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B. Non -Substantial Amendments to the Action Plan <br />Non -Substantial Amendments are defined as minor, one that does not materially change the activities or <br />eligible beneficiaries. This provision should not be construed as allowing the general administrative <br />budget to exceed the allowable limit. Additionally, a Substantial Amendment is not required in the case <br />where the City is simply requesting additional funding from HUD. HUD must be notified five days in <br />advance of a Non -Substantial Amendment becoming effective. Non -Substantial Amendments are not <br />subject to the public notification and public comment procedures previously identified in the Federal <br />Register or this Action Plan, however the City will publish all Amendments, Substantial or Non - <br />Substantial, to the Disaster Recovery website and will be numbered sequentially for ease of <br />identification and reference. <br />Leveraging Funds <br />The City is currently exploring other sources of funding and will amend the Action Plan when those <br />sources become apparent or available. The City's 2016 regular CDBG Action Plan includes the allocation <br />of $211,104 specifically awarded to a subrecipient for minor rehabilitation of flood- damaged homes. To <br />date, the City has explored the following options for additional funding to support community recovery: <br />• Clean Water State Revolving Funds administered by the Texas Water Development Board. The City is <br />in the process of being awarded a $2 million grant for flood mitigation. <br />• Private funding in the amount of $500,000 specifically identified to address drainage/flooding in the <br />Blanco Gardens neighborhood. <br />• Hazard Mitigation Grant Programs 404 and 406. The City has applied for funding to both the State <br />and FEMA. The applications are still under review. It is unclear at this time whether this funding will <br />become available during this recovery process. <br />• The city will utilize city owned property for the Reconstruction on City Owned Property (RCGP) <br />activity. <br />%' IL C � y iofific,,, fl o n s <br />In accordance with HUD guidelines and the Federal Register requirements, the City certifies that: <br />A. The City will affirmatively further fair housing, which means that it will conduct an analysis to <br />identify impediments to fair housing choice within its jurisdiction and take appropriate actions to <br />overcome the effects of any impediments identified through that analysis, and maintain records <br />reflecting the analysis and actions in this regard (see 24 CFR 570.487(b)(2) and 570.601(a)(2)). In <br />addition, the City certifies that agreements with subrecipients will meet all civil rights related <br />requirements pursuant to 24 CFR 570.503(b)(5). <br />B. The City has in effect and is following a residential anti -displacement and relocation assistance <br />plan in connection with any activity assisted with funding under the CDBG-DR program. <br />C. The City is compliant with restrictions on lobbying required by 24 CFR part 87, together with <br />disclosure forms, if required by part 87. <br />D. The Action Plan for Disaster Recovery is authorized under State and local law (as applicable) and <br />that the City, and any entity or entities designated by the City, possess(es) the legal authority to <br />carry out the program for which it is seeking funding, in accordance with applicable HUD <br />regulations and this Notice. The City certifies that activities to be administered with funds under <br />this Notice are consistent with its Action Plan. <br />Last Updated 3/03/20 Page 58 of 63 <br />