HomeMy WebLinkAboutApproval of 2008 CDBG Action Plan~,t,f~' ~-~.
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U.S. Department of Housing and Portland, OR 97204-1632
.~r ~ ~ Urban Development (971) 222-2610
4; ~? Region X Portland Field Office FAX (971) 222-2670
'-.~~~~-D~~~~pe~ Community Planning & Development Division
September 18, 2008
Ms. Sarah Wheeler
Assistant City Planner
City of Meridian Planning Department
660 East Watertower, Suite 202
Meridian, ID 83642
Dear Ms. Wheeler:
SUBJECT: 2008 Program Year Action Plan Approval
Community Development Block Grant (CDBG)
~~tVE
pity ®f Meridian
P9anning Department
Thank you for the timely submission of the city's 2008 Action Plan and for providing the
additional information and modifications we requested during our review.
We have completed our review for compliance with the regulations at 24 CFR Part 91 and are
approving Meridian's plan. Please see the enclosed review for HUD's comments on the plan.
Congressional release of CDBG entitlement funds is being requested in the amount of $237,775.
Upon release, we will prepare and forward to The Honorable Tammy De Weerd, Mayor, City of
Meridian, a set of grant agreements for execution.
The effective date for the city's 2008 Action Plan is October 1, 2008. Our approval of the Action
Plan does not constitute a determination that the activities are eligible and in compliance with
program requirements. Responsibility for compliance with program requirements lies with the
city of Meridian.
At this time, we wish to remind the city that the Consolidated Annual Performance and
Evaluation Report (CAPER) for the 2007 program year will be due on or before December 29,
2008. The city must update information in the Integrated Disbursement and Information System
(IDIS) for each activity open at the beginning of the 2007 program year. In addition, please
submit the required narratives as outlined in the "Guide for Consolidated Plan Performance
Narratives" located at http://www.hud.gov/offices/cpd/about/conplan. The narratives must
include an Executive Summary, a summary of resources and geographic distribution of funds,
and the general narratives, e.g., aself-assessment evaluating the city's accomplishments in
achieving the Strategic Plan goals and priorities identified in the city's 2007 - 2011 Consolidated
Plan.
www. hud.gov/oreyon
2
A Financial Summary report must also be submitted with the CAPER that includes a
reconciliation of the city's CDBG financial records with LOCCS data as of September 30, 2008,
the end of your 2007 program year.
We look forward to working with the city on the effective implementation of the activities
described in your Annual Action Plan. If you have any questions, please contact Murrianna K.
Thomson, CPD Representative, on 971-222-2621 or via email at
Mu~rianna.K. Thomson@hud.gov.
Sincerely,
~~
oug Carl on, Director
Community Planning and Development
Enclosure
Comments on the City of Meridian, Idaho's Action Plan
for Program Year (PY) 2008
Community Development Block Grant Program (CDBG)
The city of Meridian's second Action Plan for the period covered by the Consolidated
Plan for FY 2007 - 2011 describes the city's proposed use of CDBG funds in FY 2008
(October 1, 2008 -September 30, 2009) to address pressing community needs in
accordance with the strategies, goals, and objectives in its Consolidated Plan.
We provide these comments to give feedback on the city's 2008 - 2009 Action Plan and
to assist the city in clarifying and developing future action plans. Comments are
provided by the following HUD offices:
I. Community Planning and Development, Portland Field Office
II. Director, Boise Field Office
III. Fair Housing and Equal Opportunity (FHEO), Seattle Regional Office
IV. ,Office of Public Housing, Seattle Regional Office
Regarding future submissions:
- The items listed with an arrow indicate areas where the city should expand their
narrative or provide additional supporting documentation
I. COMMUNITY PLANNING AND DEVELOPMENT, Portland Field Office
This section summarizes the review of the city's Annual Action Plan by the Community
Planning and Development Division in the Portland Field Office.
Citizen Participation t6 91.1051
The narrative demonstrates that the city has fulfilled the requirements for citizen
participation.
In support of your narrative on the city's citizen participation plan, in future years, please
provide:
- Copies of ads placed in newspapers advertising citizen participation
opportunities
- Copies of any announcements posted on city property or libraries announcing
citizen participation opportunities
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Strategic Plan ~§ 91.215(a)(1)1
- Please be sure to label those items in your Action Plan that fulfill the
requirements of the Strategic Plan
Action Plan ~§ 91.2201
Includes SF-424 ~§ 91.220(a)]
The city's application for federal assistance includes the city's DUNS number and is
signed by the Mayor. Please note that the amount of CBDG funding the city is to
receive has been adjusted by HUD since the original award amounts were announced
in January 2008. The new PY 2008 CDBG grant amount for the city of Meridian, Idaho
is $237,775. Please amend your copy of the SF- 424 to reflect the new approved
amount (a reduction of $14). Per our request during the review, the city has modified
the amounts it has allocated for administration. There was no need to modify the
amounts allocated for this year's activities. The city has provided HUD corrected tables
that reflect the revised CDBG funding.
Executive Summary (§ 91.220(b)]
The city's executive summary included all required information and summarized the
objectives and outcomes identified in the plan.
- In future years, please be sure to provide the correct citation for "Summary of
Public Comments." The citation provided [§ 91.220(c)] was incorrect and should
have been § 91.220(b).
Resources and Objectives ~§ 91.220(c)]
Federal Resources [§ 91.220(c)(1)] -The city listed other federal resources
expected to be available, as required by the regulations.
Other Resources [§ 91.220(c)(2)] -The city listed resources from private, state,
and local sources that are reasonably expected to be made available to address
the needs identified in the plan as required by the regulations.
Annual Objectives [§ 91.220(c)(3)] -The city summarized the specific annual
objectives expected to be achieved in the Summary of Specific Annual
Objectives tables as required by the regulations.
Activities to be Undertaken ~§ 91.220(d)]
The city has described each activity for the program year. Our office requested and
received modified tables reflecting the funding amounts, national objectives, proposed
outcomes, and performance measures. The tables now include all the required
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information on objectives, proposed outcomes and accomplishments, proposed units,
funding amounts, types of families/businesses that will benefit from the activities, and
target dates for completion as required by the regulations.
Expenditure limits -The City has not exceeded the 20% CDBG administrative cap nor
has it exceeded the 15% CDBG public service cap, based on the 2008 grant amount of
$237,775.
Outcome Measures ~§ 91.220(e)]
Each action plan project includes a proposed outcome and a performance measure as
required.
- In future years, please be sure to provide the outcomes and performance
measures in a format that more closely follows the guidance found in the
Federal Register dated March 7, 2006.
Geographic Distribution ~§ 91.220(fl]
The city's action plan provided Census Tract, Block Group maps of the CDBG income
qualified areas provided by Ada County. The city also indicated that some of the
activities would be available city-wide but would primarily benefit LMI citizens.
- In future years, please expand your narrative on geographic distribution to
include a rationale for choosing the target area(s) that you select beyond the fact
that they are L/M (i.e., Why this L/M area and not another L/M area? Or why all
three L/M areas?)
Affordable Housing ~§ 91.220(g)]
The requirements were met through the city's use of Table 36, Annual Housing
Completion Goals.
Public Housing ~§ 91.220(h)]
There is no public housing in Meridian. The Section 8 housing choice voucher program
is managed by the Boise City/Ada County Housing Authority and the city is not involved.
Homeless and Other Special Needs Activities (§ 91.220(1)]
Meridian provided a brief narrative responding to the requirement for information on
Sources of Funds, Homelessness, Chronic Homelessness, Homelessness Prevention,
and Discharge Coordination Policy. The city did not initially provide a narrative
addressing the needs of other special needs populations but provided an expanded
narrative for this section to fulfill the basic requirements with assurances that the
section will be expanded in future years as more data becomes available.
3 of 5
- In future years, please expand the portion of this narrative that concerns the
needs of the homeless. This could be accomplished by obtaining a description
of the local continuum's plan and incorporating it into Meridian's Action Plan
narrative. By doing so, the city would then be able to provide a better synopsis
of what Meridian is planning in conjunction with other agencies to address the
issues under this heading.
Barriers to AfiFordable Housing [§ 91.220Q)]
The city described the actions that it will take during the next year to remove barriers to
affordable housing.
Other Actions ~§ 91.220(k)]
The city addressed the actions it will take to address the following:
• Foster and maintain affordable housing
• Evaluation and reduction of lead-based hazards
• Developing institutional structures/enhancing coordination between housing and
service agencies
Program Specific Requirements (~§ 91.220(1)]
CDBG [§ 91.220(1)(1)]
Activities [§ 91.220(I)(1)(i)] -The city's proposed CDBG projects are
adequately described.
Funds Available [§ 91.220(I)(1)(ii)] -The city has made the necessary
adjustments to the 2008 - 2009 program year funding distribution and the total of
all CDBG activities equals the revised CDBG funding amount of $237,775. The
city has no other related funds available for use this program year.
Urgent Needs [§ 91.220(I)(1)(iii)] -None of the city's proposed activities were
identified as an "urgent need."
- In future years, we would suggest the city include in the narrative describing
the proposed activities a statement referring to the fact that, at the time of
submission, the city does not have any urgent needs
Low- and Moderate-Income Benefit [§ 91.220(I)(1)(iv)] -All CDBG activities
have been designated by the city as benefiting low- and moderate-income
citizens per information provided on the tables for the proposed activities.
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II. DIRECTOR, BOISE FIELD OFFICE
Meridian's Action Plan for 2008 is focused on HUD's compliance requirements. It is a
good plan. City staffers have done a good job working to connect to a wide variety of
community partners and it appears this outreach is ongoing.
Meridian staffers have also done a good job identifying both geographic neighborhoods
(LMI) that need to be served using CDBG funding as well as a variety of specific
community needs within the identified neighborhoods. The projects undertaken with
the Senior Center represent a good example of a starting point in delivering assistance
to citizens in need. It is intriguing to see the plans for providing affordable housing in
cooperation with Boise Valley Habitat for Humanity.
The purchase and use of a HUD Dollar Home (HUD Single Family Good Neighbor
Program) may leave the city waiting for quite a while to purchase one, as while these
homes have been available in Idaho, availability has been sparse.
All in all, it is a good plan and it represents a solid start to a community taking on a new
status as an Entitlement Community.
III. FAIR HOUSING AND EQUAL OPPORTUNITY (FHEO), Seattle Regional Office
The grantee did not address housing needs by race/ethnicity. Therefore, we were
unable to determine the extent of housing needs among different groups in the service
area, nor how the grantee is addressing those needs. We request that in all
subsequent Annual Plans, the grantee include a description of the geographic areas of
the jurisdiction (including areas of minority concentration) in which it will direct
assistance during the ensuring program year, giving the rationale for the priorities for
allocating investment geographically. Also, the grantee did not identify actions it would
be taking to address Fair Housing impediments. Therefore, we request that the grantee
be notified that it must identify actions to address Fair Housing impediments every year.
IV. OFFICE OF PUBLIC HOUSING. Seattle Regional Office
The Plan is considered complete with no items missing in any of the reviewed areas.
We have no comments.
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Federal Register /Vol. 71, No. 44 /Tuesday, March 7, 2006 /Notices 11471
be incorporated into the Consolidated
Plan Management Process {CPMP) Tool
so that local objectives and outcomes
can be entered at the beginning of the
Consolidated Plan or Annual Action
Plan development process, and
accomplishments under those objectives
and outcomes can be reported on in the
CAPER.
II. Discussion of Public Comments
General Comments
The public comment period closed on
September 8, 2005. In addition to the 56
comments submitted in writing to HUD
headquarters, additional comments
were received during an interactive
satellite broadcast from HUD
headquarters in Washington, DC, and
five regional feedback sessions that were
held in San Francisco, Philadelphia,
Detroit, Atlanta, and Austin. Each of
those events provided opportunities for
public comment.
There were multiple requests for HUD
to develop a performance measurement
Web site that would contain all the
information that has been made
available. That request has been
acknowledged and there is now a CPD
Web site that hosts this information.
The URL is: http://www.hud.gov/offices/
cpd/about/performance/index. cfm.
A number of comments praised the
outcome measurement system and
thanked HUD and the working group for
the simplicity of the system; also, many
comments posed questions. These
questions are addressed in a question
and answer format that has been
distributed to grantees and is available
on the Performance Measurement Web
site. Several comments requested
clarification of terms and definitions.
These have been provided to grantees
and are available on CPD's Performance
Measurement website.
There were also many comments
made about IDIS that were important to
that system, but not necessarily relevant
to the inclusion of the performance
measurement indicators. Those .
comments have been forwarded to
CPD's System Development and
Evaluation Davision. There were also
comments on the Consolidated Plan
Management Process and those
comments have been forwarded tb
CPD's Office of Policy Development and
Coordination.
Many comments suggested that issues
and terminology of local interest be
added to the framework. Unfortunately,
because the framework was developed
to capture national indicators in a
standardized format, unique local
information cannot be included.
However in CPD Notice 03-09, issued in
September 2003, HUD encouraged
grantees to develop local performance
measurement systems that complement
this new national system by capturing
the results of activities of local
importance.
Specific Comments
Comment There were several
comments indicating that these
performance measures should replace
Consolidated Plans, Annual Action
Plans, Consolidated Annual
Performance and Evaluation Reports
(CAPER), and Performance Evaluation
Reports (PER).
Response-HUD anticipates that
when Phase II of the IDIS re-engineering
is complete in 2007, Consolidated Plans,
Annual Action Plans, CAPERS, and
PERs will become one continuous
document.
Comment-There were several
comments indicating the need for
training on the performance
measurement system and generally on
IDIS, and specific training for
entitlements, states, and urban counties,
sub-recipients; training grantees to train
their sub-recipients; and guidance/
training on how the indicators apply to
each program.
Response-HUD expects to provide
training on IDIS in 2006. This training
will incorporate the performance
measurement framework; also, HUD has
prepared guidance, questions and
answers, and definitions. This, along
with other related information, are
available on CPD's Performance
Measurement website.
Comment-Several commenters
indicated that changes to administrative
procedures, and possibly to grantee
staffing, would have to be made at the
local level and some asked that HUD
provide assistance to tell grantees how
this should be done.
Response-HUD will provide training
on what data will need to be collected,
but grantees will determine within their
own administrative procedures how to
coordinate the front-end planning,
implementation, and reporting of
activities. Because grantee procedures
vary significantly based on agency size
and expertise, HUD is not the
appropriate entity to develop local
administrative procedures for grantees.
Comment-Some comments referred
to the difficulty that grantees would
have in developing outcome statements.
Response-HiTD will use the data that
are reported and aggregated in IDIS to
develop the outcome statements. If a
jurisdiction has an activity that does not
fit into the framework, that grantee may
create an outcome statement in the
narrative of the CAPER or PER to
provide information to their citizens
about the results of the activity.
Comment-Comments asked that
HUD clarify the timing of when grantees
will begin}tsing the performance
measurement system.
Response-The elements of the
outcome performance measurement
system will appear in the existing
version of IDIS in Spring 2006. Because
of the need for HUD to show results,
grantees will be requested to enter data
as soon as the system is available. Later
in 2006, Phase I of the re-engineered
IDIS will be released. At that time,
grantees will be required to enter the
performance data into the system.
Comment-There were comments
suggesting that 40 percent be included
in the breakout of numbers for area
median income because this number
would help show the percentage of
"working poor;" that many projects.
exceed the HOME program minimum
levels and assist persons between 30
percent and 50 percent; and that
breaking down those income levels
would cause additional work for CDBG
grantees.
Response-Individual program
requirements dictate the income
percentages that are to be reported.
Therefore, grantees need only provide
the information that is currently
required for each specific program. The
area median income percentages
published in this notice reflect the range
of information required by all four CPD
formula grants. When grantees enter
data for activities into IDIS, only the
income percentages applicable to those
program activities will be populated for
selection.
Comment-Several commenters urged
HUD to provide sufficient time for
grantees to revise forms and other
business practices, that data collection
should not begin until the re-engineered
IDIS is available, and that information
pertinent to these changes should be
made available to grantees as soon as
possible.
Response-On October 28, 2005, CPD
issued a memo that provided the basic
information needed to revise forms,
such as applications from sub-recipients
for funding, sub-recipient agreements,
and client applications. Grantees could
also use that memo to begin to plan for
any administrative changes that might
be required.
Comment-Some commenters
requested that an indicator for section
504 compliance be included for owner-
occupiedhousing units.
Response-HUD agrees. Although
section 504 does not apply to
homeowners, the accessibility indicator
has been added for owner-occupied
Federal Register /Vol. 71, No. 44 /Tuesday, March 7, 2006 /Notices 11473
ffi. Envir®nmental Impact
This notice does not direct, provide
for assistance or loan and mortgage
insurance for, or otherwise govern or
regulate, real property acquisition,
disposition, leasing, rehabilitation,
alteration, demolition, or new
construction, or establish, revise or
provide for standards for construction or
construction materials, manufactured
housing, or occupancy. Accordingly,
under 24 CFR 50.19(c)(1), this notice is
categorically excluded from
environmental review under the
National Environmental Policy Act of
1969 (42 U.S.C. 4321).
Dated: March 1, 2006.
Pamela H. Patenaude,
Assistant Secretary for Community Planning
and Development.
BILLING CODE 4210-67-P
Federal Register /Vol. 71, No. 44 /Tuesday, March 7, 2006 /Notices 11475
IDIS will begin accepting data in Spring 2006 and HUD is strongly encouraging every
grantee to begin to enter data at that time for all completed activities, based on information that is
available. The objectives and indicators reported in IDIS will reflect the rationale for funding
that activity. The outcome will be based on the result the grantee hoped to achieve by funding
the activity, The indicators will describe, in numerical terms, any particular benefit that the
activity produced. In Fa112006, it will become mandatory for all formula grantees to enter the
required performance measurement data (objectives, outcomes, and indicators) into IDIS for all
existing activities with a status of budgeted or underway as of the beginning of FY2007, as well
as for all new activities.
Grantees are only required to report the indicators that appear for each activity; however,
if a jurisdiction has activities that are not covered by these indicators, grantees can manually
report any objectives, outcomes, and indicators in the narrative section of the Consolidated
Annual Performance and Evaluation Report (CAPER) or State Performance Evaluation Report
(PER), or HOPWA Annual Performance Report (APR).
The system has been, designed to enable grantees and HUD to inform Congress, OMB,
and the public of many of the outcomes of the covered programs. The goal is to begin focusing
on more outcome-oriented information and be able to aggregate results across the broad
spectrum of programs funded by these block grants at the city, county, and state level.
>EiOW WILL IT WORK?
Based on the intent when funding an activity, grantees will determine which of the three
objectives best describes the purpose of the activity. The objectives will appear on an IDIS
screen and the grantee will choose from the options presented. The three objectives aze:
Suitable Living Environment - In general, this objective relates to activities that are designed to
benefit communities, families, or individuals by addressing issues in their living environment.
Decent Housing -The activities that typically would be found under this objective aze designed
to cover the wide range of housing possible under HOME, CDBG, HOPWA or ESG. This
objective focuses on housing programs where the purpose of the program is to meet individual
family or community needs and not programs where housing is an element of a larger effort,
since such programs would be more appropriately reported under Suitable Living Environment.
Creating Economic Opportunities -This objective applies to the types of activities related to
economic development, commercial revitalization, or job creation.
Similarly, once the objective for the activity is selected, the grantee will then choose
which of the three outcome categories best reflects what they are seeking to achieve by funding
that activity, and then enter the outcome on the appropriate IDIS screen. It is important that the
data are not diluted by too much information. Therefore, grantees are encouraged to report
which one of the three outcomes is most appropriate for their activity. However, if the grantee-
believes that two outcomes of equal importance will be realized, then a second outcome may also
be selected. The three outcome categories are:
Federal Register /Vol. 71, No. 44 /Tuesday, March 7, 2006 /Notices 11477
There are certain data elements commonly reported by all programs, although each of the
four programs may require different specificity or may not require each element listed below.
Grantees will only report the information required for each program, as currently required. No
new reporting requirements are being imposed for program activities that do not currently collect
these data elements. The elements include:
• Amount of money leveraged (from other federal, state, local, and private sources) per
activity;
Number of persons, households, units, or beds assisted, as appropriate;
• Income levels of persons or households by: 30 percent, 50 percent, 60 percent, or 80
percent of area median income, per applicable program requirements. However, if a
CDBG activity benefits a target area, that activity will show the total number of persons
served and the percentage of low/mod persons served. Note that this requirement is not
applicable for economic development activities awarding funding on a "made available
basis;"
Race, ethnicity, and disability (for activities in programs that currently report these data
elements)
HUD will combine the objectives, outcomes, and data reported for the indicators to
produce outcome narratives that will be comprehensive and will demonstrate the benefits that
result from the expenditure of these federal funds.
This system maintains the flexibility of the block grant programs, as the objectives,
outcomes, and indicators will be determined by the grantees, based on the intent of the activities
they choose to fund. The standardized format provides that reporting will be uniform, and
therefore the achievements of these programs can be aggregated for each grantee locally and for
a1T grantees at the national level.
Specific Outcome Indicators
1) Public facility or infrastructure activities
Number of persons assisted:
• with new access to a facility or infrastructure benefit
• with improved access to a facility or infrastructure benefit
• where activity was used to meet a quality standard or measurably improved quality,
report the number that no longer only have access to a substandard facility or
infrastructure
2) Public service activities
Number of persons assisted:
• with new access to a service
• with improved access to a service
• where activity was used to meet a quality standard or measurably improved quality,
report the number that no longer only have access to substandard service
Federal Register /Vol. 71, No. 44 /Tuesday, March 7, 2006 /Notices 11479
Number of units of permanent housing designated for homeless persons and
families, including those units receiving assistance for operations
Of those, number of units for the chronically homeless
7) Rental units rehabilitated
Total number of units:
Of total:
Number affordable
Number section 504 accessible
Number of units created through conversion of nonresidential buildings to
residential buildings
Number brought from substandard to standard condition (HQS or local code)
Number qualified as Energy Star
Number brought into compliance with lead safe housing rule (24 CFR part 35)
Of those affordable:
Number occupied by elderly
Number subsidized with project-based rental assistance (federal, state or local
program)
Number of years of affordability
Number of housing units designated for persons with HIV/AIDS, including those
units receiving assistance for operations
Of those, the number of units for the chronically homeless
Number of units of permanent housing for homeless persons and families,
including those units receiving assistance for operations
Of those, number of units for the chronically homeless
S)1FIonieownerstup Units Constructed, Acquired, and/or Acquired with Rehabilitation (per
project or activity)
Total number of units
Of those:
Number of affordable units
Number of years of affordability
Number qualified as Energy Star
Number section 504 accessible
Number of households previously living in subsidized housing
Of those affordable:
Number occupied by elderly
Number specifically designated for persons with HIV/AIDS
Of those, the number specifically for chronically homeless
Number specifically designated for homeless
Of those, number specifically for chronically homeless
F'ederafl 12egister /Vol. 71, No. 44 /Tuesday, March 7, 2006 /Notices 11481
16) Jobs retained
Total number of jobs
Employer-sponsored health care benefits
17~ Businesses assisted
Total businesses assisted
New businesses assisted
Existing businesses assisted
Of those:
Business expansions
Business relocations
SUNS number(s) of businesses assisted
(HUD will use the DUNS numbers to track number of new businesses that remain operational
for 3 years after assistance)
18) Does assisted business provide a good or service to meet needs of service
area/neighborhood/commututy (to be determined by community)?
[FR Doc. 06-2174 Filed 3-3-06; 12:08 pm]
BILLI(VG CODE 4216-67-C