1. The Lifecycle of Grants: Introduction to CDBG Administration November 7, 2012

2. TOPICS Federal and State Administration Program History and Objectives National Objectives Eligible and Ineligible CDBG Activities Citizen Participation

3. The Lifecycle of Grants Grant Agreement and Fair Housing (Wed P.M.) Environmental Review (Wed P.M.) Financial Management (Thurs A.M.) Acquisition, Relocation, and Procurement (Thurs P.M.) Contract and Construction Management (Thurs P.M.) Labor Standards (Fri A.M.) Monitoring and Closeout (Fri A.M)

4. MATERIALS Community Development Program Timeline Chart PowerPoint Presentations Environmental Review Templates File Guide Monitoring Tool Miscellaneous Handouts

5. CDBG PROGRAM HISTORY

6. ESTABLISHING LEGISLATION Authorized under Title I of the Housing and Community Development Act of 1974 Combined a number of existing community development programs into one funding source Provided for increased flexibility for local governments Regulations located at 24 CFR Part 570

7. STATE ADMINISTERED CDBG State Program (Small Cities) established in 1982 Targeted at cities with populations of less than 50,000 and counties with populations of less than 200,000 Reflected desire for increased flexibility Regulations located at 24 CFR Part 570.480

8. CDBG PRIMARY OBJECTIVES Development of viable communities, principally for low- and moderate-income (LMI) persons, through; – Decent housing – Suitable living environment – Expanded economic opportunity

9. KEY DEFINITIONS Entitlement Program Grants given to cities with populations of 50,000 and counties with populations of 200,000 State and Small Cities Program Grants given to states, which administer the program to non-entitled cities/counties CDBG Recipient The CDBG unit of general local government that receives its CDBG grant from HUD or the state

10. OHIO STATE PROGRAM ADMINISTRATION Department of Housing and Urban Development Awards funds to the Ohio Development Services Agency Office of Community Development (Community Services Division) Administers the program for the State of Ohio Eligible communities include 79 counties, direct cities, and villages, depending on the individual program parameters

11. OHIO STATE PROGRAM ADMINISTRATION Community Development Program: CDBG eligible activities, including public facilities, public services, demolition/clearance, and limited housing Economic Development Loan and Public Infrastructure Grant Program: Grants for off-site infrastructure and loans for fixed asset financing tied to job creation/retention Residential Public Infrastructure Grant Program: Public water and sanitary sewer projects Community Housing Improvement Program: private owner/rental rehab, home repair, acquisition/rehab/resale, down payment assistance rehab

12. COMMUNITY DEVELOPMENT PROGRAM Administered by the Ohio Department of Development Office of Community Development’s Economic and Appalachian Development Section Staff

13. COMMUNITY DEVELOPMENT PROGRAM GOAL: To provide communities with a flexible housing and community development resource that can be used to address locally identified needs that are eligible CDBG activities and qualify under the national objective of Low- and Moderate-Income (LMI) Benefit or Elimination of Slum and Blight.

14. Economic and Appalachian Development Section Mary R. Oakley, Manager Michael Novakov, Community Development Analyst – AREA A Timothy Leasure, Community Development Analyst – AREA B David (DJ) Pasquariello, Community Development Analyst – AREA C Michael Norton-Smith, Community Development Analyst – AREA D Michael Kinninger, Community Development Analyst – AREA F Area E: Open Christa Callihan, Federal ARC & State Appalachian Development Beverly Cooper, Federal ARC & State Appalachian Development

16. Training and Technical Assistance Section Staffing Betsy Giffin, Manager Tim Allen, Environmental Review Specialist Cecilia Castillo, Environmental Review Specialist Joyce Hill, Civil Rights Specialist Shannon Southworth, Community Development Analyst

17. Fiscal Grant Management Section Staffing Maddie Forrester, Manager Jolanda Cunningham, Fiscal Specialist Stephanie Miller, Account Clerk Natalie Qualls, Fiscal Specialist Carlotta Underwood, Fiscal Specialist Wendy Van Over, Fiscal Specialist

18. Fiscal Grant Management Section Staffing Maddie Forrester, Manager Jolanda Cunningham, Fiscal Specialist Stephanie Miller, Account Clerk Natalie Qualls, Fiscal Specialist Carlotta Underwood, Fiscal Specialist Wendy Van Over, Fiscal Specialist

19. Introductions Name Agency/Community Number of Years CDBG Experience

20. National Objective Citizen Participation Fair Housing/Civil Rights Environmental Review Financial Management Acquisition/Relocation Procurement Construction and Contract Management Labor Standards Grants Management System FEDERAL/STATE REQUIREMENTS

21. NATIONAL OBJECTIVES

22. All CDBG activities must result in one of the following: – Benefit low- and moderate-income (LMI) persons – Prevent or eliminate slum & blight – Meet an urgent need having a particular urgency because existing conditions pose a serious and immediate threat to the health or welfare of the community Regulations located at 24 CFR §570.208 and §570.483

23. ! Area Benefit Limited Clientele Jobs Area Basis NATIONAL OBJECTIVES URGENT NEEDSLUM/BLIGHT LMI HousingUrban Renewal Spot Basis

24. Some activities qualify under more than one national objective Rule of thumb, choose the one that is easiest to document NATIONAL OBJECTIVES

25. There are 4 ways an activity can satisfy the LMI national objective: – Area benefit – Limited clientele – Housing – Job creation or retention Regulations located at §570.208(a)(1-4) NATIONAL OBJECTIVE: LMI

26. To qualify a project using LMI Area benefit, applicants must determine: – The service area of activity – Whether the area is primarily residential – Whether the activity benefits all residents of the service area – Whether the area is 51% LMI – Whether the activity is a public facility for which assessments will be charged LMI AREA BENEFIT

27. A project’s service area can be defined as: – An entire community (city, county, village) – A Census Tract or Block Group, or multiple Census Tracts or Block Groups – A neighborhood – Residents along street or water/sewer line LMI AREA BENEFIT

28. EXAMPLE 1: Park Improvement Project – What is the true service area? – Who uses the park? – What does geography of area show? – How many other parks in the area? – What services does the park provide (neighborhood park vs. baseball diamonds) LMI AREA BENEFIT

29. EXAMPLE 2: Water or Sewer Project – Who is on service route? – Who will connect to infrastructure? – What type of infrastructure is it? A water tower or wastewater treatment plant might benefit the entire town whereas a waterline might only benefit the residents on one street LMI AREA BENEFIT

30. EXAMPLE 3: Street Improvement Project – State Route or major thoroughfare everyone in the community uses – Connector street used by several neighborhoods or entire community – Residential road used by a single neighborhood or residents of street LMI AREA BENEFIT

31. LMI percentage can be determined by utilizing Census Data (2000 – updated in 2007) – Generally easiest way to qualify a project – However, sometimes beneficiaries do not correspond with Census Tracts or Block Groups i.e. project may benefit portions of 3 different Census Tracts – Data is often out of date and/or doesn’t fully describe condition of area Population shifts, effects of economic crisis, etc.

32. In instances when Census Data is not applicable, an Income Survey of the service area can be used – OHCP policy requires an adequate sample size and random selection of households – Income Survey approved methodology and procedures can be found at http://development.ohio.gov/cms/uploadedfiles/CDD/OH CP/OHCP08-03.pdf http://development.ohio.gov/cms/uploadedfiles/CDD/OH CP/OHCP08-03.pdf LMI AREA BENEFIT

33. NATIONAL OBJECTIVE FILE GUIDE LMI Area Wide Benefit Projects Qualified by Census Community must include Census Map with project service area and affected block groups Exhibit NO 1: Service Area Map Area Percentage LMI: Projects Qualified by Income Survey Community must complete Income Survey as per OCD Policy 08-03 Exhibit NO 2a: Income Survey Summary Sheet Exhibit NO 2b: Individual Response Sheets Exhibit NO 2c: HUD Section 8 Income Limits Calculated Percentage LMI:

34. LMI Limited Clientele activities benefit special populations (senior citizens, homeless shelters, disabled adults) Activities must meet one of four requirements – Benefit to clientele who are presumed to be principally LMI – Requires information that demonstrates 51% of participants are LMI – Participation limited to LMI only – Nature and location indicate activity’s clientele will primarily be LMI persons. LMI LIMITED CLIENTELE

35. Limited Clientele Groups Include: – Abused children; – Battered spouses; – Severely disabled adults; – Homeless persons; – Illiterate adults; – Migrant farm workers; – Elderly persons; – Persons living with AIDS; and – Programs with eligibility requirements that limit the benefits of an activity to LMI persons. LMI LIMITED CLIENTELE

36. EXAMPLES: – ADA Compliance (elevators, curb cuts, ramps, bathroom modifications) – Senior Centers – Meals on Wheels – Public Health Clinic – Literacy Education – Homeless or domestic violence shelters LMI LIMITED CLIENTELE

37. NATIONAL OBJECTIVE FILE GUIDE LMI Limited Clientele Activity is designed for and used by persons who are presumed to be LMI Lim. Clientele Class: *If Limited Clientele designation requires income verification for eligibility, please provide documentation (Exhibit NO 4)

38. Determination of LMI status is based on the Department of Housing and Urban Development Section 8 Annual Income (24 CFR Part 5) Limits LMI is 80% or less of Area Median Income: – 0-30% Extremely Low Income – 30-50% Very Low Income – 50-80% Low Income OCD is required to report beneficiaries from all 3 categories to HUD LMI DIRECT BENEFIT

39. LMI Direct Benefit objective is divided into two categories Housing – Typically the Community Housing Improvement Program (CHIP) funds the majority of OCD’s housing projects Job Creation/Retention – Typically the CDBG Economic Development Program funds the majority of OCD’s economic development projects LMI DIRECT BENEFIT

40. To qualify a Housing project using LMI Direct Benefit, structures must be occupied by LMI households – Income documentation required from homeowner/household Typical activities include homeowner rehab, rental acquisition/rehab, emergency home repair, homebuyer assistance Starting in FY 2013, home repair is the only eligible housing activity for Community Development Program funding LMI DIRECT BENEFIT

41. Household connections for residential water and sanitary sewer projects are also qualified under the direct benefit national objective To qualify, the housing units must be occupied by LMI households – Income documentation required from homeowners/households LMI DIRECT BENEFIT

42. NATIONAL OBJECTIVE FILE GUIDE LMI Direct Benefit  Community must income verify all households assisted with CDBG funds. Exhibit NO 3a: List of Assisted Households Exhibit NO 3b: Income Verification Documentation Total LMI Households Assisted:

43. To qualify a project using LMI Direct Benefit Job Creation/Retention at least 51% of the jobs created and/or retained must be available to LMI persons – Income documentation is required from new hires/retained employees LMI DIRECT BENEFIT

44. NATIONAL OBJECTIVE FILE GUIDE Economic Development  Community must demonstrate that 51% of jobs created by companies assisted with CDBG funds are made available to LMI persons Name of Company Assisted: Number of Jobs Created: LMI Jobs: Percentage of LMI Jobs: Exhibit NO 6a: Job Creation Summary Certification Exhibit NO 6b: Employee Job Benefit Verification Forms

45. Slum & Blight objective is divided into two categories – Area Basis; addressing conditions in an entire area – Spot Basis; addressing conditions with a single structure or location Regulations located at 24 CFR §§570.208(b) SLUM & BLIGHT

46. Area Basis – Activities are designed to address dilapidated physical environment Not based on income of residents Selected activities must focus on conditions contributing to the deterioration of the area; – Must be defined area & meet definition of slum/blighted area under state/local law SLUM & BLIGHT

47. Area Basis: Must also meet either A or B – (A) The public improvements in the area are in a general state of deterioration – (B) At least 51%* of the properties throughout the area experience one or more of the following conditions Physical deterioration of buildings or public improvements Abandonment of properties Chronic high occupancy turnover rates or vacancy rates in commercial or industrial buildings Significant decline in property values or abnormally low property values relative to other areas in community Known or suspected environmental contamination SLUM & BLIGHT

48. Typical Area Slum & Blight activities include; – Code enforcement – Commercial rehabilitation – Historic preservation – Infrastructure SLUM & BLIGHT

49. Spot Basis – Activities that address specific conditions of blight, physical decay or environmental contamination not in slum & blight area EXAMPLE: Single Building – Activities limited to: acquisition, clearance, relocation, historic preservation, remediation of environmentally contaminated properties, and building rehabilitation SLUM & BLIGHT

50. OCD’s Downtown Revitalization activities are funded under the Slum & Blight National Objective – Downtown Revitalization Program: Area Slum & Blight – Discretionary: Area or Spot Slum & Blight SLUM & BLIGHT

51. NATIONAL OBJECTIVE FILE GUIDE Elimination of Slum/Blight Community must complete building/infrastructure condition survey to demonstrate blighting conditions Exhibit NO 5a: Building or Infrastructure Condition Survey Exhibit NO 5b: Slum/Blight Certification Percentage of Infrastructure/Buildings determined to be blighted

52. OCD does not administer a program with urgent need as the national objective. – Projects can be funded by Discretionary Program – OHCP attempts to qualify projects with either LMI benefit or Slum & Blight. Typical activities include: infrastructure, interim assistance, rehabilitation of community facilities etc. EXAMPLE: – Building destroyed by fire or natural disaster, but hazardous conditions, materials remain at site URGENT NEED

53. Used to address emergency situations To meet the urgent need test: – Existing conditions pose serious and immediate threat to health/welfare of community – Existing conditions are recent (18 months) or recently became urgent – Recipient cannot finance on its own – Other funding sources are not available URGENT NEED

54. CDBG ELIGIBLE ACTIVITIES

55. Variety of eligible activities, including: – Public facility activities – Public services – Planning and administration – Economic Development Regulations located at 24 CFR §570.201 - §570.206 CDBG ELIGIBLE ACTIVITIES

56. Majority of Community Development (Allocation Program & Neighborhood Revitalization) Program dollars expended for: – Public Facility improvements – Public Service Activities* * Neighborhood Revitalization funds cannot be used for public services CDBG ELIGIBLE ACTIVITIES

57. Public Facilities – Infrastructure Streets, sidewalks, water, sewer – Neighborhood Facilities Parks, playgrounds, community centers – Facilities for Special Needs Populations Homeless shelters, group homes CDBG ELIGIBLE ACTIVITIES

58. Maintenance and repair of public facilities – Exception: modification for ADA compliance Operating costs – Exception: costs related to CDBG public service activity Buildings for general conduct of government – Exception: modification for ADA compliance General government expenses i.e. trash pick-up or equipment purchase Political activities INELIGIBLE ACTIVITIES

59. Public Services – Employment Job Training – Crime Prevention/Public Safety – Child Care LMI families – Health Health Services Substance Abuse Services CDBG ELIGIBLE ACTIVITIES

60. Public Services – Housing Counseling Energy Conservation Downpayment Assistance Services for homeless persons – Education Literacy Tutoring for LMI children CDBG ELIGIBLE ACTIVITIES

61. Public Services – Welfare Services Self Sufficiency Programs – Services for Seniors Transportation – Recreational Services Boys & Girls Clubs CDBG ELIGIBLE ACTIVITIES

62. Public Service Costs – Labor, supplies, and materials directly related to the provision of eligible services – CDBG may pay for operations and maintenance of facility where service occurs Cannot provide operational support to nonprofits – Costs must be documented CDBG ELIGIBLE ACTIVITIES

63. Public Services Restrictions – The activity is capped at 15% – The service must be: A new service OR A quantifiable increase in the level of an existing service that has been provided by the grantee or another entity on its behalf with local government funding for 12 months prior to the request for funds CDBG ELIGIBLE ACTIVITIES

64. “Quantifiable Increase” restriction does not mean that a currently funded service organization needs to do more each year CDBG funds can be used for services previously supported by local government, ONLY in instances where the government no long has necessary funds. – Local governments cannot shift funds to new activities and use CDBG to cover services CDBG ELIGIBLE ACTIVITIES

65. Public Services – Income payments (payments to households) – On-going operations as a stand alone public service – Political activities – Religious activities Eligible services can be provided by religious entity if there is no discrimination or religious instruction required INELIGIBLE ACTIVITIES

66. National Objective Citizen Participation Fair Housing/Civil Rights Environmental Review Financial Management Acquisition/Relocation Procurement Construction and Contract Management Labor Standards Grants Management System FEDERAL/STATE REQUIREMENTS

68. CITIZEN PARTICIPATION

69. Why is Citizen Participation important? – It is required – It establishes and prioritizes the needs of the residents and beneficiaries – It gives residents a community voice – It depoliticizes the process Regulations located at 24 CFR 570.486(a)(5) and 91.105(e)(1)

70. Requires communities to establish a Citizen Participation Plan, which provides for Local Government requirements – The plan should include methodologies to encourage the participation of LMI residents for which the CDBG program was designed to serve CITIZEN PARTICIPATION

71. Citizen Participation File Guide Community: Grant Number: General Information Notes: Community must have a citizen participation plan updated within the last five years of program inception Exhibit CP 1: Community Citizen Participation Plan Plan Last Updated: Note:Subsequent plan updates do not have to be included retroactively

72. Solicitation of Projects Counties must solicit projects from local jurisdictions at least 30 days prior to application due date Counties must maintain documentation of solicitation and criteria/ranking for selecting projects CITIZEN PARTICIPATION

73. Citizen Participation File Guide Counties must solicit projects from local jurisdictions at least 30 days prior to application due date Applicable Not Applicable Exhibit CP 3a: Proof of solicitation (e.g. letter) Date of Solicitation: Exhibit CP 3b: Criteria for ranking/selecting projects

74. Public Notices A minimum of 2 notices is required for participation in the CDBG Community Development Program – The second notice is required to be project specific Regulations located at 24 CFR 570.486 CITIZEN PARTICIPATION

75. Public Hearing #1 Notification – Notice should be published in newspaper easily accessible in the area (other options for notification) – Notice should identify approximate Formula Allocation amount – Notice should also list all CDBG, HOME, and OHTF programs for which the community may apply during given fiscal year CITIZEN PARTICIPATION

76. Public Hearing #1 – Notice should include a summary of Formula Allocation program requirements – Notice should include national and state objectives – Notice should include date local and state applications are due – Notice must include date, time, and location of Public Hearing #1 – Notice must be published at least 10 days prior to Public Hearing #1 CITIZEN PARTICIPATION

77. Public Hearing #1 Requirements – Community should maintain a copy of the notice in the project file – Community should also maintain minutes of the hearing and a list of attendees – Community should establish a Citizens’ Complaint File Community is required to respond to complaints thoroughly and within 15 days – All documentation should be maintained in the project file CITIZEN PARTICIPATION

78. CITIZEN PARTICIPATION FILE GUIDE First Public Hearing Date: Notice must be published at least 10 days prior to public hearing Notification method used: Newspaper Legal Ad Alternative Notification Method OCD 07-01 Exhibit CP 4a: Public Hearing Notice Date of Publication: Exhibit CP 4b: Verification of Publication (newspaper or alternative method) Did public notice provide required information (e.g. allocation amount, programs) YesNo Community must maintain public hearing documentation Exhibit CP 4c: Sign-in Sheets for First Public Hearing Exhibit CP 4d: Minutes for First Public Hearing

79. CITIZEN PARTICIPATION FILE GUIDE Community must have a citizen complaint file that includes a copy of the Citizen Complaint Policy Exhibit CP 2a: Citizen Complaint File Exhibit CP 2b: Citizen Complaint Policy Were any questions/complaints received for this grant: Yes No If Yes, did the community respond within 15 days: Yes No Exhibit CP 2c: Community must retain records of any citizen complaints

80. Public Hearing #2 Notice – Same publication requirements – Notice should include proposed activities to be undertaken – Notice should include amount and source of funds (CDBG, HOME, etc.) allocated for each activity – Notice should include National Objective to be met by each activity – Notice should include timetable of activities to be undertaken CITIZEN PARTICIPATION

81. Public Hearing #2 Requirements – Same procedure as Public Hearing #1 – Community should maintain A copy of the notice Minutes of the hearing A list of attendees A Citizens’ Complaint File – Documentation should be maintained in the project file CITIZEN PARTICIPATION

82. CITIZEN PARTICIPATION FILE GUIDE Second Public HearingDate: Notice must be published at least 10 days prior to public hearing Notification method used: Newspaper Legal Ad Alternative Notification Method OCD 07-01 Exhibit CP 5a: Public Hearing Notice Date of Publication: Exhibit CP 5b: Verification of Publication (newspaper or alternative method) Did notice include a list of selected projects with name, location, and anticipated amount YesNo Community must maintain public hearing documentation Exhibit CP 5c: Sign-in Sheets for Second Public Hearing Exhibit CP 5d: Minutes for Second Public Hearing

83. To save time, communities should identify alternate Formula projects at the second public meeting This expedites the application process in the event the community is not awarded matching funds from one of OCD’s competitive programs and is required to select an alternate project CITIZEN PARTICIPATION

84. Special Public Hearings Amendment Public Hearing – If community amends a grant, another public hearing may be required – EXAMPLE: Change of Activity Project Specific Public Hearing – A community can use Public Hearing #1 to meet program requirement for Economic Development, Residential Public Infrastructure or Community Housing Improvement Program – Second Public Hearing must be project specific CITIZEN PARTICIPATION

85. Citizen Participation File Guide

86. Amendment Public HearingApplicableNot Applicable Notice must be published at least 10 days prior to public hearing Date of Hearing: Notification method used: Newspaper Legal Ad Alternative Notification Method OCD 07-01 Exhibit CP 6a: Public Hearing Notice Date of Publication: Exhibit CP 6b: Verification of Publication (newspaper or alternative method) Did notice include a description of the proposed amendment YesNo Community must maintain public hearing documentation Exhibit CP 6c: Sign-in Sheets for Amendment Public Hearing Exhibit CP 6d: Minutes for Amendment Public Hearing

87. Revisions to Public Hearing requirements – Published newspaper notice – Post a notice in common areas of city hall/county courthouse – Post a notice in acquired cities, villages, and township halls (investment areas) – Post a notice at other locations frequented by the public and/or targeted population i.e. libraries, schools, senior center, community center – Post a notice on local government’s website CITIZEN PARTICIPATION

88. Revisions to Public Hearing requirements – Community must provide verification that at least 3-5 of the approved outreach outlets were used to notify the public of the public hearing Print out from website Copy of notice List of posted locations – Communities are still required to give at least 10 days notice, maintain minutes & an attendance list for the hearing, and follow citizen complaint procedures All guidelines can be found in OCD Notice 07-01 CITIZEN PARTICIPATION

89. QUESTIONS?

90. CASE STUDIES

91. PASQUARIELLO COUNTY Pasquariello County submitted an application to assist the Johnstown Township Fire Department with the purchase of a fire truck and related equipment. Johnstown Township has a population of 400 residents, 62.5% (250) LMI. The Johnstown Township Fire Department also serves the Village of Davidsville and the unincorporated area of DJ. Davidsville has a population of 1000, 25% (250) LMI and DJ has a population of 100, 10% (10) LMI.

92. PASQUARIELLO COUNTY Is the project eligible? Does the project meet a national objective? Will Pasquariello County be approved for funding for this project?

93. PASQUARIELLO COUNTY Is the project eligible? Activity Purpose: Public Facilities Activity Name: Fire Protection Facilities and Equipment

94. PASQUARIELLO COUNTY Does the project meet a national objective? What is the service area?: Johnstown Township, Village of Davidsville, and the unincorporated area of DJ Total population of 1500 residents (400 +1000 + 100)/510 (250 + 250 + 10) LMI = 34% LMI

95. PASQUARIELLO COUNTY Will Pasquariello County be approved for funding for this project? NO

96. GIFFINVILLE Giffinville has requested CDBG funds to purchase ADA playground equipment for Betsytown Park. Betsytown Park is a neighborhood park, which serves residents of 2 Census Tracts on the west side of Giffinville. Giffinville has a population of 18000. 11000 or 61.1% of the population is LMI.

97. GIFFINVILLE Giffinville includes the following Census Tracts: – CT 1 (North Side): Population 5000/4000 LMI (80%) – CT 2 (East Side): Population 2000/1500 LMI (75%) – CT 3 (South Side): Population 3000/2000 LMI (66.7%) – CT 4 (West Side): Population 4000/2000 LMI (50%) – CT 5 (West Side): Population 4000/1500 LMI (37.5%)

98. GIFFINVILLE Is the project eligible? Does the project meet a national objective? Will Giffinville be approved for funding for this project?

99. GIFFINVILLE Is the project eligible? Activity Purpose: Public Facilities Activity Name: Parks and Recreation Facilities

100. GIFFINVILLE Does the project meet a national objective? Who will benefit?: Giffinville - West Side Project does not meet the area wide LMI benefit national objective Project does not meet the Limited Clientele national objective because disabled children is not one of the automatic categories

101. GIFFINVILLE Will Giffinville be approved for funding for this project? NO

102. MICHAELTON Michaelton has applied for CDBG funding for the purchase of 16 garbage trucks for city-wide refuse collection Michaelton has a population of 6000. 4500 (75%) residents are LMI

103. MICHAELTON Is the project eligible? Does the project meet a national objective? Will Michaelton be approved for funding for this project?

104. MICHAELTON Is the project eligible? General Conduct of Government NO

105. LEASUREVILLE Leasureville has a population of 5001. 2000 (39.9%) of the residents are LMI. Leasureville has submitted an application for CDBG assistance with a Wastewater Treatment Plant improvement project. The Wastewater Treatment Plant will serve the entire city. The Wastewater Treatment Plant is located in 1 of the city’s 4 Census Tracts. The Census Tract is 58% LMI.

106. LEASUREVILLE Is the project eligible? Does the project meet a national objective? Will Leasureville be approved for funding for this project?

107. LEASUREVILLE Is the project eligible? Activity Purpose: Public Facilities Activity Name: Water and Sanitary Sewer Improvements

108. LEASUREVILLE Does the project meet a national objective? Who will benefit?: Leasureville Project does not meet the area wide LMI benefit national objective because the city is not at least 51% LMI The project cannot be qualified based on the 1 LMI Census Tract because the Wastewater Treatment Plant serves the entire city

109. LEASUREVILLE Will Leasureville be approved for funding for this project? NO

110. NORTH NORTONSBURG North Nortonsburg has a population of 6000, 3000 (50%) LMI. The city is comprised of 2 Census Tracts: – CT 1: 4000/1900 (47.5% LMI) – CT 2: 2000/1100 (55% LMI) North Nortonsburg has applied for CDBG assistance for 2 separate park improvement projects

111. NORTH NORTONSBURG Project 1: Construction of a baseball field and modification of an existing restroom facility for ADA accessibility at Smith Park. Project 2: Purchase and installation of park benches and picnic tables and construction of a restroom facility at Michael Park. Smith Park serves the entire city and provides amenities not found at other parks in the city. Michael Park is a neighborhood Park that only serves Census Tract 2 (55% LMI)

112. NORTH NORTONSBURG Are the projects eligible? Activity Purpose: Public Facilities Activity Name: Park and Recreation Facilities

113. NORTH NORTONSBURG Do the projects meet a national objective? Project 1 Who will benefit?: Entire city Project does not meet the area wide LMI benefit national objective because the city is not at least 51% LMI However, restroom modification activity can be completed under Limited Clientele national objective

114. NORTH NORTONSBURG Do the projects meet a national objective? Project 2 Who will benefit?: Census Tract 2 Project meets the LMI area wide benefit national objective. Therefore, all of the proposed improvements are eligible. YES

115. MARYTOWN Marytown submitted an application for funding for ADA accessible curb cuts and sidewalk improvements. Marytown proposes to complete 20 ADA curb cuts and 12,000 linear feet of sidewalk improvements. The improvements will be made city-wide. The application lists the national objective as LMI – Limited Clientele Marytown has a population of 9,500. Marytown is 42% LMI by Census

116. MARYTOWN Is the project eligible? Does the project meet a national objective? Will Marytown be approved for funding for this project?

117. MARYTOWN Is the project eligible? Activity Purpose: Public Facilities Activity Name: Sidewalk Improvements

118. MARYTOWN Does the project meet a national objective? Who will benefit?: Marytown Activities are not limited to Limited Clientele activities that will benefit eligible Limited Clientele groups ADA curb cuts would meet a national objective, but the sidewalk improvements would not

119. MARYTOWN Will Marytown be approved for funding for this project? NO Marytown would be asked to restructure the project to only complete ADA improvement projects to benefit the Limited Clientele population

120. QUESTIONS?