To: Board of Supervisors
From: John Kopchik, Director, Conservation and Development
Report Title: Allocation of FY 2024/25 CDBG, HOME, and ESG Funds and Approval of FY 2024/25 Action Plan
☒Recommendation of the County Administrator ☐ Recommendation of Board Committee
RECOMMENDATIONS:
1. FIND the FY 2024/25 Annual Action Plan exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3) of the CEQA guidelines;
2. APPROVE and ADOPT the Draft FY 2024/25 Annual Action Plan (Attachment A);
3. APPROVE the Family and Human Services Committee recommendations for the allocation of $849,500 in FY 2024/25 Community Development Block Grant (CDBG) funds in the Public Services (PS) category (Attachment B-1) and $369,404 Emergency Services Grant (ESG) funds (Attachment B-2);
4. APPROVE the Finance Committee recommendations for the allocation of $345,700 in FY 2024/25 CDBG funds in the Economic Development (ED) category (Attachment C-1) and the allocation of $369,196 in the Infrastructure/Public Facilities (IPF) category (Attachment C-2);
5. APPROVE the Department of Conservation and Development’s recommendations for the allocation of $3,824,557 in FY 2024/25 CDBG funds in the Housing category and $5,040,063 in HOME Investment Partnership Program (HOME) funds (Attachment D), as recommended by the Department of Conservation and Development Director;
6. DIRECT the Department of Conservation and Development Director, or designee, to file a CEQA Notice of Exemption for the FY 2024/25 Annual Action Plan with the County Clerk;
7. AUTHORIZE the Department of Conservation and Development Director, or designee, to execute the program certifications and applications (SF-424's) for transmittal to the U.S. Department of Housing and Urban Development (HUD); and
8. AUTHORIZE the Department of Conservation and Development Director, or designee, to execute CDBG and ESG program agreements with the recommended organizations for the recommended activities, as approved and adopted in the FY 2024/25 Annual Action Plan by the Board of Supervisors.
FISCAL IMPACT:
There is no General Fund impact. All funds are provided to Contra Costa County on a formula basis through the U.S. Department of Housing and Urban Development (HUD).
Catalog of Federal Domestic Assistance Numbers:
• CDBG Program - 14.218
• HOME Program - 14.239
• ESG Program - 14.231
BACKGROUND:
The primary objective of the CDBG program is to develop viable urban communities by providing decent housing, a suitable living environment, and expanded economic opportunities, primarily for low-income persons and households (persons/households earning no more than 80 percent of the Area Median Income). CDBG funds are allocated on an annual formula basis to eligible entitlement jurisdictions, including Contra Costa County, by the U.S. Department of Housing and Urban Development (HUD). The County's Department of Conservation and Development (DCD) administers CDBG funds on behalf of the "Urban County." The Urban County includes the unincorporated County and all incorporated cities and towns except the cities of Antioch, Concord, Pittsburg, and Walnut Creek. Those specific cities administer independent CDBG programs. The County's CDBG Program will be entering its fiftieth year. On November 4, 2014, the Board of Supervisors adopted funding guidelines for the use of CDBG funds to specific activity categories as follows: Housing - 45 percent; Public Services (PS) - 17 percent; Economic Development (ED) - 10 percent; Infrastructure/Public Facilities (IPF) - 8 percent; and Program Administration - 20 percent.
The HOME program aims to expand the supply of decent, safe, sanitary, and affordable housing for very low and low-income households. HUD allocates HOME funds to eligible participating jurisdictions and HOME consortia on a formula basis. The Contra Costa HOME Consortium (Consortium) consists of the Urban County and the cities of Antioch, Concord, Pittsburg, and Walnut Creek. As the Consortium representative, DCD is responsible for administering and managing the HOME program for the Consortium.
Contra Costa County, as an entitlement jurisdiction, receives ESG program funds on an annual formula basis from HUD for use in funding renovation, rehabilitation, or conversion of buildings for use as emergency shelters for persons experiencing homelessness; provision of essential services for people without housing, emergency shelter operations and related services, and homelessness prevention and rapid-rehousing activities. DCD administers the ESG program funds on behalf of the Urban County.
FY 2024/25 Annual Action Plan Process and Funding Recommendations
Contra Costa County, as an entitlement or participating jurisdiction, is entitled to receive CDBG, HOME, and ESG funds from HUD each year for housing and community development activities. To receive these annual awards of federal funds, the County must submit to HUD a strategic plan, called the Consolidated Plan, every five years. The Consolidated Plan identifies priorities of local needs and general objectives on how these needs will be addressed. As part of the Consolidated Plan process, the County must submit an Annual Action Plan for each year during the five-year Consolidated Plan period. An Annual Action Plan specifies and describes what actions and activities will be carried out during the program year to address priority needs identified in the County's current Consolidated Plan, and identifies the use and amount of CDBG, HOME, and ESG funds and program income anticipated to be received during the program year by activity and identifies proposed accomplishments by activity. The proposed FY 2024/25 CDBG, HOME, and ESG Action Plan (Attachment A) covers the final year of the County's five-year 2020-2025 Consolidated Plan period.
The following sub-committees or advisory committees of the Board of Supervisors consider County staff’s funding recommendations prior to final approval by the Board of Supervisors:
• Family and Human Services Committee - CDBG PS category and ESG Program funds
• Finance Committee - CDBG ED and IPF categories
• Affordable Housing Finance Committee - CDBG Housing category, and HOME funds
The Family and Human Services (FHS) Committee met on May 20, 2024, to consider staff recommendations for FY 2024/25 CDBG PS and ESG programs and projects. The meeting was noticed, and project applicants were encouraged to attend and provide input into the allocation process. After discussion, the FHS Committee approved staff recommendations as shown in Attachments B-1 and B-2.
The Finance Committee met on June 3, 2024, to consider staff recommendations for the FY 2024/25 CDBG-ED programs and IPF projects. The meeting was noticed, and project applicants were encouraged to attend and provide input into the allocation process. After discussion, the Finance Committee approved staff recommendations as shown in Attachments C-1 and C-2.
A meeting of the Affordable Housing Finance Committee (AHFC) was scheduled for Wednesday, June 5, 2024; however, the meeting was unable to be held due to lack of quorum of committee members. There was not enough time to schedule and hold another AHFC meeting prior to the Board of Supervisors meeting on Tuesday, June 25, 2024, where all federal and local funding will be considered and approved. HUD’s deadline to submit the FY 2024/25 Action Plan, which must include all CDBG and HOME funded activities, is July 8, 2024. Therefore, staff’s recommendations for CDBG and HOME housing activities, as shown in Attachment D, are being forwarded to the Board, as recommended by the Conservation and Development Director, in order to meet HUD’s July 8, 2024 deadline.
CEQA: The Action Plan is exempt from CEQA review. However, individual projects may be subject to further determination and study, which the project's lead agency will undertake. Depending on the location of recommended projects, the County may be the responsible agency for some housing projects. CEQA determinations will be made and approved by the responsible agency for the respective housing projects before entering into project agreements or other legal documents for each respective housing project.
National Environmental Policy Act (NEPA): All CDBG, HOME, and ESG projects/programs are subject to a NEPA environmental review in accordance with HUD NEPA regulations (24 CFR Part 58). The NEPA review for each project will be completed prior to entering into project agreements or other legal documents for each respective project.
CONSEQUENCE OF NEGATIVE ACTION:
Negative action will prevent the FY 2024/25 Action Plan from being submitted to HUD by the July 8, 2024, deadline and jeopardize the County's receipt of the FY 2024/25 CDBG, HOME, and ESG funds.