To: Honorable Mayor and Members of Town Council
Through: David L. Corliss, Town Manager
From: Matt Gohl, Special Projects Manager
Karen Storey, Grant Administrator
Title
Resolution Approving the Town of Castle Rock 2022 Community Development Block Grant Annual Action 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. On July 20, 2021, Town Council approved the Castle Rock 2021-2025 Consolidated Plan and Citizen Participation Plan. Castle Rock’s distribution for program year 2021 was $230,932 and the Town’s program year began on October 1, 2021.
Castle Rock’s funding for program year 2021 is being used for administration costs, public services and public facilities. The public service funds have been allocated in the amount of $25,000 to supplement the existing hot meal delivery program for seniors offered through the Castle Rock Senior Activity Center. Public facilities funding in the amount of $150,106 was allocated to ADA accessibility improvements for the Butterfield Park restroom so it can be utilized by citizens of all abilities.
The Town’s CDBG distribution for program year 2022 will be $234,817 and will be available starting October 1, 2022. Staff is seeking Town Council approval of a resolution approving Castle Rock’s 2022 CDBG Annual Action Plan (AAP). The AAP provides information as to how the Town will utilize its 2022 CDBG funding, including ongoing support of senior programs, ADA improvements and administrative cost recovery as outlined in the 2021-2025 Consolidated Plan. The 2022 AAP is included in Exhibit 1 for reference.
Should Town Council approve this resolution, staff will submit the 2022 Annual Action Plan to HUD by the August 16, 2022 deadline and begin the 2022 program year implementation. The 2022 program year will begin on October 1 and projects will be determined after that time.
Discussion
The Town of Castle Rock accepted entitlement status into the CDBG program in September 2020. The Town’s grant allocation for fiscal year 2022 is increasing slightly to $234,817, up from $230,932 in 2021. The majority of grant funds must be utilized to support defined national objectives while up to 20 percent of this funding can be used to support costs associated with administering the CDBG program.
Overview/Background
There are numerous CDBG entitlement cities and counties in Colorado including:
• Adams County
• Arapahoe County
• Arvada
• Aurora
• Boulder
• Broomfield City/County
• Castle Rock
• Colorado Springs
• Commerce City
• Denver
• El Paso County
• Fort Collins
• Grand Junction
• Greeley
• Jefferson County
• Lakewood
• Longmont
• Loveland
• Pueblo
• Thornton
• Weld County
• Westminster
Examples of CDBG funded projects accomplished by these entities include establishing a high school mentoring program to empower students from low-income communities to
graduate high school (Arapahoe County); senior services, educational and job training programs, childcare services (Colorado Springs); food delivery, day care assistance, low-income, senior, and special needs housing plus homebuyer assistance (Fort Collins); and, childcare scholarships, 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
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 Strategic Priorities
CDBG funding priorities are determined through analysis of available data, input from the public and area stakeholders. Significant public outreach occurred during development of the 2021-2025 Consolidated Plan (ConPlan). Numerous needs were identified during this previous planning process including affordable housing, special needs services, public facility needs, mental health support, domestic violence resources and more. The Town’s CDBG allocation, while not insignificant, is not sufficient to meet all of the needs outlined in the data gathering and public input process. In June 2021, Town Council approved strategic priorities centered on seniors and ADA improvements for Castle Rock’s CDBG funding. Additionally, Town Council supported utilizing CDBG funding, up to 20 percent, to support the costs associated with administering the CDBG program.
2021 CDBG Highlights
CDBG funding for the 2021 program year is being used to support three activities that are discussed in more detail below.
First, the additional hot meal delivery project at the Castle Rock Senior Activity Center was approved in February of 2022 in the amount of $25,000. Since its implementation, over 350 meals have been delivered to 23 new participants. Funding for this program has totaled $6,425 from March through May. We look forward to continued growth of this program in the coming months.
Next, the Butterfield Park restroom will be upgraded to be ADA accessible so it can be utilized by citizens of all abilities. This project is underway now and will complement the Possibilities Playground at Butterfield Crossing Park. The contract was awarded in June 2022 and will use the $150,106 public facilities allocation to support renovation costs. Construction is scheduled for completion by the end of August.
Lastly, the administrative cost allocation for the grant in program year 2021 totals $46,186. This funding supports a part-time Grant Manager, technical support and other consulting services as needed. The total amount reimbursed through May is $13,321.
2022 Annual Action Plan
Public Comment Period
The 2022 AAP (Exhibit 1) was made available for public comment from June 17 - July 18, 2022. No comments have been received as of the writing of this memo. Any comments received throughout the public comment period will be incorporated into the AAP prior to HUD submission. The 2022 AAP was 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.
In addition to the formal 30-day public comment period, staff held a CDBG Open House on June 16, 2022. Attendees included nine staff members, Mayor Gray and Councilmember Johnson - there was no public attendance.
Recommendation
Staff recommends continuing to utilize CDBG funding to support senior services, ADA improvements and to offset program administration costs as presented in the 2022 AAP. Public services and administration allocations are limited to 15 and 20 percent, respectively. Recommended funding allocations for the 2022 AAP are shown below for reference.
Project Name and Proposed Activity |
Funding |
CDBG: Administration (20%) • Community Development Department Admin |
$46,963 |
CDBG: Public Services (15%) • Supportive services for LMI & special needs |
$35,223 |
CDBG: Public Facilities & Infrastructure (65%) • Public facilities, infrastructure |
$152,631 |
Total: |
$234,817 |
Next Steps
Should Town Council approve this resolution, staff will ensure that the 2022 AAP is submitted to HUD by the August 16, 2022 deadline. Following HUD acceptance of the plan, staff will proceed with selection of projects and implementation of the AAP.
Participation in CDBG and other HUD programs requires that the Town certify that it takes appropriate measures to Affirmatively Further Fair Housing (AFFH) in Castle Rock. Although the AFFH definition was changed in 2020, a 2021 rule change reverts to definitions from the 2015 rule. AFFH is currently defined 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. Staff continues to monitor AFFH rule changes and will provide updates to Town Council as necessary.
Budget Impact
The Town’s CDBG allocation for the next year is $234,817. Approved grant expenditures are reimbursed by through the CDBG program, so there is no net financial impact to the Town. Reimbursable costs include program administration and approved project expenses.
Recommendation
Staff recommends approval of Castle Rock’s CDBG 2022 Annual Action Plan.
Proposed Motion
“I move to approve the resolution as introduced by title”
Alternate Motions
“I move to approve the resolution as introduced by title, on the following conditions: (list conditions)”
“I move to continue this item to the meeting on (date) to allow time for: ___”
Attachments
Resolution
Exhibit 1: Castle Rock CDBG 2022 Annual Action Plan