Agenda Item Wording:
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Consolidated Plan Development. Receive an update and provide direction on development of the City’s next 5-year Fiscal Year (FY) 2025/26 - FY 2029/30 Consolidated Plan (ConPlan) for the use of U.S. Department of Housing and Urban Development (HUD), federal Community Development Block Grant (CDBG), and HOME Investment Partnership Program (HOME) funds.
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Deadline for Action: 12/3/2024
Submitting Department: Finance and Technology Services
Contact Name and Phone Number: Margie Perez, Housing Specialist, margie.perez@visalia.city <mailto:margie.perez@visalia.city>, (559) 713-4460; Melody Murch, Assistant Finance Director, melody.murch@visalia.city <mailto:melody.murch@visalia.city>, (559) 713-4379; Renee Nagel, Finance Director, renee.nagel@visalia.city <mailto:renee.nagel@visalia.city>, (559) 713-4375
Department Recommendation:
Staff recommends that Council:
1. Review community outreach results;
2. Provide input on high priority needs; and
3. Provide direction on preparation of the Draft Strategic Plan, Action Plan, projects, and program activities for the use of CDBG and HOME funding for the next 5-years.
Background Discussion:
As required by the U.S. Department of Housing and Urban Development (HUD), the City develops a Consolidated Plan (ConPlan) every 5-years to guide the use of federal Community Development Block Grant (CDBG) and HOME Investment Partnership (HOME) funding. The 5-year ConPlan is the framework for the allocation of resources to support projects and programs benefiting low-and moderate-income people by increasing housing and economic opportunities, strengthening low-income neighborhoods, addressing public services, and providing for infrastructure needs. As part of the process for the next 5-year term (FY 2025/26 - FY 2029/30), staff has been working with a consultant, Baker Tilly, Inc. The process has included preparing and disseminating public notices, information flyers and surveys, collecting and analyzing surveys, conducting community public meetings and stakeholder interviews, and collecting the results to identify high priority needs. Baker Tilly also conducted a Housing Windshield Survey analysis to assess housing conditions, which is a requirement of the Housing Element and provides data that supports affordable housing program needs.
Consolidated Planning Process: The Consolidated Plan (ConPlan) establishes a comprehensive strategy, that identifies community needs, prioritizes those needs, and details how they will be addressed. The ConPlan strategy also incorporates the City’s Citizen Participation Plan (CPP), which governs how the City will conduct outreach to the community and encourage their participation in the ConPlan, Action Plan, Amendments, and Consolidated Annual Performance and Evaluation Report (CAPER) process for this next 5-year term. Also included in the ConPlan is the preparation of an Analysis of Impediments to Fair Housing Choice (AI), which assists in identifying any barriers to affordable housing, as well as examines policies and fair housing practices surrounding housing choices.
Community Surveys, Public Outreach & Stakeholder Meetings: Through public noticing of community meetings and surveys (see attachment “A-1” survey results), opportunities were provided for the community to give feedback on spending priorities for the next 5-years. This feedback serves as the framework for a community-wide dialogue to identify housing and community development priorities. Staff has engaged citizens and stakeholders to assess community development and housing needs and identify the highest priority needs related to the use of both CDBG and HOME funding over the next 5-years (FY 2025/26 - FY 2029/30).
The survey’s links and public notices were posted on the City’s website, and City social media outlets from July 12, 2024, through August 2, 2024. The survey announcements were also posted on the Kings/Tulare Homeless Alliance listserv, the Tulare County Homeless Task Force email list, and the Community Care Coalition email list to approximately 1,000 stakeholders. Surveys were also provided during community meetings and community stakeholder meetings held in the months of September and October 2024.
The Community Organization and Resident Surveys were used to gather feedback and information from organizations and residents within the community for the FY 2025/26 - FY 2029/30 Consolidated Plan. Both surveys were open for responses from July 12 through August 2, 2024. The Community Organization Survey reopened between August 12 through August 16, 2024, and from September 25 through October 4, 2024, to collect additional responses from organizations that attended virtual stakeholders focus groups; the Community Resident Survey reopened between September 6 through September 13, 2024, to collect additional responses from those that attended September community meetings. The Community Organization Survey had 23 respondents, and 122 individuals responded to the Resident Survey. No responses were logged for the Spanish Resident Survey.
Additionally, the City of Visalia Housing Division surveyed individuals during two other events - the 2023 Farmworker Women’s Conference and the Citizens Advisory Committee Meeting on the FY 2025/26 - FY 2029/30 Consolidated Plan. Please see below for a brief description of the organization and citizen survey results. Please see Attachment “A-1” for full survey results.
Organization Survey Results: Organizations that completed the organizational survey serve the following populations: low-income, homeless, youth, elderly, victims of domestic violence, disabled, protected class members, and individuals with HIV/AIDS. The top 5 gaps (needs) identified by various organizations include:
1) shortage of affordable housing,
2) homelessness prevention programs,
3) mental health services,
4) substance abuse treatment programs, and
5) job training programs.
Citizen Survey Results: The combined citizen survey results below include results from the online citizen survey, the Farmworker Women Conference survey, and the Citizen Advisory Committee community meeting survey.
The citizen survey top 5 public service needs include:
1) mental health,
2) homeless/homeless prevention,
3) youth,
4) domestic violence, and
5) job training.
The citizen survey top 5 greatest housing needs include:
1) senior housing,
2) development of affordable rental housing,
3) emergency drop-in shelter,
4) permanent supportive housing, and
5) home repair assistance.
The citizen survey top 5 economic development needs include:
1) job training,
2) job creation/retention,
3) workforce development,
4) small business assistance, and
5) business mentoring.
The top 5 citizen survey infrastructure improvements needed include:
1) streets/roads,
2) parks,
3) flood drainage,
4) street lighting, and
5) sidewalks.
Comments Received: In addition to surveys conducted, citizen comments were also received. Below is a summary of citizens comments received. These comments will be included in the final Consolidated Plan document.
Comments received during the CAC meeting included suggestions to:
• Utilize CDBG funds for housing and services for unaccompanied youth, including aged out foster youth ages 18 to 24 years old as well as youth services for ages 13 to 18 years old.
Comments received during community and stakeholder meetings include the need for:
• Ongoing supportive services,
• Ongoing operating/sustainable funding of projects serving older adults, homelessness prevention, and intensive case management services,
• Housing for unaccompanied youth, including aged out foster youth ages 18 to 24 years old,
• Senior/disabled housing development,
• Senior/disabled housing rehabilitation to remain in their homes,
• Affordable rental housing,
• Tenant-based rental subsidies, and
• A low-barrier emergency shelter.
Emailed citizen comments received include suggestions to fund:
• Street asphalt, driveway approach, and sidewalk repairs in low-income residential areas due to damage caused by solid waste trucks.
Funding Sources and Use of Funds
Community Development Block Grant (CDBG): The purpose of the CDBG program is to enhance and maintain viable urban communities through the provision of decent affordable housing, a suitable living environment, and the expansion of economic opportunities for low - moderate income persons and households. HUD allows up to 20% of a CDBG award to be used towards general program administration and planning and permits up to 15% to support Public Service activities. The remaining 65% is available for other projects vital to community development such as public facilities and improvements, economic development, and housing.
CDBG National Objectives
To be eligible for CDBG funding, each activity must meet one of HUD’s three National Objectives. The National objectives are:
1. Benefit low- and moderate-income individuals.
2. Aid in the prevention or elimination of slum and blight.
3. Meeting other community development needs having a particular urgency because existing conditions pose a serious and immediate threat to the health or welfare of the community and other financial resources are not available.
The Benefit to Low and Moderate-Income Individuals (also known as Low/Mod or LMI) is considered the “primary” National Objective of the CDBG program, because federal regulations require that 70% of expended CDBG funds support LMI beneficiaries. The definition of a low or moderate-income person or household is having an income equal to or less than 80% of the area median income (AMI) as established by HUD. The qualifying FY 2024/25 80% annual gross income for a family of four in Visalia is $70,300 or lower.
CDBG eligible activities include but are not limited to:
1. Public services (limited to 15%)
a. Homeless, rental/mortgage assistance, domestic violence, housing counseling, job training, senior disabled, youth, health/mental health, substance abuse, crime awareness, childcare, legal, and fair housing.
2. Acquisition & Disposition
a. Acquisition & disposition of real property, cleanup of contaminated sites, relocation.
3. Public Facilities & Improvements
a. Homeless facilities (emergency shelter or navigation center), senior centers, youth centers, and infrastructure including water, sewer, street, sidewalk, parks/recreation, and ADA (American with Disabilities Act) accessibility improvements.
4. Economic Development
a. Acquisition, construction, rehabilitation, small business assistance, job creation/retention, technical assistance, and job training*.
5. Housing
a. Homeowner assistance, housing counseling*, rehabilitation of single/multi-family, emergency repairs, energy efficiency improvements, code enforcement, lead-based paint testing/abatement, and historical preservation.
(*indicates activities limited to the 15% public services cap).
Although various types of infrastructure are also eligible for CDBG funding in low- and moderate-income areas, staff has limited the discussion of eligible activities to those lacking significant sources of other funding. A full list of the roughly 100 types of activities eligible for CDBG has been provided as an attachment to this item (Attachment “B-1”). Some items in this listing are noted as “not applicable” to the City of Visalia. This list of eligible activities also notes which have been excluded from this discussion based upon the availability of other funding sources, or the lack of survey responses identifying them as needs within the City of Visalia. Although this has been done to focus the discussion on eligible activities with the most limited funding options, staff welcomes comments and direction on any activities included in the full listing attached.
HUD Encouraged Funding:
• Continuum of Care - HUD strongly encourages local jurisdictions to support the local Continuum of Care (CoC), as they oversee the HUD mandated Point-In-Time (PIT) count, Coordinated Entry Systems (CES), Homeless Management Information Systems (HMIS), and Permanent Supportive Housing (PSH) rental subsidy vouchers for our region. The local CoC ensures CES and HMIS grant compliance that allows for continued and additional federal and state grant funding opportunities for the City of Visalia.
• Fair Housing Services - A mandate in the Fair Housing Act of 1968 requires HUD and its recipients to promote fair housing choice, eliminate disparities, and foster inclusive communities. As a result, HUD strongly encourages local jurisdiction support of fair housing services to affirmatively further the purposes of the Fair Housing Act.
HOME Investment Partnership Program (HOME): The purpose of HOME funding is to create and/or retain affordable housing. HUD defines affordable housing as housing where a household pays no more than 30% of their gross income for housing costs, including utilities. Most HOME affordability housing developments are built for households with incomes at 60% or less than the area median income (AMI) level. For example, a qualifying Visalia family of four at 60% AMI in FY 2024/25 has an income of $52,740 or lower and should not be spending more than $15,822 per year on housing. This measure of affordability reveals the housing challenges of low-income households. To assist with this need, HOME funding requires that at least 15% of the annual grant be provided to a certified Community Housing Development Organization (CHDO) (501C non-profit) for the development of affordable housing (rental and/or ownership). Self Help Enterprises (SHE) is currently the only local organization which meets the HOME CHDO certification requirements, and the City works with them to provide funding for their qualifying housing development projects. However, any organization can apply to administer a Tenant-Based Rental Assistance (TBRA) program.
HOME funds can be used for housing within four basic programs:
1. Development of Housing
a. Types: Affordable rental or owner-occupied housing, transitional housing, and permanent supportive housing (PSH).
b. Special populations can include senior and/or homeless.
2. Homebuyer assistance
3. Rehabilitation for owner-occupants
4. Tenant-Based Rental Assistance (TBRA)
Below in Tables 2 and 3 are the CDBG and HOME funded activities approved in the current 5-year Consolidated Plan (FY 2020/21 - FY 2024/25). These tables are also included as Attachment “C” to this item.
Staff Recommended Strategies: As part of the ConPlan analysis, staff reviews current high priority needs, required programs, and existing successful activities. Below are staff recommended strategies for the use of CDBG and HOME funds, based upon the data collected.
Community Development Block Grant (CDBG):
• HUD allows up to 20% of CDBG administration. HUD also allows up to 15% of the annual CDBG grant toward public service activities. Requirements for the use of these funds include fair housing and partnering with the Continuum of Care, both of which are funded as part of the 15% public service funding activities. Staff recommend the maximum amounts to be programmed for administration and public services, with additional public service activities to be determined on an annual basis by the Annual Action Plan process, based upon an annual Notice of Funding Availability (NOFA).
• Based upon the community needs assessment, staff recommends CDBG funding for a youth improvement project, such as a park or public facility improvement project. Eligible locations are limited to low-to-moderate income areas and not located in a flood plain. If the project is located in a flood plain, it would require ongoing flood insurance. As a result, the eligible areas are limited to Jefferson Park, Woodland Park, and the Anthony Community Center.
• In addition, based upon the community needs assessment, staff recommends CDBG funding for the development of a year-round overnight emergency shelter for people experiencing homelessness. A year-round overnight emergency shelter is a vital part of the process to bring individuals out of homelessness, and will support the Police Department in providing immediate shelter for those in need, including those residing in the parks, commercial, and residential areas. However, ongoing sustaining operating for an emergency shelter will need other funding. Staff will continue to research if an extended overnight emergency shelter is financially feasible through leveraging other potential funding including additional federal, state, and local funding sources.
• Staff recommends continued funding for:
o Code Enforcement in low-income areas,
o Senior Mobile Home Repair Program, and
o Public improvements to address the continued need for ADA accessible sidewalks.
Note: Council may choose to fund the current CDBG Code Enforcement position in the General Fund and use the CDBG funding for other CDBG eligible activities. However, CDBG Code Enforcement position allows for consistent monthly CDBG drawdowns that assists in grant compliance.
• Staff also recommends beginning a Senior Single-Family Home Repair Program for senior/disabled low-to-moderate-income owner occupants of single-family homes to assist with essential home repairs such as roof repairs/replacement, plumping repairs, ADA improvements, and efficiency improvements etc. to assist seniors/disabled residents to remain in their homes.
HOME Investment Partnership Program (HOME): HOME funding requires that 15% of the annual grant be provided to a certified Community Housing Development Organization (CHDO) (501C non-profit) for the development of affordable housing (both rental and ownership). Self Help Enterprises (SHE) is the only local organization which meets the HOME CHDO certification requirements and continues to be successful with the use of HOME funds. In addition, there is a shortage of rental subsidies in our region to support permanent supportive housing (PSH) units for people experiencing homelessness. HOME Tenant-Based Rental Assistance (TBRA) can assist in providing much needed rental subsidies for PSH units within the City of Visalia. Any organization regardless of CHDO certification can apply to administer a Tenant-Based Rental Assistance (TBRA) program.
HOME Activities Not Recommended: HOME also allows for homebuyer assistance and owner-occupied rehabilitation. However, in efforts to maximize funding staff does not recommended utilizing HOME funds for these activities since homebuyer assistance will be covered by Permanent Local Housing Allocation (PLHA) funds and owner-occupied rehabilitation will be covered by CDBG funds.
Based on the community needs assessment, staff recommends utilizing HOME funds for:
• Development of a senior affordable housing,
• Affordable housing for low-income families, and
• Tenant-Based Rental Assistance (TBRA) to support PSH units for people experiencing homelessness.
Proposed CDBG and HOME FY 2025/26 - FY 2029/30 Activities: Below in Tables 4 and 5 are proposed CDBG and HOME funded activities for the next 5-year Consolidated Plan (FY 2025/26 - FY 2029/30). These tables are also included as Attachment “D” to this item. Also, included in Attachment "D” are the proposed next 5-year Permanent Local Housing Allocation (PLHA) funded activities.
Council Input and Direction: Staff is presenting the identified needs compiled to date, which have been clearly expressed by Visalia residents and the results of the data analysis (HUD CHAS, Census, etc.), to provide Council with full knowledge of the identified needs. Based upon the information provided, and Council’s knowledge of the needs of their constituents, staff is requesting direction concerning the recommended CDBG and HOME priorities and activities for the next 5-years. This is an opportunity for Council to express their priorities and to suggest activities to be included in the in the DRAFT Consolidated Plan which will be brought back to Council in the Spring of 2025 for review and adoption.
Additional Information on Housing Conditions and Fair Housing
Housing Windshield Survey: Included with the consulting services from Baker Tilly was a Housing Windshield Survey which gives insight to real-time existing conditions of single-family and multi-family dwellings within the City. City staff directed and identified areas of Visalia to be included in the windshield survey as part of the ConPlan analysis. Baker Tilly and City staff conducted these surveys on September 18th, 2024. Baker Tilly and City staff drove through the identified neighborhoods and randomly selected homes to profile to ensure impartiality and provide a better reflection of the neighborhood being surveyed. These homes were considered a representative sample of conditions within the neighborhood. Using the rubric created jointly by Baker Tilly and City staff, the following variables were identified:
1. Type of building (single family/multifamily/mixed use)
2. Overall neighborhood condition
3. Roof Condition
4. Siding Condition
5. Landscaping Condition
6. Fence Condition
7. Right of Way Condition
8. Average age of housing stock
Variables 2 through 8 were given ratings of poor, fair, good, or great. The ratings are defined as follows on Table 1 - Definition of Ratings:
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Table 1 - Definitions of Ratings |
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Poor |
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Homes constructed prior to 1978 |
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Showing signs of deferred maintenance |
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Unkempt yard, siding falling off, roof needs replacement |
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Fair |
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Home greater than 30 years old |
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Showing signs of needing renovation |
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Home may need rehabilitation soon |
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Good |
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Home between 15-30 years old |
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Home may be becoming slightly outdated |
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Will need slight renovations in the near future |
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Well-Kept |
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New home |
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Well maintained yard with new roof and siding |
Five neighborhoods were analyzed within the City of Visalia, as well as twenty-one total subsections of these neighborhoods. For a detailed description of the neighborhoods surveyed, please see Attachment F, DRAFT Windshield Survey.
Of the twenty-one areas analyzed on these variables, a vast majority were in good condition (73.3%) with the remainder split between poor (12.4%) and fair (14.3%). No area analyzed was considered to be in 100% well-kept condition, meaning all areas have an opportunity for some improvement. Of the thirteen poor rate variables, twelve were within the Oval Park neighborhood, making the Oval Park area the neighborhood which could benefit from the most improvements. This survey yielded insight into areas of the City that have a high possibility of homes with lead-based paint issues, and neighborhoods that have sidewalks that need improvements to meet ADA standards. Several sidewalks require ADA improvements as they are cracked, uneven, and need ADA curb cut improvements or installation to accommodate those with physical disabilities.
The information provided in the Housing Windshield Survey furnishes the City with data that could be used for future funding sources to help in rehabilitation efforts and public improvements. A copy of the Housing Windshield Survey is included as Attachment “D” to this report.
Analysis of Impediments to Fair Housing Choice (AI): As noted above, the ConPlan includes the AI, which assesses the extent of housing needs among specific income groups, evaluates housing choices, and analyzes conditions in the private and public sector that could impede a person’s access to such housing. AI information reflects barriers (see attachment “G” for draft identified potential impediments) related to:
• Lending practices
• Land Use Policies & Practices
• Regional Collaboration related to services
• Opportunity Indicators
• Housing Discrimination
As a result of the analysis to date, the City will continue to work with its partners and consultants to provide fair housing education as well as to monitor discrimination. The City recently updated its Housing Element that also includes Affirmatively Furthering Fair Housing. The City shall continue to work with surrounding cities and non-profit providers, as well as the Continuum of Care to share new programs and funding opportunities to address homelessness. The City recommends continued efforts in making programs, such as affordable housing development, available citywide to address segregation and concentration barriers. Baker Tilly staff will also be conducting an analysis of Visalia’s market conditions, and a homeless needs assessment, as well as preparing the Strategic Plan and the first year (2025) Action Plan, based on high priority needs identified through community outreach and City and Council input.
Next Steps
Staff will release a NOFA during winter 2024/2025 to seek applications from organizations prepared to administer public services, and the various proposed ConPlan programs for the 2025/2026 program year. The NOFA is a competitive process, and the resulting staff recommendations for public service and program funding will be brought to Council as part of the proposed Annual Action Plan for 2025/2026.
Staff will use the priorities and direction provided by Council tonight, along with the results of the NOFA process, the data collected, and analysis performed, to draft the proposed Consolidated Plan, and proposed 2025/2026 Annual Action Plan which will be brought to Council in the Spring of 2025 for review, public comment, and adoption.
Fiscal Impact:
None at this time. Staff will return in the Spring 2025 to appropriate CDBG and HOME funds for FY 2025/2026 as part of the ConPlan and Annual Action Plan process.
Prior Council Action:
● April 20, 2020 - Adoption of current Consolidated Plan.
● Annual Action Plans adopted - April of 2021, 2022, 2023, and 2024.
● Consolidated Annual Performance and Evaluation Report (CAPER) approved and submitted to HUD September 2021, 2022, 2023, and 2024. ● September 3, 2024 - Public hearing to receive public comment as part of the Public Participation process for development of the FY 2020/26 - FY 2029/30 Consolidated Plan for the use of CDBG and HOME funds.
Other: None
Alternatives: None recommended.
Recommended Motion (and Alternative Motions if expected):
recommendation
I move to direct staff to prepare the draft Con Plan, projects and program activities for the use of CDBG and HOME funding for the next 5-years and FY 25/26 Action Plan to include Council’s approved recommendations.
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Environmental Assessment Status: N/A
CEQA Review: N/A
Attachments:
● Attachment A-1: Survey Results
● Attachment A-2: Citizen ConPlan project requests
● Attachment B-1: CDBG Eligible Activity Descriptions
● Attachment B-2: CDBG Eligible Activities Full List
● Attachment C: FY 2020/21 - FY 2024/25 ConPlan CDBG & HOME Activities
● Attachment D: Proposed FY 2025/26 - FY 2029/30 CDBG, HOME & PLHA Activities
● Attachment E: Low-and-Moderate Income Areas
● Attachment F: Draft Windshield Survey Report
● Attachment G: Draft Analysis of Impediments to Fair Housing Choice (AI)
● Attachment H: FY 2025/26 - FY 2029/30 ConPlan PowerPoint