Agenda 09/13/2016 R Item #16D15 16.D.15
09/13/2016
EXECUTIVE SUMMARY
Recommendation to authorize the necessary budget amendments, in the amount of$3,081,352 for
the U.S. Department of Housing and Urban Development (HUD) Fiscal Year 2016-2017 budget as
approved in the HUD Action Plan for entitlement funds and authorize the Chairman to sign the
standard HUD entitlement agreements upon arrival.
OBJECTIVE: To expend federal funds to assist the citizens of Collier County
CONSIDERATIONS: The FY 2016-2017 Annual Action Plan was approved by the Board at
their June 28, 2016 meeting with permission to transmit the Plan to HUD for the entitlement funds for
FY 2016-2017,based on estimated funding allocations.
FY16-17 Allocations
CDBG HOME ESG Total
Collier County $2,417,287** $479,663 $184,402 $3,081,352
*
*Includes City of Naples allocation and projected program income
The Community and Human Services (CHS) Division operates its Federal grant cycle from October 1
to September 30 to coincide with the County's budget year. Staff salaries are an eligible expense
under the administrative portion of the grant funding and the primary funding source used to support
CHS staff that administers the CDBG,HOME and ESG funds to the sub-recipients.
HUD funds are available October 1, 2016 (fiscal year October 1, 2016 to September 30, 2017),but due
to HUD's internal administrative process they will not have the requisite entitlement agreements
prepared and sent to us before the beginning of the fiscal year. By approving this item, staff will have
the ability to draw down these funds for administration.
This item also authorizes the Chairman to sign the associated entitlement agreements and certifications
at a later date without further Board Action. These are standard agreements and HUD forms that
do not provide for adjustment. Each entitlement agreement will be reviewed by the County Attorney's
Office for legal sufficiency. To be clear, no subrecipient expenditures will be incurred until the
subrecipient agreements are approved by the Board. Subrecipient agreements will only be brought forth
at a future meeting. Therefore, the effective impact of this action is to have administrative funds
available to operate the program and accept the funding officially when the HUD acceptance forms
are provided. By allowing the Chairman to sign when the HUD acceptance forms arrive it will allow
staff to get the project subrecipient agreements on the agenda sooner, greatly assisting the County in
meeting its critical timeliness deadlines and providing funding to our community partners at the earliest
possible date.
As a condition of award, Collier County retains funds to administer all three programs. Two of the
three programs require match, HOME is a 25% ($119,916) program match and ESG is a 1:1
match ($184,402). While HOME requires a 25% match for project related activities, it does not require
administration funds to be matched.
Project match requirements will be identified in the sub-recipients contracts, when they are presented
to the Board for approval at a future meeting.
Packet Pg. 1586
16.D.15
09/13/2016
FISCAL IMPACT: These HUD grant agreements totaling $3,081,352, which include projected
program income in the amount of$225,000, will allow CHS to administer, implement, and monitor
the projects outlined in the FY2016-2017 Annual Action Plan. Costs associated with grant
administration and staffing are primarily covered by the entitlement funding and there is no
additional effect on ad valorem or general fund dollars over that budgeted for FY16. Grant revenues
and expenditures associated with these grants will be maintained and monitored in the Housing
Grant Fund (705). Projects are established as CDBG 33479, HOME 33480 and ESG 33481. Budget
amendments are required in the amount of$2,417,287for CDBG, $479,663 for HOME, and $184,402
for ESG.
A portion of the ESG program will be implemented in-house. The related match amount ($60,000)
will be available within FY16 Housing Grant Match (706) Reserves funded by the General Fund.
The remaining$13,000 will be covered by Fund(123)Collier Co Seniors. A budget amendment in the
amount of$60,000 is required in FY16 to appropriate the reserve amount of$60,000 to ESG project
(33481).
GROWTH MANAGEMENT IMPACT: Acceptance and implementation of this action will further
the goals, objectives and policies, consistent with Ordinance No. 2013-10, of the Housing Element
of the Growth Management Plan.
LEGAL CONSIDERATIONS: The HUD entitlement grant agreements and certifications will be
approved for form and legality only if substantially identical to documents received in past years
from HUD. HUD entitlement grant agreements and certifications from FY 2015-2016 are attached for
reference. Accordingly, this item is approved as to form and legality and requires a majority vote
for approval. -JAB
RECOMMENDATION: That the Board of County Commissioners authorizes the necessary
budget amendments for the HUD Fiscal Year 2016-2017 budget as approved in the HUD Action
Plan for entitlement funds and authorizes the Chairman to sign the standard HUD entitlement
agreements upon arrival.
Prepared by: Cormac Giblin,Senior Housing and Grants Coordinator; Community and Human
Services
ATTACHMENT(S)
1. CDBG -HUD funding letter 2015 Backup (PDF)
2.ESG -HUD funding letter 2015 Backup (PDF)
3. HOME-HUD funding letter 2015 Backup (PDF)
4. HUD Letter 2015 Backup (PDF)
Packet Pg. 1587
16.D.15
09/13/2016
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.D.15
Item Summary: Recommendation to authorize the necessary budget amendments, in the amount
of $3,081,352 for the U.S. Department of Housing and Urban Development (HUD) Fiscal Year 2016-
2017 budget as approved in the HUD Action Plan for entitlement funds and authorize the Chairman to
sign the standard HUD entitlement agreements upon arrival.
Meeting Date: 09/13/2016
Prepared by:
Title:—Community&Human Services
Name: Cormac Giblin
08/24/2016 1:26 PM
Submitted by:
Title: Division Director-Cmnty&Human Svc—Public Services Department
Name: Kimberley Grant
08/24/2016 1:26 PM
Approved By:
Review:
Community&Human Services Blanca Aquino Luque Level 1 Sim.Reviewer 1-8 Completed 08/24/2016 2:39 PM
Public Services Department Kimberley Grant Level 1 Sim.Reviewer 1-8 Completed 08/25/2016 9:09 AM
Community&Human Services Maggie Lopez Level 1 Sim.Reviewer 1-8 Completed 08/25/2016 10:04 AM
Public Services Department Hailey Margarita Alonso Level 1 Division Reviewer Completed 08/25/2016 3:31 PM
Public Services Department Steve Carnell Level 2 Division Administrator Review Completed 08/25/2016 4:37 PM
County Attorney's Office Jennifer Belpedio Level 2 Attorney of Record Review Completed 08/25/2016 4:41 PM
Grants Erica Robinson Level 2 Grants Review Completed 08/26/2016 9:20 AM
County Attorney's Office Jeffrey A.Klatzkow Level 3 County Attorney's Office Review Completed 08/26/2016 10:41 AM
Office of Management and Budget Valerie Fleming Level 3 OMB Gatekeeper Review Completed 08/26/2016 3:57 PM
Grants Therese Stanley Level 3 OMB 1st Reviewer 1-4 Completed 08/29/2016 2:07 PM
County Manager's Office Nick Casalanguida Level 4 County Manager Review Completed 08/29/2016 3:19 PM
Board of County Commissioners MaryJo Brock Meeting Pending 09/13/2016 9:00 AM
Packet Pg. 1588
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r Funding Approval/Agreement L!.S.Department 01 Housing and Urban Development
0 Office of Community Plannmv and Development
Title I of the Housing and Community
r Development,4c1 (Public Lase 920353) Conmmunity Development Block Grant Program GMB Approval No
H1 00515R of 20515R 7503-0193(Fon 9/31/701 R1
1.Name of Grantee(as shown in item 5 of Standard Form 424) 3a.Grantee's 9-digit Tax ID Number 3b.Grantee's 9-digit DUNS Number i
Collier County 59600(1558 (176997790 ca
2.Grantee's Complete Address(as shown in item 5 of Standard Form 424) 4.Date use of funds may begin
3339 Tamiami Trail East Suite 211 10/1/12015
Naples.FL 34 112 5a.Project/Grant No.1 6a.Amount Approved
B-15-UC-12-0016 52.202.632
5b.Project/Grant No.2 6b.Amount Approved
Grant Agreement: This Gram Agreement between the Department of Housing and Urban Development(HUD)and the above named Grantee is made pursuant to the
authority of Title 1 of the Housing and Community Development Act of 1974.as amended.(42 USC 5301 et seq.).The Grantee's submissions for Title I assistance,the
HOD regulations at 24 CFR Pim 570 (as now in effect and as may he amended from time to time), and this Funding Approval, including any special conditions.
constitute part of the Agreement. Subject to the provisions of this Grant Agreement,HUD will make the funding assistance specified here available to the Grantee upon
execution of the Agreement by the parties. The funding assistance specified in the Funding Approval may be used to pay costs incurred after the date specified in item
4 above provided the activities to which such costs are related are carried out in compliance with all applicable requirements. Pre-agreement costs may not he paid with
funding assistance specified here unless they are authorized in HUD regulations or approved by waiver and listed in the special conditions to the Funding Approval.
The Grantee agrees to assume all of the responsibilities for environmental review.decision making,and actions.as specified and required in regulations issued by the
Secretary pursuant to Section 104(g)of Title I and published in 24 CFR Part 58. The Grantee further acknowledges its responsibility for adherence to the Agreement by
sub-recipient entities to which it makes funding assistance hereunder available.
U.S.Department of Housing and Urban Development (By Name) Grantee Name
Ann D.Chavis Collier County
Title Title evp p
HOD Conurmnity Planning and Development Director N'1Lk 4i Q
Signalbre Date 11/4/2015 Signature---77— Date(mm/dd/yyyy)
1 /0 S pDf U
7.Category of Title I Assistance for this Funding Action B.Special Conditions 9a.Date HUD Rhceiddd Submission 10.check one
(check only one) (check one) 08/12/2015 ®a.Orig.Funding
®a.Entitlement,Sec 106(b) ❑None 9b.Date Grantee Notified Approval
1:1b.State-Administered,Sec 106(d)(1( ®Attached 11/4/2015 0 b.Amendment
❑
9c.Date of Start of Program Year Amendment Number c.HUD-Administered Small Cities,Sec 106(d)(2)(B) 9
❑d.Indian CDBG Programs,Sec 106(a)(1) 10/1//2(115
❑e.Surplus Urban Renewal Funds,Sec 112(b) 11.Amount of Community Development
f.Special Purpose Grants,Sec 107 Block Grant FY(2015) FY( ) FY( )
g.Loan Guarantee,Sec 108 a.Funds Reserved for this Grantee 52.202,632
b.Funds now being Approved S2.202.632
c.Reservation to be Cancelled
(1 la minus 11b)
12a.Amount of Loan Guarantee Commitment now being Approved 12b.Name and complete Address of Public Agency
N/A N/A
Loan Guarantee Acceptance Provisions for Designated Agencies:
The public agency hereby accepts the Grant Agreement executed by the
Department of Housing and Urban Development on the above date with
respect to the above grant number(s) as Grantee designated to receive 12c.Name of Authorized Official for Designated Public Agency
loan guarantee assistance, and agrees to comply with the terms and
conditions of the Agreement, applicable regulations, and other Title
requirements of HUD now or hereafter in effect, pertaining to the
assistance provided it.
Signature
HUD Accounting use Only
Effective Date
Batch TAC Program Y A Reg Area Document No. Project Number Category Amount (mm/dd/yyyy) F
153
1 7 6 — — —
Y Project Number Amount
Y Project Number Amount
Date Entered PAS(man/dd/yyyy) Date Entered LOCCS(mmldd/yyyy) Batch Number Transaction Code Entered By Verified By
24 CFR 570 form HUD-7082(4/93)
ATTEST:
DWIGHT C.BRCCK,CLERK
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Signature on
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County of Collier Grant#B-15-UC-12-0016
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8. Special Conditions.
(a) The period of performance for the funding assistance specified in the Funding
Approval ("Funding Assistance") shall begin on the date specified in item 4 and
shall end on September I, 2022. The Grantee shall not incur any obligations to be
paid with such assistance after September 1, 2022. (Source: 31 U.S.C. 1551-
1557)
(h) If Funding Assistance will be used for payment of indirect costs pursuant to 2
CFR 200, Subpart E- Cost Principles, attach a schedule in the format set forth
below to the executed Grant Agreement that is returned to HUD. The schedule
shall identify each department/agency that will carry out activities with the
Funding Assistance, the indirect cost rate applicable to each department/agency
(including if the de minimis rate is charged per 2 CFR §200.414), and the direct
cost base to which the rate will be applied. Do not include indirect cost rates for
subrecipients.
Administering Direct
Department/Agency Indirect cost rate Cost Base
N/A %
N/A
N/A %
(c) The grantee shall comply with requirements established by the Office of
Management and Budget(OMB)concerning the Universal Numbering System
and System for Award Management (SAM) requirements in Appendix A to 2
CFR part 25, and the Federal Funding Accountability and Transparency Act
(FrATA) in Appendix A to 2 CFR part 170.
(d) The grantee, unit of general local government or Insular Area that that directly or
indirectly receives CDBG funds may not sell, trade, or otherwise transfer all or
any such portion of such funds to another such entity in exchange for any other
funds, credits or non-Federal considerations,but must use such funds for activities
eligible under title I of the Housing and Community Development Act of 1974
(the Act). (Source: P.L. 113-235, Consolidated and Further Continuing
Appropriations Act, 2015,Division K, Title II, Community Development Fund)
(e) CDBG funds may not be provided to a for-profit entity pursuant to section
105(a)(17) of the Act unless such activity or project has been evaluated and
selected in accordance with Appendix A to 24 CFR 570- "Guidelines and
Objectives for Evaluating Project Costs and Financial Requirements." (Source -
P.L. 113-235, Consolidated and Further Continuing Appropriations Act, 2015,
Division K,Title II, Community Development Fund).
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(f) The grantee shall ensure that no CDBG funds are used to support any Federal,
State, or local projects that seek to use the power of eminent domain, unless
eminent domain is employed only for a public use. For the purposes of this
requirement, public use shall not be construed to include economic development
that primarily benefits private entities. Any use of funds for mass transit,
railroad, airport, seaport or highway projects as well as utility projects which
benefit or serve the general public (including energy-related, communication-
related, water- related and wastewater-related infrastructure), other structures
designated for use by the general public or which have other common-carrier or
public-utility functions that serve the general public and are subject to regulation
and oversight by the government, and projects for the removal of an immediate
threat to public health and safety or brownsfield as defined in the Small Business
Liability Relief and Brownsfield Revitalization Act (Public Law 107-118) shall
be considered a public use for purposes of eminent domain. (Source: P.L. 113-
235, Consolidated and Further Continuing Appropriations Act, 2015,Division K,
Title IV, General Provisions, Section 407)
(g) E.O. 12372-Special Contract Condition -Notwithstanding any other provision of
this agreement, no funds provided under this agreement may be obligated or
expended for the planning or construction of water or sewer facilities until receipt
of written notification from HUD of the release of funds on completion of the
review procedures required under Executive Order (E.O.) 12372,
Intergovernmental Review of Federal Programs, and HUD's implementing
regulations at 24 CFR Part 52. The recipient shall also complete the review
procedures required under E.O. 12372 and 24 CFR Part 52 and receive written
notification from HUD of the release of funds before obligating or expending any
funds provided under this agreement for any new or revised activity for the
planning or construction of water or sewer facilities not previously reviewed
under E.O. 12372 and implementing regulations.
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Emergency Solutions Grants Program Office of Community Planning and Development Ng
Subtitle B of Title IV of the McKinney-Vento Homeless Assistance
Act,
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42 U.S.C. 11371 et seq.
CFDA Number 14.231
1. Recipient Name and Address: 2.Unique Federal Award Identification Number:
Collier County E15-UC-12-0016
3339 Tamiami Trl E Suite 211 3.Tax Identification Number: 596000558
Naples,FL 34112
4.Unique Entity Identifier(DUNS):076997790
5.Fiscal Year(yyyy): 2015
6. Previous Obligation(Enter"0"for initial Fiscal Year allocation) $0
7.Amount of Funds Obligated or Deobligated by This Action(+or- 5180,474
8.Total Amount of Federal Funds Obligated $180,474
9.Total Required Match:$
10.Start Date of Recipient's 11.Date HUD Received Recipient's 12. Date On Which Recipient
Program Year(10/01/2015) Consolidated Plan Submission May Begin Incurring Costs(the
08/12/2015 later of the dales listed in 10 and
11)
10/01/2015
13.Type of Agreement(check applicable box) 14.Special Conditions
® Initial Agreement(Purpose#1—Initial Fiscal Year allocation) ❑Not applicable ®Attached
❑ Amendment(Purpose#2—Deobligation of funds) 15.Period of Performance End Date(mm/dd/yyyy)
❑Amendment(Purpose#3—Obligation of additional funds) 11/03/2017
General Terms and Conditions: This Agreement between the U.S. Department of Housing and Urban
Development (HUD) and the Recipient is made pursuant to the authority of Subtitle B of Title IV of the McKinney-
Vento Homeless Assistance Act (42 U.S.C. 11371 et seq.). The Recipient's Consolidated Plan submissions
(including the Recipient's approved annual Action Plan and any amendments completed in accordance with 24
CFR Part 91),the Emergency Solutions Grants Program regulations at 24 CFR Part 576 (as now in effect and as
may be amended from time to time), and this Agreement, including any special conditions attached to this
Agreement, constitute part of this Agreement. The Recipient shall comply with requirements established by the
Office of Management and Budget concerning the Universal Identifier and System of Award Management (SAM)
requirements in Appendix A to 2 CFR Part 25 and the Federal Funding Accountability and Transparency Act
requirements in Appendix A to 2 CFR Part 170. Subject to the terms and conditions of this Agreement, HUD will
make the funds for the specified Fiscal Year available to the Recipient upon execution of this Agreement by the
Recipient and HUD, and the funds may be used to pay costs incurred on or after the date specified in Box 12
above. All funds for the specified Fiscal Year that HUD provides by reallocation are covered by this Agreement
upon execution of an amendment by HUD, without the Recipient's execution of the amendment or other consent.
The Recipient agrees to assume all of the responsibilities with respect to environmental review, decision making,
and action required under the HUD regulations at 24 CFR Part 58. Nothing in this Agreement shall be construed
as creating or justifying any claim against the federal government or the Recipient by any third party. To the
extent authorized by HUD regulations at 24 CFR Part 576, HUD may, by its execution of an amendment,
deobligate funds previously awarded to the Recipient without the Recipient's execution of the amendment or other
consent.
16.For the U.S.Department of HUD(Name,Title,and Contact Information of 17.Signature 18.Date of Obligation/Federal
Authorized Official) Award Date
Ann D.Chavis /j 11 /04/2015
HUD CPD Director
19.For the Recipient(Name and Title of Authorized Official) 20.Signature f 21. Date
Funding Information(HUD Accounting Use Only):
PAS Code: Region: Program Code:
Appropriation: Office: Allotment:
Appro Symbol:
ATTEST: •
DWIGHT E,BROOK,CLL1-,
AttEgffiltfCtr> an's
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14. Special Conditions: Indirect Cost Rate
(a) The period of performance for the funding assistance specified in the Funding Approval
("Funding Assistance") shall begin on the date specified in item 10 and shall end on the date
specified in item 15. The recipient shall not incur any obligations to be paid with such assistance
after the date specified in item 15.
(b) If Funding Assistance will be used for payment of indirect costs pursuant to 2 CFR 200, Subpart
E - Cost Principles, attach a schedule in the format set forth below to the executed Grant
Agreement that is returned to HUD. The schedule shall identify each department/agency that
will carry out activities with the Funding Assistance, the indirect cost rate applicable to each
department/agency (including if the de minimis rate is charged per 2 CFR §200.414), and the
direct cost base to which the rate will be applied. Do not include indirect cost rates for
subrecipients.
Administering Direct
Department/Agency Indirect cost rate Cost Base
N/A
N/A
N/A %
County of Collier Grant#E-15-UC-12-0016 •
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Participant Name and Address 2. Grant Number:
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M15-UC120217 m
Collier County 3a Tax Identification Number: 3b. Unique Entity identifier(formerly
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3339 Tamiami Trl E Suite 211 596000558 DUNS):076997790
Naples,FL 34112 5.Appropriation Number 6. FY
865/80205 2015
6. Previous Obligation(Enter"0"for initial FY allocation) $0.00
a. Formula Funds $
b. Community Housing Development Org.(CHDO)Competitive $
7. Current Transaction(+or-) $453,588
a. Formula Funds $453.588
1. CHDO(For deobligations only) $
2. Non-CHDO(For deobligations only) $
b. CHDO Competitive Reallocation or Deobligation $
8. Revised Obligation
a. Formula Funds $
b. CHDO Competitive Reallocation $
9. Special Conditions(check applicable box) 10.Date of Obligation(Congressional Release Date)
ELI Not applicable ❑Attached 11/4/2015
11.Indirect Cost Rate* 12.Period of Performance:
Administering Agency/Dept. Indirect Cost Rate Direct Cost Base 11/04/2015—09/01/2023
N/A _i ' If funding assistance will be used for payment of indirect costs pursuant to 2 CFR
cr 200, Subpart E-Cost Principles, provide the name of the department/agency, its
indirect cost rate(including if the de minimis rate is charged per 2§CFR 200.414),
_% and the direct cost base to which the rate will be applied. Do not include cost rates
.• for subrecipients.
This Agreement between the Department of Housing and Urban Development (HUD)and the Participating Jurisdiction/Entity is made pursuant to the authority of the HOME
Investment Partnerships Act(42 U.S.C.12701 et seq.).The Participating Jurisdiction's/Entity's approved Consolidated Plan submission/Application and the HUD regulations at
24 CFR Part 92(as is now in effect and as may be amended from time to time) and this HOME Investment Partnership Agreement,form HUD-40093, including any special
conditions,constitute part of this Agreement.Subject to the provisions of this Agreement,HUD will make the funds for the Fiscal Year specified,available to the Participating
Jurisdiction/Entity upon execution of this Agreement by the parties.All funds for the specified Fiscal Year provided by HUD by formula reallocation are covered by this Agreement
upon execution of an amendment by HUD,without the Participating Jurisdiction's execution of the amendment or other consent.HUD's payment of funds under this Agreement is
subject to the Participating Jurisdiction's/Entity's compliance with HUD's electronic funds transfer and information reporting procedures issued pursuant to 24 CFR 92.502.To the
extent authorized by HUD regulations at 24 CFR Part 92, HUD may, by its execution of an amendment, deobligate funds previously awarded to the Participating
Jurisdiction/Entity without the Participating Jurisdiction's/Entity's execution of the amendment or other consent.The Participating Jurisdiction/Entity agrees that funds invested in
affordable housing under 24 CFR Part 92 are repayable when the housing no longer qualifies as affordable housing.Repayment shall be made as specified in 24 CFR Part 92.
The Participating Jurisdiction agrees to assume all of the responsibility for environmental review,decision making,and actions,as specified and required in regulation at 24 CFR
92.352 and 24 CFR Part 58.
The Grantee shall comply with requirements established by the Office of Management and Budget(OMB)concerning the Universal Numbering System and System for Award
Management(SAM)requirements in Appendix A to 2 CFR part 25,and the Federal Funding Accountability and Transparency Act(FFATA)in Appendix A to 2 CFR part 170.
The Period of Performance for the funding assistance shall begin on the date specified in item 12 and shall end on September 1`e of the 5"'fiscal year after the expiration of the
period of availability for obligation.Funds remaining in the account will be cancelled and thereafter not available for obligation or expenditure for any purpose.Per 31 U.S.C.1552.
The grantee shall not incur any obligations to be paid with such assistance atter the end of the Period of Performance.
13.For the U.S.Department of HUD(Name and Title of Authorized Official) 14.Signal 4e 15. Date
Ann D.Chavis-HUD Community Planning and Development Director / ( 11/04/2015
16. For the Participating Jurisdiction/Entity(Name and Title of Authorized Official) 17.S nature- 18. Date
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19.Check one:
I Initial Agreement ❑ Amendment# .'
ATTEST:_:
20. Funding Information: HOME DWIGHT E.E3F CK CLERK
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Source of Funds Appropriation Code PAS Code Amount
2015 865/80205 HMF $453,588 a G �. 1 ./ Al'
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U.S. Department of Housing and Urban Development
c° Community Planning and Development Division a
Region IV, Miami Field Office
Brickell Plaza Federal Building
909 SE First Avenue, Rm. 500
Miami, FL 33131-3042 a
November 5, 2015
Ms. Kimberley Grant
Director of Community and Human Services Department
Collier County Board of County Commissioners
3339 Tamiami Trail East, Suite 211
Naples, Florida 34112
Dear Ms. Grant:
SUBJECT: Collier County
Action Plan Program Year 2015 Approval
We are pleased to approve your one-year Action Plan for Program Year 2015 funding.
The grant assistance that is being approved with the Action Plan is as follows:
Community Development Block Grant (CDBG) Program: $ 2,202,632
HOME Investment Partnerships (HOME) Program: $ 453,588
Emergency Solution Grant (ESG) Program: $ 180,474
The total allocation for your community: $ 2,836,694
Your FY 2015 program year began on October 1, 2015.
We would like to take this opportunity to commend the County on the successful
completion of your one-year Action Plan. We believe that the goals and objectives developed
through this process provide the foundation for the formulation of new partnerships at all levels
of government and with the private sector including for-profit and non-profit organizations.
These partnerships are invaluable as you and your partners address the problems of
affordable housing, homelessness, and economic opportunities for all citizens, particularly for
very low-income and low-income persons.
A primary goal of the Department is to reduce housing discrimination, affirmatively
further fair housing through CPD programs and promote diverse, inclusive communities. To that
end, we encourage your community to take all measures necessary to ensure compliance with the
Fair Housing requirements associated with these funds. A copy of your Consolidated Plan was
provided to the Office of Fair Housing and Equal Opportunity for review. Comments from that
review are enclosed with this letter.
HUD's mission is `Create strong,sustainable,inclusive communities and quality,affordable homes for all'.
www.hud.2ov www.espanol.hud.„ov
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In accordance with §92.254(a)(5), a PJ undertaking HOME-assisted homebuyer
activities, including any projects funded with HOME program income, must establish resale or
recapture provisions that comply with HOME statutory and regulatory requirements and set forth
the provisions in its consolidated plan. We have determined that the County's Recapture
provisions are appropriate and are hereby approved.
Enclosed are three originals of each of the required Grant Agreements and Funding
Approvals. This constitutes the contract between our Department and the County. You should
note any special conditions listed in the Funding Approvals. Please return two executed
originals for each Grant, and retain the others for your records. In addition to the Grant
Agreements, we have also enclosed a copy of "Consolidated Plan Advice and Guidance"
applicable to the various Programs.
Again, we congratulate you and your staff on the preparation of the Plan. We look
forward to working with you during the coming years to accomplish the goals you have set forth
and to further refine and improve the Plan development process. In the meantime, if you have
any questions or desire assistance concerning this letter or other items related to the community
development programs; please contact Nora E. Casal, Senior Community Planning and
Development Representative at (305) 520-5009 or via email message at Nora.E.Casal@hud.gov.
Sincerely,
/
Ann D. Chavis
Director
Community Planning and Development Division
Enclosures
cc: Lisa Bustamante, Program Manager,US HUD
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CONSOLIDATED PLAN ADVICE AND GUIDANCE 2015
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All Formula Grants
**Please note Special conditions attached to the grant agreements**
Indirect Cost Rate
if funding assistance will be used for payment of indirect costs pursuant to 2 CFR 200,
Subpart E-Cost Principles, grantees must attach a schedule to the Executed Grant Agreement that
identifies each department/agency,its indirect cost rate (including if the de Minimis rate is
charged per 2 § CFR 200.414), and the direct cost base to which the rate will be applied on the
grant agreement. If there are more than four agencies/departments carry out activities with the
Funding Assistance, attach a list with the additional agencies/departments that will carry out
activities with the Funding Assistance. Do not include cost rates for subrecipients or project
sponsors.
Fair Housing and Equal Opportunity
A primary goal of the Department is to reduce housing discrimination, affirmatively
further fair housing through CPD programs and promote diverse, inclusive communities. To that
end, we encourage your community to take all measures necessary to ensure compliance with the
Fair Housing requirements associated with these funds.
Reporting Requirements for Fiscal Year 2015 Grants
The Consolidated Annual Performance Evaluation Report (CAPER) (Section 91.520) for
the 2014 Program Year is due in this office no later 90 days after your program year end date,
which includes CDBG, HOME, and ESG.
Integrated Disbursement Information System (IDIS)
The Community may add or delete individuals authorized to access the Integrated
Disbursement and Information System (IDIS). An IDIS Access Request Form must be prepared,
notarized and returned to this office with the Grant Agreement. The Direct Deposit sign-up
Form (SF-1199A) must be completed: if there is the need to establish or change banking
information. Both the Grantee and the financial institution must complete the form. The
completed SF-1199A Form must be returned to this office.
As a reminder, please also note that CPD is changing its disbursement approach in IDIS
from FIFO to a grant-based approach and will issue guidance to ensure that grantees have
appropriate instructions for beginning to draw upon their FY 2015 CDBG funds.
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Environmental Review Procedures
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Certain activities included in the Consolidated Action Plan are subject to the provisions
of 24 CFR Part 58 (Environmental Review Procedures for the CDBG Program). Funds for such
activities may not be obligated or expended unless the release of funds has been approved in
writing by HUD. A request for the release of funds must be accompanied by an environmental
certification. HUD's web site has helpful information on these environmental review
requirements at: https://www.hudexchange.info/environmental-review/. Technical assistance on
these procedures is also available from your CPD Representative or from Mr. Ubaldo A. Cazzoli,
Environmental Specialist, at (305) 520-5005.
Addendums to the Grant Agreement for the CDBG Program:
• In addition to the conditions contained on form HUD 7082, the grantee shall comply
with requirements established by the Office of Management and Budget (OMB)
concerning the Dun and Bradstreet Data Universal Numbering System (DUNS), the
Central Contractor Registration (CCR) database, and the Federal Funding
Accountability and Transparency Act as provided in 2 CFR part 25, Universal
Identifier and Central Contractor Registration, and 2 CFR part 170, Reporting
Subaward and Executive Compensation Information.
• The grantee shall ensure that no CDBG funds are used to support any Federal, State, or
local projects that seek to use the power of eminent domain, unless eminent domain is
employed only for a public use. For the purposes of this requirement, public use shall not
be construed to include economic development that primarily benefits private
entities. Any use of funds for mass transit, railroad, airport, seaport or highway projects
as well as utility projects which benefit or serve the general public (including energy-
related,communication-related, water-related and wastewater-related infrastructure),
other structures designated for use by the general public or which have other common-
carrier or public-utility functions that serve the general public and are subject to
regulation and oversight by the government, and projects for the removal of an immediate
threat to public health and safety or brownsfield as defined in the Small Business
Liability Relief and BrownsfieId Revitalization Act (Public Law 107-118) shall be
considered a public use for purposes of eminent domain.
• The Grantee or unit of general local government that indirectly receives CDBG funds
may not sell, trade, or otherwise transfer all or any such portion of such funds to another
such entity in exchange for any other funds, credits or non-Federal considerations, but
must use such funds for activities eligible under Title I of the Act.
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Please note the July 24, 2013, HOME final rule (24 CFR Part 92) new requirements are
in effect, As you know, the HOME program statute provides that funds are available to
participating jurisdictions (PJs)for 24 months after the last day of the month in which HUD
notifies the PJ of HUD's execution of the HOME Investment Partnerships Agreement. If not
placed under a binding commitment to affordable housing within the 24-month period, the funds
are to be deobligated. The statute also provides that at least 15 percent of each PJ's allocation
must be reserved for investment in housing to be developed, sponsored, or owned by Community
Housing Development Organizations (CHDOs).
One of the most significant changes made by the 2013 HOME final rule was the
elimination of non-project specific reservations to CHDOs. The term CHDO reservation in the
rule refers to a commitment to a specific project to be owned, developed, or sponsored by a
CHDO. It is critical that PJs remain cognizant of this change to ensure that they meet the 24-
month CHDO reservation deadline requirement.
ESG Guidance/Expenditure Deadlines and Change in Environmental Review
Responsibilities
The office of Special Needs Assistance Programs (SNAPS) has provided training and
guidance documents for recipients/subrecipient that can be accessed at
www.hudexchange.info/esg.,; and an ESG Fact Sheet (copy attached) which provides a quick
reference for basic ESG program information.
There are two critical deadlines set forth in the ESG program regulations. Title 24 of the
Code of Federal Regulations (CFR), Section 576.55(b), requires that all ESG grant amounts be
obligated by 180 days and expended by 24 months after the date of the grant award letter. Any
grant amounts that are not obligated and expended by these dates may be recovered and
reallocated for use in accordance with 24 CFR 576.67. These deadlines represent maximum time
periods. We trust that each grantee will make every effort to obligate and expend all funds
within these periods.
On Friday, July 6, 2012, President Obama signed the Moving Ahead for Progress in the
21s` Century Act (MAP-21) (Public Law 112-141) into law. The law includes several changes to
the homeless assistance programs under title TV of the McKinney-Vento Homeless Assistance
Act, as amended (42 U.S.C. 11360 et seq.). Among these changes, MAP-21 restores
authorization for states and units of general local government to assume HUD's responsibilities
for environmental review under 24 CFR Part 58 (environmental reviews performed by states and
units of general local government) for the Emergency Solutions Grants program (ESG). Based
on this change, HUD revised the ESG grant agreement to incorporate the relevant provision of
MAP-21 and provide that the grantee agrees to assume all of the responsibilities with respect to
environmental review, decision making, and action required under HUD's regulations at 24 CFR
Part 58. This agreement will enable you to use the same environmental review procedures that
have been required for all Emergency Shelter Grants. HUD will also incorporate these
procedures into the upcoming final rule for the Emergency Solutions Grants program.
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Under these procedures, each unit of general local government that receives ESG funds
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from HUD or a State, and each State that provides ESG funds to private nonprofit organizations,
will carry out the environmental review responsibilities under Part 58. Also, each State that
provides ESG funds to a unit of general local government will provide for the assumption of
environmental review responsibilities by the units of general local government and act on their
requests for release of funds.
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FIIEO REVIEW COMMENTS—Collier County FY 2015 Action Plan
The County did not address two impediments identified in its Analysis of
Impediments in this year's Action Plan. The County must ensure that it
takes specific actions to address the following impediments, in both its next
Consolidated Plan as well its next AAP: 1) tenant/landlord language
harriers; and 2) discrimination based on race,national origin or disability.
For each impediment, the County should identify specific milestones and
timetables, and state how results will be measured.
➢ In compliance with 24 CFR 91.225,The County's projects should meet its
obligation to affirmatively further fair housing choice. In particular, when
funding HOME projects and amending its AAP as proposed, including the
acquisition of sites by Habitat for Humanity.
if the County needs any technical assistance on this matter or throughout its program
year, please feel free to contact Aaron Levine at aaron.d.levine@hud.gov or 305-520-5037.