To: Honorable Mayor and Members of Town Council
Through: David L. Corliss, Town Manager
From: Matt Gohl, Special Projects Manager
Title
Resolution Approving the Town of Castle Rock 2021-2025 Consolidated Plan and Citizen Participation Plan
Body
________________________________________________________________________________
Executive Summary
In September 2020, Town Council accepted entitlement status into the federal Community Development Block Grant (CDBG) program beginning in fiscal year 2021. Castle Rock’s distribution amount is $230,932 and the Town’s program year will begin on October 1, 2021. Staff is seeking Town Council direction on a resolution (Attachment A) approving Castle Rock’s plans for CDBG involvement.
Staff engaged a consultant (Civitas, LLC) to develop a Consolidated Plan (ConPlan) and Citizen Participation Plan (CPP) as required by the US Department of Housing and Urban Development (HUD). The ConPlan is developed using a combination of available data sources and public input; and, includes a needs assessment, market analysis, strategic plan and more. The full draft of the Town’s ConPlan is available in Exhibit 1. The Citizen Participation Plan (CPP) guides the Town’s public input and general communication procedures related to CDBG. The CPP is available in Exhibit 2.
Should Town Council approve this resolution, staff will submit ConPlan information to HUD by the August 16, 2021 deadline and begin program implementation. This will include a solicitation for project applications and general program administration. Actual projects will be determined through a future application process.
Discussion
The Town of Castle Rock accepted entitlement status into the CDBG program in September 2020. The Town’s actual funding allocation is $230,932 for fiscal year 2021. A portion of this funding can be used to support related administrative costs associated with operating the CDBG program. Since accepting entitlement status in 2020, staff has been engaged, with the support of Civitas, LLC, in developing necessary plans and preparing for CDBG implementation.
Overview/Background
There are numerous CDBG entitlement cities and counties in Colorado that include:
Examples of CDBG funded projects accomplished by these entities include housing rehabilitation and sewer line replacement (Centennial); energy efficiency grants (Englewood); street/sidewalk accessibility improvements (Centennial); establishing a high school mentoring program to empower students from low-income communities to graduate high school (Arapahoe County); low-income, senior, and special needs housing plus homebuyer assistance (Fort Collins); and, park/playground improvements (Lakewood). In general, CDBG funds must be used for activities that meet one of the following criteria:
• benefit low and moderate income persons
• prevent or eliminate slums or blight
• address community development needs having a particular urgency because existing conditions pose a serious and immediate threat to the health or welfare of the community for which other funding is not available
Although the Town has not participated in the CDBG program for several years, these grant funds were used in the past to complete alleyway improvements, to make curbs ADA accessible and to support public service programs. Other examples of eligible activities that qualify for CDBG funding include:
• Acquisition of real property
• Relocation and demolition
• Rehabilitation of residential and non-residential structures
• Construction of public facilities and improvements, such as water and sewer facilities, streets, neighborhood centers, and the conversion of school buildings for eligible purposes
• Public services, within certain limits
• Activities relating to energy conservation and renewable energy resources
• Provision of assistance to profit-motivated businesses to carry out economic development and job creation/retention activities
Castle Rock Needs, Goals & Recommendations
CDBG funding priorities are determined through analysis of available data, input from the public and area stakeholders. Public input efforts included a community survey, stakeholder survey and two public meetings. Surveying was conducted by Civitas, LLC in a coordinated effort with Douglas County, who is also initiating a CDBG program for 2021. Note that Douglas County is planning to vote on their ConPlan at the July 27 Board of County Commissioners meeting. Additionally, two virtual public meetings were hosted on April 12 and 15, 2021. Public outreach efforts have resulted in 208 citizen survey responses, nine stakeholder responses and three public meeting participants (plus several Town Council and staff members).
Numerous needs were identified including affordable housing, special needs services, public facility needs, mental health support, domestic violence resources and more. The Town’s $230,932 CDBG allocation, while not insignificant, is not sufficient to meet all of the needs outlined in the data gathering and public input process. However, staff recommends the following for initial CDBG funding priorities.
A portion of CDBG funding, up to 20 percent, will be used to support the costs associated with administering the CDBG program. The remainder CDBG funding will be used toward senior and special needs/ADA initiatives. Note that HUD has established that a maximum of 15 percent can be used towards public services, such as transportation or senior services, while the remaining amount can be used toward facility/infrastructure projects like accessibility improvements at parks or on sidewalks. Below is a summary of these proposed activities and associated funding amounts.
Town council unanimously approved this priority distribution and strategic direction for CDBG grant utilization at the June 1, 2021 regular meeting.
Citizen Participation Plan
HUD requires development of a CPP that will be followed in relation to CDBG program administration. Public participation is a key element of CDBG planning and program development. The CPP provides guidance for noticing public hearings and meetings, purposes of such meetings and describes how documents will be made available for citizen review. This includes making information available for citizens with Americans with Disabilities Act (ADA) and bilingual needs. Castle Rock does not have a large number with limited English-speaking proficiency (LEP) so the Town is not required to develop formal language policies at this time. Rather, the Town will provide translation and/or accessibility services if needed and as requested. Town Council approval of the resolution presented this evening will endorse both the ConPlan (Exhibit 1) and CPP (Exhibit 2).
Public Comment Period
The ConPlan and CPP were made available for public comment from June 18 - July 19, 2021 and no comments were received. Documents were available for review at www.CRgov.com/cdbg <http://www.CRgov.com/cdbg>, the Philip S. Miller Library and in the Town Hall lobby for inspection. Additionally, printed copies of these documents are available upon request.
Next Steps
Should Town Council approve this resolution, staff will move forward with implementation of the CDBG program and ensure that plans are submitted to HUD by the August 16, 2021 deadline. Once HUD accepts the Town’s ConPlan, staff will proceed with CDBG implementation - including soliciting applications for specific projects and determining future oversight of the grant program.
Additionally, of note are recent rule changes made regarding Affirmatively Furthering Fair Housing (AFFH). Participation in CDBG and other HUD programs requires that the Town certify that it takes appropriate measures to AFFH in Castle Rock. The recent rule change overturns the 2020 change and reverts to definitions from the 2015 rule. The new rule defines AFFH as taking “meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially or ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws.” While the 2020 rule allowed a wider interpretation of AFFH, the reversion to the 2015 rule requires a more proactive approach to AFFH for entities who accept HUD funding. A staff memo with more information and interpretation of this rule change has been provided in Attachment B for review.
Budget Impact
CDBG is a reimbursable grant program. Any Town projects would be reimbursed as approved. Additionally, up to 20 percent of administration costs associated with running the CDBG program are reimbursable. Any additional administrative costs would be borne by the Town and are expected to be minimal, if any.
Recommendation
Staff recommends approval of Castle Rocks 2021 - 2025 Consolidated Plan, Citizen Participation Plan and proceeding with CDBG program implementation.
Proposed Motion
“I move to approve the Resolution as introduced by title.”
Attachments
Attachment A: Resolution
Exhibit 1: Castle Rock 2021 - 2025 Consolidated Plan and Certifications
Exhibit 2: Citizen Participation Plan
Attachment B: AFFH Rule Change Memo