Cities Index.
1 - Approval request for the United States Department of Housing and Urban Development (HUD) required draft Fiscal Year 2024-2025 Annual Action Plan, allocating Federal Community Development Block Grant (CDBG) and Home Investment Partnership Program (HOME) funds

Victorville City Council
May 7, 2024

Document
1 - Approval request for the United States Department of Housing and Urban Development (HUD) required draft Fiscal Year 2024-2025 Annual Action Plan, allocating Federal Community Development Block Grant (CDBG) and Home Investment Partnership Program (HOME) funds
Meeting
May 7, 2024
Body
Victorville City Council
Original file
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Text extracted from the city's file for reading and search. Open the original on victorvilleca.primegov.com. That file is the official record.

Item Number: {{item.number}}
City Council / Board of Directors
Public Hearing(s)
Meeting of: May 7, 2024
Submitted By:

Scott Webb, City Planner

Subject:

Approval request for the United States Department of Housing and Urban Development (HUD) required draft Fiscal Year 2024-2025 Annual Action Plan, allocating Federal Community Development Block Grant (CDBG) and Home Investment Partnership Program (HOME) funds.

Recommendation:

That the Honorable City Council:
(1) Conduct a public hearing to receive citizen, public and agency comments regarding the draft Fiscal Year 2024-2025 Annual Action Plan;
(2) Approve Resolution No. 24-033 - Adopting the 2024-2025 Annual Action Plan, as presented for submittal to HUD, which contains the funding recommendations made by the Community Planning and Development (CPD) Grant Subcommittee; (3) Authorize the City Manager to execute all necessary documents for submittal to HUD; and
(4) Approve the continued inclusion of operating restrictions for food distributors/ providers, as recommended by the CPD Grant Subcommittee, within applicable subrecipient contracts.

Fiscal Impact:

Taking action in accordance with the staff recommendation will appropriate approximately $1,987,246 in fiscal year 2024-2025 Federal CDBG and HOME funds allocated to the City of Victorville and will reallocate $450,000 in fiscal year 2022-2023 & 2023-2024 CDBG funds to be dispersed to eligible applicants as outlined in the 2024-2025 Annual Action Plan. Fiscal year 2024-2025 CDBG funding includes a total allocation of $1,381,396 that has no matching requirement, while HOME funding includes a total allocation of $605,850, which has a matching requirement that has been waived by HUD due to the City being considered in fiscal distress (based upon poverty rate and per capita income). Except for CDBG and HOME administration costs not covered in full by limited 3 6
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grant allowances (e.g. portions of City staff time, facilities use, etc.), the subject funding will not utilize City monetary assets.

In summary, the City of Victorville’s annual budget for Fiscal Year 2024-2025 shall reflect additional revenue and expenditures in the amount of $1,381,396 (CDBG - City Org. 2813025) in Fiscal Year 2024-2025 Federal CDBG allocations, $605,850 (HOME – City Org. 2823027) in Fiscal Year 2024-2025 Federal HOME allocations, and $450,000 (CDBG – City Org. 2813025) in reallocated CDBG funding from Fiscal Years 2022-2023 & 2023-2024.

Strategic Plan Goal:

Approval of the draft Fiscal Year 2024-2025 Annual Action Plan will formally allocate available CDBG/HOME funds, as well as reallocate previously received CDBG funds, which will enable the City to further fulfill the following Goals outlined in the 2024-2026 Strategic Plan:
• Goal A (Financial Sustainability) – Community Development Block Grant (CDBG) and HOME Investment Partnership (HOME) funds represent funding opportunities that require limited financial commitments while ensuring greater availability of general fund resources.
• Goal D (Reduce Homelessness) – Eligible activities such as public service and housing projects are aimed to directly benefit the homeless population as well as those at risk of homelessness, providing the City an opportunity to expand the outreach network and partnerships.

Executive Summary:

The purpose of the request for approval of the 2024-2025 Annual Action Plan (Attachment A) is to allow the City of Victorville to apply for and obtain Federal Community Development Block Grant (CDBG) and Home Investment Partnership (HOME) funding, which is a one-year allocation plan intended to implement the previously adopted 2022- 2026 Consolidated Plan (ConPlan). The Annual Action Plan is the formal means to apply for CDBG and HOME funds per federal standards and approval of this document will direct the allocation/reallocation of over $2.4 million in CDBG and HOME funds during fiscal year 2024-2025. In accordance with the priority needs and goals outlined in the 2022-2026 ConPlan, the Annual Action Plan directs yearly funding to programs that also meet the national objectives of benefiting low and moderate income persons, aids in the elimination of slums and blight, and meets local community needs. A brief synopsis of the ConPlan and Annual Action is provided below.
2022-2026 Consolidated Plan
•A five-year planning document that was last approved on April 19, 2022, and is utilized to guide the City’s use of CDBG and HOME funds through June 30, 2027. •Based upon community input received through two in person workshops in Old Town Victorville, five separate community stakeholder meetings, a digital and written survey, 3 6
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as well as two City Council public hearings on the item, the ConPlan established priority needs and set goals with quantifiable deliverables to ensure the federal funding is spent in a manner that benefits the residents of the City of Victorville, specifically low- and moderate-income residents.
•The ConPlan is supported by additional studies such as a Housing Needs Assessment, a Housing Market Analysis, an Analysis of Impediment to Fair Housing Choice, and other strategies to ensure the ConPlan reflects local issues of importance in a manner suited to address the City’s priorities.
•The City reports yearly on the progress made in meeting the goals outlined in the ConPlan through the completion of the Consolidated Annual Performance and Evaluation Report (CAPER) to confirm funds are being directed in a manner consistent with the ConPlan.
2024-2025 Annual Action Plan
•Attachment B contains the funding components of the FY 2024-2025 allocation of $2,437,246 in CDBG/HOME funds, which includes $450,000 of reallocated CDBG funds and $605,850 of HOME funds.
•The 2024-2025 Annual Action Plan is the third year of the five year cycle of the 2022- 2026 ConPlan and directs the use of new federal funding from July 1, 2024, through June 30, 2025.
•The Action Plan establishes a one-year expenditure plan for the use of HUD funds and enables the implementation of the priority housing and community development needs identified in the 2022-2026 ConPlan.
•Funding recommendations are based upon qualified proposals that are compliant with the priority needs outlined in the ConPlan, their feasibility to utilize funding in accordance with the ConPlan and federal standards, as well as the availability of funds. Final recommendations are made by the CPD Grant Subcommittee after reviewing and analyzing all applications in a public meeting.

Background:

CDBG/HOME & CDBG-CV Funding Administration
The City of Victorville is a recipient of U.S. Department of Housing and Urban Development (HUD) funds, which include Community Development Block Grant (CDBG) and HOME Investment Partnerships Grant (HOME) that are administered by HUD’s Office of Community Planning and Development (CPD).

The Planning Department is responsible for the administration of the City’s CDBG and HOME grants. CDBG & HOME funded programs and projects must reflect the needs outlined in the City’s Consolidated Plan (ConPlan). The ConPlan is a five-year planning 3 6
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document required by HUD from all communities receiving community development funds. The ConPlan is carried out through Annual Action Plans, which provide a concise summary of the actions, activities and the specific federal and non-federal resources that will be used each year to address the priority needs and specific goals identified by the ConPlan. The current ConPlan was originally approved by the City Council on April 19, 2022, for fiscal years 2022-2026. The following two subsections of this report describe the process for this coming year’s Annual Action Plan for CDBG and HOME funds. 2024-2025 Annual Action Plan Process
On December 19, 2023, the City Council appointed Mayor Becerra and Mayor Pro Tem Harriman to serve on the Community Planning and Development (CPD) Grant Subcommittee. The purpose of the CPD Grant Subcommittee with regard to CDBG/HOME grant programs is to review all eligible grant applications and determine consistency with the needs and goals established in the City’s Consolidated Plan.

On March 5, 2024, the City Council conducted a public hearing to obtain citizen, agency, and prospective applicant comments regarding the City’s needs and strategies for the 2024-2025 Annual Action Plan. Following the public hearing, the CPD Grant Subcommittee met on March 26, 2024, to review and recommend allocation of $1,831,396 of CDBG funds, which includes $450,000 of reallocated funds (Attachment B), as well as $605,850 of HOME Investment Partnerships Program (HOME) funds. The draft 2024-2025 Annual Action Plan (Attachment A) describes the programs and projects the CPD Grant Subcommittee recommended for CDBG fund disbursement. HOME funds are discussed within the Entitlement City Tasks and Requirements (Attachment D) and not included in the 2024-2025 Annual Action Plan since the HOME funds are allocated to the consortium between Victorville and Apple Valley. Victorville’s HOME funds will be included in Apple Valley’s Annual Action Plan since Apple Valley serves as the lead agency for the consortium. Additionally, the CPD Grant Subcommittee Recommendations (Attachment C) include the final recommendations made for each eligible CDBG/HOME application received and twenty-four separate projects/programs are recommended for a funding allocation.

Copies of the draft Annual Action Plan were made available for public review and comment as required by HUD beginning April 1, 2024, through April 30, 2024. All public comments received during this public hearing and the public comment period will be attached and incorporated into the Annual Action Plan with submittal to HUD occurring after approval by the City Council.

CDBG/HOME Funding Sources
In 1997, the City of Victorville became an Entitlement City with HUD. This status allows the City to receive CDBG funds directly from HUD. Prior to Victorville’s status as an Entitlement City, CDBG funding was awarded to the City of Victorville through the County of San Bernardino and was subject to projects/programs that fulfilled a countywide need rather than those specific to the City.
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The City of Victorville successfully formed a consortium in 2003 with the Town of Apple Valley in order to meet the threshold of obtaining HOME entitlement status with HUD.

The successful formation of the consortium results in an annual allocation of HOME funds to both communities, which can be used in concert with CDBG funding to address specific needs within the City of Victorville.

Discussion:
2024-2025 Annual Action Plan
Approval of the 2024-2025 Annual Action Plan will establish a one-year expenditure plan for the use of HUD funds and enable the implementation of the priority housing and community development needs identified in the 2022-2026 ConPlan. Included in the Annual Action Plan are the programs and projects proposed for fiscal year 2024-2025 funding, which have been reviewed and recommended for approval by the CPD Grant Subcommittee. As proposed, projects not recommended for CDBG funding maintained sufficient unspent funding from previous years allocations, or were determined to be ineligible or inconsistent with funding priorities.

HUD annual allocations to the City of Victorville for fiscal year 2024-2025 include $1,381,396 in CDBG funds and $605,850 in HOME funds. These allocations are approximate at this time pending the release of the Federal budget; however, in previous years allocations have historically increased by approximately 1% - 3% in CDBG funds and approximately 2% - 4% in HOME funds. These two HUD programs will provide almost $2 million to the City of Victorville and can be used for services that assist low- to moderate-income persons. Also included in available funding is $450,000 in reallocated funds from fiscal years 2022-2023 & 2023-2024, which are available due to projects that were cancelled by the subrecipient, allocated funding declined, or projects that did not meet HUD guidelines. Specifically, the subject Annual Action Plan (and the Town of Apple Valley’s 2024-2025 Annual Action Plan with regard to HOME funds) includes proposed funding to the following projects:

Organization / Project Name Allocation
CDBG Public Service Projects
Assistance League of Victor Valley / Operation School Bell $10,000 High Desert Second Chance / Food Collaborative $40,000
High Desert Second Chance / Senior & Veteran Program $10,000 Inland Fair Housing and Mediation Board / Fair Housing Services $24,000 Legal Aid Society of San Bernardino / C.A.R.E. Legal Services $18,000 Moses House Ministries / Family Resources & Referrals $20,000 Partners Against Violence / Victim of Violence Program $15,000 Symba Center / Medical & Behavioral Health Program for Homeless $30,000 Victor Valley Domestic Violence / A Better Way $20,000
City of Victorville / Motel Voucher Program $20,209
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Organization / Project Name Allocation
CDBG Construction / Other Projects
Route 66 Historic Museum / Restroom Construction and Rehabilitation $150,000 Victor Valley Community Services Council / Senior Home Repair $30,000 Victorville Senior Citizens Club / Parking Lot Repair $100,000 Economic Development Department / Old Town Façade Improvement $300,000 Code Enforcement Department – Abatement $50,000
Code Enforcement Department – Code Enforcement $150,000 Code Enforcement Department – Demolition $100,000
Planning Department - Residential Rehabilitation Program $101,908 Planning Department – Wellness Center Solar Panels/Carport $210,000 Planning Department – Wellness Center Fill Station & Water Fountain $6,000 Public Works Department – Brentwood LMAD Beautification $150,000 CDBG Administration
Administration $276,279
HOME Housing Projects
Senior Home Repair Program $223,541
Hughes Training and Development $230,847
Community Housing Development Organization (CHDO) Project Northgate Village Apartments - 15% minimum required allocation $90,878
Administration $30,292
The total amounts of the subject CDBG and HOME categories are provided in the following tables, which includes the minimum/maximum requirements implemented by HUD. Staff finds that the proposed funding recommendations comply with the applicable HUD standards and requirements. Additionally, the HOME administration allocations are in accordance with a consortium agreement in place with the Town of Apple Valley who acts as the lead agency on HOME matters and retains a maximum of 50% of the City’s HOME administration allocation ($60,584 / 2 = $30,292) with appropriate documentation supporting such.

CDBG Allocations
Project Type Proposed Funding Comments
Public Service Projects $207,209 Maximum allowed by HUD-15% Construction/Other Projects $1,347,908* Minimum allowed by HUD-20% Administration $276,279 Maximum allowed by HUD-20%
TOTAL (2024-2025) $1,831,396
*Includes $450,000 in reallocated FY 22-23 & FY 23-24 CDBG funds 3 6
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HOME Allocations
Project Type Proposed Funding Comments
Housing Projects $454,388 Maximum allowed by HUD-N/A
CHDO Projects $90,878 Minimum allowed by HUD-15%
Administration –
Victorville’s portion $30,292
Administration – Apple
Valley’s portion of
Victorville’s share
$30,292
(Maximum w/
documentation)
Maximum allowed by HUD-10%
TOTAL (2024-2025) $605,850
Further discussion on the funding categories noted above is located in the attached “Entitlement City Tasks & Requirements” document (Attachment D), which includes specific information on the funding considerations and methodology used to compose the 2024-2025 Annual Action Plan in accordance with HUD guidelines and standards.

Subrecipient Operating Restrictions
While HUD grant funds are typically allocated without specific operating restrictions, allocations in previous years have been awarded in some instances with contract language to ensure funds are spent to serve the City of Victorville residents or are provided in accordance with the City’s Zoning Ordinances. Therefore, the CPD Grant Subcommittee has recommended inclusion of the following contract language relating to food distribution activities being recommended for HUD funding, which was also included in their recommendation for Fiscal Year 2023-2024 CDBG/HOME funding. “The City of Victorville’s Homelessness Strategic Action Plan prioritizes the establishment of strategic partnerships with service providers to proactively house the unsheltered homeless population. With this in mind, it is imperative to establish rules of engagement for partnering food service providers that give direct or indirect aid to the unsheltered homeless in Victorville. This is necessary to achieve the desired outcome of housing the unsheltered and reducing associated environmental impacts.

Subrecipients of CDBG funds and their partnering feeding agencies shall ensure their employees and/or volunteers adhere to the following operating standards when providing direct assistance to unsheltered homeless:
•Service providers shall coordinate mobile food distribution with the Victorville Homeless Engagement Outreach Division of the Code Compliance Department to ensure additional resources are provided to the unsheltered individuals; •Service providers shall not distribute daily meals from a fixed location unless the food is served and consumed on the premises and all necessary land use, building permits and any applicable permits issued by the San Bernardino County Department of Environment Health have been obtained; and
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•Service providers shall monitor areas where food has been distributed to collect and dispose of debris associated with the food distribution (e.g. bags, cartons, utensils, food waste).

Subrecipients that distribute food to feeding agencies that serve the Victorville unsheltered homeless population are required to list those agencies in their required CDBG reporting and reimbursement requests. Prior to distributing food to these feeding agencies, subrecipients shall obtain a signed acknowledgment from the feeding agencies to abide by the food distribution requirements listed above. Said acknowledgment(s) shall be provided to the City of Victorville with the CDBG reporting or reimbursement request.” Based on the information provided in this report, staff recommends that that Honorable City Council proceed with approving the 2024-2025 Annual Action Plan in accordance with staff’s recommendations listed on Page 1 of this report. Staff will be available to answer questions during the public hearing.

Attachments: A. Resolution No. 24-033 (2024-2025 Annual Action Plan) B. 2024-2025 CDBG/HOME Anticipated Funding
C. 2024-2025 CPD Grant Subcommittee Recommendations
D. Entitlement City Tasks and Requirements
E. CDBG Target Area Maps

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