Public Hearing on the 2021 Federal Housing and Urban Development (HUD) Department Consolidated Annual Performance and Evaluation Report (CAPER) for the CDBG Program

David Mohlenbrok, Community Development Director

Laura Webster, Director of Long Range Planning and Housing

Leslie Woodman, Housing Specialist

Adopt a Resolution of the City Council of the City of Rocklin Authorizing Staff to Submit the 2021 Consolidated Annual Performance and Evaluation Report (CAPER) and Authorizing the City Manager to Execute and File All Documents Required for Submittal to the U.S. Department of Housing and Urban Development (HUD)

As a recipient of HUD Community Development Block Grant (CDBG) funds, the City of Rocklin must complete a Consolidated Annual Performance and Evaluation Report (CAPER) on an annual basis. The CAPER identifies programs and activities that the City undertook during the 2021 Program Year (PY) to meet the priority needs identified in the 5-year Consolidated Plan. In addition, the CAPER discusses actions that the City took to address barriers to affordable housing, public services for seniors and the homeless, and ADA improvements. The City was awarded $284,327 for the 2021 Program Year. However, total resources available in PY 2021 were slightly more ($296,981.51) due to unspent funds from the previous year. Additional information on the source of prior unspent funds and an update on CARES Act funding will be detailed later in this report. 

On July 30, 2022, a Public Review Draft CAPER document was made available for an 18-day period. Notice of the Public Review Draft CAPER’s availability, comment period and the scheduled public hearing before the City Council was published in the Placer Herald newspaper. In addition, the notice was e-mailed to various service providers through dissemination by the Placer Collaborative Network (PCN) and The Placer Consortium on Homelessness (PCOH) list serves and in the City’s posting box outside of City Hall. The report was made available through links in e-mail notices, at City Hall and on the City’s website. Comments on the draft report were due by the end of the business day, Tuesday, August 16, 2022. No comments have been received to date.

Subsequent to release of the Public Review Draft CAPER, City staff was able to review responses to a Third Notice of Funding Availability for CDBG-CV-1 and CDBG-CV-3 funds and collaborate further with entities who had submitted proposals. Through that process, staff was able to identify additional qualified parties with interest in creating eligible programs for all CDBG-CV-1 funds that need re-allocation due to termination of some original CV-1 programs and the remaining CDBG-CV-3 funds ($229,113) that had not yet been allocated to specific programs.

As a result, the discussion of the status and outlook for spending of the City’s CDBG-CV-1 and CV-3 Funds that was provided in the Public Review Draft 2021 CAPER has now been updated to reflect this positive turn of events. The proposed 2021 CAPER document provided as Exhibit A to the Resolution in tonight’s packet had been revised to reflect the updated status.

Shortly after adoption of the 2021 CAPER, staff will bring forward the Third Amendment to the City’s 2020 Annual Action Plan in another public hearing to address the details of new allocations and re-allocations for CDBG-CV-1 and CV-3 Funds.  

ANALYSIS:

Unspent Standard CDBG Funds from PY 2020

In PY 2020, the public facilities category funding for improvements within the public right of way and pedestrian paths of travel to benefit disabled individuals was increased, due to carryovers, to $190,290.51.  However, actual funds spent on ADA improvements in PY 2020 totaled $187,255.00, leaving $3,035.51 of available funds in PY 2020 unspent. 

Foothills Habitat for Humanity was allocated $9,619 in PY 2020 for their Handyman program, but the program was temporarily discontinued as a result of safety concerns during the Coronavirus pandemic.  These funds along with $3,035.51 (i.e., total of $12,654.51) were reallocated to public facilities for the ADA improvement project identified in the 2021 Annual Action Plan.

CARES Act – CDBG-CV-1 and CDBG-CV-3

Although not technically a part of the PY 2021 Annual Action Plan, the City is including a brief update regarding CARES Act funding and spending in the CAPER.  The City’s initial allocation of CDBG-CV-1 ($164,189) funds was the primary focus of the first substantial amendment to the 2020 Annual Action Plan approved by the City Council on September 22, 2020.  The programs identified in the first substantial amendment included:

• The Gathering Inn received $45,189 in CDBG-CV-1 funds for a Mental Health Clinician position and $20,000 for a medical clinic to prevent, prepare for, and respond to Coronavirus and its effects on homeless populations.

• Stand Up Placer received $15,000 in CDBG-CV-1 funds to respond to needs for services stemming from Coronavirus.

   

• Lighthouse received $5,000 in CDBG-CV-1 funds for the basic essentials program, providing diapers and car seats to Rocklin residents who struggle to afford these supplies as a result of income reduction related to Coronavirus. Lighthouse also received $25,000 in CDBG-CV-1 funds for a counseling program to respond to clients struggling with issues including, but not limited to, financial loss, at home school and childcare challenges, food insecurity, and caring for family members affected by COVID-19 or other issues directly related to Coronavirus.

   

• The Salvation Army received $39,000 for a rental assistance program and $15,000 for the food box program in CDBG-CV-1 funds to respond to income reductions related to Coronavirus.

Since the allocation of CDBG-CV-1 funds was approved for the above programs, spending has occurred in some programs, but not yet in others.  The Gathering Inn has expended $56,674.98 of the funds allocated for their mental health and medical clinic programs combined.  However, due to staffing changes, staffing losses and other challenges handling the large influx of funds available from a variety of sources with limited staff, the other CDBG-CV-1 subrecipients have yet to implement their programs.  The Salvation Army formally terminated its contract for the $15,000 in CDBG-CV-1 funds that had been allocated for their food box program indicating that tracking of the Coronavirus relationship as opposed to other food box recipients without a COVID-19 relationship did not work well with their method of food distribution and was too cumbersome to implement. Stand Up Placer has conducted counseling services for clients both with and without a Coronavirus related impact, but since the spending timelines for standard CDBG funds has a shorter timeframe than CDBG-CV-1 funds, they have focused their invoicing toward standard CDBG activities first.  During the public review period for the 2021 CAPER, Lighthouse also formally terminated its contract for $25,000 associated with their CDBG-CV-1 Counseling program and $5,000 in CDBG-CV-1 associated with their Basic Essentials program, due to not having a Rocklin office up and running to administer the programs.

Under current contracts, the deadline for remaining subrecipients to spend CDBG-CV-1 funds is through June 30, 2023. With the pandemic and its ongoing impacts continuing, the City is hopeful that these recipients will be able to provide the programmed services within that timeframe. The City is also open to working with these entities to amend their programs in the 2020 Action Plan, if needed, to create the opportunity for better utilization of the funds.     

In addition to CDBG-CV-1 funds, on September 11, 2020, the City was also notified that it had received $299,113 in a third round of CDBG-CV-3 funding from the CARES Act. The City released two rounds of Notices of Funding Availability (NOFA’s) for the CDBG-CV-3 funds on December 18, 2020 and May 14, 2021 to solicit proposals from non-profits and other entities to utilize the CDBG-CV-3 funds. Applications for CDBG-CV-3 funds were only submitted by two entities and the combined requested funding amounts did not equal the total amount of funds available. Approval of the second substantial amendment to the 2020 Annual Action Plan was approved by the City Council on August 10, 2021 and included the following programs:

•    The Gathering Inn (TGI) to receive $50,000 in CDBG-CV-3 funds to provide housing assistance (Rapid Rehousing & Homeless Prevention), employment assistance (required work-related supplies, short term transportation funding), and educational assistance (distance learning supplies, books, programs, etc.) to guests in TGI programs who have direct ties to Rocklin.

•    The Salvation Army to receive $20,000 in CDBG-CV-3 funds for the rental assistance program to respond to income reductions related to Coronavirus.

•    The remaining $229,113 in CDBG-CV-3 funds was identified as “To be determined” in the Annual Action Plan to allow for future use if other activities were developed that can address the prevention of, preparation for, and response to the Coronavirus.

Similar to CDBG-CV-1 programs, spending of the CDBG-CV-3 funds for the above programs has been largely delayed as subrecipients struggle to keep up with the variety of funding they have received and/or have encountered difficulties in utilizing the funds for the activities originally envisioned.

In an effort to create another opportunity to accept new or revised proposals to spend the CDBG-CV-1 and CDBG-CV-3 funds available, the City issued a third NOFA on May 7, 2022 to solicit proposals from new parties and/or provide the opportunity for existing CDBG-CV-1 or CDBG-CV-3 subrecipients to submit revised proposals. The City has received new or revised proposals from three entities. Based on the total amount requested collectively and subject to future City Council approval, it appears that the City will be able to encumber the total amount of funds available. The City will expedite preparation of a Third Amendment to the 2020 Annual Action Plan for City Council approval to address changes to original programs and award allocations to new programs as applicable.     

Rocklin’s CDBG-CV-1 and CDBG-CV-3 funds must be completely expended by November 9, 2026, however, 80% ($370,641.60) of the funds must be expended within 3 years (by November 9, 2023).

The City’s focus will be to work with current and new subrecipients to maximize their spending within the mandated timeframes.  

Table 1 below identifies the total amount of Standard CDBG and CDBG-CV funds that were made available to the City of Rocklin for FY 2021 and the amount of funds expended by the City of Rocklin in PY 2021.

¹ Includes Final 2021 allocation of $284,327 plus prior year funds carryover of $12,654.51.

Table 2 below breaks down how much PY 2021 Standard CDBG funding was budgeted to each subrecipient, how much was spent and how many households were assisted.

Note - Increasing or reducing the amount allocated to an activity by less than 50% does not require an Annual Action Plan amendment.

The third table below provides a description of the racial and ethnic composition of the families that were assisted in PY 2021.

The City was awarded $284,327 from HUD for PY 2021 and had a remaining amount of $12,654.51 in unspent funds from the previous year’s grant programs, making a total of $296,981.51 available to be expended in PY 2021. The City expended $296,981.51 in PY 2021.

Processing of the CAPER and submittal of this report to HUD is necessary in order for the City to continue to receive CDBG funds annually.