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HomeMy WebLinkAboutCity of Lansing Draft Action Plan 2020 for public comment y�N S r�C Department of Economic Development Office Development and Planning 316 N. Capitol Avenue, Suite D-1 Brian McGrain, Director Lansing, Michigan 48933 �r PH: 517.483.4040—FAX: 517.483.6036 H i www.lansingmi.gov/development Andy Schor, Mayor March 11, 2020 Chris Swope ' City Clerk l Lansing, MI Re: ACTION PLAN 2020, CITY OF LANSING, MICHIGAN Dear Chris: Please find enclosed a draft copy of the City of Lansing's Action Plan 2020 (7/1/2020- 6/30/2021) to be placed on file at the City Clerk's office. As you know, this is our annual document that is prepared for the Department of Housing and Urban Development in order to receive our federal funds for Community Development Block Grant (CDBG), HOME and Emergency Solutions Grant (ESG)funds. Each year, the City of Lansing provides a draft copy of the Consolidated Plan and/or the Action Plan document (s) for public review for a 30-day comment period. The comment period for the attached document should be made available for public review from March 12 -April 13, 2020. This is the fifth and final year of the city's current Five-Year Plan, 2016-2020. Later this year, the City will be.preparing to develop the next Five-Year Consolidated Plan, 20217 2025. If you have any questions, please feel free to contact me at ext. 4063. Thank you for your time and cooperation. Have a great day Sincerely, Doris M. Witherspoon Senior Planner "Equal Opportunity Employer" PROPOSED FUNDING ALLOCATIONS PROGRAM ACTIVITIES AND USE OF FUNDS ANNUAL ACTION PLAN 2020 (7/1/20 — 6/30/21) CITY OF LANSING COMMUNITY DEVELOPMENT OBJECTIVES The primary objective of Lansing's Housing and Community Development Program is the development of a viable community which will provide standard housing in a suitable living environment, principally to benefit low and moderate income persons, preserve and expand existing businesses and industries, and create an atmosphere conducive to stability in neighborhoods. a. Provide standard housing in a suitable living environment through rehabilitation, new construction and improvement of the housing stock primarily in CDBG eligible neighborhoods and in specifically designated housing target areas. b. Provide housing counseling and assistance that will benefit low and moderate-income households. C. Promote home ownership for low and moderate-income households and promote deconcentration of poverty. d. Maintain at current levels the number of public and assisted housing units available to low and moderate-income households. e. Provide homeless prevention assistance, emergency shelter, street outreach and supportive human services for people with special needs, people who are homeless and those at risk of becoming homeless. f. Provide assistance for permanent supportive housing and human services for low and moderate income households with a history of chronic homelessness, including those with special needs. g. Promote economic opportunity for low and moderate-income individuals by facilitating economic development, providing employment opportunity, sponsoring job training, supporting business development, micro-enterprise lending and business or financial educational programs and initiatives. h. Promote economic development to provide jobs, business services and shopping opportunities for residents located in CDBG eligible areas. i. Provide community and neighborhood services, recreational opportunities and public facilities and promote neighborhood social cohesion to improve the quality of life in CDBG eligible neighborhoods. j. Increase security and safety in neighborhoods by supporting public safety and crime prevention initiatives, public educational programs and citizens' awareness in CDBG eligible areas. k. Improve the city's transportation, public facilities and infrastructure systems in CDBG eligible areas. MARCH 5,2020 I. Protect and improve the city's physical environment, including preventing or eliminating blight, removing lead or other safety hazards, preserving historic resources, mitigating flood hazards, promoting healthy housing and improving energy fitness in housing occupied by low and moderate-income households. M. Promote fair housing objectives. n. Provide affordable housing and economic development that benefits low and moderate income people in the context of mixed use development along transit corridors. MARCH 5,2020 COMMUNITY DEVELOPMENT BLOCK GRANT CDBG Single-family, Owner-Occupied Rehab Program/Public Improvements Includes loans and grants for rehabilitation of owner-occupied housing units through city sponsored programs, and in conjunction with affordable housing efforts sponsored by nonprofit housing corporations, public and private developers, and other state and federal agencies. Includes funds to meet lead hazard reduction regulations in rehabilitated structures, funds to assist in emergency housing rehabilitation, market analysis activities and technical assistance to nonprofit housing corporations, contractors, and low- and moderate-income households. Includes loans and grants for owner-occupied single-family units through city sponsored programs, loans to rehabilitate historic homes in conjunction with rehabilitation of the unit, and loans or grants for ramps, hazard remediation or weatherization. Includes staff, office space, technical assistance, training and other direct project costs associated with delivery of Community Development Block Grant, HOME, Emergency Solutions Grant and other State and Federal Programs. General street, sidewalk, water/sewer improvements, including assistance to income eligible owner-occupants or those in CDBG-eligible areas for special assessments related to new improvements. Includes improvements to neighborhood parks, recreational facilities; public neighborhood, medical and community facilities in CDBG priority areas. Proposed funding amount: $1,293,549 CDBG Rental Rehab Program Includes loans and grants for rehabilitation of rental housing units through city sponsored programs. Includes funds to meet healthy housing standards and/or lead hazard reduction regulations in rehabilitated structures. Proposed funding amount: $1,000 Acquisition Includes acquisition, maintenance and security of properties acquired through programs, and activities related to acquisition, disposition, relocation and clearance of dilapidated and blighted structures. Funds may also be used to acquire and clear properties in the flood plain. Includes staff time associated with this activity. Proposed funding amount: $100,000 MARCH 5,2020 Public Services (limited to 15%) Includes services for low- and moderate-income individuals such as: homeownership counseling, education, neighborhood counseling, youth and senior programs, neighborhood clean-ups, community gardens, home repair classes. Services are for low- and moderate-income individuals and/or those in CDBG-eligible areas located within the Lansing city limits. Proposed funding amount: $ 306,819 (15% of CDBG) Economic Development Loans, technical assistance and training to low- and moderate-income owners of and persons developing micro-enterprises within or planning to locate within the Lansing city limits. Technical assistance to individuals and for-profit businesses including workshops, technology assistance, and fagade improvement loans/grants. Creation of jobs to benefit low and moderate-income city of Lansing residents. Technical assistance to individuals and for-profit businesses including workshops, technology assistance, fagade improvement loans/grants, market analysis, business promotion, referrals for the attraction of new business and expansion of existing business within CDBG-eligible areas of Lansing. Proposed funding amount: $ 50,000 CDBG General Administration (limited to 20%) Includes staff and other costs associated with preparation of required Consolidated Planning documents, environmental clearances, fair housing activities and citizen participation activities associated with the delivery of CDBG, HOME and other state and federal programs. Includes planning and general administration costs associated with delivery of CDBG and other state and federal programs. Includes indirect administrative costs and building rent paid to the city. Proposed funding amount: $409,092 TOTAL CDBG, CDBG PI, and CDBG Previous Years Funds = $2,160,460 ($2,045,4602 + $75,000 PI + $40,000 previous years funds) HOME Down Payment Assistance Funds provided to homebuyers for down payment and closing costs for purchase of a single-family home located within the Lansing city limits. Up to $40,000 will be available as a 0% interest second mortgage for homebuyers with income at or below 80% of median income. Assistance not limited to first-time homebuyers. May include staff time and/or homeownership counseling fees associated with this activity. Proposed funding amount: $100,000 MARCH 5,2020 New Construction/HOME Rehab/Development Program Includes funds for loans and grants for housing construction and rehabilitation with non-profit and for-profit developers, including CHDOs. HOME funds allocated for housing developed in partnership with the city, including Supportive Housing Program (SHP) and Acquisition, Development and Resale (ADR) activities. Projects may include new construction and rehabilitation activities with non-profit and for-profit developers, including CHDOs. Funds may be used for staff time associated with these activities. Proposed funding amount: $600,393 CHDO Set-aside (15% minimum required) Reserved for housing developed, sponsored or owned by CHDOs in partnership with the City. Proposed funding amount: $ 112,799 Community Housing Development Organization (CHDO) Operating (limited to 5%) Funds reserved at option of the City to provide operating funds to CHDO's utilizing the City's HOME funds to produce affordable housing in the community. Proposed funding amount: $37,599 _HOME General Administration (limited to 10%) Includes staff and general administration costs to deliver the HOME program. Proposed funding amount: $75,199 TOTAL HOME, Program Income, and HOME previous years available funds: $925,990 ($751,990 + $124,000 Previous year+ $50,000 PI) EMERGENCY SOLUTIONS GRANT (ESG) Street Outreach Street Outreach activities. Proposed funding amount: $ 5,294 Homeless Prevention MARCH 5,2020 Homeless Prevention activities. Proposed funding amount: $61,758 Administrative Activities (limited to 7.5%) Funds provided to offset the cost of administering emergency solutions program. Proposed funding amount: $ 12,351 Homeless Management Information System (HMIS) Funds will be provided for HMIS and comparable database costs. Proposed funding amount: $ 5,294 Shelter Operation Funds provided to shelter providers to cover cost of maintenance, operations, insurance, utilities and furnishings in shelter facilities. Proposed funding amount: $ 91,755 TOTAL ESG: $176,452 SUMMARY Forty—Fifth Year Community Development Resources Program Annual Action Plan CDBG Entitlement Grant: $2,045,460 CDBG Program Income (est.) $75,000 CDBG Previous Years Annual $40,000 Funding HOME Program Funds $751,990 HOME Previous Years Annual $124,000 Funding HOME Program Income (est.) $50,000 ESG Program Funds: $176,452 TOTAL $3,262,902 MARCH 5,2020 Administrative, management and operation costs for the above programs include the administration, management and operations of the eligible activities, as well as other federal and state community development programs in which the city is now or may be participating. MARCH 5,2020 CITY OF LANSING , MI ANNUAL ACTION PLAN FISCAL YEAR 2020 (JULY 11 2020 - JUNE 301 2021 ) Prepared for the U.S. Department of Housing and Urban Development by the City of Lansing, Michigan Department of Economic Development and Planning 316 N. Capitol Avenue Lansing, MI 48933-1234 Executive Summary AP-05 Executive Summary - 24 CFR 91.200(c), 91.220(b) 1. Introduction The City of Lansing Department of Economic Development and Planning is the lead organization responsible for the administration of the Community Development Block Grant (CDBG), HOME and ESG federal funds received from the Department of Housing and Urban Development(HUD).The City has been successful in leveraging additional state and local resources to support grant funded activities. Federal funds are available to low to moderate income households citywide. The City of Lansing is submitting its FY 2020 Annual Action Plan which covers July 1, 2020 through June 30, 2021. The FY 2020 Annual Action Plan is the fifth and final year of the City of Lansing's five-year, 2016-2020 Consolidated Plan.The proposed activities to be carried out in FY 2020 are based on needs, priorities, strategies and goals established in the five-year Consolidated Strategy and Plan Submission for the period 2016-2020. This annual plan is based on community development fund resources: CDBG, HOME and ESG funds expected to be available in FY 2020.The anticipated goals are based on the availability of other sources of funding projected to be available during this time period to leverage the federal community development fund resources. The requisite information presented in the Action Plan is according to the final rule established by the Department of Housing and Urban Development at 24 CFR 91, Consolidated Submission for Community Planning and Development Programs. Through the Master Plan and other planning processes,the city continues to solicit input from the community, particularly promoting participation from low and moderate income citizens on community needs.The City of Lansing has collaborative partnerships with various City of Lansing departments, State offices, Tri-County Regional Planning Commission (TCRPC)), Michigan State Housing Development Authority (MSHDA), Ingham County Land Bank, Capital Region Housing Collaborative (CRHC) formerly the Greater Lansing Homeless Resolution Network or the Continuum of Care (CoC), Lansing Housing Commission, adjacent municipalities and other community groups and organizations to provide a regional approach to integrate housing, land use, economic and workforce development, transportation and infrastructure development in a comprehensive and inclusive manner. It should be noted that the City of Lansing has made several amendments to its Action Plan: Minor amendment to its Annual Action Plan 2016 resulting in amending its Consolidated Plan 2016- 2020.The amendment reflected a minor adjustment within the CDBG activities but no change in the overall amount of the CDBG funding allocations. More specifically, the changes including reducing Annual Action Plan 1 2020 OMB Control No:2506-0117(exp.06/30/2018) • Provide homeless prevention assistance, emergency shelter, street outreach and supportive human services for people with special needs, people who are homeless and those at risk of becoming homeless. • Provide assistance for permanent supportive housing and human services for low and moderate income households with a history of chronic homelessness, including those with special needs. • Promote economic opportunity for low and moderate-income individuals by facilitating economic development, providing employment opportunity, sponsoring job training, supporting business development, micro-enterprise lending and business or financial educational programs and initiatives. • Promote economic development to provide jobs, business services and shopping opportunities for residents located in CDBG eligible areas. • Provide community and neighborhood services, recreational opportunities and public facilities and promote neighborhood social cohesion to improve the quality of life in CDBG eligible neighborhoods. • Increase security and safety in neighborhoods by supporting public safety and crime prevention initiatives, public educational programs and citizens' awareness in CDBG eligible areas. • Improve the city's transportation, public facilities and infrastructure systems in CDBG eligible areas. • Protect and improve the city's physical environment, including preventing or eliminating blight, removing lead or other safety hazards, preserving historic resources, mitigating flood hazards, promoting healthy housing and improving energy fitness in housing occupied by low and moderate-income households. • Promote fair housing objectives. • Provide affordable housing and economic development that benefits low and moderate income people in the context of mixed use development along transit corridors 3. Evaluation of past performance This is an evaluation of past performance that helped lead the grantee to choose its goals or projects. In FY 2019, the City of Lansing received $2,008,152 of Community Development Block Grant, $707,152 HOME and $170, 259 of ESG (Emergency Solutions Grant). The City of Lansing takes various initiatives to ensure success in meeting the Action Plan objectives and addressing community needs. The City of Lansing counted several accomplishments during the past fiscal year which included the continued increased awareness of the CDBG—home rehabilitation programs, which included making homes lead safe, worked closer with sub recipients to address the needs of the low and moderate income populations and provided several programs and services to address the specific needs of the homeless and those at risk of homelessness. For FY19 Lansing completed the following for CDBG and LS L: Annual Action Plan 3 2020 OMB Control No:2506-0117(exp.06/30/2018) second public hearing is held before the Planning Board in January/February on the proposed funding allocations. During this hearing, the public had the opportunity to comment on the distribution of the proposed funding allocations.The public had another opportunity to make comments on the Action Plan, including funding allocations at the April 27, 2020 final Public Hearing before the Lansing City Council. At their May 4, 2020 City Council plans to propose passing a resolution to submit the City of Lansing's FY 2020 Annual Action Plan. A draft of the summary plan was made available for a 30-day public review and comments period from March 12, 2020—April 13, 2020. A notice of the opportunity for public review and comments was published in the Wednesday, March 4, 2020 Lansing City Pulse (a general circulation newspaper), made available at the Capital Area District Library,the City Clerk's office, the Department of Economic Development and Planning as well as on the City of Lansing's website. A summary of comments or views and the city's response is included as an attachment in the Action Plan submission.The facilities where the public hearings were held are barrier free to accommodate persons with disabilities. In the event that a significant number of non-English speaking residents attend the public hearings, the city would provide a resource person for translation purposes. The City makes every possible effort to reach its minority population, low-income and those with special needs. S. 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. The City of Lansing follows its Citizen Participation Plan in terms of engaging the community in public input.The first public hearing was held on December 3, 2019 before the Planning Board to receive public comments about housing and community development needs.The second of three public hearings regarding the federal funding allocations was held on February 4, 2020. The minutes of the public hearings are included in the final submission of the Action Plan The final public hearing was held on April 27, 2020 before the Lansing City Council. Also,the public had an opportunity to review and comment on the draft Action Plan during the public comment period from March 12, 2020—April 13, 2020. At their May 4, 2020 City Council plans to propose passing a resolution to approve submittal of the City of Lansing's FY 2020 Action Plan, which reflected the actual funding allocations. 6. Summary of comments or views not accepted and the reasons for not accepting them All comments are considered during the public comment period. Annual Action Plan 5 2020 OMB Control No:2506-0117(exp.06/30/2018) k % / ± � v c OD r / � u § \ \ } \ 0 2 / J % / c © _0 = f E e g 1 % § � ƒ s / { y G to C \ f E E E / y / / — \ _? 3 < w > ƒ / 0 k / CL ai \ \ \ f u k E ° 0 / \ \ \ $ o � c � m f / / bn s / d / � \ \ \ / \ o / - y y y U •_ % 41 e » » > e •� 7 7 f f f u \ \ $ _k D 0 0 k 0 b f / \ v 2 E e t •2 o ■ # m m = � t 2 E _ & / < % \ ./ • / - � m -0 \ / c e Q e C fu E o / � / E 2 - CL Q O Q $ tw 0 § c / cu z z z >ai \ o \ 0. 2 \ \ \ E o L \ - \ [ E ) \ ) } k \ k ■ c Lu E % F @ d CL/ \ 0 § § a) o { .g / 0 c & C U s E / 2 Q / c e § u 0 k / / \ \ \ \ 0 ^ o f a ƒ a / < y k o 'E ' 2 r _ 4 \ coaj cu 0) \ # � » 4- E 0 / / 2 ƒ & k G u / ) < \ � t ■ 3 c § E \ f •� / 0 2 / $ 7 E 2 ) @ ¥ u < < < E < @ ° m » ) L k [ \ / 2 k / / ƒ / k k k \ ai / ° / i i 2 i m / cL ( k k \ j a � c a 2 e / u U e � 0 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 (91.23.5(1)) The City of Lansing's process of engaging and enhancing the coordination between public and assisted housing providers, private and governmental health, mental health and services agencies involves being an integral part of several organization's planning process/committees as well as staying abreast of overall activities in the community. Several city staff members assume leadership roles as well as serve on several committees with various agencies/organizations, such as the Capital Region Housing Collaborative (CRHC), formerly, Greater Lansing Homeless Resolution Network (GLHRN), the Continuum of Care, Power of We Consortium, Tri-County Regional Planning Commission, Lansing Housing Commission, involved in planning activities and meeting the needs of their specific clientele.Through this collaborate effort, duplication of services is eliminated and coordination of programs and services are met in the community. 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. The City of Lansing Department of Economic Development and Planning—Development Office (EDP- DO), oversees the Consolidated Plan/ESG submission and coordinates with the Capital Region Housing Collaborative (CRHC),the Ingham County Continuum of Care (CoC), several ways. The Office works closely with the City's Human Relations and Community Services Department (HRCS) that serves as CoC Recipient and Collaborative Applicant, sub-contracting and monitoring all CoC and ESG sub-recipient agencies. Coordination occurs with key staff persons from both city departments serving on the CoC Board, Finance and Strategic Planning Committees, helping to determine/voting ESG fund allocations, interpreting HUD regulations and priorities, and sharing best practices. The HRCS Department helps plan both ESG and CoC open and competitive application processes,and oversees the CoC Planning grant.These activities are coordinated closely with the EDP-DO's Con/Action Plan to ensure all goals addressing homelessness are in alignment. Ongoing gaps analyses are conducted to ensure ESG and CoC funds are targeted and focused on the homeless populations with the greatest needs. HRCS Department is the lead HMIS agency, leveraging CoC-wide HMIS data to identify areas for improvements.The EDP-DO holds several public hearings to gain input from the community. Planned action steps to end chronic homelessness includes the continued partnership with key community organizations. CRHC has a Strategic Plan that is comprehensive,visionary and realistic to help resolve homelessness. ESG funds help provide necessary shelter beds for individuals and families, prevention for at-risk families, and outreach services for youth in coordination with other federal and state-funded programs such as PATH,State ESG, FEMA, etc. Annual Action Plan 9 2020 OMB Control No:2506-0117(exp.06/30/2018) homeless and shared findings with the Strategic Planning committee who made several recommendations to the Board to address CH homeless. Policies and procedures for the operation and administration of HMIS have been in place for several years.The policies mirror statewide HMIS P&P's developed by the Michigan Coalition Against Homelessness with input from CoC's across the state.The policies and procedures are reviewed and updated annually and adopted by the CoC Board. Locally, the HMIS P&P's are incorporated into the CoC's Policies and Procedures manual. 2. 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L O In u >Q *O'DoaC_O ul u a1 w o @ co Ea, � 0O o Co 0 c � aCJaO N a- a) C C .E c C 'v1 O C- v1 a-+ E 2 v1 C W 6 3 +_+ C E LJ '-z > O c m u .ai .3 V) m O O O N -C a, c p O Q +J uLn do o E E uO c L c •+, o a) +, o v ° a yc = +, uc U a)u U > u 5 o o o E 7D O ° -0 " c o0 > p U + C t a O o p o o O U -a p n a, v p o � + c J v v 7 to to > so- 4-1 O 'a E E o -0 E � 0 L Z Li .� ° .� d a v O O O C O c 4J c o E OE O E O_ O_ 0 0 m 4+ m Y @ ++ m 41 N z °- z z °- z ° r0 f6 v�i (6 f0 vvi m f0 uvi f0 f0 kn z O O a7 O O 0) 0 O O O O a 0 'D o C7 Q 0 0 u tD I� 00 Q1 2 / ƒ ƒ ± / k Q = \ % / Ln = E u /2 3 / % o .> _ e 3 / 4- � / 7 / / / \ ) / \ g \ g < m / \ k ± ± \ E 9 / $ / / \ J \ 2 a 5 c a \ / / / \ q / _ = E k m o / a)/ 7 \ } 3 /aj � / / 2 u 'o \ / � � � G » ) 6 k \ § \ o , _\ \ / o � ƒ ( / / k : \ %§ m » � m % / \ u a:( y .ƒ 'n \\ q on � ° o u / — t CD ° / o / 5 / < CD § / •Z $ 4 5 / 3 / / f » % n / O LU E � / ƒ y e s < $ 0 \ § / \ E E c ° a / % e ¥ 2 y •I a) 2 G / E m u § E u u m / g o # $ 0 § 2 = 3 . k / / \ 5 / / t $ ƒ E / , m f o O — c w � f \ % E E \ . k L� \ Ln / > 3 \ / / u f w S E G � $ \ u u -0 / V) 3 > $ ± > I > k § \ / Ln o S 12 f / f 2 tm \ { / 7 \ ° = m § / § e § ° _ § § I e = g 3 2 2 $ 2 / § \ 2 0 0 u / rn c a C O O 4' N Q O _ N l0 C C C Q 0 T O O L ++ O O L O d X Ul 3 r N � � r-1 4-J L O U LD E o �O E o L. 3 z d N o co V r_ M ai V a o co Q a 0 Location Description Includes loans and grants for rehabilitation of owner-occupied housing units through city sponsored programs, and in conjunction with affordable housing efforts sponsored by nonprofit housing corporations and other state and federal agencies. Includes funds to meet lead hazard reduction regulations in rehabilitated structures, funds to assist in emergency housing rehabilitation, market analysis activities and technical assistance to nonprofit housing corporations, contractors,and low-and moderate-income households. Includes loans and grants for owner-occupied single-family units through city sponsored programs, loans to rehabilitate historic homes in conjunction with rehabilitation of the unit, and loans or grants for ramps, hazard remediation or weatherization. Includes staff, office space, technical assistance,training and other direct project costs associated with delivery of Community Development Block Grant, HOME, Emergency Solutions Grant and other State and Federal Programs. General street, sidewalk, water/sewer improvements, including assistance to income eligible owner-occupants or those in CDBG-eligible areas for special assessments related to new improvements. Includes improvements to neighborhood parks, recreational facilities; public neighborhood, medical and community facilities in CDBG priority areas. Planned Activities Includes loans and grants for rehabilitation of owner-occupied housing units through city sponsored programs, and in conjunction with affordable housing efforts sponsored by nonprofit housing corporations and other state and federal agencies. Includes funds to meet lead hazard reduction regulations in rehabilitated structures,funds to assist in emergency housing rehabilitation, market analysis activities and technical assistance to nonprofit housing corporations, contractors,and low-and moderate-income households. Includes loans and grants for owner-occupied single-family units through city sponsored programs, loans to rehabilitate historic homes in conjunction with rehabilitation of the unit, and loans or grants for ramps, hazard remediation or weatherization. Includes staff, office space, technical assistance,training and other direct project costs associated with delivery of Community Development Block Grant, HOME, Emergency Solutions Grant and other State and Federal Programs. General street, sidewalk, water/sewer improvements, including assistance to income eligible owner-occupants or those in CDBG-eligible areas for special assessments related to new improvements. Includes improvements to neighborhood parks, recreational facilities; public neighborhood, medical and community facilities in CDBG priority areas. Annual Action Plan 51 2020 OMB Control No:2506-0117(exp.06/30/2018) 3 Target Area SOUTHWEST LANSING BAKER DONORA COMSTOCK PARK URBANDALE OAK PARK PRUDDEN EAST VILLAGE POTTER WALSH Goals Supported Acquisition Needs Addressed Suitable Living Environment Funding CDBG: $100,000 Description Includes acquisition, maintenance and security of properties acquired through programs, and activities related to acquisition, disposition, including demolition, relocation and clearance of dilapidated and blighted structures. Funds may also be used to acquire and clear properties in the flood plain. Includes staff time associated with this activity. Target Date 6/30/2021 Estimate the number and type of families that will benefit from the proposed activities Location Description Includes acquisition, maintenance and security of properties acquired through programs, and activities related to acquisition, disposition, including demolition, relocation and clearance of dilapidated and blighted structures. Funds may also be used to acquire and clear properties in the flood plain. Includes staff time associated with this activity. Planned Activities 4 Project Name Public Services Target Area SOUTHWEST LANSING BAKER DONORA COMSTOCK PARK URBANDALE OAK PARK PRUDDEN EAST VILLAGE POTTER WALSH Annual Action Plan 53 2020 OMB Control No:2506-0117(exp.06/30/2018) Description Technical assistance to individuals and microenterprises. Technical assistance to individuals and for-profit businesses including workshops, education,training, summits and pitch events. Target Date 6/30/2021 Estimate the number and type of families that will benefit from the proposed activities Location Description Technical assistance to individuals and microenterprises.Technical assistance to individuals and for-profit businesses including workshops, education,training, summits and pitch events. Planned Activities 6 Project Name CDBG General Administration Target Area SOUTHWEST LANSI NG BAKER DONORA COMSTOCK PARK URBANDALE OAK PARK PRUDDEN EAST VILLAGE POTTER WALSH Goals Supported CDBG General Administration Needs Addressed Suitable Living Environment Funding CDBG: $409,092 Description Includes staff and other costs associated with preparation of required Consolidated Planning documents, environmental clearances, fair housing activities and citizen participation activities associated with the delivery of CDBG, HOME and other state and federal programs. Includes planning and general administration costs associated with delivery of CDBG and other state and federal programs. Includes indirect administrative costs and building rent paid to the city. Target Date 6/30/2021 Annual Action Plan 55 2020 OMB Control No:2506-0117(exp.06/30/2018) Estimate the number and type of families that will benefit from the proposed activities Location Description Funds provided to homebuyers for down payment and closing costs for purchase of a single-family home located within the Lansing city limits. Up to $40,000 will be available as a 0% interest second mortgage for homebuyers with income at or below 80%of median income. Assistance not limited to first-time homebuyers. May include staff time and/or homeownership counseling fees associated with this activity. Planned Activities Funds provided to homebuyers for down payment and closing costs for purchase of a single-family home located within the Lansing city limits. Up to$40,000 will be available as a 0% interest second mortgage for homebuyers with income at or below 80%of median income. Assistance not limited to first-time homebuyers. May include staff time and/or homeownership counseling fees associated with this activity. 8 Project Name New Construction Target Area SOUTHWEST LANSING BAKER DONORA COMSTOCK PARK U R BAN DALE OAK PARK PRUDDEN EAST VILLAGE POTTER WALSH Goals Supported New Construction Needs Addressed Suitable Living Environment Affordable Housing Public Improvements Economic Development Public Housing Assistance to homeless and special needs groups Funding HOME: $600,393 Annual Action Plan 57 2020 OMB Control No:2506-0117(exp.06/30/2018) 9 Target Area SOUTHWEST LANSING BAKER DONORA COMSTOCK PARK URBANDALE OAK PARK PRUDDEN EAST VILLAGE POTTER WALSH Goals Supported HOME General Administration- limited to 10% Needs Addressed Affordable Housing Funding HOME: $75,199 Description Includes staff and general administration costs to deliver the HOME program. Target Date 6/30/2021 Estimate the number and type of families that will benefit from the proposed activities Location Description Includes staff and general administration costs to deliver the HOME program. Planned Activities Includes staff and general administration costs to deliver the HOME program. 10 project Name CHDO Set-aside - 15% minimum required Target Area SOUTHWEST LANSING BAKER DONORA COMSTOCK PARK URBANDALE OAK PARK PRUDDEN EAST VILLAGE POTTER WALSH Goals Supported CHDO Set-aside - 15% minimum required Needs Addressed Affordable Housing Funding HOME: $112,799 Annual Action Plan 59 2020 OMB Control No:2506-0117(exp.06/30/2018) Location Description Community Housing Development Organization (CHDO) Operating- limited to 5%. Planned Activities Community Housing Development Organization (CHDO) Operating- limited to 5%. 12 Project Name HOMELESS SVS- EMERGENCY SHELTER-STREET OUTREACH-HOMELESS PREVENTION- HMIS-ADMIN Target Area SOUTHWEST LANSING BAKER DONORA COMSTOCK PARK URBANDALE OAK PARK PRUDDEN EAST VILLAGE POTTER WALSH Goals Supported Homeless Svcs-Shelter Operation-Street Outreach Needs Addressed Assistance to homeless and special needs groups Funding ESG: $176,452 Description The 2020 Federal Fiscal Year allocation of ESG Emergency Solutions Grant for the City of Lansing will be provided for homeless prevention activities, street outreach activities, emergency shelter and HMIS-funds will be used to cover the cost of maintenance, operations, insurance, utilities and furnishings in shelter facilities, data collection through HMIS and administration costs. $88,285 or 55%of the total ESG funding allocations will be used to fund emergency shelter. Street Outreach activities will account for 3%or$5,028 of the ESG funding. The amount of ESG funds budgeted for street outreach and emergency shelter activities does not exceed 60%. 35%or$60,000 will be used for Homelessness Prevention.Another 3%or 5,028 will be used for HMIS and 7%($11,918) of the 7.5%allowable administrative costs will cover those administrative related item. Target Date 6/30/2021 Annual Action Plan 61 2020 OMB Control No:2506-0117(exp.06/30/2018) Planned Activities The 2020 Federal Fiscal Year allocation of ESG Emergency Solutions Grant for the City of Lansing will be provided for homeless prevention activities, street outreach activities, emergency shelter, HMIS and administration -funds will be used to cover the cost of maintenance, operations, insurance, utilities and furnishings in shelter facilities,data collection through HMIS and administration costs. $91,755 or 52%of the total ESG funding allocations will be used to fund emergency shelter. Street Outreach activities will account for 3%or$5,294 of the ESG funding.The amount of ESG funds budgeted for street outreach and emergency shelter activities does not exceed 60%. 35%or$61,758 will be used for Homelessness Prevention. Another 3%or 5,294 will be used for HMIS and 7% ($12,351) of the 7.5%allowable administrative costs will cover those administrative related items. Annual Action Plan 63 2020 OMB Control No:2506-0117(exp.06/30/2018) Affordable Housing AP-55 Affordable Housing— 91.220(g) Introduction The City of Lansing will provide for the rehabilitation of 25 owner occupied homes and 29 additional for rental rehabilitation activities and 5 units for acquisition, including demolition with CDBG funds.Also, down payment assistance will be provided to 7 housing units and 4 proposed new construction with HOME funding. Details of the proposed funding and units provided are included in the City of Lansing's proposed funding allocation documentation and part of the Consolidated Plan submission. One Year Goals for the Number of Households to be Supported Homeless 0 Non-Homeless 75 Special-Needs 0 Total 75 Table 9-One Year Goals for Affordable Housing by Support Requirement One Year Goals for the Number of Households Supported Through Rental Assistance 29 The Production of New Units 4 Rehab of Existing Units 37 Acquisition of Existing Units 5 Total 75 Table 10-One Year Goals for Affordable Housing by Support Type Discussion The City of Lansing will project to accomplish the numbers identified in the goals and objectives of the Annual Action Plan for 2020. More specifically, for Affordable Housing, the one year goals for number of households supported through rental assistance is zero (29); production of new units is seven (4); rehabilitation of existing units is thirty-seven (37), acquisition is one (5), totaling seventy-five. Annual Action Plan 65 2020 OMB Control No:2506-0117(exp.06/30/2018) AP-65 Homeless and Other Special Needs Activities— 91.220(i) Introduction The City of Lansing Economic Department and Planning (EDP) and Human Relations and Community Services (HRCS) Departments work closely together in addressing the needs of the homeless population in this community. EDP and HRCS works with the CoC, Capital Region Housing Collaborative (CRHC) to administer the ESG dollars in the community. 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 Street outreach targets people staying in encampments and other unsheltered situations with the objectives of engaging people, assessing and addressing immediate needs, and referring people to the CoC's coordinated entry agency (CEA). The CoC funds outreach projects for both adults and youth. PATH funding has been awarded to the CoC, which is a significant increase in resources for outreach activities. Outreach and needs assessment are necessary for our CoC to ensure people who are not engaged in our shelter and services systems receive consideration, and if applicable, prioritization for intensive housing resources such as PSH.The CoC also works closely with VA outreach programs to identify and engage veterans in unsheltered settings. Once engaged, individual needs assessments are provided through the CoC's Coordinated Entry Agency or by outreach workers trained in using the VI-SPDAT assessment tools. Day shelters in the community provide opportunities for people experiencing homelessness to access resources to meet their immediate basic needs and to meet with coordinated assessment staff without having to stay in a shelter. In January 2019, a new "Outreach Center" opened targeting people who are unsheltered homeless and do not typically utilize the traditional shelter system.The facility offers a safe, secure place for people to stay as well as facilities for showering and washing clothes. This has created another avenue for people who are homeless but do not choose to stay in shelters, to engage with housing services and access the coordinated entry system. The CoC conducts an unsheltered Point in Time (PIT) Count annually. Each year the number of locations visited has increased and the outreach efforts further the effectiveness of the PIT by building a greater awareness of locations where people stay and a better understanding of why some are not engaged in the shelter system. Since many outreach staff are involved in the PIT,there are opportunities to refine Annual Action Plan 67 2020 OMB Control No:2506-0117(exp.06/30/2018) necessary,to other community supports and mainstream resources.This may include: Referral to DHHS State Emergency Relief or Emergency Services, Rapid Re-Housing projects to provide short or medium term rental assistance, PSH for eligible households, placement on the homeless preference Housing Choice Voucher waiting lists or addition to the Behavioral Health Coordination Interdisciplinary Team (IDT) list for high-needs individuals for wrap-around case coordination.This past year,the local CMH established a Mobile Crisis Unit that can provide mental health outreach services wherever clients may be, sheltered or unsheltered.This has enhanced homeless provider engagement efforts. Coordinated Entry staff participates with shelters, housing, and health/mental health providers in a weekly IDT meeting where high VI-SPDAT families and individuals (those with the longest history of homelessness, chronic homelessness, and greatest needs) are identified and prioritized for PSH and the most intensive resources and services provided based on their individual needs. This collaboration allows case managers to work in a more coordinated way on specific cases. The CoC has adopted Housing First policies for PSH and RRH projects, where appropriate. Efforts to shorten the length of time that people experience homelessness include a shelter diversion strategy to help people calling and presenting at shelters to identify alternative arrangements before they enter a shelter. For people in shelters, the Coordinated Entry staff are available on-site to meet with clients to develop housing plans, provide resources on affordable housing and housing leads and inform people of available mainstream benefits or housing assistance.Additional RRH resources coming into the community from HUD CoC DV Bonus funding will help with housing people fleeing DV situations.This has been an underserved group and the project is slated to start in the fall of 2020 to specifically address this population. Length of time in shelter is increasing locally, which is by design. Extending stays for people with severe barriers to housing has proven more effective than requiring them to shuffle through different shelters or unsheltered situations. Keeping people connected to case managers and housing specialists in the shelter system has led to more successful housing outcomes especially for high-needs clients, compared to having arbitrary stay limits at shelters. Housing for homeless veterans is being addressed by the CoC Veterans Services Coordination Workgroup. The group has a By Name List (BNL) of homeless veterans and service providers who are collaborating and connecting veterans to available resources to end their homelessness. The entire response system is continuously reviewed to ensure veterans who become homeless are served and rehoused quickly. USICH recognized our CoC in May 2019 as having met all the criteria and benchmarks of"effectively ending"veteran homelessness through the coordinated efforts. To address recidivism, Rapid re-housing providers work with their clients throughout the term of their program enrollment on budgeting, increasing income, establishing savings accounts, and accessing and utilizing mainstream resources and other support networks to ensure that housing can be maintained after the financial assistance has ended. 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 Annual Action Plan 69 2020 OMB Control No:2506-0117(exp.06/30/2018) people with co-occurring disorders, prioritizing homeless. Discussion There is a broad array of resources available in the community to assist people experiencing homelessness. Programs that address housing and supportive housing needs include the following: Walnut Street Apts, serving nine clients with a history of mental illness and homelessness, who are referred through Community Mental Health (CMH) and provided housing at a reduced rate with case management; Ballentine Apartments (previously Transitional Housing Program), subsidized by MSHDA, project based voucher project with supportive services, an 18 unit (16-1bd, 2 2bd) family serving single adults and small families; Gateway Child and Family Charities has a Permanent Services Housing(PSH) program for young adults with children, a 10-12 unit facility providing housing and supportive services; Mid -Michigan Recovery System (MMRS), provides housing and supportive services assistance to clients recovering from substance abuse, in a bridge housing program; Lansing Housing Commission (LHC) has a Shelter Plus Care program with 36 single I bedroom units. There are also PSH programs in the community providing housing and case management supportive services to those in need. Many of the units are for single adults and a portion of rent is paid.They include Advent House Ministries (3 programs), LHC has a 68 single-1 bedroom; 2—2bedroom PSH program, Holy Cross Services has 2-3 PSH programs. CoC member agency, Capital Area Housing Partnership, offers the Tuesday Toolmen Program, which utilizes senior citizen volunteers to provide handicap ramps and other interventions including grab bars, to assist with improving safety and mobility. The City of Lansing's CoC is the Capital Region Housing Collaborative (CRHC). The CRHC is working to resolve and prevent homelessness through the promotion of partnerships and programs that create housing opportunities, build life skills and provide integrated supportive services to individuals and families as well as special needs (i.e. elderly, frail elderly, persons with disabilities(mental, physical, developmental, persons with alcohol or other drug addiction), persons with HIV/AIDS and their families, DV Survivors and public housing residents in need. There are several resources available in the larger community for those at risk of homelessness and those special needs groups. The Network will continue a collaborative approach to creating a comprehensive,visionary, realistic Strategic Plan (attached)to help the homeless.The CRHC has participated with several organizations to develop discharge planning policies among the four systems of care: foster care, hospitals, mental health and corrections. HMIS will continue to be the data system used to gather comprehensive data about clients receiving services Annual Action Plan 71 2020 OMB Control No:2506-0117(exp.06/30/2018) AP-85 Other Actions — 91.220(k) Introduction: The City of Lansing will continue its efforts to assure that fair housing principles are followed in the city. The City of Lansing Department of Economic Development and Planning (EDP) have completed its Analysis of Impediments (AI)to Fair Housing Choice. It is the intent to produce a comprehensive document that meets HUD guidelines as well as provide pertinent data, location of population concentration of protected groups, economic analysis, home lending patterns and practices, analysis of fair housing complaints, etc.A completed copy of the report is attached to the plan.The City of Lansing's DEDP, Human Relations and Community Services (HRCS) Department and Lansing Housing Commission work collaboratively to address fair housing issues which includes working with community organizations to educate citizens about fair housing issues and pursue enforcement in cases of housing discrimination; work to eliminate predatory lending practices that disproportionately affect protected groups, and respond to inquiries/complaints relative to fair housing. The City of Lansing has a strong faith-based community, particularly among the homeless service providers. Most of the homeless shelters are grounded in organizations that are motivated by their religious principles. Several of the emergency services in Lansing are supported or operated by faith- based organizations. City staff involvement with the homeless population includes serving on several boards to address the needs of this community including the Continuum of Care. This partnership includes: assistance in funding rehabilitation and new construction of housing units. The City continues to make a concerted effort to work with various agencies to prioritize programs and services for those in the greatest need. Actions planned to address obstacles to meeting underserved needs The actions that the City of Lansing plans to undertake to address obstacles in meeting the underserved needs in the community are addressed in the projects section of the Plan. More specifically, the City of Lansing makes every effort to address housing and community development needs. However, addressing all housing, community development and homeless needs is a difficult task due to lack of funding and shrinking funds.The City of Lansing will continue to utilize all resources including leveraging funds to meet the needs of the underserved. The most vulnerable and underserved population includes those that are at risk of or homeless. More specifically, as identified through its collaborative efforts with the Continuum of Care (CoQ the City of Lansing's planned action steps to meeting the underserved needs includes partnering with several organizations, creating a comprehensive,visionary, realistic CoC plan to help the homeless/underserved. HMIS data leveraged to measure progress and identify changing Other actions to address the underserved needs include the continued efforts to implementing the Lead Safe Lansing program and working with the Ingham County Health Department to identify those homes with lead and assisting those low income families with lead remediation. Also, many low income persons/families have several issues with maintaining a good credit rating as well as obtaining safe and Annual Action Plan 73 2020 OMB Control No:2506-0117(exp.06/30/2018) needs in the city.The City has a Housing Ombudsman position to specifically address the housing needs in the Lansing community. Actions planned to enhance coordination between public and private housing and social service agencies There are formal and informal efforts at coordinating activities between or among many participants including the city, state and federal units of government, housing commission, public agencies or private sector agencies such as lending institutions, health care provider, non-profit housing corporation,social service agencies, neighborhood organizations, etc. Specific and detail activities the City plans to take to enhance coordination between public and private housing and social service agencies include the following: continued coordinated activities in the with community; continued meeting with partner agencies and organizations to strengthen the working relationship, CoC will continue its Humans Services Committee meetings which improves the CoC performance via enhanced coordination among GLHRN, community and member agencies.The City will continue to support the CoC organization to assist in addressing the needs of those homeless and or at-risk of homelessness. The City of Lansing coordinates activities with the Ingham County Health Department as well as provides funding for them to identify those homes containing lead with children under the age of six living in those homes.The City of Lansing will utilize its Lead Safe Lansing funds to rehabilitate/remediate those lead based homes.The City of Lansing will continue its collaborative efforts with the Michigan State Historic Preservation Office to offer training to staff as it relates to historic preservation/properties.The City of Lansing will work collaboratively with the Lansing Housing Commission on self-sufficiency activities for their clients to prepare them for housing by moving resident out of public housing into newly renovated units.Also,the City of Lansing will continue to address Fair Housing issues and assure that in preparation for the upcoming Affirmatively Furthering Fair Housing Plan, continue to implement the policies/procedures/recommendations identified to address impediments in the City of Lansing's 2015 Analysis of Impediments to Fair Housing Choice. Discussion: Per Lansing's HOME Manual, below is Lansing's policy regarding Affirmative Marketing Requirements: Affirmative Marketing and Minority Outreach: Each HOME developer must adopt and follow affirmative marketing procedures and requirements for rental and homebuyer projects containing 5 or more home-assisted housing units. These procedures and actions will provide information and otherwise attract eligible persons in the program service area to the available housing or assistance without regard to race, color, national origin, sec, religion, familial status or disability. HOME developers shall use the Equal Housing Opportunity Slogan, logo, or statement min all advertisements, public service announcements, press releases and information mailings. The HUD fair housing poster must be displayed in offices where rental activity takes place for all properties with 5 or Annual Action Plan 75 2020 OMB Control No:2506-0117(exp.06/30/2018) Program Specific Requirements AP-90 Program Specific Requirements— 91.220(1)(1,2,4) Introduction: Program Specific requirements for Community Development Block Grant, HOME and ESG are identified below. Community Development Block Grant Program (CDBG) Reference 24 CFR 91.220(I)(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 50,000 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: 75,000 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. 80.00% HOME Investment Partnership Program (HOME) Reference 24 CFR 91.220(I)(2) 1. A description of other forms of investment being used beyond those identified in Section 92.205 is Annual Action Plan 77 2020 OMB Control No:2506-0117(exp.06/30/2018) severity of needs and urgency of housing crisis and targets the most appropriate response. Depending on urgency and priority, the VI-SPDAT is followed by a more comprehensive assessment to identify unique housing barriers and needs.Those experiencing chronic homelessness and with the highest services needs are prioritized for supportive housing resources and wrap-around service coordination.This assessment serves as the basis for creating a housing plan and a tool for resource coordination and resolution of the housing crisis. Housing assessments are entered on HMIS to facilitate sharing with CoC member agencies that use HMIS. The Housing Plan must be completed for all individuals that receive a housing assessment and are determined eligible for services.The Housing Plan is a guide for the household and service agencies and provides focus, goals, outcomes and collaboration of community resources and referrals to mainstream services.The CEA staff also assists in gathering needed documentation for program eligibility, maintains the CH By-Name List, and refers priority households to PSH and RRH programs. 2. Identify the process for making sub-awards and describe how the ESG allocation available to private nonprofit organizations (including community and faith-based organizations). The CRHC-CoC uses an open solicitation process for notifying potential applicants.The CoC issues a request for proposal (RFP)to all CoC member agencies to apply for ESG funds and applications are submitted and reviewed by the CoC Finance Committee.The CoC Board, community partners, and fiduciary determine sub-awards through a competitive application using an impartial, data-driven process. Decisions are made based on HUD and CoC priorities, in an open process with all agencies and City Departments.The ESG application and Ranking and Review tool are developed by the CoC Finance Committee, and reviewed and approved by the CoC Board and the fiduciary. The review includes assessment of program goals, objectives, measureable outcomes,target populations to be served, organizational capacity and other factors. Prior to the application process, the CoC assesses community needs and gaps. ESG funding allocations are then divided into the five eligible components with larger allocations designated for the components most needed in the community, with an eye to services funded through other sources. ESG funding opportunities are advertised via email, websites, network meetings, and city resources, to encourage new and existing applicants. The CoC Network encourages new proposals by any interested and eligible agency including private non-profits, community and faith-based organizations. All applicants are notified via e-mail of the funding decisions. 3. 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 CoC Board has members who are formerly homeless. However, in instances where there is no representation on the CoC Board of Directors,the general CoC"Network" membership always consists of homeless and/or formerly homeless participants who are instrumental in the decision- making process of the CoC.The general meetings are held the third Thursday of the month but there Annual Action Plan 79 2020 OMB Control No:2506-0117(exp.06/30/2018) • Average length of stay (ES only) • Average length of time to move into housing (RRH only) • Returns to homelessness within 1 year of discharge (RRH & Prevention; only agencies using HMIS) Recidivism to shelter—for ES: people returning to shelter following a shelter discharge; for Prevention and RRH: people returning to homelessness within 12 months of program exit. The baseline for comparison of the performance measures is set using historic project-level data, performance benchmarks from national organizations including USICH and the National Alliance for Ending Homelessness, and benchmarks from other similar project types in the CoC. High performing agencies share their practices with other providers to spread effective practices to all CoC members. Programs performing below targets are expected to explain the reasons behind their low achievement and how they plan to improve going forward. Depending on the nature of the explanation and the plan presented, Programs that are under-performing year after year are considered for reallocation or de-funding, depending on the CoC Board's and the fiduciary's priorities and assessment of capacity. Following the CQI committee's approval of the accuracy and completeness of the ESG quarterly report the information is sent to the CoC Board for their review and approval. Annual Action Plan 81 2020 OMB Control No:2506-0117(exp.06/30/2018)