state, local, and federal resources, to support housing and community development activities.
The following funds were leveraged during FY2024-2025.
Human Services Resources Allocation Process (HSRAP): In FY2024-2025, the City allocated
General Funds to HSRAP to address primary human service needs in Palo Alto. These funds
support human service initiatives, guided by the Human Relations Commission’s priority needs
and administered by the Office of Human Services.
Local Housing Trust Fund (LHTF): In FY2022-2023, the City of Palo Alto received $3.4 million from
HCD to use alongside local matching funds toward the production of rental housing units at
varying affordability levels. 70 percent of these funds target housing units for residents with
incomes at or below 60 percent of the area median income (AMI), while 30 percent are for
residents with incomes at or below 30 percent AMI.
Permanent Local Housing Allocation (PLHA): As a PHLA entitlement jurisdiction, Palo Alto
received an annual PHLA allocation from HCD. The City uses these funds to assist persons who
are experiencing homelessness or who are at risk of experiencing homelessness. Funding is used
toward street outreach and operating expenses for the Palo Alto Homekey shelter, and for
affordable rental housing preservation, new construction, and operating subsidies.
HOMEKEY: Palo Alto Homekey is a forthcoming modular interim housing shelter with the
capacity to serve over 200 individuals annually with on -site supportive services. As a co-
development partnership between the City and LifeMoves, the project is receiving a combination
of funding from both state and local contributions, including the Palo Alto Community Fund, the
Peery Foundation, Sobrato Philanthropies, Santa Clara County, and the City itself. These
additional funding sources address expenses beyond what federal funds can cover, such as pre -
development costs, feasibility studies, and site acquisition.
9
CR-20 - Affordable Housing 91.520(b)
Evaluation of the jurisdiction's progress in providing affordable housing, including the
number and types of families served, the number of extremely low -income, low-income,
moderate-income, and middle-income persons served.
One-Year Goal Actual
Number of homeless households to
be provided affordable housing
units
0 0
Number of non-homeless
households to be provided
affordable housing units
0 0
Number of special-needs
households to be provided with
affordable housing units
5 2
Total 5 2
Table 5 – Number of Households
Number of households supported
through rental assistance
Number of households supported
through the production of new
units
Number of households supported
through the rehab of existing units
5 2
Number of households supported
through the acquisition of existing
units
Total 5 2
Table 6 – Number of Households Supported
Discuss the difference between goals and outcomes and problems encountered in meeting
these goals.
While not a recipient of HOME funds, the City continued its partnership with Rebuilding Together
Peninsula through its Safe at Home Program. The Program represents preservation of affordable
housing, as the program provides for critical home repairs and accessibility modifications at no
cost to the recipient. Those served include LMI homeowners that are elderly and/or are people
with disabilities, who are physically and financially unable to maintain safe living conditions for
themselves and their families. With Rebuilding Together Peninsula, the City assisted a total of 2
LMI households with rehabilitation through CDBG funds during PY2024. The number of
households assisted through the Safe at Home Program is dependent on available funds and
the
CAPER- 2025
Discuss how these outcomes will impact future annual action plans.
Rebuilding Together Peninsula’s multi
’s successful
Include the number of extremely low-income, low-income, and moderate-income persons
served by each activity where information on income by family size is required to determine
the eligibility of the activity.
Number of Households Served CDBG Actual HOME Actual
Total 2 0
Table 7 – Number of Households Served
Narrative Information
“housing for social and economic balance” as a key priority in both
has made “implementing housing strategies for social
and economic balance” a key priority.
11
to LMI residents, the City has an interactive Affordable Housing Resources Map embedded on
their website featuring affordable housing properties and projects managed by affordable
housing organizations.
In addition, the Housing Authority of the County of Santa Clara (HACSC) administers the federal
Section 8 program countywide, providing rental subsidies and developing affordable housing for
low-income households, seniors, and persons with disabilities.
12
CR-25 - Homeless and Other Special Needs 91.220(d, e); 91.320(d, e); 91.520(c)
Evaluate the jurisdiction’s progress in meeting its specific objectives for reducing and ending
homelessness through:
Reaching out to homeless persons (especially unsheltered persons) and assessing their
individual needs
The City of Palo Alto has an enduring local commitment to address homelessness and provide
services for the unhoused.
Jurisdictions in the County of Santa Clara participate in the county-wide Point-in-Time (PIT) Count
every two years. At the time of this report, the 2025 PIT Count’s preliminary results show that
there are 10,711 individuals experiencing homelessness in Santa Clara County. This represents
an 8.2 percent increase from 2023. Simultaneously, the number of sheltered homeless
individuals increased by approximately 30 percent as compared to 2023, marking an increase in
shelter capacity. Unsheltered homeless individuals remained relatively the same as in 2023, with
an increase of just one percent. The full 2025 PIT Count Report, which includes detailed data
about the City of Palo Alto’s homeless trends, will be available in late summer or early fall of
2025. According to Santa Clara County’s 2023 PIT Count, there were 206 homeless persons in the
City of Palo Alto, including 187 unsheltered individuals and 19 sheltered individuals.
The City of Palo Alto provides funding for unhoused services and homelessness prevention
through multiple funding channels, including CDBG, Human Services Resource Allocation Process
(HSRAP), Permanent Local Housing Allocation (PLHA), and the Emerging Needs Fund. This broad
financial support is directed toward service provision and homeless prevention.
Services for the City’s homeless population include workforce development, basic needs stipends
for work experience, food, seasonal homeless shelter, school supplies for children, case
management, tele-medicine equipment, and shower/laundry services. Additionally, the City
contracted with a local nonprofit to provide a two-person full time Outreach Team to reach out
and provide services to unhoused individuals in the community, including those living in cars and
RVs. The City also opened an Overnight Warming Location (OWL) that operated during winter
and provided 19 “nights indoors.”
The City also has several initiatives aimed at preventing homelessness from oc curring, including
assistance through LifeMoves and the Silicon Valley Independent Living Center. LifeMoves’
Opportunity Services Center (OSC) is specifically designated by the County of Santa Clara as the
Emergency Assistance Network Agency for financial assistance in the City of Palo Alto. The OSC
in Palo Alto exclusively serves homeless individuals. Further, LifeMoves at the OSC provides
intake services to all clients served to assess needs and to provide appropriate resources and
referrals. LifeMoves also provides basic need services such as access to restrooms, showers,
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laundry, used clothing, hygiene supplies, healthcare, mail and telephone services, food,
transportation assistance, counseling, information and referral services, and other critical
services as needed.
The City of Palo Alto will continue to explore its funding strategy and collaborate with other Santa
Clara County cities to ensure that limited federal and local resources are targeted to critical
community needs such as homelessness.
Addressing the emergency shelter and transitional housing needs of homeless persons
During FY2024-2025, LifeMoves’ Opportunity Services Center (OSC) received funding from the
City of Palo Alto to provide emergency shelter and/or transitional housing for homeless persons.
This project received $28,247 in CDBG funding from the City and has significantly extended its
operational hours, thereby providing enhanced support to Palo Alto’s homeless community. This
extension has provided vulnerable clients with more time within a secure and nurturing
environment, ensuring they receive the critical assistance they require. During FY2024-2025,
LifeMoves offered case management services to 47 individuals in the City of Palo Alto through its
CDBG funds.
Helping low-income individuals and families avoid becoming homeless, especially extremely
low-income individuals and families and those who are: likely to become homeless after
being discharged from publicly funded institutions and systems of care (such a s health care
facilities, mental health facilities, foster care and other youth facilities, and corrections
programs and institutions); and, receiving assistance from public or private agencies that
address housing, health, social services, employment, education, or youth needs
In FY2024-2025, the City of Palo Alto administered CDBG funds to Alta Housing and LifeMoves to
help low-income individuals and families avoid becoming homeless, especially those who are
extremely low-income and those who are discharged from publicly funded institutions and
systems of care.
Alta Housing received $11,575 in CDBG funding and offered on-site counseling services to
residents at Alma Place and Barker Hotel who are part of the Single-Room Occupancy (SRO)
Resident Support Program. This program encompasses 145 units with the majority of residents
being low-income, persons with disabilities, seniors, veterans, and/or formerly homeless adults.
Many residents experience difficulty managing daily living skills, such as managing finances,
maintaining mental and physical health, maintaining living spaces, and having good relationships
with others. Without onsite support, such issues can become so severe that tenants risk losing
their housing. Case management was provided to 516 residents through CDBG in FY2024-2025.
LifeMoves received $28,247 in CDBG funding and provided case management services to 47
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homeless and/or very low-income City residents. Case management services included assistance
with housing and job searches, referrals to other resources, and mentoring.
The City follows the guidance of Santa Clara County’s Continuum of Care (CoC) as it relates to
individuals who may be discharged from publicly funded institutions and systems of care. The
Santa Clary County CoC has developed the Santa Clara County Countywide Quality Assurance
Standards for Homeless Housing and Service Programs (2021). This was developed with the
expectation of providing quality, standardized services to persons who have become homeless
to facilitate their successful re-entry back into their communities. As a member of the CoC, the
City of Palo Alto will be following the standards established in the documents.
Helping homeless persons (especially chronically homeless individuals and families, families
with children, veterans and their families, and unaccompanied youth) make the transition to
permanent housing and independent living, including shortening the peri od of time that
individuals and families experience homelessness, facilitating access for homeless individuals
and families to affordable housing units, and preventing individuals and families who were
recently homeless from becoming homeless again
In FY2024-2025, the City undertook several activities to help homeless persons, especially
chronically homeless individuals and families, families with children, veterans and their families,
and unaccompanied youth make the transition to permanent housing and independent living.
Through CDBG funding, Silicon Valley Independent Living Center (SVILC) conducted case
management and offered their Housing Workshops. These Housing Workshops educate
households on skills and topics that are conducive to independent living. Topics and skills include
credit card readiness and credit repair, types of low-income housing and eligibility, application
and interview preparation, tenant and landlord rights and responsibilities, housing and home
modifications laws and resources, security deposit and rental assistance programs, and long-term
supportive services. During FY2024-2025, SVILC used CDBG funds to assist 24 unduplicated Palo
Alto residents with disabilities with one-on-one assistance and the development of an
independent living plan for housing. These individualized independent living plans resulted in
improved access to decent affordable housing.
In addition, Project Sentinel provided community education and outreach regarding housing laws
and practices, investigation, counseling, and legal referrals for victims of housing discrimination.
During FY2024-2025, 7 LMI residents were provided individual case management and
consultation through CDBG funds.
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CR-30 - Public Housing 91.220(h); 91.320(j)
Actions taken to address the needs of public housing
The Santa Clara County Housing Authority (SCCHA) administers Housing Choice Vouchers (HCVs)
and Project-Based Vouchers (PBVs) in the City of Palo Alto. As of January 2025, there were 272
total vouchers in use in the City, including 67 PBVs at the Buena Vista Mobile Park. SCCHA’s
waiting list for the County is operated on a lottery basis, with preference given to households
who have lived and worked in the County for the past five years and to veterans. For PBV units,
accessibility features are tracked, and a lottery is used to match households based on specific
accessibility needs.
SCCHA currently has no public housing units in its portfolio that are located in the City of Palo
Alto. Following SCCHA’s conversion of its public housing portfolio under the Rental Assistance
Demonstration (RAD) program, only four traditional public housing units remain in the County,
all of which are located in the City of Santa Clara.
Actions taken to encourage public housing residents to become more involved in
management and participate in homeownership
While the majority of the public housing units have been converted to affordable housing stock,
the Santa Clara County Housing Authority (SCCHA) is proactive in incorporating resident input
into the agency’s policy making process. An equitable and transparent policy making process that
includes the opinions of residents is achieved through the involvement of two tenant
commissioners, one being a senior citizen, on the Authority’s board.
SCCHA also operates a Family Self-Sufficiency (FSS) Program for households participating in the
Housing Choice Voucher (HCV) Program. Through the FSS Program, as earned income and rent
portions increase, SCCHA makes monthly deposits into a household savings account. Upon the
completion of the Program, which involves meeting personal goals, the savings are provided to
the household. The FSS Program encourages financial independence and stability, and is typically
five years in length, with an average completion time of 3 years and 10 months.
Actions taken to provide assistance to troubled PHAs
Not applicable.
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CR-35 - Other Actions 91.220(j)-(k); 91.320(i)-(j)
Actions taken 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. 91.220 (j); 91.320 (i)
The City of Palo Alto is committed to taking actions to remove or ameliorate the negative effects
of public policies that serve as barriers to affordable housing. In July 2024, the City adopted the
2023-2031 Housing Element, which includes several programs meant to tackle impediments to
affordable housing development. The 2023-2031 Housing Element was certified by HCD on
August 20, 2024. Programs include modifications to existing zoning standards to allow for denser
development, further streamlining the development review process, provisions of development
standards that incentivize housing production, reevaluation of fees to support development, and
more.
The Housing Trust Silicon Valley (Housing Trust) was established to provide available financial
resources targeted at bridging the affordable housing gap within Santa Clara County. Originally
known as the Housing Trust Fund of Santa Clara County, the Housing Trust’s overarching mission
is to contribute to rendering Silicon Valley a more financially accessible place to live. The Housing
Trust achieves this by disbursing loans and grants to increase the affordable housing supply,
supporting first-time homebuyers, forestalling homelessness, and enhancing community
stability. Palo Alto was one of the founding contributors to this initiative and has continued to
support and help fund the Housing Trust. Notably, the partnership has a provision to ensure that
funds allocated by the City of Palo Alto are exclusively channeled toward qualifying affordable
housing projects within the City’s municipal boundaries.
To further remove or ameliorate the negative effects of public policies that result in barriers, the
City has development impact fees encompassing four distinct categories. These include housing,
traffic, community facilities, and parkland dedication. The introduction of development impact
fees in the City are a result from comprehensive nexus studies undertaken for both commercial
and residential development. Outcomes from the studies laid the groundwork for revised fees
associated with residential and non-residential housing, which became effecting on June 19,
2017. The housing impact fees are subject to annual updates, with fees charged being periodically
evaluated and modified to ensure that they support, rather than prohibit, housing development.
Actions taken to address obstacles to meeting underserved needs. 91.220(k); 91.320(j)
The City's CDBG program demonstrates a committed effort to collaborate with various funding
entities, aiming to maximize the impact of each dollar invested. This is accomplished through
strategic collaborations with other municipal resources, such as the Human Services Resource
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Allocation Process (HSRAP), enabling the pooling of funds designated for site acquisition in low -
income housing alongside diverse funding sources. However, Palo Alto faces challenges in fully
addressing barriers that impede the fulfillment of underserved needs, given that needs outshine
the annual availability of CDBG funds over the years. In response, the City supplements its CDBG
funding with other resources and funds. For example:
•During FY2024-2025 (PY 2024), the City allocated General Funds to the City’s Human
Service Resource Allocation Process (HSRAP) to address primary human service needs in
Palo Alto. HSRAP funds, coupled with CDBG public service funds, are allocated to local
non-profit organizations.
•Palo Alto’s Commercial Housing Fund is used primarily to increase the number of new
affordable housing units for Palo Alto’s work force. It is funded with mitigation fees
required from developers of commercial and industrial projects.
•Palo Alto’s Residential Housing Fund is derived from mitigation fees collected through the
City’s Below Market Rate (BMR) Housing Program from residential developers and various
other miscellaneous sources, such as the proceeds generated from the sale or leasing of
City property.
•The City established the Below Market Rate (BMR) Emergency Fund to offer continuous
funding for loans to BMR owners, encompassing special assessment loans. This supports
the restoring and safeguarding of the City's collection of BMR ownership units.
•While the City itself is not a recipient of HOME funds, HOME funds are made accessible
through a competitive selection process administered by the State of California HOME
program and the County’s HOME Consortium.
Actions taken to reduce lead-based paint hazards. 91.220(k); 91.320(j)
Lead-based paint (LBP) was popularized in the early twentieth century but was banned for use in
public housing through the Lead-Based Paint Act of 1971 and later in 1978 for use in private
residential housing. According to the U.S. Environmental Protection Agency (EPA), LBP can be
found on window frames, walls, on the outside of a home, or on other surfaces. While LBP in
good condition does not typically pose a threat, chipped paint or paint dust is harmful when
ingested. This is particularly concerning for young children, as elevated blood lead levels are
associated with cognitive impairments amongst other issues. According to the State of California
Department of Health, children are most susceptible to LBP poisoning due to hand-to-mouth
behaviors.
City housing and CDBG staff disseminate information and make referrals to property owners,
developers, and non-profit organizations engaged in the restoration of older housing, particularly
concerning hazards linked to LBP. In line with this, any dwelling slated for rehabilitation aided by
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City financial support is subjected to an assessment for the presence of LBP hazards. The City
extends financial support for mitigating LBP hazards in rehabilitated units with City funding.
Additionally, the City enforces contractor training and certification to mitigate the potential use
of LBP in the construction of 40 new units. All development and rehabilitation projects must be
evaluated according to HUD’s Lead Safe mitigating LBP hazards in rehabilitated units Housing
Rule 24 CFR Part 35.
Actions taken to reduce the number of poverty-level families. 91.220(k); 91.320(j)
The City of Palo Alto is actively committed to ending and reducing poverty. During FY2024-2025
(PY 2024), the following activities were undertaken to reduce the number of poverty-level
families:
•LifeMoves provided case management services, including assistance with housing and job
searches to 47 homeless/very low-income community residents. LifeMoves provides
necessities for persons who are homeless or at risk of becoming homeless. Additionally,
LifeMoves operates the Opportunity Services Center (OSC), which is a comprehensive,
one-stop, multi-service, day drop-in center providing critical services for homeless Palo
Alto residents. Specifically, the center provides showers, laundry, clothing, snacks, case
management, and shelter/housing referral services.
•Alta Housing provided counseling and supportive case management services to 516 low-
income residents of single room occupancy facilities to help them maintain housing
stability. Activities included financial counseling, health maintenance, information and
referral, problem solving, employment assistance, crisis intervention, and case
management.
•The Silicon Valley Independent Living Center (SVILC) assisted 24 very low-income Palo Alto
residents with disabilities and their families in searching for affordable and accessible
housing. CDBG funds were used to support the Housing and Emergency Services for
Persons with Disabilities Program and case management services. The Program provides
education and training on all aspects of how to conduct a housing search to transition
from homelessness, healthcare facilities, or unstable/temporary housing into safe, long-
term community-based housing. In addition, the Program includes group workshops, one-
on-one service training, and access to independent living services (including emergency
food assistance, security deposits, and information/referral to other services).
Actions taken to develop institutional structure. 91.220(k); 91.320(j)
The City is actively working towards enhancing collaboration between governmental bodies and
private sector entities to harness collective endeavors, pool resources, and identify additional
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revenue to address community service requirements and create affordable housing. This
collaborative approach encompasses several key initiatives, including participation in:
•Meetings among entitlement jurisdictions through the CDBG Coordinators;
•Meetings of the Regional Housing Working Group;
•Joint jurisdiction Request for Proposals and project review committees;
•Community service and housing initiatives funded by multiple jurisdictions ; and
•HOME Consortium meetings among member jurisdictions to discuss affordable housing
projects.
Actions taken to enhance coordination between public and private housing and social service
agencies. 91.220(k); 91.320(j)
The City of Palo Alto benefits from a strong housing and community development partnership
network both within its jurisdiction and the wider region. Collaborative relationships with
organizations such as the County and the Continuum of Care (CoC) further strengthen this
network. To foster increased collaboration between public and private sectors, the City actively
partners with local jurisdictions and developers, facilitating the exchange of knowledge and
resources. In addition to the strategies mentioned above, the City remains dedicated to
harmonizing its goals with its Human Services Resource Allocation Process (HSRAP) funding
initiatives, ensuring a comprehensive approach to meeting community needs
Identify actions taken to overcome the effects of any impediments identified in the
jurisdictions analysis of impediments to fair housing choice. 91.520(a)
The City is committed to actively promoting fair housing in accordance with the adopted 2020 -
2025 Analysis of Impediments. Measures undertaken to advance fair housing in Palo Alto include:
•2023-2031 Housing Element: Includes programs to address affirmatively further fair
housing, such as outreach/education services, the continuation and enforcement of the
Below Market Rate (BMR) program that provides more affordable units, the expansion of
housing services, and the implementation of more renter protections.
•City of Palo Alto Local Housing Funds: A sizable portion of the City's local housing funds
were allocated towards augmenting and conserving the inventory of affordable housing.
•Section 8 Housing Vouchers: The Office of Human Services held regular meetings with
the County of Santa Clara Housing Authority to facilitate the placement of homeless
individuals using Section 8 vouchers.
•Information Access: The Office of Human Services provided affordable housing
information and referral services.
•Assessment of Fair Housing (AFH) Plan: In a joint effort with the County of Santa Clara
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and its cities, Palo Alto adopted its updated AFH Plan in May 2023.
•Project Sentinel: During FY2024-2025, the City provided CDBG funding to Project
Sentinel, a non-profit organization dedicated to assisting individuals with housing
problems. Project Sentinel served 7 LMI individuals with case management services.
CR-40 - Monitoring 91.220 and 91.230
Describe the standards and procedures used to monitor activities carried out in furtherance
of the plan and used to ensure long-term compliance with requirements of the programs
involved, including minority business outreach and the comprehensive planning
requirements
The City remains actively engaged in overseeing all subrecipients and projects to ensure their
adherence to the federal CDBG program and comprehensive planning requirements. This
monitoring process encompasses the review of quarterly performance reports, reimbursement
requests, supporting documentation, and agency audit reports. Biennial desk-site monitoring is
conducted for all CDBG subrecipients, involving assessing client files, project objectives,
compliance with agreements, administrative and financial management, and internal controls.
The City completed its last subrecipient monitoring process in Spring 2024 for all subrecipients
and will conduct subrecipient monitoring again in the next Fiscal Year. The City also completed
risk assessments for all subrecipients.
Citizen Participation Plan 91.105(d); 91.115(d)
Describe the efforts to provide citizens with reasonable notice and an opportunity to
comment on performance reports.
Electronic copies of the FY2024-2025 draft CAPER were made available on the City’s website for
the required 15-day public comment period from September 9, 2025, through September 24,
2025. Hardcopies of the draft CAPER were also available for review at the Development Center,
Planning and Development Services at City Hall, and at the City’s Downtown Public Library. On
August 30, 2025, an advertisement was placed in the Daily Post newspaper advertising the
upcoming availability of the draft CAPER for public review and comment. The Human Relations
Commission (HRC) held a public hearing on September 11, 2025, to discuss and hear public
comments on the draft CAPER.
Per the City’s adopted Citizen Participation Plan (CPP), Palo Alto offers translation services when
a substantial number of non-English speaking residents can be reasonably expected to participate
or when a reasonable accommodation request is made. Non-English speaking residents requiring
translation assistance or any accommodations, along with persons with disabilities requiring
assistance, are advised to submit their request as soon as possible but no later than 48 hours
before a scheduled meeting, program, or service.
For the September 11th HRC meeting agenda, staff report, and meeting information, please visit
City’s website.
Comments, if any, received by phone, email, and/or during the public meeting will be
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summarized and provided in the draft CAPER attachments that will later be submitted to HUD.
CR-45 - CDBG 91.520(c)
Specify the nature of, and reasons for, any changes in the jurisdiction’s program objectives
and indications of how the jurisdiction would change its programs as a result of its
experiences.
Not applicable. The City does not plan to change the CDBG program objectives.
Does this Jurisdiction have any open Brownfields Economic Development Initiative (BEDI)
grants?
No.
[BEDI grantees] Describe accomplishments and program outcomes during the last year.
Not applicable.
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CR-58 – Section 3
Identify the number of individuals assisted and the types of assistance provided
Total Labor Hours CDBG HOME ESG HOPWA HTF
Total Number of Activities 0 0 0 0 0
Total Labor Hours
Total Section 3 Worker Hours
Total Targeted Section 3 Worker Hours
Table 8 – Total Labor Hours
Qualitative Efforts - Number of Activities by
Program
CDBG HOME ESG HOPWA HTF
Outreach efforts to generate job applicants who are Public Housing
Targeted Workers
Outreach efforts to generate job applicants who are Other Funding
Targeted Workers.
Direct, on-the job training (including apprenticeships).
Indirect training such as arranging for, contracting for, or paying
tuition for, off-site training.
Technical assistance to help Section 3 workers compete for jobs
(e.g., resume assistance, coaching).
Outreach efforts to identify and secure bids from Section 3 business
concerns.
Technical assistance to help Section 3 business concerns understand
and bid on contracts.
Division of contracts into smaller jobs to facilitate participation by
Section 3 business concerns.
Provided or connected residents with assistance in seeking
employment including drafting resumes, preparing for interviews,
finding job opportunities, connecting residents to job placement
services.
Held one or more job fairs.
Provided or connected residents with supportive services that can
provide direct services or referrals.
Provided or connected residents with supportive services that provide
one or more of the following: work readiness health screenings,
interview clothing, uniforms, test fees, transportation.
Assisted residents with finding childcare.
Assisted residents to apply for or attend community college or a four
year educational institution.
Assisted residents to apply for or attend vocational/technical training.
Assisted residents to obtain financial literacy training and/or coaching.
Bonding assistance, guaranties, or other efforts to support viable bids
from Section 3 business concerns.
Provided or connected residents with training on computer use or
online technologies.
Promoting the use of a business registry designed to create
opportunities for disadvantaged and small businesses.
Outreach, engagement, or referrals with the state one-stop system,
as designed in Section 121(e)(2) of the Workforce Innovation and
Opportunity Act.
Other.
Table 9 – Qualitative Efforts - Number of Activities by Program
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Narrative
Not applicable.
CAPER 28
OMB Control No: 2506-0117 (exp. 09/30/2021)
CAPER 29
OMB Control No: 2506-0117 (exp. 09/30/2021)
CAPER 30
OMB Control No: 2506-0117 (exp. 09/30/2021)
CAPER 31
OMB Control No: 2506-0117 (exp. 09/30/2021)
CAPER 32
OMB Control No: 2506-0117 (exp. 09/30/2021)
Proof of Notice for Comment Period