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Public Hearing -Adopt Second Amendment to the COVID-19 Response Funding Plan <br />December 1, 2020 <br />Page 3 <br />there is less need for funding in one activity relative to another activity. Staff may also need to <br />remove or replace an eligible activity entirely without returning to City Council for approval. The <br />Plan may be adjusted in response to shifting needs and priorities to most effectively respond to the <br />COVI D-19 pandemic on behalf of the community, but the amount of funds available for expenditure <br />of these new CDBG-CV3 funds will not exceed $3,520,819. <br />Second COVID-19 Substantial Amendment to the Fiscal Year 2019-2020 Annual Action Plan <br />On June 4, 2019, City Council approved the Fiscal Year 2019-2020 Annual Action plan. The City <br />of Santa Ana's Annual Action Plan details the funding strategy for the Community Development <br />Block Grant (CDBG), Emergency Solutions Grant (ESG), and HOME Investment Partnerships <br />programs each year. The Annual Action Plan implements our jurisdiction's Five -Year Consolidated <br />Plan and was developed through significant public input, analyses, and planning. The Annual <br />Action Plan describes in detail how these federal grant funds will be allocated and used to serve <br />the community. Title 24 Section 91.505 of the Code of Federal Regulations stipulates that <br />participating jurisdictions shall amend their approved plans whenever they make one of the <br />following decisions: <br />1. To make a change in its allocation priorities or a change in the method of distribution of <br />funds; <br />2. To carry out an activity, using funds from any program covered by the Consolidated Plan <br />(including program income) not previously described in the action plan; or <br />3. To change the purpose, scope, location or beneficiaries of an activity. <br />The City of Santa Ana has been awarded $3,520,819 in CDBG-CV3 funds and $11,598,442 in <br />ESG-CV2 funds that were not previously described in the Fiscal Year 2019-2020 Annual Action <br />Plan or the First COVID-19 Substantial Amendment. Per the regulations for these federal funds, a <br />Second COVID-19 Substantial Amendment to the FY 2019-2020 Annual Action Plan is required <br />(Exhibit 3). <br />Usually a 30 day public comment period is required under the City's Citizen Participation Plan. <br />HUD recognizes the efforts to contain COVID- 19 require limiting public gatherings, such as those <br />often used to obtain citizen participation, and that there is a need to respond quickly to the growing <br />spread and effects of COVID- 19. Therefore, in a memorandum dated March 31, 2020, HUD has <br />waived 24 CFR 91.105(c)(2) and (k), 24 CFR 91.115(c)(2) and (i) and 24 CFR 91.401 to allow the <br />City to determine what constitutes reasonable notice and opportunity to comment given their <br />circumstances. The City has determined that five days constitutes reasonable notice and <br />opportunity to comment given the circumstances surrounding the COVID-19 pandemic. City <br />Council approved an update to the Citizen Participation Plan on April 21, 2020 to allow for a five <br />day public comment period. <br />As required by HUD, the Second COVID-19 Substantial Amendment to the Fiscal Year 2019-2020 <br />Annual Action Plan was made available for a five day public comment review period from <br />November 20, 2020 to November 24, 2020. A public notice was published on November 20, 2020 <br />in the Orange County Register in English, La Opinion in Spanish, and the Ngoi Viet in Vietnamese <br />75B-3 <br />