INTENT TO REQUEST RELEASE OF FUNDS (NOI/RROF)
January 24, 2025
Portland Housing Bureau
1900 SW 4th Avenue, Suite 7007
Portland, OR 97201
(503) 823-2802
REQUEST FOR RELEASE OF FUNDS
On or about February 4, 2025, the Portland Housing Bureau will submit a request to the U.S. Department of Housing and Urban Development (HUD) for the release of Community Development Block Grant (CDBG) funds under Title I of the Housing and Community Development Act of 1974 as amended, Public Law 93-383, as amended; to undertake the following multi-year program/project:
TIER 1 BROAD REVIEW PROJECT: SAFETY AND SECURITY GRANT PROGRAM
In Fiscal Year 2024-25 the Housing Bureau set aside funds to assist Affordable Housing Agencies on emergency needs for safety and security, including measures necessary to address crime and drug-related activity. Affordable Housing Agencies may submit separate applications for funding to address crime and drug-related activity.
Safety and security grant funding will be limited to an overall total of 150,000 dollars per Affordable Housing Agency within the City's fiscal year. An Affordable Housing Agency's funding award will be based on several factors including the proposal's cost estimate, the number of deeply affordable units identified within the application, as well as the description of the identified emergency safety and security need. An agency may apply for funding for one or more of its projects as long as its request does not exceed an overall total of 150,000 in the fiscal year.
The intent of these grants is to provide one-time project-specific assistance for emergency safety and security items that could not be absorbed within the Affordable Housing Agency's Capital Fund budget. Emergency Safety and Security eligible items must meet Uniform Physical Condition Standards (UPCS) and local code requirements. Any physical modifications must comply with all applicable accessibility requirements, including under Section 504 of the Rehabilitation Act, Title II of the Americans with Disabilities Act, the Architectural Barriers Act (ABA) of 1968, the Fair Housing Act, and ORS 695A. Emergency Safety and Security grant funds may be used to purchase, install, repair, or replace capital needs items including, but not limited to items that address the threat to safety posed by crime and drug-related activity, such as:
- Security systems/cameras including digital video recorders, license plate readers, and secure Wi-Fi transmission of video signal.
- Fencing;
- Lighting systems;
- Emergency alarm systems;
- Window bars;
- Deadbolt locks;
- Doors;
- Training: trauma-informed, de-escalation training for property management staff, front desk staff, security personnel
- Salaries for maintenance staff that is being utilized for Safety and Security grant eligible activities, e.g., to install, replace or repair security camera systems, fencing, lighting systems, emergency alarm systems, doors, locks, window bars.
TIERED REVIEW
The proposed Safety and Security CDBG Grant Program to be funded is categorically excluded from the National Environmental Policy Act requirements, but subject to compliance with some of the environmental laws and authorities listed at § 58.5 of 24 CFR Part 58. In accordance with §58.15, a tiered review process has been structured, whereby some environmental laws and authorities have been reviewed and studied for the intended target area listed above. Other applicable environmental laws and authorities will be complied with, when individual projects are ripe for review. Specifically, the target area has been studied and compliance with the following laws and authorities has been established in this first tier:
- Airport Hazards
- Coastal Barrier Resource Act
- Air Quality / Clean Air Act
- Coastal Zone Management Act
- Endangered Species Act
- Explosives and Flammable Hazards
- Farmland Protection
- Noise Abatement and Control
- Sole Source Aquifers
- Wetlands Protection
- Wild and Scenic Rivers Act
Tier 2 Site Specific Review: The site-specific reviews will cover the following laws and authorities not addressed in the Tier 1 broad review:
- Historic Preservation Act
- National Flood Insurance Program
- Contamination and Toxic Substances
- Floodplain Management
Mitigation Measures: For the Tier 2 site-specific laws and authorities, mitigation will be implemented as required.
Should individual aggregate projects exceed the threshold for categorical exclusion detailed at §58.35(a), an Environmental Assessment will be completed and a separate Finding of No Significant Impact and Request for Release of Funds published. Copies of the compliance documentation worksheets are available at the address below.
An Environmental Review Record (ERR) that documents the environmental determinations for this project, and more fully describes the tiered review process cited above, is on file at the City of Portland Housing Bureau, 1900 SW 4th Avenue, Suite 7007, Portland, OR 97201 and may be examined or copied Tuesdays through Thursdays, 9:00 a.m. to 4:00 p.m. by sending a request to anna.shook@portlandoregon.gov.
During the comment period, this review is also available on HUD's Environmental Review Records page.
PUBLIC COMMENTS
Any individual, group, or agency may submit written comments on the ERR to the Portland Housing Bureau. All comments received by 4:00 pm on February 3, 2025 will be considered by the Portland Housing Bureau prior to authorizing submission of a Request for Release of Funds and Environmental Certification to HUD.
Please send written comments or email comments to anna.shook@portlandoregon.gov.
ENVIRONMENTAL CERTIFICATION
The City of Portland certifies to HUD that Anna Shook in her official capacity as the Certifying Officer for the City of Portland consents to accept the jurisdiction of the Federal Courts if an action is brought to enforce responsibilities in relation to the environmental review process and that these responsibilities have been satisfied. HUD/Portland’s approval of the certification satisfies its responsibilities under NEPA and related laws and authorities and allows the City of Portland to utilize HUD program funds.
OBJECTIONS TO RELEASE OF FUNDS
HUD will consider objections to its release of funds and the City of Portland’s certification for a period of fifteen days following either the anticipated submission date (cited above) or HUD’s actual receipt of the request (whichever is later) only if the objections are on one of the following bases:
(a) that the Certification was not executed by the Certifying Officer of the City of Portland;
(b) the City of Portland has omitted a step or failed to make a decision or finding required by HUD regulations at 24 CFR Part 58;
(c) the City of Portland has committed funds or incurred costs not authorized by 24 CFR Part 58 before approval of a release of funds by HUD;
(d) another Federal agency acting pursuant to 40 CFR Part 1504 has submitted a written finding that the project is unsatisfactory from the standpoint of environmental quality. Objections must be prepared and submitted in accordance with the required procedures (24 CFR Part 58), and may be addressed to HUD and sent to the email address as follows: Portland_RROF@hud.gov
Potential objectors may contact HUD directly to verify the actual last day of the objection/comment period.
Anna Shook, Analyst II
Certifying Officer Designee