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CDBG Action Plan Council Memo Resubmittal 102009October 20, 2009 MEMORANDUM TO: Mayor De Weerd and City Council FROM: Matt Ellsworth CC: Anna Canning Caleb Hood RE: PY 2009 CDBG Action Plan Revisions BACKGROUND The City adopted the Program Year 2009 (PY09) CDBG Action Plan with Resolution 09-678 on August 11, 2009. The Plan was then forwarded to HUD for review. UPDATE On September 28, 2009, staff received a letter from HUD requesting some additions and revisions to the City-adopted Action Plan. The letter directs the City to submit a revised Action Plan to HUD by October 23, 2009. Until HUD approves the PY09 Action Plan, the City cannot access CDBG funds for the current program year (October 1, 2009 -September 30, 2010). The letter and comments from HUD are included as Attachment 1. Based on HUD's comments and a review of the City-adopted PY2009 Action Plan, staff proposes the following changes: Change: Reduce total entitlement for PY2009 from $249,962 to $249,947. Reason: The actual award from HUD will be $151ess than their original estimate. Change: Increase budgeted amount for Program Administration from $49,467 to $49,947. Reason: The City used its entire Administration budget in PY2007, and is on pace to do the same in PY2008. Administration covers, among other things, City staff time spent administering/monitoring the program, and fulfilling various additional requirements. This is an administratively intense program, and staff feels that it is important for the City to receive the fullest allowable reimbursement for resources devoted to its implementation. HUD caps Planning Department . 33 E. Broadway Avenue Meridian, ID 83642 Phone 208-884-5533 . Fax 208-888-6854 . www.meridiancity.org Page 2 administrative expenditures at 20% of each annual entitlement, and the proposed budgeted amount is 19.98% of the PY09 award. Change: Decrease budgeted amount for Meridian Food Bank from $20,494 to $20,000. Reason: The increase in funding for Administration has to come from somewhere, and there are unused public service dollars from other activities in previous program years that can more than offset the reduction in PY09. As a result the Food Bank will actually receive a small increase in funding for the next 12 months over what is proposed in the City-adopted Action Plan. Staff discussed this change with the Food Bank on October 7, and they support it. The remainder of changes requested by staff will not impact proposed activities or their budgets; they are mostly "clean-ups" requested by HUD. A rundown of additional changes to the PY09 Action Plan is included as Attachment 2. ACTION REQUESTED That City Council approve Resolution Plan as described herein. Resolution _ revising the PY2009 CDBG Action is included as Attachment 3. NEXT STEPS Staff will forward the revised PY2009 Action Plan back to HUD to consider and (hopefully) approve so that the City can secure the next round of CDBG funding. Page 3 Attachment 1: Letter & Comments from HUD on PY2009 Action Plan ~tneti~o~ QPP 1 ~c~ U.S. Departmen$ D~ Housing arld 40E} Southwest Sbcth Avenue. suite 7t)© 1 Pprtiand, 4R 97204-1632 ~~~ I ~ .~ ~ Urban Development ~g71j X22-2s1o o~ ~~ a`` Regipn X Pprtland Field Oftice FAX (871}222-2670 9°.vru csv~~~Y Comnlunlty Planning ~ Devetflpment D'nns~on September 23, 2049 ,~ ~=t5r~~.. ;;~~~,y !~~ .~,, (- Matthew P. Ellsworth ~, ~t ;, _. ' ~ `' `~ ~~'~ ~~ Associate Planner & CDBG Administrator ' ` ' City of IWleridian Planning Depar~ent ~~ t~~ ; ff ; : ~. ~ ~ i ~ : 33 East Broadveay y~ g ~y q,N.~ ~y ~ ~ y ~ RL¢ ~~~f~Yi F.S;S T ~~+~P Sr;.~f,~; 8 a!t:'W ii Meridian, ID 83612 Dear Mr. EIIs«=orth: SUBJECT: City of Meridian 2449 Annual Action Plan We are providing the enclosed review comments to provide feedback to the cit~- on its Annual Action Plan for Program Year 2009. They summarize our review of the city's Plan to meet the requirements at 24 CFR Part 91. The Annual Action Plan was received prior to the due date of August 16, 2049. Out review revealed a very organized and easy to read Annual Action Plan. This expedited the review proeeess and we encourage the city to continue to use this format in future submissions. While the submission was detailed, it did not provide all of the infoi~naliori ~rQquired by the regulations. Our review comrrients should be used to assist the city in clarifying the current Plan, Please submit a zevised Annual Action Plan within 30 days of the elate of this letter. Your cooperation and oversight of the CDBG program which benefits lave- aitd moderate-income residents in Meridian is sincerely appreciated. V4'e look forward to working with the city to meet the goals of its 2p09 Annual Action Plan. Please contact 1Vlumanna K, Thomson, CPD Representative, at 971-222-2621 or via email Atufrranrtt~K Thonrson~.6r gvv should you have questions regarding the CDBG program. Sincerely, lson, Director Cornitiunity Planning and J3evelopment Page 4 Comments on the City of Meridian, Idaho's Annual Action Plan Program Year 20x9 Community Development Block Grant Program (CDBG) CUMMUNI~'Y PLANNING AND DEVELOPMENT The following narrative contains the results of HUD's review of the Annual Action Flan for the city of Meridian. i Please note that any comments in bolded italics and ararlred n,ith an arrow are t® be addressed by tl:e city As an appendix to our comments, we are enclosing a copy of HUD's Annual Action Review Checklist for the qty's use when responding. If the information in question has been included in fire city's Annum Action Plan and HUD was unable to locate that information, please indicate the page or pages where we may find the missing information. General Comments The city of Meridian's Annual Action Plan for the year 20U9 was submitted on hme. The discussion of citizen participation efforts was ineiudeci in the Annual Action Plan as required. Y Please provide proof ofpublecation and a copy of the pubtlc announcement that open:ed the 30 day public comment period (Question 7, page 1) Action Plan 24 02.91,220 'i'he Standard Form-~24 was provided and signed by ttie appropriate official. Please provide a corrected SF-424 reflecting tlae revi?ced funding amount for the city of t'~lerldian for PY20D9 of X249,947 (Question 1, page I) 3> Revisions to funding amoreuts are needed on the f®llowing pages, based on the fundiftg amount of >~2d9,947: • 3-S • 11-14 17 • 31-37 (Table 3C) • SI-S4 (SF-424) Page 1 of 7 Page 5 Comments on the City of Meridian, Ids~ho's Annual Acfian Plan Program Year 2009 Community Development Block Grant Program (CDBG} 1=Iomeless and Qther S ecial Needs Activities 24 CI'R 91.220 i The city wss io include narrative indicating if supportive housing activities were being undei4aken to address the priority housing needs of persons who sire not homeless (elderly, frail elderly, persons with disabilities, persons with )FIIV/AIDS, persons with alcohol or other substance abuse problems). `r Please provide additional narrative addressing the supportive f:Dosing needs irrentivned strove (Qrcestinn 3, page 3) Other Actions 24 C1+R 91.220 The information provided by the city was sufficient to satisfy the requirements in this section. Pro ram S ecific Ire uirements 24 CFR 91.220 CDBG The total amount of funds allocated did not equal the amount of the grant. t~lien rise Tables 3C have beets revised; please ensure that the fialydiug allotted to eaelr aetivaty wiU add up to sire grant amount (Questlnn 1 a, page 4) NOME This section is not applicable to the city of I~ieridian. American Dream Dorvnpavit~ent Initiative This section is not applicable to the city of Meridian. ~-Ialir~a This section is not applicable to the city ofMeridisin. Page ~ of 7 Page 6 Comments on the City of Meridiaa, Idaho's Annaal Action PIan Program Year 2009 Community Development Block grant Program (CDB~} Nlonitorin 24 GFR 91..230 The Action Plan was to describe the standards and procedures that the city will use to monitor act~vthes tamed out in furtherance o£the plan. `i' Please prQVl(le ITtlrrat~Ve reSpF)P1dIlTg t0 tITTS r@gTTa~PCiTaBITt (QG[BS1~tlTT X, page S) The Action Plan was to describe the actions to be taken by the city to monitor its performance in meeting its goats anti objectives set forth in its Consolidated Plan. v Please provide Taarrative respaTadirTg to tdais regTTtrerTTeaat (+QuestiQTa Z, page S) The Action Plan was to describe the steps/actions being taken to ensure compliance with prograixi requirements, including requirements involving the timeliness of expenditures. ~ Please provide --arrative resp©ridutg to this T'equireTTTeTTt (QuestTVrT. 3, page b) The Action Plaii was to describe the stepsiactions tite city will use to ensure tong-term compliance with housing codes, including any actions or on-site inspections it plans to undertake dunng the program year. S= Please provide rTarrutive respoTidUag to tlils regT-iretne-Tt (QTTest~a~T 4, page d) The Action Plan was to describe actions to betaken by the city to monitor its subrecipients, ineiudin€; sponsors or adaaiiiistering agents. ~ Please prQVTde Trarratdve responding to Haas requirement (QTTestfoTT S, page 8) Certificati©ns 24 CFI2 91.225 Our review included ensuring the completeness and accuracyofrequireri certifications, All certifications were in order. Pale ~ of 7 Page 7 Comments on the City of meridian, Idaho's Annual Action Pian Program Year 2409 Community Developmen# Bloc1~ Grant Pr®gram (GDBG} Tables The tables that Meridian has submitted for PY 2009 are conriplete with the exceptyon of Table 3C. i~ As naenttoned utrder the Action Plan l:eaditsg, please revise adl aetivit~tx(wading amotatts and resubmit Table 3C for ail PY 2004 activities to include the following additional adjustments: i~ Project Title -Boise Cdt~~/Ada County 1FloushzgAuthorlty Honaeownershdp Please indicate the estimated nutnber of un~s upon completion when resubmittuag TJie Objeetlve on the table in item 3 on page 12 of the Plata shoaald be changed to LMI1' Y Project Title - Cerrtergsrial Park After review of tl:is aetevity, we feel that t#ae rorre~ct Matrix Code should be 31{ {Parks, Recreational 1~'actlities) Addlttonally, fire A,nnttal Units and Utalts Upon Completion do not tttatclt the Performance Indicators found on Table 3A {five residents vs. one unit) and the suggest that the Performance Indicators on Table 3A may need to be adjusted for PY 2009 aaad the MuUI--Year Goal statement revised tlttder the descriptlott the last sentence indicates flied tfie cdty will prepare a survey; in fact, the city wild be completing a survey and we as the city to prouide a revised description when updalutg this table A Project Title -Five Mile Creek Patlawrry, Segment H. 1 After review of this actlv&Sa, we feel the correct Matrix Code should be 3E {1Veigliborhood Factltties; there is no change to the CDBC Citation Additionally, tide Annual Units and Units ITpon Completion rlo taot ttrtrtch the Performance Indicators found on Table 3A {j"ave residents v~ One facility improvement and we suggest brat the Performance Indicators on Table 3A may need to be adjusted for PY 2009 and tlae Mufti-Year Goal statement revised ~i` Project Title -Boys & Girls Club Transportation Program After review of this activity, we feel the correct Matrix Code sJtould be OSE {Transportation Services) and the correct CDBC Citation should be 24 CFR 570.ZOX {e) AddltYonally, as the activvity proposes to serve aLow/Mod Clientele {LMC), Please review LMC criteria footed in tlae CDBG Desk Guide starting on page 3-I4 to ensure tired the city will 8e able to document that at least 51 % of the betrejlciaries of the activity will be L/M lncotne persons Page 5 of 7 Page 8 Comments on the City of Meridian, Idaho's Annual Action Plan Program Year 2009 Commanity Development Black Grant Program {CDBG) Please advise if the students nslao will be usarag flies service are currenldy enrolled as rr:e»abers of the l~lerzdian Bo1}s arrd G~trls Club fYe also refer lice city to Chapter 9, Public Services, l» the Basically CDBG rraanaal for further information ort Public Service activaties and LAIC f+i~e remind t1:e city= to review cleat 3 on page 2-19 and 2-Z©tn the handbook "Playing by the Rules"to erasure dais activity is in compliance with the regulations ;- Project 7Ytle - N1'eridian Food Bank • after review of tl:is ao~vrty, tii=e feol ilae correct Matrcr Code sfiotrld be OS (Public Seruices - Genera!) and flee correct CDBG C/tation should be 24 CFR S7~ 2©1(e) • ~4s a LMC activity, it must prirrrarily heiae„(!t low- and moderate-is3eorrcepc;rsons and we ask that Uie crt}=please ensure that aderluate docunaeratat~on ~tsts to verifjr that lice ben~ctaries ojthis activity are indeed LMC • the would like a brief statement tndleatirag how the food bank determines income to ensure fleet this activity meets LMC criteria Project Title - Firgade Improvements • After review of tl:is activiry, we ask tFiat flee city resubmit the table revlsiyag o Tla a Qbjective 1Vufraber (there are ~w ED-i categories) c~ Tlae MattxY Code to ]4E {the orae listed is far acquisition of real property) BQISE STATE FIELD UFFICE Meridians Action Plan ~s focused ort a few very simple objectives that can be successfully completed. This year`s plan shows more flexibility than previous plans with priorities and Cnanc~af comnt~tments shaltin, towards programs that are working very well. City staffers contsnue to do a goon job with an ongoing effort to connect to a wide variety of community partners. Early on in the plan, the city recognizes that one planned acti~~ity, equipment installation in Centennial Park is net in a desi,~ated LlVII neighborhood -- a red flag regarding the use of GiaBG funding. This recognition is repeated more than once in the plan, but it appears that this is not explaine4 until later in the plan (page !'~ that a neighborhood income survey is being conducted for the park in question. Perhaps an earlier mention is warranted. City staff has shown great flexibility in respondirxg to public input and moving resources to programs that work. In one case, flue means boosting budgeted amounts from $25,000 to $35,004 to support hoinebuyers working through the Boise City/Ada County Housing Authority's Housing Choice Voucher Homeownership program, Page b of 7 Page 9 Comments on the Cit1,~ of ll~eridian, Idaho's Annual Actian Plan Program Year 2009 Community Development Block Grant program (CDBG) Staff also showed great candor m explaining the reasons why the City intends to "overhaul" its Comprehensive Plan. PUBLIC HOUSING SEATeTLE REGIONAI.OFFICE The Action Plan is considered complete with no iteixrs missing in any of the reviewed areas. There are no further comments. FHE4 SEATTLE REGIONAL UFFICE The office of Fair Housing and 1~qual Opportunity (FRED) has reviewed the 20x9 Annual Action Flan for ttie city of Meridian and its cert~cation for af3E"irmafiively furthering and coe:raplying with anti-discrimination laws, At this time we accept with conditions th@ qty's certificatiaus. However please note the following comments: The Action Plan is designed to show that the specific activities to be tamed out during the applicable one-year penod are consistent with the five-year strategy of its Consolidated Plan. Specifically, the plan should describe activities that address the housing needs of racial anti ethnic groups, the needs of persons with disabilities and the activities that will remove fair housing impediments. We are not able to determine these factors from the information included in the Action Plan. Page 7 of 7 Page 10 Attachment 2: Additional Changes to PY09 Action Plan Pg. ii: Revised table of contents Pg. 3: Revised Table 1 to reflect adjusted dollar amounts. Pg. 3: Added new footnote (number 2) explaining eligibility survey for Centennial Park improvements. Pg. 4: Revised Table 2 to reflect adjusted dollar amounts. Pg. 5: Revised dollar amounts. Pg. 11: Revised dollar amounts in text and table. Pg. 12: Changed Objective for Homeownership Assistance to Low Moderate Housing (LMH) from Low Moderate Clientele (LMC). Pg. 13: Revised dollar amounts in text and table. Pg. 13: Revised Table 3 to reflect adjusted dollar amounts. Pg. 17: Revised dollar amount in text. Pg. 18: Added new monitoring narrative. Pg. 25 - 29: Revised Table 3.A by: a. Adding Specific Annual Objective SL 1.1 for public facility projects. b. Clarifying and revising Performance Indicators throughout. Pg. 32 - 38: Revised dollar amounts, HUD Matrix Codes, Performance Indicators, CDBG Citations, etc. in Tables 3C. Page 11 Attachment 3: Resolution ,revising the PY09 CDBG Action Plan