Agenda Item
City Council
Item #: 6.1. 7/25/2023 File #: 23-0460
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director
1. SUBJECT
Examination of Census Tract 219.14 (El Modena area) for Community Development Block Grant funding eligibility during Fiscal Years 2000 - 2023.
2. SUMMARY
An examination of the eligibility of the El Modena area in Census Tract 219.14 for Community Development Block Grant funding determined that Census Tract 219.14 has not met the eligibility requirements from the Department of Housing and Urban Development for funding as of 2000, with the exception of 2010, due to a one-time waiver.
3. RECOMMENDED ACTION
Receive and file.
4. FISCAL IMPACT
None.
5. STRATEGIC PLAN GOALS
Goal 4: Provide outstanding public service
b: Provide facilities and services to meet customer expectations.
6. DISCUSSION AND BACKGROUND
On May 9, 2023, during the Public Hearing for the approval of the 2023-2024 Annual Action Plan, staff received direction from the City Council to return with information on the changes in eligibility of Census Tract 219.14 for Community Development Block Grant (CDBG) funding. The request was made in response to public concerns over the lack of investment of CDBG funding in the El Modena area that corresponds to Census Tract 219.14.
Staff retained the services of a CDBG mapping consultant at Michael Baker International (MBI) to conduct an independent examination of the area to determine the following:
1. Eligibility of the El Modena area using the data sources available directly from the Federal Department of Housing and Urban Development (HUD) and the U.S. Census Bureau;
2. Identify changes to socio-economic conditions of the area between 2000-2023 to determine when CDBG funding eligibility had changed; and
City of Orange Printed on 7/20/2023Page 1 of 3
powered by Legistar™
Item #: 6.1. 7/25/2023 File #: 23-0460
3. Identify other factors, economic or otherwise, that impact the eligibility of an area.
The findings of this effort were provided to HUD to confirm accuracy and validity.
Background
HUD provides entitlement cities, such as the City of Orange that receive annual CDBG funding, with American Community Survey (ACS) data to determine eligibility of CDBG funding as it becomes available. ACS data represents smaller Census Bureau data collection samples in limited geographic areas during the years between the decennial census, with those samplings extrapolated to the entire census tract. At the time of the creation of the 2020-2024 Consolidated Plan (equivalent to Fiscal Years 2021-2025) and corresponding Annual Action Plans, including the 2023-2024 Action Plan, the most recent data available was the ACS 2015 data.
The Consolidated Plan (Con Plan) is a five-year strategic plan required by HUD that outlines the priorities for the five Annual Action Plans. Annual Action Plans are specific to each year in the Consolidated Plan cycle and outline the City’splan and intent for the use of funds in each program year.
Map Examination Findings
The examination of Census Tract 219.14 by MBI determined that the area has not qualified under HUD’seligibility guidelines from 2000 to the present. In order for an area to qualify, 50% or more of the households in an area must have incomes below 60% of the Area Median Income (AMI). The exception of eligibility of Census Tract 219.14 is in 2010 as a result of a one-time waiver from HUD that permitted selected counties to use uncapped income limits to determine eligibility.
For specific details on how the determination of the eligibility of Census Tract 219.14 was made, refer to MBI’s report (Attachment 1).
Internal Review
At the Public Hearing on May 9, 2023, the information that staff had at the time cited ACS 2015 data as the source data used to create the eligibility map (Attachment 2) in the 2020-2024 Con Plan. The map in the Con Plan depicted Census Tract 219.14 as a CDBG eligible area. The maps used in the application process for the subsequent Action Plans corresponding to the Con Plan, however, depicted a different eligibility map with Census Tract 219.14 no longer qualifying using the same source data (Attachment 3).
As part of the internal review of the records for Census Tract 219.14, the Con Plan map and the maps in the subsequent Action Plans were recreated by the City’sGIS Division to verify the source data cited in each of the maps for accuracy. GIS staff were able to determine that the source data had been incorrectly cited for the map approved with the Con Plan (Attachment 2) and confirmed that the source data used to create the map was ACS 2010 data. The subsequent maps used in the Annual Action Plans (Attachment 3), where Census Tract 219.14 is not an eligible area, however, were confirmed to have been generated with ACS 2015 data.
Conclusion
Census Tract 219.14 has not met the eligibility criteria for CDBG funding from 2000 to the present, with the exception of 2010 due to a one-time waiver from HUD in response to the subprime mortgage City of Orange Printed on 7/20/2023Page 2 of 3
powered by Legistar™
Item #: 6.1. 7/25/2023 File #: 23-0460
crisis of 2007-2010.
In order to correct the eligibility map in the 2020-2024 Con Plan, staff will return to Council to substantially amend the Con Plan and adopt a corrected map to be generated by the City’smapping consultant to ensure the correct data set is used and interpreted. Additionally, staff will update the Citizen Participation Plan that outlines the policies adopted by the City to ensure citizen participation in the development of the Con Plan and the Annual Action Plans and the Policies and Procedures, in order to ensure that the process for updating the map in the Con Plan and Annual Action Plans are streamlined moving forward.
7. ATTACHMENTS
· Attachment 1 - Michael Baker International Study of Census Tract 219.14 · Attachment 2 - 2020-2024 Consolidated Plan Eligibility Map · Attachment 3 - 2021 Annual Action Plan Eligibility Map City of Orange Printed on 7/20/2023Page 3 of 3
powered by Legistar™