Community Development Block Grant

1. Community Development Block Grant Application Workshop March 31, 2014

2. CDBG - Agenda at a Glance • Welcome & Introductions • Program Design Changes • Overview – Eligibility and National Objective • CDBG Application Tips • Other Issues • “Flagged” Activities, Preagreement, Fair Housing, Environmental, Drawdown • PY’14 Application MT

3. CDBG – PY’14 Application • PY’2014 Allocation: $4,924,053 • Final amount available changes based on any recaptured or deobligated funds • Deadline, 12:00 p.m – Friday, June 27, 2014th • In hands of OHCD staff by the deadline • (not postmarked) • 1 original and 1 electronic (required)

4. CDBG – PY’14 Application • Drawdown Threshold. Previous years’ grants must have been drawn down as follows: • 50% of Program Year 2012 • 75% of PY’11 & PY’10 • 90% of PY’09 • 100% of PY’08 and earlier • PY’08 and prior year funds will be deobligatedfor redistribution in current cycle. Communities can reapply. • State cannot grant exemption from the Drawdown Threshold for the same grant year in consecutive years. • Options – Deobligation(with or without reapplication), Do not apply in current year, Reallocate (if possible) MT

5. CDBG – PY’14 Application • Application Caps • $150,000, $250,000 & $350,000 • Potential impact on “Administration” • Original (PY’13) Cap reductions consistent with State program reductions. • Actions taken to minimize impact of reductions (recapture) • Multiple ways to apply (setasides) • Activities above cap • Housing Development & Economic Development (Jobs) • NOT – Rehabilitation Programs (residential/commercial) MT

6. Program Design Changes • Setasides • Affordable Housing Program (25%) • Homelessness (10%) • Residential Rehabilitation - $300,000 • ALL activities, including those which qualify for set-aside consideration, still eligible under annual competitive application cycle • Consistent with previous distributions for categories • Meant to encourage applications in these areas while reducing administrative burden on municipalities • Encourage coordination of resources and timely distribution of funds

7. CDBG – PY’14 Application • $300,000 Residential Rehabilitation Supplemental Fund • Communities will receive base allocation based upon need and past performance. • Additional funds available for fully-obligated/expended residential rehabilitation programs with additional need. • Unobligated prior year funds distributed as part of current cycle.

8. CDBG – PY’14 Application • $300,000 Residential Rehabilitation Supplemental Fund (Continued) • Procedure: Ongoing - Grant awards increased on a case-by-case basis (site specific) based upon cost estimates for projects ready-to-go. Most recent contract amended for increase. • May use funds for Lead Hazard Reduction and Mobile Home Replacement efforts. • Ensures continuity of programs. MT

9. Homelessness Setaside (10%) • Coordinated with State Consolidated Homeless Fund (CHF) RFP • Primarily 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 consideration • Procedure: • Shelter/Service provider applies directly to CHF; • OHCD forwards application and Form to municipality for consideration; • Municipality completes Form (comment - assumption) and returns to OHCD; • If form not returned, not considered for ESG or CDBG funding; • Public Notification – Local (general) and State (specific). MT

10. Program Design Changes • Affordable 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, 2014 • Procedures – 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) • Environmental • Labor Standards (if applicable) • Contracting MT

11. Program 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 MT

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13. CDBG – PY’14 Application • 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 MT

14. 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.) MT

15. CDBG – PY ’14 Application • Low/Moderate Income – Area Benefit • Survey • HUD Low/Moderate Income Summary Data Tables (LMISD) (Census tracts and block groups) • Changes anticipated but timing uncertain • Application forms match HUD • Technical Assistance funds available for surveys MT

16. CDBG Administration • HUD LMI Summary Data • Update expected as early as July 2014 • Presumption - Awards that have been formally announced are grandfathered. • Activities in application status (prior to “official” award) will be required to update using new data. • Regulations/guidance pending MT

17. CDBG Application Tips • National ObjectiveCommon Errors • Area Benefit and Limited Clientele are mutually exclusive! Don’t select both. • If activity serves an entire area which qualifies as LMI, it’s Area Benefit (example: neighborhood parks, sidewalks) • If activity serves a limited number of people or target population, it’s limited clientele (example: boys/girls club, food pantry, senior center) MT

18. CDBG Application Tips • If using census-delineated areas, use HUD’s LMI Summary Data Tables. Other data sources are not acceptable. • For limited clientele, organizations must collect data for persons benefitting (person is member of LMI family) and provide this in the application. Actual, not assumed. • If subgrantee completes this portion of an application, PLEASE REVIEW/EDIT to address any issues. MT

19. CDBG Application Tips • Be Well Organized – Make life easier for the review committee! • Organize in order by priority • Tabs for each activity, labeled if possible (even post-its are ok) • Be sure all referenced attachments are actually attached! • Use the correct form – Res. Rehab form should only be used for programs. Other residential rehab. Should use “projects” form • DON’T OMIT ABSTRACTS! These are provided to the Committee. JH

20. CDBG Application Tips • Make sure cover sheet summary agrees with individual activity budgets • Source/Use of Funds: If multiple funding sources, specify which part of project is to be paid for with CDBG • Be sure to indicate whether other funds are in place, application pending, etc. • Supporting Documentation is Crucial. Sufficient detail so it is clear that all likely costs have been considered. • Construction Cost estimates should include language indicating that Davis Bacon wages have been taken into account (if applicable) • Unspent funds for same activity in previous year(s) reduces liklihood of funding JH

21. CDBG Application Tips • Assistance to nonprofits • CDBG requests to assist in general operating costs is not as competitive as funds having a closer connection to the LMI recipient • Example: funding to purchase food for pantry (not for overhead costs) • If nonprofit writes their abstract, review/edit to be sure it contains key information on use of funds, not solely mission statement or history of agency. JH

22. CDBG Application Tips Limit Subrecipient Involvement in application preparation. Edit abstracts It is Towns’ responsibility to notify RIHPHC and Narragansett Tribe Maintenance of Effort: CDBG cannot supplant state or local government funding Digital copy of materials should be in format requested JH

23. CDBG Application Tips • RIHPHC Threshold Letter • Letter to be written by muincipality, not subrecipient applicants • Provide detailed project description so that SHPO can make accurate determination regarding need for further review • SHPO sends Programmatic Agreement & letter indicating which activities s/he will want to review. A copy goes into the ERR. • HUD Guidance: activities found to “have no adverse affect” cannot convert to exempt during the ER process JH

24. CDBG Administration • “Flagged” activities • Increased Reliance on Reporting/Timeliness • 2013 Activities include conditions expediting progress/drawdowns • Remediation Plans require timelines and benchmarks with achieveable outcome(s) within 6 months of plan submittal • Program Income • Additional HUD reporting • Spend down JH/PW

25. CDBG- PY ‘14 Application • Preagreement • Be sure to indicate on Cover Sheets if preagreement is requested • Preagreement may be requested at any time during the year, not just during the application period • Request must clearly prove that immediate approval of funding is necessary • Approvals may be conditioned upon receiving other funding for a project JH

26. CDBG • Fair Housing • For each grant year, a community must engage in at least one activity to affirmatively further fair housing. • For each grant, the first QPR should include a statement indicating what will be done in that grant year to meet the requirement. • Starting in PY’14 – Application requires details of fair housing activity undertaken in previous year JH

27. CDBG – PY ’14 Application • Environmental Review • Choice Limiting Actions • Obligating funds (CDBG/otherwise) prior to completion of environmental review process may require we eliminate activity from consideration. • CDBG cannot reimburse a cost already incurred prior to application. • NEW HUD Guidance: Purchase/ Sale Agreement executed prior to application submittal date is NOT a choice-limiting action. JH

28. CDBG • New Drawdown Procedure • Several towns drawing funds significantly in advance of need, resulting in funds returned to State • New drawdown process will require backup documentation to prove expenses have been incurred (eg. invoices from vendors) • Form currently in development JH

29. Considerations/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 MT

30. CDBG • Questions & Answers • Limitation on conversations once RFP issued. • Q&As forwarded via email to PheamoWitcher and responses posted periodically. • All forms available starting 4/4 at: www.planning.ri.gov/community/development/blockgrants MT

31. CDBG Contacts June House – 222-2079 Charles Kimes – 222-6489 PheamoWitcher – 222-4494 Laura Sullivan – 222-5817 Michael Tondra – 222-7901 (Dawn Vittorioso) MT