HomeMy WebLinkAbout75B - PH COVID-19 RESPONSE FUNDING PLANREQUEST FOR
COUNCIL ACTION
CITY COUNCIL MEETING DATE:
APRIL 21, 2020
TITLE
PUBLIC HEARING -ADOPT COVID-19
RESPONSE FUNDING PLAN;
AUTHORIZE APPROVAL OF
AGREEMENTS TO IMPLEMENT THE
PLAN; APPROVE A SUBSTANTIAL
AMENDMENT TO THE FISCAL YEAR
2019 — 2020 ANNUAL ACTION PLAN;
APPROVE AMENDMENT TO CITIZEN
PARTICIPATION PLAN; APPROVE
APPROPRIATION ADJUSTMENTS
FOR $6,486,644 IN FEDERAL AND
STATE GRANT FUNDS
/s/Kristine
CITY MANAGER
CLERK OF COUNCIL USE ONLY:
_•-e• 9
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As Recommended
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As Amended
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Ordinance on 1" Reading
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Ordinance on 2ntl Reading
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Implementing Resolution
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Set Public Hearing For
CONTINUED TO
FILE NUMBER
RECOMMENDED ACTION
1. Adopt a plan for the allocation, administration and implementation of $6,486,644 in federal and
state funding to respond to the coronavirus ("COVID-19°) pandemic including $1,385,224 in
Homeless Housing, Assistance and Prevention Program COVID-19 Funds, $3,374,017 in
Community Development Block Grant Coronavirus Funds, and $1,727,403 in Emergency
Solutions Grant Coronavirus Funds, subject to adjustment by the City Manager as needed in
response to shifting needs and priorities so long as the amount of funds does not exceed the
amount available ("COVID-19 Response Funding Plan").
2. Direct the City Attorney to finalize and authorize the City Manager to enter into negotiations,
execute agreements, and approve any other required actions necessary with various service
providers, contractors, and subrecipients, who will implement the COVID-19 Response Funding
Plan, subject to non -substantive changes approved by the City Manager and City Attorney.
3. Approve a Substantial Amendment to the Fiscal Year 2019 — 2020 Annual Action Plan in order
to allocate and program $3,374,017 in Community Development Block Grant-Coronavirus
Funds, and $1,727,403 in Emergency Solutions Grant Coronavirus Funds to prevent, prepare
for, and respond to the coronavirus, and authorize its submission to the U.S. Department of
Housing and Urban Development.
4. Approve an Amendment to the Citizen Participation Plan to allow for a 5-day public comment
period, and authorize its submission to the U.S. Department of Housing and Urban Development.
5. Affirm an appropriation adjustment recognizing Homeless Housing, Assistance and Prevention
75B-1
Public Hearing — Adopt COVID-19 Response Funding Plan
April 21, 2020
Page 2
Program grant funds from the State of California, Business, Consumer Services, and Housing
Agency for COVID-19 response in the amount of $1,385,224 in revenue account (no.
12218002-52025) and appropriating same to expenditure account (nos. 12218710-various).
6. Approve an appropriation adjustment recognizing Community Development Block Grant
Coronavirus funds from the U.S. Department of Housing and Urban Development for COVID-
19 response in the amount of $3,374,017 in revenue account (no. 13518002-52000) and
appropriating same to expenditure account (nos. 13518788-various).
7. Approve an appropriation adjustment recognizing Emergency Solutions Grant Coronavirus
funds from the U.S. Department of Housing and Urban Development for COVID-19 response
in the amount of $1,727,403 in revenue account (no. 13518002-52000) and appropriating same
to expenditure account (nos. 13518789-various).
DISCUSSION
On March 23, 2020, the City received an award of $1,385,224 in Homeless Housing, Assistance
and Prevention Program ("HHAP") COVID-19 Funds from the State of California in response to the
coronavirus ("COVID-19") pandemic (Exhibit 1). These funds were appropriated under the City
Manager's emergency authorities, pursuant to Section 3 of Resolution 2020-016 proclaiming a
Local Emergency regarding Novel Coronavirus. The general purpose of the funds is to protect the
health and safety of people experiencing homelessness. Specifically, the funds are for COVID-19
prevention and containment efforts for shelters, including, but not limited to, medically indicated
services and supplies, such as testing and handwashing stations, and enhancements to existing
shelter facilities. This will allow for proper social distancing and isolation to reduce the spread of
COVID-19 among the homeless population. To most effectively address the needs of the
community while complying with the eligible uses for this source of state funds, staff has identified
the following three general activities for the use of these funds:
1. Service the twenty-two (22) trailers received from the State of California
2. Enter into Emergency Occupancy Agreements with one or more hotels in the City
3. Purchase additional supplies, furnishings and increase staffing at the Link
On April 2, 2020, the City received an award of $3,374,017 in Community Development Block
Grant Coronavirus ("CBDG-CV") Funds from the United States Department of Housing and Urban
Development ("HUD") in response to the COVID-19 pandemic (Exhibit 2). This allocation was
authorized by the Coronavirus Aid, Relief, and Economic Security Act ("CARES Act") which was
signed by President Trump on March 27, 2020, to respond to the growing effects of this historic
public health crisis. The general purpose of the funds is to prevent, prepare for, and respond to the
COVID-19 pandemic. To most effectively address the needs of the community while complying
with the eligible uses for this source of funds, staff has identified the following six general activities
for the use of these federal funds:
1. Tenant improvements to start up the new permanent emergency shelter sooner than
planned for COVID-19 homeless response
2. Emergency Rental Relief Fund
75B-2
Public Hearing — Adopt COVID-19 Response Funding Plan
April 21, 2020
Page 3
3. Economic Development - Small Business Incentive Program
4. Wrap -around case management services and infection control for homeless individuals
quarantined in hotels
5. ALTA-Med COVID-19 Evaluation Center
6. Food Distribution for Seniors and/or Residents
On April 2, 2020, the City received an award of $1,727,403 in Emergency Solutions Grant
Coronavirus ("ESG-CV") Funds from HUD in response to the COVID-19 pandemic (Exhibit 3). This
allocation was also authorized by the CARES Act. The general purpose of the funds is to prevent,
prepare for, and respond to the COVID-19 among individuals and families who are homeless or
receiving homeless assistance; and to support additional homeless assistance and homelessness
prevention activities to mitigate the impacts of COVID-19. To most effectively address the needs
of the community while complying with the eligible uses for this source of funds, staff has identified
the following two general activities for the use of these federal funds:
1. Operating costs to start up the new permanent emergency shelter sooner than planned for
COVID-19 homeless response
2. Wrap -around case management services and infection control for homeless individuals in
trailers
Collectively, these three awards and eleven general activities have been consolidated into a
COVID-19 Response Funding Plan for the allocation, administration and implementation of
$6,486,644 in federal and state funding to respond to the COVID-19 pandemic (Exhibit 4). The
Plan provides more details on each activity that is proposed to be carried out with each source of
funds. However, the Plan is subject to adjustment as needed in response to shifting needs and
priorities so long as the amount of funds does not exceed the amount available. For example, staff
may need to change one eligible activity to another eligible activity because there is insufficient
funds in that activity to fully carry it out, or there is less need for funding in one activity relative to
another activity. Staff may also need to remove or replace an eligible activity entirely without
returning to City Council for approval. The Plan may be adjusted in response to shifting needs and
priorities to most effectively respond to the COVID-19 pandemic on behalf of the community, but
the amount of funds available for expenditure will not exceed $6,486,644.
Substantial Amendment to the Fiscal Year 2019 — 2020 Annual Action Plan and Amendment to the
Citizen Participation Plan
On June 4, 2019, City Council approved the Fiscal Year 2019 - 2020 Annual Action Plan. The City
of Santa Ana's Annual Action Plan details the funding strategy for the Community Development
Block Grant (CDBG), Emergency Solutions Grant (ESG), and HOME Investment Partnerships
programs each year. These Annual Action Plans implement our jurisdiction's Five -Year
Consolidated Plan and are developed through significant public input, analyses, and planning. The
Annual Action Plan describes in detail how these federal grant funds will be allocated and used to
serve the community. Title 24 Section 91.505 of the Code of Federal Regulations stipulates that
participating jurisdictions shall amend their approved plans whenever they make one of the
following decisions:
75B-3
Public Hearing — Adopt COVID-19 Response Funding Plan
April 21, 2020
Page 4
1. To make a change in its allocation priorities or a change in the method of distribution of
funds;
2. To carry out an activity, using funds from any program covered by the Consolidated Plan
(including program income) not previously described in the action plan; or
3. To change the purpose, scope, location, or beneficiaries of an activity.
The City of Santa Ana has been awarded $3,374,017 in CDBG-CV funds and $1,727,403 in ESG-
CV funds that were not previously described in the Fiscal Year 2019 — 2020 Annual Action Plan.
Per the regulations for these federal funds, a Substantial Amendment to the FY 2019-2020 Annual
Action Plan is required (Exhibit 5).
Usually a thirty (30) day public comment period is required under the City's Citizen Participation
Plan. HUD recognizes the efforts to contain COVID-19 require limiting public gatherings, such as
those often used to obtain citizen participation, and that there is a need to respond quickly to the
growing spread and effects of COVID-19. Therefore, in a memorandum dated March 31, 2020,
HUD has 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 City to determine what constitutes reasonable notice and opportunity to comment given
their circumstances. The City has determined that 5 days constitutes reasonable notice and
opportunity to comment given the circumstances surrounding the COVID-19 pandemic. City
Council last approved an update to the Citizen Participation Plan on September 17, 2019. This
Amendment to the Citizen Participation Plan will allow for a 5-day public comment period (Exhibit
6).
As required by HUD, the Substantial Amendment to the Fiscal Year 2019 — 2020 Annual Action
Plan and Amendment to the Citizen Participation Plan was made available for a 5-day public
comment review period from April 17, 2020 to April 21, 2020. A public notice was published on
April 17, 2020 in the Orange County Register in English, La Opinion in Spanish, and the Ngoi Viet
in Vietnamese to inform the public of the commencement of the 5-day public comment period and
public hearing. Comments received will be included in the final submission of the Substantial
Amendment to HUD.
Following approval by City Council, staff will submit the Substantial Amendment to the FY 2019-
2020 Annual Action Plan to HUD in order to draw down the $3,374,017 in CDBG-CV funds and
$1,727,403 in ESG-CV funds. Staff will also submit the amended Citizen Participation Plan.
STRATEGIC PLAN ALIGNMENT
Approval of this item supports the City's effort to meet the following Goals, Objectives and
Strategies: Goal # 3 - Economic Development, Objective # 5 (leverage private investment that
results in tax base expansion and job creation citywide), Strategy C (develop a knowledge base
to foster economic development by actively partnering with non- profit organizations); and
Goal # 5 - Community Health, Livability, Engagement & Sustainability, Objective # 4 ( support
neighborhood vitality and livability), Strategy D (implement new Neighborhood Improvement
Initiatives focusing on residential areas that have been adversely affected by disinvestment and
75B-4
Public Hearing — Adopt COVID-19 Response Funding Plan
April 21, 2020
Page 5
decline. Program and services from a variety of resources will be utilized to achieve positive and
sustainable improvements), and Objective # 6 (focus projects and programs on improving the
health and wellness of all residents), Strategy C (integrate a variety of health and wellness
programs into existing programming at each of the city's community/ recreation centers (e. g.
Develop equitable health access points)).
FISCAL IMPACT
Upon affirmation and approval of the appropriation adjustments, funds will be available in the grant
program account (nos. 12218710, 13518788 and 13518789). It is anticipated that the HHAP
COVID-19, CDBG-CV, and ESG-CV allocations will be expended as follows:
Fiscal Year
Grant
Accounting Unit-
Fund
Accounting Unit,
Amount
Year
Account #
Description
Account Description
FY 2019-20
N/A
12218710-various
Emergency and
HHAP COVID-19
$1,385,224
Health Grants
Community
FY 2019-20
2020
13518788-various
Development
CDBG-CV
$3,374,017
Block Grant —
Coronavirus
Emergency
FY 2019-20
2020
13518789-various
Solutions Grant—
ESG-CV
$1,727,403
Coronavirus
Total for FY 2019-20
$6,486,644
Any CDBG-CV and ESG-CV funds unspent by the end of the current fiscal year will be carried
forward for expenditure in FY 2020-21 if eligible and allowed by the grants. The HHAP COVID-19
funds are only allowable for use through June 30, 2020.
Exhibits: 1. Award Letter for $1,385,224 in HHAP COVID-19 Funds
2. Award Letter for $3,374,017 in CDBG-CV Funds
3. Award Letter for $1,727,403 in ESG-CV Funds
4. COVID-19 Response Funding Plan
5. Substantial Amendment to the FY 2019-2020 Annual Action Plan
6. Amended Citizen Participation Plan
75B-5
C&UPOIRKU EXHIBIT
HOMELESS COORDINATING
AND FINANCING COUNCIL
Business, Consumer Services and Housing Agency
Gavin Newsom, Governor I Lourdes M. Castro Ramirez, Secretary
March 23, 2020
City of Santa Ana
Attn: Kristine Ridge, City Manager
20 Civic Center Plaza
Santa Ana, CA 92701
RE: Award Announcement —COVID-1 9 Emergency Homelessness Funding
Agreement #: 20-HCFC-00019
Dear Kristine Ridge,
In response to the COVID-19 outbreak and to protect the health and safety of
people experiencing homelessness, Governor Gavin Newsom signed SB 89 on
March 17 allocating funding to help protect this vulnerable population. We are
pleased to announce that City of Santa Ana has been awarded a grant in the
amount of $1,385,224.15.
This funding is immediately available as a result of swift action taken by the
California State Legislature in unanimously approving SB 89 to help California
fight the COVID-19 pandemic. Additionally, this is described in the March 18,
2020 letter from the Department of Finance to the Joint Legislative Budget
Committee, pursuant to the provisions of Section 36.00, Chapter 2, Statutes of
2020, and the augmentation to Budget Act of 2019 Item 0515-101-0001. The
purpose of this funding is to protect the health and safety of people
experiencing homelessness and reduce the spread of the COVID-19 outbreak.
Specifically, this award is intended for investments into COVID-19 prevention
and containment efforts for shelters, including, but not limited to, medically
indicated services and supplies, such as testing and handwashing stations, and
enhancements to existing shelter facilities. This will allow for proper social
distancing and isolation to reduce the spread of COVID-19 among the homeless
population. While eligible uses for funding are broad and should be determined
based on the need of the jurisdiction, suggested uses include but are not limited
to:
916 Capitol Mall, Suite 360-A I Sacramento, CA 958141(916) 653-4090
www. bcsh.ca.00v/hcfc
75B-6
• Emergency Shelter Operations - furnishings, supplies, and
equipment needed to maintain a sanitary shelter environment for clients and
staff.
• Shelter Capacity - support for increasing shelter capacity and the acquisition
of new shelters.
• Isolation Capacity - support for the acquisition/lease of hotels, motels, trailers,
and other alternative isolation placements.
• Street Outreach - supplies and equipment needed to protect staff engaging
with unsheltered from COVID-19 and to meet the urgent physical needs of
people experiencing homelessness.
• Transportation - support for the transportation of those experiencing
homelessness to and from shelters and medical care.
• Staffing - support for additional staff for infectious disease preparedness and
case management for clients.
We also invite you to review guidance documents and the most up-to-date
information for homeless assistance providers available on our website at
httr)s://www.bcsh.ca.gov/hcfc/coronavirusl 9.
The Standard Agreement along with instructions on how to fill it out are
enclosed. Please review and follow the instructions thoroughly. Incorrect
information provided may result in a delay of disbursement of funds.
City of Santa Ana will receive its full disbursement of funds after the Standard
Agreement is fully executed.
In an effort to ensure that these funds are immediately achieving their intent, we
request that every jurisdiction execute and return this Standard Agreement no
later than 30-days from receipt of this letter. For further information, please
contact Amber Ostrander, HAAP Grant Manager at 916-651-7995 or by email at
amber.ostrander@bcsh.ca.gov.
On behalf of Governor Newsom and our entire California State family, we thank
you for all you are doing to protect and assist some of the most vulnerable
members of our community.
Sincerely,
Lourdes M. Castro Ramirez, Secretary
Council Chair
75B-7
EXHIBIT 2
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
IIIIIIII Qa _ WASHINGTON, DC 20410-7000
ASSISTANT SECRETARY FOR
COMMUNITY PLANNING AND DEVELOPMENT
April 2, 2020
The Honorable Miguel Pulido
Mayor of Santa Ana
20 Civic Center Plaza
Santa Ana, CA 92701-4058
Dear Mayor Pulido:
I am pleased to inform you of a special allocation to your jurisdiction of Community
Development Block Grant funds to be used to prevent, prepare for, and respond to the coronavirus
(COVID-19). This allocation was authorized by the Coronavirus Aid, Relief, and Economic
Security Act (CARES Act), Public Law 116-136, which was signed by President Trump on March
27, 2020, to respond to the growing effects of this historic public health crisis.
The CARES Act made available $5 billion in Community Development Block Grant
Coronavirus (CDBG-CV) funds. Of this amount, the Department is immediately allocating $2
billion based on the fiscal year 2020 CDBG formula The remaining $3 billion shall be allocated
based on needs using best available data, in the following tranches: $1 billion shall be allocated to
States and insular areas within 45 days of enactment of the Cares Act, and $2 billion shall be
distributed to states and local governments at the discretion of the Secretary. Up to $10 million will
be set aside for technical assistance. Given the immediate needs faced by our communities, the
Department has announced the first allocation of funds. Your jurisdiction's allocation is
$3,374,017.
The CARES Act adds additional flexibility for both the CDBG-CV grant and, in some cases,
for the annual FY2020 CDBG grants in these unprecedented times. The public comment period is
reduced to not less than 5 days, grantees may use virtual public hearings when necessary for public
health reasons, the public services cap is suspended during the emergency, and States and local
governments may reimburse costs of eligible activities incurred for pandemic response regardless of
the date.
In addition, the CARES Act authorizes the Secretary to grant waivers and alternative
requirements of statutes and regulations the Secretary administers in connection with the use of
CDBG-CV funds and fiscal year 2019 and 2020 CDBG funds (except for requirements related to
fair housing, nondiscrimination, labor standards, and the environment). Waivers and alternative
requirements can be granted when necessary to expedite and facilitate the use of funds to prevent,
prepare for, and respond to coronavirus.
The Department is developing a notice that will further describes the CARES Act's
provisions, a Quick Guide to the CARES Act flexibilities and other provisions, and other resources
www.hud.g7 5 B=guol.hud.gov
to enable swift implementation of CDBG-CV grants. As these become available, they will be
posted on HUD's website and distributed to grantees. The Department will also support grantees
with technical assistance.
As you develop your plan for the use of these grant funds, we encourage you to consider
approaches that prioritize the unique needs of low- and moderate —income persons and the
development of partnerships between all levels of government and the private for -profit and non-
profit sectors. You should coordinate with state and local health authorities before undertaking any
activity to support state or local pandemic response. CDBG-CV grants will be subject to oversight,
reporting, and requirements that each grantee have adequate procedures to prevent the duplication
of benefits. HUD will provide guidance and technical assistance on DOB and regarding prevention
of fraud, waste, and abuse and documenting the impact of this program for beneficiaries.
The Office of Community Planning and Development (CPD) is looking forward to working
with you to successfully meet the urgent and complex challenges faced by our communities. If you
or any member of your staff has questions, please contact your local CPD Field Office Director or
CPDQuestionsAnsweredghud.gov.
Sincerely,
X/&�&
John Gibbs
Acting Assistant Secretary
for Community Planning and Development
U.S. Department of Housing and Urban Development
75B-9
EXHIBIT 3
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
IIIIIIII Qa _ WASHINGTON, DC 20410-7000
ASSISTANT SECRETARY FOR
COMMUNITY PLANNING AND DEVELOPMENT
April 2, 2020
The Honorable Miguel Pulido
Mayor of Santa Ana
20 Civic Center Plaza
Santa Ana, CA 92701-4058
Dear Mayor Pulido:
I am pleased to inform you of special Emergency Solutions Grants (ESG) Program funds
HUD is allocating to your jurisdiction in the amount of $1,727,403, as authorized by the
Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Public Law 116-136. These
special ESG-CV funds are to be used to prevent, prepare for, and respond to the coronavirus
pandemic (COVID-19) among individuals and families who are homeless or receiving homeless
assistance; and to support additional homeless assistance and homelessness prevention activities to
mitigate the impacts of COVID-19.
President Trump signed the CARES Act on March 27, 2020 to help the Nation respond to the
coronavirus outbreak. The CARES Act made available an additional $4 billion in ESG-CV funds to
supplement the Fiscal Year (FY) 2020 ESG funding provided under the Further Consolidated
Appropriations Act, 2020 (Public Law 116-94). Of this amount, the Department is immediately
allocating $1 billion for ESG-CV grants based on the FY 2020 ESG formula. The rest of the
funding for ESG-CV grants will be allocated directly to States or units of local government by a
separate formula developed by the Secretary. Up to $40 million of the additional funds will be set
aside for technical assistance.
Given the immediate needs faced by our communities, the Department has announced the fast
allocation of funds, which are subject to the following flexibilities and conditions provided by the
CARES Act:
• The funds may be used to cover or reimburse allowable costs incurred by a State or
locality before the award of funding (including prior to the signing of the CARES Act)
to prevent, prepare for, and respond to COVID-19;
• The funds are not subject to the spending cap on emergency shelter and outreach
under 24 CFR 576. 1 00(b)(1);
• Up to 10 percent of funds may be used for administrative costs, as opposed to 7.5
percent as provided by 24 CFR 576.108(a);
• The funds are exempt from the ESG match requirements, including 24 CFR 576.201;
• The funds are not subject to the consultation and citizen participation requirements
that otherwise apply to the Emergency Solutions Grants, however each recipient must
vvww.hud.75 B - Ipdol.hud.gov
publish how its allocation has and will be used, at a minimum, on the hiternet at the
appropriate Government web site or through other electronic media;
• The funds may be used to provide homelessness prevention assistance (as authorized
under 24 CFR 576.103 or subsequent HUD notices) to any individual or family who
does not have income higher than HUD's Very Low -Income Limit for the area and
meets the criteria in paragraphs (1)(ii) and (1)(iii) of the "at risk of homelessness"
definition in 24 CFR 576.3;
• That recipients may deviate from applicable procurement standards when using these
funds to procure goods and services to prevent, prepare for, and respond to
coronavirus, notwithstanding 24 CFR 576.407(1) and 2 CFR 200.317-200.326;
• While we encourage you to offer treatment and supportive services when necessary to
assist vulnerable homeless populations, individuals and families experiencing
homelessness must not be required to receive treatment or perform any other
prerequisite activities as a condition for receiving shelter, housing, or other services
for which these funds are used, notwithstanding 24 CFR 576.401(e).
In addition, the Act authorizes the Secretary to grant waivers of and specify alternative
requirements for statutes and regulations the Secretary administers in connection with the use of
ESG funds (except for requirements related to fair housing, nondiscrimination, labor standards, and
the environment). These waivers and alternative requirements can be issued when necessary to
expedite and facilitate the use of funds to prevent, prepare for, and respond to coronavirus.
The Department is developing a notice that will further lay out the CARES Act provisions and
other waivers and requirements to enable swift implementation of additional ESG-CV grants. This
notice and any subsequent notices of waivers and alternative requirements will be made available on
HUD's website and distributed to grantees. The Department will also support grantees with
technical assistance.
As your jurisdiction develops its plan to use these grant funds, HUD encourages approaches
that prioritize the unique needs of persons experiencing homelessness and the development of
partnerships between all levels of government and the private for -profit and non-profit sectors.
Your jurisdiction should coordinate with State and local health authorities before undertaking any
activity to support state or local pandemic response. HUD encourages you to share successes that
may help other grantees. Like other supplemental funding, ESG-CV grants are subject to oversight
and tracking, such as requirements to prevent the duplication of benefits. We look forward to
working with you to prevent fraud, waste, and abuse and to document the impact of this program for
beneficiaries.
Importantly, proper reporting in the Integrated Disbursement and Information System (IDIS)
is critical to ensuring grantees are complying with program requirements and policies, providing
demographic and income information about the persons who benefit from funded activities, and
allowing HUD to monitor recipients. Your jurisdiction's ongoing attention is essential to ensuring
complete and accurate reporting of performance measurement data.
75B-11
HUD's Office of Community Planning and Development (CPD) is looking forward to
working with your jurisdiction to successfully meet the urgent and complex challenges faced by our
communities. If you or your staff has questions, please contact your local CPD Field Office
Director or CPDOuestionsAnswered cghud.Qov.
Sincerely,
A)6&
John Gibbs
Acting Assistant Secretary
for Community Planning and Development
U.S. Department of Housing and Urban Development
75B-12
EXHIBIT 4
COVID-19 Response Funding Plan
As of April 21, 2020
PROGRAM■ING SOURCE
GENERAL DESCRIPTION
Homeless Housing, Assistance and Prevention Program
To protect the health and safety of homeless populations and reduce the
COVID-19 Funds (HHAP COVID-19)
spread of the COVID-19 outbreak.
Servicing 22 trailers received from the State of California. Trailers have been
$ 400,000
Servicing the trailers from the State of CA
placed at the Link and on Carnegie street. Services include generators,
furnishings, water supply, sewage cleaning.
Lease Agreement for an entire hotel or a block of rooms to quarantine either
835,224
Emergency Occupancy Agreement for Hotels
homeless individuals and families or first responders. Includes expenses for
damages and pets.
Cleaning supplies such as bleach, disinfectant wipes, scrubbers, mops;
Protective equipment such as masks, disposable gloves; program participant
150,000
Additional supplies, furnishing and staffing at
needs such as bed linens, towels, hand sanitizer, soap, tissue packets; cots,
the Link
room dividers; train or bus tokens, taxi or rideshare for program participant
travel to and from medical care; hiring additional staff to support infectious
disease preparedness.
$ 1,385,224
ITotal Available Funds
Community Development Block Grant-Coronavims Funds
To preven4 prepare for, and respond to the coronaviros (COVID-19).
(CDBG-CV)
Over 1/3rd of the total cost for $3,266,000 in tenant improvements required to
Tenant improvements to start up the new
start up the new permanent emergency shelter sooner than October 2020.
$ 1,310,435
permanent emergency shelter sooner than
The remaining portion will come from the Homeless Housing, Assistance and
planned for COVID-19 homeless response
Prevention Program and Homeless Emergency Assistance Program (non-
COVID-19 funds).
Proposed public services contact with the Salvation Army, United Way and/or
500,000
Emergency Rental Relief Fund
Catholic Charities to assist renters and homeowners impacted by COVID-19
who are unable to paytheir rent or mortgage due to loss of income.
500,000
Economic Development - Small Business
Expansion of City -run Small Business Incentive Program to provide additional
Incentive Program
loans and grants.
Wrap -around case management services
400,000
and infection control for homeless individuals
Proposed public services contract with CityNet
quarantined in hotels
Screening and testing operation in partnership with AltaMed, a non-profit
250,000
ALTA-Med COVID-19 Evaluation Center
medical services provider. Testing, diagnosis, or other services at a fixed
location. Grant agreement with ALTAMed for up to two weeks of testing for
Santa Ana residents.
Food Distribution for Seniors and/or
Proposed grant agreement with Meals on Wheels to support food distribution
76,180
Residents
to seniors or grant agreement with Orange County Food Bank or Community
Action Partnership of Orange County.
Recipients can use up to 20% of the allocation for administrative purposes.
337,402
Administrative Costs Allowance (CDA)
Used 10% instead of the 20%that is allowed in order to contribute a total of
�$337,402
in eligible grant administrative expenses to COVID-19 response.
$ 3,374,017
Total Available Funds
To preven4 prepare for, and respond to the coronavims (COVID-19)
Emergency Solutions Grant Coronavims Funds
among individuals and families who are homeless or receiving homeless
(ESG-CV)
assistance; and to support additional homeless assistance and
homelessness prevention activities to mitigate the impacts of COVID-19.
Operating cost to start up the new permanent
Proposed contract with Illumination Foundation to provide up to 4 months of
$ 1,353,700
emergency shelter sooner than planned for
emergency shelter provider services to start up the new permanent emergency
COVID-19 homeless response
shelter sooner than October 2020 (June through September 2020).
Wrap -around case management services
Proposed contract for services with Illumination Foundation, Mercy House,
200,963
and infection control for homeless individuals
and/or a vendor to be determined
in trailers
172,740
Administrative Costs Allowance (CDA)
Recipients can use up to 10% of the allocation for administrative purposes.
$ 1,727,403
Total Available Funds
$ 6,486,644 TOTAL
75B-13
EXHIBIT 5
CITY OF SANTA ANA
JULY 19 2019 - JUNE 309 2020
ANNUAL ACTION PLAN
COVID-19
SUBSTANTIAL AMENDMENT
75B-14
SUBSTANTIAL AMENDMENT TO THE FY 2019-2020 ANNUAL Substantial
ACTION PLAN TO ADD COMMUNITY DEVELOPMENT BLOCK Amendment # 2
GRANT — CORONAVIRUS (CDBG-CV) AND EMERGENCY
SOLUTIONS GRANT — CORONAVIRUS (ESG-CV) FUNDS
TABLE OF CONTENTS
PAGE
Introduction................................................................................................................ 2
Amendments.............................................................................................................. 3
PublicReview............................................................................................................ 4
Exhibits
Exhibit 1-Public Hearing Notice/Summary of Comments and Responses ................. 5
04/2020 1
75B-15
SUBSTANTIAL AMENDMENT TO THE FY 2019-2020 ANNUAL I Substantial
ACTION PLAN TO ADD COMMUNITY DEVELOPMENT BLOCK Amendment # 2
GRANT — CORONAVIRUS (CDBG-CV) AND EMERGENCY
SOLUTIONS GRANT— CORONAVIRUS (ESG-CV) FUNDS
SUBSTANTIAL AMENDMENT TO THE FY 2019-2020 ANNUAL ACTION PLAN TO
ADD COMMUNITY DEVELOPMENT BLOCK GRANT — CORONAVIRUS (CDBG-CV)
FUNDS AND EMERGENCY SOLUTIONS GRANT - CORONAVIRUS (ESG-CV)
FUNDS
INTRODUCTION
The City of Santa Ana's federal Annual Action Plan details the funding strategy for the
Community Development Block Grant (CDBG), Emergency Solutions Grant (ESG), and
HOME Investment Partnerships programs each year. These Annual Action Plans
implement our jurisdiction's Five -Year Consolidated Plan and are developed through
significant public input, analyses, and planning. This document is a Substantial
Amendment to the City of Santa Ana's Fiscal Year 2019-2020 Annual Action Plan,
which was submitted to the U.S. Department of Housing and Urban Development
(HUD) in May 2019.
Title 24 Section 91.505 of the Code of Federal Regulations stipulates that participating
jurisdictions shall amend their approved plans whenever they make one of the following
decisions:
1. To make a change in its allocation priorities or a change in the method of
distribution of funds;
2. To carry out an activity, using funds from any program covered by the
Consolidated Plan (including program income) not previously described in the
action plan; or
3. To change the purpose, scope, location, or beneficiaries of an activity.
04/2020 2
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SUBSTANTIAL AMENDMENT TO THE FY 2019-2020 ANNUAL I Substantial
ACTION PLAN TO ADD COMMUNITY DEVELOPMENT BLOCK Amendment # 2
GRANT — CORONAVIRUS (CDBG-CV) AND EMERGENCY
SOLUTIONS GRANT — CORONAVIRUS (ESG-CV) FUNDS
SUBSTANTIAL AMENDMENT
On March 27, 2020 the United States Congress passed the Coronavirus Aid, Relief, and
Economic Security Act (H.R. 748). The bill provided $5 billion in Community
Development Block Grant - Coronavirus (CDBG-CV) funds to rapidly respond to
COVID-19 and the economic and housing impacts caused by it, including the expansion
of community health facilities, childcare centers, food banks, and senior services. The
bill also provided an additional $4 billion in Emergency Solution Grant - Coronavirus
(ESG-CV) funds to supplement the Fiscal Year (FY) 2020 ESG funding.
The City of Santa Ana will receive $3,374,017 in CDBG-CV and $1,727,403 in ESG-CV
funding. These funds are not a part of any program covered by the City's Five -Year
Consolidated Plan (including program income) not previously described in the Annual
Action Plan and therefore a Substantial Amendment to the FY 2019-2020 Annual Action
Plan is required. Usually a thirty (30) day public comment period is required. However,
the U.S. Department of Housing and Urban Development (HUD) has waived this
requirement provided that no less than five (5) days are provided for public comments
on each substantial amendment.
The CDBG-CV and ESG-CV funds allocated under the CARES Act may be used for a
range of eligible activities to prevent, prepare for, and respond to the coronavirus
(COVID-19). The proposed activities must meet one of the three National Objectives as
required by the CDBG regulations:
Benefit low -and -moderate income persons.
Aid in the prevention or elimination of slums or blight, and
Meet an urgent need.
City staff is recommending to allocate the CDBG-CV and ESG-CV funds as follows:
CDBG-CV
Allocation
FY 2019-2020 CDBG-CV
$3,374,017
Administrative Costs Allowance (Community Development Agency)
$337,402
Tenant improvements to start up the new permanent emergency shelter
for COVID-19 homeless response
$1,310,435
Emergency Rental Relief Fund
$500,000
Economic Development - Small Business Incentive Program
$500,000
Wrap -around case management services and infection control for
homeless individuals quarantined in hotels
$400,000
ALTA-Med COVID-19 Evaluation Center Testing Services
$250,000
Food Distribution for Seniors and/or Residents
$76,180
04/2020 3
75B-17
SUBSTANTIAL AMENDMENT TO THE FY 2019-2020 ANNUAL I Substantial
ACTION PLAN TO ADD COMMUNITY DEVELOPMENT BLOCK Amendment # 2
GRANT — CORONAVIRUS (CDBG-CV) AND EMERGENCY
SOLUTIONS GRANT — CORONAVIRUS (ESG-CV) FUNDS
ESG-CV
Allocation
FY 2019-2020 ESG-CV
$1,727,403
Administrative Costs Allowance (Community Development Agency)
$172,740
Operating cost to start up the new permanent emergency shelter for
COVID-19 homeless response
$1,353,700
Wrap -around case management services and infection control for
homeless individuals in trailers
$200,963
In addition and for the purpose of an expedited use of the CDBG-CV and ESG-CV
funding, the bill eliminates the cap on the amount of funds a grantee can spend on
public services, removes the requirement to hold in -person public hearings in order to
comply with national and local social gathering requirements, and allows grantees to be
reimbursed for COVID-19 response activities regardless of the date the costs were
incurred.
Public Review
Pursuant to HUD regulations, the City's Citizen Participation Plan and current HUD
waivers for grant programs and consolidated plan requirements to prevent the spread of
COVID-19, staff published a 5-day comment period and public hearing. Public
comments and City Council's allocation recommendations will be included in the
Substantial Amendment to the FY 2019-2020 Annual Action Plan.
0a/z02.0 4
75B-18
SUBSTANTIAL AMENDMENT TO THE FY 2019-2020 ANNUAL I Substantial
ACTION PLAN TO ADD COMMUNITY DEVELOPMENT BLOCK Amendment # 2
GRANT — CORONAVIRUS (CDBG-CV) AND EMERGENCY
SOLUTIONS GRANT — CORONAVIRUS (ESG-CV) FUNDS
Exhibit 1
Summary of Public Comments
Proof of Publication 5-Day Comment Period and Public Hearing
Summary of public comments
SUMMARY OF PUBLIC COMMENTS RECEIVED DURING 5-DAY COMMENT PERIOD AND STAFF
RESPONSE:
The draft amendment was available from April 17, 2020 to April 21, 2020 for HUD's
required 5-day public comment period. A public notice was published on April 17, 2020 in
the Orange County Register in English, La Opinion in Spanish and the Ngoi Viet in
Vietnamese to inform the public of the commencement of the 5-day public comment
period and public hearing. XX comments were submitted for the Substantial
Amendment.
April 21, 2020 City Council Meeting Public Hearing:
At its Regular Meeting on April 21, 2020, the City Council approved the SUBSTANTIAL
AMENDMENT TO THE FISCAL YEAR 2019 — 2020 ANNUAL ACTION PLAN IN
ORDER TO ALLOCATE AND PROGRAM $3,374,017 IN COMMUNITY
DEVELOPMENT BLOCK GRANT-CORONAVIRUS FUNDS, AND $1,727,403 IN
EMERGENCY SOLUTIONS GRANT CORONAVIRUS FUNDS TO PREVENT,
PREPARE FOR, AND RESPOND TO THE CORONAVIRUS, AND AUTHORIZE ITS
SUBMISSION TO THE UNITED STATES DEPARTMENT OF HOUSING AND URBAN
DEVELOPMENT by a vote of (X:X).
PROOF OF PUBLICATION 5-DAY COMMENT PERIOD AND PUBLIC HEARING
See attachment.
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EXHIBIT 6
U.S. Department of Housing and Urban Development (HUD)
Community Planning and Development Grant Programs
April 21, 2020
Community Development Agency,
20 Civic Center Plaza, 61h Floor
M D G Santa Ana, CA 92702
ASSOCIATES -INC. (714) 647-5360
75B-20
City of Santa Ana
Citizen Participation Plan
Table of Contents
A.
Encouraging Citizen Participation.........................................................................................................2
B.
Citizen Participation Plan........................................................................................................................3
1.
Plan Development................................................................................................................................3
2.
Citizen Participation Plan Amendments..........................................................................................4
C.
Five -Year Consolidated Plan..................................................................................................................5
1.
Plan Development................................................................................................................................6
2.
Consolidated Plan Amendments......................................................................................................8
D.
Action Plan.................................................................................................................................................9
1.
Plan Development................................................................................................................................9
2.
Action Plan Amendments.................................................................................................................11
E.
Consolidated Annual Performance and Evaluation Report (CAPER)..........................................12
1.
Report Development.........................................................................................................................12
F.
Analysis of Impediments or Assessment of Fair Housing (Al or AFH)..............................................13
1.
Al or AFH Development.....................................................................................................................13
2.
AI or AFH Amendments.....................................................................................................................15
G.
Public Hearings, Notification and Access..........................................................................................16
1.
Public Hearings/Meetings.................................................................................................................16
2.
Documents for Public Review..........................................................................................................17
3.
Access to Meetings and Hearings...................................................................................................18
4.
Access to Consolidated Plan Documents and Records............................................................18
H.
Technical Assistance..............................................................................................................................19
I.
Comments and Complaints.................................................................................................................19
J.
Appeals.....................................................................................................................................................20
K.
CDBG Disaster Recovery (CDBG-DR).................................................................................................20
L.
AntFDisplacement and Relocation.....................................................................................................21
1.
Persons Not Eligible for Assistance...................................................................................................22
2.
AntFDisplacement Policy..................................................................................................................23
3.
Displacement Assistance..................................................................................................................24
4.
One -For -One Replacement Dwelling Units...................................................................................25
5.
Decent, Safe and Sanitary Dwelling...............................................................................................25
M.
Real Property Policies.............................................................................................................................26
1.
Use of Real Property...........................................................................................................................26
2.
Real Property Acquisition..................................................................................................................27
3.
Eligible Activities..................................................................................................................................27
4.
Environmental Review Process (24 CFR Part 58)...........................................................................27
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Is] kIVA4ZIZ_ AIIs]IZAI[07.12 Wc1a
As required by the U.S. Department of Housing and Urban Development (HUD)
regulations found at 24 CFR 91.105, this Citizen Participation Plan sets forth the City of
Santa Ana's (City) policies and procedures for providing citizens and other interested
parties with opportunities to participate in an advisory role in the planning,
implementation, and evaluation of the Community Development Block Grant (CDBG)
HOME Investment Partnerships (HOME), and Emergency Solutions Grant (ESG) programs.
The purpose of the CDBG program is the provision of decent housing, a suitable living
environment, and expanded economic opportunities for low- and moderate -income
residents earning less than 80 percent of the Area Median income (AMI), or in
predominately low- and moderate -income neighborhoods where at least 51 percent of
the households are low and moderate -income households. The purpose of the HOME
program is to produce new and preserve existing affordable housing opportunities. The
purpose of the ESG program is to assist individuals and families quickly regain stability in
permanent housing after experiencing a housing crisis or homelessness.
As a recipient of CDBG, HOME, and ESG funds, the City is required to produce the
following Consolidated Plan Documents:
• Citizen Participation Plan - the City's policies and procedures for community
participation in the planning, implementation, and evaluation of the CDBG,
HOME, and ESG programs.
• Analysis of Impediments to Fair Housing Choice or Assessment of Fair Housing (Al
or AFH) - a five-year plan completed by the City individually or as in the case of
Santa Ana, as part of a local consortium of other HUD grantees pursuant to HUD
guidance for the evaluation of local housing conditions, economics, policies and
practices and the extent to which these factors impact the range of housing
choices and opportunities available to all residents in an environment free from
discrimination.
• Consolidated Plan - a five-year plan that documents the City's housing and
community development needs, outlines strategies to address those needs and
identifies proposed program accomplishments.
• Action Plan - an annual plan that describes specific CDBG, HOME, and ESG
projects and activities that will be undertaken over the course of the program
year, which runs from July 1 to June 30.
City of Santa Ana Page 1
Citizen Participation Plan I April 2020
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• Consolidated Annual Performance and Evaluation Report (CAPER) - an annual
report that evaluates the City's accomplishments and use of CDBG funds.
The HUD requirements for citizen participation do not restrict the responsibility or authority
of the City for the development and execution of the Consolidated Plan documents or
the CDBG, HOME, and ESG programs, but rather facilitate citizen access to, and
engagement with the CDBG, HOME, and ESG programs.
In accordance with the regulations, the minimum annual number of public hearings
before the Santa Ana City Council and Community Redevelopment and Housing
Commission at which citizens may express their views concerning the Consolidated Plan
Documents shall be two (2) public hearings. These public hearings shall occur at two
different points during the program year, as directed by the Executive Director of
Community Development. Additional public hearings and comment periods may be
held in the development of the AFH or Al and the Consolidated Plan for 2020-2024 and
in the event of a substantial amendment to the Citizen Participation Plan, Consolidated
Plan, or Action Plan becomes necessary as described later in this document. The City, at
its discretion, may conduct additional outreach, public meetings or public hearings as
necessary to foster citizen access and engagement.
A. Encouraging Citizen Participation
The City encourages citizens to participate in the development of the Citizen
Participation Plan, Consolidated Plan, AFH or Al, Action Plan, and CAPER. The City
encourages participation by low- and moderate -income persons, particularly those living
in slum and blighted areas (if any such areas are formally designated) and in areas where
CDBG funds are proposed to be used, and by residents of predominantly low- and
moderate -income neighborhoods. Low- and moderate -income neighborhoods are
defined as those in which 51 percent of the residents have incomes at or below 80
percent of area median income. The City shall also take appropriate actions to
encourage the participation of all its citizens, including minorities and non-English
speaking persons, as well as persons with disabilities.
The City shall make a concerted effort to notify and encourage the participation of
citizens, local and regional institutions, the local Continuum of Care organization
addressing homelessness, and public and private organizations including businesses,
developers, nonprofit organizations, philanthropic organizations, community -based and
faith -based organizations, broadband internet service providers, organizations engaged
in narrowing the digital divide, agencies whose primary responsibilities include the
management of flood prone areas, public land or water resources, emergency
management agencies, state and local health service providers, social service providers,
fair housing organizations, state and local governments, public housing authorities,
affordable housing developers, businesses, community and faith based organizations,
and other stakeholders in the amendment of the Citizen Participation Plan or the
development of the Al or AFH, Consolidated Plan, or Action Plans through mailings
(including electronic mailings), online postings and public notices in the newspaper.
City of Santa Ana
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The City may also explore alternative public involvement techniques and quantitative
ways to measure efforts that encourage citizen participation in a shared vision for
change in communities and neighborhoods, and the review of program performance as
directed by the Executive Director of Community Development. All communication
regarding the Citizen Participation Plan and the Consolidated Plan documents should be
directed to:
City of Santa Ana
Community Development Agency
Attn: Executive Director of Community Development
20 Civic Center Plaza, 61h Floor
Santa Ana, CA 92702
(714)647-5360
B. Citizen Participation Plan
The following describes the process and procedures related to the development of the
Citizen Participation Plan.
1. Plan Development
The City's Citizen Participation Plan development procedures are outlined below.
a. Plan Considerations
As a part of the Citizen Participation Plan process, and prior to the adoption of the
Consolidated Plan, the City shall make available the information required by HUD.
This information shall be made available to citizens, public agencies, and other
interested parties.
b. Plan Review and Comment
The draft Citizen Participation Plan shall be made available for public review for a
30-day period. The Citizen Participation Plan shall be provided in a format
accessible to persons with disabilities upon request. Such formats may include, but
are not limited to those providing oral, Braille, electronic or large print versions of
the plan to those visually impaired and delivering copies to those who are
homebound.
The Citizen Participation Plan shall encourage comment and participation by
minorities and non-English speakers. Publication of the availability of the draft plan
shall be in accordance with the City's adopted Limited English Proficiency (LEP)
Plan.
Written comments shall be accepted by the Executive Director of Community
Development during the public review period. A summary of all written comments
and those received during the public hearing as well as the City's responses shall
be attached to the Citizen Participation Plan prior to submission to HUD.
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C. Public Hearing
The City shall conduct a public hearing or meeting before the Community
Redevelopment and Housing Commission (or a similar standing City Commission)
to accept public comments on the draft Citizen Participation Plan, however final
recommendations will be approved by the City Council. The City Council may
approve or reject the Citizen Participation Plan, or approve the plan with
modifications.
d. Submittal to HUD
The Citizen Participation Plan shall be approved as a stand-alone document. The
City shall provide HUD with copies of the approved document, a summary of all
written comments and those received during the public hearing as well as the
City's responses and proof of compliance with the minimum 30-day public review
and comment period requirement. A summary of any comments or views not
accepted and the reasons therefore shall be included.
2. Citizen Participation Plan Amendments
The City shall follow the following procedure to amend the Citizen Participation Plan,
as necessary:
a. Amendment Considerations
The City shall amend the Citizen Participation Plan, as necessary, to ensure
adequate engagement and involvement of the public in making decisions
related to the programs and documents governed by 24 CFR Part 91. Formal
amendment of the Citizen Participation Plan may be required should a provision
of the Citizen Participation Plan be found by the City to conflict with HUD
regulations.
b. Public Review and Comment
Amendments to the Citizen Participation Plan shall be made available for public
review for a 30-day period. A public hearing shall be conducted so that citizens
may express their views. Written comments shall be accepted by the Executive
Director of Community Development during the public review period. A summary
of all written comments and those received during the public hearing as well as
the City's responses shall be attached to the amended Citizen Participation Plan
prior to submission to HUD.
HUD recognizes the efforts to contain COVID-19 require limiting public gatherings,
such as those often used to obtain citizen participation, and that there is a need
to respond quickly to the growing spread and effects of COVID-19. Therefore, in a
memorandum dated March 31, 2020, HUD has waived 24 CFR 91.105(c)(2) and
W. 24 CFR 91.1151c1121 and lit and 24 CFR 91.401 to allow the Citv to determine
City of Santa Ana
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what constitutes reasonable notice and opportunity to comment given their
circumstances. The City has determined that 5 days constitutes reasonable notice
and opportunity to comment given the circumstances surrounding the COVID-19
pandemic. The waiver is in effect through the end of the 2020 program year.
Minor edits to the plan, such as updating contact information, will not constitute a
"Substantial Amendment", and therefore, will not be released for public review
and comment. Copies shall be made available following the process described
in Section G of this document.
c. Public Hearina
The City shall conduct a public hearing to review and accept public comments
on the draft amendment to the Citizen Participation Plan.
d. Submittal to HUD
A copy of the Citizen Participation Plan, including a summary of all written
comments and those received during the public hearing as well as the City's
responses and proof of compliance with the minimum 30-day public review and
comment period requirement shall be submitted to HUD for their records. A
summary of any comments or views not accepted and the reasons therefore shall
be supplied to HUD as applicable.
C. Five -Year Consolidated Plan
The following paragraphs describe the policies and procedures for the development of
the Five -Year Consolidated Plan. To comply with 24 CFR Part 91.105(b), the information
supplied in the draft Consolidated Plan for public review shall include:
• The amount of assistance the City expects to receive (grant funds and
program income);
• The range of activities that may be undertaken; and
• The estimated amount of funding that will benefit low- and moderate -income
persons.
The City shall also provide an assessment of community development and housing
needs, identify short term and long-term community development objectives directed
toward the provision of decent housing and the expansion of economic opportunities
primarily for persons of low- and moderate -income.
Additionally, the City shall attest to its compliance with the acquisition and relocation
requirements of the Uniform Relocation Assistance and Real Property Acquisition Policies
Act of 1970, as amended, and implementing regulations at 49 CFR 24, as effectuated by
the City's adopted Residential Anti -Displacement and Relocation Assistance Plan, as
required under Section 104(d) of the Housing and Community Development Act of 1974,
as amended. Persons displaced as a result of HUD -assisted activities, whether
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implemented by the City or by others, shall receive relocation benefits as required under
Federal Law.
The City shall make this information available in the Consolidated Plan published for
public review and comment.
1. Plan Development
The City encourages the participation of residents and stakeholders in the
development of the Consolidated Plan. The City shall implement the following
procedures in the development and adoption of the Consolidated Plan:
a. Plan Considerations
The City will make a concerted effort to notify and encourage the participation of
citizens, local and regional institutions, the local Continuum of Care organization
addressing homelessness, and public and private organizations including
businesses, developers, nonprofit organizations, philanthropic organizations,
community -based and faith -based organizations, broadband internet service
providers, organizations engaged in narrowing the digital divide, agencies whose
primary responsibilities include the management of flood prone areas, public land
or water resources, emergency management agencies, state and local health
service providers, social service providers, fair housing organizations, state and
local governments, public housing authorities, affordable housing developers,
businesses, community and faith based organizations, and other stakeholders in
the development of the Consolidated Plan through mailings (including electronic
mailings), online postings and public notices in the newspaper.
When preparing the portion of the Consolidated Plan describing the City's
homeless strategy and the resources available to address the needs of homeless
persons (particularly chronically homeless individuals and families, families with
children, veterans and their families, and unaccompanied youth) and persons at
risk of homelessness, the jurisdiction shall consult with:
• The Orange County Continuum of Care (CoC);
• Public and private agencies that address housing, health, social service,
victim services, employment, or education needs of low-income individuals
and families; homeless individuals and families, including homeless
veterans; youth; and/or other persons with special needs;
• Publicly funded institutions and systems of care that may discharge persons
into homelessness (such as health-care facilities, mental health facilities,
foster care and other youth facilities, and corrections programs and
institutions); and
• Business and civic leaders.
When preparing the portion of the Consolidated Plan concerning lead -based
paint hazards, the City shall consult with state or local health and child welfare
agencies and examine existing data related to lead -based paint hazards and
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poisonings, including health department data on the addresses of housing units in
which children have been identified as lead poisoned.
When preparing the description of priority non -housing community development
needs, the City shall notify adjacent units of general local government, to the
extent practicable. The non -housing community development plan must be
submitted to the State of California and to the County of Orange.
The City shall consult with adjacent units of general local government, including
local government agencies with metropolitan -wide planning responsibilities to
identify solutions to problems of a regional nature.
The City shall consult with the Housing Authority of the City of Santa Ana and the
Orange County Housing Authority concerning public housing needs and planned
programs and activities.
As recipients of Emergency Solutions Grant (ESG) funds, the City shall consult with
the Continuum of Care in determining how to allocate its ESG grant for eligible
activities; in developing the performance standards for, and evaluating the
outcomes of, projects and activities assisted by ESG funds; and in developing
funding, policies, and procedures for the operation and administration of the
Homeless Management Information System (HMIS).
The City shall employ, at its discretion, a variety of methods to solicit input from
these persons/service providers/agencies. These methods include, but are not
limited to telephone or personal interviews, focus groups, surveys, internet-based
feedback and consultation workshops.
b. Plan Review and Comment
The complete, draft Consolidated Plan shall be made available for public review
for a 30-day period. The draft Consolidated Plan shall be provided in a format
accessible to persons with disabilities upon request. Such formats may include, but
are not limited to providing oral, Braille, electronic or large print versions of the plan
to those visually impaired and delivering copies to those who are homebound.
The City shall encourage comment and participation by minorities and non-
English speakers. Publication of the availability of the draft Consolidated Plan shall
be in accordance with the City's adopted LEP Plan.
The City shall encourage comment and participation by low- and moderate -
income residents, especially those living in low- and moderate -income
neighborhoods, in areas where CDBG funds are proposed to be used and
residents of public and assisted housing. Activities to encourage participation may
include, but are not limited to, advertising publication of the Consolidated Plan in
target areas, hosting community meetings in target areas, and making copies of
the Consolidated Plan available in these neighborhoods. Copies shall be made
available followina the process described in Section G of this document.
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Written comments shall be accepted by the Executive Director of Community
Development during the public review period. A summary of all written comments
and those received during the public hearing as well as the City's responses shall
be attached to the Consolidated Plan prior to submission to HUD.
c. Public Hearina
The City shall conduct a public hearing to accept public comments on the draft
Consolidated Plan. Section G describes the process for publishing notice for and
conducting public hearings.
d. Submittal to HUD
The Consolidated Plan shall be submitted to HUD with a summary of all written
comments and those received during the public hearing as well as the City's
responses and proof of compliance with the minimum 30-day public review and
comment period requirement. A summary of any comments or views not
accepted and the reasons therefore shall be supplied to HUD as applicable. The
Consolidated Plan shall be submitted to HUD 45 days before the program year
pursuant to regulations, or at such later date as prescribed by HUD.
2. Consolidated Plan Amendments
The City shall follow the following procedure to complete substantial or minor
amendments to the Consolidated Plan, as necessary:
a. Amendment Considerations
The City shall substantially amend the Consolidated Plan if a "substantial change"
is proposed by City staff or the City Council. For the purpose of the Consolidated
Plan, a "substantial change" is defined as:
• More than 30 percent of the most recent annual federal grant allocation is
reallocated to other eligible program activities within the fiscal year.
(Amended amounts will not be cumulative, that is, each amendment will
stand on its own for purposes of determining the 30 percent threshold.)
• An activity is undertaken that was not previously included in the
Consolidated Plan or subsequent annual plans
The City may make minor changes to the Consolidated Plan, as needed, so long
as the changes do not constitute a substantial amendment as described above.
Changes to numeric accomplishment goals within an existing Strategic Plan goal
shall not constitute a substantial amendment. Such minor changes to the
Consolidated Plan do not require a public review and comment period or a public
hearing.
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b. Public Review and Comment
The City encourages residents and stakeholders to participate in the development
of substantial amendments. Substantial Amendments to the Consolidated Plan
shall be made available for public review for a 30-day period. Written comments
shall be accepted by the Executive Director of Community Development or
designee during public review period. A summary of the comments and the City's
responses to the comments shall be attached to the Consolidated Plan Substantial
Amendment.
Given the need to expedite actions to respond to COVID-19 in a memorandum
dated March 31, 2020, HUD waived 24 CFR 91.105(c)(2) and (k), 91.115(c)(2) and
(i). The 30-day minimum for the required public comment period is waived for
substantial amendments, provided that no less than 5 days are provided for public
comments on each substantial amendment through the end of the 2020 program
year.
The City shall encourage participation from all residents, especially low- and
moderate -income residents, minorities, non-English speakers and those with
disabilities. Copies shall be made available in accordance with the process
described in Section G of this document.
C. Public Hearing
The City shall conduct a public hearing to accept public comments on the draft
Substantial Amendment to the Consolidated Plan. Section G describes the
process for publishing notice for and conducting public hearings.
d. Submittal to HUD
A copy of the Consolidated Plan Substantial Amendment, including a summary of
all written comments and those received during the public hearing as well as the
City's responses and proof of compliance with the minimum 30-day public review
and comment period requirement shall be submitted to HUD for their records. A
summary of any comments or views not accepted and the reasons therefore shall
be supplied to HUD. A copy of any minor amendments shall be submitted to HUD
when required.
D. Action Plan
The following describes the process and procedures related to the development of the
Action Plan each year:
1. Plan Development
Each year, the City prepares an Action Plan listing the activities to be undertaken with
Community Planning and Development (CPD) funds. The City shall implement the
following procedures in the development and adoption of the Action Plan:
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a. Plan Considerations
In addition to residents, the City will ensure that members of the public (including
City staff) and private agencies that provide the following services will be
consulted in the development of the Action Plan:
• Health Service Providers
• Social Services for: Children, Elderly, Disabled, Homeless, and Persons
with AIDS
• State and Local Health Agencies
• Adjacent Local Governments
• Housing Authority (Santa Ana and Orange County Housing Authority)
b. Plan Review and Comment
The draft Action Plan incorporating the City's proposed uses of CDBG, HOME, and
ESG funds shall be made available for public review for a 30-day period.
In a manner similar to that set forth for the Consolidated Plan, the City shall
encourage participation from all residents, especially low- and moderate -income
residents, minorities, non-English speakers and those with disabilities. The City shall
make the plan accessible to all such groups. Copies shall be made available
following the process described in Section G of this document.
Written comments shall be accepted during public review period by the Executive
Director of Community Development. A summary of the comments and the City's
responses to the comments shall be attached to the draft Action Plan.
c. Public Hearing
The City shall conduct two (2) public hearings during the preparation of the Action
Plan:
• The first public hearing will be held before the Santa Ana Community
Redevelopment and Housing Commission to accept public comments on
funding priorities for the upcoming year; and
• The second public hearing will be held before the Santa Ana City Council
to accept public comments on the draft Annual Action Plan
The Community Redevelopment and Housing Commission will recommend the
Action Plan to City Council for approval. City Council shall approve, approve
with modifications, or reject the Action Plan. Section G describes the process
for publishing notice for and conducting public hearings.
d. Submittal to HUD
Upon adoption of the Annual Action Plan by the City Council, staff shall submit the
Action Plan to HUD. Documents related to the public participation process,
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including copies of public notices and a summary of all public comments
received, shall be attached to Action Plan. The Action Plan shall be submitted to
HUD at least 45 days before the program year pursuant to regulations, or as
otherwise allowed or required by HUD.
2. Action Plan Amendments
The City shall follow the following procedure to complete substantial and minor
amendments to the Action Plan, as needed:
a. Amendment Considerations
The City shall substantially amend the Action Plan if a "substantial change" is
proposed by City staff or the City Council. For the purpose of the Action Plan, a
"substantial change" is defined as:
• Addition of a new activity not previously identified in the Action Plan,
without regard to funding source;
• Cancellation of an existing activity identified in the Action Plan, without
regard to funding source;
• A change in the purpose, scope, location or beneficiaries of an activity; or
• Changes in the use of CDBG funds from one eligible activity to another
eligible activity meeting the following thresholds:
Net Increase or
Trigger for Substanti
Minor Amendment *
Decrease
Amendment*
> 30% of the most recent
<30% of the most recent
Net Increase
rant allocation
grant allocation
> 30% of the most recent
<30% of the most recent
Net Decrease
rant allocation
grant allocation
* (Amended amounts will not be cumulative, that is, each amendment will stand on its own for
purposes of determining the 30 percent threshold.)
The City may make minor changes to the Action Plan, including any change not
included in the definition of a "substantial change' above, as needed, so long as
the changes do not constitute a substantial amendment as described above.
Such minor changes to the Action Plan do not require a public review and
comment period or a public hearing. However, City Council approval of activity
funding changes may be required based on the amount and City policy.
b. Public Review and Comment
The City encourages citizen participation in the development of substantial
amendments. Substantial Amendments to the Action Plan shall be made
available for public review for a 30-day period. Written comments shall be
accepted during the public review period. Comments should be directed to the
Executive Director of Community Development. A summary of the comments and
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the City's responses to the comments shall be attached to the Action Plan
Substantial Amendment.
Given the need to expedite actions to respond to COVID-19 in a memorandum
dated March 31, 2020, HUD waived 24 CFR 91.105(c)(2) and (k), 91.1 15(c)(2) and
(i). The 30-day minimum for the required public comment period is waived for
substantial amendments, provided that no less than 5 days are provided for public
comments on each substantial amendment through the end of the 2020 program
year.
The City shall encourage participation from all residents, especially low- and
moderate -income residents, minorities, non-English speakers and those with
disabilities. The City shall make the plan accessible to all such groups. Copies shall
be made available following the process described in Section G of this document.
C. Public Hearing
The City shall conduct a public hearing before the Community Redevelopment
and Housing Commission (or a similar standing City Commission) to review and
consider the Substantial Amendment to the Action Plan. The City shall accept
public comments on the Substantial Amendment to the Action Plan at the public
hearing. After public comments are heard and considered, the Commission will
recommend the Substantial Amendment to City Council. City Council shall
approve, approve with modifications, or deny the request for a substantial
amendment to the Action Plan. Section G describes the process for publishing
notice for and conducting public hearings.
d. Submittal to HUD
A copy of the Substantial Amendment to the Action Plan along with copies
documenting the public participation process (i.e. public notices and public
comments) shall be submitted to HUD for their records. Similarly, minor
amendments shall be submitted to HUD.
E. Consolidated Annual Performance and Evaluation Report (CAPER)
The City shall implement the following procedures in the development of the
Consolidated Annual Performance and Evaluation Report (CAPER):
1. Report Development
The City shall develop, approve and submit a CAPER within 90 days of the
conclusion of each program year.
a. Report Considerations
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Staff shall evaluate and report the accomplishments of the previous program year
for all CDBG, HOME, and ESG activities and shall provide information on program
expenditures and other metrics as required by HUD.
b. Review and Comment
The City encourages citizen participation in the development of the CAPER. The
draft CAPER shall be made available for public review for a 15-day period. Written
comments will be accepted during a public review period by the Executive
Director of Community Development.
A summary of any written comments received, or oral comments provided during
the public hearing and the City's responses to those comments shall be attached
to the CAPER submission to HUD. Copies of the draft CAPER shall be made
available following the process described in Section G of this document.
c. Submittal to HUD
Upon completion of the public review period, City staff shall submit the CAPER to
HUD. Documents related to the public participation process, including copies of
public notices and a summary of all public comments received, shall be attached
to the CAPER. The CAPER shall be submitted to HUD within 90 days following the
end of the program year pursuant to regulations.
F. Analysis of Impediments or Assessment of Fair Housing (AI or AFH)
The Analysis of Impediments to Fair Housing Choice (AI) or Assessment of Fair Housing
(AFH) is a five-year plan completed by the City individually or as part of a local
consortium of other HUD grantees pursuant to HUD guidance for the evaluation of local
housing conditions, economics, policies and practices and the extent to which these
factors impact the range of housing choices and opportunities available to all residents
in an environment free from discrimination. As of April 2019, HUD has suspended the AFH
planning framework. HUD currently requires the submission of an Al for grantees
submitting Consolidated Plans for FY 2019. If HUD renews the AFH planning framework,
the AFH will replace the Al in the context and implementation of this section. The following
describes the process and procedures related to the development of the Al or AFH.
1. Plan Development
The City shall implement the following procedure in the preparation and adoption
of the Al or AFH:
a. Considerations
As soon as feasible after the start of the public participation process for the Al or
AFH, the City will make the HUD -provided data and any other supplemental
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information available to residents, public agencies and other interested parties by
posting the data on the City's website and referencing this information in public
notices.
The City will make a concerted effort to notify and encourage the participation of
citizens, local and regional institutions, the local Continuum of Care organization
addressing homelessness, and public and private organizations including
businesses, developers, nonprofit organizations, philanthropic organizations,
community -based and faith -based organizations, broadband internet service
providers, organizations engaged in narrowing the digital divide, agencies whose
primary responsibilities include the management of flood prone areas, public land
or water resources, emergency management agencies, state and local health
service providers, social service providers, fair housing organizations, state and
local governments, public housing authorities, affordable housing developers,
businesses, community and faith based organizations, and other stakeholders in
the development of the Al or AFH through mailings (including electronic mailings),
online postings and public notices in the newspaper, as well as telephone or
personal interviews, mail surveys, internet-based feedback and consultation
workshops.
b. Review and Comment
The draft Al or AFH shall be made available for public review for a 30-day period.
Written comments shall be accepted during public review period by the Executive
Director of Community Development. A summary of the comments and the City's
responses to the comments shall be attached to the Al or AFH. Copies shall be
made available following the process described in Section G of this document.
C. Public Hearing
The Community Redevelopment and Housing Commission (or a similar standing
City Commission) shall conduct a public hearing to accept public comments on
the draft Al or AFH. After public comments are heard and considered by the
Community Redevelopment and Housing Commission, the Commission will
recommend the draft Al or AFH to City Council. The City Council shall approve or
reject the Al or AFH. Section G describes the process for publishing notice for and
conducting public hearings.
d. Submittal to HUD
Upon adoption of an Al or AFH, the City shall retain the Al in its records and
annually report on the status and disposition of the Fair Housing Plan
recommendations. Upon adoption of an Al or AFH, the City shall submit the Al or
AFH to HUD for review and acceptance or rejection. The goals of the Al and AFH
shall be incorporated into the Consolidated Plan prior to submission of the
Consolidated Plan to HUD.
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2. Al or AFH Amendments
The City shall follow the following procedure to complete substantial amendments
to Al or AFH, as needed.
a. Amendment Considerations
The City shall substantially amend the Al if a "substantial change" is proposed by
City staff or the City Council. For the purpose of the Al, a "substantial change" is
defined as the addition or deletion of Fair Housing Plan recommendations.
The City shall substantially amend the AFH if a "substantial change" is proposed
by City staff or the City Council or as otherwise required by HUD. An AFH that was
previously accepted by HUD must be revised and submitted to HUD for review if a
material change occurs. A material change is a change in circumstances in the
jurisdiction of a program participant that affects the information on which the AFH
is based to the extent that the analysis, the fair housing contributing factors, or the
priorities and goals of the AFH no longer reflect actual circumstances. Examples
include Presidentially declared disasters, under title IV of the Robert T. Stafford
Disaster Relief and Emergency Assistance Act (42 U.S.C. 5121 et seq.), in the
program participant's area that are of such a nature as to significantly impact the
steps a program participant may need to take to affirmatively further fair housing;
significant demographic changes; new significant contributing factors in the
participant's jurisdiction; and civil rights findings, determinations, settlements
(including Voluntary Compliance Agreements), or court orders; or, upon HUD's
written notification specifying a material change that requires the revision. A
revision to the AFH consists of preparing and submitting amended analyses,
assessments, priorities, and goals that take into account the material change,
including any new fair housing issues and contributing factors that may arise as a
result of the material change.
b. Public Review and Comment
The City encourages residents and stakeholders to participate in the development
of substantial amendments. Substantial Amendments to the Al or AFH shall be
made available for public review for a 30-day period. Written comments will be
accepted by the Executive Director of Community Development or designee
during the public review period. A summary of the comments and the City's
responses to the comments will be attached to the Consolidated Plan Substantial
Amendment.
The City will encourage participation from all residents, especially low- and
moderate -income residents, minorities, LEP identified groups, and those with
disabilities. The City will take efforts to make the plan accessible to all such groups.
Copies will be made available following the process described in Section G of this
document.
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C. Public Hearing
The City shall conduct a public hearing before the Community Redevelopment
and Housing Commission (or a similar standing City Commission) to accept public
comments on the draft amendment to the Al or AFH. After public comments are
heard and considered, the Commission will recommend the draft amendment to
the City Council. City Council may approve or reject the amendment to the Al or
AFH. A revised AFH must be submitted within 12 months of the onset of a material
change that triggers a "Substantial Amendment," or at such later date as HUD
may specify. Section G describes the process for publishing notice for and
conducting public hearings.
G. Public Hearings, Notification and Access
The following policies and procedures outlining the public hearing process and public
hearing notification apply to the development and substantial amendment of the Citizen
Participation Plan, Five Year Consolidated Plan, Action Plan, CAPER, and Al or AFH.
1. Public Hearings/Meetings
a. Public Hearing Process
The City shall conduct a minimum of two (2) public hearings per year to obtain
citizens' views and comments. These meetings shall be conducted at different
times of the program year and together will cover the following topics:
• Housing and Community Development Needs
• Development of Proposed Activities
• Review of Program Performance
During a program year when the City develops an Al or AFH and Consolidated
Plan, at least one public hearing shall be conducted prior to the draft Al or AFH
and Consolidated Plan being published for comment.
b. Public Hearing Notification
Staff shall ensure adequate advance notice of all public meetings and hearings.
Notices shall be printed/posted at least 14-days prior to the meeting date.
Adequate noticing shall include:
• Publishing a public notice in a newspaper of general circulation; and
• Posting copies of notices on the City website.
Notices shall include information on the topic of the meeting, including summaries
when appropriate, to properly inform the public. Notices shall be published in
accordance with the LEP and shall be accessible to those with disabilities. Meeting
location and access is described below.
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2. Documents for Public Review
Staff shall ensure adequate advance notice of all public review/comment periods.
Notices shall be printed / posted prior to the commencement of the public review
period alerting residents of the documents for review and providing a summary of the
contents of the documents to include information on the content and purpose of the
document and the list of locations where copies of the entire draft document(s) may
be reviewed. The public comment period for each Consolidated Plan Document and
substantial amendment to each document subject to public review is listed below:
Document
Public Comment Period
Citizen Participation Plan
30 days
Consolidated Plan
30 days
Action Plan
30 days
CAPER
15 days
Al or AFH
30 days
The City shall ensure that documents are available for disabled, minority and non-
English speaking residents (Spanish, Vietnamese, and Mandarin in accordance with
City's LEP Plan). In addition, individuals needing a City form, notice or agenda to be
translated to another language, please contact the City of Santa Ana Clerk of the
Council at (714) 647-6520.
Adequate noticing shall include:
• Publishing a public notice in the following newspapers of general circulation:
o English - Orange County Register
o Spanish - La Opinion
o Nguoi Viet -Vietnamese
• Posting copies of notices on the City website; and
• Posting notices at City Hall.
The City shall place an adequate supply of draft copies of each document and
substantial amendments to each document subject to public review at the following
locations:
Community Development Agency
20 Civic Center Plaza, 6m Floor
Santa Ana, CA 92702
City of Santa Ana
Citizen Participation Plan I April 2020
Office of the City Clerk
20 Civic Center Plaza, Room 809
Santa Ana, CA 92702
Santa Ana Main Public Library
26 Civic Center Plaza
Santa Ana, CA 92702
Page 17
75B-38
Public Notices and draft documents shall also be posted to the City website at:
http://www.santc3-anc3.org/cd
All printed reports and materials shall be made available in a form accessible to
persons with disabilities, upon request.
3. Access to Meetings and Hearings
Meetings for items that require Community Redevelopment and Housing Commission
action shall be conducted in front of the Commission at 4:30 P.M. at the Santa Ana
City Hall Council Chambers (22 Civic Center Plaza, Santa Ana, California, 92701).
Meetings for items that require City Council action shall be conducted in front of the
Santa Ana City Council at 4:30 P.M. at the Santa Ana City Hall Council Chambers (22
Civic Center Plaza, Santa Ana, California, 92701). For public meetings or hearings not
requiring action by the Community Redevelopment and Housing Commission or City
Council, the City shall make every effort to conduct such meetings in the low- and
moderate -income target areas and at times accessible and convenient to potential
and actual beneficiaries.
It is the objective of the City to comply with Section 504 of the Rehabilitation Act of
1973, as amended, the Americans with Disabilities Act (ADA) of 1990 and the ADA
Amendment Act of 2008, the Fair Housing Act, the Architectural Barriers Act, The LEP
Plan, and the City's adopted Title VI Plan in all respects.
Individuals with disabilities who need special assistance to participate in City Council
meetings can contact Office of the City Clerk's Department, 20 Civic Center Plaza,
Room 809, Monday through Thursday and alternate Fridays, 8:00 a.m. - 5:00 p.m., at
(714) 647-6520. Requests shall be made at least 48 hours prior to the meeting to
enable the City to make arrangements to assure accessibility.
The City of Santa Ana will provide appropriate auxiliary aids and services whenever
necessary for those individuals who have hearing, sight or speech impairments, unless
to do so would result in a fundamental alteration of its programs or an undue
administrative or financial burden. No surcharge will be placed on a particular
individual with a disability or any group of individuals with disabilities to cover the cost
of providing these auxiliary aids/services or reasonable accommodations. For
information regarding the Americans with Disabilities Act, the City's ADA Transition
Plan, contact the City's ADA Coordinator at (714) 647-5624, (714) 647-6745 (TTY) or
mortiz@santa-anc.org.
4. Access to Consolidated Plan Documents and Records
Approved Consolidated Plan Documents and any approved amendments thereto,
shall be kept on file in the Community Development Agency (20 Civic Center Plaza,
61h Floor, Santa Ana, CA 92704) and online at: http://www.santa-ana.ora/cd
Reasonable efforts shall be made to accommodate requests for documents in other
lonauaaes in accordance with the Citv's LEP Plan.
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Reasonable efforts shall be made to accommodate requests for documents in an
accessible format for those with disabilities. Such formats may include, but are not
limited to providing oral, Braille, electronic or large print versions of the plan to those
Visually impaired and delivering copies to those who are homebound.
Requests for information and records shall be made to the City in writing. Staff shall
respond to such requests within 15 working days or as soon as possible thereafter.
H. Technical Assistance
Technical assistance to applicants for CDBG, HOME, and ESG funds is available from the
Department of Community Development as follows:
• If published, any Notice of Funding Availability (NOFA) shall provide self-
explanatory application form (s) to facilitate access to CPD funds.
• Staff shall answer, in writing, all written questions and answer verbally all verbal
inquiries received from citizens or representative groups pertaining to the NOFA
and application(s).
• Staff shall conduct a project eligibility analysis to determine the eligibility of each
project. In cases where only minor adjustments are needed to make proposals
eligible or otherwise practical, staff shall advise the applicants on the options
available and desired changes to the proposals.
• Staff shall arrange for translation on as -needed basis.
To request technical assistance, contact the Housing Division Manager at (714) 647-
5360.
I. Comments and Complaints
Citizens or the City government, as well as agencies providing services to the community,
are encouraged to state or submit their comments in the development of the
Consolidated Plan Documents and any amendments to the Consolidated Plan. Written
and verbal comments received at public hearings or during the comment period, shall
be considered and summarized, and included as an attachment to the City's final
Consolidated Plan. Written comments should be addressed to: Executive Director of
Community Development, Community Development Agency, 20 Civic Center Plaza, 6+h
Floor, Santa Ana, CA 92702.
A written response shall be sent in response to written comments within 15 working days.
A complaint regarding the Consolidated Planning process and Consolidated Plan
amendments must be submitted in writing to the Community Development Agency. A
written response shall be made to written complaints within 15 working days,
acknowledging the complaint. Written complaints should be addressed to: Executive
Director of Community Development, 20 Civic Center Plaza, 61h Floor, Santa Ana, CA
92702. The City shall accept written complaints provided that the complaint specifies:
• The description of the objection, and supporting facts and data; and
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• Provide name, address, telephone number, and the date of complaint.
J. Appeals
Appeals concerning the Consolidated Plan Documents, statements, or
recommendations of City Staff should be made to the following persons in the order
presented:
• Housing Division Manager
• Executive Director, Community Development Agency
• City Manager
• City Council
• Los Angeles Area Office of HUD (if concerns are not answered)
K. CDBG Disaster Recovery (CDBG-DR)
In the event of a federally -declared major disaster or emergency for which the City of
Santa Ana is to receive and administer HUD disaster recovery assistance pursuant to the
Robert T. Stafford Disaster Relief and Emergency Assistance Act and related
Congressional Appropriations, either directly from HUD or through the State of California,
the following citizen participation requirements shall apply to the development of Action
Plans and Substantial Amendments to Action Plans for disaster recovery:
1. Before the City adopts the Action Plan for a disaster recovery grant or any
substantial amendment to a disaster recovery grant Action Plan, the City will
publish the proposed plan or amendment on the City website and will cross-
reference with any additional disaster recovery websites established to provide
information to the public concerning assistance that may be available.
2. The City and/or subrecipients will notify affected citizens through USPS and/or
electronic mailings, press releases, public service announcements, public
notice(s), and/or through social media.
3. The City will ensure that all citizens have equal access to information about the
programs, including persons with disabilities and Limited English Proficiency Plan
(LEP) persons. Program information will be made available in the appropriate
languages for the City.
4. Subsequent to publication of the Action Plan or substantial amendment, the City
will provide a reasonable opportunity of at least seven (7) days for receiving
comments, or a longer period as prescribed by the Federal Register Notice
governing administration of the HUD disaster recovery assistance.
5. The City will take comments via USPS mail to: Community Development Agency,
Executive Director of Community Development, 20 Civic Center Plaza, 61h Floor,
Santa Ana, CA 92702.
6. In the Action Plan, the City will specify criteria for determining what changes in the
City's plan constitute a substantial amendment to the plan. At a minimum, the
following modifications will constitute a substantial amendment: a change in
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program benefit or eligibility criteria; the addition or deletion of an activity; or the
allocation or reallocation of a monetary threshold of more than $750,000.
A public website shall be established and publicized specifically for the disaster.
Initially, the City's website may be used at: www.sonta-ana.org. The website shall
contain the Action Plan (including all amendments); each Quarterly Performance
Report (QPR); procurement policies and procedures; executed contracts; status
of services or goods currently being procured by the City (e.g., phase of the
procurement, requirements for proposals, etc.).
8. The City will consider all written comments regarding the Action Plan or any
substantial amendment. A summary of the comments and the City's response to
each comment will be provided to HUD or the State with the Action Plan or
substantial amendment.
9. The City will provide a timely written response to every citizen complaint. The
response will be provided within 15 working days of the receipt of the complaint,
to the extent practicable.
10. The Citywill notify HUD when it makes any plan amendment that is not substantial.
HUD or the State will be notified at least five business days before the amendment
becomes effective.
L. Anti -Displacement and Relocation
The City's Anti -displacement and Relocation Plan describes how Santa Ana will assist
persons who must be temporarily relocated or permanently displaced due to the use of
HUD funds. This plan takes effect whenever the City funds projects that involve the
following:
• Property acquisition;
• Potential displacement of people from their homes and the need to relocate
people (either permanently or temporarily); and
• The demolition or conversion of low- and moderate -income dwelling units.
Two acts apply whenever any of the above issues are present: The Uniform Relocation
Assistance and Real Property Policies Act of 1970 (URA) and Section 104(d) of the Housing
and Community Development Act of 1974. Each of these acts place different obligations
on the City.
The URA governs the processes and procedures which the City must follow to minimize
the burden placed on low- and moderate -income tenants, property owners, and
business owners who must move (either temporarily or permanently) as the result of a
project funded in whole or in part by the CDBG, HOME, or ESG programs. The URA applies
to:
• Displacement that results from acquisition, demolition, or rehabilitation for HUD -
assisted projects carried out by public agencies, nonprofit organizations,
private developers, or others;
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• Real property acquisition for HUD -assisted projects (whether publicly or
privately undertaken);
• Creation of a permanent easement or right of way for HUD -assisted projects
(whether publicly or privately undertaken); and
• Work on private property during the construction of a HUD -assisted project
even if the activity is temporary.
Displacement occurs when a person moves as a direct result of federally assisted
acquisition, demolition, conversion, or rehabilitation activities, because they are:
• Required to move; or
• Not offered a decent, safe, sanitary and affordable unit in the project; or
• Treated "unreasonably" as part of a permanent or temporary move.
A person may also be considered displaced if the necessary notices are not given or
provided in a timely manner and the person moves for any reason.
The term displaced person means any person that moves from real property or moves
their personal property from real property permanently as a direct result of one or more
of the following activities:
• Acquisition of, written notice of intent to acquire, or initiation of negotiations to
acquire such real property, in whole or in part, for a project;
• Rehabilitation or demolition of such real property for a project; and
• Rehabilitation, demolition, or acquisition (or written notice of intent) of all or a
part of other real property on which the person conducts a business or farm
operation, for a project.
The City shall cause advisory and financial assistance to be available to eligible tenants
(or homeowners) who meet the above definition.
1. Persons Not Eligible for Assistance
A person is not eligible for relocation assistance under the provisions of the URA if any
of the following occurs:
• The person was evicted for serious or repeated violation of the terms and
conditions of the lease or occupancy agreement, violation of applicable
Federal, State, or local law, or other good cause. However, if the person was
evicted only to avoid the application of URA, then that person is considered
displaced and is eligible for assistance;
• The person has no legal right to occupy the property under State or local law;
• The City determines that the person occupied the property to obtain
relocation assistance and the HUD Field Office concurs in that determination;
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• The person is a tenant -occupant that moved into the property after a certain
date, specified in the applicable program regulation, and, before leasing and
occupying the property, the City or its subrecipient provided the tenant -
occupant written notice of the application for assistance, the project's impact
on the person, and the fact that he or she would not qualify as a "displaced
person" because of the project;
• The person is a tenant -occupant of a substandard dwelling that is acquired or
a tenant -occupant of a dwelling unit to which emergency repairs are
undertaken and the HUD field office concurs that:
o Such repairs or acquisition will benefit the tenant;
o Bringing the unit up to a safe, decent, and sanitary condition is not
feasible;
o The tenant's new rent and average estimated monthly utility costs will
not exceed the greater of: the old rent/utility costs or 30 percent of gross
household income; and
o The project will not impose any unreasonable change in the character
or use of the property.
• The person is an owner -occupant of the property who moves because of an
arm's length acquisition;
• The City or its subrecipient notifies the person that they will not displace him or
her for the project; and
• The person retains the right of use and occupancy of the real property for life
following the acquisition.
The City determines that the person is not displaced as a direct result of the
acquisition, rehabilitation, or demolition for the project and the HUD field office
concurs in the determination.
2. Anti -Displacement Policy
The City will take reasonable steps to minimize displacement occurring as a result of
its CDBG activities. This means that the City will:
• Consider if displacement will occur as part of funding decisions and project
feasibility determinations;
• Assure, whenever possible that occupants of buildings to be rehabilitated are
offered an opportunity to return;
• Plan substantial rehabilitation projects in "stages" to minimize displacement;
and
• Meet all HUD notification requirements so that affected persons do not move
because they have not been informed about project plans and their rights.
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The City seeks to minimize, to the greatest extent feasible, the displacement, whether
permanently or temporarily, of persons (families, individuals, businesses, nonprofit
organizations, or farms) from projects funded with CDBG involving single- or multi-
family rehabilitation, acquisition, commercial rehabilitation, demolition, economic
development, or capital improvement activities.
Projects that the City deems beneficial but that may cause displacement may be
recommended and approved for funding only if the City or its subrecipient
demonstrates that such displacement is necessary and vital to the project and that
they take efforts to reduce the number of persons displaced. Further, they must clearly
demonstrate that the goals and anticipated accomplishments of a project outweigh
the adverse effects of displacement imposed on persons who must relocate.
3. Displacement Assistance
Consistent with the goals and objectives of the CDBG program, the City will take all
reasonable steps necessary to minimize displacement of persons, even temporarily. If
displacement occurs, the Citywill provide relocation assistance to all persons directly,
involuntarily, and permanently displaced according to HUD regulations.
If the City temporarily displaces a low- or moderate -income household, that
household becomes eligible for certain relocation payments. The assistance applies
to those persons residing in the residence at the time the application is processed and
is based on the following procedures:
• If the structure and its occupants are determined eligible for temporary
relocation assistance, the owner -occupants and tenants are eligible for the
actual reasonable cost (based on fair market rent) of temporary lodging
facilities until the structure is determined habitable by the City's inspector;
• The City must approve housing and the Lessor and Lessee must sign a rent
agreement before move -in. Housing must be comparable functionally to the
displacement dwelling and decent, safe, and sanitary. This does not mean that
the housing must be in comparable size. The term "functionally equivalent"
means that it performs the same function, has the same principal features
present, and can contribute to a comparable style of living. Approved lodging
accommodations include apartments and houses. The City does not reimburse
"rental expenses" for living with a friend or family member;
• Either the City will provide the owner -occupants and tenants a direct payment
for moving expenses (to and from temporary housing) and storage costs, or
the City will arrange moving and storage of furniture with a moving company.
If the City makes a direct payment, complete documentation and receipts are
necessary to process claims when storage costs exceed the amount assumed
by the direct payment;
• Damage deposits, utility hookups, telephone hookups and insurance costs are
not eligible for reimbursement; and
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• The City may pay the cost of relocation assistance from Federal funds or funds
available from other sources.
4. One -For -One Replacement Dwelling Units
The City will generally avoid awarding funds for activities resulting in displacement.
However, should the City fund an activity, specific documentation is required to show
the replacement of all occupied and vacant dwelling units demolished or converted
to another use. The City will assure that relocation assistance is provided as described
in 24 CFR 570.606(b) (2).
Before obligating or expending funds that will directly result in such demolition or
conversion, the City will make public and submit to the HUD field office the following
information in writing:
• A description of the proposed assisted activity;
• The general location on a map and approximate number of dwelling units by
size (number of bedrooms) that will be demolished or converted to a use other
than as low- and moderate -income units;
• A time schedule for the commencement and completion of the demolition or
conversion;
• The general location on a map and approximate number of dwelling units by
size (number of bedrooms) that will be provided as replacement units;
• The source of funding and a time schedule for the provision of replacement
dwelling units; or
• The basis for concluding that each replacement dwelling unit will remain a low -
and moderate -income unit for at least ten years from the date of initial
occupancy.
In the implementation of HUD programs, the City will take all reasonable steps
necessary to minimize displacement of persons from their homes. The City will avoid
funding projects that cause displacement of persons or businesses and will avoid
funding any project that involves the conversion of low- and moderate -income
housing to non-residential purposes.
5. Decent, Safe and Sanitary Dwelling
The basic definition is found at 49 CFR 24.2(l). The term decent, safe, and sanitary
dwelling means a dwelling that meets the following standards and any other housing
and occupancy codes that are applicable. It will:
• Be structurally sound, weather tight, and in good repair;
• Contain a safe electrical wiring system adequate for lighting and other
devices;
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• Contain a safe heating system capable of sustaining a healthful temperature
for the displaced person;
• Be adequate to accommodate the displaced person. There will be a
separate, well lit, ventilated bathroom that provides privacy to the user and
contains a toilet, sink, and a bathtub or shower, all in good working order and
properly connected to appropriate sources of water and to a sewage
drainage system. There should be a kitchen area that contains a fully usable
sink, properly connected to hot and cold water and to a sewage drainage
system, and adequate space and utility service connections for a stove and
refrigerator;
• Contain unobstructed egress to safe, open space at ground level;
• For a mobility -impaired person, be free of any barriers that would preclude
reasonable ingress, egress, or use of the dwelling by such person. This
requirement will be satisfied if the displaced person elects to relocate to a
dwelling that they select, and the displaced person determines that they have
reasonable ingress, egress, and the use of the dwelling; and
• Comply with lead -based paint requirements of 24 CFR Part 35.
M. Real Property Policies
The City and its subrecipients must follow specific guidelines regarding the acquisition
and use of real property funded in whole or in part with HUD funds.
1. Use of Real Property
The following standards apply to real property within the recipient's control and
acquired or improved, in whole or in part, using HUD funds. These standards will apply
from the date funds are first spent for the property until five years after the project is
audited and closed.
A recipient may not change the use of any such property (including the beneficiaries
of such use) from that for which the acquisition or improvement was made unless the
recipient gives affected citizens reasonable notice of, and opportunity to comment
on, any such proposed change, and either:
• The use of such property qualifies as meeting a national objective and is not a
building for the general conduct of government;
• The requirements in the paragraph below are met;
• If the recipient determines, after consultation with affected citizens, that it is
appropriate to change the use of property to a use that does not qualify under
the above paragraph, it may retain or dispose of the property. The City must
be reimbursed in the amount of the current fair market value of the property
less any portion attributable to expenditures of non-federal funds for the
acquisition of and improvements to the property;
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If the change of use occurs within five years of the project being audited and
closed, income from the disposition of the real property will be returned to the
City's HUD programs; and
Following the reimbursement of the federal program pursuant to the above
paragraph of this section, the property is no longer subject to any federal
requirements.
2. Real Property Acquisition
All real property acquisition activities described in this section and funded in whole or
in part with CDBG funds and all real property that must be acquired for an activity
assisted with Federal funds, regardless of the actual funding source for the acquisition,
are subject to the URA (as amended).
Real property acquisition is any acquisition by purchase, lease, donation, or otherwise,
including the acquisition of such interests as rights -of -way and permanent easements.
HUD Handbook 1378 and 49 CFR Part 24 currently contains such regulations. These
regulations detail a standard procedure for acquiring property and methods of
determining a purchase price and outline other documents that must be provided to
the City before disbursement of funds. These regulations further require the applicant
to provide relocation payments and assistance to any business or residential
occupant of the property whom the acquisition will displace.
3. Eligible Activities
The City, or its subrecipient may acquire real property for a project using CDBG funds
where the proposed use of the acquired property will be an activity that the City can
demonstrate as beneficial to low- and moderate -income persons.
4. Environmental Review Process (24 CFR Part 58)
HUD requires that all real property acquisition projects be reviewed before the
commitment of Federal funds to assess the impact of a project on the environment.
The City will undertake this review process. The applicant should be aware, however,
that this review process may delay the date by which CDBG funds may be available
and, in case of serious adverse environmental impacts, may effectively stop a project.
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