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HomeMy WebLinkAbout042-R-21 Approving the Amended Citizen Participation Plan for the City’s 2021 Action Plan3/24/2021 42-R-21 A RESOLUTION Approving the Amended Citizen Participation Plan for the City's 2021 Action Plan WHEREAS„ the Congress of the United States did pass Public Law 93-383, Title I of the Housing .and Community Development Act of 1974 (which established the Community Development Block Grant {CDBG} Program); Public Law 101-625, the Cranston -Gonzales ,National Affordable Housing Act (which established the HOME Investment Partnerships Program); and Public Law 100-77, the Stewart B. McKinney Homeless Assistance Act (which established the Emergency Solutions Grants (ESG) Program); and WHEREAS, the City of Evanston is an "Entitlement City" by definition in said Acts and, as such, is eligible to make application to the United States Department of Housing and Urban Development (HUD) for said grant programs; and WHEREAS, the City of Evanston, as a HUD entitlement community, is required to submit its Consolidated Plan periodically (3-5 years) and its annual Action Plan to HUD that states its plan and specific strategies to develop viable urban communities by providing decent housing, a suitable living environment, and expanding economic opportunities principally for low- and moderate -income persons. Said plan is to detail community planning and development programs, as well as housing programs, against whose goals the plan and the jurisdiction's performance under the plan will be evaluated by HUD; and 42-R-21 WHEREAS, HUD requires jurisdictions to encourage citizen participation in the development of any Consolidated Plan, annual Action Plan and Consolidated Annual Performance and Evaluation Report to encourage participation by low- and moderate -income persons, particularly those living in areas where CDBG funds are proposed to be used, and in order to achieve such requirement, jurisdictions shall develop and adopt a Citizen Participation Plan which, when approved by HUD, shall allow greater flexibility in the use of CDBG funds in the revitalization area(s) as described in 24 C.F.R. §§ 570.200-.913 (2014), as amended. Each Citizen Participation Plan must afford citizens a reasonable opportunity to comment on the Citizen Participation Plan and any amendments thereafter, and make said Citizen Participation Plan or subsequent amendments publicly accessible, as well as fulfill any and all requirements set forth in 24 C.F.R. § 91.105 (2014), as amended. WHEREAS, the Community Development Department of the City of Evanston, as the lead agency for the development of the 2021 Action Plan, developed said plan with detailed analyses of housing and community development needs; and priority needs of the community and strategies to address those priority needs; in accordance with the Consolidated Plan Regulation, 24 C.F.R. §§ 91.1-.600 (2014), as amended; and WHEREAS, the Amended Citizen Participation Plan for the City's proposed 2021 Action Plan included the required citizen participation and consultation; and WHEREAS, the City Council's Housing and Community Development Act Committee is charged with oversight of the City's CDBG program; the Evanston 42-R-21 Housing and Homelessness Commission is charged with oversight of the City's HOME and Emergency Solutions Grant programs; and WHEREAS, the City published a draft of the 2021 Action Plan, including the Amended Citizen Participation Plan, for public comment from November 16, 2020, to December 15, 2020; and the Housing and Community Development Act Committee conducted a public hearing to receive input on the plan on December 15, 2020, and recommends approval by the Evanston City Council of the aforementioned Citizen Participation Plan NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF EVANSTON, COOK COUNTY, ILLINOIS: SECTION 1: That the Amended Citizen Participation Plan for the City's Proposed 2021 Action Plan (attached hereto as Exhibit A and incorporated herein by reference) is approved. SECTION 2: That the City Manager of the City of Evanston is hereby authorized to transmit said Amended Citizen Participation Plan, to the U.S. Department of Housing and Urban Development (HUD) and to provide any additional information as may be required by HUD. SECTION 3: That this resolution shall be in full force and effect from and after the date of its passage and approval in the manner provided by law. Attest: idxow-do Gomez Eduardo Gomez, Deputy City Clerk Adopted: April 12 , 2021 oLvi 41)Ar� Stephen H. Hagerty, Mayor Approved as to form: vf,� dal e. Ccta� Nicholas E. Cummings, Corporation Counsel 42-R-21 EXHIBITA Amended Citizen Participation Plan for the City's Proposed 2021 Action Plan Amended Citizen Participation Plan City of Evanston Citizen Participation Plan Amendments for Citizen Comment 11/16 - 12/15/2020 Changes highlighted in blue Introduction and Purpose As a recipient of Community Development Block Grant (CDBG), HOME Investment Partnerships (HOME) and Emergency Solutions Grant (ESG) entitlement funds from the U.S. Department of Housing and Urban Development (HUD), the City of Evanston is required to develop a Consolidated Plan and annual Action Plans to guide its use of those funds, and Consolidated Annual Performance and Evaluation Reports (CAPER) to report accomplishments against the goals of those plans. The City is also responsible for engaging the public in all phases of the development of its Consolidated Planning process. In addition to consulting with public and private agencies to define community needs and resources available to address them, the City encourages participation from all residents, particularly low- and moderate -income residents, non-English speaking residents, persons with disabilities, and other segments that receive services funded by its entitlement grants, to expand their participation in the Consolidated Planning process. The City of Evanston's Citizen Participation Plan (CPP) outlines the policies and procedures the City has developed to encourage Evanston residents and stakeholders to participate in the development of the City's Consolidated Plans, annual Action Plans and Consolidated Annual Performance and Evaluation Reports (CAPER), as well as any substantial amendments to the Consolidated Plan or Action Plans. The CPP is designed in accordance with Section 104 (a) of the Housing and Community Development Act of 1974, codified at 42 U.S.C. Section 5304 (a) and 24 CFR Part 91.105. The City's Community Development Department is the lead agency with responsibility for the Consolidated Planning process, including implementation of its Citizen Participation Plan. Development of the Consolidated Plan and Action Plans Community Development staff employ online surveys and public meetings to get input on the housing, community and economic development needs and priorities from its residents for the development of the Consolidated Plan. Surveys, focus groups and individual conferences are used to get input from housing providers, non-profit services providers, public agencies and elected and appointed officials. The City's Housing & Community Development Act Committee holds one or more meetings to solicit input regarding needs in the community and to hear public comment on the priorities and activities proposed in the plans. A draft of the Consolidated Plan and/or Action Plan is posted on the City's website and printed copies are made available at the Lorraine H. Morton Civic Center during the required 30-day comment period. Public input on the plan is sought by the Housing & Community Development 1 City of Evanston Citizen Participation Plan Act Committee at a public meeting and in written form during the 30-day comment period. The committee recommends approval of the plans to City Council subsequent to that process. City Council meetings at which action to adopt or approve the plans is taken also offer opportunity for public comment. Any public comments received during the comment period or at the public meetings is summarized and attached to the Consolidated Plan and/or Action Plan prior to its submission to HUD, including any comments or views that are not accepted and the reasons for which they are not accepted. Consolidated Plans and Action Plans must be approved by City Council prior to the end of the preceding calendar year to ensure expenses incurred by CDBG funded programs can be charged starting January 1st, the beginning of the City's fiscal year. Action Plans are submitted to HUD once the city is in receipt of final grant amounts. Needs Assessment - CARES Act Substantial Amendment to the 2019 Action Plan Housing and Grants staff received input on the needs resulting from the COVID-19 pandemic from Evanston stakeholders and residents during the development of the CARES Act substantial amendment. Sources include: • Mayor Hagerty's COVID-19 Task Force comprising key members of the education, government, business, faith, nonprofit, health, and senior communities. Organizations include AMITA Health Saint Francis Hospital, NorthShore University HealthSystem, Representative Jan Schakowsky, State Senator Laura Fine, State Representatives Robyn Gabel and Jennifer Gong-Gershowitz, Cook County Commissioner Larry Suffredin, Evanston senior living communities, Evanston Chamber of Commerce, Evanston Community Foundation, Interfaith clergy and leaders, Evanston Own It, Northwestern University, Evanston/Skokie School District 6S, and Evanston Township High School District 202. The task force has been met at least weekly since 3/17/2020. • City of Evanston Emergency Operations Center, a cross -departmental team formed to address the immediate needs of the COVID-19 emergency, secure resources to address those needs, and develop a multi -phase "re -opening" plan for the City, coordinated with the State of Illinois and federal plans. • Non-profit agencies that are addressing the needs for housing, shelter, food, and other necessities, including Connections for the Homeless, Meals On Wheels Northeast Illinois, Interfaith Action, YWCA Evanston North Shore, Family Promise, and the McGaw YMCA Men's Residence Program. • Surveys of local businesses and landlords/property managers to determine needs and their ability to access assistance through programs such as the Small Business Administration's Payroll Protection Plan. Process for Citizen Participation The City of Evanston invites public participation at all. stages of the Consolidated Planning process. The City is committed to making reasonable and timely access to the needs assessment, strategy development and budget recommendation process for all members of the community, particularly low- and moderate -income persons. 2 City of Evanston Citizen Participation Plan Substantial Amendments to the Consolidated Plan or Action Plans HUD requires entitlement communities to specify the criteria that trigger an amendment to the Consolidated Plan or Action Plan and describe the public process for amending those plans. The City of Evanston defines a substantial amendment to the Consolidated Plan or Action Plan as: • A change in funding among the Goals used in the development of the plan (SP-45 for Consolidated Plan, AP-20 for Annual Action Plans), that is greater than 20% of the total allocated towards the Goal • The deletion of a Goal included in a plan • The addition of a Goal not currently included in a plan Substantial amendments to the Consolidated Plan are proposed to the Housing & Community Development Act Committee for review and a public hearing is conducted. Additionally, the public is provided a minimum of 30 days to review and make comment on the proposed change. If approved by that committee, the substantial amendment is submitted to City Council for approval. Substantial amendments to Action Plans are proposed to the Housing & Community Development Act Committee if pertaining to CDBG, or the Planning & Development or Human Services Committee if pertaining to HOME or ESG. A public hearing is conducted during the required 30-day comment period to allow the public to review and make comment on the proposed change. If approved at the committee level, the substantial amendment is submitted to City Council for approval. All City Council meeting agendas include public comment, so the Council meeting may also serve as the public meeting for the 30-day public comment period. Any substantial amendment approved by City Council is submitted to HUD as it occurs during the year or at the end of the program year. All public comment received during the comment period or at the public meeting are considered, summarized and attached to the substantial amendment when submitted to HUD; any comments or views that are not accepted and the reasons for which they are not accepted are also included. CARES Act Substantial Amendment Process The CARES Act substantial amendment requires amendments to both the 2019 Action Plan and 2015-2019 Consolidated Plan. These amendments, and this amendment to the Citizen Participation Process, will be posted on the City of Evanston's HUD Consolidated Plan webpage for a minimum of five (5) days, as required. Comments on the substantial amendments may be submitted via email to housing@citvofevanston.org during the five-day public comment period. In addition, the CARES Act substantial amendment must be approved by City Council before it is submitted to HUD. The substantial amendment is included in the packet for the City Council "virtual" meeting and posted at least 48 hours prior to that meeting. Input may be provided in writing via email, or verbally by telephone or online during public comment. Any public comment received, including at public comment at the City Council meeting, are considered, summarized and attached to the substantial amendment when submitted to HUD; any comments or views that are not accepted and the reasons for which they are not accepted are included. 3 City of Evanston Citizen Participation Plan All other amendments shall be considered "non -substantial." This includes amendments to either the Consolidated Plan or Action Plan that are required when plans are based on estimated funding and are modified based on actual grant amounts. Non -substantial amendments to CDBG, HOME or ESG may be approved by the Housing & Community Development Act Committee, Planning & Development Committee or Human Services Committee depending on the program affected and shall not trigger a public comment period or re- submission to HUD for approval. Consolidated Annual Performance and Evaluation Report The Consolidated Annual Performance and Evaluation Report (CAPER) identifies the expenditures and performance results for each Annual Action Plan activity in a completed program year and any outstanding activities from prior program years. Corresponding to the City's fiscal year of January 1- December 31, CAPERs are submitted to HUD by March 31, within 90 days of the City's CDBG, HOME and ESG program year. Prior to its submission to HUD, the draft CAPER is posted on the City's website for the required 15-day public comment period and The Housing & Community Development Act Committee holds a public meeting for input on it. Input is also accepted in written form. The Housing & Community Development Act Committee recommends acceptance of the CAPER to City Council. The City Council meeting at which the CAPER is approved also provides opportunity for public comment. Any public comment received during the comment period or at the public hearing is considered, summarized and attached to the CAPER for submission to HUD. Public Meetings Opportunities for citizen input on housing, economic development and public services needs are provided throughout the year through public comment at regularly scheduled public meetings of the Housing & Community Development Act Committee, Housing & Homelessness Commission, Economic Development Committee, Planning & Development Committee and Human Services Committee, as well as at City Council meetings. To ensure access for persons with disabilities, most meetings are held at the Lorraine H. Morton Civic Center and occasionally at other locations that are accessible to persons with mobility impairments including the Main Public Library, Levy Center and Fleetwood-Jourdain Community Center. Translators are provided at meetings if requested 48 hours in advance of the meeting. Meetings of the City Council and standing committees of the Council are broadcast on Evanston cable channel and streamed live on the internet. Notices of public meetings and comment periods include contact information for anyone needing assistance because of a disability or language difference. If an individual is unable to attend a public hearing and wishes to comment on the subject matter of the hearing, written comments may be submitted to the Community Development Department via email, USPS or in person. Amendment for Public Meetings During Declarations of Emergencies During the COVID-19 pandemic, Evanston public meetings have been modified based on Governor Pritzker's order that waives some requirements of the Illinois Open Meetings Act to 4 City of Evanston Citizen Participation Plan allow local governments to hold "remote" meetings to help control the spread of COVID-19' That order waives the requirement that a quorum of members of a public body be "physically, 'present" at the meeting location, and limits the circumstances under which an individua[ member may take part by video or audio conference. It applies to City Council meetings, as well as Evanston board, committee and commission meetings. The order did not suspend other provisions of the Open Meetings Act pertaining to public notice of all meetings or that meetings be open and accessible to the public and press, and includes that there must be a way for the: public to address the Council, board, committee or commission. Funding Allocation Process Funding recommendations for CDBG, HOME and ESG are presented and discussed at meetings of the committees that oversee each grant program. The Housing & Community Development Act Committee conducts an annual application process for CDBG to develop funding recommendations for programs/projects that the City anticipates undertaking in the upcoming fiscal year. City staff holds one or more pre -application meetings to provide technical assistance to applicants, particularly new applicants, and schedules individual meetings as needed. Applications are submitted via an online grants application program, ZoomGrants, and are available for public review on the City's website and at one or more committee meetings where applicants present their proposals and answer questions from committee members. The Housing & Community Development Act Committee holds a public meeting at which members develop CDBG funding recommendations for the upcoming year. Application review and funding meetings are televised on the City of Evanston cable TV channel. Applications for Economic Development projects or programs are accepted throughout the year and first reviewed and underwritten by staff, then by the Economic Development Committee. HOME and ESG funding recommendations for individual activities or subgrants are made by the Housing & Homeless Commission at a public meeting following the procedures described above. Recommendations from the Commission go to either Planning & Development or Human Services Committee for approval and are recommended to City Council. CARES Act Funding Allocation Process To expedite access to funding and provide relief to residents, City staff developed the substantial amendment for CARES Act funding based on the needs identified through the assessment process described above. This enables the City to submit its substantial amendment before the detailed regulations for CDBG-CV and ESG-CV are released. It also allows gireater flexibility to prevent, prepare for, and respond to the coronavirus by addressing needs that will likely arise in the months ahead. Funding allocations to specific activities will be made on a rolling basis to target needs that are not being addressed through other CARES Act funding and potential duplication of benefits. This process is similar to how HOME and ESG funds are allocated to one or more goals in the annual Action Plan rather than the annual application process used for CDBG entitlement which uses an open application process and allocations are made to specific activities to develop the Action Plan. Funding allocations for specific activities will be reviewed and approved by City Council prior to implementation. City Council may 5 City of Evanston Citizen Participation Plan delegate authority to approve funding allocations for specific activities to the Housing and Community Development Act Committee, Housing and Homelessness Committee, Economic Development Committee, Mayor's COVID-19 Task Force, or other board, committee or commission that has been formed by the City to oversee the type of activities being funded on behalf of City Council. Any such action will be approved by City Council at a public meeting that provides members of the public the opportunity to provide input on the action. Information on the proposed action will be included in the agenda and packet for the meeting that is posted at least 48 hours in advance, in compliance with the Open Meetings Act. Amendment to the Funding Allocation Process, November 16, 2020 The process and timing to develop the draft 2021 Action Plan has been affected by the*" coronavirus pandemic, which has disparate impact on our low/moderate income residents,; ,particularly people of color. In addition, Evanston is experiencing substantial increases in homeless and unstably housed residents due to income loss from the continued impact of the pandemic. In addition, there is increased food insecurity and inability of residents at high risk of infection to shop for groceries. Child care and programming for elementary through high school age students is greatly reduced, affecting families, particularly those without a parent or adult at home to supervise children's remote learning, resulting in more women dropping out of the workforce to care for children or older family members, and reducing income for necessities. There is also increased need for job counseling and training for workers who have been laid off and are unable to find living wage jobs.. Staff is working with community partners and the Mayor's COVID-19 Task Force to address these needs with CDBG-CV and ESG-CV funding, and to develop a plan that continues to support Evanston's recovery from COVID-19 using CDBG and local Mental Health Board funds. and to address inequities in access to services for residents with greatest needs, particularly Blacks, Latinos and other people of color. This results in a change to the timing and application: process for CDBG and Mental Health Board funds. The allocation of CDBG funds to specific activities will be made later than in typical years. It is` expected that some or all CDBG funds will be allocated to specific activities after receipt of the City's 2021 CDBG grant amount, following the current practice for HOME and ESG funding. All available CDBG, HOME and ESG funds will be allocated to Goals in the final 2021 Action Plan for submission to City Council for approval and then to HUD. If this process results in a substantial amendment to the draft 2021 Action Plan, a second 30-day comment period and public meeting for input on the amended plan will be held, following the process outlined in the CPP. A substantial amendment to the Action Plan is defined in the CPP as:. • A change in funding among the Goals used in the development of the plan (AP-20) that is greater than 20% of the total allocated towards the Goal • The deletion of a Goal included in the plan' • The addition of a Goal not currently included in a plan_ 1. City of Evanston Citizen Participation Plan Any changes to the Action Plan following receipt of the City's entitlement grant amounts that increase or decrease funding for a goal by less than 20% shall be considered "non -substantial" , and may be approved by the Housing & Community Development Act Committee, Planning &I Development Committee or Human Services Committee, as appropriate, based on the program. affected. These changes would not trigger a second public comment period. CDBG allocations to individual activities may be made on a rolling basis to allow greater capacity to respond to changing needs during the COVID-19 recovery. Programs or projects ,proposed for CDBG funding will be reviewed and approved by the Housing and Community Development Act Committee before submission to City Council for approval in most cases but could go directly to City Council, following the CARES Act activity approval process_' There is no change to the process of allocating HOME and ESG funding to specific activities, Changes to the amounts allocated to Goals in the final Action Plan based on actual grant amounts will not constitute a substantial amendment unless they result in a change to funding for any goal by more than 20%, or the addition or deletion of a Goal. Public Outreach The City uses multiple communications channels to inform residents about the Consolidated Planning process and engage them in its development, approval and assessment. The following outreach efforts may be taken as appropriate to provide citizen access to the Consolidated Planning process. Failure to use any one of these shall not be considered a violation of this Plan. • Notices of all public comment periods and public hearings are published in a paper of general circulation, on the homepage of the City website, on the City's social media accounts (Facebook, Twitter, etc.), and via the City's e-newsletter that goes to over 45,000 emails prior to the opening of the public comment period. The notice includes the dates of the comment period; the date, time and location of the public hearing. • Notices of public meetings are sent to the media for all public meetings in accordance with the Illinois Open Meetings Act and posted on bulletin boards in the Lorraine H. Morton Civic Center. Meeting agendas, packets and minutes are posted online for public review at www.citvofevanston.org. • Email notification is sent to community organizations and individuals who request to receive information about meeting dates, agendas, funding application and allocation schedules, and other information. Access to Information The City of Evanston Consolidated Plan, including this CPP, Annual Action Plans, any Substantial Amendments to those plans, and Consolidated Annual Performance and Evaluation Reports are available online at www.citvofevanston.org. The City website may be translated into 150 different languages using Google Translate. In addition, the Consolidated Plan, Action Plans and CAPERs are available in print format for public review during regular working hours at: 7 City of Evanston Citizen Participation Plan Community Development Department Lorraine H. Morton Civic Center 2100 Ridge Ave, 3rd Floor Evanston, IL 60201 847-448-4311 This information shall be provided in a format accessible to persons with disabilities, upon adequate notice. Requests for additional information may be made to the Community Development Department at the address and phone listed above. A response shall be provided within 15 working days of receipt of the request, where practicable. If printed copies are requested, photocopier charges and miscellaneous charges for other related services and materials will be assessed in accordance with the City's Freedom Of Information Act policy. Comments/Complaints Any complaints relating to the Consolidated Plan, Action Plan or CAPER received in writing will receive a written response within 15 working days. The following points are used as guidance in responding to complaints: • Stated needs and objectives are inconsistent with available and reliable data • Stated projects are inappropriate for meeting needs and approved objectives • Consolidated Plan does not comply with regulations for the Community Development Block Grant, HOME Investment Partnerships or Emergency Shelter grants programs. Displacement The City of Evanston will make every effort to minimize the displacement of persons as a direct result of the implementation of projects funded by its HUD entitlement grant programs. If displacement does occur, the City will fellow all applicable federal regulations to alleviate the impact of such permanent and involuntary relocations. Section 108 Loan Guarantee The City of Evanston intends to apply for a Section 108 Loan Guarantee, authorized under HUD regulation 24 CFR Part 570, Subpart M, in the form of a Pooled Fund. If received, the Section 108 Program will be subject to all provisions set forth within this Citizen Participation Plan. Applications for Section 108 loan guarantee assistance may be included as part of the process for obtaining CDBG or HOME Entitlement funds, or may be undertaken separately anytime during the program year. The required public hearing to inform citizens of uses of funds will be carried out by the City's Economic Development Division or Community Development Department staff. 8 City of Evanston Citizen Participation Plan