TO:Andrew P. Powers, City Manager
FROM:Kelvin Parker, Community Development Director
DATE:May 7, 2024
SUBJECT: FY 2024-25 Community Development Block Grant Action Plan RECOMMENDATION:
1. Find that the federally funded activities related to the FY 2024-25 Community Development Block Grant (CDBG) Action Plan qualify for a Categorical Exemption under the California Environmental Quality Act (CEQA) Guidelines pursuant to Section 15301, Existing Facilities, and Section 15061(b)(3), Common Sense Exemption.
2. Find that the federally funded activities related to the FY 2024-25 CDBG Action Plan qualify for the following National Environmental Policy Act (NEPA) exemptions: a) “Categorically Excluded Subject to 58.5 Statutory Worksheets” and activities are categorically excluded and subject to 24 CFR 58.35(a)(3)(i) or 24 CFR 58.35(a)(3)(ii) and activities converted to exempt under 24 CFR 58.34(a)(12); b) “Categorically Excluded Not Subject to 58.5” and are exempt under 24 CFR
58.35(b)(2) or 24 CFR 58.34(a)(4); and c) exempt from determination under 24 CFR 58.34(a)(3).
3. Approve for submittal to U.S. Department of Housing and Urban Development (HUD) FY 2024-25 CDBG Action Plan.
4. Approve budget appropriation in FY 2024-25 in the amount of $39,400 from A/C #120-0000-438-1000 (CDBG Fund Revenue - Federal Grants/CDBG) as follows:
$38,400 to A/C #120-1010-644-5920 (CDBG Fund Expenditure - Consultant/Contractual Grants and Donations) and $1,000 to A/C #120-1010-644- 6920 (CDBG Fund Expenditure - Administrative Costs).
5. Authorize City Manager to adjust the budget and proposed allocations if HUD revises the amount of the City’s FY 2024-25 CDBG grant; and authorize City Manager to finalize and execute grant agreements and related documents in connection with FY 2024-25 CDBG Action Plan.
LEVINE ACT ITEM: Yes
FY 2024-25 Community Development Block Grant Action Plan May 7, 2024
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3 FINANCIAL IMPACT:
$39,400 Increase to Adopted FY 2024-25 CDBG Fund Budget Fully offset by $39,400 Increase to Adopted FY 2024-25 CDBG Revenue Fund Budget. $575,000 is included in the Adopted FY 2024-25 CDBG Fund Budget. In addition, there is $32,423.85 in unused funds previously approved with prior CDBG grants, which is being reprogrammed for FY 2024-25 projects. The City’s anticipated FY 2024-25 CDBG Grant from HUD is $614,380.00 and $646,803.35 is the estimated total cost for projects, public services, and administration for FY 2024-25. From this funding, $115,803.85 will be used to offset grant administrative costs.
BACKGROUND:
Ventura County Regional Consolidated Plan (RCP)
The RCP is the five-year strategic umbrella plan for CDBG, HOME Investment Partnerships (HOME), and Emergency Solutions Grants (ESG) funding plans. The City, as a participating jurisdiction, annually updates the County’s long-range plan with an Action Plan that sets forth expenditures for that year’s CDBG funding.
In 2020, the County of Ventura formed HOME Consortium in partnership with the cities of Camarillo, Simi Valley, and Thousand Oaks, allowing HUD HOME funds to be managed regionally by the County of Ventura with an annual budget of $1.4 million. Prior to 2020, the City and non-profit affordable developers were under the very competitive State HOME Program from which the City last received a funding award in 2009.
The RCP includes the following high-priority needs for Thousand Oaks:
•Assistance for Senior Residents
•Homelessness
•Homeownership Opportunities
•Housing Support and Stability
•New Rental Housing
•Rehabilitation & Preservation of Existing Housing Units •Social Services
Community Development Block Grant (CDBG)
As part of the CDBG program, HUD annually distributes an entitlement grant to U.S. counties and cities. These funds may be used for community improvements, such as housing, public facilities, and infrastructure, as well as grants to non-profit organizations delivering public and social services to the City’s low-income residents.
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3 HUD regulations allow the City to use up to 20 percent of the annual grant to recover administrative costs to implement the CDBG program. HUD regulations also allow the City to use up to 15 percent of the annual grant to provide public and social services grants. At least 70 percent of all CDBG-funded activities must primarily benefit lower-income persons.
The CDBG grant amount fluctuates from year to year. This report proposed FY 2024-25 CDBG Action Plan for the City to be $646,803.85, which includes the City’s share of the annual Federal CDBG entitlement of $614,380.00 and prior year’s unused funds of $32,423.85.
DISCUSSION/ANALYSIS:
Housing shortages, extremely low vacancy rates, and the high costs of living in the City have caused many families and individuals to experience housing insecurity, homelessness, and/or the risk of becoming homeless. Maintaining existing multi- family and single-family affordable housing units is an important component of supporting the housing needs of City residents. Additionally, the City strives to support the local provisions of "essential" public and social services for vulnerable populations and very low-income individuals and households. This includes those who are unhoused or at risk of homelessness, the elderly, and residents with disabilities.
Annual Needs Assessment
The annual “Community Needs Assessment” was conducted for 70 days from November 1, 2023, to January 10, 2024, in accordance with the City's Citizen Participation Plan (City Council Resolution No. 2020-013). In this process, the City solicited public comments and applications from community stakeholders for potential CDBG-funded activities that would address the unmet needs of at-risk Thousand Oaks residents.
On Thursday, November 16, 2023, the City held an administrative “Needs Assessment” public hearing and CDBG grant workshop via both online and in- person attendance. Nineteen members of the public were present in person or via videoconference, representing 13 diverse organizations. Eight speakers provided testimony during the public comment portion of the meeting or at the workshop.
At the end of the needs assessment period on January 10, 2024, the City received 13 applications, of which nine were for CDBG Public Services and four were for CDBG Community Development Projects.
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3 CDBG Grant Review Committee
The CDBG Grant Review Committee (Committee) was composed of City staff from the City Manager’s Office, and the Community Development and Finance Departments.
Prior to opening the application period, the Committee was tasked with creating the application, instructions, and evaluation guidelines. The Committee reviewed and assessed each application using a criterion and scoring matrix specific to the CDBG-funded programs.
All activities were assessed to ensure applicants followed federal rules, identified a community need, and proved that the proposed activity was ready to be implemented in a timely manner. The Thousand Oaks Housing Element goals and the priority list from the 2020-2024 Ventura County Regional Specific Plan were among the resources used by the Committee.
Due to limited funding, the Committee recommended approval for organizations that provided unduplicated and essential services, addressed previously identified priority needs within the City, had strong financial management skills, and had a reasonable understanding of HUD standards. The Committee’s application recommendations to the proposed CDBG Action Plan are summarized in Attachment #1. All new application activities are expected to begin July 1, 2024.
Proposed FY 2024-25 CDBG Action Plan Activities
The City’s FY 2024-25 Action Plan proposes CDBG-funded activities for the fifth year of the 2020-2025 Ventura County Regional Consolidated Plan. The County of Ventura, as the lead agency for the HOME Consortium, will be submitting documents to HUD.
The City expects to receive $614,380.00 in CDBG funds for the FY 2024-25 Action Plan. Additionally, $32,423.85 is available for reallocation from the 2021 and 2022 CDBG closed activities. The total FY 2024-25 CDBG budget is $646,803.85, as summarized in Attachment #2.
During the preparation of the draft Action Plan for the 30-day public review period, which started on April 2, 2024, HUD had not yet announced the specific amount of the HUD entitlement grant. In past years, HUD has made changes to the grant amount. For example, HUD cut the overall CDBG grant for 2020 by $88 and raised the total CDBG grant allocation for 2021 by $8,445. Should HUD’s authorized entitlement grant amount differ from the expected amount, City staff requests authorization for the City Manager to adjust the CDBG budget and execute grant FY 2024-25 Community Development Block Grant Action Plan May 7, 2024
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3 agreements and related documents in connection with the FY 2024-25 CDBG Action Plan accordingly.
CDBG Community Development Project Budget: $440,000
The City received four proposals totaling $626,000 for Community Development activities. Three applications were for housing rehabilitation and one application was for childcare micro-enterprise.
With redevelopment funds no longer available, projects that rehabilitate existing multi-family and single-family affordable units are a high priority for the City. These projects are significant because they assist very low and low-income households who are at risk of becoming homeless. The three recommended FY 2024-25 CDBG projects and program activities are expected to benefit approximately 94 units occupied by very low and low-income Thousand Oaks residents as described in Table 1.
Table 1: CDBG Community Development Projects
Agency Activity Budget
Many Mansions Bella Vista project includes the
installation of a security camera system
for the entire property, renovating the
gazebo, installing new lights, and painting
(72 affordable units) HS9263
$172,000
Habitat for Humanity of
Ventura County
Habitat Home Repair Mobile Home
Rehab for Low-Income Owner/Occupants
(10 units) HS9264
$134,000
Senior Alliance for
Empowerment (SAFE)
Mobile Home Rehab for Low-Income
Senior Owner/Occupants (12 units)
HS9265
$134,000
Total Community Development Project $440,000
CDBG Public/Social Services Budget: $91,000
Nine proposals totaling $205,000 were received for Public / Social Services. The City supports the local delivery of essential public and social services to persons who are homeless or at risk of homelessness, and very low-income households who are disabled or seniors. The five recommended FY 2024-25 CDBG public service activities are expected to benefit approximately 712 extremely low, very low, and low-income Thousand Oaks residents as described in Table 2.
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3 Table 2: CDBG Public/Social Services
Agency Non-Homeless Programs Budget
Many Mansions Community Services to Many Mansions
residents (500 clients) BG9828
$23,000
Conejo Valley
Senior Concerns
Meals on Wheels (150 clients) BG9818 $15,000
St. Paschal Baylon /
St. Vincent de Paul
Assistance to Needy (30 clients) BG2029 $15,000
Total Non-Homeless Program $53,000
Agency Homeless Program Budget
Turning Point
Foundation
Our Place Safe Haven: Emergency Shelter
and Navigation Center (9 clients) BG9835
$23,000
Harbor House Seasonal Shelter (23 clients) BG9836 $15,000 Total Homeless Program $38,000
Total Non-Homeless and Homeless Programs $91,000
CDBG Administration Budget: $115,803.85
For FY 2024-25, the CDBG Program administration budget is expected to be $115,803.85, which is below the 20 percent maximum allowable threshold to recover a portion of CDBG costs. The administration budget includes City staff, issuance and publishing of public notices, printing, and overhead costs to ensure CDBG programs are monitored and in compliance with HUD’s regulations and requirements. The budget includes preparing for and implementing the Ventura County Regional Consolidated Plan and the Analysis of Impediments to Fair Housing Choice/Affirmatively Furthering Fair Housing. In addition, the budget includes the County of Ventura Fair Housing Program, a service provided free to all Thousand Oaks residents.
Environmental Review
The recommendations were reviewed pursuant to the California Environmental Quality Act (CEQA) and staff determined that all FY 2024-25 CDBG proposed activities are exempt from CEQA.
•The housing rehabilitation activities are exempt from CEQA pursuant to Section 15301 Existing Facilities, which consists of “the operation, repair, maintenance, permitting, leasing, licensing, or minor alteration of existing public or private structures, facilities, mechanical equipment, or topographical features, involving negligible or no expansion of existing or former use.”
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3 •Although Public Service Programs and CDBG Administration provide various services to people, they do not propose any physical change to the environment. Therefore, they are exempt pursuant to Section 15061(b)(3) of the State CEQA Guidelines, in that they are “covered by the commonsense exemption that CEQA applies only to projects which have the potential for causing a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA.”
The recommendations were reviewed pursuant to the National Environmental Policy Act (NEPA) and staff determined that all FY 2024-25 CDBG proposed activities are exempt or converted to exempt.
•Housing Rehabilitation activities were reviewed under the “Categorically Excluded Subject to 58.5 Statutory Worksheets” for rehabilitation of minor rehabilitation of single-family homes 24 CFR 58.35(a)(3)(i) and multifamily buildings 24 CFR 58.35(a)(3)(ii). These activities are categorically excluded subject to 24 CFR 58 and converted to exempt under 24 CFR 58.34(a)(12). •Public Service activities are “Categorically Excluded Not Subject to 58.5” and are exempt under supportive (public) service under 24 CFR 58.35(b)(2) or 24 CFR 58.34(a)(4).
•Administration is exempt from determination under 24 CFR 58.34(a)(3).
Community Outreach
During the drafting of the Action Plan, the City used the following methods to reach out to the community:
•Legal notice in the local newspaper of record, the Ventura County Star. •Prominent display ad in the Thousand Oaks Acorn, a free newspaper widely read by Thousand Oaks residents.
•City’s website on the Community Development Department page.
Notices were also provided to the local public housing authority, the Area Housing Authority of the County of Ventura, and Many Mansions for distribution to their residents.
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3 The 2024-25 Action Plan was prepared in collaboration with public and local stakeholders. A draft copy of the Action Plan was posted to the City’s website and available at the City Hall Community Development public counter for public review for 30 days, from April 2, 2024 to May 3, 2024. All public comments received throughout the review process, including those received at the public hearing, will be incorporated into the final Action Plan document that will be presented to HUD.
An electronic copy of the proposed Action Plan is provided under separate cover for review by City Council, and a copy is posted on the City’s website at:
http://www.toaks.org/departments/community-development/planning/phd LEVINE ACT (California Government Code § 84308):
This item is subject to the Levine Act. City Councilmembers who have received a campaign contribution of more than $250 (aggregated) within the preceding 12 months from a party or their agent/representative, or a financially-interested participant involved in this proceeding may do either of the following: (1) disclose the contribution on the record and recuse themselves from this proceeding; or if applicable (2) return the portion of the contribution that exceeds $250 within 30 days from the time the official knew or should have known about the contribution, and participate in the proceeding.
All parties and their agents/representatives must disclose on the record of this proceeding any aggregated contribution of more than $250 made to any Councilmember within the preceding 12 months. Councilmembers are prohibited from accepting, soliciting, or directing a campaign contribution of more than $250 (aggregated) from a party, their agent/representative, or a financially interested participant during a proceeding and for 12 months following the date a final decision is made. In addition, a party, their agent/representative, or a financially interested participant is prohibited from contributing more than $250 (aggregated) to a Councilmember during a proceeding and for 12 months following the date a final decision is made.
COUNCIL GOAL COMPLIANCE:
Meets the following City Council goals:
A. Create a more equitable, accessible, safe, welcoming, and inclusive government and community regardless of race, color, ethnicity, religion, sex, physical or mental ability, sexual orientation, gender identity and expression, age, language, education, and/or socio-economic status.
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3 C. Operate City government in a fiscally and managerially responsible and prudent manner to ensure that the City of Thousand Oaks remains one of California's most desirable places to live, work, visit, recreate, and raise a family.
H. Participate in public-private and multi-jurisdictional opportunities to ensure residents have access to high levels of parks, recreation, education and leisure programs and services.
PREPARED BY: Lynn Oshita, Community Development Analyst Attachments:
Attachment #1 – 2024-25 CDBG Recommended Activities Summary Attachment #2 – 2024-25 CDBG Action Plan Budget
Documents Provided Under Separate Cover:
#1 – 2024-25 CDBG Action Plan –
http://www.toaks.org/departments/community-development/planning/phd cdd:480-70\ H:\COMMON\Housing & Redevelopment\2024 CDBG\2024 COUNCIL\ACTION PLAN