HomeMy WebLinkAboutItem 5.7 Three-Year Cooperative Agreement with Alameda County for Participation in the Urban County Program for Community Development Block Grant and HOME Investment Partnership Funds Agenda Item 5.7
STAFF REPORT
CITY COUNCIL
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DATE: June 16, 2026
TO: Honorable Mayor and City Councilmembers
FROM: Colleen Tribby, City Manager
SUBJECT:
Three-Year Cooperative Agreement with Alameda County for Participation
in the Urban County Program for Community Development Block Grant
and HOME Investment Partnership Funds
Prepared by: Jason Earl, Senior Management Analyst
EXECUTIVE SUMMARY:
The City Council will consider a three-year cooperative agreement with Alameda County for
participation in the Alameda County Urban County program for Community Development Block
Grant and HOME Investment Partnership funds. This agreement will allow the City's continued
participation in the Urban County program beginning July 1, 2027, for federal fiscal years
2027-2029. The City must notify HUD and the County of its decision by June 23, 2026.
STAFF RECOMMENDATION:
Adopt the Resolution Authorizing the Continued Participation of the City of Dublin in the
Alameda County Urban County for Community Development Block Grant Funds and
Authorizing Execution of the Cooperation Agreement Between the City and County of Alameda
Regarding Participation in the Alameda County Urban County for Community Development
Block Grant Funds.
FINANCIAL IMPACT:
The agreement would allow the City to continue receiving CDBG and/or HOME funds during
the upcoming three-year cycle. Dublin has used CDBG and/or HOME funds to directly support
City programs as well as programs that serve Dublin residents through Tri-Valley
organizations. Historically, Dublin has exceeded its proportional share of allocated funds by
accessing unused public service and capital funds from other Urban County jurisdictions.
Although the agreement would not directly change the City’s financial obligations, fewer funds
may be available in the future because of increased use by other Urban County jurisdictions.
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DESCRIPTION:
Background
The Community Development Block Grant (CDBG) program is a federally authorized program,
administered by the U.S. Department of Housing and Urban Development (HUD), that
provides annual funding to state and local jurisdictions to support community development
activities benefiting low- and moderate-income residents. Funding allocations are determined
by HUD using a formula that considers factors such as population, poverty, housing age,
overcrowding, and regional growth trends.
The City currently receives CDBG funds through the Urban County program administered by
the Alameda County Department of Housing and Community Development (HCD). The Urban
County program provides an opportunity for cities with a population of less than 50,000 to
receive CDBG funds (cities over 50,000 may also choose to receive their CDBG allocation
through the Urban County program). As a city with a population over 50,000, Dublin could
choose to become an Entitlement City and administer the CDBG funds directly by HUD.
Historically Dublin has participated in the Urban County program as the administration
requirements of an Entitlement City are significant and the funding allocation would be similar
or less. As a result, Dublin participates in the Urban County program through a Cooperative
Agreement with Alameda County for the unincorporated portions of the County and the cities
of Albany, Emeryville, Newark, and Piedmont.
Alameda County administers the CDBG program on behalf of participating jurisdictions,
including preparation of the required Consolidated Plan, Annual Action Plan, and Citizen
Participation Plan. The Consolidated Plan is updated every five years. The current Plan is for
years 2025 - 2030 and outlines community needs, priorities, goals, and projections, while the
Annual Action Plan is completed annually to identify program goals, activities, and budget
allocations. The County is also responsible for HUD-required compliance activities, including
financial administration, reporting, and ongoing monitoring of subrecipients.
Alameda County HCD administers certain CDBG-funded programs that serve all Urban County
jurisdictions. These include fair housing and landlord-tenant services provided through a
County contract with ECHO Housing. The County also administers program activities such as
the Minor Home Repair Program, which is administered by Healthy Homes. The City of Dublin
receives approximately $19,000 annually for the Minor Home Repair Program.
Dublin’s allocation of Public Service Grants, which are discretionary CDBG funds, are currently
allocated through the City’s Human Services Grants Program and provide financial support to
local non-profits. These discretionary funds are subject to the federal cap limiting public service
expenditures to 15 percent of the City’s total non-capital CDBG allocation. Historically, Dublin
has exceeded its proportional share of the cap by accessing unused public service funds from
other Urban County jurisdictions. For example, in Fiscal Year 2025-26 Dublin received $55,500
in Public Service Grant funding which is nearly triple its federal cap amount of approximately
$18,000. Future allocations will depend on the extent to which other participating jurisdictions
utilize their public service funds, which may reduce the availability of excess funds. In recent
discussions, Alameda County has indicated that the urban county jurisdictions currently
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anticipate using their public service fund allocations going forward, thus reducing future excess
allocations available to Dublin. Over the past six years, the City of Dublin has secured
$419,908 in public service funding for local service organizations, which is more than $314,000
above the amount the City would have received under the federal limitation of 15 percent on
non-capital CDBG funding for service grants, as shown in Table 1.
Table 1. Public Service CDBG Funding FY 2020/21 through FY 2025/26
Fiscal Years
Non Capital CDBG
Funding
Public Service
Funds
Dublin Received
Public Service Funds
capped at 15% Difference
FY 2020/21 $125,821 $85,984 $18,873 $67,111
FY 2021/22 $125,357 $83,608 $18,804 $64,804
FY 2022/23 $126,639 $84,954 $18,996 $65,958
FY 2023/24 $129,099 $54,862 $19,365 $35,497
FY 2024/25* $104,889 $55,000 $11,490 $43,510
FY 2025/26 $122,039 $55,500 $18,306 $37,194
Total $733,844 $419,908 $105,834 $314,074
* The County reduced our non-capital funding because they directly funded $19,397 for Dublin’s Minor Home
Repair program
The Capital Grant Program is administered by Alameda County and provides CDBG funding
for capital improvement projects. Funding applications are submitted to the County.
Approximately $350,000 is available annually for allocation among Urban County jurisdictions.
Capital Pool funds are shared among Urban County jurisdictions and awarded on a
competitive basis; Therefore, the amount available to the City of Dublin varies annually. Over
the past 6 years the City has secured $1,858,335 in capital funding for local service
organizations, as shown in Table 2.
In the current fiscal year, the City of Dublin secured $319,000 in Capital Grant funding through
the Urban County Program. This funding includes $269,000 for Tri-Valley Haven to rebuild and
expand its domestic violence shelter and $50,000 for the School of Imagination to construct a
new classroom serving additional students in Dublin. This funding level exceeds the
approximately $160,000 in Capital Grant funding the City would receive as an Entitlement City.
Table 2 summarizes Capital Grant funding awarded to the City over the past six years.
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Table 2. Capital Grant Funding FY 2020/21 through FY 2025/26
Fiscal Year Amount Recipient(s)
FY 2020-21 $ 330,000 Open Heart Kitchen
FY 2021-22 $ 300,000 Open Heart Kitchen
FY 2022-23 $ 419,130 Axis Community Health $200,000
School of Imagination parking lot $219,130
FY 2023-24 $ 240,205 Tri Valley Haven
FY 2024-25 $ 250,000 Tri Valley Haven
FY 2025-26 $ 319,000 School of Imagination $50,000
Tri Valley Haven $269,000
Total $ 1,858,335
The City is required to make a determination every three years regarding continued
participation in the Urban County program or election to become an Entitlement City. Dublin
first became eligible for Entitlement City status in 2014, when its population exceeded 50,000.
In 2014, 2017, 2020, and 2023, the City Council chose to remain in the Urban County
program. The City must again decide whether to: 1) remain in the Urban County program by
entering into a new three-year Cooperative Agreement, or 2) become an Entitlement City and
initiate the steps necessary to establish that program. The City is required to notify the U.S.
Department of Housing and Urban Development (HUD) and Alameda County HCD of its
decision by June 23, 2026.
Analysis
The City of Dublin has the option to become an Entitlement City and receive CDBG funds
directly from HUD, assuming responsibility for administration of the CDBG program beginning
in 2027, or to remain a participant in the Urban County Program. Table 3 provides a
comparison of CDBG program components under the current Urban County structure and the
estimated Entitlement City model for Dublin. All dollar amounts are based on Fiscal Year 2025 -
26 funding levels and estimates provided by HUD.
Table 3. Urban County & Entitlement City Program Matrix
Program Component
Urban County Program
(FY 2027/2028)
Entitlement City
(FY 2027/2028 Estimated)
CDBG Annual Allocation
(Allocated to programs
noted below)
$274,500 (estimated portion of
Urban County funds attributable
to Dublin's participation in the
program. These funds are not
the exclusive use of Dublin nor
are they a cap on annual
funding available to Dublin
based programs and services)
$274,500 +/- (estimated total
amount that would be available to
Dublin in year 1 of the program)
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Program Component
Urban County Program
(FY 2027/2028)
Entitlement City
(FY 2027/2028 Estimated)
Public Service Grants
(To non-profit service
providers and limited to
15% max. of annual
allocation)
$18,000 (Note: Can utilize
unused Urban County funds to
increase this amount. For
example, Dublin is awarding
$55,500 in FY 2025/26 by
accessing unused funds from
other Urban County
jurisdictions)
$41,175 (estimated total amount
based on the above number)
Capital Grants (To non-
profit organizations for
capital improvements)
Portion of $350,000 Urban
County pool awarded by County
(Recent examples include: Tri-
Valley Haven $269K domestic
violence shelter expansion
funding, School of Imagination
$50K classroom expansion
funding. Total funding of $319K
for FY 2025/26)
$163,925 total to be allocated by
Dublin for City and/or community
projects (Unused funds can be
carried over into future years with
certain limitations)
Economic Development
(Job creation for small, low
income owned or operated
businesses)
Amount varies per year and
determined by program
administration and funded from
the annual CDBG allocation
based on program priorities.
Amount varies per year and
determined by program
administration and funded from
the annual CDBG allocation based
on program priorities. (would
reduce amount of funding for
Capital projects)
Tenant-Based Rental
Assistance (Emergency
housing funds available
partly from CDBG
program, and partly
HOME)
This program is administered
directly through the Urban
County.
CDBG can be used for related
support services outside of 15%
services cap. HOME funds are
used to provide financial
assistance and are administered
by the County.
HOME Funds (rental
assistance, down payment
assistance, homebuyer
counseling, affordable
housing production)
Share of $585,000 pool
awarded on competitive basis to
organizations serving Urban
County jurisdictions.
$75,000 (program administered by
City, but funds continue to be
administered by HCD)
HUD 108 Loans (For
Capital Projects or
Programs as 20-year, low
interest loan)
Available only in partnership
with an Entitlement City
(example: Axis Health and the
City of Livermore which is an
Entitlement City)
Up to 5x CDBG allocation (total
cumulative balance of all
outstanding HUD 108 Loans
cannot exceed this amount)
Program Administration
(20% max. of annual
allocation to cover
program administration,
and preparation of
Consolidated Plan, Annual
Action Plan, Citizen
Participation Plan)
$6,600 to Dublin $54,900 to Dublin
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Program Component
Urban County Program
(FY 2027/2028)
Entitlement City
(FY 2027/2028 Estimated)
Consolidated Plan Prepared every 5 years by
County with staff input (costs
offset by Program
Administration funds)
Prepared every 5 years by the City
(estimated cost: $55,000)
Annual Action Plan and
Citizen Participation
Plan
Prepared annually by County
with staff input
Prepared annually by City (costs
offset by Program Administration
funds)
Monitoring and
Reporting to HUD
Prepared annually by the
County
Prepared annually by the City
Comparable/Nearby Entitlement Cities
Table 4 below provides the Fiscal Year 2025-26 CDBG allocations for comparable nearby
Entitlement Cities. CDBG funding levels for cities are based on three primary factors: the age
of its housing inventory, the number of low-income census tracts, and its population size.
Although Dublin is comparable in size to other cities, it has a significantly smaller stock of older
housing and no low-income census tracts. As a result, Dublin is eligible for a lower level of
CDBG funding.
Table 4. Comparable Entitlement City Annual Allocations
City
Population
2020 Census
CDBG Allocation
FY 2026/27
Walnut Creek (Contra Costa County) 70,127 $ 400,232
Pleasanton (Alameda County) 79,871 $ 384,450
Milpitas (Santa Clara County) 80,273 $ 538,212
Livermore (Alameda County) 87,955 $ 394,163
Dublin (Alameda County) 72,589 $ 274,500
Urban County Program
Historically, the City of Dublin has benefited from participation in the Urban County program by
accessing Capital Grant funding from the Urban County pool and by utilizing more than its
proportional share of available Public Service Grant funds, while not having the burden of the
costs and staff time associated with program administration and reporting as an Entitlement
City. At a minimum, the City will receive a share of CDBG proportional to its population, and
may have opportunities to request unused funds to support CDBG-eligible programs in Dublin.
In addition, the City could potentially utilize CDBG Economic Development funds to support job
creation and retention efforts, including the establishm ent, stabilization, or expansion of small
businesses that are owned by low-income individuals or employing low-income workers.
Entitlement City
Becoming an Entitlement City would provide the City with greater control over CDBG program
administration, provide greater certainty regarding annual Capital Grant funding, and result in
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an estimated $41,000 annually for Public Service Grant funding. However, it could also reduce
the maximum amount of potential Capital Grant funding dollars available each year because
the City could no longer utilize unused funds in the Urban County pool. This increased control
would also result in additional work to administer the program including up-front consultant
time and costs to establish the program. Staff believes significant additional staff time would be
necessary to manage the CDBG start-up and ongoing program administration, either through
redeployed staff resources or through use of a consultant.
Participation Agreement
Staff recommends that the City remain in the Urban County program. The new three-year
Cooperation Agreement will enable the City to continue participating in the Urban County
program beginning July 1, 2027, for federal fiscal years 2027 through 2029. The City Council is
currently being asked to adopt the resolution included as Attachment 1, authorizing the
continued participation in the Urban County Program and authorizing the execution of the
Cooperation Agreement with Alameda County included as Attachment 2.
ENVIRONMENTAL REVIEW:
This information report is not subject to the requirements of the California Environmental
Quality Act (CEQA), pursuant to CEQA Guidelines Section 15378 as it does not meet CEQA’s
definition of a project and will not result in direct or indirect physical changes in the
environment.
STRATEGIC PLAN INITIATIVE:
None.
NOTICING REQUIREMENTS/PUBLIC OUTREACH:
The City Council Agenda was posted.
ATTACHMENTS:
1) Resolution Authorizing the Continued Participation of the City of Dublin in the Alameda
County Urban County for Community Development Block Grant Funds and Authorizing
Execution of the Cooperation Agreement Between the City and County of Alameda
Regarding Participation in the Alameda County Urban County for Community Developmen t
Block Grant Funds
2) Exhibit A to Resolution - Cooperative Agreement Between City of Dublin and the County of
Alameda
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Attachment 1
Reso. No. XX-26, Item X.X, Adopted 06/16/2026 Page 1 of 2
RESOLUTION NO. XX – 26
A RESOLUTION OF THE CITY COUNCIL
OF THE CITY OF DUBLIN
AUTHORIZING THE CONTINUED PARTICIPATION OF THE CITY OF DUBLIN
IN THE ALAMEDA COUNTY URBAN COUNTY FOR COMMUNITY DEVELOPMENT BLOCK
GRANT FUNDS AND AUTHORIZING EXECUTION OF THE COOPERATION AGREEMENT
BETWEEN THE CITY AND COUNTY OF ALAMEDA REGARDING PARTICIPATION IN THE
ALAMEDA COUNTY URBAN COUNTY FOR COMMUNITY DEVELOPMENT BLOCK GRANT
FUNDS
WHEREAS, the United States Congress has enacted the Housing and Community Development
Act of 1974 and Federal regulations have been adopted pursuant thereto, hereinafter called the “Act”;;
and
WHEREAS, Title I of the Act consolidates previously separate grant programs for open space,
public facility loans, water and sewer grants, urban renewal, model cities, rehabilitation loans, and
affordable housing into a program called the Community Development Block Grant (“CDBG”) program;
and
WHEREAS, Title I makes available entitlement grants to cities whose 2020 Census population
exceeds 50,000 persons; and to counties which qualify as an urban county; and
WHEREAS, the term "urban county" means any county within a metropolitan area which:
(1) is authorized under state law to undertake essential community development and housing
assistance activities in its incorporated areas which are not units of general local government;
and,
(2) has a combined population of 200,000 or more in such unincorporated areas and in its
included units of local government:
(A) in which it has authority to undertake essential community development and
housing assistance activities and which do not elect to have their population excluded;
or,
(B) with which it has entered into cooperation agreements to undertake or to assist in
the undertaking of essential community development and housing assistance activities;
and
WHEREAS, the U.S. Department of Housing and Urban Development (“HUD”) has made a
determination that the County of Alameda has the essential powers to operate as an urban county; and
WHEREAS, four cities (Albany, Emeryville, Newark and Piedmont) in Alameda County have a
2020 Census population of less than 50,000 and desire to participate in the Alameda County Urban
County; and one city has a population over 50,000 (Dublin) and desires to participate in the Alameda
County Urban County Program to continue in the Alameda County Urban County for federal fiscal years
2027, 2028 and 2029; and
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Reso. No. XX-26, Item X.X, Adopted XX/XX/2026 Page 2 of 2
WHEREAS, the participating cities, combined with the unincorporated portions of the County of
Alameda, form a combined 2020 Census population of 200,000 or more persons, thereby qualifying as
an urban county, and becoming eligible for an entitlement of CDBG and HOME Investment Partnership
(HOME) funds; and
WHEREAS, the participating cities agree that by executing these cooperative agreements they
may not apply for grants under the Small Cities o r State CDBG Program from appropriations for fiscal
years during the period in which it is participating in the Urban County's CDBG program; and
WHEREAS, the County and City cannot withdraw from the cooperative agreement while the
Program Year 2027-2029 Agreement remains in effect.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Dublin does hereby
resolve, declare, determine, and order as follows:
SECTION 1. The Dublin City Council hereby authorizes the continued participation of the City of
Dublin in the Alameda County Urban County.
SECTION 2. The Dublin City Council hereby authorizes the City Manager to execute a
cooperation agreement with the Alameda County in order to continue the City’s participation in the
Urban County.
SECTION 3. This resolution shall take effect immediately upon its adoption.
BE IT FURTHER RESOLVED that the City Manager is authorized to execute the cooperative
agreement, attached hereto as Exhibit A, and make any necessary, non-substantive changes to carry
out the intent of this Resolution.
PASSED, APPROVED AND ADOPTED BY the City Council of the City of Dublin, on this 16th
day of June, 2026 by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
______________________________
Mayor
ATTEST:
_________________________________
City Clerk
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Attachment 2
Exhibit A to the Resolution
Cooperative Agreement – Page 1 of 13
ALAMEDA COUNTY HOUSING AND COMMUNITY DEVELOPMENT
DEPARTMENT
COOPERATIVE AGREEMENT
BETWEEN
CITY OF DUBLIN
AND
THE COUNTY OF ALAMEDA
This AGREEMENT is made and entered into on this 1st day of July, 2026 by and between the
COUNTY OF ALAMEDA, a body corporate and politic of the State of California (hereinafter
referred to as the “COUNTY”), and the CITY OF DUBLIN, a California municipal corporation
located within Alameda County (hereinafter referred to as the “CITY”).
WHEREAS, the Congress of the United States has enacted the Housing and Community
Development Act of 1974, hereinafter referred to as “the Act”, and Federal regulations have been
adopted pursuant thereto; and
WHEREAS, Title I of the ACT consolidates previously separate grant programs for open
space, public facility loans, water and sewer grants, urban renewal, model cities, rehabilitation
loans, and affordable housing; and
WHEREAS, Title I makes available entitlement grants to (1) cities whose 2020 Census
population exceeds 50,000 persons; and (2) counties which qualify as an urban county; and
WHEREAS, the term “urban county” means any county within a metropolitan area which
is authorized under state law to undertake essential community development and housing
assistance activities in its incorporated areas which are not units of general local government, and
which has a combined population of 200,000 or more in such unincorporated areas and in its
included units of local government with which it has entered into cooperation agreements to
undertake or to assist in the undertaking of essential community development and housing
assistance activities; and
WHEREAS, four cities (Albany, Emeryville, Newark, and Piedmont) in Alameda County
have a 2024 Census population of less than 50,000 and desire to participate in the Alameda County
Urban County, and one city has a population over 50,000 (Dublin) and desires to participate in the
Alameda County Urban County, and
WHEREAS, the participating cities, combined with the unincorporated portions of the
County of Alameda, form a combined 2024 Census population of 200,000 or more persons,
thereby qualifying as an urban county and becoming eligible for an entitlement of Community
Development Block Grant (CDBG) and HOME Investment Partnership (HOME) funds; and
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Cooperative Agreement – Page 2 of 13
WHEREAS, the participating cities agree that by executing these cooperative agreements
they may not apply for grants under the Small Cities or State CDBG Program from appropriations
for fiscal years during the period in which they are participating in the Urban County’s CDBG
program; and
WHEREAS, the COUNTY and the CITY cannot withdraw from this cooperative
agreement while the Program Years 2027, 2028, and 2029 remain in effect; and
WHEREAS, the COUNTY and the CITY desire to provide flexibility in the administration
of CDBG-funded activities by establishing within this Agreement two parallel administrative
frameworks: (i) a Pass-Through Framework, under which the CITY directly administers CDBG-
funded activities as a subrecipient of the COUNTY; and (ii) a Direct Administration Framework,
under which the COUNTY directly administers and implements CDBG-funded activities on behalf
of the URBAN COUNTY, with the CITY able to elect the Direct Administration Framework on a
per-activity basis prior to commitment to activity in accordance with the procedures set forth
herein.
THEREFORE, it is agreed that:
I. GENERAL COOPERATION AND URBAN COUNTY OPERATION
1. The CITY and COUNTY will cooperate in the operation of the URBAN COUNTY to
undertake, or assist in undertaking, community renewal and lower income housing assistance
activities, specifically urban renewal and publicly assisted housing, hereinafter called
“PROGRAM”, to be carried out with annual Community Development Block Grant, hereinafter
called “CDBG”, and HOME Investment Partnership funds, hereinafter called “HOME”, from
federal fiscal years 2027, 2028, and 2029 appropriations and from any program income generated
from the expenditure of such funds. Community renewal and lower income housing assistance
activities shall be those designated or referred to within Title I of the ACT and Title II of the
Cranston-Gonzalez National Affordable Housing Act and the regulations issued pursuant thereto.
2. The COUNTY is authorized to and shall act in a representative capacity as the lead entity for
all members of the URBAN COUNTY for the purposes of administering the CDBG program. The
COUNTY assumes overall responsibility for ensuring that the URBAN COUNTY’s CDBG
program is carried out in compliance with the requirements of the CDBG program, including
requirements concerning the Consolidated Plan.
3. The CITY may not apply for grants under the Small Cities or State CDBG Program from
appropriations for fiscal years during the period in which the CITY is participating in the Urban
County’s CDBG program.
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Cooperative Agreement – Page 3 of 13
4. The CITY may only receive a portion of the formula allocation under the HOME Program
through the Urban County. If the Urban County does not receive a portion of the HOME formula
allocation, the CITY cannot form a HOME Consortium with other local governments. An Urban
County or a unit of government participating with the Urban County may apply to the State of
California for HOME funds, if the State allows. The distribution of HOME funds to the Urban
County is based on the review and recommendations of proposals received in response to an annual
RFP issued by the COUNTY.
5. The CITY may only receive the formula allocation under the Emergency Solutions Grant
(ESG) Program through the Urban County. If the Urban County does not receive the ESG formula
allocation, the CITY cannot participate in an Urban County ESG arrangement with other local
governments. An Urban County or a unit of government participating with the Urban County may
apply to the State of California for ESG funds, if the State allows.
II. URBAN COUNTY GOVERNANCE
6. The CITY shall designate a staff member to participate in the Urban County Technical
Advisory Committee (the “TAC”). The TAC shall serve as the primary forum for member
jurisdiction participation in URBAN COUNTY governance and funding recommendations. CITY
participation in the TAC shall apply regardless of the administrative framework under which any
individual CDBG-funded activity is carried out under this Agreement.
7. The CITY shall have thirty (30) calendar days to approve the portions of the Consolidated
Plan which pertain to the CITY before the COUNTY submits the final Consolidated Plan to U.S.
Department of Housing and Urban Development (HUD). The COUNTY shall incorporate the
CITY’s changes to the Consolidated Plan, if any, provided that they meet CDBG requirements.
This review right shall apply regardless of the administrative framework under which any
individual CDBG-funded activity is carried out.
8. The TAC shall provide input and recommendations on each project proposed for funding
with CDBG funds before the COUNTY approves funding for the project, provided that TAC
approval or disapproval shall not obstruct the implementation of the approved Consolidated Plan
or the COUNTY’s compliance with applicable federal requirements. Final authority for project
selection, funding decisions, and implementation shall rest with the COUNTY as lead entity.
9. The CITY shall designate a representative to whom all notices and communications from the
COUNTY shall be directed. The COUNTY’s duty to notify the CITY shall be complete when the
communication is sent to the designated official or deputy. It is the exclusive duty of the designated
official or deputy to notify the correct individuals or departments within the CITY.
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Cooperative Agreement – Page 4 of 13
III. ADMINISTRATIVE FRAMEWORKS FOR CDBG ACTIVITIES
10. Definitions. For purposes of this Agreement, the following terms shall have the meanings set
forth below:
a. “CDBG Activity” (Activity) means any activity proposed for funding from CDBG
appropriations under this Agreement.
b. “Pass-Through Activity” means a CDBG Activity that is administered by the CITY directly
as a subrecipient of the COUNTY, with the COUNTY distributing CDBG funds to the
CITY for the activity.
c. “Direct Activity” means a CDBG Activity that is administered and implemented by the
COUNTY directly on behalf of the URBAN COUNTY, with no distribution of CDBG
funds to the CITY for the activity.
d. “Notice of Election” means a written notice filed by the CITY with the COUNTY, in
substantially the form attached hereto as Exhibit B, designating a specific CDBG Activity
as a Direct Activity.
e. “Schedule of Activities” means the running schedule of CDBG Activities funded under
this Agreement, in the form attached hereto as Exhibit A, identifying each Activity’s
administrative framework.
f. “Commitment of funds” means the COUNTY (or the CITY as the sub recipient) and the
project owner have executed a written legally binding agreement under which HOME
assistance will be provided to the owner for an identifiable project.
11. Default Framework. Each CDBG Activity proposed by or for the benefit of the CITY shall
be administered as a Pass-Through Activity unless and until the CITY files a Notice of Election
designating that Activity as a Direct Activity in accordance with Paragraph 12.
12. Election Procedure.
a. Timing. The CITY may elect to designate a CDBG Activity as a Direct Activity prior to
commitment of funds to the Activity. Once a CDBG Activity has commenced under the
Pass-Through Framework, it cannot subsequently be converted to a Direct Activity under
this Agreement.
b. Authorization. The CITY shall determine the appropriate internal authorization for filing a
Notice of Election in accordance with the CITY’s own protocols. A Notice of Election may
be executed by the City Manager (or designee) or pursuant to a resolution of the City
Council, at the CITY’s discretion.
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Cooperative Agreement – Page 5 of 13
c. Filing and Acceptance. The CITY shall file the Notice of Election with the COUNTY. The
COUNTY shall record the election in the Schedule of Activities and confirm acceptance
and the effective date in writing to the CITY. The COUNTY may decline to accept a Notice
of Election only if the Activity has already commenced as a Pass-Through Activity or if
the Notice does not satisfy the requirements of this Agreement.
d. Irrevocability. An election to designate a CDBG Activity as a Direct Activity is one -way
and may not be revoked. Once a Notice of Election is filed and accepted by the COUNTY,
the Activity shall remain a Direct Activity for its duration.
13. Allocation. The CITY’s notional fair-share allocation of CDBG funds shall be preserved
regardless of the administrative framework under which any individual Activity is carried out. The
TAC may recommend, and the COUNTY may approve, reallocation of funds among Activities or
among participating jurisdictions as necessary to ensure compliance with CDBG requirements,
including timely expenditure requirements under 24 CFR 570.902. The COUNTY retains final
authority on reallocation decisions consistent with Paragraph 8.
14. Schedule of Activities. The Schedule of Activities (Exhibit A) shall be maintained by the
COUNTY as a running record of all CDBG Activities funded under this Agreement. The Schedule
shall be updated by the COUNTY administratively, without amendment of this Agreement, upon:
(a) Commitment of funds to an Activity; (b) filing and acceptance of a Notice of Election; (c)
reallocation of funds pursuant to Paragraph 13; or (d) Activity completion. The COUNTY shall
provide the CITY with an updated Schedule of Activities upon request and not less than annually.
IV. PASS-THROUGH FRAMEWORK
15. Application. This Section IV applies to each CDBG Activity that is a Pass-Through Activity
under this Agreement.
16. Subrecipient Designation. Pursuant to 24 CFR 570.501(b), the CITY is treated as a
subrecipient of the COUNTY for each Pass-Through Activity and is subject to the requirements
applicable to subrecipients, including the requirement of a written subrecipient agreement
satisfying 24 CFR 570.503
17. Distribution of Funds. The COUNTY shall distribute CDBG funds to the CITY for each
Pass-Through Activity in accordance with the CITY’s notional fair-share allocation as set forth in
Paragraph 13 and the terms of the applicable subrecipient agreement.
18. Reporting and Records. The CITY shall provide the COUNTY with all information
concerning the CITY and the activities the CITY carries out under this Agreement that the
COUNTY requires to prepare: (1) documents required to be submitted to HUD; (2) the annual
performance report; and (3) such other documents as the COUNTY may require to carry out
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community renewal and lower income housing activities or meet Federal requi rements. All
information shall be submitted on forms prescribed by the COUNTY. The CITY agrees to make
available upon request all records concerning the activities carried out under this Section IV for
inspection by the COUNTY or Federal officials during regular business hours.
19. Program Income. The CITY shall inform the COUNTY of any income generated by the
expenditure of CDBG funds received by the CITY for a Pass-Through Activity. The CITY shall
pay any such program income to the COUNTY, or the CITY may retain program income subject
to the requirements set forth in this Agreement and with written approval of the COUNTY. Any
program income the CITY is authorized to retain may only be used for eligible activities in
accordance with all CDBG requirements as may then apply. The COUNTY has the responsibility
for monitoring and reporting to HUD on the use of any such program income, thereby requiring
appropriate record-keeping and reporting by the CITY as may be needed for this purpose. In the
event of close-out or change in status of the CITY, any program income that is on hand or received
subsequent to the close-out or change in status shall be paid to the COUNTY.
20. Real Property. With regard to real property that is within the control of the CITY due to being
acquired or improved in whole or in part using CDBG funds under a Pass-Through Activity, the
CITY must give timely notification to the COUNTY of any modification or change in the use of
the real property from that planned at the time of acquisition or improvement, including
disposition. The CITY must reimburse the COUNTY in an amount equal to the current fair market
value (less any portion thereof attributable to expenditures of non-CDBG funds) of property
acquired or improved with CDBG funds that is sold or transferred for a use which does not qualify
under the CDBG regulations. Any program income generated from the disposition or transfer of
such property prior to or subsequent to the close-out, change of status, or termination of the
cooperation agreement between the COUNTY and the CITY shall be paid to the COUNTY.
21. Indemnification – Pass-Through Activities. With respect to each Pass-Through Activity, the
CITY shall defend, indemnify, and hold harmless the COUNTY, its officers, employees, and
agents from liability for any fines, penalties, or damage of any type accruing to the COUNTY by
virtue of the CITY’s failure to comply with any requirement of the ACT and the regulations issued
pursuant thereto, or failure to comply in any respect with the PROGRAM described herein with
respect to that Activity. Further, the CITY shall defend, indemnify, and hold harmless the
COUNTY, its officers, employees, and agents against any and all liability for injury or damage
caused by any act or omission of the CITY or any of the CITY’s employees or volunteers in the
performance of the Activity, and the CITY shall hold the COUNTY harmless from any and all
loss occasioned in the performance of, or otherwise arising out of, that Activity. The provisions of
California Government Code Section 895.4 apply to the allocation of liability between the parties
for Pass-Through Activities.
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V. DIRECT ADMINISTRATION FRAMEWORK
22. Application. This Section V applies to each CDBG Activity that is a Direct Activity under
this Agreement.
23. Direct Administration. The COUNTY shall directly administer and implement each Direct
Activity on behalf of the URBAN COUNTY as the entitlement grantee. The CITY shall not
directly administer such Activity. The CITY’s role with respect to each Direct A ctivity shall be
governance and consultation through the TAC and the procedures set forth in Section II of this
Agreement, together with the cooperation obligations set forth in Paragraphs 25 and 28.
24. Compliance with 24 CFR Part 570. The COUNTY shall comply with all applicable
requirements of 24 CFR Part 570 in its administration of each Direct Activity. Where the
COUNTY engages a third-party service provider, contractor, or subgrantee to carry out any portion
of a Direct Activity, that entity shall be treated as a subrecipient pursuant to 24 CFR 570.501(b),
and a written agreement satisfying 24 CFR 570.503 shall be executed with that entity.
25. Reporting and Records. The COUNTY shall be responsible for preparing and submitting all
required documentation to HUD and maintaining all program records for each Direct Activity,
including but not limited to: (1) documents required to be submitted to HUD; (2) the annual CDBG
performance report as it relates to the Activity; and (3) such other documents required to carry out
eligible activities or meet Federal requirements. The CITY agrees to provide the COUNTY with
site access, project-related information, and reasonable cooperation as needed for COUNTY
administration of each Direct Activity.
26. Program Income. Any program income generated by the expenditure of CDBG funds for a
Direct Activity shall be paid to and retained by the COUNTY, subject to the requirements set forth
in this Agreement and applicable CDBG regulations. The COUNTY shall use any such program
income only for eligible activities in accordance with all CDBG requirements as may then apply.
27. Real Property. With regard to real property that is within the control of the COUNTY due to
being acquired or improved in whole or in part using CDBG funds under a Direct Activity, the
COUNTY shall comply with applicable property disposition and use restrictions under 24 CFR
Part 570. Any program income generated from the disposition or transfer of such property shall be
retained by the COUNTY.
28. Indemnification – Direct Activities. Pursuant to California Government Code Section 895.4,
with respect to each Direct Activity, the COUNTY shall defend, indemnify, and hold harmless the
CITY, its officers, employees, and agents from liability for any fines, penalties, or damage of any
type accruing to the CITY by virtue of the COUNTY’s failure to comply with any requirement of
the ACT and the regulations issued pursuant thereto, or failure to comply in any respect with the
PROGRAM described herein with respect to that Activity. Further, the COUNTY shall defend,
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indemnify, and hold harmless the CITY, its officers, employees, and agents against any and all
liability for injury or damage caused by any act or omission of the COUNTY or any of the
COUNTY’s employees or volunteers in the performance of the Activity, and the COUNTY shall
hold the CITY harmless from any and all loss occasioned in the performance of, or otherwise
arising out of, that Activity.
VI. UNIVERSAL COMPLIANCE AND PROHIBITIONS
29. Civil Rights and Fair Housing. As a recipient of the CDBG/HOME/ESG Funds from HUD,
the COUNTY and the CITY must take all actions necessary to assure compliance with the Urban
County’s certification required by Section 104(b) of Title I of the Housing and Community
Development Act of 1974, as amended, regarding Title VI of the Civil Rights Act of 1964, the
Fair Housing Act, and to affirmatively further fair housing. The COUNTY and the CITY must
comply with Section 109 of Title I of the Housing and Community Development Act of 1974,
which incorporates Section 504 of the Rehabilitation Act of 1973 and the Age Discrimination Act
of 1975, and other applicable laws, and all regulations issued pursuant thereto. Further, urban
county funding for activities in or in support of any city that does not affirmatively further fair
housing within its own jurisdiction or that impedes the COUNTY’s actions to comply with its fair
housing certification is prohibited.
30. Non-Violent Civil Rights Demonstrations. The COUNTY and the CITY must adopt and
enforce a policy prohibiting the use of excessive force by law enforcement agencies within their
respective jurisdictions against any individual engaged in non-violent civil rights demonstrations,
and a policy of enforcing applicable State and local laws against physically barring entrance to or
exit from a facility or location which is the subject of such non-violent civil rights demonstrations
within their jurisdictions.
31. Prohibition on Transfer of Funds. Neither the COUNTY nor the CITY may sell, trade, or
otherwise transfer all or any portion of the CDBG/HOME FUNDS to a metropolitan city, urban
county, unit of general local government, or Indian tribe or insular area that directly or indirectly
receives CDBG funds in exchange for any other funds, credits, or non-federal considerations. The
COUNTY and the CITY must use the CDBG/HOME FUNDS for activities eligible under Title I
of the Housing and Community Development Act of 1974, as amended, and Title II of the
Cranston-Gonzalez National Affordable Housing Act.
32. Audit Cooperation. The CITY agrees to cooperate, at no cost to the COUNTY, in any audit
of program activities involving program funds received by or expended for the benefit of the CITY,
including preparing appropriate financial statements, promptly following up and taking corrective
action on audit findings, complying with any corrective action plans issued in connection with the
audit, and providing the auditor with information as needed for the auditor to perform the audit
required by applicable regulations. This obligation applies to both Pass-Through Activities and to
the CITY’s cooperation in audits of Direct Activities to the extent the CITY’s records, personnel,
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or facilities are relevant to the audit.
VII. TERM, TRANSITION, AND EXECUTION
33. Term. This Agreement shall go into effect immediately upon the signature of both parties
and shall continue in full force and effect until the CDBG/HOME/ESG Funds and program income
received with respect to activities carried out during the three-year qualification period (Federal
fiscal years 2027, 2028, and 2029) are expended and the funded activities completed. The CITY
will be included in the urban county for the entire three-year period funded by CDBG/HOME/ESG
Funds from Federal fiscal years 2027, 2028, and 2029. Appropriations may not be withdrawn from
the urban county during this agreement period. During the three-year qualification period, Federal
fiscal years 2027, 2028, and 2029, the CITY and any other included unit of general local
government shall not withdraw from nor be removed from the Urban County and cannot terminate
or withdraw from the cooperation agreement.
34. Transition from Prior Cooperation Agreements. Activities funded under prior cooperation
agreements between the COUNTY and the CITY, including but not limited to the cooperation
agreement covering Federal fiscal years 2024, 2025, and 2026, shall continue to be governed by
those prior agreements until the funds with respect to those funding years are expended and the
funded activities are completed. The administrative framework election procedures established by
this Agreement apply only to CDBG Activities funded from federal fiscal years 2027, 2028, and
2029 appropriations and any program income arising therefrom.
35. Counterparts. This Agreement may be executed in counterparts, each of which shall be
deemed to be an original, but all of which, taken together, shall constitute one and the same
Agreement.
[SIGNATURES TO FOLLOW ON THE NEXT PAGE]
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IN WITNESS WHEREOF, the parties hereto have executed this Agreement as of the day
and year first above written.
COUNTY OF ALAMEDA CITY OF DUBLIN
By: _______________________________ By: ______________________________
President of the Board of Supervisors Colleen Tribby
City Manager
Date: ______________________________ Date:_____________________________
Approved as to form by: Approved as to form by:
Andrea L. Weddle, Interim County Counsel
By: _______________________________ By: ______________________________
Kathleen Flynn, John Bakker
Deputy County Counsel City Attorney
Date: _____________________________
By signing above, signatory warrants and represents that he/she executed this Agreement in
his/her authorized capacity and that by his/her signature on this Agreement, he/she or the entity
upon behalf of which he/she acted, executed this Agreement.
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EXHIBIT A
SCHEDULE OF CDBG ACTIVITIES
This Schedule is maintained by the COUNTY as a running record of all CDBG Activities funded
under the Cooperative Agreement between the City of Dublin and the County of Alameda dated
July 1, 2026. The Schedule is updated administratively by the COUNTY upon Commitment to
Activity, filing and acceptance of a Notice of Election, reallocation of funds, or Activity
completion. Updates do not require amendment of the Cooperative Agreement.
Activity
ID
Activity Name /
Description
Program
Year
Initial
Allocation
Administrative
Framework
Notice of
Election
Date
Status
Administrative Framework values: “Pass-Through” or “Direct Administration.” Notice of
Election Date is populated only for Direct Activities. Status values: “Active,” “Completed,” or
“Closed-Out.”
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EXHIBIT B
FORM OF NOTICE OF ELECTION
This form, when completed and signed by an authorized representative of the City and submitted
to the County, constitutes a Notice of Election under Paragraph 12 of the Cooperative Agreement.
[CITY LETTERHEAD]
[Date]
Director
Alameda County Housing and Community Development Department
[Address]
Re: Notice of Election to Designate CDBG Activity as a Direct Activity
Dear Director:
Pursuant to Paragraph 12 of the Cooperative Agreement between the City of Dublin and the
County of Alameda dated July 1, 2026 (the “Cooperative Agreement”), the City of Dublin hereby
provides notice of its election to designate the following CDBG Activity as a Direct Activity, to
be administered and implemented by the County of Alameda on behalf of the Urban County:
Activity Name: ____________________________________________
Activity Description: ____________________________________________
Program Year: ____________________________________________
Anticipated Allocation: $__________________________________________
Anticipated Activity Commitment Date: ____________________________________
This election is one-way and may not be revoked. The City acknowledges that, upon County
acceptance of this Notice, the County shall directly administer and implement the Activity, and
the provisions of Section V of the Cooperative Agreement (Direct Administration Framework) –
including the indemnification, program income, real property, and reporting provisions – shall
govern the Activity.
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Authorization. The City has authorized this Notice of Election as follows (check one):
☐ This Notice is executed by the City Manager (or designee) pursuant to existing City
authorization.
☐ This Notice is executed pursuant to City Council Resolution No. _________ adopted on
_____________. Resolution attached hereto.
Sincerely,
___________________________________
Name:
Title:
cc: City Council
City Attorney
COUNTY ACCEPTANCE
The County of Alameda confirms receipt and acceptance of this Notice of Election. The above-
referenced Activity has been recorded in the Schedule of Activities (Exhibit A) as a Direct
Administration Activity effective on the date set forth below.
___________________________________ Date: _________________________
Director, Alameda County HCD
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