From: Patrick Cudah
To: Kimberley White; Alex Stillman; Meredith Matthews; Sarah Schaefer; Rhea Varley; David Loya Cc: Building Bayside Better
Subject: Subject: Council Meeting Feb 4 Agenda item 11a CDBG PI scoping menu items Date: Wednesday, February 4, 2026 1:50:23 PM
Attachments: RFP Arcata EIR-EIS Services_8.19.25pages_referenced.pdf deed_trust_full_doc.pdf
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City of Arcata City Council
Mayor Kimberley White, Alexandra Stillman Councilmember, Meredith Matthews Councilmember, Sarah Schaefer Councilmember
C/O City Clerk:
Email: [email protected]
Subject: CDBG PI scoping menu items (Agenda item 11a)
Dear Mayor and Councilmembers and Planning Staff,
Ahead of Wednesday’s Council meeting, I wanted to pass along some context that may be helpful as CDBG PI scoping is discussed. I understand this will be viewed through the broader lens of community development, and my intent here is simply to add clarity and background to inform that discussion.
Re: The CDBG menu item of 1622 and 1632 Old Arcata Road I want to make sure everyone has the context that the site property has an existing $1m lien of deed of trust and rents from 2010, (attached below). A brief search in the online county records indicates this is a current and first-position lien over the proposed project site. Council may also recall that the 2023 Resolution 234-17 (attached below) for the RG site directs that a first-position lien be recorded over the same property to securitize the $180k loan. However, it appears from a review of the county recorder’s files that this may not have occurred, as the HCD first-position requirement would be blocked by the existing lien already in first position.
Because CDBG funds cannot substitute for private financing and must be used only for eligible activities meeting HUD’s national objectives, the existing lien as read may make this site structurally ineligible for the program, raising questions about its inclusion on the menu.
This information related to the Roger Garage item on your CDBG menu could also impact scoring under the Application Corrections category in the CDBG Scoring Matrix sheet presented in the staff report. The overall application score could be reduced where the $1m lien appears to be collateralized across four other properties, including the two site parcels (not yet merged), creating obvious apportionment constraints. For instance, the proposed allocation amount of $650,000 noted in the RG candidate scoping list is, as of yet, undefined for apportionment purposes and may create additional application pathway problems.
Lastly, I want to provide some NEPA background relevant to the CDBG PI menu item for 1622 and 1632 Old Arcata Road (Roger’s Garage). The menu item lists the NEPA Environmental Review Level as “Unknown,” but that does not fully reflect the site record.
NEPA status should be more accurately described as “Pending” as its applicability is not speculative. Council previously approved the Helix RFQ, which states: “The consultant will be asked to prepare environmental documentation meeting the requirements of both CEQA and NEPA” (see attached selected RFP-RFPq pages).
This project's financing was brought forward and discussed twice before in a CDBG PI context, establishing the public record of NEPA nexus during the May and June 2025 Council meetings, including presentations as a soft-loan structure and/or as a pass-through purchase approach. These prior efforts show that NEPA applicability has already been established in connection with the project’s financing and structuring discussions, reinforcing that the “Unknown” label on the menu item is inaccurate and misleading.
Thank you for your time. I respectfully recommend pausing, deferring, or removing the Roger’s Garage item from the CDBG PI menu pending clarification of lien status and NEPA sequencing.
Patrick Cudahy
Bayside