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HomeMy WebLinkAboutResolutions - 2024.07.18 - 41362 AGENDA ITEM: 2024 Annual Action Plan and Consolidated Grant Application to the United States Department of Housing and Urban Development for the Office of Community Planning and Development Formula Programs Grant Funding DEPARTMENT: Health & Human Services - Neighborhood and Housing Development MEETING: Board of Commissioners DATE: Thursday, July 18, 2024 6:00 PM - Click to View Agenda ITEM SUMMARY SHEET COMMITTEE REPORT TO BOARD Resolution #2024-4248 Motion to approve the submission of the PY 2024 Annual Action Plan and consolidated application totaling $9,477,415 for activities designed to accomplish the goals and objectives for the Community Development Block Grant (CDBG) Program, HOME Investment Partnerships Act (HOME) Program and the Emergency Solutions Grants (ESG) Program. ITEM CATEGORY SPONSORED BY Grant Penny Luebs INTRODUCTION AND BACKGROUND The Neighborhood and Housing Development plans to submit a Program Year (PY) 2024 Annual Action Plan to the United States Department of Housing and Urban Development (HUD). The PY 2024 Annual Action Plan contains a consolidated Federal grant application in the amount of $9,477,415 for activities designed to accomplish the goals and objectives of the Community Development Block Grant (CDBG) Program, HOME Investment Partnerships Act (HOME) Program and the Emergency Solutions Grants (ESG) Program. The Neighborhood and Housing Development received notification, by letter dated May 18, 2024, of the PY 2024 consolidated allocation of $6,261,266 which includes funding in the amount of $3,645,249 for CDBG, $2,293,996 for HOME and $322,021 for ESG, for the program year period of July 1, 2024 through June 30, 2025. HUD requires Oakland County to estimate CDBG Home Improvement Program (HIP) Revolving Loan Fund (RLF) and HOME Program Income (PI) at the time of each Annual Action Plan application and reconciliation of actual RLF and PI at the end of each program year and at grant acceptance. The PY 2024 Annual Action Plan estimates CDBG Home Improvement Program Revolving Loan Fund at $1,000,000 and HOME Investment Partnerships Act Grant Program Income at $1,700,000. The total program revenue for the PY 2024 CDBG Program is $4,645,249, which includes the grant allocation amount of $3,645,249 and estimated CDBG Revolving Loan Funds of $1,000,000, with no County match required. The total program revenue for the PY 2024 HOME Program is $4,510,145, which includes a grant allocation amount of $2,293,996, a grant match of $516,149, and an estimated HOME Program Income of $1,700,000. The HOME program requires a 25% match for all housing activities which is appropriated in the General Fund. The ESG grant requires a 100% match for volunteer services, donations or cash contributions, which are met by the ESG service agencies with no County funds required. The application includes funding to continue twenty-four (24) Special Revenue positions as identified in Schedule B. The PY 2024 Annual Action Plan was unanimously endorsed by the Citizen Advisory Council. At the time of the grant award, HUD requires Oakland County to have annual Agreements with each Subrecipient with the purpose and intent of passing those responsibilities to each Subrecipient to carry out the project(s) described in the CDBG application. POLICY ANALYSIS Application of this grant does not obligate the county to any future commitment and continuation of this program is contingent upon continued future levels of grant funding. BUDGET AMENDMENT REQUIRED: No Committee members can contact Michael Andrews, Policy and Fiscal Analysis Supervisor at 248.425.5572 or andrewsmb@oakgov.com or the department contact persons listed for additional information. CONTACT Khadija Walker-Fobbs, Neighborhood & Housing Development Officer ITEM REVIEW TRACKING Aaron Snover, Board of Commissioners Created/Initiated - 7/19/2024 AGENDA DEADLINE: 07/18/2024 6:00 PM ATTACHMENTS 1. Grant Application Sign-Off 2. FY24 CPD Formula Letter - Oakland County, MI (2) 3. Postion Schedule B 6-13-2024 (2) 4. PY 2024 AAP 061724 (2) 5. PY 2024 SF424s and Certifications for Signature (3) COMMITTEE TRACKING 2024-07-09 Public Health & Safety - Recommend to Board 2024-07-18 Full Board - Adopt Motioned by: Commissioner Christine Long Seconded by: Commissioner Ann Erickson Gault Yes: David Woodward, Michael Spisz, Michael Gingell, Penny Luebs, Karen Joliat, Kristen Nelson, Christine Long, Robert Hoffman, Philip Weipert, Gwen Markham, Angela Powell, Marcia Gershenson, William Miller III, Yolanda Smith Charles, Charles Cavell, Brendan Johnson, Ajay Raman, Ann Erickson Gault, Linnie Taylor (19) No: None (0) Abstain: None (0) Absent: (0) Passed GRANT REVIEW SIGN-OFF – Neighborhood Housing Development GRANT NAME: 2024 Consolidated Plan Grant Application for Community Development Block Grant (CDBG) APP00166, HOME Investment Partnership Grant (HOME)APP00167 and Emergency Solutions Grant (ESG) APP00168 FUNDING AGENCY: U.S. Department of Housing and Urban Development (HUD) DEPARTMENT CONTACT PERSON: Stacey Sledge 248-452-2151 STATUS: Grant Application (Greater than $50,000) DATE: 07/02/2024 Please be advised that the captioned grant materials have completed the internal grant review. Below are the returned comments. The Board of Commissioners’ liaison committee resolution and grant application package (which should include this sign- off and the grant application with related documentation) should be downloaded into Civic Clerk to be placed on the next agenda(s) of the appropriate Board of Commissioners’ committee(s) for grant acceptance by Board resolution. DEPARTMENT REVIEW Management and Budget: Approved. – Sheryl Johnson (07/02/2024) Human Resources: Approved by Human Resources. Continues funding for 23 FTE and 1 PTNE position with no changes. HR action not needed. – Heather Mason (06/27/2024) Risk Management: Approved. No County insurance requirements identified. – Robert Erlenbeck (07/01/2024) Corporation Counsel: Approved. I see no legal issues with the application. – Bradley Benn (07/02/2024) U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT WASHINGTON, DC 20410-7000 PRINCIPAL DEPUTY ASSISTANT SECRETARY FOR COMMUNITY PLANNING AND DEVELOPMENT www.hud.gov espanol.hud.gov May 18, 2024 Mr. David Coulter County Executive of Oakland County 2100 Pontiac Lake Road Building 41W Waterford, MI 48328-0409 Dear Mr. Coulter: Congratulations! I am pleased to give you formal notice of your jurisdiction’s Fiscal Year 2024 (FY24) allocations for the Office of Community Planning and Development’s (CPD) formula programs. Your jurisdiction’s FY24 available amounts are as follows: Community Development Block Grant (CDBG) Emergency Solutions Grant (ESG) HOME Investment Partnerships (HOME) $3,645,249.00 $322,021.00 $2,293,996.19 These grant funds provide the financial tools to support low-to-moderate income individuals, families, and communities to address homelessness, affordable housing challenges, aging infrastructure, and economic hardships. CPD is committed to being your partner throughout the process of using these funds. Our local office will assist in finalizing grant agreements, offer technical assistance, training when needed, monitor and implement grant funds for eligible projects in a timely manner. The Department of Housing and Urban Development will work with your team to ensure proper reporting in the Integrated Disbursement and Information System to improve performance data on how these programs are benefitting and touching people’s lives, build trust with stakeholder groups, Congress, and amplify the success stories that you and your jurisdiction are able to accomplish with these vital resources. In addition, you also have $18,226,245 in available Section 108 borrowing authority based on your CDBG allocation and outstanding Section 108 balances as of May 14, 2024. Since Section 108 loans are federally guaranteed, this allows your jurisdiction to borrow up to five times of your current CDBG allocation to access loan capital for larger projects at a low interest rate. HUD encourages you to consider using this CDBG multiplier for high priority housing projects, such as housing rehabilitation and conversion of nonresidential properties to residential uses and mixed-use development. This could help fill gaps left by Congress’ cut to the HOME program for FY24. As you begin to plan for the use of FY24 grant funding, please also consider having strategic conversations with your local team to ensure that existing grants are being maximized to meet your local priorities and community needs. A few questions that you might consider asking: 2 www.hud.gov espanol.hud.gov • What were our goals in our most recent Consolidated Plan? How did our commitments in FY23 and previous Action Plans support those goals? • Do we have any expiring funds? Are there plans to use our funding from past years before the end of the period of performance? • What, if any, findings have HUD / the Office of Inspector General made against our jurisdiction in the last five years? What have we done to address those findings? The combination of higher mortgage interest rates, limited for-sale housing inventory, and high home prices has created a challenging environment for homebuyers – particularly low- income families seeking to purchase their first home. In preparing the annual action plan for your jurisdiction’s CPD formula funds, we urge you to consider how your HOME Program and other funds may be used to increase the supply of modestly priced housing or provide direct purchase assistance to low-income families seeking to buy a home. The timely expenditure of your previous year funds is critical to mitigate risks of recapture. If your community’s priorities have changed, you have an opportunity to repurpose funding. Our team can work with you to ensure that funds are fully utilized and reach the populations intended by these programs. Please contact our Field Office to learn more. The Department greatly appreciates your leadership in using these funds to address your most pressing local needs by increasing access to affordable housing, supporting renters and homeowners, providing life-saving assistance to people experiencing homelessness, creating jobs and opportunities for people with modest means, improving public facilities, community resilience, and public services. If you or any member of your staff have questions or would like to request technical assistance, please contact your local CPD Field Director. Sincerely, Marion Mollegen McFadden Principal Deputy Assistant Secretary for Community Planning and Development Special Revenue Grant Schedule B - Continuations Cost Center # Pos. #Budgeted Class CCN1060702 P00000730 Neighborhood & Housing Development Specialist Senior CCN1060704 P00000999 Supervisor Neighborhood & Housing Development CCN1060704 P00001279 Neighborhood & Housing Development Coordinator CCN1060701 P00001370 Grant Compliance & Program Coordinator CCN1060701 P00001371 Supervisor NHD Administrative Services CCN1060704 P00001457 Neighborhood & Housing Development Field Technician CCN1060704 P00001768 Neighborhood & Housing Development Technician CCN1060704 P00002426 Neighborhood & Housing Development Field Technician Senior CCN1020615 P00002489 Fiscal Services Accountant III CCN1060701 P00003182 Supervisor Neighborhood & Housing Development CCN1060704 P00003230 Neighborhood & Housing Development Technician CCN1060701 P00003231 Neighborhood & Housing Development Coordinator CCN1060702 P00003354 Housing Counseling Supervisor CCN1060704 P00003430 Neighborhood & Housing Development Coordinator CCN1060701 P00003567 Neighborhood & Housing Development Specialist Senior CCN1060701 P00005341 Student CCN1060704 P00005413 Neighborhood & Housing Development Assistant CCN1060704 P00006098 Neighborhood & Housing Development Coordinator CCN1060704 P00009522 Neighborhood & Housing Development Field Technician Senior CCN1060704 P00009578 Neighborhood & Housing Development Field Technician CCN1060702 P00010806 Neighborhood & Housing Development Specialist Senior CCN1060701 P00014810 Chief Neighborhood & Housing Development CCN1060701 P00014811 Neighborhood & Housing Development Coommunity Liaison CCN1060701 P00015987 Neighborhood & Housing Development Officer FT/PT Hours Filled As FTE 2080 Neighborhood & Housing Development Specialist Senior FTE 2080 Supervisor Neighborhood & Housing Development FTE 2080 Neighborhood & Housing Development Coordinator FTE 2080 Grant Compliance & Program Coordinator FTE 2080 Supervisor NHD Administrative Services FTE 2080 Neighborhood & Housing Development Field Technician FTE 2080 Neighborhood & Housing Development Technician FTE 2080 Neighborhood & Housing Development Field Technician Senior FTE 2080 Fiscal Services Accountant III FTE 2080 Supervisor Neighborhood & Housing Development FTE 2080 Neighborhood & Housing Development Technician FTE 2080 Neighborhood & Housing Development Coordinator FTE 2080 Housing Counseling Supervisor FTE 2080 Neighborhood & Housing Development Coordinator FTE 2080 Neighborhood & Housing Development Specialist Senior PTNE 1250 Student FTE 2080 Neighborhood & Housing Development Assistant FTE 2080 Neighborhood & Housing Development Coordinator FTE 2080 Neighborhood & Housing Development Field Technician Senior FTE 2080 Neighborhood & Housing Development Field Technician FTE 2080 Neighborhood & Housing Development Specialist Senior FTE 2080 Chief Neighborhood & Housing Development FTE 2080 Neighborhood & Housing Development Coommunity Liaison FTE 2080 Neighborhood & Housing Development Officer Special Revenue Grant Schedule B - Continuations Grant Emergency Solutions Grant CDBG and HOME CDBG and HOME Community Development Block Grant CDBG and HOME CDBG and HOME CDBG and HOME CDBG and HOME CDBG/Management and Budget Community Development Block Grant CDBG and HOME CDBG and HOME Emergency Solutions Grant CDBG and HOME Community Development Block Grant Community Development Block Grant Community Development Block Grant Community Development Block Grant CDBG and HOME Community Development Block Grant Emergency Solutions Grant Community Development Block Grant Community Development Block Grant Community Development Block Grant Special Revenue Grant Schedule B - Continuations Annual Action Plan 2024 1 OMB Control No: 2506-0117 (exp. 09/30/2021) Annual Action Plan 2024 2 OMB Control No: 2506-0117 (exp. 09/30/2021) Executive Summary AP-05 Executive Summary - 91.200(c), 91.220(b) 1. Introduction The Oakland County PY 2024 Annual Action Plan is submitted pursuant to U.S. Department of Housing and Urban Development (HUD) Code of Federal Regulations (CFR) (24 Part 91, 2/9/06) as a single submission covering the planning and application aspects of HUD’s Community Development Block Grant (CDBG), HOME Investment Partnership Act (HOME) and Emergency Solutions Grant (ESG) formula programs. The purpose of the PY 2024 Annual Action Plan is to describe activities to be undertaken with HUD programs by Oakland County for the period of July 1, 2024 - June 30, 2025. 2. Summarize the objectives and outcomes identified in the Plan This could be a restatement of items or a table listed elsewhere in the plan or a reference to another location. It may also contain any essential items from the housing and homeless needs assessment, the housing market analysis or the strategic plan. Oakland County developed the following mission statement and goals based on data analysis conducted and information collected through citizen participation and consultation efforts: Oakland County Mission: Promote equitable and inclusive communities through: 1. Quality Affordable Housing: Develop and preserve affordable options, increasing housing choice and opportunity. 2. Community Investment: Invest in public services and infrastructure to improve quality of life for vulnerable populations. 3. Fair Housing: Reduce discrimination and promote diverse, inclusive communities. 4. Engagement: Collaborate with residents to deepen community involvement. Annual Action Plan 2024 3 OMB Control No: 2506-0117 (exp. 09/30/2021) 3. Evaluation of past performance This is an evaluation of past performance that helped lead the grantee to choose its goals or projects. The demand for programs funded by CDBG, HOME and ESG remains greater than funds available. A recap of performance from the County’s PY 2022 Consolidated Annual Performance and Evaluation Report (CAPER) includes the following accomplishments. Accomplishments: • Affordable Housing: Rehabilitated 129 low-income homes ($2.8 million) and Participating Communities provided minor repair grants ($545,994). Additionally, $1,000,000 of HOME Partnership Funds have been committed to Shepherd House, a 53- unity affordable rental community for seniors. • Community Investment: Invested in code enforcement ($147,133), sidewalks ($227,493), public facilities improvements ($726,917) (i.e. parks and recreational facilities, fire stations and senior centers), and public services ($684,506) (i.e. domestic violence, senior services, transportation, childcare, youth services). ESG shelters served 1,583 homeless individuals ($102,655 for operations, $16,399 for HMIS). Provided rental assistance and relocation services ($11,130). • Fair Housing: Provided fair housing education and counseling ($16,646), assisting 134 households and referring 2,429 more by phone. Promoted fair housing choice and anti- poverty programs. • Community Engagement: Endeavoring to strengthen community ties, the department collaborates with partners and participates in local initiatives. This included attending board meetings, task forces, and participating resource fairs. Updates to the Division website and resources to improve online accessibility. 4. Summary of Citizen Participation Process and consultation process Summary from citizen participation section of plan. Opportunities for input were provided throughout the year. Presentations were made to the Oakland County BOC, Oakland County Citizens Advisory Council (CAC), public hearings, HOME Consortium meetings, online survey and direct solicitation/outreach. Annual Action Plan 2024 4 OMB Control No: 2506-0117 (exp. 09/30/2021) Each participating community (PC) that applies for CDBG funds from Oakland County is required to hold a public hearing to receive input on how funds should be allocated within their jurisdiction. Information on local public hearings is submitted to the OCNHD as part of each annual CDBG application. The PY2024 application was due December 1, 2023. On April 23, 2024, the Citizen’s Advisory Council held a public hearing at 4:00 p.m. to hear public comments on the OCNHD PY2024 Draft Annual Action Plan. A second public hearing will be held on June 25, 2024. County level public hearings are advertised in The Oakland Press, a newspaper of general local circulation, as well as listed on the home page of OCNHD. On April 22, 2023, the (PY) 2023 Draft Annual Action Plan (AAP) was made available for a 30-day comment period. On June 17, 2024, the Final Annual Action Plan (AAP) was made available for the 15-day Comment Period. 5. Summary of public comments This could be a brief narrative summary or reference an attached document from the Citizen Participation section of the Con Plan. A full summary of Public Comments will be available at the conclusion of the 15-Day comment period, July 1, 2024. 6. Summary of comments or views not accepted and the reasons for not accepting them Comments and views are accepted on an ongoing basis. 7. Summary The PY 2024 Annual Action Plan reflects a coordinated effort to determine how federal and leveraged funds will be expended to address Oakland County’s community and housing priorities/needs for the PY 2024 Annual Action Plan period of July 1, 2024 - June 30, 2025. Annual Action Plan 2024 5 OMB Control No: 2506-0117 (exp. 09/30/2021) PR-05 Lead & Responsible Agencies - 91.200(b) 1. Agency/entity responsible for preparing/administering the Consolidated Plan The following are the agencies/entities responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source. Agency Role Name Department/Agency CDBG Administrator OAKLAND COUNTY HHS/Neighborhood & Housing Development Division HOME Administrator OAKLAND COUNTY HHS/Neighborhood & Housing Development Division ESG Administrator OAKLAND COUNTY HHS/Neighborhood & Housing Development Division Table 1 – Responsible Agencies Narrative The Oakland County Board of Commissioners (BOC) designated the Department of Health and Human Services Oakland County Neighborhood & Housing Development Division as the lead agency responsible for administering its CDBG, HOME and ESG programs including the development of the Con Plan, Annual Action Plan and the Consolidated Annual Performance and Evaluation Report. The Division serves as the lead agency for administration of the CDBG and ESG programs on behalf of 52 participating communities including: the Cities of Auburn Hills, Berkley, Birmingham, Bloomfield Hills, Clarkston, Clawson, Farmington, Ferndale, Hazel Park, Huntington Woods, Keego Harbor, Lathrup Village, Madison Heights, Northville, Novi, Oak Park, Orchard Lake Village, Pleasant Ridge, Rochester, Rochester Hills, South Lyon, Sylvan Lake, Troy, Walled Lake, Wixom, the Townships of Addison, Bloomfield, Brandon, Commerce, Groveland, Highland, Holly, Independence, Lyon, Milford, Oakland, Orion, Oxford, Rose, Royal Oak, Springfield, West Bloomfield, White Lake and the Villages of Beverly Hills, Franklin, Holly, Lake Orion, Leonard, Milford, Ortonville, Oxford and Wolverine Lake. The Neighborhood & Housing Development Division has a long and successful history in federal program administration. The Division works with various partners and has the capacity to serve as the lead agency for the Oakland County HOME Consortium. Annual Action Plan 2024 6 OMB Control No: 2506-0117 (exp. 09/30/2021) The Consortium member communities include Oakland County, Farmington Hills, Pontiac, Royal Oak, and Southfield. All the municipalities are eligible to receive and administer HUD funds and have established housing and community development programs. All members work in concert and with partners to extend program efficiency, scope and reach. Partnerships include housing developers, public housing commissions, service providers, homeless advocates and for profit and non-profit institutions. Consolidated Plan Public Contact Information Written comments are being accepted by mail and email to the attention of: Khadija Walker-Fobbs, Officer Oakland County Neighborhood & Housing Development Division 1200 N. Telegraph Rd, 34E, Pontiac MI 48341 or electronically via: nhd@oakgov.com Annual Action Plan 2024 7 OMB Control No: 2506-0117 (exp. 09/30/2021) AP-10 Consultation - 91.100, 91.200(b), 91.215(l) 1. Introduction The Division, as lead agency of the Oakland County HOME Consortium, consulted with other government, non-profit and private agencies, including the Alliance for Housing (Alliance), Oakland County's Continuum of Care (CoC) to develop the PY 2024 Annual Action Plan. Consultation included presentations to the Oakland County Board of Commissioners (BOC), Oakland County Citizen Advisory Council (CAC), the Oakland County Food Policy Council, public hearings, HOME Consortium team meetings, an online survey and direct solicitation/outreach. Provide a concise summary of the jurisdiction’s activities to enhance coordination between public and assisted housing providers and private and governmental health, mental health and service agencies (91.215(l)). Private and governmental health, mental health and service agencies participate in the CoC. The Alliance (CoC) board meets bi-monthly, and the full membership meets every other month. OCNHD staff collaborate with the Oakland Community Health Network (OCHN) through the Alliance (CoC) to serve the needs of low income and disabled residents. OCNHD staff provide those involved in the CoC with information, education and referral upon request. To increase awareness of OCNHD, staff participated in various public events sponsored by agencies including Oakland County Health Division, MSHDA, Head Start, Senior Centers, Oakland County Veterans Department, FDIC - Smart Money Week. OCNHD staff participates in annual Community Resource Day events to support those that are precariously housed. The OCNHD division works with the Homeless Healthcare Collaboration (HHC) whose mission is to improve the health and well-being of persons experiencing homelessness in Oakland County. HHC’s mission is to connect community and health care organizations to coordinate resources for persons experiencing homelessness. HHC works closely with the CoC. Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans, and unaccompanied youth) and persons at risk of homelessness. Private and governmental health, mental health, and service agencies participate in the CoC, meeting regularly throughout the year. HOME Consortium members often attend these events, maintaining constant contact, especially during shared project planning and implementation phases. In 2023, OCNHD leadership along with the CoC brought together over 50 stakeholders representing various systems that touch individuals and families impacted by homelessness. Annual Action Plan 2024 8 OMB Control No: 2506-0117 (exp. 09/30/2021) The new initiative is based on work facilitated in 2021 by MPHI and agency partners, to put together a Blueprint to End Homelessness. The Blueprint to End Homelessness work is a collaboration of partners focused on action-oriented steps to address the needs of homeless individuals and families. In 2012, the Oakland County Health Division gathered community partners serving homeless and vulnerable populations to discuss barriers to obtaining/providing services and develop plans to address clients’ needs. This group, known as the Homeless Healthcare Collaboration, prioritized housing and healthcare issues, identifying basic needs like identification and transportation as significant barriers to accessing essential services such as healthcare, housing, employment, and education. These concerns persist today, with over 100 representatives from various service providers participating in ongoing meetings. The Homeless Healthcare Collaboration created two action taskforces: the Hospital Discharge Taskforce, now paused, and the Identification Taskforce, which continues to work on breaking barriers related to lack of proper identification. Additionally, the Transportation Taskforce focuses on enhancing public transportation and seeking alternative solutions. An infographic highlighting transportation needs was created, after which the taskforce's work was integrated into broader coordination efforts within the Collaboration. The Homeless Healthcare Collaborative aims to improve the health and well-being of homeless individuals in Oakland County by connecting community and healthcare organizations to coordinate resources. In 2014, the National Association of County and City Health Officials (NACCHO) recognized the Collaboration as a Model Practice for its exemplary and replicable response to a local public health need. The Alliance for Housing, a 501(c)(3) non-profit organization formerly known as the Oakland County Taskforce on Homelessness and Affordable Housing, is responsible for coordinating the CoC and organizing the County’s response to HUD's annual CoC application. The Alliance works to end homelessness and increase affordable housing opportunities, comprising about 100 organizations including emergency shelters, health service providers, for-profit and nonprofit affordable housing developers, supportive housing program administrators, municipalities, governmental agencies, and faith-based service providers. The Alliance holds general membership meetings with published agendas at least quarterly, while its board of directors meets at least bi-monthly. The Executive Committee determines the date, time, and place of these meetings, which are open to the public. An annual meeting of the Board of Directors and its membership is also held, with all meetings conducted either in-person or virtually. Describe consultation with the Continuum(s) of Care that serves the jurisdiction’s area in determining how to allocate ESG funds, develop performance standards for and evaluate Annual Action Plan 2024 9 OMB Control No: 2506-0117 (exp. 09/30/2021) outcomes of projects and activities assisted by ESG funds, and develop funding, policies and procedures for the operation and administration of HMIS Oakland County consults with the Alliance for Housing, Oakland County's Continuum of Care lead agency, when determining how to allocate its ESG funds. This is done via survey and request for input when considering changes. The ESG guidelines and contracts require that recipients of funding must: • Be members of the Alliance (although membership is not necessary to apply) • Participate in the Homeless Management Information System unless barred from under the Violence Against Women Act • Participate in the coordinated entry system, and • Follow the performance measurement and outcomes standards. All agencies currently receiving ESG funding also receive funding through the Alliance through a MSHDA grant. Adopting similar strategies and processes assist the agencies in administering the programs seamlessly for their clients. The Alliance has three standing committees: Systems Coordination and Implementation - Develops resources to implement community strategies, provides member agencies with access to technical assistance, best practices, referrals, and other tools to increase their effectiveness in addressing community needs. Strategic Planning, Funding, and Advocacy Committee - Inform the community of issues regarding housing and homelessness, provides platform for advocacy and public awareness of current political and legislative issues, promotes the Alliance for Housing as a resource for the effective engagement of public and political entities, Writes and oversees planning and funding opportunities. Project Monitoring and Performance Outcomes - Promotes quality funded projects by evaluating project proposals, making funding recommendations and monitoring progress and implements/monitors the Homeless Management and Information System (HMIS). An Application Review Committee made up of representatives not funded through the CoC but with relevant expertise rank projects for the annual HUD application. The Alliance determines how to allocate CoC funds by developing performance standards, evaluating outcomes, and developing funding priorities. The Alliance also provides ongoing needs assessment and analysis; technical assistance; increased stakeholder participation; development strategies for addressing identified needs; monitoring of progress toward strategic objectives and action Annual Action Plan 2024 10 OMB Control No: 2506-0117 (exp. 09/30/2021) steps; coordination of various organizational structures related to homelessness and coordination of the annual CoC NOFA application. The CoC is a planning process which gives providers an opportunity to design effective approaches to address the needs of homeless persons. CoC participants consult in the Con Plan process by identifying gaps and priorities within the housing continuum. Homelessness prevention is a goal in the CoC’s Plan to End Homelessness. Strategies in place to reach the CoC’s homelessness prevention goal include creating relationships with landlords so intervention can occur before eviction, ensuring all CoC agencies have eviction prevention strategies, creating an online resource guide of financial assistance programs for case managers and spreading outreach information through faith based and educational institutions. These efforts and using a centralized intake and housing assessment tool assure that funds are distributed to those most in need, consistent with the County’s anti-poverty strategy. 2. Agencies, groups, organizations and others who participated in the process and consultations Annual Action Plan 2024 11 OMB Control No: 2506-0117 (exp. 09/30/2021) Table 2 – Agencies, groups, organizations who participated 1 Agency/Group/Organization Community Housing Network, Inc Agency/Group/Organization Type Services - Housing Services-Persons with Disabilities Services-homeless Service-Fair Housing What section of the Plan was addressed by Consultation? Housing Need Assessment Public Housing Needs Homeless Needs - Chronically homeless Homeless Needs - Families with children Homelessness Needs - Veterans Homelessness Needs - Unaccompanied youth Homelessness Strategy Non-Homeless Special Needs Market Analysis Economic Development Anti-poverty Strategy Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Formal and informal consultation occurred with various agency/group/organization types during the development of the Annual Action Plan. This included the previously mentioned Community Needs Survey. Valuable insights were obtained and incorporated into the Annual Action Plan. 2 Agency/Group/Organization Alliance for Housing Oakland County Continuum of Care Agency/Group/Organization Type Housing Services - Housing Service-Fair Housing Annual Action Plan 2024 12 OMB Control No: 2506-0117 (exp. 09/30/2021) What section of the Plan was addressed by Consultation? Housing Need Assessment Public Housing Needs Homeless Needs - Chronically homeless Homeless Needs - Families with children Homelessness Needs - Veterans Homelessness Needs - Unaccompanied youth Homelessness Strategy Market Analysis Economic Development Anti-poverty Strategy Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Formal and informal consultation occurred with various agency/group/organization types during the development of the Annual Action Plan. This included the previously mentioned Community Needs Survey. Valuable insights were obtained and incorporated into the Annual Action Plan. 3 Agency/Group/Organization HAVEN Agency/Group/Organization Type Housing Services - Housing Services-Children Services-Victims of Domestic Violence Services-homeless Annual Action Plan 2024 13 OMB Control No: 2506-0117 (exp. 09/30/2021) What section of the Plan was addressed by Consultation? Housing Need Assessment Public Housing Needs Homeless Needs - Chronically homeless Homeless Needs - Families with children Homelessness Needs - Veterans Homelessness Needs - Unaccompanied youth Homelessness Strategy Non-Homeless Special Needs Market Analysis Economic Development Anti-poverty Strategy Lead-based Paint Strategy Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Formal and informal consultation occurred with various agency/group/organization types during the development of the Annual Action Plan. This included the previously mentioned Community Needs Survey. Valuable insights were obtained and incorporated into the Annual Action Plan. 4 Agency/Group/Organization HOPE Agency/Group/Organization Type Housing Services - Housing Services-homeless Services-Health Annual Action Plan 2024 14 OMB Control No: 2506-0117 (exp. 09/30/2021) What section of the Plan was addressed by Consultation? Housing Need Assessment Homeless Needs - Chronically homeless Homeless Needs - Families with children Homelessness Needs - Veterans Homelessness Needs - Unaccompanied youth Homelessness Strategy Non-Homeless Special Needs Market Analysis Economic Development Anti-poverty Strategy Briefly describe how the Agency/Group/Organization was consulted. What are the anticipated outcomes of the consultation or areas for improved coordination? Formal and informal consultation occurred with various agency/group/organization types during the development of the Annual Action Plan. This included the previously mentioned Community Needs Survey. Valuable insights were obtained and incorporated into the Annual Action Plan. Identify any Agency Types not consulted and provide rationale for not consulting No agencies were intentionally excluded. Other local/regional/state/federal planning efforts considered when preparing the Plan Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? Continuum of Care Alliance for Housing Both plans have in common the goal to end homelessness in Oakland County. Blueprint to End Homeless Initiative Oakland County Neighborhood & Housing Development Division Neighborhood & Housing Development is the lead agency coordinating the effort on this initiative that started in 2023, after the development of the Blueprint to End Homelessness plan in 2021. Both the Blueprint and the Strategic Plan have the common goal of ending homelessness in Oakland County and are in progress with ongoing efforts. Annual Action Plan 2024 15 OMB Control No: 2506-0117 (exp. 09/30/2021) Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan? Analysis of Impediment to Fair Housing Oakland County Neighborhood & Housing Development Division All of the plans have the in common the goal to reduce and/or eliminate barriers that prevent methods to affirmatively further fair housing and are ongoing efforts. Table 3 – Other local / regional / federal planning efforts Narrative A wide variety of agency types involved in housing, community development and public service programs throughout Oakland County were encouraged and invited to participate in the consultation process. No agencies were intentionally excluded. Annual Action Plan 2024 16 OMB Control No: 2506-0117 (exp. 09/30/2021) AP-12 Participation - 91.401, 91.105, 91.200(c) 1. Summary of citizen participation process/Efforts made to broaden citizen participation Summarize citizen participation process and how it impacted goal-setting The OCNHD is required to set forth the County’s policies and procedures for citizen participation in the process of developing and implementing the Con Plan and all its components. In accordance with 24 CFR Part 91.105 et seq, Oakland County maintains a Citizen Participation Plan (CPP). The Plan applies to the CDBG, HOME and ESG programs as well as to the development and implementation of the Con Plan and AAP. The CPP outlines the procedures and processes used by the County to solicit citizen input. The County followed the CPP outreach, noticing, and hearing requirements in development of the Con Plan. Oakland County encourages residents to participate in the Con Plan and AAP process. In addition, input is requested on the CAPER, environmental reviews, requests for release of funds and plan amendments. Oakland County maximizes citizen participation through its Citizen Advisory Council (CAC). The Housing and Community Development Act of 1974 requires that cooperating cities, townships, and villages, in addition to citizens at large, provide input on community development needs. Oakland County’s BOC Resolution #7835 established a CAC with the goal to provide a mechanism for citizens representing broad socio-economic and geographic areas to voice concerns on the planning, implementation and assessment of the "Urban County" program. The CAC consists of twenty members appointed by the BOC who are representatives of participating communities, County Commissioners and the general public. The members selected represent Oakland County’s LI population. The CAC serves in an advisory capacity to Division staff and the BOC to develop and assess federal grant program policies and operations. Despite selection from various geographic regions, all members represent the County. Oakland County encourages participation in the formulation of priorities, strategies and funding allocations related to the Con Plan. To broaden citizen participation, the County’s PY 2024 Annual Action Plan process included: • Advertised citizen participation opportunities in print media, website, online social media, and via email through listservs and individual emails • Made Community Needs Survey available from 01/09/2024 to 6/7/2024 online or in print and available in several languages • Emailed Community Needs Survey link and language to CAC members Annual Action Plan 2024 17 OMB Control No: 2506-0117 (exp. 09/30/2021) • Used the Department of Public Communications to push the survey via social media channels and listservs • Newspaper ads for public hearings • Encouraged participation with events/meetings Citizen Participation Outreach Sort Or der Mode of Out reach Target of Out reach Summary of response/atte ndance Summary of comments re ceived Summary of co mments not accepted and reasons URL (If applica ble) 1 Public Hearing Non- targeted/bro ad community No comments received. Oakland County accepts all comments if they are offered. 2 Public Hearing Non- targeted/bro ad community No comments received Oakland County accepts all comments if they are offered. 3 Newspaper Ad Non- targeted/bro ad community Public notices were published in the paper of record, the Oakland Press, on April 11, 2024 and June 9, 2024. N/A N/A 4 Internet Outreach Non- targeted/bro ad community Public notices were published online via the Oakland Press, on April 11, 2024 and June 9, 2024. N/A N/A Annual Action Plan 2024 18 OMB Control No: 2506-0117 (exp. 09/30/2021) Sort Or der Mode of Out reach Target of Out reach Summary of response/atte ndance Summary of comments re ceived Summary of co mments not accepted and reasons URL (If applica ble) 5 Internet Outreach Non- targeted/bro ad community On April 11, 2024 posted a notice of 30- day public comment period on the Oakland County Neighborhood & Housing Development Division main website landing page - No responses. On June 9, 2024 the Notice of 15- day public comment period on the Oakland County Neighborhood & Housing Development Division main website landing page. N/A N/A Table 4 – Citizen Participation Outreach Annual Action Plan 2024 19 OMB Control No: 2506-0117 (exp. 09/30/2021) Expected Resources Annual Action Plan 2024 20 OMB Control No: 2506-0117 (exp. 09/30/2021) AP-15 Expected Resources - 91.420(b), 91.220(c)(1,2) Introduction The mission of the OCNHD is to support equitable and inclusive communities through: • Preserving and/or developing quality affordable housing • Supporting capital improvements and public service programs to meet the needs of the communities • Reducing housing discrimination • Community engagement In PY 2024, the OCNHD will use CDBG, HOME and ESG funds, as well as recycled paybacks, Program Income, County match, competitive Comprehensive Housing Counseling Grant, SLFRF-ARPA funds, and state housing counseling grants to further the goals and objectives of the PY 2021-2025 Consolidated Plan. Anticipated Resources Program Source of Funds Uses of Funds Expected Amount Available Year 1 Expected Amount Available Remainder of ConPlan $ Narrative Description Annual Allocation: $ Program Income: $ Prior Year Resources: $ Total: $ Annual Action Plan 2024 21 OMB Control No: 2506-0117 (exp. 09/30/2021) Program Source of Funds Uses of Funds Expected Amount Available Year 1 Expected Amount Available Remainder of ConPlan $ Narrative Description Annual Allocation: $ Program Income: $ Prior Year Resources: $ Total: $ CDBG public - federal Acquisition Admin and Planning Economic Development Housing Public Improvements Public Services 3,645,249 1,000,000 0 4,645,249 0 Public facilities, neighborhood and housing improvements and public services benefitting low-income persons throughout Oakland County Urban County participating communities. HOME public - federal Acquisition Homebuyer assistance Homeowner rehab Multifamily rental new construction Multifamily rental rehab New construction for ownership TBRA 2,293,996 1,700,000 0 3,993,996 0 Acquisition, rehabilitation, new construction of affordable housing including rental development and homebuyer throughout Oakland County HOME Consortium participating communities. Note: PY2024 HOME Match = $516,419 Annual Action Plan 2024 22 OMB Control No: 2506-0117 (exp. 09/30/2021) Program Source of Funds Uses of Funds Expected Amount Available Year 1 Expected Amount Available Remainder of ConPlan $ Narrative Description Annual Allocation: $ Program Income: $ Prior Year Resources: $ Total: $ ESG public - federal Conversion and rehab for transitional housing Financial Assistance Overnight shelter Rapid re-housing (rental assistance) Rental Assistance Services Transitional housing 322,021 0 0 322,021 0 Emergency Shelter, Homeless Prevention and Rapid Re-Housing, HMIS and Administration throughout Oakland County Urban County participating communities. Table 2 - Expected Resources – Priority Table Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied CDBG - No Match Requirement • In-kind County level administrative functions: human resources, marketing, fiscal services, purchasing, auditing, corporation counsel, record retention and mail room support services • Infrastructure and public facility projects supported with funds from participating communities Annual Action Plan 2024 23 OMB Control No: 2506-0117 (exp. 09/30/2021) • Revolving Loan Fund (RLF) generated from paybacks on CDBG funded housing rehabilitation loans supplement the HIP. During PY 2024 Consolidated Plan OAKLAND COUNTY 221 OMB Control No: 2506-0117 (exp. 09/30/2022) the County will recycle approximately $1,000,000 in CDBG RLF into the HIP for the rehabilitation of approximately 40 single-family homes of LI residents. • Emergency, youth, senior and other public services designed to meet special needs of LI residents are expanded through leverage from various public service agencies. HOME - 25% Match Requirement • Oakland County ensures that all housing projects receive $1 of non-federal match for every $4 of HOME funds expended, in accordance with federal guideline (s.92.218). • The HOME program requires a 25% match on all non-administrative activities. In PY 2024, $516,149 in general funds will serve as match for County level housing rehabilitation, rental development/preservation and homebuyer assistance activities. • CHDO’s leverage HOME funds with state and private resources to develop affordable housing • OCNHD leveraged $1,000,000 in HOME funding through a Notice of Funding Availability (NOFA) that resulted in the development of an approximately $21,500,000 rental housing development. The 53-unit affordable housing community in under construction and will be completed in 2025. • Program Income generated from paybacks on HOME funded housing rehabilitation loans supplement the HIP. During PY 2024, the Division estimates approximately $1,700,000 in PI will enable the rehabilitation of approximately 60 single-family homes of LI residents and expand affordable housing development. ESG - 100% Match Requirement • Oakland County passes on the match requirements to its vendors • Cash contributions for allowable costs including staff salaries/fringe benefits Annual Action Plan 2024 24 OMB Control No: 2506-0117 (exp. 09/30/2021) • Noncash contributions • Volunteer services are matched at the current minimum wage salary unless the recipient can verify a higher rate of pay for current employees performing similar work • Real property, equipment, goods or services that if the recipient had to pay for them with grant funds, the payments would have been indirect costs • The value of donated goods and services such as clothing, food, diapers, haircuts, etc. The value placed should be consistent with Office of Management and Budget Circulars. Annual Action Plan 2024 25 OMB Control No: 2506-0117 (exp. 09/30/2021) If appropriate, describe publically owned land or property located within the jurisdiction that may be used to address the needs identified in the plan Oakland County created a land bank to manage vacant, tax foreclosed property and cause its redevelopment as affordable housing by public or private entities. Discussion A variety of non-federal resources will supplement the CDBG, HOME and ESG funds. Non- federal resources available fall into three general categories - funds required to match the HOME and ESG programs as required by regulation, non-federal funds used by local communities to supplement CDBG allocations for larger scale projects, and the Oakland County Housing Trust Fund (OCHTF). Oakland County uses PI generated from paybacks on CDBG and HOME funded housing rehabilitation loans to expand the HIP and rental gap development/preservation program. The OCHTF provides gap funding for rental and for-sale mixed income housing throughout the County. In general, the land for OCHTF developments is identified and provided by its development partners. Groups and individuals are encouraged to establish non-profits complying with HUD requirements to permit them to receive funds under the HOME program, as well as funds under Section 811, Supportive Housing for Persons with Disabilities. Annual Action Plan 2024 26 OMB Control No: 2506-0117 (exp. 09/30/2021) Annual Goals and Objectives AP-20 Annual Goals and Objectives - 91.420, 91.220(c)(3)&(e) Goals Summary Information Sort Order Goal Name Start Year End Year Category Geographic Area Needs Addressed Funding Goal Outcome Indicator 1 Affordable Housing 2021 2025 Affordable Housing CDBG Admin/HIP Direct Project Costs/RLF and HOME Admin/Project Delivery Costs Oakland County HOME Consortium Oakland County CDBG ADMINISTRATION & PLANNING CDBG HOUSING/MHR CDBG HOUSING/HSG REHAB CDBG HOUSING/RLF (EST) HESG GENERAL PROGRAM ADMINISTRATION HOME/HOMEBUYER HOME/HOUSING REHAB HOME/RENTAL DEVELOPMENT HOME/RENTAL ASSISTANCE Rental units constructed: 53 Household Housing Unit Rental units rehabilitated: 25 Household Housing Unit Homeowner Housing Rehabilitated: 300 Household Housing Unit Annual Action Plan 2024 27 OMB Control No: 2506-0117 (exp. 09/30/2021) Sort Order Goal Name Start Year End Year Category Geographic Area Needs Addressed Funding Goal Outcome Indicator 2 Facilities and Services 2021 2025 Non-Housing Community Development CDBG Administration & Planning Oakland County HOME Consortium Oakland County CDBG ADMINISTRATION & PLANNING CDBG CLEARANCE & DEMO CDBG PF & INFRASTRUCTURE CDBG PS/HSG COUNSELING CDBG PS/BATTERED & ABUSED CDBG PS/PUBLIC SERVICES HESG HOMELESSNESS HOME GENERAL PROGRAM ADMINISTRATION Public Facility or Infrastructure Activities other than Low/Moderate Income Housing Benefit: 300000 Persons Assisted Public Facility or Infrastructure Activities for Low/Moderate Income Housing Benefit: 2000 Households Assisted Homeless Person Overnight Shelter: 280 Persons Assisted Homelessness Prevention: 100 Persons Assisted Buildings Demolished: 25 Buildings Housing Code Enforcement/Foreclosed Property Care: 36000 Household Housing Unit Other: 2 Other Annual Action Plan 2024 28 OMB Control No: 2506-0117 (exp. 09/30/2021) Sort Order Goal Name Start Year End Year Category Geographic Area Needs Addressed Funding Goal Outcome Indicator 3 Discrimination 2021 2025 Affordable Housing Homeless Non-Homeless Special Needs Non-Housing Community Development CDBG Administration & Planning Oakland County HOME Consortium Oakland County CDBG ADMINISTRATION & PLANNING CDBG CODE ENFORCEMENT CDBG HOUSING/MHR CDBG HOUSING/MHMHR CDBG HOUSING/HSG REHAB CDBG HOUSING/RLF (EST) CDBG PF & INFRASTRUCTURE CDBG PS/HSG COUNSELING CDBG PS/BATTERED & ABUSED CDBG PS/PUBLIC SERVICES HESG GENERAL PROGRAM ADMINISTRATION HESG HOMELESSNESS HOME GENERAL PROGRAM ADMINISTRATION HOME/HOMEBUYER HOME/HOUSING REHAB HOME/RENTAL DEVELOPMENT HOME/RENTAL ASSISTANCE Public service activities other than Low/Moderate Income Housing Benefit: 700 Persons Assisted Annual Action Plan 2024 29 OMB Control No: 2506-0117 (exp. 09/30/2021) Sort Order Goal Name Start Year End Year Category Geographic Area Needs Addressed Funding Goal Outcome Indicator 4 Community Engagement 2021 2025 Affordable Housing Homeless Non-Homeless Special Needs Non-Housing Community Development CDBG Administration & Planning Oakland County HOME Consortium Oakland County CDBG ADMINISTRATION & PLANNING CDBG HOUSING/MHR CDBG HOUSING/MHMHR CDBG HOUSING/HSG REHAB CDBG PS/HSG COUNSELING CDBG PS/BATTERED & ABUSED CDBG PS/PUBLIC SERVICES HOME/HOUSING REHAB HOME/RENTAL ASSISTANCE Public service activities for Low/Moderate Income Housing Benefit: 50 Households Assisted Direct Financial Assistance to Homebuyers: 10 Households Assisted Homelessness Prevention: 20 Persons Assisted Housing Code Enforcement/Foreclosed Property Care: 3 Household Housing Unit Table 3 – Goals Summary Goal Descriptions 1 Goal Name Affordable Housing Goal Description Annual Action Plan 2024 30 OMB Control No: 2506-0117 (exp. 09/30/2021) 2 Goal Name Facilities and Services Goal Description 3 Goal Name Discrimination Goal Description 4 Goal Name Community Engagement Goal Description Annual Action Plan 2024 31 OMB Control No: 2506-0117 (exp. 09/30/2021) AP-35 Projects - 91.420, 91.220(d) Introduction How the CDBG Formula Works: After setting aside funds for special purposes such as technical assistance, projects specified by Congress and the Indian CDBG program, the annual appropriation for CDBG formula funding is split so that 70% is allocated among eligible metropolitan cities and counties (referred to as entitlement communities) and 30% among the states to serve non- entitled communities. HUD uses two basic formulas, known as Formula A and Formula B, to allocate CDBG funds to entitlement communities. A similar dual formula system allocates funds to states. For entitlements, Formula A allocates funds a community based on its metropolitan shares of: (1) population weighted at 25%; (2) poverty weighted at 50%; and (3) overcrowding, weighted at 25%, times appropriations. Formula B allocates funds to a community based CDBG formula targeting to community development need on: (1) its share of growth lag, weighted at 20%; and its metropolitan shares of (2) poverty, weighted at 30% and (3) pre-1940 housing weighted at 50%, times appropriation. HUD calculates the amount for each entitlement jurisdiction under each formula. Jurisdictions are then assigned the larger of the two grants. That is, if a jurisdiction gets more funds under Formula A than Formula B, the grant amount is based on Formula A. With this dual system, the total amount assigned to CDBG grantees has always exceeded the total amount available through appropriation. To bring the total grant amount allocated to entitlement communities within the appropriated amount, HUD uses a pro rata reduction (calculated as a percentage). # Project Name 1 CDBG Administration 2 CDBG Housing Rehabilitation/Revolving Loan Fund Estimate 3 CDBG Housing/HIP Direct Delivery Costs 4 CDBG/PS Housing Counseling Services 5 CDBG/PS Battered & Abused 6 CDBG Mobile Home Minor Home Repair 7 CDBG Clearance and Demolition 8 CDBG Code Enforcement 9 CDBG Minor Home Repair Annual Action Plan 2024 32 OMB Control No: 2506-0117 (exp. 09/30/2021) # Project Name 10 CDBG Public Facilities and Infrastructure 11 CDBG/PS Public Service 12 HOME Administration/Program Income Estimate 13 HOME Housing Rehabilitation 14 HOME CHDO Rental 15 HOME CHDO Operating Experiences 16 ESG Administration and EGS Homelessness 17 HOME CHDO Homebuyer 18 HOME Rental 19 CDBG Rental Table 4 – Project Information Describe the reasons for allocation priorities and any obstacles to addressing underserved needs Quantitative research (housing market and demographic analysis) and qualitative research (surveys, public meetings, focus groups, and resident input) impacted the priority needs and strategies for the Oakland County PY 2021-2025 Consolidated Plan. Oakland County prioritized benefit to low-income persons and areas using a formula allocation method. Activities selected meet national program objectives and Consolidated Plan goals. Oakland County does not allocate investments geographically and does not plan to identify any specific Neighborhood Revitalization Strategy Areas (NRSA). The obstacle to addressing underserved needs is the lack of adequate financial resources. Annual Action Plan 2024 33 OMB Control No: 2506-0117 (exp. 09/30/2021) AP-38 Project Summary Project Summary Information Annual Action Plan 2024 34 OMB Control No: 2506-0117 (exp. 09/30/2021) 1 Project Name CDBG Administration Target Area Oakland County Goals Supported Affordable Housing Facilities and Services Discrimination Community Engagement Needs Addressed CDBG ADMINISTRATION & PLANNING Funding CDBG: $929,050 Description Administration of the CDBG program including management, public information, policy development, and fair housing activities. Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities Not applicable. Location Description Oakland County Neighborhood & Housing Development Division 1200 N. Telegraph Rd., 34E, Pontiac, MI 48341-1032 Planned Activities General Program Administration 2 Project Name CDBG Housing Rehabilitation/Revolving Loan Fund Estimate Target Area Oakland County Goals Supported Affordable Housing Discrimination Needs Addressed CDBG HOUSING/HSG REHAB CDBG HOUSING/RLF (EST) Funding CDBG: $874,019 Description Contract work of the County's Home Improvement Program which is available to income qualified homeowners and owner occupants of attached single family rental units (2-4 units) in participating communities. Estimated loan payments to fund future Home Improvement Program loans which are available to income qualified homeowners in participating communities. Target Date 6/30/2025 Annual Action Plan 2024 35 OMB Control No: 2506-0117 (exp. 09/30/2021) Estimate the number and type of families that will benefit from the proposed activities 50 Location Description Specific and variable Planned Activities Contract work of the County’s Home Improvement Program which is available to income qualified homeowners and owner occupants of attached single family rental units (2-4 units) in participating communities. Estimated loan payments to fund future Home Improvement Program loans which are available to income qualified homeowners in participating communities. 3 Project Name CDBG Housing/HIP Direct Delivery Costs Target Area Oakland County HOME Consortium Oakland County Goals Supported Affordable Housing Needs Addressed CDBG HOUSING/HSG REHAB Funding CDBG: $652,020 Description County's Home Improvement Program direct delivery costs of contract work available to income qualified homeowners of single-family owner- occupied units and owner occupants of attached single family rental (2-4 units) in participating communities. Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities Not applicable. Location Description Oakland County Neighborhood & Housing Development Division 1200 N. Telegraph Rd., Building 34E, Pontiac, MI 48132-1032 Planned Activities Housing Rehab Direct Delivery Costs 4 Project Name CDBG/PS Housing Counseling Services Target Area Oakland County HOME Consortium Oakland County Goals Supported Discrimination Community Engagement Annual Action Plan 2024 36 OMB Control No: 2506-0117 (exp. 09/30/2021) Needs Addressed CDBG PS/HSG COUNSELING Funding CDBG: $320,046 Description Comprehensive housing counseling services to help address housing matters including foreclosure, homebuyer and tenant issues. Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 280 Location Description Oakland County Neighborhood & Housing Development 1200 N. Telegraph Rd., 34E, Pontiac, MI 48341-1032 Planned Activities Comprehensive housing counseling services to help address housing matters including foreclosure, homebuyer and tenant issues. 5 Project Name CDBG/PS Battered & Abused Target Area Oakland County Goals Supported Facilities and Services Discrimination Needs Addressed CDBG PS/BATTERED & ABUSED Funding CDBG: $91,540 Description Services for victims of domestic violence, dating violence, sexual assault or stalking as part of a County executed and administered contract with HAVEN. Target Date 06/30/2025 Estimate the number and type of families that will benefit from the proposed activities 600 Location Description HAVEN 801 Vanguard Dr., Pontiac, MI 48341 Planned Activities Services for victims of domestic violence, dating violence, sexual assault or stalking as part of a County executed and administered contract with HAVEN. 6 Project Name CDBG Mobile Home Minor Home Repair Annual Action Plan 2024 37 OMB Control No: 2506-0117 (exp. 09/30/2021) Target Area Oakland County Goals Supported Affordable Housing Needs Addressed CDBG HOUSING/MHMHR Funding CDBG: $65,407 Description Minor home repair for the mobile homes of income qualified households. Repairs will conform to Oakland County guidelines and State of Michigan Lead Based Paint requirements. Target Date 06/30/2025 Estimate the number and type of families that will benefit from the proposed activities 25 Location Description Specific and Variable Planned Activities Minor Home Repairs to mobile homes of income qualified households. 7 Project Name CDBG Clearance and Demolition Target Area Oakland County Goals Supported Facilities and Services Discrimination Needs Addressed CDBG CLEARANCE & DEMO Funding CDBG: $0.00 Description Demolition of vacant and blighted structures Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 0 Location Description Specific and variable Planned Activities Clearance and Demolition 8 Project Name CDBG Code Enforcement Target Area Oakland County Goals Supported Facilities and Services Discrimination Annual Action Plan 2024 38 OMB Control No: 2506-0117 (exp. 09/30/2021) Needs Addressed CDBG CODE ENFORCEMENT Funding CDBG: $315,090 Description Code Enforcement activities Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 45,000 Location Description Area-wide Benefit eligible areas only Planned Activities Code Enforcement Activities in AWB areas 9 Project Name CDBG Minor Home Repair Target Area Oakland County Goals Supported Affordable Housing Discrimination Needs Addressed CDBG HOUSING/MHR Funding CDBG: $437,186 Description Minor Home Repairs for the home of income qualified households. Repairs will confirm to Oakland County's guidelines and State of Michigan Lead Based Paint guidelines. Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 120 Location Description Specific and Variable Planned Activities Minor Home Repair 10 Project Name CDBG Public Facilities and Infrastructure Target Area Oakland County Goals Supported Facilities and Services Discrimination Needs Addressed CDBG PF & INFRASTRUCTURE Annual Action Plan 2024 39 OMB Control No: 2506-0117 (exp. 09/30/2021) Funding CDBG: $718,505 Description Public Facilities and Infrastructure Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 6,500 Location Description Specific and Variable Planned Activities Parks and Recreation facilities, Remove Architectural Barriers, Senior Centers, and Sidewalks. 11 Project Name CDBG/PS Public Service Target Area Oakland County Goals Supported Facilities and Services Discrimination Community Engagement Needs Addressed CDBG PS/PUBLIC SERVICES Funding CDBG: $242,385 Description Public Services Target Date CDBG PS/PUBLIC SERVICES Estimate the number and type of families that will benefit from the proposed activities 20,150 Location Description Specific and variable Planned Activities Senior Services, Childcare services, Youth Services, Disabled Services, Mental Health Services, Emergency Services, Yard Services, and Transportation Services. 12 Project Name HOME Administration/Program Income Estimate Target Area Oakland County HOME Consortium Goals Supported Affordable Housing Discrimination Needs Addressed HESG GENERAL PROGRAM ADMINISTRATION Annual Action Plan 2024 40 OMB Control No: 2506-0117 (exp. 09/30/2021) Funding HOME: $379,400 Description County's cost of administering the Oakland County HOME Program Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities Not Applicable Location Description Oakland County Neighborhood & Housing Development Division 1200 N. Telegraph Rd, Building 34E Pontiac, MI 48341-1032 Planned Activities General Program Administration 13 Project Name HOME Housing Rehabilitation Target Area Oakland County HOME Consortium Goals Supported Affordable Housing Discrimination Community Engagement Needs Addressed HOME/HOUSING REHAB Funding HOME: $2,317,826 Description Direct project costs of contract work of the County's Home Improvement Program which is available to income qualified homeowners in participating communities. Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 65 Total: Grant (40), Match (10), Program Income (15) Location Description Specific and variable Planned Activities Direct project costs of contract work of the County's Home Improvement Program which is available to income qualified homeowners in participating communities. 14 Project Name HOME CHDO Rental Target Area Oakland County HOME Consortium Annual Action Plan 2024 41 OMB Control No: 2506-0117 (exp. 09/30/2021) Goals Supported Affordable Housing Discrimination Needs Addressed HOME/RENTAL DEVELOPMENT Funding HOME: $1,100,000 Description Contracts with qualified developers to create affordable housing for income qualified renters through acquisition, rehabilitation or new construction. Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 12-22 Units, 24-44 low-income persons Location Description Specific and variable Planned Activities Contracts with qualified developers to create affordable housing for income qualified renters through acquisition, rehabilitation or new construction. 15 Project Name HOME CHDO Operating Expenses Target Area Oakland County HOME Consortium Goals Supported Affordable Housing Discrimination Needs Addressed HOME/RENTAL ASSISTANCE Funding HOME: $103,230 Description Fund the operating expenses of Community Housing Development Organizations (CHDOs) when carrying out Oakland County HOME funded projects. Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities Not applicable Location Description Specific and variable Planned Activities CHDO Operating Expenses 16 Project Name ESG Administration and EGS Homelessness Annual Action Plan 2024 42 OMB Control No: 2506-0117 (exp. 09/30/2021) Target Area Oakland County HOME Consortium Goals Supported Facilities and Services Discrimination Needs Addressed HESG GENERAL PROGRAM ADMINISTRATION HESG HOMELESSNESS Funding ESG: $322,021 Description County's cost of administering the Oakland County ESG program. Fund qualified agency to perform data collection/evaluation through HMIS. The agency will provide reports/training/technical assistance to ESG participating agencies and the County. Funds will be provided to a qualified agency to provide rental assistance and housing relocation and stabilization services for eligible homeless and/or at risk or homelessness clients. Fund qualified shelters for eligible essential service for homeless clients, shelter operations and organizational support. Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 1550 Location Description Specific and variable Planned Activities • Administration (7.5%) = $24,152 • Homeless Management Information System Data Collection (7.5%) = $24,152 • Homeless Prevention and Rapid Rehousing Services = $101,664 • Emergency Shelter Operations and Essential Services = $172,054 17 Project Name HOME CHDO Homebuyer Target Area Oakland County HOME Consortium Goals Supported Affordable Housing Discrimination Needs Addressed HOME/HOMEBUYER Funding HOME: $409,689 Description Contracts with qualified Community Housing Development Organizations (CHDOs) to develop affordable housing for income qualified homebuyers through acquisition, rehab or new construction. Annual Action Plan 2024 43 OMB Control No: 2506-0117 (exp. 09/30/2021) Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 3 Location Description Specific and variable Planned Activities Acquisition, Housing Rehabilitation and New Construction 18 Project Name HOME Rental Target Area Oakland County HOME Consortium Goals Supported Affordable Housing Discrimination Needs Addressed HOME/RENTAL DEVELOPMENT Funding HOME: $200,000 Description Contracts with qualified CHDOs to construct or rehabilitate affordable single family (1-4 units) and multifamily rental housing in HOME Consortium Communities. This investment targets renters at or below 60% of area median income. Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 3 Location Description Specific and Variable Planned Activities Acquisition, Housing Rehabilitation and New Construction 19 Project Name CDBG Acquisition and Renovation Target Area Oakland County Goals Supported Affordable Housing Discrimination Needs Addressed CDBG RENTAL Funding CDBG: $0.00 Annual Action Plan 2024 44 OMB Control No: 2506-0117 (exp. 09/30/2021) Description Contracts with multifamily rental property owners and developers to acquire and/or renovate existing multifamily rental properties for low- to moderate-income families. Target Date 6/30/2025 Estimate the number and type of families that will benefit from the proposed activities 40 Location Description Specific and variable Planned Activities Acquisition and/or renovation of multifamily rental properties for low- to moderate-income families. Annual Action Plan 2024 45 OMB Control No: 2506-0117 (exp. 09/30/2021) AP-50 Geographic Distribution - 91.420, 91.220(f) Description of the geographic areas of the entitlement (including areas of low-income and minority concentration) where assistance will be directed Oakland County Neighborhood & Housing Development administers HUD CPD grant programs through the authorization of the Oakland County Board of Commissioners. Current programs consist of CDBG, HOME and ESG. Oakland County targets these program funds towards low- income areas, individuals, and households as prioritized by HUD, based on Oakland County demographics and U.S. Census Bureau estimates. In addition to these programs, the Division continues to administer Neighborhood Stabilization Programs (NSP). The County contains 61 units of general local government, including twenty-one townships, ten villages and thirty cities. The following fifty-two (85%) of Oakland County communities participate in the County's "Urban County" CDBG housing and community development programs: Cities - Auburn Hills, Berkley, Birmingham, Bloomfield Hills, Clarkston, Clawson, Farmington, Ferndale, Hazel Park, Huntington Woods, Keego Harbor, Lathrup Village, Madison Heights, Northville, Novi, Oak Park, Orchard Lake Village, Pleasant Ridge, Rochester, Rochester Hills, South Lyon, Sylvan Lake, Troy, Walled Lake, Wixom Townships - Addison, Bloomfield, Brandon, Commerce, Groveland, Highland, Holly, Independence, Lyon, Milford, Oakland, Orion, Oxford, Rose, Royal Oak, Springfield, West Bloomfield, White Lake Villages - Beverly Hills, Franklin, Holly, Lake Orion, Leonard, Milford, Ortonville, Oxford and Wolverine Lake. Farmington Hills, Royal Oak, Pontiac, Southfield and Waterford Township are HUD entitlement communities. These communities with over 50,000 residents are "entitled" to receive HUD funds and have chosen to administer their own CDBG programs. The City of Lake Angelus, Novi Township, Southfield Township and the Village of Bingham Farms do not receive HUD funds. Geographic Distribution Target Area Percentage of Funds Oakland County HOME Consortium 33 Oakland County 67 Table 5 - Geographic Distribution Rationale for the priorities for allocating investments geographically Oakland County CDBG - CDBG funds are distributed based on an allocation method approved by the BOC. The method deducts administrative costs up to 20% from the grant and apportions 1/3 of the grant balance to the Home Improvement Program (HIP) and 2/3 of the balance to 53 Annual Action Plan 2024 46 OMB Control No: 2506-0117 (exp. 09/30/2021) participating communities (PC's). The allocation of funds to PC's follows the federal CDBG "option one" method from the Housing and Community Development Act, as amended [42 USC 5306(b) (2)]. The County formula is: (P+3L)/4 P= ratio of a PC's population to population in all PC's L= ratio of community's low-income (LI) population to that of all PC's. The LI ratio is factored 3 times and then multiplied by the total amount of funds available each year. All PC’s falling below $7,000 receive $7,000 as a minimum award. Oakland County HOME - Oakland County invests HOME and CDBG funds in the HIP which operates throughout 56 communities on a 1st-come 1st-serve basis targeting applicants who qualify as LI homeowners of single-family (SF) owner-occupied units in PC's. CDBG funds are also used to operate the HIP for owner occupants of attached SF rental (2-4 units) in Urban County PC's. Qualified Community Housing Development Organizations (CHDOs) may also receive HOME to construct or rehabilitate affordable SF (1- 4 units) and multifamily rental housing in 56 communities. This investment targets renters at or below 60% of area median income. CHDOs will be able to increase the supply of rental units by Acquisition/Rehabilitation or New Construction. A portion of HOME program income (PI) will be designated to CHDOs to fund homeownership opportunities for persons prioritized as LI, 1st time homebuyers in Consortium communities. Homebuyer assistance is provided to make homeownership affordable. HOME funds will also be reserved to provide gap financing for developers to build/rehabilitate affordable rental housing. Oakland County ESG – Emergency Shelter: distributed among eligible shelter providers that complete the application process. The allocation to each agency would be based on the individual agency’s total number of persons served each day/night for the period of 7/1 - 6/30 of the previous year as a % of total served. The Shelter Operations portion of the grant shall be no more than 60% of the grant and never more than the 2010 level. Homeless Management Information System (HMIS) - The HMIS lead agency will receive up to 7.5% to ensure that shelter personnel are trained, and that reported data is complete and correct. Administration - The County retains 7.5% for administration, planning, implementation, reimbursement and reporting. Housing Relocation and Stabilization Services/Rental Assistance - The balance of the grant will be allocated for Homeless Prevention and/or Rapid Re-Housing programs. A maximum of 2 agencies will be funded through an RFP based on a point criteria: (Capacity/Experience 40), Outreach Plan (25) HMIS (15), prior experience with use of Mainstream Resources/Leveraging (15) and CoC participation (5). Discussion Federal CDBG Formula - After setting aside funds for technical assistance, projects specified by Congress and the Indian CDBG program, the annual appropriation for CDBG is split, 70% Annual Action Plan 2024 47 OMB Control No: 2506-0117 (exp. 09/30/2021) allocated among eligible metropolitan cities and counties (referred to as entitlement communities) and 30% among states to serve non-entitled areas. HUD uses 2 formulas, A and B, to allocate CDBG to entitlements. A similar dual formula allocates funds to states. For entitlements, Formula A allocates funds to a community based on its metropolitan share of: (1) population weighted 25%; (2) poverty weighted 50%; and (3) overcrowding, weighted 25%, times appropriations. Formula B allocates funds based on the metropolitan share of: (1) growth lag, weighted 20%; (2) poverty, weighted 30% and (3) pre-1940 housing weighted 50%, times appropriation. HUD calculates the amount for each entitlement under each formula. Jurisdictions are then assigned the larger of the two. That is, if a jurisdiction gets more funds under A than B, the grant amount is based on A. 2011-2015 Low/Moderate Income Summary Data (LMISD) - HUD announced that new LMISD will go into effect on 4/1/19. These data are used to qualify all new area-benefit activities as of 4/1/19. HUD released Community Planning and Development Notice 19-02 which provides guidance on geographic datasets used for compliance purposes with CDBG grant requirements. The Notice: • Announces the publication of the LMISD based on the American Community Survey (ACS) 2011- 2015 5-year estimates (2015 ACS). These data will replace the prior LMISD based on the ACS 2006-2010 5-year estimates (2010 ACS) for the purposes of demonstrating compliance with the CDBG National Objective of providing benefit to low- and moderate-income persons on an area basis (“Area Benefit” or LMA) and other purposes discussed this Notice; • Announces an effective date of 4/1/19 for use of the 2015 ACS LMISD to qualify LMA activities; and, provides a transition policy for circumstances when prior 2010 ACS LMISD may continue to be used; • Explains the geographic format of these data and how to use the LMISD to demonstrate compliance for LMA activities; • Announces the publication of margin of error (MOE) data for all geographies in the LMISD, including all census places and block groups, and provides instructions for use. Additionally, this Notice describes guidance regarding the confidence interval and acceptable MOE for local income surveys, based on the LMISD MOE; • Announces that HUD will set a 5-year publication schedule for other geographic data used for reporting race/ethnicity, disability, and age of beneficiaries, as well as poverty data used to qualify certain activities for assistance; and, • Provides instruction for reporting LMA activities in the grantee reporting systems for the various programs. Annual Action Plan 2024 48 OMB Control No: 2506-0117 (exp. 09/30/2021) CDBG - Eighty percent of all CDBG funds are allocated to benefit fifty-two participating communities. HOME - All HOME funded activities are available in the 56 HOME Consortium communities. ESG - Emergency Solutions Grant typically funds 6 shelters. HAVEN, Hope Hospitality and Lighthouse of Michigan’s PATH program are centrally located in Pontiac. Community Ground Sanctuary is in the southeastern community of Royal Oak. Welcome Inn Day Center is in the southcentral community of Southfield. South Oakland Shelter is a rotating shelter with locations throughout the County. The ESG funded HPRP is available countywide. Annual Action Plan 2024 49 OMB Control No: 2506-0117 (exp. 09/30/2021) Affordable Housing AP-55 Affordable Housing - 91.420, 91.220(g) Introduction Oakland County will address the affordable housing need by supporting CHDO homebuyer programs and rental development opportunities, supporting homeless prevention and rapid re- housing services, rehabilitation of existing units through the Home Improvement Program, gap financing of rental multi-unit preservation/development, and housing counseling services. One Year Goals for the Number of Households to be Supported Homeless 1,500 Non-Homeless 388 Special-Needs 173 Total 2,061 Table 6 - One Year Goals for Affordable Housing by Support Requirement One Year Goals for the Number of Households Supported Through Rental Assistance 150 The Production of New Units 53 Rehab of Existing Units 167 Acquisition of Existing Units 3 Total 373 Table 7 - One Year Goals for Affordable Housing by Support Type Discussion The One Year Goal for Rental Assistance is provided through the Oakland County ESG program homeless prevention and rapid re-housing services component (150 units). The One Year Goal for Rehab of Existing Units is provided through the Oakland County Home Improvement Program (150 units). The One Year Goal to produce 53 new units and to acquire 3 units for renovation will be accomplished through the CHDO activities and the Rental Development/Preservation Gap Financing program. The Housing Counseling Unit will assist approximately 350 households to acquire and maintain affordable housing. In addition, the Unit will provide approximately 2000 households with information and referrals on housing related issues. Annual Action Plan 2024 50 OMB Control No: 2506-0117 (exp. 09/30/2021) The above numbers are goals for PY 2024. The actual number may be higher or lower. Annual Action Plan 2024 51 OMB Control No: 2506-0117 (exp. 09/30/2021) AP-60 Public Housing - 91.420, 91.220(h) Introduction Oakland County does not administer public housing. Public Housing Commissions in Ferndale, Pontiac, and Royal Oak Township have public housing units. Ferndale, Pontiac and Southfield Housing Commissions offer Housing Choice Vouchers (HCV). In addition, as of September 2019 the Michigan State Housing Development Authority (MSHDA) has allocated just under 1,615 HCV for Oakland County. Plymouth Housing Commission and Detroit Housing Commission and other commissions in the region, while not located in Oakland County, offer a significant number of HCVs. Many HCV holders choose to reside in Oakland County. Actions planned during the next year to address the needs to public housing The Ferndale, Pontiac, and Royal Oak Township Public Housing Commissions (PHCs) are not under Oakland County control. As part of the Consolidated Plan development process the County invited the PHCs to participate in the formulation of the Analysis of Impediments to Fair Housing Choice. One PHC participated. The County has regular meetings with the Pontiac Housing Commission on the needs for public housing and partnership opportunities to bring housing to families. Actions to encourage public housing residents to become more involved in management and participate in homeownership Oakland County housing counselors will meet with public housing residents and/or housing choice voucher holders to explore the potential for future homeownership including converting a rental voucher to a homeownership voucher. The housing counseling unit provides referrals to each local PHC. The status of each PHC waiting list is provided to the Neighborhood & Housing Development Division through its Alliance membership. If the PHA is designated as troubled, describe the manner in which financial assistance will be provided or other assistance A troubled PHA is one that has a Public Housing Assessment System (PHAS) score of 59% or lower. Pontiac Housing Commission is listed as "Troubled" in the most recent listing released October Annual Action Plan 2024 52 OMB Control No: 2506-0117 (exp. 09/30/2021) 2023. https://www.hud.gov/program_offices/public_indian_housing/reac/products/prodphasintrule Oakland County Neighborhood & Housing Development Division does not administer a public housing commission. The plan for Pontiac Housing Commission to remove its "Troubled" designation is currently unknown. Annual Action Plan 2024 53 OMB Control No: 2506-0117 (exp. 09/30/2021) AP-65 Homeless and Other Special Needs Activities - 91.420, 91.220(i) Introduction The NHD has administered the Emergency Solutions Grant (ESG) program since 1987 and is a member of the Alliance for Housing of Oakland County, the Continuum of Care. The Alliance is a 501(c) (3), nonprofit organization working toward a common goal to end homelessness and increase affordable housing opportunities. The Alliance is made up of many organizations from the private and public sector including emergency shelters, warming centers, providers of health services including mental health and developmental disability services, affordable housing developers, supportive housing programs, municipalities, government agencies, faith-based service providers and more. The Alliance competes nationally for funding including annual applications for HUD Continuum of Care Homeless Assistance Grants. Describe the jurisdictions one-year goals and actions for reducing and ending homelessness including Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs Continuum of Care's efforts to reduce the number of individuals and families who become homeless are driven by its Plan to End Homelessness. This plan was written in 2006 and has been updated several times. The Alliance for Housing (CoC) has developed a strategic Plan in addition to the original plan. Most of the original goals have been made. Oakland County established a “Blueprint to End Homelessness” during 2021 to seek new goals, ensure equity in programming, increase alternative funding sources and to become a unified funding agency under the HEARTH Act. Under the current plan Goal 3 states: Increase and strengthen the amount of prevention, both emergency and system-wide and Rapid Re-Housing Services. Strategies under this goal to reduce homelessness include addressing impediments to fair housing choice as identified in the Oakland County Con Plan Jurisdictions’ Analyses of Impediments. All strategies to achieve this goal are coordinated with ESG recipients. Oakland County Con Plan jurisdictions address homelessness prevention by contributing to the achievement of the goals through emergency service dollars. The Continuum of Care’s efforts focus on relationship building and outreach. Physical outreach is targeted to emergency shelters, warming centers and the streets. Brochures and flyers are distributed at shelters, human services agencies, schools, WIC providers, libraries and other areas frequented by at risk families. Outreach includes press releases, the Continuum of Care website and newsletters. Homeless Student Liaisons provide a means for reaching families Annual Action Plan 2024 54 OMB Control No: 2506-0117 (exp. 09/30/2021) through the schools. Program staff works to build trust; many unsheltered families fear their children will be taken from them if discovered. Contact focuses on introducing services to engage, rather than frighten or alienate and works to quickly identify housing. When the family accepts the system of care, they are likely to stay engaged, improving the chance of long-term success. The Continuum of Care has specific outreach procedures in place to identify and engage homeless individuals and families. Projects for Assistance in Transition from Homelessness (PATH) teams canvass community shelters and the streets to engage homeless in obtaining services. Unsheltered homeless are the most difficult to engage and least likely to seek assistance. By meeting homeless individuals and families where they are, team members gain trust and make connections to resources and services. The Continuum of Care also hosts annual Community Resource Day events to introduce and immediate access to resources. Housing and services providers serve persons with disabilities and ensure accessibility through a variety of accommodations. Additionally, Continuum of Care providers who operate outreach services all have Language Access Plans (LAP) in place to aid with persons with limited English proficiency or other language barriers that may prevent access to services. Interpretation services are provided by organizations such as ACCESS for Arabic translations and deaf interpreters accessed through the State of Michigan Division on Deaf, DeafBlind and Hard of Hearing. Oakland County has a contract with Telelanguage which provides more than 150 language services including American Sign Language for any county administered program. Addressing the emergency shelter and transitional housing needs of homeless persons Recipient agencies conduct an initial evaluation to determine each individual or family’s eligibility for ESG assistance and the amount and types of assistance the household needs to regain stability in permanent housing. The evaluations are conducted in accordance with the centralized assessment requirements of the Oakland County Continuum of Care. After initial evaluation, a housing plan is developed, and a participant must meet with his or her caseworker as prescribed under the plan. Unless prohibited under the Violence Against Women Act, as amended or the Family Violence Prevention and Services Act, the recipient will be connected to appropriate supportive services including assistance in obtaining permanent housing, mental health treatment, counseling and other services essential for achieving independent living. They will also be linked to federal, state, local and private assistance available to assist with obtaining housing stability including Medicaid, food assistance, WIC, unemployment benefits, SSI, SSDI, Veteran’s benefits, medical assistance, legal aid, employment assistance and other locally available assistance programs. A plan will be Annual Action Plan 2024 55 OMB Control No: 2506-0117 (exp. 09/30/2021) developed to assist the program participant to retain permanent housing after the assistance ends, considering all relevant considerations such as the program participants current or expected income and expenses, other public or private assistance for which the program participant will be eligible and likely to receive, and the affordability of available housing in the area. Each participant will be linked to available PSH programs or the local Housing Choice Voucher (HCV) Programs, PHA and project based rental assistance when the waiting lists are open. Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again Oakland County ESG funds are used in part to fund a Homeless Prevention and/or Rapid Re- Housing (HPRRH) program. South Oakland Shelter (SOS)/Lighthouse of Oakland County and Community Housing Network administer HPRRH contracts and provided a combination of rental assistance, rental fees, utility assistance and case management to homeless and at risk of homeless households. SOS offers a twelve month follow up program of in-home case management that assisted 90% of HPRRH clients to maintain housing after one year. With ESG- CV funds, the waivers were used to extend the amount of time a recipient can receive assistance to prevent further homelessness during the pandemic. In the Continuum of Care geographic area, the average length of time families are homeless before entering a program is 1-3 months. The average length of time individuals are homeless before entering shelter is 1 week or less and 1-3 months for individuals entering transitional housing or permanent housing programs. As part of the intake assessment in HMIS, the length of homeless episodes is a universal data element and is routinely completed. This data is collected and shared with the Systems Implementation and Coordination Committee, who is charged with developing plans to increase the effectiveness of funded and non-funded programs serving homeless populations. HMIS is analyzed to create plans to specifically reduce the length of time individuals and families remain homeless. Data from both Continuum of Care and ESG funded projects as well as non-HUD funded projects is considered with equal weight in the planning process. Planning includes strengthening existing program capacity and efficient connections to community programs including Housing Choice Voucher waitlists, mainstream services and other available programs. Annual Action Plan 2024 56 OMB Control No: 2506-0117 (exp. 09/30/2021) The Continuum of Care is actively working to reduce returns to homelessness of individuals and families in its geographic area by tracking returns to homelessness and stays in permanent housing using HMIS. HMIS is used to generate and share quarterly reports which include data on episodes of homelessness experienced by participants who have exited rapid re-housing, transitional housing, and/or PSH. These reports are provided to the Board and the Project Monitoring and Performance Outcomes committee. Reports help to inform the overall technical assistance offered and ongoing strategic planning measurement and adjustments. Program specific technical assistance includes an examination of exit procedures as well as follow-up care procedures and accessibility. Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); or, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs. The following information is excerpted from the Neighborhood & Housing Development ESG Homeless Certification. Persons living on the street - Supportive services include outreach, food, health care and clothing to persons who reside on the streets. In most cases, it is not feasible to require the homeless persons to document that they reside on the street. It is enough for the agency’s staff to certify that the persons served, indeed, reside on the street. The outreach or service worker should sign and date a general certification verifying that services are going to homeless persons and indicating where the persons reside. Persons coming from living on the street - The agency should obtain information to indicate that a participant is coming from the street. This may include names of other organizations or outreach workers who have assisted them in the recent past who might provide documentation. If you are unable to verify that the person is coming from residing on the street, have the participant prepare or you prepare a written statement about the participant’s previous living place and have the participant sign the statement and date it. Merely obtaining a self-certification is not adequate. If the participant was referred by an outreach worker or social service agency, you must obtain written verification from the referring organization regarding where the person has been residing. This verification should be on agency letterhead, signed and dated. Persons coming from an emergency shelter for homeless persons - The agency should have written verification from shelter staff that the participant has been residing at the emergency shelter for homeless persons. The verification should be on agency letterhead, signed, and Annual Action Plan 2024 57 OMB Control No: 2506-0117 (exp. 09/30/2021) dated. Persons coming from transitional housing for homeless persons - The agency should have written verification from the transitional housing facility staff that the participant has been residing in the transitional housing. The verification should be on agency letterhead, signed and dated. The agency should also have written verification that the participant was living on the streets or in an emergency shelter prior to living in the transitional housing facility (see above for required documentation) or was discharged from an institution or evicted prior to living in the transitional housing facility and would have been homeless if not for the transitional housing (see below for required documentation). Discussion Persons from a short-term stay (up to 30 consecutive days) in an institution- The agency should have written verification from the institution’s staff that the participant has been residing in the institution for 30 days or less. The verification should be signed and dated. The agency also should have written verification that the participant was residing on the street or in an emergency shelter prior to the short term stay in the institution. See above for guidance. Persons being evicted from a private dwelling - The agency must have evidence of the formal eviction proceedings indicating that the participant was being evicted within the week before receiving rental assistance. If the person’s family is evicting him/her, a statement describing the reason for eviction should be signed by the family member and dated. In other cases where there is no formal eviction process, persons are considered evicted when they are forced out of the dwelling unit by circumstances beyond their control. In those instances, the agency must obtain a signed and dated statement from the participant describing the situation. The agency must make efforts to confirm that these circumstances are true and have written verification describing the efforts and attesting to their validity. The verification should be signed and dated. The agency must also have information on the income of the participant and what efforts were made to obtain housing and why, without the rental assistance, the participant would be living on the street or in an emergency shelter. Persons being discharged from an institution - The agency must have evidence from the institution’s staff that the participant was being discharged within the week before receiving rental assistance. The agency must also have information on the income of the participant and what efforts were made to obtain housing and why, without the rental assistance, the participant would be living on the street or in an emergency shelter. Staff workers will reach out to those who are incarcerated in the Oakland County Jail and have identify as homeless to ensure an adequate discharge plan. Annual Action Plan 2024 58 OMB Control No: 2506-0117 (exp. 09/30/2021) Fleeing domestic violence - The agency must have written verification from the participant that he/she is fleeing a domestic violence situation. If the participant is unable to prepare the verification, prepare a written statement about the participant’s previous living situation and have the participant sign the statement and date it. Annual Action Plan 2024 59 OMB Control No: 2506-0117 (exp. 09/30/2021) AP-75 Barriers to affordable housing -91.420, 91.220(j) Introduction Oakland County will continue to work to foster equitable and inclusive communities by committing to creating and preserving affordable housing and eliminate barriers to affordable housing and residential investment. This includes the continued administration of its various housing programs, the identification of non-federal funding sources and partnerships, and the ongoing community education of housing issues. Actions it planned to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment Michigan is a home rule state. Oakland County has no authority over public policies including land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations and policies affecting the return on residential investment. During PY 2020, Oakland County completed a new Analysis of Impediments to Fair Housing Choice (AI) effective July 1, 2021. The AI identifies barriers to affordable housing to be addressed in a Fair Housing Plan which informed the County’s Five-Year Consolidated Plan (PY 2021 - PY 2025). Discussion Although Oakland County, cannot directly affect any of those barriers it continues to look for ways to collaborate, educate and convene local municipalities on understanding the effects of policies on the creation of affordable housing and the ability of individuals to continue to benefit from residential investment. Oakland County also commits to keeping HUD certified counselors on staff to educate residents on their rights and choices. Oakland County also commits to working with local social service agencies, the citizen advisory committee, board of commissioners and other advocacy organizations to look for new ways to address public policies that either directly or adversely create barriers to creating, obtaining or accessing affordable housing. Annual Action Plan 2024 60 OMB Control No: 2506-0117 (exp. 09/30/2021) AP-85 Other Actions - 91.420, 91.220(k) Introduction Consolidated Plan regulations require an analysis of Census data to determine if there are any instances of housing problems being more severe for an ethnic or racial group than for the County. Two types of priority problems constitute worst case needs for federal housing assistance Actions planned to address obstacles to meeting underserved needs Underserved Need: Severe rent burden Definition: A renter paying more than one-half of his or her income for total tenant payment (rent and utilities). Actions Planned to Address: • CDBG funded Subsistence Services • Development of new affordable housing units • ESG funded Homeless Prevention and Rapid Re-housing services • No-cost housing counseling • Affordable housing referrals • Referrals to utility assistance providers Underserved Need: Severely inadequate housing Definition: A unit is generally considered severely inadequate if any of the following criteria apply: • No hot and cold running water. • No bathtub or shower. • No flush toilet. • Shared plumbing facilities. • Cold for 24 hours or more and more than two breakdowns of heating equipment have occurred that lasted longer than 6 hours. Annual Action Plan 2024 61 OMB Control No: 2506-0117 (exp. 09/30/2021) • Electricity not used. • Exposed wiring, not every room has working electrical plugs, and fuses have blown more than twice. Actions Planned to Address: • CDBG/HOME funded Home Improvement Program • CDBG funded Minor Home Repair • CDBG funded Mobile Home Repair • HOME, CDBG, Housing Trust Fund rental rehabilitation programs • Referrals for weatherization assistance • No-cost housing counseling Actions planned to foster and maintain affordable housing Oakland County funds programs to maintain affordable housing. CDBG and HOME funds support the Home Improvement Program (HIP) offering 0% interest loans for repairs, ensuring low-income homeowners can stay in their homes. In 2019, a $500,000 HOME loan helped renovate affordable rental units in Pontiac. The Oakland County Housing Trust Fund (OCHTF) also uses HOME funds to create affordable rental opportunities. Community Development Housing Organizations (CHDOs) can participate in OCHTF rental programs, building or rehabbing affordable rental units for low-income residents. The homebuyer program helps low-income families purchase homes with subsidies. Emergency Solutions Grant funds provide temporary rental assistance and case management to extremely low-income residents at risk of homelessness. Housing counselors funded by HUD, MSHDA, and CDBG offer advice to renters and homeowners seeking affordable housing. Staff also advocate for affordable housing initiatives. Actions planned to reduce lead-based paint hazards The Division continues to address risks of Lead Based Paint (LBP) through implementation of the LeadSafe Housing Regulation and the State of Michigan Lead Abatement Act. The Home Annual Action Plan 2024 62 OMB Control No: 2506-0117 (exp. 09/30/2021) Improvement Program includes a risk assessment on rehabilitation work which disturbs painted surfaces pursuant to 24 CFR Part 35. Division staff are certified LBP Inspectors/Risk assessors with the State of Michigan. LBP hazards are addressed using lead abatement work practices. LBP clearances are performed on HIP projects. Contractors performing the work are licensed LBP abatement contractors with the State. LBP abatement has been an integral component of the HIP since 2000. The Division will continue to abate LBP hazards in single-family owner- occupied dwellings which qualify with program guidelines in participating communities. The Division also hosts LBP training for qualified contractors on the HIP approved bidder list. The County purchased new XRF machines to perform lead inspections/risk assessments more efficiently. Housing units funded with federal funds must meet LBP regulations. The County operates a housing rehabilitation program for single-family dwellings (1-4 units). The program has specific procedures which outline the steps to educate, test, contain and/or remediate LBP. Rehabilitation projects in which the structure was constructed before 1978 fall under the Federal LBP regulations. A lead hazard information pamphlet is provided to all prospective HIP participants. If the structure was built before 1978 a LBP risk assessment is conducted. A LBP risk assessment is provided to the homeowner along with the specification. The findings are incorporated into the specifications for the rehabilitation work. Contractors participating in the HIP doing work involving LBP must present documentation certifying them as an LBP certified contractor. An occupancy plan is developed to ensure occupants will not be exposed during site work. Results of clearance tests are provided to the homeowner. These actions educate the public of the danger of LBP and provide an LBP free living environment for occupants upon completion of site work. Actions planned to reduce the number of poverty-level families The County's Anti-Poverty Strategy is to help low-income persons stay in their homes, support low-income persons in crisis and job creation. The HOME program provides funds for non- profits, local governments, and developers to create affordable rental and homeownership opportunities. CDBG assists those in poverty with crisis, emergency, housing, housing counseling services and job creation. Crisis Services - Many communities have taken the lead in providing emergency food and clothing for families in crisis. Local communities also fund minor home repair programs and home chore programs for persons unable to perform tasks such as cleaning and shopping due to age and/or physical disability or provide transportation services for senior and disabled residents. The County will continue to encourage local communities to use CDBG funds for anti- Annual Action Plan 2024 63 OMB Control No: 2506-0117 (exp. 09/30/2021) poverty projects and coordinate the availability of other resources and programs. Actions planned to develop institutional structure The institutional structure, through which this AAP will be implemented, includes agencies of County government, local communities, non-profit organizations, and private industry. Division staff conduct CDBG, HOME and ESG workshops to keep partners current on new developments and policies. These workshops provide subrecipients, CHDOS and developers with opportunities to ask questions, share ideas and provide feedback. Additional technical consultations between Division staff and local agencies regularly occur as necessary to provide technical assistance. Pre-bid and pre-construction meetings are held prior to CDBG and HOME assisted projects providing education and technical assistance to ensure that affirmative marketing, procurement, Section 3, U.S. Department of Labor and Davis-Bacon Act requirements are met. The Division will continue efforts to update marketing materials to educate and provide awareness. Technical assistance provided by the Division focuses on defining program eligibility requirements; establishing and undertaking correct program processes; measuring performance; furthering collaboration between partners and building partner capacity. Actions planned to enhance coordination between public and private housing and social service agencies During 2024, Division staff will continue to provide information to local units of government and assist them in identifying and coordinating funding opportunities, with a focus on increasing actions aimed at expanding community development improvements and services to LMI persons and limited clientele populations. The Division will continue to coordinate the provision of CPD Grant resources in efforts to further affordable housing development and homebuyer assistance, as well as continuing financial assistance to individuals and families who are either homeless or in immediate risk of losing their housing. Oakland County will continue to work with local financial lending institutions, MSHDA, non-profits, developers, and other organizations in partnership efforts to further affordable housing funds and initiatives. Division staff will provide information from HUD and MSHDA to public agencies, individuals and/or non- and for-profit developers who may be interested in utilizing their entity's programs for producing affordable housing projects. Staff will continue to review and approve appropriate requests for Certificates of Consistency with the Con Plan to ensure that proposed programs meet goals and objectives. Division staff will continue to work with various agency staff to provide referrals to programs. In addition, staff will continue to provide technical assistance and information about fair housing and the advancement of housing related projects for populations in need of affordable and barrier-free housing to local governments, non-profits, CHDOs and for-profit developers. The Annual Action Plan 2024 64 OMB Control No: 2506-0117 (exp. 09/30/2021) Division coordinates with service providers by facilitating and participating in community- wide committees and engaging local experts to recommend and provide programs for target populations. Primarily, this is done through the collaborative relationship with Alliance for Housing. Division staff participate in and provide support to work groups of the Continuum of Care. Staff assist the Continuum of Care with its responsibilities for monitoring, evaluating and applying for funds through the HUD Continuum of Care and ESG funding processes. NHD will continue to support partners and develop new affiliations to assist serving low-income populations. Initiatives will focus on disseminating educational information through workshops, partner meetings and traditional and innovative media advertising to better inform the public about programs. Technical assistance will focus on improvements to application processes, refining methods of determining eligibility; ensuring correct processes are performed; monitoring; measuring performance; coordinating and enhancing collaboration between multiple partners, as well as assisting partners to build their capacity. Discussion The Division will continue to provide gap financing for rental and for-sale affordable housing through the OCHTF as well as have a finer focus on the health and safety home improvements for owner occupied rehabilitation. Annual Action Plan 2024 65 OMB Control No: 2506-0117 (exp. 09/30/2021) Program Specific Requirements AP-90 Program Specific Requirements - 91.420, 91.220(l)(1,2,4) Introduction CDBG Revolving Loan Funds are used to support Home Improvement Program projects in accordance with CDBG & HUD guidelines. Community Development Block Grant Program (CDBG) Reference 24 CFR 91.220(l)(1) Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in projects to be carried out. 1. The total amount of program income that will have been received before the start of the next program year and that has not yet been reprogrammed 0 2. The amount of proceeds from section 108 loan guarantees that will be used during the year to address the priority needs and specific objectives identified in the grantee's strategic plan. 0 3. The amount of surplus funds from urban renewal settlements 0 4. The amount of any grant funds returned to the line of credit for which the planned use has not been included in a prior statement or plan 0 5. The amount of income from float-funded activities 0 Total Program Income: 0 Other CDBG Requirements 1. The amount of urgent need activities 0 2. The estimated percentage of CDBG funds that will be used for activities that benefit persons of low and moderate income. Overall Benefit - A consecutive period of one, two or three years may be used to determine that a minimum overall benefit of 70% of CDBG funds is used to benefit persons of low and moderate income. Specify the years covered that include this Annual Action Plan. 98.00% HOME Investment Partnership Program (HOME) Reference 24 CFR 91.220(l)(2) 1. A description of other forms of investment being used beyond those identified in Section 92.205 is as follows: Other forms of investment include private and other public investments. HOME funds will Annual Action Plan 2024 66 OMB Control No: 2506-0117 (exp. 09/30/2021) not be invested in a loan guarantee as an eligible activity as indicated in 24 CFR 92.205(b). 2. A description of the guidelines that will be used for resale or recapture of HOME funds when used for homebuyer activities as required in 92.254, is as follows: The Oakland County Neighborhood & Housing Development Division has comprehensive program guidelines which provide for the recapture of HOME funds in compliance with program requirements 24 CFR 92.254(a). Under the recapture provision, the HOME investment subject to recapture is the HOME assistance that enables the homebuyer to afford the dwelling unit. This homebuyer assistance is a subsidy ($1,000.00 minimum) that makes the home affordable to a low-income homebuyer. The County’s home buyer assistance is a deferred payment loan with 0% interest. The Division secures its interest in the property with a mortgage and note. One hundred percent of the HOME investment is recaptured upon conversion of property use and/or ownership unless, due to foreclosure, there are not enough proceeds to pay the full amount of the loan. The County will accept the balance of the net proceeds as payment in full, the debt will be extinguished and the affordability period ends. Recaptured funds must be used to carry out HOME eligible activities. Annual Action Plan 2024 67 OMB Control No: 2506-0117 (exp. 09/30/2021) 3. A description of the guidelines for resale or recapture that ensures the affordability of units acquired with HOME funds? See 24 CFR 92.254(a)(4) are as follows: The HOME Program stipulates an affordability period on projects assisted with HOME funds to ensure that HOME investments yield affordable housing over the long term. Section 215 of the National Affordable Housing Act outlines the term “affordable housing”. To qualify as affordable, all rental and homeownership units constructed or rehabilitated with HOME funds must adhere to the regulation. It is the responsibility of each HOME participating jurisdiction to report to HUD the number of affordable units completed on an annual basis. Although the CDBG program does not require the qualification of units as “affordable” following the HOME Section 215 regulations, it is useful to keep track of affordable units rehabilitated with CDBG funds. Oakland County meets Section 215 requirements as: • HOME assisted units are available for households at 80% of area median income (AMI) or below • Initial purchase price of units does not exceed HUD Homeownership Value Limits • The units serve as the owner’s principal residence • All newly constructed housing meets energy efficiency standards • Recapture provisions allow the County to provide assistance as a deferred loan secured by mortgage and note (0% interest) • The loan becomes due and payable when the homeowner vacates, sells, transfers, or assigns any legal or equitable interest in the property except where prohibited by law. Upon the deaths of the loan recipients, it is the responsibility of the estate or heirs to repay the loan when the estate is settled. 4. Plans for using HOME funds to refinance existing debt secured by multifamily housing that is rehabilitated with HOME funds along with a description of the refinancing guidelines required that will be used under 24 CFR 92.206(b), are as follows: The Oakland County HOME Consortium does not intend to refinance existing debt secured by multifamily housing rehabilitated with HOME funds. Annual Action Plan 2024 68 OMB Control No: 2506-0117 (exp. 09/30/2021) 5. If applicable to a planned HOME TBRA activity, a description of the preference for persons with special needs or disabilities. (See 24 CFR 92.209(c)(2)(i) and CFR 91.220(l)(2)(vii)). Not Applicable. 6. If applicable to a planned HOME TBRA activity, a description of how the preference for a specific category of individuals with disabilities (e.g. persons with HIV/AIDS or chronic mental illness) will narrow the gap in benefits and the preference is needed to narrow the gap in benefits and services received by such persons. (See 24 CFR 92.209(c)(2)(ii) and 91.220(l)(2)(vii)). Not Applicable. 7. If applicable, a description of any preference or limitation for rental housing projects. (See 24 CFR 92.253(d)(3) and CFR 91.220(l)(2)(vii)). Note: Preferences cannot be administered in a manner that limits the opportunities of persons on any basis prohibited by the laws listed under 24 CFR 5.105(a). Not Applicable. Annual Action Plan 2024 69 OMB Control No: 2506-0117 (exp. 09/30/2021) Emergency Solutions Grant (ESG) 1. Include written standards for providing ESG assistance (may include as attachment) For the Homeless Assistance and Rapid Re-housing portion of the grant, recipient agencies will conduct an initial evaluation to determine each individual or family’s eligibility for ESG assistance and the amount and types of assistance the household needs to regain stability in permanent housing. The evaluations will be conducted in accordance with the centralized assessment requirements of the Oakland County Continuum of Care. Eligibility requirements for the Rapid ReHousing and/or prevention components of the program include: • The program participant must meet the criteria under the Federal homeless definition as amended under the HEARTH act. A homeless certification form is required. • The household income must be less than 30% of AMI. Annual income will be calculated using the standards for calculating income under HOME and Section 8 income guidelines. • The household cannot have assets more than $1,000 for an individual or $2,000 for a family • The program participant lacks enough resources and support networks necessary to retain housing without ESG Assistance, but for this assistance they would be homeless. After initial evaluation, a housing plan will be developed, and a participant must meet with his or her caseworker as prescribed under the plan. Unless prohibited under the Violence Against Women Act, as amended or the Family Violence Prevention and Services Act, the recipient will be connected to appropriate supportive services including assistance in obtaining permanent housing, mental health treatment, counseling and other services essential for achieving independent living. They will also be linked to federal, state, local and private assistance available to assist with obtaining housing stability including Medicaid, food assistance, WIC, unemployment benefits, SSI, SSDI, Veteran’s benefits, medical assistance, legal aid, employment assistance and other locally available assistance programs. A plan will be developed to assist the program participant to retain permanent housing after the assistance ends, considering all relevant considerations such as the program participants current or expected income and expenses, other public or private assistance for which the program participant will be eligible and likely to receive and the affordability of available housing in the area. Each participant will be linked to available PSH programs or the local HCV, Section 8 Voucher Programs, Public Housing Authorities and Annual Action Plan 2024 70 OMB Control No: 2506-0117 (exp. 09/30/2021) project based rental assistance when the waiting lists are open. 2. If the Continuum of Care has established centralized or coordinated assessment system that meets HUD requirements, describe that centralized or coordinated assessment system. Oakland County agencies practice a no wrong door approach. Coordination among emergency shelter providers, essential services providers, homelessness prevention and rapid re-housing assistance providers, other homeless assistance providers and mainstream services and housing providers will be done through HMIS sharing, the centralized assessment form, the local Homeless Assistance and Recovery Agency (HARA) and the Community Inter-Agency Service Team (CIST). All ESG recipients will be required to be an active member of the Continuum of Care and attend bimonthly CIST meetings. At these meetings, case managers can share information and resources and assist each other with resources for clients. MSHDA and Michigan DHHS with the full support from the Michigan Coalition Against Homelessness requires the use of a single assessment tool for people experiencing homelessness. This tool, known as the Vulnerability Index - Service Prioritization Decision Assistance Tool (VI-SPDAT) will provide HARAs and other housing agencies with a standardized, evidence-informed assessment process that prioritizes vulnerability. Michigan’s Campaign to End Homelessness is committed to Housing First and has identified VI-SPDAT as the tool that will be implemented in every community so that our state moves forward in ending homelessness while supporting HEARTH Act regulations. Youth programs are exempt and use their own similar statewide assessment tool. Oakland County providers meet once a month and have calls weekly to discuss VI-SPDAT scores and prioritize program openings based on need. VI-SPDAT training is provided and offered free of charge. The training is mandatory for HARA midlevel management, HARA front line staff, DHHS Continuum of Care mid-level management and DHHS Continuum of Care Program front line staff. The DHHS Continuum of Care Program includes the following projects: Rapid Re-Housing Initiative, Transitional Supportive Housing Leasing Assistance Program, Rural Housing & Supportive Services and the Rural Homeless PSH Initiative. HARA and DHHS Continuum of Care Program and Executive Directors are strongly encouraged to attend the training. HMIS entry is not granted to agency employees until VI-SPDAT training has been completed. 3. Identify the process for making sub-awards and describe how the ESG allocation available to private nonprofit organizations (including community and faith-based organizations). Generally, each June the Division hosts an ESG application workshop. The workshop is advertised in the Oakland Press, on the Oakland County website and on the Alliance for Annual Action Plan 2024 71 OMB Control No: 2506-0117 (exp. 09/30/2021) Housing list serve. The workshop provides details on the application requirements for the emergency shelter, HMIS and homeless prevention and rapid re-housing activities. Applicants are required to submit supporting documents including non-profit status, HMIS certification, non-debarment status, financial statements, insurance, policies and procedures and budgets. All emergency shelters that meet the application requirements receive funding based on formula. The lead agency of the CoC receives the HMIS funds. HPRP is scored based upon specific criteria and the awards are determined by committee. One-year contracts are awarded once funds are released. 4. If the jurisdiction is unable to meet the homeless participation requirement in 24 CFR 576.405(a), the jurisdiction must specify its plan for reaching out to and consulting with homeless or formerly homeless individuals in considering policies and funding decisions regarding facilities and services funded under ESG. The Division has a member of Citizen Advisory Council who was previously homeless and was “couch surfing” with her child for a period of time. Though this does not meet the official definition of homeless, Oakland County is committed to having representation of formerly homeless individuals on its advisory board. However, through consultation with the Continuum of Care and citizen participation process, the County obtains input from homeless or formerly homeless persons. In addition, as previously required in the ESG and Homeless Prevention and Rapid Re-Housing Program, the Division is passing this requirement on to funded agencies via contract language. This requirement will be checked at monitoring. The Continuum of Care has a formerly homeless person on their board. The Continuum of Care provides input to the Division on the ESG program. 5. Describe performance standards for evaluating ESG. ESG Monitoring Standards and Procedures - Oakland County will continue to implement a monitoring policy to ensure that ESG recipients follow applicable requirements. Annual onsite monitoring of shelters and transitional housing providers will include inspections to ensure that housing conforms to habitability standards under the HEARTH Act as well as LBP regulations. In addition to project performance, accountability, financial responsibility and adherence to federal grant management regulations. Monitor reviews will sample client files to ensure that case management, action plans and referrals to mainstream benefits are provided and the files are maintained appropriately. Reimbursement requests will be reviewed, and cross referenced with contracts and procurement documents as warranted. Rapid re-housing and homeless prevention files will be checked to ensure that all required documents including homeless certification forms, income calculations, lease, recertification documents and habitability inspection reports are Annual Action Plan 2024 72 OMB Control No: 2506-0117 (exp. 09/30/2021) accurate. In addition, before reimbursement can be made verification will be required including certification of homelessness, lease documents, income calculations, as well as cancelled checks and invoices. A contract will be developed requiring quarterly reimbursement requests and timely expenditure of funds. Monitoring was done via desk audits or in person as the COVID-19 pandemic restrictions allow. Performance Measures - Oakland County’s ESG program complies with CoC performance measurements which are available at https://www.oaklandhomeless.org/ Homeless - 65% of participants who meet the homeless definition will be stably housed 90 days after being exited from ESG/HARA through independent means or through linkage to another program (e.g. PSH, subsidized housing). Chronically Homeless - 50% of participants who meet the chronically homeless definition will be stably housed 90 days after being exited from ESG/HARA through independent means or through linkage to another program (e.g. PSH, subsidized housing) In April 2016, MDHHS, MSHDA and MCAH issued an important update to the SPDAT which outlines the VI- SPDAT and SPDAT requirements. For the past two years SPDAT has brought Michigan further along in the goal to redesign systems by providing every community a standardized evidence-based tool to support coordinated entry while taking Housing First practices to scale statewide. Since the implementation of the VI-SPDAT, the Alliance has reported that the tool helps them gauge the progression of client self-sufficiency as it relates to housing. Because the full VI-SPDAT is used during every follow-up meeting completed with active ESG clients assisted, it is instrumental in practicing progressive engagement with clients to ensure not only that basic needs are being fulfilled but that linkage to other resources is being made. Additional MSHDA/ESG outcomes include • Percentage of those served who maintain housing one year after assistance ends (RRH and Prevention) • Percentage of clients that increase income within that year and/or within the timeframe of active housing assistance • Length of time between screening/intake and moving into housing • Minimum number of households served each PY Modifications to the residency factor in the ESG formula have been discussed at the staff level. The Division plans to meet with stakeholders and to present any proposed changes for CAC and BOC consideration. For the PY 2021-2025 Consolidated Plan the Division will follow its Citizen Participation Plan Annual Action Plan 2024 73 OMB Control No: 2506-0117 (exp. 09/30/2021) amendment process if required to address any ESG formula changes that may impact the County’s program. OMB Number: 4040-0004 Expiration Date: 11/30/2025 * 1. Type of Submission:* 2. Type of Application: * 3. Date Received: 4. Applicant Identifier: 5a. Federal Entity Identifier:5b. Federal Award Identifier: 6. Date Received by State:7. State Application Identifier: * a. Legal Name: * b. Employer/Taxpayer Identification Number (EIN/TIN):* c. UEI: * Street1: Street2: * City: County/Parish: * State: Province: * Country: * Zip / Postal Code: Department Name:Division Name: Prefix:* First Name: Middle Name: * Last Name: Suffix: Title: Organizational Affiliation: * Telephone Number:Fax Number: * Email: * If Revision, select appropriate letter(s): * Other (Specify): State Use Only: 8. APPLICANT INFORMATION: d. Address: e. Organizational Unit: f. Name and contact information of person to be contacted on matters involving this application: Application for Federal Assistance SF-424 Preapplication Application Changed/Corrected Application New Continuation Revision B-24-UC-26-0002 County of Oakland, Michigan 386004876 HZ4EUKDD7AB4 Pontiac Oakland MI: Michigan USA: UNITED STATES 48341-1032 Health and Human Services Khadija Walker-Fobbs Housing Officer 248 230-4536 248 858-5311 walker-fobbsk@oakland.gov Neighborhood and Housing Development 1200 N. Telegraph Rd. 34E * 9. Type of Applicant 1: Select Applicant Type: Type of Applicant 2: Select Applicant Type: Type of Applicant 3: Select Applicant Type: * Other (specify): * 10. Name of Federal Agency: 11. Catalog of Federal Domestic Assistance Number: CFDA Title: * 12. Funding Opportunity Number: * Title: 13. Competition Identification Number: Title: 14. Areas Affected by Project (Cities, Counties, States, etc.): * 15. Descriptive Title of Applicant's Project: Attach supporting documents as specified in agency instructions. Application for Federal Assistance SF-424 B: County Government U.S. Department of Housing and Urban Development 14.218 Community Development Block Grant B-24-UC-26-0002 Community Development Block Grant Public Facilities, neighborhood and housing improvements and public services benefiting low income persons in Oakland County Urban County participating communities. View AttachmentsDelete AttachmentsAdd Attachments View AttachmentDelete AttachmentAdd AttachmentSee Attachment A * a. Federal * b. Applicant * c. State * d. Local * e. Other * f. Program Income * g. TOTAL . Prefix:* First Name: Middle Name: * Last Name: Suffix: * Title: * Telephone Number: * Email: Fax Number: * Signature of Authorized Representative:* Date Signed: 18. Estimated Funding ($): 21. *By signing this application, I certify (1) to the statements contained in the list of certifications** and (2) that the statements herein are true, complete and accurate to the best of my knowledge. I also provide the required assurances** and agree to comply with any resulting terms if I accept an award. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties. (U.S. Code, Title 18, Section 1001) ** The list of certifications and assurances, or an internet site where you may obtain this list, is contained in the announcement or agency specific instructions. Authorized Representative: Application for Federal Assistance SF-424 * a. Applicant Attach an additional list of Program/Project Congressional Districts if needed. * b. Program/Project * a. Start Date:* b. End Date: 16. Congressional Districts Of: 17. Proposed Project: MI-008 Add Attachment Delete Attachment View Attachment 07/01/2024 06/30/2025 3,645,249.00 1,000,000.00 4,645,249.00 a. This application was made available to the State under the Executive Order 12372 Process for review on b. Program is subject to E.O. 12372 but has not been selected by the State for review. c. Program is not covered by E.O. 12372. Yes No Add Attachment Delete Attachment View Attachment ** I AGREE Mr./Mr.David/David /T. Coulter/Woodward County Executive/Chair Board of Commissioners 248 585-0484/248 858-0100 * 20. Is the Applicant Delinquent On Any Federal Debt? (If "Yes," provide explanation in attachment.) * 19. Is Application Subject to Review By State Under Executive Order 12372 Process? If "Yes", provide explanation and attach coulterd@oakgov.com/woodwardd@oakgov.com MI-009, MI-011, MI-014 Oakland County Urban County Participating Communities: Cities:Auburn Hills, Berkley, Birmingham, Bloomfield Hills, Clarkston, Clawson, Farmington, Ferndale, Hazel Park, Huntington Woods, Keego Harbor, Lathrup Village, Madison Heights, Northville, Novi, Oak Park, Orchard Lake Village, Pleasant Ridge, Rochester, Rochester Hills, South Lyon, Sylvan Lake, Troy, Walled Lake, Wixom Townships: Addison, Bloomfield, Brandon, Commerce, Groveland, Highland, Holly, Independence, Lyon, Milford, Oakland, Orion, Oxford, Rose, Royal Oak, Springfield, West Bloomfield, White Lake Villages: Beverly Hills, Franklin, Holly, Lake Orion, Leonard, Milford, Ortonville, Oxford, Wolverine Lake OMB Number: 4040-0009 Expiration Date: 02/28/2025 ASSURANCES - CONSTRUCTION PROGRAMS PLEASE DO NOT RETURN YOUR COMPLETED FORM TO THE OFFICE OF MANAGEMENT AND BUDGET. SEND IT TO THE ADDRESS PROVIDED BY THE SPONSORING AGENCY. Public reporting burden for this collection of information is estimated to average 15 minutes per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Office of Management and Budget, Paperwork Reduction Project (0348-0042), Washington, DC 20503. Certain of these assurances may not be applicable to your project or program. If you have questions, please contact the Awarding Agency. Further, certain Federal assistance awarding agencies may require applicants to certify to additional assurances. If such is the case, you will be notified. As the duly authorized representative of the applicant:, I certify that the applicant: NOTE: 1.Has the legal authority to apply for Federal assistance, and the institutional, managerial and financial capability (including funds sufficient to pay the non-Federal share of project costs) to ensure proper planning, management and completion of project described in this application. 2.Will give the awarding agency, the Comptroller General of the United States and, if appropriate, the State, the right to examine all records, books, papers, or documents related to the assistance; and will establish a proper accounting system in accordance with generally accepted accounting standards or agency directives. 3.Will not dispose of, modify the use of, or change the terms of the real property title or other interest in the site and facilities without permission and instructions from the awarding agency. Will record the Federal awarding agency directives and will include a covenant in the title of real property acquired in whole or in part with Federal assistance funds to assure non- discrimination during the useful life of the project. 4.Will comply with the requirements of the assistance awarding agency with regard to the drafting, review and approval of construction plans and specifications. 5.Will provide and maintain competent and adequate engineering supervision at the construction site to ensure that the complete work conforms with the approved plans and specifications and will furnish progressive reports and such other information as may be required by the assistance awarding agency or State. 6.Will initiate and complete the work within the applicable time frame after receipt of approval of the awarding agency. 7.Will establish safeguards to prohibit employees from using their positions for a purpose that constitutes or presents the appearance of personal or organizational conflict of interest, or personal gain. 8.Will comply with the Intergovernmental Personnel Act of 1970 (42 U.S.C. §§4728-4763) relating to prescribed standards of merit systems for programs funded under one of the 19 statutes or regulations specified in Appendix A of OPM's Standards for a Merit System of Personnel Administration (5 C.F.R. 900, Subpart F). 9.Will comply with the Lead-Based Paint Poisoning Prevention Act (42 U.S.C. §§4801 et seq.) which prohibits the use of lead-based paint in construction or rehabilitation of residence structures. 10.Will comply with all Federal statutes relating to non- discrimination. These include but are not limited to: (a) Title VI of the Civil Rights Act of 1964 (P.L. 88-352) which prohibits discrimination on the basis of race, color or national origin; (b) Title IX of the Education Amendments of 1972, as amended (20 U.S.C. §§1681 1683, and 1685-1686), which prohibits discrimination on the basis of sex; (c) Section 504 of the Rehabilitation Act of 1973, as amended (29) U.S.C. §794), which prohibits discrimination on the basis of handicaps; (d) the Age Discrimination Act of 1975, as amended (42 U.S.C. §§6101-6107), which prohibits discrimination on the basis of age; (e) the Drug Abuse Office and Treatment Act of 1972 (P.L. 92-255), as amended relating to nondiscrimination on the basis of drug abuse; (f) the Comprehensive Alcohol Abuse and Alcoholism Prevention, Treatment and Rehabilitation Act of 1970 (P.L. 91-616), as amended, relating to nondiscrimination on the basis of alcohol abuse or alcoholism; (g) §§523 and 527 of the Public Health Service Act of 1912 (42 U.S.C. §§290 dd-3 and 290 ee 3), as amended, relating to confidentiality of alcohol and drug abuse patient records; (h) Title VIII of the Civil Rights Act of 1968 (42 U.S.C. §§3601 et seq.), as amended, relating to nondiscrimination in the sale, rental or financing of housing; (i) any other nondiscrimination provisions in the specific statue(s) under which application for Federal assistance is being made; and (j) the requirements of any other nondiscrimination statue(s) which may apply to the application. Previous Edition Usable Authorized for Local Reproduction Standard Form 424D (Rev. 7-97) Prescribed by OMB Circular A-102 11.Will comply, or has already complied, with the requirements of Titles II and III of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (P.L. 91-646) which provide for fair and equitable treatment of persons displaced or whose property is acquired as a result of Federal and federally-assisted programs. These requirements apply to all interests in real property acquired for project purposes regardless of Federal participation in purchases. 12.Will comply with the provisions of the Hatch Act (5 U.S.C. §§1501-1508 and 7324-7328) which limit the political activities of employees whose principal employment activities are funded in whole or in part with Federal funds. 13.Will comply, as applicable, with the provisions of the Davis- Bacon Act (40 U.S.C. §§276a to 276a-7), the Copeland Act (40 U.S.C. §276c and 18 U.S.C. §874), and the Contract Work Hours and Safety Standards Act (40 U.S.C. §§327- 333) regarding labor standards for federally-assisted construction subagreements. 14.Will comply with flood insurance purchase requirements of Section 102(a) of the Flood Disaster Protection Act of 1973 (P.L. 93-234) which requires recipients in a special flood hazard area to participate in the program and to purchase flood insurance if the total cost of insurable construction and acquisition is $10,000 or more. 15.Will comply with environmental standards which may be prescribed pursuant to the following: (a) institution of environmental quality control measures under the National Environmental Policy Act of 1969 (P.L. 91- 190) and Executive Order (EO) 11514; (b) notification of violating facilities pursuant to EO 11738; (c) protection of wetlands pursuant to EO 11990; (d) evaluation of flood hazards in floodplains in accordance with EO 11988; (e) assurance of project consistency with the approved State management program developed under the Coastal Zone Management Act of 1972 (16 U.S.C. §§1451 et seq.); (f) conformity of Federal actions to State (Clean Air) implementation Plans under Section 176(c) of the Clean Air Act of 1955, as amended (42 U.S.C. §§7401 et seq.); (g) protection of underground sources of drinking water under the Safe Drinking Water Act of 1974, as amended (P.L. 93-523); and, (h) protection of endangered species under the Endangered Species Act of 1973, as amended (P.L. 93-205). 16.Will comply with the Wild and Scenic Rivers Act of 1968 (16 U.S.C. §§1271 et seq.) related to protecting components or potential components of the national wild and scenic rivers system. 17.Will assist the awarding agency in assuring compliance with Section 106 of the National Historic Preservation Act of 1966, as amended (16 U.S.C. §470), EO 11593 (identification and protection of historic properties), and the Archaeological and Historic Preservation Act of 1974 (16 U.S.C. §§469a-1 et seq). 18.Will cause to be performed the required financial and compliance audits in accordance with the Single Audit Act Amendments of 1996 and OMB Circular No. A-133, "Audits of States, Local Governments, and Non-Profit Organizations." 19.Will comply with all applicable requirements of all other Federal laws, executive orders, regulations, and policies governing this program. SIGNATURE OF AUTHORIZED CERTIFYING OFFICIAL TITLE SF-424D (Rev. 7-97) Back APPLICANT ORGANIZATION DATE SUBMITTED County Executive/Chair Board of Commissioners County of Oakland, Michigan David Coulter/David T. Woodward 20.Will comply with the requirements of Section 106(g) of the Trafficking Victims Protection Act (TVPA) of 2000, as amended (22 U.S.C. 7104) which prohibits grant award recipients or a sub-recipient from (1) Engaging in severe forms of trafficking in persons during the period of time that the award is in effect (2) Procuring a commercial sex act during the period of time that the award is in effect or (3) Using forced labor in the performance of the award or subawards under the award. OMB Number: 4040-0004 Expiration Date: 11/30/2025 * 1. Type of Submission:* 2. Type of Application: * 3. Date Received: 4. Applicant Identifier: 5a. Federal Entity Identifier:5b. Federal Award Identifier: 6. Date Received by State:7. State Application Identifier: * a. Legal Name: * b. Employer/Taxpayer Identification Number (EIN/TIN):* c. UEI: * Street1: Street2: * City: County/Parish: * State: Province: * Country: * Zip / Postal Code: Department Name:Division Name: Prefix:* First Name: Middle Name: * Last Name: Suffix: Title: Organizational Affiliation: * Telephone Number:Fax Number: * Email: * If Revision, select appropriate letter(s): * Other (Specify): State Use Only: 8. APPLICANT INFORMATION: d. Address: e. Organizational Unit: f. Name and contact information of person to be contacted on matters involving this application: Application for Federal Assistance SF-424 Preapplication Application Changed/Corrected Application New Continuation Revision M-24-DC-26-0210 County of Oakland, Michigan 386004876 HZ4EUKDD7AB4 Pontiac Oakland MI: Michigan USA: UNITED STATES 48341-1032 Health and Human Services Khadija Walker-Fobbs Housing Officer 248 230-4536 248 858-5311 walker-fobbsk@oakland.gov Neighborhood and Housing Development 1200 N. Telegraph Rd. 34E * 9. Type of Applicant 1: Select Applicant Type: Type of Applicant 2: Select Applicant Type: Type of Applicant 3: Select Applicant Type: * Other (specify): * 10. Name of Federal Agency: 11. Catalog of Federal Domestic Assistance Number: CFDA Title: * 12. Funding Opportunity Number: * Title: 13. Competition Identification Number: Title: 14. Areas Affected by Project (Cities, Counties, States, etc.): * 15. Descriptive Title of Applicant's Project: Attach supporting documents as specified in agency instructions. Application for Federal Assistance SF-424 B: County Government U.S. Department of Housing and Urban Development 14.239 HOME Investment Partnerships Program M-24-DC-26-0210 HOME Investment Partnerships Program Acquisition, rehabilitation, new construction of affordable rental and/or owner housing and homebuyer assistance in Oakland County HOME Consortium and CDBG participating communities View AttachmentsDelete AttachmentsAdd Attachments View AttachmentDelete AttachmentAdd AttachmentOakland County HOME Consortium * a. Federal * b. Applicant * c. State * d. Local * e. Other * f. Program Income * g. TOTAL . Prefix:* First Name: Middle Name: * Last Name: Suffix: * Title: * Telephone Number: * Email: Fax Number: * Signature of Authorized Representative:* Date Signed: 18. Estimated Funding ($): 21. *By signing this application, I certify (1) to the statements contained in the list of certifications** and (2) that the statements herein are true, complete and accurate to the best of my knowledge. I also provide the required assurances** and agree to comply with any resulting terms if I accept an award. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties. (U.S. Code, Title 18, Section 1001) ** The list of certifications and assurances, or an internet site where you may obtain this list, is contained in the announcement or agency specific instructions. Authorized Representative: Application for Federal Assistance SF-424 * a. Applicant Attach an additional list of Program/Project Congressional Districts if needed. * b. Program/Project * a. Start Date:* b. End Date: 16. Congressional Districts Of: 17. Proposed Project: MI-008 Add Attachment Delete Attachment View Attachment 07/01/2024 06/30/2025 2,293,996.00 516,149.00 1,700,000.00 4,510,145.00 a. This application was made available to the State under the Executive Order 12372 Process for review on b. Program is subject to E.O. 12372 but has not been selected by the State for review. c. Program is not covered by E.O. 12372. Yes No Add Attachment Delete Attachment View Attachment ** I AGREE Mr./Mr.David/David /T. Coulter/Woodward County Executive/Chair Board of Commissioners 248 585-0484/248 858-0100 * 20. Is the Applicant Delinquent On Any Federal Debt? (If "Yes," provide explanation in attachment.) * 19. Is Application Subject to Review By State Under Executive Order 12372 Process? If "Yes", provide explanation and attach MI-009, MI-011, MI-014 coulterd@oakgov.com/woodwardd@oakgov.com Cities: Auburn Hills, Berkley, Birmingham, Bloomfield Hills, Clarkston, Clawson, Farmington, Farmington Hills, Ferndale, Hazel Park, Huntington Woods, Keego Harbor, Lathrup Village, Madison Heights, Northville, Novi, Oak Park, Orchard Lake Village, Pleasant Ridge, Pontiac, Rochester, Rochester Hills, Royal Oak, Southfield, South Lyon, Sylvan Lake, Troy, Walled Lake, Wixom Townships: Addison, Bloomfield, Brandon, Commerce, Groveland, Highland, Holly, Independence, Lyon, Milford, Oakland, Orion, Oxford, Rose, Royal Oak, Springfield, West Bloomfield, White Lake Villages: Beverly Hills, Franklin, Holly, Lake Orion, Leonard, Milford, Ortonville, Oxford, Wolverine Lake OMB Number: 4040-0009 Expiration Date: 02/28/2025 ASSURANCES - CONSTRUCTION PROGRAMS PLEASE DO NOT RETURN YOUR COMPLETED FORM TO THE OFFICE OF MANAGEMENT AND BUDGET. SEND IT TO THE ADDRESS PROVIDED BY THE SPONSORING AGENCY. Public reporting burden for this collection of information is estimated to average 15 minutes per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Office of Management and Budget, Paperwork Reduction Project (0348-0042), Washington, DC 20503. Certain of these assurances may not be applicable to your project or program. If you have questions, please contact the Awarding Agency. Further, certain Federal assistance awarding agencies may require applicants to certify to additional assurances. If such is the case, you will be notified. As the duly authorized representative of the applicant:, I certify that the applicant: NOTE: 1.Has the legal authority to apply for Federal assistance, and the institutional, managerial and financial capability (including funds sufficient to pay the non-Federal share of project costs) to ensure proper planning, management and completion of project described in this application. 2.Will give the awarding agency, the Comptroller General of the United States and, if appropriate, the State, the right to examine all records, books, papers, or documents related to the assistance; and will establish a proper accounting system in accordance with generally accepted accounting standards or agency directives. 3.Will not dispose of, modify the use of, or change the terms of the real property title or other interest in the site and facilities without permission and instructions from the awarding agency. Will record the Federal awarding agency directives and will include a covenant in the title of real property acquired in whole or in part with Federal assistance funds to assure non- discrimination during the useful life of the project. 4.Will comply with the requirements of the assistance awarding agency with regard to the drafting, review and approval of construction plans and specifications. 5.Will provide and maintain competent and adequate engineering supervision at the construction site to ensure that the complete work conforms with the approved plans and specifications and will furnish progressive reports and such other information as may be required by the assistance awarding agency or State. 6.Will initiate and complete the work within the applicable time frame after receipt of approval of the awarding agency. 7.Will establish safeguards to prohibit employees from using their positions for a purpose that constitutes or presents the appearance of personal or organizational conflict of interest, or personal gain. 8.Will comply with the Intergovernmental Personnel Act of 1970 (42 U.S.C. §§4728-4763) relating to prescribed standards of merit systems for programs funded under one of the 19 statutes or regulations specified in Appendix A of OPM's Standards for a Merit System of Personnel Administration (5 C.F.R. 900, Subpart F). 9.Will comply with the Lead-Based Paint Poisoning Prevention Act (42 U.S.C. §§4801 et seq.) which prohibits the use of lead-based paint in construction or rehabilitation of residence structures. 10.Will comply with all Federal statutes relating to non- discrimination. These include but are not limited to: (a) Title VI of the Civil Rights Act of 1964 (P.L. 88-352) which prohibits discrimination on the basis of race, color or national origin; (b) Title IX of the Education Amendments of 1972, as amended (20 U.S.C. §§1681 1683, and 1685-1686), which prohibits discrimination on the basis of sex; (c) Section 504 of the Rehabilitation Act of 1973, as amended (29) U.S.C. §794), which prohibits discrimination on the basis of handicaps; (d) the Age Discrimination Act of 1975, as amended (42 U.S.C. §§6101-6107), which prohibits discrimination on the basis of age; (e) the Drug Abuse Office and Treatment Act of 1972 (P.L. 92-255), as amended relating to nondiscrimination on the basis of drug abuse; (f) the Comprehensive Alcohol Abuse and Alcoholism Prevention, Treatment and Rehabilitation Act of 1970 (P.L. 91-616), as amended, relating to nondiscrimination on the basis of alcohol abuse or alcoholism; (g) §§523 and 527 of the Public Health Service Act of 1912 (42 U.S.C. §§290 dd-3 and 290 ee 3), as amended, relating to confidentiality of alcohol and drug abuse patient records; (h) Title VIII of the Civil Rights Act of 1968 (42 U.S.C. §§3601 et seq.), as amended, relating to nondiscrimination in the sale, rental or financing of housing; (i) any other nondiscrimination provisions in the specific statue(s) under which application for Federal assistance is being made; and (j) the requirements of any other nondiscrimination statue(s) which may apply to the application. Previous Edition Usable Authorized for Local Reproduction Standard Form 424D (Rev. 7-97) Prescribed by OMB Circular A-102 11.Will comply, or has already complied, with the requirements of Titles II and III of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (P.L. 91-646) which provide for fair and equitable treatment of persons displaced or whose property is acquired as a result of Federal and federally-assisted programs. These requirements apply to all interests in real property acquired for project purposes regardless of Federal participation in purchases. 12.Will comply with the provisions of the Hatch Act (5 U.S.C. §§1501-1508 and 7324-7328) which limit the political activities of employees whose principal employment activities are funded in whole or in part with Federal funds. 13.Will comply, as applicable, with the provisions of the Davis- Bacon Act (40 U.S.C. §§276a to 276a-7), the Copeland Act (40 U.S.C. §276c and 18 U.S.C. §874), and the Contract Work Hours and Safety Standards Act (40 U.S.C. §§327- 333) regarding labor standards for federally-assisted construction subagreements. 14.Will comply with flood insurance purchase requirements of Section 102(a) of the Flood Disaster Protection Act of 1973 (P.L. 93-234) which requires recipients in a special flood hazard area to participate in the program and to purchase flood insurance if the total cost of insurable construction and acquisition is $10,000 or more. 15.Will comply with environmental standards which may be prescribed pursuant to the following: (a) institution of environmental quality control measures under the National Environmental Policy Act of 1969 (P.L. 91- 190) and Executive Order (EO) 11514; (b) notification of violating facilities pursuant to EO 11738; (c) protection of wetlands pursuant to EO 11990; (d) evaluation of flood hazards in floodplains in accordance with EO 11988; (e) assurance of project consistency with the approved State management program developed under the Coastal Zone Management Act of 1972 (16 U.S.C. §§1451 et seq.); (f) conformity of Federal actions to State (Clean Air) implementation Plans under Section 176(c) of the Clean Air Act of 1955, as amended (42 U.S.C. §§7401 et seq.); (g) protection of underground sources of drinking water under the Safe Drinking Water Act of 1974, as amended (P.L. 93-523); and, (h) protection of endangered species under the Endangered Species Act of 1973, as amended (P.L. 93-205). 16.Will comply with the Wild and Scenic Rivers Act of 1968 (16 U.S.C. §§1271 et seq.) related to protecting components or potential components of the national wild and scenic rivers system. 17.Will assist the awarding agency in assuring compliance with Section 106 of the National Historic Preservation Act of 1966, as amended (16 U.S.C. §470), EO 11593 (identification and protection of historic properties), and the Archaeological and Historic Preservation Act of 1974 (16 U.S.C. §§469a-1 et seq). 18.Will cause to be performed the required financial and compliance audits in accordance with the Single Audit Act Amendments of 1996 and OMB Circular No. A-133, "Audits of States, Local Governments, and Non-Profit Organizations." 19.Will comply with all applicable requirements of all other Federal laws, executive orders, regulations, and policies governing this program. SIGNATURE OF AUTHORIZED CERTIFYING OFFICIAL TITLE SF-424D (Rev. 7-97) Back APPLICANT ORGANIZATION DATE SUBMITTED County Executive/Chair Board of Commissioners County of Oakland, Michigan David Coulter/David T. Woodward 20.Will comply with the requirements of Section 106(g) of the Trafficking Victims Protection Act (TVPA) of 2000, as amended (22 U.S.C. 7104) which prohibits grant award recipients or a sub-recipient from (1) Engaging in severe forms of trafficking in persons during the period of time that the award is in effect (2) Procuring a commercial sex act during the period of time that the award is in effect or (3) Using forced labor in the performance of the award or subawards under the award. OMB Number: 4040-0004 Expiration Date: 11/30/2025 * 1. Type of Submission:* 2. Type of Application: * 3. Date Received: 4. Applicant Identifier: 5a. Federal Entity Identifier:5b. Federal Award Identifier: 6. Date Received by State:7. State Application Identifier: * a. Legal Name: * b. Employer/Taxpayer Identification Number (EIN/TIN):* c. UEI: * Street1: Street2: * City: County/Parish: * State: Province: * Country: * Zip / Postal Code: Department Name:Division Name: Prefix:* First Name: Middle Name: * Last Name: Suffix: Title: Organizational Affiliation: * Telephone Number:Fax Number: * Email: * If Revision, select appropriate letter(s): * Other (Specify): State Use Only: 8. APPLICANT INFORMATION: d. Address: e. Organizational Unit: f. Name and contact information of person to be contacted on matters involving this application: Application for Federal Assistance SF-424 Preapplication Application Changed/Corrected Application New Continuation Revision E-24-UC-26-0002 County of Oakland, Michigan 386004876 HZ4EUKDD7AB4 Pontiac Oakland MI: Michigan USA: UNITED STATES 48341-1032 Health and Human Services Khadija Walker-Fobbs Housing Officer 248 230-4536 248 858-5311 walker-fobbsk@oakland.gov Neighborhood and Housing Development 1200 N. Telegraph Rd. 34E * 9. Type of Applicant 1: Select Applicant Type: Type of Applicant 2: Select Applicant Type: Type of Applicant 3: Select Applicant Type: * Other (specify): * 10. Name of Federal Agency: 11. Catalog of Federal Domestic Assistance Number: CFDA Title: * 12. Funding Opportunity Number: * Title: 13. Competition Identification Number: Title: 14. Areas Affected by Project (Cities, Counties, States, etc.): * 15. Descriptive Title of Applicant's Project: Attach supporting documents as specified in agency instructions. Application for Federal Assistance SF-424 B: County Government U.S. Department of Housing and Urban Development 14.231 Emergency Solutions Grant E-24-UC-26-0002 Emergency Solutions Grant Emergency Shelter, Homeless Prevention and Rapid Re-Housing, HMIS, and Administration View AttachmentsDelete AttachmentsAdd Attachments View AttachmentDelete AttachmentAdd AttachmentSee Attachment B * a. Federal * b. Applicant * c. State * d. Local * e. Other * f. Program Income * g. TOTAL . Prefix:* First Name: Middle Name: * Last Name: Suffix: * Title: * Telephone Number: * Email: Fax Number: * Signature of Authorized Representative:* Date Signed: 18. Estimated Funding ($): 21. *By signing this application, I certify (1) to the statements contained in the list of certifications** and (2) that the statements herein are true, complete and accurate to the best of my knowledge. I also provide the required assurances** and agree to comply with any resulting terms if I accept an award. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties. (U.S. Code, Title 18, Section 1001) ** The list of certifications and assurances, or an internet site where you may obtain this list, is contained in the announcement or agency specific instructions. Authorized Representative: Application for Federal Assistance SF-424 * a. Applicant Attach an additional list of Program/Project Congressional Districts if needed. * b. Program/Project * a. Start Date:* b. End Date: 16. Congressional Districts Of: 17. Proposed Project: MI-008 Add Attachment Delete Attachment View Attachment 07/01/2024 06/30/2025 322,021.00 322,021.00 a. This application was made available to the State under the Executive Order 12372 Process for review on b. Program is subject to E.O. 12372 but has not been selected by the State for review. c. Program is not covered by E.O. 12372. Yes No Add Attachment Delete Attachment View Attachment ** I AGREE Mr./Mr.David/David /T. Coulter/Woodward County Executive/Chair Board of Commissioners 248 585-0484/248 858-0100 * 20. Is the Applicant Delinquent On Any Federal Debt? (If "Yes," provide explanation in attachment.) * 19. Is Application Subject to Review By State Under Executive Order 12372 Process? If "Yes", provide explanation and attach MI-009, MI-011, MI-014 coulterd@oakgov.com/woodwardd@oakgov.com A Oakland County Urban County Participating Communities: Cities: Auburn Hills, Berkley, Birmingham, Bloomfield Hills, Clarkston, Clawson, Farmington, Ferndale, Hazel Park, Huntington Woods, Keego Harbor, Lathrup Village, Madison Heights, Northville, Novi, Oak Park, Orchard Lake Village, Pleasant Ridge, Rochester, Rochester Hills, South Lyon, Sylvan Lake, Troy, Walled Lake, Wixom Townships: Addison, Bloomfield, Brandon, Commerce, Groveland, Highland, Holly, Independence, Lyon, Milford, Oakland, Orion, Oxford, Rose, Royal Oak, Springfield, West Bloomfield, White Lake Villages: Beverly Hills, Franklin, Holly, Lake Orion, Leonard, Milford, Ortonville, Oxford, Wolverine Lake OMB Number: 4040-0009 Expiration Date: 02/28/2025 ASSURANCES - CONSTRUCTION PROGRAMS PLEASE DO NOT RETURN YOUR COMPLETED FORM TO THE OFFICE OF MANAGEMENT AND BUDGET. SEND IT TO THE ADDRESS PROVIDED BY THE SPONSORING AGENCY. Public reporting burden for this collection of information is estimated to average 15 minutes per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Office of Management and Budget, Paperwork Reduction Project (0348-0042), Washington, DC 20503. Certain of these assurances may not be applicable to your project or program. If you have questions, please contact the Awarding Agency. Further, certain Federal assistance awarding agencies may require applicants to certify to additional assurances. If such is the case, you will be notified. As the duly authorized representative of the applicant:, I certify that the applicant: NOTE: 1.Has the legal authority to apply for Federal assistance, and the institutional, managerial and financial capability (including funds sufficient to pay the non-Federal share of project costs) to ensure proper planning, management and completion of project described in this application. 2.Will give the awarding agency, the Comptroller General of the United States and, if appropriate, the State, the right to examine all records, books, papers, or documents related to the assistance; and will establish a proper accounting system in accordance with generally accepted accounting standards or agency directives. 3.Will not dispose of, modify the use of, or change the terms of the real property title or other interest in the site and facilities without permission and instructions from the awarding agency. Will record the Federal awarding agency directives and will include a covenant in the title of real property acquired in whole or in part with Federal assistance funds to assure non- discrimination during the useful life of the project. 4.Will comply with the requirements of the assistance awarding agency with regard to the drafting, review and approval of construction plans and specifications. 5.Will provide and maintain competent and adequate engineering supervision at the construction site to ensure that the complete work conforms with the approved plans and specifications and will furnish progressive reports and such other information as may be required by the assistance awarding agency or State. 6.Will initiate and complete the work within the applicable time frame after receipt of approval of the awarding agency. 7.Will establish safeguards to prohibit employees from using their positions for a purpose that constitutes or presents the appearance of personal or organizational conflict of interest, or personal gain. 8.Will comply with the Intergovernmental Personnel Act of 1970 (42 U.S.C. §§4728-4763) relating to prescribed standards of merit systems for programs funded under one of the 19 statutes or regulations specified in Appendix A of OPM's Standards for a Merit System of Personnel Administration (5 C.F.R. 900, Subpart F). 9.Will comply with the Lead-Based Paint Poisoning Prevention Act (42 U.S.C. §§4801 et seq.) which prohibits the use of lead-based paint in construction or rehabilitation of residence structures. 10.Will comply with all Federal statutes relating to non- discrimination. These include but are not limited to: (a) Title VI of the Civil Rights Act of 1964 (P.L. 88-352) which prohibits discrimination on the basis of race, color or national origin; (b) Title IX of the Education Amendments of 1972, as amended (20 U.S.C. §§1681 1683, and 1685-1686), which prohibits discrimination on the basis of sex; (c) Section 504 of the Rehabilitation Act of 1973, as amended (29) U.S.C. §794), which prohibits discrimination on the basis of handicaps; (d) the Age Discrimination Act of 1975, as amended (42 U.S.C. §§6101-6107), which prohibits discrimination on the basis of age; (e) the Drug Abuse Office and Treatment Act of 1972 (P.L. 92-255), as amended relating to nondiscrimination on the basis of drug abuse; (f) the Comprehensive Alcohol Abuse and Alcoholism Prevention, Treatment and Rehabilitation Act of 1970 (P.L. 91-616), as amended, relating to nondiscrimination on the basis of alcohol abuse or alcoholism; (g) §§523 and 527 of the Public Health Service Act of 1912 (42 U.S.C. §§290 dd-3 and 290 ee 3), as amended, relating to confidentiality of alcohol and drug abuse patient records; (h) Title VIII of the Civil Rights Act of 1968 (42 U.S.C. §§3601 et seq.), as amended, relating to nondiscrimination in the sale, rental or financing of housing; (i) any other nondiscrimination provisions in the specific statue(s) under which application for Federal assistance is being made; and (j) the requirements of any other nondiscrimination statue(s) which may apply to the application. Previous Edition Usable Authorized for Local Reproduction Standard Form 424D (Rev. 7-97) Prescribed by OMB Circular A-102 11.Will comply, or has already complied, with the requirements of Titles II and III of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (P.L. 91-646) which provide for fair and equitable treatment of persons displaced or whose property is acquired as a result of Federal and federally-assisted programs. These requirements apply to all interests in real property acquired for project purposes regardless of Federal participation in purchases. 12.Will comply with the provisions of the Hatch Act (5 U.S.C. §§1501-1508 and 7324-7328) which limit the political activities of employees whose principal employment activities are funded in whole or in part with Federal funds. 13.Will comply, as applicable, with the provisions of the Davis- Bacon Act (40 U.S.C. §§276a to 276a-7), the Copeland Act (40 U.S.C. §276c and 18 U.S.C. §874), and the Contract Work Hours and Safety Standards Act (40 U.S.C. §§327- 333) regarding labor standards for federally-assisted construction subagreements. 14.Will comply with flood insurance purchase requirements of Section 102(a) of the Flood Disaster Protection Act of 1973 (P.L. 93-234) which requires recipients in a special flood hazard area to participate in the program and to purchase flood insurance if the total cost of insurable construction and acquisition is $10,000 or more. 15.Will comply with environmental standards which may be prescribed pursuant to the following: (a) institution of environmental quality control measures under the National Environmental Policy Act of 1969 (P.L. 91- 190) and Executive Order (EO) 11514; (b) notification of violating facilities pursuant to EO 11738; (c) protection of wetlands pursuant to EO 11990; (d) evaluation of flood hazards in floodplains in accordance with EO 11988; (e) assurance of project consistency with the approved State management program developed under the Coastal Zone Management Act of 1972 (16 U.S.C. §§1451 et seq.); (f) conformity of Federal actions to State (Clean Air) implementation Plans under Section 176(c) of the Clean Air Act of 1955, as amended (42 U.S.C. §§7401 et seq.); (g) protection of underground sources of drinking water under the Safe Drinking Water Act of 1974, as amended (P.L. 93-523); and, (h) protection of endangered species under the Endangered Species Act of 1973, as amended (P.L. 93-205). 16.Will comply with the Wild and Scenic Rivers Act of 1968 (16 U.S.C. §§1271 et seq.) related to protecting components or potential components of the national wild and scenic rivers system. 17.Will assist the awarding agency in assuring compliance with Section 106 of the National Historic Preservation Act of 1966, as amended (16 U.S.C. §470), EO 11593 (identification and protection of historic properties), and the Archaeological and Historic Preservation Act of 1974 (16 U.S.C. §§469a-1 et seq). 18.Will cause to be performed the required financial and compliance audits in accordance with the Single Audit Act Amendments of 1996 and OMB Circular No. A-133, "Audits of States, Local Governments, and Non-Profit Organizations." 19.Will comply with all applicable requirements of all other Federal laws, executive orders, regulations, and policies governing this program. SIGNATURE OF AUTHORIZED CERTIFYING OFFICIAL TITLE SF-424D (Rev. 7-97) Back APPLICANT ORGANIZATION DATE SUBMITTED County Executive/Chair Board of Commissioners County of Oakland, Michigan David Coulter/David T. Woodward 20.Will comply with the requirements of Section 106(g) of the Trafficking Victims Protection Act (TVPA) of 2000, as amended (22 U.S.C. 7104) which prohibits grant award recipients or a sub-recipient from (1) Engaging in severe forms of trafficking in persons during the period of time that the award is in effect (2) Procuring a commercial sex act during the period of time that the award is in effect or (3) Using forced labor in the performance of the award or subawards under the award. CERTIFICATIONS In accordance with the applicable statutes and the regulations governing the consolidated plan regulations, the jurisdiction certifies that: Affirmatively Further Fair Housing --The jurisdiction will affirmatively further fair housing. Uniform Relocation Act and Anti-displacement and Relocation Plan -- It will comply with the acquisition and relocation requirements of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended, (42 U.S.C. 4601-4655) and implementing regulations at 49 CFR Part 24. It has in effect and is following a residential anti-displacement and relocation assistance plan required under 24 CFR Part 42 in connection with any activity assisted with funding under the Community Development Block Grant or HOME programs. Anti-Lobbying --To the best of the jurisdiction's knowledge and belief: 1.No Federal appropriated funds have been paid or will be paid, by or on behalf of it, to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement; 2.If any funds other than Federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with this Federal contract, grant, loan, or cooperative agreement, it will complete and submit Standard Form-LLL, "Disclosure Form to Report Lobbying," in accordance with its instructions; and 3.It will require that the language of paragraph 1 and 2 of this anti-lobbying certification be included in the award documents for all subawards at all tiers (including subcontracts, subgrants, and contracts under grants, loans, and cooperative agreements) and that all subrecipients shall certify and disclose accordingly. Authority of Jurisdiction --The consolidated plan is authorized under State and local law (as applicable) and the jurisdiction possesses the legal authority to carry out the programs for which it is seeking funding, in accordance with applicable HUD regulations. Consistency with plan --The housing activities to be undertaken with Community Development Block Grant, HOME, Emergency Solutions Grant, and Housing Opportunities for Persons With AIDS funds are consistent with the strategic plan in the jurisdiction’s consolidated plan. Section 3 -- It will comply with section 3 of the Housing and Urban Development Act of 1968 (12 U.S.C. 1701u) and implementing regulations at 24 CFR Part 75. Signature of Authorized Official David Coulter County Executive Date Signature of Authorized Official David T. Woodward Chairperson, Board of Commissioners Date Specific Community Development Block Grant Certifications The Entitlement Community certifies that: Citizen Participation -- It is in full compliance and following a detailed citizen participation plan that satisfies the requirements of 24 CFR 91.105. Community Development Plan -- Its consolidated plan identifies community development and housing needs and specifies both short-term and long-term community development objectives that that have been developed in accordance with the primary objective of the CDBG program (i.e., the development of viable urban communities, by providing decent housing and expanding economic opportunities, primarily for persons of low and moderate income) and requirements of 24 CFR Parts 91 and 570. Following a Plan -- It is following a current consolidated plan that has been approved by HUD. Use of Funds -- It has complied with the following criteria: 1.Maximum Feasible Priority. With respect to activities expected to be assisted with CDBG funds, it has developed its Action Plan so as to give maximum feasible priority to activities which benefit low- and moderate-income families or aid in the prevention or elimination of slums or blight. The Action Plan may also include CDBG-assisted activities which the grantee certifies are designed to meet other community development needs having particular urgency because existing conditions pose a serious and immediate threat to the health or welfare of the community, and other financial resources are not available (see Optional CDBG Certification). 2.Overall Benefit. The aggregate use of CDBG funds, including Section 108 guaranteed loans, during program year(s) 2024 [a period specified by the grantee of one, two, or three specific consecutive program years], shall principally benefit persons of low and moderate income in a manner that ensures that at least 70 percent of the amount is expended for activities that benefit such persons during the designated period. 3. Special Assessments. It will not attempt to recover any capital costs of public improvements assisted with CDBG funds, including Section 108 loan guaranteed funds, by assessing any amount against properties owned and occupied by persons of low and moderate income, including any fee charged or assessment made as a condition of obtaining access to such public improvements. However, if CDBG funds are used to pay the proportion of a fee or assessment that relates to the capital costs of public improvements (assisted in part with CDBG funds) financed from other revenue sources, an assessment or charge may be made against the property with respect to the public improvements financed by a source other than CDBG funds. In addition, in the case of properties owned and occupied by moderate-income (not low-income) families, an assessment or charge may be made against the property for public improvements financed by a source other than CDBG funds if the jurisdiction certifies that it lacks CDBG funds to cover the assessment. Excessive Force -- It has adopted and is enforcing: 1. A policy prohibiting the use of excessive force by law enforcement agencies within its jurisdiction against any individuals engaged in non-violent civil rights demonstrations; and 2. A policy of enforcing applicable State and local laws against physically barring entrance to or exit from a facility or location which is the subject of such non-violent civil rights demonstrations within its jurisdiction. Compliance with Anti-discrimination laws -- The grant will be conducted and administered in conformity with title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d) and the Fair Housing Act (42 U.S.C. 3601-3619) and implementing regulations. Lead-Based Paint -- Its activities concerning lead-based paint will comply with the requirements of 24 CFR Part 35, Subparts A, B, J, K and R. Compliance with Laws -- It will comply with applicable laws. Signature of Authorized Official David Coulter County Executive Date Signature of Authorized Official David T. Woodward Chairperson, Board of Commissioners Date APPENDIX TO CERTIFICATIONS INSTRUCTIONS CONCERNING LOBBYING CERTIFICATION: Lobbying Certification This certification is a material representation of fact upon which reliance was placed when this transaction was made or entered into. Submission of this certification is a prerequisite for making or entering into this transaction imposed by section 1352, title 31, U.S. Code. Any person who fails to file the required certification shall be subject to a civil penalty of not less than $10,000 and not more than $100,000 for each such failure. OPTIONAL Community Development Block Grant Certification Submit the following certification only when one or more of the activities in the action plan are designed to meet other community development needs having particular urgency as specified in 24 CFR 570.208(c): The grantee hereby certifies that the Annual Plan includes one or more specifically identified CDBG- assisted activities which are designed to meet other community development needs having particular urgency because existing conditions pose a serious and immediate threat to the health or welfare of the community and other financial resources are not available to meet such needs. Signature of Authorized Official David Coulter County Executive Date Signature of Authorized Official David T. Woodward Chairperson, Board of Commissioners Date Specific HOME Certifications The HOME participating jurisdiction certifies that: Tenant Based Rental Assistance -- If it plans to provide tenant-based rental assistance, the tenant-based rental assistance is an essential element of its consolidated plan. Eligible Activities and Costs -- It is using and will use HOME funds for eligible activities and costs, as described in 24 CFR §§92.205 through 92.209 and that it is not using and will not use HOME funds for prohibited activities, as described in §92.214. Subsidy layering -- Before committing any funds to a project, it will evaluate the project in accordance with the guidelines that it adopts for this purpose and will not invest any more HOME funds in combination with other Federal assistance than is necessary to provide affordable housing; Signature of Authorized Official David Coulter County Executive Date Signature of Authorized Official David T. Woodward Chairperson, Board of Commissioners Date Emergency Solutions Grants Certifications The Emergency Solutions Grants Program recipient certifies that: Major rehabilitation/conversion/renovation – If an emergency shelter’s rehabilitation costs exceed 75 percent of the value of the building before rehabilitation, the recipient will maintain the building as a shelter for homeless individuals and families for a minimum of 10 years after the date the building is first occupied by a homeless individual or family after the completed rehabilitation. If the cost to convert a building into an emergency shelter exceeds 75 percent of the value of the building after conversion, the recipient will maintain the building as a shelter for homeless individuals and families for a minimum of 10 years after the date the building is first occupied by a homeless individual or family after the completed conversion. In all other cases where ESG funds are used for renovation, the recipient will maintain the building as a shelter for homeless individuals and families for a minimum of 3 years after the date the building is first occupied by a homeless individual or family after the completed renovation. Essential Services and Operating Costs – In the case of assistance involving shelter operations or essential services related to street outreach or emergency shelter, the recipient will provide services or shelter to homeless individuals and families for the period during which the ESG assistance is provided, without regard to a particular site or structure, so long the recipient serves the same type of persons (e.g., families with children, unaccompanied youth, disabled individuals, or victims of domestic violence) or persons in the same geographic area. Renovation – Any renovation carried out with ESG assistance shall be sufficient to ensure that the building involved is safe and sanitary. Supportive Services – The recipient will assist homeless individuals in obtaining permanent housing, appropriate supportive services (including medical and mental health treatment, victim services, counseling, supervision, and other services essential for achieving independent living), and other Federal State, local, and private assistance available for these individuals. Matching Funds – The recipient will obtain matching amounts required under 24 CFR 576.201. Confidentiality – The recipient has established and is implementing procedures to ensure the confidentiality of records pertaining to any individual provided family violence prevention or treatment services under any project assisted under the ESG program, including protection against the release of the address or location of any family violence shelter project, except with the written authorization of the person responsible for the operation of that shelter. Homeless Persons Involvement – To the maximum extent practicable, the recipient will involve, through employment, volunteer services, or otherwise, homeless individuals and families in constructing, renovating, maintaining, and operating facilities assisted under the ESG program, in providing services assisted under the ESG program, and in providing services for occupants of facilities assisted under the program. Consolidated Plan – All activities the recipient undertakes with assistance under ESG are consistent with its consolidated plan. Discharge Policy – The recipient will establish and implement, to the maximum extent practicable and where appropriate, policies and protocols for the discharge of persons from publicly funded institutions or systems of care (such as health care facilities, mental health facilities, foster care or other youth facilities, or correction programs and institutions) in order to prevent this discharge from immediately resulting in homelessness for these persons. Signature of Authorized Official David Coulter County Executive Date Signature of Authorized Official David T. Woodward Chairperson, Board of Commissioners Date