TxCDBG Community Development Fund and Planning Fund Application Workshop PROGRAM YEARS (PY) 2013-2014
Application Deadline October 26, 2012 5:00 PM
Agenda • CDBG Overview • Significant Changes • Application Illustration • Documenting a National Objective • Planning • Questions and Answers
TxCDBG Primary Objective • Development of viable communities, principally for low/mod persons, through: • Decent housing • Suitable living environment • Expanded economic opportunity
Can I really do this project? • Is the applicant eligible? • Is the activity eligible? • Will it meet a national objective? • Will it help to meet the low/mod income targeting requirements?
Eligible Applicants • Non-entitlement cities - populations less than 50,000 thousand persons; • Cities that are not designated as a central city of a metropolitan statistical area; or • Cities that are not participating in urban county programs. • Non-entitlement counties generally have fewer than 200,000 persons in the non-entitlement cities and unincorporated areas located in the county.
BENEFICIARY IDENTIFICATION METHODS • Low-and-Moderate Income Summary Data • Race and Ethnicity Data (TXMA05) • Gender Data (American FactFinder - SF1 P12) • TxCDBG Survey • Types: • Census • Simple Random Sample
Eligible Activities • Housing & other real property activities • Economic development (TDA) • Public facilities • Public services • Planning and administration • Others Regulation cites CFR 24 §570.201 - §570.206, §570.482
Eligible Activities w Acquisition w Activities carried out through w Public facilities & privately owned Nonprofit Development organizations utilities w Economic development w Clearance, rehabilitation, w Activities under 105(a)(14), (15) and reconstruction, construction (17) w Architectural barrier removal w Technical assistance w Loss of rental income w Housing services w Disposition of real property w Assistance to institutions of higher w Public services learning w Payment of non - federal share w Microenterprise assistance w Relocation w In - rem housing w Planning and capacity building w Homeownership w Tornado shelters w Program administrative costs
Ineligible Activities • Regulations expressly prohibit: • Buildings for conduct of government & general government expenses • Political activities • New housing construction (exceptions for CBDOs and Entitlements) • Income payments • Purchase of equipment • Operating and maintenance expenses
National Objectives • Activities Benefiting Low-and-Moderate Income Persons • Low-and-Moderate Income Area Benefit – (LMA) • Low-and-Moderate Income Limited Clientele – (LMC) • Low-and-Moderate Income Housing – (LMH) • Low-and-Moderate Income Job Creation and Retention – (LMJ) • Prevention / Elimination of Slums or Blight • Addressing Slums or Blight on an Area Basis - (SBA) • Addressing Slums or Blight on a Spot Basis - (SBS) • Urgent Need • Meet other community development needs of particular urgency that represent an immediate threat to the health and safety of residents of the community. – (URG)
LMI Area Benefit (LMA) • Activities that benefit all residents of an area • 51% LMI persons • Area must be primarily residential • Must determine service area of activity (CGA) • Beneficiary Identification Methods include LMISD and TxCDBG Surveys. • Typical activities: water/sewer, parks, community centers, roads
LMI Housing (LMH) • To meet the housing national objective, structures must be occupied by low/mod households • One unit structures occupied by LMI persons • One unit of duplex occupied by LMI persons • 51% of 3+ units occupied by LMI persons • Aggregation allowed in some instances • This is the only L/M national objective for housing activities • Typical activities: homeowner unit rehab, rental acquisition and rehab, homebuyer assistance
LMI Job (LMJ) • In order to meet this criteria, activities must createorretain permanent jobs AND • 51% of the jobs created/retained must be available toorheld by LMI persons • Jobs counted on full time equivalent (FTE) basis • Typical activities: business loans, commercial rehabilitation, infrastructure to a business
Slum and Blight – Area Basis (SBA) Area must meet definition of slum/blighted area under state/local law AND Meet either A) or B) below: A) At least 25% of properties throughout the area experience 1 or more of the following: Physical deterioration of buildings or improvements Abandonment of properties; Chronic high occupancy turnover rates or chronic high vacancy rates in commercial/industrial buildings; Significant declines in property values or abnormally low property values relative to other areas in community; or Known or suspected environmental contamination. B) The public improvements in the area are in a general state of deterioration Typical activities: code enforcement, infrastructure, commercial rehabilitation
Slum and Blight – Spot Basis (SBS) • Activities that address specific conditions of blight, physical decay or environmental contamination not in slum/blight area • Activities limited: acquisition, clearance, relocation, historic preservation, remediation of environmentally contaminated properties, or building rehabilitation • Acquisition & relocation must be precursor to another eligible activity that addresses slum/blighted conditions • Rehab limited to elimination of conditions detrimental to public health & safety
Urgent Need (Disaster Relief) (URG) • To meet the urgent need test: • Existing conditions pose serious & immediate threat to health/welfare of community • Existing conditions are recent or recently became urgent • Discovered and reported to TxCDBG within 30 days or Urgent Need • Must notify TxCDBG within 12 months from the date of the declaration Disaster Relief • Recipient cannot finance on its own • Other funding sources not available • Typical activities: infrastructure, interim assistance, rehab of community facilities
Citizen Participation • Published 72 hours prior to hearing • Weekdays – after 5:00 pm • Weekend – convenient time • Interpreter if needed • Publish 5 days prior to submitting application • Identify TxCDBG fund category • Amount of TxCDBG funds requested • Short description of proposed project • Location(s) of the project activities • Location and hours when the application will be available for public review
Significant Changes • Page 1 – Application deadline: October 26, 2012 • submit electronically • Page 5 – Clarification on Operation and Maintenance expenses. Do not include it in the application. • Page 8 – For on-site sewage facilities, applicants must provide a waiting list of homeowners to indicate need and justify budget • Page 12 – Added Faith-based Organizations to the list of local service providers under Citizen Participation
Significant Changes (continued) • Page 15 – Added Local Opportunity (Section 3 language) to Minority Participation • Page 16 – Under Fair Housing requirements, communities that receive CDBG funds will be required to have Fair Housing training (Chief elected officials and consultants). • Page 20 – Under Multi-activity applications a Table 1 is needed for each Activity or target area. • Page 25 – FFATA – CCR Registration required for all HUD funding now. Used to be only ARRA funding.
Significant Changes (continued) • Page 24 – Provide email address for the local official on the 424 Form • Page 23 – Project Approval – Most recent annual local audit is required. • Page 24 – Needs Addressed in the Application. For city applicants with work in ETJ, they must describe how the activity is meeting the applicant’s community development and housing needs. • Page 25 – Created a Project Summary Page 2 for Force Account (the questions will be in the app, this is just reference) and also to address Drought contingency plans for non-water/sewer projects.
Significant Changes (continued) • Page 26, Table 1 – Address Engineering costs in excess of 25% of TxCDBG funds considered unreasonable and a justification is required. • Page 29 – Don’t forget to provide in NPO a Justification of the Beneficiary Identification Method used. • Page 33 – Attachments section (new format) • Page 42 – Added pre-agreement written request and sample letter. Pre-agreement request must be submitted (prefer with the app) and a response will be generated by TDA. Limited to Admin and Engineering only.
Significant Changes (continued) • Page 26 – Added Application Checklist • Matching Fund Appendix II, page 42 – Procurement of Professional services can be done in preparation of the application (still not a reimbursable item) • Page 52 – in sample resolution deleted “urban”
Documenting Beneficiaries What information do we collect? • Number of beneficiaries • Income levels • Gender • Race/Ethnicity • Location Why? • To satisfy a CDBG National Program Objective: principally benefit low- to moderate-income persons (51% LMI).
Census Rules • 60% of a Census Geographic Area’s population must receive benefits in order for that area’s Census data to be eligible • The Census Geographic Areas for which we have income data are: County-wide, City-wide, Census Tract, Block Group • Resources: LMISD spreadsheet, American Fact Finder (www.factfinder2.census.gov)
Census FAQs • Where is the LMISD? • TexasAgriculture.gov >> Grants & Services >> Community Development >> All Resources >> Beneficiary Documentation • What information is contained in the LMISD? • Census-based population and income data
Census FAQs • How do I calculate LMI %? • Divide the Low/Mod population into the total population (POP100 or LOWMODUNIV) • What is an income category? • Denotes Very Low, Low, and Moderate income (30%, 50%, 80% of AMFI)
LMISD Spreadsheet • COUNTYNAME – identifies the name of the county where the corresponding geography is located • PLACENAME – identifies the name of the city where the corresponding geography is located. Blank spaces in this column indicate unincorporated portions of counties
LMISD Spreadsheet • TRACT – census tract • BLKGRP – block group • LOWMOD –number of low- to moderate-income persons • LOWMODUNIV – HUD projection of total population
LMISD Spreadsheet • POP100 – total population count according to Census forms • PMOD – number of persons above 50% and up to 80% AMFI • PLOW – number of persons above 30% and up to 50% AMFI • PVLOW – number of persons 30% AMFI and below
Gender & Race/Ethnicity Data http://factfinder2.census.gov
Statistical Inference • This cycle’s Census data was collected differently than in the past. • It may be necessary to make adjustments to be sure beneficiary info makes sense.
Statistical Inference Example: LOWMODUNIV population is 100. Gender data shows 52 males and 55 females. Maintain proportion: • 52 + 55 = 107 • 52 / 107 = 0.4859 (~49%) • 100 * .4859 = ~49 males (51 females)
Survey Rules • Minimum 80% response rate with 100% effort (two attempts per house) • Random sample required if surveying ≥ 200 households (optional if < 200) • Approved surveys are good for 5 years (so for the 2013-2014 cycle, surveys from 1/1/08 are OK)
Survey Rules • For random sample surveys, we only count Sample Pool responses. • Vacancies are not counted. • Non-responses count as a non-LMI response at the average family size of all respondents.
Survey FAQs • Where are the forms? • TexasAgriculture.gov >> Grants & Services >> Community Development >> All Resources >> Beneficiary Documentation • Which forms do I need? • Survey Methodology Manual, Survey Questionnaire, Survey Tabulation Form, maybe Random Number Generator/Sample Size Calculator depending on size of survey
Survey FAQs • What’s the difference between a census type survey and a simple random sample survey? • “Census-style” surveys count 100% of the responses received.
Random Samples Random sample surveys involve selecting a portion of a group at random and inferring its characteristics onto the group as a whole.
Random Samples • Do I have to sample? • Only if you’re surveying 200 households or more, but optional otherwise • How do TxCDBG random sampling procedures work?
Order of Survey Forms Survey forms must be in the following order: (Only random sample surveys will include the Sample Size Calculator/Random Number Generator, subbed-out questionnaires, and non-sample questionnaires.)