STAFF REPORT
City of Lancaster
PH 2
5/7/2024
JC
Date: May 7, 2024
To: Mayor Parris and City Council Members
From: Larissa De La Cruz, Director - Community Development Lisa Anderson, Analyst - Housing
Subject: Adoption of the City of Lancaster’s Community Development Block Grant Program (CDBG) and HOME Investment Partnership Program (HOME) 2024- 2025 Program Year (PY) Action Plan
Recommendations:
a. Conduct a public hearing and upon accepting public testimony; b. Approve and adopt the CDBG and HOME Action Plan for the 2024-2025 PY to be submitted to the United States Department of Housing and Urban Development (HUD); c. Appropriate approximately $1,463,022.00 from PY 2024-2025 CDBG Funds; d. Appropriate approximately $724,611.00 from PY 2024-2025 HOME Funds; e. Provide City Staff with a methodology for distributing funds should the City’s 2024-2025 CDBG and HOME annual allocations increase or decrease; and f. Authorize the City Manager or designee to execute all contracts and associated documents, including subrecipient agreements, subject to City Attorney approval.
Fiscal Impact:
There will be no negative impact to the General Fund. As an entitlement grantee, the City is eligible to receive CDBG and HOME funds annually from HUD. The 2024-2025 Action Plan allocates approximately $1,463,022.00 in CDBG funds and $724,611 in HOME funds in furtherance of the City’s Consolidated Plan Strategic Plan Goals.
Background:
1 6
0 6
The City has been a CDBG entitlement community since 1986 and started receiving HOME funds in 2020. The City receives annual grants for developing viable urban communities that encompasses decent housing, provides suitable living environments, and expands economic opportunities, primarily for the benefit of low- and moderate-income persons. The proposed Action Plan is intended to provide a summary of proposed program activities, eligibility criteria, and funding levels for the 2024-2025 PY. All programs and/or projects submitted in the Plan are compliant with the HUD guidelines for eligible activities.
In accordance with Title 24 CFR part 91, this Action Plan lists the activities the City will undertake to address priorities and objectives with anticipated CDBG and HOME funding received during the 2024-2025 PY. A new Action Plan is developed and submitted for each program year within the five-year planning period of the 2020-2024 Consolidated Plan.
To proceed with the City's Action Plan, which serves as the formal document to HUD for CDBG and HOME funding, it is necessary for the City Council to take public testimony on proposed projects.
In compliance with federal requirements and in accordance with the City’s Citizen Participation Plan, the City published its proposed Action Plan on April 5, 2024, providing a 30-day public review and comment period. Comments received during the review period, spanning April 5, 2024, through May 7, 2024, will be attached to the Action Plan and incorporated into the plan where appropriate.
The Action Plan will be brought to the Council on May 7, 2024, for approval. The documents will be submitted to HUD to ensure the availability of CDBG and HOME funds. Approval of the Action Plan will enable CDBG and HOME funding availability as of July 1, 2024, the start of the 2024-2025 PY.
Analysis:
As of the date of the preparation of this staff report, HUD has not released the City’s CDBG and HOME annual allocation and therefore HUD has advised the City to prepare its Action Plan utilizing the City’s current year CDBG and HOME annual allocations. For this reason, it is anticipated that during the 2024-2025 PY, the City will receive approximately $1,463,022.00 of CDBG funds and $724,611.00 in HOME funds to be allocated to eligible activities. The program activities listed below will be implemented from July 1, 2024, to June 30, 2025 2024-2025 CDBG Activities
Public Service
Lancaster Homeless Group dba Street Company: Coffee
Manufacturing Homeless Employment Program $50,000
Lost Angels Children’s Project: Work Program $88,000
Sub-Total: $138,000
Capital
City of Lancaster: Housing Rehabilitation Program $926,418 City of Lancaster: Section 108 Loan Repayment Children’s Center $106,000
Sub-Total: $1,032,418
Administration
1 6
0 6
City of Lancaster: CDBG Administration $252,604
Fair Housing Foundation: Fair Housing Services (Admin CAP) $40,000 Sub-Total: $292,604
TOTAL 2024-2025 CDBG PROGRAM $1,463,022
2024-2025 HOME Activities
Housing
CHDO Set Aside $108,692
Homebuyer Assistance Program $543,458
Sub-Total: $652,150
Administration
Program Administration $72,461
Sub-Total: $72,461
TOTAL 2024-2025 HOME PROGRAM $724,611
Due to the uncertainty in the City’s 2024-2025 annual allocations, a request of the City Council is being made to provide staff and the public with a methodology for which activity budgets will be adjusted when the final allocations are released by HUD. It is recommended that City Council adopt the following language for adjusting activity budgets for the CDBG and HOME programs:
CDBG
•Should the CDBG allocation be higher than $1,463,022.00:
oAdmin – Fair Housing will remain funded at $40,000.00 and the CDBG Administration budget will be increased to maximize the 20% cap for administrative activities.
oPublic Service – The City will not award any additional activities but will increase the award of those agencies allocated funds in the 2024-2025 AAP, proportionately, up to the 15% public service cap.
oCapital – Balance of funds will be allocated to the City’s Home Rehabilitation Program.
oFunding levels for all outstanding activities will remain the same as proposed in the 2024-2025 AAP.
•Should the CDBG allocation be lower than $1,463,022.00:
oAdmin – Fair Housing will remain funded at $40,000.00 and the CDBG Administration budget will be decreased to be compliant with the 20% cap for administrative activities.
oPublic Service – Decrease the award of those agencies allocated funds in the 2024- 2025 AAP, proportionately, to be compliant with the 15% cap for public service activities.
oCapital – Balance of funds will be deducted from the City’s Home Rehabilitation Program.
1 6
0 6
oFunding levels for all outstanding activities will remain the same as proposed in the 2024-2025 AAP.
HOME
•Should the HOME allocation be higher than $724,611.00:
oAdmin – Increase HOME Administration budget to maximize the 10% cap for Administrative activities.
oCHDO – Increase CHDO set-aside to the minimum 15% required for CHDO activities.
oHousing – Balance of funds shall be awarded to the Homebuyer Assistance Program.
•Should the HOME allocation be lower than $724,611.00:
oAdmin – Decrease HOME Administration budget to be compliant with the 10% cap for Administrative activities.
oCHDO – Decrease CHDO set-aside to the minimum 15% requirement for CHDO activities.
Housing – Balance of funds shall be deducted from the Homebuyer Assistance Program.
Attachment:
1. City of Lancaster Draft 2024-2025 Action Plan