HomeMy WebLinkAboutCDBG Program Changes}
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MONTANA
DEPARTMENT OF
Local Government Assistance Dii
1424 9th Avenue PO Box 200523
Helena, MT 59620.0523
."1 I, ? Q U l5
>R X10 EC 2 6 2000
CITY OF L
TO: LOCAL GOVERNMENT OFFICIALS AND OTHERS INTERESTED IN THE
-MONTANA COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG)
PROGRAM
FROM: GUS,BYROM, CDBG PROGRAM MANAGER 6l?
HOUSING AND PUBLIC FACILITIES
SUBJECT: PROPOSED CHANGES TO THE APPLICATION GUIDELINES FOR THE
YEAR 2001 CDBG PROGRAM FOR THE HOUSING AND COMMUNITY
REVITALIZATION AND PUBLIC FACILITIES CATEGORIES
DATE: December 21, 2000
The following presents a summary of proposed changes to the year 2001 Montana
Community Development Block Grant (CDBG) Program Application Guidelines for
• Housing and Community Revitalization and Public Facility projects. Some of the
proposals represent changes in past policies for Montana's CDBG Program. We
would appreciate your reaction to them or suggestions for alternatives.
Montana's CDBG program is a federally funded, competitive grant program
designed to help communities of less than 50,000 population with their greatest
community development needs. All CDBG projects must principally benefit low and
moderate income persons. The program was established by the federal Housing and
Community Development Act of 1974. The Montana Department of Commerce
(MDOC) administers the program "under contract" with the U.S. Department of
Housing and Urban Development (HUD). In 1982, MDOC took over administration
of the "nonentitlement" CDBG program for communities of less than 50,000
population from HUD. The MDOC Economic Development Division administers the
Economic Development category. The Housing and Community Revitalization and
Public Facilities categories are administered by the MDOC Local Government
Assistance Division.
To expedite the public comment process and reduce printing and distribution costs,
the MDOC is distributing a summary of only the major proposed changes to the
guidelines at this time, rather than the entire text. This summary focuses on the
key issues that local government officials and others need to be aware of in order
• to offer comments. The final guidelines will be distributed this March to local
governments and other interested persons on the CDBG mailing list.
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COAL BOARD (406)414-290(1 ? CDBG (4061 4 44-24 88 ? CrAP (4061414-3757 ? HRMI BOARD (406) 4443757 ? 15EP (406) 444-2400
We are proposing minimal changes in funding allocations or ranking criteria because
17 of the 38 communities which are current applicants for Treasure State •
Endowment. Program (TSEP) funding have stated their intent to apply for CDBG
funds in May,. 2001. Any major change in application requirements or funding
allocations could seriously disrupt proposed funding packages that these
communities have been working towards for months.
The text or organization of the guidelines may be subject to some change to
improve the clarity and utility of the guidelines for CDBG applicants.
Public Hearing on CDBG Guidelines Scheduled for January 11, 2001
A public hearing on the year 2001 CDBG Application Guidelines will be held
Thursday, January 11, 2001 at 1:30 P.M. in the Downstairs Conference Room of
the Department of Commerce, 1424 9th Avenue, Helena, Montana. Written
comments may also be submitted to the Local Government Assistance Division,
Department of Commerce, Capitol Station, Helena, Montana 59620. Comments
must be received no later than 5:00 P.M., Friday, January 19, 2001 in order to be
incorporated into the formal record.
Proposed Application Deadlines, Allocation of Funds, and Program Changes for the
Year 2001 Program •
1. Proposed Application Deadlines
The following application deadlines are proposed for this year's CDBG
program:
Type of Grant Deadline
Planning April 6, 2001
Public Facilities May 25, 2001
Housing and Community Revitalization August 31, 2001
II. Proposed Allocation and Distribution of Funds
In 2000, the Montana CDBG program received an allocation of $7,788,000.
Montana's allocation of CDBG funds for 2001 will be $8,122,000. One-third of
the total amount available for new CDBG grants will be set aside for the Economic
Development category of the CDBG program or $2,592,780.
,.
MDOC attempts to allocate funds between the Housing and Community •
Revitalization and Public Facilities categories based upon the relative and changing
demand for funds for each category. Funding allocations for the Housing and
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Community Revitalization and Public Facilities categories are based on the
approximate percentage of applications requested for the previous two-year period.
• Using a two-year average adjusts for any variability in the demand for CDBG public
facilities funding that may be associated with the biennial cycle of the State's
legislatively approved infrastructure funding programs: the Department of Natural
Resources and Conservation (DNRC) Renewable Resources Grant and Loan Program
and MDOC's Treasure State Endowment Program (TSEP).
•
•
In this way, the funding reserved for each category can "respond to changing
demand for CDBG Housing and Community Revitalization and Public Facilities
grants over time. Through this method, the amounts allocated between the two
categories will change based upon actual past demand; however, the basic method
of distribution remains unchanged. The chart below lists the number of Housing
and Community Revitalization and Public Facilities applications and the total dollars
requested for the last two years.
CDBG APPLICATIONS RECEIVED__
1999-2000
HOUSING & COMMUNITY PUBLIC FACILITIES
REVITALIZATION
YEAR # OF APPS TOTAL $ # OF TOTAL $
REQUESTED APPS REQUESTED
1999 7 $2,206,307 20 $6,630,144
2000 5 2,500,000 15 5,801,956
Total: 12 4,706,307 35 12,632,100
% of Total
Applications 26% 74%
Based upon an analysis of the average number of applications received yearly for
each category, the resulting percentage is 26 % for Housing and Community
Revitalization projects and 74 % for Public Facilities projects.
As a result of the method of distribution described above, the allocations for the
Housing and Community Revitalization and Public Facilities categories for 2001 will
be established at 26% and 74%, respectively, of the total available funding for
these two categories or $5,035,560.
Based upon the method of distribution described above, CDBG funds are proposed
to be allocated for the year 2001 program in the following manner:
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Total Fiscal Year 2001 State CDBG Allocation
Less CDBG funds for State program administration
(as provided by federal statutory formula)
Amount Available for Award to Local Governments
Less 1 /3 Allocation for Economic Development Projects
Total Available for Housing and Community Revitalization
and Public Facility Projects
Less Planning Grants
Sub-Total
Allocation for Housing and Community Revitalization Projects
(26%)
Allocation for Public Facilities Projects (74%)
58;122,000
$ 343,660 •
$7,778,340
$2,592,780
$5,185,560
$ 150,000
$5,035,560
$1,309,246
$3,726,314 1
III. Proposed Changes for the Year 2001 CDBG Program - Housing and Community
Revitalization and Public Facilities Categories
A. Public Facilities Category
1. Public Facilities Ranking Criteria
For 2001, the CDBG program proposes that 25 points be transferred from the
"Community Efforts" ranking criterion to the "Community Planning and Needs
Assessment" criterion, as shown below.
Public Facilities applications will be evaluated according to the following criteria and
may be assigned up to a maximum of 800 points:
CURRENT PROPOSED
•
1. Community Planning and Needs Assessment 100 Points 125 Points
2. Need for Project 125 Points 125 Points
3. Project Concept and Technical Design 100 Points 100 Points
4. Community Efforts 100 Points 75 Points •
5. Need for Financial Assistance 150 Points 150 Points
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B.
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6. Benefit to Low and Moderate Income
7. Implementation and Management
TOTAL:
100 Points
125 Points
800 Points
100 Points
125 Points
800 Points
The rationale for the proposed change is that many grantee activities related to
demonstrating Community Efforts are also central to grantee activities related to
the Community Planning and Needs Assessment criterion. The thoroughness and
depth with which grantees document and analyze needs and conduct community
planning to address those needs (Criterion #1) is deemed to be a major determinant
in the success of Community Efforts (Criterion #4) and the eventual success of the
project. Therefore, for 2001 it is proposed that the Community Planning and
Needs Assessment criterion be increased in weighting to reflect its greater
importance.
2. Utilization of TSEP Scores for CDBG Engineering Reviews
For 2001, the CDBG program proposes, where applicable, to utilize the engineering
scores the Treasure State Endowment Program (TSEP) assigned during the 2000
TSEP competition, for the same projects submitted to the spring Public Facilities
CDBG competition. if the Preliminary Engineering Report submitted as part of the
CDBG grant application is different or has been expanded or modified, it would be
the responsibility of the giant applicant to identify the new materials or
modifications to the CDBG program; otherwise, the same score assigned by TSEP.
in the year 2000 will be used for criteria 2, "Need for Project" and criteria 3,
"Project Concept and Technical Design" in CDBG for the year 2001 (based upon
assigned scores for TSEP Statutory Priority #1 and Statutory Priority #3).
Applicants who indicate that the preliminary engineering has been expanded or
modified, will receive a separate CDBG engineering review and will then be
assigned an appropriate score based upon the merits and ranking criteria described
in the CDBG guidelines. The text of the CDBG criteria for engineering reviews will
also be amended to be consistent with the TSEP criteria.
Housing And Community Revitalization Category Ranking Criteria
1. Housing And Community Revitalization Category Ranking Criteria
For 2001, the CDBG program proposes that the six ranking criteria be consolidated
into five. Criteria 4, "Community Efforts" would be combined with criteria 3,
"Project Strategy and Impact" into a new third criteria, entitled "Project Strategy
and Community Efforts", as shown below. The weighting of the criteria would also
be adjusted. Experience has shown that within the Housing category community
efforts are closely intertwined with project strategy and that unnecessary
duplication can be eliminated by combining the two criteria.
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Existing Housing Criteria
1. Community Planning and Needs Assessment 125 Points
2. Need for Project 100 Points
3. Project Strategy and Impact 150 Points
4. Community Efforts 150 Points
5. Benefit to Low and Moderate Income Persons 150 Points
6. Implementation and Management 125 Points
TOTAL: 800 Points
Proposed Change for 2001 (Italics and Bold)
1. Community Planning and Needs Assessment 150 Points
2. Need for Project 150 Points
3. Project Strategy and Community Efforts 200 Points
4. Benefit to Low and Moderate Income Persons 150 Points
5. Implementation and Management 150 Points •
TOTAL: 800 Points
C. CDBG Planning Grants
1. Maximum Grants and Required Match
According to local officials, the up-front costs of preparing a local needs
assessment or housing study often present a serious obstacle for communities who
want to apply for CDBG assistance, particularly for small communities with limited
resources. The CDBG program is able to play a unique role in assisting Montana
communities because of its ability to offer planning grants to local governments.
The grants can be used for a variety of planning activities including the initial
planning necessary to get a project underway, or to conduct other important
community planning activities such as preparing or updating a comprehensive plan
or growth policy, preparing a neighborhood redevelopment plan, a housing study,
capital improvement plan, or similar planning processes needed to help a
community address critical needs.
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For 2001, CDBG planning grants would be available in amounts up to $15,000.
Local governments must provide a match on a 50-50 basis that must be firmly
committed by the time CDBG funds are released. Firm loan commitments, such as
funds borrowed from the Montana Board of Investments or from a local bank, are
acceptable forms of match. Grants or other cash contributions from other local,
state, or federal agencies or programs or private foundations are also acceptable
forms of match.
Grant applicants may substitute "in-kind" services for cash match, as long as the
value of the match can be adequately documented. For example, a community
preparing a local comprehensive plan could count the local planning staff's time
working on the plan as long as adequate time sheets were maintained to document
the time spent on the project.
The MDOC could still reduce or entirely waive the match requirement in those
hardship cases where the local government can clearly demonstrate that higher
financial participation or the contribution of in-kind services in lieu of cash is not
possible and the local need relates to the immediate need to protect public health
or safety. In these cases, applicants may request MDOC to waive the 50 percent
matching requirement where:
1. The planning study is directly related to the existence of a serious deficiency in
a basic or necessary community facility or service (or the community lacks the
• facility or service entirely) and adverse consequences clearly attributable to the
deficiency have occurred, or are likely to occur;
2. The application clearly demonstrates that higher local financial participation is
not feasible or appropriate. For planning studies related to the preparation of
capital improvement programs, this would include circumstances where utility
(water and wastewater) rates exceed the "target rate" as described in the Year
2001 CDBG Application Guidelines for Public Facilities projects; and
3. Other sources of match are not reasonably available.
2. Ranking Criteria For Planning Grant Applications
The CDBG Program will use the following criteria to evaluate the proposals and to
rank the applications in the likely event that the total requests exceed available
funding. Planning Grant applications may be assigned up to a maximum of 250
points. For 2001, the CDBG program is proposing that the weighting of scores be
equal for each ranking criteria. The criteria and proposed weightings are:
Maximum Points Current Proposed
is 1. Relationship to Community's Long-Range
Planning Process 100 Points 50 Points
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2. Threat to Public Health or Public Safety 80 Points 50 Points
3. Financial Need 60 Points 50 Points
4. Benefit to Low and Moderate Income 40 Points 50 Points •
5. First Time Recipient 20 Points 50 Points
TOTAL POINTS: 300 Points 250 Points
Because of the availability of new funds from the Treasure State Endowment
Program, the CDBG program proposes will, not fund preliminary engineering studies
related to water, sewer, or solid waste projects. The 1999 Legislature, during the
special session in May 2000, appropriated $425,000 in each biennium until 2005 for
TSEP grants to local governments for preliminary engineering studies (contact Jim
Edgcomb, TSEP Program Manager, at 406-444-5284 for more information).
These TSEP grants will be available after July 2001. The department will begin the rule
making early in 2001 in order to adopt guidelines related to the provision of these
grants. Additionally, the Department of Natural Resources and Conservation
Renewable Resource Program will be requesting legislative approval for approximately
$300,000 that, if approved would be available during the next biennium for water and
wastewater preliminary engineering and related studies.
The CDBG program planning funds would instead focus on those planning needs where
little or no other funds are available.
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3. Eligible Activities
Funds can be used for the preparation of plans, studies, analyses, or research in
the following areas:
? Community growth policies (master or comprehensive plans) or strategic
plans. CDBG Planning Grants can also be used to update an existing
comprehensive plan in order to conform to the new minimum requirements
for local government "growth policies" set out by Senate Bill 97 passed by
the 1999 Legislature.
? Capital improvement plans or programs.
? Preparation of community needs assessments, action plans or
implementation strategies.
? Housing plans, including housing needs studies, housing condition surveys,
housing affordability studies or plans, housing project feasibility studies, or
the development of housing assistance programs.
? Neighborhood redevelopment plans, urban renewal plans, analyses of •
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impediments to fair housing choice, and environmental and historic
s preservation studies.
• ? Preparation of plans intended to mitigate adverse effects of construction in
areas subject to flooding or other natural hazards, such as earthquakes or
wildland fire, or to prepare plans for reuse of vacant industrial areas
("brownfields") for possible redevelopment.
? Conduct of income surveys necessary to complete a CDBG application.
? Preparation of downtown revitalization studies. These CDBG planning grants
could be used as match for architectural design assistance from the School
of Architecture at Montana State University.
? Preparation of preliminary architectural plans for housing or public facilities
projects.
? Preparation of funding applications for housing or public facilities projects.
IV. Dates And Locations For Public Facilities Workshops This Spring
In cooperation with the Water, Wastewater, and Solid Waste Agencies
• Coordinating Team (WzASACT), the CDBG program will be co-hosting three
workshops this Spring 2001 designed to familiarize local governments with federal
and state low interest loan and grant programs that are available to assist local
governments and water and sewer districts in financing water, sewer, and solid
waste improvement projects. The dates and locations are as follows:
Tuesday- March 13 - Elks Lodge - Sidney
March 14 - CDBG '/: Day Session - Elk's Lodge
Thursday - March 15 - Howard Johnson - Billings
March 16 - CDBG '/2 Day Session - Howard Johnson
Thursday - March 22 - Cavanaugh's (Colonial Inn) - Helena
March 23 - CDBG % Day Session - Cavanaugh's
Local government officials and all those interested in learning how to plan for and
finance local infrastructure improvements are strongly encouraged to attend one of
these sessions. The second day of each workshop will focus solely on CDBG
application requirements.
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V. Conclusion
Since the establishment of the Montana CDBG program in 1982, the Community
Development Bureau of the Department of Commerce has attempted to keep the
CDBG program as useful to local governments as possible, consistent with the
federal laws and regulations under which it must operate. The proposals
presented in this report are an important part of the Department's on-going effort
to continually re-evaluate and improve the program. It is very important that local
officials and others interested in community development review and provide
comments on these proposals. By responding to your suggestions, the CDBG
program can continue to positively assist Montana local governments as they seek
solutions to their greatest community development needs.
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