REPORT TO THE CITY COUNCIL
November 6, 2014
FROM: JENNIFER CLARK, Director
Development and Resource Management Department
SUBJECT
Title
RESOLUTION - For the Substantial Amendment No. 2012-002, No. 2013-001, and No. 2014-002 to the Fiscal Years 2012, 2013, and 2014 Annual Action Plans to incorporate the planned use of the Emergency Solutions Grant funds
(Continued from October 30, 2014)
Body
RECOMMENDATION
Staff recommends that the City Council:
1) Approve a Resolution for the substantial Amendment No. 2012-002, No. 2013-001, and No. 2014-002 to the fiscal years 2012, 2013, and 2014 Annual Action Plans to incorporate the planned use of the Emergency Solutions Grant funds; and
2) Authorize the City Manager to sign all implementing documents and approval as to form by the City Attorney.
EXECUTIVE SUMMARY
Each year the City of Fresno submits an Annual Action Plan to the U.S. Department of Housing and Urban Development (HUD) describing how it will utilize federal funding to accomplish certain federal and local objectives. The Emergency Solutions Grant (ESG) Program is a part of that application. This amendment is intended to clarify the use of the funding, to comply with certain narrative submission requirements, and to include the consultation with the Fresno/Madera Continuum of Care (FMCoC) prior to the public review period.
BACKGROUND
The City of Fresno has been the recipient of homelessness program funding for a number of years. This program was previously under the guidelines of the ESG program but in 2010, the program was overhauled and renamed the ESG Program as part of the HEARTH Act. Beginning in 2011, the priorities and funding categories of the program were redirected to long-term housing solutions rather than temporary shelter solutions. With the changes in the national program requirements along with new national initiatives to end homelessness, the City has been working to amend its program guidelines and realign anticipated outcomes to be consistent with the national expectations.
The ESG Program is designed to identify sheltered and unsheltered homeless persons, as well as those at risk of homelessness, and provide the services necessary to help those persons quickly regain stability in permanent housing after experiencing a housing crisis and/or homelessness. The City and County of Fresno, separately, are recipients of an annual allocation of ESG funding. The two agencies will work together to release a request for proposals for federal fiscal years 2013 and 2014 later this fall.
Subrecipient awards for 2011 and 2012 were approved previously. This amendment is centered on bringing the Annual Action Plan into compliance with the HEARTH Act regulations and to establish future funding categories.
The formula allocations for the ESG program are as follows:
|
FFY 2011* |
FFY 2012 |
FFY 2013 |
FFY 2014 |
Allocation |
$188,386 |
$596,740 |
$418,409 |
$517,584 |
*second allocation
On August 10, 2014, the Housing and Community Development Division released a Notice of Upcoming Public Comment Period to inform the public that a draft amendment to the Annual Action Plan would be available beginning August 25, 2014. City Staff attended the August 8, 2014 meeting of the FMCoC to describe the planned activities and timelines for the amended Action Plan and to receive feedback. At that meeting, the agencies expressed concerns about the City's timeliness in award of ESG funding and the burden of the matching requirements. Both concerns have been addressed in the draft Amendment.
On August 24, 2014, the Housing and Community Development Division released a Public Notice regarding the Public Review and Comment on Proposed Use of ESG Funds. No formal comments were received during the first 30-day comment period; however, a number of recommendations regarding technical compliance were raised internally and externally. These include the addition of the priorities from the City & County of Fresno Ten Year Plan to End Chronic Homelessness adopted in 2008, addition of the specific providers including their one-year goals and specific action steps as provided in their proposals for service, and replacing the Veteran's Administration (VA) gaps analysis with the current Point in Time survey that was conducted by the Fresno FMCoC.
These recommendations were incorporated into the draft document considered by the Housing and Community Development Commission (HCDC) at their public hearing on September 10, 2014. The commission heard and considered a recommendation to the City Council regarding the amended 2011-2014 Action Plans. One public comment was made which focused on the need for a general emergency shelter to serve non-specific clientele. The HCDC considered the activities discussed in the Amendment; comments made by the Commission members included the need to process federal funds in a timely manner and to extend the FFY 2012 subrecipient contracts for an additional nine months for subgrantees to be able to complete their activities.
On September 18, 2014, the FMCoC requested additional time to review the changes made during the first 30-day comment period. After consultation with HUD, staff decided to open a new comment period and request additional consultation from the FMCoC. The draft was provided to the Chair of the FMCoC for review prior to opening a new comment period; no changes were recommended at that time. On September 26, 2014 a second notice was published initiating a second, 30-day public comment period. City Staff attended the October 9, 2014 regular meeting of the FMCoC to solicit additional feedback regarding the proposed activities and budget. A number of comments were received at that time. The first comment was to clarify the FMCoC's position on a "come as you are" shelter which was the result of a different community conversation and while it held merit, it was not the recommendation of the FMCoC. The second comment was to ensure the City would continue to consult with the FMCoC not only on the Action Plan but on accomplishments and monitoring of subrecipient activities. Finally, the FMCoC requested the City and County amend the joint policies and procedures to require participation in the CAHM system for subrecipients of the ESG program. City Staff and the FMCoC executive committee strongly recommended that all members review and make comment on the second draft.
These recommendations were incorporated into the draft presented to the HCDC on October 22, 2014. There was no quorum at the HCDC meeting. However, two members of the public were present and made comment. The concerns centered around timeliness of allocation of funds and accountability by the agencies receiving funding, the HCDC as a board, and the City as a whole. City Staff concurs with the public testimony that the City must be proactive to ensure that the funds are allocated in a timely manner, that the agencies which are receiving the funds are accountable to both the City and HUD, and that the HCDC has an active role in both funding allocation and ensuring commitments are met. The public comment period ended on October 25, 2014; there were no written public comments.
The attached Resolution and Amended Action Plan reflect the recommendations and comments by the FMCoC, the public, and the HCDC received during all comment periods, public hearings, and consultation meetings
Staff recommends approval.
ENVIRONMENTAL FINDINGS
By the definition provided in the California Environmental Quality Act Guidelines Section 15378, this item does not qualify as a "project" and is therefore exempt from the California Environmental Quality Act requirements.
LOCAL PREFERENCE
Local preference was not considered because the amendment does not include a bid or award of a construction or services contract.
FISCAL IMPACT
There is no increase or decrease to the approved budget for the Emergency Solutions Grant (ESG).
Attachment A: Draft Amendment
Attachment B: Resolution