ADECA’s CDBG Program: National Objectives and Eligible Activities

ADECA’s CDBG Program:National ObjectivesandEligible Activities Kathleen A. Rasmussen, Ph.D. ADECA CED Division Statewide Initiatives Unit Chief 334-353-0323 Kathleen.rasmussen@adeca.alabama.gov

www.adeca.alabama.gov 1. From the drop-down menu click on Divisions • Click on Community and Economic Development • In the left column, click on Community Development Programs • In the left column, click on Community Development Block Grant, then click on: • Application Manual, or • Current Forms & Sample Documents, or • Basically CDBG Course Training Manual, or • CDBG Guide to National Objectives and Eligible Activities

ADECA’s CDBG Funds are for Alabama’s Non-entitlement Communities ADECA allocates CDBG funds via grants to counties, large cities (that have a population of 3,001 or more) and small cities (that have a population of 3,000 or less). Eligible cities and counties must be a Non-entitlement Community in Alabama. For 2019 CDBG funds, a Non-entitlement Community is defined as those cities and counties that do not include the cities of Anniston, Auburn, Bessemer, Birmingham, Decatur, Dothan, Fairhope, Florence, Gadsden, Huntsville, Mobile, Montgomery, Opelika, and Tuscaloosa, and Jefferson County and Mobile County, as these are the Entitlement Communities in Alabama. If your community is not included in this list of Entitlement Communities, then you should be eligible to apply to ADECA for CDBG funding.

Unit of General Local Government (UGLG) Roles & Responsibilities • The UGLG, through its chief elected official, is legally, financially, contractually, and programmatically responsible for the CDBG project • The UGLG is responsible to the State and to the Federal government even if the UGLG has contracted with a grant administrator to administer the CDBG project on its behalf

CDBG Program - Goals Development of viable communities by providing the following, principally of benefit to persons of low- and moderate-income: • Decent Housing • Suitable Living Environments • Expanded Economic Opportunities

CDBG Program - National Objectives Each grant project’s activity must meet one (1) of the CDBG Program’s three (3) National Objectives: • Benefit / address the needs of persons of low and moderate income (LMI) • Aid in the prevention or elimination of slums or blight • Address an urgent need within the local community

Objective 1: Benefit LMI Persons HUD defines “low- and moderate-income persons” as families and individuals whose incomes are no more than 80% of the median income of the area involved. The State (ADECA) is required to expend a minimum of 70% of its CDBG funds for activities that benefit LMI persons.

Criteria: Benefit to LMI Persons • (a) LMI persons in the project area benefit from the activity • (b) LMI persons who are Limited Clientele are served by the activity • (c) LMI Housing in the project area • (d) LMI Employment (job creation and/or retention)

LMI: (a) Area Benefit • The project activity benefits all residents located in a particular neighborhood / area • Typically involves public improvements (water, sewer, streets, drainage, etc.) • The 51% or more LMI population is documented by one of two ways: • LMI Summary Data (ACS 5-Year 2011-2015 Low- and Moderate-Income Summary Data) – see the HUD website at: https://www.hudexchange.info/programs/acs-low-mod-summary-data/ • Individual house-to-house / household surveys

LMI: (b) Limited Clientele • The activity benefits a specific group of persons (i.e., a senior center that is used by senior citizens, or a domestic violence / abuse shelter that is used by victims of domestic violence / abuse): • The population to be served is generally presumed to be LMI, or • The population to be served requires documentation on family size and income

LMI: (c) Housing The activity is for housing that: • Will provide or improve the permanent residential structures for housing LMI residents • The households served can be either owner-occupied or renter-occupied housing

LMI: (d) Employment The activity is for economic development: • That will create or retain jobs (employment) • LMI income qualification is based on household income prior to the new employment – not wages/salary of new job • Number of jobs must be calculated on a full time equivalent (FTE) basis • Jobs that are created or retained must be permanent jobs, not temporary jobs • Jobs that are created indirectly by the project are not included in the job count

Objective 2: Prevention or Elimination of Slums/Blighted Areas • Conducted on an “Area Basis” = the activity targets a clearly defined slum or blighted area / neighborhood within the community’s limits • Conducted on a “Spot Basis” = the activity targets specific blight outside of a defined area / neighborhood, but still lies within the community’s limits

Slums/Blight – On an “Area Basis” • Must officially designate slum/blight “area” 1. 35% of buildings are deteriorated or dilapidated 2. 25% of commercial structures are vacant, or 25% of usable commercial space is unused 3. Public infrastructure throughout area is inadequate or is in a deteriorating condition 4. Public and private investment in last 5-10 years has ceased 5. Area is characterized by accumulation of trash and junk, and portrays a distressing visible appearance

Slums/Blight – On an “Area Basis” Continued: 6. Occurrences of criminal acts in the area have increased in the last few years 7. Retail sales have ceased to increase or have actually declined in last 5-10 years NOTE: Boundaries of the area must be delineated, and the area must be officially designated as a slum or blighted area by local government resolution.

Slums/Blight – On a “Spot Basis” • The activity must prevent the spread of slum/blight to adjacent properties • The activity must be designed to eliminate a specific condition of slum/blight or physical decay that is not located in one specific designated slum/blighted area – but which physical decay is located in several areas throughout the community

Objective 3: To Address an Urgent Need Within the Community 1. Existing (not potential) conditions must pose a serious and immediate threat to the health or welfare of the community 2. Conditions are of recent origin (generally occurred within the past 18 months) 3. Community is unable to finance activity on its own 4. Other sources of funding are not available to the community to finance activity

Acquisition of Real Property Developing or Upgrading Public Infrastructure Demolition/Clearance Housing Rehabilitation Economic Development Architectural Barrier Removal Parks and Recreation Public Facilities (senior centers, fire stations, storm shelters) Planning Studies Grant Admin work Eligible Activities

Ineligible Activities Buildings or portions thereof used for the general conduct of government General government expenses Political activities Purchases of equipment Operations and maintenance costs New housing construction

Project Beneficiary Table CDBG Grant Application Manual at Tab 3, Tab 5, Tab 6, and Tab 7, and ADECA’s website contain the following: • LMI Summary Data (“ACS 5-Year 2011-2015 Low- and Moderate-Income Summary Data”) found at: https://www.hudexchange.info/programs/acs low-mod-summary-data/ • PY2019 HUD Income Limits (available June 1st) • Project Beneficiary Table

Project Beneficiary Table CDBG Grant Application Manual at Tab 4, and website: • Definition of “Limited Clientele” • ADECA CDBG Policy Letter #22 -Establishment of LMI Benefit for Area Wide Projects, Revision 3, dated 2/27/2003 • HUD Website: • https://www.hudexchange.info/resources/documents/Notice-CPD-14-013-Guidelines-for-Conducting-Income-Surveys-LMI-CDBG-Activity.pdf

Project Beneficiary Table Sample Survey Forms (Tab 4 and website) • Sample CDBG Beneficiary Survey Form • Sample Housing Rehabilitation Survey Form - “Owner Occupied” • Sample Housing Rehabilitation Survey Form - “Renter Occupied” • Sample Employee Income Certification Form • Sample Survey Form - for water / sewer connections / hookups

Any Questions?

ADECA’s CDBG Program: National Objectives and Eligible Activities