Attachment A - Draft CDBG Annual Action Plan FY 2024-25 060324

ANNUAL ACTION PLAN
FISCAL YEAR 2024-2025
DRAFT (June 6, 2024)
for
City Council Public Meeting:

June 18, 2024
ADMINISTERED BY: PLANNING & DEVELOPMENT SERVICES

FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 1

Table of Contents
Executive Summary .................................................................................................................................................. 2 AP-05 Executive Summary - 91.200(c), 91.220(b) ................................................................. 2 The Process ............................................................................................................................................................... 6 PR-05 Lead and Responsible Agencies - 91.200(b) ................................................................ 6 AP-10 Consultation - 91.100, 91.200(b), 91.215(l) ............................................................... 8 AP-12 Participation - 91.401, 91.105, 91.200(c) ................................................................ 16 Expected Resources ................................................................................................................................................ 20 AP-15 Expected Resources - 91.420(b), 91.220(c)(1,2) ......................................................... 20 Annual Goals and Objectives .................................................................................................................................. 24 AP-20 Annual Goals and Objectives - 91.420, 91.220(c)(3)&(e) ............................................... 24 AP-35 Projects - 91.420, 91.220(d) ................................................................................ 27 AP-38 Project Summary ............................................................................................. 28 AP-50 Geographic Distribution - 91.420, 91.220(f) ............................................................. 34 AP-75 Barriers to affordable housing -91.420, 91.220(j) ...................................................... 35 AP-85 Other Actions - 91.420, 91.220(k) ......................................................................... 38 Program Specific Requirements .............................................................................................................................. 42 AP-90 Program Specific Requirements - 91.420, 91.220(l)(1,2,4) ............................................ 42 Appendices ............................................................................................................................................................. 43 APPENDIX A ........................................................................................................... 43 Public Comments ................................................................................................. 43 APPENDIX B ........................................................................................................... 44 Public Notices ..................................................................................................... 44 APPENDIX C ........................................................................................................... 49 Application for Federal Assistance SF-424 Forms and Certifications ...................................... 49

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Executive Summary
AP-05 Executive Summary - 91.200(c), 91.220(b)

1. Introduction
The City of Palo Alto (City) Fiscal Year (FY) 2024-25 Annual Action Plan (AAP) contains the City’s plan to carry out housing and community development activities funded by Federal formula grant funds received from the U.S. Department of Housing and Urban Development (HUD), Community Development Block Grant (CDBG) program. The City operates on a two-year grant funding cycle for CDBG public service grants and a one-year cycle for CDBG capital housing rehabilitation and public facilities and improvement projects. This Action Plan covers the fifth and final year of the City’s five-year 2020-2025 Consolidated Plan, which was adopted by the Palo Alto City Council on June 15, 2020.

The Planning and Development Services Department is the lead agency for the Consolidated Plan and subsequent 5 Annual Action Plans for the City’s CDBG program. HUD requires entitlement jurisdictions to submit a Consolidated Annual Performance and Evaluation Report (CAPER) that describes the distribution of federal entitlement grant funds over the Consolidated Plan’s five-year planning period and identifies how funding allocations help meet the goals covered in the Consolidated Plan.

The City received its CDBG FY 2024-25 entitlement grant amount on May 7, 2024,CDBG funds available for allocation in FY 2024-25 total $1,037,807.61, which includes the entitlement grant ($513,653), anticipated program income ($60,000) to be receipted in FY 2024-25, and unspent funds from prior years ($461,154.61).

The City is aware that program income receipts can be inconsistent and makes its best effort to estimate future income and execute ongoing program budget adjustments as necessary. The City is also reallocating $119,478.74 in CDBG CARES Act ( CDBG-CV) funds, including unspent funds from the canceled LifeMoves - COVID-19 Testing project ($34,200.50) and unspent CDBG-CV Planning & Administration funds ($85,278.24) The City’s FY 2024-25 AAP covers the time period from July 1, 2024, to June 30, 2025. The FY 2024-25 AAP contains the accomplishments the City expects to achieve in FY 2024-25. All the projects, programs, and activities in the FY 2024-25 AAP reflect the 2020-2025 Consolidated Plan goals. CDBG-funded programs and activities principally benefit City residents that have extremely low, low, and moderate- incomes and/or populations that have special needs, such as the elderly, disabled, and homeless.

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Fiscal Year 2024-25 CDBG and CDBG-CV Budget Summary
Applicant Agency Allocation
Public Services (15% Cap = $77,047.95)
Alta Housing - SRO Resident Support Services $11,575
Catholic Charities of Santa Clara County – Long Term Care Ombudsman Program $7,575
LifeMoves – Case Management $28,247
Silicon Valley Independent Living Center (SVILC) – Case Management $14,075 Project Sentinel – Fair Housing Services $15,575
Subtotal $77,047
Economic Development (No Cap)
WeeCare/Upwards $120,000
Subtotal $120,000
Housing Rehabilitation (No Cap)
Rebuilding Together Peninsula (RTP) – Safe at Home $73,585 Community Work Group/Abode – Alma Garden $404,800
Subtotal $478,385
Public Facilities & Improvements (No Cap)
Fire Station – Sidewalk Improvements Project $62,645.61 Homekey Palo Alto – Recreation Project $185,000
Subtotal $247,645.61
Planning & Administration (20% Cap = $114,730.60)
City of Palo Alto Planning & Administration $114,730
Subtotal $114,730
Grand Total for CDBG Budget $1,037,807.61
Public Services CDBG-CV
CDBG-CV MOVE Mountain View - Safe Parking Program $110,000 Planning & Administration CDBG-CV (20% Cap)
CDBG-CV City of Palo Alto Planning & Administration $9,478.74 Grand Total for CDBG-CV Budget $119,478.74

2. Summarize the objectives and outcomes identified in the Plan This could be a restatement of items or a table listed elsewhere in the plan or a reference to another location. It may also contain any essential items from the housing and homeless needs assessment, the housing market analysis or the strategic plan

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The City is part of the San Francisco Metropolitan Bay Area, located 35 miles south of San Francisco and 14 miles north of San José. The City is located within the County of Santa Clara, borders San Mateo County, and encompasses an area of approximately 26 square miles, one-third of which consists of open space.

According to the U.S. Census Bureau, 2022 ACS Census , the City's total resident population is 66, 021 and has a density of 2,745 persons per square mile. Between 2020 and 2021 the City’s median household income grew from $174,003 to $194,782, a 11.9% increase. According to the U.S. Census data, 6.1% of all residents within the City had incomes below the federal poverty level. The City has the most educated residents in the country and is one of the most expensive cities to live in. According to the 2020 Palo Alto Business & Economic Activity Report in 2020, the City has between 4,100 and 7,000 for- profit and no t for profit businesses and 92,000 to 114,000 employees.

Additionally, according to the 2023 Point in Time (PIT) homeless count, there were 187 unsheltered homeless individuals and 19 sheltered. The 2022 PIT homeless count revealed there were 263 unsheltered homeless individuals and 11 sheltered homeless individuals in Palo Alto in 2022. This reflects an overall estimated 24.5% decrease in homelessness in Palo Alto.

The FY 2024-25 Annual Action Plan provides a summary of how the City will utilize its CDBG allocation to meet the needs of the City’s lower-income and special-needs populations. In FY 2023-24, the City received $514,242 from the federal CDBG program and utilized $80,825 of program income. In FY 2024-25, they City has available a total of $1,037,807.61 CDBG funds. This higher amount is largely due to activities identified in past AAPs that were canceled and previously unspent funds from completed activities. Canceled CDBG activities included Downtown Streets Inc . and Mitchell Park Place. Completed activities with remaining FY2021-22 funds were Catholic Charities, Rebuilding Together Peninsula, and City of Palo Alto Planning and Administration; remaining FY2022-22 funds were Catholic Charities, Life Moves, Project Sentinel, and City of Palo Alto Planning and Administration ; remaining FY2023-24 funds were City of P alo Alto Planning and Administration. The City also intends to reallocate $119,478.74 in CDBG-CV funds. The canceled CDBG-CV was LifeMoves-COVID-19 Testing.

3. Evaluation of past performance
An evaluation of past performance help s City leaders allocate funds to priority activities, as well as select projects that are more aligned with its priority needs and goals. The City is responsible for ensuring compliance with all rules and regulations associated with the CDBG entitlement grant program. Prior Annual Action Plans (AAPs) and Consolidated Annual Performance and Evaluation Reports (CAPERs) provide many details about the accomplishment goals, projects, and programs completed by the City and its subrecipients.

A review of the FY 2022-23 CAPER reveals that 310 persons and/or employers were assisted. Specifically:
• LMI elderly were assisted: 62
• Residents that received counseling services: 148
• Homeless individuals received shelter: 49
• Individual that received housing complaint services: 22 • Persons with disabilities receiving assistance: 24

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• LMI homeowners receiving home improvements: 5
• Workforce development program assistance: 0

The City evaluates the performance of subrecipients on a q uarterly basis. Subrecipients submit required quarterly progress reports that include client data, performance objectives, and data on outcome measures.

Prior to the start of the program year, subrecipients and the City collaboratively develop program objectives, ensuring that they are aligned with the City's overall goals and strategies. The City then utilizes the quarterly reports to review progress toward achievement of annual goals.

4. Summary of Citizen Participation Process and consultation process The City solicited input throughout the development of the FY 202 4-25 Annual Action Plan ( AAP). As required by HUD, the City provides multiple opportunities for public review and comment on the AAP, as well as any substantial amendments. Per the City’s adopted Citizen Participation Plan, the City holds a 30- day public review comment period for the AAP. The City also publishes the required notification of upcoming public hearings and the 30 -day public review comment period in a local newspaper of general circulation, on the City’s CDBG webpage , and via email blasts to stakeholders. The City held two advertised public hearings on the AAP, HRC meeting on February 8, 2024, and the City Council meeting on June 18, 2024. The AAP 30-day public review period began on March 13, 2024 and ran through April 12, 2024.

5. Summary of public comments
This could be a brief narrative summary or reference an attached document from the Citizen Participation section of the Con Plan.

Public comments received by the City will be reported here.

6. Summary of comments or views not accepted and the reasons for not accepting them The City accepts and responds to all submitted public comments. As noted above, all public comments were reported and addressed as part of this FY 2024-25 Annual Action Plan.

7. Summary
No further discussion

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The Process
PR-05 Lead and Responsible Agencies - 91.200(b)

1. Agency/entity responsible for preparing/administering the Consolidated Plan The following are the agencies/entities responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source.

Agency Role Name Department/Agency
Lead Agency PALO ALTO
CDBG Administrator PALO ALTO Department of Planning & Development Services Table 1 – Responsible Agencies

Narrative
The City is the Lead and Responsible Agency for the United States Department of Housing and Urban Development’s (HUD) entitlement programs in Palo Alto. The Department of Planning and Development Services (PDS) is responsible for administering the City’s CDBG program. The City joined the HOME Consortium in 2015 and receives federal HOME Investment Partnership (HOME) funds through the County.

Entitlement jurisdictions receive entitlement funding (i.e., non-competitive, formula funds) from HUD. HUD requires the City to submit a five-year Consolidated Plan and Annual Action Plan to HUD listing priorities and strategies for the use of its federal funds.

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The Consolidated Plan helps local jurisdictions to assess their affordable housing and community development needs and market conditions. As a part of the Consolidated Plan process for 2020 -2025, the City collaborated with the County of Santa Clara (County) as the Urban County (representing the cities of Campbell, Los Altos, Los Altos Hills, Los Gatos, Monte Sereno, Morgan Hill, and Saratoga); the cities of Cupertino, Gilroy, Mountain View, Sunnyvale, San José, and Santa Clara; and the Santa Clara County Housing Authority (SCCHA) to identify and prioritize housing and community development needs across the region, and to develop strategies to meet those needs. The FY 202 4-25 AAP represents the fifth year of CDBG funding of the 2020-2025 Consolidated Plan.

Consolidated Plan Public Contact Information
Rebecca Atkinson, Planner
City of Palo Alto
Department of Planning and Development Services
250 Hamilton Avenue, 5th Floor
Palo Alto, CA 94301
E-mail: [email protected] Phone: (650) 329-2596

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AP-10 Consultation - 91.100, 91.200(b), 91.215(l)

1. Introduction
The Annual Action Plan is a one-year plan that describes the eligible projects, programs, and activities to be undertaken with funds expected during FY 2024-25 and their relationship to the priority housing, homeless, and community development needs outlined in the 2020 -25 Consolidated Plan. Consultation with the City and region’s soc ial services, Human Relations Commission (HRC), Santa Clara Housing Coordinators group, City Departments, and City Council occurred in the development of the AAP.

Provide a concise summary of the jurisdiction’s activities to enhance coordination between public and assisted housing providers and private and governmental health, mental health and service agencies (91.215(l)).

The projects, programs, and activities identified in the Annual Action Plan were shaped through a detailed collaborative process. The City CDBG program administrators performed technical assist ance, as well as interviewed and monitored subrecipients. They also conducted consultations with the City’s Public Works, Planning, Housing, Human Services, and Economic Devel opment staff. The City continue s to work with and consult with city departments, non-profit organizations that provide programs and services for low- income households , private industry, homeless providers, and housing development groups . The City supports the development of affordable housing opportunities both regionally and within the City. City staff provides technical assistance to awarded public service subrecipients and new CDBG applicants, as well as attends monthly Santa Clara County Continuum of Care and Housing Coordinators meetings.

Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans, and unaccompanied youth) and persons at risk of homelessness.

The Santa Clara County Office of Supportive Housing is the administrator of the regional Continuum of Care (CoC). The City’s Office of Human Services Manager is in contact with the Santa Clara County Office of Supportive Housing and Destination Home regarding issues of homelessness in the community. The Santa Clara County CoC is a group comprising of stakeholders throughout the County, including governmental agencies, homeless service and shelter providers, homeless population, housing advocates, affordable housing developers, and various private parties, including businesses and foundations.

City staff continues to attend monthly CoC Housing Coordinator meetings. The CoC plans and prepares significant reports supported by its CDBG entitlements and cities . Reports adopted by the CoC strive to improve conditions for the homeless, record data related to homelessness, develop a system for volunteer assistance that helps identify gaps in homeless services, establish funding priorities, and pursue a systematic approach to addressing homelessness.

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The CoC is governed by the CoC Board, which takes a systems-change approach to preventing and ending homelessness. This same CoC Board is comprised of the same individuals who serve on the Destination:

Home (Destination Home) Leadership Board. Destination Home is a public -private partnership that is committed to collective impact strategies to end chronic homelessness.

Regional efforts of the CoC include the development of The Community Plan to End Homelessness, which identifies strategies to address the needs of people experiencing homelessness in the County, including chronically homeless individuals and families, families with children, veterans, and unaccompanied youth.

The plan also addresses the needs of persons at risk of homelessness. The new community plan to end homelessness can be viewed at
Reports and Publications - Office of Supportive Housing - County of Santa Clara (sccgov.org).

As part of the development of the 2020 -25 Consolidated Plan, the City directly consulted both the CoC and County Office of Supportive Housing for their expertise and experience in identifying community needs.

Describe consultation with the Continuum(s) of Care that serves the jurisdiction’s area in determining how to allocate ESG funds, develop performance standards for and evaluate outcomes of projects and activities assisted by ESG funds, and develop funding, policies and procedures for the operation and administration of HMIS The City is not an ESG entitlement jurisdiction and therefore does not receive ESG funds. However, the City does administer federal grant programs that help homeless and low -income families in Santa Clara County. The City uses its CDBG-CV funds to support safe parking lots that house non-sheltered homeless persons and families. Annually the City funds its homeless shelter for its supportive case management services. Over the last several years the City has developed funding and building plans for its new Homekey Shelter. Homekey Palo Alto is a planned modular interim housing shelter with the capacity to serve over 200 individuals annually with on-site support services. This project will be constructed by 2025.

The City provides local fund s for the County to conduct its annual Point in Time (PIT) count, an annual regional collaborative effort to count and survey sheltered and unsheltered people experiencing homelessness. The data from the County of Santa Clara PIT count is used to plan, fund, and implement actions for reducing chronic homelessness and circumstances that bring about homelessness. For 2023, the PIT count was conducted on January 26, 2023. The CoC reported there were 275 persons placed in transitional housing, 1,480 persons sheltered, and 5,904 persons unsheltered. There were 187 unsheltered homeless individuals and 19 sheltered in the City of Palo Alto. The City’s 2022 PIT homeless count was 263 unsheltered homeless individuals and 11 sheltered homeless individuals. This reflects an overall estimated 24.5% decrease in homelessness in Palo Alto.

The Santa Clara County Office of Supportive Services takes the role of Homeless Management Information System (HMIS) administration. The County, and its consultant Bitfocus, work jointly to operate and oversee HMIS. Both software and HMIS system administration are now provided by Bitfocus. Funding for

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HMIS in Santa Clara County comes from HUD, the County of Santa Clara, and the City of San Jose. The County’s HMIS is used by many City service providers across the region to record information and report outcomes.

2. Agencies, groups, organizations and others who participated in the process and consultations

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Agencies, groups, organizations who participated
1 Agency/Group/Organization REBUILDING TOGETHER PENINSULA Agency/Group/Organization Type Housing
What section of the Plan was addressed by Consultation? Affordable Housing Preservation Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination?
Attended pre-application workshop. Stakeholder
communications and application submission and
project selection.
2 Agency/Group/Organization SILICON VALLEY INDEPENDENT LIVING CENTER Agency/Group/Organization Type Services - Housing
Services-Elderly Persons
Services-Persons with Disabilities
What section of the Plan was addressed by Consultation? Non-Homeless Special Needs Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination?
Attended pre-application workshop. Stakeholder
communications and application submission and
project selection.
3 Agency/Group/Organization PROJECT SENTINEL
Agency/Group/Organization Type Services - Housing
Fair Housing and mediation services
What section of the Plan was addressed by Consultation? Fair Housing Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination?
Attended pre-application workshop. Stakeholder
communications and application submission and
project selection.
4 Agency/Group/Organization ALTA HOUSING
Agency/Group/Organization Type Services - Housing

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What section of the Plan was addressed by Consultation? Non-Homeless Special Needs Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination?
Attended pre-application workshop. Stakeholder
communications and application submission and
project selection.
5 Agency/Group/Organization LIFEMOVES
Agency/Group/Organization Type Services-homeless
What section of the Plan was addressed by Consultation? Homeless Needs - Chronically homeless Homeless Needs - Families with children
Homelessness Needs – Veterans
Strengthening Neighborhoods – Public Facilities
Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination?
Attended pre-application workshop. Stakeholder
communications and application submission and
project selection.
6 Agency/Group/Organization CATHOLIC CHARITIES
Agency/Group/Organization Type Services-Housing
What section of the Plan was addressed by Consultation? Non-Homeless Special Needs Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination?
Attended pre-application workshop. Stakeholder
communications and application submission and
project selection.
7 Agency/Group/Organization WEECARE/UPWARDS
Agency/Group/Organization Type Business and Civic Leaders What section of the Plan was addressed by Consultation? Economic Development

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Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination?
Attended pre-application workshop. Stakeholder
communications and application submission and
project selection.
8 Agency/Group/Organization COMMUNINITY WORK GROUP/ABODE Agency/Group/Organization Type Housing
What section of the Plan was addressed by Consultation? Affordable Housing Preservation Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination?
Attended pre-application workshop. Stakeholder
communications and application submission and
project selection.
9 Agency/Group/Organization MOVE MOUNTAIN VIEW
Agency/Group/Organization Type Services-homeless
What section of the Plan was addressed by Consultation? Homeless Needs - Chronically homeless Homeless Needs - Families with children
Homelessness Needs - Veterans
Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination?
Attended pre-application workshop. Stakeholder
communications and application submission and
project selection.
10 Agency/Group/Organization PEARL TRANSIT CORP.

Agency/Group/Organization Type Business and Civic Leaders What section of the Plan was addressed by Consultation? Non-Homeless Special Needs

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Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination?
Stakeholder communications and application
submission and project not selected.

Table 2 - Agencies, groups, organizations who participated

Identify any Agency Types not consulted and provide rationale for not consulting There were no gaps in the consultation process.

Other local/regional/state/federal planning efforts considered when preparing the Plan Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? Continuum of Care Regional Continuum of
Care Council
Identifies housing inventory count to facilitate the provision of housing services to those experiencing homelessness.

Housing Element City of Palo Alto Identifies barriers to affordable housing, such as land- use controls, inefficiencies of the development review process, and strategies to alleviate such barriers. 2019 & 2020 STD/HIV
Annual Report Santa Clare County This report provides a summary of findings for Santa Clara County HIV surveillance data.

SCCHA Moving to Work
Annual Plan
Santa Clara County
Housing Authority
Addresses housing authority updates and strategies pertaining t o public housing and vouchers.

Regional Housing Need
Plan for San Francisco
Bay A
Association of Bay Area
Governments
This plan analyzes the total regional housing need for the County and all of the Bay Area. This effort aligns with the Strategic Plan's goal to assist in the creation and preservation of affordable housing.

Community Plan to End
Homelessness in Santa
Clara
Destination: Home
The Community Plan to End Homelessness in the County is a five-year plan to guide governmental actors, nonprofits, and other community members as they make decisions about funding, programs, priorities and needs. This effort aligns with the Strategic Plan's goal to support activities to end homelessness.

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Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? Palo Alto's
Infrastructure: Catching
Up, Keeping Up
City of Palo Alto
Infrastructure Blue Ribbon
Plan. Accessibility
Summary
This plan details recommendations for infrastructure maintenance and replace, as well as identifies potential sources of funding. This effort aligns with the Strategic Plan's goal to support activities that strengthen neighborhoods through the provision of community services and public improvements.

City of Palo Alto
Comprehensive Plan
(2030)
City of Palo Alto
This plan is the primary too l for guiding future development in Palo Alto. It provides a guide for long- term choices and goals for the City future. This effort aligns with the Strategic Plan's goal to support activities that strengthen neighborhoods through the provision of community services and public improvements.

Table 2 - Other local / regional / federal planning efforts Narrative
No additional content needed.

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AP-12 Participation - 91.401, 91.105, 91.200(c)

1. Summary of citizen participation process/Efforts made to broaden citizen participation Summarize citizen participation process and how it impacted goal-setting

The Planning and Development Services Department is the lead agency for overseeing the development of the Consolidated Plan and Action Plan.

Per the City’s adopted Citizen Participation Plan, the City is to allow a 30 -day public review and comment period for the Action Plan. The City published notifications of public hearings and the 30-day public review comment period in the local newspaper of general circulation, on its CDBG webpage, and via email blasts. The City held two advertised public hearings on February 8, 2024, and June 18, 2024. The Action Plan 30-day public review period began on March 13, 2024 and ran through April 12, 2024. The City has not received any public comments to date. (Any comments to be inserted here once public hearings are completed) Citizen Participation Outreach
Sort Or
der
Mode of Outr
each
Target of Outre
ach
Summary of
response/attenda
nce
Summary of
comments received
Summary of
comments
not accepted
and reasons
URL (If applicable)
1 Newspaper Ad
& Internet
Outreach
Non-
targeted/broad
community
Email Blast to
interested
organizations,
persons
Accepted NOFA
application between
October 3 –
November 17, 2023.
4 new CDBG
applications were
received; 6 applications
were received in
Program Year 1 and
applied to Year 2 of the
two-year funding cycle.

And 2 new CDBG-CV
applications.

All comments
accepted
https://www.cityofpaloalto.org/files
/assets/public/v/1/planning-amp-
development-services/cdbg-general-
information/py-2024-2025-cdbg-
nofa-application-package-

10.02.23.pdf.

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Sort Or
der
Mode of Outr
each
Target of Outre
ach
Summary of
response/attenda
nce
Summary of
comments received
Summary of
comments
not accepted
and reasons
URL (If applicable)
2 Consultation
Listing
Social Service,
City Departments,
Area Housing
developers
Pre-Application
Conference on
October 26, 2023
Application description,
stakeholder
consultation
All comments
accepted
https://cityofpaloalto.zoom.us/rec/s
hare/OEnSZX1HwWN6fKv2PHYowU
myEheUO0GEkAA3_grogQrkP0mzJn
EB9x4C6eVDipHo.zOLaGzGCkZuWtP
SE
https://www.cityofpaloalto.org/files
/assets/public/v/1/planning-amp-
development-services/cdbg-general-
information/plans-and-
reports/action-plans/py-2024-25-
pre-proposal-conf-pres-10-26-23.pdf
3 Newspaper Ad
Non-
targeted/broad
community
Notice of Human
Relations
Commission & City
Council Public
Hearings announced
FY2024-25 CDBG
Funding Allocations,
published in the
Daily Post on January
24, 2024.

No comments received All comments
accepted
https://www.cityofpaloalto.org/Dep
artments/Planning-Development-
Services/Housing-Policies-
Projects/Community-Development-
Block-Grant
4 Public Hearing
Non-
targeted/broad
community
HRC met on Feb 8,
2024, to discuss
FY2024-25
Applications and AAP
activities.

No comments received
All comments
will be
accepted
https://www.cityofpaloalto.org/City-
Hall/Boards-Commissions/Human-
Relations-Commission

FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 18

Sort Or
der
Mode of Outr
each
Target of Outre
ach
Summary of
response/attenda
nce
Summary of
comments received
Summary of
comments
not accepted
and reasons
URL (If applicable)
5 Newspaper Ad
Non-
targeted/broad
community
Notice of City Council
Public Hearing
announcing FY2024-
25 CDBG Funding
Allocations,
published in the
Daily Post on March
13, 2024.

CORRECTION NOTICE
of City Council Public
Hearing Date
published in Daily
Post on June 3, 2024.

Not yet completed
All comments
will be
accepted

6 Public Hearing
Non-
targeted/broad
community
The City Council held
its second public
hearing on June 18,
2024, to discuss
Draft AAP. Council
members
recommended
approval.

Not yet completed
All comments
will be
accepted

7 Internet
Outreach
Non-
targeted/broad
community
Webpage postings
for both hearings
Jan 24th No comments
received
March 13th No
comments received
All comments
will be
accepted
https://www.cityofpaloalto.org/Dep
artments/Planning-Development-
Services/Housing-Policies-
Projects/Community-Development-
Block-Grant

FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 19

Sort Or
der
Mode of Outr
each
Target of Outre
ach
Summary of
response/attenda
nce
Summary of
comments received
Summary of
comments
not accepted
and reasons
URL (If applicable)
8 Internet
Outreach
Non-
targeted/broad
community

Email Blast to
interested
organizations,
persons
3 Email Blasts were
sent on January 24
and March 13, 2024,
and June 3, 2024, to
all documented
contacts, interested
agencies, and
individuals.

Jan 24th No comments
received
March 13th No
comments received
June 3rd No comments
received
All comments
will be
accepted

Table 3 – Citizen Participation Outreach

FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 20

Expected Resources
AP-15 Expected Resources - 91.420(b), 91.220(c)(1,2)
Introduction
In FY 2024-25, the City will allocate a total of $1,037,807.61 CDBG funds to eligible activities that address the needs identified in the Consolidated Plan. These CDBG funds reflect the sum of a $513,653 FY 2024-25 Entitlement Grant, $60,000 Program Income (estimated) to be receipted in FY 2024-25, and $464,154.61 in unspent funds from prior years that are reallocated. The City acknowledges that program income receipts may vary and endeavors to forecast future income while implementing necessary adjustments to the ongoing program budget. In FY 2024-25, the City reallocated a total of $119,478.74 in CDBG CV funds to eligible activities to prevent and respond to the spread of coronavirus. The total reallocated CDBG-CV funds is the sum of $34,200.50 unspent funds from the canceled LifeMoves -COVID-19 Testing P roject and $85,278.24 unspent funds from Planning & Administration funds. It should be noted that while the HUD CDBG allocations are critical, the allocations are not sufficient to overcome barriers and address all needs that low - income individuals and fa milies face in attaining self-sufficiency . The City efforts include leveraging local county, regional, state and federal funds estimating $5.3 million, that align with goals outlined in the Consolidated Plan.

The City continues to leverage additional resources, as described below, to provide support and services to the communities' populations in need.

The following section discusses the anticipated resources available for community development activities during the remaining year of the City’s 5-Year Consolidated Plan.

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Anticipated Resources
Program Source
of Funds
Uses of Funds Expected Amount Available Year 5 Expected Amount
Available
Remainder of
ConPlan
$
Narrative Description
Annual
Allocation
: $

Program
Income: $
Prior Year
Resources: $
Total:
$
CDBG public -
federal

Admin and
Planning
Economic
Development
Housing
Public
Improvements
Public Services
513,653 60,000
(estimate
d)
464,154.61
CDBG
$119,478.74

CDBG-CV
1,037,807.61
CDBG
$119,478.74

CDBG-CV

This is the 5th year of the 2020-2025 ConPlan.

CDBG funds are used for public services that
benefit low income and special needs
households, economic development, housing
rehabilitation through preservation of owner-
occupied homes, and public facilities &
improvement projects. A total of $464,154.61
in unspent funds from prior years are
reprogrammed in the FY2024-25 AAP. The
following canceled projects required a
substantial amendment for their
corresponding program years:
-PY 2021-22 Downtown Streets Inc. -
Workforce Development Program project
$133,068.07. In total, $191,018.05 of unspent
funds from PY2021-22 are available for
reprogramming.
-PY 2022-23 Mitchell Park Place project
$356,330. Reconciliation of PI receipted
resulted in total $269,435.96 unspent funds
from PY2022-23 are available for
reprogramming.

In total, $3,700.60 of unspent funds from
PY2021-22 are available for reprogramming.

All prior years’ resources were reallocated to
PY2024-25 Housing Rehabilitation projects.

Table 4 - Expected Resources – Priority Table

FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 22

Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied
The City joined the Santa Clara County's HOME Consortium in 2015 and does not receive federal HOME funds on an entitlement basis from HUD.

The HOME Consortia consists of the cities of Cupertino, Gilroy, Palo Alto, and the Urban County. HOME funds can be used to fund eligible affordable housing projects for acquisition, construction, and rehabilitation. Starting in FY 2015 - 16 developers of affordable housing projects w ere eligible to competitively apply through an annual RFP process directly to the County for HOME funds to help subsidize affordable housing projects in Palo Alto. Applications are directly submitted through the County's request for proposal process for av ailable HOME funds. Certain nonprofit organizations known as Community Housing Development Organizations (CHDOs) may also apply for funding from California Departm ent of Housing and Community Development (HCD) for housing projects located within Palo Alto. The City has only received one HOME grant from 1992 HOME funding for the Barker Hotel project. Proceeds from HOME loan repayments are deposited into a HOME Program Income Fund and used in accordance with the HOME program regulations.

In addition, the Coun ty funds only projects that has the local support of the City. If the City receives HOME dollars from its participation in the HOME consortium, the required 25% matching funds will be provided from the City’s Affordable Housing Fund, which is comprised of two sub - funds: the Commercial Housing Fund and the Residential Housing Fund. To date, no projects within the City have been funded through the HOME Consortium. Moving forward, the City plans to increase outreach to developers in the City to provide additio nal information on the HOME Consortium and available funding.

Other State and Federal Grant Programs
In addition to the CDBG entitlement dollars, the federal government has several other funding programs for community developm ent and affordable housing activities. These include Section 8 Housing Choice Voucher Program, Section 202, Section 811, the Federal Home Loan B ank Affordable Housing Program (AHP), and others. It should be noted that in most cases, the City would not be the applicant for these funding sources as many of these programs offer assistance to affordable housing developers rather than local jurisdictions. The projects funded leverage private, HSPAP, and County funds estimated 1.6 million to support their programs.

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In September 20 22, multiple State bills were signed, including SB 6 (Middle -Class Housing Act) and AB 2011 to advance housing development progress. These two bills streamline the regulatory process and ensure that workers building homes are being paid a fair wage . The bi ll helps generate new housing units plus general thousands of jobs. The California Housing Accelerator provided funding for shovel-ready projects in 2022 whose financing was stalled because of the difficulty in receiving tax credits. The City c ontinues to track and look for opportunities to leverage State resources for the City.

If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan
The City has no surplus public land.

Discussion
Local Housing and Community Development Sources. Other local resources that support housing and community development programs include:
• Palo Alto Commercial Housing Fund provides assistance for the development of below market rate (BMR) housing units which are, in part, funded by mitigation fees obtained from commercial and industrial development projects. • ADA coordinator and city-wide ADA capital improvement listing. • The Housing Element outlines the City’s detailed housing priorities and needs. • Rebuilding Together Peninsula assists 4-6 low-to moderate income homeowners with home improvements.

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Annual Goals and Objectives
AP-20 Annual Goals and Objectives - 91.420, 91.220(c)(3)&(e) Goals Summary Information
Sort
Order
Goal Name Start
Year
End
Year
Category Geographic
Area
Needs Addressed Funding Goal Outcome Indicator
1 Affordable
Housing
2020 2025 Affordable
Housing
Affordable Housing CDBG: $478,385

Homeowner Housing
Rehabilitated: 5 Households
Rehabilitating rental housing
units for extremely low income
households: 10
2 Homelessness 2020 2025 Homeless Homelessness CDBG: $28,247

CDBG-CV:
$110,000
Public service activities other
than Low/Moderate Income
Housing CDBG Benefit: 158
Persons Assisted
CDBG-CV Benefit: 150 Persons
Assisted

FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 25

Sort
Order
Goal Name Start
Year
End
Year
Category Geographic
Area
Needs Addressed Funding Goal Outcome Indicator
3 Strengthen
Neighborhoods
2020 2025 Non-Homeless
Special Needs
Non-Housing
Community
Development
Community Services
and Public
Improvements
CDBG: $
$252,717.61
Public Facility or Infrastructure
Activities other than
Low/Moderate Income Housing
Benefit: 435 households
Assisted

Public service activities other
than Low/Moderate Income
Housing Benefit: 75 Persons
Assisted
4 Fair Housing 2020 2025 Non-Housing
Community
Development
Fair Housing CDBG: $15,575 Public service activities other than Low/Moderate Income
Housing Benefit: 12 Persons
Assisted
5 Economic
Development
2015 2020 Non-Housing
Community
Development
Economic
Development
CDBG: $120,000 Jobs created/retained: 0 Jobs
Businesses assisted: 15
Businesses Assisted
Table 5 – Goals Summary

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Goal Descriptions
The goal of the City of Palo Alto, with funding from CDBG, is to increase self- sufficiency, housing opportunities and economic opportunity for lower-income residents and individuals so that they can achieve a higher quality of life . In 2020, the City has established the following goals as a guide for allocating CDBG funding during the 5-year consolidated planning period:
1 Goal Name Affordable Housing
Goal Description Assist in the creation and preservation of affordable housing for low income and special needs households. 2 Goal Name Homelessness
Goal Description Prevent and end homelessness, such as funding affordable housing opportunities, resource centers for homeless individuals, and support for tenants of single-room occupancy units 3 Goal Name Strengthen Neighborhoods
Goal Description
Provide community services and public improvements to benefit low-income and special needs households. This includes assisting those with disabilities to transition from unstable housing to permanent housing, supporting residents of long- term care facilities, and supporting individuals experiencing domestic violence. 4 Goal Name Fair Housing
Goal Description Promote fair housing choice by funding fair housing organizations to provide fair housing services, such as education, tenant-landlord mediation, and testing.
5 Goal Name Economic Development
Goal Description
Support economic development activities that promote employment growth and help lower-income people secure and maintain jobs. This includes funding nonprofits working toward developing the skills of low-income and homeless individuals.

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AP-35 Projects - 91.420, 91.220(d)
Introduction
The Consolidated Plan goals represent high priority needs for the City of Palo Alto (City) and serve as the basis for the strategic actions the City undertakes to meet these needs. The projects, listed in no particular order are:
# Project Name CDBG and CDBG-CV
1 2024 Alta Housing SRO Resident Support Services
2 2024 Catholic Charities of Santa Clara County: Long Term Care Ombudsman Program 3 2024 LifeMoves: Case Management
4 2024 Silicon Valley Independent Living Center (SVILC): Case Management 5 2024 Project Sentinel – Fair Housing Services
6 2024 WeeCare/Upwards
7 2024 Rebuilding Together Peninsula (RTP) – Safe at Home 8 2024 Community Work Group/Abode – Alma Garden
9 2024 Fire Station – Sidewalk Improvements Project
10 2024 HomeKey Palo Alto – Recreation Project
11 2024 Planning & Administration
12 2024 CDBG-CV MOVE Mountain View - Safe Parking Program 13 2024 CDBG-CV Planning & Administration
Table 6 – Project Information CDBG

Describe the reasons for allocation priorities and any obstacles to addressing underserved needs
The City awards CDBG funding to projects and programs that primarily benefit s low-income, homeless and special needs households. The City operates on a two-year grant funding cycle for CDBG public service grants and a one-year cycle for CDBG capital housing rehabilitation and public facilities and improvement projects. Projects are only considered for funding within the Consolidated Plan period if they address the goals discussed.

FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 28

AP-38 Project Summary
Project Summary Information
1 Project Name 2024 Alta Housing SRO Resident Support Services Program Target Area Citywide
Goals Supported Homelessness
Needs Addressed Homelessness
Funding CDBG: $11,575
Description SRO Resident Support Services Program.

Eligible Activity (Matrix Code): 05O, Mental Health Services CDBG National Objective: LMC
Target Date 6/30/2025
Estimate the number
and type of families
that will benefit from
the proposed activities
Case management and support counseling services will be provided to an estimated 131 residents of Barker Hotel and Alma Place.

Location Description 439 Emerson Street, Palo Alto, CA 94301 735 Alma Street Palo Alto, CA 94301
Planned Activities Alta Housing’s Resident Support Services program project activities include case management and counseling services to residents at the Barker Hotel (25 units) and at Alma Plac e (106 units). Funding would support a SRO Service Coordinator services to assist residents with managing daily living skills, maintaining their mental and physical health, one-on-one support counseling, and crisis intervention. 2 Project Name 2024 Catholic Charities of Santa Clara County: Long Term Care Ombudsman Program
Target Area Citywide
Goals Supported Strengthen Neighborhoods
Needs Addressed Community Services
Funding CDBG: $7,575
Description Long-Term Care Ombudsman Program.

Eligible Activity (Matrix Code): 05A, Senior Services
CDBG National Objective: LMC
Target Date 6/30/2025
Estimate the number
and type of families
that will benefit from
the proposed activities
The program will provide advocacy and complaint investigation for 50 elderly residents of long-term care facilities in Palo Alto.

Location Description Long-term care and skilled nursing facilities throughout the City.

Planned Activities Catholic Charities' Long -Term Care Ombudsman Program (LTCOP) project activities include regular contact with Palo Alto Residential Care Facilities to observe and monitor conditions of care and handle and resolve issues regarding residents' rights, unmet ne eds, allegations of abuse, and complaints effectively, thus promoting resident well -being.

Funding would support Program services.

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3 Project Name 2024 LifeMoves: Case Management
Target Area Citywide
Goals Supported Homelessness
Needs Addressed Homelessness
Funding CDBG: $28,247
Description Opportunity Services Center/Hotel De Zink
Eligible Activity (Matrix Code):- 03T, Operating Costs of Homeless/AIDS Patients Programs
CDBG National Objective: LMC
Target Date 6/30/2025
Estimate the number
and type of families
that will benefit from
the proposed activities
27 unduplicated individuals (homeless and/or very low -income individuals per year) will receive case management services, including assistance with housing/job searches , referrals and mentoring at the Opportunity Services Center and Hotel De Zink.

Location Description 33 Encina Way, Palo Alto, CA 94301 Planned Activities LifeMoves project activities include case management services to Opportunity Services Center and Hotel De Zink clients in locating housing and/or employment and be connected to benefits. Additionally, activities include provision of services at the Opportu nity Services
Center, such as showers, restrooms, laundry facilities, benefits enrollment assistance, transportation vouchers, and referrals for medical and dental care for residents of Palo Alto and surrounding areas who are homeless or at risk of homelessness.
4 Project Name 2024 Silicon Valley Independent Living Center (SVILC): Case Management
Target Area Citywide
Goals Supported Strengthen Neighborhoods
Needs Addressed Community Services and Public Improvements Funding CDBG: $14,075
Description Case Management.

Eligible Activity (Matrix Code): 05B, Handicapped Services CDBG National Objective: LMC
Target Date 6/30/2025
Estimate the number
and type of families
that will benefit from
the proposed activities
25 unduplicated Palo Alto residents will benefit from one-on-one housing assistance.

Location Description Citywide

FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 30

Planned Activities Silicon Valley Independent Living Center (SVILC) project activities assist very low income Palo Alto residents with disabilities and their families with their housing search for affordable, accessible housing. Funding would support the Housing and Emergency Services for Persons with Disabilities Program and case management services. The Program provides education & training on all aspects of how to conduct a housing search to transition from homelessness, health care facilities, or unstable, temporary housing into safe, long -term community -based housing. It includes group workshops, one-on-one service training, and access to IL (Independent Living) services, including emergency food assistance, security deposits/rent (as funding allows), information & referral to ensure the long-term sustainability of housing. 5 Project Name 2024 Project Sentinel – Fair Housing Services Target Area Citywide
Goals Supported Fair Housing
Needs Addressed Fair Housing
Funding CDBG: $15,575
Description Fair Housing Services.

Eligible Activity (Matrix Code): O5J, Fair Housing Activities CDBG National Objective: LMC 24 CFR 570.208(a)(2)
Target Date 6/30/2025
Estimate the number
and type of families
that will benefit from
the proposed activities
12 unduplicated low and moderate income individuals will be provided with fair housing services of complaint counseling, investigation, and where appropriate enforcement referral.

Location Description Citywide
Planned Activities Project Sentinel’s project activities include fair housing counseling and investigative services for Palo Alto residents through casework, increase knowledge of fair housing laws and individual counseling on the fair housing laws to improve understanding of residents' and housing providers' rights or obligations. Funding would provide operating expenses for these fair housing services.
6 Project Name 2024 WeeCare/Upwards
Target Area Citywide
Goals Supported Economic Development
Needs Addressed Economic Development
Funding CDBG: $120,000
Description WeeCare/Upwards assists Family Childcare Home microenterprise businesses and will provide business improvement services to such businesses in the City.

Eligible Activity (Matrix Code): 18B Economic Development-Technical Assistance. CDBG National Objective LMCSV
Target Date 6/30/2025

FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 31

Estimate the number
and type of families
that will benefit from
the proposed activities
15 daycare microenterprises will benefit from this project. Plus, the possibility of new full-time jobs will be created by WeeCare/Upwards.

Location Description Citywide
Planned Activities WeeCare/Upwards, a for-profit organization, project activities support their BOOST program for low -income Family Child Care Home (FCCH) providers in Palo Alto. The BOOST program provides specialized technical assistance and business support for income qualifying FCCH’s. 7 Project Name 2024 Rebuilding Together Peninsula (RTP)– Safe at Home Target Area Citywide
Goals Supported Affordable Housing
Needs Addressed Affordable Housing
Funding CDBG: $73,585
Description Eligible Activity (Matrix Code): 14A
National Objective LMH 24 CFR 570.202(a)(1)
Target Date 6/30/2025
Estimate the number
and type of families
that will benefit from
the proposed activities
5 LMI households will benefit from home improvements.

Location Description Citywide
Planned Activities RTP project activities preserve affordable housing by transforming homes at no cost to the service recipient. The majority of the low- income homeowners served will be elderly seniors and/or people with disabilities, who are physically and or financially unable to maintain safe living conditions for themselves and their families. Funding covers the costs of home repair, such as construction materials and payment of subcontractors.
8 Project Name 2024 Community Work Group/Abode – Alma Garden Target Area 2024 Alma Garden Apartments 2507-2533 Alma Street, Palo Alto, CA 94306
Goals Supported Affordable Housing
Needs Addressed Affordable Housing
Funding CDBG: $404,800
Description Eligible Activity (Matrix Code): 14B
National Objective LMH 24 CFR 570.202(a)(1)
Target Date 6/30/2025
Estimate the number
and type of families
that will benefit from
the proposed activities
10 LMI households will benefit from apartment unit improvements.

Location Description Citywide

FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 32

Planned Activities Community Work Group/Abode project activities include rehabilitating rental housing units in Alma Garden, an affordable multi-family housing complex for extremely low income households, to address existing health and safety concerns. Funding would be spent on a project manager, bathroom upgrades, exterior repairs, and electrical and water utility upgrades.
9 Project Name 2024 Fire Station – Sidewalk Improvements Project Target Area City-Wide
Goals Supported Strengthen Neighborhoods
Needs Addressed Community Services and Public Improvements Funding CDBG: $62,645.61

Description This project will focus on renovations of sidewalks, curbs, and curb ramps located at 3600 Middlefield Road.

Eligible Activity (Matrix Code): 03L, Sidewalks
National Objective LMC
Target Date 9/30/2025
Estimate the number
and type of families
that will benefit from
the proposed activities
331 LMI households
Location Description 3600 Middlefield Rd, Palo Alto, CA 94303, Fire Station No.4 Planned Activities Plan, design and reconstruct the sidewalk, curbs and curb ramps at the intersection area of Meadow Drive and Middlefield Road. The anticipated project requires a contractor bidding process and has an estimated completion timeframe of 18 months.
10 Project Name 2024 Homekey Palo Alto – Recreation Project Target Area City-Wide
Goals Supported Homelessness
Needs Addressed Homeless
Funding CDBG: $185,000
Description This project will provide an on-site play structure and area at the HomeKey Palo Alto shelter.

Eligible Activity (Matrix Code): 03C, Homeless Facilities National Objective LMC
Target Date 6/30/2025
Estimate the number
and type of families
that will benefit from
the proposed activities
104 households annually
Location Description 1237 San Antonio Road
Planned Activities LifeMoves, this homeless service provider will manage the design and construction of recreation area and recreation equipment within the Homekey Palo Alto shelter property. The anticipated project completion timeframe is 12 months.
11 Project Name 2024 Planning & Administration

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Target Area Citywide
Goals Supported Strengthen Neighborhoods
Needs Addressed Community Services and Public Improvements Funding CDBG: $114,730
Description Eligible Activity (Matrix Code): 21A, General Program Administration Planning and Administration: CDBG Citation: 570.206(a)
Target Date 6/30/2025
Estimate the number
and type of families
that will benefit from
the proposed activities
The City will provide general administrative support to the CDBG program.

Location Description Citywide
Planned Activities Administer the administrative costs for the overall management, coordination, and evaluation of the CDBG program, and the project delivery costs associated with bringing projects to completion. 12 Project Name 2024 CDBG-CV MOVE Mountain View – Safe Parking Program Target Area City-Wide
Goals Supported Homelessness
Needs Addressed Homelessness
Funding CDBG: $110,000
Description MMW operates and provides homeless services at multiple approved Safe Parking Lots in Palo Alto. Case managers helping assist homeless individuals staying on approved parking lots.

Eligible Activity (Matrix Code): 03T, National Objective LMC Target Date 6/30/2025
Estimate the number
and type of families
that will benefit from
the proposed activities
150 individuals will be assisted through the safe parking program.

Location Description Citywide
Planned Activities CDBG funds will be used for case management staff salaries working with the MMV Safe Parking Program. Establishing housing partnership with property owners and landlords. Rather than solely referring clients to existing housing opportunities, MOVE MV case managers and or housing specialists forge direct connections by facilitating client sponsorship in rental placement. Beneficiaries include vehicle dwellers and other homeless persons living in Palo Alto parking lots. 13 Project Name 2024 CDBG-CV Planning & Administration
Target Area City-Wide
Goals Supported Strengthen Neighborhoods
Needs Addressed Community Services and Public Improvements Funding CDBG: $9,478.74
Description Planning and Administration: CDBG Citation: 570.206(a) Target Date 6/30/2025

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Estimate the number
and type of families
that will benefit from
the proposed activities
The City will provide general administrative support to the CDBG-CV program.

Location Description Citywide
Planned Activities Administer the administrative costs for the overall management, coordination, and evaluation of the CDBG-CV program, and the project delivery costs associated with bringing projects to completion.

AP-50 Geographic Distribution - 91.420, 91.220(f)
Description of the geographic areas of the entitlement (including areas of low -income and minority concentration) where assistance will be directed.

The City allocates CDBG funds to benefit low-moderate income (LMI) households and does not have any designated target areas. Instead, the City focuses CDBG funds on public services, housing preservation, economic development-business assistance, and capital improvements across the City as a whole.

Geographic Distribution
Target Area Percentage of Funds
Citywide 100%
Table 7 - Geographic Distribution

Rationale for the priorities for allocating investments geographically This question is not applicable to Palo Alto’s program.

Discussion
See discussion above.

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AP-75 Barriers to affordable housing -91.420, 91.220(j) Introduction
The City of Palo Alto is committed to providing equitable opportunities to all residents of Palo Alto in order to expand access to housing and increase housing mobility. The City will take action to overcome patterns of segregation, address disparities in housing needs and access to opportunity, and foster inclusive communities. The City’s Housing Element contains a listing of action s established to reduce the barriers to affordable housing, including but not limited to racial inequities, high housing and land costs, regulatory constraints, and public resistance. Currently the City is experiencing a constrained housing supply market, so when housing developments produce housing units that are considered “relatively” affordable, higher- income buyers and renters outbid lower-income households. Subsequently, a home’s final sale or rental price may exceed the projected sales or rental costs. Public subsidies are often needed to guarantee affordable homes for low- and moderate-income households. The City wants to ensure adequate planning is undertaken to provide its “fair share” of affordable and market-rate housing, demonstrating a strategy for removing barriers to increase housing production that addresses today’s housing shortage.

To address the requirements of AB 686, the City participate d in the 2020 -2025 Santa Clara County Consolidated Plan (ConPlan). The County’s ConPlan identifies eight housing goals for the County and each of its participating jurisdictions, including Palo Alto. Additionally, the ConPlan identifies regional and local barriers to fair housing around the region, with heavy emphasis on racial and economic disparity, land use and zoning, and lack of assistance and resources. Programs were identified to reduce barriers in the City, including adjusting zoning amendments to expand affordable and alternative housing opportunities and increasing accessibility to information.

Actions it planned to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment.

Palo Alto is addressing the barriers to affordable housing through:
• Density Bonus Ordinance: The City recently updated its Density Bonus Ordinance, which lowered the eligibility requirements to qualify for a higher density bonus percentage up to 80% and provided more exceptions to applicable zoning and development sta ndards. One significant update is if a 100% affordable development is located within half a mile of a major transit stop, the City cannot impose any density limits and is entitled to a maximum height increase of three additional stories or 33 feet.
• Remove Density requirements in certain zoning districts. • Below Market Rate (BMR) Housing Program: Established in 1974, the City’s BMR requires developers to provide a certain percentage of units as BMR in every approved project of three units or more. The progra m originally required that for developments on sites of less than five acres, the developer must provide 15 percent of the total housing units as BMR housing units. If

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the site was larger than five acres, the developer was required to provide 20 percent of the units as BMR housing. The City of Palo Alto has historically used in -lieu fees and development impact fees charged on new, market- rate housing and/or commercial development to finance 100% affordable developments. The City updated its Commercial and R esidential Impact Fee Nexus Studies and adopted two ordinances making changes to its BMR program and adopted a new fee structure. The ordinances became effective on June 19, 2017. • Fair Housing: Protect tenants from displacement through more robust tenant p rotections and better access to legal services. The City annually provides CDBG funding to Project Sentinel, a non- profit entity that provides expertise in fair housing law and tenant -landlord disputes. Program services include information, referrals, community outreach, and education. In addition, Project Sentinel resolves fair housing complaints via investigation, mediation, education and outreach to both property owners and tenants about fair housing policies. • Fair Housing: Increase access to lending opportunities for residents of historically low -income communities of color.
• Housing Incentive Program (HIP): Effective May 2, 2019, the HIP was enacted as an alternative to the State Density Bonus law and provides development incentives including no housing density restrictions, increased floor area ratios and increased lot coverage. The HIP is available to specific areas of the City where higher-density development is encouraged. • Affordable Housing (AH) Combining District: In 2018, the City Council adopted the Affordable Housing Combining District to provide flexible development standards beyond the State Density Bonus Law to allow 100% affordable housing projects located in a commercially zoned area. • Workforce Housing (WH) Combining District: The City Council also adopted in 2018 the Workforce Housing Combining District to encourage the development of housing within half -mile of major fixed rail transit by modifying flexible development standards for the public facilities (PF) zoning district.
• The average Palo Alto home, as of February 1, 2023 , costs about 8 times the national average home price, and the monthly rent is about 2.5 times the national average. • Title 18 (Zoning) Relating to Accessory Dwelling Units and Junior Accessory Dwelling Units:

The City recently updated amended its Ordinance Title 18, which included “the development of a single -family home, ADU, and/or a JADU on a lot t hat allows for single -family development shall not be considered a multifamily development pursuant to PAMC Section

18.04.030, nor shall they require Architectural Review pursuant to other sections of Chapter

18. In addition to addressing the square footage height restrictions, 18.09.040 • The City Amended Chapter 9.68 (Rental Housing Stabilization) of the Municipal Code to expand just cause eviction protections to Palo Alto renters, including reducing the minimum time period

FY2024-25 ANNUAL ACTION PLAN DRAFT Page | 37

required for renters to qualify for just cause eviction protections.

Discussion
Please see above.

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AP-85 Other Actions - 91.420, 91.220(k)
Introduction
The following provides a description of today's obstacles and or barriers to meeting LMI or underserved populations, including vulnerable populations, housing preservation needs, lead -paint issues, increased earning capacity for LMI households, city delivery structure for supporting needed services, and regional approaches to serving and helping the homeless populations.

Actions planned to address obstacles to meeting underserved needs The City collaborative works with social service providers, affordable housing developers , housing preservation entities, fair housing and homeless assistance agencies to address obstacles to permanent housing for all residents. To address this, the City supplements its CDBG funding with other resources and funds, such as:
• Support social services entities including Alta Housing and Catholic Charities that provide needed supportive services for extremely low-income and or elderly residents. • In FY 2022-23, the City’s Human Service Resource Allocation Process (HSRAP) provided $622,377 from the General Fund in support of human services. The HSRAP funds, in conjunction with the CDBG public service funds, are distributed to local non-profit agencies. • Support low income persons with disabilities. Provide CDBG funds to Sil icon Valley Independent Living Center (SVILC) with case management needs.
• Support the city’s homeless population through CDBG awards and other funding sources to:

LifeMoves Shelter and proposed Homekey Palo Alto shelter development project. • The Housing A uthority of the County of Santa Clara (HACSC) administers the federal Section 8 program countywide. The program provides rental subsidies and develops affordable housing for low-income households, seniors and persons with disabilities living within the County. • Continue to locally support, through General City Funds, the Downtown Streets Team to reduce homelessness through a “work first” model. Downtown Streets Team uses its community connections to provide training and job opportunities to homeless people, specifically in the downtown area.

Actions planned to foster and maintain affordable housing The City will foster and maintain affordable housing by continuing the following programs and ordinances:
• Support low income homeowners through annual CDBG allocat ions for housing rehabilitation .

Provide CDBG funds to Rebuilding Together Peninsula to preserve existing affordable housing stock. The City is also planning an affordable housing rehabilitation and replacement project, Buena Vista Mobile Home Park that will benefit approximately 270 residents. • Support Community Work Group (Abode ) with CDBG funds to preserve 10 affordable housing

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units.
• Annual CDBG allocations to Rebuilding Together Peninsula to preserve existing affordable housing stock.
• A Business Tax was approved in late 2022 to fund affordable housing, public safety, homeless services, rail crossing safety, and general city services. • The Below Market Rate Emergency Fund, which provides funding on an ongoing basis for loans to BMR owners for special assessment loans and for rehabilitation and preservation of the City’s stock of BMR ownership units.
• Apply to both the State of California HOME program, and the County’s HOME Consortium to fund supported affordable housing projects.
• The Commercial Housing Fund and Residential Housing Fund are used by the City to assist new housing development or the acquisition, rehabilitation, or the preservation of existing housing for affordable housing.
• The Density Bonus Ordinance regulations allow for bonuses of 20 to 35 percent, depending on the amount and type of affordable housing provided.
• The City’s participation in the County's HOME Consortium will allow developers of affordable housing projects to be eligible to competitively apply through an annual RFP process directly to the County for HOME funds to help subsidize affordable housing projects in Palo Alto, including acquisition, construction, and rehabilitation.
• The City is collaborating with Santa Clara County and Eden Housing in the development of Michell Park Place, a new affordable housing development project providing 50 affordable units located in one of the City’s LMI census tracts.

Actions planned to reduce lead-based paint hazards
The City’s housing and CDBG staff provides technical assistance, information , and referrals to property owners, developers, and non -profit organizations rehabilitating older housing about lead -based paint (LBP) hazards. Any house to be rehabilitated with City financial assistance is required to be inspected for the existence of LBP and LBP hazards. The City will provide financial assistance for the abatement of LBP hazards in units rehabilitated with City funding. The City also requires that contractors be trained and certified in an effort to decrease the risk of potential use of LBP in new units. All development and rehabilitation projects must be evaluated according to HUD’s Lead Safe Housing Rule 24 CFR Part 35 .

Rebuilding Together Peninsula, through its housing rehabilitation program, ensures each rehab includes lead-based paint assessment and mitigation on impacted areas for each housing case.

Actions planned to reduce the number of poverty-level families The City, in its continuing effort to reduce poverty, will prioritize funding agencies that provide direct assistance to the homeless and those in danger of becoming homeless. In FY 2024-25, these programs will include the following:
• LifeMoves provides basic necessities for persons who are homeless or at risk of becoming

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homeless. The Opportunity Services Center is a comprehensive, one-stop, multi-service, day drop- in center that provides critical services for homeless Palo Alto reside nts. Specifically, the facility provides showers, laundry, clothing, snacks, case management, and shelter/housing referral services.
• Homekey Palo Alto, although not CDBG funded, is supported by the City and other state and federal resources to build a new interim housing shelter that will serve over 200 individuals annually. This new facility includes 88 rooms with interior shows and restrooms. • Alta Housing provides counseling and supportive case management services for low -income residents of single -room occupancy facilities to help them maintain housing stability. Activities include financial counseling, health maintenance, information, and referral, problem -solving, employment assistance, crisis intervention, and case management. • WeeCare provides business services and best management practices for small daycare businesses in the City. Many of which provide childcare for LMI families. • Buena Vista Mobile Home Park development project, although not CDBG funded, is supported by the City to replace, and increase the number of residential units in the development. Plus improve neighborhood amenities include walking trails, bulk trash removal, new water/sewer infrastructure.

Actions planned to develop institutional structure
The administration of the City’s CDBG program requires collaboration between several departments including the finance department, administration, Human Services, and Planning and Development Services Department staff. The Planning and Development S ervices Department assigns critical staff to manage project development, subrecipient contracting and technical assistance, consultant management, collaboration with public works departme nt staff, and fund draws and activity spending.

The Finance Department assists in the process by reconciling CDBG and City budget accounts and draw approvals. The Human R elations Commission and Council hold public hearings and recommend recommendations and final approvals of annual CDBG project activities and projects.

The City strives to improve intergovernmental and private sector cooperation to synergize efforts and resources and develop new revenues for community service needs and affordable housing pr oduction.

Collaborative efforts include:
• Regular meetings between entitlement jurisdictions at the CDBG Housing Coordinators meetings and Regional Housing Working Group.
• Joint jurisdiction Request for Proposals and project review committees. • Collaborations between the City’s housing and public works departments. • Coordination on project management for projects funded by multiple jurisdictions. • HOME Consortium meetings between member jurisdictions for affordable housing projects.

Actions planned to enhance c oordination between public and private housing and social

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service agencies.

The City benefits from a strong jurisdiction and region -wide netwo rk of housing and community development partners, such as the County and the Continuum of Care. To improve intergovernmental and private sector cooperation, the City continues to participate with other local jurisdictions and developers in sharing information and resources.

In FY 2024 -25, the City award ed CDBG funds to the Alma Garden project for the preservation of 10 residential very low income rental units.

The City is collaborating with Santa Clara County and Eden Housing in the development of Michell Park Place, a new affordable housing development project providing 50 affordable units located in one of the City’s LMI census tracts.

In addition to the actions listed above, the City continue s to coordinate with the City’s Human Relations Commission on funding efforts to address community needs comprehensively.

Discussion
Please see discussions above.

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Program Specific Requirements
AP-90 Program Specific Requirements - 91.420, 91.220(l)(1,2,4) Introduction
Community Development Block Grant Program (CDBG) Reference 24 CFR 91.220(l)(1) Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in pro jects to be completed.

Community Development Block Grant Program (CDBG)
Reference 24 CFR 91.220(l)(1)
Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in projects to be carried out.

1. The total amount of program income that will have been received before the start of the next program year and that has not yet been reprogrammed 60,000

2. The amount of proceeds from section 108 loan guarantees that will be used during the year to address the priority needs and specific objectives identified in the grantee's strategic plan. 0

3. The amount of surplus funds from urban renewal settlements 0

4. The amount of any grant funds returned to the line of credit for which the planned use has not been included in a prior statement or plan 0

5. The amount of income from float-funded activities 0
Total Program Income: 60,000

Other CDBG Requirements

1. The amount of urgent need activities 0

2. The estimated percentage of CDBG funds that will be used for activities that benefit persons of low and moderate income. Overall Benefit - A consecutive period of one, two or three years may be used to determine that a minimum overall benefit of 70% of CDBG funds is used to benefit persons of low and moderate income. Specify the years covered that include this Annual Action Plan. 100.00%

Discussion
Please see the discussion above.

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Appendices

APPENDIX A
Public Comments
The City held two Advertised public hearing on February 8, 2024, and June 18, 2024. The draft CDBG FY2024-25 Annual Action Plan dated February 1, 2024 was circulated for public comments and reviewed from March 13, 2024, through April 12, 2024. No public comments were received during this 30-day public comment and review period time. No public comments were received to date, June 3, 2024. All comments will be accepted and recorded once received. Any written comments received will be in the public participation document.

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APPENDIX B
Public Notices

• Publication October 2, 2023: Notice of CDBG and CDBG-CV Funding Availability (NOFA) • Publication January 24, 2024: Notice of Public Review, Comment Period, and Public Hearing for the FY 2024-25 Community Development Block Grant (CDBG) Annual Action Plan • Publication March 13, 2024: Notice of Public Review, Comment Period , and Public Hearing for the Fiscal Year (FY) 2024-25 Community Development Block Grant (CDBG) Annual Action Plan • Publication June 3, 2024: Correction Notice - Public Hearing Date Change, Notice of Public Review and Public Hearing for the Fiscal Year ( FY) 2024-25 Community Development Block Grant (CDBG ) Annual Action Plan
•

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APPENDIX C
Application for Federal Assistance SF-424 Forms and Certifications

(to be completed and signed after City Council action on the CDBG FY 2024-25 Annual Action Plan)

Palo Alto City CouncilJune 18, 2024

Palo Alto City Council
June 18, 2024