FISCAL YEAR 2014-2015
ANNUAL ACTION PLAN
1
Community
Development Block
Grant (CDBG)
CDBG Regulations 24 CFR Part 570
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FISCAL YEAR 2013 INCOME LIMIT SUMMARY
FOR VENTURA COUNTY
Median Income $86,700
Income
Limit
Category
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
7 Person
8 Person
Extremely
Low
Income
(30%)
$18,350
$21,000
$23,600
$26,200
$28,300
$30,400
$32,500
$34,600
Very Low
Income
(50%)
$30,600
$35,000
$39,350
$43,700
$47,200
$50,700
$54,200
$57,700
Low
Income
(80%)
$48,950
$55,950
$62,950
$69,900
$75,500
$81,100
$86,700
$92,300
Source: US Department of Housing and Urban Development December 11, 2012
Income Limit areas are based on FY 2013 Fair Market Rent (FMR) areas.
http://www.hud.gov/offices/cpd/affordablehousing/programs/home/limits/index.cfm
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CDBG ENTITLEMENT GRANT PROGRAM OBJECTIVES
•
•
•
The primary objective of the CDBG is to develop viable urban communities by
providing decent housing, a suitable living environment, and expanded
economic opportunities, principally for persons of low and moderate income.
The two ways to achieve this objective are:
 Grantee can only use funds to assist eligible activities meeting one of the
three national objectives (benefiting the extremely low-, very low and lowincome persons, prevent and eliminate slums or blight, or meet community
development needs having a particular urgency). The activities must be
eligible and meet a national objective. (CFR 570.201 to 570.206 Eligible
Activities and CFR 570.208 Criteria for National Objectives).
Grantee must spend 70% of its funds for activities that address the national
objective of benefiting low- and moderate-income persons. The following
expenditures do not accrue to the 70% expenditure credit:
 Planning and Administration
 Slum and blight activities
 Urgent need activities
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CDBG ENTITLEMENT GRANT PROGRAM PARTNERS
• The primary instrument towards achieving the primary
objective is to extend and strengthen partnerships amongst
all levels of government, private sector and non-profit
organizations.
• The CDBG key partners:
1. CDBG Grantee
2. Subrecipient
3. Community-Based Development Organization
(CBDO)
4. Contractor
5. Unit General Local Government
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ELIGIBLE CDBG ACTIVITIES
In general, any activity that is not specifically authorized under the CDBG
regulations and statute is ineligible.
• 24 CFR 570.201 to 570.206 lists CDBG eligible activities (Attachment #1)
• 24 CFR 570.207 discusses about the ineligible activities (Attachment #2)
CDBG funds can be used to support public services, affordable housing activities
along with other community and economic development activities:
• Housing
• Other Real Properties
• Public Facilities and Improvements
• Public Services
• Economic Development
• Revitalization Areas (NRSA)
• Other Eligible Activities
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CDBG NATIONAL OBJECTIVES
Attachment #3 is related to 24 CFR 570.208 criteria for national objectives. Each eligible activity must meet
one of the 3 national objectives
1. Benefit principally low and moderate income (LMI) persons.
• LMI Area benefit (LMA):
• Boundaries of the service area must be primarily residential. The activity should benefit all
the residents in the particular area,
• Income data of residents and percent LMI
• Commonly used category for community-wide activities
• If less than 51 % exception rule applies
• Examples of LMA activities are street improvements, neighborhood facilities, water and
sewer lines, and façade improvements in a commercial district that serves a LMI
neighborhood
• Limited Clientele (LMC):
• Documentation on household size and income of each person receiving the benefit, in order
to show that at least 51%of the clientele are LMI, or
• Documentation that facility/service designed for or used exclusively by one of the eligible
“presumptive” groups, or
• Documentation of nature and location of the facility/service such that it can be presumed to
service LMI, or
• Data showing a special project for accessibility barriers removal.
• LMI Housing (LMH)
• The purpose of the eligible activity is to provide or improve permanent residential structures,
that upon completion, will be occupied by low and moderate income households.
• For structures with 3 or more units, low and moderate income households must occupy at
51% of the units
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CDBG - NATIONAL OBJECTIVES
•
CONT’D
LMI Job (LMJ)
• Written agreement with required provisions
• Listing of job title of permanent job filled (available to LMI)
• Evidence of job lost without CDBG
• Listing of job title of permanent jobs retained, including part-time
2. Aid in the prevention and elimination of slums or blight:
•
•
•
Area Slum/Blight:
• Boundaries of the area meeting the definition of slum/blight under the local law;
• Description of conditions qualifying the area (substantial number of deteriorated or
deteriorating buildings, or public improvements) and the activity must address one or more of
the conditions that contributed to the deterioration of the area;
• Documentation must be maintained on the boundaries and the conditions that qualified the
area at the time of its designation.
Spot Slum/ Blight:
• Activities that eliminate specific conditions of blight or physical decay on a spot basis not
located in a designated slum and blighted area.
• Only acquisition, clearance, relocation, historic preservation and building rehabilitation
activities qualify for this national objective
Urban Renewal area:
• Activities located within an Urban Renewal project area or Neighborhood Development
Program action area that are necessary to complete an Urban Renewal Plan,
• Documentation of the Urban Renewal Plan including maps and supporting documentation
must be maintained at the time the CDBG activity is carried on.
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CDBG - NATIONAL OBJECTIVES
CONT’D
3. Meet a need with a particular urgency: this category is designated only for activities that alleviate
emergency conditions. Urgent need activities must satisfy the following qualifying criteria:
• The existing conditions must pose a serious and immediate threat to the health or welfare of the
community; and
• The existing conditions must be of recent origins, or must recently become urgent (last 18
months); and
• The grantee is unable to finance the activity on its own; and
• Other sources of funding are not available.
Guide to National Objectives and Eligible Activities for Entitlement Communities
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CDBG - NATIONAL OBJECTIVES
CONT’D
National
Objectives
Low/Mod
Slum/Blight
LMA
Area Basis
LMC
Spot Basis
LMH
Urban
Renewal
Urgent
Needs
LMJ
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CDBG CAPS
There are 3 categories in CDBG grant:
Administration
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•
•
Program Administration: overall program management, coordination, monitoring, reporting and
evaluation
Other eligible activities: fair housing activities, indirect costs, citizen participation costs
20% of Current Year Allocation and Current Year Program Income Funds
Public Services
•
•
•
15% of Current Year Allocation and Prior Year Program Income Funds
The public service must be a new service or a quantifiable increase in the level of a service
Example of public services include, but are not limited to: child care, health care, job training,
recreation programs, educational programs, public safety services, fair housing activities, services
for homeless and for senior citizens, drug abuse counseling and treatment, energy conservation
and testing, homebuyer downpayment assistance and welfare (but excluding provisions of income
payments)
Capital Improvements Projects (CIP) or Direct Benefits Projects
•
•
•
•
Housing Activities: housing services, housing rehabilitation, lead-based paint testing and
abatement, and homeownership assistance...
Public Facilities and Improvements: infrastructure, community facilities, special needs and public
facilities
Other Real Property Activities such as Code Enforcement, acquisition, disposition …
Economic Development: Business Technical Assistance, micro-enterprise assistance, commercial
rehabilitation
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CDBG ENTITLEMENT GRANT COMPLIANCE REQUIREMENTS
1. To meet the primary objective of CDBG, grantee is required to expend not less
than 70 % of CDBG funds for activities that benefit LMI persons.
2. Under the provisions of 570.902(a), a grantee is considered to be timely, if its
rate of expenditure does not exceed 1.5 times the annual current program
year grant 60 days prior to the end of the fiscal year. The grantee will be
subjected to a reduction of the total amount by which it exceeded the threshold
in case of non-compliance. Timely use of funds has been increasingly important
in times of tight budget. (Attachment #4 - IDIS PR 56)
3. Environmental review must be complete by the grantee for all project activities
prior to obligating CDBG funds. No HUD money may be used to fund projects
that cannot receive National Environmental Protection Act (NEPA) clearance.
This report must be completed for every CDBG-, HOME- and ESG-funded
activity to show that there is no impact on the environment or, if there is, that
there is no negative impact on the environment. (24 CFR Part 58)
4. Under certain conditions, the grantee and its subrecipients may incur costs prior
to the effective date of the grant agreement with HUD. Pre-award costs should
not exceed 25% of grant amount or $300,000, whichever if greater.
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PERFORMANCE MEASUREMENT
Performance measurement is an organized process for gathering information to determine
how well programs/activities are meeting established needs and goals:
• Develop and use a standardized methodology and system to measure the outcomes of
the 4 Community Planning and Development (CPD) formula grant programs: CDBG,
HOME, ESG and HOPWA,
• Use a framework by grantee to classify activities in the ConPlan and to report specific
required data,
• Enable HUD to report on the outcomes of the 4 grants nationally.
The three components of the measurement system are:
1. Objectives (3):
• Creating Suitable Living Environments
• Providing Decent Housing
• Creating Economics Opportunities
2. Outcomes (3):
• Availability/Accessibility applies to activities that make services, infrastructure, public
services, public facilities, housing, or shelter
• Affordability applies to activities that provide affordability in a variety of ways to LMI
people such as creation and maintenance of affordable housing, basic infrastructure
hook-ups, or transportation or day care services.
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PERFORMANCE MEASUREMENT CONT’D
•
Sustainability applies to activities aiming at improving communities or neighborhoods,
by removing or eliminating slums or blighted areas.
3. Indicators (4):
• Amount of leverage from other Federal, state, local and private sources per activity,
• Number of persons, households, businesses, units or beds assisted, as appropriate,
• Income levels of persons or households: extremely low- (30% of AMI), very low (50%
of AMI) and low-income (80% of AMI). For CDBG LMA activities, the data reported
will need to show the total number of persons served and the percentage of LMI
individuals served.
• Race, ethnicity, and disability data: under CDBG, race/ethnicity data is required only
when the undertaken activity benefits directly persons or households such as job
creation, housing rehabilitation. This indicator data is not required for activities under
CDBG LMA, slum/blight, or urgent need national objectives.
Race: white, Black/African American, Asian, American Indian/Alaskan Native, Native
Hawaiian/Other Pacific Islander, American Indian/Alaskan Native & White, Asian White,
Black/African American & white, American Indian/Alaskan Native & Black/African, Other
multi-racial, Asian/Pacific Islander
Ethnicity: Hispanic
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REPORTING REQUIREMENTS
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•
•
•
•
•
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Labor Laws and Requirements: HUD-4710 Form - Semi-annual Labor Standards
Enforcement Report
Minority Business: HUD-2516 Form – Annual Minority Business Enterprise contract and
Subcontract Activity
Section 3: HUD-60002 – Annual Section 3 Hiring and Contracting Summary Report
Federal Financial Report - SF-425 and SF-425A sent to HUD on a quarterly basis
Quarterly performance updating in IDIS for CDBG activities
Annual Performance Report or Grantee Performance Report (GPR IDIS PR 03)
Consolidated Annual Performance and Evaluation Report (CAPER)
Annual Reports are used to meet 3 basic purposes:
 Provide HUD with necessary information to assess each grantee’s ability to carry out
its programs in compliance with applicable regulations and requirements,
 Provide information necessary for HUD to report to Congress, and
 Provide grantees with an opportunity to describe its program achievements with their
citizens.
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MONITORING
Monitoring projects is important to any systematic plan of action of managing
CDBG (timeliness issue, primary objective, funding criteria for each activity…).
Different types of review/monitoring:
• Desk review: administrative and financial monitoring
• Field Monitoring: project monitoring
• HUD Monitoring: program performance monitoring
• Corrective Action and Training and Technical Assistance
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CDBG- ADMINISTRATIVE REQUIREMENTS
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•
•
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•
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Labor Standards Requirements: 29 CFR Parts 1, 3, 5, 6 and 7.
Procurement 24 CFR 570.502, 570.610 and 85.36
Environmental Review 24 CFR Part 58
Lead Safe Housing Rule: 24 CFR Part 35, 570.608.
Uniform Relocation Act: 24 CFR Part 42, 49 CFR Part 24 and HUD Handbook
1378.
Fair Housing and Equal Opportunity Laws: Section 109 and 570.602.
www.hud.gov/offices/fheo/index.cfm
Desk procedure
•
Program policies and procedures
•
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CITIZEN PARTICIPATION PLAN
The Oxnard Citizens Participation Plan , originally adopted by
the City Council on October 18, 1994, and modified on July
25, 2000, consists of:
• Public Outreach and Access
• Public Hearings
• Technical Assistance
• Comments and complaints
• Amendments
24 CFR 91.200(c) and 91.215 (I)
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CONSOLIDATED PLAN AND ANNUAL ACTION PLANS
The consolidated Plan is prepared by the grantee in accordance with 24
CFR Part 91 and describes needs, resources, priorities and proposed
activities to be undertaken with respect to HUD’s CPD formula programs
(CDBG, HOME, HESG and HOPWA).
• June 2013 the City Council approved 2013-2018 Consolidated Plan and
2013-2014 Action Plan;
• HUD approved the submission of the 2013-14 Plan in August 2013; and
agreement was executed in September 2013.
• FY 2013-2018 Consolidated Plan and FY 2013-14 are posted on the
City website at:
http://housing.cityofoxnard.org/Uploads/ConsolidatedPlanFY2013-2018andAnnualActionPlanFY2013-2014DraftSubmitted.pdf
• Information related to the preparation for the 2nd year Annual Action
Plan (FY 2014-15) are posted at: http://housing.cityofoxnard.org/10/91
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FUNDING PRIORITIES
The Strategic Plan of the Consolidated Plan has established following
priority needs and goals:
• Housing Need with a high priority level targeting extremely-low and lowincome households and with the goal of assisting the first-time
homebuyers to achieve homeownership, creating new affordable rental
housing units and housing preservation and maintaining a safe and
healthy living environment through code enforcement.
• Homelessness with high priority targeting homeless families with
children, chronic homelessness individuals, veterans and victims of
domestic violence with the goals of reducing homelessness by
providing housing and supportive services, financial assistance
(homeless prevention and rapid re-housing to at-risk of becoming
homeless persons), job training and placement and shelter services.
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FUNDING PRIORITIES CONT’D
• Non-Housing Community Development with high priority needs,
targeting transitional age youth, and low-income at-risk youth with the
goals of providing job training and placement, supportive services and
recreational services.
• Public Facilities and Improvements needs with high priority level
targeting the low- and moderated income areas
• Non-Homeless Special Needs targeting the elderly person, the
mentally-ill persons, disabled and substance abused persons by
proving housing and supportive services
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HUD FORMULA GRANT PROGRAMS
FIVE YEAR ENTITLEMENT SUMMARY (FY 2010-2014)
2010
2011
2012
2013
2014*
CDBG
$2,961,698
$2,472,356
$2,063,138
$2,185,785
$1,967,200
HOME
$1,147,134
$1,012,662
$667,268
$646,077
$581,500
$120,297
$187,486
$214,100
$150,512
$135,460
$4,229,129
$3,672,504
$2,944,506
$2,982,374
$2,684,160
ESG
TOTAL
http://portal.hud.gov/hudportal/HUD?src=/program_offices/comm_planning/about/budget
* Estimated amount only
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ANNUAL ACTION PLAN 2014-2015 ALLOCATION
The estimated amount for the program year 2014 is $1,967,200
1. Administration maximum amount $393,440
2. Public Services maximum amount $295,080. This category will have a
limit for projects funding award ($20,000 minimum and $100,000
maximum).
3. CIP Projects balance $1,278,720.
Adjustments will be done automatically when we will receive PY 2014 HUD
allocation.
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EVALUATION CRITERIA
All proposals will be evaluated on specific criteria, including:
• Compliance with the CDBG national objectives and the primary
objective;
• Eligibility as a CDBG activity;
• Ability to receive NEPA clearance;
• Overall impact in addressing community needs as identified in the City’s
Consolidated Plan;
• Compliance and consistency with local policies, plans and goals as
identified in the City Consolidated Plan;
• Financial feasibility and timeliness;
• Extended benefit to persons of low and moderate income;
• Clarity of the proposal narrative; and
• Completeness of the proposal
The due date of the proposal packet is January 24, 2014 at 12 P.M.
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CONSOLIDATED ANNUAL PERFORMANCE AND EVALUATION REPORT (CAPER)
Within 90 days of the end of the fiscal year, a jurisdiction is required to
provide an annual report, known as CAPER, to HUD. The CAPER
summarizes the City’s performance for the fiscal year and must include a
description of the resources made available, the investment of available
resources, the geographic distribution and location of investments, the
families and persons assisted (including the racial and ethnic status of
persons assisted), and other actions indicated in the Strategic Plan and the
Action Plan. The grantee should strive to ensure that all applicable
deadlines are met and the performance information are accurate.
Local jurisdictions that receive CDBG must include the Financial Summary
Report (Attachment # 5 - PR26) in addition to the narrative provided in the
template.
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INTEGRATED DISBURSEMENT AND INFORMATION SYSTEM (IDIS)
IDIS is the online system for CDBG, HOME, HESG and HOPWA formula
grant programs and HOPWA competitive program. IDIS serves 2 major
purposes (disbursement and information). Grantees use the system:
1. to track the projects/activities and draw down funds and program
income, and,
2. to record the results of grant funded activities. Grantee Performance
Report (Attachment #6 - PR 03), Summary of Accomplishments
(Attachment #7 - PR 23) and CDBG Financial Summary Report
(Attachment #5 - PR26) are specific to CDBG.
HUD uses the data grantees provide in IDIS to report on the performance
of the grant programs to Congress and other programs stakeholders.
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PROPOSAL PACKET
1. Project Overview and Information (Attachment #8 – POI)
• POI as a funding application form
• POI as an IDIS activity data form
• POI as a documentation of the environmental review
2. Proposal Narrative
3. Itemized Budget
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FY 2014-2015 ANNUAL ACTION PLAN SCHEDULE
Important Dates:
• December 10, 2013: FY 2014-15 Needs Assessment public hearing
• March 18, 2014: Second Public Hearing related to priorities and uses of
funds. Mandatory attendance for agencies who have submitted funding
applications
• May 6, 2014: 3rd public hearing related to proposed projects to be
funded for FY 2014-15 Annual Action Plan
• May 15, 2014: Submission of FY 2014-15 Annual Action Plan to HUD
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PROPOSAL AND APPLICATION PROCESS
• January 9, 2014: Pre-Application Sessions. Mandatory workshops for
potential applicants.
• January 24, 2014 at 12 PM: Due Date of the proposal packet.
• February 21, 2014 at 12 PM: Due Date of the application packet. If the
project is approved by the council to receive CDBG funding, the entire
application packet will be part of the agreement.
• March 18, 2014: Public Hearing mandatory attendance for all
applicants who have submitted an application packet.
• May 6, 2014: Final Public hearing to adopt the FY 2014-15 Annual
Action Plan.
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General Information
Contact information:
William E Wilkins
385-8094 bwilkins@oxnardhousing.org
CDBG Juliette Dang 385-7493 juliette.dang@ci.oxnard.ca.us
HOME Karl Lawson
385-8095 karl.lawson@ci.oxnard.ca.us
ESG Will Reed
385-8044 will.reed@ci.oxnard.ca.us
*******************
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QUESTIONS?
Written comments are recommended via email contact:
juliette.dang@ci.oxnard.ca.us
Phone contacts: Juliette Dang at 805 -385-7493 (English)
Angelica Navarro at 805 -385-8275 (English/Spanish)
FY 2013-2018 CONSOLIDATED PLAN
FY 2013-2014 ACTION PLAN