FY 2021 22 CITY OF GLENDALE HUD ANNUAL ACTION PLAN
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FY 2021‐22 CITY OF GLENDALE HUD ANNUAL ACTION PLAN PUBLIC COMMENT PERIOD 2021‐22 Annual Action Plan is open for public review and comment from Friday, March 12, 2021 through Sunday, April 11, 2021 and is available at glendaleaz.com/communityserviceplans. Comments may be sent to revitalization@glendaleaz.com through the end of the comment period.
EXECUTIVE SUMMARY
ES‐05 Executive Summary – 24 CFR 91.200(c), 91.220(b)
1. Introduction
As a recipient of Community Development Block Grant
(CDBG) and Emergency Solutions Grant (ESG) funds, the
City of Glendale is required to submit an Annual Action
Plan (AAP) under Federal Regulations at 24 CFR Part 91.
The purpose of the Year 2 Annual Action Plan is to review
and update the assessments presented in the City of
Glendale’s Five‐Year Consolidated Plan for Fiscal Years (FY)
2020‐2024. In addition, the AAP identifies the City’s
housing and community development needs; analyzes the
housing market; establishes housing and community
development priorities, and identifies the resources
available from Community Development Block Grant
(CDBG) and Emergency Solutions Grant (ESG) entitlement
grants, as well as the HOME Investment Partnership
Program (HOME) allocations provided through the
Maricopa HOME Consortium.
This Program Year 2 AAP implements the second year of
activities that will address goals established by the City of
Glendale’s FY 2020‐2024 Consolidated Plan.
The CDBG entitlement for Fiscal Year (FY) 2021‐22 is
$2,423,635 and the ESG entitlement for FY 2021‐22 is
$211,275. The City is a participant in the Maricopa HOME
Consortium (Consortium) and will receive $686,496 in
HOME funds from Maricopa County in FY 2021‐22.
2. Summary of the objectives and outcomes identified in
the Plan Needs Assessment Overview
Identified below are the goals and outcomes that
the City of Glendale has identified as the basis for its
strategies and related activities to be carried out under the 2020‐24 Consolidated Plan and subsequent
Annual Action Plans. Actual activities may vary each Plan year and will be based on priorities established
during the Consolidated Plan process and the amount of the City’s annual allocation. While goals and
outcomes are identified in the Consolidated Plan with estimated funding, actual funding for activities will
be based on the Annual Action Plan Goals and Objectives and final entitlement allocations from HUD.The City’s 2020‐24 Five Year Consolidated Plan goals are:
Promote Access to Decent Affordable Housing
Glendale will work to promote access to affordable quality housing throughout the City through a
GOAL 1
variety of activities that may include construction, rehabilitation and replacement of owner and
renter housing, homeownership assistance, or rental assistance that helps low‐ and moderate‐
income families obtain and/or maintain decent, safe, and affordable housing.
Increase Access to Homeless Services/Housing
Through its ongoing Strategic Planning process and work with the Maricopa Regional Continuum
GOAL 2
of Care, the City will identify ways to partner with government, nonprofit and private sector
organizations to offer additional emergency shelter, transitional housing, permanent and
supportive housing, and necessary supportive services to mitigate crisis situations and promote
self‐sufficiency to homeless people and those at risk of homelessness.
Increase Access to Public Services for Vulnerable Populations
Through our funding of nonprofit agencies, the City will provide additional services to support
GOAL 3
low‐ and moderate‐income people, particularly food assistance and senior and youth
services. Other vulnerable groups may include those with disabilities, victims of
domestic abuse, children in or aged out of foster care, those suffering from addiction or mental
health diseases and possibly others.
Provide Educational Programs and Business Assistance
Through our funding of programs with government and nonprofit providers or collaborative
partnerships, the City will provide additional services to support low‐and‐moderate income youth
GOAL 4
and adults with educational programs. Programs can include those that supplement youth
learning and skills development, job training and skills development for adults, specific
employment training, financial self‐sufficiency training, and direct financial assistance to
businesses.
Enhance Livability of Neighborhoods
Several areas within the City have significant aging infrastructure needs, particularly related to
GOAL 5
ADA compliance and water systems. Neighborhood enhancements, such as parks, streetscape
beautification, demolition of unsafe and blighted structures, and exterior commercial
rehabilitation would also be considered under this category. The City will pursue these strategies
to enhance livability of neighborhoods in eligible areas or on a spot basis.
Affirmatively Further Fair Housing Regulations
Per 42 U.S.C. §§ 3601‐19, the Fair Housing Act, all Federal programs relating to housing and
GOAL 6
urban development be administered in a manner that affirmatively furthers fair housing.3. Evaluation of past performance
As a recipient of CDBG funds, the City is required to submit at the end of each program year a Consolidated
Annual Performance and Evaluation Report (CAPER). The CAPER summarizes the accomplishments of
the prior program year and the progress made towards the goals established in the Consolidated Plan. Note
that the 2019‐20 CAPER activities were funded under the City’s 2015‐19 Consolidated Plan and were
developed to advance the goals in that Consolidated Plan.
The CAPER for FY 2019‐ 20 was reviewed to assist with the formulation of goals and objectives as stated in
this Plan, as well as to evaluate past performance. Combined, the City expended $2,036,642.20 in CDBG,
HOME, and ESG funds in FY2019‐20.
The City addressed the Decent/Affordable Housing and Homeless objective by funding homeowner housing
rehabilitation activities, homeless assistance, homebuyer assistance, and acquisition and rehabilitation of
housing for resale.
The City addressed the Suitable Living Environment objective by funding home modifications for persons
with disabilities, public facility renovations, infrastructure improvements, and public services that
assisted seniors, youth, homeless persons, and affirmatively furthered fair housing. In addition, the City
addressed the Expanded Economic Opportunities goal by providing funding for façade treatment/business
building rehabilitation and job creation.
Programs and funding allocations are considered and approved based on extensive public participation,
input from Glendale's non‐profit partners, City Council goals, discussions with the City’s Community
Development Advisory Committee (CDAC), community resident and business input, and supporting data
that identifies urgent community needs. Glendale has transitioned to the outcome‐based Federal model.
Glendale also has its own internal strategic objectives that are outcome‐based and are used extensively
throughout the organization. In FY 2019‐20, and with the exception of the 1.5 expenditure ratio, the City
met all of its statutory requirements, including the HOME commitment dates. The City is committed to
monitoring outcomes compared to intended objectives and evaluating their effectiveness in addressing
community needs and reprogramming funding that is not being efficiently used, if needed.
4. Summary of citizen participation process and consultation process
Glendale residents, especially those who are low‐income or likely to be beneficiaries of federal CDBG,
HOME, and ESG funding, are encouraged to participate in the development of the Five‐Year Consolidated
Plan, Annual Action Plans, Plan Amendments and the CAPER. Per 24 CFR Part 91.105, citizen participation
requirements guide the development of the AAP process.
The Annual Action Plan development process is consistent with the City’s Citizen Participation Plan shared
by each of the members of the Maricopa HOME Consortium. Components of this Plan include:
Hold a minimum of two (2) public hearings related to the development of the Annual Action Plan
with one (1) public hearing conducted during the development of a draft Annual Action Plan and
one (1) public hearing conducted after a draft Annual Action Plan is available to the public, and
within the required 30‐day comment period;
Incorporation of the following information into public hearings: 1. the total amount of CDBG,HOME and ESG funding available during the upcoming program year, and the possible activities
that may receive allocations; 2. the anticipated amount of funding that will benefit low and
moderate income community members, and other applicable elements of the Plan;
Distribution of the draft Annual Action Plan to libraries, local housing authorities, and other
locations (as appropriate) to make the Plan available to a wide public audience
Posting the draft Plan on the City’s website during the 30‐day comment period
Notification of the availability of the draft Plan in a newspaper of general local circulation;
Provide accommodations to persons with disabilities, including the hearing impaired, and
persons with limited English proficiency.
Hold public hearings in the evenings and at times that would be convenient for working
families, including households with children.
5. Summary of public comments
The FY 2021‐22 AAP was available for public comment for a 30‐day period starting Friday, March 12th, 2021
through April 11th, 2021. Public hearings were conducted on Thursday, March 11, 2021 and Thursday,
March 18, 2021. The second public hearing was held during the regular Community Development Advisory
Committee Meeting. TBD comments were received during the comment period.
6. Summary of comments or views not accepted and the reasons for not accepting them
TBD
7. Summary
As one of Arizona’s fastest growing cities, Glendale has the opportunity to expand housing and economic
opportunities for its citizens. With significant growth comes challenges for affordable housing, especially
with the robust growth of its single‐family market. Because of this continued growth, current upward price
trends in the housing market ensure that affordable housing will remain an issue for the foreseeable
future.
Glendale is working to provide more affordable housing through HOME funding of Habitat for Humanity,
Tenant Based Rental Assistance, First‐time Homebuyer Assistance, and through rehabilitation assistance to
support low‐ and moderate‐income citizens, with particular consideration given to keeping seniors and
people with disabilities in their homes. Mortgage/rental/utility assistance is also a priority for helping
citizens maintain their housing and prevent homelessness.
The City will also identify neighborhood enhancements such as infrastructure improvements within low‐
mod income areas, such as water system and ADA improvements to parks serving low‐ and moderate‐
income households. Streetscape beautification, demolition of unsafe structures and commercial
rehabilitation are among other possible activities to enhance neighborhoods. The City will consider
other infrastructure and public facility improvements, such as libraries, youth centers, and recreation
centers as possible neighborhood enhancements, though these amenities are not as high a priority.
Glendale will fund public services for low‐ and moderate‐income families through the funding
of several governmental and nonprofit agencies whose efforts and expertise are critical to maximizing the
impact of CDBG and ESG funds. Additionally, CARES Act funding will be utilized to meet the needs ofcitizens most impacted by the COVID‐19 pandemic. Through its work with the Continuum of Care and an ongoing Strategic Planning Process, the City will work to prevent and reduce homelessness and provide needed housing and supportive services to vulnerable citizens. Glendale has succeeded as a community by working in partnership with other agencies throughout the West Valley and in Maricopa County by building on each organization’s respective strengths. By tapping into the human assets of its community, Glendale can work to ensure that all citizens have an opportunity to be independent, productive members of the community who live stable and productive lives. PR‐05 Lead & Responsible Agencies ‐ 91.200(b) 1. Agency/entity responsible for preparing/administering the Consolidated Plan The following are the agencies/entities responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source. Agency Role Name Department/Agency CDBG Administrator GLENDALE Community Revitalization Division ESG Administrator GLENDALE Community Revitalization Division Table 1 – Responsible Agency Narrative The City of Glendale's Community Revitalization Division, located at 5850 West Glendale Avenue, Suite 107, Glendale, Arizona 85301, is the lead and responsible agency for the development of the Annual Action Plan (AAP) for CDBG and ESG funds. The City receives an allocation of Home Investment Partnerships Program (HOME) funds as a member of the Maricopa HOME Consortium. The Maricopa County Human Services Department is the lead agency for the Annual Action Plan Public Contact Information Mr. Matthew Hess, Revitalization Administrator Community Revitalization Division, Community Services Department City of Glendale 5850 W Glendale Avenue, Suite 107 Glendale, AZ 85301 623‐930‐3670 AP‐10 Consultation ‐ 91.100, 91.200(b), 91.215(l) 1. Introduction In its operation of the federal block grant programs, the City works with local and statewide governmental
agencies and non‐profit organizations, as well as other City departments, to ensure funds are allocated equitably and related services are provided to the City of Glendale residents. 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 (91.215(l)). The City consulted with public and private agencies, the state, and the public housing authority for preparation of the Year 2 Annual Action Plan. The City provides funding for several social service providers that are based in Glendale, AZ to provide services to the residents of Glendale. These agencies include Back to School Clothing Drive, Community Legal Services and Arizona YWCA of Metro Phoenix. The City’s Community Housing Division is responsible for addressing the rental housing needs of low and very low‐income Glendale households that cannot afford housing in the private market through the administration of the federally funded Housing Choice Voucher program. The City provides CDBG public services funding to support seniors, disabled, youth and adults, education, homeless prevention, food banks and other social services. The City consulted with its housing authority, which is a City Divisional Unit, by including staff representatives in the public meetings and conducting interviews with housing authority management. In addition, the City consulted with staff from related City departments, specifically the City’s Community Action Program (CAP) that assists low‐to‐moderate income residents experiencing financial hardships or crisis. CAP provides various types of assistance to prevent homelessness, such as case management, information and referral to local social service agencies. CAP provides direct financial assistance for eligible households. 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 Glendale is a participant in the Maricopa Regional Continuum of Care (COC) and is a member of the Maricopa Association of Governments (MAG). The City provides support to the COC and several non‐ profit partners that provide services to alleviate homelessness, including, but not limited to shelter assistance, transportation, street outreach and housing navigation, rental subsidies, employment, food and others. The City of Glendale participates with MAG’s regional Point‐In‐Time Homeless Street and Shelter Count and provides data to HUD for the Housing Inventory Count Report. The City utilizes this data to develop strategies to address homelessness. The City participates with MAG’s Continuum of Care Regional Committee on Homelessness, which is responsible for developing the Regional Plan to End Homeless and prepares the COC application for funding to support homeless assistance programs. The City also participates in the ESG Funders Group. This ESG collaboration group is a team of ESG grantees that meet once a month to coordinate best practices and consistent procedures related to the ESG program performance standards and efforts to end homelessness.
The City also has the Homeless Executive Taskforce. This is an internal initiative between City Departments.
Together they discuss the issues facing homelessness and collaborate on solutions to end homelessness.
In January of 2019, the City of Glendale adopted a Homeless Strategy that will align existing resources with
new opportunities to reduce homelessness in Glendale. This process is a focused strategy which is
progressive and holistic: research, education, coordination, outreach, and performance management.
The results of the new process will provide the City with four distinct strategies:
Coordinated and responsive homeless engagement;
Effective implementation of housing stabilization programs;
Efficient and effective utilization and distribution of current resources/funding;
Reduction in Glendale residents experiencing or at‐risk of experiencing homelessness.
The Homeless Strategic Action Plan is a framework which allows it to grow and evolve as the City and data
analysis deems necessary and prudent. The updated homeless action plan expands the foundation
established in the original plan, allowing and encouraging the City to improve the focused, strength‐based
approach which will continue to address and assist the homeless population in our community. With the
additional funding resource provide through the CARES Act and COVID‐19 Pandemic funding, the City of
Glendale will, in a coordinated effort fund a master services agreement with a partnering agency to meet
this Homeless Strategy.
In addition, the West Valley Municipal Human Services Collaborative, which the City of Glendale created in
2018, continues to grow and connect cities in the west valley to maximize limited resources and work
together to address the homeless population, which cross jurisdictional boundaries.
Describe consultation with the Continuum(s) of Care that serves the jurisdiction’s area in determining
how to allocate ESG funds, develop performance standards for and evaluate outcomes of projects and
activities assisted by ESG funds, and develop funding, policies and procedures for the operation and
administration of HMIS
The City receives ESG funds and consults with Continuum of Care (CoC) as part of the process to prioritize
the needs to address homelessness, the allocation of ESG funding, and performance standards. To ensure
the participation of the homeless population in the planning process, the City of Glendale engages in
regional activities and dialogue with the State of Arizona and the CoC Committee on Homelessness. An
example of a successful regional collaborative effort is the region’s Annual Homeless Count. The City’s
collaboration is intended to use the most current and accurate information available to design and
implement necessary housing and social service assistance to bring homeless persons back into our
workforce, schools, faith‐based institutions, and other community institutions as well as facilitate them
becoming stable. The City consulted with the CoC to discuss the best method to allocate funding to non‐
profit agencies. As the program progresses, performance standards will be developed based on the needs
of the community and regulatory guidance. All outcomes will be reviewed and measured for effectiveness,
as required.2. Agencies, groups, organizations and others who participated in the process and consultations
1 Agency/Group/Organization Glendale Union High School District
Regional organization
Agency/Group/Organization Type Services‐Education
Services ‐Homeless
Housing Need Assessment
Homelessness Strategy
Homeless Needs ‐ Families /w
children
What section of the Plan was addressed by
Non‐Homeless Special Needs
Consultation?
Market Analysis
Anti‐poverty Strategy
Economic Development
Transportation issues
How was the Agency/Group/Organization The agency was provided a direct opportunity to
consulted and what are the anticipated review and comment on the draft Annual Action
outcomes of the consultation or areas for Plan.
improved coordination?
2 Agency/Group/Organization Glendale Community Action Program
Agency/Group/Organization Type Other government ‐ Local
Housing Need Assessment
Homelessness Strategy
Homeless Needs ‐ Families with children
What section of the Plan was addressed by Homeless Needs ‐ Chronically homeless
Consultation? Non‐Homeless Special Needs
Market Analysis
Anti‐poverty Strategy
Economic Development
How was the Agency/Group/Organization The agency was provided a direct opportunity to
consulted and what are the anticipated review and comment on the draft Annual Action
outcomes of the consultation or areas for Plan.
improved coordination?
Glendale Community Development
3 Agency/Group/Organization
Advisory Committee (CDAC)
Planning organization
Agency/Group/Organization Type Other government – Local
Business Leaders
Housing Need Assessment
Homelessness Strategy
Homeless Needs ‐ Families with children
What section of the Plan was addressed by Homeless Needs ‐ Chronically homeless
Consultation? Non‐Homeless Special Needs
Market Analysis
Anti‐poverty Strategy
Public Housing NeedsHow was the Agency/Group/Organization The agency was provided a direct opportunity to
consulted and what are the anticipated review and comment on the draft Annual Action
outcomes of the consultation or areas for Plan.
improved coordination?
4 Agency/Group/Organization Phoenix Rescue Mission (PRM)
Regional organization
Services ‐ homeless
Agency/Group/Organization Type Services ‐ Health
Services ‐ Employment
Service ‐ Fair Housing
Housing Need Assessment
Homelessness Strategy
Homeless Needs ‐ Families with children
Homeless Needs ‐ Chronically homeless
Homelessness Needs ‐ Veterans
What section of the Plan was addressed by
Homelessness Needs ‐ Unaccompanied
Consultation?
youth
Non‐Homeless Special Needs
Market Analysis
Anti‐poverty Strategy
Fair Housing issues
How was the Agency/Group/Organization The agency was provided a direct opportunity to
consulted and what are the anticipated review and comment on the draft Annual Action
outcomes of the consultation or areas for Plan.
improved coordination?
5 Agency/Group/Organization Glendale Public Housing Authority
Housing
Agency/Group/Organization Type
PHA
What section of the Plan was addressed by Housing Need Assessment
Consultation? Public Housing Needs
How was the Agency/Group/Organization The agency was provided a direct opportunity to
consulted and what are the anticipated review and comment on the draft Annual Action
outcomes of the consultation or areas for Plan.
improved coordination?
6 Agency/Group/Organization Glendale Chamber of Commerce
Regional organization
Agency/Group/Organization Type
Business Leaders
Non‐Homeless Special Needs
Market Analysis
What section of the Plan was addressed by
Anti‐poverty Strategy
Consultation?
Economic Development
Transportation issues
How was the Agency/Group/Organization The agency was provided a direct opportunity to
consulted and what are the anticipated review and comment on the draft Annual Action
outcomes of the consultation or areas for Plan.
improved coordination?7 Agency/Group/Organization Glendale Community Revitalization Division
Services related to the following:
Housing; Children; Elderly Persons; Persons with
Agency/Group/Organization Type Disabilities; Victims of Domestic Violence;
Homelessness; Health; Education; Employment; Fair
Housing; Veterans; Housing
Housing Need Assessment
Homelessness Strategy
Homeless Needs ‐ Families with children
Homeless Needs ‐ Chronically homeless
Homelessness Needs – Veterans
Homelessness Needs ‐ Unaccompanied
youth
What section of the Plan was addressed by
Non‐Homeless Special Needs
Consultation?
Market Analysis
Anti‐poverty Strategy
Economic Development
Transportation issues
Public Housing Needs
Lead‐based Paint Strategy
Fair Housing issues
How was the Agency/Group/Organization The agency was provided a direct opportunity to
consulted and what are the anticipated review and comment on the draft Annual Action
outcomes of the consultation or areas for Plan.
improved coordination?
8 Agency/Group/Organization Glendale Community Services Department
Services related to the
following: Housing; Children; Elderly
Persons; Persons with Disabilities; Persons with
HIV/AIDS; Victims of Domestic Violence;
Agency/Group/Organization Type
Homelessness; Health; Education; Employment; Fair
Housing
Housing
PHA
Housing Need Assessment
Homelessness Strategy
Homeless Needs ‐ Families with children
Homeless Needs ‐ Chronically homeless
Homelessness Needs – Veterans
What section of the Plan was addressed by Homelessness Needs ‐ Unaccompanied
Consultation? youth
Non‐Homeless Special Needs
Market Analysis
Anti‐poverty Strategy
Economic Development
Transportation issues Public Housing Needs
How was the Agency/Group/Organization The agency was provided a direct opportunity to
consulted and what are the anticipated review and comment on the draft Annual Action
outcomes of the consultation or areas for Plan.
improved coordination?
9 Agency/Group/Organization Glendale Economic Development Department
Planning organization
Services‐Education
Agency/Group/Organization Type
Services‐Employment
Other government – Local
What section of the Plan was addressed by Economic Development
Consultation?
How was the Agency/Group/Organization The agency was provided a direct opportunity to
consulted and what are the anticipated review and comment on the draft Annual Action
outcomes of the consultation or areas for Plan.
improved coordination?
10 Agency/Group/Organization Maricopa Regional Continuum of Care
Services related to the following:
Housing; Children; Elderly Persons; Persons with
Disabilities; Persons with HIV/AIDS; Victims of
Domestic Violence; Homelessness;
Agency/Group/Organization Type Other government ‐ County
Housing
PHA
Regional organization
Planning organization
Housing Need Assessment
Homelessness Strategy
Homeless Needs ‐ Families with children
What section of the Plan was addressed by Homeless Needs ‐ Chronically homeless
Consultation? Homelessness Needs ‐ Veterans
Homelessness Needs ‐ Unaccompanied
youth
Public Housing Needs
How was the Agency/Group/Organization The agency was provided a direct opportunity to
consulted and what are the anticipated review and comment on the draft Annual Action
outcomes of the consultation or areas for Plan.
improved coordination?
Table 2 – Agencies, groups, organizations who participated
Other local/regional/state/federal planning efforts considered when preparing the Plan
How do the goals of your Strategic
Name of Plan Lead Organization Plan overlap with the goals of each
plan?
Continuum of Care Maricopa Association of As a member of the CoC, the CityGovernments coordinates planning and implementation
of homelessness relief goals.
The Envision Glendale 2040 Plan’s Housing
Element was informed by the 2015
City of Glendale Planning Consolidated Plan and focuses on offering a
Envision Glendale 2040
Division wide variety of housing types that meet the
range of socioeconomic needs of the City’s
current and future residents.
The City Council’s Vision and Mission
Glendale City Council Vision and
includes a commitment to Innovation and
Mission: How We Make a Glendale City Council
Improved Community Experience, with
Difference
which this Con Plan will align.
The General Plan Land Use Map identifies
Envision Glendale 2040 General City of Glendale Planning
areas of the City in which the City envisions
Plan Land Use Map Division
opportunities for different zoning densities.
The study’s focus on housing cost burden
and housing problems/ conditions aligns
City of Glendale 2017 Strategic City of Glendale Community with the Con Plan’s goals to provide
Housing Study Revitalization Division affordable housing and housing
rehabilitation assistance to low‐and
moderate‐income residents.
The plan focuses on a coordinated
Homelessness Action City of Glendale Community approach throughout Glendale and the
Plan 2019 Update Revitalization Division West Valley to support the needs of the
area’s homeless people.
The AIFHC provides information regarding
the City’s new strategies for informing
2020‐25 Maricopa County citizens about Fair Housing laws. The lack
Maricopa County Human
Regional Analysis of Impediments of affordable and accessible housing for
Services
to Fair Housing Choice people with disabilities, continue to be
challenges the City seeks to address within
this Con Plan.
One of the Strategy Map’s four strategic
City of Glendale Balanced City of Glendale City priorities is Community Livability, including
Scorecard Strategy Map Manager’s Office a safe and inclusive environment providing
a blend of amenities and infrastructure.
Table 3 ‐ Other local / regional / federal planning efforts
Identify any Agency Types not consulted and provide rationale for not consulting.
N/A
Narrative
The collaboration between the City, local jurisdictions, and the housing authority is expected to continue to
solidify throughout the years. To eliminate gaps in services and reach hard to serve populations on the localand regional level, this collaboration between the City and local jurisdictions to align services efficiently will
continue.
AP‐12 Participation ‐ 91.401, 91.105, 91.200(c)
1. Summary of citizen participation process/Efforts made to broaden citizen participation
Summarize citizen participation process and how it impacted goal‐setting
In order to ensure broader participation, residents were given multiple opportunities to comment on the
plan during the plan development and the completed plan was available for a 30‐day comment period.
Efforts were made to provide accommodations and give opportunities to persons with disabilities and
persons with Limited English Proficiency to provide input and public comments. Some provisions were
made to provide auxiliary aids to persons with disabilities, the notices and Plan documents could be
provided in alternative formats and public notices were available to non‐English speaking individuals.
Meetings were held at a time of day that would facilitate the participation of members of the public who
work and information and notices were provided through the City’s website for persons not wishing or able
to attend meetings.
Citizen Participation Outreach
Outreach Summary of Summary of comm
Mode of Target of Summary of resp
Sort Comments ents not accepted
Outreach Outreach onse/ attendance
Order received and reasons
Public Hearing
1 Public TBD TBD TBD
03‐18‐2021
No
comments
Public Hearing No members of the
2 Public received N/A
03‐11‐2021 public attended
from the
public
The City
Council
provided
All City of
feedback
Glendale Council
City Council City Council and related
proceedings are
3 Workshop Public Members, other to the City’s
aired on
2/23/21 government officials 2021‐22
Facebook and
Public
Youtube Live.
Services
grant
applications
The City All City of
City Council 7 City Council
Council Glendale Council
4 Workshop Public Members, other
provided proceedings are
12/8/20 government officials
feedback on aired onOutreach Summary of Summary of comm
Mode of Target of Summary of resp
Sort Comments ents not accepted
Outreach Outreach onse/ attendance
Order received and reasons
CDBG, Facebook and
HOME and Youtube Live.
ESG
activities for
FY 2021‐22
Table 4 – Citizen Participation Outreach
EXPECTED RESOURCES
AP‐15 Expected Resources ‐ 91.420(b), 91.220(c)(1,2)
Introduction
The City of Glendale receives Community Development Block Grant (CDBG) and Emergency Solutions Grant
(ESG) funding directly from HUD as a participating entitlement jurisdiction. As a result of the COVID‐19
pandemic, the City also received CDBG‐CV and ESG‐CV funding that will continue to be expended in FY
2021‐22 towards the activities established in the FY 2020‐2024 Consolidate Plan and FY 2020 ‐ 21 AAP.
In addition, the City also receives HOME Investment Partnership Program (HOME) funds from Maricopa
County as a member of the Maricopa HOME Consortium. The city of Glendale has been allocated $686,496*
of HOME funds through the Maricopa HOME Consortium for FY 2021‐22.
The first‐year funding for the Five‐Year Consolidated Plan was confirmed by HUD and used as a basis to
estimate the available federal resources for the five‐year period by multiplying the first‐year allocation by
five. In subsequent years, the actual annual allocation for each year may vary depending on appropriations
for Community Planning and Development programs. Goals, objectives and activities have been adjusted
in the Year Two AAP to accommodate anticipated funding amounts. The City also factors in an estimate of
program income that is to be received each year.
HOME Consortium Allocations*
*Allocations include funding allocated for projects and activities as well as administration. Additional detail
on HOME fund allocations within the HOME Consortium is located in section AP‐35 Projects section of this
plan. The HOME Program administrative cap is 10% of the total annual HOME allocation. As reimbursement
for its administrative duties as lead agency of the Consortium, Maricopa County will receive administrative
funds from other Consortium Members in the amount of five percent (5%) of each member’s pro rata share
of HOME Program grant allocations for each year. This percentage will be calculated on the Consortium’s
annual HOME Program allocation. The City will receive the following allocations for FY 2021‐22: CDBG ‐
$2,423,635; ESG ‐ $211,275; HOME ‐ $686,496Anticipated Resources
Source Uses of Funds Expected Narrative
of Amount Description
Funds Expected Amounts ($) Available Year 1 Available
Remainder
of ConPlan
Annual Program Prior Year Total:
Allocation: Income: Resources: $
public Acquisition
‐ Admin and
federal Planning
Remainder
Economic
estimation
Development
CDBG assumes same
Housing
funding level
Public
for Years 3‐5.
Improvements
Public
Services 2,423,635 20,000 0 2,443,635 7,270,905
public Shelter
‐ operations
Remainder
federal Rapid re‐
estimation
housing
ESG assumes same
Street
funding level
outreach
for Years 3‐5.
Essential
Services 211,275 0 0 211,275 633,825
Table 5 ‐ Expected Resources – Priority Table
Explain how federal funds will leverage those additional resources (private, state and local funds), including
a description of how matching requirements will be satisfied.
Part of Glendale’s strategy includes providing funding to local nonprofits who in turn leverage outside funding
sources to serve Glendale’s citizens. Additionally, the City and its sub‐recipients provide matching HOME and
ESG funding, including $451,042 in FY2020‐21. Leverage, in the context of the CDBG and HOME, means
bringing other local, state, and federal financial resources to maximize the reach and impact of the City’s HUD
programs. HUD, like many other federal agencies, encourages the recipients of federal monies to demonstrate
that efforts are being made to strategically leverage additional funds in order to achieve greater results.
Leverage is also a way to increase project efficiencies and benefit from economies of scale that often come
with combining sources of funding for similar or expanded scopes. Funds will be leveraged if financial
commitments toward the costs of a project from a source other than the originating HUD program are
documented.
During FY 2021‐ 22, the City of Glendale will allocate HOME funds from the Maricopa HOME Consortium to
create a First‐Time Homebuyer Program. The City will obtain a subrecipient to develop and administer the
program that will assist approximately fifteen (15) households with direct financial assistance for
downpayments, closing costs, and principal reduction to purchase a home in the City.
The 25% required HOME match will be provided through donated time, services, and dollars from Habitat forHumanity. The planning and administrative costs of managing the federal grant programs, such as some staff costs, are also funded from the City’s general fund dollars. The City will employ ESG funds for the City’s homeless prevention activities and to fund shelter operational costs for homeless service activities. The 100% required ESG match is provided by subrecipients from eligible ESG sources. If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan NA Discussion The City does not have access to surplus land for the purposes of building affordable housing. Any acquisition would happen through the actions of a non‐profit organization. The City is devoted to addressing the affordable housing crisis. In partnership with the Caesar Chávez Foundation, 80 affordable housing units will be made available to Glendale residents. The project is scheduled to be completed and ready for occupancy this by the end of 2023. Glendale will utilize the $2,423,635 in CDBG funding and approximately $20,000 in CDBG Program Income toward projects in FY 2021‐22. Additionally, the City will utilize $211,275 in ESG funding for projects in FY 2021‐22. In FY 2020‐ 21, the City received $1,457,342 of CDBG‐CV funding, $749,455 in ESG‐CV and $2,997,188 of ESG‐CV 2 funding. The infusion of COVID‐19 related funding was previously awarded to subrecipient and will continue to be expended in FY 2021‐22 on programs that are designed to eliminate the burdens caused by the world‐wide pandemic. Annual Goals and Objectives AP‐20 Annual Goals and Objectives ‐ 91.420, 91.220(c)(3)&(e) Goals Summary Information
Sort Goal Name Start End Category Geographic Needs Funding Goal Outcome
Order Year Year Area Addressed Indicator
1 Promote Access 2020 2024 Affordable Citywide Affordable CDBG: Public Facility
to Decent Housing CDBG Housing $1,401,588 or
Affordable Public Housing Target Infrastructure
Housing Areas ‐ Activities for
85301 and Low/Moderate
85302 Income
Housing
Benefit: 350
Households
Assisted
Homeowner
Housing
Rehabilitated:
85 Household
Housing Unit
Tenant‐based
rental
assistance /
Rapid
Rehousing: 50
Households
Assisted
2 Increase Access 2020 2025 Homeless Citywide Affordable CDBG: Tenant‐based
to Homeless CDBG Housing $223,076 rental
Services/Housing Target Housing & ESG: assistance /
Areas ‐ Services for $201,042 Rapid
85301 and Homeless/At‐ ESG‐CV: Rehousing: 80
85302 Risk People $674,510 Households
Services & Assisted
Facilities for Homeless
Vulnerable Person
Groups Overnight
Employment, Shelter: 42
Job Training, Persons
Financial Assisted
Literacy Homelessness
Prevention: 75
Persons
Assisted
Businesses
assisted: 10
Businesses
Assisted
3 Public Services 2020 2025 Non‐Homeless Citywide Services & CDBG: Public servicefor Vulnerable Special Needs Facilities for $72,500 activities other
Populations Vulnerable CDBG‐CV: than
Groups $465,874 Low/Moderate
Income
Housing
Benefit: 1500
Persons
Assisted
4 Educational 2020 2025 Non‐Housing Citywide Employment, CDBG: Public service
Programs and Community CDBG Job Training, $31,026 activities other
Business Development Target Financial CDBG‐CV: than
Assistance Areas ‐ Literacy $700,000 Low/Moderate
85301 and Income
85302 Housing
Benefit: 1500
Persons
Assisted
Businesses
assisted: 10
Businesses
Assisted
5 Increase 2020 2025 Non‐Housing Citywide Improved CDBG: Public Facility
Livability of Community CDBG Neighborhood $248,688 or
Neighborhoods Development Target Facilities Infrastructure
Areas ‐ Activities for
85301 and Low/Moderate
85302 Income
Housing
Benefit: 19083
Households
Assisted
6 Comply with 2020 2025 Fair Housing Citywide Fair Housing CDBG: Public service
Affirmatively $10,000 activities other
Furthering Fair than
Housing Low/Moderate
Income
Housing
Benefit: 150
Persons
Assisted
Table 6 – Goals SummaryGoal Descriptions
1 Goal Name Promote Access to Decent Affordable Housing
Goal Glendale will work promote access to decent affordable quality housing throughout
Description the City through a variety of activities that may include: construction, rehabilitation
and replacement of owner and renter housing, homeownership assistance, or rental
assistance that helps low‐ and moderate‐income families obtain or maintain housing.
CDBG National Objective(s): BENEFIT TO LMI PERSONS/HOUSEHOLDS
2 Goal Name Increase Access to Homeless Services/Housing
Goal Through its ongoing Strategic Planning process and work with the Maricopa
Description Association of Governments Continuum of Care programs, the City will identify ways to
partner with government and nonprofit providers to offer additional emergency
shelter, transitional shelter, permanent and supportive housing, and necessary
services to mitigate crisis situations and promote self‐sufficiency to homeless people
and those at risk of homelessness.
CDBG National Objective(s): BENEFIT TO LMI PERSONS/HOUSEHOLDS
3 Goal Name Public Services for Vulnerable Populations
Goal Through our funding of nonprofit agencies, the City will provide additional services to
Description support low‐ and moderate‐income people, including food assistance and senior and
youth services.
CDBG National Objective(s): BENEFIT TO LMI PERSONS/HOUSEHOLDS
4 Goal Name Educational Programs and Business Assistance
Goal Through our funding of programs with government and nonprofit providers or
Description collaborative partnerships, the City will provide additional services to support low‐ and
moderate‐income people with youth and adult educational programs for the
community. Programs can include those that supplement youth learning and skills
development, job training and skills development for adults, specific employment
training, financial sufficiency training, and direct financial assistance to businesses that
qualify for support based on HUD program requirements.
CDBG National Objective(s): BENEFIT TO LMI PERSONS/HOUSEHOLDS
5 Goal Name Increase Livability of Neighborhoods
Goal Per HUD Policy 24CFR570.201(c) Public Facilities and Improvements, several areas
Description within the City have significant aging infrastructure needs, particularly related to ADA
Compliance and water systems. Neighborhood enhancements, such as parks,
streetscape beautification, demolition of unsafe and blighted structures, and exterior
commercial rehabilitation would also be considered under this category.
CDBG National Objective(s): BENEFIT TO LMI PERSONS/HOUSEHOLDS;
SLUM/BLIGHT. Slum and Blight conditions exist in several of the City's older primarily
residential areas, including the Centerline Redevelopment Area, and are considered
eligible per the State of Arizona's conditions for redevelopment areas. Use of
slum/blight on an area basis will occur in these defined areas. The City does not
expect to qualify projects as slum/blight on a spot basis.
7 Goal Name Comply with Affirmatively Furthering Fair Housing
Goal The City will comply with all federal regulations related to affirmatively furthering fair
Description housing to provide fair access for all Glendale citizens to housing opportunities.AP‐35 Projects ‐ 91.420, 91.220(d)
Introduction
The following section provides the list of approved projects/activities for the use of entitlement grant funds
under the Community Development Block Grant (CDBG), Emergency Solutions Grants (ESG) HOME
Investment Partnerships Program (HOME) and for FY 2021‐2022.
Grant Source Amount
CDBG HUD $2,423,635
ESG HUD $211,275
HOME Maricopa County $686,496
Total FY 2021‐22 Allocations: $3,321,406
The following activities are funded under the HOME Investment Partnerships Program (HOME) through the
Maricopa HOME Consortium for FY 2021‐2022, and appear as projects in the Maricopa Home Consortium’s
Annual Action Plan for FY 2021‐2022 (A total of $686,496 in HOME funds will be received in FY 2021‐2022):
HOME Buyer Assistance (24 CFR 92.205) – Provide funding for first‐time home buyers purchasing
improved or unimproved real property, associated with the acquisition of single‐family housing forcurrent activity levels and the needs of their constituent population. The efficient use of previous year's
resources and the field observations garnered by providers helped to determine levels of needs. The
Comprehensive Housing Affordability Strategy (CHAS) data and other studies and planning documents were
also used to guide the determination of priorities.
ESG: In addition to the above criteria, request for proposal responses, CDAC and City Council deliberations,
and previous expenditures, the City consulted with the Continuum of Care in determining allocation
priorities for ESG funding. The Continuum of Care coordinates regional efforts to address homelessness
and shelter issues.
A unique factor for the 2nd AAP year is the availability of the COVID‐19 CV funding. In FY 2020‐21, funds
were allocated to organization that have programs that will help and support the most vulnerable and
COVID burdened citizens of Glendale. CV funds were used to fully fund all public service grant applications
and to provide additional services with legal services for housing related issues.
Obstacles to Addressing Underserved Needs
The City of Glendale is making efforts to address and identify activities of highest priority. The housing
market conditions related to demand and supply of both rental and homeownership, as well as the
availability of affordable housing, also determine the use of housing‐related funding such as HOME
Consortium allocations. The amount of available funding simply is not adequate to meet the demand
based on applications received by the City. The fact that many low and moderate‐income households are
cost burdened or severely cost burdened (spending more than 30% or 50% respectively of their income on
housing expense) also remains an obstacle to addressing the underserved. The City is challenged to
develop and implement a well‐coordinated and integrated outcome‐driven service delivery system that
meets the City's housing and community development needs and goals.
AP‐38 Project Summary
Project Summary Information
1 Project Name COG Residential Rehabilitation
Target Area Citywide
Goals Supported Retain Affordable Housing ‐ City Administered
Needs Addressed Rehabilitation of existing units ‐ DH
Funding CDBG: $727,091
Description The City will directly administer housing‐rehabilitation
activities on private residential owner‐occupied units per
CDBG regulations at 24 CFR 570.202, 570.201(I)
Target Date 6/30/2022
Estimate the number Approximately 11 households will be assisted
and type of families
that will benefit from
the proposed activities
Location Description City widePlanned Activities This activity will include costs related to construction,
planning and permitting, environmental reviews, hazard
testing, mitigation and abatement, temporary relocation of
occupants and direct project staff costs.
2 Project Name Residential Rehabilitation ‐ Glendale Emergency Home Repair
Program
Target Area Citywide
Goals Supported Retain Affordable Housing ‐ Subrecipient
Needs Addressed Rehabilitation of existing units ‐ DH
Funding CDBG: $387,782
Description The City will enter into a subrecipient agreement with Habitat
for Humanity of Central Arizona to provide emergency home
repair services for low‐to‐moderate income Glendale
homeowners. This activity is eligible under CDBG regulations
at 24 CFR 570.201 and 24 CFR 570.202.
Target Date 6/30/2023
Estimate the number Approximately 60 households will be assisted
and type of families
that will benefit from
the proposed activities
Location Description City‐wide
Planned Activities Activities will include home repairs that if not addressed in a
timely manner have the potential of affecting the health and
safety of the occupants and address items such as HVAC,
plumbing, electrical and structural issues.
3 Project Name CDBG Services for Vulnerable Populations
Target Area Citywide
Goals Supported Public Services for Vulnerable Populations
Needs Addressed Services & Facilities for Vulnerable Groups
Funding CDBG: $363,545
Description These programs will provide a diverse array of services to
vulnerable populations, including: seniors, youth, the
disabled, those experiencing food insecurity.
Target Date 6/30/2022
Estimate the number Approximately 31,239 persons will benefit from this activity
and type of families
that will benefit from
the proposed activities
Location Description Citywide
Planned Activities Goldensun Peace Ministries: Agency staff provide
direct care, provide transportation, plan, and
offer learning opportunities, and assist each
resident in their development of independent
living skills. Each adult has a diagnosed
developmental disability such as Autism, Spina
Bifida, Intellectual Disability, and Down’sSyndrome. ($4,497)
One Step Beyond, Inc: The program will focus on
training in employment and life skills preparation,
access to recreational and cultural opportunities,
and advocacy for people who have disabilities and
their families. Participants include individuals who
have Down syndrome, cerebral palsy, autism, and
other disabilities living mainly in Peoria, Glendale,
Surprise, and surrounding communities. ($14,740)
Sun City Area Interfaith Services, Inc./Benevilla:
The Program will assist older adults and adults
with disabilities maintain their independence and
health through the provision of daytime care
services and provide much needed respite to
these individuals’ primary caregiver(s), enabling
them to remain employed and/or to recharge
from their constant caregiving duties. As a
licensed and accredited adult day healthcare
provider, the program helps older adults delay or
even eliminate the need to move into an assisted
living or nursing facility. ($19,653)
Back to School Clothing Drive Association: the
New Clothes, New Beginnings Program purchases
new school uniform pieces, backpacks, and school
supplies for children from low‐income families.
($9,826)
Community Legal Services: Planned activities
include Fair Housing Outreach, education, and
training, including outreach to communities such
as minorities, recent immigrants, and those living
with disabilities. ($52,974)
Phoenix Rescue Mission: funds will be used to
support program personnel to conduct the
program out of the Hope for Hunger Food bank.
This individual will work with hundreds of
volunteers to prepare the food boxes for
distribution to Glendale residents in need. This
staff member also will work with St. Mary's Food
bank and other sources to request needed food,
receive, sort it, store it, and then oversee the
volunteers who pack the food boxes. The funds
also will be used to purchase boxes and other
program supplies. ($261,855)
4 Project Name Demolition
Target Area CDBG‐eligible Census Tracts and Block Groups City‐wide
Goals Supported Increase Livability of NeighborhoodsNeeds Addressed Improved neighborhood facilities, neighborhood economic
development
Funding $218,127
Description The City recognizes that unsafe and blighted structures pose
safety risks to residents, devalue adjacent property, and divert
valuable public resources. The City will target unsafe structures
for demolition and clearance in income‐eligible areas in order
to make them suitable for redevelopment purposes.
Target Date 6/30/22
Estimate the number Approximately 1,000 households will benefit on an area basis.
and type of families
that will benefit from
the proposed activities
Location Description Demolition and clearance activities will take place in income‐
eligible Census Tracts and Block Groups throughout the City.
Planned Activities Actions within this activity will include construction,
planning/permitting, environmental review, hazardous material
testing and abatement, disposal of materials, clearance of land,
staffing costs and other necessary actions to fully clear selected
properties.
5 Project Name COG Public Housing Improvements
Target Area None
Goals Supported Affordable Housing
Improve Quality of Public Facilities
Needs Addressed General Public Facilities and Improvements
Funding CDBG: $242,363
Description The City will review its Public Housing Capital Improvement
Plan and Needs Assessment to determine priority of work to be
completed at one or more of the City’s three public housing
campuses. Work may include, but is not limited to roofing,
exterior painting, site improvements, and others as defined in
the Public Housing CIP.
Target Date 6/30/2022
Estimate the number Up to 155 households may benefit across three public housing
and type of families campuses.
that will benefit from
the proposed activities
Location Description 6106 W Lamar Rd (Lamar Homes); 5320 W. Maryland Ave
(Cholla Vista Apartments) and 5215 W Ocotillo Rd (Glendale
Homes), Glendale, AZ 85301
Planned Activities Funds will be available for construction, engineering,
architectural, planning and permitting, environmental review,
hazardous material testing and abatement, staff costs and
others that may be required to complete this activity.
6 Project Name Emergency Solutions Grant FY 2021‐2022
Target Area CitywideGoals Supported Promote Access to Decent Affordable Housing
Increase Access to Homeless Services/Housing
Public Services for Vulnerable Populations
Needs Addressed Affordable Housing
Housing & Services for Homeless/At‐Risk People
Services & Facilities for Vulnerable Groups
Funding ESG: $211,275
Description ESG funds will be used to support Emergency Shelter
Operations and Outreach Services, Homeless Prevention
Activities ‐‐ Rapid Re‐Housing, and Program Administration
under a single service delivery umbrella. Leveraging prior year
ESG‐CV2 funds this activity will provide a comprehensive
solution to homelessness and will be used to support
Permanent Supportive Housing/ Housing First, Homeless
Prevention Activities ‐‐ Rapid Re‐Housing, and Program
Administration.
Target Date 06/30/2023
Estimate the number Approximately 250 individuals will benefit.
and type of families
that will benefit from
the proposed activities
Location Description Citywide
Planned Activities As of publication of this Draft Plan, the City is in currently in
procurement for one or more agencies to design and
implement a Master Services Agreement that will provide a
menu of ESG‐eligible services to those experiencing or at risk
of homelessness in the City. This approach will require that
qualified subrecipients develop a flexible service delivery
system where clients receive individualized assessments and
case management, and can access services depending on
their individual needs. The City will expect that the successful
organization will provide a system that uses all ESG‐eligible
activities in any combination that they feel is necessary to
achieve the City’s goal to reduce homelessness in the City.
7 Project Name CDBG Administration FY 21‐22
Target Area Citywide
Goals Supported CDBG Program Administration
Needs Addressed Affordable Housing
Housing & Services for Homeless/At‐Risk People
Services & Facilities for Vulnerable Groups
Employment, Job Training, Financial Literacy
Improved Neighborhood Facilities
Fair HousingFunding CDBG: $484,727
Description General administration and oversight activities, such as payroll,
supplies, training, overhead and other possible costs eligible
under 24 CFR 570.206.
Target Date 06/30/2022
Estimate the number All CDBG and ESG beneficiaries are considered to benefit from
and type of families administrative activities
that will benefit from
the proposed activities
Location Description The Community Revitalization Division is responsible for
administration of CDBG and ESG program activities and is
located at Glendale City Hall, 5850 W Glendale Ave, Glendale,
AZ 85301.
Planned Activities General administration and oversight activities, such as payroll,
supplies, training, overhead and other possible costs eligible
under 24 CFR 570.206.
AP‐50 Geographic Distribution ‐ 91.420, 91.220(f)
Description of the geographic areas of the entitlement (including areas of low‐income and minority
concentration) where assistance will be directed.
The City of Glendale has identified low to moderate‐income target areas where more than 51% of the
populations are households with incomes at 80% of the Area Median Income as defined and adjusted
annually by HUD. However, for the most part, the City does not direct its assistance based on those target
areas. The Census Tracts which contain a higher concentration of low/mod income persons are 924, 925,
926, 926.01, 926.02, 926.05, 927.15 927.17, 927.18, 928, 930.01, and 930.02. The CDBG, ESG, and HOME
regulations allow for resources to be allocated based on the income characteristics of beneficiaries. As
such, the City allocates its resources for public service activities, affordable housing, and emergency home
repair citywide. CDBG and ESG funding allocations for public service are allocated on a citywide basis. See
attached maps illustrating the City’s low to moderate‐income target areas.
Public facilities and infrastructure improvement activities funded by CDBG will be located in the City's low
to moderate‐income census tracts if they meet an area benefit national objective. Such activities will be
carried out in the target areas and the City's Downtown Redevelopment Target Area (DRTA), as adopted by
the City Council. Public facilities and improvements will be focused in zip codes 85301 and 85302.
CDBG funded public facilities and infrastructure improvement activities will also be carried out in non‐
designated areas. Such public facilities and improvement activities will benefit limited clientele (special
needs) populations.
Geographic Distribution
Target Area Percentage of Funds
CDBG Target Areas ‐85301 and 85302 20
Table 8 ‐ Geographic Distribution
Rationale for the priorities for allocating investments geographically.You can also read