housing stabilization retention rates,
or comparative program efficiency evaluations.
Instead, the Council and public are largely presented with generalized descriptions of services and broad statements regarding community benefit. That is not sufficient for evidence based public budgeting. A public funding recommendation without measurable performance analysis is not strategic governance. It is administrative inertia.
2. THE REPORT TREATS PUBLIC SERVICE FUNDING AS A PASS-THROUGH ENTITLEMENT
SYSTEM RATHER THAN A COMPETITIVE ACCOUNTABILITY PROCESS One of the clearest examples is the proposed $4,215 funding adjustment involving ECHO Housing and the Rent Mediation/Eviction Protection category. The staff report frames the adjustment as a technical response to HUD allocation changes. However, the public is never shown:
whether demand exceeded available assistance,
whether alternative programs were evaluated,
whether the funding produces measurable prevention outcomes, whether eviction prevention efforts are succeeding,
or whether the City has established objective prioritization criteria for these allocations.
The report effectively assumes that continuation equals justification, and that is sequentially backwards. Programs should justify continuation through demonstrated outcomes, not through historical participation alone.
3. THE ACTION PLAN FAILS TO CONFRONT THE CITY’S UNDERLYING FISCAL
UNSUSTAINABILITY
The broader issue is that Union City continues expanding expectations for publicly subsidized services without demonstrating how those services remain sustainable as operational costs escalate.
The report repeatedly discusses:
assistance,
services,
outreach,
community support,
and program expansion,
while largely avoiding:
long term cost drivers,
operational liabilities,
staffing sustainability,
pension exposure,
infrastructure burdens,
and realistic revenue limitations.
At some point the City must confront a difficult but unavoidable reality because public services are not self-executing. Every additional subsidy, service expansion, outreach initiative, tenant assistance program, homelessness intervention effort, or administrative compliance obligation requires:
staffing,
overhead,
enforcement,
reporting,
technology,
legal review,
and ongoing fiscal support.
Yet the Action Plan rarely discusses sustainability in concrete operational terms. Instead, the report reads as though federal dollars exist outside ordinary fiscal gravity when in reality, they do not.
4. THE REPORT COMPLETELY FAILS TO ADDRESS REGIONAL DEMAND PRESSURES AND
NON-RESIDENT SERVICE BURDENS
One of the most glaring omissions in the entire Action Plan is the absence of meaningful discussion regarding regional demand burdens on Union City services and facilities.
Many publicly funded programs increasingly operate in environments where:
non resident usage,
regional displacement pressures,
housing spillover,
transit adjacency,
and broader Bay Area affordability dynamics substantially affect local demand.
Yet the report provides almost no serious discussion regarding:
resident versus non resident utilization,
regional service migration,
proportional taxpayer burden,
or whether Union City residents are effectively subsidizing broader regional pressures.
That omission matters because finite local resources are being allocated within a metropolitan environment where service demand increasingly crosses jurisdictional boundaries. If the City is not measuring those impacts, then the City is not fully evaluating program sustainability.
5. THE REPORT PRESENTS EQUITY LANGUAGE WITHOUT DEFINING WHAT SUCCESS
ACTUALLY LOOKS LIKE
The Action Plan repeatedly invokes concepts such as:
equity,
inclusion,
affordability,
accessibility,
and vulnerable populations.
Those are important goals, but the report rarely translates those concepts into measurable operational standards.
The public is not told:
what specific outcomes define success,
how success is measured,
when programs are considered ineffective,
whether any programs have underperformed,
whether any applicants were rejected,
or whether any funded organizations failed prior performance expectations.
Without those standards, “equity” risks becoming a procedural justification rather than an evaluative framework. Public policy cannot be measured solely by intent. It must be measured by outcomes.
6. THE CITY’S CDBG PROCESS REMAINS INSUFFICIENTLY TRANSPARENT The report also fails to provide meaningful visibility into the underlying allocation process itself.
The public is not provided:
complete scoring rubrics,
ranking matrices,
evaluation narratives,
reviewer identities,
conflict disclosures,
comparative applicant analysis,
or detailed justification explaining why some organizations were prioritized over others.
This is especially problematic because many nonprofit funding ecosystems become institutionally selfperpetuating over time. Once organizations enter recurring funding pipelines, there is often little structural incentive for rigorous reevaluation unless governments deliberately impose strong accountability frameworks. The City should not assume continuation funding is politically or operationally neutral.
Every recurring allocation represents an ongoing public prioritization decision.
7. THE ACTION PLAN REFLECTS A BROADER GOVERNANCE PATTERN IN WHICH THE CITY
EXPANDS EXPECTATIONS WITHOUT MATCHING STRUCTURAL ACCOUNTABILITY This issue extends beyond CDBG.
Increasingly, Union City public reports:
emphasize aspirations,
emphasize values,
emphasize inclusivity,
emphasize outreach,
emphasize expansion of services,
while comparatively underemphasizing:
enforcement capacity,
operational sustainability,
cost recovery,
fiscal constraints,
measurable outcomes,
and long-term maintenance obligations.
The result is that public expectations continue expanding while the structural discussion surrounding how the City realistically sustains those expectations remains underdeveloped.
That imbalance is becoming increasingly visible across multiple policy areas.
8. REQUEST FOR SUPPLEMENTAL ANALYSIS AND GREATER PUBLIC DISCLOSURE Before future CDBG allocations are approved, the City should provide:
detailed scoring matrices,
measurable program outcome metrics,
cost effectiveness comparisons,
resident versus non resident utilization analysis,
longitudinal program evaluations,
rejected application summaries,
fiscal sustainability projections,
and clearer standards defining program success or failure.
The public should not be asked to approve recurring federal funding allocations based primarily on generalized descriptions and goodwill assumptions.
9. CONCLUSION
The issue before the Council is not whether community services matter- they do. The issue is whether Union City is building a durable, transparent, performance-based allocation framework capable of surviving escalating fiscal pressures, increasing regional demand, and growing operational complexity.
At present, the Action Plan reads less like a rigorous accountability document and more like a continuation mechanism for existing funding structures.That is not enough. If the City expects public confidence in its allocation decisions, then future reports must move beyond generalized narratives and begin presenting the hard operational, fiscal, demographic, and performance data necessary for meaningful public oversight.
Respectfully Submitted,
Henry Soong