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PUBLIC HEARING: 2017-2018 ANNUAL ACTION PLAN FOR THE COMMUNITY DEVELOPMENT BLOCK GRANT, HOME INVESTMENT PARTNERSHIPS, AND EMERGENCY SOLUTION GRANT PROGRAMS
recommended action
RECOMMENDATION
It is recommended that the City Council adopt a resolution:
1. Approving the 2017-2018 Annual Action Plan with any modifications deemed appropriate by the Council; and
2. Authorizing the City Manager, or his designee, to execute all documents and forward them to the U.S. Department of Housing and Urban Development and to take actions necessary and appropriate to carry out the purpose and intent of the resolution.
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Summary
The U.S. Department of Housing and Urban Development (HUD) requires that jurisdictions prepare a one-year Annual Action Plan (Action Plan), Exhibit 1 to the Resolution, to receive Community Development Block Grant (CDBG), Home Investment Partnerships (HOME), and Emergency Solutions Grant (ESG) funding. The Action Plan identifies the specific projects (Exhibit 2) that will be funded during the year to help accomplish the goals established in the five-year Consolidated Plan. The Action Plan also serves as a portion of the Housing Division’s budget.
In a typical year, the Action Plan is due to HUD on May 15th, however, due to delays with federal appropriations, HUD has extended the due date to August 16, 2017, or 60 days after HUD announces allocation amounts, whichever comes first.
The City is preparing the Action Plan despite the uncertainty of the CDBG and HOME programs created by the current Federal budget proposal which eliminates all funding for these programs. As directed by HUD staff, we are proceeding with preparing the 2017-18 Action Plan to meet the mandated deadlines and assuming the same funding allocations as were received in 2016-17. If CDBG and HOME funds are received, but the allocations are significantly less than those indicated in this Action Plan, the Plan contains contingency provisions which recommend how reductions in the proposed budget will be made.
DISCUSSION
Background
To receive certain federal funds, including CDBG, HOME, and ESG, HUD requires jurisdictions to prepare a one-year Annual Action Plan. The Action Plan identifies the specific projects and activities that will be funded during that year to help accomplish the goals established in the five-year Consolidated Plan which the Council adopted in April 2015. The Action Plan contains funding recommendations for the use of CDBG, HOME, and ESG funds for the upcoming program year, including the funding recommendations proposed by the Community Development Committee (CDC), which is an advisory body to the City Council.
With the current uncertainties of the federal budget, HUD staff has instructed the City to use the same allocations as last year. Allocations under each program are as follows:
|
|
Program Year 2015-2016 |
Program Year 2016-2017 |
Program Year 2017-2018 |
|
CDBG |
$3,235,647 |
$3,143,802 |
$3,143,802 |
|
HOME |
$1,092,805 |
$1,151,969 |
$1,151,969 |
|
ESG |
$ 295,268 |
$ 291,273 |
$ 291,273 |
|
TOTAL |
$4,623,720 |
$4,587,044 |
$4,587,044 |
Community Input and Funding Process
The process of developing the Action Plan began in November 2016 with the placement of a public notice in The Record notifying the public of a CDC meeting to discuss community needs and the start of the application period for CDBG and ESG funds. HOME funds will be allocated to projects through a separate process. Notices were sent to approximately 40 agencies, organizations, interested citizens, and posted on the City’s website.
The deadline for submitting CDBG and ESG applications was January 13, 2017. All complete applications for eligible uses were reviewed by the CDC. The CDC held three public meetings to review the applications, and one additional meeting to decide on contingency provisions in case allocations from HUD are less than expected.
A public notice regarding the availability of the draft Action Plan was published in The Record and posted on the City’s website. The public notice began a 30-day review period for these documents. At the time of the preparation of this staff report, no comments had been received.
Present Situation
2017-2018 ACTION PLAN
The following is an overview of each of the funding sources and a summary of recommended funding for each program:
Community Development Block Grant Program
CDBG is a flexible program that provides communities funding to address a wide range of unique community development needs that benefit low-income residents. Cities with more than 50,000 people and counties with a population of more than 200,000 are eligible to receive this funding from the federal government. Each year HUD determines the CDBG allocation using a formula that considers total population, the number of persons in poverty, housing overcrowding, and the age of the housing within the jurisdiction.
CDBG funds can be used for a wide range of activities, including:
• Rehabilitation of residential and commercial property;
• Demolition;
• Public facilities and improvements;
• Economic development; and
• Public services
The primary eligibility requirement for each activity is that it must benefit low-income persons. HUD defines low-income as a household that is at or below 80 percent of the area median income (AMI), which in Stockton is an annual income of $47,100 for a family of four.
Activities that are generally ineligible include assistance for buildings or portions of buildings used for the conduct of government; general local government operating and maintenance expenses; partisan political purposes including voter registration; equipment purchases; and new housing construction.
In 2015-16, CDBG funds were allocated to organizations that provided food to over 50,000 Stockton residents, including 200 seniors served by Meals on Wheels. Funds were also used by the Child Abuse Prevention Council for its Crisis and Respite Child Care Center that served over 270 children. Funds were provided to the Women’s Center to assist with renovating Dawn House, its emergency shelter, and to St. Mary’s to help provide more up-to-date equipment in its dental clinic. Four businesses received assistance to improve their facades, and five jobs were created through the Small Business Micro Loan Program.
The following is a summary of the activities recommended for funding for the 2017-2018 Program Year for CDBG:
CDBG Program Delivery Costs
This category includes Administration, which are the costs associated with daily operations, such as staff costs to administer the program, materials/supplies, training, and consultant services. The City is allowed to use up to 20 percent of its entitlement and program income for this purpose, which has increased this year due to repayment of a loan from the Successor Agency. Program Delivery includes staff costs attributed directly to projects as well as project delivery costs, such as obtaining title reports and appraisals.
|
Program Delivery Costs |
Program Year 2016-2017 |
Program Year 2017-2018 |
Difference: 2016-2017 to 2017-2018 |
Percentage: 2016-2017 to 2017-2018 |
|
Administration/Oversight |
$709,760 |
$836,444 |
$126,684 |
17.8% |
|
Program Delivery |
$281,414 |
$281,414 |
$0 |
0% |
Housing Programs
The Emergency Repair Program is designed to provide assistance to low-income homeowners to address emergency problems which represent an immediate health and safety danger to the occupants. The Housing Loan Pool provides funds for the City’s housing rehabilitation programs, which includes programs to assist low-income homeowners or owners of rental property. The amount of funding available for the Housing Loan Pool program is less for Program Year 2017-2018 due to a reduced amount of reprogrammed funds. However, HOME funds are also available for the housing programs. The Emergency Repair loans will continue to be funded out of the CDBG Revolving Loan (RL) fund, which is a separate fund into which CDBG loan repayments are placed, and then reused for new loans. Rehabilitation loans are provided to eligible homeowners on a first come, first served basis. Funding for rental projects will be made available through a Notice of Funding Availability (NOFA) process with funding recommendations brought to the City Council for approval.
|
Housing Programs |
Program Year 2016-2017 |
Program Year 2017-2018 |
Difference: 2016-2017 to 2017-2018 |
Percentage: 2016-2017 to 2017-2018 |
|
Emergency Repair Program (RL) |
$60,000 |
$65,000 |
$5,000 |
8% |
|
Housing Loan Pool |
$764,179 |
$564,111 |
($200,068) |
(26%) |
Subrecipient Assistance
Twenty-one applications requesting funding were received (Attachment A). The CDC held three public meetings to review the applications and recommended that nine organizations receive funding. Of the nine, four are for new activities this year, including one new subrecipient.
Two of the projects recommended for funding are scalable and were not recommended by the CDC to receive the full amount that they requested. However, due to the recent availability of additional funds from the repayment of a CDBG loan by the Successor Agency, staff is recommending fully funding one of the scalable activities recommended by the CDC, which will result in a total of $90,000 being recommended to Stockton Shelter for the Homeless for a Jobs Program.
Staff is also recommending allocating $300,000 for a yet-to-be identified project to assist with the Council’s on-going efforts to address homelessness. The funds could be used to address a need for capital improvements at one or more of the homeless facilities. The specific use of the funds would be brought back to Council for consideration at a future date.
It is being recommended that $600,000 be allocated to sub-recipients and the homeless initiative. Staff also recommends funding $176,810 to San Joaquin Fair Housing, which is a HUD mandated activity. This brings the total amount of CDBG funding allocated to sub-recipients and the homeless to $776,810.
Applications were submitted by many qualified, and deserving organizations with the total amount of funds requested nearing $1 million. The CDC focused on providing funding for one-time projects, such as public facilities, economic development, and providing funding to activities where the CDBG funds were paying for project costs rather than salaries. Due to the uncertainty of organizations receiving funding on an annual basis, the CDC tries to avoid providing funding for salaries. Funding recommendations are indicated below:
|
CDBG FUNDING: CDC Recommendations: Subrecipient Assistance |
Program Year 2016-2017 |
Program Year 2017-2018 |
Difference: 2016-2017 to 2017-2018 |
Percentage: 2016-2017 to 2017-2018 |
Project Type |
|
Emergency Food Bank |
$20,000 |
$35,000 |
$15,000 |
75% |
Public Service (Food) |
|
Second Harvest Food Bank |
$20,000 |
$30,000 |
$10,000 |
50% |
Public Service (Food) |
|
Stockton Shelter for the Homeless** |
$0 |
$30,000 |
$30,000 |
New Activity |
Economic Development (Jobs) |
|
SJC HSA - Meals on Wheels |
$7,500 |
$14,000 |
$6,500 |
86.7% |
Public Service (Food) |
|
Disability Resource Agency (DRAIL) |
$0 |
$10,000 |
$10,000 |
New Activity |
Public Service (ADA Accessibility) |
|
Salvation Army Stockton Corps |
$0 |
$24,000 |
$24,000 |
New Activity |
Public Facility |
|
Read to Me Stockton |
$36,000* |
$50,000 |
$14,000 |
38.9% |
Public Service (Literacy) |
|
Gospel Center Rescue Mission |
$36,000* |
$12,000 |
($24,000) |
(66.7%) |
Public Facility |
|
Tuleburg Press |
$0 |
$35,000 |
$35,000 |
New Activity |
Public Service (Literacy) |
*Funded with General Funds dollars, not CDBG
|
Staff Recommendations: Subrecipient Assistance |
Program Year 2016-2017 |
Program Year 2017-2018 |
Difference: 2016-2017 to 2017-2018 |
Percentage: 2016-2017 to 2017-2018 |
Project Type |
|
Stockton Shelter for the Homeless** |
$0 |
$60,000 |
$60,000 |
New Activity |
Economic Development (Jobs) |
|
Homeless Initiative |
$0 |
$300,000 |
$300,000 |
New Activity |
Public Service |
|
San Joaquin Fair Housing |
$176,800 |
$176,810 |
$10 |
.006% |
Fair Housing |
**Combined CDC and Staff recommendations for Stockton Shelter total $90,000.
Attachment A includes a description of all applications that were received.
Economic Development Program
The City is proposing to fund several programs to assist businesses. These include the Façade Program which provides funds for improvements to the exterior of commercial properties and the Emergency Grant Program which assists businesses by repairing emergency conditions that endanger the health and safety of employees or the general public and for which private funds are not readily available. For the 2017-18 Program Year the Micro-Business Loan Pool, which provides funds to assist small businesses to start or expand, will be funded out of the CDBG Revolving Loan (RL) fund. The $50,000 shown below for the Micro-Business Loan Pool is only the amount of program income anticipated for the 2017-18 fiscal year; additional funds are available in the RL for the program.
Also, it is recommended that funding be allocated to an Entrepreneurship/Business Incubator Program. This program, which is operated by City staff, began in the 2015-16 Program Year and provides funding to new and existing small business programs that focus on enhancing services for startup businesses and entrepreneurship programs. In 2016 the funds were awarded to five organizations, including the Downtown Stockton Alliance to operate a new retail business incubator, Stockton Impact Corps which is using the funds to enhance its micro loan program, and Goodstock Productions to increase and enhance its Stockmarket events in Downtown Stockton. The Entrepreneurship-Business Incubator funds will be allocated to specific projects through a NOFA process while funds from the other programs will be allocated on a first come, first served basis. A new program, the Fresh Produce Access Grant, is also being recommended. This will provide funding to purchase and install refrigeration equipment or supply fresh produce in neighborhood stores to encourage the sale of fresh produce in areas where it is currently not available.
|
Economic Development Programs |
Program Year 2016-2017 |
Program Year 2017-2018 |
Difference: 2016-2017 to 2017-2018 |
Percentage: 2016-2017 to 2017-2018 |
|
Façade Program |
$300,000 |
$350,000* |
$50,000 |
16.7% |
|
Micro-Business Loan Pool |
$120,000 (Funded with $60,000 of RL and $60,000 of entitlement) |
$50,000 |
($70,000) |
(58.3%) |
|
Emergency Grant Program |
$10,000 |
$10,000 |
$0 |
0% |
|
Entrepreneurship/Business Incubator |
$80,000 |
$80,000 |
$0 |
0% |
|
Fresh Produce Access Grant |
$0 |
$40,000 |
$40,000 |
New Activity |
Debt Service
The City has received two Federal Section 108 loans totaling $25.5 million. Future CDBG entitlements and/or program income were pledged as repayment sources for the loans. Loan repayment began in 2002 and will extend through 2024. Projects partially funded with the Section 108 loans include Dean DeCarli Waterfront Square, the Cineplex, the Stockton Marina, Joan Darrah Promenade, Morelli Boat Launch, Fox Theatre, and Gleason Park Apartments.
|
Debt Service |
Program Year 2016-2017 |
Program Year 2017-2018 |
Difference: 2016-2017 to 2017-2018 |
Percentage: 2016-2017 to 2017-2018 |
|
Debt Service - Section 108 Loan |
$1,892,299 |
$1,918,659 |
$26,360 |
1.4% |
HOME Investment Partnership Program
HOME funds must be used by local governments to create affordable housing for low-income households. HOME funds are awarded annually as formula grants to participating jurisdictions. The program allows States and local governments to use HOME funds for grants, direct loans, loan guarantees or other forms of credit enhancement. The incomes of a household receiving HOME funds must not exceed 80 percent of AMI.
HOME funds are used for the following types of activities: homebuyer programs, homeowner rehabilitation programs, and rental housing programs.
In 2015-16, HOME funds were used to rehabilitate the homes of seven low-income homeowners and three HOME funded multi-family projects, with a total of 131 affordable units, were under construction. One of these, Cal Weber 40, is having an impact on the efforts to revitalize downtown and another, Zettie Miller’s Haven, is providing housing for 81 Special Needs or Senior households.
HOME Administration/Loan Fund
Administration includes the general costs associated with the administration and oversight of the HOME program. A jurisdiction may spend up to ten percent of its entitlement and program income on administrative costs. Housing Program Delivery includes costs attributed to specific housing projects.
The Loan Fund sets aside HOME funds which are available for projects throughout the year. The City’s rehabilitation and down payment assistance programs, as well as loans for multi-family developments, are funded from this pool.
In 2015-16 the City began allocating HOME funds to multi-family projects through a NOFA process rather than one a first-come, first-served basis. Projects receiving funding through this process include Anchor Village and Hunter Street Apartments which are both close to starting construction and the Grand View Village and Medico Artist Lofts which are still in the planning phase. Habitat for Humanity and S.T.A.N.D. also received funding for single-family programs. The 2017-2018 HOME Loan Fund will also be allocated through a NOFA process with funding recommendations brought to Council for final approval.
In addition to the Federal HOME funds, the City still has program income from CalHome funds that it received from the State Department of Housing and Community Development (HCD). Approximately $70,000 is available to fund down payment assistance loans and owner-occupied rehabilitations.
|
HOME Administration |
Program Year 2016-2017 |
Program Year 2017-2018 |
Difference: 2016-2017 to 2017-2018 |
Percentage: 2016-2017 to 2017-2018 |
|
HOME Administration |
$135,197 |
$140,197 |
$5,000 |
3.7% |
|
Housing Program Delivery |
$114,582 |
$114,582 |
$0 |
0% |
|
Loan Fund |
$1,187,050 |
$1,184,528 |
($2,522) |
(0.2%) |
Community Housing Development Organizations Project Assistance
HUD regulations require that 15 percent of the City’s HOME allocation be reserved for affordable housing projects undertaken by Community Housing Development Organizations (CHDO), which are community-based organizations that develop affordable housing. Currently, Visionary Home Builders and STAND are the City’s certified CHDOs. HUD has established requirements for CHDO certification, and the City utilizes a checklist to ensure that all the requirements are met before certifying an organization as a CHDO.
|
CHDO Assistance Program |
Program Year 2016-2017 |
Program Year 2017-2018 |
Difference: 2016-2017 to 2017-2018 |
Percentage: 2016-2017 to 2017-2018 |
|
CHDO Set Aside (New Allocation) |
$172,795 |
$172,795 |
$0 |
0% |
Emergency Solutions Grant Program
ESG provides funding to emergency shelters, homeless service providers, and for homeless prevention and rehousing programs. Eligible activities are street outreach, emergency shelters, homelessness prevention, and rehousing assistance. Funds may also be used to provide the required Homeless Management Information System (HMIS) and for administrative activities. The emphasis of the ESG program is to assist people to regain stability in permanent housing after experiencing a housing crisis and/or homelessness; therefore, HUD limits the amount of a jurisdiction’s ESG grant that can be used for assistance to emergency shelters to not more than 60 percent.
In 2015-16, ESG funds were allocated to six organizations. These organizations provided shelter and services to over 3,550 people, of which approximately 700 were children. An additional 780 people received medical and dental care, as well as case management services which helped them access various benefit programs such as Food Stamps, Medi-Cal and General Relief. Rent assistance was provided to 185 individuals to prevent them from becoming homeless or to assist those that were homeless to get back into housing.
The CDC reviewed the six applications that were received requesting ESG funds. The CDC’s recommendations are shown below. The ESG funds are generally allocated using a formula based on the number of beds at each shelter, except for St. Mary’s, which is not a shelter, and Stockton Shelter, which has many more beds than the other shelters. Based on the formula, Gospel Center Rescue Mission would have received $34,525. However, they only requested $25,000. The CDC’s recommendation is to allocate Gospel $25,000 and divide the $9,525 which would have gone to them based on the formula evenly between the other four organizations.
|
ESG Funding |
Program Year 2016-2017 |
Program Year 2017-2018 |
Difference: 2016-2017 to 2017-2018 |
Percentage: 2016-2017 to 2017-2018 |
|
Emergency Shelter Activity |
|
Gospel Center Rescue Mission |
$25,000 |
$25,000 |
$0 |
0% |
|
Haven of Peace |
$21,030 |
$21,030 |
$0 |
0% |
|
St. Mary's |
$46,080 |
$46,080 |
$0 |
0% |
|
Stockton Shelter |
$54,820 |
$54,820 |
$0 |
0% |
|
Women's Center - Youth & Family Services |
$27,830 |
$27,830 |
$0 |
0% |
|
Subtotal |
$174,760 |
$174,760 |
$0 |
0% |
|
|
|
|
|
|
|
Other Activities |
|
CVLIHC - Homelessness Prevention/Rapid Re-Housing |
$106,513 |
$106,513 |
$0 |
0% |
|
Administration |
$10,000 |
$10,000 |
$0 |
0% |
|
TOTAL ESG FUNDING |
$291,273 |
$291,273 |
$0 |
0% |
Contingency Provisions
Due to delays in Congress with HUD’s FY 2017-18 appropriations, HUD has instructed jurisdictions to include contingency provisions in their Action Plan to address how the estimated allocations will be adjusted once actual allocations become known. By including contingency provisions, the City will avoid the need to make significant revisions to its plan once allocations are received.
If the City’s overall reduction is minimal, for example, between one and five percent, decreases will first come out of the Housing Loan Pool and depending on the exact reduction, with small reductions to other activities if necessary. If the City’s allocations are reduced more than five percent, reductions will impact sub-recipient allocations, in addition to requiring adjustments in other activities.
On May 4, 2017, the CDC met to determine the best approach to devise a contingency plan for sub-recipient allocations. The CDC made a recommendation to prioritize CDBG sub-recipients by rank and eliminate funding from some sub-recipients rather than immediately reducing all of the sub-recipient's allocations. The table below shows the CDC’s recommended ranking, with the activities listed from the highest to the lowest priority. Depending on the amount of the City’s allocation, sub-recipient’s would either have funding eliminated or reduced as needed based on the CDC’s recommended priorities.
As recommended by the CDC, Stockton Shelter’s proposed Jobs Program would be the first sub-recipient to be effected if the City’s CDBG allocation is reduced, having its award reduced by the $30,000 originally recommended by the CDC. However, as discussed previously, staff is recommending an additional $60,000 for the Jobs Program funded with the Program Income which would not be affected under this scenario.
The CDC also recommended that no sub-recipient award falls below $10,000. If an award falls below $10,000, that activity would be eliminated, and the funding will be distributed to the next ranked project.
Contingency Recommendations
|
CDBG FUNDING: CDC Recommendations: Subrecipient Assistance |
Program Year 2017-2018 |
Priority |
Notes |
Project Type |
|
San Joaquin Fair Housing |
$176,810 |
1 |
Reduce by % if necessary |
Fair Housing Services (Required to Fund) |
|
Emergency Food Bank |
$35,000 |
2 |
Reduce food programs equally by % if necessary |
Public Service (Food) |
|
Second Harvest Food Bank |
$30,000 |
|
|
Public Service (Food) |
|
SJC HSA - Meals on Wheels |
$14,000 |
|
|
Public Service (Food) |
|
Gospel Center Rescue Mission |
$12,000 |
3 |
|
Public Facility |
|
Disability Resource Agency (DRAIL) |
$10,000 |
4 |
Eliminate 2nd in Priority 4 |
Public Service (ADA Accessibility) |
|
Salvation Army Stockton Corps |
$24,000 |
|
Eliminate 1st in Priority 4 |
Public Facility |
|
Read to Me Stockton |
$50,000 |
5 |
Eliminate 2nd in Priority 5 |
Public Service (Literacy) |
|
Tuleburg Press |
$35,000 |
|
Eliminate 1st in Priority 5 |
Public Service (Literacy) |
|
Stockton Shelter for the Homeless |
$30,000 |
6 |
All or Nothing/ Eliminate 1st |
Economic Development (Jobs) |
|
TOTAL |
$416,810 |
|
As an example of how the contingency plan would be implemented, if the City receives a 10% reduction in its CDBG allocation, the funding for sub-recipient’s would be reduced by 10%, or approximately $41,681. In this scenario, $30,000 of Stockton Shelter’s allocation would be eliminated first, leaving a $11,681 reduction to be distributed evenly to the Priority 5 projects. Therefore, approximately $5,840 would be subtracted from both Read to Me Stockton (leaving $44,160) and Tuleburg Press (leaving $29,160).
In a second example, using a 25% reduction, approximately $104,202 would need to be cut from subrecipients. Again, $30,000 of the allocation to Stockton Shelter for the Homeless would be eliminated first, leaving $74,202 in further reductions. Next, the $35,000 allocation to Tuleburg Press would be eliminated because this activity is ranked to be eliminated first in Priority 5, and no sub-recipient award shall fall under $10,000. Finally, Read to Me Stockton’s allocation would be reduced by the remaining $39,202 because they are ranked to be eliminated second in Priority 5.
Once reductions exceed 40% or more, Priorities 3 through 6 would be eliminated, and reductions to the food programs would be distributed evenly by percentage. San Joaquin Fair Housing would be reduced by percentage, as necessary.
In the contingency plan, the ESG sub-recipient’s allocations would be changed by the percentage that the City’s allocation from HUD changes. All other CDBG and HOME allocations would be reduced by percentage, including Administration and Program Delivery, Housing Loans, Façade Improvement Program, Micro-Business Loan Pool, Emergency Grant Program, Entrepreneurship/Business Incubator, Fresh Produce Access Grant, and the CHDO allocation.
Notification
In conformance with the HUD’s requirements and the City’s Citizen Participation Plan, a summary of the Action Plan and a notice of the public hearing were printed in The Record on March 24, 2017. In addition, notification of the Contingency Provisions and a notice of the public hearing were printed in The Record on May 20, 2017. Also, each organization submitting an application has been notified in writing of the CDC’s recommendation and of the date and time of this public hearing. A copy of the draft Action Plan and the draft Citizen Participation Plan were also posted on the City’s website.
FINANCIAL SUMMARY
The Action Plan includes estimated appropriations for the Economic Development Department - Housing Division’s 2017-18 budget. These appropriations are dependent upon the receipt of anticipated funds from HUD. The most recent proposed Federal budget eliminates both the CDBG and HOME programs; however, there is no indication of cuts to the ESG program. If the CDBG and HOME programs are not eliminated, but the allocations are significantly different than what is included in this Action Plan, the contingency provisions will be implemented and allocations adjusted. If the funds are received at close to the levels shown in this Plan, budget adjustments will be made to the CDBG Housing Loan Pool and the HOME Program Loan Fund. Other activities, such as Administration and the CHDO allocation which are a percentage of the annual allocations, will also be adjusted as necessary. Adjustments to the allocation of ESG funds will be made on a percentage basis, with each organization retaining the same percentage of the total grant amount as recommended by the CDC.
Attachment A - Applications Received