STRATEGIC PRIORITY: Fiscally Sound
AGENDA DATE: August 27, 2025
COUNCIL DISTRICT(S): N/A
DEPARTMENT: Budget and Management Services
EXECUTIVE: Jack Ireland
______________________________________________________________________
SUBJECT
Title
Authorize (1) to initiate consideration of Substantial Amendment No. 1 to the FY 2025-26 Action Plan, including amendments to the Five-Year Consolidated Plan; amendments to the FY 2025-26 Action Plan; and amendments to the Community Development Block Grant CARES Act Program Grant, HOME Investment Partnerships American Rescue Plan Program Grant, and Community Development Block Grant Disaster Recovery Program Grant, to: (a) incorporate adjustments to City of Dallas plans, policies, and programs, implemented by the City Manager pursuant to City Council authorization, to ensure compliance with Federal Executive Orders and other directives; (b) reflect departmental and operational efficiencies set forth in the City Manager’s Recommended FY 2025-26 Operating and Capital Budget, with realignment of funding in open HUD grant budgets; and (c) reprogram unspent CDBG Entitlement Funds in the amount of $2,000,000 for use on public improvement projects as FY 2025-26 Reprogramming Budget No. 1; and (2) a public hearing to be held on October 8, 2025, to accept comments on the proposed changes - Financing: No cost consideration to the City
Body
BACKGROUND
The City of Dallas receives four formula entitlement grants each year from the U.S. Department of Housing and Urban Development (HUD). These four grants make up the Five-Year Consolidated Plan and consist of the CDBG, HOME Investment Partnerships Program (HOME), Emergency Solutions Grant (ESG), and Housing Opportunities for Persons with AIDS (HOPWA).
The City’s Five-Year Consolidated Plan is a comprehensive analysis and strategic plan that identifies community needs, prioritizes those needs, and details how they will be addressed over the five-year planning period. The Five-Year Consolidated Plan is then supported by the Annual Action Plan for each of the five years.
On June 12, 2024, the City Council authorized final adoption of the City’s latest Five-Year Consolidated Plan for FY 2024-25 through FY 2028-29 and the first FY 2024-25 Action Plan, with the FY 2024-25 HUD Consolidated Plan Budget in the amount of $30,949,109, starting October 1, 2024. On August 6, 2025, the City Council authorized final adoption of the second FY 2025-26 Action Plan, with the FY 2025-26 HUD Consolidated Plan Budget in the amount of $29,886,873, starting October 1, 2025.
In addition to the four-formula entitlement grants above, the City of Dallas has received additional one-time HUD grant awards, which are part of the Consolidated Plan and are subject to the City’s Citizen Participation Plan for HUD Grant Funds. These include:
• Community Development Block Grant CARES Act Program (CDBG-CV) Grant ($20,678,587, consisting of $8,899,802 approved on April 22, 2020, with additional funds of $11,778,785 approved on November 11, 2020)
• HOME Investment Partnerships American Rescue Plan Program (HOME-ARP) Grant ($21,408,139, consisting of $21,376,123 approved on January 12, 2022, with additional funds of $32,016 approved on June 11, 2025)
• Community Development Block Grant Disaster Recovery Program (CDBG-DR) Grant ($40,400,000, consisting of $24,433,000 approved on December 14, 2022, with additional funds of $15,967,000 approved on April 12, 2023)
Updates Needed to Five-Year Consolidated Plan and Annual Action Plans
Based on recent developments, it is necessary to make certain changes to the City’s Consolidated Plan and Annual Action Plans for:
• Adjustments to City of Dallas plans, policies, and programs to ensure compliance with new Federal Executive Orders and other Federal directives.
• Departmental and operational efficiencies set forth in the City Manager’s Recommended FY 2025-26 Operating and Capital Budget, with realignment of funding in open HUD grant budgets.
• Reprogramming of unspent CDBG Entitlement Funds for use on public improvement projects.
The City of Dallas Citizen Participation Plan requires that a substantial change to the purpose, location, scope, or beneficiaries of an activity in the Five-Year Consolidated Plan and Annual Action Plan be reviewed and approved through a citizen participation process (including public notice, public hearing, and a 30-day comment period). While some of the changes included here, on their own, would not constitute a substantial change, staff recommend that all of the necessary changes, taken together, be included in one substantial amendment to go through the citizen participation process.
Over the last several months, Federal partners have issued a number of Executive Orders and other directives, requiring review of City plans, programs or policies, and existing systems. Primary among those directives relating to Federal grant requirements are:
• Executive Order 14173 - Ending Illegal Discrimination and Restoring Merit-Based Opportunities; Federal Grant Requirements (Diversity, Equity, and Inclusion) (DEI)
• Executive Order 14218 - Taxpayer Subsidization of Open Borders; Federal Grant Requirements (Immigration Compliance)
• Executive Order 14173 - Guidance and Federal Grant Requirements (Minority & Women Business Enterprises) (MWBE)
• Executive Order 14321 - Ending Crime and Disorder in America’s Streets
On June 25, 2025, the City Council directed the City Manager to review and evaluate city programs and policies for compliance with federal directives, temporarily pause for operational purposes a city program or policy to ensure compliance with federal directives, and timely brief City Council on all temporarily paused city programs or policies and present recommendations for any proposed City Council final action. On August 6, 2025, the City Manager briefed the City Council, and received directions and authorization to make necessary changes to ensure compliance with Federal Executive Orders and other directives.
In the development of the new Five-Year Consolidated Plan, the City recognized the need for the goals and strategies in the new plan and subsequent Annual Action Plans to align with existing systems, strategies and policies to ensure consistency among them and a baseline for a strategic approach for implementation to address identified needs. Existing systems include the Continuum of Care and the Ryan White Planning Council of the Dallas Area. Existing strategies and policies include the Dallas Housing Policy 2033, Poverty Study, Broadband & Digital Equity Plan, Comprehensive Environmental and Climate Action Plan (CECAP), Public Infrastructure Needs Inventory, Homeless Solutions Strategy, assessment of fair housing study, among others. Incorporation of these existing systems, strategies and policies was intended to tell one comprehensive story of the City’s needs and plans to address those needs to further the goals and requirements of the Consolidated Plan.
Because the City’s Five-Year Consolidated Plan and Annual Action Plans are informed by these City plans, policies, and programs, as well as existing systems, changes made to those documents and systems to ensure compliance with Federal Executive Orders and other directives will also be incorporated into the City’s Consolidated Plan and Annual Action Plans. Upon final approval, this item will authorize the City Manager to make necessary changes to the Five-Year Consolidated Plan and Annual Action Plans, to ensure compliance with Federal directives.
Departmental and Operational Efficiencies
In the City Manager’s Recommended FY 2025-26 Operating and Capital Budget, some departmental and operational efficiencies (e.g., department consolidations) have been proposed that will require changes to the City’s Five-Year Consolidated Plan and Annual Action Plans, including realignment of funding in open HUD grant budgets. These changes would be necessary to enable the City to better account for and report the use of HUD grant funds, and may entail creating additional funds/units, and transferring appropriations, expenses and/or cash between funds/units, projects, and individual object codes and/or categories in accordance with HUD regulations and the City's Citizen Participation Plan. Upon final approval, this item will authorize the City Manager to make necessary changes to the Five-Year Consolidated Plan and Annual Action Plans, to reflect these departmental and operational efficiencies, including realignment of funding in open HUD grant budgets.
Reprogramming of CDBG Entitlement Funds
Staff have identified urgent needs for additional funding for public improvement projects. Upon review of funding, unspent Community Development Block Grant (CDBG) Entitlement Funds in the amount of $2,000,000 are available to meet those needs. Staff recommends reprogramming unspent CDBG Entitlement Funds for public improvement projects, as follows.
CDBG - Source of Funds:
FY2025-26 Reprogramming Budget No. 1
• One Time Revenue (Program Income) - $2,000,000
CDBG - Use of Funds:
• Public facilities repair and and/or renovations - $2,000,000
Upon final approval, this item will authorize the City Manager to reprogram unspent CDBG Entitlement Funds for one-time public improvement projects.
Federal regulations require that a public hearing be held on the Substantial Amendment No. 1 to the FY 2025 26 Action Plan. Federal regulations and the City’s Citizen Participation Plan also require a public comment period of not less than 30 days and a public hearing to receive comments.
A summary of this Substantial Amendment No. 1 to the FY 2025 26 Action Plan will be published in the Dallas Morning News on or about September 14, 2025, to provide an opportunity to submit written comments through October 7, 2025.
PRIOR ACTION/REVIEW (COUNCIL, BOARDS, COMMISSIONS)
On April 22, 2020, the City Council held a public hearing and approved final adoption of the Proposed FY 2020-21 HUD Consolidated Plan Budget; the Proposed CARES Act Relief Funds Budget, No. 1 from HUD; the Proposed FY 2019-20 Reprogramming Budget by Resolution No. 20-0655.
On November 11, 2020, the City Council authorized final adoption of Substantial Amendment No. 1 to the FY 2020-21 Action Plan to accept Coronavirus Aid, Relief, and Economic Security (CARES) Act Community Development Block Grant (CDBG) Funds No. 3 from HUD by Resolution No. 20-1845.
On January 12, 2022, the City Council authorized final adoption of Substantial Amendment No. 2 to the FY 2021-22 Action Plan to accept HOME investment Partnerships Program American Rescue Plan Act (HOME-ARP) Grant Funds from HUD by Resolution No. 22-0200.
On December 14, 2022, the City Council authorized final adoption of the 2022 Community Development Block Grant Disaster Recovery (CDBG-DR) Budget and Action Plan to accept CDBG-DR funds from HUD by Resolution No. 22-1836.
On April 12, 2023, the City Council authorized final adoption 2022 Amended CDBG-DR Budget and Action Plan to accept additional CDBG-DR Funds from HUD by Resolution No. 23-0521.
On June 12, 2024, the City Council authorized final adoption of the FY 2024-25 HUD Consolidated Plan Budget, including FY 2023-24 CDBG Reprogramming Funds, and the new Five-Year Consolidated Plan by Resolution No. 24-0873.
On June 11, 2025, the City Council authorized Ordinance No. 33127 to amend the FY 2024-25 Operating and Capital Budget Appropriations Ordinance to authorize additional appropriations for HOME-ARP Grant Funds by Resolution No. 25-0904.
On June 25, 2025, the City Council directed the City Manager to review and evaluate city programs and policies for compliance with federal directives; to temporarily pause for operational purposes a city program or policy to ensure compliance with federal directives; and to timely brief City Council on all temporarily paused city programs or policies and present recommendations for any proposed City Council final action by Resolution No. 25-1081.
The City Council was briefed on “Grant Task Force Update, Recommendations, and Next Steps” on August 6, 2025.
On August 6, 2025, the City Council authorized closing the public hearing and final adoption of the FY 2025-26 HUD Consolidated Plan Budget by Resolution No. 25-1185.
The City Council was briefed by memorandum regarding this matter on August 22, 2025. <https://dallascityhall.com/government/citymanager/Documents/FY24-25%20Memos/Upcoming%20Agenda%20Item%20%2325-2514A.pdf>
FISCAL INFORMATION
No cost consideration to the City.