Community Development Block Grant

Community Development Block GrantCommunity Development Block Grant

Application WorkshopApplication Workshop

March 31, 2014March 31, 2014

CDBG - Agenda at a GlanceCDBG - Agenda at a Glance Welcome & IntroductionsWelcome & Introductions Program Design ChangesProgram Design Changes Overview – Eligibility and Overview – Eligibility and

National ObjectiveNational Objective CDBG Application TipsCDBG Application Tips Other IssuesOther Issues

““Flagged” Activities, Preagreement, Fair Housing, Flagged” Activities, Preagreement, Fair Housing, Environmental, DrawdownEnvironmental, Drawdown

PY’14 ApplicationPY’14 Application

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CDBG – PY’14 ApplicationCDBG – PY’14 Application

PY’2014 Allocation: $4,924,053PY’2014 Allocation: $4,924,053 Final amount available changes based Final amount available changes based

on any recaptured or deobligated fundson any recaptured or deobligated funds

Deadline, Deadline, 12:00 p.m12:00 p.m – – Friday, June 27, 2014Friday, June 27, 2014thth

In hands of OHCD staff by the deadline In hands of OHCD staff by the deadline ((notnot postmarked) postmarked)

1 original and 1 electronic (required)1 original and 1 electronic (required)

CDBG – PY’14 ApplicationCDBG – PY’14 Application Drawdown Threshold. Previous years’ grants must Drawdown Threshold. Previous years’ grants must

have been drawn down as follows:have been drawn down as follows: 50% of Program Year 2012 50% of Program Year 2012 75% of PY’11 & PY’1075% of PY’11 & PY’10 90% of PY’0990% of PY’09 100% of PY’08 and earlier100% of PY’08 and earlier PY’08 and prior year funds PY’08 and prior year funds will be deobligated will be deobligated for for

redistribution in current cycle. Communities can redistribution in current cycle. Communities can reapply.reapply.

State cannot grant exemption from the Drawdown State cannot grant exemption from the Drawdown Threshold for the same grant year in consecutive Threshold for the same grant year in consecutive years.years.

Options – Deobligation (with or without Options – Deobligation (with or without reapplication), Do not apply in current year, reapplication), Do not apply in current year, Reallocate (if possible)Reallocate (if possible)

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CDBG – PY’14 ApplicationCDBG – PY’14 Application Application CapsApplication Caps

$150,000, $250,000 & $350,000$150,000, $250,000 & $350,000 Potential impact on “Administration”Potential impact on “Administration” Original (PY’13) Cap reductions Original (PY’13) Cap reductions

consistent with State program reductions.consistent with State program reductions. Actions taken to minimize impact of Actions taken to minimize impact of

reductions (recapture)reductions (recapture) Multiple ways to apply (setasides)Multiple ways to apply (setasides)

Activities above capActivities above cap Housing Housing DevelopmentDevelopment & Economic & Economic

Development (Development (JobsJobs)) NOT – Rehabilitation Programs NOT – Rehabilitation Programs

(residential/commercial)(residential/commercial)

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Program Design ChangesProgram Design Changes

SetasidesSetasides Affordable Housing Program (25%)Affordable Housing Program (25%) Homelessness (10%)Homelessness (10%) Residential Rehabilitation - $300,000Residential Rehabilitation - $300,000

ALL activities, including those which qualify ALL activities, including those which qualify for set-aside consideration, still eligible for set-aside consideration, still eligible under annual competitive application cycleunder annual competitive application cycle

Consistent with previous distributions for Consistent with previous distributions for categoriescategories

Meant to encourage applications in these Meant to encourage applications in these areas while reducing administrative burden areas while reducing administrative burden on municipalitieson municipalities

Encourage coordination of resources and Encourage coordination of resources and timely distribution of fundstimely distribution of funds


$300,000 Residential Rehabilitation $300,000 Residential Rehabilitation Supplemental FundSupplemental Fund

Communities will receive base allocation Communities will receive base allocation based upon need and past performance.based upon need and past performance.

Additional funds available for fully-Additional funds available for fully-obligated/expended residential obligated/expended residential rehabilitation programs with additional rehabilitation programs with additional need.need.

Unobligated prior year funds distributed Unobligated prior year funds distributed as part of current cycle. as part of current cycle.


$300,000 Residential Rehabilitation $300,000 Residential Rehabilitation Supplemental Fund (Continued)Supplemental Fund (Continued)

Procedure: Ongoing - Grant awards Procedure: Ongoing - Grant awards increased on a case-by-case basis (site increased on a case-by-case basis (site specific) based upon cost estimates for specific) based upon cost estimates for projects ready-to-go. Most recent projects ready-to-go. Most recent contract amended for increase. contract amended for increase.

May use funds for Lead Hazard May use funds for Lead Hazard Reduction and Mobile Home Reduction and Mobile Home Replacement efforts.Replacement efforts.

Ensures continuity of programs.Ensures continuity of programs.

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Homelessness Setaside (10%)Coordinated with State Consolidated Homeless Fund (CHF) RFPPrimarily supports shelter operations and service programs. Rental Assistance also available. Limited rehabilitation possible.Emergency Solutions Grant (ESG) regulations require local “approval” of application.Review/Assumption Form necessary for ESG and/or CDBG considerationProcedure:

1. Shelter/Service provider applies directly to CHF;

2. OHCD forwards application and Form to municipality for consideration;

3. Municipality completes Form (comment - assumption) and returns to OHCD;

4. If form not returned, not considered for ESG or CDBG funding;

5. Public Notification – Local (general) and State (specific). MTMT

Program Design ChangesProgram Design ChangesAffordable Housing Setaside (25%)Coordinated with State Building Homes RI (BHRI)/Affordable Housing Partnership RFP – capital funding for affordable housing dev’t.Spring, 2014 and Fall, 2014Procedures – Similar to Homelessness Setaside (only applies to CDBG)Review/Assumption Form

Entities for local review Comment but not accept responsibilities Agree to accept responsibilities

(and associated administration award)o Environmentalo Labor Standards (if applicable)o Contracting MTMT

Program Design ChangesProgram Design Changes Economic Development

Priority category for State CDBG funding Proposed use of existing provision(s) of

State CDBG Program (Preagreement) Local acceptance of Economic

Development proposals (assistance to for-profit entities for job creation) - ongoing

Consultation with State OHCD/CDBG Staff to assure program requirements met (underwriting, public benefit, national obj)

Once finalized, submit request for CDBG “pre-agreement” consideration

State may commit future CDBG funding and permit current “obligation” of funds. Subsequent formal application would detail activity.

Environmental Review MTMT

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CDBG National Objectives Benefitting persons of LMI Income Elimination of slums/blight Urgent need

In order to be fundable, an activity MUST meet Eligibility AND National Objective requirements.

Documentation must be maintained Failure to meet National Objective

will result in de-obligation or recapture of funds

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CDBG – PY ’14 Application

Primary Objective for the Small Cities Program: Benefit to low- and moderate- income persons Area Benefit Limited Clientele Housing Jobs

Preventing or eliminating blight (area or spot basis)

Urgent Need. (not generally applicable to “regular” CDBG, applies to immediate threat to public health or welfare.)

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CDBG – PY ’14 ApplicationCDBG – PY ’14 Application

Low/Moderate Income – Area Low/Moderate Income – Area BenefitBenefit SurveySurvey HUD Low/Moderate Income Summary HUD Low/Moderate Income Summary

Data Tables (LMISD) (Census tracts Data Tables (LMISD) (Census tracts and block groups)and block groups)

Changes anticipated but timing uncertainChanges anticipated but timing uncertain Application forms match HUDApplication forms match HUD Technical Assistance funds available for Technical Assistance funds available for

surveyssurveys

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CDBG AdministrationCDBG Administration

HUD LMI Summary DataHUD LMI Summary Data Update expected as early as July Update expected as early as July

20142014 Presumption - Awards that have Presumption - Awards that have

been formally announced are been formally announced are grandfathered. grandfathered.

Activities in application status (prior Activities in application status (prior to “official” award) will be required to to “official” award) will be required to update using new data.update using new data.

Regulations/guidance pendingRegulations/guidance pending

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CDBG Application TipsCDBG Application Tips

National ObjectiveNational ObjectiveCommon ErrorsCommon Errors

Area Benefit and Limited Clientele are Area Benefit and Limited Clientele are mutually exclusivemutually exclusive! Don’t select both.! Don’t select both.

If activity serves an entire area which If activity serves an entire area which qualifies as LMI, it’s Area Benefit qualifies as LMI, it’s Area Benefit (example: neighborhood parks, (example: neighborhood parks, sidewalks)sidewalks)

If activity serves a limited number of If activity serves a limited number of people or target population, it’s limited people or target population, it’s limited clientele (example: boys/girls club, clientele (example: boys/girls club, food pantry, senior center)food pantry, senior center)

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If using census-delineated areas, use If using census-delineated areas, use HUD’s LMI Summary Data Tables. HUD’s LMI Summary Data Tables. Other data sources are not acceptable.Other data sources are not acceptable.

For limited clientele, organizations must For limited clientele, organizations must collect data for persons benefitting collect data for persons benefitting (person is member of LMI family) and (person is member of LMI family) and provide this in the application. Actual, provide this in the application. Actual, not assumed.not assumed.

If subgrantee completes this portion of If subgrantee completes this portion of an application, PLEASE REVIEW/EDIT an application, PLEASE REVIEW/EDIT to address any issues.to address any issues.

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CDBG Application Tips CDBG Application Tips Be Well Organized – Make life easier for Be Well Organized – Make life easier for

the review committee!the review committee! Organize in order by priorityOrganize in order by priority Tabs for each activity, labeled if possible Tabs for each activity, labeled if possible

(even post-its are ok)(even post-its are ok) Be sure all referenced attachments are Be sure all referenced attachments are

actually attached!actually attached! Use the correct form – Res. Rehab form Use the correct form – Res. Rehab form

should only be used for programs. Other should only be used for programs. Other residential rehab. Should use “projects” residential rehab. Should use “projects” formform

DON’T OMIT ABSTRACTS! These are DON’T OMIT ABSTRACTS! These are provided to the Committee.provided to the Committee.

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CDBG Application Tips CDBG Application Tips

Make sure cover sheet summary agrees with Make sure cover sheet summary agrees with individual activity budgetsindividual activity budgets

Source/Use of Funds: If multiple funding Source/Use of Funds: If multiple funding sources, specify which part of project is to be sources, specify which part of project is to be paid for with CDBGpaid for with CDBG

Be sure to indicate whether other funds are Be sure to indicate whether other funds are in place, application pending, etc.in place, application pending, etc.

Supporting Documentation is Crucial. Supporting Documentation is Crucial. Sufficient detail so it is clear that all likely Sufficient detail so it is clear that all likely costs have been considered.costs have been considered.

Construction Cost estimates should include Construction Cost estimates should include language indicating that Davis Bacon wages language indicating that Davis Bacon wages have been taken into account (if applicable)have been taken into account (if applicable)

Unspent funds for same activity in previous Unspent funds for same activity in previous year(s) reduces liklihood of fundingyear(s) reduces liklihood of funding

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Assistance to nonprofitsAssistance to nonprofits CDBG requests to assist in general CDBG requests to assist in general

operating costs is not as competitive as operating costs is not as competitive as funds having a closer connection to the funds having a closer connection to the LMI recipientLMI recipient

Example: funding to purchase food for Example: funding to purchase food for pantry (not for overhead costs)pantry (not for overhead costs)

If nonprofit writes their abstract, If nonprofit writes their abstract, review/edit to be sure it contains key review/edit to be sure it contains key information on use of funds, not information on use of funds, not solely mission statement or history of solely mission statement or history of agency.agency.

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Limit Subrecipient Involvement in Limit Subrecipient Involvement in application preparation. application preparation. Edit abstractsEdit abstracts It is Towns’ responsibility to notify It is Towns’ responsibility to notify

RIHPHC and Narragansett TribeRIHPHC and Narragansett Tribe Maintenance of Effort: CDBG Maintenance of Effort: CDBG

cannot supplant state or local cannot supplant state or local government fundinggovernment funding

Digital copy of materials should be Digital copy of materials should be in format requested in format requested

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RIHPHC Threshold Letter RIHPHC Threshold Letter Letter to be written by muincipality, not Letter to be written by muincipality, not

subrecipient applicantssubrecipient applicants Provide detailed project description so that Provide detailed project description so that

SHPO can make accurate determination SHPO can make accurate determination regarding need for further reviewregarding need for further review

SHPO sends Programmatic Agreement & letter SHPO sends Programmatic Agreement & letter indicating which activities s/he will want to indicating which activities s/he will want to review. A copy goes into the ERR.review. A copy goes into the ERR.

HUD Guidance: activities found to “have no HUD Guidance: activities found to “have no adverse affect” cannot convert to exempt during adverse affect” cannot convert to exempt during the ER processthe ER process

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CDBG AdministrationCDBG Administration

““Flagged” activitiesFlagged” activities Increased Reliance on Increased Reliance on

Reporting/TimelinessReporting/Timeliness 2013 Activities include conditions 2013 Activities include conditions

expediting progress/drawdownsexpediting progress/drawdowns Remediation Plans require timelines and Remediation Plans require timelines and

benchmarks with achieveable outcome(s) benchmarks with achieveable outcome(s) within 6 months of plan submittalwithin 6 months of plan submittal

Program IncomeProgram Income Additional HUD reporting Additional HUD reporting Spend downSpend down

JH/PWJH/PW

CDBG- PY ‘14 ApplicationCDBG- PY ‘14 Application

PreagreementPreagreement Be sure to indicate on Cover Sheets if Be sure to indicate on Cover Sheets if

preagreement is requestedpreagreement is requested Preagreement may be requested at any time Preagreement may be requested at any time

during the year, not just during the application during the year, not just during the application periodperiod

Request must clearly prove that immediate Request must clearly prove that immediate approval of funding is necessaryapproval of funding is necessary

Approvals may be conditioned upon receiving Approvals may be conditioned upon receiving other funding for a projectother funding for a project

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CDBGCDBG

Fair HousingFair Housing For each grant year, a community must For each grant year, a community must

engage in at least one activity to engage in at least one activity to affirmatively further fair housing.affirmatively further fair housing.

For each grant, the first QPR should For each grant, the first QPR should include a statement indicating what will include a statement indicating what will be done in that grant year to meet the be done in that grant year to meet the requirement.requirement.

Starting in PY’14 – Application requires Starting in PY’14 – Application requires details of fair housing activity details of fair housing activity undertaken in previous yearundertaken in previous year

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CDBG – PY ’14 ApplicationCDBG – PY ’14 Application

Environmental ReviewEnvironmental Review Choice Limiting ActionsChoice Limiting Actions Obligating funds (CDBG/otherwise) prior Obligating funds (CDBG/otherwise) prior

to completion of environmental review to completion of environmental review process may require we eliminate activity process may require we eliminate activity from consideration.from consideration.

CDBG cannot reimburse a cost already CDBG cannot reimburse a cost already incurred prior to application.incurred prior to application.

NEW HUD Guidance:NEW HUD Guidance: Purchase/ Sale Purchase/ Sale Agreement executed prior to application Agreement executed prior to application submittal date is NOT a choice-limiting submittal date is NOT a choice-limiting action.action.

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CDBGCDBG New Drawdown ProcedureNew Drawdown Procedure

Several towns drawing funds Several towns drawing funds significantly in advance of need, significantly in advance of need, resulting in funds returned to Stateresulting in funds returned to State

New drawdown process will require New drawdown process will require backup documentation to prove backup documentation to prove expenses have been incurred (eg. expenses have been incurred (eg. invoices from vendors)invoices from vendors)

Form currently in developmentForm currently in development

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Considerations/UpdatesConsiderations/Updates

Recipient Review – Charles Kimes New Monitoring Procedures New Staff

CDBG, Disaster Recovery – Laura Sullivan (Incremental) Action Plan Submitted LMI (Sandy/Irene/Nemo – Statewide) Solicited

Program Oversight – Pheamo Witcher

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CDBGCDBG

Questions & AnswersQuestions & Answers Limitation on conversations once Limitation on conversations once

RFP issued. RFP issued. Q&As forwarded via email to Q&As forwarded via email to

Pheamo Witcher and responses Pheamo Witcher and responses posted periodically.posted periodically.

All forms available starting 4/4 at:All forms available starting 4/4 at:

www.planning.ri.gov/community/development/blockgrantswww.planning.ri.gov/community/development/blockgrants

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CDBGCDBG

ContactsContactsJune House – 222-2079June House – 222-2079

Charles Kimes – 222-6489Charles Kimes – 222-6489Pheamo Witcher – 222-4494Pheamo Witcher – 222-4494Laura Sullivan – 222-5817Laura Sullivan – 222-5817

Michael Tondra – 222-7901 (Dawn Michael Tondra – 222-7901 (Dawn Vittorioso)Vittorioso)

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Documents

Community Development Block Grant