To: Board of Supervisors and Board of Commissioners
Department or Agency Name(s): Community Development Commission
Staff Name and Phone Number: Michelle Whitman, 707-565-7504
Vote Requirement: Majority
Supervisorial District(s): Countywide
Title:
Title
Federal Funding Policies and 2025 Community Participation Plan
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Recommended Action:
Recommended action
Board of Supervisors:
A) Approve Fiscal Year 2025-2026 Community Development Block Grant, HOME Investment Partnerships Program, Emergency Solutions Grant, Community Development Block Grant Cares Act, and Low-and Moderate-Income Housing Asset Fund-Homeless Services Funding Policies for affordable housing, non-housing capital projects, fair housing programs, homeless prevention, homeless services, emergency shelter, and rapid rehousing programs;
B) Approve the proposed 2025 Community Participation Plan.
Board of Commissioners:
C) Authorize submittal of a $500,000 Community Development Block Grant fund request by the Community Development Commission for the Housing Rehabilitation Loan and Earthquake Resistance Bracing System programs, and a $310,000 HOME Investment Partnerships fund request by the Sonoma County Housing Authority for the Tenant-Based Rental Assistance Program, for consideration during the Fiscal Year 2025-2026 Consolidated Plan funding cycle.
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Executive Summary:
Approval of this agenda item will approve the updated Federal Funding Policies for the upcoming fiscal year, 2025-2026, as well as approve the Community Participation Plan, which are separate documents, but both required of grantees by the U.S. Department of Housing and Urban Development (HUD). The funding policies are typically updated once a year if there are changes in the administration process of federal funding programs managed by the Sonoma County Community Development Commission (CDC) or if new funding programs need to be added or deleted. The Community Participation Plan is typically updated every five years. This agenda item will also authorize the CDC and the Sonoma County Housing Authority (SCHA) to apply for federal funding for programs managed by the CDC. If funding is allocated to these programs, allocations would be reflected in the CDC Fiscal Year (FY) 2025-2026 budget, which will be presented to your Board later this year.
The Federal Funding Policies guide the administration and allocation of Community Development Block Grant (CDBG), HOME Investment Partnerships Program (HOME), Emergency Solutions Grants (ESG), and Low-and Moderate-Income Housing Asset Fund-Homeless Services (LMIHAF-Homeless Services). The proposed updates reinstate the Community Development Block Grant Cares Act (CDBG-CV) program as there are funds that remain to be allocated; remove the HOME American Rescue Plan Act (HOME-ARP) program, because all funds have been allocated; insert a footnote to the activity titled “Permanent Affordable Housing Projects” in Appendix A establishing affordable housing projects on sites designated as a floodplain or floodway as ineligible for federal funding; and include other non-substantial revisions throughout the document to properly implement the programs.
The proposed 2025 Community Participation Plan (the “Plan”) amends the current June 2020 Citizen Participation Plan. The Plan provides a community engagement framework in the CDC’s administration of all U.S. Department of Housing and Urban Development (HUD) funding programs and removes expired coronavirus provisions. Additionally, the Plan clarifies the public’s participation role in the preparation of the five-year Consolidated Plan, annual Action Plan, including substantial amendments to the Action Plan, Consolidated Annual Performance Evaluation Report, and updates to the Federal Funding Policies.
This report also requests authorization for the CDC to submit a funding request for $500,000 in FY 2025-2026 CDBG funds for the Housing Rehabilitation Loan program (HRLP) and Earthquake Resistant Bracing System (ERBS), and the SCHA to submit a $310,000 request for FY 2025-2026 HOME funding for the Tenant-Based Rental Assistance program. If funding is allocated to these programs, the allocations would be incorporated in the FY 2025-2026 Annual Action Plan as well as in CDC’s FY 2025-2026 budget, which will be presented to your Board later this year.
Discussion:
The CDC administers various loan and grant programs using policies and procedures that are consistent with the applicable local, state, or federal requirements of the funding sources being used, and with the policies and goals of the County and CDC. The policies are updated as needed to enable staff to properly implement the programs and ensure compliance with the most current requirements and regulations.
Federal Funding and LMIHAF-Homeless Services Policies
The Urban County, comprised of the County of Sonoma, the cities of Cloverdale, Cotati, Healdsburg, Rohnert Park, Sebastopol, Sonoma, and the Town of Windsor, is the entitlement jurisdiction of federal CDBG, HOME, ESG grant programs. These jurisdictions entered a Joint Powers Agreement (JPA) to form the Urban County. The JPA designates the County as the lead agency with final decision-making authority and assigns CDC as fiscal agent for the programs. CDC administers all these funding programs, including LMIHAF-Homeless Services, which is a county program derived from the former Sonoma County, City of Sonoma, and City of Sebastopol redevelopment agencies when the redevelopment agencies dissolved in 2012. In 2014, your Board approved the annual use of up to $250,000 in LMIHAF revenue for homelessness-prevention and rapid rehousing program, the maximum permitted by California Redevelopment Law.
The Federal Funding and LMIHAF-Homeless Services policies guide administration, solicitation, and selection of proposals to receive funds. Attachment 1, the proposed policies, reflect the following minor updates:
1. Insertion of text regarding the FY 2025-2026 Funding Policies and consistency with the upcoming 2025-2029 Consolidated Plan.
2. Insertion of text regarding the transition of the disaster resiliency framework undertaken by the Board of Supervisors after the disaster wildfires into the office of Grants and Special Projects.
3. Clarification regarding the non-use of awarded funds for environmental review expenses.
4. Removal of text pertaining to phasing-in “Build America, Buy America” requirements as the phasing process has been completed by HUD.
5. Insertion of footnote 3 to the activity titled “Permanent Affordable Housing Projects”, establishing affordable housing projects on sites that are on a designated floodway or floodplain as ineligible for federal funding.
6. Replacement of the HOME-ARP Addendum with the previous CDBG-CV Addendum as all HOME-ARP funds have been used and there are remaining funds of CDBG-CV to be allocated to future projects.
7. Replacement of “Analysis of Impediments to Fair Housing” with “assessment of fair housing” or “AFFH”, terminology throughout the document as well as replacement of “citizen participation” with “community participation” to promote public engagement.
8. Other non-substantive clerical, minor clarifications, and or corrections throughout the document.
On November 20, 2024, the Cities and Towns Advisory Committee and the Community Development Committee held a concurrent public hearing to review and consider the proposed changes. No public comment was received prior to the hearing or made at the hearing. Each Committee voted to recommend approval to your Board.
2025 Community Participation Plan (CPP)
Jurisdictions receiving housing and community development funds under the CDBG, HOME, and ESG federal programs are required to adopt and follow a CPP. The purpose of the CPP is to provide a written policy and procedure that describes the actions to be taken to provide for, and to encourage, public participation in the development of the Assessment of Fair Housing (AFFH), Consolidated Plan and Annual Action Plans, any substantial amendments to an adopted Consolidated Plan, and the Consolidated Annual Performance Evaluation Report (CAPER), which are required documents by HUD.
The County of Sonoma welcomes and solicits input from all county residents. The proposed CPP removes language related to coronavirus that is no longer applicable and clarifies the public engagement process in the implementation of the Consolidated Plan.
The proposed CPP was available for a 30-day public comment period from October 21, 2024 through November 20, 2024. The draft was available on the CDC’s website, CDC office, and the Sonoma County Central Library in Santa Rosa. On November 20, 2024, the Community Development Committee and the Cities and Towns Advisory Committee held a concurrent public hearing to review and consider the proposed changes. No public comments were received prior to the hearing or made at the hearing. Each committee voted to recommend approval of the amended Plan to your Board.
Authorization for CDC and Housing Authority Funding Requests
The Funding Policies require all project sponsors to include with their application evidence of their governing board’s approval to submit a request for funding. To comply with this requirement the CDC and the SCHA request your Board’s approval for the following funding requests:
1. A request by CDC to apply for $500,000 in FY 2025-2026 CDBG funding for the Housing Rehabilitation Loan Program and Mobile Home Earthquake Resistant Bracing System Grant Program.
2. A request by the SCHA to apply for $310,000 in FY 2025-2026 HOME funding to provide monthly rental subsidies and or security deposits under the Tenant-Based Rental Assistance program.
These proposed approvals are actions that are exempt from the California Environmental Quality Act (CEQA) under CEQA Guideline 15061(b)(3).
Strategic Plan:
This item directly supports the County’s Five-year Strategic Plan and is aligned with the following pillar, goal, and objective.
Pillar: Healthy and Safe Communities
Goal: Goal 1: Strengthen operational effectiveness, fiscal reliability, and accountability
Objective: Objective 2: Identify and leverage grant funding sources for permanent supportive and affordable housing development.
The Federal Funding Policies guide the administration and allocation process of grants to eligible projects. These projects include affordable housing production, housing preservation and public services addressing fair housing and homelessness in the county. Approval of the policies will support the CDC’s efforts to create affordable housing, preserve affordable housing, and reduce homelessness countywide as well as support the goals of the Consolidated Plan. Approval of the CPP will ensure public participation in the allocation process of these funds and in the preparation of documents required by HUD.
Racial Equity:
Was this item identified as an opportunity to apply the Racial Equity Toolkit?
No
Prior Board Actions:
11/07/2023 Approval of the 2023-2024 Federal Funding and LMIHAF-Homeless Services Policies
06/09/2020 Approval of the 2020 Citizen Participation Plan
Fiscal Summary
Narrative Explanation of Fiscal Impacts:
The requests in this agenda item do not impact the adopted or projected budgets as they only involve policies and a public participation plan to enhance opportunities for participation of the public in future HUD related action items. The annual Action Plan with proposed funding allocations will come before your Board at a future date in 2025. In regards to authorizing CDC to request funding, any funding awards made to the CDC would be included in a future report along with the budget and presented to your Board.
Narrative Explanation of Staffing Impacts (If Required):
The proposed revisions to the policies and approval of the 2025 Community Participation Plan will not cause staffing impacts.
Attachments:
Attachment 1: Proposed Federal Funding and LMIHAF-Homeless Services Policies
Attachment 2: Proposed 2025 Community Participation Plan
Related Items “On File” with the Clerk of the Board:
Attachment 1: Proposed Federal Funding and LMIHAF-Homeless Services Polices RED-LINE
Attachment 2: Proposed 2025 Community Participation Plan RED-LINE
11/07/2023 2023-2024 Federal Funding and LMIHAF-Homeless Services Policies
06/09/2020 Designation of Signatories for the Conduct of Banking Business and Resolution for Receipt of State Cares Act Emergency Solutions Grant Funding and Amendment of the FY2019-20 Action Plan to include CARES ACT Allocation of CDBG and Federal ESG