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HomeMy WebLinkAbout5.11.22 CDBG-DR Action Plan 2020 (3) From:Hatcher, Casey To:BOS Cc:Boston, Shelby; Jimerfield, Joshua Subject:2020 CDBG-DR Action Plan Date:Wednesday, May 11, 2022 10:29:38 AM Good morning Board Members Congress appropriated $201,046,000 in CDBG-DR funds for disaster recovery activities and $30,157,000 for mitigation activities to California for 2020 disasters. State HCD issued the Draft Grant Action Plan for 2020 CDBG-DR, which includes two major disaster declarations for California in 2020. The North Complex Fire is included for Butte County along with more than 9,900 fires that burned in the State between August and November of 2020. The Action Plan calculates an unmet need between $600 Million and $1.3 Billion for housing, infrastructure, and economic recovery. The appropriation of $231 Million does not meet the needs of communities across California for disaster recovery after these fire. Given the substantial unmet need, the Action Plan focuses on housing programs and leveraging other funding sources. It is unclear at this time if there will additional appropriations for 2020 CDBG-DR and what other resources the State hopes to leverage for disaster recovery needs. The State Action Plan proposes to use the CDBG-DR funds primarily for housing with a limited amount for infrastructure: Housing ($183 Million) o Owner-occupied reconstruction (OOR) program ($45.8 Million) – similar to the current RecoverCA program (program administered by HCD) o OOR mitigation ($21.4 Million) – the State will use a portion of the mitigation funds to enhance the OOR reconstructions with mitigation activities, such as defensible space (program administered by HCD) o Homebuyer assistance program ($9.1 Million) – down payment assistance to low-to- moderate-income homeowners to relocate outside the high-risk areas/disaster declared areas (program administered by HCD) o Multifamily housing ($128.3 Million) – financing for affordable rental housing development (program administer by HCD) o Multifamily mitigation ($7.1 Million) – the State will use a portion of the mitigation funds to enhance the MHP constructions with mitigation activities, such as hardening and wildfire retrofitting (program administered by HCD) Infrastructure ($7.3 Million) o Funding for local jurisdiction for the local share of costs for approved FEMA Public Assistance infrastructure projects. The Multifamily allocation for the Butte County area is $33,720,696, which will be administered by the State. This allocation is based on Butte County’s percentage of low-to-moderate income renters impacted based on FEMA individual assistance data. Butte County has the second largest multifamily allocation and Santa Cruz County received the largest allocation at $43,479,657. The State is accepting public comment on the draft Action Plan until June 6, 2022. County staff will attend the public comment meeting on May 18, 2022 at 6:00 pm and provide input about the unmet needs in Butte County including housing, infrastructure, and hazard mitigation projects. County staff will also share concerns about the multifamily housing program being operated at the State level and the lack of local input to the process. Our staff have established a good relationship with HCD and they often look to us when they have questions about the local perspective and impacts. This is the third round of CDBG-DR funds that apply to Butte County in the last five years. Please let me know directly if you have any questions. Thank you. Casey Casey Hatcher Deputy Chief Administrative Officer Butte County Administration 25 County Center Drive, Suite 200, Oroville, CA 95965 T: 530.552.3336 | M: 530.518.3508 Twitter | Facebook | YouTube | Pinterest Dbmjgpsojb!Efqbsunfou!pg! Ipvtjoh!boe!Dpnnvojuz! Efwfmpqnfou! Dpnnvojuz!Efwfmpqnfou!Cmpdl! Hsbou!Bdujpo!Qmbo!3131! Qvcmjd!Dpnnfou!Esbgu! Nbz!7-!3133! Qvcmjd!Mbx!228.54! 2 Table of Contents List of Figures...............................................................................................................................5 I. Executive Summary...............................................................................................................9 A.Overview............................................................................................................................9 B.Disaster Specific Overview..............................................................................................10 1. 2020 Wildfires...............................................................................................................10 2. August and September Wildfires (DR-4558)................................................................10 3. September, October, and November Wildfires (DR-4569)...........................................11 C. Ongoing Threat.............................................................................................................11 D. Anticipated Unmet Recovery Needs.............................................................................12 Proposed Uses of CDBG-DR Funds...........................................................................................14 II. Needs Assessment..............................................................................................................15 A.Background......................................................................................................................15 B.Summary of Disaster Impacts..........................................................................................18 C. HUD-Designated Most Impacted and Distressed Areas..............................................19 1. Expanding MID Zip Codes to Full Counties..................................................................10 D. Demographic Profile of Impacted Counties..................................................................13 E.Impacts on Low-and Moderate-Income Populations.......................................................13 1. Social Vulnerability Index (SOVI).................................................................................13 F. Housing Impact................................................................................................................17 1. Cost Burdened Households..........................................................................................17 2. Persons Experiencing Homelessness..........................................................................19 3. Mobile Housing Units....................................................................................................23 4. Social and Public Service Programs............................................................................25 5. Insurance......................................................................................................................30 G. Impact on Vulnerable Populations................................................................................32 1. Race.............................................................................................................................32 2. Ethnicity........................................................................................................................35 3. Households with Children.............................................................................................38 4. Population with Disabilities...........................................................................................40 5. Population 65 and Older...............................................................................................43 6. Population with Limited English Proficiency.................................................................46 H. Analysis of Housing Unmet Need.................................................................................49 1. Overview of Data Sources............................................................................................49 1 2.Limitations of Data........................................................................................................50 3. FEMA Individual Assistance.........................................................................................52 4. Small Business Administration Loans..........................................................................69 5. Summary of Housing Impacts......................................................................................70 6. Cost of Reconstruction.................................................................................................71 7. CAL FIRE Alternative Methodology..............................................................................72 I. Infrastructure Unmet Need...............................................................................................73 1. FEMA Public Assistance Overview..............................................................................73 2. Hazard Mitigation Grant Program.................................................................................75 J. Economic Revitalization Unmet Need..............................................................................78 Affirmatively Further Fair Housing.......................................................................................82 Racially and Ethnically Concentrated Areas of Poverty.......................................................83 Poverty Rate........................................................................................................................85 Housing Tenure...................................................................................................................88 Median Housing Value.........................................................................................................90 Gross Rent...........................................................................................................................91 Educational Attainment........................................................................................................92 Impacts on Low-and Moderate-Income (LMI) Populations.................................................94 HUD Income Limits..............................................................................................................97 Impact on Housing...............................................................................................................99 K.Mitigation Needs Assessment........................................................................................100 1. Overview.....................................................................................................................100 2. Mitigation Funding Background..................................................................................101 3. Method........................................................................................................................102 4. State Hazard Mitigation Plan......................................................................................103 5. Primary Hazard Rankings -2020 Impacted Counties................................................104 6. ....................................................108 7. Local Hazard Mitigation Plans....................................................................................134 8. Risk Assessment........................................................................................................140 9. Relevant State Laws and Programs...........................................................................143 10. -2022 Budget................................................................................148 11. Statewide Plan Alignment for Equitable Recovery from Disasters.........................148 III. General Requirements...................................................................................................150 A.Citizen Participation.......................................................................................................150 B.Outreach and Engagement............................................................................................150 2 1.Stakeholder Consultation...........................................................................................151 2. Stakeholder Meetings and Public Hearings................................................................153 3. Tribal Partners............................................................................................................156 4. Limited English Proficiency.........................................................................................156 C. Complaints..................................................................................................................156 D. Public Website............................................................................................................157 E.Substantial Amendments...............................................................................................157 F. Non-Substantial Amendments.......................................................................................158 G. Consideration of Public Comments............................................................................158 H. Displacement of Persons or Entities...........................................................................159 I. Protection of People and Property.................................................................................160 J. Appeals Process............................................................................................................164 K.Contractor Standards.....................................................................................................165 L.Preparedness, Mitigation, and Resiliency......................................................................166 M. Cost Controls for Cost-Reasonableness....................................................................167 N. Duplication of Benefits Review...................................................................................167 O. Fair Housing...............................................................................................................167 P.Demonstrable Hardship.................................................................................................168 Q. Not Suitable for Rehabilitation....................................................................................168 IV.Grantee Proposed Use of Funds...................................................................................168 A.Connection of Programs to Unmet Needs.....................................................................168 1. Unmet Needs and Proposed Programs......................................................................168 B.Allocation of Funds.........................................................................................................169 C. National Objective......................................................................................................169 D. Program Budget.........................................................................................................170 E.Leveraging Funds..........................................................................................................170 F. Program Allocations.......................................................................................................171 1. Method of Distribution.................................................................................................171 2. Criteria to Determine Method of Distribution..............................................................171 3. HCD Administered......................................................................................................172 4. Subrecipient Administered..........................................................................................173 5. Reimbursement Payments to Subrecipients..............................................................173 6. Program Income.........................................................................................................173 7. Recapture...................................................................................................................174 8. Eligible Geographic Areas..........................................................................................174 3 G.Housing Recovery Programs......................................................................................174 1. Owner Occupied Housing Rehabilitation and Reconstruction Program.....................175 2. Homebuyer Assistance Program................................................................................183 3. Multifamily Housing Program (MHP)..........................................................................184 H. Infrastructure Recovery Program...............................................................................193 1. FEMA Public Assistance Program (PA) Match...........................................................194 I. Mitigation Program.........................................................................................................196 1. OOR Mitigation...........................................................................................................199 2. MHP Mitigation...........................................................................................................199 V. Administration and Planning..............................................................................................200 A.Application Status..........................................................................................................200 B.Program Budget.............................................................................................................202 C. Program Income.........................................................................................................202 D. Projection of Expenditures and Outcomes.................................................................203 E.Certification and Risk Analysis.......................................................................................203 VI.Appendices....................................................................................................................204 A.CDBG-DR Certifications.................................................................................................204 B.Summary and Response of Public Comments..............................................................206 C. Common Acronyms....................................................................................................206 D. Standard Form 424.....................................................................................................206 4 List of Figures Figure 1: Unmet Need Calculation HUD Methodology............................................................13 Figure 2: Unmet Needs Calculation Alternative Methodology.................................................13 Figure 3: 2020 CDBG-DR Action Plan Total Allocation and Program Funding by Program Type ....................................................................................................................................................15 Figure4: FEMA IA Declared Counties DR-4558 and DR-4569...............................................16 Figure 5: FEMA DR-4558 Disaster Declaration Areas................................................................17 Figure 6: DR-4569 Disaster Declaration Areas...........................................................................18 Figure 7: HUD Most Impacted and Distressed Counties and Zip Codes....................................19 Figure 8: HUD Most Impacted and Distressed Zip Codes and Counties....................................10 Figure 9: Expanded List of Most Impacted and Distressed Counties.........................................10 Figure 10: Most Impacted and Distressed Areas 2020 Disasters............................................11 Figure 11: Map of Expanded MID Areas for 2020 Disasters......................................................12 Figure 12: 4558 Social Vulnerability Index..................................................................................14 Figure 13: 4569 Social Vulnerability Index..................................................................................15 Figure 14: SOVI Ranking and FEMA IA Major/Severe Properties Northern CA......................16 Figure 15: SOVI Ranking and FEMA IA Major/Severe Properties Southern CA.....................17 Figure 16: 4558 Cost Burdened Households..............................................................................18 Figure 17: 4569 Cost burden......................................................................................................19 Figure 18: 4558 Point-In Time Homeless Population 2020........................................................19 Figure 19: 4569 Point-in Time Homeless Population 2020.........................................................20 Figure 20: 4558 Point-In Time Homeless Population by Shelter Status 2020............................21 Figure 21: 4569 Point-In Time Homeless Population by Shelter Status 2020............................22 Figure 22:4558 Percent Housing Mobile Homes.......................................................................24 Figure 23: 4569 Percent Housing Mobile Homes.......................................................................25 Figure 24: Case Management Caseloads and Closures............................................................26 Figure 25: DR-4558 Case Management Vulnerabilities..............................................................26 Figure 26: DR-4569 Case Management Vulnerabilities..............................................................27 Figure 27: Case Management Housing Goals............................................................................27 Figure 28: DR-4558 Case Management Needs..........................................................................28 Figure 29: DR-4569 Case Management Needs..........................................................................29 Figure 30: D-SNAP Applicants for DR-4558 & DR-4569............................................................30 Figure 31: Residential Insurance Claims for DR-4558 & DR-4569.............................................31 Figure 32 Demographics by Race for DR-4558 Counties........................................................32 Figure 33: Demographics by Race for DR-4569 Counties..........................................................33 Figure 34: Percent Black or African American Population Map Northern CA..........................34 Figure 35: Percent Black or African American Population Map Southern CA.........................35 Figure 36: Percent Hispanic or Latino Population for DR-4558 Counties...................................36 Figure 37: Percent Hispanic or Latino Population for DR-4569 Counties...................................37 Figure 38: Percent Hispanic or Latino Population Northern CA...............................................37 Figure 39: Percent Hispanic or Latino Population Southern CA..............................................38 Figure 40: 4558 Households with Children.................................................................................39 Figure 41: 4569 Households with Children.................................................................................40 Figure 42: 4558 Population With a Disability..............................................................................41 Figure 43: 4569 Population with a Disability...............................................................................42 Figure 44: Persons with Disability Map Northern CA...............................................................42 5 Figure 45: Persons With Disabilities Map Southern CA...........................................................43 Figure 46: 4558 Elderly population.............................................................................................44 Figure 47: 4569 Elderly Population.............................................................................................44 Figure 48: Elderly Population Map Northern CA......................................................................45 Figure 49: Elderly Population Map Southern CA.....................................................................46 Figure 50: 4558 Population with Limited English Proficiency.....................................................47 Figure 51: 4569 Population with Limited English Proficiency.....................................................47 ...............48 Figure 53: 4569 ................49 Figure 54: Total FEMA IA Registrations by Disaster..................................................................53 Figure 55: Total FEMA IA Registrations For 4558 And 4569......................................................54 Figure 56: FEMA Individual Assistance by Renter and Owner...................................................55 Figure 57:Average FEMA IA Verified Loss Over $0 by County..............................................56 Figure 58: FEMA IA Renters, Loss Over $0 with Personal Property Damage, by HUD Damage Category.....................................................................................................................................57 Figure 59: FEMA IA Renters, Loss Over $0 With Personal Property Damage, By HUD Damage Category.....................................................................................................................................57 Figure 60: Low and Moderate Income Renters With a FEMA Verified Loss by County..............58 Figure 61: Low and Moderate Income Renters by HUD Income Category.................................59 Figure 62: FEMA IA Owners with Real Property Over $0 by Damage Category........................60 Figure 63: FEMA IA Owners With Real Property Over $0 by Damage Category Major/Severe Only.............................................................................................................................................61 Figure 64: Renter Households by HUD Income Category..........................................................62 Figure 65:LMI Owner By Income Over $0 Real Property Loss, With Income......................63 Figure 66: Low Income Renter and Owner Characteristics........................................................63 Figure 67: FEMA IA With Major/Severe Damage Northern CA...............................................64 Figure 68: FEMA IA With Major/Severe Damage Southern CA...............................................65 Figure69: Over 65, Total Verified Loss Over $0........................................................................65 Figure 70: CAL FIRE 2020 Disaster Damage Survey by Structure Type...................................66 Figure 71: CAL FIRE Damage Survey Residential Structures Only by Damage Category.....67 Figure 72: CAL FIRE Single Family Properties Destroyed in 2020 Disasters..........................68 Figure 73: SBA Home Loan Applications and Verified Loss by County DR-4558...................69 Figure 74: SBA Home Loan Applications and Verified Loss by County DR-4569...................70 Figure 75: SBA Ratio..................................................................................................................71 Figure 76: Housing Unmet Need HUD Methodology...............................................................71 Figure 77: Average Cost of Reconstruction for Stick Built Homes from Solution 1 of 2017-2018 CDBG-DR OOR Program...........................................................................................................72 Figure 78: CDBG-DR Multi family Housing Program Cost Per Unit............................................72 Figure 79: FEMA PA For DR-4558.............................................................................................73 Figure 80: FEMA PA Local Share Only for DR-4558 by Category.............................................74 Figure 81: FEMA PA For DR-4569.............................................................................................74 Figure 82: FEMA PA Local Share Only for DR-4569 by Category.............................................74 Figure 83: HMGP Program Applications and Local Match DR-4569.......................................75 Figure 84: HMGP Program Applications and Local Match DR-4558.......................................76 Figure 85: HMGP Applications For 4569 And 4558 As Of February 2022 (In FEMA Review)76 Figure 86: Total SBA Business Loans Approved........................................................................78 Figure 87: SBA Applicant Breakdown, EIDL and Business Loans DR-4569...........................79 6 Figure 88: SBA Applicant Breakdown, EIDLand Business Loans DR-4558...........................80 Figure 89: SBA Economic Injury Disaster Loan, DR-4569.........................................................80 Figure 90: SBA Economic Injury Disaster Loan, DR-4558.........................................................80 Figure 91: EIDL And Business Loans DR-4558.......................................................................81 Figure 92: EIDL and Business Loans DR4569........................................................................81 Figure 93: RECAP Areas And FEMA IA Major/Severe Properties Northern CA......................84 Figure 94: RECAP Areas And FEMA IA Major/Severe Properties Southern CA.....................85 Figure 95: 4558 Poverty Rate By County...................................................................................86 Figure 96: 4569 Poverty Rate by County....................................................................................86 Figure 97: Poverty Rate Map Northern CA..............................................................................87 Figure 98: Poverty Rate Map Southern CA.............................................................................88 Figure 99: 4558 Housing Tenure by County...............................................................................89 Figure 100: 4569 Housing Tenure By County.............................................................................89 Figure 101: 4558 Median House Value Owner Occupied Housing.........................................90 Figure 102: 4569 Median House Value Owner OccupiedHousing.........................................90 Figure 103: 4558 Median Gross Rent.........................................................................................91 Figure 104: 4569 Median Gross Rent.........................................................................................91 Figure 105: 4558 Educational Attainment...................................................................................92 Figure 106: 4569 Educational Attainment...................................................................................92 Figure 107: Population Without A College Degree Map Northern CA.....................................93 Figure 108: Population Without A College Degree Map Southern CA.....................................94 Figure 109: 4558 LMI Population Data By County......................................................................95 Figure 110: 4569 LMI Population Data By County......................................................................95 Figure 111: Low-And Moderate-Income Population MAP Northern CA.................................96 Figure 112: Low-and Moderate-Income Population Map Southern CA.................................97 Figure 113: Statewide Income Limits..........................................................................................98 Figure 114: 4558 Income Limits..................................................................................................98 Figure 115: 4569 HUD Income Limits.........................................................................................99 Figure 116: MID Residential Insurance Claims for DR-4558 and DR-4569................................99 Figure 117: 2020 Declared Disasters and Most Impacted and Distressed Areas....................102 Figure 118: State of California Primary Hazard Grouping........................................................104 5 Figure 119: Primary Hazard Ranking, by 2020 Impacted Counties.........................................104 Figure 120: 2020 Impacted Counties by State of California Primary Hazards..........................106 Figure 121: State of California Other Hazards of Concern.......................................................106 Figure 122: LHMPs Year Approved and Year Expired.............................................................107 Figure 123: Earthquake Shaking Hazard Affecting Buildings...................................................109 Figure 124: Probability of Earthquake Magnitude 6.7 or Greater Occurring in 30 years, by Region.......................................................................................................................................110 Figure 125: Flood Hazards in California...................................................................................111 Figure 126: FEMA Flood Insurance Rate Map.........................................................................112 Figure 127: Fire Hazard Severity Zones in State Responsibility Areas....................................115 Figure 128: Wildfire Threat Areas.............................................................................................116 Figure 129: Air Pollution MID Northern CA............................................................................119 Figure 130: Air Pollution MID -Central CA...............................................................................120 Figure 131: Air Pollution MID -Los Angeles.............................................................................121 Figure 132: Exposure to Cleanup Sites MID Northern CA.....................................................122 Figure 133: Exposure to Cleanup Sites MID -Central CA........................................................123 7 Figure 134: Exposure to Cleanup Sites MID -Los Angeles......................................................124 Figure 135: Drinking Water Contaminants MID Northern CA................................................125 Figure 136: Drinking Water Contaminants MID -Central CA...................................................126 Figure 137: Drinking Water Contaminants MID -Los Angeles.................................................127 Figure 138: Solid Waste Sites MID Northern CA...................................................................128 Figure 139: Solid Waste Sites MID -Central CA......................................................................129 Figure 140: Solid Waste Sites MID -Los Angeles....................................................................130 Figure 141: Responsibility Areas by Agency............................................................................131 Figure 142: BIA Land Area Representations Northern CA....................................................133 Figure 143: BIA Land Area Representations Southern CA....................................................134 Figure 144: Local Hazard Mitigation Plans -Top Hazards.......................................................135 Figure 145: Statewide Risk and Exposure, May 2022..............................................................136 Figure 146: Summary of General Plan Safety Elements..........................................................136 Figure 147: FEMA Community Lifelines Components..............................................................140 Figure 148: Statewide Hazards by Community Lifeline (1 of 2)................................................141 Figure 149: Statewide Hazards by Community Lifeline (2 of 2)................................................141 Figure 150: 2020 Disaster Impacted Counties with Community Wildfire Protection Plans.......142 Figure151: Recovery Needs by County from 2020 Disasters..................................................153 Figure 152: Fire Hazard Severity Zones in State Responsibility Areas....................................162 Figure 153: 2020 CDBG-DR Action Plan Total Allocation and Program Funding by Program Type..........................................................................................................................................170 Figure 154: CBDG-DR Owner-Occupied Housing Program Applicant Prioritization Tiers........181 Figure 155: Multifamily Housing Program NOFA Regional Set-Asides....................................187 Figure 156: Multifamily Housing Program Maximum Per-Unit Subsidy Limits (As of April 2022) ..................................................................................................................................................189 Figure 157: 2020 CDBG-DR Action Plan Budget by Total and Programs................................202 8 I.Executive Summary A.Overview InFebruary 2022, the U.S. Department of Housing and Urban Development (HUD) announced that the State of California will receive$201,046,000 in funding to support long-term recovery efforts following the wildfires of 2020.These funds were made availableundertheDisaster Relief Supplemental Appropriations Act, 2022 (Pub. L. 117-43),andallocated to the state through the publication of the Federal RegisterNotice, FR-6303-N-01(FRN).The total amount of$231,203,000 allocatedto California, to support recovery and infrastructure,includes awards of$201,046,000 for disaster recoveryactivities and $30,157,000for mitigation activities. The President issued two major disaster declarationsfor California in 2020, DR-4558 and DR- 4569, which together refer to the impact of more than 9,900 fires that swept through the state between August and November of that year. After the President declares a major disaster, Congress may appropriate Community Development Block Grant-Disaster Recovery (CDBG-DR) fundingto HUD to support recovery projects and activitiesin areas most impacted by a disaster.CDBG-DR funding is designed to address significant unmet needs in housing, economic development, infrastructure, and services programs after all other assistance has been exhausted. The California Department of Housing and Community Development (HCD) is the lead and responsible agency for administering the CDBG-DR funds allocated to the State of California. HCD strives to ensure that every Californian has a safe, stable, and affordable home. However, California is in a housing crisis a half century in the making. After decades of underproduction, housing supply is far behind need leading to soaring housing prices and rents. Disaster ongoing housing crisisdisproportionately impacts and highlights the historical disadvantages of Black, Indigenous and People of Color, vulnerable populations, and federally protected classes. This Action Planthe collective local and statewide impact ofthe 2020 disastersDR-4558 and DR-4569, the unmet needs listed above allocating funding to recovery projects and programs in theareasmost impacted and distressed by the disasters.HCD commits to directingatleast70percent,$161,842,100,of the total 2020 grant allocation,$231,203,000, tobenefit lowand moderate income (LMI) individuals or areas in accordance with Section 103 of the Housing and Community Development Act. HCD also commits to directing no less than 80 percent,$184,962,400,of the total allocation to benefit HUD-identified most impacted and distressed areas (MID). The MID areas are further described in the Unmet Needs Assessment section. To streamlinethe recovery processand hasten recovery activities, HUD included waivers, alternative and additional requirements, and clarifications for CDBG-DR expenditures in the FRN.HCD has addressed these changes throughout this document. 9 B.Disaster Specific Overview 1.2020 Wildfires The 1 history.A%In January and Februaryof 2020, California experienced one of the driest periods on record for that time of year, followed by a mass die-off of trees across the state.While consistent rain in March and Aprilalleviated drought conditions, the risk of wildfires remained high for both Northern and Southern California, and the state braced for the summer. In mid-August 2020, a series of massive and severe summer thunderstorms over Northern California caused a siege of dry lightning, which sparked the first fireofthe record-breaking and devastating season.By the end of the year, more than 9,900 fires had claimed 33 lives, burned through an estimated 4,304,379 acres, destroyed or damaged over 11,000structures, and 2 resulted in over $12billion in damages.@% The President issued the first of twomajor disaster declarations(DR-4558)in August of 2020, which designated 15 countiesas eligible forimmediate aid. In October, afteranother wave of , the President issued a second 3 declaration (DR-4569), covering 10 counties.?% 2.August and September Wildfires (DR-4558) On August 16, 2020, an unprecedented number of lightning strikes were recorded over California.During the first hours of the storm, approximately 2,500 lightning strikes hit the Bay Area; within the next 96 hours, 4 more than 12,000 lightning strikes were recorded over California.>%The siege ignited650 fires across Northern California, which proliferated and intersected to produce three massive wildfires: the SCU Lightning Complex, the August Complex, and the LNU Lightning Complex. On September 10, 2020, the August Complex fire set a record for the single-largest wildfire in acres. 1 California Department of Forestry and Fire Protection(CALFIRE) Incident Archive, n.d. https://www.fire.ca.gov/incidents/2020/. 2 California Department of Forestry and Fire Protection (CAL FIRE) . n.d., https://www.fire.ca.gov/media/0fdfj2h1/2020_redbook_final.pdf. 3 Ibid. 4 Times,August 23, 2020.https://www.latimes.com/california/story/2020-08-23/dry-lightning-northern-california-fire- scourge. 10 The President granted a major disaster declaration for the State of California on August 20, 2020. The declaration, FEMA DR-4558, spanned an incident period from August 14, 2020 5 November 17, 2020.=% 3.September, October, and November Wildfires (DR-4569) Asthe state battled the first onslaughtintolateSeptember,a record-breaking heat wave and katabatic winds whipped smaller ignitions into new megafiresthatimpactedFresno, Los Angeles, Madera, Mendocino, Napa, San Bernadino, San Diego, Shasta, Siskiyou, and Sonoma Counties.The new waveprompted a second major disaster declarationon October 16, 2020, and spanned an incident period from September 4, 2020,to November 17, 2020. C.Ongoing Threat Thedisasters of 2020werefollowed closelybyyet another historic fire season in 2021, when ongoing drought, extreme heat, reduced snowpack, and vastly diminished tree mass ignited an unusually early wildfire season in California.By July of 2021,fires had burned more than three times as many acrescompared to the previous year.The President issued a major disaster declaration for Northern California in August of 2021,asthe state was facing "unprecedented fire conditions" as new ignitions and megafiresraged on.The 2021 wildfire season ultimately sparked approximately 8,600 firesandburned about 2.5million acres, compared with 10.1 6 million in 2020.<% Thistrend shows no sign of slowing. According to broadscientific consensus, the frequency and 7 severity of wildfires inNorth Americaare increasing due to climate change.;%In California, climate change impactsthat contribute to wildfire riskinclude sustained and widespread drought,massive reductionsin tree and vegetation coverage,increased severity of seasonal katabatic winds, and others. The state experienced its second driest water year on record in 2021, and as ofMay 2022, all 58counties in the state are under a drought emergency proclamation. -incremental transition between very dry and ve 5 Federal Emergency Management Agency (FEMA).-4558-FEMA.gov, n.d. https://www.fema.gov/disaster/4558. 6 Incident Archive, n.d. https://www.fire.ca.gov/incidents/2021/. 7 Miller, Rebecca. https://www.scientificamerican.com/article/climate-change-is-central-to-californias-wildfires/. 11 climate change will make forests more susceptible to extreme wildfires, especially if greenhouse 8 gas emissions continue to rise. Meanwhile, anthropogenic factors such as ignitions, infrastructure, and development at the wildland-urban interfaceincrease both the likelihood of future wildfires and exposure to those hazards. Approximately 85 percent of all fire ignitions in California are the result of human activity, with the rest due to lightning. Veriskmost-recently updated FireLine Risk Report, whichanalyzes wildfire risktoresidential structuresby examining principal factors like flammable vegetation, topography,fire response, infrastructure, and wind patterns,shows that 2 million housing units totalare at high and extreme risk of wildfire. Another 1.6 million, or 12 percent, are at 9 moderate risk. While the breadth and severity of the 2020 wildfires are astonishing for a single event, the devastation and disruption compound when placed on a timeline alongside previous and subsequentdisaster declarations, ongoing intermittent firesandflooding,and the enormous impact of the COVID-19 pandemic on D.Anticipated UnmetRecovery Needs Giventheprofound destruction and disruptionwrought by the 2020 wildfires on the State of California, unmet needs in the statMost Impacted and Distressed areas (MID)remain significant.HCD is committed toaddressing these needs viapursuing additional resources, including additional CDBG-DR funding, and leveraging other resources to support the statewide recovery effort. In addition, HCD continues tocoordinate closely with local, state, and federal partners to collect and analyze data, identify resources, and understand how unmet needs evolve over time. The following figure provides a summary of disaster impacts from DR-4558and DR-4569using February 3, 2022,Federal 10 Register Notice. 8 State of California, California Natural Resources Agencyrnia Climate Assessment, August 27, 2018. http://www.climateassessment.ca.gov/. 9 https://www.verisk.com/insurance/visualize/verisk-2021-wildfire-risk-analysis-provides-updated-data-on-rising-threat/. 10 Department of Housing and UrbanDevelopment (HUD).Allocations for Community Development Block Grant Disaster Recovery and Implementation of the CDBGDR Consolidated Waivers and Alternative Requirements NoticeFederal Register Vol. 87, No.23(February 3, 2022):6364. https://www.govinfo.gov/content/pkg/FR-2022-02- 03/pdf/2022-02209.pdf 12 F IGURE 1:U NMET N EED C ALCULATION HUDM ETHODOLOGY Percentof TypeData SourceTotal ImpactTotal ResourcesUnmet NeedTotal Allocation FEMA Public Assistance Infrastructure$53,722,462$43,649,500.37$10,072,961.632% (Category C-G Only) FEMA Hazard InfrastructureMitigation Grant $92,820,363$66,479,431$26,340,9325% Program FEMA Individual Housing$506,090,564$42,523,200$463,567,36480% Assistance EconomicSBA-Business$86,171,242$7,295,400$78,875,84214% Total-$738,804,631$159,947,531.37$578,857,099.63100% While the table above provides an unmet needs calculation based on the methodology outlined in the Federal Register Notice. The State of California submits the following unmet needs calculation using theCaliforniaDepartment of Forestry and Fire Protection (CAL FIRE) damage survey. Further details of the methodology used can be found in the Unmet Needs section of the document. This methodology uses a property by property survey conducted post- disaster of all destroyed properties, which presents a more accurate picture of the unmet recovery needs that FEMA Individual Assistance (FEMA IA) which impacted residents must register for. F IGURE 2:U NMET N EEDS C ALCULATION A LTERNATIVE M ETHODOLOGY % of Total TypeData SourceTotal ImpactTotal ResourcesUnmet Need Allocation FEMA Public Assistance Infrastructure$53,722,462$43,649,500.37$10,072,961.631% (Category C-G Only) FEMA Hazard InfrastructureMitigation Grant $92,820,363$66,479,431$26,340,9322% Program CAL FIRE Housing$1,237,714,545$42,523,200$1,195,191,34591% Damage Survey EconomicSBA-Business$86,171,242$7,295,400$78,875,8426% Total$1,470,428,612$159,947,531.37$1,310,481,080.63100% 13 Proposed Uses of CDBG-DRFunds HCD proposes the following programs to address the 2020 disasters: 1.Housing Programs Owner-Occupied Reconstruction Program(OOR) The program will provide rehabilitation or reconstruction assistance to eligible applicants based on the extent of damage to their primary residences. All projects will incorporate wildfire mitigation measures including the use of ignition-resistant building materials and the creation of defensible space, reducing risk from future wildfire disasters. OOR Mitigation Program All projects will incorporate wildfire mitigation measures including the use of ignition-resistant building materials and the creation of defensible space, reducing risk from future wildfire disasters. Homebuyer Assistance Program(HBA) HBA will be a standalone program run by HCD with the assistance of either a state agency partner or a procured contractorand will provide down payment and other housing assistance to low-to moderate-income disaster impacted homeowners, enabling them to relocate outside of high-risk areas or the disaster declared areas. Multifamily HousingProgram(MHP) The Multi-Family Housing Program (MHP) is designed to meet the unmet rental housing need, including the needs of individuals displaced from rental mobile homes, single-family and multifamily rental units, as well as individuals made homeless as a result from the disaster. Multifamily projects include apartment complexes and mixed-use developments. These developments are also intended to help replace rental housing units available to Housing Choice Voucher holders that were lost. The objective of the CDBG-DR funds is to provide necessary gap financing for the development of rental housing units in the HUD MID areas from DR-4558 and DR-4569. Multifamily Mitigation Program Theprogram will provide hardening, wildfire retrofitting, of multifamily units to withstand future disasters by increasing resilience to future wildfires and reducing or eliminating the long-term risk of loss of life, injury, damage to and loss of property, and suffering and hardship. 2.Federal Emergency Management AgencyPublic Assistance Match Program (FEMA PA) The Infrastructure Program aligns infrastructure investments with other planned federal funds in that the CDBG-DR funds will be used to fund the non-federal share match on approved FEMA Public Assistance (PA) projects. 14 F IGURE 3:2020CDBG-DRA CTION P LAN T OTAL A LLOCATION AND P ROGRAM F UNDING BY P ROGRAM T YPE 2020 CDBG-DR Action Plan Total Allocation$231,203,000Program % Administration$11,560,1505% 2020 Total Funding CDBG-DR (with administration)$201,046,00087% 2020 Total Funding Mitigation Set-Aside (with $30,157,00013% administration) CDBG-DR Program Funding$190,993,700 Housing Programs$183,353,95296% Multifamily Housing Program$128,347,76670% Owner Occupied Housing Program$45,838,48825% Homebuyer Assistance Program$9,167,6985% Infrastructure Programs$7,639,7484% FEMA PA Match$7,639,748100% Mitigation Set-Aside Program Funding$28,649,15015% Owner Occupied Housing Mitigation Program$21,486,86375% Multifamily Housing Mitigation$7,162,28725% II.Needs Assessment The State of California completed the following needs assessment to identify the effects, long- term needs, and priorities for CDBG-DR funding allocated as a result of the 2020 disasters. The two presidentially declared disasters covered by this needs assessment include the FEMA declarations DR-4568 and DR-4569. The needs assessment includes specific details about unmet needs within the eligible and Most Impacted and Distressed communities. This includes details for housing, infrastructure, and economic revitalization. This assessment takes into consideration pre-disaster needs in addition to unmet recovery needs resulting from the 2020 disaster. It discusses additional types of assistance that may be available to affected communities and individuals, such as insurance, other federal assistance or other possible funding sources. HCD understands that additional information may become available, and anticipates that if additional funds are allocated, there may be a different methodology for the distribution offunds. Adjustments to the Action Plan may be needed as a result of additional data or modified distribution methods; HCD will amend this assessment and the Action Plan as needed in the future. A.Background The table below lists the counties that FEMA designatedforFEMA IAfollowing the wildfires of 2020,which were comprised of two FEMA disaster declarations: DR-4568 and DR-4569.FEMA IA designation allows theindividuals and households in these counties to apply for financial and direct services after a federallydeclared disaster. These jurisdictionsare also referred to as -impacted counties. 15 F IGURE 4:FEMAIAD ECLARED C OUNTIES DR-4558 AND DR-4569 45584569 ButteFresno LakeLos Angeles LassenMadera MendocinoMendocino MontereyNapa NapaSan Bernadino San MateoSan Diego Santa ClaraShasta Santa CruzSiskiyou SolanoSonoma Sonoma Stanislaus Trinity Tulare Yolo The following FEMA maps illustrate the federally declared disaster areas and the type of FEMA funding approved for each impacted county for both DR-4558 and DR-4569. 16 F IGURE 5:FEMADR-4558D ISASTER D ECLARATION A REAS 17 F IGURE 6:DR-4569D ISASTER D ECLARATION A REAS B.Summary of Disaster Impacts Thescope and severity of damage wrought by the 2020 wildfires is difficult to overstate.The 2020 wildfire season ignited as the state was recovering from another historic fire season in 2017and 2018, whichimpacteddozens of counties acrossnorthern California.The2020 wildfires claimed31 lives, destroyed more than 10,000 buildings, burned more than 4percentof prompted FEMA IA declarations for22 counties, and forced the evacuation or displacement of tens of thousands of residents. The 2020 fires financial resourcesand recovery infrastructure, which were already beleaguered by the slew of earlier fire and fire-related environmental disasters and the global COVID-19 pandemic.According to the National Interagency Fire Center, Federal wildfire suppression costs in the United States have spiked from an annual average of about $425 million from 1985 to 1999 to $1.6 billion from 2000 to 2019.In California, suppression costs have nearly doubled over the last decade from the previous one, with CAL FIRE estimating $700 million in spending for the 2019/2020 fiscal 18 22 year. As California prepares for the 2022 fire season, the effects of climate change show no signs of slowing, and areas already damaged by earlier fires and those vulnerable to future disasters are bracing for continued challenges. The fires and megafires that comprised DR-4558 and DR- 4569 only further highlight the need for both disaster recovery and mitigation funding, planning, All of these impacts further exacerbated the existing housing crisis in California. Communities impacted by the 2020 wildfires had near zero housing vacancies prior to disasters, limiting options for disaster survivors for either temporary or more long-term housing options. High housing costs resulted in rent-burdenedhouseholds and many who live precariously close to homelessness. C.HUD-Designated Most Impacted and Distressed Areas HUD requires that 80 percent of CDBG-DR funding be spent within areas designated as Most 12 Impacted and Distressed(MID areas). HUD determines MID areasusing the following factors: Areas where FEMA has determined the damage was sufficient to declare the disaster a eligible to receive Individual and Households Program(IHP) funding Areas with concentrated damage defined as: o Counties exceeding $10 million in serious unmet housing needsand most impacted zip codes o Zip codes with $2 million or more of serious unmet housing needs o Disaster meeting the Most Impacted threshold o One or more county that meets the definition of Most Impacted and Distressed o An aggregate of Most Impacted zip codes of $10 million or more HUD designated five countiesand nine zip codes asMIDareas from theDR-4558 and DR-4569 disasters. F IGURE 7:HUDM OST I MPACTED AND D ISTRESSED C OUNTIES AND Z IP C ODES Most Impacted and Most Impacted and Distressed CountiesDistressed Zip Codes Butte95448 Napa95688 Santa Cruz93602 Los Angeles93664 11 A Journal -The Wildfire Crisis, November 1, 2021, https://www.nfpa.org/News-and-Research/Publications-and-media/NFPA- Journal/2020/November-December-2020/Features/Wildfire. 12 HUD, Federal Register Vol. 87, No. 23 (February 3, 2022): 6364. 19 Siskiyou94558 -94574 -95404 95409 - 96047 - 1.Expanding MID Zip Codes to Full Counties The Federal Register Notice provided clarification that, where HUD has identified an entire zip code as a MID area for the purposes of allocating funds, a grantee may expand program operations to the whole county or counties that overlap with that zipcode. HCDproposesto expand eligibility to the county level for allnine identifiedzip codes. The figure below lists each zip codewith its corresponding county. Napa County is the only jurisdiction not already listed as a MID county by HUD. F IGURE 8:HUDM OST I MPACTED AND D ISTRESSED Z IP C ODESAND C OUNTIES HUD-Designated MID ZIP CodeOverlapping County 95448Sonoma County 95688Solano County 93602Fresno County 93664Fresno County 94558Napa County 94574Napa County 95404Sonoma County 95409Sonoma County 96047Shasta County F IGURE 9:E XPANDED L IST OF M OST I MPACTED AND D ISTRESSED C OUNTIES Expanded List of Eligible Counties(HUD- identified MID counties and zip codes) Butte Fresno County Napa Santa Cruz Los Angeles Shasta Siskiyou 10 Solano Sonoma F IGURE 10:M OST I MPACTED AND D ISTRESSED A REAS 2020D ISASTERS 11 F IGURE 11:M AP OF E XPANDED MIDA REAS FOR 2020D ISASTERS 12 D.Demographic Profile of Impacted Counties Thecounties impacted by DR-4558 and DR-4569 represent a diverse range of demographics. The geographic spread of the disasters across the State of Californiaresults in a wide range of populations, geographies, housing inventories, resources, and challenges. Disaster impacted counties include coastal, interior, mountainous, and desert geographies ranging from southernmost county of San Diego to the northernmost county of Siskiyou. The counties themselves represent a large range of populations from low population density, rural counties like Trinity to dense, urban counties like Los Angeles. The counties also exhibitdiffering needs regardingpopulations and access to resources. There is a considerable disparitybetween the lowest median income counties (Siskiyou at $45,241) to thehighest median income counties (Santa Clara at $124,055) and a similarly large difference for housing values and gross rent. The following sectionshowsthatmany of theimpacted th counties rankamong the top 90percentile of vulnerability in the United States(Fresno, Madera, Tulare), while othersfall intothe lowest quartile of vulnerability in the country (San Mateo, Santa Clara, Sonoma). Some counties, like Monterey and Tulare,have special challenges like a large limited English proficiency population, or a particularly large, unhoused population like Los Angeles County. Even the wealthiest, most well-resourced counties have pockets of vulnerability. For instance, Napa County has the lowest poverty rate but still has 6.7 percent of the total population living in poverty. Every county also has a significant portion ofpeople who may have additional challenges or needs in disaster and disaster recovery, including homeless populations, people over age 65, and people living with disabilities. E.Impacts on Low-and Moderate-Income Populations 1.Social Vulnerability Index(SOVI) The CDCs social vulnerability index is aranking system that combines 15 social factors including poverty rate, unemployment rate, income, educational attainment, ages65 and older, ages17 or younger, civilianswith a disability, single-parent households, minority, speaks l,-unit structure, mobile homes, crowding, no vehicle, and group 13 quarters. The CDC social vulnerability index is intended as a tool to help public health officials and local planners better prepare forand respond to disastersbyestimating and planning forthe needs of vulnerable populations. The SOVIcan help countiescalculatesupply and emergency personnel needs to serve an area,identifyareas in need of emergency shelters, plan evacuation methods for those without cars or withmobility issues, and identify or who may have special needs 13 ol and Prevention, January 19, 2021), https://www.atsdr.cdc.gov/placeandhealth/svi/documentation/SVI_documentation_2018.html. 13 regarding evacuation, and toidentify communities that may have access to greater resources 14 duringdisaster response andrecovery. The percentile ranking represents the portion of counties nationwide that are equal to or lower in vulnerability to the county. A higher ranking indicates higher vulnerability. For instance, a percentile ranking of .75 means that 75percentof counties in the country are LESS vulnerable and only 25percentare more vulnerable. Themost vulnerable disaster impacted counties include Lake, Mendocino, Monterey, Stanislaus, Tulare, Fresno, Los Angeles, Madera, and San Bernardino Counties which are all in th the top 70percentile vulnerability in the country. Tulare, Fresno, and Madera all rankin the top th 90percentile. F IGURE 12:4558S OCIAL V ULNERABILITY I NDEX Overall SoVI® County Percentile Ranking Butte61.4% Lake71.9% Lassen40.4% Mendocino70.2% Monterey73.7% Napa33.3% San Mateo12.3% Santa Clara22.8% Santa Cruz45.6% Solano43.9% Sonoma21.1% Stanislaus86.8% Trinity49.1% Tulare94.7% Yolo67.7% Source: 2018 Center for Disease Control/Agency for Toxic Substances and Disease Registry Social Vulnerability Index 14 and Prevention, October15, 2020), https://www.atsdr.cdc.gov/placeandhealth/svi/fact_sheet/pdf/SVI_FactSheet_v10152020-H.pdf 14 F IGURE 13:4569S OCIAL V ULNERABILITY I NDEX Overall SoVI® County Percentile Ranking Fresno93.0% Los Angeles77.2% Madera91.2% Mendocino70.2% Napa33.3% SanBernardino82.5% San Diego42.1% Shasta47.4% Siskiyou50.9% Sonoma21.1% Source: 2018 Center for Disease Control/Agency for Toxic Substances and Disease Registry Social Vulnerability Index 15 The maps below show the SOVI scores by Census Tract compared with FEMA Verified Losses for both renter-occupied and owner-occupied households with major and severe damage. F IGURE 14:SOVIR ANKING AND FEMAIAM AJOR/S EVERE P ROPERTIES N ORTHERN CA Source: 2018 Center for Disease Control/Agency for Toxic Substances and Disease Registry Social Vulnerability Index, ESRI 16 F IGURE 15:SOVIR ANKING AND FEMAIAM AJOR/S EVERE P ROPERTIES S OUTHERN CA Source: 2018 Center for Disease Control/Agency for Toxic Substances and Disease Registry Social Vulnerability Index, ESRI F.Housing Impact 1.CostBurdened Households HUD describes households that spend more than 30percentof their gross monthly income on housing costs asCost-burdened households usually experiencegreater 15 struggles with other livingcosts like healthcare, food, transportation,andchildcare, and often 15 https://www.hcd.ca.gov/policy-research/specific-policy-areas/housing-transportation.shtml 17 16 lackadequate savings to spend onevacuation, shelter, or recoveryfrom disaster scenarios. Due to financial insecurity, these households are often less able to recover or bounce back quickly after a disaster.Every disaster impacted county population is atleast 43 percent cost burdened. Butte, Monterey, Napa, Santa Cruz, Solano, Sonoma, Stanislaus, Trinity, Tulare, Yolo, Fresno, Los Angeles, Napa, San Bernadino, San Diego, Shasta, and Sonoma County all have populations that are at least 50 percent cost burdened. F IGURE 16:4558C OST B URDENED H OUSEHOLDS Number paying 30 Percent paying 30 CountyHouseholdspercent or more in percent or more in housing costshousing costs Butte34,98919,41455% Lake8,6264,05347% Lassen3,0101,30543% Mendocino13,7976,82449% Monterey 62,25533,09553% Napa17,4298,70850% San Mateo105,00048,62646% Santa Clara279,110124,37345% Santa Cruz38,25721,39156% Solano57,71629,74452% Sonoma72,98137,91352% Stanislaus73,32236,62750% Trinity1,84696052% Tulare59,37230,63152% Yolo35,98118,07850% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 16 Ibid. 18 F IGURE 17:4569C OST BURDEN Number paying 30%Percent paying CountyHouseholdsor more in housing 30%or more in costshousing costs Fresno143,78276,22853% Los Angeles1,797,279985,88455% Madera16,1097,91549% Mendocino13,7976,82449% Napa17,4298,70850% San Bernadino255,760139,72355% San Diego 525,182286,02654% Shasta25,63312,72950% Siskiyou6,7313,15347% Sonoma72,98137,91352% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 2.Persons Experiencing Homelessness Persons experiencing homelessness are especially vulnerable during disasters and require additionalsupportduring disaster recovery. Lack of permanent addresses or limited digital communications accesscan make locating and evacuating unhoused people very difficult,and the trauma of a majordisaster can amplify any existing physical ormental health challenges. Forpeoplealreadystruggling with housing and resource instability, a disaster and subsequent displacementcan be disproportionately destructive. Thetables below illustratea one-night count of unhoused people in each county. These counts measuredthe number ofsheltered and unsheltered persons experiencing homelessness in each of the continuum of care regions, some of which are shared by multiple counties. Some of the counties share the same continuum of care regions and resources. Results of the one-night count ranged from 261 persons (Colusa, Glenn, Trinity Counties CoC0 to 63,706 persons (Los Angeles City and County CoC). F IGURE 18:4558P OINT-I N T IME H OMELESS P OPULATION 2020 Impacted CoC 2020 Homeless Continuum of Care Name CountyNumberCount ButteChico, Paradise/Butte County CoCCA-5191,274 LakeLake County CoCCA-529357 19 Redding/Shasta, Siskiyou, Lassen, Plumas, Del LassenCA-5161,529 Norte, Modoc, Sierra Counties CoC MendocinoMendocino County CoCCA-509751 Monterey Salinas/Monterey, San Benito Counties CoCCA-5062,683 NapaNapa City & County CoCCA-517464 SanMateoDaly City/San Mateo County CoCCA-5121,572 Santa ClaraSan Jose/Santa Clara City & County CoCCA-5009.605 Santa CruzWatsonville/Santa Cruz City & County CoCCA-5082,256 SolanoVallejo/Solano County CoCCA-5181,162 SonomaSanta Rosa, Petaluma/Sonoma County CoCCA-5042,745 StanislausTurlock, Modesto/Stanislaus County CoCCA-5102,107 TrinityColusa, Glenn, Trinity Counties CoCCA-523261 TulareVisalia/Kings, Tulare Counties CoCCA-5131,297 YoloDavis, Woodland/Yolo County CoCCA-521641 Source: HUD 2020 Continuum of Care Homeless Assistance Programs Homeless Populations and Subpopulations Point-in Time County *The 2020 count took place in January 2020. This year was chosen because it counted the unsheltered population while the 2021 counts likely undercounted due to COVID-19 limitation. F IGURE 19:4569P OINT-IN T IME H OMELESS P OPULATION 2020 Impacted CoC 2020 Homeless Continuum of Care Name CountyNumberCount FresnoFresno City & County/Madera County CoCCA-5143,641 Los AngelesLos Angeles City & County CoCCA-60063,706 MaderaFresno City & County/Madera County CoCCA-5143,641 Mendocino*Mendocino County CoCCA-509751 Napa*Napa City & County CoCCA-517464 San San Bernardino City & County CoCCA-6093,125 Bernardino San Diego San Diego City and County CoCCA-6017,638 Redding/Shasta, Siskiyou, Lassen, Plumas, Del ShastaCA-5161,529 Norte, Modoc, Sierra Counties CoC Redding/Shasta, Siskiyou, Lassen, Plumas, Del SiskiyouCA-5161,529 Norte, Modoc, Sierra Counties CoC Sonoma*Santa Rosa, Petaluma/Sonoma County CoCCA-5042,745 20 Source: HUD 2020 Continuum of Care Homeless Assistance Programs Homeless Populations and Subpopulations Point-in TimeCounty *The 2020 count took place in January 2020. This year was chosen because it counted the unsheltered population while the 2021 counts likely undercounted due to COVID-19 limitation. Additional data from the same point-in time count reveals that themajority individuals seeking shelter after disasters in impacted CoCs come fromunhoused populations. F IGURE 20:4558P OINT-I N T IME H OMELESS P OPULATION BY S HELTER S TATUS 2020 Impacted Emergency Transitional Continuum of Care NameUnsheltered CountyShelterHousing ButteChico, Paradise/Butte County CoC280156838 LakeLake County CoC813336 3581481,023 Redding/Shasta, Siskiyou, Lassen, LassenPlumas, Del Norte, Modoc, Sierra Counties CoC MendocinoMendocino County CoC70106575 Salinas/Monterey, San Benito 3972881,998 Monterey Counties CoC NapaNapa City & County CoC12437303 San MateoDaly City/San Mateo County CoC514157901 San Jose/Santa Clara City & County 1,2454387,992 Santa Clara CoC Watsonville/Santa Cruz City & County 4031531,700 Santa Cruz CoC SolanoVallejo/Solano County CoC14585932 Santa Rosa, Petaluma/Sonoma 7383051,702 Sonoma County CoC Turlock, Modesto/Stanislaus County 8032171,087 Stanislaus CoC TrinityColusa, Glenn, Trinity Counties CoC6051150 TulareVisalia/Kings, Tulare Counties CoC205155937 YoloDavis, Woodland/Yolo County CoC20143397 Source: HUD 2020 Continuum of Care Homeless Assistance Programs Homeless Populations and Subpopulations Point-in Time County 21 F IGURE 21:4569P OINT-I N T IME H OMELESS P OPULATION BY S HELTER S TATUS 2020 Impacted Emergency Transitional Continuum of Care NameUnsheltered CountyShelterHousing FresnoFresno City & County/Madera County CoC8151452,681 Los AngelesLos Angeles City & County CoC14,0773,53946,090 MaderaFresno City & County/Madera County CoC8151452,681 MendocinoMendocino County CoC70106575 NapaNapa City & County CoC12437303 San San Bernardino City & County CoC5371982,390 Bernardino San DiegoSan Diego City and County CoC2,3071,3603,971 Redding/Shasta, Siskiyou, Lassen, Plumas, Shasta3581481,023 Del Norte, Modoc, Sierra Counties CoC Redding/Shasta, Siskiyou, Lassen, Plumas, Siskiyou3581481,023 Del Norte, Modoc, Sierra Counties CoC Santa Rosa, Petaluma/Sonoma County Sonoma7383051,702 CoC Source: HUD 2020 Continuum of Care Homeless Assistance Programs Homeless Populations and Subpopulations Point-in Time County Addressing homelessness is an ongoing challenge for communities across California, but the state commits significant state resources for local governments including areas impacted by the 22-23 budget proposes $7.2 billion in 2021-2022 for nearly 17 30 homelessness related programs across state departments.HCD is a key agency in implementing these programs from federally funded programs to newer programs like Project Roomkey ($1.4 billion),designed to rapidly expand housing for persons experiences 18 homelessness who are at high-risk for COVID-19 and other communicable diseases.Other 19 HCD program resources available for persons experiencing homelessness include: Emergency Solutions Grant Program-Grants to address homelessness by providing funding for supportive services, emergency shelter/transitional housing, homelessness prevention assistance, and permanent housing. 17 https://lao.ca.gov/Publications/Report/4521 18 2022, https://homekey.hcd.ca.gov/content/background 19 Programs: Active, Homelessness, https://www.hcd.ca.gov/programs-active 22 HOME American Rescue Plan-Assists individuals or households at risk of, or experiencing homelessness, and other vulnerable populations, by providing housing, rental assistance, supportive services, and non-congregate shelter. Housing for a Healthy California-Funds the creation and support of new and existing permanent supportive housing for people who are experiencing chronic homelessness or are homeless and high-cost health users. Housing Navigators Program-Provides funds to counties for the support of housing navigators to help young adults aged 18 to 21 years secure and maintain housing, with priority given to young adults in the foster care system. Multifamily Housing ProgramState program providing low-interest, long-term deferred-payment loans for new construction, rehabilitation, and preservation of permanent rental housing for lower-income households. No Place Like Home-Funds the development of permanent supportive housing for persons who are in need of mental health services and are experiencing homelessness, chronic homelessness, or at risk of chronic homelessness. Permanent Local Housing Allocation (PLHA)-Grant funding available to eligible local governments in California for housing-related projects and programs that assist in addressing the unmet housing needs of their local communities. PetAssistance and Support (PAS) Program-Grant funds to homeless shelters for pet shelter, food and basic veterinary services for pets owned by individuals experiencing homelessness. Transitional Housing Program-Funds to help young adults 18-24 years secure and maintain housing, with priority given to those formerly in the foster care or probation systems. Veterans Housing and Homelessness Prevention Program-Long-term loans for development or preservation of rental housing for very low-and low-income veterans and their families. While shelter, addressing homelessness, supportive housing, and other efforts remain needs for areas impacted by the 2020 disasters, HCD proposes to utilize its proposed Multifamily to create long-term housing solutions to add units for low-income individuals in disaster impacted areas. The Outreach and Engagement section of this document provides additional detail on consultations with renters and homeowners displaced by the 2020 disasters. 3.Mobile Housing Units Mobile homes are more vulnerable to disasters than permanent residential structuresdue to structural deficiencies and an increasedlikelihood of being in exposed, higher-riskareas.A 2020 case study of mobile home parks in flood-affected communities found that mobile home parks faced unique disaster vulnerabilitiesdue to ahighconcentration socioeconomic instability, 23 stigmatization bylocal governmentand community, and exclusion or disenfranchisement during 20 post disaster recovery due to that stigmatization. The tables below show the mobile home percentage ofthe residential housing stock of each disaster impacted county.Mobile homes account for10 percent or more of the total housing stock in Butte, Lake, Lassen, Trinity, Shasta, and Siskiyou counties and likely reflect a substantial portion ofhomes damaged by the 2020 wildfires. F IGURE 22:4558P ERCENT H OUSING M OBILE H OMES Percent Housing County Units Mobile Homes Butte11.9% Lake22.0% Lassen12.1% Mendocino9.4% Monterey 4.4% Napa6.5% San Mateo1.1% Santa Clara2.9% Santa Cruz5.9% Solano2.6% Sonoma5.0% Stanislaus4.2% Trinity20.7% Tulare6.0% Yolo4.4% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 20 asters: Understanding (American Society of Civil Engineers, January 21, 2020), https://ascelibrary.org/doi/abs/10.1061/(ASCE)NH.1527- 6996.0000357. 24 F IGURE 23:4569P ERCENT H OUSING M OBILE H OMES Percent Housing CountyUnits Mobile Homes Fresno3.5% Los Angeles1.6% Madera5.6% Mendocino9.4% Napa6.5% San Bernadino5.3% San Diego 3.4% Shasta11.1% Siskiyou11.1% Sonoma5.0% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 4.Social and PublicService Programs Disasters exacerbate preexisting conditions in communities, and disproportionately affect vulnerablepopulations.Deaths, injuries, and theloss of property or possessions due to disasterscanmagnify ongoinghealth and mental health issues and createadditional challenges these challenges by identifying vulnerable communities, providing financial and logistical support, and promoting physical and mental wellness in communities throughout California. Social service professionals act as advocates and service providers to underserved populations, andconnectsurvivorswithcritical suppliesand services before, during, and after a disaster. Social services directlymitigatetheimpacts of disasters on vulnerable populations, and help communities recover stronger and faster. The following programs provide these services to impacted communities across California, from the local to state level: Case Management Disaster Case Management is provided by local DCMP agencies throughout the state in the disaster impacted counties. In more rural areas, multiple counties may be served by the same organization. For instance, Northern Valley Catholic Social Services serves Trinity,Lassen, Butte, Shasta, and Siskiyou. In previous disasters, the State was told what a significant effort it desperately need help building capacity. Catholic Charities of California, an organization thatcoordinatesthe Disaster Case Management Program, provided the following table of case management activities and metrics 25 through February 9, 2022. The table shows that while disaster 4558 had more survivors, disaster4569 had a higher caseload. 4558 closed about four times more cases which were majority programmatic. F IGURE 24:C ASE M ANAGEMENT C ASELOADS AND C LOSURES Metric45584569Unassigned Survivors1431907620 Caseload24050670 Waitlist163121189 Referrals Number of Referrals Made26522327 Value$634,747$303,250$34,058 Closures Total Survivors Closed1,027287361 The below tables regarding vulnerabilities of case management clients shows that DR-4558 saw many cases in which people were uninsured/underinsured or dealing with housing insecurity, poverty, or unemployment. DR-4569 saw many cases in which people spoke limited English, were uninsured/underinsured, or dealing with unemployment or emotional distress. Disaster DR-4569 had many more clients who spoke limited English (eighteen percent) than disaster 4558 (one percent). F IGURE 25:DR-4558C ASE M ANAGEMENT V ULNERABILITIES VulnerabilitiesNumberPercent Uninsured/Underinsured39027% Housing Insecurity30421% Poverty20414% Unemployment20314% Urgent Basic Needs18613% Elderly 65+16712% Emotional Distress16311% Disabled15111% Isolated1128% Functional Needs (AFN)1047% SingleHead of Household604% Safety Risk554% Limited Info. Access514% Immediate Medical Needs373% 26 Limited Transportation322% Minor Child (w/o adult)161% Limited Literacy161% Limited English161% F IGURE 26:DR-4569C ASE M ANAGEMENT V ULNERABILITIES VulnerabilitiesNumberPercent Limited English16018% Uninsured/Underinsured14716% Unemployment14616% Emotional Distress14516% Elderly 65+12113% Housing Insecurity10512% Poverty10111% Limited Literacy839% Urgent Basic Needs718% Single Head of Household546% Disabled485% Immediate Medical Needs384% Functional Needs (AFN)293% Isolated243% Safety Risk162% Minor Child (w/o adult)30% Limited Transportation30% Limited Info. Access30% When asked about housing goals, residents in both disasters overwhelmingly wanted to stay in the county in comparison to other answer choices, with more than 30 percent wanting to remain in the county and only about 2 or 3 percent wanting to leave. F IGURE 27:C ASE M ANAGEMENT H OUSING G OALS DR-4558DR-4558DR-4569DR-4569 Ultimate Housing GoalNumberPercentNumberPercent Stay in County50535%38843% Stay, Renter19614%20322% Stay, Owner28320%16718% Stay, Undecided121%101% 27 Stay, Other141%81% Leave county493%182% Leave, Renter262%142% Leave, Owner151%30% Leave, Undecided50%10% Leave, Other30%00% Unknown413%526% Data about needs reveals that the highest needs for DR-4558 were household needs, repair/rebuild, advocacy, and food/nutrition. For DR-4569, the top needs were utilities, household needs, food/nutrition, and repair/rebuild. For both disaster, the lowest ranked needs included domestic animal services, funeral assistance, and missing person assistance. F IGURE 28:DR-4558C ASE M ANAGEMENT N EEDS NeedsNumberPercent Household Needs28420% Repair/Rebuild27419% Advocacy22216% Food/Nutrition20314% Clothing14310% Utilities14310% Emotional/Spiritual Care1148% Employment Assistance947% Functional Needs (AFN)745% Transportation715% Removal of Debris634% Legal Assistance403% Medical Assistance383% Education/Job Training352% Domestic Animal Services292% Children's Services222% Medical Insurance171% Funeral Assistance00% Missing Person Assistance00% 28 F IGURE 29:DR-4569C ASE M ANAGEMENT N EEDS NeedsNumberPercent Utilities15217% Household Needs12914% Food/Nutrition10512% Repair/Rebuild10211% Clothing9010% Employment Assistance526% Advocacy273% Emotional/Spiritual Care273% Children's Services233% Medical Assistance212% Removal of Debris202% Transportation152% Legal Assistance142% Medical Insurance131% Education/Job Training101% Functional Needs (AFN)101% Domestic Animal Services51% Funeral Assistance10% Missing Person Assistance00% California HOPE Program TheCalifornia HOPE program was launched after the 2017 wildfires to provide mental health support to survivors of disasters.HOPE is funded by FEMA and is administered by the California State Mental Health Authority (CMHA). California HOPE counselors work withto processimmediate trauma and loss, prioritize needs and solve problems, developcoping strategies, and connect with peopleand agencies for continued support. Disaster CalFresh Disaster CalFresh is the statewide Supplemental Nutrition Assistance Program (SNAP) that provides monthly food benefits for low-income Californians. Disaster CalFresh (D-CalFreshor D-SNAP) is activatedto meet the temporary nutritional needs of disaster survivorswithin the first 30-daysaftera Presidential Declaration for Individual Assistance has been declared, 29 commercial food distribution has been disrupted, and the State of California has approvedD- CalFresh operation. The table below shows that 294 households were served in the disaster impacted counties totaling $144,493 in operations. This was done in four waves in nearly every county except Lassen, San Mateo, Stanislaus, Trinity, Tulare, and Yolo. F IGURE 30:D-SNAPA PPLICANTS FOR DR-4558&DR-4569 Number of Total D- Disaster CalFresh Impacted Approval WaveHouseholds CalFresh CountiesDate ServedIssuances Lake, Monterey, San Mateo, One29-Sep-2071$32,716 Santa Cruz, Solano, and Yolo TwoButte, Napa and Sonoma29-Sep-2050$22,339 ThreeSanta Clara9-Oct-208$3,345 Fresno, Los Angeles, Madera, Mendocino, Napa, San Four5-Nov-20165$86,093 Bernardino, San Diego, Shasta, Siskiyou, and Sonoma D-CalFresh 294$144,493 Totals 5.Insurance While standard homeownersinsurance does cover losses from a wildfire, many policies do not provide enough funding to replace the entire home. Additionally, high rates of underinsured property owners put increasing strain on disaster recovery and rebuilding needs. Often the costs between meeting updated building codes can further exacerbate the gap between residential claim payout and the actual cost to rebuild. There may be a shortfall in insurance funds needs to rebuild homes, especially to a more resilient standard. The state enacted two laws to help insured victims of wildfire. AB 1799 (Chapter 69, Statues 2018) requires that insurance companies provide standardized information to wildfire victims after they have suffered a loss, including information on the coverage they have paid for, their full insurance policy, endorsements, and their declaration page to better inform wildfire victims. The second, AB 1797 (Chapter 205, Statues 2018), requires that insurers writing residential property insurance conduct a replacement cost estimate on an every-other year basis. This would ensure policy holders are covered with current and timely estimates that accurately reflect s overseeing insurance companies, performing financial reviews and examining insurers doing business in California. CDI enforces insurance laws and has authority over how insurers and licensees conduct business in California. i.DR-4558 and DR-4569 Residential Insurance Claims 30 Followingthe DR-4558 and DR-4569 disasters, 31,121 residential claims were filed. The number of claims fortotal losses was 2,986 claims and thesum of losses incurred was about $3.7 billion. F IGURE 31:R ESIDENTIAL I NSURANCE C LAIMS FOR DR-4558&DR-4569 Sum of Number of Sum of Number of CountyClaims Resulting in Sum of Losses Incurred ² Claims Total Loss Butte1,151511$ 275,660,707 Fresno3,245339$ 251,172,676 Humboldt4619$ 6,729,989 Lake4764$ 5,342,411 Lassen5013$ 6,261,300 Los Angeles8,13767$ 166,775,590 Madera31015$ 9,277,708 Mendocino80-$ 929,505 Monterey55850$ 66,522,434 Napa2,240393$ 785,190,738 San Bernardino1,3655$ 23,125,567 San Diego13514$ 13,663,593 San Mateo1488$ 9,046,897 Santa Barbara4-$ 31,385 Santa Clara12913$ 10,757,201 Santa Cruz5,631702$ 896,012,754 Shasta15651$ 38,345,165 Siskiyou10668$ 28,020,265 Solano2,134221$ 393,511,936 Sonoma4,533312$ 630,433,075 Stanislaus80-$ 1,304,992 Trinity7340$ 15,841,973 Tulare272123$ 49,404,606 Yolo6218$ 25,182,440 StatewideTotal31,1212,986$ 3,708,544,907 31 G.Impact on Vulnerable Populations 1.Race Race is a protected class under the Fair Housing Act. As such, HCD assesses all programs to evaluate the equity and impact on protected classes. Disaster impacts vulnerable populations disproportionatelymunity isolation and 21 cultural insensitivity. FEMA than their Black neighbors. The reportfound that white residents of counties with significant disaster damage that received FEMA assistance had their wealth increase years later (five times as much, on average, as white residents who had not experienced FEMA 22 assistance) while Black residents maintainedless wealth in the same time period. The tables belowshow the racial demographics of each disaster impacted county: F IGURE 32D EMOGRAPHICS BY R ACE FOR DR-4558C OUNTIES Native American Hawaiian Black or Indian Some andPopulation WhiteAfrican andAsian Other CountyOtherof two or alonealone AmericanAlaska Race Pacific more races aloneNative alone Islander alone alone Butte139,6513,3203,05010,3335081,18413,474 Lake44,2021,1581,737940893864,209 Lassen19,5342,2449394722831421,585 Mendocino56,2056073,5281,7301105924,896 Monterey 120,0779,0511,31425,1231,8592,17014,120 Napa68,9092,30050710,5203169105,728 San Mateo275,90214,7011,021227,7838,8405,84038,969 Santa Clara555,70842,1483,240753,3995,94510,19578,267 Santa Cruz145,5512,85085312,0722771,64913,310 Solano155,12560,0511,62470,9533,7752,98830,820 21 Fothergill, Maestas, and Disastersvol. 23,2 (1999): 156-73. doi:10.1111/1467-7717.00111 22 ne 7, 2021, https://www.nytimes.com/2021/06/07/climate/FEMA-race-climate.html. 32 Sonoma285,7927,1253,05322,2391,7082,90924,599 Stanislaus207,90814,3022,62133,1693,7132,73422,453 Trinity11,374664162,21224106977 Tulare125,0225,3323,45815,9975112,13210,770 Yolo93,9115,72294829,8721,0791,27811,893 Source: U.S. Census Bureau, 2020 DEC F IGURE 33:D EMOGRAPHICS BY R ACE FOR DR-4569C OUNTIES Native American Hawaiia Black or Indian SomePopulatio n and WhiteAfrican andAsian Othern of two CountyOther alonealone AmericaAlaska Race or more Pacific n aloneNative aloneraces Islander alone alone Fresno271,88944,2956,074109,6651,2335,20929,546 Los Angeles2,563,609760,68918,4531,474,23720,52258,683313,053 Madera48,3994,1311,7383,5811227234,383 Mendocino56,2056073,5281,7301105924,896 Napa68,9092,30050710,5203169105,728 San 566,113173,3228,412176,2046,17312,11768,400 Bernadino San Diego1,422,205145,01412,841400,58912,99118,125167,240 Shasta136,8941,7614,0475,8393231,03712,524 Siskiyou32,0574711,757866382653,095 Sonoma285,7927,1253,05322,2391,7082,90924,599 Source: U.S. Census Bureau, 2020 DEC 33 F IGURE 34:P ERCENT B LACK OR A FRICAN A MERICAN P OPULATION M AP N ORTHERN CA Source: U.S. Census Bureau, 2015 -2019 American Community Survey, 5-Year Estimates 34 F IGURE 35:P ERCENT B LACK OR A FRICAN A MERICAN P OPULATION M AP S OUTHERN CA Source: U.S. Census Bureau, 2015 -2019 American Community Survey, 5-Year Estimates 2.Ethnicity A 2020research studyposits that Hispanic or Latino communities need special consideration in disaster planning processes and recovery in order to achieve equitable outcomes. The study found that vulnerable people were often not included in the planning process and suffered from 23 Examples include emergency information that is not available in Spanish, significant lack of insurancecoverage availableoraffordable to immigrants. California has a large population of undocumented Latino/a and Indigenous immigrants, last estimated at 2.6 million residents. The study also 23 of undocumented Geoforum; journal of physical, human, and regional geosciencesvol. 116 (2020): 50-62. doi:10.1016/j.geoforum.2020.07.007 35 found that immigrants may be afraid to seek assistanceafter disasters due to fears of detention 24 and deportation. Thefollowingtables showthesize and percentage ofHispanic communitiesin disaster impacted counties. The majority of impactedcounties have Hispanic or Latino populations that make upat least 20 percent of the total countypopulation. In Monterey,Tulare, Fresno, Madera, and San Bernadino, the majority of the population is Hispanic or Latino. F IGURE 36:P ERCENT H ISPANIC OR L ATINO P OPULATIONFOR DR-4558C OUNTIES CountyTotal PopulationHispanic or LatinoPercent Hispanic Butte211,63240,11219.0% Lake68,16315,44222.7% Lassen32,7307,53123.0% Mendocino91,60123,93326.1% Monterey 439,035265,32160.4% Napa138,01948,82935.4% San Mateo764,442191,38625.0% Santa Clara1,936,259487,35725.2% Santa Cruz270,86194,29934.8% Solano453,491128,15528.3% Sonoma488,863141,43828.9% Stanislaus552,878265,97848.1% Trinity16,1129375.8% Tulare473,117309,89565.5% Yolo216,40371,70033.1% Source: U.S. Census Bureau, 2020 DEC 24 Ibid. 36 F IGURE 37:P ERCENT H ISPANIC OR L ATINO P OPULATIONFOR DR-4569C OUNTIES CountyTotal PopulationHispanic or LatinoPercent Hispanic Fresno1,008,654540,74353.6% Los Angeles10,014,0094,804,76348.0% Madera156,25593,17859.6% Mendocino91,60123,93326.1% Napa138,01948,82935.4% San Bernadino2,181,6541,170,91353.7% San Diego 3,298,6341,119,62933.9% Shasta182,15519,73010.8% Siskiyou44,0765,52712.5% Sonoma488,863141,43828.9% Source: U.S. Census Bureau, 2020 DEC F IGURE 38:P ERCENT H ISPANIC OR L ATINO P OPULATION N ORTHERN CA Source: U.S. Census Bureau, 2015 -2019 American Community Survey, 5-Year Estimates 37 F IGURE 39:P ERCENT H ISPANIC OR L ATINO P OPULATION S OUTHERN CA Source: U.S. Census Bureau, 2015 -2019 American Community Survey, 5-Year Estimates 3.Households with Children The CDC Social Vulnerability Index uses household composition with dependent children under 18 25 disaster events.Children specifically lack the resources to cope with and effectively recover from disasters without adult help. At the same time, children are rarely incorporated into disaster planning exercises, although they are the most likely to sufferPTSD and lingering mental health effects from disasters. Furthermore, households with children under 18 are more likely to 25 Centers for Disease Control and Prevention, 38 require assistance with finances, transportation, medical care, and childcare during the disaster 26 event and recovery. The tables below illustrate the percent of households with children in all disaster impacted counties. Trinity has the smallest number of households with children,at 17.9 percent,while in Fresno, Madera, and Tulare counties, at least 40 percent of householdsinclude children. F IGURE 40:4558H OUSEHOLDS WITH C HILDREN Households with one or more CountyTotal households people under 18 years Butte85,32026.7% Lake25,66026.2% Lassen9,28025.7% Mendocino34,40827.3% Monterey 127,15538.9% Napa48,70531.6% San Mateo263,54332.9% Santa Clara640,21536.3% Santa Cruz95,81829.1% Solano149,86534.9% Sonoma189,37428.3% Trinity5,93917.9% Tulare138,23845.8% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 26 no. 1 (2011). https://doi.org/10.2202/1547-7355.1792. 39 F IGURE 41:4569H OUSEHOLDS WITH C HILDREN Households with one or more CountyTotal households people under 18 years Fresno307,90640.8% Los Angeles3,316,79533.0% Madera44,88143.3% Mendocino34,40827.3% Napa48,70531.6% San Bernadino636,04141.9% San Diego 1,125,28633.1% Shasta71,18128.2% Siskiyou19,24023.0% Sonoma189,37428.3% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 4.Population with Disabilities People with disabilities are disproportionately impacted by disasters,as disruptions in support systemsandmedical careexacerbate challenges people reckon with as part of regular life.Due to impaired or limited physical or cognitive abilities, individuals may be unable to evacuate safely or easily, create or maintain a preparedness plan, advocate fully for their needs, or seek out necessary care while displaced. After disasters, people with disabilities face significant barriers in finding and securing appropriate housing, transportation, employment, physical and 27 mental healthservices,and other supports critical to long-term recovery. The American Community Survey measures six disability types: Hearing Difficulty, deaf or having serious difficulty hearing. Vision difficulty, blind or having serious difficulty seeing, even when wearing glasses. Cognitive Difficulty because of a physical, mental, or emotional problem, having difficulty remembering, concentrating, or making decisions. Ambulatory Difficulty, having serious difficulty walking or climbing stairs. Self-care difficulty, having difficulty bathing or dressing. 27 Stough, L.M., Sharp, A.N., Resch, J.A., Decker, C. and Wilker, N. (2016), Barriers to the long-term recovery of individuals with disabilities following a disaster. Disasters, 40: 387-410.https://doi.org/10.1111/disa.12161 40 Independent living difficulty, because of a physical, mental, or emotional 28 office or shopping. Thefollowing tables show the percent and number of the population with a disability in each disaster impacted county. Lake, Lassen, Trinity, Shasta, and Siskiyou counties have the highest percent population with a disability,each with a population of more than 18 percent. All CDBG-DR programs have an obligation to comply with relevant federal laws that prohibit discrimination on the basis of disability and torequire physical accessibility and the provision/allowance of reasonable accommodations and reasonable modifications, including the federal Fair Housing Act, Section 504 of the Rehabilitation Act of 1973, and the Americans with Disabilities Act. F IGURE 42:4558P OPULATION W ITH A D ISABILITY Percent with CountyTotal PopulationWith Disability Disability Butte223,22938,36917.2% Lake63,49412,69320.0% Lassen21,1903,90218.4% Mendocino86,35214,72317.0% Monterey 417,24936,9108.8% Napa137,80616,24411.8% San Mateo763,66562,8148.2% Santa Clara1,917,643154,2128.0% Santa Cruz272,49132,57212.0% Solano429,48352,64212.3% Sonoma495,51658,94011.9% Stanislaus540,18171,01113.1% Trinity12,5292,62120.9% Tulare457,85755,43212.1% Yolo215,93820,6499.6% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 28 https://www.census.gov/topics/health/disability/guidance/data-collection-acs.html. 41 F IGURE 43:4569P OPULATION WITH A D ISABILITY Percent with CountyTotal PopulationWith Disability Disability Fresno973,266128,01513.2% Los Angeles10,012,895992,7199.9% Madera147,25319,14813.0% Mendocino86,35214,72317.0% Napa137,80616,24411.8% San Bernadino2,099,054230,64411.0% San Diego 3,216,326317,9249.9% Shasta177,76132,48218.3% Siskiyou43,3568,06818.6% Sonoma495,51658,94011.9% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates F IGURE 44:P ERSONS WITH D ISABILITY M AP N ORTHERN CA Source: U.S. Census Bureau, 2015 -2019 American Community Survey, 5-Year Estimates 42 F IGURE 45:P ERSONS W ITH D ISABILITIES M AP S OUTHERN CA Source: U.S. Census Bureau, 2015 -2019 American Community Survey, 5-Year Estimates 5.Population65 and Older Senior households face special challenges and are disproportionately affected bydisasters. Challenges for seniorsmay include owner-occupied households non-existent or inadequate insurance (due to a lack of resources, or becausethe mortgage has beenpaidoff),individuals unable to accessmedication or carewhen medical systems are disrupted,ormobility or cognitive impairments that hinder safe evacuations,issues while may limit ability to evacuate. Thefollowing table shows the percentage of population over 65 in disasterimpacted counties. Mendocino, Trinity, Shasta and Siskiyou counties each have elderly populationsthat make up more than 20 percent of the county population. 43 F IGURE 46:4558E LDERLY POPULATION Percent 65 and CountyTotal PopulationSum of 65 and older older Butte223,34440,66318.2% Lake64,27614,68522.8% Lassen30,6004,42114.4% Mendocino87,11019,23422.1% Monterey 432,97759,06113.6% Napa138,57226,61019.2% San Mateo765,623123,81716.2% Santa Clara1,924,379259,98813.5% Santa Cruz273,17044,91316.4% Solano444,53869,96815.7% Sonoma496,80197,46119.6% Stanislaus540,18171,01113.1% Trinity12,5413,50728.0% Tulare463,95552,82611.4% Yolo215,93820,6499.6% Source: U.S. Census Bureau, 2016 -2020 American Community Survey, 5-Year Estimates F IGURE 47:4569E LDERLY P OPULATION Percent 65 and CountyTotal PopulationSum of 65 and older older Fresno990,204121,12912.2% Los Angeles10,040,6821,370,14113.6% Madera155,92521,85814.0% Mendocino*87,11019,23422.1% Napa*138,57226,61019.2% San Bernadino2,162,532250,03211.6% San Diego 3,323,970467,73714.1% Shasta179,26736,92320.6% Siskiyou43,51610,98325.2% 44 Sonoma*496,80197,46119.6% Source: U.S. Census Bureau, 2016 -2020 American Community Survey, 5-Year Estimates F IGURE 48:E LDERLY P OPULATION M AP N ORTHERN CA Source: U.S. Census Bureau, 2015 -2019 American Community Survey, 5-Year Estimates 45 F IGURE 49:E LDERLY P OPULATION M AP S OUTHERN CA Source: U.S. Census Bureau, 2015 -2019 American Community Survey, 5-Year Estimates 6.Population with LimitedEnglish Proficiency The Civil Rights Act of 1964 prohibits discrimination on the basisof national origin andrequires that government entitiesensure thatpersons with Limited English Proficiency (LEP) have access to the same benefits, services, and information as English-speakingresidents. As such, disaster preparedness and recovery must consider and plan forthose who need translators and translated materials. The tables below show the total and percent Limited English Proficiency populations in all disaster impacted counties. Monterey, Tulare, Fresno, Los Angeles, and Madera all have a percent population of people who speak English that is well over 10 percent of the population. 46 F IGURE 50:4558P OPULATION WITH L IMITED E NGLISH P ROFICIENCY Percent of people Total population People who speak Countywho speak English over 5less than well less than well Butte211,1945,6152.7% Lake60,5621,7062.8% Lassen29,2226752.3% Mendocino82,1053,8104.6% Monterey 402,24568,60717.1% Napa131,7309,6127.3% San Mateo722,53549,9336.9% Santa Clara1,810,821158,7118.8% Santa Cruz259,50917,4436.7% Solano417,77419,9404.8% Sonoma472,31925,7005.4% Stanislaus507,01846,0839.1% Trinity11,947890.7% Tulare427,01357,31913.4% Yolo206,71312,4336.0% Source: U.S. Census Bureau, 2016-2020 American Community Survey, 5-Year Estimates F IGURE 51:4569P OPULATION WITH L IMITED E NGLISH P ROFICIENCY Percent of people Total population People who speak County who speak English over 5less than well less than well Fresno913,84099,82310.9% Los Angeles9,447,6211,215,44212.9% Madera144,54118,28712.7% Mendocino*82,1053,8104.6% Napa*131,7309,6127.3% San Bernadino2,009,812153,8127.7% San Diego 3,118,216200,3246.4% Shasta168,8251,7471.0% 47 Siskiyou41,2846031.5% Sonoma*472,31925,7005.4% Source: U.S. Census Bureau, 2016-2020 American Community Survey, 5-Year Estimate Languages Spoken bythose with Limited English Proficiency The tables below show the languages spoken bypersons over the age of fivewho speak . Because disaster preparedness and recovery must includethe need for translators and translated materials, it is important to assess whichlanguages are commonly- spoken in impacted areas.In every disaster impacted county, the majority of non-English speakers speak Spanish. A few of the larger counties also includea significant number of Indo- European and Asian or Pacific Island speakers as well. F IGURE 52:4558L ANGUAGES S POKEN FOR T HOSE WHO S PEAK E NGLISH ESS T HAN W ELL Speaks Speaks Speaks Asian Speaks Indo-Speaks Speaks Asian or orSpeaks Speaks Indo-EuropeaOther SpanisPacific Pacific Other County SpanishEuropean nLanguag hIsland Island Language LanguageLanguage LanguageLangua e ge PercentPercent NumberNumberPercent*NumberNumberPercent* ** Butte3,5071.7%3350.2%1,7070.8%660.0% Lake1,5422.5%990.2%650.1%-0.0% Lassen5902.0%310.1%540.2%-0.0% Mendocin 3,6644.5%560.1%890.1%10.0% o Monterey65,21416.2%5690.1%2,1870.5%6370.2% Napa8,7366.6%2550.2%5840.4%370.0% San Mateo25,5143.5%3,8690.5%19,9542.8%5960.1% Santa 61,2633.4%10,6930.6%84,9094.7%1,8460.1% Clara Santa 16,3566.3%2690.1%7490.3%690.0% Cruz Solano13,0643.1%9700.2%5,7801.4%1260.0% Sonoma22,3854.7%6990.1%2,5300.5%860.0% Stanislaus37,5897.4%3,4650.7%2,6820.5%2,3470.5% Trinity680.6%-0.0%210.2%-0.0% 48 Tulare54,12812.7%6370.1%2,1640.5%3900.1% Yolo8,7874.3%1,7640.9%1,7780.9%1040.1% Source: U.S. Census Bureau, 2016-2020 American Community Survey, 5-Year Estimate, *percent of population over language F IGURE 53:4569L ANGUAGES S POKEN FOR T HOSE WHO S PEAK E NGLISH ESS THAN W ELL SpeaksSpeaks SpeaksSpeaks Asian or Asian or SpeaksSpeaks SpeaksSpeaksIndo-Indo- CountyPacific Pacific OtherOther SpanishSpanishEuropeanEuropean Island Island LanguageLanguage LanguageLanguage LanguageLanguage NumberPercent*NumberPercent*NumberPercent*NumberPercent* Fresno 81,2628.9%5,4310.6%11,0321.2%2,0980.2% Los 870,6539.2%79,7700.8%254,2082.7%10,8110.1% Angeles Madera 17,44112.1%3580.2%2450.2%2430.2% Mendocino 3,6644.5%560.1%890.1%10.0% Napa 8,7366.6%2550.2%5840.4%370.0% San 126,8226.3%2,5250.1%21,8751.1%2,5900.1% Bernardino San Diego 139,2324.5%7,8290.3%41,3281.3%11,9350.4% Shasta 7330.4%3230.2%6600.4%310.0% Siskiyou 4511.1%190.0%1330.3%-0.0% Sonoma 22,3854.7%6990.1%2,5300.5%860.0% Source: U.S. Census Bureau, 2016-2020 American Community Survey, 5-Year Estimate, *percent of population over H.Analysis of Housing Unmet Need 1.Overview of Data Sources Both DR-4558 and DR-4569 led to significant impacts onhousingin impacted areas. The geographic spread of the disasters across the State of California also presents challenges for identifyingconsistent data to understand housing unmet needs. This section examines the data available to understand impacts to housing across the disaster area. Fire Protection (CAL FIRE) Damage Inspection, the Census and American Community Survey, Continuum of Care Point-in-Time Counts, Centers for Disease Control social vulnerability data, 49 Housing and Urban Development (HUD)income data,and insurance claim information provided by the California Department of Insurance(CDI). 2.Limitations of Data This section presents an analysis of FEMA IA, SBA, CAL FIRE and CDIdata to reflect damage caused by DR-4558 and DR-4569 and to demonstrate the ongoing unmet recovery needs of residents impacted by the disasters. Ultimately, no one data source accurately captures the population impacted by DR-4558 and DR-4569. This Action Plan and unmet needs analysis captures a point in time and reflects the best available data at the time of its publication. In addition to using the process outlined for understanding housing unmet needs provided by This alternative methodology continues to rely on verified inspections of properties, and more automatically excludes LMI households due to presence of insurance. This FEMA policy results data. This number represent nearly double what FEMA has included in its data set for DR 4558 and 4569 combined (1,573). FEMA Individual Assistance (IA)The Federal Emergency Management Agency (FEMA) Individual Assistance Program is the primary basis for establishing housing unmet recovery need for CDBG-DR grantees.Residents register voluntarily for FEMA IA, and eligible applicants include both renters and owners. FEMA Verified Loss awards only provide assistance for repair and replacement to make the home habitable. As the data limitations above note, residents must register with FEMA for assistance, which leaves a gap between the true disaster impacts and the households that register for assistance.Whilethe FEMA-IA datasetalone doesnot represent the full scale of the disaster impacts, data available at the household level, including income and damage, allows for an analysis that follows the unmet needs calculation outlined in the Federal Register Notice. Small Business AdministrationSimilar to FEMA IA, the SBA disaster loan program is a voluntary program available to impacted households. As a loan program, SBA residential loan registrations skew towards homeowners. However, compared to FVL inspections, which only cover the cost for repair and replacement, SBA loan amounts are based on an inspection that covers the full cost to restore a home. CAL FIRE Damage InspectionAs the state fire agency, CAL FIRE deploys inspectors after all disasters within the State of California. Using ArcGIS, inspectors use parcel maps to document damage by property. The damage inspection includes parcel, address, structure type, construction type, damage categories, and vegetation clearance information for all impacted properties. This parcel-by-parcel survey includes commercial, mobile home, outbuildings and detached structures, and residential structures. For purposes of this analysis, HCD limited the CAL FIRE data to residential structures, including Single Family, Multifamily, and Mobile Home structures. This parcel level assessment provides a more robust picture of structural damage but not include damage estimate amounts or information on the household resident. California Department of Insurance Claims(CDI)While floods and hurricanes can rely on National Flood Insurance Program data, fire damage must be collected from 50 individual insurance companies. HCD requested address level insurance claim information for disaster impacted households through the CDI, but household level information on claims was not available. However, the CA Department of Insurance collected information from individual insurance companies on claims by zip code. As better data becomes available, HCD will provide an updated estimate of claims by household. This data covers a large period of time and does not guarantee that claims are disaster related. American CommunitySurvey2019 (ACS-5 Year) and Decennial Census (DEC 2020)The American Community Survey(ACS)isongoing andupdatedannually, and isbased on a sample of United States residents(3.5 million) in the 50 states. The ACS asks more comprehensive questions than the ten- mic development, census, on the other hand, is conducted every ten years and counts every person living in the United States. The census asks a shorter set of questions concerning age, sex, race, Hispanic origin, and owner/renter status. The goal of the 29 others use to provide daily services, products, and support for.Both the ACS and DEC data are displayedat a county level in this report and therefore, may aggregate the data in a way that obscures important details.For example, poverty rate may be low at a County-levelbutconcentrated in just a few zip codes which may be more vulnerable. Center for Disease Control/ Agency for Toxic Substances and Disease Registry Social Vulnerability DataThe CDC/ATSDR Social Vulnerability Index was created as a geographic database to help emergency response planners and public health officials identify and map communities to prepare and respond to disaster events. The index ranks each census tract in the United States (and aggregates into the county level) on 15 social factors, including socioeconomic status below poverty, unemployment rate, income, no high school diploma, household composition and disability age 65 or older, age 17 or younger, civilian with a disability, single parent households, minority status and language transportation multi-unit structures, mobile homes, crowding, no vehicle, group 30 quarters. The benefit of this data is that it provides an aggregate score to better understand holistic vulnerabilitiescompared to similar geographies around the United States. The limitation of this data is that it was last updated in 2018 and therefore, may be outdated. Homeless Point-In-Time CountThe Point-In-Time (PIT) Count isan annual count conducted by every Continuum of Care(CoC)in the country over the course of asingle night in January. It counts the number of people housed in emergency shelter, transitional housing, Safe Havens, and the number of peoplewho are unsheltered. 29 2021, https://www.census.gov/content/dam/Census/library/publications/2021/acs/acs_pums_handbook_2021.pdf. 30 51 Because the count only takes place on oneday, it is a static count and may not reflect annual numbers. Because point-in-time counts include the number of people sleeping outside and in shelters, they often undercount-people experiencing homelessness who are sleeping in motels, 31 etc. This count often underestimates children and families experiencing homelessness. Low-andModerate-IncomeDataThis data is available on HUDExchange at the block group, census tract,and county level.The limitation of this data is that the LMI calculations come from the 2011-2015 ACS data and may be outdated.Percent LMI is used to determine if programs meet national objectives for Community Development Block Grant funding. According to the description of the LMI data provided, the statistical information used in the calculation of estimates identified in the data sets comes from two sources: 1) the 2011-2015 American Community Survey (ACS), and 2) the Income Limits for Metropolitan Areas and for Non-MetropolitanCounties. The data necessary to determine an LMI percentage for an area is not published in the publicly availableACS data tables. Therefore, the Bureau of Census matches family size, income, and the 32 income limits in a special tabulation to produce the estimates. Housing and Urban Development (HUD)IncomeLimit Data-This data is available on HUD Exchange at the block group, census tract, and county level.The HUD limits calculate thevery low (50%) income limit, extremely low-incomelimits, and low (80%) income limits for 1 person to 8 person families for every county and state in the United States. The limits are recalculated annuallyto determine eligibility for public housing, 33 section 8 vouchers, and disabilities and elderly programs. 3.FEMA Individual Assistance The Federal Emergency Management Agency (FEMA) Individual Assistance Program is the primary basis for establishing housing unmet recovery need for CDBG-DR grantees. However, as the data limitations above note, residents must voluntarily registerwith FEMA for assistance, which leaves a gap between the true disaster impacts and the households that register for assistance. Despite these limitations, the following section provides an overview of the housing impacts for FEMA Disasters 4558 and 4569. Across both disasters, a total of 42,010 households registered for FEMA IA assistance, including 21,284 owner-occupied households and 20,626 renter households. The 2020 FRN outlines the following the damage categories by owner-occupied and rental units: o FEMA Inspected Owner Units o Minor-Low:Less than $3,000 of FEMAinspected real property damage. 31 Agans, Robert P., Jefferson, Malcolm T., Bowling, James M., Zeng, Donglin, Yang, Jenny and Silverbush, Mark. "Enumerating the Hidden Homeless: Strategies to Estimate the Homeless Gone Missing From a Point-in-Time Count" Journal of Official Statistics, vol.30, no.2, 2014, pp.215-229.https://doi.org/10.2478/jos-2014-0014 32 -Year 2011-2015 Low-and Moderate- Housing and Urban Development, n.d.),https://www.hudexchange.info/programs/acs-low-mod-summary-data/. 33 https://www.huduser.gov/portal/datasets/il.html#2021_query. 52 o Minor-High:$3,000 to $7,999 of FEMAinspected real property damage. o Major-Low:$8,000 to $14,999 of FEMAinspected real property damage and/or 1 to3.9 feet of flooding on the first floor. o Major-High:$15,000 to $28,800 of FEMAinspected real property damage and/or 4 to5.9 feet of flooding on the first floor. o Severe:Greater than $28,800 of FEMAinspected real property damage or determined destroyed and/or 6 or more feet of flooding on the first floor. o FEMA Inspected Owner Units Personal Property o Minor-Low:Less than $2,500 of FEMAinspected personal property damage. o Minor-High:$2,500 to $3,499 of FEMAinspected personal property damage. o Major-Low:$3,500 to $4,999 of FEMAinspected personal property damage or 1 to3.9 feet of flooding on the first floor. o Major-High:$5,000 to $9,000 of FEMAinspected personal property damage or 4 to5.9 feet of flooding on the first floor. o Severe:Greater than $9,000 of FEMAinspected personal property damage or determined destroyed and/or 6or more feetof flooding on the first floor. o FEMA Inspected Rental Units o Minor-Low:Less than $1,000 of FEMAinspected personal property damage. o Minor-High:$1,000 to $1,999 of FEMAinspected personal property damage or o Major-Low:$2,000 to $3,499 of FEMAinspected personal property damage or 1 to3.9 feet of flooding on the first floor or determinatio FEMA inspector. o Major-High:$3,500 to $7,500 of FEMAinspected personal property damage or 4 to5.9 feet of flooding on the first floor. o Severe:Greater than $7,500 of FEMAinspected personal property damage or determined destroyed and/or 6 or more feetof flooding on the first floor or determination The following table provides a breakdown by disaster and by tenure of FEMA IA applicants. F IGURE 54:T OTAL FEMAIAR EGISTRATIONS BY D ISASTER Grand DisasterOwnersRenters Total 455814,68914,94429,633 45696,6955,68212,377 Total21,38420,62642,010 Source: FEMA, November 2021 FEMA DR-4558 and 4569 impacted large portions of the State of California and the FEMA IA registrations by County below show how impacts varied across the State. For DR-4558, Santa Cruz, Butte, Sonoma, and Napa Counties had the highest total FEMA IA registrants, and the registrants for both renters and owners were nearly equal. For DR-4569, Los Angeles and San Diego Counties had the highest number of FEMA IA registrations, reflecting the impacts but also higher population centers than many of the other impacted Counties. 53 F IGURE 55:T OTAL FEMAIAR EGISTRATIONS F OR 4558A ND 4569 CountyOwnerRenterTotal 4558 Butte (County)1,6551,4593,114 Lake (County)276399675 Lassen (County)413374 Mendocino (County)423375 Monterey (County)469521990 Napa (County)1,2141,2292,443 Nevada (County)151631 San Mateo (County)1,0148561,870 Santa Clara (County)1,0749662,040 Santa Cruz (County)3,1363,1426,278 Solano (County)7166941,410 Sonoma(County)1,2441,4252,669 Stanislaus (County)4859107 Trinity (County)11035145 Tulare (County)186127313 Yolo (County)231216447 4569 Fresno (County)7364531,189 Los Angeles (County)1,7091,6643,373 Madera (County)11177188 Mendocino (County)6948117 Napa (County)426418844 San Bernardino (County)433514947 San Diego (County)7165211,237 Shasta (County)9493187 Siskiyou (County)202118320 Sonoma (County)532429961 Source: FEMA, November 2021 While total registrations show the scale and scope of the disaster impacts, FEMA Verified Loss provides a more accurate understanding of households that not only registered for FEMA, but also inspected by FEMA for a documented loss related to the disaster,a FEMA Verified Loss. The following figure provides an overview of the number of FEMA Verified Losses over $0 by County for both owner-occupied and renter-occupied units.For DR-4558, Butte County and Santa Cruz experienced the highest level of FEMA Verified Losses, and the registrations were evenly distributed between owner-occupied and renter-occupied households. However, Santa 54 experienced by renters. For DR-4569, registrations in Los Angeles County were highest, followed by Fresno, San Diego, and Siskiyou Counties. F IGURE 56:FEMAI NDIVIDUAL A SSISTANCE BY R ENTER AND O WNER CountyOwnerRenterTotal 45581,1471,5772,724 Alameda(County)11 Butte (County)407409816 Lake (County)131326 Lassen (County)33 Mendocino (County)22 Monterey (County)314475 Napa (County)102128230 San Mateo (County)7074144 Santa Clara (County)504494 Santa Cruz (County)268603871 Solano (County)76103179 Sonoma (County)84117201 Stanislaus (County)11 Trinity (County)20626 Tulare (County)8311 Yolo (County)123244 4569533437970 Fresno (County)7255127 Los Angeles (County)158135293 Mendocino (County)9413 Napa (County)375592 San Bernardino (County)542882 San Diego (County)7746123 Shasta (County)161632 Siskiyou (County)7056126 Sonoma (County)404282 Source: FEMA, November 2021 The previous figure provides an overview of the total count of FEMA IA Verified Losses, but to understand the costs measured through data collected by FEMA, the following provides an overview of average FEMA Verified Losses for properties with over $0 in losses by County. This figure includes both Personal Property (Renter)and Real Property (Owner)damages. These numbers do not reflect the total cost needed for reconstruction of owner-occupied or renter- occupied households. 55 F IGURE 57:A VERAGE FEMAIAV ERIFIED L OSS O VER$0 BY C OUNTY CountyOwnerRenterTotal 4558$57,569$4,863$27,099 Butte (County)$78,391$6,280$42,247 Lake (County)$43,754$4,249$24,002 Lassen (County)$172,943$172,943 Mendocino (County)$7,477$7,477 Monterey (County)$20,674$3,363$10,518 Napa (County)$34,073$5,734$18,302 San Mateo (County)$13,718$5,076$9,277 Santa Clara (County)$10,986$4,343$7,876 Santa Cruz (County)$62,258$3,620$21,663 Solano (County)$60,589$4,740$28,452 Sonoma (County)$49,979$5,126$23,871 Stanislaus (County)$7,288$7,288 Trinity (County)$92,887$8,557$73,426 Tulare (County)$34,532$6,515$26,891 Yolo (County)$6,279$7,598$7,238 4569$42,276$6,418$26,165 Fresno (County)$82,307$7,144$49,756 Los Angeles (County)$20,391$5,436$13,500 Mendocino (County)$16,449$1,792$11,939 Napa (County)$34,163$6,901$17,865 San Diego (County)$10,188$5,902$8,585 Shasta (County)$68,947$8,896$38,921 Siskiyou (County)$109,824$8,833$64,939 Sonoma (County)$52,966$6,496$29,164 Source: FEMA, November 2021 Impact on Renters Through FEMA IA, renters are eligible to apply for monthly rental assistance and for funding to replace damaged or destroyed personal property. FEMA does not inspect rental properties for real property damage, so the following table only includes personal property damage. The following figure shows the number of renters who registered for FEMA IA that have a Verified Loss over $0 of personal property damage. The table shows the number of renter-occupied households by County and HUD-defined damage category. 56 F IGURE 58:FEMAIAR ENTERS,L OSS O VER$0 WITH P ERSONAL P ROPERTY D AMAGE,BY HUD D AMAGE C ATEGORY Minor-Minor-Major-Major- CountySevereGrand Total LowHighLowHigh 45586761051294502201,580 Butte (County)120483912181409 Lake (County)713213 Monterey (County)272210344 Napa (County)328184822128 San Mateo (County)3117241174 Santa Clara (County)21119344 Santa Cruz (County)345315011661603 Solano (County)46753213103 Sonoma (County)46724814117 Trinity (County)336 Tulare (County)123 Yolo (County)422632 4569108152520491443 Fresno (County)1112291255 Los Angeles (County)454105818135 Mendocino (County)314 Napa (County)122251655 San Diego (County)121325546 Shasta (County)17816 Siskiyou (County)423252256 Sonoma (County)52424742 Source: FEMA, November 2021 categories, so the following figure pulls out the major and severe renter households by County. Overall, across both disasters there are more Major-High FEMA IA registrations, followed by renters categorized as Severe. Butte, Santa Cruz, and Napa Counties have the highest total number of Major/Severe renter-occupied households with Verified Losses. F IGURE 59:FEMAIAR ENTERS,L OSS O VER$0W ITH P ERSONAL P ROPERTY D AMAGE,B Y HUD D AMAGE C ATEGORY CountyMajor-LowMajor-HighSevereTotal 4558129450220 799 Butte (County)3912181 241 Lake (County)32 5 Monterey (County)2103 15 Napa (County)184822 88 57 San Mateo (County)72411 42 Santa Clara (County)1193 23 Santa Cruz (County)5011661 227 Solano(County)53213 50 Sonoma (County)24814 64 Trinity (County)33 6 Tulare (County)12 3 Yolo (County)4226 32 45692520491 320 Fresno (County)22912 43 Los Angeles (County)105818 86 Mendocino (County) 0 Napa (County)2516 41 San Diego (County)3255 33 Shasta (County)78 15 Siskiyou (County)32522 50 Sonoma (County)4247 35 Source: FEMA, November 2021 provides further insight into the renter population that applied for FEMA IA and had a Verified Loss. The following figure shows the total number of renters with a verified loss by HUD income category. HUD defines income categories using the following categories: Low and Moderate Income (LMI) 80 percent Area Median Income (AMI) and below. Very Low Income (VLI) 50 percent AMI and below. Extremely Low Income (ELI) 30 percent AMI and below. Over 80 percent AMI typically defined as not LMI. Overall, the 2020 disasters i other categories (VLI and ELI) show the challenges in addressing renter unmet recovery needs for the disaster given limited household income at the time of the disaster, and this is exacerbatedby costs from displacement or economic impacts resulting from the disaster. F IGURE 60:L OW AND M ODERATE I NCOME R ENTERS W ITH A FEMAV ERIFIED L OSS BY C OUNTY Low and Very Extremely Moderate Low Low Total IncomeIncomeOver 80 CountyIncome(30 Renters(80 (50 percentAMI percent percent percent AMI) AMI)AMI) Butte (County)292334918822 Fresno (County)36951012 Lake (County)532 58 Los Angeles (County)681582817 Mendocino (County)2110 Monterey (County)2979112 Napa (County)11626183141 San Diego (County)2323612 San Mateo (County)289667 Santa Clara (County)215412 Santa Cruz (County)43791103139104 Shasta (County)133163 Siskiyou (County)48614217 Solano (County)5912132014 Sonoma (County)9412213427 Trinity (County)5230 Tulare (County)211 Yolo (County)10433 Source: FEMA, November 2021 The following figure combines both HUD defined damage categories and income categories to show the nexus between income level and disaster damage from the 2020 disasters for renter- occupied households with FEMA Verified Losses over $0. Renters are found to be less likely to bounce back after a disaster ability to recovery from the damage and displacement caused by a natural disaster and the 2020 disasters are no exception, the highest category are Extremely Low Income renters. F IGURE 61:L OW AND M ODERATE I NCOME R ENTERS BY HUDI NCOME C ATEGORY Low and Extremely Very Low Over 80% Income CategoryTotal Renters Moderate Low IncomeAMI IncomeIncome Major-High3987969137113 Major-Low9912174723 Minor-High8613124219 Minor-Low5189311921393 Severe20641418143 Grand Total1,307238258520291 Source: FEMA, November 2021 59 Impact on Homeowners This section provides an overview of 2020 wildfireimpacts on homeowners in FEMA IAareas through analysis of FEMA IA registration data.Asnoted above, this data setprovides limited information,asa)not all eligiblehomeowners registered, and b)that FEMA does not inspect owner-occupied properties with insurance. Despite these limitations, FEMA IA data does provide insight into the demographics of impacted householdsand severity of damage across geographies. The following table shows the HUD-defined damage categories for owner- occupied households that registered for FEMA IAandsustaineda Verified Loss above $0. Overall, Butte and Santa Cruz County containedthe highest total number of properties with severe damage for DR-4558, while Fresno and Siskiyou had the highest number of severe properties for DR-4569. F IGURE 62:FEMAIAO WNERS WITH R EAL P ROPERTY O VER$0 BY D AMAGE C ATEGORY CountyMinor-LowMinor-HighMajor-HighSevereTotal 45586413563421,042 Butte (County)131129198359 Lake (County)8210 Lassen (County)123 Mendocino (County)11 Monterey (County)231226 Napa (County)6262593 San Mateo (County)65267 Santa Clara (County)46248 Santa Cruz (County)1711167249 Solano (County)4731969 Sonoma (County)54141574 Stanislaus (County)11 Trinity (County)102719 Tulare (County)516 Yolo (County)1212 456927336100382 Fresno (County)22112650 Los Angeles (County)1009109 Mendocino (County)819 Napa (County)141924 San Diego (County)4411147 Shasta (County)6814 Siskiyou (County)1843759 Sonoma (County)17825 Source: FEMA, November 2021 60 As noted above for renters, HUD only considers Major and Severe damage for its housing unmet needs calculation. All ofthe homes that registered for FEMA IAand were confirmed asa Verified Loss over $0 fell into the Major-High and Severe Categories.Butte, Santa Cruz, and Siskiyou experienced the highest number of Major/Severe registrations from the 2020 disasters. F IGURE 63:FEMAIAO WNERS W ITH R EAL P ROPERTY O VER$0 BY D AMAGE C ATEGORY M AJOR/S EVERE O NLY CountyMajor-HighSevereTotal 455856342 398 Butte (County) 29198227 Lake (County) 22 Lassen (County) 22 Mendocino (County) 0 Monterey (County) 123 Napa (County) 62531 San Mateo (County) 22 Santa Clara (County) 22 Santa Cruz (County) 116778 Solano (County) 31922 Sonoma (County) 41519 Stanislaus (County) 0 Trinity (County) 279 Tulare (County) 11 Yolo (County) 0 45696100 106 Fresno (County) 12627 Los Angeles (County) 99 Mendocino (County) 11 Napa (County) 99 San Diego (County) 112 Shasta (County) 88 Siskiyou (County) 43741 Sonoma (County) 88 Source: FEMA, November 2021 As with renters, HUD uses AMI to determine owner-occupied households that qualify as low income. The following figure shows FEMA IA owner-occupied registrants with Verified Losses over $0 by HUD income category. Butte County stands out with a significant number of Extremely Low Income (ELI)owner-occupied households. 61 F IGURE 64:R ENTER H OUSEHOLDS BY HUDI NCOME C ATEGORY Low and VeryExtremely Total Over 80% CountyModerate LowLow OwnersAMI IncomeIncomeIncome Butte (County)262425512243 Fresno (County)32105413 Lake (County)3210 Lassen (County)330 Los Angeles (County)3967620 Mendocino (County)51220 Monterey (County)134414 Napa (County)6818121226 San Diego (County)1613111 San Mateo (County)3351225 Santa Clara (County)186327 Santa Cruz (County)18122313296 Shasta (County)9153 Siskiyou (County)528132110 Solano (County)3766718 Sonoma (County)52710827 Stanislaus (County)110 Trinity (County)134243 Tulare (County)22 Yolo (County)413 Source: FEMA, November 2021 defined in the Federal Register Notice, compared to HUD income categories. Overall, the table below shows that low-income owner-occupied households were disproportionately impacted by the 2020 disasters. 62 F IGURE 65:LMIO WNER B Y I NCOME O VER$0R EAL P ROPERTY L OSS,W ITH I NCOME Low and Extremely Very Low Over 80% Damage CategoryTotal OwnersModerate Low IncomeAMI IncomeIncome Major-High52912247 Minor-High4211 Minor-Low464737398220 Severe343657511192 Grand Total863149161233320 Source: FEMA, November 2021 Low Income Renter and Owner Characteristics FEMA IA data also provides insight into other characteristics of impacted households including FEMA Verified Loss (FVL), income level (AMI), as well as registrants with flood and homeowner insurance.In the2020 FRN, HUD instructsgrantees to examine the following populations: Renters under50 percent AMI with a FEMA Verified Loss Homeowners with a FEMA Verified Loss who are under 80 percent AMI and without flood insurance Homeowners with a FEMA Verified Loss who are under 80 percent AMI without homeowner insurance The following table provides an overview of damage sustained by renters and homeowners as a result ofFEMA DR-4558 and DR-4569, and reflects the categories listed above. F IGURE 66:L OW I NCOME R ENTER AND O WNER C HARACTERISTICS FEMA IA Homeowners with Homeowners with FVL, Renters Under 50 percent Damage FVL, LMI, No Flood LMI, No Home Owner AMI with an FVL CategoryInsuranceInsurance Major-High4625553 Major-Low11900 Minor-High8800 Minor-Low59800 Severe227350283 Total1,494405336 Source: FEMA, November 2021 The following map shows the number of FEMA IA damaged properties that qualify as Major or Severe damage by Census Tract. The highest concentrations fallwithin Butte County and Siskiyou Countyin Northern California. 63 F IGURE 67:FEMAIAW ITH M AJOR/S EVERE D AMAGE N ORTHERN CA Source: FEMA, November 2021; U.S. Census Bureau; ESRI The following figure illustratesthe concentration of FEMA IA damaged properties with Major/Severe Damage. Santa Cruz and Fresno County containthe highest number of Major/Severe damage properties. 64 F IGURE 68:FEMAIAW ITH M AJOR/S EVERE D AMAGE S OUTHERN CA Source:FEMA, November 2021; U.S. Census Bureau; ESRI Impact on Homeowners and Renters Over 65 While all federally protected classes are at risk of disaster impacts, people over the age of 65 are particularly vulnerableduring fire events. The following provides further detail on FEMA IA registrants over the age of 65 with total verified losses over $0. F IGURE 69:O VER 65,T OTAL V ERIFIED L OSS O VER$0 CountyOwners Over 65Renters Over 65Grand Total Butte (County)11658174 Fresno(County)281240 Lake (County)235 Lassen (County)22 Los Angeles (County)372158 65 Mendocino (County)426 Monterey (County)8816 Napa (County)393574 San Diego (County)111223 San Mateo (County)20727 Santa Clara (County)15823 Santa Cruz (County)7752129 Shasta (County)9615 Siskiyou (County)331043 Solano (County)21526 Sonoma (County)392867 Trinity (County)88 Tulare (County)112 Yolo (County)6410 Source: FEMA, November 2021 CAL FIRE Damage Survey CAL FIRE conducts a parcel survey of properties impacted by fires and natural disasters using ArcGIS and ArcCollector. The Damage Inspection Worksheet includes property addresses, the incident (disaster) name, and information about the damaged property. For DR-4588and DR- 4569, CAL FIRE surveyed a total of 25,778structures.This on-the-ground analysis has its limitations: survey staff are not building inspectors,inspectionsare completedimmediately post- disaster, and surveyorsare only able to examineproperties that are accessible. Despite these factors, the data presents a clearer picture of damage than either SBA or FEMA IA. CAL FIRE damage assessments are conducted on the ground post-disaster, while SBA and FEMA IA are voluntary application processes. The following figure shows the total number of structures surveyed. F IGURE 70:CALFIRE2020D ISASTER D AMAGE S URVEY BY S TRUCTURE T YPE AffecteMinor (10-MajorDestroyed No Structure TypeInaccessibleTotal d (1-9%)25%)(26-50%)(>50%)Damage Church31417 Commercial Building Multi Story102140173226 Commercial Building Single 3813256056231,178 Story Hospital11415 66 Infrastructure2010105318211286 S OURCE:1 Mixed Commercial/Residential11174166243 S OURCE:2 Mobile Home Double Wide1324192292665 S OURCE:3 Mobile Home Single Wide1114162235656 Mobile Home Triple Wide431356 Motor Home11145342272779 MultifamilyResidenceMulti 41127886 Story MultifamilyResidenceSingle 6121126154 Story School22162343 Single Family Residence Multi 21240141,3444,145105,765 Story Single Family Residence Single 2163382,5034,490707,320 Story Utility Misc.Structure23166563,2414,609868,289 Grand Total776172989,26915,27418925,778 Source: CAL FIRE Damage Assessment, November 2021 Tofurthersupplement the analysis of unmet housing recovery needs in the 2020 impacted counties, HCD analyzed CAL FIRE survey data and narrowed the scope to include residential structures only. Inthe table below, residential structures include the following structure types: Mixed Commercial/Residential Mobile Home Double Wide Mobile Home Single Wide Mobile Home Triple Wide Motor Home MultifamilyResidenceMulti Story MultifamilyResidenceSingle Story Single Family Residence Multi Story Single Family Residence Single Story A total of 5,356 surveyed residential structures were categorizedas destroyed, with the highest concentration of destroyed properties foundin Butte, Santa Cruz, Napa, and Sonoma Counties. F IGURE 71:CALFIRED AMAGE S URVEY R ESIDENTIAL S TRUCTURES O NLY BY D AMAGE C ATEGORY Destroyed Total by AffectedMinorMajor County (1-9%)(10-25%)(26-50%)(>50%)County Butte46341,5191,572 67 Fresno2986522565 Lake88 Lassen314044 Los Angeles228199130 Madera14748 Mendocino14142 Monterey13316380 Napa100143615732 San Bernardino246 San Diego513036 San Mateo41418 Santa Clara73189100 Santa Cruz701069171,003 Shasta15106121 Siskiyou821209220 Solano6081313382 Sonoma79123502596 Stanislaus11415 Trinity122528 Tulare721173183 Yolo369 Total47479295,3565,938 Source: CAL FIRE Damage Assessment, November 2021 To further narrow the CAL FIRE damage survey data, the figure below limits the county analysis to include only Single Family structures (Single Family Residence Multi Story and Single Family Residence Single Story) that were inspected and categorized as destroyed.According to this limited dataset, a total of 3,847 single-family residential structures were recorded as destroyed due to the 2020 disasters. HCD proposes using this number of households as a more accurate count of the total losses for owner-occupied properties when compared to FEMA IA and SBA home loan registrations. F IGURE 72:CALFIRES INGLE F AMILY P ROPERTIES D ESTROYED IN 2020D ISASTERS CountyTotal Butte697 68 Fresno441 Lake5 Lassen19 Los Angeles91 Madera18 Mendocino18 Monterey61 Napa479 San Bernardino4 San Diego15 San Mateo11 Santa Clara64 Santa Cruz827 Shasta63 Siskiyou111 Solano274 Sonoma448 Stanislaus10 Trinity19 Tulare168 Yolo4 Grand Total3,847 Source: CAL FIRE Damage Assessment, November 2021 4.Small Business Administration Loans Small Business Administration Housing (SBA) loans are the basic form of federal disaster assistance for homeowners with good credit history and income, andwhose private property sustained damage that is not fully covered by insurance. Homeowners and renters whose property was damaged by a presidentially declared disaster are eligible toapply for an SBA low- interest loan. Interest rates on these loans are determined by law and are assigned on a case- by-case basis. Households in DR-4558 impacted counties submitted a total of 4,182 applications, but to date only 478 have been approved. Householdsin DR-4569 impacted counties submitted 2,029 SBA home loan applications, and only 148 applications have been approved. The figures below give an overview of total applications, approvals,and total SBA Verified Losses by county. F IGURE 73:SBAH OME L OAN A PPLICATIONS AND V ERIFIED L OSS BY C OUNTY DR-4558 Total SBA Applications Total SBA Loans SBA Total County -4558 SubmittedApprovedVerified Loss Butte71893$59,800,759 Lake1251$669,641 Lassen16$1,344,401 69 Mendocino5$674,961 Monterey19512$10,663,475 Napa43937$24,189,721 San Mateo37223$18,208,033 Santa Clara3546$8,320,439 Santa Cruz1,071222$108,605,977 Solano30853$36,126,752 Sonoma38625$15,355,618 Stanislaus9$317,779 Trinity313$3,708,872 Tulare501$4,346,307 Yolo1032$4,242,321 Total4,182478$296,575,056 Source: Small Business Administration, January 2022 F IGURE 74:SBAH OME L OAN A PPLICATIONS AND V ERIFIED L OSS BY C OUNTY DR-4569 Total SBA Applications Total SBA Loans SBA Total County -4569 SubmittedApprovedVerified Loss Fresno29528$22,197,541 Los Angeles74624$20,834,485 Madera474$2,263,948 Mendocino293$2,045,137 Napa13525$12,072,111 San Bernardino1975$5,230,914 San Diego2638$6,517,140 Shasta516$3,188,147 Siskiyou9728$12,466,944 Sonoma16917$13,320,455 Total2,029148$100,136,823 Source: Small Business Administration, January 2022 5.Summary of Housing Impacts Based on HUD guidance in the 2020 FRN, the following figure compares Major/Severe FEMA IA properties with a Verified Loss toSBA home loan verified losses to determine an SBA ratio and a total basis for reconstruction. Using this formula, HCD uses the SBA Average Real Property Verified Loss for Severe Properties only, setting the per-unit cost of reconstruction for housing units at $321,735. This number is well below the cost of a full reconstruction or developing a new unit for either an owner-occupied or renter-occupied unit in the 2020 disaster impacted areas butwill serve as the base figurefor the HUD-required housing unmet need methodology below. 70 F IGURE 75:SBAR ATIO Count of Total Total SBA Total FEMA IA Real Property Damage Category Verified LossVerified LossVerified Loss Major-High13$2,053,381.98$307,945.86 Severe119$38,286,571.58$18,637,803.25 Average of Severe 119$321,735.90$156,620.20 Properties Only SBA Ratio (SBA FVL/FEMA Real 2.05 Property FVL) Source: Small Business Administration;January 2022; FEMA November 2021 Using the methodology provided by HUD in the 2020 FRN, the following figure provides the baseline calculation for housing unmet needs in counties impacted by the2020 disastersin California. F IGURE 76:H OUSING U NMET N EED HUDM ETHODOLOGY Damage OwnerRenterTotal OwnerRenterTotal Category -CountTotal DamageCountTotal DamageCountTotal Damage Major-Low-$0147$47,295,177147$47,295,177 Major-High62$19,947,626621$199,797,991683$219,745,617 Severe442$142,207,266301$96,842,505743$239,049,770 Total504$162,154,8911,069$343,935,6721,573$506,090,564 6.Cost of Reconstruction The State of California data from CAL FIRE provides further insight into the number of structures destroyed during the 2020 fires, but this only covers one side of the cost of reconstruction. The following section shows the actual cost to develop both owner-occupied and Multifamily housingunits for the 2017 and 2018 disasters funded by CDBG-DR. The cost of construction reflects the rising cost of building materials, labor supply issues, and standard construction costs such as building to the required building codes. When compared to the average total verified loss by SBA, which establishes an average cost based on Severe properties only, of $321,735 per unit, there continues to be a substantial gap between the SBA approved number and the actual cost of reconstruction in areas impacted by the 2020 disasters. While the intent of CDBG-DR is to provide gap financingfor both homeowners and renters recovering from disaster, many of the OOR applicants are predominantly LMI and have few other resources to assist with reconstruction costs. As shown in the figure below, all of the average cost of reconstruction are at least $100,000 over the SBA per unit cost. 71 F IGURE 77:A VERAGE C OST OF R ECONSTRUCTION FOR S TICK B UILT H OMES FROM S OLUTION 1 OF 2017-2018CDBG-DROORP ROGRAM County Average Estimated Cost to 2020 Impacted ReconstructArea? Butte $501,503Y Lake$455,535Y Los Angeles $546,800Y Napa $644,137Y San Diego$578,684Y Santa Barbara $472,777 Sonoma$655,162Y Ventura $460,673 Source: HCD Program Data, April 2022 TheMultifamily Housing ongoing housing crisis, and help to address the rental housing shortage exacerbated by disasters. While MHPprojects generally rely on multiple funding sources, developer capacity and building costs in the rural areas in rural areas and other rising costs impact the per unit cost for developing MHP units in impacted areas. The figure below shows the average cost per unit proposed for 2017 and 2018 CDBG-DR MHP applicants. Only Yuba County falls below the per unit cost estimated by SBA for the 2020 disaster, all others exceed the average cost for reconstruction. F IGURE 78:CDBG-DRM ULTIFAMILY H OUSING P ROGRAM C OST P ER U NIT Average Cost 2020Impacted Subrecipient Per UnitArea City of Chico$480,480Y City of Napa$494,734Y City of Santa Rosa$570,157Y City of Ventura$704,222 County of Butte$394,308Y County of Los Angeles$540,815Y County of Mendocino$472,034Y County of Santa Barbara$780,573 County of Sonoma$741,805Y County of Ventura$569,093 County of Yuba$129,802 City of Redding$388,236Y Source: HCD Program Data, April 2022 7.CAL FIRE Alternative Methodology However, the number of properties identified through FEMA IA, which only includes households that registered withFEMA, falls far below the actual number of households impacted by the 2020 disasters. To accurately estimate the owner-occupied housing lossesand unmet needs, 72 HCD proposes the following methodology that more accurately reflects the unmet disasters needs. Total Destroyed Single Family Residential Structures 3,847 Damage multiplier $321,735.90(SBA Ratio) Total Damage, Owner-Occupied$1,237,714,545 I.Infrastructure Unmet Need 1.FEMA Public AssistanceOverview The FEMA Public Assistance (FEMAPA) program is designed to provide immediate assistance todisaster-impacted jurisdictions for emergency work (under FEMA Sections 403 and 407) and permanent work (Sections 406 and 428) on infrastructure and community facilities. Data from these programs was used to assessthe impact of the disasters on infrastructure and calculate unmet need. Although there is a clear need for infrastructure repair and improvements, this Action Plan focuses on unmet recovery needs with prioritization given to housing recovery and housing- related infrastructure projects.One reason for this prioritization is that although total project costs have been calculated, project eligibility has not been determined for all project worksheets submitted. Therefore, the local share figures are preliminary and likely to increase substantially moving forward. In total the total cost share needed for both state and local match for FEMA PA projects for 2020 disasters is $10,072,692 and local share only is $2,518,240. FEMA PA projects fall under the following categories: Emergency Protective Work o Category A Debris Removal o Category B Emergency Protective Measures Permanent Work o Category CRoads and Bridges o Category D Water Control Facilities o Category E Public Buildings and Contents o Category F Public Utilities o Category G Parks, Recreational, and Other Facilities The following tables summarize the FEMA PA assistance in review by FEMA and the California (CalOES)as of February 2022. As noted above, these values are subject to change and will be re-evaluated as the Action Plan is amended and/or through program design. Across areas impacted by DR-4558, impacted counties submitted FEMA PA projects totaling over $46 million for Categories C through G. A majority of the requests were made for Category F Utilities, followed by Category C Roads and Bridges. F IGURE 79:FEMAPAF OR DR-4558 CountiesTotal DamageTotal Unmet Need Butte County$5,095,822.38$955,466.71 Lassen County$80,183.46$15,034.40 73 Monterey County$2,398,310.27$449,683.18 Napa County$1,789,529.23$335,536.74 San Mateo County$1,084,522.75$203,348.02 Santa Clara County$2,192,896.54$411,168.10 Santa Cruz County$26,711,669.83$5,008,438.12 Solano County$659,118.57$123,584.74 Sonoma County$301,052.47$56,447.34 Trinity County$4,425,474.61$829,776.50 TulareCounty$1,378,650.27$258,496.93 4558 Total$46,117,230.38$8,646,980.77 Source: FEMA February 2022 F IGURE 80:FEMAPAL OCAL S HARE O NLY FOR DR-4558 BY C ATEGORY Total Unmet Need (Local 4558-CategoryProjectsTotal Damage Share Only) C-Roads and Bridges50$12,052,705.98$564,970.60 D-Water Control Facilities1$54,001.49$2,531.32 E-Buildings and Equipment27$7,857,067.92$368,300.06 F-Utilities29$23,192,882.42$1,087,166.37 G-Parks, Recreational Facilities, 11$2,960,572.57$138,776.84 and Other Items Total -4558118$46,117,230.38$2,161,745.19 Source: FEMA February 2022 The following figures outline the FEMA PA requests from jurisdictionsimpacted by the DR-4569 disasters. The total request for FEMA PA projects Category C through G totals $7.6 million. Category C Road and Bridges make up the majority of requested projects, followed by Category EBuildings and Equipment. F IGURE 81:FEMAPAF OR DR-4569 CountiesTotal DamageTotal Unmet Need Fresno County$4,847,465.02$908,899.70 Madera County$22,060.87$4,136.42 Napa County$1,985,974.68$372,370.26 Shasta County$81,310.79$15,245.78 Siskiyou County$64,462.08$12,086.64 Sonoma County$603,957.69$113,242.07 4569 Total$7,605,231.13$1,425,980.86 Source: FEMA February 2022 F IGURE 82:FEMAPAL OCAL S HARE O NLY FOR DR-4569 BY C ATEGORY Total Unmet Need 4569-CategoryProjectsTotal Damage (Local Share Only) C-Roads and Bridges17$5,411,501.24$253,664.12 D-Water Control Facilities1$76,574.35$3,589.42 74 E-Buildings and Equipment12$794,786.38$37,255.61 F-Utilities5$1,030,820.84$48,319.73 G-Parks, Recreational 2$291,548.32$13,666.33 Facilities, and Other Items Total -456937$7,605,231.13$356,495.22 Source: FEMA February 2022 2.Hazard Mitigation Grant Program The FEMA Hazard Mitigation Grant Program (HMGP) serves as a resource to fund programs that reduce the risk of loss of life and property and is activatedfollowing a presidential major disaster declaration. HMGP funds, provided at the amount of FEMA disaster recovery assistance under the presidential declaration, are allocated on a sliding scale formula based on an appropriate percentage of the estimated total of federal assistance (less administrative costs) wherein each individual activity is required to have at least a 25 percent non-federal cost share. The HMGP funding ceiling is estimated by FEMA at 90-days post disaster and maintained at the same amount until a lock-in ceiling is established six months after the disaster declaration. Twelve months after adisaster declaration,a final review of the lock-in ceiling determines an official final amount of HMGP fundsavailable to jurisdictions. The final amount will not be less than the six-month lock-in amount. CalOES manages the State of Californi provided the following data in February 2022. This data will continue to evolve as projects are approved by FEMA and any changes will be reflected in subsequent Action Plan amendments or program design. The figures below show the total HMGP applications from DR-4569 impacted counties and reflect the mitigation needs of the disaster impacted areas. In total, eligible applicantssubmitted a total of over $52 million in projects and need a total of $16.9 million in local match. The list of applicants does not reflect the total counties eligible in DR-4569 since applications are voluntary. F IGURE 83:HMGPP ROGRAM A PPLICATIONS AND L OCAL M ATCH DR-4569 CountyTotal HMGP RequestTotal Local Match Needed Los Angeles$16,636,780$6,092,427 Napa$971,250$242,813 San Bernardino$1,500,000$187,500 San Diego$1,671,576$360,686 San Mateo$2,675,000$675,000 Santa Clara$3,106,169$747,880 Shasta$23,542,135$7,836,992 Sonoma$2,605,342$677,389 Total -4569$52,708,252$16,820,687 Source: FEMA February 2022 75 The following figure provides the total HMGP request and local match needed for DR-4558 impacted counties. In total DR-4558 counties submitted over $40 million in HMGP projects and need a total local match of $9.5 million. F IGURE 84:HMGPP ROGRAM A PPLICATIONS AND L OCAL M ATCH DR-4558 CountyTotal ImpactUnmet Need Butte$985,300$246,325 Lake$2,690,229$675,891 Mendocino$1,653,059$444,763 Monterey$775,864$135,824 Napa$8,294,666$1,274,493 San Mateo$9,707,311$2,429,997 Santa Cruz$2,402,972$783,669 Sonoma$3,502,734$1,004,290 Trinity$9,999,976$2,499,994 Tulare$100,000$25,000 Total -4558$40,112,111$9,520,245 Source: FEMA February 2022 The figure below lists the typesof HMGP projects submitted and currently in review by FEMA. The variety of mitigation projects below in DR-4558 and DR-4569 impacted counties represent the current mitigation needs of the communities that were able to submit HMGP applications. F IGURE 85:HMGPA PPLICATIONS F OR 4569A ND 4558A S O F F EBRUARY 2022(I N FEMA R EVIEW) Butte Fire Protection & Prevention Community Education Generators: Butte County Fire Station Lake Hidden Valley Lake Defensive Space and Ignition Resistant Construction (DSIRC) HVLCSD Water Distribution System Advance Assistance Project Lake County Special Districts Replacement of Redwood Water Storage Tanks Number 3 and 4 Project Los Angeles 1st ES East Building Seismic Retrofit Albion ES Auditorium Seismic Retrofit Aldama ES Main Building & Auditorium Seismic Retrofit Automated Earthquake Early Warning System Backup Generator for Topanga Forks Pump Station in Los Angeles County Bell Hazard Mitigation Planning Grant City of Carson Hazard Mitigation Plan City of Hermosa Beach LHMP Update City of La Habra Heights, -Emergency Power Generator City of Long Beach Hazard Mitigation Plan City of Los Angeles Hazard Mitigation Plan Review and Update 76 City of Monrovia Electrical System Backup Generator Project City of Monterey Park Local Hazard Mitigation Plan Update (MPK LHMP Plan Update) City of Rancho Palos Verdes Goat Vegetation Management Project City of Whittier 2021 Natural Hazard Mitigation Plan Update Irving MS-Auditorium Seismic Retrofit LA+USC Outpatient Clinic Seismic Retrofit Local Hazard Mitigation Plan Update Lockwood ES Main Building Seismic Retrofit Metropolitan Water District of Southern California Hazard Mitigation Plan New Plan Micheltorena ES Main Building Seismic Retrofit Seismic Retrofitting Four City Buildings 2021 Seismic Upgrades to Potable Water Reservoirs Update to Local Hazard Mitigation Plan Update to the 2017 Hazard Mitigation Plan Wildfire & Vegetation Management Mendocino Mendocino County Critical Facilities Generators Orr Springs Road Fuels Reduction Monterey Advance Assistance -Nacimiento Dam Spillway Plunge Pool Mitigation Development Napa Advance Assistance -Kimball Creek Dam Raise Emergency Backup Power Napa County Critical Facilities Clean Backup Power for Berryessa Highlands St. Helena Defensible Space and Fuels Management St. Helena Hospital Defensible Space and Hazardous Fuels Removal Project St. Helena Hospital Water Main Hardening Project Wastewater Treatment Plant Emergency Backup Power San Bernardino City of Ontario Local Hazard Mitigation Plan (Update) City of Redlands Seismic Assessment of Potable Wells, Pump Stations, and Transmission Main East Valley Water District Water Main Seismic Retrofit San Bernardino County Flood Mitigation-Advance Assistance Slope Stabilization -Mt. Vernon Avenue San Diego California Wildfire Mitigation Program -San Diego County San Diego County Advance Assistance (AA) Flood Resilience Project San Mateo Price Storm Drainage Pump Station Improvement Project Redwood Shores Sea Level Rise Protection Advance Assistance San Mateo County Events and Emergency Operations Center Generator and Electrical Upgrade Project Wildfire Hazard Fuel Reduction at Junipero Serra County Park 77 Wildfire Hazard Risk Reduction at Edgewood County Park and Natural Preserve Santa Clara Cupertino Civic Center Plaza Microgrid Los Gatos Hazardous Fuel Reduction Santa Clara County Multi-Jurisdictional Multi-Hazard Mitigation Plan Update Santa Cruz County of Santa Cruz Roadside Hazardous Fuel Reduction Program Jordan Gulch Middle Fork Embankment Stabilization Lick Observatory Vegetation Management Project Shasta California Wildfire Mitigation Program Shasta County Sonoma Charles M. Schulz Airport Operations Center Backup Generator City of Rohnert Park Water Tank System Seismic Retrofit Healdsburg Badger Substation Liquefaction Mitigation Measures RRCSD LHMP 2023 Update SCWA LHMP 2023 Update Wildfire Fuel Reduction Project Trinity Trinity County Hazardous Fuels Reduction Tulare Multi-Jurisdictional Local Hazard Mitigation Plan Update J.Economic Revitalization Unmet Need The SBA offers Business Physical Disaster Loans and Economic Injury Disaster Loans (EIDL) to businesses to repair or replace disaster damaged property, including real estate, inventories, supplies, machinery, equipment,and working capital until normal operations resume. Businesses of all sizes are eligible. Private, nonprofit organizations such as charities, churches, and private universities are also eligible. The law limits these business loans to $2 million and the amount cannot exceed the verified uninsured disaster loss.In total for Business and EIDL approved applications in 2020 disaster impacted areas, applicants requested over $86 million in support, while only $7.2 million has been dispersed to date. This leaves $78.8 million in unmet needs for businesses in impacted areas. F IGURE 86:T OTAL SBAB USINESS L OANS A PPROVED Sum of Total Verified Sum of Total Amount CountyUnmet Need LossDisbursed Butte$688,899$176,200$512,699 Fresno$126,426$110,200$16,226 Lake$0$112,600-$112,600 Lassen$0$0$0 Los Angeles$12,000$12,000$0 78 Madera$0$0$0 Mendocino$0$0$0 Monterey$116,377$25,000$91,377 Napa$73,341,678$2,859,600$70,482,078 San $0$0$0 Bernardino San Diego$0$298,600-$298,600 San Mateo$4,600$250,000-$245,400 Santa Clara$0$900,000-$900,000 Santa Cruz$1,397,188$885,100$512,088 Shasta$0$0$0 Siskiyou$0$0$0 Solano$571,431$801,500-$230,069 Sonoma$4,683,481$864,600$3,818,881 Stanislaus$0$0$0 Trinity$0$0$0 Tulare$0$0$0 Yolo$5,229,161$0$5,229,161 Total$86,171,242$7,295,400$78,875,842 Source: Small Business Administration, January 2022 The following figure shows the breakdown of application status for DR-4569. Only 30 applications out of 428 have beenapproved. F IGURE 87:SBAA PPLICANT B REAKDOWN,EIDL AND B USINESS L OANS DR-4569 Auto Decline Grand CountyApprovedDeclinedDuplicateWithdrawn -CreditTotal Fresno29912243 Los Angeles24335281163 Madera2911 Mendocino211711 Napa2331312262 San 1162037 Bernardino San Diego210712444 Shasta112 Siskiyou214925 Sonoma18521430 Grand Total3090918209428 Source: Small Business Administration, January 2022 79 F IGURE 88:SBAA PPLICANT B REAKDOWN,EIDL AND B USINESS L OANS DR-4558 CountyApprovedAuto Decline -CreditDeclinedDuplicateWithdrawnGrand Total Butte81327-66114 Lake-6111826 Lassen-1--12 Monterey456-2439 Napa2971523487 San Mateo183-2840 Santa Clara-5812741 Santa Cruz131923383141 Solano769-3355 Sonoma7106-2952 Stanislaus----11 Tulare-3--25 Yolo223-1118 Grand Total71851017357621 Source: Small Business Administration, January 2022 The figure below compares the total applications compared to total approved application and the total amount of EIDL distributed to date for DR-4569 and DR-4558 impacted areas. F IGURE 89:SBAE CONOMIC I NJURY D ISASTER L OAN,DR-4569 Total of EIDL 4569 CountiesTotal ApplicationsTotal Approved Applications Disbursed Fresno40430$60,200.00 Los Angeles110026 Madera734 Mendocino453 Napa21548 San Bernardino2955 San Diego35310$298,600.00 Shasta656 Siskiyou13128 Sonoma22418 Source: Small Business Administration, January 2022 F IGURE 90:SBAE CONOMIC I NJURY D ISASTER L OAN,DR-4558 Total SBA EIDL Total Approved EIDL County -4558Total of EIDL Disbursed ApplicationsApplications Butte111$25,000 Lake61$112,600 Lassen1 Monterey12 Napa303$139,600 80 San Mateo18 Santa Clara223$900,000 Santa Cruz5911$692,100 Solano151$7,200 Sonoma619$792,700 Stanislaus1 Tulare1 Yolo4 Source: Small Business Administration, January 2022 F IGURE 91:EIDLA ND B USINESS L OANS DR-4558 County -4558ApprovedTotal LoansTotal Verified LossTotal Distributed Butte8152$366,533,486$151,200 Lake45$26,122$0 Lassen3$0$0 Mendocino3$0$0 Monterey449$1,340,705$25,000 Napa29114$76,974,096$2,720,000 San Mateo163$933,223$250,000 Santa Clara73$831,481$0 Santa Cruz13184$9,965,779$193,000 Solano782$2,735,622$794,300 Sonoma770$7,412,185$71,900 Stanislaus2$0$0 Tulare8$543,117$0 Yolo232$5,913,825$0 Source: Small Business Administration, January 2022 F IGURE 92:EIDL AND B USINESS L OANS DR4569 Total SBA Total Approved SBA Total Verified Total Counties -4569 ApplicationsApplicationsLossDistributed Fresno311$1,035,180$103,100 Los Angeles1131$42,660,710$12,000 Madera8$1,400,988$0 Mendocino9$508,653$0 Napa4523$88,031,414$100,000 San Bernardino25$62,522$0 San Diego29$1,530,898$0 Shasta$0$0 Siskiyou23$21,091,956$0 Sonoma191$1,265,478$25,000 Grand Total30226$157,587,799$240,100 Source: Small Business Administration, January 2022 81 Affirmatively Further Fair Housing Disasters exacerbate existing problems in a community, particularly as protected classes have fewer resources to rebound from them. With high housing costs across the state and limited options available, disasters further tighten already stressed housing markets, including many areas impacted by the 2020 disasters. Due to lack of available housing, many disaster survivors, if financially able, move out of the area or state, while others are forced to live in 34 temporary housing or lose their home.=@:%HCD is committed to Affirmatively Furthering Fair Housingand all disaster recovery and mitigation programs will adhere to its approved Analysis 35 of Impediments to Fair Housing.HCD goes beyond the federal requirements for furthering fair housing including implementation of AB 686, and the ongoing work of the FairHousing and 36 Accountability and Enforcement teams within the department.The following provides an analysis of federal protected classes within the areas impacted by the 2020 disasters, including Most Impacted and Distressed Areas. The Fair Housing Act defines federal protected classes as race, color, national origin, religion, sex, familial status, and disability. HCD is committed to fulfilling its fair housing and civil rights duties for all CDBG-DR and Mitigation activities. Furthermore, fair housing and civil rights obligations, including potential impacts to protected classes, will be taken into consideration in the event that CDBG-DR and Mitigationfunds are re- programmed in the future. This section of the Action Plan includes an assessment ofeligible areas forCDBG-DR and Mitigation funds. HCD confirms that none of its proposed programswill have an unjustified discriminatory effect or failure to benefit racial and ethnic minorities in proportion to their communities needs particularly in racially and ethnically concentrated areas of poverty. HCD also provides details on the impacts to persons with disabilities in this section, the outreach and engagement section, and notes how programs will consider persons with disabilities in the proposed program section. This section of the Action Plan, as well as the previous section, provides detail on the racial and ethnic make-up of the population that align with proposed programsbased on section provides data at the lowest level available for the following populations: o Renters and owners; o Limited English Proficient populations; o Persons with disabilities; o Federally protected classes; o Indigenous populations; o Racially and ethnically concentrated areas of poverty; and 34 Fixing America'sBroken Disaster Housing Recovery System-Part One: Barriers to a Complete and Equitable National Low Income Housing Coalitionand Fair Share Housing Center, September 4, 2020), https://nlihc.org/sites/default/files/Fixing-Americas-Broken-Disaster-Housing-Recovery-System_P1.pdf. 35 Development, June 2020, https://www.hcd.ca.gov/policy-research/plans-reports/docs/final2020ai.pdf 36 https://www.hcd.ca.gov/community- development/affh/index.shtmland more information on accountability and enforcement work is found here: https://www.hcd.ca.gov/community-development/accountability-enforcement.shtml 82 o Historically distressed and underserved communities. This section examines data showing protected classes, vulnerable populations, and historically underserved groups in the areas impacted by the 2020 disasters, including maps showing LMI and RECAP areas. The Outreach and Engagement section provides how protected classes can participate in the planning process, which protected classes may be recipients or beneficiaries of CDBG-DR or Mitigation approach to ensuring both outreach and program activities follow both federal and state requirements in terms of accessibility and reasonable accommodation. l proposed programs addressing barriers that individuals may face when enrolling in and accessing CDBG-DR assistance. This section provides an analysis of the proximity of natural and environmental hazards to affected populations in the MID area including protected classes, vulnerable populations, and underserved communities. Racially and Ethnically Concentrated Areas of Poverty HUD defines Racially and Ethnically Concentrated Areas of Poverty (RECAP) as areas that have a non-White population of 50 percent or more with 40 percent or more of the population in in poverty, or a poverty rate that is greater than three times the average poverty rate in thearea. The following maps show the RECAP areas within the counties impacted by DR-4558 and DR- 4569. 83 F IGURE 93:RECAPA REAS A ND FEMAIAM AJOR/S EVERE P ROPERTIES N ORTHERN CA Source: HUD, April 2022; FEMA; U.S. Census Bureau, ESRI 84 F IGURE 94:RECAPA REAS A ND FEMAIAM AJOR/S EVERE P ROPERTIES S OUTHERN CA Source: HUD, April 2022; FEMA; U.S. Census Bureau, ESRI Poverty Rate People living in poverty are disproportionately affected bydisasters.People in povertyaremore likely to be exposed to disasters due to a higherlikelihood to live in riskier areasdisaster risk and a history of redlining nonwhite, lower income populations to high-riskareas makes homes in riskier areas more accessible and less expensive for people in poverty. People in poverty are also more vulnerable to the long-term economic impacts of disasters, as they lack the resources 37 andwealth recoverquicklyfrom the impacts of disaster. Of the counties impacted byDR-4558and 4569, Butte, Fresno, Madera,Trinity and Tulare have the highest poverty rates,withmore than 19 percent of the population living in poverty.San Mateo, Santa Clara, and Napa have the lowest poverty rates,withless than 8 percent of the 37 StéphaneHallegatteet alFrom Poverty to Disaster and Back: AReview of the LiteratureEconomics of Disasters and Climate Change4, no. 1 (April 24, 2020): pp. 223-247,https://doi.org/10.1007/s41885-020-00060-5. 85 population living in poverty. In total, the disaster impactedover 3,000,000 people living in poverty across all impacted counties. F IGURE 95:4558P OVERTY R ATE B Y C OUNTY CountyTotalBelow poverty levelPercent below poverty level Butte220,09141,97419.1% Lake63,15711,75318.6% Lassen21,0102,83013.5% Mendocino85,68415,25117.8% Monterey 416,28454,39313.1% Napa136,36010,6147.8% San Mateo761,22651,0856.7% Santa Clara1,896,320142,5347.5% Santa Cruz262,22434,41913.1% Solano430,78041,1219.5% Sonoma492,49045,4189.2% Stanislaus538,64381,41515.1% Trinity12,4632,37219.0% Tulare456,186108,51223.8% Yolo209,22239,91919.1% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates F IGURE 96:4569P OVERTY R ATE BY C OUNTY CountyTotalBelow poverty levelPercent below poverty level Fresno968,001218,25422.5% Los Angeles9,928,7731,480,44614.9% Madera146,83729,27319.9% Mendocino85,68415,25117.8% Napa136,36010,6147.8% San Bernadino2,091,206333,61316.0% San Diego3,234,305374,78711.6% Shasta176,27429,42316.7% Siskiyou43,0748,10218.8% Sonoma492,49045,4189.2% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 86 F IGURE 97:P OVERTY R ATE M AP N ORTHERN CA Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 87 F IGURE 98:P OVERTY R ATE M AP S OUTHERN CA Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates Housing Tenure AHarvard Universityposited that renters are uniquely vulnerable to climate change and related disasters because renters receive less assistance after disasters than homeowners. The study citeda 2019 HUD analysis of CDBG- DR-funded recovery examples,which showed that only an eighth of housing activities funding went to affordable rental construction or rental assistance.They also found that renter ster risks, and 38 adequate insurance cover.A 2017 survey showed that nearly 40 percent of renters did not have the funds necessary to evacuate in a disaster-more than three times the percent of 39 homeowners. 38 https://www.jchs.harvard.edu/americas-rental-housing-2022. 39 Ibid. 88 Every county impactedby the 2020disasters is an owner-occupied majority county except for Los Angeles. At the same time, population, with the most renter-occupied housing units inButte, Mendocino, Monterey, Santa Clara, Tulare, Fresno, Los Angeles, San Bernadino, and San Diego which all have more than 40 percent renter-occupied housing units. F IGURE 99:4558H OUSING T ENURE BY C OUNTY CountyOwner-occupied housing unitsRenter-occupied housing units Butte59.0%41.0% Lake66.4%33.6% Lassen67.6%32.4% Mendocino59.9%40.1% Monterey 51.0%49.0% Napa64.2%35.8% San Mateo60.2%39.8% Santa Clara56.4%43.6% Santa Cruz60.1%39.9% Solano61.5%38.5% Sonoma61.5%38.5% Stanislaus57.8%42.2% Trinity68.9%31.1% Tulare57.1%42.9% Yolo51.6%48.4% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates F IGURE 100:4569H OUSING T ENURE B Y C OUNTY CountyOwner-occupied housing unitsRenter-occupied housing units Fresno53.3%46.7% Los Angeles45.8%54.2% Madera64.1%35.9% Mendocino59.9%40.1% Napa64.2%35.8% San Bernadino59.8%40.2% San Diego 53.3%46.7% Shasta64.0%36.0% Siskiyou65.0%35.0% Sonoma61.5%38.5% Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 89 Median Housing Value After disasters, areasthat were affected byor adjacent to disaster incidentsoftenexperiencea 40 statistically significant decline inhousing value.The table below established the median housing values in impacted counties before the wildfires of 2020. Thepre-2020median house values for disaster-impactedcounties range from around $200,000 (Lake, Lassen, Tulare, Fresno, Madera, Shasta) to a high range of$984,000 for Santa Clara and $1,089,400 for San Mateo County. F IGURE 101:4558M EDIAN H OUSE V ALUE O WNER O CCUPIED H OUSING CountyMedianValue Butte$271,700 Lake$219,400 Lassen$203,000 Mendocino$377,500 Monterey $516,600 Napa$635,900 San Mateo$1,089,400 Santa Clara$984,000 Santa Cruz$756,600 Solano$406,900 Sonoma$609,600 Stanislaus$291,600 Trinity$287,700 Tulare$205,000 Yolo$424,900 Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates F IGURE 102:4569M EDIAN H OUSE V ALUE O WNER O CCUPIED H OUSING CountyMedian valueowner occupied housing Fresno$255,000 Los Angeles$583,200 Madera$251,200 Mendocino$377,500 Napa$635,900 San Bernadino$328,200 San Diego $563,700 Shasta$252,300 Siskiyou$198,900 40 Journal of Forest Economics33 (December 2018): pp. 1-7, https://doi.org/10.1016/j.jfe.2018.09.002. 90 Sonoma$609,600 Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates Gross Rent The median gross rent for disaster impacted counties also exhibitsa wide variation,ranging fromthelowest pointof $799 gross rent per monthin Tulareand $856 gross rent per month in Siskiyou to $2,268 gross rent per month in Santa Clara and $2,316 gross rent per month in San Mateo. F IGURE 103:4558M EDIAN G ROSS R ENT CountyMedian gross rent Butte$ 1,060 Lake$ 978 Lassen$ 956 Mendocino$ 1,146 Monterey $ 1,495 Napa$ 1,700 San Mateo$ 2,316 Santa Clara$ 2,268 Santa Cruz$ 1,717 Solano$ 1,592 Sonoma$ 1,621 Stanislaus$ 1,155 Trinity$ 799 Tulare$ 942 Yolo$ 1,324 Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates F IGURE 104:4569M EDIAN G ROSS R ENT CountyMedian gross rent Fresno$ 998 Los Angeles$ 1,460 Madera$ 1,014 Mendocino$ 1,146 Napa$ 1,700 SanBernadino$ 1,283 San Diego $ 1,658 Shasta$ 1,039 Siskiyou$ 856 Sonoma$ 1,621 Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 91 Educational Attainment the educational attainment and their disaster preparedness level. The studyfound that individuals withpost-secondary educational attainment were more likely tohavean emergency plan and were more informed onwhere to 41 find criticalinformation duringemergencies. The tables below show that alldisaster impacted counties have a significant portion of the population, at least 15,000 people, that have less than a high school degree and at least 40,000 peopleineach county that have no collegeeducation. F IGURE 105:4558E DUCATIONAL A TTAINMENT LessHigh school Some Bachelor's Graduate or than high graduate college or County degreeprofessional degree school(includesassociate's graduateequivalency)degree Butte25,12829,27431,24552,40568,784 Lake22,48326,31230,72754,86152,500 Lassen30,44840,23342,23649,32762,500 Mendocino22,04430,63830,90635,42950,820 Monterey 22,31131,10737,64057,55081,640 Napa26,69134,41844,61664,99783,228 San Mateo27,67436,74747,88879,080120,894 Santa Clara27,72735,85047,30086,004124,577 Santa Cruz23,09730,94441,04461,66578,491 Solano27,13038,25145,58662,57380,063 Sonoma27,02034,01042,39057,26671,176 Stanislaus70,345100,758111,72542,77618,022 Trinity15,98725,66831,17336,11126,563 Tulare19,46529,45533,50154,78578,869 Yolo17,17923,08634,47027,56225,289 Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates F IGURE 106:4569E DUCATIONAL A TTAINMENT Less than High school Some Bachelor's Graduate or high graduate college or County degreeprofessional degree school(includesassociate's graduateequivalency)degree Fresno20,19728,74334,38853,79878,501 41 Journal of Emergency Management9, no. 4 (January 2011): pp. 45-52, https://doi.org/10.5055/jem.2011.0066. 92 Los Angeles22,76530,41437,64257,01681,014 Madera20,69930,32632,31157,13064,677 Mendocino22,04430,63830,90635,42950,820 Napa26,69134,41844,61664,99783,228 San24,81631,58737,96154,34175,361 Bernadino San Diego 23,60831,61538,81661,99085,114 Shasta25,10831,07032,58849,79564,519 Siskiyou19,38428,64628,49139,39954,320 Sonoma27,02034,01042,39057,26671,176 Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates F IGURE 107:P OPULATION W ITHOUT AC OLLEGE D EGREE M AP N ORTHERN CA Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates 93 F IGURE 108:P OPULATION W ITHOUT AC OLLEGE D EGREE M AP S OUTHERN CA Source: U.S. Census Bureau, 2015-2019 American Community Survey, 5-Year Estimates Impacts on Low-and Moderate-Income(LMI)Populations Proposed disaster recovery and mitigation activitiesmust prioritize the protection of low-and- moderateincome (LMI) persons and meet the overall LMI benefit national objective. Seventy percentofCDBG-DRfunds must be spent to benefit LMI persons and 80 percent of the total allocation must be expended to benefitpopulations within the MID. As defined by HUD, LMI households earn a gross household income of under 80 percent of Area Median Income (AMI), adjusted for family size.Lake, Tulare,and Los Angeles countiescontain LMIpopulations accounting for morethan 51%of the total county populations.While the rest of the countiesare not considered LMI designated counties, they dohave significant LMI populations that make up at least 38 percent of the total population. 94 F IGURE 109:4558LMIP OPULATION D ATA B Y C OUNTY Total 2015 Low-to-Total 2015 Low-to- 2011-2015 Percentage Low-to- County Moderate Income moderate Universe Moderate Income Estimate PersonsPopulation Butte99,833217,09546.0% Lake32,50063,17551.4% Lassen8,35521,72038.5% Mendocino39,09085,22545.9% Monterey200,300408,77549.0% Napa56,784135,72041.8% San Mateo339,795738,96546.0% Santa Clara753,4891,834,32041.1% Santa Cruz128,945257,45050.1% Solano163,204414,76039.4% Sonoma199,775486,14541.1% Stanislaus108,434247,32543.84% Trinity6,36013,05548.7% Tulare240,338448,08353.6% Yolo100,465199,24550.4% Source: HUD 2011 2015 LMI F IGURE 110:4569LMIP OPULATION D ATA B Y C OUNTY Total 2015 Low-to-Total 2015 Low-to- 2011-2015 Percentage Low- County Moderate Income Moderate Universe to-Moderate Income Estimate PersonsPopulation Fresno462,085938,78049.2% Los Angeles5,526,1549,863,02556.0% Madera69,150144,37547.9% Mendocino39,09085,22545.9% Napa56,784135,72041.8% 894,8682,043,42543.8% San San Diego1,494,8103,134,09047.7% Shasta75,015175,92542.6% Siskiyou21,68043,27050.1% Sonoma199,775486,14541.1% Source: HUD 2011 2015 LMI 95 F IGURE 111:L OW-A ND M ODERATE-I NCOME P OPULATION MAPN ORTHERN CA Source: HUD 2011 2015 LMI 96 F IGURE 112:L OW-AND M ODERATE-I NCOME P OPULATION M AP S OUTHERN CA Source: HUD 2011 2015 LMI HUDIncome Limits Proposed disaster recovery andmitigation programs and projects must prioritize the protection of low-and-moderateincome (LMI) persons and meet the overall LMI benefit national objective. Seventypercent ofCDBG-DRfunds must be spent to benefit LMI persons and80 percent must be expended to benefit the MID. As defined by HUD, LMI households earn a gross household 42 income of under 80 percent of Area Median Income (AMI), adjusted for family size.Statewide median income as of 2021in California is $90,100; a household of four is considered LMI if 43 earning a gross income of $64,850or less. 42 U.S. Department of Housing and Urban Development Office of Planning and Community Development. Laws and Regulations:Low-and Moderate-Income Definitions under the CDBG Program. Available at: https://www.huduser.gov/portal/datasets/cdbg-income-limits.html 43 fornia Code of Regulations (Thomson Reuters Westlaw, 2021), https://bit.ly/3EXCQDG. 97 F IGURE 113:S TATEWIDE I NCOME L IMITS Household 1 person2 persons3 persons4 persons5 persons6 persons7 persons8 persons Size Extremely Low $18,900$21,600$24,350$27,050$29,200$31,350$33,500$35,700 Income (30%) Low Income $31,550$36,050$40,550$45,050$48,650$52,250$55,850$59,450 (50%) Low Income $50,450$57,650$64,850$72,100$77,850$83,600$89,400$95,150 (80%) Source: 2021 HUD Income Limits The following figures provide a breakdown of the 2021LMI HUD income limits bycounties impacted byDR-4558 and DR-4569. F IGURE 114:4558I NCOME L IMITS 1245678 3 persons County personpersonspersonspersonspersonspersonspersons Butte$39,050$44,600$50,200$55,750$60,250$64,700$69,150$73,600 Fresno$39,050$44,600$50,200$55,750$60,250$64,700$69,150$73,600 Lake$39,050$44,600$50,200$55,750$60,250$64,700$69,150$73,600 Lassen$40,450$46,200$52,000$57,750$62,400$67,000$71,650$76,250 Los Angeles$66,250$75,700$85,150$94,600$102,200$109,750$117,350$124,900 Madera$39,050$44,600$50,200$55,750$60,250$64,700$69,150$73,600 Mendocino$40,500$46,300$52,100$57,850$62,500$67,150$71,750$76,400 Monterey $56,950$65,100$73,250$81,350$87,900$94,400$100,900$107,400 Napa$63,050$72,050$81,050$90,050$97,300$104,500$111,700$118,900 San Bernadino$44,250$50,600$56,900$63,200$68,300$73,350$78,400$83,450 San Diego $67,900$77,600$87,300$97,000$104,800$112,550$120,300$128,050 San Mateo$102,450$117,100$131,750$146,350$158,100$169,800$181,500$193,200 Santa Clara$82,450$94,200$106,000$117,750$127,200$136,600$146,050$155,450 Santa Cruz$78,050$89,200$100,350$111,500$120,450$129,350$138,300$147,200 Shasta$39,800$45,450$51,150$56,800$61,350$65,900$70,450$5,000 Siskiyou$39,050$44,600$50,200$55,750$60,250$64,700$69,150$73,600 Solano$54,350$62,100$69,850$77,600$83,850$90,050$96,250$102,450 Sonoma$65,150$74,450$83,750$93,050$100,500$107,950$115,400$122,850 Stanislaus$39,950 $45,650 $51,350 $57,050 $61,650 $66,200 $70,750 $75,350 Trinity$39,050 $44,600 $50,200 $55,750 $60,250 $64,700 $69,150 $73,600 Tulare$39,050 $44,600 $50,200 $55,750 $60,250 $64,700 $69,150 $73,600 Yolo$49,650$56,750$63,850$70,900$76,600$82,250$87,950$93,600 Source: 2021 HUD Income Limits 98 F IGURE 115:4569HUDI NCOME L IMITS 12345678 County personpersonspersonspersonspersonspersonspersonspersons Fresno$39,050$44,600$50,200$55,750$60,250$64,700$69,150$73,600 Los Angeles$66,250$75,700$85,150$94,600$102,200$109,750$117,350$124,900 Madera$39,050$44,600$50,200$55,750$60,250$64,700$69,150$73,600 Mendocino$40,500$46,300$52,100$ 57,850$62,500$67,150$71,750$76,400 Napa$63,050$72,050$81,050$90,050$97,300$104,500$111,700$118,900 San Bernadino$44,250$50,600$56,900$63,200$68,300$73,350$78,400$83,450 San Diego$67,900$77,600$87,300$97,000$104,800$112,550$120,300$128,050 Shasta$39,800$45,450$51,150$56,800$61,350$65,900$70,450$75,000 Siskiyou$39,050$44,600$50,200$55,750$60,250$64,700$69,150$73,600 Sonoma$65,150$74,450$83,750$93,050$100,500$107,950$115,400$122,850 Source: 2021 HUD Income Limits Impact on Housing Most Impacted and Distressed Areas The total claims filed within the Most Impacted and Distressed areas represented 55 percent of the claims in the MID Counties and 20 percent of the claims in the MID zip codes.MID counties also represented 58 percent of total claims resulting in total loss and MID zip codes represent 38 percent of total claims resulting in total loss. The sum of the losses incurred in the MID Counties was $2,151,660,054 or 58 percent of the total losses incurred, and the sum of losses incurred in the MID zip codes was $1,805,900,609 or 49 percent of total losses incurred. Total losses were highest in Santa Cruz Countyat about $800 million, and the94574 zip code at about $476 million. The 96047incurred the lowest amount of direct loss at $36million. F IGURE 116:MIDR ESIDENTIAL I NSURANCE C LAIMS FOR DR-4558 AND DR-4569 Sum of Sum of Number of CountiesNumber of ClaimsSum of Losses Incurred Claims Resulting in Total Loss MID Counties Butte1,151511$275,660,707 Napa2,240393$785,190,738 Santa Cruz5,631702$896,012,754 Los Angeles8,13767$166,775,590 99 Siskiyou10668$28,020,265 17,2651,741$2,151,660,054 Most Impacted and Distressed Total for Counties MID Zip Codes 93602407156$100,234,661 93664326101$74,616,120 94558521172$157,694,393 94574706144$476,797,756 9540430777$113,990,526 954092,837160$385,546,610 9544824160$95,379,272 95688894213$365,367,329 9604711747$36,273,942 Most Impacted and Distressed 6,3561,130$1,805,900,609 Total for ZipCodes K.Mitigation Needs Assessment 1.Overview The geographic breadth, unprecedented severity, and diversity of communities impacted by the 2020 wildfires creates unique challenges to recovery, as well as opportunities to integrate The Federal Register Notice sets forth new requirements that grantees use 15 percent of their total allocation to fund mitigation activities and requires that grantees include a mitigation needs assessment in the Action Plan that clearly illustrates the connections between impactsof current and future hazards,mitigationneeds, and proposed mitigation activities. To address this challenge, this Action Plan includes: A Mitigation Needs Assessment in this plan in addition to a disaster recovery-focused unmet needsassessment Proposed mitigation activities that clearlytie back to the 2020 disasters and the Mitigation Needs Assessment Proposed eligible activities that do not have a tie-back, but are tied to the Mitigation Needs Assessment and meet the HUD definition of mitigation Descriptions of how mitigation measures have been incorporated into recovery-related construction projects 100 Mitigation activities are those that increase resilience to future disasters and reduce or eliminate the long-term risk of loss of life, injury, damage to and loss of property, and suffering and hardship. HCD conducted the followingrisk-based assessment of current and future hazards to inform the use of the CDBG-DR mitigation set-aside.Ensuring continuous operation of indispensable services, whichinclude critical business and government functions, services critical to health and human safety, and economic security for all community members, is vital toassessing and planning for disaster mitigation needs. 2.Mitigation Funding Background On October 29, 2021, the U.S. Department of Housing and Urban Development (HUD) allocated over $2 billion in Community Development Block Grant Disaster Recovery (CDBG DR) funds appropriated by the Disaster Relief Supplemental Appropriations Act, 2022 (Public Law 11743). HUD allocated $231,203,000 of that appropriation to the State of California for disaster recovery and mitigation activities as a result of the 2020 wildfires (DR-4558 and DR- DR mitigation set- HUD provided Federal Register Notice 6303N01 (the Notice) on February 3, 2022, as framework for CDBG-DR and MIT programming. The Notice provides definitions of mitigation activities, expenditure requirements, and funding timelines separate from the CDBG-DR allocation provided for thesame disaster events. Although Public Law 11743 tied the disaster recovery portion of the total allocation to the State of California to the 2020 wildfires, themitigation set-asideintended to focus on preventative actions. The Notice requires that MITfunds respond to risks, based on a risk- based Mitigation Needs Assessment. In the development of this Action Plan, HCD has reviewed and incorporated the following resources to enhance the Mitigation Needs Assessment. Mitigation Plan (SHMP) FEMA Local Mitigation Planning Handbook Department of Homeland Security (DHS) Office of Infrastructure Protection, National Association of Counties, Improving Lifelines Brief, U.S. Forest Service (USFS) wildland fire resources, National Interagency Coordination Center for coordinating the mobilization of resources for wildland fire, and HUD Community Planning and Development (CPD) Mapping tool MID Local Hazard Mitigation Plans (LHMPs) The Mitigation Needs Assessment is updated to consider the California SHMP and LHMPs as they relate to the MIDsfor the 2020wildfires that occurred from August 14 September 26 (DR- 4558) and from September 4 November 17 (DR 4569). 101 F IGURE 117:2020D ECLARED D ISASTERS AND M OST I MPACTED AND D ISTRESSED A REAS Source: HUD, ESRI 3.Method The Mitigation Needs Assessment builds ondocuments developed by the State of California to address state and local mitigation efforts including: the SHMP, the LHMPs, data collected from county resources, and the local stakeholder knowledge in disaster-impacted areas. The Mitigation Needs Assessment captures a point in time for the mitigation needs of the DR-4558 and DR-4569 impacted areasandresponds to requirements set forth in the FRN. If new risks are identified, or risks identified in this Action Plan are addressed, the state may update the Mitigation Needs Assessment through a non-substantial or substantial Action Plan Amendment. The following section provides a risk-based Mitigation Needs Assessment that identifies and analyzes current and future disasters. 102 4.State Hazard Mitigation Plan Theserves as the foundation for the Mitigation Needs Assessment. D Services (Cal OES)and approved by FEMA in 2018, the SHMP is a federallymandated documentthat identifies hazards that could potentially affect California and lays out a state-wide 1 planto reduce loss of life and propertythat may be caused by a disaster.The SHMP is currently being updated and an update is expected by 2023. 2 Cal OES led the development of the 2018 SHMP pursuant to 44 CFR part 201.4.The State Hazard Mitigation Team (SHMT), comprisedof 800 members from public, private, local, tribal, state, and federal agencies, and over 300 organizations, drafted the SHMP using analysis and The development of this Action Plan, as well as all Californiaaction plans and amendments since 2018, were directly informed by findings and risk assessment produced by the 2018 SHMP process. CDBG-DRfundsfor activities proposed in this plan. risks. As of May 2022,the 2018 SHMP remains the guiding document for the development of this Mitigation Needs Assessment. Cal OES is in the early stages of updating the SHMP, with the goal of publishing for public review by December 2022 and approval and adoption by September 23, 2023. Cal OES and is convening working group meetings with partner state agencies to review and update relevant sections of the plan, and to document any changes from the 2018 publication. The2018 SHMParranged risk assessments into groupings of hazards with similar characteristics. While the SHMP addresses ahost of disasterswith potential to impact the state, s. Thesethree hazardshavehistorically caused the greatest human, property, and/or monetary losses, as well as economic, social, and environmental disruptions within the state. They also have the greatest potential to cause significant losses and disruptions in the future. Past major disaster events have led to the adoption of statewide plans for mitigation of these hazards, including the California Earthquake Loss Reduction Plan, State Flood Hazard Mitigation Plan, and California Fire Plan. As a result of the frequency, 3 main hazards of concern, including the findings of the 2018 SHMP. For example, earthquake, while still considered a primary hazard, is grouped with related geologic hazards including landslides and volcanoes. Flooding is still considered a primary hazard, but the new flood hazards also include sections on other types of flood hazards, including coastal flooding, tsunami, levee failure, and dam safety. The third primary hazard, fire, includes both wildfire and structural fires. During the most recent SHMP update, the SHMT, made the decision with the Cal OES SHMP Coordinator to update the hazard organizationstructure using primary hazards, hazard grouping, and related secondary hazards. 103 F IGURE 118:S TATE OF C ALIFORNIA P RIMARY H AZARD G ROUPING HazardHazard Grouping Earthquake -Earthquakes represent the most Landslide and Other Earth Movement destructive source of hazards, risk, and Volcano vulnerability, both in terms of recent state history and the probability of future destruction of greater magnitudes. Flood -Floods represent the second most Riverine, Stream and Alluvial Flood destructive source of hazard, vulnerability, and Sea-Level Rise, Coastal Flooding, and risk, both in terms of recent state history and the Erosion probability of future destruction at greater Tsunami andSeiche magnitudes than previously recorded. Levee Failure and Safety Dam Failure and Safety Fire-California is recognized as one of the most Wildfire fire-prone natural landscapes in the world. Urban Structural Fires Source: CA SHMP Section 1.2 -page 8 5.Primary Hazard Rankings -2020Impacted Counties The relative rank of the three main hazards as derived from review of California-approved LHMPs as of April 2022is shown in Figures 4 and 5. All counties have risk for the primary hazards of flood, fire, and earthquake, as these hazards are neither localized nor limited to any one region and have large area impact when they do occur. Counties with proximity to major fault lines or that contain areas with large amounts of biomass will have one or more of the primary hazards with a high ranking. In Figure 4, Butte County has a high ranking for flood and fire risks because its geography includes the Sacramento River aswell as large forested areas. Butte County also contains a minor active fault line that covers a small area, but it is not as likely to cause the same amount of damage as a fire or flood, thus dropping the relative ranking for earthquake to moderate. Figure 5 lists the higher ranked primary hazards by county, demonstrating that these are also not localized hazards. For example,afire burning in Sonoma 4 may spread and impact parts of Napa or Mendocino counties as well. 5 F IGURE 119:P RIMARY H AZARD R ANKING,BY 2020I MPACTED C OUNTIES CountyRankingHazard Butte Flood High Fire Butte Moderate to lowEarthquake FresnoFlood High Fire Fresno Moderate to lowEarthquake LakeEarthquake High Flood Fire 104 Lassen*no data as of High April 2022 Lassen Moderate to low*no data as of April 2022 Los AngelesEarthquake High Flood Fire MaderaHighFire MaderaEarthquake Moderate to Low Flood MendocinoHighEarthquake MendocinoFlood Moderate to Low Fire MontereyEarthquake High Fire MontereyModerate to Low NapaHighFire NapaModerate to LowEarthquake Flood San Bernadino Earthquake HighFlood Fire San DiegoHigh*no data as of April 2022 San DiegoModerate to Low*no data as of April 2022 San MateoHighEarthquake San MateoModerate to LowFlood Fire Santa ClaraEarthquake High Flood Santa ClaraModerate to LowFire Santa CruzEarthquake High Flood Fire ShastaEarthquake High Flood Fire SiskiyouFlood High Fire SiskiyouModerate to LowEarthquake SolanoEarthquake High Flood Fire SonomaEarthquake High Flood Fire StanislausHigh*no data as of April 2022 StanislausModerate to Low*no data as of April 2022 TrinityHighFire Earthquake Moderate to Low Flood YoloHighFire 105 Flood YoloModerate or LowEarthquake F IGURE 120:2020I MPACTED C OUNTIES BY S TATE OF C ALIFORNIA P RIMARY H AZARDS HazardRankingCounties Lake, Los Angeles, Mendocino, Monterey, San EarthquakeHigh Bernardino, San Mateo, Santa Clara, Santa Cruz, Shasta EarthquakeModerate to Low Butte, Madera, Napa, Siskiyou, Trinity, Yolo Earthquake *No Data as of May 2017Lassen, San Diego, Stanislaus Butte, Fresno, Lake, Los Angeles, San FloodHigh Bernardino, Santa Cruz, Shasta, Siskiyou, Solano, Sonoma, Yolo Flood Madera, Mendocino, Napa, San Mateo, Santa Moderate to Low Clara, Trinity Flood *No Data as of May 2017Lassen, San Diego, Stanislaus Butte, Fresno, Lake, Los Angeles, Madera, FireHigh Monterey, Napa, San Bernardino, Santa Cruz, Shasta, Siskiyou, Solano, Sonoma, Trinity, Yolo FireModerate to Low Mendocino, San Mateo, Santa Clara Fire *No Data as of May 2017Lassen, San Diego, Stanislaus In addition to the three primary hazards, the 2018 SHMP identifies other hazards of concern that impact various regions of the State of California. These other hazards typically are characterized by more isolated, localized, and/or infrequent disaster incidents. The figure below groups secondary hazards into three broad categories with two of the three being human- caused rather than natural disasters. S TATE OF C ALIFORNIA O THER H AZARDS OF C ONCERN F IGURE 121:S TATE OF C ALIFORNIA O THER H AZARDS OF C ONCERN Other Hazards Category Secondary Hazards Name Agricultural and Silvicultural Pests and Diseases Air Pollution Aquatic Invasive Species Avalanches Other Climate and Drought and Water Shortages Weather-Influenced HazardsEnergy Shortage and Energy Resiliency Epidemic/Pandemic/Vector Borne Disease Extreme Heat Freeze Severe Weather and Storms Tree Mortality 106 Hazardous Material Release Oil Spills Sociotechnical/ Natural Gas Pipeline Hazards Technological Hazards Radiological Accidents Train Accidents Resulting in Explosions and/or Toxic Releases Well Stimulation and Hydraulic Fracturing Hazards Terrorism Threat and Disturbance Cyber Threats Hazards Civil Disorder in California The 2018 SHMP thoroughly categorizes each identified hazard, inclusive of a description, extent, location, hazard history, changing future conditions, impact, future probability, and does not reference all sections of the SHMP, but the full final plan is available on the Cal OES website. The State of California has a total of 451 jurisdictions with adopted and FEMA-approved LHMPs. Cal OES Hazard Mitigation Planning staff administers the LHMP program for the state. The figure below provides information about the approval and expiration dates for LHMPs in the counties impacted by the 2020 wildfires. F IGURE 122:LHMP S Y EAR A PPROVED AND Y EAR E XPIRED Plan Plan Approved Plan Expiration Butte County Local Hazard Mitigation Plan Update October 2019 2024 City of Clearlake Local Hazard Mitigation Plan Update June 2019 2024 Colusa County Local Hazard Mitigation Plan Update 2018 2023 Fresno County Multi-Hazard Mitigation Plan 2018 2023 Glenn County Multi-Jurisdiction Hazard Mitigation Plan 2018 2023 Lake County Hazard Mitigation Plan Update 2018 2023 Lassen County Multi-Jurisdictional Hazard Mitigation Plan 2018 2023 Update Los Angeles County All-Hazard Mitigation Plan Update ongoing N/A Madera County Local Hazard Mitigation Plan Update 2017 2022 Monterey County Hazard Mitigation PlanUpdate Update ongoing TBD Mendocino County Multi-Hazard Mitigation Plan 2014 2019 Napa County Operational Area Hazard Mitigation Plan Update 2020 2025 Nevada County Local Hazard Mitigation Plan Update 2017 2022 Orange County Local Hazard Mitigation Plan Update 2019 2024 San Bernadino County Multi-Jurisdictional Hazard Mitigation Update ongoing TBD Plan San Diego County Multi-Jurisdictional Hazard Mitigation Plan 2018 2023 Update San Mateo Multijurisdictional Local Hazard Mitigation Plan Update ongoing TBD Santa Barbara County Multi-Jurisdictional Hazard Mitigation 2017 2022 Plan Update Santa Clara County Operational Area Hazard Mitigation Plan 2017 2022 Santa Cruz Local Hazard Mitigation Plan 2021 2026 Shasta County and City of Anderson Multi-Jurisdictional Hazard 2017 2022 Mitigation Plan Siskiyou County Hazard Mitigation Plan 2019 2024 Solano County Multi-Jurisdictional Hazard Mitigation Plan Update ongoing TBD 107 Sonoma County Hazard Mitigation Plan Update 2016(Update currently 2021 underway) Trinity County Hazard Mitigation Plan September 2016 2021 Tulare County Hazard Mitigation Plan 2018 2023 Ventura County Multi-Hazard Mitigation Plan Update 2015 2020 Yuba County Multi-Jurisdictional Local Hazard Mitigation Plan 2015(Update currently 2020 Update underway) 6. the risks and mitigation activities identified in the SHMP. Flooding and fire occur the most often. Most recently fire has emerged as an annual threat roughly comparable to floods. Earthquakes, on the other hand, have a lower frequency but can result in extreme disaster events and 6 A review of the risks imposed by each primary hazard related to the MID informed the Mitigation Needs Assessment and provided focus for proposing mitigation activities. a.Earthquakes and Geologic Hazards Earthquakes represent the most destructive hazard, both in terms of recent state history and the probability of future destruction, inclusive of risk and vulnerability. In the disaster-impacted counties, earthquakes are identified as a high hazard for six counties, and four counties have identified earthquakes as a moderate to low hazard. b.Probability of Seismic Hazards Statewide Based on the most recent earthquake forecast model for California, the United States Geological Survey (USGS) and other scientists estimate a 72 percent probability that at least one earthquake of magnitude 6.7 or greater, capable of causing widespread damage, will strike the San Francisco Bay Area before 2044. For the Los Angeles region, the same model forecasts a 60 percent probability that an earthquake of magnitude 6.7 or greater will occur before 2044. The figure below demonstrates the risks of impacts and damages from earthquake shaking throughout California. The more intense estimates follow the major fault lines in the state, such as the San Andreas, showing which counties are most at risk for building and infrastructure damage from intense shaking. 108 F IGURE 123:E ARTHQUAKE S HAKING H AZARD A FFECTING B UILDINGS Source: Branum, D., R. Chen, M. Petersen and C. Wills. 2016. Earthquake Shaking Potential for California. California Geological Survey, United State Geological Survey. Available at https://www.conservation.ca.gov/cgs/Documents/MS_048.pdf The figure below, from the USGS Open File Report 2013-1165, shows the likelihood of an intense earthquake (6.7 magnitude or greater) across fault lines within the state. These two figures show the significance of earthquake risks and impacts to regions in California and the need for preparation and mitigation efforts to reduce the high probability of property and infrastructure damage during the next large earthquake or series of tremors. 109 F IGURE 124:P ROBABILITY OF E ARTHQUAKE M AGNITUDE 6.7 OR G REATER O CCURRING IN 30 YEARS,BY R EGION Source: Field, Edward H., Glenn Biasi, Peter Bird, et al. 2013. Uniform California Earthquake Rupture Forecast Version 3 The Time-Independent Model. U.S. Department of Interior and U.S. Geological Society. Available at: https://pubs.usgs.gov/of/2013/1165/pdf/ofr2013-1165.pdf c.Probability of Flood Hazards Statewide The Flood Insurance Rate Map (FIRM) designations identify components of the 500 year and 100-year floodplains. High concentrations of one percent annual chance flood hazard areas are shown throughout the Central Valley, especially in the Sacramento-San Joaquin Delta region, as well as in other inland regions. The figure below, produced by the California Department of Water Resources, shows the flood hazard areas through the state. The areas designated for one percent and five percent flood hazards align with major rivers and delta systems that run through the Central Valley and Sacramento regions, as well as other significant watersheds and reservoirs across the state. 110 F IGURE 125:F LOOD H AZARDS IN C ALIFORNIA Source: 2018 California State Hazard Mitigation Plan, Section 7.1, page 383 111 F IGURE 126:FEMAF LOOD I NSURANCE R ATE M AP Source: 2018 California State Hazard Mitigation Plan, Section 7.1, page 386 d.Climate Change and Flood Hazards Climate change impacts are already being felt throughout the State of California, including the disaster-impacted counties. Impacts are reflected in the reduction of precipitation in some regions and an increase in severity and frequency of flooding in other regions. Change in snowfall or rainfall patterns can also contribute to a severe increase in flooding events. Climate primary hazards. For example, larger and more frequent wildfires brought on by climate change 112 can reduce the ability of a landscape to retain rainfall, which often leads to flooding and mudflows. e.Wildfire Hazards Wildfire hazards arethe most prominent cause of damage and recovery efforts inCalifornia in recent years, as evidenced by a series of major disaster declarations and consistent fire incidentsacross the state since 2015. In 2017,California received two significant national disaster declarations for wildfires thattook place across Northern and Southern California over a span of approximately three months. DR- 4344 burned over 200,000 acres, destroying an estimated 7,050 parcels and 8,922 structures. Additionally, 41 lives were lost in the Central LNU Complex fire in Napa and Sonoma Counties. DR-4353 burned over 300,000 acres in Southern California and destroyed over 1,000 residences. The fires also impacted electricity, gas, cellular telephone, internet, drainage, 7 sewer, and water services.The damages caused by DR-4344 and DR-4353 weredirectly As described in earlier sections, the2020 California wildfire season sparkednearly 9,000fires thatburnedmore than 4% of the state's roughly 100 million acres of land, making 2020 the 44 largest wildfire season recorded in California's modern history. The disasters of 2020 were followed closely by yet another historic fire season in 2021, when ongoingdrought, extreme heat, reduced snowpack, and vastly diminished tree mass ignited an unusually early wildfire season in California. The President issued a major disaster declaration for Northern California in August of 2021,and by the end of season,approximately 8,800 fires 45 had burned roughly 2.5 million acres of the state. This trend shows no sign of slowing. According to broad scientific consensus, the frequency and severity of wildfires in North America are increasing due to climate change, which continues to 46 drive hotter and drier fire seasons in the western United States. f.Probability of Fire Hazards Statewide The SHMP identifies flammable expanses of brush, diseased timberland, overstocked forests, hot and dry summers, extreme topography, intense fire weather and wind events, summer t.Repeated destructive fire events and intense fire seasonsfrom 2015 through present day have reinforced the need to implement robust mitigation efforts. The current drought in California started in early 2020, following a five-year state-wide drought from 2012 to 2017. By the end of 2020, nearly 75% of the state was in severe drought conditions or worse 44 k). 45 Ibid. 46 Climate Change Is Central to California's WildfiresScientific American, October 29, 2020. 113 47 After a briefreprieve in the fall and winter of that year caused by heavy rain and snow, conditions improved, andas of February 2022, most of California is considered under severe and moderate drought conditions, with only 2% of the state in extreme drought. Continued drought conditionsare particularly troublesome when paired with the impacts of earlier droughts and wildfires on tree growth and recovery across millions of acres. Drought which, under healthy conditions, can serve as a bulwark and stabilizer against rapidly spreading fires. In December 2017, the U.S. Forest Service (USFS) and CAL FIRE announced that a total of 129 million trees died due to drought and bark beetles across 8,900,000 acres of the state. Ongoing droughtinhibited tree recovery, making forests vulnerable to bark beetles and increasing the wildfire risk for California communities. Under severe or long-term drought conditions, dead and dry trees and vegetation act as fuel for wildfires. As of April 2022, several fire-prone areas of the state are experiencing the driestspringmonths on record. According to 2022Fire Season Outlook, dry conditions and higher-than- average temperatures are expected to continue through theSpring andwill likelyresult in 48 moderate to extreme droughtfor most of the state by the summer. Meanwhile, anthropogenic factors such as ignitions, infrastructure, and development at the wildland-urbaninterface exposure to those hazards. Approximately 85 percent of all fire ignitions in California are the result of human activity, with the rest due to lightning. -recently updated FireLine Risk Report, which analyzes wildfire riskto residential structuresby examining principal factors like flammable vegetation, topography, fire response infrastructure, and wind patterns, shows that 2 million housing units15 percent of t totalare at high and extreme risk of wildfire. Another 1.6 million, or 12 percent, are at 49 moderate risk. CAL FIRE and the Office of the State Fire Marshal produce maps to show areas with significant fire hazards based on local fuels, terrain,weather, and other factors. These maps impact requirements for clearance and property development standards and new construction, as well as influence risk determinations on properties that are within Fire Hazard Severity Zones. Maps also include State Responsibility Areas that CAL FIRE oversees, and give a hazard score of moderate, high, and very-high based on based on a number of factors that influence fire 47 13, 2021), https://drought.ca.gov/media/2021/12/CA_Drought_Update_12-13-21.pdf. 48 https://bit.ly/3MCPZol. 49 October 13, 2021, https://www.verisk.com/insurance/visualize/verisk-2021-wildfire-risk-analysis-provides-updated- data-on-rising-threat/. 114 likelihood and fire behavior (i.e. fire history, fuel levels, terrain, and weather). Figure 11 shows the most recent Fire Hazard Severity Zones for state responsibility areas. F IGURE 127:F IRE H AZARD S EVERITY Z ONES IN S TATE R ESPONSIBILITY A REAS Source: State of California and the Department of Forestry and Fire Protection, 2007, https://osfm.fire.ca.gov/media/6636/fhszs_map.pdf 115 g.Wildfire Threat Areas According to the 2018 SHMP, fire threat is a combination of two factors, fire frequency, or likelihood of a given area burning and potential fire behavior. The map below highlights the extent of high, very high, and extreme wildfire threat areas across the state,including areas impacted by the 2020 fires. F IGURE 128:W ILDFIRE T HREAT A REAS Source: California Department of Forestry and Fire Protection, Fire and Resource Assessment Program, Fire Threat. 2019. Available at https://frap.fire.ca.gov/media/10315/firethreat_19_ada.pdf h.Climate Change and Wildfire Hazard While wildfires are caused and exacerbated by complex interacting factors, global climate change isdrivingthe conditions that increase the frequency and severity of major fire disasters like those in 2017, 2020, and 2021. Climate change alters wildfire hazards in frequency, size, and severity-often beyond the historic range-bylengthening thefireseason, drying vegetation, decreasing forest health, and altering ignition patterns. significant shifts in temperature, precipitation, flooding, anderosionin the state have all contributed to recent 116 record-breaking wildfire seasons.The average annual temperature in most of California rises 1- 2°Feach yearandis expected to rise 4.4°F5.8°F by mid-century and 5.6°F8.8°F by 2100. Consequently, warming air temperatures will increase moisture loss from soils, which will lead to drier seasonal conditions even if precipitation increases.on levels remain stable, 50 groundwater in the state,are projected to decline by more than 30% by 2050. The impact of climate change on wildfire hazards grewstarkly apparentas a series of escalating wildfire seasons pummeled the state over the last several years. The 2020 wildfireseasonwas the largest recordedseasoninmodern history andfeatured some of the most destructive single incidentson record, as fewer than40 of the nearly 10,000 firesaccounted the vast majority of burned acreage.The 2021 wildfire season included four of the 20 largest wildfires in history andmarks the first time that fire crossed the granite crest of the Sierra, 51 . Wildland fire also has secondary impacts, in the form of air pollution and soil erosion resulting in increased siltation in streams and lakes, or mudslides. Areas decimated by fire experience increases in runoff during rainstorms when vegetation is no longer available tostabilize absorbent soil.Resulting erosion contributes tomudslides in the immediate area, and rivers and lakesreceive displaces soil and debris asrunoffwashes downstream. Winds that feed fires also carry ash and smoke over large areas of the state, often creating hazardous breathing conditions that can aggravate respiratory conditions or be dangerous with prolonged exposure. projected up to a 77% increase in average area burned by wildfires and a 50% increase in the 52 frequency of fires exceeding 25,000 acres by 2100.Fortunately, theState has redoubled worsening fire seasons. i.Climate Change Climate change is related to changes in climatological conditions that result from increased greenhouse gas (GHG) concentrations in the atmosphere which are linked to an increase in average global temperature. According to the National Oceanic and Atmospheric Administration (NOAA) Earth System Research Laboratory Trends in Atmospheric Carbon Dioxide, monthly GHG levels now exceed 400 parts per million (ppm) for the first time in recorded history. Increased GHG emissions and global average temperature result in changes to the global climate shifts in seasonal temperature patterns, changes in precipitation amount, timing and location, sea-level rise, ocean acidification due to increased carbon dioxide (CO) absorption, 2 altered wind and storm event frequency, severity, and location. These climatological changes result in prolonged drought, increased coastal flooding and erosion, tree mortality, increase in 50 California, 2021), https://climateresilience.ca.gov/overview/impacts.html. 51 Ibid. 52 2018), https://climateassessment.ca.gov/. 117 average temperatures (more extreme heat days, fewer cold nights), shifts in the water cycle with less annual snow fall, and more snowmelt and rainwater running off sooner in the year. As a result, California continues to experience increased extreme weather events and hazards, most recent examples being heat waves, wildfires, droughts, and floods. Impacts from climate change are considered secondary hazards in the Mitigation Needs Assessment. Extreme temperatures and increased or decreased precipitation create the conditions for more intense fires, flooding, and landslides. These weather events have the potential to cause injuries or fatalities, environmental damage, property damage, infrastructure damage, and interruption of operations. Examples of specific types of impacts include softening of asphalt roads and warping of railroad rails, damage to roads, flooding of roadways, rail routes, and airports from extreme events, and interruptions to flight plans due to severe weather. As a result of the increase in climate augmented extreme weather events and hazards, California Executive Order S-03-05 created the California Climate Change Assessment Program. The program executes scientific assessments on the potential impacts of climate change in California and reports potential climate adaptation responses. The first assessment was completed and released in 2006 and concentrated on the effects of climate change on critical state resources including water supply, public health, agriculture, coastal areas, forestry, and electricity production/demand. The second assessment, released in 2009, provides estimates of the economic impacts of climate change on the state. The third assessment released in 2012 came as a result of requests for more information regarding vulnerability and adaptation options discussed in the 2009 California Adaptation Strategy. The cutting edge climateresearch. The fourth assessment seeks to provide improved vulnerability assessments based on more in-depth understandings of projected weather extremes, and reports on scientific results that can support action, especially if greenhouse gas emissions 14 continue to rise. The state must prepare for a changing climate and increased threat of frequent and extreme weather events. Verisk Analytics gauged the risk to residential properties in California and found about 15 percent of all housing units in the state have a high to extreme risk of wildfire damage. In seven counties, mostly in Northern California, more than 15 two- j.Environmental Hazards California has many manmade environmental hazards that effect human morbidity, mortality, and quality of life that can be magnified during disaster scenarios. These include pollution, hazardous wastecleanup sites, drinking water contaminants, etc. The maps below show pollution in percentile in comparison to nationwide pollution around the most impacted and distressed areas. Pollution burden includes both exposures to ozone concentrations, traffic, pesticides, PM2.5 concentrations, diesel PM emissions, drinking water contaminants, ead risk from housing, use of certain high-hazard, high volatility pesticides, and toxic releases from facilities.Black and Latino Californians both disproportionately reside in high pollution burden areas and are disproportionately impacted by high pollution burdens. Pollution not only leads to major health issues like asthma, cancer, low 118 birth weight, cardiovascular disease 53 ecosystem resources.The below maps show that Los Angeles is the MID with the most air th pollution with most of the southern part of the county in the nationwide top 30percentile for air pollution.The maps below also show the locations of superfund sites which are polluted locations in the United States requiring long term cleanup due to hazardous material contamination. F IGURE 129:A IR P OLLUTION MIDN ORTHERN CA Source: CalEnviroScreen 4.0, ESRI 53 Assessment, 2021), https://oehha.ca.gov/media/downloads/calenviroscreen/report/calenviroscreen40reportf2021.pdf. 119 F IGURE 130:A IR P OLLUTION MID-C ENTRAL CA Source: CalEnviroScreen 4.0, ESRI 120 F IGURE 131:A IR P OLLUTION MID-L OS A NGELES Source: CalEnviroScreen 4.0, ESRI The below maps outline cleanup sites in California. These can include superfund sites which are shown by location in each map but also . Superfund sites are contaminated sites in which the federal government is involved in the cleanup, while the less 54 risky brownfields usually have only tribal or state government involved in the cleanup. Proximity to superfund sites increases the prevalence of low-birth-weightchildren, liver disease, 55 elevated blood lead levels in children, and cognitive and behavioral problems in children.The maps below show that Siskiyou, Butte, and Los Angeles all have significant portions of the county exposed to cleanup sites. 54 https://19january2017snapshot.epa.gov/enforcement/types-contaminated-sites_.html. 55 121 F IGURE 132:E XPOSURE TO C LEANUP S ITES MIDN ORTHERN CA Source: CalEnviroScreen 4.0, ESRI 122 F IGURE 133:E XPOSURE TO C LEANUP S ITES MID-C ENTRAL CA Source: CalEnviroScreen 4.0, ESRI 123 F IGURE 134:E XPOSURE TO C LEANUP S ITES MID-L OS A NGELES Source: CalEnviroScreen 4.0, ESRI The maps below show drinking water contaminants in the Most Impacted and Distressed counties. Both drink water sources and quality vary around thestate, with low income and rural communities often being disproportionately exposed to contaminants in drinking water. Drinking water contamination often includes nitrate from fertilizer or animal waste that leeches into groundwater, perchlorate a groundwater contaminantthat effects thyroid hormone levels, arsenic a known carcinogen, lead from house pipes and fixtures, and other microbial 56 contaminations from poorly treated water.The maps below show that every Most Impacted th and Distressed County has a significant area that is in the top 30percentile of most drinking water contaminants. 56 Ibid. 124 F IGURE 135:D RINKING W ATER C ONTAMINANTS MIDN ORTHERN CA Source: CalEnviroScreen 4.0, ESRI 125 F IGURE 136:D RINKING W ATER C ONTAMINANTS MID-C ENTRAL CA Source: CalEnviroScreen 4.0, ESRI 126 F IGURE 137:D RINKING W ATER C ONTAMINANTS MID-L OS A NGELES Source: CalEnviroScreen 4.0, ESRI The below maps illustrate proximity to solid waste sites,operations, and facilities.Proximity to solid waste sites can increase the risks of air, water, and soil contamination as well as concerns about odors, vermin, and increased truck traffic. Although many newer sites are made to reduce the contamination risks, old, closedsites are monitored less frequently and can degrade the environment including leeching to nearby plants and animals. The maps below show that Siskiyou,Monterey, and Los Angeles all have more than 25 waste sites in one of the county census tracts. 127 F IGURE 138:S OLID W ASTE S ITES MIDN ORTHERN CA Source: CalEnviroScreen 4.0, ESRI 128 F IGURE 139:S OLID W ASTE S ITES MID-C ENTRAL CA Source: CalEnviroScreen 4.0, ESRI 129 F IGURE 140:S OLID W ASTE S ITES MID-L OS A NGELES Source: CalEnviroScreen 4.0, ESRI 130 k.California Responsibility Areas In California there are Local Responsibility Areas (LRA), Federal Responsibility Areas (FRA), and State Responsibility Areas (SRA), which are defined by legal and congressional jurisdictional boundaries. The figure below shows all three Responsibility Areas in the State of California by color coding. Within the responsibility areas are different agencies and 16 organizations charged with the task of protecting and defending designated areas. F IGURE 141:R ESPONSIBILITY A REAS BY A GENCY Source: California Department of Forestry and Fire Protection, 2017 131 The organizations include: United States Forest Service (USFS) -The mission of the USFS is to sustain the health, present and future generations. In meeting its mission, the USFS manages and provides wildland fire protection on 18 national forests in California covering almost 21 million acres. The Bureau of Land Management (BLM) -The mission of the BLM is to sustain the health, diversity, and productivity of the public lands for the use and enjoyment of present and future generations. In meeting its mission, the BLM manages and protects over 15 million acres in California and provides wildland fire protection on almost 14 million acres. The National Park Service (NPS) -The mission of the NPS is to preserve the natural and cultural resources and values of the national park system for the enjoyment, education, and inspiration of this and future generations. In meeting its mission, the NPS manages over 7.5 million acres in California. U.S Fish and Wildlife Service -The U.S. Fish and Wildlife Service, working with others, is responsible for conserving, protecting, and enhancing fish and wildlife and their habitats for the continuing benefit of the American people through federal programs relating to migratory birds, endangeredspecies, interjurisdictional fish and marine mammals, and inland sport fisheries. In meeting its mission, the FWS is responsible for managing 34 National Wildlife Refuges in California, covering about 465,000 acres. California Department of Forestry and Fire Protection (CAL FIRE)-CAL FIRE is responsible for the wildland fire protection system in the state. The Board of Forestry has the authority to determine State Responsibility Areas (SRA) for private lands. These are lands for which CAL FIRE has wildland fire protection responsibility. All non-federal lands not assigned to an SRA are by default LRA. As a result, wildfire protection in California (approximately 90 million acres) is divided almost equally among CAL FIRE, local government, and the federal government. The Bureau of Indian Affairs and Tribal Government (BIA)- mission is to enhance the quality of life, to promote economic opportunity, and to carry out the responsibility to protect and improve the trust assets of American Indians, Indian tribes and Alaska Natives. The BIA is responsible for wildland fire protection on the other 103 reservation and rancherias. The BIA provides protection for tribal trust lands in northern California, but contracts with CAL FIRE for the protection of scattered tribal trust lands in southern California. The following maps show the BIA recognized tribal governments in Northern and Southern California. 132 F IGURE 142:BIAL AND A REA R EPRESENTATIONS N ORTHERN CA Source: U.S. Department of the Interior Indian Affairs, https://biamaps.doi.gov/bogs/datadownload.html 133 F IGURE 143:BIAL AND A REA R EPRESENTATIONS S OUTHERN CA Source: U.S. Department of the Interior Indian Affairs, https://biamaps.doi.gov/bogs/datadownload.html 7.Local Hazard Mitigation Plans Local Hazard Mitigation Plans (LHMPs)provide critical hazard and risk information for each county in the state as well as actionable and localized mitigation approaches identified by its authors. The table below illustrates which hazards each MID county identified as threats to their jurisdiction in their most recent LHMP. Asseen below,themostcommonly identifiedhazardsin the areas designated as MIDs for DR- 4558 and DR-4569are wildfires, floods, and earthquakes.This consistencybolstersthe state-wide hazard rankingsandreinforces the prioritization of wildfire mitigation -term recovery plan. Flooding is also identified as a primary hazard as evidenced by the mudslides and debris flows. Although earthquakes are identified as a primary hazard,due to the nature of disasters that 134 triggered the funding, the focus of the mitigation approaches will be on wildfires and, where applicable, flooding. F IGURE 144:L OCAL H AZARD M ITIGATION P LANS-T OP H AZARDS 2017 2017 - - 2019 Hazard 2017 - 2014 2021 20212017 -2017 - - Mitigation -- - 2019 2017 2015 2021 2017- 2018 Plans - 2010 - 2016 2018 - - - - 2019 2013- - 2018 2018 - - - - Mateo ButteFresno 2018LakeLassenLos Angeles MaderaMendocinoMonterey 2016 (2022)Napa San Bernadino Santa Clara Santa Cruz San Diego Santa Barbara SanShastaSiskiyou Solano Sonoma Stanislaus Trinity TulareVentura Yolo Agricultural x x x Pest/Invasive species Dam Failure xxxxxx Climatexxxxxxxxxxx Change Earthquake xxxxxxxxxxxxxxx Flood xxxxxxxxxxxxxxxxx Hazardous xxxxx Materials Release Landslides xxxxxxx Severe xxxxxxxxxx Weather or Storms Tsunami xxx Wildfire xxxxxxxxxxxxxxxxxxxxxx Other Human-xx Caused Hazard a.Primary Risks and Exposure Identified in LHMPs In addition to indexing thehazards that threaten local jurisdictions, LHMPsalso outline the risk that hazards may causedamage toor destruction ofhuman safety, structures, critical facilities, and public/private property. The table below represents therisk and exposure calculated for all California counties in the SHMP as of May 2022. The data identifies earthquakes asthe most severe risk multiplier by a wide margin, meaning that both counties and state plans agree that when earthquakes occur, they are likely to do the most severe damage to the largest number of people,structures, and resources. 135 F IGURE 145:S TATEWIDE R ISK AND E XPOSURE,M AY 2022 Other Statewide Risk and Exposure -May EarthquakeFlood RiskFire RiskHazard 2017 Risk Structures subject to earthquake risk7,270,459379,953737,4911,942,642 People subject to earthquake risk3,401,541871,0702,072,3584,182,930 Critical facilities subject to earthquake 9,2386,43411,65014,160 risk Potential value of structures/property $230 billion$44.4 billion$192 billion$135 billion subject to earthquake risk Source: 2018 California State Hazard Mitigation Plan b.Safety Element of County General Plans The State of California mandates viaSB-379that each county develop a Safety Element as one section of its County General Plan. The Safety Element lays out apolicyframework forreducing the potential risk of death, injuries, property damage, and economic and social dislocation resulting from a list of large-scale hazards. Creatinga SafetyElementalso requires a county to assess the vulnerabilitiesunique to their localpopulation and environment,andto developa better understandingof how climate change affects their communities.With this knowledge, local officials can more effectively plan and implement measures that increase the long-term resiliency of their jurisdictions. The figure below summarizes the Safety Elements by county and the year the Safety Element was last updated. Safety Elements are reviewed and approved by CAL FIRE. F IGURE 146:S UMMARY OF G ENERAL P LAN S AFETY E LEMENTS Year CountySafety Element Summary Adopted Policies to project the community through the year 2030. Butte2016 Covers noise, floods, seismic and geologic hazards, fires, hazardous materials, disaster preparedness, and community health. The Health and Safety Element is divided into seven sections: Emergency Management and Response; Fire Hazards; Flood Hazards; Fresno2000 Seismic and Geological Hazards; Airport Hazards; Hazardous Materials; and Noise. Provides goal, policies, and implementation measures designed to protect public health, safety, and welfare of community from Lake2008 unreasonable risks while minimizing damage to structures, property, and infrastructure resulting from natural and manmade hazards. 1974 Incorporates the most current Hazard Mitigation Plan by reference and Lassen(Updated provides the current structure for the element, there have been no 2020) changes since the original adoption in 1974. 136 Identifies environmental hazards including seismic activity, geotechnical hazards, floods, and fires. Los Ángeles 1990 Outlines regulations in place to mitigate risks and identifies agencies that provide oversight. Provides goals, policies, and implementation program designed to Madera1995 address health and safety concerns. Sets policy to minimize natural hazard risks (e.g., earthquakes, wildfire, Mendocino2009 flooding) as well as manmade hazards and nuisances (e.g., noise, poor air quality, hazardous materials). Establishes policies and programs to protect the public from risks Monterey2010 associated with seismic, geologic, flood, and wildfire hazards. Identifies earthquakes, fires, floods, liquefactions (when water saturated , and dam inundation as potential risks to public safety. References the Napa County Operational Area Hazard Mitigation Plan Napa2009 (NOAHMP), adopted in 2004, as the primary resource for detailed analyses of each of the potential hazard types. Policies related to interdepartmental cooperation in hazard mitigation efforts, information dissemination, risk evaluation, and the need for individual/community disaster plans are outlined in the safety element. Establishes goals, policies, and programs to protect the community San 2012 from risks associated with natural and man-made hazards such as Bernadino geologic, flooding, and fire hazards. Contributes to land use policies and standards by relating the type and Santa Clara1994 intensity of land use relative to estimated level of risk, and the availability of services and facilities to ensure safety. Updated policies in the GP/LCP Public Safety Element address climate change, coastal bluffs and beaches, erosion control, flood hazards, fire 1994 Santa Cruzhazards, and environmental justice. (2021) Updated air quality policies and relocation of the policies from the Conservation and Open Space Element to the Safety element. Safety considerations in the planning and decision-making process by 2011 establishing policies related to future development that will minimize San Diego (2021) risk of personal injury, loss of life, property damage, and environmental damage associated with natural and human-cause hazards. 2003 Designate land uses in order to minimize the danger of natural and San Mateo (2012) man-made hazards to life and property. Encompasses General Plan elements concerned with aspects of Shasta County's natural and man-made environment which pose Shasta2004 potentialthreats to human life or property, including seismic and geologic hazards, flood protection, dam inundation, fire safety and sheriff protection, noise, and hazardous materials. Examines the particular, physical needs of a county in relationto safety Siskiyou1974 and seismic-safety, and to establish procedures for the orderly development of the county relative to physical problems. 2008 natural and human-made hazards, promote public health, preserve air Solano (2015) and water quality, and guide development in a sustainable manner that respects the needs of both people and the environment. Intended to protect community from unreasonable risks from seismically induced surface rupture, ground shaking, ground failure, tsunami, dam Sonoma2014 failure, slope instability leading to mudslides, landslides, subsidence and other known geologic hazards, flooding, and fire. 137 Includes maps of known hazards, and assesses evacuation routes, water supply needs, road widths, clearances around structures, and items related to potential catastrophic events. 1994- Information on the various types of safety hazards are summarized Stanislaus2016 within the Safety Element. (2017) Sets forth goals, objectives, and policies for airport safety, flood risks or dam failures, hazardous materials, seismic or geological hazards, Trinity2014 wildfires and structures, air quality, climate change, and military operation area. Establishes policies to protect the public from risks associated with Tulare2012 natural and human-made hazards such as seismic hazards, geologic hazards, flooding, wildfire hazards, and air pollution. This element ensures that appropriate consideration of both natural and Yolo2008 human-made hazards and risks are factored into land use decision- making. c.Threat to Community Lifelines The following section identifies risks to indispensable services and community lifelines for the State of California. In February 2019, FEMA released the Community Lifelines Implementation 38 Toolkit which focuses on seven categories of Community Lifelines.FEMA defines these lifelines as critical business, government and essential services that provide health, safety, and economic security within a community. Community lifelines in preparedness planning and recovery provide details on the critical functions and stakeholders that facilitate the most effective response and get services and infrastructure back online after a disaster. Toexamine how risks and hazards affect human health, safety, and economic security, the state has completed a quantitative analysis of the significant potential impacts and risks of these critical service areas: Safety and Security-Wildfires and flood hazards create significant immediate threats to life and property in impacted communities. Emergency responders, police officers, at the time of the threat and address situations until they are able to return to normal. First responders and personnel are responsible for ensuring plans, systems, and communications are in place to meet the need of the situation, secure any threats to life, and mitigate citizen needs for recovery. CommunicationThe destruction of communications infrastructure by fire severely impacts first responder communications and emergencynotification capabilities. Cellular communications, broadband,radio,and television infrastructure are susceptible to damageby active fires andcan leave responders unable to coordinate and residents unable to receive critical evacuation or shelter orders. Food, Water, Sheltering-Water storage facilities and delivery systems are at serious risk of wildfire damage. For example, increased sediment loading due to soil erosion resulting from fires can decrease water storage capacity in dams and reservoirs. maintain and restore forested watersheds can reduce the risk of damaging fires that can 40 cut water supplies. 138 Flood Risk-The SHMP calculates that one in every five California residents live in a floodplain (500-year flood zone) and all counties in California have populations that have some exposure to flood risks. The SHMP reports that the statewide value of structures and contents at risk from a 500-year flood event is more than $575 billion, distributed over all 10 Hydrologic Regions. Specifically, Los Angeles, Orange, and Santa Clara Counties are most in jeopardy with more than 500,000 people, structures, and contents worth more than $70 billion, at risk of flooding. Flooding disproportionately affects urban areas, along with the high concentrations of socially vulnerable populations in d San Francisco Bay Areas. There are over 20,000 state-owned structures at risk of flooding (in 100 and 500-year flood plains) totaling $14.22 billion at risk. In the 100-year flood zone there are $11.62 billion at risk. Transportation-Transportation infrastructure (i.e. highways, bridges, railways) are susceptible to wildfire disruption which can severely impact emergency response and emergency evacuations of residents. The SHMP identifies the closure of U.S. Highway 101 during the 2017 Thomas fire, which impacted movement of residents and 41 emergency response capabilities. Health and Medical-Wildfire and flood disasters create medical and public health hazards. Survivors must be triaged, immediate medical needs assessed, and long-term medical care thatmay have been disrupted, such as proscriptions or regular treatments, must be addressed. Field facilities providing medical treatment need supplies and medicine, which may need to be coordinated with first responders and government officials. Animals are often a concern as well. Often veterinary care and safe housing for pets and service animals is required, in addition to addressing citizen needs. Furthermore, wildfires create hazardous air quality conditions that reach far beyond the boundaries of the impacted area. California has air quality districts responsible for 42 monitoring the safety of the air using the Air Quality Indexand releasing warnings to the public if it is unsafe to be outside. However, these air quality ratings do not always come with clear guidance for schools and other institutions for when or if closures may be warranted or other measures may be necessary. Hazardous Material (Management)Management of hazardous materials and containment of those materials during a disaster event are critical to public safety. Uncontained hazardous materials during a disaster can affect the ability of first responders to provide search and rescue. Such materials may also exacerbate additional hazards in a disaster situation. Community leaders and service providers must coordinate with facilities to identify existing security gaps. Energy (Power and Fuel)-Energy delivery systems (electricity, natural gas, oil) impact the ability of residents and first responders to access internet, phone, radio, and television. Disruption to energy delivery systems can adversely affect critical medial services and water infrastructure (i.e.,water pumps) if redundant systems are not operationalized (i.e.,emergency generators). Issues with downed powerlines can block 43 roadways, stopping egress and ingress of residents and first responders. The focus of the Implementation Toolkit is organizing resources and activating lifelines for support during incident response. By identifying the most heavily impacted Community Lifelines, HCD will be able to focus CDBG-DRfunds in those areas and provide long-lasting or permanent 139 interventions, breaking the cycle of repeated federal, state, and local investment in the same vulnerable lifelines. Examples include efforts to improve emergency communication protocols between agencies for faster response times or improving shelter networks to provide resources to those recovering from a disaster more efficiently. The components of the Community Lifelines are indicated below: F IGURE 147:FEMAC OMMUNITY L IFELINES C OMPONENTS Community ComponentCommunity LifelinesComponent Lifelines Safety and Law Enforcement/SecurityEnergyPower (Grid) Security Search and RescueTemporary Power Fire ServicesFuel Government ServiceCommunicationsInfrastructure Alerts, Warnings, Responder Safety Messages Imminent Hazard Mitigation911 and Dispatch Food, Water, Responder Evacuations ShelteringCommunications Food/Potable WaterFinancial Services ShelterTransportationHighway/Roadway Durable GoodsMassTransit Water InfrastructureRailway AgricultureAviation Health and Medical CareMaritime Medical Patient MovementPipeline Public HealthHazardous MaterialFacilities Hazardous Debris, Fatality Management Pollutants, Contaminants 8.Risk Assessment The risk assessment figure below summarizes the threat categories identified in the impacted areas for each of the FEMA Community Lifelines. The risk assessment highlights the threats by hazard for each of the seven FEMA Community Lifelines The combined threat column summarizes the average threat posed by each hazard and communicates the impact of each hazard. The three top hazards, wildfires, flooding, and earthquakes pose the most extreme threats to the Community Lifelines due to their history of impact across the state. Additionally, dam failure and tsunami are categorized as extreme threats due to the projected destructive impact across the Community Lifelines. Climate change, hazardous material release, and landslides/other 140 earth movements are categorized as high threats due to their unpredictable nature and acute impacts to the Community Lifelines. F IGURE 148:S TATEWIDE H AZARDS BY C OMMUNITY L IFELINE (1 OF 2) Food, Water, Health and HazardSafety and SecurityEnergy ShelteringMedical Agricultural Pest/Invasive Very Low ThreatHigh ThreatModerate ThreatVery Low Threat species Dam FailureExtreme ThreatExtreme ThreatExtreme ThreatExtreme Threat Climate ChangeHigh ThreatHigh ThreatHigh ThreatHigh Threat EarthquakeExtreme ThreatExtreme ThreatExtreme ThreatExtreme Threat FloodExtreme ThreatExtreme ThreatExtreme ThreatExtreme Threat Hazardous High ThreatHigh ThreatHigh ThreatModerate Threat Material Release Landslide and Other Earth Extreme ThreatExtreme ThreatModerate ThreatHigh Threat Movements Severe Moderate ThreatModerate ThreatModerate ThreatHigh Threat Weather/Storms TsunamiExtreme ThreatExtreme ThreatExtreme ThreatExtreme Threat WildfireExtreme ThreatExtreme ThreatExtreme ThreatExtreme Threat Other Human- Moderate ThreatModerate ThreatModerate ThreatModerate Threat Caused Hazards F IGURE 149:S TATEWIDE H AZARDS BY C OMMUNITY L IFELINE (2 OF 2) Food, Water, Health and HazardSafety and SecurityEnergy ShelteringMedical Agricultural Pest/Invasive Very Low ThreatVery Low ThreatVery Low ThreatLow Threat species Dam FailureExtreme ThreatExtreme ThreatExtreme ThreatExtreme Threat Climate ChangeHigh ThreatHigh ThreatHigh ThreatHigh Threat EarthquakeExtreme ThreatExtreme ThreatExtreme ThreatExtreme Threat FloodExtreme ThreatExtreme ThreatExtreme ThreatExtreme Threat Hazardous Moderate ThreatModerate ThreatHigh ThreatHigh Threat Material Release Landslide and Other Earth High ThreatExtreme ThreatHigh ThreatHigh Threat Movements Severe High ThreatModerate ThreatLow ThreatModerate Threat Weather/Storms TsunamiExtreme ThreatExtreme ThreatExtreme ThreatExtreme Threat WildfireExtreme ThreatExtreme ThreatExtreme ThreatExtreme Threat Other Human- Moderate ThreatModerate ThreatModerate ThreatModerate Threat Caused Hazards 141 1.Community Wildfire Protection Plans Community Wildfire Protection Plans are community-based planning documents that identify and address local hazards and risks from wildfire and provides a roadmap of actions for a community to address wildfire threats. Community Wildfire Protection Plans (CWPP) also create the opening for government entities to be eligible for federal funding opportunities for plan Restoration Act (HFRA), passed in Congress in 2003. CWPPs can vary in scope, scale, and detail but must meet three minimum requirements to be adopted per the HFRA and the State or California. The requirements include: Collaboration CWPPs must be collaboratively developed. Local and state officials must meaningfully involvenongovernmental stakeholders and federal agencies that manage land in the vicinity of the community. Prioritized Fuel Reduction CWPPs must identify and prioritize areas for hazardous fuel-reduction treatments on both federal and non-federal land. Treatment of Structural Ignitability CWPPs must recommend measures that homeowners and communities can take to reduce the ignitability of structures throughout \[4\] the plan area. F IGURE 150:2020D ISASTER I MPACTED C OUNTIES WITH C OMMUNITY W ILDFIRE P ROTECTION P LANS Year Adopted or Last Year Adopted or Last DR-4558DR-4569 UpdatedUpdated Butte County2008Fresno CountyN/A Lake County2009Los Angeles County2012 Lassen County2009Madera CountyN/A Mendocino County2005Mendocino County2005 Monterey County2011Napa County2009 Napa County2009San Bernadino County2011 San Mateo County2018San Diego County2006 Santa Clara County2009Shasta County2016 Santa Cruz County2010Siskiyou County2009 Solano CountyIn developmentSonoma County2010 Sonoma County2010 Stanislaus CountyN/A Trinity County2011 Tulare County2010 Yolo CountyIn development Source: California Community Wildfire Protection Plans -Wildland Fire Lessons Learned Center https://www.wildfirelessons.net/communities/community-home/librarydocuments?communitykey=49e8c861-f977-4684-b67f- d1176e5d5b38&tab=librarydocuments 142 9.Relevant State Lawsand Programs a.California State Laws AB 2140, Hancock. General plans: safety element \[6\] AB 2140authorizes a city, county, or a city and county to adopt, with its Safety Element, a federally specified LHMP that includes specified elements and require Cal OES to give preference to local jurisdictions that have not adopted a LHMP with respect to specified federal programs for assistance in developing and adopting a plan. AB 6421035(2021),Friedman. Wildfires. This legislation directs HCD, CalFire and Dept of Insurance to make recommendations on how to understand and model wildfire risk for a community and specific parcels through the input of mitigating factors. This legislation also direct CalFire to update and revise Fire Severity maps. The results include recommendations cost-effective ways to gather data on mitigation factors, an evaluation of the effectiveness of using natural infrastructure as a community buffer as well as identification of barriers to determining the wildfire risk of a community and specific parcels. AB 19451035(2021),Aguiar-Curry. Wildfires. This bill establishes a new state funded program for predevelopment through reconstruction, of damage and loss of homes occupied by or affecting lower income households. This bill would require HCD to establish an application process for CDFIs to apply for emergency short-term or temporary loans under the program. CDFIs would then issue short-term loans to nonprofits, local or tribal governments for notonly construction/development purposes, but also for childcare and social services linked to a project. SB 1035, Jackson. General plans The Planning and Zoning Law requires cities and counties to adopt a comprehensive, long-term general plan that includes, among others, a housing element and a safety element for the protection of the community from unreasonable risks associated with the effects of various hazards, such as seismic, flooding, and wildland and urban fires. Existing law requires the housing element to be revised at least once every eight years. However, the housing element is also reviewed and updated according to revisions of the safety element. This helps jurisdictions to identify new information related to flood and fire hazards that was not previously available and be able to address risk in both elements of the general plan. Existing law also requires the safety element to be reviewed and updated as necessary to address climate adaptation and resiliency strategies applicable to the city or county. SB 901, Dodd. Wildfires \[7\] SB 901was signed into law to help mitigate wildfire risk and expand and speed up recovery efforts. In addition, it established the Commission on Catastrophic Wildfire Cost and Recovery within the Office of Planning and Research. The Commission consists of five appointed members withspecified expertise and is required to hold at least four public meetings 143 throughout the state relating to the costs of damage associated with catastrophic wildfires. In 2019 the Commission, in consultation with the Public Utilities Commission (PUC) and the Insurance Commissioner, prepared a report containing its assessment of the issues surrounding catastrophic wildfire costs and the reduction of damage, and making recommendations for changes to law that would ensure equitable distribution of costs among affected parties. AB 430, Gallagher Housing Development: Camp Fire Housing Assistance The Camp Fire Housing Assistance Act Establishes a ministerial approval process for housing development in the cities of Biggs, Corning, Gridley, Live Oak, Orland, Willows, Yuba City, and Oroville that meet specified objective planning standards. Development proponents are required to hold at least one public meeting on the project before applying. Project approvals that expire after three years may receive a one-time, one-year extension if the developer demonstrates significant progress. Project approvals do not expire if the project includes investments in affordable housing, and approvals for all projects remain valid once vertical construction has been initiated. These provisions expire on January 1, 2026. AB 782, Berman California Environmental Quality Act: Exemption: Public Agencies The California Environmental Quality Act exemption creates a CEQA exemption for the acquisition, sale, or other transfer of interest in land, as well as the granting or acceptance of funds, by a public agency for conservation purposes. California FAIR Plan The FAIR Plan is an association of all insurers authorized to provide basic property insurance in California and provides insurance of last resort. The Plan is intended to provide basic property insurance to those who cannot obtain insurance in the voluntary market due to circumstances outside of their control. No public funding is used in the FAIR Plan and it is not administered by \[8\] a stateagency. In November 2019, the state ordered the FAIR Plan to offer more comprehensive policies and increase the amount of coverage to $3 million, in comparison to the current basic policies that require additional coverage to meet the needs of property owners. State insurance regulators have placed a one-year moratorium banning insurers from dropping policies of homeowners in and around areas hardest hit by recent fires. This is a response to the complaints of homeowners that they cannot find affordable insurance, or insurance at all. The moratorium includes more than 800,000 homeowners in zip codes next to 16 recently declared wildfire \[9\] disasters in Northern and Southern California. California State Programs California Department of Forestry and Fire Protection (CAL FIRE):CAL FIRE is a California State department dedicated to the fire protection and stewardship of over 31 million acres of California's privately-owned wildlands. In addition, the Department provides varied emergency services in 36 of the State's 58 counties via contracts with local governments. CAL FIRE is responsible for fire prevention in the State Responsibility Area (SRA) and has expanded its efforts significantly to meet evolving - 144 department, meaning that CAL FIRE crews and equipment are also dispatched to non- wildfire emergency scenarios, including auto accidents, hazardous material spills, search and rescue missions, civil disturbances, earthquakes, and more. o Fire Prevention Program (FPP): The Fire Prevention Program consists of multiple activities including wildland pre-fire engineering, vegetation management, fire planning, education and law enforcement. Typical fire prevention projects include brush clearance, prescribed fire, defensible space inspections, emergency evacuation planning, fire prevention education, fire hazard severity mapping, and fire-related law enforcement activities. o Office of the State Fire Marshal (OSFM):The OSFM has operated as part of CAL FIRE since 1995 and supports the D property through fire prevention engineering programs, law and code enforcement and education. The OSFM also collects, analyzes, and reports on critical incident statistics forlocal and state government emergency response agencies, which support the building of action plans and other long-term recovery documents. o Urban & Community Forestry Grant Program (UCF):The UCF works to expand and improve the management of trees and related vegetation in communities throughout California, and to lead the effort to advance the development of sustainable urban and community forests in California.To meet that goal, the UCF administers State and Federal grants throughout California communities to advance urban forestry efforts. o California Forest Improvement Program (CFIP):The purpose of the CFIP is to encourage private and public investment in, and improved management of, California forest lands and resources. The CFIP is dedicated to ensuring the availability of adequate high quality timber supplies, supporting timber-industry employment and related economic benefits, and to protecting, maintaining, and enhancing a productive and stable forest resource system for the benefit of present and future generations. The CFIP provides cost-share assistance to private and public land ownerships containing 20 to 5,000 acres of forest land for activities including preparation of forest management plans, supervision by a Registered Professional Forester for reforestation, stand improvements, and forestland/wish and wildlife habitat improvements. o Wildfire Prevention Grant Program (WPGP): funding for fire prevention projects and activities in and near fire threatened communitiesandfocuses on activities thatincreasethe protection of people, structures, and communities.Through the grant program, CAL FIRE provides assistance to qualifying projects and activities, including hazardous fuels reduction, wildfire prevention planning, and wildfire prevention education with an emphasis on improving public health and safety while reducing greenhouse gas emissions. CalifoCal OES is aCalifornia state cabinet-level office responsible for overseeing and coordinating emergency preparedness, response, recovery and homeland security activitieswithin the state.Cal OESwas created by AB 38 (2008), superseding both the Office of 145 Emergency Services (OES) and Office of Homeland Security (OHS).Cal OES manages hazard mitigation activities and projects through the 404 Hazard Mitigation Grant Program, Building Resilient Infrastructure and Communities Program, and the Flood Mitigation Assistance Program. o Hazard Mitigation Grant Program (HMGP):After aPresidential Disaster Declarationin the state of California,CalOES activates Mitigation Grant Program (HMGP)tofundplans and projects that reduce the effects of future natural disasters. Fundsare administered by the Cal OES HMGP Unit. Eligible sub-applicants include state agencies, local governments, special districts, and some private non-profits. o Building Resilient Infrastructure Communities (BRIC):Authorized by Section 203 of the Stafford Act,BRICwill support states, local communities, tribes and territories as they undertake hazard mitigation projects, reducing the risks they face from disasters and natural hazards.BRIC-supported projects may include natural hazard risk reductions on a neighborhood scale, interventions that mitigate risk to critical infrastructure or achieve community-level risk reduction, activities that provide protection and benefits for disadvantaged communities, or projects that address climate impacts and advance climate adaptation. o Flood Mitigation Assistance Grant Program (FMA):The FMA is a competitive grant program that provides funding to states, local communities, federally recognized tribes and territories. Funds can be used for projects that reduce or eliminate the risk of repetitive flood damage to buildings insured by the National Flood Insurance Program. California Office of Planning and Research (OPR):OPR studies future research and planning needs, fosters goal-driven collaboration, and delivers guidance to state partners and local communities, with a focus on land use and community development, climate risk and resilience, and high road economic development. o Integrated Climate Adaptationand Resiliency Program (ICARP):Governor Brown signed Senate Bill 246 in 2015, which directed OPR to form the Integrated Climate Adaptation and Resilience Program (ICARP). JDBSQ!jt!eftjhofe!up! efwfmpq!b!dpiftjwf!boe!dppsejobufe!sftqpotf!up!uif!jnqbdut!pg!dmjnbuf!dibohf! bdsptt!uif!tubuf-!boe!up!develop holistic strategies to coordinate climate activities at the state, regional and local levels, while advancing social equity. ICARP administers grant programs to local jurisdictions through the Adaptation Planning Grant Program, Regional Resilience Planning and Implementation Grant Program, and Community Resilience and Heat Grant Program. Adaptation Planning Grant Program(APG): The APG program provides funding to local, regional, and tribal jurisdictions to supportplanning needs, provides communities the resources to identify climate resilience priorities, and supports the development of a pipeline of climate resilient infrastructure projects across the state. o Regional Resilience Planning and Implementation Grant Program:This program will support regions in advancing resilience through capacity-building, planning, and project implementation. o Community Resilience and Heat Grant Program:This program will help communities prepare for theimpacts of extreme heat. Department of Housing and Community Development 146 o Regional Early Action Planning Program (REAP 2.0): Administered by the California Department of Housing and Community Development(HCD),in collaboration with OPR, the Strategic Growth Council, and the California Air Resources Board,REAP 2.0 is a flexible program that seeks to accelerate progress towards California state housing goals and climate commitments through a strengthened partnership between the state, its regions, and local entities.The program seeks tosupport infill housing development, reduce miles traveled by commuters, increase housing supply at all affordability levels, affirmatively further fair housing, and facilitate the implementation of adopted regional and local plans to achieve these goals.REAP 2.0 provides a $600 million state and federal investment to advance implementation of adopted regional plans by funding planning and implementation activities that accelerate infill housing and reductions in per capita Vehicle Miles Traveled (VMT). The program is funded through $500 million from the Coronavirus Fiscal Recovery Fund of 2021 and $100 million from the State General Fund.REAP 2.0 was established as part of the 2021 California Comeback Plan underAB 140. o CalHome and CalHome Disaster Programs: The CalHome program is designed to assist low-and very low-income households to become or remain homeowners by making grants to local public agencies and nonprofit developers for the following activities: Assisting individual first-time homebuyers through deferred-payment loans for down payment assistance Home rehabilitation, including for manufactured homes not on permanent foundations Acquisition and rehabilitation Homebuyer counseling Self-help mortgage assistance Technical assistance for self-help homeownership In its 2021 CalHome NOFA, HCD announced the availability of $57 million of state funds, with $20 million reserved for mobile homes. In November 2021, HCD made $23 million available for counties impacted by the 2020 disasters. As of the publication of this Action Plan, HCD is still evaluating program applications for this round of funding. However, with any funding awarded within the 2020 MID area, HCD will ensure that CalHome or CalHome Disaster is considered within the total cost to rebuild, as layering funding is critical for reconstruction in the 2020 impacted areas. While CalHome is not considered a duplication of benefit, the OOR program will evaluate all applicants and available funding sources. 147 57 10.-2022 Budget Governor Newsom submitted his 2020-2021 budget request in January 2021 that includes funding to address the threat of catastrophic wildfires, climate change, and forest resilience. Climate Catalyst Fund, $47 million in loans for climate related projects including wildfire and forest resilience. CalOES expansion of a disaster recovery outreach campaign and: ®$256 million to reimburse local governments for emergency activities. ®$17.3 million for the California Earthquake Authority to update its Early Warning System. ®$25 million for CalOES and CAL FIRE to implement a home hardening pilot grant program. $500 million for a third round of Low-Income Housing Tax Credits (LIHTC) Wildfire and Forest Resilience: ®$512 million for Resilient Forest and Landscapes Forest thinning, tree planting, prescribed fires; forest health and watershed recovery grants; investment in Tribal communities; support for small landowners to manage forest lands; targeted investment for state landholdings. ®$335 for Wildfire Fuel Breaks Partnership between CAL FIRE and the California Conservation Corps to complete 45-60 fuel breaks; provide technical assistance to local communities to develop fire safety projects, cross- jurisdictional plans, and fund project implementation. ®$38million for Community Hardening Educational programs, defensible space outreach, and basic home retrofits. ®$39 million for Science-Based Management Research on long-term forest health. ®$76 million for Forest Sector Economic Stimulus Expand wood product market to use thinned materials; low interest loans through the Climate Catalyst Fund. prevention programs. 11.Statewide Plan Alignment for Equitable Recovery from Disasters eplanning and recovery project implementation for climate resilience and sets equitable recovery goals for state with these goals outlined by OPR and presents programs that allow disaster impacted communities with different capacity levels to have access to disaster recovery and mitigation programs. 57 -21 Budget: Overview of the Ca October 5, 2020), https://lao.ca.gov/Publications/Report/4263. 148 OPR prioritizes creating an equitable recovery, disaster resilience, and climate change recovery, and mitigation from natural hazards continue to impact the State of California and its residents. HUD requires CDBG-DR grantees to focus on vulnerable populations in its recovery and mitigation activities, and HCD and its state partners further that commitment by defining, identifying, and prioritizing vulnerable populations in its recovery and mitigation programs. In the context of climate adaptation, OPR and the Integrated Climate Adaptation and Resiliency Program (ICARP) define climate vulnerability as: are at risk of exposure to climate change impacts. Vulnerable communities experience heightened risk and increased sensitivity to climate change and have less capacity4 and fewer resources to cope with, adapt to, or recover from climate impacts. These disproportionate effects are caused by physical (built and environmental), social, political, and/ or economic factor(s), which are exacerbated by climate impacts. These factors5 include, but are not limited to, race, class, sexual orientation and identification, 58 national origin, and income inequality. - DR and Mitigationprogram endeavor to align planning efforts at the state and local level, promote housing and infrastructure to reduce climate risk and reduce climate risk, and develop planning documents that are used throughout government decision-making processes. For the proposed disaster recovery and mitigation programs, HCD will work to align program design to fit the following activities: 59 Plan Alignmentalign recovery and mitigation activities with existing state and local planning documents including: o General Plans (Housing and Safety Element), Local Hazard Mitigation Plan, Regional Transportation Plan, Community Wildfire Protection Plan, Local Coastal Programs Encourage planning efforts beyond jurisdictional boundaries. Ensure infrastructure projects account for the useful life of critical infrastructure, not just the design life. silience/ mitigation and equitable recovery goals include: o Adopting zoning ordinances that facilitate infill, risk reduction, and sustainable land use and that are consistent across relevant planning documents. o Rebuilding transportation infrastructure thatimproves accessibility for non- vehicular transport modes and evacuation routes. o Building new housing units that are within existing development footprints and walkable to job centers, schools, and public services. 58 Research, July 2018), https://opr.ca.gov/docs/20180723-Vulnerable_Communities.pdf. 59 Plan Alignment Clearinghouse. 149 o Using nature-based solutions to reduce community climate risk, protect watershed health and reduce infrastructure costs. o Hardening structures to reduce climate hazard risk to homes and businesses. o Coordinating incentives for strategic land assemblage to conserve natural/working lands, restore natural landscape functions, and/or transfer redevelopment to lower-risk locations. o Supporting workforce development programs in industries critical to forest resource management (e.g.,prescribed burning, advanced wood products) and renewable energy. III.General Requirements A.Citizen Participation HCDhas developed a Citizen Participation Plan in compliance with 24 CFR 91.115 or 91.105 (except as provided for in notices providing waivers and alternative requirements) and applicable U.S. Department of Housing and Urban Development (HUD) alternative requirements as published in Federal Register Notices for CDBG-DR which supersede/waive and replace certain requirements with respect to citizen participation. This plan isintended to maximize the opportunity for citizen involvement in the planning and development of programs and projects responding to the2020 wildfire season (DR-4558 and DR-4569)including proposed program activities and amount of funding. Consultation During Action Plan Development The FRN, 87 FR 6379, Section III.B.2.i requires state grantees receiving an allocation of CDBG- DR funds to consult with all disaster-affected local governments (including any CDBG- entitlement grantees), Indian tribes, and any public housing authorities in determining the use of funds. This approach ensures that a state grantee sufficiently assesses the recovery needs of all areas affected by the disaster. B.Outreach and Engagement TheAction Planpresents an opportunity to defining housing problems, educating, and creating solutions for post disaster housing recovery needs. The inclusion of vulnerable population and community stakeholders in the action plan public participation process helps ensure the needs of these stakeholders is identified and addressed. HCD recognizes the outreach challenges and encourages participation of citizens in all aspects of the State's CDBG DR program and implementation process, by going above and beyond the disaster recovery requirements. HCD is doing additional outreach events to reach broader audience as well as reducing barriers to accessing HCD resources beyond disaster recovery. This is intended to ensure that populations such as persons with disabilities or limited English proficiency are aware of the support that may be available to them through CDBG DR, and other state assisted programs in the jurisdictions in which they reside. In addition, disaster recovery programs and policies are aligning housing strategies with climate change objectives, housing production, infrastructure improvements, resiliency goals to mitigate future disasters. The new FRN has combined the housing recovery and mitigation activities in 150 one. In proposed resilience-related activity descriptions,HCD will include outreach strategies to increase awareness of the hazards in MID-area communities (including for members of protected classes, vulnerable populations, and underserved communities). The goal is to build back better, not just replace what was lost. Successful public participation is important because vulnerable population have historically faced barriers to engaged or receiving assistance from disaster recovery programs. The Outreach Plan outlines a comprehensive plan to inform stakeholders about the CDBG-DR grantand proposed programs,andto engageotherfederal and state resources to assist with recovery after a disaster. This plan identifies not only mandated outreach requirements, but also thebroader set of stakeholders engaged with housing and community developmentin impacted areas. Finally, the outreach plan addresses actions by HCD to reduce barriersfor engagement and participation in disaster recovery programs. 1.Stakeholder Consultation Community outreach methods will seek to engage a diverse group of community members, including populations defined as protected classes by HUD, including but not limited to persons with limited English proficiency, persons with disabilities, and ensure a balance with rural community outreach. The broad set of stakeholders targeted for outreach include: Disaster Property Owners Disaster Affected Cities and Counties Affordable Housing Developers Voluntary, Charitable, Faith, and Community based Organizations Tribal Government Long-Term Housing Recovery Groups Non-Profits Government Agencies Local Emergency Management Agencies Public Housing Authorities(PHAs) Private Sector Organizations that represent protected class members and vulnerable population. To facilitate outreach involvement, HCD will coordinate actions to encourage participation and allow equal access to information about the action plan. These methods include a variety of digital and not digital means, in multiple languages, and with varying level of detailed information. These may include, but are not limited to: Print media, such as the newspaper (mandated for FRN) State of California CalOES),State of California Office of Planning and Research (OPR), and CAL FIRE HCD Emails and meeting announcements to Government Agencies HCD Emails to Affordable Housing Developers in DR counties HCD Emails and Meeting announcements to Voluntary Organizations and Non-Profits Announcements in interagency meetings -DR website in English and Spanish 151 Direct mail and email to Tribal Government via HCD and CalOES contact list Interagency consultation and coordination -term Recovery Meetings Organized by CalOES and FEMA Recovery Support Function Meetings (RSF) Virtual targeted community meetings in disaster impacted areas Virtual meetings with stakeholders listed above Broad HCD Distribution List o CDBG-DR program contact list o Other State and Federal program contact list o o HPD contact list Primary Stakeholder Group The primary stakeholders include mandated outreach per FRN as well as key partners helping Disaster Survivors Affected Disaster Recovery Cities and Counties (multiple meetings) o Housing and Community Development Staff o Infrastructure Public Works/Debris Removal o Planning and Permitting o Emergency Response Managers Tribal Government in disaster declared areas Government Partners (multiple meetings) o CalOES o OPR o CalFire o Department of Insurance o CalSTA/CalTrans o FEMA Public Housing Authorities (PHAs) Long-Term Housing Recovery Groups Disaster Case Managers Organizations that represent protected class and vulnerable population NOTE:HUD defines vulnerable populations as a group or community whose circumstances present barriers to obtaining or understanding information or accessing resources. In the action plan, HCD will identify those populations (i.e., which protected class, vulnerable population, and historically underserved groups were considered) and how those groups can be expected to benefit from the activities. Secondary Stakeholder Advisors The secondary stakeholder comprises groups that are either not directed impacted by the disaster or mandated by the FRN. These secondary groups can assist primary stakeholders in 152 their recovery needs and or will benefit from awareness of disaster recoveryefforts as the state implements various housing, transportation, or climate change policies. They include: Affordable Housing Developers in the disaster impacted counties Statewide organizations such as Housing California or California Housing Partnership Corporation Organizations that work primary in rural communities, such as, Rural Community Assistance Corporation (RCAC) State and Local Hazard Mitigation Planners, Funders, and Implementers Legislative Offices and Policy makers Regional Planning Entities Universities and Research Groups 2.Stakeholder Meetingsand Public Hearings There will be multiple meetings for specific target groups and topics starting in March of 2022 and ending with final public comment meeting. HCD will advertise these public meetings 14 days prior in English and Spanish to all the stakeholders identified above according to HUD and translation services, and or any other questions. Registration instructions for the meetings will be included in the announcements. Stakeholder Meetings will have included or will includethe following events: Pre-Federal Register (FRN) Notice Meetings:Prior totherelease of the FRN, HCD metwith stakeholders in each IA-declared countyto explain the CDBG-DR processes and Action Plan requirements. Impacted counties identified the following items as recovery priorities: o Fresno:damage to community sewer and water systems in and near burn areas; need hazardous material/debris removal; damage to primary residences and vacation homes o Napa:Support for residents using emergency rental assistance o Siskiyou:need for direct housing assistance and utilities connection for FEMA trailers o Lake:private wells and septic systems damaged or destroyed; cabins and vacation homes damaged or destroyed o Madera:need for direct housing assistance o Mendocino:Residents requesting direct assistance; unknown level of housing need o San Diego:Debris removal; temporary and long-term housing o Santa Cruz:Infrastructure damage; need case management support for housing individuals and families F IGURE 151:R ECOVERY N EEDS BY C OUNTY FROM 2020D ISASTERS CountyInitial Recovery Need from 2020 Disasters ButteTemporary housing; reconstruction and new construction of housing 153 Santa CruzInfrastructure rebuilding NapaSupport for residents using emergency rental assistance Support for residents using emergency rental assistance; utilities Sonoma assistance for LMI residents damage to community sewer and water systems in and near burn Fresnoareas; need hazardous material/debris removal; damage to primary residences and vacation homes Need for direct housing assistance and utilities connection for FEMA Siskiyou trailers TrinityLong-term lack of affordable housing Water system destroyed; significant un-and under-insured segment Tulare of homeowners Residents requesting direct assistance; unknown level of housing Mendocino need Private wells and septic systems damaged or destroyed; cabins and Lake vacation homes damaged or destroyed YoloSmall number of damaged homes MaderaNeed for direct housing assistance Infrastructure damage; need case management support for housing Santa Cruz individuals and families San DiegoDebris removal; temporary and long-term housing Pre-Public Comment Action Plan Meetings:HCD meets withstate agency partners and local governments on an ongoing basis about specific 2020 CDBG-DR allocation requirements, processes, and updated timelines.Meetingswill focus on the development of Action Plan document and preparation for public release and before the start of public comment period. o Local Government Kick Off Meeting (4/20/22)42 attendees from local governments impacted by the 2020 disasters participated in a briefing and discussion on CDBG-DR funding. The following providesa summary of the feedback provided by local government stakeholders: Trinity Countynoted that elderly and retired population are struggling to recover; a lot of vegetation from Bureau of Land Management, U.S. Forest Service, and private land that needs to be cleared. Butte County Population with access and functional needs are struggling to recover fromthe 2020 disaster and other overlapping disasters. Renters and precariously housed population have few options due to limited availability of housing overall. Rural homeowners are having a tough time rebuilding due to significant uninsured and under insured population from the 2020 disaster as well as previous disasters. 154 The community is experiencing funding and planning fatigue due to overlapping disasters, and while there are damages from the 2020 disasters, these are overshadowed by previous disasters. Low-and moderate-income renters continue to struggle with recovery, highest needs but limited to no immediate support available. The need for rebuilding or replacing septic systems remain one of the biggest barriers to recovery. There is a high need to develop and maintain defensible space to protect communities, but fuel management is also needed. Shasta Lake and Shasta Countyneed to retain workforce and bring back businesses in impacted areas; identified the need for workforce housing to ensure that middle income workers can assist with recovery efforts. Santa Cruz Countyforest fuel load reduction is critical for its recovery and mitigation against future fires. o Long-Term Recovery Group Meeting (4/27/22)HCD conducted a meeting with long-term recovery groups in impacted areas, including the MID, to brief nonprofit service providers on CDBG-DR and mitigation requirements, proposed programs, and solicit feedback from stakeholders who work directly with residents who were directly impacted by the 2020 disasters. 23 service providers attended the meeting. Public Comment Period Meeting o HUD requires CDBG-DR grantees to convene at least one public hearing on the proposed action plan after it has published on its website to solicit public comment and before submittal of the action plan to HUD. HCD will provide a period of 30 calendar days for comments on the AP. Directions for submitting comments will be included in the public hearing notice. Comments may be submitted to the Department via mail, email, or by telephone through the contact out to the contact information provided in the public notice. o The Team will develop FAQ (Frequently Asked Questions) for the HCD website after the first public meeting and update throughout the planning process. The presentation materials will be shared with all attendees and meeting recordings will be posted on the HCD website. o HCD will ensure that thereare no potential barriers that may limit or prohibit vulnerable populations or underserved communities and individuals affected by substantial amendment. HCD will take reasonable measures to increase coordination, communication, affirmative marketing, targeted outreach, and engagement with underserved communities and individuals, including persons with disabilities and persons with Limited English Proficiency (LEP). o Proposed Meeting ScheduleHCD will conduct the following meetings during the 2020 Action Plan public comment period. HCD will conduct outreach for the meetings to ensure robust participation, following the Citizen Participation Plan for public meetings. Public comment meeting (English) May 18, 2022, 6pm Public comment meeting (Spanish) May 19, 2022, 6pm 155 Public comment meeting (Affordable housing developers) May 26, 2022, 10am Tribal Governments May 24, 2022, 1pm Post-Action Plan Meetings: HCD will submit the action plan to HUD in June of 2022. During the 60-day review period, HCD willcontinue to collaborate on a monthly basis with disaster survivors, interagency partners, and disaster-affected cities and counties about program timeline, implementation, and other state funding available for housing programs and mitigation. 3.Tribal Partners It is important to ensure there is tribal engagement from the public outreach to implementation of disaster recovery programs.communities clearly identified tribal members impacted by the 2020 wildfires, primarily in Siskiyou County.In 2019, Assembly Bill 1010 was signed into law which codified tribal participation in affordable housing programs requiringHCD to open all state programs to tribes/TDHEs(tribally designated entity), by changingthe definition of local public entity to include tribes/TDHEs, and allowingHCD to waive or modify program requirements. Bill 1010 Program known as the G. David Singleton California Indian Assistance Program (CIAP). CIAP ensures that tribes and TDHEs receive comprehensive technical assistance on HCD programs, land use planning, natural and environmental resource planning, economic resource planning, tribal housing trust funds, etc. In accordance with CIAP,Tribal Affairs engages, educates, collaborates with tribal partners through a variety of methods to assist tribes throughout all stages of the funding process for disaster recovery programs.The stages include all aspects of the project from consultations and listening sessions to application workshops to trainings. HCD hosted anAction Plan kick off presentation with impacted Tribal Governments on April 21, 2022.17 people participated in the meeting including the Big Valley Band Rancheria (Lake County), Robinson Rancheria (Lake County), Viejas Band of Kumeyaay Indians (San Diego County), and Karuk Tribe (Siskiyou County). This presentation included information about CDBG-DR, as well as other housing, infrastructure and planning funding sources to help tribal continue to work with CIAP to help tribal communities to implement CDBG-DR programs 4.Limited English Proficiency Toreduce barriers for non-English speakers or those with accessibility challenges, HCD will make every effort to accommodate the needs of residents at all public hearings. HCD will solicit information about the need for translators for public hearings in the notification of the hearing. Translation services may be arranged via mail, email, or by telephone through the contact y reaching out to the contact information provided in the public notice. HCD maintains a list of staff that can provide translating services in American Sign Language. C.Complaints HCD will provide a timely response to citizen complaints. Citizens may file awritten complaint or appeal through the Disaster Recovery email: DisasterRecovery@hcd.ca.gov 156 Director of Disaster Recovery: Maziar.Movassaghi@hcd.ca.gov. Citizens may also submit complaints by postal mail to the following address: ATTN: Maziar Movassaghi Director of Disaster Recovery Housing & Community Development 2020 W. El Camino Avenue, Suite 500 Sacramento, CA 95833 The response willbe provided within fifteen working days of the receipt of the complaint, if practicable. To submit fair housing compliant, contact one of the following: U.S. Department of Fair Housing and Equal Opportunity (FHEO) o Phone: (415) 489-6524 (800) 347-3739 (415) 436-6594 TTY o Email: ComplaintsOffice09@hud.gov California Department of Fair Employment and Housing (DFEH) o Phone: 800-884-1684 800-700-2320 TTY California's Relay Service at 711 o Email: contact.center@dfeh.ca.gov D.Public Website HCD will maintain a comprehensive website dedicated to CDBG-DR programs and related activities, including the final Action Plan, public comments, and Citizen Participation Plan. The website can be found at the following addresshttps://www.hcd.ca.gov/community- development/disaster-recovery-programs/cdbg-dr/cdbg-dr-2020/index.shtml. In addition to the public website, HCD will procure a vendor to communicate with program applicants regarding their application status. This is mentioned further in the next section. E.SubstantialAmendments HCD will follow the CDBG Citizen Participation and all requirements in the Federal Register Notice prior to making a substantial amendment to the Action Plan. This means that HCD will follow the sameprocedures required for the preparation and submission of an action plan for disaster recovery, with the exception of the public hearing requirements and consultation requirements, which are not required for substantial amendments. Substantial amendments are characterized by: An addition or deletion of any CDBG-DRfunded program, Any funding change greater than $10million of the CDBG-DRallocation,or Any change in the designated beneficiaries of the program. 157 There are additional circumstances for which HCD is required by the Consolidated Notice, 87 FR 6364, to submit a substantial amendment. If method of distribution for a program is not known at the time HCD submits the action plan to HUD. Method of distribution descriptions must include: Eligibility criteria for assistance. This includes description of all exceptions that may be provide on case-by-case basis. Associated national objectives for each program. Description of the maximum amount of assistance (i.e., awardcap) available to a beneficiary under each of the disaster recovery programs. Projected uses for the CDBG-DR funds, by responsible entity, activity, and geographic area. Identify all allocation criteria involved in method of distribution to local governments or Indian tribes. Thecriteria must be identified in the action plan or substantial amendment and approved by HUD before distributing the funds to a local government or Indian tribe. Identify all criteria, and the relative importance of each criterion, and any eligibility requirements, used to select applications for funding. This is applicable to applications solicited for programs carried out directly. Description of resale or recapture requirements and for which activity the use is proposed. The resale or recapture requirements must clearly describe the terms of resale or recapture and the specific circumstances under which resale or recapture will be used. Substantial amendments require a 30-day public comment period. Substantial amendments will be available on the State of California CDBG-DRAction Plan websitefor public review and comment for at least 30 days before finalization and incorporation into the comprehensive 60 Action Plan.A summary of all comments received will be included in the final substantial amendment submitted to HUD for approval. F.Non-Substantial Amendments Non-substantial Amendments are minor, administrative changes that do not materially alter activities or eligible beneficiaries. Such amendments will be presented to HUD five days prior to incorporation in the comprehensive Action Plan. Every amendment to the Action Plan (substantial and non-substantial) will be numbered and posted on the HCD website. G.Consideration of Public Comments HCD will consider all public comments received in writing, via email, or delivered in person at official public hearings regarding this Action Plan or any substantial amendments. HCD will 60 HCD Website: Community Development Block Grant Program -Disaster Recovery(CDBG-DR) 158 make public comments available to citizens, public agencies, and other interested parties upon request. To ensure citizens have equal access and opportunity to provide comments on the Action Plan, HCD will post notices and work with local governments to ensure outreach to impacted residents and vulnerable populations. Additionally, HCD conducted a four-factor analysis to determine populations with Limited English Proficiency, will translate pertinent materials into Spanish, have American Sign Language (ASL) interpreters available and a Spanish language translator at everymeeting. HCD will also provide translation services for additional languages if requested in advance. H.Displacement of Persons or Entities HCD develops all programs with the intent to minimize displacement of persons or entities, following itsexistingResidential Anti-displacementand Relocation Assistance Plan (RARAP)in accordance with 24 CFR part 42.325. all program policies and procedures, applications, and technical assistance provided will include policies around displacement. HCD will amend the existing RARAP to reflect the requirements and applicable waivers and requirements as modified by the Consolidated Notice, 87 FR 6381,prior to implementing any activity with 2020 CDBG-DR grants funds. HCD will minimize displacement of persons or entities as a result of the implementation of CDBG-DR projects by ensuring that all programs are administered in accordance with the Uniform Relocation Assistance and Real Property Acquisition Act (URA) of 1970,as amended (49 CFR Part 24) and part 104(d) of the Housing and Community Development Act of 1974 and the implementing regulations at 24 CFR part 570.496(a). All recovery programs outlined in this Action Plan will be implemented with the goal of minimizingdisplacement of individuals and families from their home, whether rental or owned, and/or their neighborhoods. HCD understands the individualized nature of disaster recovery and the complexities of the recovery process, as well thenecessity to join in that process to provide support and guidance through that process. As such, HCD offers a housing counseling program for disaster impacted individuals to include up to two optional counselingopportunities and one required counseling opportunity to support their housing recovery process. ReCoverCA Current homeowners entering into the ReCoverCA housing programs receive counselingserviceson propertymaintenance,financial management, disaster recovery funding resources, financial and credit literacy, and other areas as needed and appropriate to assist in helping ReCoverCA program participants determine their housing recovery plan, improve their housing conditions, and meet their financial goals. Traditionallyunderservedpopulations, state and federally protected classes, including racial and ethnic minorities,theelderly, veterans,personswith disabilities, persons with limited English proficiency and residents of rural areas,face uniquedisasterrecoveryhousing,andeconomic 159 61 challengesReCoverCA HousingCounselingProgramprovides expert, unbiased guidance, and information to help families andindividuals,particularlythemostvulnerable, meet theirhousingneeds through an informed decision-making process. Rehabilitation or reconstruction projects occasionally require persons to be temporarily displaced from their residential dwelling. Although temporarily displaced persons do not receive the same relocation assistance and payments as persons permanently displaced under the URA, they are entitled to certain rights and protections. When necessary and appropriate, residential tenants who will not be required to move permanently maybe required to relocate temporarily for the project Temporary relocation should not extend beyond one year before the displaced persons return to their previous unit or location. While not expected, if temporarily relocatedresidential tenants are displaced for more than one year, tenantsare entitled to permanent relocation assistance, which is not inclusive of any temporary relocation assistancepreviously provide. All conditions of temporary relocation must be reasonable. required relocation plans and implement relocation advisory services for the OOR Program as requested by HCD. The relocation assistance requirements at part 104(d)(2)(A) of the Housing and Community Development Act and 24 CFR 42.350 are waived to the extent that they differ from the requirements of the URA and implementing regulation at 49 CFR part 24, as modifiedby the Notice, for activities related to disaster recovery. Without this waiver, disparities exist in relocation assistance associated with activities typically funded by HUD and FEMA (e.g., buyouts and relocation). The impacts of the disasters are vast and, in many cases, have destroyed homes. In the instance that homes may be rehabilitated, HCD will opt for rehabilitation to minimize the displacement of the homeowner. Additionally, the required affordability periods of at least 55yearsfor Multifamily rentalunits will also assist with prevention of displacement. I.Protection of People and Property The State of Californiahas a long history of promoting building design and zoning to protect people and property from harm due to natural disaster. Since the mid-1980s the state has California Fire Safe Council was established to promote fire safety and to support local community fire safe councils. At the sametimethe California Wildland Urban Interface (WUI) HCD Committee. This multi-agency state level committee is established pursuant to AB 642 (2021) to 61 to Fair Housing:https://www.hcd.ca.gov/policy-research/plans-reports/docs/final2020ai.pdf. 160 review revised fire severity maps being development by CalFire and develop a comprehensive wildfire mitigation plan. Wildland-Urban Interface (WUI) Requirements The WUI is the area where structures meet or intermingle with undeveloped wildland vegetation. These structures are vulnerable to fire damage, as they are close to fire hazards. In 2003,the California State Fire Marshall, in consultation with the Director of Forestry and Fire Protection and HCD, was tasked with developing statewide fire protection requirements for roofs, exterior walls, structure projections, and structure openings of buildings located in WUI Fire Areas. These requirements became fully effective in 2007, and all new homes built in the WUI Fire Areas must meet these building requirements. Through a collaborative effort of the California Department of Forestry and Fire Protection (CAL FIRE), Office of the State Fire Marshal, local fire districts, building associations and other public safety organizations, the WUI codes have been developed to encourage ignition resistant construction standards to maximize ignition resistance. TheWUI codes are a requirement for new buildings in Fire Hazard Severity Zones in State Responsibility Areas (where the state is primarily responsible for the prevention and suppression of forest fires), and otherwise adopted at the discretionof local districts responsible for their own fire protection. Mostimpacted areas are located in State Responsibility Areas. Building standard include specific regulation of materials and design for roofing, attic ventilation, 62 exterior walls, deking and underfloor. WUI flammable vegetation within 30 feet of buildings and modify vegetation within 100 feet around buildings to create a defensible space for firefighters to safely protect vulnerable property and to reduce fuels by which fire may continue to grow or spread. In accordance with the Federal Register Notice requirement to support the adoption and enforcement of modern and/or resilient building codes and mitigation of hazard risk, structures located in any Fire Hazard Severity Zone within State Responsibility Areas, any Local Agency Very-High Fire Hazard Severity Zone, or any Wildland Urban Interface Fire Area designated by the enforcing agency. The following figureshowsthe fire hazard areas for the counties impacted by the DR-4558and DR-4569disasters. 62 and Investigations Division (CAL FIRE, December 14, 2021),https://osfm.fire.ca.gov/media/kmfiqck3/2021-sfm-wui-listed-products-handbook-12- 14-2021.pdf. 161 F IGURE 152:F IRE H AZARD S EVERITY Z ONES IN S TATE R ESPONSIBILITY A REAS Source: CAL FIRE, U.S. Census Bureau Construction Standards The State Housing Law Program continuously refines the building standards to ensure they comply with new or changing laws and regulation and develops statewide building standards for new construction of all building types and accessories. The State HousingLaw Program also develops the building standards necessary to provide accessibility in the design and construction of all housing other than publicly funded housing. The building standards are published as the California Building Standards Code under the California Code of Regulation, Title 24, and construction standards in the Standard Agreement and orconstruction agreements, executedas applicable forproject type and beneficiary,must meet or exceed all applicable requirements for housing or building construction. 162 All new construction is required to pass quality inspections and code enforcement inspections over the development of the project, in addition to meeting accessibility requirements of the federal Fair Housing Act, Section 504 of the Rehabilitation Act of 1973,Title VI of the Civil Rights Act of 1964, and the Americans with Disabilities Act. HCD will require a post construction warranty period of one-year for all work performed, including any work completed by subcontractors. Elevation Standards HCD will require its subgrantees and contractors to comply with the national floodplain elevation standards for new construction, repair of substantially damaged structures, or substantial improvements to residential structures in flood hazard areas. All structures designed for residential use within a 100-year (or one percent annual chance) floodplain will be elevated with the lowest floor at least two feet above the base flood elevation level and comply with the requirements oftheConsolidated Notice, 87 FR 6370. Costs of elevation will be included as part of the overall cost of rehabilitation of a property. Many homes in the impacted areas with substantial damage need updates to meet current federal, state and local code requirements when repaired. If a home is within a 100-year floodplain, a cost estimate will be completed and compared with local and national averages comparable to requiredfor elevation and the geography of the location. Any building that has a total cost of repairs greater than 50 percent of the pre-disaster value of the property is considered substantially damaged and will require the entire home to be brought into code compliance. Where a neighborhoodor large tract of houses havesubstantial damage and also require elevation, the overall impact of elevation on the long-term affordability and maintenance of the housing stock for the area will be considered in determining the best and most reasonable way forward to provide repairs. Flood Insurance Requirements Property owners receiving assistance through the Owner-Occupied Housing Recovery Program will be required to acquire and maintain flood insurance if their properties are located in a FEMA designated special flood hazard area. Greenand Resilient Building Standards AllCDBG-DR fundedprojects must identify an industry-recognizedgreen building standard and a minimum energy efficiencystandard. These standards are further addressed in housing and and procedures. Project files will include the requirements incorporated per project. Federal Green Building Standards HUD requires all rehabilitation, reconstruction, and new construction to be designed to incorporate principles of sustainability, including water and energy efficiency, resilience, and mitigating the impact of future disasters. Wherever feasible, the State of California follows best practices, such as those provided by the U.S. Department of Energy, Home Energy Professionals: Professional Certifications and Standard work specifications. For CDBG-DR 163 funded projects, HUD requires green building standards for replacement and new construction of residential housing.All rehabilitation projects will follow the policies and proceduresspecified in the HUD Community Planning and Development (CPD) Green Building Retrofit Checklist, to the extent applicable, for rehabilitation other than the rehabilitation of substantially damaged residential buildings. State Green Building Standards All new construction of residential buildings or reconstruction of substantially damaged buildings Code (CAL Greendatory in 2011, and adopted to address five divisions of building construction and improve public health, safety, and general welfare. The divisions addressed are as follows: planning and design, energy efficiency, water efficiencyand conservation, material conservation and resource efficiency, and environmental quality. In May 2018, the California Energy Commission adopted new building standards that requires all newly constructed homes to include solar photovoltaic systems, effective January 1, 2020. Homes built with the 2019 standards use approximately 53 percent less energy than those built under the 2016 standards. CAL Greenapplies to the planning, design, operation, construction, use, and occupancy of nearly every newly constructed building or structurein the state, as well as additions and 63 size. Residential Construction Standards All residential construction projects will comply with the housing construction codes of the State of California, including all units developed under the Owner-Occupied Housing Recovery Program or the MultifamilyHousingRecovery Program.Housing construction codes for building in California follow federal and state laws, regulations, and adaptions for construction of single family and Multifamily units. J.Appeals Process HCD will provide a mechanism for homeowners, cities, counties, and other entities to receive timely responses to complaints and appeals in order to maintain quality operations. The Complaints Section providesinformation on how to file a written complaint to HCD. Homeowners may appeal the quality of the rehabilitation work and file complaints. HCD will utilize a program implementation contractor to implement the owner-occupied housing program. 63 California Department of Housing and Community Development - (HCD, 2019), https://hcd.ca.gov/building-standards/index.shtml. 164 HCD, along with the program implementation contractor, will developarobust appealprocess that will be outlined in the program policies and procedures. The appeals process will include atminimum a two-level process which includes a program appeals process and state level appeals process. Prior to an appeals process, program staff will work with homeowners and contractors to resolve issues and ensurethe work completed meets code requirements and program standards. Contractors will be required to provide a one-year warranty period on work performed and will be required to address about the quality and timeliness of the work. The program will develop detailed procedures around process for homeownersgiven circumstances that the quality of rehabilitation work completed on their home does not meet program standards. The program staff will berequired to review and manage the appeals process. In the event that an appeal is not resolved in the program appeals process, the state appeals process will be activated. Further details on the appeals processes will be outlined in the program policies and procedures.Information about theappeals process and filing a complaint will be provided to homeowners with program materials, policies, and procedures. The process and expectation will also be explained to contractors and included within the construction contracts. K.Contractor Standards The Owner-Occupied Rehabilitation and Reconstruction Program completes repairs and procurement process. As part of thisprocess, contractors are required to complete a vendor background questionnaire and to report pertinent information relating to the contractor and/or its key personnel. Prior to contract execution, company background checks are conducted, and channels are established with other agencies to verify and validate those that will be providing services on behalf of the program. Processing steps including multiple levels of quality assurance and quality control review are conducted to validate vendor provided application construction process. Vendor-contractors participating in the program must be licensedproperly licensed by the state of California and must meet all state and bonding requirements associated with the size and types of projects that they are working on. They must also maintain general liability and builders risk insurance as well as workers compensation coverage at all times. The program conducts periodic construction inspections that verify progression of work and vendor-contractor is not completing work in keeping with industryhomebuilding contractor standards andworkmanshipmaysubmitagrievance to the program and the state in writing as detailed in section 12.3 of the policies and procedures for the Owner-Occupied Rehabilitation and Reconstruction Program. During the program application process, participants are provided with a notice of the danger of fraud and scams perpetrated by unscrupulous individuals, contractors, and businesses. Anyone wishing to report suspicious or fraudulent activity may contact the program via email at ReCoverCA@hcd.ca.govor via phone at (916) 263-6461. 165 If, during reconstruction or rehabilitation or their homes, applicants are victimized through theft, vandalism, or contractor fraud, they are encouraged to report all incidents immediately to the program via email at ReCoverCA@hcd.ca.gov or contact a program representative via phone at (916) 263-6461.Applicants experiencing contractor fraud will be required to complete a formal complaint with a government authority such as a law enforcement agency, the California a court detailing the cause and amount of fraud in sufficient form can suffice. All cases of suspected contractor fraud will be reviewed by HCD for administrative and potential unmet needs consideration. As detailed in section 9.5.15 of this program policy, ReCoverCA has procedures the program can provide scope to cover the appl HCD has established areferral process with the HUD Office of Inspector Generalfor any suspected applicant or contractor wrongdoing. After internal fact gathering and review, HCD will forward suspected fraudulent activity for additional law enforcement follow-up, as necessary. L.Preparedness, Mitigation, and Resiliency To integrate hazard mitigation and resilience planning with recovery efforts HCD will promote sound, sustainable, long-term recovery planning informed by post-disaster evaluation of hazard risk, including climate-related hazards, and the creation of resilience performance metrics. HUD defines resilience for CDBG- and recover quickly from extreme events and changing conditions, including natural hazard 64 construction related programs include construction standards that will incorporate resilience and hazard mitigation measures into CDBG-DR funded activities. In response to 87 FR 6370 this Action Plan must align with existing FEMA or other state, local, or tribal hazard mitigation plans. In addition, mitigation measures must be incorporated when carrying out activities to construct, reconstruct, or rehabilitate residentialor non-residential structures with CDBG-DR funds. Forthese construction activities for residential or non-residential structures, HCD must establish resilience performance metrics for the activity including: An estimate of the projected risk to the completed activity from natural hazards, including those hazards that are influenced by climate change. Identification of the mitigation measures that will address the projected risks, and e data. For OOR and MHP HCD will take into account the fire severity zones in which the funded OOR and MHP properties are located to assess how Cal Fire and local jurisdictions make those 64 Climate Resilience and Disaster Recovery at HUDDisasterRecovery& Special Issues Division -Office of Community Planning & Development, n.d.), https://www.hud.gov/sites/dfiles/CPD/documents/Climate_Action_Equity_and_Recovery_Slides.pdf. 166 determinationsto include how climate change impacts wildfire risk.Additionally, HCD will considerfire-resistant characteristics required for compliance with Wildland Urban Interface (WUI)code as well as any building methods and materials that the program is using that will exceed WUI standards. HCD will assist subrecipients to define appropriate resilience metrics for infrastructure projects with the FEMA PA Match Program. M.Cost Controls for Cost-Reasonableness All construction activities that utilize CDBG-DR funds, including the mitigation set-aside, must be reasonable and consistent with market costs at the time and placeof constructionor procurement. To comply with this requirement, HCD will follow the procedures outlined in Section VI, Part N of the HCD CDBG-DR Grants Administration Manual(CDBG-DR GAM) to complete and document independent cost estimates (ICE), cost or price analyses, and cost reasonablenessdetermination within each of its procurements.Additionally, for OOR are such as Xactimate for all estimating to ensure cost reasonable industry standards. Specific parameters regarding cost reasonableness requirements will also be outlined within policies and procedures on a program- by-program basis. Subrecipients must take into account the costs and benefits of incorporating hazard mitigation measures to protect against the specific identified impacts of future extreme weather events and other natural hazards. N.Duplication of BenefitsReview Asupplication of benefits occurs when an impacted homeowner or community receives financial assistance from multiple sources such as FEMA, USACE, EDA, insurance, etc. for a cumulative amountthat exceeds the total need for a particular mitigation purpose.A duplication of benefits (DOB) review will be applied to all CDBG-DR activities. need, subrecipients must follow . The process for determining any duplicates includes assessing the need, identifying the total assistance available to the applicant deducting benefits received for a different purpose, deducting funds received for the same purpose but different eligible use, and funds not available. Once the duplicated funds have been identified and subtracted from the unmet need amount, any remaining unmet need can be assisted with the CDBG-DR funds. All agreements between HCD and beneficiaries, and HCD and subrecipients requireall sources of possible duplicative assistance to be disclosed to HCD. Additionally, a subrogation clause contained in these agreements requires any person who receives further assistance to repay that assistance, if the amount of assistance exceeds the funding required for the project. O.Fair Housing HCD will follow policies and procedures for compliance with Affirmatively Furthering Fair Housing (AFFH) requirements during the planning and implementation of all the activities listed in this Action Plan. Such policies and procedures involve a review that includes an assessment 167 of the demographics of the proposed housing project area, socioeconomic characteristics, environmental hazard or concerns, and other factors material to the AFFH determination. Programs are required to comply with all relevant fairhousing laws, including the federal Fair Housing Act, Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, and the Americans with Disabilities Act. These laws prohibit discrimination in housing and federally assisted programs on the basis of race, color, national origin, religion, sex, disability, and familial status. The federal obligation to affirmatively further fair housing stems from the Fair Housing Act. State fair housing laws, including the California Fair Employment and Housing Act, are also required for Fair Housing compliance. P.Demonstrable Hardship policies for applicants who demonstrate undue hardship. A demonstrable hardship is defined as provide and maintain a minimal standardof livingor basic necessities, such as food, housing, clothingand transportation, causing economic distress well beyond mere inconvenience. A demonstrable hardship must occur after the fires and must be documented with objective evidence. The demonstrable hardship must be of a severe, involuntary and unexpected nature, and not generally for the same reasons shared with other households affected by the disaster. Examples of demonstrable hardship may include job loss, failure of a business, divorce, severe medical illness, injury, death of a family member or spouse, unexpected and extraordinary medical bills, disability, substantial income reduction, unusual and excessive amount of debt due to a natural disaster, etc. However, there is no one event that automatically defines a demonstrable hardship. HCD will consider ea hardship is claimed, and documentation can be provided showing the cause and other factors relevant to the issue of demonstrable hardship. Q.Not Suitable for Rehabilitation HCD defines a structure as not suitable for rehabilitation in two scenarios: The cost for rehabilitation is over 50 percent of the pre-disaster fair market value of the home The cost for rehabilitation exceeds the cost to reconstruct the home. IV.Grantee Proposed Use of Funds A.Connection of Programs to Unmet Needs 1.Unmet Needs and Proposed Programs Programs are developed to address the most severeunmet needs and in full compliance with the Federal Register Notice.The level of unmet recovery need identified in both eligible 2020 counties, as well as the MID counties far exceeds the amount available through the current 168 2020 funding allocation.With limited funds available, HCDmust prioritize its limited funding on areas that will make the most impact for low and moderate income, federally protected classes, and vulnerable populations. In an effort to maximize its impact, HCDproposes to use the 2020 funds to focus on unmet housing need and infrastructure funding that can support housing development. As discussed in the Unmet Needs section, there areunmet recoveryneeds across all eligible activities. The needs assessment influenced the development and prioritization of recovery activities outlined in the Action Plan. HCD consulted with affected citizens, stakeholders, local governments, and public housing authorities to assess needs. Following the guidance in the focus its 2020 CDBG-DR resources primarily on housing program in MID areas, with the remaining funding for FEMA PA match for housing-related infrastructure projects in MID areas. HCD acknowledges that any proposed CDBG-DR funded programs must also consider eligible CDBG activities, must be responsive to CDBG national objectives, must comply with all regulatory guidance issued to HCD, and must consider best practices established through similar recovery initiatives. Allocation of Funds As required by the Federal Register notice, 87 FR 6364, this Action Plan must describe the method of distribution of funds and the descriptions of specific programs or activities HCD will carry out directly. This Action Plan outlines the following: Eligible affected areas and subrecipients; Criteria for eligibility; Methodologyused to distribute funds to subrecipients; Activities for which funding may be used; and Program requirements, including Duplicationof Benefits analysis. Allocations for the CDBG-DRprograms are based on needs as identified through an analysis of FEMA IA and FEMA PA claims.The primary consideration in developing effective CDBG-DR programming is the unmet needs analysis. Programs are developedto address the most severe unmet needs and in full compliance with the Federal Register Notice. TheNeeds Assessment showsthattotal unmet recovery needs surpass the CDBG-DR funds allocated to the state by HUD. HCD based programming decisions on best available data from multiple sources, including FEMA, SBA, private insurance, state agencies, and local governments, broad engagement withthe public and stakeholders, and planning discussions about program typologies and design options to maximize the benefits of the available funding. The allocations for each recovery programare based on the unmet needs analysis, which identified housing and infrastructure as a crucial unmet recovery need. HCD also performed a mitigation needs assessment to inform activities proposed for the mitigation set-aside. B.National Objective In accordance with 24 CFR 570.208, all CDBG-DR andMitigationfunded activities must satisfy a national objective. Each program description had detailed information on the national objective it is projected to meet. HCD anticipates that through program design and implementation, all 169 programswill either meet the low to moderate income housing national objective, lowto moderatearea benefit national objective, or urgent need national objective. C.Program Budget The budget table below,Figure 152,provides budget for each proposed CDBG-DR and Mitigationprogram in the Action Plan.The program allocations include program funds as well as activity delivery costs(ADCs)which are anticipated tobe incurred by HCD, its contractors, and subrecipients where applicable. F IGURE 153:2020CDBG-DRA CTION P LAN T OTAL A LLOCATION AND P ROGRAM F UNDING BY P ROGRAM T YPE 2020 CDBG-DR Action Plan Total Budget$231,203,000Program % Administration$11,560,1505% 2020 Total Funding CDBG-DR (with administration)$201,046,00087% 2020 Total Funding Mitigation Set-Aside (with $30,157,00013% administration) CDBG-DR Program Funding$190,993,700 Housing Programs$183,353,95296% Multifamily Housing Program$128,347,76670% Owner Occupied Housing Program$45,838,48825% Homebuyer Assistance Program$9,167,6985% Infrastructure Programs$7,639,7484% FEMA PA Match$7,639,748100% Mitigation Set-Aside Program Funding$28,649,15015% Owner Occupied Housing Mitigation Program$21,486,86375% Multifamily Housing Mitigation$7,162,28725% D.Leveraging Funds Over the last three decades, HCD has providedmore than $3 billion in funding for the development of affordable housing and associated infrastructure. HCD manages non- entitlement programs, providing leadership and policies to preserve and expand safe and affordable housing opportunities and promote strong communities for all Californians. By administering programs that provide grants and loans from both state and federal housing programs, HCD canleverage existing programstoincreasethe impact of CDBG-Dr funding. Tomaximize the impact of the CDBG-DR funding provided to the state, there will be an ongoing commitment to identify and leverage other federal and non-federal funding sources. HCD will alsoutilize existing relationships and strive to create new partnerships with other federal and state agencies, corporations, foundations, nonprofits, and other stakeholders as a means of leveraging all viable sources of funding. CDBG-DR funds will be used to address critical unmet needs that remain following the infusion of funding from other federal sources, including FEMA and SBA. Existing state resources and other funds from the disaster appropriation will also be examined to ensure that all available funding is used where it is most needed. 170 Furthermore, the state has designed all housing programsin this Action Plan to cover the gap in funding remaining after insurance, and other assistance has been applied to each project. Understanding the limited funding for recovery, the state will encourage all program applicants to seekout other funding sources to meet their full recovery needs. The state has authorized many housing programs that may complement the recovery effort. These programs are either competitive or are issued based on a formula allocation; no loans or grants are made directly to individual households. Cities, counties, qualified CHDOs, affordable housing corporations, and other qualified applicants may apply to build more affordable housing in their community to speed recovery. E.Program Allocations 1.Method of Distribution HCD will distribute funds to beneficiaries using one of two methods: 1) HCD administered programs and 2) 2.Criteria to Determine Method of Distribution Funds are distributed among proposed programs using an objective methodology targeted towards the Most Impacted and Distressed identified earlier in this document. Distribution methods are designed to consider the unique context and needs of affected populations as well as the administrative capacity ofjurisdictions that will manage the local recovery process. This methodology ensures that CDBG-DR funds will be used to maximum benefit to address unmet housing recovery, infrastructure repair, mitigation goals, and economic revitalization needs. As requiredby the Federal Register Notice, HCDconducted an assessment of its internal capacity during program planning and design. The capacity assessment concluded that, with organizational and staffing adjustments at HCD, theDepartment can successfully launch and directly manage a large statewide program. HCD also assessed the capacity of local governments to administer CDBG-DR funded programs during recovery planning and coordination discussions. This assessment included evaluations of localitiesmiliaritywith key grant administration requirements, experience managing programs similar to those proposed in thisAction Plan, and ability to addnecessary capacity and subject matter expertise through hiring or procurement. Through the conversations and working sessions with local officials, HCD gained a clear understanding of local strengths and how best to leverage the capacity and expertise at the local level. These assessments concluded that local governments are best positioned to operate and manage project specific funding related to infrastructure. a.MultifamilyProgram Allocation For the Multifamily Program, allocations are based on FEMA IA applicant data for LMI renter- occupied households that were categorized as having Major or Severe damage according to recovery needs for the 2020 disasters, HCD proposes to limit funding available for all CDBG-DR and mitigation programs to only MID counties. 171 HCD is aware that disasters disproportionately affect LMI households, and that this disparate impact, combined with pre-disaster vulnerabilities, make the recovery process especially challengingfor vulnerable populations and underserved communities.LMI households are also more likely to be displaced during and after a disasterdue to limited resources and a diminished stock of affordable, available, and safe housing. To mitigate those inequities, HCD applied the following allocation model: Number of LMI 2020 Impacted Percent of Total Renters Impacted Allocation CountyDamage (FEMA FVL) Santa Cruz (County)49934%$43,479,657 Butte (County)38726%$33,720,696 Napa (County)14210%$12,372,969 Sonoma (County)1329%$11,501,633 Los Angeles (County)1198%$10,368,896 Solano (County)896%$7,754,889 Siskiyou (County)493%$4,269,546 Fresno (County)433%$3,746,744 Shasta (County)131%$1,132,737 Total1,473100%$128,347,766 b.Infrastructure Funding Allocation The overall allocation to the infrastructure recovery program is based on the unmet needs analysisfor the local match for FEMAPA projects for categories C-G. 3.HCD Administered HCD will directly operate theOwner-Occupied Housing Rehabilitation and Reconstruction Program(OOR)and the Multifamily program. For the OOR staff will engage impacted homeownersstatewide to apply for assistance.HCD willutilizea qualified vendor to perform full scale program management duties to augment HCD capacity and ensure high quality customer service delivery. Program staff will work with the procured vendor to maintain program timeliness, provide oversight, and ensure all levels of the program are compliant. HCDwill directly administer the MultifamilyProgram and will directly solicit applications for affordable housing development projects. Funding will be made available to applicants by HCD through a Notice of Funding Availability (NOFA) process whereby applicants will compete for funds in one of six regional set-asides based on the location of the proposed project. The Homebuyer Assistance Programwill be a standalone program directly administered and implemented by HCD with the assistance of either a state agency partner or a procured contractorand will provide down payment and other housing assistance to low-to moderate- income disaster impacted homeowners, enabling them to relocate outside of high-risk areas or thedisaster declared areas. 172 4.SubrecipientAdministered HCD will engage with subrecipients to administer the Infrastructure RecoveryProgram. The Program will fund the CDBG-DR eligible local match for FEMAPA projectsfor categories C-G. All projects will be vetted for CDBG-DR compliance and eligibility, ensuring that proposed projects adhere to federal requirements and the requirements set forth in the Action Planand program policies and procedures. The implementation and management of individual projects will be the responsibility of participating subrecipients, while HCD will provide monitoring and broad oversight of subrecipientadministered funds. 5.Reimbursement Payments to Subrecipients HCD operates on a reimbursement basis for all CDBG-DRand MIT projects. All costs must be incurred and paid for by the subrecipient prior to HCD providing a reimbursement from the U.S. Treasury. Subrecipients are expected to submit payment requests on a monthly basis according to the Standard Agreement and provide evidence that all invoices and costs incurred were paid and the work was inspected. Payments for eligible costs are processed when submitted to HCD as reimbursements for subrecipients for expenses incurred during the project. Mitigation staff then reconcile expenditures with FI$Cal and Grants Network, the financial system and systems of record for the state and HCD. Processes for monitoring expenditures of subrecipients and payment processing are outlined in Under certain conditions, subrecipients may incur costs prior to the effective date of their grant agreement. The subrecipient may then pay those costs (including reimbursing itself if it used its own funds to pay the costs) after the effective date of the grant agreement. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with written approval of HCD. If pre-awardcosts (also known as pre-agreement costs) are incurred for an eligible activity listed in this action plan, the payment for eligible costs must comply with the pre-award regulations at 24 CFR 570.200(h) and 570.489(b) and follow the guidance issued by HUD in the Community and Planning Development (CPD) notice 15-07. Full eligibility criteria will be provided in the program policies and proceduresand will be made available during the project application phase. 6.Program Income In some circumstances, CDBG-DRor CDBG-MITfunded activities may generate program project or administration costs related to the awarded project before additional grant dollars are expended. Any incomegenerated by a subrecipient must be reported to HCD on a regular basis, as detailed in the Standard Agreement between HCD and the subrecipient. HCD reports all program income to HUD through the HUD Disaster Recovery Grant Reporting System (DRGR). 173 Furtherdetails on how program income is managed and reported on by subrecipients and HCD is provided in the GAM. 7.Recapture Under the OOR an applicant may be required to repay all, or a portion of the assistance received from the Program. The reasons for grant recapture mayincludethe following reasons: Providing false or misleading information to the OOR Withdrawal from OOR priorto completion of the project. Withdrawal from the program must be in writing or email and a new survey and application will be required if the applicant wishes to participate again. Construction is not completed due to non-cooperation by owner(s). Non-compliance with the approved SOW in a manner that would make the home ineligible (i.e., did not comply with lead paint abatement requirements). Failure to report the receipt of additional insurance, SBA, FEMA,non-profit assistance and/or any other DOB received after award. To address any potential future DOB, applicant beneficiaries must, as a requirement for participating in OOR, agree to enter into a signed subrogation agreement to repay any assistance later received for the same purpose as the CDBG-DR funds. If, afteran awardis issued, a re-assessment of need occurs and the applicant receives an increased award, then the applicant shall be required to sign a revised subrogation agreement to repay any assistance later received for the same purpose as the CDBG-DR funds. 8.Eligible Geographic Areas HUD requires that 80 percent of CDBG-DR funding be spent within areas designated as Most Impacted and Distressed(MID areas).HCD will spend 100 percent of the 2020 DR Allocation, to include the mitigation set-aside, in the HUD MID areas. The following counties make up the MID areas for DR-4558 and DR-4569: Butte, Fresno, Los Angeles,Napa, Santa Cruz, Shasta, Siskiyou, Solano, and Sonoma.Data sources relating to these MID counties arefurther explained in the Unmet Needs Assessment section of this Action Plan. F.Housing Recovery Programs HCDwill implementasuite ofhousing recovery programs to address the unmet recovery need in the HUD MID areas:an Owner-Occupied Housing Rehabilitation and Reconstruction Program (OOR), a Homebuyer Assistance Program (HBA)and a MultifamilyHousing Program(MHP). Together, the housing programs will receive$183,353,952of the received CDBG-DR funds. This represents approximately 96percent of the CDBG-DR funds allocated in PL 117-43to the State of California.The unmet needs analysisidentified a total housing unmet recovery need of$463,567,364, for both owner-occupied and rental dwellings.Additionally, HCD is allocating 100 percentof the Mitigation set-aside program funding,$28,649,150, to benefit OOR and MHP properties.At the outset of the OOR launch, an interest survey will be conducted to identify 174 demand for the program being launched and inform the need for additional programming considerations. The survey will assist in evaluatingthe specific recovery needs of impacted property owners as well identifydemographic information to assist in targeting recovery funds to vulnerable populations. Additionally, HCD has consulted withhousing counseling agencies in the development of this Action Plan and will continue to work with these agencies as the housing recovery programs are implemented. HCD will follow policies and procedures for compliance with Affirmatively Furthering Fair Housing (AFFH) requirements during the planning and implementation of each housing activity to lessen area racial, ethnic, and low-income concentrations, and/or promote affordable housing across the disaster-affected areas. Programs will also be developed with the intent to minimize displacement of persons or entities following 24 CFR part 42.325, 49 CFR part 24 of the URA, 104(d) of the HCDA, and regulations under 24 CFR part 570.496(a). arketing procedures for outreach to protected class groups least likely to apply. Additionally, materials will be provided in other languages, such as Spanish, to accommodate LEP persons. Language access services for persons who are LEP and the availability of accessible features and reasonable accommodations for persons with disabilities will be provided through case management. OOR and MHP projects will incorporate mitigation measures for home and property hardening which may include the creation of defensible space zones to reduce wildfire risk to properties. Home hardening includes the use of materials and methods that make a home or multifamily buildingmore resistant to wildfire. Eligible activities that meet the definition of mitigation definition and meet a national objective will utilize the CDBG-DR Mitigation set-aside.HCD will track all use of the Mitigation set-aside as a separate activity type in the HUD Disaster Recovery and Grant Reporting system (DRGR). HCDhas createda comprehensive suite of programs under the ReCoverCA umbrella that respond to the needs of both disaster-impacted communities and the individuals that reside within them. Owner Occupied Housing Rehabilitation and Reconstruction Program Owner Occupied Housing Rehabilitation and Reconstruction Mitigation Program Housing Counseling Homebuyer Assistance Program 1.Owner Occupied Housing Rehabilitation and Reconstruction Program Theprimary objective of OORis the provision of decent, safe, and sanitary housing in the areas impacted by the DR-4558 and DR-4569 disasters.Additionally, the program is designed to ensure that the housing needs of very-low, low-, and moderate-income households and vulnerable populations, including individuals that were made homeless as a result of the disaster, are addressed to the greatest extent feasible. Furthermore, the program will not only address disaster-related damages but also will mitigate potential future damage. The program will provide rehabilitation orreconstruction assistance to eligible applicants based on the extent of damage to their primary residences. All projects will incorporate wildfire mitigation measures including the use of ignition-resistant building materials and the creation of defensiblespace, reducing risk from future wildfire disasters. 175 Allocation Amount(Program Level): 100 percent of the funds budgeted for OOR rehabilitation and reconstruction, as well OOR Mitigation will meetunmetneed in the HUD-MID) counties. OORRehabilitation and ReconstructionCDBG-$45,838,488 DR funds OOR MitigationHome HardeningMitigation $21,486,863 set-aside OOR projects will utilize funds fromthe budget line items above to cover the costs to rehabilitate or reconstruct owner-occupied residential structuresandincorporate mitigation measures.All activity costs allocating tothe Mitigation set-aside will meet the definition of mitigation as required in the FRN. ProgramDelivery Responsible Entity OOR and contract managers. The 2020 programOOR Program for2017 and 2018 disasters, using itssystems and processesto ensure both a rapid startup and iterative improvement.The state utilizesa qualified vendor to perform full scale program management services, including capacity-building for HCD staff, marketing and distribution of the program survey, overseeing intake, completing eligibility andbenefit determinations, providing case management through the process, quality control to prevent fraud, waste, and abuse, construction monitoring, and construction management. Applicantsareassigned case managers to support them through the recovery process from application to construction and project closeout. Form of Assistance Assistance is provided in the form of a grant award to qualifying applicants for therehabilitation or reconstruction of their primary residence.enters into an agreement with the property owner and managesand performsall rehabilitation or reconstruction activities,as well as mitigation activities included within the contract scope of work.The award is providedin increments as construction and mitigation activities are completed. Maximum Assistance: The maximum amount of assistance availablefor rehabilitation or reconstruction is $500,000 per damaged structure after applying any duplication of benefits reductions.Reconstruction is permissible where the total cost of rehabilitation is greater than the cost to reconstructor where rehabilitation is otherwise technically infeasible. Reconstruction is defined as the rebuilding of a structure on the same site in substantially the same manner. A reconstructed property must not 176 increase the number of dwellings on site, although the number of rooms may increase or decrease. In addition to the grant award for rehabilitation or reconstruction,the mitigation set-aside will assist in covering home hardeningcoststo include the cost of WUI construction codes; the set- aside isavailable in amounts not to exceed 10percentofeach reconstruction CDBG-DR award. Additionally, the OOR Mitigation program is eligible to owner-occupied properties that did not suffer damage in the DR-4558 or DR-4569 events, but are located in the MID, and can utilize the rehabilitation activity to enable the single-familyunit to meet the WUI code standards to make their homes more resistant to wildfire. OOR applicants applying for rehabilitation to bring their homes up to WUI code standards may receive up to $50,000 in grant assistance. Hardships: As a standard practice, OORapplicants requiring more than the cap onAssistance must fund the remainder of their project with private funds or other resources, however, exceptions to the maximum award will be considered on a case-by-case basis. In situations where the applicant has a demonstrable hardship, the specific conditionswill be evaluated to determine how best to proceed. adisaster that prohibits or severely affects their ability to provide a minimal standard of living or the basic necessities of life, including food, housing, clothing, and transportation. Such instances typically include job loss, business failure, divorce, severe medical illness, and disability. Program staff will evaluate instances of demonstrable hardship on a case-by-case basis after review of the circumstances. The criteria for documenting such hardship may have the award cap increased up to the amount required to complete the repair or reconstruction of their property. a.Eligible Activities Through the FRN,87 FR 6370, HUD adopts alternative requirements to activities eligible under HCDA Section 105(a) which allows California to carry outmodified activitiestocomply with the requirements in the FRN to incorporate mitigation measures as a construction standard. Housing activities allowed under CDBG-DR; HCDA Section 105(a)(1), 105(a)(3-4), 105(a)(8), 105(a)(11), 105(a)(18), and 105(a)(25), include but are not limited to: Single family owner-occupied rehabilitation, reconstruction, and/ornew construction; Repair and replacement of manufactured housing units; Hazard mitigation; Elevation; Relocation Assistance; Demolition only; Public service with the 15 percent cap (e.g.,housing counseling, legal counseling, job training, mental health, and general health services); and Other administrativeactivities associated with the recovery of single-family housing stock impacted. 177 b.National Objective In accordance with 24 CFR 570.208andSection 104(b)(3) of the Housing and Community Development Act (HCDA), all CDBG-DR funded activities must satisfy a national objective. All OORactivities will meet either the urgent need or LMI housing national objective criteria related to disaster recovery.As stated in the Needs Assessment, the location of the disasters present unique challenges for addressing housing impacts. The disasters impacted households of all incomes and landscapes, including suburban neighborhoods and rural communities. While there are regional differences in the housing markets, all of the impacted areas struggle to provide an adequate supply of affordable homes to area residents. The dollar amounts reflected in the budgetary split between OORwhich will serve homeowners, and the MHP, which will serve renters, take displacement of LMI would-be applicants into account and the MHPbudget is based on FEMA IA data. Thus,the prioritization criteria for participation in OORwill ensure that housing recovery programming will be directed toward LMI beneficiaries.However, HCD understands the devastating impacts the fires had on non-LMI owners, and the urgency to provide assistance and return them to their homes. Figure 63in the needs assessment shows the impacted counties which had impacts to non LMI homeowners.HCD has made tiers three and four of its prioritizationsavailable to non LMI homeownersin the MID.Utilizing urgent need is critical to ensuring the recovery of theentire community. HCD anticipates thatall OOR urgent need funding will be spent in the required 36 months per the FRN. c.Incorporation of Mitigation Measures HCD will incorporate mitigation measures into activities under the OORby meeting or exceeding the State of California building code, which incorporatesmitigation measures. For example, there are minimum standards for materials and materialassemblies to provide a reasonable level of exterior wildfire exposure protection for buildings in WIUareas; in high-risk fire areas, WUIcode is also applied, which is an additional code upgrade that includes fire resistant exterior materials and requirements to maintain defensible space around the home. The program will apply the mitigation measures in the WUI code to areas both inside and outside of where it is mandated by code. In addition, the code requiresindoor fire sprinklers for single-family homes.All residential construction projects must comply with the current published housing construction codes for the State of California. Housing construction codes for building in California follow federal and state laws, regulations, and adaptions for construction of single family and Multifamilyunits. Building standards are published as the California Buildings Standards Code under the California Code of Regulations, Title 24, and construction standards must meet or exceed all applicable requirements for housing or building construction. Const https://www.hcd.ca.gov/building-standards/index.shtml. Specific code compliance to achieve hazard mitigation, such as WUIcodes, are implemented where applicable according to local code and the unique needs of impacted communities. Applying WUI codes to areas within the burn scar but outside of declared WUI areas recognizes that risk maps cannot keep pace with the rapidly changing fire risk. 178 WUIcodes are designed to mitigate the risks from wildfire to life and property. The standards within a WUI code vary according to the scope that a community is willing to adopt and enforce. WUI area codesmay include the following topics: Structure density and location: number of structures allowed in areas at risk from wildfire, plus setbacks (distance between structures and distance between other features such as slopes). Building materials and construction: roof assembly and covering, eaves, vents, gutters, exterior walls, windows, non-combustible building materials, and non- combustible surface. Vegetation management: tree thinning, spacing, limbing, and trimming; removal of any vegetation gr vegetation removal, and brush clearance; vegetation conversion, fuel modifications, and landscaping. Emergency vehicle access: driveways, turnarounds, emergency access roads, marking of roads, and property address markers. Water supply: approved water sources and adequate water supply. Fire protection: automatic sprinkler system, spark arresters, and propanetank storage. d.Deed Restrictionsand Restrictive Covenants To safeguard the CDBG-DR investment in the property, HCD requiresa deed restriction or restrictive covenant on properties funded through the program. The deed restriction or restrictive covenantremainsin effect for a period oftwo years following the date of receipt of the certificate of occupancy of the rehabilitated or reconstructed structure. For the length of the deed restriction or restrictive covenant, the property must remain as the primary residence of the owner-occupants to whomthe rehabilitation/reconstruction grant was made.Selling the property, using it as a second home, converting it into rental property, or otherwise changing its owner of record will result in non-compliance. Propertieswill be monitored annuallyby HCD for compliance with the deed restrictive covenantand failure to comply with the deed restriction or restrictive covenant will result in grant fund recovery. The deed restriction or restrictive covenant may be releasedon a case-by-case basis by HCD in certain circumstances. The specific language and requirements in the deed restriction or restrictive covenant will be set forth in the program policies and proceduresand will be available for applicants participating in the OOR program. e.Affirmative Marketing The outreach to protected class groups least likely to apply to the OOR Program. Additionally, materials will be provided in languages other than English, such as Spanish, to accommodate LEP persons. Language access services for persons who are LEP and the availability of accessible features and reasonableaccommodations for persons with disabilities will be provided to applicants through case management. f.Applicant Eligibility(Per OOR Property) Applicants will be eligible to participate in the OOR Program if they meet the following criteria: 179 Must have owned the home at the time of the qualifying disaster. Must have occupied the home as their primary residence at the time of the qualifying disaster. Home must be located in a MID county. The home must have been damaged as a result of the qualifying disaster and located in a MIDcounty. Applicants only applying for OOR Mitigationmeasures are exempt. Must be current on property taxes or have an approved payment plan or tax exemption. The property must have been correctly permitted and permissible for the zoning area or local development standard. The property must be a single-family dwelling, such as astick built, modular, or mobile home (i.e., not a condominium, duplex, fourplex, or another multi-owner property). HCD will assess applicant eligibility on a case-by-casebasis according to the eligibility criteria fully defined in the program policies and procedures. Prioritization Applicants receiving OOR funding for rehabilitation and reconstruction and mitigation funds together areprioritized in accordance with the tiers outlined in(Figure): Owner-Occupied Housing Program Applicant Prioritization. HCDwill prioritizeeligible LMI households (Tiers 1-2) ahead ofnon-LMI households(Tiers 3-4).This is in recognition of theunique recovery challenges LMI households faceafterdisaster as well as requirement for 70 percent of the total CDBG-DR funding to benefit LMI populations. Within the LMI population,HCDis prioritizing the rehabilitation or reconstruction of houses with major or severe damageover those with lesser damage. HCD equates Major or Severe Damage in this context with theFEMA Substantial Damage definition of a structure that has sustained damage greater than 50 percent of its pre-disaster value.Higher damage levels typically correlatewith higher levels of unmet need. Should funding allow,afterserving eligibleLMI households (Tiers 1-2), HCD will serve non-LMI households in the same order, (Tier3),followed by those with non-major/severely damaged homes (Tier 4). Within each tier, owner occupied households with a household member that is disabled or has access or functional needs are given priority. HCDalsotook into consideration the SoVI analysis, which identified several of the counties with high ratings primarily for increased elderly and disabled populations. Applicants who apply for mitigation funding are not subject to prioritization. Only LMI households located in the MID counties are allowed to apply for mitigation funds only. 180 F IGURE 154:CBDG-DRO WNER-O CCUPIED H OUSING P ROGRAM A PPLICANT P RIORITIZATION T IERS Low-to moderate-Major or Non-LMI Minor income Severe householdsDamage (LMI)Damage households XX Tier 1 XX Tier2 XX Tier3 XX Tier4 g.Eligible and Ineligible Costs Eligible Costsinclude: Permitting, design, and planning Replacement of damaged or destroyed necessary equipment, such as HVAC units Repairs to or replacement of damaged on-site utilities such as water, sewer, electric, and gas Repairs to disaster damaged primary structures with standard grade materials Reconstruction of the disaster damaged primary structure with standard grade materials Upgrades required to meet current building code Site work to meet WUI standards Handicap accessibilityfeatures(if applicable) Lead-based paint and asbestos abatement (if applicable) Housing Counseling Tenant Relocation under the URA Eligible costs utilizing CDBG-DR funds must be expended for activities that document tie-back to the disaster event, with the exception of activities utilizing the mitigation set-aside. Eligible costs for OOR Mitigation only projects will include costs associated with bringing the home up to the WUI code standardsas defined in the policies and procedures. IneligibleCostsinclude: Repair orreplacement ofauxiliary structures, such as detached garages or carports, storage units, outhouses, orsheds Materials greater thanstandard grade unless required by the localjurisdiction or by State law, such as certaingreen buildingrequirements Partial orincomplete repairs orreconstructions ofproperties Multifamily, condominiums, duplexes, triplexes, fourplexes orother rentalproperty Repair orreplacement ofluxury ornon-critical items, such as swimming pools and securitysystems Repair orreplacement ofpersonal property orbuildingcontents New homepurchase New construction off-site of the damaged structure (except in the case of a mobile home unit in a mobile home park where the park is permanently closed due to the disaster) 181 Forced mortgage payoffs Assistance for second homes h.Uniform Relocation Reimbursement is available for all reasonable out-of-pocket expenses incurred in connection with the temporary relocation of eligible tenants,includingthe cost of moving to and from temporarily occupied housing and anyincrease in monthly rent or utility costs at temporary housing. These costs will be reviewed for cost reasonableness and initially be paid by the Uniform Relocation vendor procured by HCD. i.Housing Counseling HCD understands the individualized nature of disaster recovery, and the complexities of the recovery process, as well as the necessity to join in that process to provide support and guidance through that process. As such, HCD offers a housing counseling program for disaster impacted individuals to include up to two optional counseling opportunities and one required counseling opportunity to support their housing recovery process. HousingCounseling Program provides eligible residents guidance and counseling for their housing needs related to impacts from the 2020 natural disasters, as well as housing needs related to impacts from both the 2017 and 2018 natural disasters. Current homeowners entering into the ReCoverCA housing programs receive counseling services on property maintenance, financial management, disaster recoveryfunding resources, financial and credit literacy, and other areas as needed and appropriate to assist in helping ReCoverCA program participants determine their housing recovery plan, improve their housing conditions, and meet their financial goals. Traditionally underserved populations, state and federally protected classes, including racial and ethnic minorities, the elderly, veterans, persons with disabilities, persons with limited English proficiency, and residents of rural areas, face unique disaster recovery housing, and economic 65 challenges. guidance, and information to help families and individuals, particularlythe most vulnerable, meet their housing needs through an informed decision-making process. j.Resilience Performance Metrics HCD will establish resilience performance metrics before carrying out OOR program activities. See description of resilience performance metricsunderIII.M.Preparedness, Mitigation, and Resiliency. 65 to Fair Housing:https://www.hcd.ca.gov/policy-research/plans-reports/docs/final2020ai.pdf. 182 k.Timeline and Expenditure Projections TheOOR execution of the grant agreement between HCD and HUD and remain operational through the end of the grant term or the exhaustion of funds. 2.Homebuyer Assistance Program Given the significant cost to rebuild in high fire hazard zones,exacerbating impacts of the pandemic, and disaster impacts that may have required homeowners 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. In partnership with the OOR program intake process, HCD will provide a Homebuyer Assistance Program (HBA) as an additional programmatic option to its housing recovery portfolio to meet the needs of those impacted by the 2020disasters. HBA will be a standalone program run by HCD with the assistance of either a state agency partner or a procured contractorand will provide down payment and other housing assistance to low-to moderate-income disaster impacted disaster impacted survivors, enabling them to relocate outside of high-risk areas or the disaster declared areas. a.Unmet Need The unmet need is affordable homeownership,for low to moderate income families,in areas where housing stock already exists. b. Allocation Amount Homebuyer Assistance Program$9,167,698 c. Maximum Assistance Applicants are eligible to receive up to a maximum award of$350,000. d. Eligible Activity 105(a)(24) Homeownership Assistance e. National Objective In accordance with 24 CFR 570.208 and Section 104(b)(3) of the Housing and Community Development Act (HCDA), all CDBG-DR funded activities must satisfy a national objective. All HBA activities will meet the LMI housing national objective criteria related to disaster recovery. 183 f. Eligible applicants LMI households whose primary residence was in a HUD MIDand was impacted by the 2020 disasters. g. 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 h.Ineligible Program Costs Moving expenses including storage expenses Temporary relocation housing Costs associated with the sale of the disaster impacted property i. Form of Assistance Funding for HBA is provided in a forgivable loan. Term of forgivenessis a minimum of 2 years. j. Housing Counseling Housing counseling assistance will provide program applicants with wrap around housing and financial educational services including financial literacy education, homebuyercounseling, 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. 3.Multifamily HousingProgram (MHP) The Multi-Family Housing Program (MHP)is designed tomeet the unmet rental housing need, including the needs of individuals displaced from rental mobile homes,single-family and multifamily rentalunits, as well asindividualsmade homeless as a result from the disaster. Multifamilyprojectsinclude apartment complexes and mixed-use developments. These developments are also intended to help replace rental housing units available to Housing Choice Voucher holders that were lost. The objective of the CDBG-DR funds is to provide necessary gap financing for the development of rental housing unitsin the HUD MID areas from DR-4558 and DR-4569.Furthermore, the program will not only address disaster-related damages but also will mitigate potential future damage. The program will provide rehabilitationandreconstructionto eligible applicants based on the extent of damage to theMultifamily propertywhile also providing hardeningto the property, to include the creation of defensible space zones that reduce wildfire risk to the residence.MHP funds are also available for new construction of Multifamily propertiesin theHUDMID areas fromDR-4558 andDR-4569.Projects will include scope of work to harden the properties to include creation of defensible space zones. 184 Programpolicies and procedureswill 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. In addition, the policies and procedures outlinerequirements relative to a minimum percentage of affordable units, the percentage of affordableversus market rate units, requirements for deep affordability, requirements for permanent supportive housing units, as well as the per unit maximumfunding available. Multifamily program affirmative marketing procedures and requirements for all CDBG-assisted housing with five or more units, including efforts to reach those least likely to apply, and persons with limited English proficiency. HCD has provided additional direction regarding how project applicants(developers), through affirmative marketing plans, shallprioritize fire-impacted households for occupancy of units. Applicants should also demonstrate thatproposed projects will affirmatively further fair housing, and are likely to lessen area racial, ethnic, and low-income concentrations, and/or promote affordable housing in low-poverty, nonminority areas in response to natural hazard related impacts. Projects should also be designed with the established community in mind tomitigatethe displacement of families and must commit to anaffordability period of 55years.If other funds requiring a longer affordability period are committed to the project, the longest affordability period will prevail for the project. Applicants shall displacement. a.Allocation Amount Multifamily Rehabilitation, Reconstruction, or $128,347,766 New ConstructionCDBG-DR Multifamily Property HardeningMitigation $7,162,287 Set-Aside b.Method of Distribution and Evaluation Criteria Fundingwill be madeavailable to applicants byHCDthrough a NOFA processwhereby applicantswill compete for funds in one of six regional set-asidesbased on the location of the proposed project.Regional set-asides are comprised of the sumofallocations to geographically proximate MID counties. The allocations arebased on a formula to determine a proportionate share of the total program allocation based on impacts to theMIDcountiesin that region. In response to the NOFA, applicants may apply for funds to carry out eligible activities associated with property hardeningin addition to rehabilitation and reconstruction.Mitigation set-aside funds are available to cover up to five percent of project costs for activities that meet the mitigation definition.The Action Plan budgetincludesa set-asideformitigationforhardening ofmultifamily propertiestoinclude the creation of defensible space zones to reduce wildfire risk. A second option for existing multifamily propertiesto apply for mitigation funds to harden properties against future wildfire events is described at the end of this section. 185 The NOFAwillinclude scoring criteria and application forms, application due dates, and submission instructions, andwill be published places as determined by HCD. The threshold eligibility review considerations will include, but not be limited to: Theproposed total MHP investmentis 40 percent or less of total development costs Theproject includes at least five units Thefunding request is limited to the amount needed to fill a funding gap Theproject will meet thelow-and moderate-income housingnational objective by providing at least 51 percent of units to be occupied by households earning less than 80 percent of area median incomeorbased on a pro-rata share of the unitsas determined by cost allocation performed using the MHP maximum per-unit subsidy Projectcosts are reasonable Project is incompliancewith all other federal requirements including but not limited to applicable fair housing and equal opportunity laws, labor standards, and Section 3 The competitive scoring criteria in the NOFA will include, but maynot be limited to: Projectreadiness based on status of local land entitlementsand permitting Projectreadiness based onwhether the project can reasonably start construction within 180 days Projectreadiness based on the status of the National Environmental Policy Act environmental review Applicationincludes local support in the form of a letter or resolution from the town, city, or county that is responsible for entitlementsand the California Environmental Quality Act environmental review Project proximity to damaged areas fromDR-4558 or DR-4569 Leveragingratio Deepaffordability targeting to households earning 30 percent or less of area median income, Demonstrationofdeveloper capacityto successfully implement the project within program timeframes. 186 F IGURE 155:M ULTIFAMILY H OUSING P ROGRAM NOFAR EGIONAL S ET-A SIDES CountyAmountRegion Total Santa Cruz $43,479,657$43,479,657 (County) $33,720,696$33,720,696 Butte (County) $12,372,969$31,629,490 Napa (County) $7,754,889- Solano (County) $11,501,633- Sonoma (County) Los Angeles $10,368,896$14,115,640 (County) $3,746,744- Fresno (County) $4,269,546$5,402,282 Siskiyou (County) $1,132,737- Shasta (County) $128,347,766$128,347,766 Total The regional set asides aboverepresent the total set aside for each region which includes ADC. Subsequent toNOFA publication,threshold eligibility reviews, and competitive scoring, allocations to projects will be made tothe highest scoring projectswithin each regional set-aside based on their demonstratedfunding gaps, up to MHPfunding limits of 40 percent of total development cost and cost allocationforMHP unitsbased on the MHP maximum per-unit subsidy.Ifaregion is over-subscribed, the lowest-ranked project will receive a partial award.Ifa region is under-subscribed, excess funds from that region will be allocated to the highest-rated project(s)among all projects in other regionsthat would otherwise receive a partial award.If funds remain after fully funding the remaining gap for the highest rated project(s) among all projects in other regions that would have otherwise received a partial award, funds will be allocated to the next highest rated project(s) among all projects in other regions, and such award may partially or fully address a demonstrated funding gap. c.Delivery Responsible Entity TheMHPis administered and monitored by HCD. HCD will publish program policies and procedures to govern the program and ensure compliance with the established program policies and procedures, regulatory requirements, and broader recovery goals.HCDisresponsible for overseeing the program, publishing a NOFA, and reviewingandunderwriting applicationsto develop newconstructionmultifamily projectunitsor substantially rehabilitate multifamily project units.As part of the NOFA process, HCDreviewsdeveloper experience to ensure that developers have Multifamily housingdevelopment experience. Qualified developers must have completed at least three multifamily developments, at least one of which included affordable rental units. Multifamily developmentsfunded under this CDBG-DR grant willadhere to standard requirements set by HCD to ensure compliance, as well as specific requirements set by the governing federal income limits. All requirements of the MHPwill be outlined in detail in the programpolicies and procedures. HCD will provide technical assistance to developers to ensure compliance with CDBG-DR requirements and consistency with the program policies and procedures. In addition, periodic risk-basedmonitoring of the project construction will be conducted to test compliance and ensure timely project completion. 187 HCDissolely responsible for makingawardsto successful applicants,facilitating executionof appropriate agreements including regulatory agreements to restrict MHP units within a project for a period of not less than 55 years,and compliance with all requirements of the NOFA and the MHP policies and procedures. Once HCD selectsprojects and announces awards,theformofagreement with successful applicant developers will bea Standard Agreement which will define each commit funding to the project, establish timelines and milestones, and reiteraterelevant compliance requirements.At an appropriate time specified in the Standard Agreement, a Regulatory Agreement shall be recorded infirst position above all other liens or encumbrances. role includesdetermining thecapacity and experienceofproject developers and/or construction contractors, completion of the NEPA environmental review, project oversight,and ensuringcompliance with the accessibility requirements of both the Federal Fair Housing Act and Section 504 of the Rehabilitation Act of 1973 during construction and atinitial occupancy. HCD will be responsible for monitoring developer or contractor compliance with construction advertisement and notification to minority and women-owned businesses of contacting opportunities available for the federally assistedproject. HCD will monitor labor standards compliance andSection 3 quantitative and qualitative benchmarks during construction and will ensure long-term compliance with affordability requirements and fair housing lawsthroughout the affordability period. d.Form of Assistance Selected proposals arefunded in the form of a below-market interest rate residual receipts loan to be disbursedon a reimbursement basis via a Standard Agreement between HCD and the developerto ensure that proper financial controls and safeguards are in place to protect CDBG- DR funds. Specific payment terms and conditions areoutlined in the Standard Agreementand associated loan documents.The Standard Agreement definesfinancialand property management requirements as well as remedies to correct deficient or non-compliant projects. Standard Agreements, Regulatory Agreements, and loan documentswill also contain CDBG- DRrecapture provisions for non-performance orbreach ofdeveloperresponsibility. e.MaximumAssistance The MHP per-unit maximum assistance isconsistent with HOME limits established by HUD. 66 The methodology for calculating thoselimits isfound in 83 CFR 25693with state-wide limits published annually by HCD. As a state-wide program with a varietyof housing markets and corresponding costs, HCD usesthe HOME limit as a federallyestablished industry standard and safe harbor for cost reasonableness on a per-unit basis for housing serving low-income households. Consistent with other HUD affordable housing funding sources, the HOME maximum per-unit subsidy limits ensure an appropriate level of investment in Multifamily 66 -Unit Subsidy https://www.hudexchange.info/resource/2315/home-per-unit-subsidy/. 188 projectson a per-unit basis. This policy direction encourages leveraging with HOME, Tax Credits, State MHP, and other available affordable housing resources. F IGURE 156:M ULTIFAMILY H OUSING P ROGRAM M AXIMUM P ER-U NIT S UBSIDY L IMITS (A S OF A PRIL 2022) BedroomsMaximum Subsidy 0$159,754 1$183,132 2$222,694 3$288,094 4316,236 If HUD has issued a regional per unit subsidy increase coveringthejurisdiction of a project, the alternative subsidy amount may be used, up to 240 percent of the base subsidy limit. The minimum threshold for Multifamily housingproject participation is a total project cost of $250,000 per project. Using the maximum per-unit subsidy limits, a cost allocation will be performedoneach project to ensure that CDBG-DR funds are applied to a proportionate share of total development cost. Awards ofCDBG-DR funds will not exceeddemonstrated need, 40 percent of total development cost, or the maximum subsidy as determined through cost allocation. f.Eligible Activity 42 USC 5305(a)(4) authorizesthe 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). The eligibility of housing projects is further established in the Consolidated Notice, 87 FR 6370, which requires HCD to address unmet housing recovery needs with CDBG-DR funds. New housing construction is also eligible as established in the Consolidated Notice, 87 FR 6371, paragraph B.1 of Section II. Through the FRN, 87 FR 6370, HUD adopts alternative requirements to activities eligible under HCDA Section 105(a) which allows California to carry out modified activities to comply with the requirements in the FRN to incorporate mitigation measures as a construction standard. g.National Objective In accordance with 24 CFR 570.208, all CDBG-DR funded activities must satisfy a national objective. For the Multifamily program, all projects will meet the low to moderate income housing national objective. While proposed projects may be mixed-income, CDBG-DRfunds will only be applied to the affordable units restricted foroccupancyby low-to-moderate-income households. 189 h.Incorporation of Mitigation Measures In response to the FRN, applications must describe how hazard mitigation measures willbe incorporated into the project to reduce the impacts of recurring natural disasters andthe long- term impacts of climate change.The State of California building code, which incorporates mitigation measures, is applicable to CDBG-DR projects. All residential construction projects must comply with the current published housing construction codes for the State of California. Housing construction codes for building in California follow federal and state laws, regulations, and adaptions for construction of single family and Multifamily units. Building standards are published as the California Buildings Standards Code under the California Code of Regulations, Title 24, and construction standards must meet or exceed all applicable requirements for housing or building construction. Const https://www.hcd.ca.gov/building-standards/index.shtml. Specific code compliance to achieve hazard mitigation, such as Wildland-Urban Interface (WUI Area Building Codes, are implemented where applicable according to local code and the unique needs of impacted communities. WUI area building codes are designed to mitigate the risksfrom wildfire to life and property. The standards are within a WUI area code vary according to the scope that a community is willing to adopt and enforce. WUI area codes may include the following topics: Structure density and location: number of structures allowed in areas at risk from wildfire, plus setbacks (distance between structures and distance between other features such as slopes). Building materials and construction: roof assembly and covering, eaves, vents, gutters, exterior walls, windows, non-combustible building materials, and non- combustible surface. Vegetation management: tree thinning, spacing, limbing, and trimming; removal of any vegetation removal, and brush clearance; vegetation conversion, fuel modifications, and landscaping. Emergency vehicle access: driveways, turnarounds, emergency access roads, marking of roads, and property address markers. Water supply: approved water sources and adequate watersupply. Fire protection: automatic sprinkler system, spark arresters, and propanetank storage. Applicationsmust take into account the costs and benefits of incorporating hazard mitigation measures to protect against the specific identified impacts of future extreme weather events and other natural hazards.As noted, applicants may include up 5% of their budget solely for mitigation costs. i.Eligible Projects Eligibilityofmultifamily housing project proposals will be assessed by HCD. Specific eligibility criteria include: 190 The proposed project must be located in a Most Impacted and Distressed area, DR- 4558or DR-4569. The proposed project must have a minimum of five total units. The proposed project must have a minimum of51percent of unitsmust be affordable units. Maximum Rents: HCD is proposingto establish program affordable rents at the annual highHOME rents for each applicable area. For those unitsthat are for extremely low- income households, HCD is proposing to establish program affordable rents at the CTCAC rents for 30% area median income (AMI) for each applicable area. The proposed project must meet one of the HCD project types defined in the2019 Multifamily-5). The proposed project must meet one of the following four prioritization criteria: o Projects providing housing for Extremely Low-Income (ELI) individuals or families.ELI isdefinedas income less than 30 percent ofthearea median income (AMI) or the federal poverty level, whichever is higher for the area ofthe proposed project. Approximately 1/3 of renter households impacted by the wildfires were at30% AMI orbelow. This will bethe toppriority. o Projectsproviding permanent supportive housing (PSH) units. The HCD Supportive Housing MultifamilyHousingProgram (SHMHP) defines a PSH MultifamilyHousingproject as a project with a minimum of five supportive housingunits, or a minimum of 40 percent of total units, whichever is greater, and must have associated supportive services for theintended target population living inthe restricted units, pursuant toCalifornia Health andSafety Code Section 50675.14. If proposed projects have fewer than five supportive housing units or 40 percent of total units available as supportive housing, these projects will remain higherprioritythanaprojectwithacomparablenumber ofaffordablerentunits. o Projects which are providing residential units for low-income Elderly Persons, o Projects providing 15% of residential units for people with at least one Disability 30% AMI. All sources of funding required to complete the project must be identified and secured or readily accessible. The proposed project must be cost reasonable, which is what a reasonable person would pay in the same or similar circumstances for the same or similar itemor service. Cost reasonableness may be documented by comparing costs between vendors or by comparing submitted costs to an independent cost estimate. The proposedproject must not exceed the maximumper-unit subsidy limit. The proposed project must meet the following affordable rent requirements and tenant income limits over the duration of the minimum affordability period. At a minimum, the following thresholds must be adhered to in all projects: o HCD will determine the numberof units in an approved multifamilydevelopment that will be leased to tenants with an income of up to 80 percent of the AMI based on regulatory and program requirements. o Affordable rents will be the high HOME rentspublished annually by HUD for the jurisdiction where the project is located, except that for units targeted to 191 extremely low-income households, affordable rents shall be the CTCAC rents for 30% area median income (AMI) for each applicable area. o New construction,rehabilitation,or reconstruction of rental projects shall be deed restricted by a Regulatory Agreement for aminimum affordability period of 55years. j.Affirmative Marketing and Fair Housing MHPapplications shallinclude affirmative marketing plans accordingto marketing proceduresandrequirements as requiredforallCDBGassisted housing with five or moreunits.The affirmative marketing plans shall evaluate the most recent available American Community Survey data and determine those populations who are least likely to apply for the housing opportunityand to persons with Limited English Proficiency. Affirmative marketing plans shall includespecific and meaningful targeted outreach efforts to reach those populations identified as least likely to apply for the housing opportunity. Additionally,marketingof available Multifamily units developed or otherwise made available with MHP fundsshall include outreach toindividualsand families that wereimpacted by the disasters andSection 8 Housing Choice Voucher Programtenants tothe greatest extent possible through similar affirmative marketing effortsthataim toreach fire impacted residents.Examples ofrenters impacted by the disasters includerenters that have lost rental units orhave been displaced due tothe impacts of DR-4558andDR-4569. Applications should also demonstrate that the proposed projects will affirmatively further fair housing, and are likely to lessen area racial, ethnic, and low-income concentrations, and/or promote affordable housing in low-poverty, nonminority areas in response to natural hazard related impacts. k.Eligible and Ineligible Costs HCD commits to funding activities eligible under Title I of the Housing and Community Development Act of 1974 or those activities specified by waivers in 86 FR 6364.Selected projects will be funded through completion in accordance with their financing needs. HCD, in coordination with the subgrantee, will perform a check for duplication of benefit and federal funding supplantation prior to issuing an award to ensure that duplicative assistance is not provided for Multifamily housing. DOB and supplantation checks will be maintained in the project file. Complete lists of eligible and ineligible project and subrecipient activity delivery costs will be provided in the program policies and procedures. Eligible costs include: Activity delivery costs for HCDtoadminister and monitor the MHPprogram, including allocable direct and indirect staff costs and consultant costs Architectural andengineeringdesign Permitting fees Developer fees Mobilization, site prep, and clean up Construction costs 192 Land and building acquisition costs (on a case-by-case basis) Hazard mitigation costs Ineligible costs include: Pre-application costs and application developmentcosts Advances of any type, includingconstruction Facility operating or maintenanceexpenses Offsite improvements HCDreserves the right toquestion the applicability and eligibility ofcosts on a per-application basis. HCD will also ensure that construction costs are reasonable and consistent with current market costs for the area where theMultifamilyconstruction will take place. l.Broadband Infrastructure Projectsinvolving reconstruction, or new construction of a building with more than four rental units must include installation of broadband infrastructure. More specific information for this requirement will be included in program policy and procedures. m.Mitigation set-aside for existing Multifamilyproperties Given the number of multifamily units in the MID, and the increased need for multifamily housing, HCD recognizes the importance of mitigating existing buildings to ensures residents arein fire-protected buildings. Therefore, inaddition to funding mitigation measures withinthe MHP, HCD may provide a set aside for existing multifamily properties to incorporate mitigation rehabilitation to the properties.HCD would make available mitigation funds in a NOFA for existing multifamily property owners to apply for grants for up to $50,000 to bring properties up to WUI standards. Further details including funding, eligibility requirements, and scoring criteria will be submitted in a future substantial Action Plan Amendment. n.Resilience Performance Metrics HCD will establish resilience performance metrics before carrying out MHPprogram activities. See description of resilience performance metrics under the General Requirements section, Section III. M. o.Timeline and Expenditure Projections TheMHPwill begin following HUD agreement HUD and HCD. Project awards byHCD are expectedinthefall of2023and construction will continue through the end of the grant term, or until all projects are complete and funds are expended. Individual construction timeframes will be specific to each selected application. G.Infrastructure Recovery Program The Infrastructure Program alignsinfrastructure investments with other planned federal funds in that theCDBG-DR funds will be used to fund the non-federal share match on approved FEMA Public Assistance (PA) projects. The non-federal share match on approved FEMA PA projects 193 is an eligible use ofCDBG-DR funds.HCD mayuse grant funds to satisfy the FEMA PA Prlocal match if the use otherwise meets all CDBG-DR requirements. The CDBG-DR allocation for Infrastructure Program providesthe non-federal share match on approved FEMA PA projects. HCD will coordinate with Cal OES and the local jurisdictions to ensure that the FEMAPA projects meetthefollowing FRN requirements for infrastructureprojects: 1.How mitigation measures and strategies to reduce natural hazard risks, including climate-related risks, will be integrated into rebuilding activities; 2.Theextent to which CDBG-DR funded infrastructure activities will achieve objectives outlined in regionally or locally established plans and policies that are designed to reduce future risk to the jurisdiction; 3.How thelocal jurisdiction will employ adaptableand reliable technologies to prevent prematureobsolescence for the project-related infrastructureconstruction. 1.FEMA Public Assistance Program (PA)Match HCDwill fund the local portion of the non-federal share match for FEMA Category C (roads and bridges), Category D (water control facilities), Category E (public buildings and contents), and Category F (utilities), and Category G (parks, recreational, and other activities).Utilization of CDBG-DR funds as matching funds for a FEMA PA project requires for the CDBG-DR funds to be expended on an eligible CDBG activity.Program policies and procedureswill 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. a.Allocation Amountand Allocation Methodology HCD will make funding available to impacted jurisdictions based on eligible jurisdictions having an opportunity to submit foreligiblenon-federal share match on approved FEMA PA projects throughanapplication process. Additional details will beprovided in the program policies and procedures. FEMA PA Match Program$7,639,748 b.Disaster Related Impact and Unmet Needs Applications from eligible jurisdictionsmust identify unmet need resulting from the local match requirement from the PA project resulting from the DR-4558 or DR-4569disasters. c.Delivery Responsible Entity HCD will provide technical assistance and coordinate closely with local governments during the application phase. Once proposals arereviewed, HCD will provide funds to subrecipients for the local match for their FEMA PA projects in accordance with a Standard Agreement with the local government. Monthly progress reports will be required from the subrecipient, and reimbursement will be provided to the subrecipient based on the documented completion of agreed upon project milestones.As projects are selected, HCD will continue to provide technical assistance and complete regular monitoring throughout the project lifecycle. 194 d.MaximumGrant Award The maximum assistance allowable per project is the amount necessary to meet the localmatch requirement on a project-by-project basis based on the funding cap for each county. e.Eligible Activities Infrastructure repair is an eligible activity according to HCDA Section 105(a)(2) (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 to carry outthe eligible infrastructure activity. f.National Objective In accordance with 24 CFR 570.208, all CDBG-DR funded activities must satisfy a national objective. For the infrastructure program, all projectswill meet the low-andmoderate income (LMI) or urgent need national objective. Infrastructure funding requires a case-by-case analysis of each project for meeting these requirements It is the responsibility of the local government to substantiate the national objective as part of its proposal to HCD. g.Eligible Applicants and Projects The eligible applicants for Infrastructure Recovery Program funds are municipal and county governments in the MID that received FEMA Public Assistance funds for permanent infrastructure projects (Categories C through G) related to the DR-4558 and DR-4569 disaster events. h.Evaluation and Prioritization Criteria HCD will make Infrastructure Program funding available to impacted jurisdictions in the MID based on the application process for impacted counties and municipalities to request funding for unmet non-federal share local match needs. Eligible jurisdictions may submit applications with multiple proposed projects that meet categories D and F requirements and support housing recovery. The application will require the jurisdictions to prioritize the requests in the event that not all projects are eligible or can be funded. HCD will ensure that construction costs are reasonable and consistent with market costs for the location of the FEMA PA project. HCD will require that the construction contractor implement cost control measures or verify that reimbursable costs were correctly controlled during the project. Standard Agreements with jurisdictions will include subrogation clauses in case of the event of non-compliance with the applicable requirements and regulations. Furthermore, HCD will adopt the benefit-cost analysis conducted by local jurisdictions to comply with the requirements of FEMA PA projects.The completed BCA will be required as part of the application package submitted to HCD. 195 i.Eligibleand Ineligible Costs HCD commits to funding activities eligible under Title I of the Housing and Community Development Act of 1974 or those activities specified by waiver in 83 FR 5851. CDBG-DR funds may fund the following activities: Required FEMA PA local portion of the non-federal share match funding for approved projects under the following FEMA PA permanent work categories: Category C (Road andbridges); Category D (Water controlfacilities); Category E (Public buildings andcontents); Category F (Public utilities);and Category G (Parks, recreational, and otherfacilities). Required non-federal share match for approved projects that meet the CDBG-DRrequirements, including a tie-back to the DR-4558and DR-4569 disaster events. Eligible projects will be located in the HUD MID areas as explained in Section II. C.1. In addition, HCD may fund ADCs related to the implementation of these projects. Ineligible costs include: Required FEMA PA Match funding for approved projects under Categories A (Debris Removal) and Category B (Emergency Protective Measures). FEMA HMGP projects not related to infrastructure and/or without a tieback to the 2020 disaster events. Projects not related to infrastructure, increased code compliance, or DR-4558 and DR- 4569 disaster events. j.ResiliencePerformance Metrics HCD will establish resilience performance metrics before carrying out Infrastructureprogram activities. Seedescription of resilience performance metrics under the General Requirements section, Section III. M. k.Timeline and Expenditure Projections Applications will be released in the quarter following HUD approval of this Action Plan and the Implementation and Capacity document. Technical assistance will be provided until sufficient applications are received and approved to expend the entire allocation of Infrastructure Recovery Program funds. Individual project completion timeframes will be determined on a case-by-case basis with the subrecipients, in accordance with their agreement. H.Mitigation Program The Federal Register Noticerequires that 15 percent, $30,157,000,of the total CDBG-DR unmet needs allocation,$201,046,000, isset-aside for the state to carry out mitigation activities. HCD may meet the requirements of the CDBG-DR mitigation set-aside: 196 By incorporating mitigation measures into the recovery activities included in this Action Plan and documenting how those activities and the incorporated mitigation measures will meet the definition of mitigation, or By including eligible activities that do not have a tie-back to DR-4558 or DR-4569 but still incorporate mitigation measures, meetingthemitigation definition, into the recovery activities. HCD is allocating100 percent of the mitigation set-asideprogram fundingto incorporate property hardening activities within the OORandMHP. OOR Mitigation$21,486,863 MHP Mitigation$7,162,287 Total Mitigation Set-Aside$28,649,150 Program Funding Thecriteria to meet the FRN requirements for HCD to utilize the mitigation set-aside are described in this section while allprogram and eligibility requirements forOOR and MHP Mitigation Program are explained in the respective OOR and MHP program sections above in IV.G. Housing Recovery Programs. Mitigation activities are those that increase resilience to future disasters and reduce or eliminate the long-term risk of loss of life, injury, damage to and loss of property, and suffering and hardship. Proactively addressing the impacts of climate change and natural disasters is critical to building long-term community resilience.TheMitigation set-aside enablessingle family and multifamily,providing affordable rental units, inmost impacted communitiesfor DR-4558 and DR-4569to be more resilientto future disasters. In response to FRN requirements, proposed mitigation activities utilizing the set-aside must: Identify how the proposed use meets the definition of mitigation activities: Hardening, wildfire retrofitting, of single-family and multifamilyunits to withstand future disasters meets the definition of mitigation by increasing resilience to future wildfires and reducing or eliminating the long-term risk of loss of life, injury, damage to and loss of property, and suffering and hardship, by lessening the impact of future wildfire events. In response to the FRN requirements for all construction related activities to incorporate mitigation measures, the OOR Program incorporates mitigation measures that meet the definition of mitigation, therefore satisfying the requirement to track these mitigation activities through the MIT activity type in the Disaster Recovery and Grant Reporting (DRGR) system and the eligible use of the CDBG-DR Mitigation set-aside. The mitigation measures, aligned with the scope of work for rehabilitation or reconstruction, and new construction in the case of MHP, involve initial retrofit or bringing the property up to code with Wildland Urban Interface code standards. The WUI codes identify better construction methods and materials to make buildings more ignition-resistant to wildfire. These standards are 197 based on lab-tested and verifiable performance standards that describe the type a wildfire exposure a building must be able to withstand. Address: As required by the FRN,this Action Plan includesa risk-based Mitigation Needs Assessment to inform proposedusesof the CDBG-DR mitigation set-aside.The programs proposed in this action plan as eligible for the mitigation set-aside were designed to respond directly to the current hazards,future hazards,risks, and needsdescribed in the Mitigation Needs Assessment. A review of hazards indexed by the 2018California State Hazard Mitigation Plan found that earthquakes, flood, and fire rank as the , having caused the greatest loss of lifeandpropertyand disruption to economic, social, and environmental systems. On the county level, 15 of the 21jurisdictions impacted by DR-4558and/or DR-4569ranked and three could not provide hazard ranking data. Given the catastrophic impact of the 2020 wildfire season and the series of destructive seasons and incidents preceding 2020, and projections of severe fire incidents highlightparcel-level and community-scale wildfire mitigation asa top priority. The Mitigation Needs assessment also illustrated that a combination of economic supportforhazard interventionsandmitigation-focused policyis the most effective approachto preparing communities for future threats. The OOR Mitigation Program addresses the ubiquitous fire hazard reported across impacted counties in two significant ways: On the individual property level, the programhelps homeowners mitigate risk on their parcels by covering home hardening costs for eligible owner-occupied structures On the local jurisdiction level, the programsupports community-wide hazard mitigation by funding the development of local WUI construction codes that allow counties to regulate and mitigate high-risk conditions in fire-prone areasincluding the costof WUI construction codes, for eligible structures. For single-family units that did not suffer damage during the 2020 wildfires, eligible applicants can utilize the rehabilitationDRactivity to owners of single-family unitsmeet WUI code standards to make their homes more resistant to wildfire. TheMHP Mitigation Programaddresses local fire hazards in a similar fashion: Any rehabilitation or reconstruction of properties under the MHParerequired to incorporate mitigation measures,and the program will fundan amount up to 5 percent of an award to developers to cover the cost of those mitigation measures. Current multifamily property owners will be able to apply (via separate NOFA) for up to $50,000from the set-aside for hardening multi-family units to WUI code standards. These program features speak directly to the most pressing hazard in communities impacted by DR-4558 and DR-4569by supporting the physical construction of mitigation measures,as well as codifying mitigation measures into local land use policy. 198 Ensure that proposed activities are CDBG eligible under title I of the Housing and Community Development Act, or otherwise eligible pursuant to a waiver of alternative requirement in the FRN: HCDASection 105(a)(4)authorizes the clearance, demolition, removal, reconstruction, and rehabilitation (including rehabilitation which promotes energy efficiency) of buildings and improvement (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). The eligibility of housing projects is further established in the Consolidated Notice (FRN), 87 FR 6370, which requires HCD to address unmet housing needs with CDBG-DR funds. New housing construction is also eligible as established in the FRN, 87, FR 6371, paragraph B.1 of Section II. Through the FRN, 87 FR 6370, HUD adopts alternative requirements to activities eligible under the Housing and Community Development Act (HCDA) Section 105(a) which allows California to carry out modified activities to comply with the requirements in the FRN to incorporate mitigation measures as a construction standard. 1.OOR Mitigation The OOR program is eligible to applicants awarded funds to rehabilitate or reconstruct their home that suffered damage from the DR-4558 or DR-4569 disaster events occurring in the fall of 2020. The OOR program incorporates mitigation measures into the rehabilitation or reconstruction in a manner that satisfies the use of the Mitigation set-aside. The maximum assistance available for rehabilitation or reconstruction is $500,000 per damaged structure after applying any duplication of benefits reductions. In addition, the OOR mitigation set-aside will assist in covering home hardening costs to include the cost of WUI construction codes, the set- rehabilitation or reconstruction CDBG-DR award. Additionally, the OOR Program is eligible to owner-occupied properties that did not suffer damage in the DR-4558 or DR-4569 events but are in the MID and are low to moderate income. These households can utilize the rehabilitation activity to enable the single-familyunit to meet the WUI code standards to make their homes more resistant to wildfire. OOR applicants applying for rehabilitation to bring their homes up to WUI code standards may receive up to $50,000 in grant assistance. 2.MHP Mitigation The MHP mitigation set-aside includes two types of applications, similar to OOR. MHP projects to rehabilitate or reconstruct multifamilyproperties, as well as those proposing to newly construct multifamilyhousing units are required to incorporate mitigation measures. The use of the MHP mitigation set-aside allows developers to apply for up to 5 percent of their CDBG-DR grant for mitigation measures. Engaging a second option, existing multifamilyproperty owners may apply to a separate NOFA to receive up to $50,000 in grant assistance from the MHP mitigation set-aside for hardening 199 multi-family units to the WUI code standards.Further details of this program will be forthcoming in a separate actionplan amendment. Meet a national objective of the program: In accordance with 24 CFR 570.208 and Section 104(b)(3) of the Housing and Community Development Act (HCDA), all CDBG-DRmitigation set aside funded activities must satisfy a national objective. All OOR activities will meet either the urgent need or LMI housing national objective criteria related to disaster recovery.For the multifamilyprogram, all projects will meet the low to moderate income housing national objective. V.Administration and Planning Per the Federal Register, HCD is allowed to retain up to 5 percent of the total grant allocation to support grant administration. HCD will use the five percent for state administrative costs. This allocation is for the purposes of oversight, management, and reporting. This allocation enables HCD to provide the administrative and support services for the management and citizen participation necessary to formulate, oversee, evaluate, and report on -DR program. These activities include: Ensuringcitizen participation (including outreach and publication ofpublic notices). Preparation ofthe required CDBG-DRquarterlyreports. Preparation of Action Plan Amendments. Maintenance ofthe CDBG-DRwebsite. Monitoring ofthe expenditures for CDBG-DRprograms. Monitoring ofsubrecipients andcontractors. Coordination with HUD, FEMA, and other Federaldepartments. Certification and maintenance ofthe necessary records thatdemonstrate that Federal requirements for environmental review, fair housing, relocation, labor standards, equal opportunity, and citizen participation aremet. Coordination and administrativesupport to local governments and tribal entity for access and coordination to comprehensive disaster recovery resources. Furthermore, Administration funds may be used to cover eligible costs associated with the administration of particular program activities. A.Application Status HCD is responsible for the implementation of the CDBG-DRprograms and projects, including the means of communicating with program applicants. HCD is proposing todirectlyimplement an Owner-Occupied Rehabilitation and Reconstruction Program that will provide assistance to eligible applicants. Oversight of the application process will be managed by HCD and its contractors. For applicant communication in that program, HCD and its contractors commit to sharing timely and accurate information throughout the lifecycle of the program. HCD will procure a program implementation contractor that will be responsible for providing necessary information to each applicant and support the applicant through the lifecycle of the program. 200 HCD will include standard communication requirements in the solicitation for program implementation services. To ensure effective communication, HCD or its procured contractor will host and maintain a website with a web-based portal at www.ReCoverCa.orgfor applicants to access their application status at any time in the process. Additionally, HCD will gather information from each applicant during the intake process that will be used for communication purposes. These communication methods include: Mailings to the damaged and current mailing addresses; Emails to primary and secondary email addresses; and Phone calls to primary and secondary phone numbers. information updated. This system will also keep applicants apprised of key changes to their application status. Additionally, HCD utilizes the disaster recovery page on its website to share overall grant updates, publication of action plan amendment, and critical grant communication. HCD will provide hyperlinks to www.ReCoverCA.org, which will be specific to the Owner-Occupied Rehabilitation and Reconstruction Program, so that potential applicants can learn more about these programs.The HCD website, as well as www.ReCoverCa.org, will include a link to submit contact information so that potential applicants can receive more information about programs for which they may qualify. Once an applicant submits an application to a program, the file is assigned to a case manager. responsible for managing communications with the applicant during the lifecycle of the program. An applicant can communicate with the case manager via email, phone or through the web- based applicant portal to request an application status update. Notwithstanding the ability to communicate directly with a case manager, the web-based applicant portal will provide real-time updates on application status. The web-based applicant portal will be designed with Personally Identifiable Information (PII) requirements in mind to keep applicant information secure. Applicants with Limited English Proficiency (LEP) who require translation or interpretation (LAP). Furthermore, HCD provides status updates and program materials in a format that is in accordancewith the Americans with Disabilities Act (ADA). For the Multifamily andInfrastructure Recovery Programs, HCD will provide awards to subrecipients for them to directly manage and operate project funding. HCD will require commitments from its subrecipientsunder the Resilience Planning and Public Services programs to maintain regular applicant communication (where applicable) and to share timely and accurate information throughout the lifecycle of the program. HCD will include standard communication requirements in the notices of funding availability and within the Standard administration, Grants Network, also has built in messaging and communication functions that HCD and subrecipients can use to track applicant status and information. 201 B.Program Budget This grant has been allocated as shown in the table below. In determining the allocation across programs and unmet needs, no less than 70 percent of the funding,$161,842,100,will serve LMI household and individuals, and overall 100percent will be directed to the Most Impacted and Distressed(MID)areas. The program allocations to housing and infrastructure are designed to alleviate needs in the MIDareas and address the unmet need for many LMI households. F IGURE 157:2020CDBG-DRA CTION P LAN B UDGET BY T OTAL AND P ROGRAMS Program 2020 CDBG-DR Action Plan Total Budget$231,203,000 Percentage Administration$11,560,1505% 2020 Total Funding CDBG-DR (with administration)$201,046,00087% 2020 Total Funding Mitigation Set-Aside (with administration) $30,157,00013% CDBG-DR Program Funding$190,993,700 Housing Programs$183,353,95296% Multifamily Housing Program$128,347,76670% Owner Occupied Housing Program$45,838,48825% Homebuyer Assistance Program$9,167,6985% Infrastructure Programs$7,639,7484% FEMA PA Match$7,639,748100% Mitigation Set-Aside Program Funding$28,649,15015% OwnerOccupied Housing Mitigation Program$21,486,86375% Multifamily Housing Mitigation$7,162,28725% C.Program Income HCD managesprogram income through the provisions in the Standard Agreement, which all subrecipients must sign to receive funding from HCD. Subrecipients report program income to HCD through a request for payment and must be expended by the subrecipient prior to additional grant funds being drawn. Program income may only be used for eligible project or administration costs related to the awarded project before additional grant dollars are expended. Subrecipients provide monthly reports to HCD on program income generated and retained. Program income remaining at the endof each quarter is remitted to the state. HCD reports, quarterly,all program income to HUD throughthe HUD Disaster Recovery Grant Reporting system (DRGR). If at the end of a Standard Agreement there is remaining program income, it is 202 returned to HCD during closeout where the Division of Administration and Management Accounting office tracks the program income until it is obligated in a new Standard Agreement and track through the Standard Agreement system of record. D.Projection of Expenditures and Outcomes Tables presenting quarterly expenditure projections for the uses of the grant proposed in the Action Plan will accompany the Action Plan submission to HUD. These tables are available to the public and are posted separately from the Action Plan on the HCDwebsite. HCD submits the quarterly expenditure projections to HUD through the HUD DRGR system. The projected expenditures were determined based on anticipated staffing needs, project or program scale, project complexity, presumed level of effort, and the methods of delivery outlined in this Action Plan. E.Certificationand Risk Analysis All CDBG-DR grantees must complete the Financial Management and Grant Compliance requirements for proficient financial controls and procurement processes, and adequate procedures for proper grant management. The Department of Housing and Community Development submitted the Certification Checklist to HUD on April 6, 2022. Each grantee receiving a direct allocation under Public Law 117-43 must submit an Implementation Plan that demonstrates that it has sufficient capacity to manage the CDBG-DR tocarry out the recovery and how it will address any capacity gaps. The Department submitted the Implementation Plan for the 2020 CDBG-DR Action Plan to HUD on June 8, 2022. 203 VI.Appendices A.CDBG-DR Certifications Each grantee receiving an allocation under this Federal Register notice (87 FR 6364) must make the following certifications and submit those certifications with the Action Plan: The grantee certifies that it has in effect and is following a residential anti-displacement and relocation assistance plan (RARAP) in connection with any activity assisted with CDBG-DR grant funds that fulfills the requirements of Section 104(d), 24 CFR part 42, and 24 CFR part 570, as amended by waivers and alternative requirements. The grantee certifies its compliance with restrictions on lobbying required by 24 CFR part 87, together with disclosure forms, if required by part 87. The grantee certifies that the action plan for disaster recovery is authorized under state and local law (as applicable) and that the grantee, and any entity or entities designated by the grantee, and anycontractor, subrecipient, or designated public agency carrying out an activity with CDBG-DR funds, possess(es) the legal authority to carry out the program for which it is seeking funding, in accordancewith applicable HUD regulations as modified by waivers and alternative requirements. The grantee certifies that activities to be undertaken with CDBG-DR funds are consistent with its action plan. The grantee certifies that it will comply with the acquisition and relocation requirements of the URA,as amended, and implementing regulations at 49 CFR part 24, as such requirements may be modified by waivers or alternative requirements. The grantee certifies that it will comply with section 3 of the Housing and Urban Development Act of 1968 (12 U.S.C. 1701u) and implementing regulations at 24 CFR part 75. The grantee certifies that it is following a detailed citizen participation plan that satisfies the requirements of 24 CFR 91.115 or 91.105 (except as provided for in waivers and alternative requirements). Also, each local government receiving assistance from a state grantee must follow a detailed citizen participation plan that satisfies the requirements of 24 CFR 570.486 (except as provided for in waivers and alternative requirements). State grantee certifies that it has consulted with all disaster-affected local governments (including any CDBG-entitlement grantees), Indian tribes, and any local public housing authorities in determining the use of funds, including the method of distribution of funding, or activities carried out directly by the state. The grantee certifies that it is complying with each of the following criteria: (1) Funds will be used solely for necessary expenses related to disaster relief, long-term recovery, restoration of infrastructure and housing, economic revitalization, and mitigation in the most impacted and distressed areas for which the President declared a major disaster pursuant to the Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1974 (42 U.S.C. 5121 et seq.). 204 (2) With respect to activities expected to be assisted with CDBG-DR funds, the action plan has been developed so as to give the maximum feasible priority to activities that will benefit low-and moderate-income families. (3) The aggregate use of CDBG-DR funds shall principally benefit low-and moderate-income families in a manner that ensures that at least 70 percent (or another percentagepermitted by HUD in a waiver) of the grant amount is expended for activities that benefit such persons. (4) The grantee will not attempt to recover any capital costs of public improvements assisted with CDBG-DR grant funds, by assessing any amount against properties owned and occupied by persons of low-and moderate-income, including any fee charged or assessment made as a condition of obtaining access to such public improvements, unless: (a) disaster recovery grant funds are used to pay the proportion of such fee or assessment that relates to the capital costs ofsuch public improvements that are financed from revenue sources other than under this title; or (b) for purposes of assessing any amount against properties owned and occupied by persons of moderate income, the grantee certifies to the Secretary that it lacks sufficient CDBG funds (in any form) to comply with the requirements of clause (a). State and local government grantees certify that the grant will be conducted andadministered in conformity with title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d), the Fair Housing Act (42 U.S.C. 3601-3619), and implementing regulations, and that it will affirmatively further fair housing. An Indian tribe grantee certifies that the grant will be conducted and administered in conformity with the Indian Civil Rights Act. The grantee certifies that it has adopted and is enforcing the following policies, and, in addition, state grantees must certify that they will require local governments that receive their grant funds to certify that they have adopted and are enforcing: (1) A policy prohibiting the use of excessive force by law enforcement agencies within its jurisdiction against any individuals engaged in nonviolent civil rights demonstrations; and (2) A policy of enforcing applicable state and local laws against physically barring entrance to or exit from a facility or location that is the subject of such nonviolent civil rights demonstrations within its jurisdiction. The grantee certifies that it (and any subrecipient or administering entity) currently has or will develop and maintain the capacity to carry out disaster recovery activities ina timely manner and that the grantee has reviewed the requirements applicable tothe use of grant funds. The grantee certifies to the accuracy of its Financial Management and Grant Compliance Certification Requirements, or other recent certification submission, if approved by HUD, and related supporting documentation as provided in section III.A.1. of the Consolidated Notice and III.A.2. of the Consolidated Notice. The grantee certifies that it will not use CDBG-DR funds for any activity in an area identified as flood prone for land use or hazard mitigation planning purposes by the state, local, or tribal government or delineated as a Special Flood Hazard Area (or 100- most current flood advisory maps, unless it also ensures that the action is designed or modified to minimize harm to or within the floodplain, in accordance with Executive Order 11988 and 24 CFR part 55. The relevant data source for this provision is the state, local, and tribal government land use regulationsand hazard mitigation plans and the latest-issued FEMA data 205 or guidance, which includes advisory data (such as Advisory Base Flood Elevations) or preliminary and final Flood Insurance Rate Maps. The grantee certifies that its activities concerning lead-based paint will comply with the requirements of 24 CFR part 35, subparts A, B, J, K, and R. The grantee certifies that it will comply with environmental requirements at 24 CFR part 58. The grantee certifies that it will comply with the provisions of title Iof the HCDA and with other applicable laws. The State of California Department of Housing and Community Development herby certifies the above, as authorized by the Executive Director. Signed version submitted to HUD. B.Summary and Response of Public Comments After the public comment period ends, the state will prepare responses to the comments. A summary of the comments and responses will be added to the Action Plan for submittal to HUD. C.Common Acronyms AMI: Area Median Income CDBG-DR: Community Development Block Grant Disaster Recovery CFR: Code of Federal Regulations DOB: Duplication of Benefits DRGR: Disaster Recovery and Grant Reporting System FEMA: Federal Emergency Management Agency HCD Act: Housing and Community Development Act of 1974 HMGP: Hazard Mitigation Grant Program IA: (FEMA) Individual Assistance LIHTC: Low-Income Housing Tax Credit LMI: Low and moderate-income PA: (FEMA) Public Assistance RE: Responsible Entity RFP: Request for Proposals SBA: U.S. Small Business Administration UGLG: Unit of general local government URA: Uniform Relocation Assistance and Real Property Acquisition Act of 1970, as amended USACE: U.S. Army Corps of Engineers D.Standard Form 424 This is a standard form required for use as a cover sheet for submission of grantapplicationsfor federal assistance that provides required information about the applicant organization. The State of California Department of Housing and Community Development submitsthis form to HUD at the time of Action Plan submission through the HUD DRGR system. 206 The State also submitsStandard Form 424-D, which provides assurances for construction programs. 207