HomeMy WebLinkAboutM-81-0929TO Howard Gary 3 i C(CT October 27 , 1981
City Manager
A Quiz•
Dena Spillman, Director
Department of Community Development
Effect of 1981 Statutory Changes
in the Community Development
Block Grant Program
City Commission Agenda
November 12, 1981
The purpose of this memorandum is to bring the City Commission up to date on
recent changes in the Community Development Block Grant program which have come
about as a result of Reagan administration policies. The changes concern two
program areas: funding level and program regulations.
The budget cuts proposed by President Reagan and approved by Congress for FY'82-83
will have an adverse effect on the CDBG program in the City of Miami beginning in
June of 1982. A ten percent cut in the program will take place in June, reducing
our annual entitlement amount to $9.81 million from its current level of $10.9
million. President Reagan has further proposed an additional 12' cut in the CDBG
which would reduce our allocation to $8.6 million. It is unclear at this time
whether Congress will agree to this additional cut. Any cuts in the City's
funding level will result in staff layoffs in the Community Development, Planning,
and Trade and Commerce Departments, as well as cuts in social service programs
funded through the grant. Needless to say, needed projects in the various CD
target areas will either have to be postponed or cancelled. A possibility exists
that, due to the new census figures, the City's grant may be slightly adjusted
upward as a result of the influx of Cuban and Haitian refugees. Final grant amount
information will not be available until January, 1982, and it is doubtful whether
this adjustment will compensate for the cuts.
Changes in program regulations as a result of amendments to the Housing and Community
Development Act of 1974 will allow the City more flexibility in the areas of
citizen participation, geographic target areas, eligible activities and state and
local review requirements. Regulations concerning social service programs have been
loosened up; however, Congress has imposed a 10 limitation on the total CDBG amount
which must be instituted over a 3-year period. The net effect of this requirement
cannot be calculated at this time, however, the City will have to cut its social
service programs a minimum of $713,700 by 1984.
In light of the above, staff is recommending the following:
1. CD Planning - The CD planning schedule be revised to reflect diminished review
requirements. (See attached recommended schedule.) .
2. Citizen Participation - Even though HUD do;�!-. riot now require the intense level
of citizen involvement in the CO process that the City undertakes, it is
recommended that the Board/Forum structure be maintained during the planning
process (through April, 1982). At that time an evaluation of the process will
be undertaken and recommendations will be made to the City Commission for a
revised system during the sunrer months.
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Howard Gary
Page two
October 27 , 1981
3. Geographic Target Areas - The requirement that CD activities take place in
Neighborhood Strategy Areas is no longer part of the program. It is
recommended, however, that in order to complete on -going projects and to
continue the City's concentrated improvement efforts, that the NSA concept
be utilized for the 8th CD year. During next year's planning process, various
geographic funding strategies will be reviewed with the City Commission.
A synopsis of the above changes is attached for your information.
/rjf
Enclosure
c: Frank Castaneda
L.
FY 1982-83 Community Development Planning Schedule
Time Frame
Activity
October
Community needs analysis - meetings already held.
November
Further discussion of community needs. Planners';
synopsis of possible changes in CDBG regulations'.
Presentation of housing rehabilitation program.
Presentation by social service agancies and eco-
nomic development groups.
December
(No meetings). During this time CD and Planning
staff will finalize recommendations to community.
January
Presentation of the new CD regulations to the
community as well as funding for the 8th CDBG
year. Staff's recommendation to the community.
February
Community's response.
March
Staff's final recommendation.
April
Public Hearing before the City Commission.
May 15, 1982
Submittal of Certification to HUD.
June 16, 1982
HUD approval, and commencement of fiscal year.
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PRESUBMISSION REQUIU.ME.NTS
OLD
° Prepare and follow
written citizen
participation plan
° Furnish information to
citizens on amount of
funds available,
eligible activities,
and other important
requirements
° Hold at least two
public hearings on
housing and community
development needs
° Provide opportunity for
citizens to participate
in the development of
the application
° Encourage submission of
views and proposals,
especially from lower
,income persons and
residents of blighted
areas
° Respond to proposals
submitted
° Submit application for
review by State'and
areawide clearinghouses
(A-95)
NEW
° No specific requirement
° Furnish information to
citizens on amount of
funds available and
eligible activities
° Hold one or more public
hearings on housing and
eoununity development
needs
° Publish a draft
statement of community
development objectives
and list of proposed
activities
° Invite cor=,ent on draft
statement
° No specifie requiremcnt
° No longer requi7ed
° Make public a final
statement of comnur,ity
development objectives
and list df activities
after considering
co;nnents received
a
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ENT I TLERIENT GRAINT AWARD PROCESS
Content of Submission
.* %
Community Development and
Housing Plan (every three
years)
o Needs
C Strategies
° Three year program
Annual Community
Development Program
° Description of
activities
° Location of activities
° Cost surrnary
° Certifications of Law
Compliance
Housing Assistance Plan
° Housing conditions
° Assisted housing needs
° Three year goals
° General Iocations
° Annual RIP goals
NEtV
Statement of locality's
Community Development
Objectives
° Lisa of activities
° Certifications of Law
Compliance (including
compliance with
separately approved
11AP)
Housing Assistance Plan
(separate f: or,; CD13G
submission)
(same elements required;
simplified regulations
and forms under
development)
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PRE-AIVARD
REVIEW
• OLD
NEW
Approve application
° Grant is awarded upon
within 75 days unless it
submission of required
is determined that:
documents
° Needs are plainly
Advice on eligibility
inconsistent with
and maximum feasibile
_ generally available
priority provided upofi
facts and data
request of locality
° Program is plainly
inappropriate to meet
needs
° Activities are
ineligible
° Activities fail to meet
maximum feasible
'
priority requirements
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S.
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ELIGIBLE ACTIVITIES
Public Services
OLD
° New or increased level
of service
° Only for areas of
concentrated CDBG
activities
° Determined necessary or
appropriate to support
physical development
° Other Federal funds
unavailable -
Economic Development
OLD
° Indirect assistance to
private for profit
business through LDC's,
SBIC's, or
neighborhood -based
nonprofits
° Provision of land,
public facilities, or
conmcrcial/industrial
improvements in support
of private for profit
businesses
NEW
° No change
° No more than 10% of
funds (grantees that
allocated more than 10%
in FY 81 permitted to
exceed limit until FY
85)
° No longer required
° No Ionger required
NEW
° Direct assistance to
private for -profit
businesses
° No change
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ELIGIBLE ACTIVITIES (cont.)
i
Comprehensive Planning
OLD NEW
° Comprehensive planning ° Develop comprehensive
as provided in 701 plan
program when not
otherwise eligible and ° Develop strategies and
necessary to meet action programs
community development
program objectives ° Evaluate plans,
strategies, and action
programs
° Carry out A-95
clearinghouse functions
81 - 929
SIGNIFICANT CHANGES IN ELIGIBLE ACTIYLTIES
1. PUBLIC SERVICES
I.1111TATIONS REMOVED:
° Geographical
° Supporting relationship
° Other Federal funds
NEW 111i1TATIONS:
° Cannot exceed 101N, of grant
° Exception — if FY 81 allocation was over 10% — then by FY 85
° Still limited to new or increased services
2. SPECIAL ASSESSi1;EN1'S
° Can now be levied on portion of expenditure not funded by CDBG funds
° Can pay assessments for low -mod with CDBG funds
3. NEMzSARY OR APPROPRIATE DETERMINATIONS
° In lieu of former special approvals by HUD
° Documentation of determination is required
4. ASSISTANCE TO PRIVATE FOR PROFITS
permitted for all activities determined or. appropriate" for an
economic development project
5. PLANNING
° Coin prehensive pl:_nnin,; (,ctivities laid clrni•ini;house runctions Carl l-e fum;Ud
ev(?n thou'lh A-05 revici+-s no Is)r:,,cr re,uirrd
G. I:N 1;IIGY CONSERVA'i'lON
° Encr � conservation activities power generation i,sin, roncv,l,')lc energy
resojirees sy,.,tems —solid Nvaste recycling and convej-sionlfGCilitics purri:itted
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SUMMARY OF C14ANGFS TO MAX FEAS RULES
1. Relocated into Subpart C (Eligibility) so applies to entitlement, state and small
cities programs.
2. Three national objectives are co -equal, (i.e., removed emphasis on overall low -mod
benefit).
3. Activities in UUAG cities and 'Pockets of Poverty' qualify as lov.-mod-income
benefit projects.
4. Exception criteria (.302(d)(5)) for low -mod projects in non -low -mod areas luis been
eliminated.
5. Slum or Blight definition relaxed:
° Area need not be NSA
° Areas with substantial deterioration throughout may meet test without meeting
strict (urban renewal type) state and law definitions of slum or blighted.
° Recipients must maintain evidence supporting the local determination of slum
or blighted.
6. Spr'r ial rules established for residential rehabilitation:
Low -Mod Benefit:
° -100% of assisted single family structures must be occupied by low -mod
households
• Majority of assisted units in multiple farrrily structures must be occupied by
low -mod households
° For rental units, the income test is based on r►fforCability of the units after
rehab
° Nature of rchub iietivities unlimited
Slum or Blight:
° On a spot basis, eligible as before (only to extent necessary to eliminate
Specific conditiorLs detrimental to publir. health and Safety)
° In urvic,s qualifying as slum or blight, eligible to a hi' rcr iw!Q;1.c household (I)
only if unit is substandard (local), and (2) lirnitod to stunt.'-zrdi'ratior. unle>> all
suet deficicneies luive been removed.
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