HomeMy WebLinkAbout02/20/1990, 3 - CONSIDERATION OF AN APPLICATION FOR FUNDING FROM THE PLANNING AND TECHNICAL ASSISTANCE ALLOCATION F f MEETING DATE:
III I�I���IIIII��II I�III CI7LY O f San LUi, oBispo February 20, 199
COUNCIL AGENDA REPORT ITEM NUMBER:
FROM: John Dunn, City Administrator
Prepared by: Alison Lloyd, Administrative Analyst v--
SUBJECT: Consideration of an application for funding from the Planning and Technical
Assistance Allocation for the State Community Development Block Grant
Program on behalf of the Women's Shelter Program, Inc., which includes
a $7,500 "in kind" contribution by the City.
CAO RECOMMENDATION:
Adopt resolution approving the grant application.
BACKGROUND:
Discussion
The Women's Shelter Program, Inc. has been assisting women and children who are the
victims of domestic violence by offering emergency shelter and food, counseling and
advocacy since 1979. Although the number of persons served by the shelter and the
extent of the program have continued to increase over the years, rental costs have
escalated at a disproportionately higher rate. The cost of renting their current facility
is $2,000 per month. As a result the program has given the highest priority to identifying
and purchasing a permanent shelter site with grant funding.
The state planning and technical assistance grant would enable them to contract with the
People's Self-Help Corp. for assistance in achieving this goal. The assistance provided
by the People's Self-Help Corp. would include formally assigning a staff person to work
with the Women's Shelter Program, Inc. over a 12 to 18 month period to assess program
needs such as interior and exterior space, short-term clients versus medium-term clients,
site inventory and evaluation, financial feasibility analysis, and low interest loan or grant
procurement.
ummary of February 6
At their regularly scheduled meeting on February 6, Council was asked to approve the
Women's Shelter Program, Inc. request for City sponsorship of an application for a state
planning and technical assistance grant which would include a $7,500 cash match by the
City. Council.determined that the scope of the project was consistent with Community
Block Development Grant Programs and the general polices and objectives of the City's
Housing Element of the General Plan. In addition, Council was assured that all or a
portion of the cash match requirement could be made through "in kind" services
throughout the thirty month grant period. Based on these conditions, Council approved
the Women's Shelter Program, Inc. request with the understanding that a Public Hearing
would be held on February 20 to adopt a resolution approving the grant application.
RECEIVED
FEB 1 5 1990
lams'o
UTY CLERK
SAN LUIS OBISPO,CA
111111111jIMI city of san suis OBISPO
COUNCIL AGENDA REPORT
Council Agenda Report
Page Two
mm
Staff has reviewed the 1990 Community Development Block Grant Application and finds
that it is consistent with the conditions set by Council. Therefore, staff recommends
that the City Council approve the attached resolution approving an application for
funding from the planning and technical assistance allocation of the State Community
Development Block Grant Program.
FISCAL IMPACT:
There is a $7,500 cost associated with approving the resolution although it is anticipated
that all of a portion of it can be met through the application of "in kind" services. If
the application of "in kind" services are not adequate over the 30 month grant period to
meet the $7,500 cash match requirement, staff requests Council authorization to make
available sufficient funds to meet the remainder of the cash match requirement.
CONCURRENCES:
The City Attorney and the City Finance Director concur with the recommendation to
approve the application for the grant funds.
APPROVED:
City Ad ' 'strator
Communit Deve ment Director
Dir or of Finance
E:\women.wp 4 h
J �d
r
RESOLUTION NO. (1990 Series)
A RESOLUTION OF THE COUNCIL OF THE CITY OF SAN LUIS OBISPO
APPROVING AN APPLICATION FOR FUNDING OF A GRANT FROM
THE PLANNING/TECHNICAL ASSISTANCE ALLOCATION OF
THE STATE COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM
WHEREAS, the City of San Luis Obispo has reviewed and hereby approves an
application for: Women's Shelter Program, Inc., Affordable Housing Development in the
amount of $30,000, and
WHEREAS, the City Council has reviewed the citizen participation plan for
compliance with federal statute and has determined that this plan was followed for the
development of this application, including the execution of a grant agreement should the
application be funded, and
WHEREAS, the City Administrator is authorized and directed to act on the City's
behalf in all matters pertaining to this application.
NOW THEREFORE BE IT RESOLVED, the City Council hereby approves the
use of General Fund monies in the amount of $7,5Q0 to be used as the City's cash match
as described in the application for this project (Exhibit A).
On motion of seconded by
and on the following role call vote
AYES:
NOES:
ABSENT:
the foregoing Resolution was passed and adopted this day of
1990
�-3
Page 2
ATTEST:
MAYOR RON DUNIN
City Clerk Pam Voges
APPROVED:
.rte
City A ministrative Officer
(not available)
City Att ey
Di ector of Finance
2
February 5, 1990
City of San Luis Obispo
P. 0. Box 8100
San Luis Obispo, CA 93403-8100
Attn: Alison Lloyd
Subject: CDBG Planning and Technical Assistance Application
Dear Mrs. Lloyd:
This letter confirms Peoples ' Self-Help Housing Corporation
(PSHHC) interest in carrying out the Women's Shelter activity
described in the City's 1990 CDBG application. As noted in the
application, PSHHC has worked with the Shelter on a voluntary
basis over the past year to achieve their goal of a permanent.
affordable site for emergency and transitional housing.
We estimate that to accomplish this objective, PSHHC would need.
to assign a professional staff person an average of 1/3 time over
a 24-month period to assess Women's Shelter long-term financial/
borrowing capacity, client need, evaluate City land use, zoning
and permit issues, identify and negotiate a site, and research
and obtain funds for acquisition and/or rehabilitation of a
suitable site. The cost of this staff person on a 1/3 time basis
over a 24-month period is estimated at $30, 000.
We appreciate City sponsorship of this CDBG application. The
Women' s Shelter provides an important source of affordable
housing to a most vulnerable population group.
Sincerely,
Scott Smith _
Director of Programs .
SS:mc
Peoples' Self-Help Housing Corp.
1411 Marsh Street, Suite 103
Son Luis Obispo, California 93401
(805) 544-5717
66�q9 State of Californ
P City of San Luis Obispo CDBG Pro'
F� `' - (Applicant)
PLANNING�� TOSIROCATION
APPLICATION
PPIN ASSISTANCE
FOM
Page _ of
Ia. APPLICANT: (4 City ( J County of San _Luis Obispo
b. Department f. Phone (805) 549-7180
c. Street/P.O. Box P.O. Box 8100 g. Consultant/Other Public Ajency
Contact Person Scott Smith
City San Luis Obispo Zip 9__8100 Peoples' Self-Help Housing
h, Address 11545 Los Osos Valley Road
San Luis Obispo, CA 93401
d. Applicant's Staff Contact Person Alison Lloyd i Phone (805) 544-5717
e. Title Administrative Analyst
2. TYPE OF APPLICATION:
a. (XI On Applicant's Own Behalf e. ( J For Funding from the Economic
Development Planning/Technical
b. ( J Joint Application: Assistance Allocation:..__
and
c. ( J On Applicant's Own Behalf and on Behalf f [X( For Funding from the General
of Planning/Technical Assistance
d, ( J On Behalf of Only Allocation:
�. LEGISLATIVE REPRESENTATIVES:
Member of the Assembly
State Senator Member of Canare>
a. District Number 29 District Number 14 District Number__.
b. Name Eric Seastrand_ Name Ken Maddy Name Leon Panetta
C. Address 97, Hi aunra St—_
Address 995 Nana Address 1160 Marsh St,
City Morrp Say City San ,is nhie_p_
d. City San Luis 0 isco ---
District Number_._ District Number _ District Number.
N Name
Nome ame -
Address
Address Address
City City City
I-3
4. Activity Title: Women' s Shelter Study J
Amount Requested: $30-0011
It
Amount of Cash Match $7,500
by Applicant:
Note: Amount requested may not exceed $30,000. Refer to the General Provisions S� ts� to
determine minimum cash match required.
5a. APPLICATION HECKLIST:
[A Application Summary Form pQ Activity Description Form
Activity Budget and Schedule Form Statement of Assurances
b. ATTACHMENTS:
Resolution by Governing Body
Letters Received and Responses
( � (if applicable)
Approving Application
Letter or Resolution Documenting Joint Powers Agreement if applicable)
Cash Match Contribution ( pp
( � Additional Data (if applicable) Letters of Intent or Commitment
(if applicable)
6a. Has applicant enacted limitations on residential construction
( l no Yes
which are not establishing agricultural preserves, not imposed
by another agency, or not based on a health and safety threat`?
b. If the answer 'to 6a is yes, is the housing element approved by ( J no Yes
the Department.'
C. If the answer to 6b is no, is the application for low income ( ] no yes
housing?
7. OFFICIAL AUTHORIZED TO SUBMIT APPLICATION:
Name
John Dunn Title City Administrative Officer
(Print)
Date 2 � f o
Siunntur "'-
-
I-4
State of California
City of San Luis Obispo CDBG Progra
(Applicants)
PIANNING/TECHNICAL ASSISTANCE ALLOCATIONS
ACTMTY DESCRIPTION FORM
. Page _, of _
Attach one form for each activity.
1 . Activ ty Title: I or ina Hous na Develooment L;omp�'� thelterl
2.Housing Element Update (Portions addressing TIG Housing)
2 . CDBG funds requested for this activity: $ �000-
3 . Describe how the objective of principally benefitting the TIG will be
met by this activity. See the Program Objective Section of this RFP
for the definition of national objective as it applies to a Planning/
Technical Assistance Activity.
See Attached
3a. Total number of households to benefit: 2. 100
120
3b. Total number of households in Targeted Income Group to benefit:
1. 100
F. 120
3c. Total number of households in lowest Targeted Income Group to
benefit: 1. ' 50
2. 60
4 . Anticipated environmental level :
Exempt from NEPA (CEQA is not applicable) .
5. Identify other planning/technical assistance funds which will be
committed to this activity during the grant period.
Anount Source
A. Federal $
B. Other State $
C. Local Cash Match $ 7,500 City of San Luis Obispo
D. Private
TOTAL $ 7,500
II-3 p
3�0
6 . Detailed Activity Description.
(Attach additional pages as needed. )
- SEE ATTACHED
II-4
® J
CITY OF SAN LUIS OBISPO
1990 COMMUNITY DEVELOPMENT BLOCK GRANT APPLICATION
(PLANNING AND TECHNICAL ASSISTANCE SET-ASIDE)
PUBLIC PARTICIPATION PLAN.
It is the intent of the City of San Luis Obispo to provide
residents the opportunity to participate in the development of
the City's 1990 Community Development. Block Grant Program. The
City particularly encourages the participation of low- and
moderate-income persons who are residents of areas in which CDBG
funds are proposed to be used. To facilitate public participa-
tion, there will be a minimum of one public meeting and one
public hearing prior to the submission of any application.
Through public notices, written comment will be encouraged. In
addition, there will be a public information file available for
citizen inspection at City Hall.
1. Citizen Participation File: The file will include a copy of
the application, all public notices, written comments and
responses, and copies of State regulations pertinent to the
application. If the program is funded, performance reports
will also be included in the file. The location of this
file will be included in all public notices.
2 . written Comment: Public comment, including written comment,
will be encouraged. All written comments will be responded
to in writing and copies of this correspondence will be kept
in the Public Participation File. Any written complaints
will be responded to within 1.5 working days where
practicable.
3 . Public Meetings and Hearings:
a. Public Notice: All public meetings and hearings held as
part of the 1990 CDBG Program will .be advertised, at a.
minimum, in the local newspaper, the Telegram-Tribune.
b. Public Meetings: At least one public meeting will be
held during the program design and application prepara-
tion phase for the City's 1990 CDBG application. The
initial public meeting will include the provision of
information about CDBG funds available , national
objectives, competitive rating factors and application
time frames.
A public meeting will be held to consider any annual
grantee performance or close-out reports as required by
Section 7110 of Title 25 of the California Government
Code.
C. Public Hearings: At .least one public .hearing will be
held by the City Council to approve and authorize
submittal to the State of California the completed 1990
CDBG application..
Activity Description Form City of San Luis Obispo
Page 1 of 8
ACTIVITY DESCRIPTION FORM
3. Describe how the objective of principally benefiting the TIG
will be met by this activity. Bee the Program objective
Section of this RFP for the definition of national objective
as it applies to a Planning/Technical Assistance activity.
Activity 1. - Women's Shelter
The objective of principally benefiting TIG households will
be met because this activity directs CDBG funds towards the
planning of a project which, brought to completion, will
assist 100% low income households (households below 80% of
area median income) .
Upon completion of the activity (needs assessment, site
inventory and feasibility analysis, site negotiation and low
interest loan/grant procurement for acquisition and/or
rehabilitation) all beneficiaries of the emergency as well
as transitional (second stage) housing shall be low income.
Historically, 100% of Women's Shelter residents have been
low income. 95% have been poverty level households (on or
eligible for AFDC) . This is due in part to residents
frequent dependence upon spousal income prior to the
physical and/or emotional abuse which resulted in their
need for alternative decent, affordable shelter. The
highest income documented during the. previous year was
$17, 000 for a two person household, which is equivalent to
65% of the area median income for that household size.
Activity 2 - Housing Element Update (Portions Addressing TIG
Housing Only)
The City's Housing Element is scheduled to be updated during
1991-1.992 . The cost of researching and preparing those
portions which address housing for households in the
Targeted Income Group (TIG) shall constitute the city's cash
match requirement under this CDBG application. The CDBG
objective of principally benefiting TIG households shall be
met because in addition to identifying - current TIG housing
issues , the Element develops and adopts detailed
Implementation Programs . These Implementation Programs
identify responsible departments or sponsoring agencies,
funding sources , quantified number of TIG
units/beneficiaries, and specific timetables for completion.
For example, the recently completed Poinsettia Street
Apartments (20 TIG units/1987 CDBG program) had its roots in
the Housing Element.
Detailed Activity Description City of San Luis Obispo
Page 2 of 8
6. Detailed Activity Description
(Attach additional pages as needed. )
Activity 1 - Women's Shelter
A. DETAILED DESCRIPTION OF PROGRAM DESIGN
The purpose of the activity is to enable the Executive
Director, Board and Long Range Planning Committee of the
Women' s Shelter Program to work with a non-profit housing
consultant over an 18 to 24 month period toward accomplish-
ing the following goals: a) reducing the shelter's existing
overcrowding situation (an average of 15 women and children
per night share a 4-bedroom house; b) increasing the number
of women and children they provide housing to (last year 76
SLO households had to be referred to shelter outside the
city due to lack of space) ; c) expanding their program to
include transitional (second stage) housing in addition to
the emergency housing they currently provide; and d)
purchasing a permanent site with low interest loans or
grants in order to reduce vulnerability to rent increases
and arbitrary lease conditions.
The City will enter into a CDBG grant agreement with Women' s
Shelter Inc. , as subrecipient. Women's Shelter Inc. will
solicit consulting services of a non-profit housing
corporation such as Peoples' Self-Help Housing Corporation
to conduct the majority of the activity, in coordination
with the Shelter' s Executive Director and Long Range
Planning Committee.
The steps involved in this activity include:
1. Needs Assessment: The Consultant will complete an
assessment to - establish the level and type of
residential services needed for battered women and
their children . This assessment will include
documentation of the existing need, projection of
future need, and evaluation of emergency versus
transitional housing needs.
2 . Resources Assessment: The Consultant will evaluate the
availability of suitable financing mechanisms and grant
resources which might, separately or in tandem, enable
the Women's Shelter to purchase and/or rehabilitate
residential property. This will include a financial
analysis of the Women's Shelter operating budget and
borrowing capacity.
Ap
3-�a
Activity Description Form City of San Luis Obispo
Page 3 of 8
3 . Existina Site Evaluation: The Consultant will complete
an assessment of the physical condition of the existing
site , including rehabilitation and additional
development potential, and evaluate the consequences of
continued occupancy on that site (financial impact,
overcrowding, unmet demand etc. ) .
4 . Planning Review: In consultation with the City, the
Consultant will review local planning and zoning
ordinances which would potentially impact site
selection. This .would include an assessment of the
public review process and its effect upon the desired
site anonymity.
5. Preliminary Report: This report by the Consultant will
include: 1) an assessment of the level and type of
housing need and a projection of future need; 2) the
feasibility, including a financial analysis, of
purchasing a site which meets the emergency as well as
transitional housing needs of the Women's Shelter; 3)
land use, zoning and other ordinances which would
encourage or inhibit the location of the Women ' s
Shelter; 4) recommendations for meeting the established
residential needs of the Women's Shelter, including
resource recommendations and preparation of development
pro formas.
6. Site identification: The consultant will conduct a site
search for existing residential facilities with
significant potential . Important factors in site
identification will be security of the beneficiaries
and economic feasibility. An inventory of potential
properties will be prepared with an analysis of various
planning, security and financial issues evaluated for
each site. This inventory will be reviewed by Women's
Shelter Director and Board, and each will be rated
according to its potential. Owner(s) of the highest
rated properties will be researched and contacted
regarding sale. A long term option to purchase
agreement will be negotiated with the owner. During
this option period, permanent grant and/or low interest
loan financing will be secured.
7. Application Preparation: at the direction of the City
and the Board of Directors of the Women's Shelter, the
Consultant will prepare appropriate applications for
funding from private and public resources, such as the
Community Development Block Grant or Emergency Shelter
IsPrograms.
��-13
Activity Description Form city of San Luis Obispo
Page 4 of 8
B. DESCRIPTION OF BENEFICIARIES
The number of households potentially benefiting from this
activity is based upon the sum of city households sheltered
on-site last year, and the number of SLO households referred
to other shelters outside the city due to overcrowding.
As discussed above, the Women's Shelter provides emergency
housing to women and their children living in abusive
situations. In general women are referred to the program by
the police and sheriff ' s department, by the county' s
Victim/Witness Assistance program, or by the local Hotline.
All households served in the last calendar year were
low-income: the highest verified annual income was $17, 000
for a two person household, which is only 65% of the area
median income for that household size.
C. DESCRIPTION OF OTHER ACTIVITIES
There is no other facility or program offering affordable
emergency or transitional housing to victims of domestic
violence in the city. The San Luis Obispo City Housing
Authority currently offers one of its apartments for
residents transitioning from the Shelter ' s emergency
housing. However this one apartment is substantially less
than the estimated need.
The City identifies the Women's Shelter in their General
Plan (Housing Element) as an important housing resource for
the community.
California Rural Legal Assistance, in coordination with the
Women's Shelter Program, recently began legal classes for
women orienting them to their rights and assisting them to
obtain restraining orders as necessary. Victim knowledge
and ability to obtain these restraining orders is viewed by
the Shelter as a positive step toward reducing the incidence
of domestic violence.
D. DESCRIPTION OF THE PROBLEM
The battering of women is common: at least 1.8 million women
are battered every year. It is the single major cause of
injury to women, exceeding rapes, muggings and even auto
accidents. According to a 1982 study, more than one-million
women seek medical help for injuries caused by battering
each year; 20% of trauma room visits by women are the result
of battering.
l '
Activity Description Form City of San Luis Obispo
Page 5 of 8
Why not just leave? Fear. Fear of loss of income, loss of
shelter, loss of self.-respect, fear of further abuse.
Domestic violence shelters offer abused and resource-poor
women an immediate alternative to abuse. Annually, more than
a half a million women and children seek the safety and
support of shelter programs. These programs offer shelter,
food, counseling, and safety. They offer the abused woman
the opportunity to regroup, to step out of a crisis
situation, evaluate her resources and plan for the future.
Locally, as nationally, the demand for services for battered
women and their families is increasing dramatically. In
1985 there were 14 reported instances of spousal abuse in
San Luis Obispo County. In 1988 there were 316, a 23-fold
increase over 1985. One-quarter of the victims served by the
Victim/Witness Assistance program are related to domestic
violence.
Resources to support these programs, however, are limited.
In some cases, such as the Emergency Shelter Program and
Federal Emergency Shelter Program, domestic violence
shelters and homeless shelters compete for the same limited
funds. Most available funds are limited to operational
expenses and do not permit capital acquisition.
Most importantly, the funding expended upon housing costs
(i.e. , the lease) , dramatically reduces operating income
available for counseling and. the other intensive services
which are necessary to rebuild dysfunctional lives. The
Women ' s Shelter competes in a rental housing market
dominated by college students and urban immigrants. Rents
are astronomical and rising.
Although ideally situated, the existing facility is
expensive and inadequate. The facility is overcrowded,
housing an average of 15 women and children per night in a
four bedroom dwelling. Additionally, in 1989 the Shelter had
to direct 76 San Luis Obispo households (women and children)
to facilities outside the City (and in many cases outside
the County) due to the inadequate size of their current
dwelling.
Besides needing it larger facility, the Shelter needs to add
transitional housing to its Program. Funding sources limit
the maximum length of emergency stay, and frequently
residents are neither emotionally nor financially prepared
3^ls�
Activity Description Form City of San Luis Obispo
Page 6 of 8
for complete independence. The unfortunate result is that
many households see no alternative but to return to the
abusive situation from which they fled. The addition of
several supervised apartments would meet an important
housing need and greatly enhance the effectiveness of the
Women's Shelter Program.
Expansion of their emergency housing component or the
addition of transitional housing must consider the
long-standing problem of site stability and disproportionate.
use of operating funds for rental payments . The CDBG
activity will consider feasibility of purchasing a permanent
location utilizing low-interest loan and/or grant funds.
E. REASONABLENESS OF COSTS
Reasonableness of cost is documented with a letter from
People's Self-Help Housing Corporation, a local non-profit
housing and community development corporation. PSHHC' s
letter estimates the cost and describes the basis for
arriving at this cost.
F. PROPOSED TASKS/TIMEFRAME
Complete
1. Award Announcement April 9, 1990
2 . Fully Executed Grant Agreement (HCD/City) July 11 1990
3 . Local Contracts Executed
(City/Women's Shelter,Shelter/PSHHC) Aug. 1, 1990
4. Environmental Review Sept. 11 1990
5. CDBG Program Activity Sept. 1, 1991
. Needs Assessment
Resources Assessment
Planning Review
Site ID and Evaluation
6. Preliminary Report - analysis and
presentation of data with recommendations
to the Women's Shelter Board and Long
Range Planning Committee
7 . Site Negotiation/Purchase Agreement Sept. 1, 1992
Preparation of Loan/Grant Applications
for Acquisition and/or Rehab
3-��O
Activity Description Form City of San Luis Obispo
Page 7 of 8
G. FINAL PRODUCT
The final product of the Women's Shelter CDBG activity will be
negotiation of an Option to Purchase Agreement on a permanent
suitable site, and preparation of loan/grant applications for
acquisition and/or rehabilitation of the property.
Activity 2 - Housing Element Update (Portions addressing TIG
Housing Only)
Update of those portions of the City's Housing Element which
address TIG and special needs housing will be conducted primarily
by City staff. The timetable for accomplishing this work program
is during 1991 and 1992, with adoption by 1993.
Affordable housing sections in the existing Element which may
require update include: "Housing Condition and Rehabilitation
Needs; Affordability; Obstacles to Production of Affordable
Housing; Existing Subsidized Housing; Sites for Manufactured
Housing; Sites for Low and Moderate-Income Housing; Article 34
Authorization; Potential Loss of Low- and Moderate-cost Housing;
How the City Has Helped Maintain Affordable Housing; How the City
Has Removed Obstacles to Production of Affordable Housing; and
Housing Organizations" .
Additionally, staff will translate the issues and data identified
in these various sections of the Housing Element into the Element's
Implementation Programs, which must also be updated. These
programs are affordable housing strategies which state specific
objectives, responsible departments or sponsoring agency,
quantified number of beneficiaries or housing units, realistic
means of funding or financing the program, and timeframe for
completing the program and realizing the objective. This meets the
CDBG program objective of principle benefit to TIG households
because if brought to completion, each Program will provide housing
for persons in the targeted income group.
The number of beneficiaries resulting from this CDBG activity is
projected using data and goals quantified in the existing Element.
The sum of its various Programs totals at least 120 TIG units to
be completed during the Housing Element period, with an additional
1,440 low and very low-income units identified for inclusion in the
city's five major expansion areas upon build-out.
��7
Activity Description Form City of San Luis Obispo
Page 8 of 8
Cash Match/In-Kind Services
It is anticipated that the City will meet the $7,500 cash match
requirement through one or more of the following ways:
1. The amount of City Staff time or other resources expended on
activities directly in support of the Women's Shelter
Affordable Housing Development objective.
2. The amount of City Staff time or other resources expended to
update those portions of the Housing Element which address TIG
and special needs housing.
3. A cash contribution to cover the remaining balance if any,
should staff time or other resources allocated to the project
as outlined above be insufficient to meet all of the City's
$7,500 cash match requirement.
A special project account will be established at the City to
account for this match.
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Page _ of _
STATE OF CALIFORNIA
COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM
STATEMENT OF ASSURANCES
The City/ of5an Luis Obispo hereby assures and certifies that:
(a) It possesses legal authority to apply for the grant and to execute the proposed
program.
(b) Its governing body has duly adopted or passed as an official act or resolution,
motion, or similar action authorizing the filing of the application, including all
understandings and assurances contained therein, and directing and authorizing the
applicant's chief executive officer or other designee to act in connection with the
application and to provide such additional information as may be required.
(c) It has or will comply with all citizen participation requirements, including:
1. Preparation of a written citizen participation plan which .includes, at
minimum, the following components: .
a: Provides for and encourages citizen participation, with particular
emphasis on participation by persons of low and moderate income who
are residents of slum and blight areas and of areas in which CDBG
funds are proposed to be used, and provides for participation of
residents in low and moderate income neighborhoods as defined by
the local jurisdiction;
b. Provides citizens with reasonable and timely access to local meetings,
information, and records relating to the grantee's proposed use of
funds, as required by CDBG regulations, and relating to the actual use
of funds under this title;
C. Provides for technical assistance to groups representative of persons
of low and moderate income that request such assistance in developing
proposals with the level and type of assistance to be determined by
the grantee;
d. Provides for public hearings to obtain citizen views and to respond to
proposals and questions at all stages of the community development
program, including at least the development of needs, the review of
proposed activities, and review of program performance, which
hearings shall be held after adequate notice, at times and locations
convenient to potential or actual. beneficiaries, and with
accommodation for the handicapped. This shall include one public
meeting during the program design, annual performance report
preparation, and formal amendments. A public hearing shall be
conducted prior to application submittal;
e. Solicits and provides for a timely written answer to written complaints
and grievances, within 15 working days where practicable; and
IV-1
f. Identifies how the needs of non-English speaking residents will be met
in the case of public hearings where a significant number of non-
English speaking residents can be reasonably expected to participate.
(d) Its CDBG Program has been developed so as to primarily benefit targeted income
persons and households.
(e) It consents to assume the responsibilities for environmental review and decision-
making in order to ensure compliance with NEPA by following the procedures for
"recipients" of block grant funds as set forth in 24 CFR, Part 58, entitled
"Environmental Review Procedures for Title I Community Development Block
Grant Programs. Also included in this requirement is compliance with Executive
Order 11988 relating to the evaluation of flood hazards, and Section 102(a) of the
Flood Disaster Protection Act of 1973 (Pub. Law 93-234) regarding purchase of
flood insurance, and the National Historic Preservation Act of 1966 (16 USC 470)
and implementing regulations (36 CFR 800.8).
(f) It consents to assume the role of either "Lead Agency" as defined by Section 21067
of the California Public Resources' Code, or if another agency is or will be
designated Lead Agency, it consents to assume the role of "Responsible Agency"
as defined by Section 21069 of the California Public Resources Code, in order to
ensure compliance with CEQA.
(g) If has resolved any audit findings or performance problems for prior CDBG grants
awarded by an urban county, by HUD under the Small Cities Program, or by the
State.
(h) It certifies that there is no plan, ordinance, or other measure in effect which directly
limits, by number, the building permits that may be issued for residential
construction or the buildable lots which may be developed for residential purposes;
or if such a plan, ordinance, or measure is in effect, it will either be rescinded
before receiving funds, or it need not be rescinded because:
1. It imposes a moratorium on residential construction, to protect the health and
safety, for a specified period of time which will end when the public health
and safety is no longer jeopardized; or
2. It creates agricultural preserves under Chapter 7 (commencing with Section
51200) of Part 2 of Division 1 of Title 5 of the Government Code; or
3. It was adopted pursuant to a specific requirement of a state or multi-state
board, agency, department, or commission; or
4. The applicant has a housing element which the Department of Housing and
Community Development has found to be adequate, unless a final order has
been issued by a court in which the court determined that it is not in
compliance with Article 10.6 of Chapter 3 of Division 1 of Title 7 of the
Government Code; or
Iv-2
_T:LeZ
5. The use of the funds applied for in this application is restricted for housing
for the Targeted Income Group.
(i) It will comply with the regulations, policies, guidelines, and requirements of OMB
Circular Numbers A-87, A-128, A-102 and A-121, where appropriate, and the State
CDBG regulations.
(j) It shall comply with,the following regarding nondiscrimination:
1. Title VI of the Civil Rights Act of 1964 (Pub. Law 88-352).
2. Title VIII of the Civil Rights Act of 1968 (Pub. Law 90-284) as amended; and
will administer all programs and activities related to housing and community
development in a manner affirmatively furthering fair housing.
3. Section 109 of the Housing and Community Development Act of 1974, as
amended.
4. Section 3 of the Housing and Urban Development Act of 1968, as amended.
5. Executive Order 11246, as amended by Executive Orders 11375 and 12086.
6. Executive Order 11063, as amended by Executive Order 12259.
7. Section 504 of the Rehabilitation Act of 1973 (Pub. Law 93-112), as
amended, and implementing regulations.
8. The Age Discrimination Act of 1975 (Pub. Law 94-135).
9. The prospective contractor's signature affixed hereon and dated shall
constitute a certification under the penalty of perjury under the laws of the
State of California that the bidder has, unless exempted, complied with the
nondiscrimination program requirements of Government Code Section 12990
and Title 2, California Administrative Code, Section 8103.
(k) It will comply with relocation, displacement, replacement housing and real property
acquisition policies and requirements applicable to the Community Development
Block Grant Program.
(1) It will comply with the following regarding labor standards:
1. Section 110 of the Housing and Community Development. Act of 1974, as
amended.
2. Section 1720 et sed. of the California Labor Code regarding public works
labor standards.
3. Davis-Bacon Act as amended (46 U.S.C. 276a) regarding prevailing wage
rates.
Iv-3
vIEETING - 'AGENDA 2
DATE MN #
Robert F. Dennis
Attorney at Law
3081 RocE::view Place
San Luis Obispo , Calif . 93401
sE Ocnotss .ct;c by Lead Person
Telephone : (805) 543-0160
ReshonJ by:
February '19, -1990 Cauncl
1rCA0
'City Atiy.
John Dunn, City Administrator � °ng' �
City Hall pMNI
990 Palm Street '`
San Luis Obispo , California 93401
w
Re : Women' s Shelter Block: GranL application; Program
inadequacyf� iolations of 42 USC 5309 (a) ,
24 CFR 570.496(a) , rim c.5 CCR 7084(x) , ( b) (4)
regarding non—discrimination and affirmative Ki.- COVED
action requirements .
FEB 2 0 1990
CITY COUNCIL
Dear Mr . Lunn: SAN LUIS OBISPO, CA
p,►n .
I am deeply concerned about the state of the application
for Community Development Block: Grant -Funding for the Women' s
Shelter program. Unless fundamental changes are made , the program
will fail to meet community needs , and 'the application will
contain legal defects which will Prevent its approval .
PROGRAM INADEQUACY
My first area of concern is that the program and
application, as it is presently c:;n•, tituted, arbitrarily and
wrongfully excludes a substantial pupule.Lion in need of help:
adult inen who are victims of domestic �. iolence , and the children
in the care of these men. CorLrar ,, L,o conventional belief , the
same kinds of circumstances and patLorns of behavior which often
make women vulnerable to violence in. .he home frequently make men
vulnerable to violence as well .
Unfortunately, due in part extreme reluctance Of Male
victims to report their injuries , and due in part to the cultural
bias whit ; tends to view men battered by women as objects of
humor , this class of victims of .,:.uler.ce in the home has generally
been neglected.
Studies by Suzanne K . Ste nmecz and others show that adult
male victims of domestic violence .are approximately as numerous as
female victims at all levels of sieterity of injury, as can be seen
from the enclosed material on male victims of domestic violence
from`"Handbook of Family Violence , edited by Vincent Van Hasselt .
C) Interestingly, ;in the case of homocide , the most severe and fully
reported. form o;f domestic, viorence , husbands are victims in almost
he -same frequency as wives..
At the. risk of being presumptuous , and in spite of the
length of the . enclosed chapter , I ask that you to read it in full .
An understanding .of the problem of violence towards men is
indispensabie .to the development of a rational and humane domestic
violence response program.
Even though. many researchers have acknowledged the
prevalence of male victims of domestic violence , the habit and
tradition persists of viewing the social problem presented . by
domestic violence as solely that of "wife beating". (see, for
example , Hurray ..A. Straus, eL al ; BEhind Closed Doors — Violence.
in. the American Family, 1980, Garden City, NY; Anchor P ess ) .
' ThiB_ has led to a tendency 'to dismiss male victims of domestic
_ violence as aggressors who are injured by women who act in
self—defense .
Of course in those families in which the pattern of
violence is mutual , it is difficult to assess. what precipitates a
given act of violence. However , even if one accepts uncritically
; and at face value those studies W iLh conclude that wives are more
... likely to use violence in self—defence than husbands , a large
.fraction of the victims who are 7'1llrocenL spouses " , are male .
For example , in M. E. Wolfgang , Studies in Homocide: A
`_,_.Sociological Analysis of Criminal Homocide, •1967, New York , Harper
..and Row, it was concluded that the victim "precipitated" the
homoc,ide in 60% of the cases of husband victims , and in 9% of the
;ases• of wife victims . Given the roughly equal overall incidence
of _male and female interspousal homocide victims , these figures
I_,imply that 30% of those victims who did not "precipitate" their
:` d.eath were :usband<_ .
Are these people, and their children, expendable? This
.J.i.gure derived from homocide data, represents an estimate of the
probable minimum frac'Cion of "innocent " domestic violence victims
.who ,are male . Hopefully, responsible professionals are beginning
7`t.o`_focus on family violence as a fuction of the entire family
� relationship ,.and history, rather than as an issue of
' iAmeworthiness . To do so they must 'transcend conventional
stereotypes of . the behavior , of men and women.
From my own-, experience as an attorney, l am familiar with
. ;a .,litigata,_J fatal case of a battered male domestic partner which
almost exacLly fits the pattern or" violence generally associated
With severe wife battery: This was a relationship in which the
women was dominant and the man passive . The use of alcohol by
J— both partners tended to increase the belligerent behavior of the
l women and tended to render the man more profoundly passive.
.Friends and acquaintances wi'tneSsed repeated assaults by the women
upon the man, including the use of knives and blunt objects, which
resulted in a number of injuries , including head injuries .
' The pattern of assaults continued over a period of about
eighteen months prior to the fatal injury. Police were aware of
the pattern of violence , since they responded to a number of the
assaults which took place in public places . Witnesses noted the
inability of the man to defend himself and his evident inability
to leave the situation. Finally, the man was found in a coma
resulting from a cer?bral hemorrhage caused by a blow from a blunt
object . The injury proved lethal . Due to the absense of
witnesses to the fatal event , the case was never prosecuted,
although the female partner was the principal suspect .
In 1980, in the city in which this case occurred, this
victim, had he been a women, would have in all likelihood received
assistance and intervention from law enforcement , and a"referral
to a domestic violence shelter . If this victim had beeA a women,
he would most likely be alive today.
In addition to its impact on nen, violence to men in the
home has far reaching detrimental effects on children present in
this environment . In discussing the reasons why rnen frequently
remain in abusive relationships , Steinmetz states , at page 242 of
the Handbook:
"Often the husband becomes the victim when he
steps in to protect the children and becomes the
target of abuse. These men are afraid to leave
for fear that further violence would be directed
towards the children. Recognizing that men are
not likely 'to receive custody of the children,
even in an era of increasing recognition of their
ability to care for then , man feel that by staying
they are providing some prct,_ction for their
children. "
Clearly , �„iidrell in 61 �=w Lircums'Lances would be best
protected by extending to fathers —hu same Service_ that the
Shelter program now provides exclusively to mothers .
It is crucial that the Shelter program and grant
application be modified to address the problem of family violence
with respect to all victiess.
VIOLATIONS OF LAW
My second area of concern is the failure of the grant
application 'to address compliance with Federal and State law which
prohibits discrimination on the basis of gender in connection with
Community Development block: Grants . The Women' s Shelter program
in its present form manifestly discriminates against men who are
victims of domestic violence , and .yaii.nst children who are under
the care and protection of male victims .
In addition to the general prohibition against
discrimination, the law requires that a grantee develope an
effective affirmative action R. a.n to eliminate the continuing
affects of past discrimination by the grantee . The application
does not address this requirement either . The relevant sections
of the United States Code , the Code of Federal Regulations , and
the California Code of Regulations are enclosed for clarification,
and are discussed further below. Compliance with these provisions .
is necessary if the substantial funding available through the
Block Grant program is to be used to develope an effective
domestic violence prevention and response program in our
community.
Title 42 USCS Section 5309 (a) provides that no person
shall , on the ground of race , sex , color or national origin, "be
excluded from participation in, be denied the benefits of , or be
subjected to discrimination under any program or activity funded
in whole or in part with funds made available under" the Community
Development Block Grant pr•ograrr,. Section 5309 ( b ) provides for
the enforcement by civil action of Lhis requirement when a local
or state governmental agency fails Lo comply .
Title 24 CFR Section 570.,1 o ( a) recapitulates the
requirement of Section 5309, and provides that the grant to any
state failing to enforce this requir-ament may by reduced,
suspended or terminated, as necessary to induce compliance .
1n California, the Federal Floc!:: Grant program is
administered by the California Department of Housing and Community
Development pursuant to legislative authority to act in that role .
Pursuant to its regulatory authority, the Department has enacted
regulations to incorporate and clarify the non—discrimination
requiremen'Ls of Federal law. Title 25 CCR Section 7084 (a)
clarifies that the requirement applies to any program or activity
carried uuL by any private contractor expending Block Grant funds .
Section 7084 ( b) ( 1 ) details a substantial list of actions which
constitute unlawful discrimination when based on gender . Among
these, t :e rogram may not .
(A) Deny any facilities , services , financial aid
or other benefits provided under 'the program or
a-t_vity.
(B) Provide any facilities , services , financial
aid or other benefits which are different , or are
provided in a different form from that provided to
others under the program or activity.
(C Subject individuals Lo segregated or
separated treatment in any facility in, or in any
manner or process related to receipt of any
sarvice or benefit under the program or activity.
(D) Restrict individuals ' access to , or enjoyment
r of , any advantage or privilege enjoyed by others
in connection with facilities , services , financial
aid or other benefits under the program or
- A; -
— V
activity.
Treat an individual differently from others
Lie ter,:,ini ng .whether Lr,e imdiVidual satisfies
any admission, enrollment , eligibility,
membership, or other'Benefit provided under' 'Che
program or activity.
It should be noted that SUhSeLtiOn ( bi (5) clarifies the
forgoing in Lhat it does provide tF,1t ''living facilities " and
"rest room, facilities " may be provided to each se;; by means of
seperatL facilities . TaE::en ir, cur; Le:: this ciear'ly means that
Lf,i5 1i.L. �_u —facilities .
cf �Bgreyu Leu , at.i Lli3S 111 Li t lie Et4"i Val Btl„ ill
the s _r';'ZCB provided to meIl
Nere changes in for.,,z.1 ;:oL suffice to firing
Lhe current Women' s Shelter pro' r': into con',pliarice , Section 7064
( b) (2? provides that neither' a grantee or a contractor may
"utilize criteria or methods of : ;,. .iia raLinn wF,ich have the
effect or subjecting individuals Lo d.: scrimiria tiun. . . "
=,n affirme;tive action s ru4uircd Ly section 70csA
( i�) (4) ;.i,_r e the program or sct ai •- Ila
P d ground , a has i; rev
:2 WQmcrn' sFShelter . Thecplarnnmuet
on roh.; r: e s
effectivaiy overcome the effect,•; o ," prior discrimination, and
ensure i-;-:-, L Lhe victirr:s of prior di '- _rirlinaLion are able to
participaL; meaningfully in ti' u
:
3 : . De to the conditioned
relUcL_:::CO Cr' m,dlt' victims o !
- U;,,CSLic Violence Lo step forward
and request aid, this plan .,,iii rl0ed Lo include a coordinated
out reac;I Lft'ort working wits, ia.v e1+1., ccrr,ent and other social
�erVic'= e'ntie5 .
L should he noted that :.n_ LXeCU Live personnel of botti
the nonprofit corporation which o, ratas the Women ' s Shelter , and
the Peop. a; Self Hc-1 , Housing Corpura(, icn have the status of
public officials with respect to Li-;eir du Ly to expend Bloch-. Grant
funds in 1—awful manner . In DixSOn v . United States , ( 1964 ) 465 US
482 , 79 _ cd 2d 458, '104• S Ct 11 :c, . IL was Field that the officers
Of nonprofit corpora'Lion administering
"public officio + uonunuruty SiocE;
Grant funds were - - ror i_-urposes of liability to
federal - r iminai p. a= ecutinr! r' i
e„pendit,.r;, of Block- Grant funds .
C.CNCLUS GIkI
ting the present Si,vi. I L2. program 'Lo c011',p1ywi
requirements will not be a simple i,i&LLer . Although, Iarr, not3rant
familiar 'pith', the specific vies <_ , qualifications and experience of
the =_ tar' s rr,embers of the Shelter , suspect that some may I,av
strong obucciions 'Lo including mer! - Yn Lheir program an the same
basis as women, even if living guar Leri and therapy groups arEsegregate'.
fes,
lila ttevwlOpi;lel:i, Of d0,',re�s ; iL "'olHrlcL' shclLers and prop
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f emi ni s t j o i i t c a i p e r s e c:t J.
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TITLE 25 HOUSING AND CObtMUNITY DEVELOPMENT §7084
PROGRAMS (p. 700.27)
(Register 87.No.1-1.1.67)
O (b) In order to ensure compliance with NEPA, grantees shall assume the
responsibilities for environmental review and decision making following the
procedures for "recipients" of Block Grant funds as forth in 24 CFR, Part
58,entitled"Environmental Review Procedures for Title I Community Devel-
opment Block Grant Programs." The Department shall assume the respon-
sibiliities set forth in Subpart C of 24 CFR, Part 58 and fulfill the State's role
under Subpart J of 24 CFR, Part 58.
NOTE: Authority cited: Sections 50406(h) and (n), Health and Safety Code; 24 CFA
570.489(b).Reference:Section 50406 and 50407,Health and Safety Code;Section 21000
et seq.,Public Resources Code;42 U.S.C.4321 et seq.;42 U.S.C.5304(f)(4);25 Cal.Admin.
Code,Chapter 6.5,Subchapter 3,Section 6940 et seq.;24 CFR,Part 58;24 CFR 570.489,
570.495 and 570.496(d).
7084. Nondiscrimination..
(a) Discrimination prohibited. No person shall, on the grounds of race,
color,religion,ancestry,marital status,physical handicap,national origin,sex,
or any other arbitrary basis be excluded from particips:ion in,be denied the
benefits of,or be subjected to discrimination under, anyprogram or activity
funded in whole or in part with CDBG funds made available pursuant to this
subchapter. For the purposes of this section, "program or activity"is defined
as any function conducted by thegrantee or any private contractor receiving
community development funds or loans from the grantee.For the purposes of
this section,"funded in whole or in part with CorAmunity Development funds"
means CDBG funds in any amount which have been transferred by the Depart-
ment to the grantee and disbursed in a program or activity..
(b) Specific discriminatory actions prohibited and corrective actions.
(1) A grantee shall not,under any program or activity paid for in whole or
in part with funds allocated pursuant to this subchapter, directly or through
contractual or other arrangements, on the grounds listed in paragraph (a)
above:
(A) Deny any facilities, services, financial aid or other benefits provided
under the program or activity.
J(B) Provide any facilities,services,financial aid or other benefits which are
d• erent,or are provided in a different form from that provided to others under
the program or activity.
(C) Subject individuals to segregated or separate treatment in any facility in,
or in any manner or process related to receipt of any service or benefit under
thepprogram or activity.
(D) Restrict individuals,access to,or enjoymeat of,any advantage or privi-
lege enjoyed by others in connection with facilities, services, financial aid or
other benefits under the program or activity.
► (E) Treat an individual differently from others in determining whether the
individual satisfies any admission,enrollment,eligibility,membership,or other
requirement or condition which individuals must meet in order to be provided
any facilities,services or other benefit provided under the pr or activity.
(2) A grantee or contractor may not utilizecriteria ormethods of administra-
tion which have the effect of sub`ecting individuals to disc;irnination on the
grounds listed in paragraph (a) ave.
§70S4 HOUSING AND COMMUNITY DEVELOPMENT TITLE 25
(p 40028) PROGRAMS
(Register U No.1-1.143)
C! (3) A grantee, in detetermining the site or location of housing or facilities
provided in whole or in part with funds allocated pursuant to this subchapter,
may not make selections of any site or location which has the effect of excluding
individuals from,denying them the benefits of,or subjecting them to discrimi-
nation on the grounds listed in paragraph (a) above;or which have the purpose
or effect of defeating or substantially impairing the accomplishment of the
objectives of this section.
(4) (A) In administering a program or activity,funded in whole or in part
—with CDBG funds, regarding which the grantee has previously discriminated
against persons on the grounds listed in paragraph (a) above, the recipient
grantee must take affirmative action to overcome the effects of prior discrimi-
nation.
(B) Even in the absence of such prior discrimination,a grantee m adminis
tering a program or activity funded in whole or in part with CDBG funds should
take affirmative action to ensure that discrimination on the grounds listed in
paragraph (a) above does not limit participation in the program.Where previ-
ous(scrimmatory practice or usage tends,on the grounds listed in paragraph
(a) above,to exclude individuals from participation in,to deny them the bene-
fits of, or to subject them to discrimination under any pro am or activity
funded pursuant to these regulations, the grantee has an obligation to take
reasonable action to remove or overcome the consequences of the prior dis-
criminatory practice or usage.
(C) A grantee shall not be prohibited by this part from taking part in any
eligible activity to ameliorate an imbalance in services or facilities provided to
any geographic area or specific group of persons within its jurisdiction where
the purpose of such action is to overcome prior discriminatory practice or
usage.
— -�j5(5) Notwithstanding anything to the contrary in this section, nothing con-
tained herein shall be construed to prohibit any grantee from maintammg or
constructing se to living facilities or rest room facilities for each sex Fur-
�1 thermore,seTecflvi y on the basis of sex is not prohibited when institutional or
custodial services can properly be performed only by a member of the same sex
as the recipients of the service. --- _
(c) Other Prolubited Discrimination. Grantr3hall also,in every contract
for funding pursuant to this subchapter,agree not to discriminate on the basis
of age under the Age Discrimination Act of 1975(42 U.S.C.6101 et x ),or with
respect to an otherwise qualified handicapped individual as provided in Section
504 of the Rehabilitation Act of 197qent.
3 (29 US.G 794).
gran-
tees shall,in eveevehry conve tract for fditypursuan this ssubchapter 7agree that,
to th4 best of the grantee's ability, ey shall make all reasonable efforts in
conngetion with the planning and carrying out of any project activity assisted
with CDBC funds:
(1) To provide opportunities for ��mng and employment to targeted in-
come persons residing within the unit of local government in which the activity
is located.
(2) To award contracts for work in connection with the activity to eligible
business concerns which are located in,or owned in substantial part by persons
residing in the same area as the activity.
NOTE:.Authority cited- Section b0406(h) and (n). Health and Safety Code; 24 CFR
370.489(b).Refereti Sections1290QeLaeq.,GovernmentCode, 0106 and SM, Health
and Sefety Code:12 U.S C.Lftu;'29 U.S.G 794;4£US.C.JiM(d);42 US.Q X01!et seq.;
42 US.C.5309;42 US.C.t)101.etsi W 24 CFR 510.469 and M496(a), (b),and (e).
O
e
1111,110 1 ItI11111111'',11'',
o e o °oma„
°b'b.rr"w
7.o<
§570.494 24 CFR Ch. V (4-1-88 Edition) Office of As_
ing Federal
section 106(d)(3)(A) of the Act may in- pending disbursement for program
clude any administrative costs, direct purposes. tion 602 of tl,
and indirect, related to preparing for directs each
or carrying out the State's program. §570.495 Fri ironmenial responsibilities• agency ergo
a°e Grants provided under section 107 of financial assi
o°A the Act may not be used for ad107 ofis- The State shall assume such respon• activity by w
° the A costs required a be paid from sibilities for environmental review• de• the foregoin
the State's own resources. cisionmaking, and action (and shall re• rules. regula:
quire the assumption of such resporlsi applicability
1570.494 Crant payments; program bilities by units of general local gov. with achieve
income. ernment receiving CDBG funds from thorizing tl
(a) Payments. Payments will be the State under this subpart) as shall HUD regulaL
o made by electronic funds transfer be specified and required in regula• quirements o
r tions issued by the Secretary pursuant HUD progra
whenever possible, letter of credit,
to section 104(f)of.the Act. CFR Part I.
other means, pursuant to grant agree-
ments as required by the Federal Title VIII o.
8 Grant and Cooperative Agreement Act 570.496 Program requirements. 1968(42 U S.
8 of 1977 (41 U.S.C. 501 e1 seq.) and in Section 104(b) of the Act requires known as Uu
compliance with the Intergovernmen- that the State certify, among other provides Lira
tal Cooperation Act (42 U.S.C. 4201 el things, that the grant "will be con_ United State
ducted and administered in conformity stitutional III
f seg.) and Treasury Circular 1075 with Pub. L. 88-352 and Pub. L. 90_ throughout t
o (31 CFR Part 205). States willll utilize.
appropriate procedures to minimize 284•" and, further• that the grantee hibits any w
the time elapsing between the transfer "will comply with the other provisions in the sale or
of funds by the Treasury to the State of this title and with other applicable nancing of h�
ry and the disbursement of funds by the laws_" Section 104(d)(2) of the Act re- brokerage sr
State to recipients. quires that the Secretary determine way making
Q (b)Program income. (1)To the max- '"whether the State has carried out its dwelling; to
itnum feasible extent, the State shall certifications In compliance with the race• color°
disburse to units of general local gov- requirements of this title and other origin. Title
eminent any Program income it re- applicable laws, and whether the State Secretary to
cefves prior to making additional hes made such reviews andaudits of and activitie:
rt✓r draws from the Treasury. the units of general local government urban deveb
w (2) The State may require recipients as may be necessary or appropriate to firmativcly t
to return program Income to the determine whether they have satisfied Title VIII.
p State. These funds may be derived the applicable performance criteria^ Order 11063.
2259
from sources such as reimbursements which incorporate, among other Order 12259
to and interest from a recipient's loanthings, "the requirements• • • of this to take all ar
Program. proceeds from the disposi- title e • • and other applicable laws" palate to pr
° tion of real property, and proceeds Certain statutes are expressly made sex. of or ati
from special assessments, to the applicable,to activities assisted under leasing. rent
extent the costs were initially paid the Act by the Act itself° while other
with CDBG funds laws not referred to in the Act may be residentialr
(3)To the maximum feasible extent, applicable to such activities by their restics(in tial u
th f State shall require each recipient own terms. This section enumerates panty the (
to disburse Its program Income not re- laws which the Secretary will treat as panty there(
gated fcilil
quired to be returned to the State applicable for purposes of the determl- pro
prior to requesting additional funds nations to be made by the Secretary things, prod
from the State to finance its CDBG- under section 104(d)(2)of the Act. with the aid
funded activities, or contribut;
1 (a) Pub. .L. 88-352 and Pub. L 9o?- the Federal
(4)Interest earned by units of gener- 284. "Pub. L- 88-352"refers to Title vi tions implet
b al local government on funds distribut- of the Civil Rights Act of 1964 (42 11063 are c(
✓ ed Pursuant to this subpart, prior to U.S.C. 2000d et seq.), which provides 107.
disbursement Is not program income that no person in the United States (b) Sectio:
oand must be returned to the Treasury. shall on the grounds of race, color, or 109 of the A
However, the State shall not be held national origin, be excluded from par- in the Uni!
accountable for Interest earned on ticipation in, be denied the benefits of, ground of r
e grants for which payments are made or be subjected to discrimination or sex, be e>
a. in accordance with Paragraph (a), under any program or activity receiv-
�, 126
r^ �1
° a
4 au
t '
U
C�Ch. V (4-1-88 Edition) office of Asst. Secy. for Comm. Planning, Development, HUD §570.496
ing Federal financial assistance. Sec- in- be denied the benefits of, or be sub-
sbursement for program tion 602 of the Civil Rights Act of 1964 jected to discrimination under, any
directs each Federal department and program or activity funded in whole or
vironmental responsibilities, agency empowered to extend Federal in part with community development
financial assistance to any program or funds made available pursuant to the
shall assume such respon. activity by way of grant to effectuate Act. Section 109 further provides that
environmental review, de. the foregoing prohibition by issuing any prohibition against discrimination
g, and action (and shall re. rules, regulations, or orders of general on the basis of age under the Age Dis-
sumption of such responsi. applicability which shall be consistent crimination Act of 1975 (42 U.S.C. 6101
snits of general local gov. with achievement of the statute au- et seq.) or with respect to an otherwise
ceiving CDBG funds from thorizing the financial assistance. qualified handicapped individual as i
rider this subpart) as shall HUD regulations implementing the re- provided in section 504 of the Reha- i
f and required in regula. quirements of Title VI with respect to bilitation Act of 1973 (29 U.S.C. 794) 1
by the Secretary pursuant HUD programs are contained in 24 shall also apply to any such program
34(f)of the Act. CFR. Part 1. "Pub. L. 90-284" refers to or activity.
Title VIII of the Civil Rights Act of (c) Labor standards. Section 110 of
*gram requirements. 1968 (42 U.S.C. 3601 et seq.), popularly the Act requires that all laborers and
04(b) of the Act requires known as the Fair Housing Act, which mechanics employed by contractors or
tate certify, among other provides that it is the policy of the subcontractors on construction work
t the grant "will be con- United States to provide; within con- assisted under the Act shall be paid
administmistered in conformity ity stitutional limitations, for fair housing wages at rates not less than those pre-
L. and Pub. L. throughout the United States and pro- vailing on similar construction in the
hibits any person from discriminating locality as determined by the Secre-
further, that the grantee
t' with the other provisions in the sale or rental of housing, the fi• tary of Labor in accordance with the
and with other applicable nancing of housing,or the provision of Davis-Bacon Act. as amended (40
ion with o of the Act rle brokerage services, including in any U.S.C. 276a-276a-5). By reason of the
way making unavailable or denying a foregoing requirement, the Contract
the Secretary determine dwelling to any person, because
he State has carried out Its o[��ork Hours and Safety Standards Act
he
compliance with the race, color. religion, sex, or national (40 U.S.C. 327 et seq.) also applies.
this title and other origin. Title VIII further requires the However, these requirements apply to
It and whether the State Secretary to administer the programs the rehabilitation of residential prop.
s. 'reviews whether
and audits of and activities relating to housing and erty only if such property is designed
s. general local governmentsof urban development in a manner af- for residential use of eight or more
necessary to appropriate to firmatively to further the purposes of families.
Title VIII. In addition, Executive (d) Environmental standards. Sec-
Whether they have satisfied
able performance criteria" Order 11063, as amended by Executive tion 104(f) expresses the intent that
Order 12259, directs the Department "the policies of the National Environ-
cotporate, among other to take all action necessary and appro- mental Policy Act of 1969 and other
e requirements ' ' • of this priate to prevent discrimination be- provisions of law which further the
and other applicable laws" cause of may., color, religion (creed), purposes of such Act (as specified in
atutes are expressly made sex, or national origin, in the sale. regulations issued by the Secretary)
to activities assisted under leasing, rental, or other disposition of ' ' (be) most effectively implemented I,
the Act itself. while other ti residential property and related facili- in connection with the expenditure of
terred to in the Act may be ties(including land to be developed for funds under" the Act.Such other pro-
to such activities by their , residential use), or in the use or occu- visions of law which further the pur-
This section enumerates panty thereof,if such property and re- poses of the National Environmental 1.
k the Secretary will treat as lated facilities are. among other Policy Act of 1969 are specified in reg-
for purposes of the determi- things, provided in whole or in part ufations issued pursuant to section
be made by the Secretary with the aid of loans,advances, grants. 104(f) of the Act and contained In 24
on 104(dX2)of the Act. or contributions agreed to be made by CFR Part 58.(See 1570.495.)
L 88-352 and Pub. L. 80- the Federal Government.HUD regula- (e) Employment opportunities. Sec-
)+ 88-352" refers to Title VI tions implementing Executive Order tion 3 of the Housing and Urban De-
ril Rights Act of 1964 (42 11063 are contained in 24 CFR Part velopment Act of 1968 (12 U.S.C. i
Od et see.). which provides 107. 1701u) requires, in connection with
erson in the United States (b) Section 109 of the Act Section the planning and carrying out of any
to grounds of race, color, or 109 of the Act requires that t. person protect assisted under the Act, that to
Agin, be excluded from par In the United States shall on the the greatest extent feasible opportuni , f j
In,be denied the benefits of. ground of race, color, national origin ties for training and employment be ;
ibtected to discrimination or sex, be excluded from participation given to lower-income persons residing ;
program or activity recely-
12?
�i°
) y J��)M \n IPU'S00
AGENDA
r,R � Q®
ITEM
4. Contract Work Hours and Safety Standards Act (40 USC 327-333) regarding
overtime compensation.
5. Anti-Kickback Act of 1934 (18 USC 874) prohibiting "kickbacks" of wages in
federally assisted construction activities.
(m) It will comply with the Architectural Barriers Act of 1968 (42 USC 41511 and
implementing regulations (24 CFR Part 40•.41).
(n) It will enforce standards of conduct which govern the performance of its officers,
employees, and agents engaged in the administration of contracts funded in whole
or in part by the CDBG Program (Section 7120(d) of the State regulations).
(o) It will comply with the Hatch Act (5 USC 1501 Lt se .) regarding political activity
of employees.
(p) It will comply with the Lead-Based Paint Regulations (24 CFR Part 35) which
prohibits the use of lead-based paint on projects funded by the program.
(q) It will not employ, award contracts to, or otherwise engage the services of any
contractor while that contractor is in a. period of debarment, suspension, or
placement in ineligibility status under the provisions of 24 CFR Part 24.
(r) It will give HUD, the Comptroller General, the State Department of Housing and
Community
theirof authorized rhaccess tt,
tedto thegran
theht o examinall reords,ment, or bookspapersor documents rea
(s) It will not attempt to recover any capital costs of public improvements assisted in
whole or in part with CDBG funds by assessing properties owned and occupied
by targeted income persons unless: (A) CDBG funds are used to pay the
proportion of such assessment that relates to non-CDBG funding or; (B) for the
purposes of assessing properties owned and occupied by targeted income persons
who are not of the lowest Targeted Income Group, it does not have sufficient
CDBG funds to comply with the provisions of (A) above.
The certification is made under penalty of perjury under the laws of the State of
California.
CERTIFYING OFFICIAL: John Dunn City Administrative Officer
Print Name .
Date
signature Denotes action by Lead Person
5espond by:
Council
CAORECEIVED E
C'ry AV, b G 01�9U
Clerk-trig. i r
CITY CLERK
r-� PAN LU1S(1F1C0n CD
IY-4 2- 2 �_