What is the Community Development Block Grant Program (CDBG)? The Community Development Block Grant (CDBG) is a federal grant program administered by the U.S. Department of Housing and Urban Development (HUD) that provides funds to communities for a variety of public projects and services. 1
When was CDBG established? The CDBG Program was established by Title I of the Housing and Community Development Act of 1974, the primary goal of CDBG is to develop and strengthen viable urban communities by providing decent housing and suitable living environments principally for low-and moderate-income persons. 2
Henry County CDBG Henry County, Georgia is a new federal CDBG Program entitlement Urban County. As such, the county will receive CDBG funds each year from HUD for housing and community development activities. The County qualifies as an urban county having a population of at least 200,000. 3
Henry County CDBG Cont. Block grant funds are made available annually through HUD. The amount of each entitlement grant can change annually. A statutory formula, which includes an objective analysis of community needs based on poverty, population, and age of housing stock, is used to determine the actual annual allocation to entitlement entities.
Henry County CDBG Cont. County CDBG funds will be used to address a variety of housing, public service, public facilities, infrastructure, and economic development needs within Henry County and all of the municipalities located within its boundaries. Specifically, the Cities of Hampton, Locust Grove, McDonough and Stockbridge in addition to the unincorporated areas of Henry County will be served through the utilization of CDBG funds. 5
National Objectives Benefits low and moderate income persons Prevents or eliminates the presence of slum and or blight Addresses community development needs having a particular urgency of recent origin, due to existing conditions posing a serious and immediate threat to the health or welfare of the community within 18 months for which other funding is not available. See Section II of the CDBG Program Manual for more on CDBG National Objectives 6
Henry County Priorities Henry County s funding priorities and policies for CDBG are a result of the County s 5- year Consolidated Plan process. Henry County CDBG projects shall be designed to meet the goals and objectives of the County s current year 2012-2016 Consolidated Plan. Housing Needs Homeless Needs Community Development Needs See Section V of CDBG Program Manual
Developing a CDBG Project Meet a National Objective; Be an Eligible Activity; Be Adequately Documented; and Must have other funding for each project/activity. CDBG is not sole source funding. FY14 CDBG Applications are due on Wednesday, February 19 by 5:00 pm.
Step 1: Meeting the National Objectives All projects and services must meet at least one (1) of the following: Provide a benefit to low- to moderate-income persons and/or households; Aid in the prevention or elimination of slums or blight; or Meet an urgent community development need of recent origin that threatens the health or welfare of residents.
Criteria for Activities Benefiting Low/Moderate Income Persons A low- or moderate-income person is defined in the statute as a member of a household having an annual income equal to or less than 80% of the median income as defined by HUD. The two pertinent median income limits for CDBG are as follows: Low income = 50% of median Moderate income = 80% of median The median income changes annually, therefore, the household s low- and moderate-income levels may also change. Every applicant must document the income levels of the potential beneficiaries of CDBG funding at the time of application submission to ensure that at least 44.6% of the beneficiaries for Area Benefit project and 51% of all other LMI classifications to meet HUD guidelines. Activities, which benefit low/mod income persons, may be classified as providing: Area Benefit Limited Clientele Benefit to persons of low/moderate income Housing Benefit to persons of low/moderate income Job Creation or Retention for persons of low/moderate income For income guidelines, see Appendix A of the CDBG Program Manual.
Benefit to Low-and Moderate-Income (LMI) Persons ( 570.208(a)) Area Benefit ( 570.208(a)(1)) Establish the boundaries of the service area of the proposed community development project. The service area must be primarily residential in character and the activity must meet locally identified needs. HUD requires that at least 44.6 percent of the residents be persons of low- to moderate- income. Limited Clientele Benefit ( 570.208(a)(2)) These are nonhousing activities that benefit a specific group of people, rather than all the residents in a particular area. HUD requires that at least 51 percent of the members of these specific groups be persons of low- to moderate- income. Data on incomes of users must be available from the files of the service agency or sponsoring organization unless the activity is Presumed Benefit.
Benefit to LMI cont. Presumed Benefit Having benefit to a clientele generally presumed to be principally low/moderate income persons. Abused children Severely disabled adults (as defined by the Bureau of Census) Elderly persons (62 years of age and over) Illiterate adults Migrant farm workers Battered spouses Persons with HIV/AIDS Homeless persons
Benefit to LMI cont. Nature/ Location Be of such nature and location that it may be concluded that the beneficiaries will primarily be low- and moderate-income persons. The use of Nature/Location must be approved by HUD prior to award.
Benefit to LMI cont. LMI Housing Activities ( 570.208(a)(3)) Primarily used for the rehabilitation of residential and mixed-use buildings. Does the activity benefit LMI households, or remove blight, and Is the applicant an eligible public or private non-profit organization or a special limited profit corporation? Only Permanent housing is eligible under this subcategory for LMI benefit. The income of all adults (not necessarily related) living in the household must be combined and compared to the income limit for the number of persons living in the household.
Benefit to LMI cont. LMI Job Creation or Retention Activities ( 570.208(a)(4)) Job Creation the recipient must document that at least 51 percent of the jobs created will be held by, or will be available to LMI persons. Job Retention the recipient must document that the jobs would actually be lost without CDBG assistance
Criteria for Activities to Prevent or Eliminate Slums or Blight Activities that address the prevention or elimination of slums or blight may be classified as: An Area Basis A Spot Basis
Area Basis In order to qualify under the National Objective of slums/blight on an Area Basis, an activity must meet all of the following criteria: The area must be designated as a slum/blight area by the governing jurisdiction; and must meet the definition of a slum, blighted, deteriorated, or deteriorating area under state or local law. A substantial number of deteriorated or deteriorating buildings or public improvements must be located throughout the area. Documentation must be maintained by the governing jurisdiction on the boundaries of the area and the conditions, which qualified the area under this objective at the time of designation. The activity must address one of the conditions which contributed to the deterioration of the area. Potentially eligible activities include assistance to commercial or industrial businesses; public facilities and improvements; and code enforcement provided the assistance is designed to address one or more of the specific conditions which qualified the area.
Spot Basis In order to qualify under the National Objective of prevention or elimination of slums or blight on a Spot Basis, the activity must meet all of the following criteria: The activity must be designed to eliminate specific conditions of blight or physical decay at a specific location not incorporated in a slum or blighted area; and The activity must be limited to acquisition, clearance, relocation, historic preservation, or building rehabilitation to eliminate specific conditions detrimental to public health and safety. Potentially eligible activities under the objective to prevent or eliminate slums or blight on a spot basis include the removal of faulty wiring or falling plaster; historic preservation of a public facility; and demolition of a vacant, deteriorated, (non-historic) abandoned building.
Criteria for Activities to Meet an Urgent Community Development Need In order to qualify an activity under the objective of meeting an Urgent Community Development Need, an activity must be designed to alleviate existing conditions in which the governing jurisdiction certifies all of the following: The existing conditions pose a serious and immediate threat to the health, safety or welfare of the community; and The existing conditions are of recent origin (within the last 18 months); and The grantee is unable to finance the activity; and Other funding resources are not available. A condition will generally be considered of recent origin if it developed or became critical within 18 months preceding certification. Activities meeting the urgent needs criteria involve emergency or disaster situations with substantial costs which overextend the ability of a community to pay the costs through local taxation. Examples of activities meeting the Urgent Community Development Need objective include ruptured sewer and water mains; damages resulting from major catastrophes; or emergencies such as floods and earthquakes.
Step 2: Determining Eligibility The proper classification of an activity insures that CDBG funds are used only for eligible activities and may further identify applicable statutes, requirements, and regulations for certain activities.
Eligible Activities CDBG funds may be used for activities which include, but are not limited to: acquisition of real property; relocation and demolition; rehabilitation of residential and non-residential structures; construction of public facilities and improvements, such as water and sewer facilities, streets, sidewalks, neighborhood centers, and the conversion of school buildings for eligible purposes; public services, within certain limits; activities relating to energy conservation and renewable energy resources; and provision of assistance to profit-motivated businesses to carry out economic development and job creation/retention activities. 21
LMI Eligible Activities Area Benefit - street improvements; water and sewer line upgrades; and neighborhood facility construction Limited Clientele Benefit - construction of a senior center; public services for the homeless; job training or job creation for low/mod income individuals; and meals on wheels for the elderly Housing Benefit Activities - acquisition of property for permanent housing; rehabilitation of permanent housing; conversion of non-residential structures into permanent housing; and eligible activities connected with new housing construction
Ineligible Activities Generally, the following types of activities are ineligible: acquisition, construction, or reconstruction of buildings for the general conduct of government; political activities; certain income payments; and construction of new housing by units of general local government. See Section III of the CDBG Program Manual for more on Eligible and Ineligible Activities 23
Step 3: Obtain Adequate Documentation The essential aspect of any community development project is the information presented to document the National Objective addressed by the proposed community development project. Step 3 in this process is data collection to justify that the proposed project meets a particular National Objective. See Section IV of the CDBG Program Manual
National Objective Low/Mod Income Benefit Removal of Slum or Blight Requirements Map identifying the boundaries of the service area Income characteristics of the users Most recent quarterly/annual reports on beneficiaries and users by income Board resolution designating area under state or local law Substantial number of buildings or public improvements must be deteriorated Map delineating boundaries of area Activity addresses one or more of the deteriorated conditions Detailed narrative describing programs and comprehensive plans for improvements Urgent Need Certification that condition poses serious threat to the health and welfare of the community Condition is recent Governing jurisdiction is unable to finance project No other resources or funds are available Example of Data Sources Survey of residents incomes in the service area Census and Block Group information Income surveys of all users of project/service Pre-rehabilitation inspection reports and a Phase I Environmental Site Assessment Infrastructure conditions report Detailed survey of building conditions and code violations Urban renewal plans Turndown letters indicating no other source of funding is available Health Department reports documenting a serious condition Evidence that applicant-designed activity to address the
OTHER FEDERAL REQUIREMENTS THAT APPLY TO CDBG Environmental Review Lead-Based Paint Labor Standards Georgia Security and Immigration Compliance Minority and Women Owned Businesses (MBE/FBE) Procurement Equal Employment Opportunity Civil Rights and Section 504 Uniform Relocation Act Section 3 See Section X of the CDBG Program Manual
Each Henry County CDBG sub-recipient must comply with the statutory, regulatory, and the County program requirements. Some of these requirements include: Completing projects as expeditiously as possible and in accordance with contract requirements; Promptly notifying the County when changes in the conditions or scope of work or service for the CDBG-funded activity may occur, notification must be provided to the County in writing. Sub-recipient must await approval decision by the County prior to making actual changes in the project; Submitting requests for reimbursements in compliance with all applicable regulations, record keeping and submission schedules; Maintaining adequate filing systems that document all program activities, with particular emphasis on expenditures and benefit to low- and moderate-income persons; and Providing monthly or quarterly Progress Reports (as applicable) to the County on project progress, and on the beneficiaries (individuals or households), indicating how they benefit from the activity funded by the grant.
Timely Performance The timely performance of all CDBG sub-recipients is critical to the County remaining in compliance with HUD s 1.5 rule. For all sub-recipients that will execute public facility and housing related projects, it is important to plan for construction and rehabilitation prior to the award of CDBG funds. 1.5 rule - CDBG regulations require that no participating county or city have more than 1½ years of CDBG funds in their line of credit with HUD sixty (60) days prior to receipt of their annual program allocation.
HUD emphasizes the need for CDBG funds to be expended in an appropriate and timely manner. When funds are not expended within the contract period, CDBG policies permit the recapture and reallocation of funds from sub-recipients. The Board of Commissioners may recapture and reallocate unexpended funds to agencies and municipalities who are more aggressive and effective in the administration of their projects and services, and who consistently submit timely reporting and requests for reimbursement to the County. To avoid recapture of funds and to facilitate communication between the County and sub-recipients, in order to avoid project delays. Sub-recipients should: Ensure submission of monthly or quarterly progress reports as specified in the contractual agreement updating the County on project or program status, to include the number of low- and moderate-income individuals benefiting from the CDBG-funded activities; and Ensure submission of regular reimbursement request.
FY13 CDBG Funding Distribution $971,360 FY13 CDBG $471,384 Public Facility/Infr. $160,000 Housing Assistance $145,704 Public Service $194,272 Local Administration
Impacts to the FY14 CDBG Funding FY14 CDBG Federal funding expected to be $300 million less than the FY13 funding levels. As a result Entitlement Grantees, such as Henry County, can expect their FY14 allocation to be less than awarded in FY13. 30 Potentially new Entitlement Grantees for FY14 could also significantly affect allocation amounts
Projected FY14 CDBG Funding $874,224 Projected FY14 award $568,247 = Public Facility/ Infrastructure Improvements and Housing Assistance $131,133 = 15% ceiling for Public Services $174,844 = 20% ceiling for Local Administration 70% of all CDBG funding must be utilized to benefit LMI = $611,970
Application Instructions It is every applicant s responsibility to check the website periodically for application updates. 1. Read the CDBG Program Manual also found online. 2. Complete the application package that best matches your proposed activity. Application packages are by CDBG funding categories to include Public Service, Public Facility/ Infrastructure Improvements and Rehabilitation and Preservation. Refer to the Program Manual for list of eligible activities for each CDBG funding category. 3. Provide all required information. Incomplete applications will not be considered. 4. Separate applications are required if applying for multiple activities or services or for funding from multiple CDBG funding categories. 5. Submitted applications must follow the format of the online application package. Narratives and descriptions submitted on separate paper must be labeled and numbered to correspond to the appropriate section in the application package. Attach the narrative and description pages behind the application package page that they are responding to. 6. All requested attachments must be submitted with the application. 7. Follow Citizens Participation Requirements 8. Three (3) copies of completed applications must be submitted by Wednesday, February 19, 2014 at 5:00 pm. Late applications will not be accepted. Applications will be date and time stamped upon receipt. Applications should be delivered or mailed to the CDBG Program located in the Henry County Administration Building at 140 Henry Parkway, McDonough, GA 30253. E-mailed or faxed applications will not be accepted.
FY14 Application Review Process Departments review and ranking of applications Department completes summary of applications and funding allocation recommendations for the Board of Commissioners Funding recommendation advertised in newspapers and web page Department manages public hearings on proposed recommendations Proposed recommendations submitted to the Board of Commissioners for approval Approved allocations submitted to HUD in the Consolidated Plan and Annual Action Plan
Staff Rating of CDBG Applications 100 possible points Project Description National Objective Compliance Project Eligibility Compliance Program Development and Management Budget Comprehensive Plan / Mission Statement Compliance Citizens Participation Application Submission Checklist Application Certifications 10 points 10 points 10 points 20 points 20 points 10 points 10 points 5 points 5 points
? Questions: Write all of your questions on the index cards. Questions and responses from all Application Workshops will be posted to the website by Wednesday, February 5.