The CDBG entitlement community thread

[Suburb Repairman]

You sound liike you've got a frickin' mess on your hands. I'm pretty confident you'll get hit for repayment unless they consider your HUD rep partly responsible for not addressing it earlier. I'm kind of shocked by your situation; down here HUD reps don't react well to being brushed off and will come back with somebody less pleasant in tow (OIG). But I think you're stuck anyway--you might get your knuckles whacked for failing to do just Davis-Bacon or your Environmental properly, but project ineligibility is a deadly sin. My advice, when it comes to repayment, is to ask whether it can be docked from future allocations rather than as a direct clawback.

[kjel]

Exactly, just imagine that not only was there no before and after pictures, there was also no application, agreement or anything else. Then, imagine that the money wasn't even spent on an eligible project. ehhh.

Sounds much like what happened in Newark underneath the previous mayor (went to jail) who was in office for 20 years. Right now the down payment assistance program for low and moderate income residents is frozen by HUD until they deal with all the "old business" of lapsed HOME/CDBG contracts.

[luckless pedestrian]

Hey I have frozen funds too from past practices - we could form a club!

Nothing like being the elephant in the room at a county CDBG meeting where other towns are competing for CDBG funds and I'm an entitlement community - that was yesterday

then my wastewater committee wants to declare a public health emergency so we can use all our money for a town wide sewer system - uh...

that was yesterday!

[oktaren]

Hey I have frozen funds too from past practices - we could form a club!

Nothing like being the elephant in the room at a county CDBG meeting where other towns are competing for CDBG funds and I'm an entitlement community - that was yesterday

then my wastewater committee wants to declare a public health emergency so we can use all our money for a town wide sewer system - uh...

that was yesterday!

Yep, sounds very familiar. Even though much of the previous administration is gone, we are stuck with the same cdbg administrator as before...they won't get rid of him. It's been much of the same...

You sound liike you've got a frickin' mess on your hands. I'm pretty confident you'll get hit for repayment unless they consider your HUD rep partly responsible for not addressing it earlier. I'm kind of shocked by your situation; down here HUD reps don't react well to being brushed off and will come back with somebody less pleasant in tow (OIG). But I think you're stuck anyway--you might get your knuckles whacked for failing to do just Davis-Bacon or your Environmental properly, but project ineligibility is a deadly sin. My advice, when it comes to repayment, is to ask whether it can be docked from future allocations rather than as a direct clawback.

Yes, I do. It has been interesting to say the least. The HUD rep should have done something earlier but he doesn't seem to know what he is really doing either. Trying to navigate the past issues is hard enough but having a HUD rep that is difficult to work with and who gives us contradictory information every time we talk to him isn't helping.

I have come to the realization that we definitely will be facing some sort of repayment. It is just s question of how much. We also received an additional cdbg-r grant that made the list of 50 worst recovery projects. The money wasn't spent on what it was supposed to be spent on, the expenditures werent even eligible projects and we are looking at a repayment on that as well.

[btrage]

We were directed last week by the field office to reduce planned 2013 funds by 5%.

[Masswich]

We just got guidance to plan for a 5% increase. It comes around in a complicated way, a cut but from a higher baseline, but there you have it. We had been planning for an 8% cut, now its a 5% increase. Funny how that works.

[hilldweller]

My biggest beef with the CDBG program is the high administrative costs that come from dealing with all of the red tape/bureaucratic rules. Before the money "hits the street", so to speak, a hefty chunk of it has to go to pay for the salaries of the bureaucrats which administer the program at the federal, state, and local level. I believe the administrative costs amount to 30% or so across the board, but I could be wrong. The program could be made far simpler, and there doesn't need to be nearly as many hands involved. And then there is the costs involved with dealing with the absurd Davis-Bacon act which means the money ends up enriching politically-connected contractors rather than the needy poor. Imagine how much further the money would go towards housing rehab (to take one example) if the contractors didn't need to make 50 dollars an hour to hang sheetrock. The democratic machines in older, industrialized cities don't want to see a thing change though. CDBG is too valuable to them for patronage purposes. These cities also benefit from the funding formula which is skewed so heavily towards age of housing stock, when in reality this can be a very misleading indicator of poverty.

And these issues are before we account for the waste due to political interference in the program. Someone commented earlier that there are stringent rules as far as what CDBG funds can be spent on, but that has not been my experience at all. The money needs to be spent for the benefit of low-income census tracts, but this can be justified in various ways. It can be given to non-profits, used to fund municipal positions, or used for planning studies (more studies of poverty, essentially).

I know some will take offense to my comments as overly negative/cynical, but to be honest I'm pretty upset with planners constantly being cheerleaders for this deeply flawed program.

[OfficialPlanner]

Davis Bacon applies to all federally funded construction contracts... it's not something unique to CDBG. Just my two cents.

[luckless pedestrian]

yes, I can use part of the funds for my hours administering the program which is surprisingly high (the time complaining alone...lol/smirk)

sadly it takes the same amount of hours for a 24,000 project as it does for a 2.4 million dollar project - that' what's so crazy imho

our county admin told me level funding is our possibility

I am shocked the sequester didn't hit HUD

the best things I use cdbg for, though, in the positive, are the infrastructure improvements the town cannot afford and the programming/services - it's really the admin that is tough -

[Masswich]

My biggest beef with the CDBG program is the high administrative costs that come from dealing with all of the red tape/bureaucratic rules. Before the money "hits the street", so to speak, a hefty chunk of it has to go to pay for the salaries of the bureaucrats which administer the program at the federal, state, and local level. I believe the administrative costs amount to 30% or so across the board, but I could be wrong. The program could be made far simpler, and there doesn't need to be nearly as many hands involved. And then there is the costs involved with dealing with the absurd Davis-Bacon act which means the money ends up enriching politically-connected contractors rather than the needy poor. Imagine how much further the money would go towards housing rehab (to take one example) if the contractors didn't need to make 50 dollars an hour to hang sheetrock. The democratic machines in older, industrialized cities don't want to see a thing change though. CDBG is too valuable to them for patronage purposes. These cities also benefit from the funding formula which is skewed so heavily towards age of housing stock, when in reality this can be a very misleading indicator of poverty.

And these issues are before we account for the waste due to political interference in the program. Someone commented earlier that there are stringent rules as far as what CDBG funds can be spent on, but that has not been my experience at all. The money needs to be spent for the benefit of low-income census tracts, but this can be justified in various ways. It can be given to non-profits, used to fund municipal positions, or used for planning studies (more studies of poverty, essentially).

I know some will take offense to my comments as overly negative/cynical, but to be honest I'm pretty upset with planners constantly being cheerleaders for this deeply flawed program.

I don't take much offense but some of your comments are factually incorrect. There are caps on the various uses- 20% for administration and general planning, 15% (generally) for social services, and the 65% balance for other activities. While most communities don't use the full 20% to administer the grant, they do generally take the full 20% to do general planning. The CDBG program has determined that land use planning within that cap is eligible. And I know many communities that would do far less long-range planning without that funding. Is that a bad thing? If so it is easily amended by changing the CDBG regulations.

The social services should probably be at higher than 15%. But why is it so bad to give those funds to worthy non-profits?

As for Davis-Bacon and other red tape, I fully agree that these should be relaxed.

Mend it, don't end it.

[hilldweller]

While most communities don't use the full 20% to administer the grant, they do generally take the full 20% to do general planning. The CDBG program has determined that land use planning within that cap is eligible. And I know many communities that would do far less long-range planning without that funding. Is that a bad thing? If so it is easily amended by changing the CDBG regulations.

My point was that if the funding is going to planning (government planners and outside consultants)- is this consistent with the CDBG program objective of helping low income individuals?

Regarding the social service agencies, there are worthy non-profits and others that are not worthy. It is my opinion that these agencies should raise their own funding and not have to rely on the government, but that is a whole other issue.

[kjel]

My point was that if the funding is going to planning (government planners and outside consultants)- is this consistent with the CDBG program objective of helping low income individuals?

Regarding the social service agencies, there are worthy non-profits and others that are not worthy. It is my opinion that these agencies should raise their own funding and not have to rely on the government, but that is a whole other issue.

At the non-profit I work at we have received small amounts of CDBG funding over the years. Most of the grant allocations have been under $100,000 in value and have been for a variety of projects: a pocket park, neighborhood quality of life plan which has now been incorporated in the brand new master plan (there hasn't been a complete one in decades), and a number of small awards to improve building facilities that provide free early childhood education programs to city residents.

CDBG makes up a miniscule amount of our budget, less than 1%.

[Masswich]

My point was that if the funding is going to planning (government planners and outside consultants)- is this consistent with the CDBG program objective of helping low income individuals?

Regarding the social service agencies, there are worthy non-profits and others that are not worthy. It is my opinion that these agencies should raise their own funding and not have to rely on the government, but that is a whole other issue.

Got it. I think the rationale for why using CDBG funds for planning benefits low-mod individuals is that, but for those funds, those communities might not plan at all. And baked into that rationale is that planning is good for a community, so low-mod residents should get to have their communities planned.

I can see why you might not agree with that line of reasoning. I happen to think it makes some sense.

As for the social service agencies, I think HUD also wants them to raise their own funds and sees CDBG funds as "startup funding" only. That's not how it gets used, in large part because even with fundraising these agencies can't make their budgets work. But again, I can see your perspective.

[luckless pedestrian]

just to give examples of how I use my social service amounts:

supplement the emergency fuel fund program run out of the community center - I give 5k but they raise another 15k on top of that
supplement the community kettle dinner - it's run by volunteers but I help pay for the food
pay for part of the distribution cost from the food bank to our food pantry
ancillary cancer services (not covered by health insurance or medicare-like programs) to low mod cancer patients - that is counseling, massage therapy that is proven to reduce pain from chemo/radiation
coach-like counseling to low mod folks to help them re direct their lives

I am not the primary source, but a supplement/support

I would rather use my admin moneys for plannign studies but the town's policy is to use those funds to cover my hours, as well as the town manager's and the finance officer's time

my construction projects are sewer improvements, sidewalks, and renovations for slum and blight to a museum and an old apothocary shop in the downtown

[Saguaro]

Has anyone here gone through the process of becoming an entitlement community? We were invited by HUD to become entitlement a few years ago but declined due to the economy. Now City Council wants to revisit the issue. However, we have received about the same amount in CDBG funds through our competitive grant applications to the State-assisted program than our anticipated allocation. I think if they are similar amounts it isn't worth it due to the costs of creating the Consolidated Plan, Impediments to Fair Housing, etc. which we currently do not have. Plus I don't have to do IDIS or the CAPER. Just wondering if anyone else has been through this,how decision was made, and how the transition went.

[OfficialPlanner]

http://www.politico.com/story/2013/0...dbg-92998.html

Saw this the other day. House budget proposal would nearly halve funding levels. More than a billion less than the 1975 allocation, when the program was first introduced...

Further commentary- http://www.washingtonmonthly.com/pol...cdbg045364.php

[luckless pedestrian]

holy crap our auditor is so confused by our accounting system for cdbg! I didn't know I carried over cdbg funds - but we don't get the money until it's expended so i figured it's a net zero kind of thing - crap....

[hilldweller]

Has anyone else been following the saga of Westchester County, NY vs. HUD?
http://www.lohud.com/apps/pbcs.dll/a...nclick_check=1

I'm giving Westchester the benefit of the doubt on this. HUD is a dysfunctional and incompetent federal agency with an arbitrary interpretation of "fair housing".

[kjel]

Has anyone else been following the saga of Westchester County, NY vs. HUD?
http://www.lohud.com/apps/pbcs.dll/a...nclick_check=1

I'm giving Westchester the benefit of the doubt on this. HUD is a dysfunctional and incompetent federal agency with an arbitrary interpretation of "fair housing".

Indeed. Funding for some services we provide have been dialed back to next to nothing although we definitely incur costs to deliver those services. So we began charging a modest fee of $50 to cover materials and a smidge of staff time to deliver those services. Mr. Pointy Hair who is our program monitor says "well, there's no yes or no about charging for that particular service, just that it not be excessive and that it not be a barrier for someone to access the service. I personally don't like it or agree to charging for the service." He did not like my reply of "Well since HUD doesn't fully fund the program yet we are expected to deliver it there has to be some middle ground." Mr. Pointy Hair now has a much larger CDC in hi portfolio and they charge $150 for the same service. We heard through the vine that he was pretty much shouted down when he gave them the spiel about charging for services. He made no mention of it on his recent visit.

[Suburb Repairman]

Has anyone else been following the saga of Westchester County, NY vs. HUD?
http://www.lohud.com/apps/pbcs.dll/a...nclick_check=1

I'm giving Westchester the benefit of the doubt on this. HUD is a dysfunctional and incompetent federal agency with an arbitrary interpretation of "fair housing".

This again goes to my fundamental beef with HUD--they provide shit for guidance in regard to fair housing compliance. Instead, the pontificate philosophy from an ivory tower controlled by mal-intentioned advocacy groups (that give the legit ones a bad name). They'll tell you what is wrong, but won't so much as even point you in the direction of a viable solution. They don't provide references to other places that they feel represent a best practice. That being said, Westchester made a major mistake in its settlement in that it didn't work these issues before signing on the line. In fact, one phrase would have made all the difference in Westchester's legal standing now: "HUD shall work in good faith to provide recommendations and technical support to Westchester County to satisfy the requirements of this Agreement."

HUD doesn't even know what good faith is.

Having some familiarity with the Westchester case though, I have to say that they to some extent brought this on themselves.

[DrGrant]

Has anyone else been following the saga of Westchester County, NY vs. HUD?
http://www.lohud.com/apps/pbcs.dll/a...nclick_check=1

I'm giving Westchester the benefit of the doubt on this. HUD is a dysfunctional and incompetent federal agency with an arbitrary interpretation of "fair housing".

The tidbit missing from this article is that the 2009 settlement required the County to promote "source of income" legislation. The county legislators promoted and passed such a law, and then the county administrator turned around and vetoed it. He argued that the county succeeded in "promoting" the law, and his veto was immaterial. Pulling grants due to the lack of a zoning analysis report does seem petty, but it seems there was more to the story.

[luckless pedestrian]

ack Davis Bacon is rough on rural communities when the excavator operator also digs ditches and is a flagger... all at once

[kjel]

ack Davis Bacon is rough on rural communities when the excavator operator also digs ditches and is a flagger... all at once

It's hard on any community. I love their neat little classifications for trades which have nothing to do with what it is you need. When in doubt, pay the higher rate.

Says the lady who has to pay $52/hour to someone for putting construction debris in a dumpster......

[Brocktoon]

The neighboring community is looking at giving back its CDBG funds. I feel terrible for their CDBG grants team. Most project that can be use CDBG council will not support (no housing programs). Several council members want to get rid of all federal funds and give them back to the fed since they are "broke." They have backed off on transportation and public safety grants but CDBG is right in the cross hairs.