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Agenda 02/11/2025 Item #16D 6 (Resolution - A substantial Amendment to HUD Annual Action Plans for Program Years 2019-2020, 2022-2023 and 2024-2025)2/11/2025 Item # 16.D.6 ID# 2025-9 Executive Summary Recommendation to adopt a Resolution authorizing approval of a Substantial Amendment to Collier County's U.S. Department of Housing and Urban Development (HUD) Annual Action Plans for Program Years 2019-2020, 2022-2023, and 2024-2025 to; (a) remove an activity and return funds to CDBG CV Administration, (b) revise the second allocation of ESG-RUSH funding from Program Year 2022 to Program Year 2024, (c) reclassify the Collier County Housing Authority HVAC activity as an Affordable Housing project per HUD’s guidance and authorize submission of the Substantial Amendment to HUD. OBJECTIVE: To maintain compliance with federal regulations that allow for the acceptance and use of federal HUD entitlement funds to provide rental assistance to those who are homeless or are facing homelessness and support affordable housing efforts to benefit the citizens of Collier County. CONSIDERATIONS: The U.S. Department of Housing and Urban Development (HUD) provides entitlement funds to local governments to meet program-specific community needs. Entitlement programs include Community Development Block Grant (CDBG), HOME Investment Partnerships (HOME), and Emergency Solutions Grant (ESG). Community and Human Services (CHS) staff have recently identified changes to various activities to better address community needs. HUD regulations at 24 CFR Part 91.505 require amendments to Annual Action Plans whenever there is a change in the allocation priorities or method of distributing funds presented in the plan; a change in the use of funds to an activity not described in the Annual Action Plan; or a change in the purpose, scope, location, or beneficiaries of an activity. Collier County is proposing to amend Program Years (PY): 2019-2020, 2022-2023 and 2024-2025 U.S. Department of Housing and Urban Development (HUD) Annual Action Plans. The Board of County Commissioners approved the PY 2019-2020 Annual Action Plan on June 25, 2019 (Agenda #16.D.2), the PY 2019-2020 Annual Action Plan substantial amendment to recognize COVID-19 funding on May 12, 2020 (Agenda Item#16.F.1), PY 2022-2023 Annual Action Plan on June 28, 2022 (Agenda Item#16.D.4), PY 2024-2025 Annual Action Plan on July 23, 2024 (Agenda Item #16.D.4) and the PY 2022-2023 Annual Action Plan substantial amendment on May 28, 2024 (Agenda Item #16.D.4). A substantial amendment to an Action Plan or Consolidated Plan requires advertising and a 30-day public comment period. The required notice was published in the Naples Daily News on December 23, 2024. The advertisement identified a 30-day public comment period from December 24, 2024 to January 24, 2025. On January 6, 2025, a public hearing was held to address the proposed actions and as of the agenda publication, no comments regarding the substantial amendment were received. The following substantial amendment changes are proposed to the PY 2019-2020 Annual Action Plan (in all areas where the activity description is referenced): 2019 - 2020 Annual Action Plan Modify Project: Project Name: CDBG CV Facility Improvements Remove activity as follows: Allocation of CDBG CV funds to Collier County Library Division in the amount of $200,000 for the replacement of windows at the Immokalee Library. The CDBG CV funds will return to CDBG CV Administration as originally allocated to be used for planning purposes. The following substantial amendment changes are proposed to the PY 2022-2023 and PY 2024-2025 Annual Action Plans (in all areas where the activity description is referenced): Modify Project: Project Name: ESG22 Collier County Homeless Programs (ESG-RUSH 2nd allocation) to ESG24 Collier County Homeless Programs (ESG-RUSH 2nd allocation) Modify program year for activity as follows: Collier County received a second allocation of ESG-RUSH funds in the amount of $1,150,486 on February 15, 2024. Per HUD’s funding approval/agreement dated May 10, 2024, the federal award number is E-24-UW-12-0016 which designates activity setup under the PY 2024 Annual Action Plan. This substantial amendment will move this activity from the 2022 program year, where it was originally setup, to the 2024 program year based on HUD’s guidance. ESG-RUSH will provide homeless prevention rental assistance and homeless Page 2669 of 3773 2/11/2025 Item # 16.D.6 ID# 2025-9 rapid re-housing for households at risk of homelessness with short-term rental assistance affected by Presidentially Declared Disasters. This program will be administered by Community and Human Services. The following substantial amendment changes are proposed to the PY 2022-2023 Annual Action Plan (in all areas where the activity description is referenced): 2022-2023 Annual Action Plan Add Project: Project Name: CDBG: Rental Rehab Move activity from Project: CDBG: Public Facilities & Infrastructure to CDBG: Rental Rehab The activity remains the same: Collier County Housing Authority (CCHA) will rehabilitate affordable housing units through the purchase and installation of heating, ventilation and air conditioning systems. This substantial amendment will move the project from public facility to rental rehabilitation to allow for proper reporting purposes and will not have any impact on service location or beneficiaries. FISCAL IMPACT: There is no new fiscal impact for CDBG-CV Facility Improvements. Funds will be shifted from the Collier County Library Division in the amount of $200,000.00 to CDBG-CV Administration. The funding source is the federal CDBG-CV award B-20-UW-12-0016. Funding is available in Housing Grant Fund (1835) project 33674. There is no new fiscal impact for ESG-RUSH 2nd allocation, ESG24 Collier County Homeless Programs. The funding source is HUD Award E-24-UW-12-0016. The $1,150,486.00 is budgeted in Housing Grant Fund (1835) project 33910. The administrative portion of this funding will be limited to 7.5%. There is no new fiscal impact for CDBG PY23 Rental Rehab. The funds are budgeted in Housing Grant Fund (1835) project 33855. GROWTH MANAGEMENT IMPACT: Acceptance and implementation of this HUD substantial amendment furthers the Goals, Objectives, and Policies of the Housing Element and the Growth Management Plan. LEGAL CONSIDERATIONS: This item has been reviewed by the County Attorney, is approved as to form and legality and requires majority vote for approval. -JAK RECOMMENDATIONS: To adopt a resolution authorizing approval of a substantial amendment to Collier County's U.S Department of Housing and Urban Development (HUD) Annual Action Plans for Program Years 2019-2020, 2022- 2023 and 2024-2025 to; (a) remove an activity and return funds to CDBG CV Administration, (b) revise the second allocation of ESG-RUSH funding from Program Year 2022 to Program Year 2024, (c) reclassify the Collier County Housing Authority HVAC activity as an Affordable Housing project per HUD’s guidance and authorize submission of the substantial amendment to HUD. PREPARED BY: Tracey Smith, Grant Coordinator II, Community and Human Services Division ATTACHMENTS: 1. SA Resolution - JAK signed Page 2670 of 3773 Page 2671 of 3773 Page 2672 of 3773 Page 2673 of 3773