Colorado Springs: Public Comment Opportunity: Proposed Changes to Community Development Division Planning Documents for CARES Act Funding

The City of Colorado Springs Community Development Division (CDD) is seeking a substantial amendment to its 2020-2024 Consolidated Plan and Citizen Participation Plan in order to receive funds recently allocated by the U.S. Department of Housing and Urban Development to prevent, prepare for, and respond to the coronavirus.

Starting July 31, City staff will start its condensed 5-day public comment period to request feedback in shaping the final draft the 2020-2024 Consolidated Plan/2020 Annual Action Plan and Citizen Participation Plan. These changes will make the City eligible for the use of CARES Act funds received on April 2 from the U.S. Department of Housing and Urban Development (HUD). The Division will receive about $1.8 million in extra CDBG and $887,124 in extra ESG funds to assist low-income communities affected by the coronavirus.

The draft changes are in the document links below:

2020-2024 Consolidated Plan/2020 Annual Action Plan

Citizen Participation Plan

A summary of all changes are below. Please submit all comments and feedback to Community Development by August 4, 2020 at communitydevelopment@coloradosprings.gov.

1. Substantial Amendment 1 to the 2020-2024 Consolidated Plan and 2020 Annual Action Plan
What is a substantial amendment?

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A substantial amendment is triggered by a change of purpose, scope, location, or beneficiaries to a City's entitlement spending plans. The following changes are considered substantial amendments:
  1. Changes in funding by at least 20% of the amount allocated to the City's entitlement grant programs. Changes in projects proposed, beneficiaries or persons served. The proposed amendment deletes a project described in the Consolidated Plan. The proposed amendment adds a project not described in the Consolidation Plan.

The amendment proposed by the City of Colorado Springs Community Development Division falls under #1 and #4 because of CARES Act funding allocated by HUD to help jurisdictions prevent, prepare for, and respond to the coronavirus.

Why is a substantial amendment necessary?
Accepting this first round of CARES Act funding - $1.8 million in CARES Act CDBG (CDBG-CV) and $887,124 in Emergency Solutions Grant (ESG-CV) funding - means that City of Colorado Springs must fit these funds and a spending plan into its current action plan.

All substantial amendments must go through a public review and comment period. In accordance with the regulatory waiver granted by HUD on March 31, 2020, the City of Colorado Springs has reduced the comment period from 30 to 5 days. Any Colorado Springs resident, group, or agency may review changes and submit comments to communitydevelopment@coloradosprings.gov from Friday, July 31 to Tuesday, August 4.

How did the City decide on these changes?
The CDBG-CV and ESG-CV funds come with requirements to address the impacts of the coronavirus. Over the last few months, Community Development has collaborated with multiple community partners in areas of public health, housing, emergency response, and social work to determine the short-term and medium-term needs of the most vulnerable residents, as evidenced by client data and other local indicators of health, employment, and wellbeing. These funds will be made available, some through a competitive process, to qualified agencies meeting those needs while serving low- to moderate-income people affected by the coronavirus.

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Summary of changes in the 2020-2024 Consolidated Plan/2020 Annual Action Plan
  • SP-35 – Anticipated Resources (pg. 142): Adds amounts allocated to City's ESG and CDBG programs in Round 1 of HUD's CARES Act funding. AP-15 – Expected Resources (pg. 169): Adds amounts allocated to City's ESG and CDBG programs in Round 1 of HUD's CARES Act funding. AP-20 – Annual Goals and Objectives (pg. 173): Adds CARES Act funding to core goals and adds coronavirus response to goal descriptions. AP-35 – Project Summary (181): Adds funding and activity details to planned ESG-CV and CDBG-CV projects.

2. Changes to the Citizen Participation Plan
HUD has waived 24 CFR 91.105(c)(2) and (k) in order to respond quickly to COVID-19. This balances the need to respond quickly to the growing spread and effects of COVID-19 with the statutory requirement to provide reasonable notice and opportunity for citizens to comment on substantial amendments concerning the proposed uses of CDBG, HOME, and ESG funds.

The waiver reduces the required public comment period from 30 days to 5. The waiver also allows jurisdictions to define reasonable notice and outline opportunities for public participation throughout the period of this public health crisis.

Summary of changes to Citizen Participation Plan
  1. COVID-19 Exceptions (pg. 10): Defines vehicles for reasonable notice (newspaper, email, and website update) and establishes a 5-day public comment period for substantial amendments to plans. Section 502- Policy of Non-Discrimination (pg. 15): Updates name and contact info for the City's Office of Accessibility.
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