HomeMy WebLinkAbout0623.093December 9, 1993
HONORABLE CITY CO~NCrL
Palo Alto, California
Members of the Council:
REpoRT Ili' BRIBF
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Council action is requested to approve the proposed ~evisions and
updates to the Community Development and Citizen participation
Plans of the Community Develo~ent Block Grant (CDBG) Program.
The community Development Plan sets forth the city's community
development needs, and identifies CDBG fUnding pricrities for the
1994-95 fiscal year. The Citizen Participation Plan outlines the
methods the city will employ to: 1) encourage the participation
of citizens in all phases of the CDBG proqram~ 2) make
information about the CDBG program and process available to the
public and 3) provide for the needs of individuals with
disabilities and those who are non-English speaking~
Title I of the Housing and community Development Act of 1974 (HeD
Act) was amended by the Housing and Community Development Act ot
1992, Which became law on october 28, 1992. The 199~ Act
mandated some statutory changes to the community Development
Plans required by the HCD Act. Palo Alto's current Comm\L~ity
Development P,lan was adopted by council on october 1-, 1984
(Attac~ent l}, and the current Citi~en Participation Plan was
adopted by Council on AUgust 23, 1979 (Attachment 2).
The 1992 Act also increased the require~ £inimuN number of public
hearings from one to two and directed 'lZ'ante.es to hold pub!.ic
hearings at diffe~ent stages of the CDBG program year, in order
to encourage public participation in all phases of the program.
The attached timeline (Attachment 3) represents a general summary
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of the new proposed CDB(;. progra1ll. sched\lle incorpcra*cinq the
required cnanqss.
co!Ol!D!ITX PI!VELOP!!E~
The revi$e~ Community Development Plan (Attachment 4J is an
interim doc~ent which updates the existinq plan, provides an
overview ot eliqible activities, d~scribes community development
needs and the objectives aim~d to me~t those needs. It is
intended to serve as the required community Development Plan
until HUD issues new regulations in response to the Clinton
administrationTs directive to make qovern~ent more @fficient and
responsive.
HUn has advised Grantees that they intend to simplify the
planning, application and reporting requirements for the
ted.rally administered CDBG and HOKE Programs by consolidating
and streamlining them into one document~ Fiscal year 1994/95 is
to be a transition year in which the simplified regulations will
be promulgated. The consolidated doc'Jme~t will be required for
the 1995/96 proqram year~
CITIZ'K PARTZCIP~TlON PLAN
The draft citizen Participation Plan (Attachment 5) updates and
revis~a the existing Citizen Pa~icipation Plan to incorporate
mandated statutory changes and bring it into compliance with
existing requlatio~s_ Additionally, staff recommends that the
term and composition of the Citizens Advisory Committee be
cbangea by 1J reducing the number of CAe members from fifteen to
nine: 2, limiting membership to two consecutive two-year ~erms
and ]J eliainating aqency affiliation trom the current Committee
membership requirement~ and prohibiting board members, of
agencies applying for or receiving CDBG funds, from serving on
the C5.tizens Committee.
The reduction in the number of committee me~bers is proposed to
have the total number of members more in line with other Council
appointed boards and commissions. ~he ter~ limits are proposed
to encourage broad community representation and participation.
The third change is proposed in order to eli~inate possible
conflicts of interest and protect the integrity of the program.
On November 4, 1993, the current fifteen-~ember CDSO Citizens
Advisory committee (CAC) met to re~-liew t-_he changes to the
community Development and citizen participation Plans discussed
above~ The CAe voted to endorse Council's adoption of the plans,
with the exception of the membership restrictions on agency board
memb9rs. The CAe felt that the expertise of aqency
representatives outweighed the possible con:t'lict of interest
considerations. The Committee's concerns are summa~ized on
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Attachment 6. Attachment
Alto Housing Corporation
iss~e.
Cgnflict of Interest Issue
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7 is an opinion letter from the Palo
a~dressing the conflict of interest
The cur~ent CDBG CAC mernbe~5hip plan includes eiqht slots
reserved for members of community nonprofit organizations
oriented toward the goals of the COBG Plan. Thi~ can foster a
perceived conflict of interest ~hen the CAC membe~ is on the
board of directors of an agency applying for CDBG Cundin9.
Although the City's practice has been to require CAe members to
declare their agency affiliation l a~d refrain t~om voting on
proposal& from their agency, the conflict of interest is not
necessarily avoided.
The Political Refo~~ Act would prohibit a paid e=ployee ~f an
agency that is applyinq for funds from participating in any
committee process that would affect the agency_ However~ the Act
would not similarly apply to an unpaid board member of that
agency. However, HUD conflict of interest regulations indicate
that, under certain circumstances, board membership might
constitute a conflict of interest, e'\~en though no personal
monetary gain is involved. HOD has been unable to identify clear
conflict of interest criteria: although HUD regulations do
provide for a case-by-case waiYer process. Nonetheless I the
purpose of the conflict of interest provisions is to protect the
reputation of the program from even the appearance of providing
special treatment or servinq special interests. It is the
opinion of s~aff that the program would be best served if board
members of agencies applying forI or receivinq, CDBG funding were
prohibited from serving on the CDBG Citizens Advisory Committee.
RlI.'X>MMIlIDMIOJfS
Staff recommends that the COUncil approve the attached draft
Community Oevelopm~nt Plan for Fiscal Year 1994/95 and the
attached draft Citizen Participation Plan for the Community
~velopment Block Grant Program.
Respectfully submitted~
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CDBGUoordinator
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Assistant city Manager
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KENNETH R. SCHREIBER ;8 ..
Director of Planning and
Community Environment
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At-cachments; 1 -CUrrent Community Development Pl~n
2 -CUr~ent Citizen participation Plan
3 -1994/95 COBG Time1ine
" -Nev Draft Community Development Plan
5 -New Dratt citizen PartIcipation Plan
6 -Position Statement dated 11/S/93 from Citizens
Advisory Committee
7 -Opinion letter dated 12/8/93 from Palo Alto
Housi.nq Corporation
CC: CDBG Citizens Advisory Committee
CHR:623:93
12/9/93
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[XHiEIT A
,ALO ALTO COMMU~lTY DrYELO?!;ENT BLoer-GRA~'l' PLAN-NEEDS,
STRATEGIES A~O rUNDIHG GOAlS AND PROPOSAl SELECTION CRITERIA
1985-1988
\n1roduttlon
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Ttle COlIIIJnl t)' Devejopment Block STU!:'t (CDeG) PrDgr.m 15 enuring into I neW'
thret~ear phase of ~~! federal program. Over the list ten y!ar5 of th~
,ro~.m. PI'O ~lto ~I$ be~n ."Qcated apprcx1~te'y $6~1 ~"l;Qn for heus'"g
aTl.d CQP.UW!'.fty deve'QP~nt 9rojeC.ls direetly befil!fi t{!"'9 iC)olr: .~d md:e.r&te 1ncor:oe
persons fsee Tlble J). Fer the 1~84-a5 Progtam Year Palo Alto received
.$611.000, although t11h If''lfel of fl.tl'ldfng cOoU1d be red'uceC' fn tile future.
Annual'y. the tft} rec!1ves 10~lS propOSAls fgr f~~ding b~t tnt! level is
"JtXeu~ to (",creue in the b!Jot ft'tl' ye .. ,.5o. lfo,t coar, Progrlm has p!"o~~\1ed
funds. to fncrease the lupply of Iffo~dable ~cusing. fmprove the (on~ft;on of
tJ:fsttng PloU'sfng. reduce the tf've-l of :.::Iiscrfm1n,atfon fn hou.sfng. ,nd conHrur;:t
Ind 1r.prove community ftcJl1t1es fgr bl~d1clpped/dis6bl!d per5cns. senior
<:1t1uns. and' others, Thrcl.:gh th~ S.1.:?pcrt fc.r these proSects find. nT'Y{ces the
tVeG progra~ ~ •• Improved the qualfty of life for p.rsons Tlvlng .,d wor<lng !n
P,T. Alto,
n. PT,.
Tft. purpoo. Of till> ~l •• Is to "provld •• fr._ort for t~. Cftfzen's Alfvlsory
,t .... hue, Stiff, •• ~ Clf¥ Cou.dl 10 ... Uo; 'u.dl.g Teeo_.datl,n, I.d
. 'deth!o •• o. CD5G projett. o .. r the nut thr •• program y.an U9SS-86. ·~9S6-S7.
1987-88). The pl.n estabTlsh •• I funding .TTocltlon go.' of 801 for housl'g
related acthftfel .. 15S fer cosnmun1ty (Jcf lftfe.s ."d fmpr-ovements. Ind 5: for
Umlnlstr.tlon. An .d~ltlon.l ,II1"POSO of the Pl •• Is to serve 15 I guide to
pr~.p'ttl ... pplft •• ts In ,,'ettlng projetts .nd preparing pro~o •• 's.
The PTo. Is 4fvlded Into two prllllry Stotlo .. , S.ction On. nt, fortll tile
.jol"' hOlJsing Il"Id eor.rnunfty development PlUds in Palo llto that ~n N
.Gd.ressed by the tOSG Program.. Att",th"Tlt 1 lilts ti! SO\l'T"ces of infoT'rrat~!)!":
used 1ft establishIng the t'luds.. S~eeH1' .stntfg1u ITt sug.gested: to lddress
oleh .e.d. T~is Sectlo" "'0 .'tab'I.~., I fundfng goaT for the .. f.
eategcrf.,. The ~l.n pTaee. e~hl.i. on fundi'g project. diretted toolrd the
hou:lfng needs Df low and llOik'r.te tn:olllf' ptT'SOr'lS lhbg in P-a'o A.Ha. 'S!ct1on
~ conta.ins • set af crfUd. to be "std In w1ecUng propouts 101' fur:;Ij'\f\g~
SECTION DJI[
~'d" Stutes I ... end funding Goa"
Dwrln9 the ffrst ten , •• rs .f the COSG 'rogra., hou,I'g hi' btln the top
prl~l~ for fundl.g. Allocltlo •• for housIng related projetts In,'ude nous!ns
supply .. 'J"eh&MHtaticn .. d1scdl\{nlUOi\. aftd' e1lle'l"'gency I\ousir,g (see TI.b1e 1) ..
Of the $5.1 III IIfDll of CDSG funlls .110,.t.od to the prog ... ""rfng the first ten
,.tlrS, lS.l .,llIl.n or 87S, ~as been 11l.Clttd to hou,'ng rel.ted projecU. In
the ten yt4rs of the program .. ~e amount of '~~ds .1lo'lte~ te Housing has
wori~d fro. HS ~. lOO~.
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ATTACHMENT 1
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Ttlts tlfg?1 leve1 of call'lmiu.ent t., housfng should contfnue-. The re-c:rnt1y adopted
1'85-2000 ~ous1ng Eielent of the 'alo Alto Co~rthens~v~ Ptan ernp~i$1zes the
crfticl' flousing problfTns .~ ~e City. Two of the major objectfves fr,chided in
the HOl,lsing Element are to .fnUh I cJhersity of housir.:g DPpor-tlJr;1ties; in
Pile Alto .~d to 1nere'$~ the s~~ply af housln9. especfllly f~r persons of low
and moderate f~come. Th~s e~halis is cQnsistent with ~e nte~s fdentifled by
t~e Hu~n Re11tions CD~'SS'O~ fn .e~f"g t~tfr reto~~d.tiDnJ for Human
Strv1ce run'dfng~ Th·ut!" needs identify .sup~ort nrllfcrs to sfn91e-partnt
tlDU;seh0'1ds .. SlJ!,port nrvfc!'s to t"e diJlb1ed~ arid :'lousfng srrvftes to hm1 Hes~ .s the a-fg"'ut priority needs .. The Dtpar'tment Of HOl.uing and Urbu~ Deve-'o?TTI!nt
(HUD). ttlt Stit-e Department Qf Kcusfng to,nd' c.o~nfty [)e\lelopment. and the
AssochUDn of B~y Area Govo!rnments 'ABAG). each flln corrr.:-ended the CHy on its
h'3~ 1e~el of CDBG co~ftment to bQlJsing And ~ncauriged the City to (~~tinije
th f.s cOInttUmen"L
The .eecn~ priority for funding Is for c01!llllJ,ltl-.rlde f.clllties a.d
t~rovemrnts.. Durfng th~ first ~n years of tht program. oyer $641,000 ~as
bt'el'l 111ocatt" tD th!.s category .. whh:h is Ia of V1e tau' .11ocltilJr. (se~
Tlbl. II. Typloal communlty .. ld. flcllitles and Improv.ments Include
constructfon or rehabfTftatton or bufldinss proYf~ing servftes for
tlafldfCl'Ppea/cf'fsabled persons Ind .senior Citizens. Tbere h I contfnu1ng F!eed
to I;uht community organintions in Nking capitel 1lffTo'itlT'ltnts to t"'eir
flcflltl... This need Is .spe,lall, fmportlnt with respect t. p.!. Alto's
s,nlor populatl.n, physlc.,1y .nd/o, de,.lopmentilly dl.'bled pop,latlon, and
chSld care elfg~b1e popu1atfon~ An fncrfas~ f~ P.10 A'to's Senior pop~lltior.
and fe .. l~ h.ad-of-ho,.ehold pop.l.tlon from 1970-19BO .a. Id.ntified Ir. l~eO
U.S. Census dati.
TIle flntl <ot.gor1 of f.n4ln9 Is fO" the Il1ml.ht,..tlon of the progr.m.·.
AlSminhtrithm funds haYt!' bun al1otltl!'d fer the last three-years. Ind tllVe
.~rlg.d 3S ($21,900) of tile toUl ollocatlon for elC~ of tho •• ye .... Tht"
funds are un!! to 'P'an for an;:! tmplen!!nt the progrJ.m.
~ ~"! .. l ... ,nt of funds ooy hl.e to be set .side .ut of tho toUI .110Cltion
for the tDBG Cont1n9!'ncy aCCDunt if the U:fst1ng a'count becomes dep1tted~
This UDunt .. at the •• 1ft.1m. would be 3-51 of the CDBii .11iOcation ..
Fundln! GOlh
The Jllarr e5taDlhhfl goal$ fOT .11DcaHr.9 eOeG funds a~t)!'1g the t."rt'!' Nfn
categorfes. The f&:ndf:"lg 90a 15 are not ~nte"ded to be rigid, but ratne-r strv~ .s gold.,ln ••• onsl'tent with the .. ed. Th. funding goals ore:
lOS of COSG AIle cation
151 of CD8G ~l'octlon
51 .f CDBG AlloCltlon
Outlln.d below are t.~ •• poclffc n .. ds, follow.d by the strat.gl •• of til. thr ••
afn utegorSts. ttle Indivfdual need tlt.@gGrfe.s aroe ~ in any orlSer or
prl ... lty.
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J. HOUSING (Allocotlon 'o.~: 80S of CDBG All.ottlo' l
Housing Surp~:t
Increase th~ num,er Df housing alnits Iffordl!~1t' to 1tN and ICder.att fn;:or:-e
persons. 'nc1udfn51 renu1 units for f&~~lfes, .seniDr <:fUzel'ls. and'
~"dle.ppodfdl •• bl.d por.ons.
1. Aequ!r. ,ultabl. parr.1s through I.ndbanklng.
2. Site fmprDvements f~r Issisted housing.
3. ACQufr~ hous1n3 to be rented te low end moderate fncome ptrsons,
4. $uppcrt housing d~velopment corpcrltfDns Ind Dt~er Drganizations
workfn9 towar4 the provhfan of Iffol"d.ableo housing.
~Dus;ng Rehabf1ftation 5ervfces I Ff"a~cf"s ~ ~ner Occupitd
As,lst I ... r Ineoce ho •• ohold. in ... tlng tho ~Igh eo.t of rohabjlit,tlon
ftJ'\ln.cfng wbfc:h limfts thefr Ibtlfty to make nec.uury Plome f~ro~ement.s
.nd repairs without f1nanc181 15s~staMe!. There is a JPecfal need to
ISSlst senior c~tfle"S and sing1e-PBrent home~ners wftn rehabf11tatfon
I.ryl ••• Ind flnonelng.
1. ProvIde b.low"ftOrkot-rlto ~o .... habllitatlon flnanc!ng to low an~
IIOderate fnc:ome ftCH!IeOWner.s.
2. Proyld. h_ rehabilftatlon servf ... to low Ind .. derate Incolre
hDllltowne-rl ..
Housing Rehlbllitatlon So"le .. I Finonc!ng -MultI -rl"l1y Housing.
Asffst SPO!!1sor.s Df nOri""Profft Ind subs1cHzed rental t'lous!n,g r1e~'op!'!l!nts
fOT' low Ind mdeTlte fneo'lDe' per.sDns w1th ftfeUSIT1 IfII!.tnttnanCf and repafr
costs that eannot be relsonably paid for out of their or.-golng budget.
P.I. Alto .urrently has ovor ~OO ".!sted housln. unIts.
1. Pro,lde below-.ork.t-rlte fl",nclng or grants for f.~abllltation.
repair, or improvement of existing ~'tf-f~mfly rentel housfng for To~
and ~~rate fncQme per.son5.
Z. ProvIde r.habilitatlon .0r.I,0. to ollgf~l. low and ""der,to fncooe
housing deyelop.nts.
Houstng DiSerrmfnatfon Ind Other FfDu:s1ns ~ry'c-t's
Redwce ~ elfDrlnett dfJerfminatfon 'n hous1ng bast'd on race. rrlfgfon.
MI. f.mfT) size. and status. disab111tfes. age or an)' other arbitnry
flctor .. [due.tiDn progrllllS. coun.seUng. referra1, and legal us.fsUif:!ce
ler~ftr$ Ire nee~sslr1.
1. fund flfr ~ousfn9 services which ISI'5t persons w~o ~'vt t~eri~ncrd
dlserlmlnatlon 'n bouslng.
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z. FUnd hous!ns progr.~s providing t~"lnt/l.ndlo~d ."~ ~ous1ng se~vices
to ptrsonJ exp~r1fntrng hO~51ns confl{cts.
[~r'f"ey HouS'"9 Acgufsftfon Ind I!proytment
As"st sponsors of temporl{Y or fnterfm ~ousfng flcilftfes .frvfng ~f
~eds of l~ .~d ~derlte fncome battered persons, eistrtssed juv!ntles.
fIIn(1ftlpped!~f.u:b'ed per-sons, a.nd ot~ers se~l(fng • variety of
tndhfdulT5.
J. Fund 'wuefn an:! organfntfons-leeifnS' to e.cqu~rt! rmergency tlcuSfMg
fa'flltles.
2. PrDvide bt-low-mar-iet..,..tt! ffnandng or grants fOf' rehab1Htatiofl ()f
~me.gency hoUSfn9.
3. Proylde .eh.bllftatlor. •• r.fco, to .1fglbl. emergency housIng
prOjeots.
4. Irov!df relocation .s1Jstlnte to ~er$ons dfsplaced from nousfng~
II. Co!1MU~ln-WID!: FACILITIES' IMPROVEMH'lS IAlloCltl., Soil: 15S of CnBG
AllacaHon )
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F.,flftles for the H.ndl,.pped/DI.abl.d Por.ons
Incr ••• e the ."esslbfllty of f.,11ities .erylng ~.nd!,.pp.d/dl •• b'.d
persons, ill £:lOth pLoiblic-and prhab de-\"eTopments. Additionally, Itsfst
""gl.lutlon. In proyfdlng n .... or 1"9ro .. d f.<flftle. to 10'" tile .
spe,fflc ~eds of the h.ndlClpped/dis.bled popu,.tlon fn the communIty.
1. Provide funds to .emo •• archItectural barriers from buildings Ino
.. Jor fnteroeetlan. throughout the Cfty.
2. Prorillo funds to Ifd 10 tile construction or ocquhit! •• of f.:llltl ..
• eryfng h.ndft.pp.d/df,.~led persons.
3. Provfde btlow-rerht-rate ffnan::fng Dr grants to fllp~o¥1! e~istffl9
fa,illtles .eryfng h.ndicapped/disabled per.ons.
4. ProYlllo r.h.bllfuUon serylces to ellglbl. f"flftles •• rYlng
hlndlc.ppod/dls.bled p •• ,ons.
Child Core r,cllitfe.
Assist ~n-prDfft Ind c:o:rIIUnfty based organfZlt1ons fn Jlrovfding adeQulte
chIld care f"llltf •• ser.lng l .. er-inc.me fomlll.,.
1. Provfde funds for ~~ constr~ctfon or ICQuisftfon of chfld Clr~
flcflities 'rrY1n~ low and wodere.te fncome persons.
2. Pro¥fd~ below-.arket""Tlte f1nlntfn~ or' grants to iqlro~ eJlihting
,hl1~ Ur. hcl11tlts.
3. Proyfde •• h.MlftBtlon ... y!, .. to eH,fbl. child Clro facilities.
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Ill. Adm!nlstratlon (Allo,allon Goal: 51 of COBG Alloc.llon)
Provfd!! ftf'ceuar~ funds to PloY fer planning InC' f~'eme1'1tatfon of the CDS:
Frogrlffl, Ind to' Pt.1 for necuury cnrhud cests.
SECTION TWO
Propo,., S.lectlon Crftorla
Propouls fOr" CDSG funding are IfYI'ulted Ic(ordff'l_Q to 'ttl! following seot of
erltorh. la,h of tile flnt five He"" Ire not welghled or prioritized,
although Item 1 ~st ffrst bt satisfied before-further prop~$el revfew. The
last cr1terfl is In oyerall evaluation to determine If the rtco~nded pro~ra~
•• tl.fl •• til ••• tablished funding go.' ••
1. Propo •• , ElIgibilIty
The proposal ~st be eligible according to federal regulations established
for the CDIG program (Staff Ind Pep!. of ~o".lng , Urban D.v.lopment
eIechlon'.
2. Meed Yerlflcatlon
There should ~ rel11blt dati that Yfrfffes tne need for the project or
Icthl ~ proposed.
3. reaslblllty
ne applicant IIIst hl.e the tlpablllty to 1~le""M t~. project .,..
Icth1ty fn I t1M1!!ly II'IIInner .... it" the Infhble rtSourt!'S~ .
4. Cost/Ben,flt Analysl.
Ther •• Muld be evidence tIlat the f",l<t upon Identified need of til.
projett or Ictfyl~ "",stlfl .. the pDtontlll eost fn<urre~.
5. LonQ~xlnge Fun~fn9 [~'ftatfons
TtJerl!' 5~Oou'd be fnforNtfDn .vallablt w""c:h fndiclu.s t1'Ie long-rarlge
impl1'Btfcns Df f~ndfn9 • n~ Icthfty or hc:reasff'llS' the ltvel of funding
far In •• I.tfn, letl.'ty.
6. Ov!ral' Program £¥.1~lt1Dn
The reco~nded CDBG !>r~gr.m stuliJld Deet t!'le esUbHshed nl?eds and fundi";
8Dlls included fn the lilted,. Strlt!gies end Funding GoaTs Sfctfon of tt1fs
plan.
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IntrDduction
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EkHIBIT B
to_~ITT Dl:VElOPHEWT BLOCK GR~NT PROGU",
CITIZEN PAATICIPATION 'LAN
A ,r1~~ aspect cf the Housing and CDmmun1ty Development Act, IS ~Qu1red by
2. era '"rt 570. Sub-part D, SectIon 570.303, Is the provi.lo, of Idequate
opport~1'11ty fOT cfUzens. pertfi:ularly these whCl w111 be 'ffreud by the
prD:grl.!II. 'to pnHeipate fn In adviso!'), ro1e in ph.1"!n1ng. 11f'1~'e~r'ltfn9. u d
.s!~ssfng the program. On August 23. 197i, the City CQuncil adopted t citiZen
partIcIpation co~one"t con,istin; of • permanent efty..,.ide cemmltte •• "e~
wil1 be advisory to the otaff In fulfilling the citizen partlclpatlor.
r"t'Qu11""t'Ents. CfUnn fnyol .. t'ment will apply to preserlt IS well as future
.c:thftfes~ All aspects lOr the C~tfzen Part~c1pufon Plan .,n1 be ope!'"1 to the
gener&1 p~b'1c. The Citfzens' ~dvfsDry Committe~ will revf~ the C~tilen
Plrtlclpatlon Plln with input from the gener.l public. The '1," .111 be
.pdlte~ .s needed.
D.joetl ••• of the ?lln
1. To involve cftil~n5 fn the p1annfng. fmplementing and assessing ~f the
program b'j enc.oU'ra~fnSi the $ubmi.ss~or. of IIfe'lis and proposals.
2. To fnc1ude low and I'IOder.ate income ~trsons. ftmbers of "'nor-ity grotJpsa
res!dents of areas where funds will bt spent. the e1der1Yi the
hand1'lp~td. the ~sfness commu~1ty Ind c~v~c groups within the citiZen
particfpation p1an~
3. To Bite hforl8tioll about the tOImlU:1it,y Development programs anilable.
4. To provide technfca1 assistance suc~ IS socfl' and demogrlp~ic data, cost
estfmates and lOCI' ordinance fnfor~tfon to ~ighbcThood g~oups and
orglnlzatlon" SO that thoy may participate In the program ~roe.s ••
C""'Po~nts .f the Plan
1. The Housfng and Co~nity Dewelop~~nt C1tizens' AdvfsoTl Co~1ttee
a. Member'~ip: The Houstng and Community Dtve'opme~t Cittzens' ~dvfsory
CDImI!tte-e-h Idvhory to lUff. tach Rmber's tenure on tt,e tom1ttee
is for ~o ),el.r5. Members .. y serve IIOre than or.e tent.. T!\e
Conmittee has fffteen wr~r51 fncluding nine .embers from agencies
w'tlo represe-nt persons of low an~ I'IOderate fncorne. IJe'mbers of ~inorfty
fTDUPS. the elderly. handic.appe-I! and tUJsfntu community. Eigl"lt of the
nr",e agency llembers w111 be appofftted by the M,eyor f",om nomfnations
.. de by In)' cOlTlTlunfty fton-profit crg,e:nfntion.s or1t~ted toward tnt
10110 of the COBG Phn. Tile nlnt~ "gency ftmber wIll be •
representative of the HUN" Relat10ns Co.'IIIII1$s1ofl ..
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ATTACHMENT 2
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SI ..... ber. fro .. tM leneral pubHc .111 be .ppolnted by t'" nln.
agency .. 1tI!'rs.
b, Function.: T~ Committe, will ••• I.t in the IdentIfication of
((lllCUn1ty deyt~oPftnt .n4 !'!Ioustng ne-eds afld the setting of pr1or-Hiu.
T~'y will be Involved In do •• loplng the thre. ye.r Community
DevelopPlent Plan. the Artnua 1 COllmlLlnfty D~ytlcprT)f!nt 'lIn, tn! HcusfnS
AssfJtlrte~ Pll"~ Ind pro9~.mmfng of f~nds and lmen~~nts to the p1an.
T~ thfs end. t~ Committee wi'1 s011:1t Ind eva1u!t! proposals to be
submitted tD the Planning Oeporbnont.
The Committe. wi" ha.e .n Idvlsory rol. 'n the Impl.mentatlon of the
pro!;rlm bj' .tUng as I c:cmduit to further define tftfle~ Meds and
retommend~ng project crfterfl. Th!y will 11s~ have an I~~fscry ~ole
h policy dechfons regard''trI9 pl"'ogralf", imp1ementatforJ. Ttl! Comr::ittee
will ...... projects and .ctlvIU .. tD determine If the objoct; ... of
the CC1mlur.fty De'rf!:loplEnt Phn Ire-befng _t. In 1d'd'Hfon. Cor:n:ittee
~~rs wtll be informed of f~le~~tat1on Itrttegies and the pr~g~ess
of ph ... d Itt~.ft! ...
'rocess: The Committe! will ho1d per10dic ~eting5 to carry out the
above f~."ctiofls.. Thl!'st IlDeUfr.gs win be field in JI:n~er.r. Frbruary ..
1.4 "arch, sene.ally fn City Nill. Info.matloo on the CDIlIbUnfty
De.elopment Bloot Grar,t PrDgra .. will be ••• nlble It tM .... ting'.
The se .. r.1 public, neighborhood gToup, •• 4 ~rl •• t' .g.n<ie. will bE
encouraged to lub~1t th~fr vfews. comments. and project proposals to
the Co ... lttee •. Tile ... Ung' wOI be ope. tD the pubHc. All
.pplfclnts submitting ~elr prope •• ls will be on<0"rlg04 to Itteo4 the
IIHUng It w~fch their ~r.po .. l " tD be re.l,w.4 by the Co""lttee.
During tM .pplicltlo. d ... lopmtnt Stl!l" of the pro;r.m, sptclal
~ot1ce. of the 8eet1ngs will be -adt fn ~~ 'en1nsu1a Timts Trlb~ne
.. 4 other approprllte 1 ... 1 pu~1fcatfon"
111 reco~fldatfons. co~nts. assessaents .nd propoSl1J fro~ the
Committee w;ll be recorded and f.rwlrded to the City Counell for theIr
~ey~ew. The Conmfttee will a1d fn ~t 6fssemfnltfon Df fnrornatf~n
lbe"t the Blott Gr.nt Program Ind will lid In soliCiting comoent5 and
.Iow. from the gonor.l public.
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Z. City touncll
I. The C.ty Ca~nc11 Stts pol1ey; prfor1tfts. and approves the o~erl'l
to-.J'Ift,V lJe~eloPllent Block Granl Prcgl""llIl ..
b. T~ Cit1 Council will hold two public ~.rl.gs prior to t~e
.ub~Is.lon of the application to KUD. After t~ CommittE' and
C1ty sufr han I"i!'VfN!'d' proposais &l'Id mde tilefr recol!'R'T'ld~tiOris
to the CIty touncll, two public he. ring' will be held, 0 .. before
the finance-and Public Works Cormlfttee and the second bt!oforr ti1e
full City CouncIl. The public he.rlng. will be h.ld to obtain
views fro~ cftilens on the"performa"Cf of the pr03rem and to
obtain yfews on Ue proposed program for the comfng: year.
c. T~e Cfty Coun~~l wtll .ll~ hold ont publfc hearing thirty to sixty
d!ys prior to tlI-e start cf ~'an~fn9 fo~ the nelt yea,.'s program ii1
order to review the program s performance and ~rogre$S.
d. ~ction. of tho City Council will dIrect th. hpl .... ntatlon of CDeG
projects.
3. General 'ubllc
I. T~e gtr~rll public .. y pa~tfciplte in the V1~rOU5 stages of th!
progl"'lll by Ittendfng the tithens· Advis'Or, C.olNt.ittee !nettings an-d
tho tlty touncl1 public bearIngs. They can .1.0 upr ... th.l r
\'f ... an~ co_otl dlrftt1y to the 'l,""Ing Itlff. At In;. tI ...
citizens lay submit yiews ccnc~rr.f~g ~a'o Alto's performance f~
the progr •• to the HUO Ar •• Office, 450 Golden G.to A,.nuf. Bo.
36003, ~;nth Floor, San fr,nclsco tA S41D2. CItl,e ... can ••• il
~er~e've5 of the Commanity Oevelopme~t infDr~tfon 1n the
Planning D~pl~tment. 5th Floor. City Hill, 250 H~rnilto~ lveMue~
'.10 Alto CA 94301.
4. City Staff Report
I. The Dtpartment af '11nnin9 and Co~~1ty Enyfrcnment ~IS primery
respD"s1b~11~ fer the administratIon and coordination of the
to"""nfty D ... lopment Block Grant Pr.gram.
b. Th! PTannfn; staff" respDns1b1e for Claily "~iTif!"ifstration Indlor
< •• rdin.tlon of the progrlm. (329-Z170 or 329-2441)
c. At the beginnIng of tho planning process for the p.-.gr ... tho
Pl.nnlng .taff .. 111 provld. t~. Cltlle." Ad,h.ry Comrnft~. ,.d
the gen •• al public _fth the follow1ng Ir,fof""tlo": ~be tol.ol
amount of block. grant flJnds IVli lable. the range of Icthitiu
t..Iojat MY be undert.'ken. the-prrvfous1y fun6rd .cthfU~s. the
process that wIll be f.llowed In dr •• lng up Ind approving the
local applfcltfon. thf schedule of aeetfngs .n~ helrin9S. thE role
of the dtfz~n' fn the-progralll and I SUlMII!ry of other program
rtQuirearaerliu.
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Th! Thre~·Yelr Ind Annual CneG program will 11so be publfc,zed 6~d
dhtr1bLlt.ed. Proposed lett "Hies wi t1 be descrlbed 1n .suffi C1tr::t
~tlt1. hH:lucHng loc.ltforl. t'O .nol( c:1tf:ens to det!r~fne tI'1e
""gr .. I:<> which they Ny be aHoottd. Cftl"., will Iho be
pfo¥fded inforlMtion on the prcposed ImOUr'lt of funds to be tlse.d
fo ... aetfrlUes beneffting low and lIOd'erau rn~O!!e persons t Ind t
plan for ~fnfmflrng d1spl&cement of per50n.s Ind Issfstfng
th.s. displaced.
Tht Planning staff will Nlntaln tho Citizen Partlcfpatlon Plan.
t~ prcpond and apprD'Vl!'d appHcatfon and' t~e .nn~a' performance
report fn addition to the program recDrds~ dotu~~t$ .~d other
1nfoTlNlt1cTl Cu requfrfd by federal regulatfons) within the
Plannfng Dep2rtme~t for pub1fc ~few during normal working ho~r5
{w2'ei:da.1s 8 ".In. -5 p.lI. J .. These dotLNnef'lts fndude co~tl"'ac:ti11g
p,-oee-duru .. t'nvironmental policies. flir ~ousfl'1g Ind ot~tr equal
oppor"ti.lnit,y re-quire1lleT'kt.s .. Ind relocaHon provisions.
•• Technical Issistance wi11 ,150 be prov1ded by the staff to cftize~
trOUps Ind ,,""oups of 10.' Ind irJOaeratt fncoTne and rleignbol"hood
g'f'oups nquesting such Isshune!' JO tnlt they 1M)' I~Quate'Y
partfcipate frl tht 'llnning. S~1ementf~3 In~ asseising of the
pre9"01I. Pro." .. Inforlllltlon wIll be pr.yl4ed In .11 assisted
housing devt'opme~ts .. T!efghbol'flood' serv'fc! eenter.s and other
public flcH1tfes wflere rts16ents can It'lrn Of such programs.
f. The stiff win solicit parHe1p-ation from groups ",",,0 al"! conc!rned
wft~, the prOir-,1II and .Y prov1de 1nforNt1on fn I b-{lfngual
fashion w~en!ver , 5finfffC&~t number of residents do not speat
EogllJh a. theIr prl ... y languige.
,. Perlodl eo11y, r.port •• fll be pre'tnted to tM Cftfuns' Advlsery
Ccmmltt •• IS to the pr.gre,s of .. ,h p'ej,ct Ind Ictlvlty to
ac,e.s if objectl ••• Ire beIng Ichl ... d. Cltfz.ns wIll be
~neour.g!d to Jubmit Yirws In~ comments coneer~fng the p~og~am.
All _few. Ind prepo •• ls wIll be fon..rded to tho Cftlztos'
Adrisory Co.."ltt... M!n"t ... f t~elr .. ,tlngs will be sent to .11
appTiunts fn addft10n to • sepa.rate response tdcfressfng specific.
propon" submitted ty Ippllcants.
h. Th. staff shall rtcef .. all complaints c.ncernlng the p.og"a~,
.ate-I wr1tte-n response to .1 l correspondeflts within fifte!'n
woTtIng dlYs, and rellY <oopllints and rt.pons., to the Committee
at tilt M'J:t _toting.
f. Th. stoff .111 schtdul •• 11 req"fred pub1f, hurl.gs and arrange
for the CIUu.,· Ad.hory C .... ltt ..... Ur.g.. ~otlce of the
tI .... pllce and age''''' of the public htorfngs will be .. de teo
41Y.s prior tc tht ~nrfnSl and will be fn the non--lega' Itcticr; of
the Peninsull Times-Tribune. J~ addftfon~ I sc~e~ule of leeti~9s
of the (ftlzeo,' Ad,!sor} fo"",ftt." will be ,"blfshtd in the
non-hi'" section Df tile Perdn.su1a Times.-Tr1b!.irl! lit 'toast ten (]O)
dlYs prf.r to the ftrst .. etlng. Rec.rd. of .11 public hearings
Art tept fn the-Plann1ng Deplrtllrnt» 5th Fl()or. Chic ttnter. 250
fll~f1!.Dn honut. Pal. All:<> CA 9.4301.
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.(-<->_",",,'F
COMMUNIT\' DEVELOPMENT BLOCK GRANT (CDBG)
PR()(;R. •• M YEAR TlMEUNE
June 30, 1993
iuly 1, 1993
August IS, 1993
August 24, 1993
August/Sept 1993
Sept=ber 30, 1993
October 4, 1993
October 12, 1993
Ocwber 19, 1993
Ocwber 27, 1993
November 4, 1993
November IS, 1993
November 15, 1993
December 13, 1993
Detetnber 31, 1993
JamJ&ry 15, 1994
Febmary 4, 1994
P:\CDSG\Timeli~e
1992193 Program Year Ends
1993194 Program Y o.r Begins
1992/93 Year-·End Progress Reports Due from Agencies
Public Meeting -CRAS Needs Assessment
Monitor Agencies for 1992/93 Program Year
1992193 Grantee PerfoimallCe Report (GPR) Due to HUD
Semi Annual Labor Standards Enforcement Report Due to HUD
Minority Business Enterprise (MBE) Report Due to HUD
Public Meeting -!!uman Reiations Commis.. .. ion Community
Needs Hearing
Public llearing -Plllnning Commission reviews ClIAS
Public Meeting -Citizens~ Advisory Committee reviews CHAS
and Community Development PI,n
Request for Proposals (RFP's) MaDe<! to Agencies for 1994195
Funding
Public Hearing -City Council Reviews eliAS,
Public Hearing -City Coone;; Reviews Community
Develvpmcm Plan, Citizen Participation Plan, Progress Report
CHAS Due to H1Jl)
Semi-Annual Performance Reports Due from Agencies for July
I -December 31, 1993
RFP' s Due from Agencies for 1994/95 Funding
ATTACHMENT 3
JIlI1lliIIY IFebruary!
March, 1994
M.'ll'Cb 25, 1994
April 6, 1994
April 8,1994
April 13. 1994
M.y 16. 1994
May 31, 1994
June 15, 1994
June 20, 1994
June 30. 1994
July 1. 1994
P: \CDBG\TilT'tal!.ne
Citizen Advisory Conuniti« Process:
RecruiVSelecVTr.in DeW CAC Members;
!-Iold Public Meeting5J to di'iCllSS applicatiQilS; interview
applicam agencies; and recommend ! 994/95 funding allocation.~
(0 City Council
CAC Funding AlIoc.tion Report Due
Semi-Annual Labor Standards Enforcement Report Due to HllD
Minority Bl:siness Enterprise (MBE) Repon Due D HllD
Public Hearing -Finance Committee considers CDOO Funding
Allocations for 1994195
Public Hearing -City Council authorizes CDBG Funding
allocations for 1994/95
Final Statement Due to HUD for 1994195
Program Year cx:pendrrures
Sbort Fonn Agency ccntracts finalized and sent 10 Gty Manager
for sigr..awre
Long Form Agency C<lntraclS to Council for Approv.1
1993194 Program Year Ends
1994195 Program year Begins
cm' OF PALO ALTO
COMMUNITY DEVELOPMENT PLAN
1994 -1995
Prepared By
Dep..rnnent or Planning & Community Environment
November, 1993
ATTACHMENT 4
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TABLE OF COI'ITEIIo'TS
O· ... el"view of the Community [)e\relopment Block
Grant Program
Purpose of the Community Development Plan
Relationship to Other Pl am and Report...s .
Comprehensive Housing Affordabiliry Strategy
(elIAS) .... . ........ _ ..
Citizen Participation Plan . .
Grantee Performance Report (GPR)
National Objectives of tire CDOO Program
Overall Program Benefit Rule
Local Needs, Priorities and Objective. ..._
Community Developmelll Needs Eligible For CDBG
Funding __ __ _ __ __ _ .. __ ..
COOO Fuudir>.g Priorities For Fts<:.1 Year 1994 -1995
Project Selettion Criteria . . . . . .
Community Development Objectives -Fiscal
Year 1994 -1995 . _ . _ ..
Attachment 1: Summary of Eligible Activities Under
the CDBG Progra,-'n
Attachment 2: Sununary of Community Development Needs
AtUclunent 3: Summary of COOO Funding Priorities
Attachment 4: CDEG Project Evaluation Criteria
"' ;r
CITY OF' PALO ALTO
COMMl'NITY DEVELOPME]I;, PLA" 1994 -1995
Overview of tbe ConununI1v [)e-,'elopment Block GranLPto~
DRAFr ll':4/93
The Communlty Development Block Gram (CDBG) Progra.-n was estabtished by Congress as
Title I of the HOlJsing and Community Development Act of 1974. The primary purpose of
tb; Act is the "development of 'fiab Ie urban communities by providing decent housing
and a suitable living ennrODmE:Dt and e.'\':panding economic (Jpportunities, .ruindpaIb:.Jqr
perrg!ns of' low and moderat~ ir!g;)_!!l~"'. The City of Palo ~o\1to h4.5 partic ipared in the
eDEG program as an "entitlement" grantee siTh::e 1974, the f.rst )'ear of the program. Since
1974. Palo AitO has received over Sll,500,CXXJ in federal COBG funds:.
The CiIy's annual grant varies from year 10 year depending on the number of panicipating
cmnmunitjes nationwide and the total amount appropriated for [he progra.'1l by Congress.
1be City allocates iti CDBG funds in an annual budget based on a fiscal year beginning July
L For the fLocal year (FY) 93-~, the total grant from HUD was $700,000, In addition.
program mc{)me received in FY 92-93, as a result of CDBG loans and notes, was .$281,512.
~ of the Community Development Plan
The Community Development Plan is designed to meet the requiremtnt in the federal
regulations for &.e Community De'r'elopment Block Grant (CDBG) program that panicipating
communities develop and suhmit to HUD a plan descnoing non-hOUSing community
devtlopment needs and objectives ro meet tbese needs,1 The Palo Alto Community
Development Plan covers the one year period coinciding with L'Ie City of Palo Alto~s annual
CDBG budg~. It will be updated each year as necessary to reflect cilanges in the City's
ccrnmunity deve10pment needs or objec:ives. In order to pmvide a complete picmre of the
Cicy's CDBG progrnrr., this Plan su.'"1lI!1ati7..es the City's housing needs and objectives in
addition to the commumty development new.
The Plan providf"S an overVie\~i of the goals, priorities and objectives of the City of Palo
Alto'S CDBG program. Il focuses on lhe overall operation of the CDBG program. It covers
the annual grant application and budgeting process, the overall priorities for the use of
CDBG funds and the project selection criteria. The Plan de:!.Cribes the Cicy's (non-housing)
.community development needs and th.:: objectives which are aimed at meeting those Jleeds
.. ,
~ Ho!..sing and Community t1evelopment Ac:t of 1992 wr.ich am~nd~ the CD!3G regulations ;It Sec.
S-:O, 303Ii).
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~l1ring the: pla..1. year. The Plan gives in{eresred citizens and p'Ublk officials a basic
introduction and orient.1t:oD to the Ci1)"s c<Jmmunity dcvelopmem and housing program. The
Pian a1.0;.0 provides a framewllrli: for the decision maki ng process thai takes place during the'
3J1nu.a1 CDSO funding cycle, The Plan should be useful for organizations interestt::d in
applying for CDBG funds to help them determine if their project ideas ;are suitable for
funding under the CD BG program.
The Community Development Plan shall be reviewed and updated J!. needed and when
required by HUD.
ReJatioruhip to~ Otber Plans opld Reoorts
C2.IDJLrehen.$ive Housing Affonhb[lity Stral.egv (CHAS)
The CHAS focuses on Palo Alto's lower income hotLSin,g needs and specific strategies and
fuoding pllDS to med those needs. The CHAS is also required by federal regulation.c; in
order for the City to receive CDBG funds and other housing subsidies. Palo AIw's Annual
CHAS Plan For FY 1993 was adopted by the City Council on December 14, 1992 and
approved by HUD on February 25, 1993. A new Annual CHAS covering FY 1994 must be
prepared and submitted to HUD by December 31. 1993. Th.e new CHAS will in<:lude
amendments to the 1991-1996 CHAS which utilize 1990 Census infonnaLlon. Each year,
after the adoption of !:he five year eRAS, an annuzl one year eHAS pT an will be preparoo
and submitted to HUD. An Annual CHAS Performance Report ;s also rubmined to HUD by
December 31S! of each year.
Citiuc Part.icipation PJan
Palo AItn also has • Citizen Participation Plan for the CDBG program as required oy CDBG
regulations. That Plan describes the function and membership of (be CDBG Ci:iren
Committee (CAe), the funding cycle and project selection process, the schedule and purpose
of public hearings, public notification procedLm:s, access to infonnarion and records., a
process for responding to complaints and the program amendment process.
Gr.mtee Performance Report rGPR!
Each year, by September 30th, the City musl submit to HTJD a performance report which
describes the status of all projects und:::rway, completed or cancl!:lled during the prior fiscal
year ending June 30th. This report, called me Gra..,tee Performance Report or GPR. is
available to the public for infonnation and comment. The public may submit comments on
the GPR to the Cicy. Those comments and the City's responses are submitted to HUn with
the GPR.
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DRAFT 11/41'93
National Oblectives of th~ CDBG !'ro~am
AIl activitie5 receiving COBG funds (in whole or t..'l part) OiUst meet at least one I,)f the three
national objectives established by Congress for me CDBG program~
The three national obje(;tives are:
1. Principally Benefit Lowe: Income Persons" At kas!. 51 percent of t.lJ.e project
beneficiaries must be of lower income ~ defilY"A by HUD, or the activity must
sen .. e a geographic area where at least 51 percent of the residents are iower
income, or the activity must serve a "!imited clientele: group" as defined O}
HUD', or
3_ Meet aD \!I'gc:rJJJemergencv community need,
CDro funded acti" ... ities in Palo Alto t..a"'Ve traditionally met the fIrst national objecth'e 'Of
benefiting lower income persons and households.
Another important basic requirement of tile CDBG program !5 me overaU program benefit
rule. Over a one, two or three year period (as seleered by the City), at !.".g 70 percent of
aD activities r""';ving CDBG funds must qualify as principally benef'rting lower income
persons. Since Palo Alto has historically not funded slums and blight activities or urgent
need activities, meeting this requirement has not 'Peen a problem. TypicaUy. almost 100% of
the activities i'uJ.~ in Palo Alto meet the flISt nationa-j objet'ti ve of primarily beneftdng
lower income persons.
!&gjLNe.d& Priorities and Objectives
Witt.in the national objectives and the federal regulations on digible activities, localities are
free to deflne Iherr own community development needs, set their own priorities for funding.
and e:.'tablish tlleir o~'1llocal objectives fer the use o~ CDB(} funds. Decisions on how to
I I,imi toeod Clientel~ G.;'Q_1;IP_~ k"UD regula':.ions s:,>ecify certain gr:ou:tJ$ which are by definit.ion
cOnii.:.aered lo.-er inco~e and thus act.ivitj_!,!s which be'!t::fit. t.hose g~oups e:;cclU8l-Vely are eligible
for COSG funding without c .... vir.g to dwcur'1en': each beneficia:!'y' s lnCQ~e. These gr.oups a!"e:
setliors, pbysi::allj" and ment.a.lly o.i&at,~i':;a., "l"i".e:r:"::_ally ill, hQlILe!ess, batt~rerl 5pOU~~S. abuse::l
children, illiterate _persons, c.r mig:tolr.t .farm workers.
3
DRAFT 11141'93
speed CDSO funds are made by the locality. in this ca....~ by the Cil), Coun,,;il with advice and
fe(:ommendatoJl.5 from staff and Lhe CAe. HUD moniton. the City [0 ensure ;:r..a! only
eligible activ ities are funded and mat the naLtOna I objectives and ovcrali p'L"Ogram benefit
requirements are met, See Attachment 1 for a surr.rnary of the qualifying criteria and eligible
activities under the CDBG regulations.
Communitv ne"elQPgleDt N~s Eligible For CDBG Funding
The needs des.cnbed in this Community Developmem Plan are not a comprehensiv.-: listing of
Palo Alw's total community needs. For that complere-overvlew, the City's Comprehensive
Plan (currently bemg updated) should be wnsulted. Attachment 2 de-scribes Palo .Alto's
community development needs for flSCai year 1994 • J 995 .
COaG Fundio. Priorities .'0. Flscal \"ear 1~995
There is a broad range of conununity needs which are eligIble for CDBG funding. The
needs of lower income persons, and those of spec iaI fXJpuIation groups such as the disabled,
arc far greater than available (eden] aoo local funding (;an even begin to address. Therefore.
it is necessary to establish priorities for the limited funding available. Actachment 3
summarizes <be CDOO funding priorities established by the City of PaJo Alto. These
priorities are intended to provide guidance to prospective project sponsors as to the type of
activities that the Ci~ is interested in supporting with CDBG funds. Each year these
priorities will be reevaluated by the CAe a..'1d the Ciry Council and r.evised, as necessary.
Within each category. the priorities in A ttachmeru 3 at< list..-d geoeraUy in order of
importance. The funding ail~.tion targets are generaJ goals that reflect £he relative
importance of each category within the c.onsrraints of the federal regulations. The funding
allocation targets are not intended to be rigid. but rather to serve as guldeline~ consistent
with the need and adl.ieved ever a longer ttmeframe.
Project Selec:tioD C-lilWiI
City staff, the CAe and the City Council evaluate project proposals utilizing me evaluation
criteria stated in Attachment 4. AU projects must meet the threshold qualifying crite-ria and
be an eligible activity; the evaluation criteria are uselilO rank projects in re!ationsbip to each
other, For example, a projecl may be proposed which would meet a high pliority need and
is eligible under the CDBG regulations. but may noe be selected for funding becau~ it is
fmanciaHy infe:zslble or the sponsor does not have tlJe capability to carry it out.
4
DRAFT 1114,'93
I. Affordaple Housing Ob!eclive' Al!ocate approximately 50% of the CDBG
budget to ac.tivities which will mzke progress in meeting the City of Palo
A1to~s eHAS housing priorities and objectives,
2. Public Facilities & .!.Q1provem.c;.,m_9bjective: Allocalc approximalely 15% of
the CDOO budget to activities which will improve, rehabilitate atid expand
facilities which serve lower income. special needs groups and mcrease
accessibility for the disabled.
3, Public Ser:-!'i« ObiC'&..tive: Allocate approximately 15% of the eDna budget to
public ser.'ice activities related to lower income housing: needs and the needs
of lewer income children.
4. Fair Housing & Administration Objective: Allocate approximately 20% of the
CDBG budge[ to fair housing services and program administration.
5
SUMMARY OF ELIGIBLE AC'f1VlTlES
UNDER 111£ CDOG PROGRAM
DRAFT ll.l4i93
ATTACHMENT 1
Ail Projects Must Meet Both a NaJicnal Objective a,'lLi be a.'1 Eligibl~ Acthily
1. National Objeclives
Project must meet at least one of the three National Objo:ctives of the CDBG Progrdl:
1. Lower Income Benefit
2. Remoye "r PreYen! Slums and Blight
3. Meet Urgent Needs
II. Eligible Activity
The Federal Government has established regulJitions which detemtine project eligibility for
funding. Generally. !be following examples apply to Palo Alto.
1. Acqui.~ition of real property which is ;.ppropriate for rehabilitation.
2. Acquisition of land for housing or
• Certain predevelopmeru costs for housing
• Certain on.-site and off-site improvements that suPiK'" rhe construction
of housing
• Acqui.sition, constrolctivn, rehabilitation, installation of facilities and
shelters for persons with special needs, illCluding me homeless, baJ:ered
spouses, halfway houses, group homes for the disabled, etc.
DRAFT lli<.t>l3
3, Acquisition, construction, rehabilitation or installation of public facilities and
improvements. icc:1udin&; senior centers, centers fOi the handicapped and other
special facilities.
4. Rehabilitation of Sl.I'\lctures. including private propenies.
S. Removal of architectural barriers.
6. Relocation p3.ym~Ill(j.
7. Public servicf'S
• Fair housing activities
8. Assistance to non-profit entities to carry out eiigible activitie.s.
9. Plann.ing and administration of program.
10. Public facilities and improvements.
2
DRAFC i l/4193
AITACHMENT 2
I. HOUSING NEEDS:
SllMMARY OF
COMMUNITY DEVELOPMENT I'"EEDS
FISCAI~ YEAR 1994-1995
A Creation of Hawing Opportunities. There is a need to:
(I) Create additional afforda~Je housing units,
(2) Create other types of affordable bousi!1g opportuniTies, and
(3) Acquire, preserve and rehabillute exilting housing units,
with affordable: reoo., which serve the following populatioo groups:
• Very low and low income househo1ds.
• Homeless penoilS and families and households at risk of
bomelessness.
• Lower income families with children.
• Special needs groups including !he elderly, the mentally
and physically disabled and battered women.
R Housing Rehabilitation. There is a need to:
(1) rehabilitate and make capital improvements iO the C1cy"s existing stock of over
1,000 units of multi-family subsidtzed houstng.
(2) rehabilitate and make capital improvements to existing group housing facilities
Oocated both within Palo Alto and in nearby cities) which serve special needs
popul.ation.
(3) rehabilitate owner occupied, single family housing on an emergency. case by
case basis, to enable lower income elderly, disabled and famiiy households to
remain living in me homes that they own.
DRAFr lli4/9J
C. Transitional How ing. 1bere is a need to:
(1) Create addith:mal transrtiOL13.J housing for the: homeless i.nclud~ng persons with
special necch (located both within Palo Alto and in nearby cities).
U. PUBLIC FACILITIES & IMPROYEMFJ",.S: CAPITAL PROJECT 1Io"EEDS
COMMUNITY WIDE
A. There is a need tl) expand, modernize. rehat-ilitate, make ~i.smic and other safety related
improvements and. acces;sibiliry improvements to existing facilities .... rbich serve sper..::ial need
populations (limited clientele as defined l'y H:JD reg-J.lations).
B. There is a need ~o complete accessibility wprovement5 i.u public facilities and in pablic
streets and sidewalks throughout Palo A1to to emure compliance with the American with
Disabilities Act (ADA).
C. There are needs (within the South Bay and the Mid-Peninsula area) for rnorr;-emergency
shelter beds for the homeless (bach single peThons and families) and for rehabilitation of
existing emergency shelter facilities.
D. There are needs (within t!:ie South Bay and Mid-Peninsula area) for new facilities and
capital improvement and rehabilitation of exlsting facilities occupied by service progrdffis
which .serve the low income and special needs populations.
ill. PUBLIC SERVICES WHICH SERVE LOWER INCOME CLIE.l'lS PRIMARILY
A. There are: needs for supporting the operating expenses of organizations which provide
housing related information, counseling and supponive services sucil as:
• affordable housing infonnatioo and referral
• information and counseling on landlord/tenant issues
• shared housing collnseling and placement
• counseling, shelter services and general as!listance t,) the homeles!ri
• case manag{:mem and advocacy for the fIall and disabled elderly
2
DRAFT 1 V4i93
IV. FAIR HOUSING
A. There is .a need to provide fair housing services inciuding information. education,
complaint investigation, coun..o::eling and ad .... ocacy to promote an environment of fair housing
in Paio Alto.
v. PROGRAM ADMINISTRATION
A. There is a need to effectively administer, manage" implement ar.d morutor the CDBG
program to ensure that projects are feasible. that they are completed cn schedule, that there
is compliance with federal regulations .and that the funds ar= utilized in a timely and effective
manner.
3
•
DRAFT l1l4i9l
ATIACmlENT 3
SUMMARY OF CDBG FUNDL'iG PRIORITIES'
FISCAL YEAR 1994 -1995
.. Note: PrioritUs are shown in ordEr of importance.
J. AFFORDABLE HOUSING (GOAL: 50% or budget)
A. NEW CONSTRUC110N CONVERSION & J,PDITION Of NEW UNITS
I. Permanent bouslng for the homeless or at-lli-k of namelessness
2. Permanent tJousing for families with children
3. Other permanent housing including group home, for the disabled, shared
hoosing, etc.
4. Transitional housing ll':ith supportive services
B. PRESERVATION OF EXlSTING WWER INCO)l1:E RENTAL HOliSING
1, PreservatWn of existing, federally subsidized multi-famtly housing owned by
profit motivated investors
2. Acquisition and rehabilitation of other ei:.isting mUlti-family rental housing
3. Acquisition and re..1mbilitation of existing buildings for special needs housing
including shared housing And group homes.
U. PUBLIC FACILITIES AND IMPROVEMEl'<"TS (GOAL: 15% or budget)
1. Seismic safety and other safety related imprO\'ements to public facilities which
serve the elderly. disabled, homeless and othe'r spec [al needs. groups.
,.;.);"" '.--' -:
Itt
2. Accessibiliry improvements to public: faC'.illries and streets and sidewalks to
implement the Americans wi!h Disabilitil!s ACl (ADA).
3, General impro· ... ements and ex:par-.sion cf public facilities which 5oen'e special
needs groups.
Ill. PUBLIC SERVICES (GOAL: 15% of budget, ma...unum per
federal .egulations)
1. Scrvkes directly related to the hOUSL'1g need~ of lower income persons.
2. Cou..~ling and shetter services arid general 35,1,istance to the very low interne
or homeJe.~ popularion.
3. Services whicb address the needs of low income children and their families.
IV. ADMINISTRATION (GOAL: 20%, ma.'<imum per federal regulations)
A. Fair Hou;;ing Services
1. fait: bowing education. information, referral. advocacy, counseling: and
complaint resolution.
B. CDBG Program AdministratiC'n
1. SUffICient funding to effectivel;-administer the CDOO program.
2
DRlu'T 11.'4:93
AlTACHME),;T 4
CDOG PROJECT EVAL!;ATlON CRITERIA
~wz1uarior! Cn·tcri(l...!" jProjectJ Will Be E.,"aluated Using the Foilf.lv.;ing Facrors, To rhe utem Each
en'lena Applies To a Project)
1. Compliance With CHAS and Comrnunirv Development Plan: Project will meet pi:eds
identified ill these plans"
2. CDBG funding Priorities: The exrent 10 \J.-'hicb the pwposcd activities meet the adopted
COBG fJnding priorities for the year.
3. Readiness: The extent to which fuIKis can be obligated within one 'year and activities can be
completed within two years.
4. Soonsor Experience; Sponsor has mff, or other resources, available to carry out the activities
in a timely manner and in c.o-mpljance with federal proce<!ures. Past performance of sponsor will
be considered.
S. Financial Feasib.~ Likelihood thai sponsor will be able to obtain (or already has) suffJdent
finandal resources to complete the project.
6. [.ac~ of Ome_LFunding Resources: Extent to which CDBG is the only feasible funding
resource for t..'le proposed activity.
7. Cost Eff~.tjvenes!'~ Relative evaJiilltioD of a measure of cost as appropriate to the type of
project and c01U!dering t!le needs which are [Q be addre:ised by the project
8. LeveriiKli.l&.. The extent to which the CDBG funds will leverage (or act as seed money for)
other funding sources su.ch as bank fmancing, foundation grants and other state or federal grams ('Ir
loans, [This criteria applies Ola!nly to housing development activities and major public fa.cilitics.
For smaller projects, leveraging is not required.]
9. Qoerating Costs: Sponsor's plan for funding ongomg operating and maintenance costs of the
facilirj. project or activity.
10. Urgency: Will a delay have a sig.""llfican! impact on the service~ provided? Is this an urgent
and/or unmet need? Is this a long-term, tangible lnVesttne:lt?
.; "',
DRAFT 11/4/93
11. Exp,msion of Sen.']ces' Will the funds requested increase the services provided? Win more
clients be served?
12. Does the applicam serve a high number of Pale Alto residents?
13. Is the request for an es...c;ential $ervice, pTOgram or project?
14. Is t..'le service, progl'ai'1l or project duplicaled by otlJer organizations?
15. What is the agency's previous perfi.mnance experience?
16. Could the goals of tho: service, program or project be anained with less funding?
2
CITY or PALO ALTC
COJOroHU'Y !)EVE LOPllZHT BLOCK GRAIIT (CDBG)
OITlIEB PARTICIPATION PLAB
I~ Introduction
A primary aspect of the Housing and Community Development Act of
1987 is the provision of adequate opportunity tor citizens to
participate in an advisory role in the planning. implementation
and assessment of the community Development Bleck Grant (CDBG)
program. In order to encourage public ex~mination and appraisal
of the process, as well as to enhance program accountability,
qrantees are required to certify that they are following a
detailed citizen participation plan~ As required under 24 CFR
570.303, 104 (1) el}, and 106, the citizen participation plan
must:
1. Provide for and encourage citizen participation in the
development, implementation and assessment of the CDBG
program ~ith particular emphasis on participation by
persons of low and moderate income;
2. Provide citizens with reasonable and ti~ely access to
local meetings, information, and records relating to
the grantee's proposed and actual use of funds;
P :\aJI6\CI TlZf"j .1Ot1 1
A n.\ c fl~ENT 5
3. provide for technical assistence to groups
representative of pe~sons of low and moderate income
that requeGt such assistance in developing funding
proposals;
4. Provide for public hearings to obtain citizen views and
to respond to proposals and qu~stions at all stages of
the co~unity development program with reasonable
notice, accommodati~n for individuals with
disabilities, and at times and locations convenient to
potential O~ actual beneficiaries:
5. Provide for timely written responses to ~ritten
complaints and grievances within 15 working days where
practicable; and
6~ Identify how the needs of non-English speaking
residents will be met in the case of public hearings
ltlhere a significant number of non-English speaking
residents can be reasonably expected to participate.
rr. Qhjectiyes of the Plan
It is the intent of the City of Palo Alto to provide for and
encourage meaningful citizen involvement in the CDBG program by
forming a citizen participation structure which includes the
followinq objectives:
p:\m.G\Cnl2al.PU 2
1. To adhere to ~r.d coruply ~ith the provisions of the
community Development Acts of 1987, as amended and all
other federal regulations.
2. To encourage the participation of citizens in the
planning, i1C.plement,ation and asses&ment o~ the CDBG
program, especia::ly those --::>! low and very low income,
members of minority groups, residents of areas where
funds will be expended, the elderly, in~ividwals ~ith
di6abiliti~s, ana other neighborhood or civic qroups.
3. To make information about the CDBG Program and process
avai1able to the public throllgh reasonable and timely
access to information including publications in local
new&papers, public hearinqs, public meetings, and the
provision of technical assistance.
Ill. Components of thE Plan
1. CDBG A~vi.ory coaaittee (CAeJ
The establishment of a CDBG Advisory Committee (CAe) provides a
vehicle for ac~ive citizen inv~lvement in all phases of the
community JevelopDent Block Grant process.
(AJ functioot The COBG Advisory committee is advisory
to staff on the expenditure of CDBG funds and the CDBG
P:\CIIBG\ClTllaI. Pl.1I 3
process. The CAe will assist in the identification of
cQmmunity deve10pment needs and the as~e$sm~nt of projects
presented tor iun.:HTig consideration~ The CAe 'Will have an
advisory rol_ in the i~pl~ment~tion of the proqram by actinq
as a conduit to further defi~e citi~en needs and
recommendinq project criteria~ Tha CAe will assess projects
and activities to determine if the objectives of the
COD'\lllunity Development Plan and the Comprehensive Housing
Atfordability strategy (eHAS) are being met.
All recommendations, comments, assessment5~ and proposals
from the CAe vill be forwarded intact to the City Council
for their review. The C\C vill aid in the dlssemination of
information about the Community Development Block Grant
Program, and will aid in soliciting comments and views from
the general public.
(B) Kg~rsbip: coomittee members will be appointed
by the Xayor to serve a tvc year term. Members may not
serve mo~e than two consecutive full terms. The Committee
will have nine voting members, one of whom is a member of
the City's Human Relations commission. The other eight
members will be comprised of persons who 1ive or work in
Palo Alto, and vho are, or advocate for, persons of low and
moderatp income, or other groups oriented toward the goals
of the CDSC Plan, for example l members of ~inority grouFs~
P:\lWG\Cl1'lZ'ElI.iNJt 4
the elderly, persons with disabilities, etc. In order to
avoid a perceived conflict of interest, no person who is 3:
~ember of the board of directors of, or is employed by, an
agency that applies for or receives CDBG funding, will be
eligible to serve on the Committee during any year in which
such agency receives or applies for CDBG funding.
2 . City council
tAl The city Council sets policy, priorities. and
approves the overall community Development Block Grant
Program.
(:8) The city Council \..-ill hold a minimum of two public
he~rings per year for the purpose of obtaining citizens'
views and formulating or responding to proposals and
questions. The public hearings will be held at different
5taqes of the program year so that together they address
community development and housing needs, development of
proposed activities and program performance.
(C) Actions of the City Council will direct the
i~p1ementation of CDBG funded proje~ts.
3. General PUblio
fA) The general public is encouraged to participate in
the various stages of the COBG program by attending the
noticed public hearings or the CAe meetings. They are
encouraged to express their views and comments directly to
the CDBG Coordinator in the Planninq Division or receive
proqram information from the Pla~~ing Division Staff on the
5th floor of City Hall, 250 Hamilton Avenue, Palo Alto .. CA
94301~ At any time citizens may submit views concerning
P~lo Alto's performance in the CDBG prcgram to the HOD Area
Office a't 450 Golden Gate Avenue, San Francisco, CA ~410.2 ~
4. city staff
(A) The Department of Planning and Community
environment has the primary responsibility for the
administration and coordination of the CDBG PT.ogram~
(8) At the beginning of the planning process for the
CDBG program year, staff will provi~e the CAe and the
qenera1 public with the followinq information:
P:,CtlI(;\.CI ftZEl ......
1) 'I'he acount of grant funds and proqram income
expected to be made av~ilable during the next
fiscal/program year for proposed communi~y
development and housing activities;
2J The range of activities that may he
undertaken, including the estimated amount
proposed to be used for activities that will
benefit persons of 10 .. ' and moderate income:
6
-,"-
.. ,. . .. ;. .... : , ..
','
3) Tha proposed CDSO ~ctivities which will
likely result in relocation, and the city's
intent to m.inimize the necessity for
relocation of persons as a result of assisted
activities:
4) The type~ and levels of assistance the City
will make available (or require others to
make ~vailable) to persons who are eli~ibl~
for relocation assistance as a result of COBG
assisted activities.
(C) Planning staff ~ill maintain the Citizens'
Participation Plan, the Proposed and Final State~ents~ the
community Housing Affordabillty strategy (CHAS)~ the CDBG
Plan~ the Grantee Pgrformance Report, and all other program
records, documents, information and reports required by
federal requlations~ These documents are available tor
public review in the Planning Division, 5th floor, Civic
Center, 250 Hamilton Avenue~ Palo Alto~ CA 94301 durinq
normal workinq hours (weekdays~ 8:00 a.m.-1~:OO; 1:00 p.m.-
5:00 p.m.).
(D) Tachr.ical assistance on the CDSC regulations and
the CDBG program process will be prOVided by the staff of
the Planninq Division to non-profit agencies serving lov
7
income p~rsonsr citizen groilps and groups oT low and
mode~ate income and nei9hborhood qroups requesting such
assistance. Assistance may be in the form of general
inlormation, relevant cemographio or socio-economic data,
interpretation of HOD rules and regulations, explanati~n of
City policies and pro--.;edures affecting t.he CDsa Program, or
advice regarding alternative funding sources for projects
which are ineligible under the CDBG P4ogra~.
(E) Planning staff wjll arrange for information to be
presentea in a bilingual fashion at public hearings whenever
a significant number of non-English speaking residents can
be reasonably expected to participate. or when a request is
made for such service.
(FJ Pers~ns .ith disabilities who require auxiliary
aids or -services in using city facilities, services or
programs, or who would like information on tha City'5
compliance wi~; the Americans with Disabilities Act (ADA) of
1990 r may contact Dianah Neff, ADA Diractor, City of Palo
Alto., 250 Hamilton Avenue, Palo Alto, CA 94301:-(415) 329-
2313 {Voice) or (415) 32g-1199 (Telecommunication Device for
the Deaf -TOO machine). Public Hearings will be held in
the Council Chambers or other accessible locations. Sign
language interpreters will be provided upon request ~ith 72
hours advance notice.
P :\CllIti\C:1 TI ZE".IP". 8
(G) Planning staff -will provide a "Written response to
all written complair.ts ana grievances regarding the CDBG
program within 15 workinq days of receipt of such comp13int
or grieva.nce.
(H) Planning staff will schedule and notice all
required public hearings as ~ell as the public meetings of
the CAe. Notice of the date, time, place and agenda of the
public hearings will be aQvertised at least ten (10) days
prior to the hearing i.n the Pale Alto weekly or another
newspape~ of local circulation.
5. Final statement Amendment Procedures
(A) Amendments to the CDBG program which require HUD
notification or approval will be submitted to the CAe for
review and recommendation prior to submittal of the amended
application to the City Council for approva.l. Publ ic
hearings before the City council will be held on amendments
which are &ubstantial in nature, or when required by HUD.
Substantial amendments are defined as:
,: \CDIG\CI1IlEJ1.F~1f
1) the implementation or an activity not
previously identified in sUfficient detail to
provide affected citizens an opportunity to
submit comments, or
9
2) a change in an activity's program budget
which exceeds ten percent of the City's
latest annual entitle~ent grant~
10
1--
Suzanne PJchan:!s
C!ty of Palo A,lto
Fax; (415) 329-244Q
Dear Ms. RIchard,.
i'
./,."
11/5/93
I've summarize/! the Cltilen Advisory Commit:ee's ('or.ce!':".s .. dth the citizen
partIcipatjon pian, S~tiOl"l IT!. CQm;1'~'J"'n~~ Or the plait ~~e:l"'!'Jb@"'s;b;p,
!j Reducing the committe' to rJ:1e voting me",ters: "0 ~~k'iQ')
2} Di:sa1!oWi..'1g rne.rnbersh:p 0:-;' the Ccrnm~nee "to pen:Jr.s ...... ·bo are actively 5er"~ng
on the Board of Directors, or wlie 1i!'C employed by M agency recetvl.ng OJ"
"ppl>lng for CDBG funding,
8 of the 12 cunene members of the CAe v,ho "':ere present at the l\J\'ern'be-:-4
meejng obJected to L'1J.S cha.'1ge on several. gmunds.:
A) The l,::>ng sta.'1dins representative-s cf the ccm~!,;mty ir.tcre3ted rn hou.ilng
frequently sen."e.as unpaid members of varl'J'J.s Boards. Their e .... 'Pcrlence a..,d
expertise is extremel) .. valuable in ::iel:ber.n!.:J:1s regardin.g th~ varlous requesTs
whir.h come before the CAe-~.;ev.' u.:.ernbcrs of the Committ~e espeda:J.y
aypreC'late t..'1e !.nforma:ion tl'..et.e i'eopl~ h;-:r:g to the t;;;,ble.
B) ·T~.e.se BOru'd member-s are s.crup'l1lous in 3voicEng f3.dvccac), of their age.'1cies
when a request Is received which may re$ult 1.",: an appearance of .con.flkt of
[nterest. The other members of the Board m2y ask chern to be excused froC1
discusslor. and voting on my proposal. Thts se:f poUdng el~me."'t i$ ..... i:a1 to ar.j'
dtizen group.
e) V'll.th the reduction in sIze and tC!"!Tl lirntts L"!lpo~ed on the CAe. L"lis: elertlent of
experience will be e,:"er.: more impo,tQ.'1t In the future.
Accordingly. a couple options pre~ent themse!ves:
T' ., Re..'TIuve the lar~guage concernJng the B:)a!"d members from the Mem~hiP
section. To addrEs3 the City Anorne)"s .concerns, a new section C"n c:rcould be
inserted. Tilts sectlon would speD Out the conditions under which Eoa.--d members
or any representatives from non-p::-oflts could serle. It could limit their
jnvolvement in dlscusslons, r~q\ltre that th€.,Y eXC'.Jse thernsclo,;es u!:.G.er certain
condItions, and !lot alia"",-them to vot.e 0:1 prcposals whlch may pn~seI!t 3. cor.
H) Ch&"'1ge the language m L~e section tQ rea;! .!.omething like:
"In order to avoid a perce[ved C'onfl.Jct of lr.ten:st, members of rhe ComrrJttee who
a!"e actively servLng on the Board of Directors, or who are employed by an
agency applying for ne\\' or ~allocated CDSG fU:'ldlng will be ex:cused from
voti:i1g a!l ~'\.v 5t1eh requests.·~
ftespec tfull)"
\0 . (.:s~;f C~ U
Member at Large-:
Citizens Ad ... isory Co::nmitree
AiTACHMENT 6
I
:Y jn -:~-';;, -
,--_.;..,-::;C __ _
Palo Alia Housing Corporation
December 8, 1993
Suzanne Richards
CDBG Coordinator
City of Palo Alto
P_O_ Box 10250
Palo Alto. CA 94J()3
Re: CDBG Citizens Participation Plan
Dear Suzanne:
........ ---
/ __ ,~ •• _i:',_ .
c,
-1"
The Board of Direc.ors (If the Palo Aho Hou:-.ing Corporatirm (PAHC) has considered
your propoS«! changes 10 th!! City of PaiD Alto's CDBG Citizens Participation Pian.
We support yvt;r general approach. particularly 0;-] the C{lrdlict of intere~, issue. and
Pltlpose that it be implemented as a test for a defined pt"rioo nf time.
Members of the PAHC Board 'oIro'ho have served on !he CDBG CAe have always felt
u.ncomfortable about the pott:ntia1 p<lSltion of cont1id in which the)' are p"aced.
Nevertheless, the organization rnkes comfon in knowing t!1at they are 5e;ving so that
they can provide correct facilial information to the Commiltt'e when it Le, relevant and
useful. Thus, while we see the conflict, \\'e also see lhe bt:nefit of The current
Committee Siructure. which allows members of nonprofit agencic::, to serve and, in facl,
be generafly helpful. even though not participating on decisions affecting their
particular agency.
If the proposed conflict rule were adopted for a time limited period, it could be
determined whether Ihe cnange has a negative or pO\lrive impact on the workings of the
Committ~. Wt: would have concern jf [ne (:,'\C dil~ not atlr.<!.ct applicants wiih
sufficient ex~ricnce wilh the workings of nonprofil housir.g agencies to render gocxl
advice to the Council and good service (0 the community.
Sincerely.
540 Cowper Stree~ Suite G, Palo Alto, California 943lJ1, (415) 321-9709
ATIACKMENT 7