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Flores, Dora From:Katherine Fuentes <kat@upwards.com> Sent:Tuesday, March 26, To:Flores, David Cc:eComment; Garcia, Michael (CDA) Subject:2024-2025 Draft Annual Action Plan Feedback Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Hi David and Santa Ana Team, Thank you for this opportunity to provide comment and feedback on the 2024-2025 CDBG Allocation Process and Draft Annual Action Plan. We kindly ask that this comment make its way into the public record and be used to improve the equity of future allocation processes. Upwards is very excited to participate in this years allocation process and future processes, as we are committed to supporting the hard working microenterprise childcare providers in Santa Ana with Special Economic Development, Microenterprise Business and Technical Assistance. The City of Santa Ana's Consolidated Plan outlines Economic Development as a Strategic Plan Goal that will promote economic opportunity in the City. When we initially met with the Santa Ana CDBG Team, we were instructed to apply through the Public Service RFP in an effort to receive equitable consideration for funding. However, there seemed to be a lack of familiarity with for-profit organizations being eligible to apply for CDBG funding under the Economic Development designation. After we applied through the Public Service RFP, we were told that we were not eligible to receive funding. The BOOST Program is an eligible CDBG program, as outlined in 24 CFR Part 570. We have worked with various cities and counties all across the country using CDBG funding as a direct subrecipient, we are very familiar with the federal guidelines and the eligibility of our program. When we asked the City why we were administratively denied, we were told it was because we applied through the Public Service RFP, which is what we were directed to do. We submit CDBG applications with hundreds of cities and counties across the country, many of whom do not have a specific Economic Development RFP. Most open a Public Service RFP and ask applicants to identify their program by National Objective and Program Type, in this case, Economic Development. Based on this information, it seems that the City of Santa Ana does not provide an equitable process for programs like BOOST to be considered for funding. The City's ConPlan identifies Economic Development as a priority need and strategic goal, but staff is not providing a vehicle for applicants who are eligible to provide this service a method to be considered for funding. Upwards kindly requests that this be considered in future CDBG NOFA processes. Either the Public Service NOFA acts as a vehicle for all eligible applicants to apply for funding under any of the eligible strategic goals, or a specific NOFA is created for Economic Development programs to allow for eligible programs to be considered for funding by the elected body. Limiting an eligible applicant's ability to submit for consideration to the elected body removes the communities visibility into programs that might be considered higher priority to the community. Staff should also not administratively deny applications that are eligible under federal guidelines, as this limits the Council's ability to speak on these policy issues. Applications that are not being recommended for funding should still go before the City Council for their consideration as the policy makers of the City. 4