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Rationale for the priorities for allocating investments geographically For many programs using CDBG funds, such as residential or business rehabilitation, the exact location of the activity is not determined prior to funding the program as a whole. Pursuant to the CDBG Program Final Rule in these instances, the Consolidated Plan must identify who may apply for assistance, the process by which the grantee will select those to receive assistance, and how much and under what terms the assistance will be given. The City of Pleasanton has contracted with Neighborhood Solutions in prior fiscal years to administer a Housing Rehabilitation Program (HRP) using CDBG, HOME and Lower Income Housing funds for loans and grants serving eligible low- income home owners and renters in Pleasanton. The goal of the program is to conserve, preserve, and improve the housing and neighborhoods by addressing the needs of low income Pleasanton residents. To that end, the program provides grants or low interest loans to qualifying properties and owners to provide a variety of rehabilitation services, such as rental housing rehabilitation, minor and major home repairs, mobile home repairs, exterior paint or clean -up assistance, seismic retrofitting, and accessibility improvements. Based on past experience, units benefitting from the HRP have been spread throughout the community although mobile home grants are by definition focused in the two largest mobile home parks at 3231 and 3263 Vineyard Avenue in east Pleasanton (census tract 4507.42). These two parks are primarily occupied by low- income seniors. The rental rehabilitation program is available to those properties in Pleasanton where at least 51% of the units are occupied by low and very low income households, or in which 51% of the units will be rent - restricted through a rental agreement to qualified low income households after rehabilitation. This program provides below- market - interest -rate loans to property owners to complete the rehabilitation. Tenant incomes are verified to determine whether at least half of the units are occupied by lower income households. The property's operating budget is also examined to determine the property's long- term financial feasibility and ability to repay the loan. HOME Investment Partnership funding is allocated to the jurisdictions within the Alameda County HOME Consortium on a formula basis. HOME funds are distributed throughout all parts of the HOME Consortium. All activities to be undertaken are intended and open to serve eligible households living in the Consortium. Discussion Annual Action Plan 2016 OMB Control No: 2506 -0117 (exp. 07/31/2015) 38