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HomeMy WebLinkAbout7.8.22 2018 CDBG-DR public comment letter (2) From:Simmons, Katie To:BOS Cc:Simmons, Katie; Ring, Brian Subject:2018 CDBG-DR public comment letter Date:Friday, July 8, 2022 8:04:58 AM Attachments:2018 CDBG-DR APA 2 Public Comment - Butte County.pdf Good morning, Members of the Board, Attached is a comment letter pertaining to the 2018 CDBG-DR Action Plan Amendment 2, requesting the allocation of $18.7M for Butte County for construction workforce development be increased proportionate to the damaged/destroyed structure ratio caused by the Camp Fire. th Please send any edits or comments prior to July 14 when we will be submitting this letter to the California Department of Housing & Community Development by the deadline. Thank you, Katie Katie Simmons Deputy Administrative Officer Economic & Community Development Butte County Administration 25 County Center Drive, Suite 213, Oroville, CA 95965 Twitter | Facebook | YouTube | Pinterest State of California Action Plan for Disaster Recovery from 2018 Disasters Action Plan Amendment No. 2 California Department of Housing and Community Development Submitted to HUD: Approved by HUD: For submission to the U.S. Department of Housing and Urban Development (HUD) to fulfill requirements related to Community Development Block Grant Disaster Recovery (CDBG-DR) Funds in Response to 2018 Disasters (FEMA DR-4382 and DR-4407) I. Background and Summary of Changes .................................................................................... 3 II. Action Plan Amendments ......................................................................................................... 3 1. Executive Summary, proposed uses of CDG-DR Funds (page 10) 3 2. Proposed Disaster Recovery Programs, Connection to unmet needs 4 A. Allocation of funds (page 133) ...................................................................................... 4 B. Program Allocations (page 135) .................................................................................... 4 C. Method of Distribution within Programs (pages 135-136) ......................................... 5 3. Proposed Disaster Recovery Programs, Program Overviews 5 A. Housing Recovery Programs (page 137) ..................................................................... 5 B. Add: Homebuyer Assistance Program (page 143) ...................................................... 6 C. Multifamily Housing Program (page 143) ..................................................................... 7 D. Infrastructure Recovery Program Activities (page 152) ............................................. 7 E. Add: Paradise Sewer Project A&E (page 156) ............................................................. 8 F. Economic Revitalization Programs (pages 156-160) .................................................. 9 G. Workforce Development Program (pages 157-159) .................................................... 9 H. Small Business Recovery Program (pages 159-160) ................................................ 14 I. Background and Summary of Changes On January 27, 2020, the United States Department of Housing and Urban Development (HUD) allocated $1,017,399,000 in Community Development Block Grant-Disaster Recovery (CDBGDR) funds to the State of California to support California’s unmet recovery needs, related to the Federal Emergency Management Agency (FEMA) Major Disaster Declarations DR-4407 and DR4382 for 2018 Wildfire season. The funds were released in two allocations: Public Law 115-254 Unmet Needs allocation of $491,816,000 and Public Law 116-20 Unmet Needs allocation of $525,583,000. The California Department of Housing and Community Development (HCD) manages CDBG-DR funds, in accordance with the goals and objectives set forth in the State’s initial HUD-approved Action Plan for 2018 disasters (“18DR-Action Plan”). The 18DR-Action Plan amendment, number two (“APA 2”), is a substantial amendment; it proposes to add a new program, remove an existing program from the initial HUD-approved Action Plan and proposes to change program budgets in excess of the $10- million-dollar threshold for substantial action plan amendments. APA 2 also clarifies existing program design for 2018 CDBG-DR funds. A summary of the changes the State of California proposes to make in APA 2 to address California’s ongoing, unmet recovery needs, follows below. Summary of Changes: Action Plan Amendment 2 (APA 2) will address changes in the following sections of the Master Action Plan document: 1. Executive Summary, proposed uses of CDBG-DR Funds: The budget summary has been updated to reflect changes in the allocations. 2. Proposed Disaster Recovery Programs, Connection to unmet needs A. Allocation of funds: Figure 90 will be updated with program allocation changes. B. Program Allocations 1. HCD Administered: Homebuyer assistance will be added. 2. Subrecipient Administered: Clarity allocation formula and scoring matrix. C. Method of Distribution: Clarify eligible participants. 3. Proposed Disaster Recovery Programs, Program Overviews A. Housing Recovery Programs, add Homebuyer Assistance to the suite of housing recovery programs to address the unmet recovery needs. B. Multifamily Housing Programs, updated eligible activity. C. Infrastructure Recovery Program, add Paradise Sewer Project Architecture and Engineering (A&E) direct grant. E. Economic Revitalization Programs, updates to the Workforce Development Program and removed the Small Business Recovery Program. II. Action Plan Amendments 1. Executive Summary, proposed uses of CDG-DR Funds (page 10) Remove: FIGURE 4: 2018 CDBG-DR BUDGET SUMMARY – PROPOSED APA 1 BUDGET Replace: FIGURE 3: 2018 CDBG-DR BUDGET SUMMARY – PROPOSED APA 2 BUDGET Original APA2ChangeRevised APA2 Percentage of Program Program Allocations Total Program AllocationAllocation $1,017,399,000 Total CDBG-DR Funds $1,017,399,000 100.0% $483,794,752 Housing $455,794,752 +28,000,000 47.55% Owner-Occupied +$2,000,000 Rehabilitation and $205,107,638 $207,107,638 20.36% Reconstruction Homebuyer Assistance +$26,000,000 $26,000,000 2.56% Program Multifamily/Small Rental Housing $250,687,114 $250,687,114 24.64% $347,428,488 $347,428,488 Infrastructure $317,428,488 34.15% Local Infrastructure/FEMA $317,428,488 $317,428,488 31.2% Match $30,000,000 $30,000,000 Paradise Sewer A&E 2.95% $40,695,960 Economic Revitalization $40,695,960 4.0% $40,695,960 Workforce Development $40,695,960 4.0% ($58,000,000) $28,217,000 Planning $86,217,000 2.77% Technical Assistance & $15,000,000 $15,000,000 1.47% Capacity Building Regional & Local Planning ($58,000,000) $13,217,000 $71,217,000 1.30% Activities State and Local Program $66,392,850 $66,392,850 6.53% Delivery $50,869,950 Administration $50,869,950 5.0% 2. Proposed Disaster Recovery Programs, Connection to unmet needs A. Allocation of funds (page 133) FIGURE 91: CDBG-DR PROGRAM BUDGET (page 134) PROGRAM Percentage of PROGRAM ALLOCATION Total Total CDBG-DR $1,017,399,000 Funds Housing Programs $483,794,752 47.55% Infrastructure $347,428,488 34.15% Economic $40,695,960 4% Revitalization Program Delivery $66,392,850 6.53% Planning $28,217,0002.77% Administration $50,869,950 5% Total CDBG-DR $1,017,399,000 100 Funds B. Program Allocations (page 135) 1. HCD Administered Add: Homebuyer Assistance The State of California Department of Housing and Community Development (HCD) is seeking to create a comprehensive suite of programs that respond to the needs of both disaster-impacted communities and the individuals that reside within them. Additionally, given the significant cost to rebuild in high fire hazard zones, the time elapsed from the disaster, exacerbating impacts of the pandemic, and disaster impacts that may have required homeowners and renters to temporarily relocate to other areas of the state for work or other needs, solutions based on equity that provide choices and resources for impacted households to recover are even more critical. Furthermore, many households may not be able to afford long term homeownership in their current location due to high costs associated with rebuilding, maintenance, and insurance. HCD will add a Homebuyer Assistance Program (HBA) as an additional programmatic option to its recovery portfolio to meet the needs of those impacted by the 2018 disasters. The HBA will provide down payment and other housing assistance to low- to moderate-income disaster impacted survivors, enabling them to relocate outside of high-risk areas or the disaster declared areas. HBA will be a standalone program run by HCD with the assistance of either a state agency partner or a procured contractor. 2. Subrecipient Administered This section updated to provide clarity on allocation of funds across subrecipient administered proposed programs via an allocation formula, scoring matrix and other methodologies where appropriate. Remove: HCD developed a formula approach to allocate funds across the eligible geographies for each local program. Replace: The method by which HCD developed a formula approach to allocate funds across the eligible geographies for each local program is dependent on the type of program and existing conditions at the time that each program is launched. Some program funding may be allocated based on a formula while others may be based on a discreet scoring matrix during the application phase. Other allocation methodologies will be considered as appropriate, but all allocation methods will be published on HCDs website and clearly outlined for transparency. C.Method of Distribution within Programs (pages 135-136) This section updated to clarify eligible participants can be jurisdictions and other types where appropriate. Remove: Funding to eligible jurisdictions – counties, entitlement, and non-entitlement, school districts and colleges – will be determined through an application process. Replace: Funding to eligible jurisdictions – and other applicant types as appropriate – will be determined through an application process. 3. Proposed Disaster Recovery Programs, Program Overviews A. Housing Recovery Programs (page 137) Remove: HCD is implementing a suite of housing recovery programs to address the unmet recovery needs: an Owner-Occupied Housing Rehabilitation and Reconstruction Program, Small Rental program, and a Multifamily Housing Program. Replace: HCD is implementing a suite of housing recovery programs to address the unmet recovery needs: an Owner-Occupied Housing Rehabilitation and Reconstruction Program(OOR), Small Rental program, a Multifamily Housing Program, adding a Homebuyer Assistance Program (HBA) and offering housing counseling as part of the activity delivery for the OOR and HBA programs. APA 2 adds $3 million dollars to the programs for these costs. B. Add: Homebuyer Assistance Program (page 143) HCD will add a Homebuyer Assistance Program (HBA) as an additional programmatic option to its recovery portfolio to meet the needs of those impacted by the 2018 disasters. HBA will be a standalone program to provide down payment and other housing assistance to low- to moderate- income disaster impacted homeowners and renters, (see eligible applicants) enabling them to relocate outside of high-risk areas. 1. Unmet Needs: As the State of California continues to recover from the devastating fires in 2018, the state is expanding housing programs to meet the needs of impacted homeowners and renters. The HBA program extends the portfolio to include an option for homeowners or renters who are looking to relocate outside of the fire impacted area. Providing a program such as HBA provides an alternative option to meet the housing recovery needs of impacted households. 2. Allocation Amount: $26,000,000 3. Maximum Assistance: Applicants are eligible to receive up to $350,000. 4. Eligible Activity: HCD Act 105(a)(24) Homeownership Assistance. 5. National Objective: Low to Moderate Income Housing 6. Eligible applicants: Program eligibility includes residents of the California counties eligible to receive housing assistance pursuant to the 2018 Federal Disaster Declarations DR-4382 and DR-4407. The following counties eligible for 2018 funds: Butte, Lake, Los Angeles, Shasta, and Ventura Counties. 7. Eligible Program Costs: Down payment assistance (up to 20% of the purchase price) Housing adjustment incentive Rate buydown to lowest possible rate All reasonable closing costs (legal, closing fee, title search, c 8. Ineligible Program Costs: 1. Moving expenses including storage expenses Temporary relocation housing Costs associated with the sale of the disaster impacted property 9. Form of Assistance: Forgivable loan. Term of forgiveness will be a minimum of 2 years. 10. Housing Counseling: Housing counseling assistance will provide program applicants with wrap around housing and financial educational services including financial literacy education, homebuyer counseling, credit repair counseling, and counseling to mitigate default/foreclosure proceedings. HCD will work with HUD-approved housing counseling agencies which are uniquely situated to assist with the delivery of these services as part of the long-term recovery efforts provided through CDBG-DR funding. C. Multifamily Housing Program (page 143) This section updated for consistency of HCD Act Section 105(a) eligible activities. 1. Eligible Activity (page 145) Remove: 42 USC 5305(a)(4) authorizes the clearance, demolition, removal, reconstruction, and rehabilitation (including rehabilitation which promotes energy efficiency) of buildings and improvements (including interim assistance, and financing public or private acquisition for reconstruction or rehabilitation, and reconstruction or rehabilitation, of privately owned properties and including the renovation of closed school buildings). Replace: HCD Act 105(a)(4) authorizes the clearance, demolition, removal, reconstruction, and rehabilitation (including rehabilitation which promotes energy efficiency) of buildings and improvements (including interim assistance, and financing public or private acquisition for reconstruction or rehabilitation, and reconstruction or rehabilitation, of privately owned properties and including the renovation of closed school buildings). D.Infrastructure Recovery Program Activities (page 152) This section updated to add direct funding for Architecture and Engineering (A&E) of the Paradise Sewer Project. 1. Infrastructure Recovery Program Activities (page 152) Remove: HCD will provide impacted local governments funds to ensure that as many critical infrastructure recovery needs are addressed as possible, through multiple activities. A tie-back to the disaster is required for eligibility. Replace: HCD will provide impacted local governments funds to ensure that as many critical infrastructure recovery needs are addressed as possible, through multiple activities. A tie-back to the disaster is required for eligibility. In addition, HCD will direct $30 million toward the architectural design and engineering (A&E) phase of the Paradise Sewer Project. 2. Eligible Activity (page 154) Updated section for consistency of HCD Act Section 105(a) eligible activities. Remove: Infrastructure repair is an eligible activity according to 42 USC 5305(a)(2), which authorizes the acquisition, construction, reconstruction, or installation (including design features and improvements with respect to such construction, reconstruction, or installation that promote energy efficiency) of public works, facilities (except for buildings for the general conduct of government), and site or other improvements. In addition, CDBG-DR funds may also be used as the non-federal share match. Replace: Infrastructure repair is an eligible activity according to HCD Act 105(a)(2), the acquisition, construction, reconstruction, or installation (including design features and improvements with respect to such construction, reconstruction, or installation that promote energy efficiency) of public works, facilities (except for buildings for the general conduct of government), and site or other improvements; 3. Unmet Needs (page 156) Remove: Figure 96 Unmet Infrastructure Recovery Need Replace: Figure 96 Unmet Infrastructure Recovery Need CATEGORY IDENIIFIED UNMET NEED CDBG-DR FUNDED Infrastructure Recovery $2,838,348,374 $347,428,488 E. Add: Paradise Sewer Project A&E (page 156) 1. Unmet Needs: The unmet needs analysis established that the Town of Paradise lost 83 percent of its residents during the Camp Fire and, as the town builds back and re-establishes its pre-fire population level, an integrated sewer system will support the recovery of housing and economic activity within the Sewer Service Area. The extreme heat of the Camp Fire led to water pollution issues in the town which require costly infrastructure repairs to ensure the long-term safety and resilience of the potable water systems. In the development of the unmet needs analysis and program design for this Action Plan, HCD coordinated and consulted with local community recovery plans in order to ensure consistency and efficiencies across programming. The Town of Paradise Long-Term Community Recovery Plan, published in June 2019, has been a valuable resource in determining how to best address the recovery needs of some of the hardest hit areas from the Camp Fire. The sewer project is listed by Paradise as a “Tier I” recovery priority project in the Paradise Long-Term Community Recovery Plan, meaning that it received strong community support as evidenced by public comments submitted in public meetings. Specifically, the Recovery Plan notes that, once completed, the sewer project will allow for accompanying land use and zoning changes to cluster multi-unit housing complexes, including affordable housing. Absent a centralized sewer to serve Paradise's central business and residential corridor, individual property owners must bear the cost of, in most cases, removing and replacing damaged septic tanks in inhospitable (poorly draining soils) that are already impacted, negatively, by a high rate of failed septic systems, which will take far longer than the municipal sewer option to come on line and limits the recovery effort to the spread-out development pattern that reliance on septic requires (for leach fields, etc.). 2. Allocation Amount: $30,000,000 3. Maximum Assistance: $30,000,000 4. Eligible Activity: HCD Act 105(a)(2), which authorizes the acquisition, construction, reconstruction, or installation (including design features and improvements with respect to such construction, reconstruction, or installation that promote energy efficiency) of public works, facilities (except for buildings for the general conduct of government), and site or other improvements. 5. National Objective: Construction of the Paradise Sewer Project and its connection to the Chico wastewater treatment facility (the Chico Water Pollution Control Plant) will meet the urgent need national objective. The infrastructure program policies and procedures will include a condition on the use of the grant to require the Town of Paradise to demonstrate that construction funding is secured. 6. Eligible applicant: The Town of Paradise. 7. Eligible Program Costs: Eligible costs include the engineering, design, and architectural services required to design the Paradise Sewer Project. 8. Ineligible Program Costs: Ineligible costs include those not associated with Paradise Sewer Project A&E. 9. Form of Assistance: Assistance will be provided in the form of a grant directly to the Town of Paradise. 10. Timeline: The Town expects to implement the design phase of the project from mid 2022 through 2024 with construction starting in 2024 and ending in 2026. F. Economic Revitalization Programs (pages 156-160) This section updated to clarify economic recovery fund support in impacted areas. Remove: Therefore, the State proposes to fund economic recovery activities to support both housing and a complete community recovery in the impacted areas. Replace: Therefore, the State proposes to fund economic recovery activities that support housing, resilient infrastructure, and complete community recovery in the impacted areas. G. Workforce Development Program (pages 157-159) This section updated to clarify language for prioritized workforce development services, including supportive services. Remove: The Program prioritizes a continuum of services that increase economic opportunities for low-to-moderate income residents in the 2018 disaster declared counties. The Program also prioritizes supportive wrap-around services that are provided to remove barriers to successful participation in job training or obtaining employment. The Workforce Development Program delivers free training to eligible participants. Program guidelines will be established that outline the requirements of the program and rules for specific projects, including general eligibility, specific eligible and ineligible costs, and the criteria for evaluating project proposals. Replace: The Program prioritizes a continuum of services that increase economic opportunities for low-to-moderate income residents in the 2018 disaster declared counties. The Program also prioritizes supportive services that are provided to remove barriers to successful participation in job training or obtaining employment. The Workforce Development Program delivers training and supportive services to eligible participants. Program guidelines will be established that outline the requirements of the program and rules for specific projects, including general eligibility, eligible and ineligible costs, and the criteria for evaluating project proposals. a. Eligible Activity (page 157) Updated section to change eligible activity from economic revitalization to public services. Remove: Title I of the HCD Act 105(a)17 authorizes economic revitalization as an eligible CDBG- DR funded activity. Additionally, economic revitalization is specifically mentioned as an eligible use of CDBG-DR funds in the Federal Register Notice 83 FR 5844. Replace: The program will utilize Title I of the HCD Act 105 (a)(2), 105 (a)(4), 105(a)(8), and 105 (a)(14) authorizing the provisions of public services and assistance to public facilities respectively, as the primary eligible activities in the Workforce Development Program. b. National Objective (page 157) Updated section to change national objective from low-to-moderate income jobs to low-to-moderate income clientele. Remove: In accordance with 24 CFR 570.208, all CDBG-DR funded activities must satisfy a national objective. The Workforce Development satisfies the benefit to low-to-moderate income jobs. Replace: The Workforce Development Program satisfies the LMI national objective by benefiting low- to-moderate income limited clientele. c. Allocation Methodology (page 157) This section was updated to include regional grant allocation calculation, data and justification. Remove: The State makes funding available to eligible subrecipients, statewide, using an application process. HCD provides application guidelines for funding awards including rating factors, as part of the application outreach. Replace: Funding is available to subrecipients based on a formula to determine a proportionate share of the total program allocation based on the impacts to that jurisdiction. After consultation with identified eligible counties HCD used a methodology to calculate allocations based on four post disaster economic factors that assessed economic revitalization needs post disaster; the ratio of damaged structures from Figure 84, ratio of disaster unemployment (DUA) claims after the event from Figure 85, ratio of existing relevant workforce training resources in the eligible counties from Figure 100 and a survey of regional need for workforce development resources from Figure 101. This allocation utilizes a weighted formula that weighs the four data points, twenty percent for damaged structure ratio, twenty-five percent for disaster unemployment claims ratio, forty percent for an inverse ratio of existing relevant workforce training resources and fifteen percent for an inverse ratio of regional available regional resources. The two inverse ratio’s for local and regional trainings put greater weight to eligible counties that have fewer available workforce training resources, and less weight to eligible counties with more available workforce training resources. This weighted formula puts the most weight on the need to develop or expand existing training programs in the eligible counties and the need for an increased skilled construction labor force to aid housing and infrastructure recovery, addressing public comment. ADD: Figure 97: Workforce Development Program Regional Grant Allocations Eligible Counties Percent of Total Regional Grant Allocation Butte County 46.06% $18,742,117.42 Lake County16.32% $6,642,191.11 Shasta County 14.98% $ 6,096,458.29 Los Angeles County 8.07% $ 3,283,960.49 Ventura County14.57% $ 5,930,215.29 Total $40,695,960.00 ADD:Figure 98: Ratio of Post Disaster Economic Factors Damaged DUA Claims Inverted WF Regional WF Eligible Counties Structures RatioRatio Ratio Ratio Butte County 82.28 75.78 18.48 21.74 Lake County1.291.9330.821.74 Shasta County 7.96 4.42 18.48 32.61 Los Angeles County 7.2 16.39 1.44 13.04 Ventura County1.27 1.47 30.8 10.87 ADD: Figure 99: Regional Allocations by Post Disaster Economic Factors Damaged Regional WF Eligible Counties Structures DUA ClaimsWF Ratio Ratio Allocation Butte County $6,696,927.18 $7,709,849.62 $3,008,245.36 $1,327,095.26 Lake County $104,995.58 $196,358.01 $5,013,742.27 $1,327,095.26 Shasta County $647,879.68 $449,690.36 $3,008,245.36 $1,990,642.88 Los Angeles County $586,021.82 $1,667,516.96 $234,408.73 $796,012.98 Ventura County $103,367.74 $149,557.65 $5,013,742.27 $663,547.63 Total $8,139,192.00 $10,172,972.60 $16,278,384.00 $6,104,394.00 ADD: Figure 100: Available Workforce Development Programs in Eligible Counties Employment Total Workforce Eligible County College Trainings Development Training Department Services Services Butte County 3 2 5 Lake County 2 1 3 Shasta County 3 2 5 Los Angeles County 17 47 64 Ventura County 2 1 ADD: Figure 101: Available Regional Workforce Development Programs Regional Workforce Programs Within 50 Eligible County Miles from County Border Butte County 6 Lake County 6 Shasta County 4 Los Angeles County 10 Ventura County 12 d. Delivery (page 157) Updated section to clarify delivery and administration is open to jurisdictions and other eligible entities. Remove: The program is monitored at the state level but is delivered and administered through the use of local not-for-profit organizations acting as subrecipients to HCD. A Notice of Funding Availability (NOFA) will be used to solicit applications for funding from eligible applicants including, local non-profits, workforce development, and training organizations. Replace: The program is monitored at the state level but is delivered and administered through the use of local jurisdictions, not-for-profit organizations or other eligible entities acting as subrecipients to HCD. A Notice of Funding Availability (NOFA) will be used to solicit applications for funding from eligible applicants including, local non-profits and local jurisdictions. e. Eligibility (page 157) Section language edited to clarify the prioritization of LMI beneficiaries, to now read: Remove: Applicants must demonstrate that 51 percent of their current program participants are LMI or that they will establish a program in which at least 51 percent of their participants are LMI. The applicant must also demonstrate past success delivering workforce recovery training. These requirements will be detailed further in the workforce recovery program policies & procedures. Replace: Applicants must commit to serve primarily LMI clients, in which at least 51 percent of their participants are LMI. Additional eligibility requirements will be detailed further in the workforce development program policies & procedures. f. Prioritization (page 157-158) Section updated to clarify prioritization of partnerships and the removal Prioritization Tiers by location and income. Remove: Additional priorities will include subrecipients serving predominately LMI areas, entities with a demonstrated history of successful workforce development programming and applications that propose, with the capacity to provide, supportive services. Replace: Additional priorities will include subrecipients serving predominately LMI areas, entities that demonstrate a familiarity with successful workforce development programming, or related fields, either through direct experience or strong partners with experience and applications that propose supportive services. Remove:Figure 96 Workforce Recovery Program Prioritization WORKFORCEDEVELOPMENTPROGRAMPRIORITIZATIONTIERS Location of the Training Income ofthe Beneficiary Site All Areas that LMI Only All Incomes 4 Most Received a Impacted Counties Federal and Zip Codes Disaster Declaration Tier 1X X Tier 2X X Tier 3 X Tier 4X X g. Eligible and Ineligible Costs (page 158-159) This section was edited to reflect broadened approach to eligible activities associated with supportive services and delivery of training. Remove: Qualifying workforce development programs are reimbursed for salaries and benefits for instructors, operating costs for educational programming, supplies, materials, and required equipment. Workforce development programs include, but are not limited to, training in the following areas: Construction trades (includes labor and or licensing) Heavy Equipment Operators Wildland and Forestry Fire Training Ecological Restoration Training Forest Restoration Training Ecological and structural hardening Training Arborist Training Modular Home and Mobile Home Construction Training programs Enhanced Resilience Training programs Masonry Roofing Carpentry Concrete and flatwork Plumbing 158 Heating, Ventilation, and Air Condition (HVAC) Electricity On-the-job Training (OJT) Replace: HCD commits to funding activities eligible under Title I of the Housing and Community Development Act of 1974 and those activities specified by waiver in 83 FR 5851. Qualifying workforce development programs are reimbursed for salaries and benefits for instructors, operating costs for educational programming, supplies, materials, required equipment, indirect costs, acquisition, improvements and other costs necessary for delivery of workforce training and supportive services. A final list of eligible costs will be available in the program policies and procedures. Workforce development programs may include training related, but not limited to, the following areas: Construction trades (includes labor and or licensing) Heavy Equipment Operators Wildland and Forestry Fire Training Ecological Restoration Training Forest Restoration Training Ecological and structural hardening Training Arborist Training Modular Home and Mobile Home Construction Training programs Enhanced Resilience Training programs On-the-job Training (OJT) h. Form of Assistance (page 159) Section updated to clarify applicants qualified to receive funding from HCD. Remove: Qualifying organizations receive funding from HCD to execute programming as a reimbursement for costs incurred. Replace: Qualifying subrecipients receive funding from HCD to execute programming as a reimbursement for costs incurred. H. Small Business Recovery Program (pages 159-160) This entire program, a sub-program of Economic Revitalization, has been removed.