The Community Development (CD) Board recommends amending the allocation of Community Development Block Grant (CDBG) funding to make additional improvements to Comanche Park, including crime prevention infrastructure and street paving. The CIty Council in late 2021 approved funding a series of park improvements with CDBG-CV funds, including new playground equipment and some access improvements in Comanche Park. The park is located in a low-income area of Billings. City Council members have recently shown an increased focus on crime prevention; specifically Crime Prevention Through Environmental Design (CPTED). The safety improvements for Comanche Park are designed to expand coronavirus response and address needs identified within a January 2023 CPTED Assessment conducted by the Billings Police Department. The allocation and expenditure of funding will also assist the City in meeting a CDBG timeliness deadline in the Spring of 2023.
 

The CD Division has CDBG and CDBG-Coronavirus (CDBG-CV) funds to allocate to projects that support coronavirus and other infectious disease response and primarily benefit low-income individuals and families in Billings. Parkland usage throughout the community greatly increased during the pandemic and a variety of parks projects were approved by the City Council in 2021 and are currently moving forward to prevent, prepare for, and/or respond to the coronavirus.

Previously-Approved Comanche Park Coronavirus Impact Project
Following City Council approval in December 2021, a CDBG Grant Agreement with the Parks, Recreation & Public Lands (PRPL) Department was executed February 18, 2022, for $240,000. Project elements included:

• New playground pod, fall protection, and playground equipment,
• ADA accessible parking spots, and
• ADA accessible walkway to the playground.

Design work has been completed, the playground equipment was selected and ordered following a PRPL Facebook survey, and completion is anticipated before September 30, 2023.

Proposed Comanche Park Coronavirus Impact Project Amendments:
Since the original improvements were identified and planned for Comanche Park, it was observed by CD Board members and CD, PRPL and City Engineering staff that several of the streets that abut the park are still dirt/gravel surfaces, making for muddy and poor access conditions to the park. It seemed inconsistent and incomplete to make ADA parking and access improvements in the park without considering paving the streets used to get to the park in this area. It was further observed that City Council included funding to assess how to further incorporate CPTED into City operations and projects. Given the issues of improved access to the park and an opportunity to assess the safety of the park, CD, PRPL, and City Engineering staff prepared for the CD Board paving information for the street and alleys abutting the park, and results of a CPTED assessment conducted by the Billings Police Department, and brought them to the CD Board for consideration. After review and discussion at several meetings, the CD Board recommended including the paving and CPTED improvements to City Councilas as outlined below:

Street Paving Recommendations:                             (Estimated Cost $79,649)

CD Board recommends paving the existing gravel street sections adjacent to Comanche Park to support and encourage increased park usage (S. Plainview Street, Kalmar Drive, and a portion of S. 12th St. W).

CPTED Recommendations:                                    (Estimated Cost $53,459)

CD Board recommends installing the following safety elements and features in Comanche Park to support safety of park users and encourage increased park usage.

• Solar Lighting for:
  • Playground pod,
  • Basketball area, and
  • Walkway.
• Replacement of basketball hoop, backboard, and net.
• Wayfinding Signs.
• Park Signs.
• Perimeter detail around gleaning area (fruit trees).
• Bollard fencing or another type of barrier along the alley (north side of the park).
• Community Art.

Funding Commitment Conditions
Construction and/or Development Agreement(s) will be required. The CD Division manages all projects and activities on a close- and shovel-ready basis. If funding allocations for paving and safety improvements are approved for the above Comanche Park projects, staff will develop a timeline for project implementation and funding will be committed incrementally. Agreements shall include provisions for timely expenditures. If projects stall and/or do not move forward, CD staff may reallocate funding to another approved program or project to meet HUD imposed expenditure deadlines. CDBG-CV programs and projects include, but are not limited to other park improvements, public services, public facilities, additional public handwashing stations / restrooms, etc. CDBG programs include, but are not limited to, First Time Home Buyer, Foreclosure Acquisition / Rehabilitation, Housing Rehabilitation, and AmeriCorps VISTA.

Procedural History for CDBG-CV Park Funding Allocations and Comanche Park Improvements:

• April & September, 2020: HUD notified the City of Billings it would receive a total of $909,126 in CDBG-CV funds.
• September / October 2020: Coronavirus Surveys released citywide.
• December 2020: Coronavirus Response Initiative Report published and distributed.
• March 2021: CD Board prioritized projects / activities for CDBG-CV funding.
• April / May 2021: CDBG-CV online grant application process developed and released. Applications were received from the Downtown Business Improvement District, Inc. (BID) for the installation of a downtown public handwashing station / restroom ($117,715) and The Salvation Army for a mobile meals program ($55,000).
• June 1, 2021: CD Board recommends the City Council approve grant awards to the BID and Salvation Army. City Council approved grant awards (current status: the Salvation Army Project is complete; the prefabricated downtown restroom unit has been received and will be installed as weather permits).
• August to November, 2021: CD Board discusses using a portion of the remaining CDBG-CV funds and regular CDBG funds to install park improvements in low-income areas to help reduce the spread of COVID-19 by implementing touchless features and other elements in park facilities. Improvements may also positively affect mental health by encouraging socially-distanced exercise and outdoor activities. Staff and CD Board representatives toured several parks prior to developing a list of eligible projects that was subsequently refined with PRPL staff input. CD Board recommended moving parks projects forward.
• November 2021: CD Board discussion and prioritization of potential parks projects using CDBG and/or CDBG-CV funds. CD Board members note the lack of paved streets surrounding Comanche Park and CD staff contacted City Engineering but more research was needed and the park projects needed to move forward for approval.
• November 10, 2021: CD staff presented parks projects to the Parks, Recreation & Cemetery Board. The Board voted unanimously to recommend the City Council approve the parks projects.
• December 7, 2021: The CD Board finalizes parks projects and Fast-Track Public Services project recommendations to the City Council.
• December 20, 2021: City Council reviews and approves parks projects and funding allocations, including Fast-Track Public Service Projects.
• February 18, 2022: CDBG Grant Agreement completed with PRPL for the Comanche Park Project ($240,000).
• June 2022: PRPL Department implements online Comanche Park Playground Survey to help determine the playground concept and equipment to be installed. PRPL Facebook post shows playground equipment selected through this process.
• July 11, 2022: City Council approves playground equipment purchase; equipment subsequently ordered.
• September 2022: PRPL engages Cushing Terrell to provide Comanche Park design, construction documents, and construction administration.
• October 2022: City Engineers Office as part of the project process sends a Special Improvement District (SID) paving interest survey for the general area of S.12th Street W and Kalmar Drive.
• November 18, 2022: City Engineer advises CD staff the residents along S 12th Street W are not interested in participating in a street paving SID. CD Board and staff discuss incorporating paving into the improvements with added funding.
• December 1, 2022: PRPL notifies CD it lacks the capacity and funding to take on the added paving project as an amendment to the existing Grant Agreement.
• December 20, 2022: City Engineer agrees to assist with the paving project and shares estimated timeline (bid package developed in February; bid in March; 2023 construction), but notes that "gravel streets funding" is not available for the project because residents are not participating in an SID.
• January 9, 2023: After discussion with CD Board about City Council focus on CPTED, CD staff asks Billings Police Department to prepare a CPTED assessment for Comanche Park.
• January 31, 2023: CD staff receives Comanche Park CPTED Assessment and develops cost estimates for installing recommended CPTED improvements.
• February 7, 2022: CD Board reviews, discusses, and takes action to recommend the City Council approve allocating CDBG funds to 1) pave all three street sections adjacent to Comanche Park and increase the contingency from 10% to 20%, and 2) implement all the CPTED recommendations within the CPTED Assessment.
• March 8, 2022: Parks, Recreation & Cemetery Board reviews and discusses the proposed Comanche Park Project Amendments (results to be shared during presentation of this item at City Council).

• Comanche Park is located in a low-income area of Billings and primarily serves low-income community members.
• Other community members and visitors also benefit frim park improvements.

City Council may:

• Approve increasing the CDBG funding allocation to amend the Comanche Park Coronavirus Impact Project to 1) pave the three street sections adjacent to Comanche Park, and 2) implement recommendations included within the January 2023 CPTED Assessment. A committed funding allocation to support this amended project would assist the City in meeting CDBG timeliness deadlines; or,
• Not Approve increasing the CDBG funding allocation to amend the Comanche Park Coronavirus Impact Project. PRPL Department would need to secure other funding / financing to complete these additional projects or not move the projects forward.

The CD Board recommends utilizing available CDBG funding for amending the Comanche Park Coronavirus Impact Project. The City has received revenue from recent home buyer / home repair loan repayments and this funding must be expended as soon as possible under already approved and qualifying projects/programs. Since this recommendation contemplates using only federal funds, City staff does not anticipate any negative fiscal effects to the City budget.

An overall review of the proposed project elements reveals the project additions are consistent with already programmed parks projects the City has funded and is in alignment with the City's Consolidated Plan. There is a demonstrated need for the installation of these amenities for our low income community members, as evidenced by data collected through the City's Coronavirus Surveys and parks / trails usage data. CD staff has extensive experience developing and managing projects and are knowledgeable about federal program requirements to ensure this project meets HUD program regulations.