Guidelines
For
Utility Bill Assistance Program
Funded By
City of Fort Bragg
With
Community Development Block Grant
Adopted: xx/xx/2025
TABLE OF CONTENTS
1. HYPERLINK \l "_1.0_INTRODUCTION"INTRODUCTION 1
2. HYPERLINK \l "_2.0__PROGRAM"PROGRAM OVERVIEW
1. Program Administration 1
2. Program Service Area 1
3. Funding Source for Program Services 1
3. HYPERLINK \l "_3.0_CDBG_PROGRAM"CDBG PROGRAM REQUIREMENTS
1. Eligible Program Applicants 2
2. Ineligible Program Applicants 2
3. Eligible Utility Services 2
3. Timeframe for Receiving Program Services 3
4. Meeting CDBG National Objective Requirement 3
5. Other CDBG Federal Laws and Regulations 3
4. HYPERLINK \l "_4.0_APPLICATION_PROCESSING"APPLICATION PROCESSING FOR PROGRAM SERVICES
1. Program Marketing and Outreach 4
2. Equal Opportunity Compliance 4
3. Program Application Processing 4
4. Duplication of Benefits Policy 4
5. Program Participant / Applicant Confidentiality 6
6. Dispute Resolution / Appeals Procedure 6
7. Exceptions / Special Circumstances 6
5. HYPERLINK \l "_5.0_PROGRAM_SERVICE"PROGRAM SERVICE DELIVERY
1. Program Eligibility Review 6
2. Program Subsidy 6
6. HYPERLINK \l "_6.0__"PROGRAM OVERSIGHT BY CITY
1. Oversight of Program Operator 6
2. Tracking Services of Participants 7
ATTACHMENT A: City’s Executed Resolution Adopting Program Guidelines ATTACHMENT B: Current CDBG Income Limits
ATTACHMENT C: Sample Program Application
COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG)
UTILITY BILL ASSISTANCE PROGRAM GUIDELINES
1.0 INTRODUCTION
The City of Fort Bragg (“City”) has established the Utility Bill Assistance Program to be known as UBAP(“Program”). The purpose of the Program is to assist the City’s neediest residents by providing emergency financial assistance to low-moderate income persons via payment of utility bills directly to utility providers on behalf of qualified households. With Program assistance, the goal is to assist residents at risk losing essential utility services or housing, breaking the expensive cycle of late payments, shut offs, and restoration fees by providing one-time-only payment relief to qualifying utility account holders. These Program Guidelines have been formally adopted by the City and submitted to the California Department of Housing and Community Development, here after called “the Department”. See Attachment A for copy of the adopting resolution.
2.0 PROGRAM OVERVIEW
2.1 PROGRAM ADMINISTRATION
The City and its Program Operator (if applicable) will:
Market the Program;
Accept and process participant applications;
Document participant CDBG Program eligibility; and
Ensure set up of participant files to document all provided services and associated costs.
The City and its Program Operator will work with program participants and ensure CDBG compliance with these program guidelines.
2.2 PROGRAM SERVICE AREA
Program services are available to all eligible persons residing within Fort Bragg city limits.
2.3 FUNDING SOURCE FOR PROGRAM SERVICES
The Program is paid for with CDBG funds provided by HUD to the Department. As such, these funds have a number of federal requirements that must be met, as described below. These CDBG funds come to the City from Department grant awards that are administered under a formal grant contract. Per HCD’s current HYPERLINK "https://www.hcd.ca.gov/sites/default/files/docs/grants-and-funding/cdbg/appendix-6-6-cdbg-program-income-policy.pdf"CDBG Program Income Policy, Program Income (PI) funds may not be used for Public Services activities, including subsistence payment programs; therefore, Program Income will not be utilized for this program.
3.0 CDBG PROGRAM REQUIREMENTS
3.1 ELIGIBLE PROGRAM APPLICANTS
To be eligible for the Program, head(s) of households must:
Complete and sign a Program Application;
Sign a CDBG Public Service Program Self-Certification of Income form and provide documentation of income as requested by program staff; Meet the most recent CDBG Income Limits (less than 80% of the County median income); Submit proof of responsibility for any active utility billing account requesting assistance as a home owner or renter; Prove residency at the utility billing account address; address must be within City limits Prove that the utility is not currently shut off due to delinquent payment; Family/Household is not able to access other payment assistance for same costs (no duplication of benefit) Provide documentation of need for emergency payment
Documentation of Emergency Status
Applicants must provide documentation that emergency financial assistance is warranted. Emergency status may be determined by meeting at least one of the following:
Household income is at or below 30% of the Area Median Income (AMI) per current CDBG Income Limits and is therefore considered to be Extremely Low Income. Extremely Low Income households are presumed to be at risk of homelessness.
Recent job loss or reduction of work hours
Late/Delinquent Notices for utilities or rent. At least one utility must be delinquent in order to qualify for emergency status. The presumption is that one delinquent bill may lead to additional late payments, and one-time assistance may cover all utility payments currently due in order to break the cycle.
Additional emergencies may be considered on a case by case basis, pursuant to section 4.6.
Eligible applicants documented as meeting the Program eligibility requirements are hereafter referred to as “Program Participants”.
3.2 INELIGIBLE PROGRAM APPLICANTS
An ineligible Program applicant is anyone whose primary residence is outside of the service area. Persons residing in a household that exceeds current Income Limits are not eligible. Utility account holders whose utility is currently shut off are not eligible. Businesses or non-profit organizations are not eligible for the program. Prior recipients of Program financial assistance are not eligible for additional emergency financial assistance unless a period of no less than twelve months has passed. Applicants receiving other assistance for the same expenses (duplication of benefits) are ineligible.
3.3 ELIGIBLE UTILITY SERVICES
Utility services eligible for program payments include the following:
Water/Sewer Services
Electricity Services
Waste Collection
Propane, Kerosene, Diesel, etc. (when such fuel is required for operation of household heating or food preparation) Payments will be made directly to utility providers on behalf of qualified households. Program may pay for delivery of service and late fees but will not pay for maintenance, repair, or other penalties.
3.4 TIMEFRAME FOR RECEIVING PROGRAM SERVICES
The Program will operate as long as funding is available. Once funding is depleted or the expenditure period of the active agreement with HCD has expired, the Program will cease until or unless additional Program funding is secured. Program Participants are eligible for one-time-only financial assistance, which may cover up to three consecutive months. Program participants may reapply for the program if at least twelve months have passed since they last received assistance, as funding is available.
3.5 MEETING CDBG NATIONAL OBJECTIVE REQUIREMENT
Under federal regulations, use of CDBG funds for emergency financial assistance must meet the national objective of benefit to low and moderate income persons under the Limited Clientele definition. As such, all Program Participants must be documented as meeting the HUD low/moderate income definition prior to receiving any Program services. The most recent CDBG Public Service income self-certification form will be used to preliminarily screen applicants for income eligibility and program staff will verify income of program applicants prior to approving the use of Program funds for subsistence payments. Applicants must submit documentation of income as requested, which may include such items as tax returns, bank statements, pay stubs, etc. The most recently released CDBG Income Limits are included as Attachment B. The Income Limits are periodically updated. The current Income Limits are available at the Department website at the following link: HYPERLINK "https://www.hcd.ca.gov/funding/income-limits/state-federal-income-limits/cdbg-home-nhtf"https://www.hcd.ca.gov/funding/income-limits/state-federal-income-limits/cdbg-home-nhtf.
If the City learns that the applicant’s income information is not accurate and/or the program participant is over HUD’s income limits, then a program applicant is ineligible and program services currently offered will immediately cease.
3.6 OTHER CDBG FEDERAL LAWS AND REGULATIONS
There are a number of federal laws and state regulations that are triggered with the use of CDBG funding for a Public Service Program. The City will ensure compliance with these other CDBG regulations.
National Environmental Policy Act (NEPA) federal environmental laws per regulation 24 CFR 58 are not triggered for individual Program Participants; nor are there any compliance requirements for Davis Bacon and related Acts for Program activities under these guidelines. Acquisition and relocation laws are also not triggered when using CDBG funds for Program services.
4.0 APPLICATION PROCESSING FOR PROGRAM SERVICES
4.1 PROGRAM MARKETING AND OUTREACH
Upon the City’s receipt of a Department letter releasing Program funding, the City and/or Program Operator will conduct outreach and marketing to individuals in the Program service area. City staff and/or Program Operator will work together to develop a marketing plan for the Program to outreach to persons in the community regarding the availability and accessibility of the Program. This plan shall be kept on file and updated as needed to ensure that all residents in the service area are informed about and have access to Program applications.
4.2 EQUAL OPPORTUNITY COMPLIANCE
This Program will be implemented in ways consistent with the City’s commitment to state and federal equal opportunity laws. No person shall be excluded from participation in, denied the benefit of, or be subjected to discrimination under any program or activity funded in whole or in part with CDBG program funds on the basis of his or her religion or religious affiliation, age, race, color, ancestry, national origin, sex, marital status, familial status (number or ages of children), physical or mental disability, sexual orientation, or other arbitrary cause.
4.3 PROGRAM APPLICATION PROCESSING
Applications will be processed on a first come first served basis until available funding is depleted. See Attachment C for a sample Program Application form. City staff or Program Operator will accept applications and review for HUD income eligibility per Department standards and for other program eligibility requirements. The Program Operator will submit copies of all applicants’ Self-Certification forms to the City for review and final approval.
All Program Applications received, both denied and approved, will be logged and kept on file in accordance with Department records retention act. Applicants who do not meet eligibility requirements of the program will be notified in writing with an explanation of ineligibility. Files will be set up for all eligible program participants to document compliance with all CDBG regulations, Department policy, and adopted Program Guidelines, and to document all services provided.
4.4 DUPLICATION OF BENEFITS POLICY
A CDBG grantee is required to develop and maintain adequate procedures to prevent a duplication of benefits that address (individually or collectively) each activity or program. A grantee’s policies and procedures are not adequate unless they include, at a minimum: (1) a requirement that any person or entity receiving CDBG assistance must agree to repay assistance that is determined to be duplicative; and (2) a method of assessing whether the use of CDBG funds will duplicate financial assistance that is already received or is likely to be received by acting reasonably by evaluating need and the resources available to meet that need. It is the intent of the section below to present the City policy to uphold, enforce and document conformance with the duplication of benefits requirements which cover use of its CDBG funds when providing emergency financial assistance:
All applications to the UBAP are required to complete a Duplication of Benefits Affidavit as part of the application process. This affidavit acknowledges the City’s requirement that any person or household receiving UBAP assistance must agree to repay assistance that is determined to be duplicative.
To meet HUD’s requirements, the City has developed a method of assessing whether the use of UBAP funds will duplicate financial assistance that is already received or is likely to be received by acting reasonably in evaluating need and the resources available to meet that need.
This assessment process is as follows:
Upon receipt of the completed application packet, Program Operator reviews the Duplication of Benefits Affidavit to determine if the applicant has reported receiving any potentially duplicative assistance.
If so, the City may request additional information from the applicant, including:
Dates funds were received
Specific uses of funds received, including receipts and dates as appropriate.
Based on a review of this information, the Program Operator and/or City may:
Determine that there is no duplication and proceed with consideration of the application for the full amount requested.
Determine that there is a partial duplication and proceed with consideration of the application for an amount that reduces the request by the DOB amount Amount Requested – Amount of DOB = Eligible Amount
Determine that there is a complete duplication and deny the application In the event that an application is approved in part, the City will also include in the funding documents specific information around what the funds may be spent on so as to avoid duplication of benefits.
All application documents, including the Affidavit and Subrogation Agreement, shall be retained in compliance with HUD’s record retention requirements.
4.5 PROGRAM PARTICIPANT / APPLICANT CONFIDENTIALITY
All personal financial information will be kept confidential. Program Participant files with personal confidential information will be kept in locked, secured storage units.
4.6 DISPUTE RESOLUTION / APPEALS PROCEDURE
Any person applying for Program services has the right to appeal a denied application. The appeal must be made in writing to the City. A written response to the appeal will be provided to the applicant by the City within 30 days of receipt of the applicant’s appeal letter.
4.7 EXCEPTIONS / SPECIAL CIRCUMSTANCES
Exceptions are defined as any action which would depart from policy and procedures stated in the guidelines. Exceptions to these guidelines are limited to those that do not conflict with Federal regulations. Exceptions may be recommended by the Program Operator or the City and will require approval by a City committee comprised of the staff CDBG specialist, Community Development Director or designee, and Finance Director or designee.
5.0 PROGRAM SERVICE DELIVERY
5.1 PROGRAM ELIGIBILITY REVIEW
Upon receipt of a completed Program Application including all required attachments, City staff or Program Operator will review the Self-Certification form for income eligibility. If applicants are income-eligible, City staff or Program Operator will confirm other eligibility requirements including status of utility account holders’ bill and primary residency at the account address. Applicants whose utility service has been shut off for non-payment are not eligible for the Program.
5.2 PROGRAM SUBSIDY
For eligible Program Participants, the amount eligible for the Program subsidy will be calculated at 100% of the total utility bill balance, up to $500 (total of all utility bills, not each individual bill). The approved Program subsidy will be paid directly to the utility provider to the Program Participant’s utility account. The Program subsidy will be paid only after the Program Participant has provided a complete program application and any supplemental documents, and has been approved by the Program Operator. Payments are made via check directly to the utility provider.
6.0 PROGRAM OVERSIGHT BY CITY
6.1 OVERSIGHT OF PROGRAM OPERATOR
City staff will serve as the primary contact with the Department. If an outside consultant (Program Operator) is to be hired by the City to administer the program, the City will be responsible for securing services of a qualified Program Operator for implementation of the Program prior to starting any activities under these Program Guidelines. The scope of work for the Program Operator will include all administration and documentation required for Program services as described in these Program Guidelines and as required for CDBG compliance.
6.2 TRACKING PROGRAM SERVICES TO PARTICIPANTS
City staff oversees and monitors all work conducted by the Program Operator. Monthly or quarterly meetings will be conducted to review the program status of: 1) marketing efforts; 2) applications received; 3) eligible Program Participants being served; 4) successful Program Participant stories; 5) demand for different services and need for more resources or partners; 6) review of program tracking forms as developed by Program Operator and approved by City; 7) review of Department reports and funds requests for reimbursement of Program Services; and 8) preparation for Department monitoring of the City’s grant contract and Program services. As per the executed agreement between the City and the Program Operator, all required reports under open grant contracts will be reviewed and approved by City staff.
ATTACHMENT A
GRANTEE’S DRAFT RESOLUTION ADOPTING GUIDELINES
[To be replaced with Executed Resolution Adopting Program Guidelines]
ATTACHMENT A
GRANTEE’S DRAFT RESOLUTION ADOPTING GUIDELINES
ATTACHMENT B
CURRENT CDBG INCOME LIMITS
STATE CDBG AND HOME TABLE OF 2025 INCOME LIMITS
EFFECTIVE JUNE 1, 2025*
Income Category
Number of persons in household
12345678“30%” Limit$19,750$22,550$25,350$28,150$30,450$32,700$34,950$37,200“50%” Limit$32,900$37,600$42,300$46,950$50,750$54,500$58,250$62,000“60%” Limit$39,480$45,120$50,760$56,340$60,900$65,400$69,900$74,400“80%” Limit$52,600$60,100$67,600$75,100$81,150$87,150$93,150$99,150 PROGRAM PARTICIPANTS’ HOUSEHOLD INCOME MUST NOT EXCEED THE “80%” LIMIT FOR THE HOUSEHOLD SIZE *The above income limits are periodically updated. For the most current income limits, please visit the following link at the California Department of Housing and Community Development website:
HYPERLINK "https://www.hcd.ca.gov/funding/income-limits/state-federal-income-limits/cdbg-home-nhtf"https://www.hcd.ca.gov/funding/income-limits/state-federal-income-limits/cdbg-home-nhtf
ATTACHMENT C
SAMPLE PROGRAM APPLICATION
Exhibit “A”
PAGE
PAGE iii
PAGE
UBAP Program Guidelines Adopted: xx/xx/2025
PAGE 1
UBAP Program Guidelines Adopted: xx/xx/2025 PAGE 1
UBAP Program Guidelines A- Adopted: xx/xx/2025 PAGE 1
UBAP Program Guidelines B- Adopted: xx/xx/2025 PAGE 1
UBAP Program Guidelines C- Adopted: xx/xx/2025