The Lifecycle of Grants: Introduction to CDBG Administration November 7, 2012

The Lifecycle of Grants:Introduction to CDBG Administration

November 7, 2012

TOPICS

• Federal and State Administration • Program History and Objectives• National Objectives• Eligible and Ineligible CDBG Activities• Citizen Participation

The Lifecycle of Grants • Grant Agreement and Fair Housing (Wed P.M.)• Environmental Review (Wed P.M.)• Financial Management (Thurs A.M.)• Acquisition, Relocation, and Procurement

(Thurs P.M.)• Contract and Construction Management (Thurs

P.M.)• Labor Standards (Fri A.M.)• Monitoring and Closeout (Fri A.M)

MATERIALS• Community Development Program

Timeline Chart• PowerPoint Presentations• Environmental Review Templates• File Guide• Monitoring Tool• Miscellaneous Handouts

CDBG PROGRAM HISTORY

ESTABLISHING LEGISLATION

• Authorized under Title I of the Housing and Community Development Act of 1974

• Combined a number of existing community development programs into one funding source

• Provided for increased flexibility for local governments

• Regulations located at 24 CFR Part 570

STATE ADMINISTERED CDBG

• State Program (Small Cities) established in 1982

• Targeted at cities with populations of less than 50,000 and counties with populations of less than 200,000

• Reflected desire for increased flexibility• Regulations located at 24 CFR Part 570.480

CDBG PRIMARY OBJECTIVES

• Development of viable communities, principally for low- and moderate-income (LMI) persons, through;– Decent housing– Suitable living environment– Expanded economic opportunity

KEY DEFINITIONS• Entitlement Program

Grants given to cities with populations of 50,000 and counties with populations of 200,000

• State and Small Cities ProgramGrants given to states, which administer the program to non-entitled cities/counties

• CDBG RecipientThe CDBG unit of general local government that receives its CDBG grant from HUD or the state

OHIO STATE PROGRAM ADMINISTRATION

• Department of Housing and Urban Development Awards funds to the Ohio Development Services Agency

• Office of Community Development (Community Services Division)

Administers the program for the State of Ohio • Eligible communities include 79 counties, direct cities,

and villages, depending on the individual program parameters

OHIO STATE PROGRAM ADMINISTRATION• Community Development Program:

CDBG eligible activities, including public facilities, public services, demolition/clearance, and limited housing

• Economic Development Loan and Public Infrastructure Grant Program:Grants for off-site infrastructure and loans for fixed asset financing tied to job creation/retention

• Residential Public Infrastructure Grant Program: Public water and sanitary sewer projects

• Community Housing Improvement Program: private owner/rental rehab, home repair, acquisition/rehab/resale, down payment assistance rehab

COMMUNITY DEVELOPMENT PROGRAM

Administered by the Ohio Department of Development Office of Community Development’s Economic and Appalachian Development Section Staff

COMMUNITY DEVELOPMENT PROGRAM

GOAL: • To provide communities with a flexible housing and

community development resource that can be used to address locally identified needs that are eligible CDBG activities and qualify under the national objective of Low- and Moderate-Income (LMI) Benefit or Elimination of Slum and Blight.

Economic and Appalachian Development Section

Mary R. Oakley, Manager

Michael Novakov, Community Development Analyst – AREA ATimothy Leasure, Community Development Analyst – AREA BDavid (DJ) Pasquariello, Community Development Analyst – AREA CMichael Norton-Smith, Community Development Analyst – AREA DMichael Kinninger, Community Development Analyst – AREA F

Area E: Open

Christa Callihan, Federal ARC & State Appalachian DevelopmentBeverly Cooper, Federal ARC & State Appalachian Development

Training and Technical Assistance Section Staffing

• Betsy Giffin, Manager • Tim Allen, Environmental Review Specialist• Cecilia Castillo, Environmental Review Specialist• Joyce Hill, Civil Rights Specialist• Shannon Southworth, Community Development Analyst

Fiscal Grant Management Section Staffing

• Maddie Forrester, Manager • Jolanda Cunningham, Fiscal Specialist• Stephanie Miller, Account Clerk • Natalie Qualls, Fiscal Specialist • Carlotta Underwood, Fiscal Specialist • Wendy Van Over, Fiscal Specialist

Fiscal Grant Management Section Staffing

• Maddie Forrester, Manager • Jolanda Cunningham, Fiscal Specialist• Stephanie Miller, Account Clerk • Natalie Qualls, Fiscal Specialist • Carlotta Underwood, Fiscal Specialist • Wendy Van Over, Fiscal Specialist

Introductions

NameAgency/Community

Number of Years CDBG Experience

• National Objective • Citizen Participation• Fair Housing/Civil Rights• Environmental Review • Financial Management• Acquisition/Relocation• Procurement• Construction and Contract Management• Labor Standards• Grants Management System

FEDERAL/STATE REQUIREMENTS

NATIONAL OBJECTIVES

NATIONAL OBJECTIVES• All CDBG activities must result in one of the

following:– Benefit low- and moderate-income (LMI) persons– Prevent or eliminate slum & blight– Meet an urgent need having a particular urgency because

existing conditions pose a serious and immediate threat to the health or welfare of the community

• Regulations located at 24 CFR §570.208 and §570.483

!Area

Benefit

Limited Clientel

e

Jobs

Area Basis

NATIONAL OBJECTIVES

URGENT NEEDSLUM/BLIGHTLMI

Housing

Urban Renewal

Spot Basis

• Some activities qualify under more than one national objective

• Rule of thumb, choose the one that is easiest to document

NATIONAL OBJECTIVES

• There are 4 ways an activity can satisfy the LMI national objective:– Area benefit– Limited clientele– Housing– Job creation or retention

• Regulations located at §570.208(a)(1-4)

NATIONAL OBJECTIVE: LMI

• To qualify a project using LMI Area benefit, applicants must determine:– The service area of activity– Whether the area is primarily residential– Whether the activity benefits all residents of the service

area– Whether the area is 51% LMI– Whether the activity is a public facility for which

assessments will be charged

LMI AREA BENEFIT

• A project’s service area can be defined as:– An entire community (city, county, village)– A Census Tract or Block Group, or multiple Census Tracts or

Block Groups– A neighborhood– Residents along street or water/sewer line

LMI AREA BENEFIT

• EXAMPLE 1: Park Improvement Project– What is the true service area? – Who uses the park?– What does geography of area show?– How many other parks in the area?– What services does the park provide

(neighborhood park vs. baseball diamonds)

LMI AREA BENEFIT

• EXAMPLE 2: Water or Sewer Project– Who is on service route?– Who will connect to infrastructure?– What type of infrastructure is it?

• A water tower or wastewater treatment plant might benefit the entire town whereas a waterline might only benefit the residents on one street

LMI AREA BENEFIT

• EXAMPLE 3: Street Improvement Project– State Route or major thoroughfare everyone in

the community uses– Connector street used by several neighborhoods

or entire community– Residential road used by a single neighborhood or

residents of street

LMI AREA BENEFIT

LMI AREA BENEFIT• LMI percentage can be determined by utilizing

Census Data (2000 – updated in 2007)– Generally easiest way to qualify a project– However, sometimes beneficiaries do not correspond with

Census Tracts or Block Groups i.e. project may benefit portions of 3 different Census Tracts

– Data is often out of date and/or doesn’t fully describe condition of area

• Population shifts, effects of economic crisis, etc.

• In instances when Census Data is not applicable, an Income Survey of the service area can be used– OHCP policy requires an adequate sample size and

random selection of households– Income Survey approved methodology and procedures

can be found at http://development.ohio.gov/cms/uploadedfiles/CDD/OHCP/OHCP08-03.pdf

LMI AREA BENEFIT

NATIONAL OBJECTIVE FILE GUIDELMI Area Wide Benefit Projects Qualified by Census

Community must include Census Map with project service area and affected block groups

Exhibit NO 1: Service Area Map Area Percentage LMI: Projects Qualified by Income Survey

Community must complete Income Survey as per OCD Policy 08-03

Exhibit NO 2a: Income Survey Summary Sheet Exhibit NO 2b: Individual Response Sheets Exhibit NO 2c: HUD Section 8 Income Limits

Calculated Percentage LMI:

• LMI Limited Clientele activities benefit special populations (senior citizens, homeless shelters, disabled adults)

• Activities must meet one of four requirements– Benefit to clientele who are presumed to be

principally LMI– Requires information that demonstrates 51% of

participants are LMI– Participation limited to LMI only– Nature and location indicate activity’s clientele will

primarily be LMI persons.

LMI LIMITED CLIENTELE

• Limited Clientele Groups Include:– Abused children;– Battered spouses;– Severely disabled adults;– Homeless persons;– Illiterate adults; – Migrant farm workers;– Elderly persons; – Persons living with AIDS; and – Programs with eligibility requirements that limit the benefits of an

activity to LMI persons.

LMI LIMITED CLIENTELE

• EXAMPLES:– ADA Compliance (elevators, curb cuts, ramps,

bathroom modifications)– Senior Centers– Meals on Wheels– Public Health Clinic– Literacy Education– Homeless or domestic violence shelters

LMI LIMITED CLIENTELE

NATIONAL OBJECTIVE FILE GUIDE

LMI Limited Clientele

Activity is designed for and used by persons who are presumed to be LMI

Lim. Clientele Class:

*If Limited Clientele designation requires income verification for eligibility, please provide documentation (Exhibit NO 4)

• Determination of LMI status is based on the Department of Housing and Urban Development Section 8 Annual Income (24 CFR Part 5) Limits

• LMI is 80% or less of Area Median Income:– 0-30% Extremely Low Income– 30-50% Very Low Income– 50-80% Low Income

• OCD is required to report beneficiaries from all 3 categories to HUD

LMI DIRECT BENEFIT

LMI Direct Benefit objective is divided into two categories •Housing

– Typically the Community Housing Improvement Program (CHIP) funds the majority of OCD’s housing projects

•Job Creation/Retention – Typically the CDBG Economic Development Program funds

the majority of OCD’s economic development projects

LMI DIRECT BENEFIT

• To qualify a Housing project using LMI Direct Benefit, structures must be occupied by LMI households

– Income documentation required from homeowner/household

• Typical activities include homeowner rehab, rental acquisition/rehab, emergency home repair, homebuyer assistance

• Starting in FY 2013, home repair is the only eligible housing activity for Community Development Program funding

LMI DIRECT BENEFIT

• Household connections for residential water and sanitary sewer projects are also qualified under the direct benefit national objective

• To qualify, the housing units must be occupied by LMI households

– Income documentation required from homeowners/households

LMI DIRECT BENEFIT

NATIONAL OBJECTIVE FILE GUIDE

LMI Direct Benefit          

  Community must income verify all households assisted with CDBG funds.

  Exhibit NO 3a: List of Assisted Households   Exhibit NO 3b: Income Verification Documentation

  Total LMI Households Assisted:  

• To qualify a project using LMI Direct Benefit Job Creation/Retention at least 51% of the jobs created and/or retained must be available to LMI persons– Income documentation is required from new

hires/retained employees

LMI DIRECT BENEFIT

NATIONAL OBJECTIVE FILE GUIDEEconomic Development         

Community must demonstrate that 51% of jobs created by companies assisted with CDBG funds are made available to LMI persons

            Name of Company Assisted:    Number of Jobs Created:   LMI Jobs:   Percentage of LMI Jobs:       

  Exhibit NO 6a: Job Creation Summary Certification    Exhibit NO 6b: Employee Job Benefit Verification Forms  

• Slum & Blight objective is divided into two categories – Area Basis; addressing conditions in an entire area– Spot Basis; addressing conditions with a single

structure or location• Regulations located at 24 CFR §§570.208(b)

SLUM & BLIGHT

• Area Basis– Activities are designed to address

dilapidated physical environment• Not based on income of residents• Selected activities must focus on conditions

contributing to the deterioration of the area;– Must be defined area & meet definition of

slum/blighted area under state/local law

SLUM & BLIGHT

• Area Basis: Must also meet either A or B – (A) The public improvements in the area are in a general state of

deterioration– (B) At least 51%* of the properties throughout the area experience

one or more of the following conditions• Physical deterioration of buildings or public improvements• Abandonment of properties• Chronic high occupancy turnover rates or vacancy rates in

commercial or industrial buildings• Significant decline in property values or abnormally low property

values relative to other areas in community• Known or suspected environmental contamination

SLUM & BLIGHT

• Typical Area Slum & Blight activities include; – Code enforcement – Commercial rehabilitation– Historic preservation– Infrastructure

SLUM & BLIGHT

• Spot Basis– Activities that address specific conditions of blight,

physical decay or environmental contamination not in slum & blight area

• EXAMPLE: Single Building

– Activities limited to: acquisition, clearance, relocation, historic preservation, remediation of environmentally contaminated properties, and building rehabilitation

SLUM & BLIGHT

• OCD’s Downtown Revitalization activities are funded under the Slum & Blight National Objective– Downtown Revitalization Program: Area Slum &

Blight– Discretionary: Area or Spot Slum & Blight

SLUM & BLIGHT

NATIONAL OBJECTIVE FILE GUIDE

Elimination of Slum/Blight

Community must complete building/infrastructure condition survey to demonstrate blighting conditions

Exhibit NO 5a: Building or Infrastructure Condition Survey Exhibit NO 5b: Slum/Blight Certification Percentage of Infrastructure/Buildings determined to be blighted

• OCD does not administer a program with urgent need as the national objective. – Projects can be funded by Discretionary Program– OHCP attempts to qualify projects with either LMI benefit

or Slum & Blight.• Typical activities include: infrastructure, interim

assistance, rehabilitation of community facilities etc.• EXAMPLE:

– Building destroyed by fire or natural disaster, but hazardous conditions, materials remain at site

URGENT NEED

• Used to address emergency situations• To meet the urgent need test:

– Existing conditions pose serious and immediate threat to health/welfare of community

– Existing conditions are recent (18 months) or recently became urgent

– Recipient cannot finance on its own– Other funding sources are not available

URGENT NEED

CDBG ELIGIBLE ACTIVITIES

• Variety of eligible activities, including: – Public facility activities– Public services– Planning and administration– Economic Development

• Regulations located at 24 CFR §570.201 - §570.206

CDBG ELIGIBLE ACTIVITIES

• Majority of Community Development (Allocation Program & Neighborhood Revitalization) Program dollars expended for:– Public Facility improvements– Public Service Activities*

* Neighborhood Revitalization funds cannot be used for public services

CDBG ELIGIBLE ACTIVITIES

• Public Facilities– Infrastructure

• Streets, sidewalks, water, sewer– Neighborhood Facilities

• Parks, playgrounds, community centers– Facilities for Special Needs Populations

• Homeless shelters, group homes

CDBG ELIGIBLE ACTIVITIES

• Maintenance and repair of public facilities– Exception: modification for ADA compliance

• Operating costs– Exception: costs related to CDBG public service

activity• Buildings for general conduct of government

– Exception: modification for ADA compliance• General government expenses i.e. trash pick-up or

equipment purchase• Political activities

INELIGIBLE ACTIVITIES

• Public Services– Employment

• Job Training

– Crime Prevention/Public Safety– Child Care

• LMI families

– Health• Health Services• Substance Abuse Services

CDBG ELIGIBLE ACTIVITIES

• Public Services – Housing

• Counseling• Energy Conservation• Downpayment Assistance• Services for homeless persons

– Education• Literacy• Tutoring for LMI children

CDBG ELIGIBLE ACTIVITIES

• Public Services – Welfare Services

• Self Sufficiency Programs

– Services for Seniors• Transportation

– Recreational Services• Boys & Girls Clubs

CDBG ELIGIBLE ACTIVITIES

• Public Service Costs– Labor, supplies, and materials directly related to

the provision of eligible services– CDBG may pay for operations and maintenance of

facility where service occurs• Cannot provide operational support to

nonprofits– Costs must be documented

CDBG ELIGIBLE ACTIVITIES

• Public Services Restrictions– The activity is capped at 15%– The service must be:

• A new service OR• A quantifiable increase in the level of an

existing service that has been provided by the grantee or another entity on its behalf with local government funding for 12 months prior to the request for funds

CDBG ELIGIBLE ACTIVITIES

• “Quantifiable Increase” restriction does not mean that a currently funded service organization needs to do more each year

• CDBG funds can be used for services previously supported by local government, ONLY in instances where the government no long has necessary funds. – Local governments cannot shift funds to new

activities and use CDBG to cover services

CDBG ELIGIBLE ACTIVITIES

• Public Services– Income payments (payments to households)– On-going operations as a stand alone public

service– Political activities– Religious activities

• Eligible services can be provided by religious entity if there is no discrimination or religious instruction required

INELIGIBLE ACTIVITIES

• National Objective • Citizen Participation• Fair Housing/Civil Rights• Environmental Review • Financial Management• Acquisition/Relocation• Procurement• Construction and Contract Management• Labor Standards• Grants Management System

FEDERAL/STATE REQUIREMENTS

CITIZEN PARTICIPATION

CITIZEN PARTICIPATION

• Why is Citizen Participation important?– It is required– It establishes and prioritizes the needs of the

residents and beneficiaries– It gives residents a community voice – It depoliticizes the process

• Regulations located at 24 CFR 570.486(a)(5) and 91.105(e)(1)

• Requires communities to establish a Citizen Participation Plan, which provides for Local Government requirements

– The plan should include methodologies to encourage the participation of LMI residents for which the CDBG program was designed to serve

CITIZEN PARTICIPATION

Citizen Participation File Guide

Community: Grant

Number:

General Information Notes:

Community must have a citizen participation plan updated within the last five years of program inception

Exhibit CP 1: Community Citizen Participation Plan Plan Last Updated:

Note: Subsequent plan updates do not have to be included retroactively

Solicitation of Projects

• Counties must solicit projects from local jurisdictions at least 30 days prior to application due date

• Counties must maintain documentation of solicitation and criteria/ranking for selecting projects

CITIZEN PARTICIPATION

Citizen Participation File Guide Counties must solicit projects from local jurisdictions at least 30 days prior to application

due date Applicable Not Applicable

Exhibit CP 3a: Proof of solicitation (e.g. letter) Date of Solicitation:

Exhibit CP 3b: Criteria for ranking/selecting projects

• Public Notices

• A minimum of 2 notices is required for participation in the CDBG Community Development Program– The second notice is required to be project specific

• Regulations located at 24 CFR 570.486

CITIZEN PARTICIPATION

• Public Hearing #1 Notification– Notice should be published in newspaper easily

accessible in the area (other options for notification)

– Notice should identify approximate Formula Allocation amount

– Notice should also list all CDBG, HOME, and OHTF programs for which the community may apply during given fiscal year

CITIZEN PARTICIPATION

• Public Hearing #1 – Notice should include a summary of Formula

Allocation program requirements– Notice should include national and state

objectives– Notice should include date local and state

applications are due– Notice must include date, time, and location of

Public Hearing #1 – Notice must be published at least 10 days prior to

Public Hearing #1

CITIZEN PARTICIPATION

• Public Hearing #1 Requirements– Community should maintain a copy of the notice in the

project file– Community should also maintain minutes of the hearing

and a list of attendees – Community should establish a Citizens’ Complaint File

• Community is required to respond to complaints thoroughly and within 15 days

– All documentation should be maintained in the project file

CITIZEN PARTICIPATION

CITIZEN PARTICIPATION FILE GUIDEFirst Public Hearing Date: Notice must be published at least 10 days prior to public hearing Notification method used: Newspaper Legal Ad Alternative Notification Method OCD 07-01 Exhibit CP 4a: Public Hearing Notice Date of Publication: Exhibit CP 4b: Verification of Publication (newspaper or alternative method)

Did public notice provide required information (e.g. allocation amount, programs)

Yes No Community must maintain public hearing documentation Exhibit CP 4c: Sign-in Sheets for First Public Hearing Exhibit CP 4d: Minutes for First Public Hearing

CITIZEN PARTICIPATION FILE GUIDE

Community must have a citizen complaint file that includes a copy of the Citizen Complaint Policy

Exhibit CP 2a: Citizen Complaint File Exhibit CP 2b: Citizen Complaint Policy Were any questions/complaints received for this grant: Yes No

If Yes, did the community respond within 15 days: Yes No

Exhibit CP 2c: Community must retain records of any citizen complaints

• Public Hearing #2 Notice– Same publication requirements– Notice should include proposed activities to be

undertaken– Notice should include amount and source of funds

(CDBG, HOME, etc.) allocated for each activity– Notice should include National Objective to be

met by each activity – Notice should include timetable of activities to be

undertaken

CITIZEN PARTICIPATION

• Public Hearing #2 Requirements– Same procedure as Public Hearing #1– Community should maintain

• A copy of the notice• Minutes of the hearing • A list of attendees• A Citizens’ Complaint File

– Documentation should be maintained in the project file

CITIZEN PARTICIPATION

CITIZEN PARTICIPATION FILE GUIDESecond Public Hearing Date: Notice must be published at least 10 days prior to public hearing Notification method used: Newspaper Legal Ad Alternative Notification Method OCD 07-01 Exhibit CP 5a: Public Hearing Notice Date of Publication:

Exhibit CP 5b: Verification of Publication (newspaper or alternative method)

Did notice include a list of selected projects with name, location, and anticipated amount

Yes No

Community must maintain public hearing documentation Exhibit CP 5c: Sign-in Sheets for Second Public Hearing Exhibit CP 5d: Minutes for Second Public Hearing

• To save time, communities should identify alternate Formula projects at the second public meeting

• This expedites the application process in the event the community is not awarded matching funds from one of OCD’s competitive programs and is required to select an alternate project

CITIZEN PARTICIPATION

• Special Public Hearings• Amendment Public Hearing

– If community amends a grant, another public hearing may be required

– EXAMPLE: Change of Activity• Project Specific Public Hearing

– A community can use Public Hearing #1 to meet program requirement for Economic Development, Residential Public Infrastructure or Community Housing Improvement Program

– Second Public Hearing must be project specific

CITIZEN PARTICIPATION

Citizen Participation File Guide

Citizen Participation File GuideAmendment Public Hearing Applicable Not Applicable Notice must be published at least 10 days prior to public hearing

Date of Hearing:

Notification method used:

Newspaper Legal Ad

Alternative Notification Method OCD 07-01

Exhibit CP 6a: Public Hearing Notice

Date of Publication:

Exhibit CP 6b: Verification of Publication (newspaper or alternative method)

Did notice include a description of the proposed amendment

Yes No

Community must maintain public hearing documentation Exhibit CP 6c: Sign-in Sheets for Amendment Public Hearing Exhibit CP 6d: Minutes for Amendment Public Hearing

• Revisions to Public Hearing requirements– Published newspaper notice– Post a notice in common areas of city hall/county courthouse– Post a notice in acquired cities, villages, and township halls

(investment areas)– Post a notice at other locations frequented by the public and/or

targeted population i.e. libraries, schools, senior center, community center

– Post a notice on local government’s website

CITIZEN PARTICIPATION

• Revisions to Public Hearing requirements– Community must provide verification that at least 3-5 of

the approved outreach outlets were used to notify the public of the public hearing

• Print out from website• Copy of notice• List of posted locations

– Communities are still required to give at least 10 days notice, maintain minutes & an attendance list for the hearing, and follow citizen complaint procedures

• All guidelines can be found in OCD Notice 07-01

CITIZEN PARTICIPATION

QUESTIONS?

CASE STUDIES

PASQUARIELLO COUNTY • Pasquariello County submitted an application to assist the

Johnstown Township Fire Department with the purchase of a fire truck and related equipment.

• Johnstown Township has a population of 400 residents, 62.5% (250) LMI.

• The Johnstown Township Fire Department also serves the Village of Davidsville and the unincorporated area of DJ. Davidsville has a population of 1000, 25% (250) LMI and DJ has a population of 100, 10% (10) LMI.

PASQUARIELLO COUNTY

Is the project eligible?

Does the project meet a national objective?

Will Pasquariello County be approved for funding for this project?

PASQUARIELLO COUNTY

Is the project eligible?

Activity Purpose: Public Facilities

Activity Name: Fire Protection Facilities and Equipment

PASQUARIELLO COUNTY

Does the project meet a national objective?

What is the service area?: Johnstown Township, Village of Davidsville, and the unincorporated area of DJ

Total population of 1500 residents (400 +1000 + 100)/510 (250 + 250 + 10) LMI = 34% LMI

PASQUARIELLO COUNTY

Will Pasquariello County be approved for funding for this project?

NO

GIFFINVILLE

• Giffinville has requested CDBG funds to purchase ADA playground equipment for Betsytown Park. Betsytown Park is a neighborhood park, which serves residents of 2 Census Tracts on the west side of Giffinville.

• Giffinville has a population of 18000. 11000 or 61.1% of the population is LMI.

GIFFINVILLE• Giffinville includes the following Census Tracts:

– CT 1 (North Side): Population 5000/4000 LMI (80%)– CT 2 (East Side): Population 2000/1500 LMI (75%)– CT 3 (South Side): Population 3000/2000 LMI (66.7%)– CT 4 (West Side): Population 4000/2000 LMI (50%)– CT 5 (West Side): Population 4000/1500 LMI (37.5%)

GIFFINVILLE

Is the project eligible?

Does the project meet a national objective?

Will Giffinville be approved for funding for this project?

GIFFINVILLE

Is the project eligible?

Activity Purpose: Public Facilities

Activity Name: Parks and Recreation Facilities

GIFFINVILLE

Does the project meet a national objective?

Who will benefit?: Giffinville - West Side

Project does not meet the area wide LMI benefit national objective

Project does not meet the Limited Clientele national objective because disabled children is not one of the automatic categories

GIFFINVILLE

Will Giffinville be approved for funding for this project?

NO

MICHAELTON

• Michaelton has applied for CDBG funding for the purchase of 16 garbage trucks for city-wide refuse collection

• Michaelton has a population of 6000. 4500 (75%) residents are LMI

MICHAELTONIs the project eligible?

Does the project meet a national objective?

Will Michaelton be approved for funding for this project?

MICHAELTON

Is the project eligible?

General Conduct of Government

NO

LEASUREVILLE • Leasureville has a population of 5001. 2000 (39.9%) of the

residents are LMI.

• Leasureville has submitted an application for CDBG assistance with a Wastewater Treatment Plant improvement project.

• The Wastewater Treatment Plant will serve the entire city.

• The Wastewater Treatment Plant is located in 1 of the city’s 4 Census Tracts. The Census Tract is 58% LMI.

LEASUREVILLE Is the project eligible?

Does the project meet a national objective?

Will Leasureville be approved for funding for this project?

LEASUREVILLE

Is the project eligible?

Activity Purpose: Public Facilities

Activity Name: Water and Sanitary Sewer Improvements

LEASUREVILLE Does the project meet a national objective?

Who will benefit?: Leasureville

Project does not meet the area wide LMI benefit national objective because the city is not at least 51% LMI

The project cannot be qualified based on the 1 LMI Census Tract because the Wastewater Treatment Plant serves the entire city

LEASUREVILLE Will Leasureville be approved for funding for this project?

NO

NORTH NORTONSBURG

North Nortonsburg has a population of 6000, 3000 (50%) LMI.

The city is comprised of 2 Census Tracts:– CT 1: 4000/1900 (47.5% LMI)– CT 2: 2000/1100 (55% LMI)

North Nortonsburg has applied for CDBG assistance for 2 separate park improvement projects

NORTH NORTONSBURG• Project 1: Construction of a baseball field and modification of

an existing restroom facility for ADA accessibility at Smith Park.

• Project 2: Purchase and installation of park benches and picnic tables and construction of a restroom facility at Michael Park.

• Smith Park serves the entire city and provides amenities not found at other parks in the city.

• Michael Park is a neighborhood Park that only serves Census Tract 2 (55% LMI)

NORTH NORTONSBURG

Are the projects eligible?

Activity Purpose: Public Facilities

Activity Name: Park and Recreation Facilities

NORTH NORTONSBURG Do the projects meet a national objective?Project 1Who will benefit?: Entire city

Project does not meet the area wide LMI benefit national objective because the city is not at least 51% LMI

However, restroom modification activity can be completed under Limited Clientele national objective

NORTH NORTONSBURG Do the projects meet a national objective?

Project 2Who will benefit?: Census Tract 2

Project meets the LMI area wide benefit national objective. Therefore, all of the proposed improvements are eligible.

YES

MARYTOWN Marytown submitted an application for funding for ADA

accessible curb cuts and sidewalk improvements. Marytown proposes to complete 20 ADA curb cuts and 12,000 linear feet of sidewalk improvements. The improvements will be made city-wide.

The application lists the national objective as LMI – Limited Clientele

Marytown has a population of 9,500. Marytown is 42% LMI by Census

MARYTOWN

Is the project eligible?

Does the project meet a national objective?

Will Marytown be approved for funding for this project?

MARYTOWN

Is the project eligible?

Activity Purpose: Public Facilities

Activity Name: Sidewalk Improvements

MARYTOWN

Does the project meet a national objective?

Who will benefit?: Marytown

Activities are not limited to Limited Clientele activities that will benefit eligible Limited Clientele groups

ADA curb cuts would meet a national objective, but the sidewalk improvements would not

MARYTOWN

Will Marytown be approved for funding for this project?

NO

Marytown would be asked to restructure the project to only complete ADA improvement projects to benefit the Limited Clientele population

QUESTIONS?