CITY OF POMONA
COUNCIL REPORT
May 16, 2022
To: Honorable Mayor and Members of the City Council From: James Makshanoff, City Manager
Submitted By: Benita DeFrank, Neighborhood Services Director SUBJECT: APPROVING THE DRAFT FY 2022-2023 ANNUAL ACTION PLAN WITH PROPOSED FUNDING RECOMMENDATIONS ______________________________________________________________________________ RECOMMENDATION:
It is recommended that the City Council take the following actions:
Adopt the following resolution:
RESOLUTION NO. 2022-58 – A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF POMONA, CALIFORNIA, APPROVING THE DRAFT FY 2022-2023 ANNUAL ACTION PLAN WITH PROPOSED FUNDING FOR COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG), HOME INVESTMENT PARTNERSHIPS (HOME), AND EMERGENCY SOLUTIONS GRANT (ESG) FEDERAL ENTITLEMENT PROGRAMS (ATTACHMENT NO. 1) Approve draft funding awards for the Fiscal Year (FY) 2022-2023 Community Development Block Grant (Exhibit A) and Emergency Solutions Grant (Exhibit B) Programs; Approve funding recommendations for the FY 2022-2023 Home Investment Partnerships Program; and Approve the inclusion of funding awards in the FY 2022-2023 Annual Action Plan.
EXECUTIVE SUMMARY:
Annually, the City receives entitlement funds from the U.S. Department of Housing and Urban Development (HUD) to address housing, homelessness, community and economic development needs under the following programs: Community Development Block Grant (CDBG), HOME Investment Partnerships (HOME) and Emergency Solutions Grant (ESG) Programs. As a condition of receipt of these funds, an Annual Action Plan must be submitted to HUD. The Annual Action Plan focuses primarily on the specific activities that the City will undertake and fund for FY 2022-2023 to meet priority needs.
FISCAL IMPACT: The Fiscal Year 2022-23 Entitlement Allocations for CDBG, HOME and ESG have not been released by HUD. The anticipated funding is $3,100,717 and is based on prior year funding levels. As these are entitlement funds, they are included as revenue estimates, with corresponding expenditures in the FY 2022-23 Proposed Budget as Special Funds.
Staff expects to return to Council on July 18, 2022 with the revised funding recommendations, that will proportionately increase or decrease estimating funding levels to match actual amounts awarded by HUD.
PUBLIC NOTICING REQUIREMENTS: Notice was published on May 5, 2022, in the Inland Valley Daily Bulletin for the May 16, 2022 and July 18, 2022 Public Hearings (Attachment No. 6).
DISCUSSION:
Based on prior funding levels, the City of Pomona is estimated to receive the following allocations: CDBG: $2,043,385; HOME: $880,191; and ESG: $177,141. The total anticipated funding is $3,100,717. The FY 2022-2023 Annual Action Plan provides a 1-year roadmap for spending these funds on activities that benefit low- to moderate- income persons.
Citizen Participation
To ensure citizen and stakeholder participation in the development of the Action Plan, outreach efforts included mailing informational postcards to over 43,500 households, informing them of community meeting dates and requesting their input via a Community Needs Survey (Attachment No. 5). Due to COVID-19 restrictions and required safety protocols, no in-person meetings were conducted for stakeholder feedback. Community meetings were held virtually via ZOOM and surveys were made available online at the City’s website and at the City Hall Housing counter. The Community Needs Survey was available on-line in English and Spanish beginning October 26, 2021. The final date for submission of the FY 2022-23 survey was January 31, 2022. Approximately 290 surveys were received.
Annual Fund Amounts
The City anticipates receiving the following entitlement allocations for FY 2022-23:
2022-23 ENTITLEMENT ALLOCATIONS & REALLOCATED FUNDS
AMOUNT
Community Development Block Grant (CDBG)
$2,043,385
HOME Investment Partnership Program (HOME)
$880,191
Emergency Solutions Grant (ESG)
$177,141
ENTITLEMENT ALLOCATIONS TOTAL
$3,100,717
The Annual Action Plan is due to HUD forty-five days prior to the start of the fiscal year or no later than August 16, 2022 for this application cycle. The draft Annual Action Plan is available for public review beginning May 16, 2022 through July 18, 2022. This public hearing is the first of two meetings required to approve the Annual Action Plan for submission.
Community Development block grant (CDBG) Program
The primary purposes of (CDBG) Program funds are to: 1) provide decent housing; 2) provide a suitable living environment; and 3) expand economic opportunities, principally for low-to-moderate income persons. In accordance with the CDBG national objectives, an activity must meet one of three objectives: 1) serve low-moderate income persons; 2) aid in the elimination of slum and blight; or 3) address recent, urgent health or welfare needs (e.g., natural disaster). An activity may be eligible because it either benefits an area (activity serves a census tract which has 51% or more low-moderate income persons) or a limited clientele (persons and families with low-to-moderate income). More than 70% of all funds must be expended to assist low-to- moderate income persons and families. The City plans to expend 100% of CDBG funds to benefit low-to-moderate income persons and families.
Community Development Block Grant Low and Moderate Income Area Benefit The Low and Moderate Income Area (LMA) benefit category is the most commonly used national objective for activities that benefit a residential neighborhood. An area benefit activity is one that benefits all residents in a particular area, where at least 51% of the residents are Low to Moderate Income (LMI) persons. The LMA is determined by census data at the block group level, which is a smaller subset of the census tract. By City Council policy, within the City of Pomona, funding is distributed to each Council District based on the percentage of LMA within each district.
LMA percentages for each Council District are attached and staff will be utilizing funding percentages for CDBG district allocations (See Attachment 1 - Exhibits A & B and Attachment 2). Regardless of District allocations or percentage, project expenditures can only be made within the current HUD recognized LMA (Attachment 3) or on projects related to eligible LMI residents).
Community Development Block Grant Eligible Activities
Eligible activities fall into five general categories: Administration/Planning, Housing, Economic Development, Public Service, or Capital Improvement. Certain activities are not eligible, including single event functions, contingency funds, on-going clean-up activities, or improvements to buildings and areas for the general conduct of government (except in the case of improvements designed to assist the disabled in public areas as required by the Americans with Disabilities Act).
Listed below is the breakdown of proposed CDBG funding allocations for FY 2022-23, based on HUD requirements. The amounts provided under “capped” categories are rounded to the nearest dollar amount to ensure that these regulatory caps are not exceeded.
CDBG CATEGORY
AMOUNT
CAP
Public Service
$ 306,507
(15% cap)
Non-Public Service Activities
$1,328,201
(No cap)
Administration
$ 408,677
(20% cap)
TOTAL AVAILABLE FUNDING: $2,043,385
Citywide
Based on input from the Community Needs Survey (Attachment No. 5) and from City departments, there is a need for CDBG-funded citywide activities that otherwise could not be provided. These include projects that have been funded previously such as parks and recreation services, infrastructure projects, anti-crime programs and code enforcement. However, addressing homelessness is now ranked as the highest priority per residents. As such, the fiscal impact of a reduction or loss of CDBG funding would require the City to fund these activities from the General Fund or to significantly reduce and/or eliminate many of these services that principally benefit low-to-moderate income residents of the City. Staff is proposing additional service programs designed to meet high priority needs. Citywide needs were given a priority in funding recommendations and include:
Code Enforcement
Infrastructure – ADA Path of Travel
Community Oriented Policing Program
Fair Housing Services
Housing Services
Homeless Services Programs
Public Service Programs
Housing Improvement Programs
Request for Proposal submittals, Late Requests, and Rejections:
This year, the City received 23 applications for CDBG funds, excluding Administration. Of the 23, there were 12 applications from Community-Based Organizations (CBOs) and 11 from City Departments. All applications were reviewed and recommended for funding by the Grants Administration Committee. Also, CBO applications were reviewed by the Community Life Commission (CLC). The CLC was provided a list of the 12 CBO agencies that were deemed eligible, along with performance information for agencies previously funded. The CLC recommended all 12 proposals for funding consideration (Attachment No. 4).
CDBG Program Administration
A total of $408,677, or twenty percent of the total anticipated CDBG funding allocation, is available in FY 2022-2023 for Administration of the CDBG program, including general management, oversight, and coordination and monitoring of programs. HUD requires that municipalities cap administration costs at 20 percent of the total funding allocation.
Public Service Category
The City has received a number of public service requests from City departments, as well as from community agencies. Based on community input, there is a continuing need for youth services, homeless services, and services to seniors. There is also an ongoing need for activities focused on safety and security. Staff is proposing a continuation of CDBG funding for the Police Department's Community Problem Oriented Policing (CPOP) Program. This program provides one officer for community policing and ombudsmen services in the City's residential low-to-moderate income neighborhoods. Under CDBG regulations, this program is considered to be a public service activity.
Another high priority need this year will be for Homeless Services. There is a public service request for a CDBG Homeless Services Program to provide an increase in services to the homeless.
The City also recommends funding after school recreation and youth programs. Public agency requests include youth services, leadership development, homeless services, counseling, food programs, education and services to victims of domestic violence.
The following table is a breakdown of available FY 2022-23 public service funds, including Federally-mandated Fair Housing Services in the amount of $30,000, which is included in the HUD-required 15 percent public services cap.
CATEGORY
AMOUNT
Fair Housing Services
$ 30,000
Other Public Service Activities
$ 276,507
TOTAL AVAILABLE FUNDING: $306,507
Non-Public Service Category
Non-public services include capital improvements, housing programs and Code Enforcement. In the Code Enforcement Division, the cost of operations and personnel are shared with the City’s General Fund. This is based on the percentage of time spent in CDBG-eligible areas versus time spent in non-CDBG eligible areas. In accordance with Federal requirements, staff has identified target areas in which to concentrate CDBG-funded Code Enforcement activities. These activities target areas that are based on a variety of factors, including the number of police reports, the number of code complaints filed, the number of abatements performed and the existence of Neighborhood Watch organizations within the area and those areas that are considered deteriorated. Areas must also be designated as slum and blighted areas.
In addition, staff is proposing to fund Housing Services in an effort to maintain current housing programs and staff to provide loan processing, housing counseling, preparation of work specifications in housing related projects, and housing inspections. Staff is also proposing continued infrastructure improvements based on Council direction, specifically ADA curb ramp improvements as proposed in consultation with the Public Works Department. Finally, the non-public service category includes $13,000 for federally mandated Section 108 Loan re-payments.
HOME Investment Partnerships PROGRAM (HOME)
HOME funds are used for the preservation and creation of affordable housing. Eligible activities include Single-Family Housing Rehabilitation, Multi-Family Housing Rehabilitation, First-Time Home Buyer Programs and Tenant-Based Rental Assistance. Below is a listing of eligible categories for the HOME Program and estimated funding levels.
CATEGORY
AMOUNT
CAP
Community Housing Development Organizations
$ 132,028
(15% cap)
Administration
$ 88,019
(10% cap)
Tenant Based Rental Assistance (TBRA)
$ 0
(no cap)
First-Time Homebuyer Program
$ 400,000
(no cap)
Single-Family Housing Rehabilitation
$ 260,144
(no cap)
TOTAL AVAILABLE FUNDING: $880,191
Emergency Solutions Grant Program
Emergency Solutions Grant (ESG) program activities place emphasis on moving homeless persons from tentative, unstable living situations to more permanent, stable housing, and self-sufficiency.
These activities fall under six basic funding categories as listed below, pursuant to the Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009 (HEARTH Act), enacted into law on May 20, 2009. Each category requires a mandated 100% match for funds expended, except for Administration. To meet this obligation, each agency receiving ESG funds from the The City is required to identify the source of its matching funds as part of the application process. The City operated programs provide match through the salaries of non-ESG funded staff that assist in administering the ESG grant. Any amounts funded for Street Outreach, Emergency Shelter and Administration cannot exceed the statutory caps as regulated by HUD. The categories and suggested funding amounts for FY 2022-23 appear below:
ESG CATEGORY
AMOUNT
CAP
Homeless Prevention
$0
(No cap)
Street Outreach
$0
(60%cap)
Emergency Shelter
$106,284
(60% cap)
Rapid Re-Housing
$0
(No cap)
HMIS
$ 57,572
(No cap)
Administration
$ 13,285
(7.5% cap)
TOTAL AVAILABLE FUNDING: $177,141
The City did not solicit a Request for Funding Proposals for Homeless Services using ESG funds for FY 2022-23 because funds will be directed to the City’s Hope for Home Services Center. ESG funds will be utilized primarily for shelter operations. The total funding available for ESG activities is $177,141.
Preliminary Funding Recommendations
Preliminary funding recommendations, as submitted by staff, are based on priorities as established by prior year funding, Councilmember input, resident survey data and the good standing of agencies as established through annual performance evaluations. Under the direction of the Council, staff is authorized to bring the applications for funding to the City Council for a public hearing on May 16, 2022. The final meeting for adoption of the Annual Action Plan is tentatively scheduled for July 18, 2022. Staff hopes that the Entitlement Allocations have been released before this time. The Annual Action Plan is due to HUD no later than August 16, 2022.
Prepared by:
Isabel Abundis
Housing Analyst
ATTACHMENT(S):
Attachment 1 – Resolution No. 2022-58
Exhibit “A” -2022-2023 CDBG Funding Options
Exhibit “B” -2022-2023 ESG Funding Options
Attachment 2 – CDBG Formula Allocations
Attachment 3 – CDBG Eligible Areas Map
Attachment 4 – RFP Funding Requests/Eligibility/Performance Summary Attachment 5 – 2022-2023 Community Needs Survey
Attachment 6 – Public Notice
Approval of Draft FY 2022-23 Annual Action Plan Funding Recommendations