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R2020-102 2020-05-18RESOLUTION NO. R2020-102 A Resolution of the City Council of the City of Pearland, Texas, approving a 5 - day public comment period and newly enacted federal provisions available for use in planning expenditures related to the U. S. Department of Housing and Urban Development Community Development Block Grant Program, applicable to fiscal year program allocations in 2020, 2021 and the CARES Act CDBG-CV stimulus funds. BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PEARLAND, TEXAS: Section 1. That a 5 -day public comment period and newly enacted federal provisions available for use in planning expenditures related to the 2020 and 2021 Community Development Block Grant Program allocations, and the CARES Act CDBG-CV funding from the U.S. Department of Housing and Urban Development, attached hereto as Exhibit "A", are hereby authorized and approved. PASSED, APPROVED and ADOPTED this the 18th day of May, A.D., 2020. ATTE TAL ROAN, TRMC, CMC CITY SECRETARY APPROVED AS TO FORM: DARRIN M. COKER CITY ATTORNEY TOM REID MAYOR cn �Q*PtYf4T0 /'O U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT WASHINGTON, DC 20410-7000 9 April 2020 ASSISTANT SECRETARY FOR COMMUNITY PLANNING AND DEVELOPMENT MEMORANDUM FOR: All Fiscal Year 2020 and 2019 CDBG and CDBG-CV Grantees and All CPD Field Office Directors FROM: John Gibbs, Acting Assistant Secretary for Community Planning and Development SUBJECT: CARES Act Flexibilities for CDBG Funds Used to Support Coronavirus Response and plan amendment waiver The Coronavirus Aid, Relief and Economic Security Act (CARES Act) (Public Law , makes available $5 billion in supplemental Community Development Block Grant (CDBG) funding for grants to prevent, prepare for, and respond to coronavirus (CDBG-CV grants). Additionally, the CARES Act provides CDBG grantees with flexibilities that make it easier to use CDBG-CV grants and fiscal years 2019 and 2020 CDBG Grants for coronavirus response and authorizes HUD to grant waivers and alternative requirements. The Department has announced the allocations of the first $2 billion in CARES Act funding for CDBG grantees, as well as $1 billion for Emergency Solutions Grants (ESG) and $53.7 million for Housing Opportunities for Persons With AIDS (HOPWA). You can find the allocations at www.hud.govL/progMM offices/commplanning/budgefty20/. This memorandum transmits the attached CARES Act Flexibilities for CDBG Funds Used to Support Coronavirus Response Guide (Guide). The Guide describes the immediate availability of a 5 -day public comment period for amendments and new plan submissions, uncaps the percentage of CDBG fimding for public services to prevent, prepare for, and respond to coronavirus, as well as other flexibilities. Please note that these new provisions are not only applicable to the $5 billion in CDBG funding from the CARES Act but many of the new provisions are also applicable to FY2019and FY2020 CDBG funding. This broad applicability provides grantees with flexibility to help address the challenges facing our nation. Grantees are advised to amend or prepare their plans as soon as possible and not to wait for the pending Federal Register notice, which may provide additional waivers and alternative requirements. Similarly, grantees should not wait for HUD to allocate the remaining nearly $3 billion of the $5 billion provided by the CARES Act for the CDBG program. Upon publication of the Federal Register notice and subsequent allocations, grantees receiving allocations will then amend plans accordingly. Grantees should proceed with all amendments and plans under these new provisions by adding the CDBG-CV allocation in their plans as an available resource for the year. The CARES Act permits HUD to waive, or specify alternative requirements for, any provision of any statute or regulation that the Secretary administers in connection with the CDBG-CV funds, FY2019 and FY2020 CDBG funds (except for requirements related to fair housing, nondiscrimination, labor standards, and the environment), upon a finding by the Secretary that any such waivers or www.hud.gov espanol hud.gov alternative requirements are necessary to expedite or facilitate the use of such amounts to prevent, prepare for, and respond to coronavirus. To expedite grantees' use of CDBG-CV funds, HUD is waiving the requirements at 42 U.S.C. 12705(a)(2) to the extent it requires updates to the housing and homeless needs assessment, housing market analysis, and strategic plan and 24 CFR 91.220 and 91.320 to the extent the action plan is limited to a specific program year to permit grantees to prepare substantial amendments to their most recent annual action plan, including their 2019 annual action plan. Grantees must identify the proposed use of all funds and how the funds will be used to prevent, prepare for, and respond to coronavirus. The Department is also waiving 24 CFR 91.505 to facilitate the use of the CDBG-CV funds to the extent necessary to require submission of the substantial amendment to HUD for review in accordance with 24 CFR 91.500. To receive a CDBG-CV grant, a grantee must also submit a SF - 424, SF -424D and the certifications at 24 CFR 91.225(a) and (b) or 24 CFR 91.325(a) and (b). The Guide addresses many of the Field's initial questions. Email inquiries to CPDQuestionsAnsweredO,hud.gov will continue to receive individual replies and guidance. HUD will also be batching questions and responses and periodically making them available as FAQs. Additional resources will continue to be posted to www.hudexchane.info/pro cdb diseaseJ. Thank you for the work you and your staff do with our communities in the fight against the coronavirus. CARES Act Flexibilities for CDBG Funds Used to Support Coronavirus Response April 9, 2020 President Trump has signed The Coronavirus Aid, Relief and Economic Security Act (CARES Act). The CARES Act: • Makes available $5 billion in supplemental Community Development Block Grant (CDBG) funding for grants to prevent, prepare for, and respond to coronavirus (CDBG-CV grants); • Provides flexibilities for CDBG grantees to make it easier to use CDBG-CV grants and fiscal years 2019 and 2020 CDBG grants for coronavirus response and authorizes HUD to grant waivers and alternative requirements; • Requires CDBG-CV grantees to prevent the duplication of benefits, which means grant funds may not be used to pay costs if another source of financial assistance is available to pay that cost. HUD will publish a Federal Register notice describing the requirements for CDBG-CV grants. The notice will also include waivers and alternative requirements for CDBG-CV and fiscal year 2019 and 2020 CDBG grants. A grantee may submit a CDBG-CV action plan substantial amendment to its most recent accepted CDBG action plan for the first CDBG-CV allocation before the notice is published. To apply for CDBG-CV grants, grantees may follow existing regulatory requirements for a substantial amendment to the grantee's action plan that describes the amount of CDBG-CV funds available in the first allocation and planned use of funds, in accordance with existing requirements and the flexibilities in the CARES Act, summarized below. HUD will publish a Q&A document with further information on this process. Grantees may use CDBG-CV and CDBG funds for a range of activities to prevent, prepare for, and respond to coronavirus. For examples, see the Quick Guide to CDBG Activities for Infectious Disease Response. Summary of CARES Act Provisions for Coronavirus Response With CDBG-CV and CDBG Grants For more information, refer to applicable sections of the CARES Act, Housing and Community Development Act of 1974 (for State CDBG Grantees) and CDBG regulations (for Entitlement CDBG grantees). Description of Program Flexibility Applicability to CDBG-CV and CDBG Grants Public Service Activities Eliminates the 15 percent cap' on the amount of CDBG-CV Immediately grant funds that can be used for public services Available activities. Following enactment, the cap in section 105(a)(8) of CDBG FY 19 and Immediately V the HCD Act and 24 CFR 570.201(e) has no effect on FY 20 Grants Available CDBG Grants Not X CDBG-CV grants and no effect on FY 2019 and 2020 CDBG grant funds used for coronavirus efforts. before FY 19 Available Reimbursement of Costs Provides that grantees may use CDBG-CV grant CDBG-CV Immediately funds to cover or reimburse costs to prevent, prepare Available for, and respond to coronavirus incurred by a State or locality, regardless of the date on which such costs CDBG FY 19 and See current X were incurred, when those costs comply with CDBG FY 20 Grants regulations. requirements. For other grants, pre -agreement and pre -award cost authority is available under 24 CFR CDBG Grants See current X 570.489(b) (states) and 570.200(h) (entitlements). before FY 19 regulations. I Section 105(a)(8) of the Housing and Community Development Act of 1974, provides a different percentage cap for some grantees. Description of Program Flexibility Applicability to CDBG-CV and CDBG Grants Citizen Participation and Public Hearings for Consolidated Plans (including Action Plans) Provides that grantees may amend citizen CDBG-CV Immediately participation plans to establish expedited procedures Available to draft, propose, or amend consolidated plans. Expedited procedures must include notice and reasonable opportunity to comment of no less than 5 CDBG FY 19 and FY 20 Grants Immediately Available days. The 5 -day period can run concurrently for comments on the action plan amendment and amended citizen participation plans. CDBG Grants before FY 19 Not X Available In-person public hearings are not required. Grantees may meet public hearing requirements with virtual public hearings if: 1) national/local health authorities recommend social distancing and limiting public gatherings for public health reasons; and 2) virtual hearings provide reasonable notification and access for citizens in accordance with the grantee's certifications, timely responses from local officials to all citizen questions and issues, and public access to all questions and responses. Deadline to Submit Consolidated Plans (including Annual Action Plans) Extends the deadline for grantees to submit action plans and other updates to their consolidated plans submissions for fiscal years 2019* and 2020 to CDBG-CV Immediately Available CDBG FY 19* and FY 20 Grants Immediately Available. August 16, 2021. Without extension, the deadline for fiscal year 2020 grants would be August 16, 2020, in accordance with section 116(b) of the HCD Act and 24 CFR 91.15. CDBG Grants Not x *The deadline for fiscal year 2019 passed on August before FY 19 applicable. 16, 2019 (plans due then have been submitted). Waiver and Alternative Requirement Authority Authorizes the Secretary to issue statutory and regulatory waivers/alternative requirements for CDBG-CV and some CDBG funds when necessary CDBG-CV Immediately Available CDBG FY 19 and FY 20 Grants Immediately Available. to expedite or facilitate the use of grant funds to prevent, prepare for, and respond to coronavirus. Prohibits waivers/alternative requirements related to fair housing, nondiscrimination, labor standards, and CDBG Grants Not X the environment. before FY 19 applicable. HUD has additional regulatory waiver and statutory suspension authorities that it may use for CDBG Grants before fiscal year 2019 if necessary. Submit your questions to: CPDQuestionsAnsweredna,hud.gov