2015 CDBG Application Guidelines

2015 CDBG Application Guidelines
State of South Carolina
Community Development Block
Grant Program
2015 - 2016
Application
Guidelines
South Carolina Department of Commerce Division of Grants Administra on State of South Carolina
Community Development Block Grant Program
2015 Application Guidelines
State of South Carolina
Department of Commerce
Grants Administration
1201 Main Street, Suite 1600
Columbia, South Carolina 29201
Telephone (803) 734-0429  Fax (803) 734-0385  TDD (803) 734-1046
www.cdbgsc.com
February 2015
POLICY OF NON-DISCRIMINATION
The State of South Carolina does not discriminate on the basis of age, race, color, religion, sex, national origin,
disability or familial status in the admission or access to, or treatment or employment in, its federally assisted
programs or activities. Dick Scott, Department of Commerce, Grants Administration, 1201 Main Street, Suite 1600,
Columbia, SC 29201, Phone (803) 734-0429 (VOICE) or (803) 734-1046 (TDD), has been designated to
coordinate compliance with the non-discrimination requirements of the CDBG program.
CONTENTS
Grants Administration Staff Contact List
Councils of Government Contact List
Overview .........................................................................................................................................1 CDBG Program Goals and Outcomes ...........................................................................1 Eligible Applicants.........................................................................................................2 Types of Applications ....................................................................................................2 Eligible Activities ..........................................................................................................4 Community Development Program Categories .............................................................4 Application Process ......................................................................................................................18 Phase One: Determine Community Needs ....................................................................................20 Citizen Participation.....................................................................................................20 Community Development Needs Assessment .............................................................25 Phase Two: Project Identification ..................................................................................................27 Phase Three: Project Development ................................................................................................28 Phase Four: Application Development ..........................................................................................29 Requesting an Application ...........................................................................................29 Apply for Funding........................................................................................................29 Meeting a National Objective ......................................................................................30 Developing Project Design ..........................................................................................45 Developing Cost Estimates and Preliminary Budgets .................................................68 Requirements and Certifications ..................................................................................74 Submit Application to Grants Administration .............................................................82 Phase Five: Selection Process ........................................................................................................83 Other Program Categories ..........................................................................................................85 Regional Planning Program .........................................................................................85 Business Development Program ..................................................................................86 2015 – 2016 Application Guidelines
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Attachments
Eligible Activities
Eligible Activities from the Housing & Community Development Act
Requesting an Application
Community Development
Business Development
Determining Community Needs
Notice of Citizen Participation Plan Public Hearing
Notice of Citizen Participation Plan Availability for Review
Notice of Public Hearing Concerning Needs Assessment
Notice of Public Hearing Concerning Application
Meeting a National Objective
2014 Income Limits – Updated July 2014 (effective until updated by HUD) *
Local Income Survey for CDBG Applications
Sample Ordinance Defining Slum and Blighted Area
Sample Resolution Declaring Slum and Blighted Area
Preparing Budgets
Fees for Professional Engineering
Housing Initial Property Assessment
Other Requirements
Residential Anti-Displacement Plan
Determination to Demolish (H-1)
Business Development Assistance Program
2015 Jobs Tax Credit Designations for County Status
County Per Capita Incomes & Average Wages
Business Development Applicant/Employee Information and
EEO Reporting
* The 2015 income limits are expected to be published by HUD by late February 2015 and will supersede the 2014 limits.
GRANTS ADMINISTRATION STAFF CONTACT LIST
Name, Title
Brittany Avant
Phone
Number
Email Address
803-737-0472
[email protected]
803-734-0221
[email protected]
803-734-0568
[email protected]
803-734-0452
[email protected]
803-734-0429
[email protected]
803-734-1125
[email protected]
803-737-1988
[email protected]
803-734-0555
[email protected]
803-737-1993
[email protected]
803-734-2466
[email protected]
803-734-0709
[email protected]
Grants Manager: Upper Savannah and
Lower Savannah Regions
Dale Culbreth
Senior Grants Manager: Economic
Development Program
Jill Francisco
Grants Manager: Appalachian and
BCD Regions
ARC Program
Lisa Kalsbeck
Assistant Director, Federal Programs
Joyce Straiter
Administrative Assistant
Keely McMahan
Program Administrator
Liese Ross
Program Planning, Data Management
and Reporting
Dick Scott
Compliance Specialist: Environmental,
Acquisition, Relocation, Fair
Housing/Equal Opportunity and
Section 504 Disability Requirements
Stefanie Smith
Grants Manager: Catawba, Central
Midlands, Lowcountry Regions
Martha Whitaker
Grants Manager: Santee-Lynches,
Pee Dee, Waccamaw Regions
Lauren Wise
Planning Manager/Compliance
Specialist - Procurement, Contracts
and Labor
COUNCILS OF GOVERNMENT CONTACT LIST
COG Name, Address, Counties Served and Contacts
Phone
Fax
Appalachian Council of Governments
Post Office Drawer 6668, Greenville, SC 29606
www.scacog.org
 Counties: Anderson, Cherokee, Greenville, Oconee,
Pickens, Spartanburg
 Director: Steve Pelissier
 Contacts: Dirk Reis, Caroline Wilson, David Acker,
Chip Bentley, David Shellhorse, Jennifer Vissage
864-242-9733
864-242-6957
Upper Savannah Council of Governments
430 Helix Road, Greenwood, SC 29646
www.uppersavannah.com
 Counties: Abbeville, Edgefield, Greenwood, Laurens,
McCormick, Saluda
 Director: Patricia Hartung
 Contacts: Pam Davenport,
Christine Schwartz, Keith Smith
864-941-8050
864-941-8090
Catawba Regional Council of Governments
Post Office Box 450, Rock Hill, SC 29731
www.catawbacog.org
 Counties: Chester, Lancaster, Union, York
 Director: Randy Imler
 Contacts: Grazier Rhea, Jason Vance, Robert Moody,
Sherron Marshall
803-327-9041
803-327-1912
Central Midlands Council of Governments
236 Stoneridge Drive, Columbia, SC 29210
www.centralmidlands.org
 Counties: Fairfield, Lexington, Newberry, Richland
 Director: Benjamin J. Mauldin
 Contacts: Cyndi Gawronski, Eartha Burrell,
Wayne Shuler
803-376-5390
803-376-5394
Lower Savannah Council of Governments
Post Office Box 850, Aiken, SC 29802
www.lscog.org
 Counties: Aiken, Allendale, Bamberg, Barnwell,
Calhoun, Orangeburg
 Director: Connie Shade
 Contacts: Jeff Derwort, Leslie Crawford,
Jennifer Tinsley, Missy Freitas
803-649-7981
803-649-2248
COG Name, Address, Counties Served and Contacts
Phone
Fax
Santee-Lynches Council of Governments
Post Office Box 1837, Sumter, SC 29151
www.santeelynchescog.org
 Counties: Clarendon, Kershaw, Lee, Sumter
 Executive Director: Michael Mikota
 Contacts: Kyle Kelly, Sharon Durden, Kathy Powell
803-775-7381
803-773-9903
Pee Dee Regional Council of Governments
Post Office Box 5719, Florence, SC 29502
www.peedeecog.org
 Counties: Chesterfield, Darlington, Dillon, Florence,
Marion, Marlboro
 Director: Johnny Brown
 Contacts: Shannon Munoz, Mary Helen Geries
843-669-3138
843-669-0511
Waccamaw Regional Council of Governments
1230 Highmarket Street, Georgetown, SC 29440
www.wrcog.org
 Counties: Georgetown, Horry, Williamsburg
 Director: Sarah Smith
 Contacts: Tom Britton
Jessie Walker, Dan Newquist, David Gray
Berkeley-Charleston-Dorchester Council of Governments
1362 McMillan Avenue, Suite 100, N. Charleston, SC 29405
www.bcdcog.com
 Counties: Berkeley, Charleston, Dorchester
 Director: Ron Mitchum
 Contacts: Kathryn Basha, Michele Canon,
Kara Browder
843-546-8502
843-527-2302
843-529-0400
843-529-0305
Lowcountry Council of Governments
Post Office Box 98, Yemassee, SC 29445
www.lowcountrycog.sc.gov
 Counties: Beaufort, Colleton, Hampton, Jasper
 Director: Sabrena Graham
 Contacts: Michelle Knight, Kimberly Mullinax,
Barbara Johnson, Rhonda Davis
843-726-5536
843-726-5165
OVERVIEW
The South Carolina Community Development Block Grant (CDBG) Program is designed to
provide assistance to units of general local government in improving economic opportunities and
meeting community revitalization needs, particularly for persons of low and moderate income.
The CDBG program has been funded through the State since 1982 by the U.S. Department of
Housing and Urban Development (HUD) under the Housing and Community Development Act
of 1974, as amended (Title I).
The CDBG program is governed by Title I of the Housing and Community Development Act of
1974, as amended, and its implementing regulations for the State Program at 24 CFR Part 570,
Subpart I. All CDBG activities must be carried out in accordance with the requirements of Title
I, Subpart I, the State Consolidated Plan and this Program Description.
Grants Administration, a division of the SC Department of Commerce, administers the annual
allocation from HUD for the CDBG program. Throughout this Program Description, the term
"State" generally refers to the entity administering the CDBG program, i.e., Grants
Administration.
In the following sections, a description of the State of South Carolina's CDBG Program is
presented along with the amount of funds available and the method of distribution of those funds.
Also presented are the categories of grants to be made available, selection criteria, eligible
activities, and the eligibility requirements for applicants.
The State will conduct workshops to assist local governments and other interested parties in the
preparation of grant applications and the administration and management of funded projects in
accordance with program requirements. In addition, the State is available to provide technical
assistance to local governments and non-profit organizations regarding the CDBG program.
CDBG Program Goals and Outcomes
The Department of Commerce seeks to improve the well-being of all South Carolinians in a
manner that supports and enhances a high quality of life. The State CDBG Program supports the
agency’s efforts to strengthen communities through revitalization and improvement of
neighborhoods, public infrastructure, and the local economy.
In an effort to effectively target resources and ensure program accountability, the CDBG
program has incorporated a focus on project outcomes. Shrinking resources on the national and
state levels require that programs provide concrete evidence that their investments are resulting
in the desired outcomes.
The three overarching goals of the CDBG program are to provide decent housing, economic
opportunities and a suitable living environment. Within the context of these goals, each project
must also meet one of three outcomes identified by HUD: affordability, accessibility, or
sustainability.
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Eligible Applicants
Under Title I, all units of general local government are eligible to apply for CDBG financial
assistance with the exception of the eleven large cities and six urban counties that participate in
the CDBG Entitlement program and receive CDBG funds directly from HUD. The ineligible
cities include: Aiken, Anderson, Charleston, Columbia, Florence, Greenville, Hilton Head
Island, Rock Hill, Spartanburg, Summerville and Sumter. The HUD designated urban counties of
Charleston and Greenville as well as the unincorporated areas of the following counties are also
not eligible: Horry, Lexington, Richland, and Spartanburg. Some of the municipalities within
these counties may be included in the HUD entitlement designation and some may not. For an
eligibility determination, please contact the urban county or the state.
For any application to be considered for funding, the applicant must comply with the
requirements of this Program Description as well as applicable federal regulations and state
requirements and submit a complete and acceptable application.
Types of Applications
Individual Application
A unit of local government generally may apply for only one project per application and funding
category, and that project must be designed to address an identified priority need of the
jurisdiction. The single project requirement may be waived if Grants Administration determines
that there is an overriding administrative and/or cost benefit to undertaking separate projects
under one grant or program. Unless a project is being conducted in phases, there should not be
multiple applications to benefit the same target area or persons through the same activity.
Joint Application
Eligible applicants may apply jointly for projects to alleviate common problems or address
mutual need(s) when it is documented that mutual action is required or when it is in the best
interests of all applicants. The necessity or appropriateness for mutual action must be
acknowledged by Grants Administration prior to the submission of an application.
A joint application will be funded as a multi-jurisdictional award and must include an agreement
written in accordance with HUD and Grants Administration procedures which:

States that the parties have agreed to cooperate in undertaking the project,

Delineates the responsibilities and authorities of each party with respect to the
administration of the grant, and

Authorizes one of the parties to be the recipient of the funds and have primary
administrative responsibility.
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Applicants proposing to submit joint applications should contact Grants Administration for
further instructions. The lead jurisdiction in a joint application must comply with program
threshold requirements. Each participating jurisdiction is required to comply with all citizen
participation requirements, certifications and other Title I requirements, as applicable.
Applications for Areas Outside of a Municipal Jurisdiction
Activities must significantly benefit residents of the applicant jurisdiction and the applicant must
determine that the activities will meet a priority need. This determination should be documented
in the needs assessment and public hearing. For an activity to significantly benefit the residents
of the applicant jurisdiction, CDBG funds expended must not be unreasonably disproportionate
to the benefits of the applicant’s residents. Where activities significantly benefit another
jurisdiction or mutual action is required, a County may apply jointly with a municipality to
address the needs of areas outside the jurisdiction of a municipality. Please contact Grants
Administration if a project is not wholly within the proposed applicant’s jurisdiction. It is also
permissible for a County to undertake a project in a municipality without meeting the
requirements of a joint application, since the County's jurisdiction includes the municipality.
Applications Involving an Entitlement Jurisdiction
Generally, state CDBG funds may not be spent in entitlement communities. Residents of
entitlement jurisdictions may only receive an incidental benefit from a state CDBG funded
activity. For projects submitted by eligible State CDBG program applicants that also incidentally
benefit entitlement areas:

The applicant must determine that the proposed activity meets a priority need,

All but incidental beneficiaries must be documented as residing in the non-entitlement
area,

The project must be consistent with the Entitlement’s Consolidated Plan, and

The Entitlement may be required to provide a share of the total project cost equal to the
proportion of Entitlement benefit.
Single or Multiple Activity Projects
Applications may be submitted for single or multiple activity projects, depending on the program
category. For the Community Development Program, multiple activity projects may only be
undertaken in a target area or neighborhood, and all activities must be interrelated. The needs of
the neighborhood being addressed should be included in the applicant’s needs assessment and
the proposed outcome of the activities should determine the appropriate program category. It is
recommended that applicants proposing multiple activities seek technical assistance from Grants
Administration staff prior to applying for funding.
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Eligible Activities
Units of local government may apply for assistance under the appropriate grant program
category to undertake any of the activities specified in Section 105(a) of Title I, as amended. A
copy of Title I, as amended, is available from the State.
Examples of the types of activities that are eligible for CDBG funding are as follows:
acquisition of real property; construction of public facilities and improvements; rehabilitation of
residential and non-residential structures; limited provision of public services; assistance to
neighborhood-based non-profit organizations, local development corporations or for-profit
entities to carry out economic development activities; demolition and clearance; removal of
architectural barriers; and CDBG eligible planning and administration.
Community Development Program Categories
Below is a description of the types of grants available to address the objectives of the State's
CDBG program and the methods of distributing funds for these categories. Each category
includes a description of the objectives, requirements, grant amounts, funding limits, matching
requirements and the selection process. There are three broad grant program categories:
Community Development, Business Development, and Regional Planning. (Business
Development and Regional Planning are discussed later in the Guidelines.) The Community
Development Program is further broken down into several subcategories to address
infrastructure, community facilities, and neighborhood priorities.
Grants Administration will perform due diligence in reviewing each application for feasibility,
fundability, and compliance with program requirements. Site visits will be conducted as
necessary to verify information contained in the application. Applicants should have the
individuals responsible for writing the application, as well as those individuals who are most
familiar with the project area available during the site visit, if requested. The applicant should
ensure that the application is internally consistent and that all numbers are correct prior to
submission.
Grants Administration reserves the right to prescribe revisions in project proposals if activities
prove to be CDBG ineligible, do not address program initiatives, or are not necessary project
components; if proposed project costs are determined to be unacceptable, e.g., costs exceed
CDBG requirements or recommendations; or if there is not enough funding available to fully
fund the request. Additionally, projects should not be submitted for consideration if there is local
controversy regarding the activities or proposed outcomes. Such projects may be returned to the
applicant for local resolution. A conditional grant award or commitment may be issued in the
event there is a delay in receiving the state’s allocation from HUD.
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Community Development Programs
Total Estimated 2015 Funds:
$15,386,624
Description
This program is designed to produce outcomes that improve citizens’ quality of life and create a
competitive environment for jobs and investment by addressing priority community development
needs. Activities should contribute to healthy, safe and sustainable neighborhoods and
communities. These grants are designed to improve the quality of life for distressed and LMI
communities. Community Development projects will compete within the following
subcategories that have the same general submission requirements, except that the Ready to Go
Program will not be funded in a competitive funding round. Applications for this program will be
considered eligible once all required application information is received and if it qualifies for the
minimum score using the non-comparative scoring criteria of the Community Development
Programs. All other Community Development requirements will apply.
Community Infrastructure
Funds Available:
$10,216,505
Grant Maximum:
Grant Minimum:
$750,000*
$50,000
* Waivers of the grant maximum up to $1,000,000 will be considered based on whether the
project addresses an urgent and compelling need, regional solution, or system-wide
improvements (i.e., treatment plant), as well as the extent of leveraging and a reasonable
CDBG cost of $10,000 per household or less. A written waiver request explaining the
rationale must be submitted for consideration with the application request.
Outcome and Priorities
A Community Infrastructure application must contribute to creation of healthy and sustainable
residential communities through water, sewer, roads, drainage or other activities that address one
or more of the priorities listed in order of importance:
1) Significant improvements to existing infrastructure to address health concerns, meet
required quality standards and ensure community sustainability
2) Projects that result in a more viable regional infrastructure solution or that provide new
access to services near business centers where it is cost effective to address a documented
health threat
3) Upgrades to infrastructure to address quality standards where there are only general
health concerns or provide new services that are not near business centers when it is cost
effective to address a documented health threat
Note: Priority will not be assigned to infrastructure improvements that are necessary
because of a lack of maintenance and repairs. Similarly, a priority may not be
assigned if new service is proposed for an isolated neighborhood and there is no
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documented health threat or the service is not cost effective given the number of
households committed to benefit.
Community Enrichment
Funds Available:
$3,000,000
Grant Maximum:
Grant Minimum:
$500,000 *
$50,000
* Due to federal caps on public services/equipment, the number and amount of grants for this
purpose may be limited. Planning grants are also subject to a $25,000 maximum grant.
Outcome and Priorities
This program is designed to fund facilities, services and other activities that strengthen existing
communities and support a high quality of life within the following state priority areas:
1) Increasing economic competitiveness
2) Education and workforce development
3) Safe and healthy communities
Project investments will result in more sustainable development opportunities that contribute to
the long term vitality of communities and business centers. Activities must have the broad
support of citizens and local businesses. Generally, buildings must be owned by the local
government. Long term financial viability of the facilities/services must be demonstrated to
ensure that it does not add an undue, new operating burden on local taxpayers.
A variety of activities are eligible but consideration for funding will be based on state priorities
listed below and in the Community Development Selection Criteria:


First priority - Increasing Economic Competitiveness

Brownfield projects or demolition of obsolete buildings

Downtown streetscape improvements where there is significant business activity and
prior investments. Projects must include a plan for retail/small business support.

Planning for regional infrastructure or brownfields clean up and redevelopment

Public facilities modifications to ensure accessibility for disabled persons or for
energy efficiency improvements for CDBG eligible public facilities that will
significantly reduce operating burdens and promote sustainability (i.e., replacing
windows, upgrading HVAC, etc.)
Second priority - Education and Workforce Development

Libraries - facilities or computer equipment with broadband capability to enhance
skills training and education
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
Publically owned facilities (except operating school facilities) that offer extended
educational opportunities for adult literacy, or to serve at risk LMI children or youth
Transportation-oriented public facilities or services to serve LMI workforce
populations

Third priority - Safe and Healthy Communities

Public safety facilities and services in LMI areas - police substations or other public
improvements designed to address crime prevention

Demolition of vacant, dilapidated structures to address and support crime prevention
efforts in targeted LMI neighborhoods

Fire substations or fire trucks serving LMI residential areas that provide significant
improvement in service for in town locations or near business centers

Health clinic facilities or equipment in underserved areas or multi-service centers for
health or related social services
Equipment for public service activities must be for new or expanded services and generally
associated with a significant capital investment in facilities. Only major pieces of equipment that
have a durable life of five years will be considered for funding.
Neighborhood Revitalization Program
Funds Available:
$1,270,119*
Grant Maximum:
Grant Minimum:
$500,000
$50,000
* A portion of funds available in this program is reserved for Village Renaissance projects
eligible for multi-year funding commitments for phased implementation activities approved
under previous years’ CDBG Program Description. Such projects are subject to the applicable
Program Description requirements when the project was first approved for phased funding,
unless otherwise stated.
Outcome
This program is primarily designed to assist in the development of sustainable communities
through revitalization of in-town residential neighborhoods. Projects must incorporate
comprehensive strategies for linking commercial revitalization successes with improvements to
neighborhoods that are generally adjacent to downtown or business centers. Such neighborhoods
should be within walking distance to downtown or business centers (typically no more than a ½
mile from the downtown or business center). Neighborhoods where significant CDBG and/or
other funds have previously been expended may not be appropriate for this program. A local
government may address no more than one neighborhood at a time.
Neighborhood revitalization can involve a phased program of planning and implementation that
may be funded with CDBG and/or other funds. A locally funded neighborhood revitalization
plan (or previously CDBG-funded Village Renaissance plan) is a pre-requisite to implementation
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funding, and the plan must be submitted to GA with the application for Neighborhood
Revitalization implementation funding. The plan should identify community needs, prioritize
activities designed to comprehensively revitalize the neighborhood with CDBG and other funds,
and set out a realistic plan for implementation of CDBG eligible and other activities in two
possible consecutive implementation phases.
Neighborhood Revitalization Plan
The applicant must submit an acceptable comprehensive revitalization plan for the targeted
neighborhood that involves neighborhood residents in identifying needs and solutions. Plan
elements must include but are not limited to:



Comprehensive needs assessment (qualitative and quantitative) and prioritization:

Land use and housing existing conditions

Infrastructure and public facilities existing conditions

Public safety and services (police, fire, health, education)
Comprehensive strategies for revitalization that guide investments to achieve the
following outcomes:

Improve neighborhood involvement and interaction

Provide safety and neighborhood pride

Address infrastructure and public facilities needs

Identify in fill housing opportunities

Improve physical appearance and property values

Promote sustainability and conservation
Specific actions to prepare for implementation of revitalization strategies:

Cost estimates for CDBG eligible activities and other planned activities

Analysis of acquisition requirements

LMI survey determination for individual activities, as needed

Code enforcement ordinance or other locally adopted and enforceable procedures as
appropriate

Anti-displacement and relocation plan, as appropriate

Maps illustrating existing conditions, problems and proposed solutions

Roles and responsibilities – neighborhood and local government involvement and
commitment in planning and implementation

Time frame for implementation of all strategies, including phased activities
The plan must be submitted to GA for approval with the application for Neighborhood
Revitalization implementation funding.
Implementation Phases
Implementation of comprehensive neighborhood revitalization must involve multiple activities
including a public safety component. Activities to be undertaken must be justified and described
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in the plan. Such activities should be prioritized to address basic infrastructure and safety first
and, where feasible, geographically concentrated within the target area in order to make the
greatest impact. Eligible activities may include:

Infrastructure - water, sewer, roads, drainage

Public facilities - sidewalks, security lighting and cameras, police or fire substations,
technology, multi-service centers designed to address crime risk factors, walking trails,
green space, landscaping

Housing - infrastructure or other activities to support affordable or workforce housing;
limited exterior only improvements including facades, minor repairs, energy efficiency
improvements, handicap accessibility

Demolition and clearance of vacant and dilapidated properties

Public services - crime watch program, drug or gang education, awareness or prevention
programs. (Services are limited to 15% of the CDBG project activity costs, must be new
or expanded services, and applicant must commit to continue such services after the grant
is closed without creating an operating burden on the local government.)
All implementation phases will be competitively selected with no guarantee of funding and must
comply with applicable program threshold and citizen participation requirements for each
funding phase.
Special Projects Program
Funds Available:
$300,000
Grant Maximum:
Grant Minimum:
$150,000
$50,000
Outcome
This program is designed to meet community development needs that are not typically funded
through the other Community Development programs or one of the other HUD partner programs.
These funds will be used for alternative grant activities and partnerships that meet the
community development needs of eligible municipalities. Special projects could include historic
preservation, innovation, energy conservation, parks, and trails/greenways. Projects should have
significant leveraging, impact and community support while meeting a National Objective and
all other requirements.
A variety of activities are eligible but consideration for funding will be based on state priorities
listed below and in the Community Development Selection Criteria:

First Priority

Projects that impact economic development or increase economic competitiveness.
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
Second Priority


Projects that address public health and safety or improve the long-term sustainability
of the community.
Third Priority

Projects that address energy conservation or historic preservation.
Ready to Go Program
Funds Available:
$600,000
Grant Maximum:
Grant Minimum:
$500,000
$50,000
Outcome
This program is designed to stimulate the local economy by addressing urgent or compelling
community needs, encouraging the timely implementation of CDBG eligible projects, and being
cost effective. The project requires an upfront investment of local and other funds for planning,
project design and permitting that is substantially equivalent to the required 10% local match.
The project must be an eligible public facility improvement under the Community Infrastructure
or Community Enrichment program. All required project activities leading up to bidding must be
complete prior to submission of the application including but not limited to: project design,
environmental review, acquisition and permits. CDBG funds may only be used for construction.
Local and other funds must be used for pre-bid activities and will count toward the match
requirements of the program. Projects must be advertised for bid within 60 days of grant award.
Applications will be accepted on an ongoing basis and funding will occur throughout the year,
based on funding availability, when all application documentation has been received. No grant
award will be made until evidence is submitted that all pre-bid activities are complete. Projects
will be reviewed using the non-comparative scoring factors as listed in the Community
Development Program Selection Criteria section. The project must obtain a minimum score of
150 points to be considered eligible for funding. In the event there are more eligible applications
submitted during the same time than funds available, the highest scoring eligible projects will be
funded. Application requests that do not meet all program requirements may be considered in the
appropriate competitive program.
Community Development Program Requirements
A unit of local government, filing individually or as a lead applicant, may submit only one
application per Community Development Program category. A Community Development
Program project may consist of one primary activity and associated activities as appropriate and
necessary to implement the primary activity in one or more eligible target areas, or a project may
consist of multiple activities which address priority needs in one defined LMI neighborhood or
target area.
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The grant award limits for each category may be waived at the discretion of Grants
Administration in order to provide the level of assistance required where other resources are not
reasonably available to the unit of local government to address the need in a timely manner or
where Grants Administration determines the amount is necessary and appropriate to achieve the
State's CDBG Program objectives.
Performance Threshold
As a performance-based incentive, a unit of local government can apply for an additional
Community Development grant if it has no more than two open CDBG grants (excluding
Business Development or Regional Planning grants). However, the open grants must not have
exceeded a 30 month grant period.
There are additional program category threshold limits that apply:

No more than one Neighborhood Revitalization/Village Renaissance or streetscape
project.

No more than one Ready to Go project.

No more than one project for the same general target area/neighborhood open at the same
time (unless the current project is under construction).
For threshold purposes, a grant is considered open if it is not programmatically closed at the time
of application submission. The applicant must submit a request for waiver prior to or with the
application request. At the discretion of Grants Administration, a performance threshold waiver
may be considered only for the following reasons:

There is an urgent or compelling need for immediate assistance, such as an imminent
health threat to the public, or

It is determined that lack of performance on an open grant is due to unavoidable
circumstances or conditions beyond the control of the local government. If problems are
determined to be administrative, the local government may be allowed to apply if a
different grant administrator is responsible for the new application/project.
A unit of local government may not apply for Community Development funds if it has any open
grant which has not been programmatically closed due to the local government's lack of
compliance with significant programmatic or financial requirements of the program. A grant may
not be awarded to a local government which has a serious, outstanding audit or monitoring
finding involving the potential for significant monetary restitution or non-responsiveness on any
previously funded CDBG grant.
Local Match/Leveraging
CDBG projects are expected to leverage other public and private investments and serve as a
catalyst for future development. Projects that traditionally have the greatest long term impact are
those that have an investment by the community. Leveraging of CDBG funds is also considered
a scoring factor in the selection of projects for funding.
There must be a 10% match of the total CDBG request, unless otherwise approved, which can
come from a variety of committed sources including other, non-Commerce grants, loans, waiver
of fees, public or private investments, and documented volunteer or in-kind contributions.
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Any fees for low and moderate income hook up/connection to public water and sewer must be
waived or paid with non-CDBG funds, and may be considered part of the local match
requirement.
The required match must be for activity costs directly related to the CDBG project. The state
must approve in advance any proposed match (except application preparation or environmental
review costs) that has been spent prior to application submission for all projects except Ready to
Go. With prior written approval, the match may be used for acquisition, engineering design or
permitting prior to the submission of the application. This is encouraged so that projects are
construction ready.
The match requirement may be modified or waived by Grants Administration upon written
request and after consideration of the following minimum factors: the nature of the project, the
need being addressed, local financial capacity and the availability of other resources. Grants
Administration may request financial and other information as may be needed to make a
determination. It is unlikely that a 100% waiver will be approved since match can come from a
variety of sources.
Selection Process
Grants Administration will review all of the applications it receives for completeness and
eligibility of activities under federal and state guidelines. Applications will also be reviewed
based on the following factors to determine fundability and feasibility of the project:

Appropriateness of the technical design given the size and resources of the community
and the complexity of the problem

Project is ready to start
Applications that are incomplete or contain significant problems, deficiencies or discrepancies,
such that a determination of the viability or fundability of the project cannot be readily
determined, will not be considered and will be returned to the applicant. Projects which are
locally controversial will not be considered feasible until the controversy is satisfactorily
resolved. Clarifications to the application which are requested by Grants Administration must be
submitted within the timeframe specified and must be acceptable to Grants Administration.
Failure to adequately respond within the timeframe may result in the application being returned
to the applicant or GA may reduce or eliminate questioned activities.
An on-site review of the proposed project may be conducted as necessary to verify information
in the application. Upon completion of the feasibility and fundability review, applications will be
evaluated and scored based on the Selection Criteria below.
Community Distress

5%
(All projects) Projects will be assigned a score from highest to lowest based on location
in one of the Distressed county designations, as defined by the SC Department of
Revenue for the purpose of determining Job Tax Credits
 Tier III and IV (Distressed and Least Developed) Counties = 3
 Tier II (Moderately Developed) Counties = 2
 Tier I (Developed) Counties = 1
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Severity of the Problem


Degree that public health and safety is affected, if applicable, and
Degree facilities/services are currently serving the community and the adequacy of the
facilities/services, as applicable
 Severe need = 3
 Moderate need = 2
 Slight need = 1
Citizen Participation






10%
5%
Outreach efforts to low and moderate income citizens and racial, ethnic and special
population concentrations,
Needs assessment is comprehensive and solicited from broad community,
Project is top 3 priority need unless otherwise justified,
Public hearings held according to requirements,
Participation in hearings by broad community, and
Local leadership, businesses and residents are committed to the project and there is no
evidence of controversy or disagreement
Scores based on review of above factors:
 All requirements met and significant additional efforts and participation = 3
 Above minimum effort but additional effort or participation limited = 2
 Minimum requirements met = 1
Level of Effort

Return on CDBG investment ratio compared to all projects
 Rank ordered and assigned points in logical increments
Feasibility

5%
15%
Effective project planning addresses all aspects of project and outcomes are achievable
 Long term, viable solution to the problem
 Past efforts to solve problem and develop plans for implementation, and
 Alternatives considered and best solution being implemented, and
 Cost estimates current, appear reasonable, all necessary costs included, and
 All project resources are available in a timely manner, and
 Project is eligible and all qualifying households determined and committed
Scores based on review of above factors:
 Effective project planning and ability to achieve outcome with resources available
in a timely manner = 3
 Some concerns which impact ability to achieve outcome in a timely manner = 2
 Significant issues which impact ability to achieve outcome in a timely manner = 1
Readiness to Proceed

5%
Readiness to proceed with project if awarded
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



Environmental review submitted to GA
Site control (if applicable)
Engineer/Architect selected
Design complete
Scores based on review of above factors:
 One point will be assigned for each of the above activities completed, up to a
maximum of three points
Cost/Benefit

5%
CDBG cost/benefit ratio compared to all projects
 Rank ordered and assigned points in logical increments
Beneficiaries
5%

Total persons benefiting (2.5%)
 Rank ordered and assigned points in logical increments

LMI % benefiting (to be scored regardless of the national objective) (2.5%)
 100-85 = 3
 84-65 = 2
 64-51 = 1
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Outcome





20%
Implements a comprehensive plan for revitalization or development
Provides new or improved access to public services or facilities
Supports healthy and safe neighborhoods and community
Contributes to overall community sustainability- economically or environmentally
Acts as stimulus for additional investments
Scores based on review of above factors:
 Significant Impact = 3
 Moderate Impact = 2
 Lower Impact = 1
Project Sustainability

5%
Extent to which improvements can be maintained without creating new, undue tax
burdens
 Infrastructure operating revenues as measured by annual rate per 6,000 gal /
median household income for applicant
 Rank ordered and assigned points in logical increments
 Budgets and market studies indicate ability to sustain improvements and does not
result in new, undue operating burden
Scores based on review of above factors:
 Ability to maintain documented = 3
 Some ability = 2
 Limited ability = 1
State Priorities

10%
Extent to which project proposes to address identified state priorities as listed under each
program category or as shown below.
Community Infrastructure, Community Enrichment, Special Projects and Ready to Go:
 First priority projects = 3
 Second priority projects = 2
 Third priority projects = 1
Neighborhood Revitalization:
 First priority projects located adjacent to a downtown with significant business
activity = 3
 Second priority projects located in town or near business centers = 2
 Third priority projects located in unincorporated areas that would impact
economic competitiveness = 1
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_________________________________ OVERVIEW _________________________________
Capacity
10%
First time applicant or previous recipient with grants closed over three years will receive
maximum points.
Previous applicants - Performance on grants in last three years:




Compliance with program requirements (monitoring and match commitment) (3%)
 All requirements met on all applicable grants = 3
 Requirements are generally met (minor issues) on all grants = 2
 Significant requirements not met on 1 or more grants = 1
Achieved program benefits (3%)
 Total and LMI benefit numbers exceeded or on target for all grants = 3
 Benefit reduced by 10% or less = 2
 Benefit reduced more than 10% = 1
Timely completion of projects (3%)
 All projects completed within 24 months = 3
 All projects completed within 30 months = 2
 All projects completed within 3 years = 1
Timely submission of reports and information (1%)
 All information submitted within required timeframes = 3
 Average of less than 30 days late = 2
 Average exceeds 30 days = 1
Applications will be scored against those submitted in the same program. For example,
Community Infrastructure applications will be compared and scored against each other. The
Selection Criteria will be rated and assigned a score from 1 to 3 where 3 = the best response,
2 = average, and 1 = less than satisfactory. Zero points may be awarded to a criterion if
minimum program requirements are not addressed. The point assignment will be multiplied by
the weight of each criterion to obtain a score. There is a maximum score of 300 points.
Grants Administration may utilize the expertise of other appropriate State agencies, such as the
SC Department of Health and Environmental Control, the SC Budget and Control Board's
Division of Local Governments, or the State Housing and Finance Development Authority in
making a determination regarding the above factors. Grants Administration may request
additional information from the applicant or other sources as necessary to evaluate the
application and proposed project. Grants Administration reserves the right to negotiate or require
changes in activities or funding in order to achieve program objectives. For water and sewer
projects, the State may require that rates be adjusted to appropriate levels to ensure adequate
funding for operation and maintenance or to facilitate borrowing a portion of project costs if such
rate increases are reasonable and appropriate.
In the event of a tie where there are more applications under consideration for funding than there
are funds available, preference will be given first to those applications addressing the highest
state priorities and second, to those with the highest Outcome score. If there continues to be a tie
the one that benefits the most LMI persons will be funded. The highest scoring projects
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determined to be fundable will be recommended to the Secretary of the SC Department of
Commerce, or his designee, for funding based on the amount of funds available. Projects
generally should score at least 175 points to be considered for funding but such projects are not
guaranteed funding. The Secretary, or his designee, will make final funding determinations based
on a review of the projects utilizing the selection criteria and that best meet Department
objectives.
Grants Administration may make commitments for funding from future rounds, or any additional
allocations, reallocations, recaptured or remaining funds, to projects from this program year
which are determined by the Secretary, or his designee, to meet Department objectives. Grants
Administration may also make a commitment to a project and/or partially fund a project (i.e. for
ERR, acquisition, engineering) that scores sufficiently but is not ready due to design,
environmental or funding issues. Funding may come from this program year, reallocated or
recaptured funds, or be contingent on future years’ funding.
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APPLICATION PROCESS
The CDBG program is a flexible tool to address many community and economic development
needs, particularly for low and moderate income persons. Units of local government may apply for
funding through the program categories that were presented in the previous sections. All of the
Community Development Programs are competitive and there are always more applications than
funds available. Therefore, it is extremely important for a local government to make a strong case for
its project and follow the application procedures.
To assist in understanding the application process for the competitive CDBG programs, we have
provided a flow chart outlining the steps necessary to successfully develop a proposal for funding.
As indicated on the chart, there are five basic phases of application development:

Determining Community Needs,

Project Identification and Assessment,

Project Development,

Applying for Funding, and

Project Selection.
Basic elements of each phase are presented on the chart, with greater detail on each phase in the
sections following.
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Community Development Application Process Flowchart
Phase One:
Determine
Community Needs
Develop a Citizen Participation Plan



Identify citizens and organizations that can provide assistance, guidance, and
input into the needs assessment and application process.
Solicit input from broad community and conduct outreach to LMI persons.
Research, analyze and compile documentation on community development
needs, including obstacles to community competitiveness.





Phase Two:
Project
Identification
Evaluate Priority Needs






Phase Three:
Project
Development







Compile documentation for meeting a national objective.
Identify proposed project service area and beneficiaries or customers.
Conduct household income surveys or analyze census data.
Compile documentation indicating market conditions/need for project
(distressed Conditions of community, DHEC letters, preliminary engineering
report, etc.).
Determine how the project will work.
Analyze potential project design and feasibility issues that must be addressed.
Develop cost estimates and preliminary budget.
Submit application request by the deadline.
Complete the Project Proposal






Phase Five:
Project Selection
Process
Determine the most appropriate project to achieve the desired outcome.
Identify a project based on needs assessment.
Review any existing plans relevant to potential project.
Determine if project is feasible under CDBG. Is it an eligible activity and will it
meet a national objective?
Discuss potential project with Grants Administration and obtain technical
assistance.
Seek collaborative partners.
Request Application from Grants Administration

Phase Four:
Apply for CDBG
Funding
Hold Needs Assessment Public Hearing
Publicize and conduct needs assessment public hearing with assistance of
citizens and other partners.
Prioritize needs.
Prepare needs assessment document.
Publicize and conduct public hearing on proposed application.
Document citizen participation efforts.
Obtain local match resolution and partner commitments.
Make sure all project selection criteria have been addressed in the application.
Complete final proposal requirements and obtain local official signatures for
certifications.
Submit proposal to Grants Administration.
Projects Evaluated by Grants Administration





2015 – 2016 Application Guidelines
Grants Administration conducts feasibility review.
Applicant responds to Grants Administration questions.
Grants Administration may conduct site visit with appropriate local staff and
persons familiar with project details (grant administrator, engineer, rehabilitation
inspector, etc.).
If grant is awarded, return signed grant award to initiate project.
If grant is not awarded, contact Grants Administration and obtain technical
assistance.
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______________________ APPLICATION PROCESS – PHASE ONE ______________________
PHASE ONE: DETERMINE COMMUNITY NEEDS
The process begins locally with the involvement and participation of citizens, businesses, nonprofit organizations, and community leaders. Through public hearings and input from the broad
community, especially low and moderate income persons, the community determines its needs,
specifies which needs are obstacles to competitiveness, and develops priorities for addressing
those needs. The needs assessment should cover a broad range of community and economic
development needs, and should be specific about the location of needs (i.e., water and sewer
system improvements needed in the Clark Street neighborhood).
Citizen Participation
It is important that the public have an opportunity to participate in the development and
evaluation of CDBG projects. In fact, this is a requirement under the program regulations. The
citizen participation information included in these Application Guidelines comes directly from
the CDBG Implementation Manual.
Each locality, prior to submission of any application for CDBG funds, must certify that it has
developed a Citizen Participation (CP) Plan. The CP Plan is a document prepared by the locality
that describes the process the community will follow to involve the public in the CDBG
program. As part of this process, each locality is also required to hold public hearings at certain
stages of the process to obtain public input on community development needs and proposed
CDBG activities.
Prior to submission of a CDBG application a locality must accomplish the following steps
to involve citizens:
1) Develop a Citizen Participation Plan. Advertise its availability for review to the public.
This may be done in conjunction with the needs assessment public hearings.
2) Solicit input from local officials, businesses, organizations and citizens on the housing,
economic and community development needs of the community, particularly those of low
and moderate income and minority persons.
3) Advertise or post a notice and hold one or more public hearings to present the identified
needs and to solicit public input and comment on the needs.
4) Develop a written needs assessment which details the specific housing, economic and
community development needs and priorities, including the needs of low and moderate
income persons, and the activities to be undertaken to meet such needs.
5) Develop a CDBG application for one of the highest, eligible, priority community needs
identified in the needs assessment. A copy of the needs assessment and the public hearing
minutes must be included with the CDBG applications for the Community Development
program.
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6) Advertise or post a notice and hold a public hearing on the proposed CDBG application
to solicit public input on the proposed activities.
7) Maintain records of all citizen participation efforts including notices, advertisements for
hearings, logs, minutes and the written needs assessment for five years and make these
available to the public and to Grants Administration, as requested.
Citizen Participation Plan
A community's CP Plan, including the public hearing components, must meet the requirements
for citizen participation found in Section 104 (a)(2) and (a)(3) of Title I of the Housing and
Community Development Act of 1974, as amended, 24 CFR Part 570.486 of the State CDBG
Regulations, and the State Consolidated Plan Regulations at 24 CFR Part 91. These regulations
can be found in the CDBG Reference Manual.
The following guidelines have been developed to assist localities in developing CP Plans. These
guidelines set forth the basic elements that must be included in a community's CP Plan.
Localities may expand upon these basic elements with any additional provisions that are
consistent with the requirements of Title I.

The locality will make its written CP Plan available for public review. This must be
accomplished by either conducting a public hearing or by making the CP Plan available
for public review at a location convenient to residents of the jurisdiction. (See the
Attachments for a sample notice for each of the two options.)

Every year, or prior to the development of any application for CDBG funding, the
community will assess its community development, economic development, and
housing needs, particularly those of low and moderate income residents. This process
is called a needs assessment.

The CP Plan must also provide for citizen participation in the determination of
community needs by stating that the results of the needs assessment will be presented
at one or more public hearings and that citizen comment will be considered.

When the Community Needs Assessment is presented at a public hearing, the
community will also present information concerning the CDBG program, including
the amount of CDBG funds available, State funding guidelines, and the range of
activities that may be undertaken with such funds, particularly in relation to identified
community needs.

All notices of public hearings will be published in specified newspaper(s) of general
local circulation at least seven days prior to any public hearing. Additional
information on notices is provided in the next section.

The locality must describe in its CP Plan other methods, in addition to notices in
newspapers, by which the community will encourage participation by the residents
of slum and blighted areas and areas where CDBG activities are proposed.

Possible methods might include requesting appropriate community leaders and
agencies to inform their constituents (ministers, council members, community action
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agencies, newspaper editors, etc.), distributing notices in low and moderate income
neighborhoods (particularly in potential project target areas), posting of notices at
post offices and neighborhood businesses, and radio and television announcements.

All public meetings concerning the CDBG program must be held at times and
locations convenient to citizens, particularly to those who are the potential or actual
beneficiaries. In addition, the location of such meetings will be accessible to the disabled
or the announcement of such meetings will indicate that assistance will be provided to
accommodate the special needs of disabled persons. It may be appropriate to request
advance notice of special needs so that they can be met.

Technical assistance will be provided to groups that represent LMI persons that
request such assistance in developing proposals for CDBG funding. The unit of
general local government must specify the type and level of assistance to be provided. As
a condition of providing technical assistance, the local government may require that the
activities to be addressed in a proposal be consistent with identified community
development and housing needs and State CDBG Program guidelines, that CDBG funds
be available for funding such activities as may be involved, and that the governing body
of the local government may require approval for providing technical assistance.

The local government must consider for funding any proposals developed by
representatives of LMI persons who follow all of the requirements for public
participation. However, the determination to submit the proposal to the State for funding
consideration is the prerogative of the local elected officials since the submission of any
CDBG application requires approval by the governing body of the community.

The CP Plan must identify how the needs of residents with Limited English
Proficiency (LEP) will be met for public hearings and other activities where a
significant number of such individuals can be reasonably expected to participate.
LEP persons are persons with a limited ability to read, write, speak, or understand
English. Reasonable steps must be undertaken to ensure meaningful access to programs
and activities. HUD suggests that an assessment be conducted to determine a reasonable
level of program outreach to be provided to LEP persons weighing the following four
factors:
1) The number or proportion of LEP persons eligible to be served or likely to be
encountered by the grantee/program;
2) The frequency with which LEP persons come in contact with the program;
3) The nature and importance of the program, activity, or service provided to LEP
persons; and
4) The resources available to the grantee and costs. The capacity of small
jurisdictions to provide comprehensive services may be limited but does not
relieve them from compliance.
After completing the assessment, a recipient should include in its CP plan steps to be
taken to address the identified needs of the LEP populations they serve including
translations of vital documents and other outreach activities. At a minimum, the CP Plan
should indicate that if five percent (or 1,000) of the potential or actual beneficiaries of a
CDBG project are determined to be LEP, provisions will be made at the appropriate
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______________________ APPLICATION PROCESS – PHASE ONE ______________________
public hearings for oral interpretation of comments and/or translation of appropriate
documents into the native language of the majority of the LEP residents affected.

After the development of an application for a CDBG grant and prior to submission
of the grant application, a public hearing will be held to review and solicit public
comment on the proposed activities and to furnish citizens with information on the
following:

The amount of CDBG funds to be available,

The range of activities that may be undertaken,

The amount of funds to benefit low and moderate income persons,

The proposed activities which are likely to result in displacement, and

The local government's anti-displacement and relocation plans.
This hearing must be conducted according to the CP Plan and held no sooner than seven
days following the needs assessment public hearing. (See Public Hearings section below
for more information.)

Prior to making any substantial change in a CDBG-funded project, the locality will
hold one or more public hearings to inform its citizens, particularly those who might
be affected, of the proposed change and solicit public comment. Any substantial
change in the project as described in the approved application will require submission of
evidence that a public hearing was held prior to Grants Administration approval.

The CP Plan must provide for a timely, written answer to written complaints and
grievances, within fifteen working days (where practical). The CP Plan must state the
name, address and phone number of the person to whom written grievances are to be
delivered and the procedures by which grievances will be handled, including any appeal
process.

The CP Plan must provide that, prior to any response to a written grievance which
involves State law or policy, State CDBG program guidelines, or Federal regulations
governing the CDBG program, the community will provide the written grievance and
its proposed response to Grants Administration for review and approval of the
response. The CP Plan must also provide for the appeal of any written grievance to
Grants Administration; however, the CP Plan must state that Grants Administration
will deny those appeals which involve the consistent application of the community's
local program policies. The CP Plan should also indicate that after the appeal process
has been exhausted, the complainant may seek relief in the appropriate court of law.

The locality will conduct one or more public hearings to review program
performance and accomplishments. At least one public hearing must be held when all
activities are completed and prior to Grants Administration closing the grant. (Additional
information on public hearings is provided below.)

Citizens will be provided with reasonable access to records concerning any project
undertaken with CDBG funds. The CP Plan must show the times and location where
such information may be reviewed and any conditions, such as whether a written request
is required.
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
Note: Confidential information normally protected under the State and Federal
Freedom of Information Act (FOIA) Laws may not be made available for public
review. For example, data concerning personal or business financial statements,
earnings or sources of income.
Public Hearings and Notices
Localities are required to hold public hearings at certain stages of the process, as outlined below:

Public Hearing on the CP Plan – This hearing is optional as localities are allowed to
instead make the plan available for review at a location convenient to residents of the
jurisdiction without holding a public hearing. If the recipient chooses to hold a public
hearing on its CP Plan, it may do so in conjunction with the needs assessment public
hearing (discussed below). If a locality is developing a CP Plan for the first time, or is
amending its CP Plan, and chooses not to hold a public hearing, the Notice of CDBG
CP Plan Available for Review must be published no less than seven days prior to the date
of the needs assessment public hearing.

Needs Assessment Public Hearing – This hearing is required at least once every twelve
months (or prior to submission of an application) to discuss and receive feedback on
housing, community and economic development needs. As stated previously, it may be
held at the same time as the hearing on the CP Plan or it may be held separately. This
public hearing should be held at a central location (i.e. county building) and not in a
planned project target area.

Public Hearing Concerning Application for CDBG Funds – This hearing is required prior
to submission of the application for CDBG funds to inform the public of the proposed
CDBG activities. The locality must allow at least seven days following the needs
assessment hearing before holding a public hearing concerning application for CDBG
funds. In addition, it should not be advertised prior to the date of the needs assessment
public hearing because that could limit participation and interest.
Posting and Publishing Notices of Public Hearings
All notices of public hearings must be published in an appropriate section in a specified
newspaper of general local circulation at least seven days (not including publication date) prior
to any public hearing.

Such notices may not be printed in the legal section of the newspaper.

The notices should include a statement regarding the recipients’ policy of nondiscrimination.
In the event there is no newspaper of general circulation serving the jurisdiction of the locality
undertaking such activities (particularly in small towns), it is acceptable to post the notices for 10
days (not including the date of posting) prior to the date of the public hearing. Suitable locations
for posting include, but are not limited to:
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______________________ APPLICATION PROCESS – PHASE ONE ______________________

Municipal and county buildings accessible to the general public,

Post offices,

Libraries,

Health departments,

Department of Social Services offices, and

Local establishments frequented by area residents.
In addition to the required newspaper notice for the public hearing, the locality should make
reasonable efforts to inform citizens who may be affected by a CDBG project, but who might not
be reached through formal newspaper notices. Such efforts might include the distribution of
leaflets or notices to local organizations or churches, or the posting of notices in places likely to
be seen by citizens who might be affected by a CDBG project. Also, it is recommended that
television and radio announcements be incorporated into outreach efforts. Examples of notices of
public hearings are included in the Attachments to these guidelines.
Additional Requirements
The following additional requirements apply to public hearings:

Minutes of the public hearing should be taken, including the names and addresses of
persons attending, a summary of information presented, and comments by local officials
and citizens.

Localities must maintain files including the before-mentioned attendance records,
summaries of comments, the originals of the "affidavit of publication" for any notice
placed in a newspaper and copies of notices published or newspaper tear sheets in order
to meet CDBG program recordkeeping and monitoring requirements.

The public notice for an application public hearing should not be published or posted
before the needs assessment hearing is actually held. The purpose of a needs assessment
hearing is to determine the needs of a locality and projects should not be chosen before a
needs assessment hearing is held.
Community Development Needs Assessment
Each locality, prior to being considered for funding,
must "identify its community development and housing
needs, including the needs of low and moderate income
persons and the activities to be undertaken to meet such
needs."
This Federal requirement is intended to involve the
locality seeking CDBG funding in a basic planning
2015 – 2016 Application Guidelines
A community needs assessment is
generally considered valid for twelve
months if conducted in accordance
with a CP Plan. If a public hearing for
the needs assessment has been held
within twelve months of the
submission date, another need not be
held prior to the development of an
application.
25
______________________ APPLICATION PROCESS – PHASE ONE ______________________
process which will promote better coordinated strategies for addressing local needs, particularly
the needs of low and moderate income persons. The level of collaboration among partners is one
of the scoring criteria for CDBG applications.
An application for CDBG funds should include only those activities that address needs identified
in the needs assessment process. A joint Needs Assessment and Citizen Participation Plan
hearing may be held.
Prior to the submission of any application, the locality must have accomplished the following:

Held one or more public hearings to obtain the views of citizens on community
development, economic development and housing needs. (The activities that are to be
undertaken to address these needs must be presented in a separate public hearing prior to
the submission of the application.)

Identified its community development and housing needs and priorities, including the
needs of LMI persons, and the activities to be undertaken. The identification of local
needs must be detailed in a written needs assessment document that includes, at a
minimum, sections that describe:

Outreach - The procedures used to identify the community development needs and
establish priorities and objectives, including efforts to encourage meaningful
participation by local citizens, particularly those who are minority or of low and
moderate income. The assessment must summarize the results of outreach efforts,
participation results at hearings and the extent of participation in the needs assessment
process by the broad community including local leadership, businesses, LMI groups
and residents.

Needs - The locality's community development needs including the following
minimum components: housing, infrastructure, public facilities, public safety,
economic development, obstacles to economic competitiveness, workforce
development and downtown and neighborhood revitalization. The assessment must
specifically identify the needs of low and moderate income persons.

Priorities and Planned Actions – At a minimum, the plan should identify the
community's top three priority needs and the locality’s priorities for addressing the
needs of low and moderate income persons. Additionally, the plan must specify the
activities to be undertaken to meet the identified needs.

The activities considered for CDBG funding and the rationale for selecting the
proposed priority projects and activities.
The project proposed by the locality in its application does not have to be the highest priority
community need, but should be included in the needs assessment. There are a number of reasons,
which must be documented (including the eligibility of the project for CDBG funding or the
availability of other, more appropriate local, State or Federal resources) which would justify
submitting an application for other than the top ranked community need.
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PHASE TWO: PROJECT IDENTIFICATION
From the needs assessment process, the community and partners specify the outcomes they will
seek to address for the identified priority need. The needs assessment outlines project ideas that
would contribute to improved competitiveness and quality of life. Participation from the
community, customers, and partners ensures that there will be broad support and commitment to
the success of the identified project. The community assesses the project and reviews any
relevant plans and makes a preliminary determination of whether the project would be feasible to
address using the CDBG program. Specifically: Is it an eligible activity? Does it meet a national
objective? Is it a project that would most effectively achieve the desired outcome and could be
documented to address the published CDBG project selection criteria?
Grants Administration staff can assist the community in making this determination. The staff is
available to provide technical assistance to the community in developing the project and
preparing the application.
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PHASE THREE: PROJECT DEVELOPMENT
In this phase the local government requests an application and provides preliminary information
on the project, its location, number of beneficiaries and costs.
This is the busiest time in the application process because it involves compiling the
documentation necessary to show how the project is consistent with CDBG objectives and
project selection criteria. It is necessary to meet with citizens in the community, engineers,
public works directors, water and sewer providers, rehabilitation specialists, and others with
knowledge about the project and how it will work. Collaboration with partners at this stage is a
necessity for designing the most effective and efficient project possible. Partners contributing
human, financial or organizational resources must be involved so that they are committed to the
success of the project.
The project service area must be identified along with the project beneficiaries, or customers. In
some cases, it may be necessary to conduct door-to-door surveys to determine if the beneficiaries
qualify as being low and moderate income. (See Meeting a National Objective section below.)
Evidence on the market conditions for the project must be gathered. Such documentation shows
why the project is needed and may include previous studies, engineering reports, DHEC letters,
testing results, etc.
Preliminary cost estimates and budgets must be developed. These are based on initial
assessments for housing units in limited rehabilitation projects and preliminary engineering
reports. There are cost limits on housing, rehabilitation personnel, public services, engineering,
and administration. These CDBG program allowances, along with the maximum grant amount
and other resources available, should be taken into consideration when developing a realistic
budget.
Any potential project barriers or technical feasibility issues must also be addressed for the project
to be successful. Some of these barriers might include: Is there enough time to conduct surveys?
Are all funding sources available now? Has sufficient planning or a preliminary engineering
report been done? Does the cost and technical design appropriately fit the level of documented
need or is the project "over-designed"? Have alternative solutions been considered and a
determination made about the most viable, long term solution? An early determination must be
made to ensure the community will have all the necessary resources to implement the project,
and if it can be completed in a timely manner, if funded. The community must understand its
responsibilities if the project is funded (i.e. timeframe and regulatory compliance requirements).
Partners can also provide input on innovative methods of project delivery. Exposure to different
ideas and perspectives will strengthen the project design. The experiences of those who have
interests in the project can be a valuable resource in shaping the outcome. Partners would also
contribute to project development by acknowledging any duplication of services or shortage of
resources that may contribute to lessening the impact of the project.
Enough time to complete these tasks must be allotted prior to applying because the application
would not otherwise be acceptable.
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PHASE FOUR: APPLICATION DEVELOPMENT
Requesting an Application
Units of local government that are interested in applying for Community Development Programs
must request an application from Grants Administration prior to the deadlines indicated below.
(See the Application Request Forms in Attachments.) The request must contain:

A brief, written description of the proposed project,

The proposed number of beneficiaries and an estimate of the percentage of beneficiaries
who are LMI (if appropriate),

The project location and map,

The service area,

Total project costs,

All funding sources,

The amount of CDBG funds to be requested, and

The proposed use of such funds.
Signed application request must be submitted by the chief elected or administrative official of the
unit of local government by the application request due date. Application requests will be
reviewed to determine whether the proposed project appears to meet eligibility, national
objective and threshold requirements. Grants Administration may request a meeting with the
potential applicant or conduct a site visit to determine eligibility and feasibility prior to mailing
an application.
Application Requests are due for each of the following programs as listed below:

Community Infrastructure:
March 13, 2015 at 5:00 p.m.

Community Enrichment and
Neighborhood Revitalization:
August 14, 2015 at 5:00 p.m.
Apply for Funding
Once most of the details are worked out on the project, the locality must complete the application
and submit it to Grants Administration before the application deadline. If the community was not
able to complete all of the tasks in Phase Three, a decision to continue to work on project
development and apply in a future funding round may be better than a decision to submit a
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______________________ APPLICATION PROCESS – PHASE FOUR _____________________
project that is not carefully planned. If so, the local government should inform Grants
Administration of its intentions to wait until a future funding cycle.
If the project is to be submitted, an application public hearing must be publicized and held to
present the project plan and to obtain input from the public and from the citizens that will be
affected. Since citizen involvement is critical throughout the process, the community should
document all of its efforts. The next step is to obtain a resolution from the City/County Council
for local match and to obtain written commitments for leveraging and other contributions from
partners participating in the project. Although other funding beyond the leveraging requirement
is not mandatory, the commitment of partners to achieving the outcome contributes to a
successful project. In every project, all funding to complete the project should be secured prior to
application submission. Any other supporting documentation (photographs, maps) necessary to
address the project selection criteria and the program certifications should also be pulled
together.
Once the details of the project have been pulled together, applicants must be able to define the
proposed outcome that the project will achieve as well as performance targets that will be
reached to complete the project. In order to determine the efficiency of project design and
implementation, applicants also must be able to associate Measures with the primary activities
that make up a project. A Measure is based on a unit-level output for an activity. For example, a
primary activity would be new housing construction. The outputs of the housing activity would
be the numbers of persons, LMI persons, and houses being constructed.
As part of designing an efficient and effective project that will most likely achieve the desired
outcome, applicants will also develop a detailed budget. The budget will show sources and uses
of funds and will be the basis for determining return on the CDBG investment. The return on
investment is the ratio of CDBG dollars to other dollars being put into a project. The applicant
provides more evidence of feasible project design by submitting a Work Plan. The Work Plan
details the necessary tasks, the person or organization responsible for completing each task, and
how long completion of each task will take. Preparing the Work Plan at the project proposal
stage helps identify possible kinks in the project design and the resources necessary for each
task.
Remember that the project will be reviewed and rated against other similar projects submitted
from around the state, and the projects most likely to achieve the desired outcome in the most
needy areas will be funded. We often suggest that another staff person review the application for
content and errors, then review it against the scoring criteria before submitting the application to
Grants Administration.
Meeting a National Objective
Before any activity can be funded in whole or in part with CDBG funds, a determination must be
made as to whether the activity is eligible under Title I of the Housing and Community
Development Act of 1974, as amended. Activities must also address at least one of the following
three National Objectives of the CDBG Program:
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______________________ APPLICATION PROCESS – PHASE FOUR _____________________

Benefit low and moderate income (LMI) persons,

Aid in the prevention or elimination of slums or blight, or

Meet other community development needs having a particular urgency, because existing
conditions pose a serious and immediate threat to the health or welfare of the community
and are of recent origin or recently became urgent, and where other financial resources
are not reasonably available to meet such needs.
The total and LMI beneficiaries must be determined through census or survey, depending on the
project location and type.
National Objective 1: Benefit to LMI Persons
The LMI National Objective is often referred to as the “primary” national objective in so far as
the regulations require that Grants Administration expend 70% of its CDBG funds to meet this
particular objective. Applicants must ensure that the activities proposed, when taken as a whole,
will not benefit moderate income persons to the exclusion of low-income persons. Activities that
benefit low and moderate income (LMI) persons are divided into four types:

Area Benefit activities,

Limited Clientele activities,

Housing activities, and

Job creation/retention activities.
Development Assistance Program.)
(See
the
Business
If qualifying a project
based on primary benefit
to LMI persons, do not
“round up” the percent
LMI if it is between
50.5% and 50.99%. The
percent LMI must be
51% or greater.
Definition of “Low and Moderate Income Person”
The definition of low and moderate income (LMI) used in the State's CDBG program is the same
as that in Title I of the Housing and Community Development Act, as amended. These income
limits are to be used to qualify persons as eligible LMI beneficiaries of CDBG-assisted activities.
A LMI person is defined as a member of a family or household having an income that is less
than or equal to:

Non-metropolitan counties – 80 percent of the median family income for the county of
residence, or, the statewide non-metropolitan area median family income (MFI),
whichever is higher.

Metropolitan counties – 80 percent of the entire Metropolitan Statistical Area (MSA)
median family income.
On an annual basis, HUD provides Grants Administration with MFI figures for all counties and
the metropolitan and non-metropolitan areas of the state. HUD also provides the dollar income
amounts that are to be used to qualify a person as low and moderate income, based on family
size and county. These “income limits” reflect the appropriate MFI, as defined above, and are
posted on Grants Administration’s www.cdbgSC.com website as the data becomes available.
These amounts for counties are adjusted for family size. (See Income Limits in the Attachments.)
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HUD indicates that the updated MFI data will be released in December of each year. If these
income limits are updated by HUD after an application is submitted to GA for consideration but
prior to a grant award, the grant may be conditioned to require re-verification of LMI eligibility
prior to release of funds. If a project is determined ineligible due to the updated income limits,
the grant will be terminated.
The Consolidated Planning Regulations at 24 CFR Part 91 require the State to collect and report
information on the number of extremely low, low, moderate and middle income persons served
by each activity.
LMI Area Benefit Criteria
An Area Benefit activity is one whose benefits are available to all the
residents in a particular service area, where at least 51 percent of the
residents are LMI persons. For example, building a workforce
training center in an LMI town could qualify as an Area Benefit
activity. The benefits of this type of activity are available to all
persons in the area regardless of income. The activity’s service area
does not need to be consistent with census tracts or other officially
recognized boundaries, but must be the entire area served by the
activity. Activities of the same type that serve different areas must be
considered separately on the basis of their individual service area.
An activity that serves
an area that is not
primarily residential in
character CANNOT
qualify under the area
benefit national
objective.
In determining whether an activity will actually benefit LMI persons, the net effect of the
completed activity is considered. The mere location of an activity in an LMI area does not
conclusively demonstrate that the activity benefits LMI persons.
Examples of activities that may qualify as an Area Benefit activity include:

Building a library that serves an LMI area,

Providing drainage improvements in an LMI neighborhood, or

Constructing a water tank that serves an LMI area.
Data establishing numbers and percentages of LMI persons in an area must be verifiable.
Acceptable methods for establishing low and moderate income population in a particular area
include:

Census data provided by HUD, or

Methodologically sound surveys.
Both methods are discussed below.
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Census Data
When Census data is used to establish the LMI percentage for a population, the appropriate
source is a special HUD-generated tabulation of census data, or HUD Low and Moderate Income
(LMI) Estimates. To create these estimates, HUD obtains the most recent population and income
information available at the block group level from the US Census Bureau. This data must then
be re-tabulated to reflect HUD LMI income categories versus traditional census income
categories.
Beginning with the 2010 census, the Census Bureau’s annual American Community Survey
(ACS) is now the source for most income data and the only source for income data at the block
group level. Unlike the decennial census, which was the source for HUD LMI Estimates until
2010, the ACS is sample-based and conducted annually. This results in new ACS datasets
available each year, for 1-, 3- and 5-year periods. 5-year ACS estimates are based on five years
of collected ACS survey data and are the only estimates that include data at the block group
level.
The first LMI Estimates provided by HUD since the 2010 decennial census are based on the
2006-2010 ACS 5-year data. It is expected that HUD will provide updated LMI Estimates based
on more recent ACS data, as new 5-Year ACS data becomes available and as HUD is able to
complete the special tabulations needed to generate the LMI estimates. Information regarding
the LMI Estimates and the most current version of the estimates themselves can be downloaded
from the new HUD Exchange website:
https://www.hudexchange.info/manage-a-program/acs-low-mod-summary-datablock-groups-places
Grants Administration will post information and/or links to the most current HUD LMI data on
its website. Contact Grants Administration if you are not sure of the data for an area.
If the proposed activity’s service area is generally the same as a census place (town, city or
county), a census tract or block group, then HUD data may be able to be used to justify the
income characteristics of the area served.
Contact GA for technical assistance before trying to qualify a project based on census tract or
block group data. If the service area is not generally the same as a census tract or block group,
then an applicant should conduct household surveys to determine the LMI percentage for the
service area. HUD LMI income limits by family size are updated each year by HUD and posted
on Grants Administration’s website at www.cdbgSC.com as available.
If HUD data does not indicate the service area contains at least 51 percent LMI persons, and if an
applicant has a compelling reason to believe the data is incorrect based on a change in either
population or income of the area since the last Census, then an applicant may conduct household
income surveys to update the data. However, if the service area is a census place (city or town)
the applicant should submit its justification to GA for approval prior to undertaking a
jurisdiction-wide survey.
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Survey Data
An applicant may conduct a methodologically
sound income survey to establish the LMI status
of households or families in a CDBG project
area.
Grants Administration has developed sample
income survey forms, included in the
Attachments to these Guidelines that
communities are encouraged to use. Applicants
may utilize their own survey as long as it
contains, at a minimum, the questions contained
in the Grants Administration survey. Applicants
are reminded to obtain street addresses or
locations instead of post office boxes where an
address is indicated on the survey forms.
Grants Administration generally requires a
door-to-door survey of 100% of the target
area be conducted. Grants Administration
must approve, in advance, any alternate
methodology that is not a 100% door-todoor survey. HUD CPD Notice -05-06
dated July 26, 2005: “Suggested Survey
Methodology to Determine the Percentage
of Low and Moderate Income Persons in
the Service Area of a CDBG funded
Activity” outlines other methodologies and
appropriate sample sizes and is included in
the Attachments to Chapter 13 on National
Objectives in the Implementation Manual.
A copy of the survey instrument should be
included in the CDBG application along with an explanation of the methodology used. The
survey results must be reported on Grants Administration’s Summary of Survey Results Form
included in the application.
When the 100% door-to-door survey method is used, the applicant may only claim benefit to
LMI persons based on actual survey results, not by extrapolation. For example: a target area
contains 100 families. The applicant conducts a survey and obtains results from 80 families who
respond to the survey. The results show that 75 of the 80 families surveyed are LMI. The
applicant may correctly say that 75 percent (75 of the 100 families) of the target area is LMI. The
applicant may not say that 94 percent (75 of 80 families) is LMI, since the incomes of the 20
non-surveyed families are unknown. To determine project eligibility, all housing units/persons
within the target area must be included in the survey results, including habitable vacant units.
When family size or income is unknown or if the unit is vacant, households/families must be
counted as non-LMI. Only occupied unit beneficiaries should be listed in the application
narrative and on the Target Plan.
Surveys are generally good for three years, absent any changes to the area or to the income
limits. Updates may be required for projects with direct benefit activities (i.e. water/sewer
service lines on private property). If HUD income limits change prior to a grant award, survey
results must be updated and verified. Completed surveys must be kept on hand and available for
review by Grants Administration.
LMI Limited Clientele Criteria
A Limited Clientele activity benefits a specific group of people (rather than all the residents in a
particular area), at least 51 percent of who are LMI persons. For example, a transportation
service for severely disabled adults to obtain health care could be a Limited Clientele activity.
However, the following kinds of activities do not generally qualify under this category:
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
Activities where the benefits are available to all the residents of an area.

Activities involving the acquisition, construction, or rehabilitation of property for
housing.

Activities where the benefit to LMI persons is the creation or retention of jobs (except for
certain microenterprise and job training activities as described below).
To qualify under Limited Clientele criteria, the activity must meet one or more of the following
tests:

Benefit a clientele generally presumed to consist principally of LMI persons,
provided there is no evidence to the contrary. The only groups that are in the presumed
category are:
 Abused children,
 Elderly persons (62 and older),
 Battered spouses,
 Homeless persons,
 Severely disabled adults (as defined by the Census),
 Illiterate adults,
 Persons living with AIDS, and
 Migrant farm workers.

Require information on family size and income so that it is evident that at least 51 percent
of the clientele are persons whose family income does not exceed the appropriate LMI
limit.

Have income eligibility requirements that limit the activity exclusively to LMI persons.

Be of such a nature and in such a location that it may be concluded the activity's clientele
will primarily be LMI persons (e.g., a job training facility located within a public housing
complex).
Other special circumstances and how they are treated under this national objective category
include:

Special projects to remove material and architectural barriers that restrict the mobility and
accessibility of elderly or disabled persons to publicly and privately-owned nonresidential
buildings, facilities and improvements and the common area of residential structures
containing more than one dwelling unit.

A microenterprise assistance activity (a microenterprise consists of five or fewer
employees including the owner), but only with respect to those owners of
microenterprises and persons developing microenterprises assisted under the activity who
are actually LMI persons. For microenterprise purposes, persons determined to be LMI
may be presumed to continue to qualify as such for up to a three-year period. Refer to
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Chapter 6 of the CDBG Implementation Manual for more information on microenterprise
programs.

An activity providing job training, placement and/or other employment support services
(including but not limited to, peer support programs, counseling, child care,
transportation, and other similar services), in which the percentage of LMI persons
assisted is less than 51 percent, may qualify under the Limited Clientele criteria in the
following limited circumstances:

In such cases where training or provision of supportive services is an integrallyrelated component of a larger project, the only use of CDBG assistance for the project
is to provide the job training and/or supportive services.

The proportion of the total cost of the project borne by CDBG funds is not greater
than the proportion of the total number of persons assisted who are LMI.
LMI Housing Criteria
An LMI Housing activity is one carried out for the purpose of providing or improving
permanent, residential structures that will be occupied by LMI households upon completion. This
would include, but not necessarily be limited to, the acquisition or rehabilitation of residential
property, conversion of nonresidential property to residential, and new housing construction
(under limited circumstances). Water and sewer connections on private property are also
considered to be a housing rehabilitation activity (See Chapter 7 of the CDBG Implementation
Manual).
Housing units can be either owner or renter-occupied in either one family or multi-family
structures. Rental units occupied by LMI persons must be occupied at affordable rents as defined
by Grants Administration.
Occupancy of housing shall be based on the household income of occupants using the following
rules:

Not less than 100 percent of the single-family units rehabilitated in a designated target
area or in scattered sites must be occupied by LMI households after rehabilitation.

If the structure contains two dwelling units, at least one must be occupied by LMI.

For multi-unit structures that contain more than two dwelling units, at least 51 percent of
the units must be occupied by LMI households after rehabilitation. Where two or more
rental buildings being assisted are or will be located on the same or contiguous
properties, and the buildings will be under common ownership and management, the
grouped buildings may be considered for this purpose as a single structure.

Where CDBG funds are used to assist rehabilitation delivery services the funds shall be
considered to benefit LMI where not less than 51 percent of the units assisted are for LMI
persons.
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
An activity designed to reduce the development cost of new construction of a multifamily, non-elderly rental project may be considered to benefit LMI households if:

Not less than 20 percent of the units will be occupied by LMI households at
affordable rents, and

The CDBG proportion of the total costs of developing the project is not greater than
the proportion of units to be occupied by low and moderate income persons.
Documentation of Income for Housing Activities
Income eligibility for the beneficiaries of an LMI Housing activity is established through a
thorough examination of household income (as opposed to family income). Therefore, the
incomes of all persons (related and unrelated) living in the CDBG-assisted housing unit must be
considered, and the total household income must be within the income limit (for that household’s
size) established by HUD at the time of the housing assistance.
LMI Job Creation/Retention
A Job Creation/Retention activity is one that creates or retains permanent jobs, 51 percent of
which are held by persons from low and moderate income families. Jobs indirectly created by an
assisted activity (i.e., “trickle-down” jobs) may not be counted.

For job creation activities, the local government and the assisted business(es) must
document that permanent jobs have been created, and that at least 51 percent of the jobs,
computed on a full time equivalent (FTE) basis, have been filled by low and moderate
income persons.

For job retention activities, the local government must document that the jobs would
actually be lost without the CDBG assistance, and that either or both of the following
conditions apply with respect to at least 51 percent of the jobs:

The job is known to be held by a low and moderate income person; or

The job can reasonably be expected to turn over within the following two years and
that it will be filled by an LMI person upon turnover.
Job Creation Requirements
A written commitment to hire or retain LMI persons must be obtained for each assisted business.
The business must also provide a hiring plan which details the number of jobs to be created, the
number of jobs held or to be filled by LMI persons, the type of job, average wage, any special
skills or training required, the timetable for hiring, and whether or not health care will be
provided for the position. The plan must indicate who will be responsible for hiring and
collecting required data and for any training to be provided. Generally, it is expected that initial
hiring by the business will be completed within twenty-four (24) months from the time of the
assistance. Projections for future expansions or growth are generally not considered for purposes
of determining the number of jobs to be created.
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The job commitment should be realistic in determining the total number of jobs, the number of
jobs to be filled by LMI persons and the timeframe for hiring.

Grants Administration uses the commitment letter to qualify the proposed project under
HUD regulations and will monitor the hiring to verify that job commitments have been
fulfilled.

Failure to comply with the requirement to benefit at least 51 percent LMI persons could
result in the State requiring repayment of all or a portion of CDBG funds spent on the
project.
Grants Administration staff must meet with appropriate representatives of the business to discuss
hiring commitments, LMI job requirements and documentation prior to CDBG funds being
awarded. These meetings are coordinated with the state employment services and Technical
Schools representatives (if appropriate), the project administrator and appropriate local officials.
Job Retention Requirements
For projects proposing the retention of jobs that would otherwise be lost without CDBG
assistance, at least 51 percent of the jobs to be retained must be held by persons from low and
moderate-income families. HUD requires that there be clear, objective evidence and
documentation that jobs would be lost without the CDBG assistance; therefore, using job
retention as a basis for meeting the LMI National Objective is difficult. Consequently, in the
past, few projects have qualified as benefiting LMI through job retention.
The business should track its employees by position, such that the LMI status of the employee in
that position can be determined. Documentation is easier if employees live in, or the job and
business is located in, certain high poverty areas. See the section below for more information.
Presumption Criteria
The level of documentation required for demonstrating benefit to LMI persons when using the
Job Creation/Retention National Objective is significantly reduced for businesses located in
areas meeting certain poverty levels and for employees living in those areas. The current
regulations allow for a person to be presumed LMI under certain circumstances.
A presumption can be made about a person’s LMI status (only for job creation/retention
activities) if either:

The person filling the job resides within a census tract that either has at least 70 percent
of its residents who are LMI or meets the criteria listed below.

The assisted business and the job under consideration is to be located within a census
tract that is part of a Federally-designated Empowerment Zone or Enterprise Community
or meets the following requirements:

Has a poverty rate of at least 20 percent (as determined by the most recently available
decennial census information and does not include any portion of a central business
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district, as this term is used in the most recent Census of Retail Trade, unless the tract
has a poverty rate of at least 30 percent as determined by the most recently available
decennial census information); and

It evidences pervasive poverty and general distress by meeting at least one of the
following standards:

All block groups in the census tract have poverty rates of at least 20 percent;

The specific activity being undertaken is located in a block group that has a
poverty rate of at least 20 percent; or

Upon written request, Grants Administration and HUD determine that the census
tract exhibits other objectively determinable signs of general distress such as high
incidents of crime, narcotics use, homelessness, abandoned housing, and
deteriorated infrastructure or substantial population decline.
Contact Grants Administration for a listing of census tracts and block groups qualifying on the
basis of poverty and LMI percentage.
Generally, the presumption must be made at the time a CDBG application is submitted and
cannot be used retroactively. Once the presumption is made, all of the jobs will be presumed to
be filled by low and moderate income persons. At the application stage, the business must submit
a commitment letter and hiring plan identifying the number of jobs to be filled during the initial
hiring phase.
National Objective 2: Elimination or Prevention of Slums and Blight
Area Basis
To qualify under this national objective on an area basis, an activity must meet the following:

The area must be designated by the applicant and must meet the definition of a slum,
blighted, deteriorated, or deteriorating area under local law. A sample ordinance for units
of local government to adopt defining slum and blighted areas is included in the
Attachments to these Guidelines. A sample resolution for a local government to use to
declare a specific area as slum/blighted is also included in the Attachments. Both are
required and must be re-determined every ten years for continued qualification.

Public improvements are in a general state of deterioration throughout the designated
area,
OR

There are a substantial number of deteriorated or deteriorating buildings throughout the
designated area.
At least 25 percent of properties throughout the area must have one or more of the
following conditions:

Physical deterioration of buildings or improvements;
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

Abandonment of properties;

Chronic high occupancy turnover rates or chronic high vacancy rates in
commercial or industrial buildings;

Significant declines in property values or abnormally low property values relative
to other areas in the community; or

Known or suspected environmental contamination.
Each deteriorated building must be considered substandard under local code. All
deficiencies making such a building substandard and a blighting influence must be
corrected before less critical work on the building may be undertaken. The unit of local
government must develop minimum standards for building quality that take into account
local conditions.
Spot Basis
To qualify under this national objective on a spot basis, an activity must be designed to eliminate
specific conditions of blight or physical decay on a spot basis not located in a slum or blighted
area and be limited to the following activities:

Acquisition

If acquisition or relocation is undertaken, it must be a precursor to other activities
(funded with CDBG or other resources) that directly eliminates the specific
conditions of blight or physical decay.

Clearance

Relocation

Historic preservation

Rehabilitation of buildings

Only allowable to the extent necessary to eliminate specific conditions detrimental to
public health and safety.
The State can approve no more than 30 percent of its funds for activities that address the
Slum/Blight National Objective according to requirements of Title I of the Housing and
Community Development Act.
National Objective 3: Urgent Need
Use of this national objective category is extremely rare. It is designed only for activities that
alleviate emergency conditions. Urgent Need activities must meet the following qualifying
criteria:
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
The existing conditions must pose a serious and immediate threat to the health or welfare
of the community,

The existing conditions are of recent origin or recently became urgent (generally, within
the past 18 months),

The recipient is unable to finance the activity on its own, and

Other sources of funding are not available.
Additional National Objective Considerations
Public Facilities/Infrastructure
In any case where the activity undertaken is a public improvement and the activity is clearly
designed to serve a primarily residential area, the activity must meet the LMI Area Benefit
criteria, whether or not the requirements for job creation/retention are also met, in order to
qualify as benefiting low and moderate income persons. Because it is required that all low and
moderate income persons be connected to water/sewer infrastructure at no cost, an infrastructure
project must meet the 51% LMI area benefit test for persons and households.
Acquisition
Qualifying an acquisition activity under one of the CDBG National Objectives depends entirely
on the use of the acquired real property following its acquisition. A preliminary determination of
compliance may be based on the planned use. The final determination must be based on the
actual use of the property, excluding any short-term, temporary use. Where the acquisition is for
the purpose of clearance that will eliminate specific conditions of blight or physical decay, the
clearance activity may be considered the actual use of the property. However, any subsequent
use or disposition of the property must be treated as a “change of use” under CDBG regulations.
These requirements are for any real property, acquired or improved, in whole or in part, using
CDBG funds in excess of $100,000. If property is to be acquired for a general purpose, such as
housing or economic development, and the actual specific project is not yet identified, the grant
recipient must document the general use it intends for the property, the national objective
category it expects will be met, and make a written commitment to use the property consistent
with CDBG requirements.
Relocation
Where CDBG funds are used for required relocation assistance, the relocation assistance is
considered to address the same national objective as is addressed by the displacing activity.
Where the relocation assistance is voluntary, the applicant may qualify the assistance either on
the basis of the national objective addressed by the displacing activity or, if the relocation
assistance is to low and moderate income persons, on the basis of benefiting low and moderate
income persons.
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Downtown/Commercial or Essential Goods and Services Projects
To qualify under the LMI Area Benefit National Objective, the service area for downtown or
commercial area revitalization projects must be primarily residential in nature and have at least
51% low and moderate income residents. These types of projects may also qualify as LMI Job
Creation/Retention.
If assistance is provided to one or more businesses, then the project may qualify under LMI Area
benefit if the service area is primarily residential, and is 51% low and moderate income. There
must also be documentation that the business is providing essential goods and services to that
service area population. Goods and services might include grocery stores, dry cleaners,
pharmacies, health care, etc. A high end boutique or souvenir shop would not be considered as
providing essential goods and services. Assistance to a local business providing essential goods
and services may also qualify as a Job Creation/Retention activity that must comply with the
requirements as specified in this section of the Application Guidelines.
Documenting National Objectives and Program Benefits
LMI Area Benefit Activities
The following documentation of program benefit is required with the application for all CDBGfunded activities that are carried out under the LMI Area Benefit National Objective:

A map showing the boundaries of the service area.

A summary of income characteristics of all families and unrelated individuals in the
service area, obtained from the Census or from survey data.

If Census data is used, maps indicating the service area in comparison to Census block
groups or Census tract boundaries.

If a survey is used, a copy of the survey instrument (completed individual survey forms
are not typically required, though they may be requested), documentation of the number
of families surveyed and evidence that the survey was methodologically sound.

Documentation of occupancy and income characteristics of all families and unrelated
individuals receiving CDBG assistance for special assessments.
LMI Limited Clientele
The following documentation of program benefit is required with the application for all CDBGfunded activities that are carried out under the LMI Limited Clientele National Objective:

Documentation showing the activity is used by a segment of the population presumed by
HUD to be LMI persons (e.g., elderly, illiterate adults).

Documentation showing that at least 51 percent of the clientele of the facility or service
will be LMI persons.

Documentation that the facility or service will be used exclusively by LMI persons.
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
Documentation describing how the nature and/or the location of the activity establish that
it will be used primarily by LMI persons.

Documentation that the owner of the microenterprise or person developing the
microenterprise is LMI.

Documentation that the job training or other employment support service is integrallyrelated component of a larger project that does not involve CDBG funding or
documentation that the percentage CDBG cost is not greater than the percentage of LMI
persons assisted.
LMI Housing
The following documentation of program benefit is required with the application for all CDBGfunded activities that are carried out under the LMI Housing National Objective:

For each unit to be assisted, the size and income of the occupant household.

A copy of a written agreement with each developer receiving CDBG assistance
committing the total number of dwelling units in each single family unit or multi-family
structure assisted and the number of those units which will be occupied by LMI
households after the assistance.

For rental housing, a description of how the affordability of units occupied by LMI
households pursuant to criteria established by Grants Administration will be ensured.

For each property acquired on which there are no structures, evidence of commitments
ensuring the above criteria will be met when the structures are built and occupied.

Where applicable, records documenting that the activity qualifies under special
conditions regarding the new construction of non-elderly, multi-family housing.
LMI Job Creation/Retention
The following documentation of program benefit is required with the application for all CDBGfunded activities that are carried out under the LMI Job Creation/Retention National Objective.
Recipients are required to verify job creation/retention on-site on a quarterly basis.
Job Creation

For an activity that creates jobs, the unit of general local government must document that
at least 51 percent of the jobs will be for LMI persons.

Documentation for each assisted business must include a copy of a written commitment
by each business that at least 51% of the jobs created (full-time or full time equivalent)
will be held by LMI persons. The business must also provide a hiring plan which details
the number of jobs to be created, the number of jobs estimated to be filled by LMI
persons, the types of jobs, any special skills or training required, the timetable for hiring
and whether or not healthcare will be provided for each type of position. The plan must
indicate who will be responsible for hiring and collecting required data and for any
training to be provided.
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Job Retention

Clear and objective evidence that permanent jobs would be lost without CDBG
assistance. This may include such evidence as a notice to employees, a public
announcement by the business, or relevant financial records.

A written commitment from the business to comply with the CDBG requirements for
employment of 51% LMI persons.

For each business assisted, a listing by job title of all full time and part-time, permanent
jobs to be retained indicating which are held by LMI persons at the time the application is
prepared.

Where applicable, identification of any of the retained jobs (other than those known to be
held by LMI persons) which are projected to become available to LMI persons through
job turnover within two years of the time CDBG assistance is provided. (Information
upon which the job turnover projections were based should also be provided.)

For each retained job claimed to be held by an LMI person, information on the size and
annual income of the person's immediate family.
Slum/Blight
The following documentation of program benefit is required with the application for all CDBGfunded activities that are carried out under the Slum/Blight National Objective:
Area Basis

A resolution and ordinance from the applicant governing body designating the area as
slum and blighted, providing a description of the conditions which qualified the area at
the time of designation and providing a description of how the conditions contributed to
the area's deterioration.

A map and description of the boundaries of the designated area showing the location of
all buildings and public improvements that are deteriorated.

Inventory and detailed description documenting that public improvements are in a
general state of deterioration. Deterioration of a single element of infrastructure, such as a
road or a sidewalk, does not meet this criterion.

Inventory and detailed description of all buildings in the target area and their condition.
Include the total number of buildings, the type of buildings, and the percentage of
buildings that are deteriorated in the area as well as vacancy rates.

Evidence that the activity being proposed for CDBG assistance addresses one or more of
the conditions that contributed to the deterioration of the area.
Spot Basis

A building inspection report or other evidence that describes the specific condition of
slum or blight and how the activity to be assisted with CDBG funds will eliminate the
blighted condition.
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
For rehabilitation, a description of how the assistance will be limited to the items
necessary to eliminate specific conditions detrimental to the public health and safety.
Urgent Need
The following documentation of program benefit is required with the application for all CDBGfunded activities that are carried out under the Urgent Need National Objective:

Evidence of the seriousness and immediacy of the threat, such as an official declaration
by a state or federal official (e.g., DHEC has declared the area an imminent threat or a
disaster, such as flood or hurricane, has been declared by the Governor).

Evidence that the condition developed or became critical within 18 months preceding the
application.

Evidence that financial or other resources or funds are not reasonably available to meet
such needs.
Developing Project Design
Under the State’s Community Development Program, local recipients may utilize CDBG funds
to undertake a variety of public facilities and infrastructure improvement projects. Communities
may also undertake more comprehensive programs involving neighborhood or commercial
revitalization that include infrastructure and/or public facilities activities as part of those projects.
CDBG can be a resource to strengthen and improve communities, to make them more livable and
sustainable. In light of shrinking resources it is necessary to target investments on a few priorities
and strategies. These strategies emphasize preparing for the future:

Re-focus by targeting strategic investments

Revitalize existing communities through a comprehensive approach

Re-invest in existing infrastructure/facilities through upgrades, modernization, renovation

Renew by implementing sustainable solutions

Re-energize through community/volunteer involvement
Sustainability is development that meets the needs of the present without compromising the
ability of future generations to meet their own needs. It involves economic and environmental
resources and social equity.
Sustainable development is environmentally sensitive, economically viable, and communityoriented. It is similar to European villages where development is compact and concentrated
around the village market. There is a mix of residential and commercial within walking distance.
Farmland and open space is protected. These types of communities possess the following
characteristics:
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
Attractive communities with strong sense of place

Mix of land uses

Open space and natural areas are preserved

Range of housing opportunities and choices

Walkable neighborhoods

Development directed toward existing communities/infrastructure

Compact and green building design

Community and stakeholder collaboration
To ensure the economic vitality of communities, it is necessary to support and improve existing
business centers. By building on assets, improving the physical design and appearance, providing
basic infrastructure services that protect the health and safety of residents and guide a more
compact development, communities can build and retain a quality of life that is sustainable.
Workforce development is an essential ingredient to successful economic development. It is an
investment in the human infrastructure. It is a commitment to the state’s best resource- people.
The provision of skills training and problem solving techniques will benefit the workforce and
allow people to compete for higher paying jobs. Educational excellence leads to innovation and
creativity and this builds opportunities for community and economic development.
Regional solutions support planning and development in conjunction with your neighbors. There
are economies of scale and efficiencies that can be gained by working together and consolidating
resources to be more sustainable.
Although communities face many challenges, there is no one size fits all solution. Communities
should develop a plan and get the entire community involved. They must seek partners, include
the business community, and engage a corps of volunteers to help. Communities must also be
willing to invest in themselves first in order to solve problems and create a new future. But with
limited resources, it is necessary to prioritize and target expenditures, and leverage resources so
that they serve as a catalyst for future investment. Communities should plan carefully so that
they carry out their plans in a timely manner and do not create unexpected new tax burdens for
its citizens.
The project activities presented below provide guidance on developing projects that will help
achieve these outcomes. The full ranges of activities are listed in Section 105(a) of Title I of the
Housing and Community Development Act, as amended. The list is included in the Eligible
Activities section of the Attachments.
Infrastructure Improvement Projects
Infrastructure projects typically include the construction, rehabilitation or extension of publicly
owned water, sewer, streets, or drainage improvements. These improvements may be undertaken
to benefit residents of an area, or may be carried out for the purpose of economic development.
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Grants Administration encourages communities to evaluate regional alternatives to providing
water and sewer service to its residents where such alternatives are cost effective and
appropriate.
The Environmental Protection Agency (EPA) has smart growth policies with a focus on making
infrastructure more sustainable. With so many communities contending with aging facilities,
EPA encourages states to give greater priority to infrastructure upgrades in existing communities
versus serving new developments that have very few people or that may fuel unplanned growth
or sprawl.
CDBG grant funds should not be used to supplant local funds or to cause user rates to be
maintained at levels that are not viable. Rates should be adequate to provide funding for
necessary capital improvements, operations and maintenance. The rates and user fee structure for
water and sewer systems should demonstrate an adequate level of local effort. Rates are
considered feasible if the annual user fee is 1% or more of the area median income. Systems
should generate sufficient revenues to cover operations and maintenance and some level of repair
and capital improvement. Grants Administration reserves the right to reduce grant amounts in a
proportional manner for improvements to existing facilities where rates are lower than the
amount considered feasible. Grants Administration may request such information as necessary to
make a determination of financial viability and local level of support as it relates to a proposed
CDBG project.
A preliminary engineering cost estimate and report are generally required to be submitted with
an application to document the extent of need and capacity of the existing and proposed
infrastructure. Additionally, preliminary planning should be done to determine the number,
estimated cost and location of any required easements or property for facilities.
Infrastructure activities that are not based on job creation/retention should be undertaken in
primarily residential LMI areas. Because it is required that all low and moderate income persons
be connected at no cost, an infrastructure project must meet the 51% LMI area benefit test for
persons and households.
The most feasible projects serve neighborhoods that are densely populated and do not include a
high number of vacant units or undeveloped property. For new services to be considered a
feasible investment, at least 70% of all homeowners should be committed to connect to the
system once installed. It is required that signed user agreements/commitments be obtained prior
to submission of the application in order to demonstrate need/demand and feasibility. Vacant,
habitable units must be counted in the total units as non-LMI units. Vacant units that are not
habitable do not have to be counted in the total but the applicant must have evidence that the unit
is uninhabitable. In the event that individual streets within a service area contain a significant
percentage of vacant or uncommitted units, Grants Administration may require that such streets
be assisted with local or other funds. If water, sewer, or drainage lines are being installed,
typically all residents along the line must be counted as beneficiaries. For a system-wide
improvement, such as a water tank or a waste water treatment plant, all residents in the service
area must be counted as beneficiaries. The service area must be justified and clearly defined in
the application. Sometimes a water tank may serve residents inside and outside of the town
limits. Improvements to drainage systems, pump lift stations, trunk outfall lines, tanks, or
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treatment plants may not benefit the entire system, town, or neighborhood. Residents directly
served may need to be determined by an engineer, and all appropriate residents included in
beneficiary numbers.
If CDBG funds are used to provide water or sewer service to an area outside municipal limits, a
municipality may not require an area to be annexed as a condition of receiving the water or
sewer. It must also show a compelling reason for going outside its county/municipal boundaries.
The capacity of water/sewer systems may only be designed to meet regulatory requirements for
the intended beneficiaries. Any excess capacity must be paid with non-CDBG funds, but may be
counted toward local match requirements. Any contracts must be bid for CDBG eligible
activities, with non-CDBG eligible activities (such as for excess capacity) included as alternates
or additional cost items in the bid.
While upgrades to an eligible area are allowed where the service area is eligible, projects to
primarily repair or maintain water/sewer facilities or components are not permitted. Replacement
of facilities may be considered an upgrade if there is an increase in the size or capacity, or when
sufficient justification is approved. Evidence may include the type of materials and age of
facilities versus intended useful life, documentation that an increase in size is not necessary,
significant, reasonable increases in efficiency and capacity will be made, etc. A PER will be
required to document existing conditions and the extent of improvements beyond maintenance
and repair. Equipment for operation and maintenance is not eligible for CDBG assistance.
Generally, the local government must pay for cleaning and inspection services (CCTV) as part of
a system evaluation survey (SES) to determine the type, extent and location of improvements
needed prior to requesting a CDBG application. Such expenses are eligible as local match.
CDBG funds may not be used for exploratory TV inspections or maintenance cleaning. It is
permissible to include TV services in a construction contract to remove and properly dispose of
any internal debris or obstructions that would interfere with cured in place pipe (CIPP)
techniques or to determine where to cut holes in liners for service re-connection.
CDBG funds may be used for connection costs in the right of way for LMI and non-LMI
occupied residential units only. CDBG funds may not be used to connect non-residential or
vacant units. Stub outs for future residential or non-residential units or vacant units may not be
paid with CDBG funds. New service lines (on private property) may only be installed for LMI
households with CDBG funds, as this is considered rehabilitation of private property.
CDBG funds may only be used for hard construction and installation costs (including meters in
the right-of-way), and not to pay any water or sewer connection, impact or capacity fees. Any
associated fees for low and moderate income hook up/connection to public water and sewer must
be waived or paid with non-CDBG funds, and may be considered part of the local match
requirement.
Impact and capacity fees are not eligible to be paid with CDBG funds, partly because they are
providing funds for future, undefined public improvements and there is no way of telling
whether the use of those CDBG funds would be for an improvement that would meet a national
objective of the program. CDBG will allow waiver of such fees for LMI persons to count as local
match.
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Limited Rehabilitation
The installation of service/lateral lines on private property and connections is considered housing
rehabilitation and is required for all housing units occupied by LMI households at no cost to the
household.
LMI households that do not have any indoor plumbing (e.g., bathroom/kitchen plumbing
facilities) must be connected to the system and provided with indoor plumbing facilities at no
cost to the LMI household as part of a service line lateral project. This is referred to as Limited
Housing Rehabilitation. This requirement is not intended to provide bathroom or kitchen repairs,
but is intended solely for those units that have no facilities. Limited rehabilitation costs generally
may not exceed $10,000. Contact your grants manager for approval if costs are expected to
exceed this amount.
A housing unit will not be brought up to a minimum housing code in its entirety; however, the
work that is being performed should be done to the HQS or appropriate local codes and
standards.
Renters Assisted With Infrastructure
For rental units to be connected to water/sewer, if an LMI tenant does not occupy a particular
rental unit, the owner must pay for any connection or service line on private property.
For rental units or mobile home parks occupied by LMI tenants, the investor should pay for any
connection or service line for private property. However, CDBG funds may pay these costs after
the rental property owner enters into an agreement with the unit of local government to maintain
affordable rents and rent to LMI households for at least one year. Refer to Chapter 7 - Housing
of the Implementation Manual for affordable rental agreements and definitions.
Public Facilities Projects
Public facilities or community facilities are buildings that provide a variety of services for
residents of a community. Such buildings may also include police and fire substations in LMI
areas, libraries, health clinics, multi-service centers or workforce and education development
facilities. Fire substations may be co-located with emergency medical services (EMS) if LMI
service area requirements are met and there are no administrative offices. Applications for fire
substations or trucks should include the most recent ISO analysis to document need, as well as an
estimate of how the improvements will result in a positive change to the ISO rating. Multiservice centers must generally address three or more health, social and/or safety related programs
within an eligible service area or serve an eligible clientele. Senior services within a multiservice center should only be incidental as centers are expected to serve a broader population.
These facilities should generally offer new or expanded services to everyone in the community
or otherwise meet a national objective. Technology and green building techniques or energy
efficiencies should be integrated into public facilities, where possible.
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Under the CDBG regulations, the purchase of equipment or
furnishings (e.g., tables, chairs and filing cabinets) for a public
facility is not considered eligible. However, projects that
involve the purchase of equipment may be eligible as a public
service, under Section 105 (a) (8), as long as it is related to
delivering a service to the community, such as public safety or
job training services. This is discussed in the following section
of these guidelines. The costs to operate and maintain public
facilities are not eligible under CDBG, but the recipient must
demonstrate that these funds are available at the time of
application. CDBG will not support projects that create a new,
undue operating burden on existing taxpayers. Proposed
operating budgets and sources of funding for a five-year period
are required with the application to Grants Administration.
City Halls, county
administrative buildings or
other facilities used for the
legislative, judicial or
general administrative
affairs of government are
NOT eligible for CDBG
assistance. This also
includes the local
government’s main police
or fire stations where the
chief and other
administrative offices are
located.
Prior to applying for CDBG assistance for a public facility, the
applicant must determine the service area of the proposed facility. In order to meet a CDBG
national objective, the facility must serve a residential area which consists of 51 percent LMI
persons, or the facility must be designed to serve one of the Limited Clientele categories (i.e.,
severely disabled adults) allowed under the CDBG regulations. In determining the service area,
the applicant must evaluate the location of other facilities in the vicinity and the services
provided at such facilities in order to avoid duplication of facilities and/or services. For health
facilities there must be documentation that the proposed service area is underserved with regard
to health care based on DHEC or other similar documentation.
The next step is to determine what services and/or activities will be carried out in the facility.
These services/activities must be identified in the CDBG application. The applicant must
determine if the services/activities can result in a primary benefit to LMI persons. (An example
of an ineligible benefit might be if a training program offered courses that would serve all
residents in the county in a facility that is located in an LMI neighborhood. Simply because of its
location, it cannot be assumed that only the neighborhood residents will benefit if the entire
county can attend.) Some communities conduct surveys of area residents or hold public meetings
to determine what services may be desired at a facility. Once the services/activities are identified,
the community should obtain written commitments from any organizations or agencies that will
be providing such activities/services in the facility. Please note that inherently religious services
and some political activities are prohibited.
Local governments sometimes work with faith-based organizations on CDBG eligible facilities
and services. CDBG assistance is limited to the portion of the facility where CDBG eligible
activities are carried out and any religious activities must be conducted separately in time or
location from CDBG funded facilities or activities. CDBG funds cannot be used for structures
where religious activities are conducted, such as worship, or religious instruction. Sanctuaries,
chapels or other rooms used by a religious congregation are ineligible for CDBG assistance.
Further, CDBG beneficiaries may not be discriminated against on the basis of religion or
religious beliefs.
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Once the service area and the activities have been determined, the applicant must estimate the
number of persons who will benefit from the project. Beneficiaries should include the number of
persons that can reasonably be expected to be served by the facility. Beneficiaries should not be
double counted (e.g., one individual might participate in several activities conducted at the
facility but should only be counted once). Beneficiaries may be based on the number of persons
currently receiving the services to be provided or may be estimated based on surveys, capacity of
the building and other available information. The estimated number should be reasonable and
based on an increase in service, if applicable. The number of beneficiaries to be served is
generally expected to be met by close out.
When serving a specific low/moderate income population such as the unemployed, the family
income of the users of the facility must be documented. Chapter 13 of the Implementation
Manual contains a form entitled “Sample Local Income Survey Public Facilities Projects” which
can be used for this purpose. For more information on income documentation, please refer to
Chapter 13.
A public facility that is part of a multiple use building containing both eligible and ineligible uses
may still be eligible for CDBG assistance if the eligible portion of the building:

Meets CDBG guidelines;

Will occupy a separate, designated area within the larger facility; and

Costs attributable to the eligible portion can be determined as separate and distinct from
the overall costs. Allowable CDBG costs are limited to those attributable to the eligible
portion of the building.
In most circumstances, local governments must own public facilities because they are funded as
public facilities under CDBG eligibility guidelines. Any alternative must be approved by Grants
Administration. The use of Federal funds brings with it the requirement that the property must be
protected. As a public facility, the local government ensures the ongoing operation and
maintenance of the building for public use. Long term funding commitments and plans for
financing the operation and maintenance of the building will be required to ensure the building
will be used for the intended use and that ongoing operations are sustainable. It is generally
expected that a facility will be used for its intended purpose for a minimum of twenty (20) years.
Additional requirements on the facility include:

No encumbrances may be placed on the building, or on the land (if also owned by the
non-profit organization).

The building must be used only for the activity being funded and for the primary benefit
of LMI persons, and cannot be used primarily for general office or administration space.

The facility must be open to the public during normal business hours (generally forty
hours per week). Exceptions may be granted for after school facilities that are normally
open to the public for fewer hours, but grant amounts may also be reduced accordingly.
Residents and visitors may be charged fees for using such facilities, but the fees must be
reasonable and not preclude or restrict low and moderate income persons from using the facility.
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User fees which total more than $35,000 annually are considered CDBG program income.
Generally, applicants will be allowed to keep the program income if their program income plan
(PIP) proposes that the income be used for continued operation and improvement of the building
as a CDBG eligible public service. (See the CDBG Implementation Manual for more information
on program income.)
For existing structures being rehabilitated or converted, the community must:

Document if the building is of historic significance and whether there are environmental
hazards that must be removed or abated (refer to the Implementation Manual for more
information);

Ensure that the structure meets all Section 504/ADA accessibility requirements; and

When facilities include kitchen/food preparation areas, have the plans or specifications
approved by the Department of Health and Environmental Control (DHEC).
Public Services
One of the outcomes of community revitalization is to provide healthy and safe communities. All
CDBG revitalization activities must incorporate an anti-crime component or strategy.
The purpose of this strategy is to help rebuild and restructure communities that have suffered
because of criminal activity and social decay. Strategies should be designed to prevent, control,
and reduce crime, drug abuse, and gang activity in targeted high-crime neighborhoods and bring
in services that promote crime prevention and neighborhood revitalization. It may involve a
community based, multi-agency approach to address high crime neighborhoods and make them
places where people are vested in restoring the community as a safe place to live and raise
families.
A multi-agency approach may involve several components:
1) Law Enforcement – Criminal activities are reduced in the neighborhood by local law
enforcement agencies. By reducing both crime and citizen fear, the residents living in the
neighborhood will have a restored hope that the neighborhood can begin revitalization.
2) Community Policing – Two key concepts: community engagement and problem solving.
Law officers establish an on-going dialogue with residents to solve crime and address the
underlying causes of crime. They work to give residents a sense of responsibility within
the community to solve the crime problem together with law enforcement. It includes
programs such as crime watches, graffiti removal, and neighborhood cleanup days.
3) Prevention, Intervention and Treatment - The third component involves neighborhood
efforts to promote a safe crime free area by eliminating risk factors that lead to crime and
violence. Neighborhoods may have a multi-services center that provides various youth
and adult oriented human services in a one-stop setting. Some of the activities may
include childcare, after school programs, tutoring, recreation, parenting courses, drug
prevention programs, substance abuse treatment, mental health services, family
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counseling, and medical care. Also included may be activities to encourage home
ownership and credit counseling.
4) Neighborhood Restoration – Coordination of economic development and employment
opportunities for residents, improvements to housing stock and the physical environment
of the neighborhood which go hand in hand with other efforts to make the neighborhood
a place where residents want to live. The restoration component involves public facilities,
employment and job training, safe clean streets, home ownership opportunities, medical
services, recreation, grocery stores and other local needs.
Public safety services carried out in conjunction with other CDBG activities will be limited to
15% of the total CDBG project activity costs. Generally, law enforcement vehicles are not
eligible.
CDBG funded public service activities are only eligible for new or expanded services to
residents, not just to continue or improve existing services. The unit of local government must
commit to continue such services after the grant without creating a new, undue operating burden.
Only major pieces of equipment that have a durable life of five years or more are eligible, and
must be listed in the application.
As mentioned previously, some projects may involve the purchase of equipment or materials
needed to provide training or technology, or other services to the community. The services may
or may not be related to a public facility also funded with CDBG. Housing counseling may also
be considered a public service activity.
As with all CDBG-funded activities, public services must meet a national objective. CDBGfunded public service activities are typically categorized under the LMI Benefit National
Objective as either Area Benefit or Limited Clientele activities. The distinguishing factor
between the two categories is whether the service will be offered to all residents of a particular
LMI area or to a particular group of LMI residents in the entire community. Please refer to the
CDBG Implementation Manual, National Objectives Chapter for more information.
HUD has placed restrictions on the amount of CDBG funds the State may use for public
services. In order to meet this requirement, the State reserves the right to reduce the amount of
funding approved for grantees proposing such activities.
Downtown Revitalization Projects
A downtown development or commercial revitalization project may only be conducted in areas
with significant business activity and prior investments. The project must increase economic
competitiveness by conserving or revitalizing commercial and downtown areas. These projects
help to strengthen the local economy by stimulating business activity and development and
improving the appearance and functioning of the downtown or commercial area. All
revitalization projects must incorporate a component to address public safety. Eligible activities
include public infrastructure improvements such as: streets, parking, sidewalks, lighting, and
streetscapes, and limited water/sewer (limited to 20% or less); and may also include acquisition,
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clearance, and other public facilities (except those for the general conduct of government).
Additionally, such projects must include a market analysis for essential business goods and
services for residents and plans to improve local economic conditions through retail/small
business support, which can be paid for with CDBG funds.
The requirements discussed in the previous infrastructure subsection also apply to infrastructure
activities undertaken as part of commercial revitalization projects.
Activities that are undertaken as part of downtown or neighborhood revitalization projects also
must address one of the national objectives of the CDBG program. To qualify under the Low and
Moderate Income Area Benefit National Objective, the service area must be residential and at
least 51 percent low and moderate income based on HUD census data, or serve an area
documented as at least 51% percent based on door-to-door income surveys. If the project is not
designed to serve an area that is LMI but is instead based on job creation, it must assist a
particular business(es) and the business(es) must commit to the creation of new jobs, 51% of
which will be filled by low- and moderate-income persons. Other requirements may also apply to
these types of projects. Contact Grants Administration for technical assistance in determining
which national objective a project may qualify under and which additional program requirements
may apply.
In addition, CDBG funded commercial or downtown projects must be part of an overall
commercial or downtown revitalization strategy. The best projects involve the following
components:

There should be an active organization involved in the development and ongoing
implementation of the commercial revitalization strategy.

Projects should have the potential to leverage additional investment downtown.

Projects should be a clearly identified component of a larger plan, i.e., a master plan, a
strategic plan, or downtown/commercial plan.

Projects should include a demonstrated public-private partnership at the local level.

Projects should represent a commitment to historic preservation or represent unique
community assets as noted in the comprehensive plan.
To accomplish their goals, a community may wish to follow the national model of the Main
Street USA program or similar planning and organizational processes. The Four Points of the
Main Street Program are:

Organization involves getting everyone working toward the same goal and assembling
the appropriate human and financial resources to implement a Main Street revitalization
program. A governing board and standing committees make up the fundamental
organizational structure of the volunteer-driven program. Volunteers are coordinated and
supported by a paid program director as well. This structure not only divides the
workload and clearly delineates responsibilities, but also builds consensus and
cooperation among the various stakeholders.

Promotion sells a positive image of the commercial district and encourages consumers
and investors to live, work, shop, play and invest in the Main Street district. By
marketing a district's unique characteristics to residents, investors, business owners, and
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visitors, an effective promotional strategy forges a positive image through advertising,
retail promotional activity, special events, and marketing campaigns carried out by local
volunteers. These activities improve consumer and investor confidence in the district and
encourage commercial activity and investment in the area.

Design means getting Main Street into top physical shape. Capitalizing on its best assets such as historic buildings and pedestrian-oriented streets - is just part of the story. An
inviting atmosphere, created through attractive window displays, parking areas, building
improvements, street furniture, signs, sidewalks, street lights, and landscaping, conveys a
positive visual message about the commercial district and what it has to offer. Design
activities also include instilling good maintenance practices in the commercial district,
enhancing the physical appearance of the commercial district by rehabilitating historic
buildings, encouraging appropriate new construction, developing sensitive design
management systems, and long-term planning.

Economic Restructuring strengthens a community's existing economic assets while
expanding and diversifying its economic base. The Main Street program helps sharpen
the competitiveness of existing business owners and recruits compatible new businesses
and new economic uses to build a commercial district that responds to today's consumers'
needs. Converting unused or underused commercial space into economically productive
property also helps boost the profitability of the district.
Downtown, commercial and neighborhood projects require that a community comprehensively
work on all its opportunities, issues and problems. It requires a self-help approach as well as
collaboration and involvement of business, government and the public.
Another tool for commercial revitalization projects is the South Carolina Community
Development Law. The law authorizes the creation of a redevelopment commission and requires
a redevelopment plan involving citizen participation. The law provides a framework for
undertaking redevelopment activities in areas that have fallen into neglect and decay and for
undertaking preventive measures in areas that appear to be in decline. Redevelopment of such
areas under this law must be necessary for the public health, safety, morals or welfare of
residents. The law also provides a means to use tax increment financing in redevelopment
projects. Please refer to the state law for more information.
Neighborhood Revitalization
Neighborhoods that are safe, healthy and vibrant are the building blocks for sustainable
communities. Smart growth concepts include a mix of affordable housing options within walking
distance of work, stores, schools and services. They pay attention to details like physical
appearance, sidewalks, lighting, and community facilities that encourage neighborhood pride and
interaction. Development is planned so people can spend less time in their cars. Revitalization
and improvement is focused on existing communities, so that outlying farmland and open space
remain protected.
The core communities that are made up of downtown business centers and nearby neighborhoods
constitute a valuable resource to build upon. The Main Street Program has been a successful
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model for revitalizing downtowns. The program’s four point plan of action (as listed in the
previous section) can be applied to these adjacent neighborhoods, which often suffer from low
property values, deteriorating infrastructure, older housing and vacant properties. By linking
neighborhoods with the local economy and undertaking revitalization strategies in both, it
increases the sustainability of the community as a whole.
Neighborhoods should be within walking distance to downtown or business centers (typically no
more than a ½ mile from the downtown or business center). Neighborhoods where significant
CDBG and/or other funds have previously been expended may not be appropriate for a
comprehensive program. A local government may address no more than one neighborhood at a
time. There should be a comprehensive five year plan that involves neighborhood residents in
identifying needs and solutions. Plan elements should include but are not limited to:



Comprehensive needs assessment (qualitative and quantitative) and prioritization

Land use and housing existing conditions

Infrastructure and public facilities existing conditions

Public services (police, fire, health, education)

Inventory of vacant, dilapidated housing units
Comprehensive strategies for revitalization that guide investments to achieve the
following outcomes:

Improve neighborhood involvement and interaction

Provide safety and neighborhood pride

Address infrastructure and public facilities needs

Identify in fill housing opportunities

Improve physical appearance and property values

Promote sustainability and conservation
Specific actions to prepare for implementation of revitalization strategies:

Cost estimates for CDBG eligible activities and other planned activities

Analysis of acquisition requirements

LMI survey determination for individual activities, as needed

Code enforcement ordinance or other locally adopted and enforceable procedures as
appropriate

Anti-displacement and relocation plan, as appropriate

Maps illustrating existing conditions, problems and proposed solutions

Roles and responsibilities – neighborhood and local government involvement and
commitment in planning and implementation

Timeframe for implementation of all strategies, including phased implementation
activities
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Comprehensive neighborhood revitalization will involve multiple activities, including a public
safety component. Activities should be prioritized to address basic infrastructure and safety first
and, where feasible, geographically concentrated within the target area in order to make the
greatest impact. Housing activities may be limited to no more than 30% of all CDBG
improvements in order to focus on community-wide needs. Eligible activities may include:

Infrastructure – water, sewer, roads, drainage.

Public Facilities – sidewalks, security lighting and cameras, police and fire substations,
technology, multi-service centers to address crime risk factors, walking trails, green
space, landscaping.

Housing – infrastructure or other activities to support affordable and workforce housing;
painting of exterior facades, minor exterior repairs and exterior improvements to make
LMI owner occupied housing units more energy efficient.

Demolition and clearance of vacant and dilapidated properties.

Public Services – crime watch program, drug or gang education, awareness or prevention
programs. (Services are limited to 15% of the CDBG project activity costs, must be new
or expanded services, and applicant must commit to continue such services after the grant
is closed without creating an operating burden on the local government.)
The requirements discussed in the previous infrastructure subsection also apply to infrastructure
activities undertaken as part of neighborhood revitalization projects.
It is recommended that environmental reviews address the neighborhood and include all possible
phases/activities that might occur in the neighborhood.
Projects must address a national objective of the CDBG program. To qualify under the LMI Area
Benefit national objective, the service area must be residential and 51% LMI based on HUD
census data or survey. Housing activities must benefit LMI households.
The most successful projects have community buy in and take a self help approach. Under the
Main Street Program, having a strong organization is a key to success. The organization provides
volunteers, organizes community events and helps to keep the community informed. Resident
contributions may include a variety of other activities including trash pickup, clean up vacant
lots, plant a community garden, set up a community crime watch, install neighborhood signs,
build a neighborhood play ground or picnic area, create an elderly support group (calls to check
on them, rides to doctor or grocery store, etc.), after school programs, educational programs, and
other activities that result in a healthy neighborhood.
Acquisition, Clearance, Demolition and Brownfields
Acquisition
Typical reasons for the acquisition of real property include:

Blighted, deteriorated, properties needed to carry out community development,

Property for rehabilitation or redevelopment,
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
Property for the provision of public works, facilities, and improvements, or

To be used for other public purposes.
Costs that may be paid for with CDBG funds under this category include the cost of surveys to
identify the property to be acquired, appraisals, the preparation of legal documents, recording
fees, and other costs that are necessary to effect the acquisition.
Qualifying an acquisition activity under one of the CDBG national objectives depends entirely
on the use of the acquired real property following its acquisition. A preliminary determination of
compliance may be based on the planned use. The final determination must be based on the
actual use of the property, excluding any short-term, temporary use. Where the acquisition is for
the purpose of clearance that will eliminate specific conditions of blight or physical decay, the
clearance activity may be considered the actual use of property. If $100,000 or more of CDBG
funds is spent, any subsequent use or disposition of the property must be treated as a “change of
use.” If property is to be acquired for a general purpose, such as housing or economic
development, and the actual specific project is not yet identified, the grant recipient must
document the general use it intends for the property, the national objective category it expects
will be met, and make a written commitment to comply with CDBG requirements. See Re-Use
Plan requirements in Chapter 13 of the Implementation Manual.
If property is acquired or improved with CDBG funds, or any interest therein, is subsequently
transferred to another entity within five years of closeout, the property or interest must be sold to
the entity at the current fair market value unless the property will be used for an activity that
meets a CDBG national objective. Sales proceeds would be program income based on a pro rata
share if the local government also contributed to the activity.
The purchase of real property by the grant recipient or other entities under this eligibility
category is subject to the requirements of the Uniform Relocation Assistance and Real Property
Acquisition Policies Act. Among other things, this could mean that persons displaced as a result
of the acquisition must be provided with financial assistance.
An option to purchase property can be obtained (for 6 months at least) prior to grant award, but it
must contain language making the option contingent upon environmental review and removal of
environmental conditions. Prior to obtaining an option, a voluntary sale letter or notice of interest
in acquiring property (for involuntary transactions) must be sent, and wording should be added
that public funds are being sought for the project and an offer might not be pursued if funds are
not obtained. The voluntary letter must include an estimate of fair market value (obtained from
comparable sales in the neighborhood), and a statement that no eminent domain powers will be
used. Sample letters are included in the attachments to Chapter 10 of the Implementation
Manual.
Demolition/Clearance/Brownfield Activities
Activities under this category include:

Demolition of buildings and improvements,
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
Removal of demolition products (rubble) and other debris, and

Physical removal of environmental contaminants or treatment of such contaminants to
render them harmless.
CDBG funds may be used for clearance of debris and/or demolition of vacant, dilapidated
structures. Generally, non-housing structures to be demolished with CDBG funds must be
publically owned.
Clearance/Demolition actions can include: determination of environmental hazards on the
property (lead and asbestos) and proper removal; testing and disposal of hazardous materials;
utility disconnections; and demolition permits. Once demolition is complete, the site should be
leveled and seeded as appropriate, and any damages to sidewalks, curbs, drives, etc. repaired. It
is recommended that before and after photos be taken and maintained in the file.
Where activities under this category are integral to the construction of a building or improvement
on the cleared property, and where such construction is also to be assisted with CDBG funds, the
clearance activities may be treated as a part of the construction costs.
Clearance and demolition activities may be carried out as a Spot Slum/Blight, Area Slum/Blight
or Area Benefit national objective. For Area Benefit, the benefits must be available to all
residents in the target area and at least 51% of those residents musts be LMI. Under spot blight
the conditions must be detrimental to health and safety. Under Area Slum Blight the conditions
must have contributed to the deterioration of the area. Structures to be demolished require that
the grantee document through an inspection report that the structure is substandard or dilapidated
according to local building codes (for residential units, use H-1 Determination to Demolish
form).
Localities proposing demolition must have a written anti-displacement and relocation plan and
must follow it in the implementation of these activities.
Generally, multiple clearances or demolitions should be undertaken as part of an overall
revitalization program in a targeted area or be part of a comprehensive effort to address all
blighted properties. Demolition activities are typically carried out by the local government using
code enforcement tools or through written voluntary agreements with the property owner.
Most localities will use code enforcement tools to clear private properties that are dilapidated and
causing a blight. Such local governments have adopted ordinances that specify code enforcement
procedures. The International Building Code (IBC) has an optional International Property
Maintenance Code that can be locally adopted to address vacant and blighted properties.
State law at Title 31, Chapter 15 also provides procedures for local governments to deal with
dwellings that are unfit for human habitation. Below is a link to this law:
http://www.scstatehouse.gov/code/t31c015.php
If after being properly cited, the property owner does not bring the property into code
compliance, the locality must use its own funds to demolish the unit and then place a lien on the
property to recoup the expenses of the demolition and clearance from the owner of the property.
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A lien also ensures that there is no windfall profit to the owner for the improvement to the
property.
If the structure is privately owned and the local government does not follow the state and local
codes enforcement procedures, a voluntary demolition assistance agreement is required prior to
demolition which specifies the conditions of the assistance. The agreement grants written
permission from the property owner prior to carrying out any demolition/clearance and
documents that no persons or businesses will be displaced by the demolition and that the
property was vacant for at least 3 months prior to the grantee’s application for CDBG assistance.
Liens
When CDBG funds are used to help a locality pay for the upfront costs of demolition, a lien to
recoup those costs will be required, unless:

The demolition is done to address and support crime prevention efforts in a targeted LMI
neighborhood; and

The total CDBG cost related to demolition (such as legal, lead/asbestos testing and
removal, air monitoring, demolition, disposal, etc.) does not exceed $10,000 per property.
Properties demolished or cleared that do not meet the above guidelines will require a lien:

Generally the lien should be repaid if the property is sold within 5 years of the demolition
or clearance.

If the property is redeveloped for an LMI purpose the lien can be forgiven in whole or in
part depending on the amount of assistance.
Recovery of CDBG costs from a lien is considered program income.
Re-Use Plans
When CDBG funds are used for acquisition, demolition or improvement of publically owned
property, any subsequent use or disposition of the property must be treated as a “change of use”.
The grant recipient must document the general use or “re-use” it intends for the property, the
national objective category it expects will be met, and make a written commitment to comply
with CDBG requirements. Change of use applies for 5 years following close out of the grant. Pay
back of the grant is required if any change is ineligible. The grantee must notify GA if there are
any changes in use within five years of close out. For additional information regarding Re-Use
Plans, see Chapter5 Public Facilities in the Implementation Manual.
Housing Activity
Housing activities may be included in the comprehensive revitalization of neighborhoods. In
order to promote community sustainability, activities should take place within in-town
neighborhoods and near business centers. The development of vacant land or redevelopment of
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blighted properties is an appropriate revitalization strategy and is encouraged as a sustainable
development practice. Such activities may be carried out by non-profits, for profits or the local
government using a variety of funding sources. These activities should complement CDBG
funded neighborhood revitalization projects and water and sewer projects that involve the
connection of services to homes. Additional guidance regarding Housing Rehabilitation, New
Housing Construction and Activities in Support of Affordable Housing are included in Chapter 7
of the Implementation Manual.
Housing Rehabilitation
Housing rehabilitation projects may involve exterior improvement assistance for properties
within town neighborhoods or near business centers. These improvements are designed to make
communities more economically competitive by improving the overall physical appearance and
stabilizing neighborhood property values. Visual impact will be enhanced by painting and
making necessary repairs to facades and exteriors of concentrated neighborhood housing units
occupied by low and moderate-income persons.
In designing a housing rehabilitation program, recipients should adhere to the following HUD
and Grants Administration requirements.
Local Housing Committee
The design of a local housing assistance program may be done in conjunction with a local
housing rehabilitation advisory committee composed of persons representative of low-income
neighborhoods, local government representatives and other members of the community at large.
This committee is normally involved in setting policies and procedures for the program and
serving as a liaison between citizens in the project area, local staff and local elected officials.
Eligible Units / Improvements
Eligible units for rehabilitation include stick built or modular units that will be occupied by LMI
households after rehabilitation. Manufactured housing and vacant units are not eligible for
CDBG funding.
Eligible activities should create a positive visual/physical impact on the target area and may not
exceed $10,000 per unit. Exterior improvements to make LMI units more energy efficient are
also eligible. Typical façade/exterior repairs might include:

Painting of exterior surfaces or siding;

Roof repairs or replacement;

Porch repairs;

Installation of handrails, guardrails or handicap ramps;

Front or visible side window or exterior front door repairs or replacement; or
storm/energy efficient windows and doors throughout;
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
Gutter, fascia or eave repairs;

Crawl space door and vent repairs.
Installation of indoor facilities, if none exist within an LMI housing unit, are also eligible as
housing rehabilitation when the activity is part of water/sewer connections project.
Given the amount of CDBG funding available, it may not be possible to address all of the
exterior repairs needed on a housing unit. The locality is encouraged to obtain the necessary
leveraging to complete all such repairs. If this is not possible, then improvements should be
prioritized and targeted to those items that will make the greatest visual impact on the
community as a whole, beginning with exterior surfaces such as painting. The donation and
installation of smoke detectors or thermostats will be considered leveraging, even though they
are interior improvements.
Generally, assistance should not be provided to units that have previously received rehabilitation
assistance. Prior Grants Administration approval is required when such assistance is proposed.
Eligible Households
All households (homeowners/occupants) participating in a housing rehabilitation project are
required to be LMI. CDBG housing rehabilitation is a “direct benefit” activity and income
eligibility must be established for all persons directly benefiting from a CDBG project. Simply
because a household is elderly, disabled or exhibits other limited clientele characteristics, does
not mean that household automatically qualifies for CDBG housing assistance.
Homeowner Commitment
Prior to rehabilitating housing units (not including limited rehabilitation), there must be a written
and recorded agreement with each homeowner that specifies a commitment by the homeowner to
participate in the program and agree to the following:

Clean house and yard prior to rehabilitation. Recipients should insure that accumulations
of large piles of trash, garbage or other discarded debris on or about the premises are
removed or properly and safely stored. Such conditions, if not addressed, can pose a
serious threat to the health and safety of the residents as well as serve as a breeding
ground for rats, mice or vermin.

Contribute a minimum of five hours to any of the following:

Improvement to their own property (beyond routine maintenance),

Improvement to their neighborhood, or

Any other community service activities.
If the homeowner is physically and financially unable to contribute, it is acceptable
for a family member or other volunteer to provide the assistance. Grantees must
document the homeowner’s contribution prior to grant close out.
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
Homeowner agrees to occupy the unit or rent to an LMI household at affordable rents for
one year after the assistance.
Type of Assistance
With regard to the type and terms of assistance, recipients are responsible for designing a
housing rehabilitation program that meets community needs. Programs can be comprised of
deferred forgivable loans or traditional loans. In determining the type of assistance to be
provided, recipients should consider the income level of households to be assisted.
The following definitions are offered to explain possible program types and terms.

Deferred Forgivable Loans: Deferred forgivable loans may be provided to eligible
households for the cost of rehabilitation. These do not have to be paid back if the
homeowner commitments are met.

Loans: Loans to landlords must be conditional upon their provision of the required cash
match at the time of contract award and a written agreement to make their units available,
for at least one year or the term of the loan (whichever is greater), at rents affordable to
lower income tenants, or available for Section 8 Existing Housing Assistance.
Loans should be recorded to ensure payback if the unit is sold or if terms are not met.
Traditional loans require repayment of a principal amount plus interest. Funding recipients may
provide loans at a single interest rate, or establish a sliding scale where interest rate is related to
household income or ability to pay. The term of the loan is also at the discretion of the recipient.
All loans may be made for the same term or terms may be adjusted depending upon the size of
the loan and the borrower’s ability to pay (e.g., larger loans having longer terms). Grants
Administration recommends that single-family rehabilitation loans have terms that do not
exceed 5 years. Multi-family loans should typically have terms of 20 years or less. The
amortizing loan is instituted through the use of a mortgage and often accompanied by a
promissory note.
Maximum Levels of Assistance
All costs should be determined to be reasonable. A maximum of $10,000 in CDBG funds is
allowed for exterior improvements to stick-built or modular homes.
Property Standards and Improvements
All work completed must meet locally adopted codes. The state is also prioritizing the use of
green building and energy conservation techniques in construction practices, materials and
products. Efficient homes save homeowners money in operation costs, so all CDBG-funded
improvements, where feasible, should meet the State-adopted International Energy Efficiency
Code, ENERGY STAR, or a similar energy efficiency standard.
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Rental Properties
There are additional requirements for rental projects assisted with CDBG which include the
following:

Owners of rental units must provide a ten to fifty (depends on the number of properties
owned) percent cash match to the CDBG cost of rehabilitation of the unit and sign a
commitment to participate in the program. Match must be provided prior to executing the
construction contract. An exception to the cash match requirement may be allowed if the
homeowner is LMI and they receive no rent for the unit.

The remaining CDBG costs may be provided through either a forgivable loan, repayable
loan, or a combination of the two. Repayable loans are encouraged where there is ability
to pay.

Owners must be required to maintain insurance on the assisted property, keep taxes paid
and adequately maintain the property for at least one year if assistance is $10,000 or less
and 5 years for projects involving greater level of assistance (for multi-family).

Owners must rent to LMI tenants. Affordable rents must be instituted to protect renters
from rent increases or eviction due to housing rehabilitation. An affordable rent is defined
generally as rent plus utility costs which does not exceed the Section 8 Fair Market Rent
(FMR) for existing housing established by HUD under 24 CFR Part 888. These rent
controls must be instituted for a period of at least one year if assistance is $10,000 or less
and 5 years for multifamily projects, or for as long as there is a below-market rate for
rehabilitation loan, whichever period is longer. During this period, investor-owners may
only be allowed to impose minimal increases, primarily related to increased taxes or
insurance.


No authorized increase shall exceed 30 percent of the tenant’s monthly adjusted
income and/or the Section 8 FMR for the area, whichever is less. In no case shall
rents increase at a greater rate than the increase in the Consumer Price Index (CPI) for
the preceding twelve months.

Where the rent paid by a tenant prior to CDBG rehabilitation exceeds the FMR, after
rehabilitation rents may not increase at a greater rate than the increase in the
Consumer Price Index (CPI) for the preceding twelve months.

The rent amount must be clearly established in the contract agreement and all terms
and conditions shall remain in effect for at least five years or for the entire term of the
loan, if longer.
If a project proposes to rehabilitate multiple (more than one) properties owned by one
landlord, technical assistance is required prior to submission of the application. For
landlords owning multiple properties proposed for assistance in a target area, the
following applies:

A match of 30% of the assistance will be required if one landlord owns 2-4 units
proposed for rehabilitation.
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

A match of 50% of the assistance must be provided if one landlord owns 5 or more of
the units proposed for rehabilitation.

The match must be provided prior to construction.
Limited rehabilitation (water/sewer connection) projects involving rental units have the
following requirements:

In the event an LMI tenant does not occupy a particular rental unit, the owner must
pay for any connection, tap, or impact fees.

For rental units occupied by LMI tenants, the investor should pay for any connection,
tap or impact fees. However, CDBG funds may pay any hard costs (no fees) that are
CDBG eligible after the rental property owner enters into an agreement with the unit
of local government to maintain affordable rents and rent to LMI households for a
reasonable period of time.

In the event connection costs involve a mobile home park, an affordable rent
agreement must be obtained from the mobile home park owner prior to the provision
of the assistance.
Initial Inspection
An initial inspection of the property should be conducted to determine the condition of the unit’s
exterior and the extent of work required. The inspection should be done by a person capable and
qualified to perform such duties. An inspection checklist should be used for the initial inspection
to evaluate the dwelling’s exterior condition. Once completed, this checklist forms the basis for
outlining the type work necessary to bring the property to desired standards.
Depending on the level of assistance and the year the unit was built, a visual assessment, paint
testing or risk assessment may also be required to comply with the lead based paint regulations.
Lead-Based Paint Hazard Reduction
All units in a project assisted with CDBG funds must comply with Lead Based Paint regulations
which requires notifications to occupants, owners and purchasers.
The approach to addressing lead-based paint in CDBG funded projects depends on the level of
assistance. Please refer to the CDBG Implementation Manual in Chapter 7: Housing for more
information on the requirements.
Home Buyer/Maintenance Education
Funding recipients may incorporate homebuyer education and training on home maintenance
into their housing program. The objectives of such a program are to provide families with the
skills necessary to own and maintain their property at a standard level and provide training in
issues related to home finance and credit, maintenance and housekeeping.
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
This training can be structured as an educational program that includes either formal
classes and/or home demonstration visits to show techniques and to distribute
information.

Documentation should be kept indicating that a formal homeowner education program
has been carried out for each assisted household.

The recipient may enlist the services of the local community organizations trained in
providing this type homeowner education or carry out its own homeowner maintenance
education program.
Such organizations include:
 Department of Social Services,
 State Dept. of Consumer Affairs,
 University Extension Service Programs,
 Local lending institutions, and
 Nonprofit consumer counseling organizations.
More detailed information is available in Chapter 7 of the Implementation Manual. Funds can be
listed/budgeted as a public service activity.
Volunteers and Donations
The use of volunteers can help leverage the impact of the project on the neighborhood. If the
recipient wants to use volunteer labor in its housing or other projects, then local policies and
procedures should outline the procedures to be followed.
In accordance with Title I of the Community Development Act of 1974, as amended, volunteer
labor may be used in carrying out CDBG-funded housing rehabilitation on private residential
property. If the recipient decides to incorporate this element into its program design, the
volunteer commitment must be provided in the application. A commitment from the organization
(or individual if not part of an organization) estimating the approximate type of work, number of
hours, and available time frame should be submitted with the application. Also, volunteers must
have demonstrated capacity to do the required work and the following rules apply:

If volunteers will be provided through the efforts of a non-profit organization, the locality
should enter into an agreement with the non-profit to specify the work to be done, quality
and standards to be met and timeframe for completion.

An agreement should be executed between the homeowner and the volunteer group
clearly outlining all the work to be accomplished through donated labor and what donated
materials and supplies may be involved.

Grants Administration will require the same documentation to be in the files as if a
private, for-profit contractor has been contracted to complete the work. That
documentation should include a work write up or specification showing materials
required and the estimated cost for materials and labor.
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
All required elements of the rehabilitation work should be detailed in a work schedule.
The work schedule should specify all work items the volunteers will perform and
alternate means of accomplishing the work if the volunteers fail to perform satisfactorily.

All costs must be determined eligible and payments to contractors, subcontractors and
suppliers for materials and supplies purchased and used in the project must be
documented and procured in accordance with Grants Administration requirements.
Invoices from the supplier must be provided for work items and materials actually used
on the job.

A local government that utilizes volunteer labor for CDBG-funded housing rehabilitation
must inspect and insure the work is done in a quality manner and in compliance with
applicable codes and Grants Administration requirements.

Volunteer sign in or timesheets must kept to document the total contribution to the
project. All time must be calculated at $20.00 per hour worked (regardless of activity) or
based on the latest rate as indicated on the website www.independentsector.org.

The locality or non-profit organization providing the volunteers should obtain a blanket
liability policy for the project. The policy is CDBG eligible as long as it only covers the
CDBG project. All volunteers should also sign a waiver of liability form.
In-Kind and Donated Materials and Equipment
Donated materials, equipment and in-kind labor will extend the level of impact of a project. If
used to meet the match/leveraging requirement, documentation must be kept to verify actual
values. For in-kind work, timesheets must be kept, and the value should be based on the current
hourly rate of the employee performing the work. The value of donated materials and supplies
should be based on the market value at the time of donation. Documentation should include:

Date of donation

Name of donor

Estimate of market value and how the estimate was determined
For donations involving equipment, the FEMA rate should be used. The web site for this
information is http://www.fema.gov/schedule-equipment-rates.
Documentation should include:

Name of operator

Type of equipment used

Date/time/quantity used

Description of work
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Storage of materials for use by volunteers is an eligible CDBG expense. Any materials
purchased by CDBG for the project but not used become the property of the unit of local
government and must be used by the unit of local government or donated to a non-profit (such as
Habitat for Humanity) for future use on CDBG eligible activities.
Developing Cost Estimates and Preliminary Budgets
Pre-Agreement Costs
Prior to the effective date of the grant agreement and prior to the
The information on
release of grant funds by Grants Administration, at its own risk, an
allowable costs and
applicant may obligate and spend local funds for the purpose of
budgeting was taken from
application preparation and development of an environmental
Chapter 3 of the CDBG
assessment required by 24 CFR Part 58. Reimbursement from
Implementation Manual.
CDBG will only be allowed for expenditures identified as preagreement costs in the application and approved by Grants
Administration. The applicant may obligate and spend local funds to undertake certain other
activities related to planning and environmental review. Other activities such as acquisition or
engineering and design costs may only be undertaken with the prior written approval of
Grants Administration. This is encouraged so that project readiness can be improved.
After the effective date of the grant agreement, the applicant may be reimbursed with funds from
its grant, provided that such activities were undertaken in compliance with all applicable CDBG
requirements and detailed and approved in the application.
In order for such costs to be eligible for reimbursement under the CDBG program, applicants
must follow State procurement and contracting procedures when services are to be provided by
entities other than the local government (i.e., COGS, consultants, engineers). All contracts must
be approved by Grants Administration prior to execution in accordance with the policies outlined
in Chapter 8 of the Implementation Manual. Executed copies of contracts and agreements must
be maintained in the grant file.
The application should separate the costs for application preparation and environmental
assessment (if it is a pre-agreement cost) from general project administration. However, the total
costs should be shown in the general administration budget line item and are subject to the 10
percent maximum on general administration costs. Costs charged for application preparation will
be reviewed for reasonableness. The average charge is approximately $3,000 and costs are
generally expected not to exceed that amount. Costs which do exceed this amount must have
substantial justification and require prior approval to be CDBG reimbursable. No reimbursement
will be made to any locality that does not receive CDBG funds for the project for which costs
were incurred.
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Acquisition Costs
Estimated costs of easements for water lines, sewer lines, street widening, etc., must be budgeted
under the "Acquisition" line item. Appraisal and review appraisal fees, legal and title search
costs should also be listed under the Acquisition budget item.
Water/Sewer Tap and Connection Costs
Generally, the costs associated with connecting an LMI residential unit to a water or sewer line
are considered housing rehabilitation. These are activities that occur on private property and may
be contracted separately from or with the main water/sewer line construction. These costs
include service lines and appurtenances on private property. The provision of indoor plumbing
facilities associated with a water or sewer project is also considered housing rehabilitation.
In order to ensure that LMI households receive the benefits of residential water or sewer
improvements, any connection, tap or impact fees, and service lines (lines running between the
distribution or collection line and the housing units) must be provided to LMI households at no
cost to the LMI household as a direct beneficiary. CDBG funds may only be used for hard
construction and installation costs for low and moderate income hook-ups/connections to public
water and sewer, and not to pay any water or sewer connection, impact or capacity fees. Any
associated fees for low and moderate income hook up/connection to public water and sewer must
be waived or paid with non-CDBG funds, and may be considered part of the local match
requirement.
For rental units occupied by LMI tenants, the investor should pay for any connection, tap or
impact fees. However, CDBG funds may pay hard costs after the rental property owner enters
into an agreement with the unit of local government to maintain affordable rents and rent to LMI
households for a reasonable period of time.
In the event connection costs involve a mobile home park, an affordable rent agreement must be
obtained from the mobile home park owner prior to the provision of the assistance. (See the
CDBG Implementation Manual, Chapter 5 - Public Facilities for more information.)
Housing and Rehabilitation Personnel Costs
Funds budgeted for staff conducting a housing rehabilitation project activity (developing work
write-ups, conducting inspections, etc.) must be budgeted separately under Rehabilitation
Personnel. These are activity delivery costs and do not include costs for general administration of
the grant. The cost of any lead-based paint hazards evaluation (LBP Inspection, LBP Risk
Assessment, or Lead Hazard Screen) and lead clearance testing should be included in the
Rehabilitation Personnel line item. Generally, the cost of rehabilitation personnel should not
exceed $1,500 per unit without prior Grants Administration approval. The cost of title searches
and legal fees should also be included in the Rehabilitation Personnel line item. Housing
counseling may be considered a public service activity. The CDBG cost of rehabilitation
personnel combined with the cost of general administration should be reasonable and should not
exceed 25 percent of the rehabilitation line item cost.
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Engineering Costs
CDBG funds may be used to pay for specific engineering costs, up to the CDBG Engineering
Fee Schedule. (see the Attachments to these Guidelines). CDBG funds may be used to pay for:

Wetlands delineations,

Preparing drawings and specifications,

Providing information for use in acquiring easements or other real property,

Providing information for use in filing applications for permits or design approvals,

Revising drawings in response to directives from governmental authorities as needed,

Preparing bidding documents and revising, as needed,

Bidding the project and negotiating with contractors, as needed,

Putting the contract together and participating in the pre-construction conference,

Construction observation and inspection,

Preparing pay requests,

Conducting final inspection and providing a notice stating that the work is acceptable,

Preparing final, as-built drawings.
Any additional services or costs which exceed this schedule should be paid with local funds.
Additionally, if the fee schedule for construction management is exceeded due to a reduction in
the construction costs, then local funds must make up the difference.
Special Assessments
"Special assessment” means the recovery of the capital costs of a public improvement, such as
streets, water or sewer lines, curbs, and gutters, through:

A fee or charge levied or filed as a lien against a parcel of property as a direct result of
benefit derived from the installation of a public improvement; or

A one-time charge made as a condition of access to the public improvement.
This term does not relate to taxes or periodic charges based on the use of public improvements,
such as water or sewer user charges even if such charges include the recovery of all or some
portion of the capital costs of the public improvement.
Where CDBG funds are used to pay all or part of the cost of a public improvement, special
assessments may be used to recover capital costs as follows:

Special assessments to recover CDBG funds:
Special assessments to recover CDBG funds may only be made against properties not
owned and occupied by LMI persons. Such assessments are program income.
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
Special assessments to recover non-CDBG funds:
Special assessments to recover the non-CDBG portion may be made provided that CDBG
funds are used to pay the special assessment on behalf of all properties owned and
occupied by LMI persons, except that CDBG funds need not be used to pay the special
assessments in behalf of properties owned and occupied by moderate income persons, if
the grant recipient certifies that it does not have sufficient CDBG funds to pay the
assessments in behalf of all of the LMI owner-occupants. Funds collected through such
special assessments are not program income.

Public improvements not initially assisted with CDBG funds:
CDBG funds may be used to pay special assessments levied against property when this
form of assessment is used to recover the capital cost of eligible public improvements
initially financed solely from sources other than CDBG.
The payment of special assessments with CDBG funds constitutes CDBG assistance to
the public improvement. Therefore, CDBG funds may be used to pay special assessments
only if:
1) Installation of the public improvement was carried out in compliance with
requirements applicable to activities assisted with CDBG funds including
environmental, citizen participation and Davis-Bacon requirements;
2) Installation of the public improvement meets a criterion for national objectives (i.e.,
LMI Benefit, Slums or Blighted Area, or Urgent Need); and
3) Requirements described above for “Special assessments to recover non-CDBG funds”
are met.
Fair Housing Activities
The recipient certifies that it will take affirmative actions to further fair housing during the grant
period. Such activities are eligible as CDBG administrative costs but may also be undertaken as a
separate line item in the approved budget. As a separate line item the activities would not be
subject to administrative cost limitations; however, significant and measurable activities would
have to be carried out directly for the benefit of the recipient and its residents.
Contingency
Funds providing for contingencies may not be budgeted as a separate activity or budget line
item. A contingency must be contained within the specific activity's budget line item for which it
is intended and must be reasonable in amount.
CDBG Administrative Costs
CDBG funded administrative costs should not exceed 10 percent of the CDBG project activity
costs, excluding administrative costs, with a $50,000 maximum. In the case of a complicated
project or small project scope or other extenuating circumstances, GA will consider allowing up
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to 15 percent of the CDBG-funded project activity costs (excluding administrative costs). A
written request must be submitted to Grants Administration.
Local or other funds must be used for additional administrative costs. CDBG funds may not be
used to administer other federal or state grant programs which may be conducted in conjunction
with a CDBG project.
(Note: A general conflict exists where a local government awards a contract to a firm to
administer its CDBG program, while the same firm is to provide engineering or architectural
design service on the same project. In this case, an administrator may not oversee and approve its
own work.)
Federal regulations do not allow CDBG funds to be used to supplant available local funds.
Typically, local governments that administer their own grants (do not contract with a consultant
or COG) provide the administration as in-kind leveraging (above the required local cash match).
However, local governments that wish to charge costs or an employee’s time for administration
of the CDBG project to the CDBG budget must first submit a certification that the use of federal
grant funds for a portion of the employee’s salary will not supplant available local funds. Any
costs and time charged must be documented through the appropriate means (i.e., invoices from
local newspapers for advertisements placed for hearings, travel costs, time sheets indicating work
performed for the particular project, etc.). The documentation must be kept on file, and will be
reviewed at financial monitoring.
Required Match and Leveraging
It is the goal of the CDBG program to ensure that CDBG funds are used as a catalyst for other
investments. Matching funds and leveraging requirements may vary according to the program
category and year of funding, but written commitments must be provided for required match and
any additional funding pledged to a CDBG project. Required match generally refers to the
minimum contributions to the grant. Leveraging refers to additional, other non-CDBG funds
required to complete the project. Required match and leveraging may include funds from other
federal, state and local funding sources, private investment, or non-profit contributions.
Matching and leveraging resources may include cash, in-kind, force account labor, volunteer
labor or donations, as well as grants, loans or waiver of fees (except as otherwise noted).
Application Requirements
CDBG projects are expected to leverage other public and private investments and serve as a
catalyst for future development. Projects that traditionally have the greatest long term impact are
those that have an investment by the community. Leveraging of CDBG funds is also considered
a scoring factor in the selection of projects for funding.
There must be a minimum 10% match of the total CDBG request, unless otherwise approved,
which can come from a variety of committed sources including other, non-Commerce grants,
loans, waiver of fees, public or private investments, and documented volunteer or in-kind
contributions.
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Required match must be for activity costs directly related to the CDBG project. The state must
approve in advance any proposed match that has been spent (except application or environmental
review costs) prior to application submission for all projects except Ready to Go. With prior
written approval, the match may be used for acquisition, engineering design or permitting prior
to the submission of the application. This is encouraged so that projects are construction ready.
Localities unable to provide for the full amount of required match at the application stage must
contact Grants Administration prior to submitting the application request. Grants Administration
reserves the right to modify the matching requirement for any grant where Grants Administration
determines such modification to be necessary and appropriate based upon the nature of the
project, the identified needs to be addressed, and the availability of community or other
resources. The applicant must submit a written request to Grants Administration to waive or
modify the matching requirements. It is unlikely that a full waiver of the matching requirements
will be granted, since leveraging can come from a variety of sources. In order to determine local
financial capacity, Grants Administration may require the submission of the recently completed
audits of the applicant and/or water and sewer authority as appropriate.
Local Funds
The locality must submit with its application a resolution from its governing body that commits
any matching or leveraging funds to be provided by the applicant. The resolution must also
identify the type and source of funds and commit to sharing cost savings on a pro rata basis.
Matching funds must be committed at the application stage and must be immediately
available for the project at the time CDBG funds are released.
The revenue from the state gasoline tax that is allocated to counties for transportation projects,
known as C-Funds, can be considered local funds for match since the county exercises authority
over their use. Locally approved sales tax can also be considered a source for the match. The
required match may also come from any other, non-Department of Commerce source.
CDBG program income may be used to match a CDBG grant, where that income is proposed to
continue the same activity that generated the income and where the proposed use is consistent
with an approved Program Income Plan. For example, program income generated by a housing
rehabilitation grant must be used to match other CDBG housing rehabilitation grants unless a
change in the program income plan is pre-approved by Grants Administration
Any fees for low and moderate income hook up/connection to public water and sewer must be
waived or paid with non-CDBG funds, and may be considered part of the match requirement.
Where matching funds or a waiver of fees are to be provided by a water and sewer entity, a letter
of commitment must be submitted with the application. When tap or connection fees are waived,
only the portion which is not being paid by the grant as an actual construction cost may be
counted as a waiver.
Other Funding Commitments
Projects often will require funds other than CDBG and local funds to accomplish goals and
objectives. When other funds are committed to the project, either to meet the minimum match
requirement or as additional leveraging, a letter of commitment must be submitted with the
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application. To document a public/private commitment, the applicant must submit a letter of
commitment from the public/private sector participant that specifies the amount of funds,
conditions, and the time frame in which such commitment will be carried out. Where other funds
are required to carry out the CDBG activity, such funds must be available at the time CDBG
funds are released.
For projects utilizing volunteer labor as a part of the required leveraging, a commitment from the
organization (or individual if not part of an organization) estimating the approximate type of
work, number of hours, and available time frame should be submitted with the application. A
rate of $20 per hour should be used to figure all volunteer time, regardless of the type of work
being performed. If in-kind labor will be used as part of the required leveraging, timesheets must
be kept, and the value should be based on the current hourly rate of the employee performing the
work. For donated materials, fair market value must be documented. For equipment usage, the
appropriate FEMA equipment rate must be used to determine value.
Local lending institutions intending to participate in projects must submit letters of commitment
clearly stating that funds will be made available for use and any conditions or restrictions that
may be placed upon the program or loan applicants.
Requirements and Certifications
Conflicts of Interest
In the procurement of supplies, equipment, construction and
This information on
services by recipients and subrecipients, the provisions of the
Compliance Requirements
South Carolina Ethics, Government Accountability, and
was taken directly from
Campaign Reform Act of 1991 shall apply. In all cases not
Chapter 14 of the CDBG
governed by the ethical standards of the South Carolina Ethics,
Implementation Manual.
Government Accountability, and Campaign Reform Act of 1991,
such as the acquisition and disposition of real property and the
provision of assistance with CDBG funds by the recipient or its subrecipients to individuals,
businesses and other private entities under eligible activities, the conflict of interest provisions in
the State CDBG regulations at 24 CFR Part 570.489 (h) shall apply in addition to the State Ethics
Law.
The CDBG requirements pertaining to conflict of interest are summarized in the following
paragraphs.

Conflicts Prohibited - Except for the use of CDBG funds to pay salaries and other related
administrative or personnel costs, the general rule is that no persons (described below
under “Persons Covered”) who exercise or have exercised any functions or
responsibilities with respect to CDBG activities or who are in a position to participate in
a decision-making process or gain inside information with regard to such activities, may
obtain a financial interest or benefit from a CDBG-assisted activity, or have an interest in
any contract, subcontract or agreement with respect thereto, or the proceeds thereunder,
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either for themselves or those with whom they have family or business ties, during their
tenure or for one year thereafter.

Persons Covered - The Conflicts of Interest provisions apply to any person who is an
employee, agent, consultant, officer, or elected official or appointed official of the State,
the unit of local government, or of any designated public agencies or subrecipients that
are receiving CDBG funds.

Exceptions - Upon the written request of the applicant/recipient, Grants Administration
may grant an exception to the provisions of this section on a case-by-case basis when it
determines that such an exception will serve to further the purposes of Title I and the
effective and efficient administration of the program or project of the State or the unit of
local government. An exception may be considered only after the local government has
provided the following:


A disclosure of the nature of the conflict, accompanied by an assurance that there has
been public disclosure of the conflict and a description of how the public disclosure
was made;

A certification the affected person has withdrawn from his or her functions or
responsibilities, or the decision-making process with respect to the specific assisted
activity in question; and

An opinion of the local government's attorney that the interest for which the
exception is sought would not violate State or local law. In addition, Grants
Administration may also require an opinion from the State Ethics Commission that
the conflict does not violate State law.
Factors To Be Considered For Exceptions - In determining whether to grant a requested
exception after the local government has satisfactorily met the above requirements,
Grants Administration shall consider any opinion of the State Ethics Commission, if
requested, and the cumulative effect of the following factors, where applicable:

Whether the exception would provide a significant cost benefit or an essential degree
of expertise to the program or project which would otherwise not be available;

Whether an opportunity was provided for open, competitive bidding or negotiation;

Whether the person affected is a member of a group of low or moderate income
persons intended to be the beneficiaries of the assisted activity, and the exception will
permit such person to receive generally the same interests or benefits as are being
made available or provided to the group or class;

Whether the interest or benefit was present before the affected person was in a
position as previously described;

Whether undue hardship will result either to the State or local government or the
person affected when weighed against the public interest served by avoiding the
prohibited conflicts; and

Any other relevant considerations.
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Disclosures
Overview
Section 102 of the HUD Reform Act of 1989 contained a number of provisions designed to
ensure greater accountability and integrity in the way HUD and its recipients make certain types
of assistance available. The State CDBG Program is one of the programs that are partially
covered by the requirements of Section 102. The regulations implementing Section 102
(currently 24 CFR Part 4, Subpart A) are included in the Reference Section of the CDBG
Implementation Manual.
A unit of local government applying to the State for a grant will be required to make certain
disclosures, as will applicants for assistance from units of local government receiving State
CDBG grants. Such disclosures will only be necessary if the aggregate amount of the covered
assistance received or expected to be received by the applicant will exceed $200,000 in the
Federal fiscal year (October 1 - September 30) in which the application is submitted. The
disclosures must be made on the Section 102 Disclosure Report included in the attachments to
Chapter 14 of the Implementation Manual.
The nature of the disclosure includes the amount of assistance sought from Grants
Administration and other government assistance to be used with respect to the activities to be
carried out with the assistance, the financial interests of persons in the activities, and the sources
of funds to be made available for the activities and the uses to which the funds are to be
expended.
Assistance subject to these requirements includes any contract, grant, loan, cooperative
agreement or other form of assistance under the CDBG program. This includes construction
contracts and contracts for professional services.
Required Disclosures
Each applicant that submits an application for assistance to the State or to a unit of local
government for a specific project or activity must make the disclosures if the applicant has
received, or can reasonably be expected to receive, an aggregate amount of all forms of such
assistance in excess of $200,000 during the Federal fiscal year in which the application is
submitted. The amount of assistance also includes program income received from CDBG
projects.
Content of Disclosure
Applicants that meet the assistance threshold must disclose the following information:

Other government assistance: Any other government assistance that is or is expected to
be made available with respect to the project or activities for which the assistance is
sought.

Interested parties: The name and pecuniary interest of any developer, contractor or
consultant involved in the project or activities for which the assistance is sought that
exceeds $50,000 or ten percent (10%) of the assistance, whichever is lower. If the
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interested party is an entity, the disclosures must include an identification of each officer,
director, principal stockholder (as specified in the Section 102 Disclosure Report
instructions) or other official of the entity.

Sources and uses of funds: The expected sources of funds that are to be made available
for the project or activity, and the expected uses to which those funds are to be expended
must be disclosed. The report must identify the gross amount of funds from all sources,
including but not limited to both governmental and non-governmental sources of funds
and private capital resulting from tax benefits. Residency of an individual in housing for
which assistance is being sought is not by itself considered a pecuniary interest.
Certifications
When an application for CDBG funds is submitted to Grants Administration, it contains a
number of certifications that the local government must sign and agree to carry out as part of its
approved CDBG program. These certifications are mandated by the provisions in Title I. Grants
Administration representatives will monitor recipients for compliance with the certifications. The
following provides a summary of each certification.

Citizen Participation - The first three certifications require that a Needs Assessment and
Citizen Participation Plan be developed. It also requires that citizens be furnished
information on the CDBG program, amount of funds available and range of activities that
may be undertaken, including the amount proposed to benefit low and moderate income
persons.

Residential Anti-Displacement and Relocation Assistance Plan - Recipients must develop
and follow a plan which has two components: (1) a requirement to replace all low and
moderate income dwelling units that are demolished or converted to a use other than low
and moderate income housing as a direct result of the use of CDBG funds; and (2) a
relocation assistance requirement. This plan is required of all recipients regardless of the
type of project funded. (For additional information, refer to Chapter 11 of the
Implementation Manual.)

Minimize Displacement - The recipient certifies that it will minimize the displacement of
persons as a result of activities that are CDBG funded. CDBG funds should not be used
to carry out activities that result in displacement unless there is a health and safety threat.
The local government must provide a certification that there are no other feasible
alternatives.

Public Access to Records - The public must be provided reasonable access to records
regarding the past use of CDBG funds. This provision should be included in the Citizen
Participation Plan. Grants Administration requires recipients to hold one or more public
hearings to inform the public of the accomplishments of the CDBG program and to assess
performance.

Special Assessments - Where CDBG funds are used to pay all or part of the cost of public
improvements, special assessments may only be used to recover capital costs as follows:

No special assessments may be made to recover CDBG funds: Special assessments to
recover CDBG funds may be made only against properties not owned and occupied
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by low and moderate income persons. Such assessments are considered program
income.

Special assessments to recover non-CDBG funds: Special assessments to recover the
non-CDBG portion of a project may be made, but CDBG funds must be used to pay
the special assessment on behalf of all properties owned and occupied by low and
moderate income persons. CDBG funds need not be used to pay the special
assessments on behalf of properties owned and occupied by moderate income persons
if the grant recipient certifies that it does not have sufficient CDBG funds to pay the
assessments in their behalf. Non-CDBG funds collected through such special
assessments are not program income.

The payment of special assessments with CDBG funds constitutes CDBG assistance
to the public improvement. Therefore, CDBG funds may be used to pay special
assessments only if installation of the public improvements was carried out in
compliance with requirements applicable to activities assisted with CDBG funds,
including environmental, citizen participation and Davis-Bacon requirements; and
installation of the public improvement meets a criterion for one of the national
objectives.

Compliance with Title VI of the Civil Rights Act of 1964 and the Fair Housing Act Recipients are required to take a proactive role in affirmatively furthering fair housing in
the community. Actions to promote fair housing are required to be taken and documented
prior to close-out of a CDBG project. Recipients also agree that no person will be
excluded from participation, denied program benefits, or subjected to discrimination on
the basis of race, color, disability, familial status or national origin. (For additional
information, refer to Chapter 12 of the Implementation Manual.)

Compliance with Title I and Other Applicable Laws - The CDBG program will be
conducted in accordance with the provisions of Title I of the Housing and Community
Development Act, as amended, as well as other Federal or State requirements and laws.
These other requirements include environmental standards, labor standards, acquisition
and relocation requirements, fair housing and equal opportunity, Section 504 disability
requirements, etc.

Excessive Force - The Armstrong/Walker "Excessive Force" Amendment (P.L. 101-144)
is found in Section 519 of the Department of Veteran Affairs and Housing and Urban
Development and Independent Agencies Appropriation Act of 1990. A recipient must
certify that it has adopted or will adopt and enforce a policy to prohibit the use of
excessive force against any individuals engaged in non-violent civil rights demonstrations
by law enforcement agencies within the jurisdiction. The legislative history of this
provision indicates that it may be satisfied by any means that will stand a practicable test
of use. The policy may be adopted by a local legislative act, such as an ordinance, or by a
local administrative act, such as a written statement of policy by the chief executive, an
executive order or regulation within the police department. A unit of general local
government need not adopt a new policy if it has and is enforcing a written policy that
meets the requirements of Section 519. This provision does not amend Title I of the
Housing and Community Development Act of 1974, as amended, but applies to the
CDBG program.
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
Lobbying - The lobbying certification is a result of the requirements contained in Section
319 of Public Law 101-121. It is applicable to the lobbying of federal officials using
CDBG funds. CDBG funds may not be used to influence or attempt to influence the
awarding of any CDBG project, loan, contract or cooperative agreement. This provision
also applies to the renewal or modifications to any CDBG project, loan, contract or
agreement. If non-CDBG funds are used for this purpose, the recipient must file a
Standard Form LLL, Disclosure Form to Report Lobbying. This language must be
incorporated in any award documents at all tiers including subrecipient agreements,
recipient contracts or loans and cooperation agreements that exceed $100,000 in CDBG
funds.

Debarment Certification - Grants Administration requires a Debarment Certification be
submitted with the Start-Up Checklist requirements. The recipient certifies that neither
the local government nor its officers are debarred, suspended, ineligible or voluntarily
excluded from receiving funds. Subrecipients and contractors must also sign this
certification before entering into any financial agreements or contracts with the recipient.
SC Financial Identity Fraud and Identity Protection Act
The SC Financial Identity Fraud and Identity Protection Act (the “Act”) became effective on July
1, 2009. Following are the requirements concerning the collection, maintenance, and disposal of
personal information pertaining to residents of South Carolina. Under the Act, “personal
information” includes:

Social security number (SSN)

First name or first initial and last name

Driver’s license number

Financial account number (including credit card or debit card number and security code)

Any other information that would allow access to a person’s financial accounts
With respect to personal information, you may be subject to the following restrictions:

You may only collect personal information for legitimate purposes as required by law.

You may not make personal information available to the public.

You should minimize the dissemination of any personal information either internally
within your organization or externally with the general public.

When you are finished processing documents that contain personal information, you must
ensure that all personal information is unreadable or undecipherable.

Before disposal of any hardware or storage media, all personal information must be
removed and the media must be sanitized.

Do not store personal information on any laptop, blackberry, CD, etc. unless the file is
encrypted and password protected.
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With respect to SSNs, there are additional restrictions, including the following:

You may not intentionally print or imbed a person’s SSN, or six or more digits of such
number, on a card required for access to services.

You may not require a person to transmit a SSN, or six or more digits of such number
over the internet UNLESS there is a secure connection or the SSN is encrypted.

You many not require a person to use his/her SSN, or six or more digits of such number,
to access an internet website UNLESS a password is also required to access the internet
website.

You may not print a person’s SSN, or six or more digits of such number, on materials
mailed to that person, UNLESS state or federal law requires it.

You may not collect a person’s SSN, or six or more digits of such number, UNLESS you
are authorized by law to do so.

When collecting a person’s SSN, or six or more digits of such number, you must separate
the number from the rest of the record, or as otherwise appropriate so the SSN can easily
be redacted pursuant to a Freedom of Information Act request.

At a person’s request, you must give a statement of the purpose for collecting his/her
SSN, or six or more digits of such number, and how it will be used. You can only use the
person’s SSN, or six or more digits of such number, for the purpose stated.
If at any time there has been an unauthorized access to personal information or there is any risk
of unauthorized access, you must immediately notify all persons whose personal information has
or has a material risk of being accessed. If the number of persons is greater than 1000, notice
must also be given to the SC Department of Consumer Affairs.
If you have any questions concerning these requirements, please contact your local attorney.
Required Federal Registration for Grantees
The Federal Funding Accountability and Transparency Act (FFATA) of 2006 mandated specific
reporting requirements for recipients of federal funds. Grants Administration is required by
FFATA to submit information to the Office of Management and Budget (OMB) through an
electronic Sub Award Reporting System (FSRS) on all grant awards equal to or greater than
$25,000 which are awarded on or after October 1, 2010. In order to report in this system, each
State award recipient must have a Dun & Bradstreet (DUNS) number and a CAGE Code,
assigned as a result of registration in the federal System for Award Management (SAM), which
replaced the Central Contractor Registration system in 2012.
Since GA is required to file a FSRS report by the end of the month following grant award (or
approval of an increase), CDBG grantees are required to provide evidence of their active SAM
registration, showing CAGE Code and DUNS number. This must be submitted at the time of a
CDBG application.
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DUNS Numbers
According to federal government policy, every local government or contractor that receives
federal assistance such as CDBG must register in the System for Award Management, which in
turn requires a DUNS number. The DUNS number is a unique 9-digit identifying number
assigned by Dun & Bradstreet (D&B), and there is a streamlined process for Government
Grantees. Note that, for economic development grants, the business receiving or benefiting from
assistance must also have a DUNS number, which is required to be reported as part of grant close
out. Businesses benefiting from economic development grants can also use the streamlined
DUNS process. DUNS registration can be obtained online at:
https://iupdate.dnb.com/iUpdate/viewiUpdateHome.htm
For grantees, the DUNS number must be obtained as soon as possible, and for economic
development grants, grantees should ensure that each business has a DUNS number before
assistance is provided.
System for Award Management (SAM)
The System for Award Management (SAM) is a federal website which consolidated several
previously existing federal systems, including CCR, federal procurement systems and the
Catalog of Federal Domestic Assistance. The purpose of SAM is to reduce the number of
different systems required to enter and interact with the Federal Government. SAM training
videos, user guides and list of Frequently Asked Questions (FAQs) are all available on
www.sam.gov in the Help section. SAM’s list of “SAM Top FAQs” is included in the
attachments to this chapter.
For all CDBG grants or grant award increases equal to or greater than $25,000, the recipient
must have a CAGE Code assigned as a result of: a) having registered with the Central Contractor
Registration (CCR) system and transferred this registration into SAM, or b) registered in SAM.
The SAM system may be accessed online at www.sam.gov.
Program Income Plan
Program income is defined as gross income received by a unit of general local government or a
subrecipient of a unit of general local government that was generated from the use of CDBG
funds. Program income does not include the total amount of funds from all such grants which is
less than $35,000 received in a single year (January 1 to December 31) that is retained by a unit
of general local government or its subrecipient. More detail on Program Income is in Chapter 4
of the CDBG Implementation Manual.
Each CDBG grant must contain a Program Income Plan (PIP), whether income will be received
or not. The State will normally require that all program income derived from CDBG funds be
returned to the State unless the recipient requests to retain program income to be used for the
same activity that generated the program income. An example of this would be retaining income
received during a housing rehabilitation grant to rehabilitate additional houses. Grants
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Administration will determine when an activity is considered to be a continuation of the same
activity that generated the income.
Submit Application to Grants Administration
The required number of copies of applications should be sent to the following address:
South Carolina Department of Commerce
Grants Administration
1201 Main Street, Suite 1600
Columbia, South Carolina 29201
Number of Copies

Community Development: 5 + original + electronic version

Ready to Go: 2 + original + electronic version

Regional Planning: 1 + original + electronic version

Business Development: 2 + original + electronic version
Community Infrastructure

Applications due:
April 13, 2015 at 5:00 p.m.
Community Enrichment and Neighborhood Revitalization

Applications due:
September 14, 2015 at 5:00 p.m.
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PHASE FIVE: SELECTION PROCESS
Grants Administration will review all of the applications it receives for completeness and
eligibility of activities under federal and state guidelines. Applications will also be reviewed
based on the following factors to determine fundability and feasibility of the project:

Appropriateness of the technical design, given the size and resources of the community
and the complexity of the problem

Project is ready to start
Applications that are incomplete or contain significant problems, deficiencies or discrepancies,
such that a determination of the viability or fundability of the project cannot be readily
determined, will not be considered and will be returned to the applicant. Clarifications to the
application which are requested by Grants Administration must be submitted within the
timeframe specified and must be acceptable to Grants Administration. Failure to adequately
respond within the timeframe may result in the application being returned to the applicant or GA
may reduce or eliminate questioned activities.
A site visit of the proposed project may be conducted as necessary to verify information in the
application. If requested, applicants should have the people responsible for writing the
application, and the people who are most familiar with the project area available during the site
visit. The applicant should ensure that the application is internally consistent and that all
numbers are correct prior to submission.
The next phase of the review process involves comparison of each application to the appropriate
Selection Criteria listed previously in these Application Guidelines. Grants Administration may
utilize the expertise of other appropriate State agencies, such as the SC Department of Health and
Environmental Control or the State Housing and Finance Development Authority in making a
determination regarding the above factors. Grants Administration may request additional
information from the applicant or other sources as necessary to evaluate the application and
proposed project. Grants Administration reserves the right to negotiate or require changes in
activities or funding in order to achieve program objectives. For water and sewer projects, the
State may require that rates be adjusted to appropriate levels to ensure adequate funding for
operation and maintenance or to facilitate borrowing a portion of project costs if such rate
increases are reasonable and appropriate. Grants Administration reserves the right to reduce
grant amounts in a proportional manner for improvements to existing facilities where rates are
lower than the amount considered feasible.
In the event of a tie where there are more applications under consideration for funding than there
are funds available, preference will be given first to those applications addressing the highest
state priorities and second, to those with the highest Outcome score. If there continues to be a tie
the one that benefits the most LMI persons will be funded. The highest scoring projects
determined to be fundable will be recommended to the Secretary of the SC Department of
Commerce for funding. Funds may be recommended for projects that receive a minimum of 175
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points, as funds are available. The Secretary will make final funding determinations based on a
review of the projects utilizing the selection criteria and that best meet Department objectives.
Grants Administration may make commitments for funding from future rounds, or any additional
allocations, reallocations, recaptured or remaining funds, to projects in rank order from this
program year. Grants Administration may also make a commitment to a project and/or partially
fund a project (i.e. for ERR, acquisition, engineering) that scores sufficiently but is not ready due
to design, environmental or funding issues. Funding may come from this program year,
reallocated or recaptured funds, or be contingent on future years’ funding.
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OTHER PROGRAM CATEGORIES
Regional Planning Program
Funds Available:
$500,000
Grant Maximum:
$50,000*
* Waivers of the grant maximum may be considered for planning activities to conduct
comprehensive analyses of impediments to fair housing within a region and may also include
actions to eliminate such impediments.
Outcome
This program is designed to provide CDBG funds to Councils of Governments to assist local
governments in developing plans and building local community development capacity. This
assistance will build capacity to effectively determine community needs, long-term goals and
short-term objectives, and develop plans for carrying out effective strategies to address
community needs. The planning assistance need not be limited to the jurisdiction of the applicant
and will include both regional and local planning and technical assistance activities.
Requirements
One applicant from each regional planning district may apply for this assistance. Each of the
counties within a regional planning district must enter into an Intergovernmental Agreement to
apply for and implement regional planning assistance grants. This Agreement will designate a
lead county to apply for the grant to comply with all requirements of the application and grant.
The lead county will enter into a 12-month subrecipient agreement with the Councils of
Government to undertake the activities on behalf of the applicant. The subrecipient agreement
will include specific performance and reporting measures tied to the scope of work outlined in
the application and other appropriate factors. Planning activities must be directly related to an
activity which, if carried out, would be eligible under the CDBG program and meet one of the
three national objectives -- benefit to low and moderate income persons, aid in the prevention or
elimination of slums and blight, or meet other urgent community needs posing a serious threat to
the health or welfare of the community where other financial resources are not available to meet
such needs.
Performance Threshold
The 2013 Regional Planning grant must be 100 percent expended at the time of award of the
2014 Regional Planning Grant or unused funds must be returned to Grants Administration. All
other previous regional planning grants must be programmatically closed.
Application Deadlines and Selection Process
Applications due:
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Only one application will be funded within each of the ten planning districts of the State. The
awards will be based on completion of an acceptable application, which complies with the
program description requirements.
Business Development Program
Total Funds: $2,000,000
Outcome
This program provides financial resources for local governments to pursue opportunities that
create new jobs, retain existing employment, stimulate private investment, and revitalize or
facilitate the competitiveness of the local economy. Funding will be prioritized based on the
following order:
1) New or expanding businesses tied to job creation
2) Area economic development activities not associated with job creation
3) New or expanding local businesses that provide essential goods and services in
predominately LMI communities
Grant Amount
Grants and/or loans with performance requirements may be provided to assist new or expanding
businesses that propose to create or retain jobs. The level of assistance will be based on an
analysis of the needs of the business and the local government, the CDBG cost per job, and the
amount of investment by the business. Projects must first qualify based on the actual need for
assistance and do not automatically qualify for the maximum grant amount.
Maximum for job creation/retention:
Minimum:
$10,000 per job
$50,000
Maximum for area economic development:
Minimum:
$500,000
$50,000
Maximum for local goods and services:
o Service area less than 20% poverty or 70% LMI
o Service area equal/more than 20% poverty or 70% LMI
$350 per LMI person
$1,000 per LMI person
The maximum grant limit may be waived, by the Secretary of Commerce, where it is determined
that the increased cost is appropriate and necessary to address state and local economic
development needs as long as CDBG requirements will still be met. A waiver may be further
considered in unique circumstances where the level of assistance is determined justified by the
Secretary of Commerce based upon the overall impact of the project and where the necessary
level of assistance cannot be met by other available resources in a timely manner.
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Business Development Program Requirements
Applications for the Business Development Program must meet one of the three national
objectives of the CDBG program. There is an emphasis on expanding employment opportunities
for persons from LMI families. A unit of local government may apply at any time for a Business
Development Grant and grants will be awarded throughout the year, as funds are available based
on the funding priorities.
HUD regulations require that at least 51 percent of any jobs to be created and/or retained as a
direct result of CDBG assistance be for persons whose total family income is low to moderate
(LMI Jobs). Any business that will create or retain jobs directly as a result of any project
undertaken with a Business Development Grant must provide a written commitment of the total
number of jobs to be created or retained as a result of the grant funded activities. For new jobs,
the employer must commit to hiring at least 51 percent of the employees from low and moderate
income families. For jobs to be retained, the employer must establish that 51 percent of the jobs
to be retained are, or within a reasonable time period will be, held by persons from LMI families.
Where appropriate, Grants Administration will make a preliminary determination of the potential
for LMI jobs to be created by reviewing the entry-level job skills, educational requirements, and
job training opportunities to be provided and average wage. For retained jobs, there must also be
clear and objective evidence that permanent jobs would be lost without the CDBG assistance.
Jobs must be created within a reasonable time frame of the assistance, when the business
becomes operational (generally 24 months from time of the assistance). Grants Administration
may require a legally binding performance agreement which outlines repayment of a portion or
all of the CDBG funds awarded for a project if the jobs creation/retention commitment and LMI
hiring requirement is not met.
Generally, projects to support job creation through the location or expansion of retail and/or
services type projects (shopping centers, truck stops, etc.) may only be considered in areas which
qualify under HUD’s presumption criteria for low and moderate income benefit or in
predominately low and moderate income communities.
Grants Administration will not fund any project which involves the relocation of a business from
another state, in accordance with HUD requirements, where there would be a significant job loss
in the labor market area. Grants Administration also will not recommend relocation of a business
from one jurisdiction to another within the State. The Secretary, in an exceptional circumstance,
may waive this restriction where it is in the best interest of the State as a whole; e.g., where
relocation is necessary to retain an existing business or to permit significant expansion of
employment and such relocation will not have substantial negative impact on the local economy
and employment.
Performance Thresholds
At the discretion of Grants Administration, a grant may not be awarded to local governments
which have a serious, outstanding audit or monitoring finding related to any previously funded
CDBG grant where the grantee has not been responsive and/or there is the potential for
significant monetary restitution.
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Application Requests and Deadlines
The chief elected or administrative official of the unit of local government must request
applications for Business Development assistance from Grants Administration. Such requests
should include as appropriate, the name of the business, its product or service, estimated initial
capital investment, and the number of jobs to be created or retained. The request must also
briefly describe the project for which CDBG funds are being requested, the estimated total cost
of the project, the amount of CDBG funds being requested and the sources of all other funds
necessary to complete the project. (If a preliminary engineering cost report is available, it should
be included). Grants Administration may request a meeting with the potential applicant or may
conduct a site visit to determine the eligibility and feasibility prior to mailing an application.
Applications may be submitted at any time. Grants Administration may issue commitments at
any time for project funding contingent upon receipt of an acceptable written commitment from
the business (if job creation or retention is involved), acceptable application information,
compliance with CDBG program guidelines and HUD regulations, and continued program
funding.
Local Match
CDBG projects are expected to leverage other public and private investments and serve as a
catalyst for future development. Projects that traditionally have the greatest long term impact are
those that have an investment by the community.
There must be a 10% match/leverage of the total CDBG request, unless otherwise approved,
which can come from a variety of committed sources including other, non-Commerce grants,
loans, waiver of fees, public or private investments, and documented volunteer or in-kind
contributions.
The required match/leverage must be for activity costs directly related to the CDBG project. The
state must approve in advance any proposed match (except application preparation or
environmental review costs) that has been spent prior to application submission. With prior
written approval, the match may be used for acquisition, or engineering design or permitting
prior to the submission of the application. This is encouraged so that projects are construction
ready.
The match/leveraging requirement may be modified or waived by Grants Administration upon
written request and after consideration of the following minimum factors: the nature of the
project, the need being addressed, local financial capacity and the availability of other resources.
Grants Administration may request financial and other information as may be needed to make a
determination. It is unlikely that a 100% waiver will be approved since every community is
expected to make a contribution to the project.
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Eligible Activities
Projects Involving Essential Goods and Services
A local government or non-profit entity may use CDBG funds to assist local businesses that
provide essential goods and services needed by and affordable to LMI residents. There must be a
demonstrated market need. Activities may include acquisition and/or rehabilitation of vacant, in
town buildings for lease to a committed tenant.
Assistance may also include deferred forgivable loans to committed critical health care providers
in underserved areas for facilities or equipment. There must be documentation that the service
area is medically underserved based on DHEC or other similar documentation. Hospitals and
nursing homes are not eligible under this category.
Projects Involving Job Creation
The types of project activities that may be undertaken include the following:

Infrastructure Support: A local government may use CDBG funds to provide public
infrastructure to serve new or expanding businesses. Infrastructure includes off-site
water, sewer, roads, drainage, railroad spurs and other types of public facilities. These
types of improvements are often necessary in rural areas where infrastructure is not
always available. CDBG requires that the infrastructure provide services necessary to
serve a specific business. Speculative projects or projects that involve future growth are
generally not eligible.

Direct Assistance: A local government may provide eligible business development
assistance directly in the form of a grant and/or loan combination or a loan, or it may
provide the assistance through public or private non-profit organizations. Such assistance
may include site improvements, building, equipment, and working capital. Debt
repayment is not eligible.
A request for Direct Assistance should contain a business plan and financial information
with the following key elements:


General Information

Business name, name of principals, and the business address.

Purpose of the project- exactly what the assistance will be used for and why.

Amount proposed- the exact amount needed to achieve the purpose.
Business Description

History and nature of the business - details of what kind of business it is, its age,
number of employees and current business assets.

Ownership structure - details on company’s legal structure.
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
Management Profile



A short statement on each principal in the business – provide background,
education, experience, skills and accomplishments.
Market Information

Clearly define company’s products as well as markets.

Identify the competition and explain how this business competes in the
marketplace.

Profile customers and explain how this business can satisfy their needs.
Financial Information

Financial statements - balance sheets, profit and loss statement, and cash flow
analysis for the past two years plus year-to-date information for the current year.
If the business is starting out, provide a projected pro forma balance sheet and
financial projections for three years, including any proposed expansions, asset and
debt additions to balance sheet, and changes to income statement.

Personal financial statements of principal owners of the business.

Collateral to be pledged as security for the assistance.

Source, description, and status of all existing or proposed funding sources and
uses of funds.
For any direct assistance or local business providing essential goods and services activities, it is
required that the recipient conduct a financial analysis in accordance with HUD and State
guidelines to determine the appropriateness of such direct assistance. Businesses will be required
to submit the above mentioned financial and other information that documents the level of
assistance needed.
Grants Administration must determine the need for public assistance in offsetting private sector
expenses. A lack of financial need does not preclude CDBG assistance being made available, if
other factors warrant the assistance. However, the underwriting is necessary to determine the
level of assistance that may be appropriate when all factors are considered. This underwriting
must be conducted for any proposed activity that provides direct assistance to a business where
the activity does not involve a public facility or improvement.
Additionally, the business will be required to enter into a performance agreement and loan
agreement, as applicable, to include terms of the assistance, job creation requirements and any
other performance requirements.
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Economic Development Underwriting Guidelines
The CDBG regulations contain Guidelines and Objectives for Evaluating Project Costs and
Financial Requirements. These guidelines are designed to assist recipients in underwriting
economic development projects and in determining which projects are financially viable and will
result in the most efficient use of CDBG funds. Local governments must use the guidelines
provided as an appendix to the CDBG regulations at 24 CFR Part 570 for basic financial
underwriting of projects being considered for funding under economic development. Note that
these guidelines do not apply to public facilities or microenterprise activities.
There are six criteria:

Project costs are reasonable.

All sources of project financing are committed.

To the extent practicable, CDBG funds are not substituted for non-federal financial
support.

Project is financially feasible.

To the extent practicable, the return of the owner’s equity investment will not be
unreasonably high.

To the extent practicable, CDBG funds are disbursed on a pro-rata basis with other
finances provided to the project.
Each of these six criteria is discussed below.
1. Project Costs are Reasonable
A breakdown of all costs associated with the project (including working capital requirements)
should be evaluated to determine the reasonableness of each cost. This will help to avoid
providing too much or too little CDBG assistance for the proposed project.
If the budget is overstated there is probably no need for public resources. Conversely, if the
budget is understated, the quality of the project may be adversely affected which could also
reduce income available for debt service. In extreme cases, the project may go unfinished.
Recipients can control these risks in the following ways:

Receive project quotes from independent, third parties.

Look at costs of comparable projects.

Compare CDBG costs to capital investment.

Use guaranteed contracts, performance bonds or letters of credit.

Use retainages for contractor’s fee, developer’s fee or leasing reserve.
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2. Sources Are Committed
The grantee should verify that sufficient sources of funds have been identified to finance the
project (including debt and equity).

All other sources of funds do not have to be on hand prior to application. However, the
authorization of the public assistance may be made contingent upon conventional
financing being obtained.

Avoid the risk of approving and disbursing funds for a portion of the project without
sufficient funds from other sources to complete the development.
3. CDBG Funds Are Not Substituted for Non-Federal Funds
In general, the recipient should clearly establish that there is a need for the investment of public
resources. Incentive funds are far too scarce and valuable to waste. Typically, a project has one
or two types of funding gaps:

Financing gap, or

Rate of return gap.
Financing Gap
Calculating the financing gap determines the least amount of public funds needed for the project.
A financing gap is determined as follows:

Step 1: Determine the budget.

Step 2: Calculate the amount of debt the project can support.

Step 3: Compute the amount of equity the project can generate or the owner has
available.

If the budget is greater than/equal to the sum of debt plus equity, then there is a
financing gap. Public funds may by be invested.

If the budget is less than the sum of debt plus equity, there is no financing gap and,
therefore, no need for public investment.
The concept sounds complicated but is quite simple. As an example, assume someone contracts
to buy a house for $100,000. They go to a lender who will loan $80,000 based on income. They
have $12,000 in equity. Since their budget of $100,000 (ignoring closing costs for simplicity) is
greater than the sum of debt and equity ($92,000) the transaction cannot occur since there is a
financing gap. However, if they access an additional $8,000, they can complete the deal.
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Rate of Return Gap
A rate of return gap is a variation of the financing gap. The rate of
return gap is the ratio of income received by the owner to the equity
invested by the owner and is determined as follows:

Step 1: Determine the budget.

Step 2: Calculate debt project can support.

Step 3: Compute amount of equity necessary to complete the
project.

Step 4: Compare the benefits of the project to the equity
invested. Is the return a market rate?
Note that the rate
of return method is
more applicable to
real estate
transactions than
business deals,
particularly for
smaller projects.

If the market rate is greater than/equal to the rate of the prospective project, a gap
exists. Public funds should be invested.

If the market rate is less than the rate of the prospective project, there is no gap and
thus no need for public investment.
A simple example of how this would work: A rental house costs an investor $100,000 and will
have a debt of $80,000. The equity required to complete the house is $20,000. The benefits are
estimated at $1,000 per year in a return market that is averaging 10 percent. The return on this
property is five percent ($1,000/$20,000). If the market is demanding a 10 percent return, why
would a rational investor accept a prospective project with a five percent return? Thus, a rate of
return gap exists and public funds can be injected to drive the investor’s return to a market rate.
4. Financial Feasibility
Once a recipient has established the need for public funds, it must determine repayment terms. If
the terms are too harsh, the survival of the venture is jeopardized. If the terms of repayment are
too lenient, the public funds will over compensate the project.
The financial viability can be evaluated based on assumptions about the project’s market share,
sales levels, growth potential, revenue projections, project expenses, and debt service to
determine if the project will break even. This should also take into consideration that:

Some negative cash flow in the early years may be normal but project financing should
take this into consideration;

A financially viable project will also project sufficient revenues to provide a reasonable
return on equity investment; and

Experience and capacity of the business owners should be assessed.
5. Owner’s Equity Return is Not Unreasonably High
CDBG should not provide more than a reasonable return on investment to an owner, given
industry rates of return, local conditions, and the risk of the project. However, it is difficult to
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compute return on equity for small business projects. The use of standardized publications to
calculate rates of return for small businesses is not recommended. There are significant
variations in the data and there are many anomalies associated with small business which skew
results. This approach is more applicable to publicly–traded companies or real estate projects.
6. CDBG Funds Disbursed Pro Rata
As a general rule, CDBG funds should be disbursed proportional to the percentage of the project
they fund. For example, if CDBG funds are 20 percent of the project, CDBG funds should not
exceed 20 percent of the aggregate proceeds disbursed. One exception might be if funds are
allocated to acquisition and the property must be purchased first.
1
Public Benefit Standards
When CDBG funds are used for economic development projects or infrastructure improvements
carried out for the purpose of creating/retaining jobs for LMI persons, or to assist local
businesses that provide essential goods and services in predominantly LMI communities, the
CDBG rules require the application of Public Benefit Standards. These standards ensure that at
least a minimum level of public benefit is obtained from the expenditure of CDBG funds. Use of
these standards is mandatory.
The Public Benefit calculation must be done before the application for assistance is approved by
Grants Administration and prior to any assistance being provided. This requirement is separate
from the national objective requirement that 51 percent of the jobs ACTUALLY created or
retained be taken by LMI persons. (The performance agreement will specify the hiring
commitments and time frames and will hold the business responsible for repayment of any
CDBG funds required due to a failure to full CDBG hiring requirements.)
Projects Involving Essential Goods and Services
For projects involving assistance to local businesses that provide essential goods and services in
predominantly LMI communities, the public benefit is calculated as the cost per person
benefited.
Projects Involving Job Creation
In the case of job creation projects, the Public Benefit Standards are really a “cost per job”
calculation used to determine if the CDBG financial assistance per job created/retained is
appropriate. This requirement is separate from the national objective requirement that 51 percent
of the jobs ACTUALLY created or retained be taken by LMI persons. (The performance
agreement will specify the hiring commitments and time frames and will hold the business
responsible for repayment of any CDBG funds required due to a failure to fulfill CDBG hiring
requirements.)
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Calculating Public Benefit
Projects Involving Essential Goods and Services
These projects must qualify as an area wide LMI benefit. This means the area served must
consist of at least 51% LMI persons. The public benefit must be reasonable and the cost per LMI
person is limited to HUD requirements. The cost per LMI person residing in the area served by
the assisted business cannot exceed $350, except in a census tract with at least 20% poverty or in
a 70% LMI service area. In a 20% poverty or 70% LMI service area, the cost per LMI resident
cannot exceed $1,000.
Projects Involving Job Creation
The public benefit calculation begins by determining the total number of jobs to be created or
retained as a result of the activity for each particular business for which the activity is principally
being undertaken. (For example, 10 jobs to be created at Business A, 5 jobs to be created at
Business B, etc.) When counting jobs within each applicable business for public benefit
purposes, include all jobs to be directly created or retained as a result of each public
facility/improvement.
The total “CDBG cost per job” is then calculated by dividing:

The total dollar amount of CDBG funds to be spent for the activity (less administrative
costs), by

The total number of: jobs to be created or retained as a result of each
facility/improvements by all of the businesses for which the project is principally being
undertaken.
Cost per Job is Less than $10,000
When the CDBG cost of the project is less than $10,000 per job, only those particular businesses
for which the public facility/improvement is being undertaken must submit a commitment letter
and hiring plan. Other businesses in the service area, or those that later locate in the area, do not
need to be considered.
Where the public facility/improvement is undertaken for the principle benefit of one business,
but where other businesses might also benefit, the requirement may be met by demonstrating that
51 percent of the aggregate total of jobs created or retained as a result of the
facility/improvements by the assisted businesses is for LMI persons. The principle businesses
must meet the 51 percent requirement when hiring is completed and the total number of jobs
actually created should not raise the cost per job above $10,000 (unless there are documented
circumstances beyond their control that prevented the hiring of the total number of employees
committed).
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Cost per Job is More than $10,000
While not likely due to State policy, if the CDBG cost per job of the public
facility/improvements is $10,000 or more, then all jobs created or retained by all businesses
benefiting from the public facility/improvement must be tracked for the purpose of meeting the
national objective (i.e., determining that at least 51 percent of the total jobs are for LMI
persons).The tracking period begins the day funds are awarded to a recipient and ends one year
after physical completion of the public improvement/facility (approximately 24 months from the
time of assistance).
If the CDBG cost is greater than $10,000 per job, information is needed from all businesses
within the service area of the public facility/improvement at the time of the application. For each
such business, a commitment letter and hiring plan must be submitted, covering any expected
expansion. Businesses not anticipating expansions must submit a letter indicating that no
expansion or increase in employment is anticipated within the next two years as a result of the
public facility/improvement.
The letter should also state that if the business subsequently determines to increase its
employment as a result of the public facility/improvement prior to the expiration of the covered
period, that the business will submit a commitment letter and hiring plan covering the anticipated
increase in employment. This commitment letter and hiring plan must indicate that at least
51 percent of new employees will be hired from LMI families.
The unit of local government must also submit an assurance that it will require any business
newly locating in the service area during the covered period (12 months after completion) to
submit a commitment letter and hiring plan for any anticipated increase in employment. At least
51 percent of the new employees must be hired from LMI families. The unit of local government
must provide a description of activities to be undertaken to meet this assurance. The assurance
must also state that if the local government is unable to document to the State’s satisfaction that
at least 51 percent of the jobs created or retained (in the aggregate) in the service area during the
covered period were for LMI persons, it may be required to repay all CDBG funds awarded to
that project.
“Anti-Pirating” of Jobs
Section 588 of the Quality Housing and Work Responsibility Act of 1998 prohibits States and
local governments from using CDBG funds for employment relocation activities or “job
pirating”. Job pirating refers to the use of federal funds to lure or attract a business and its jobs
from one community to another community. CDBG funds may not be used to assist for-profit
businesses, including expansions, as well as infrastructure improvement projects or business
incubators which are designed to facilitate business relocation IF:

The funding will be used to assist directly in the relocation of a plant, facility or
operation; and

The relocation is likely to result in a significant loss of jobs in the labor market area from
which the relocation occurs.
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The following are definitions to assist in determining if a business location falls under these
provisions:
Labor Market Area (LMA)

An LMA is an economically integrated geographic area within which individuals can live
and find employment within a reasonable distance or can readily change employment
without changing their place of residence.
Operation

A business operation includes, but is not limited to, any equipment, employment
opportunity, production capacity or product line of the business.
Significant Loss of Jobs

A loss of jobs is significant if:

The number of jobs to be lost in the LMA in which the affected business is currently
located is equal to or greater than one-tenth of one percent of the total number of
persons in the labor force of that LMA;
OR in all cases

The loss of jobs is 500 or more.

A job is considered to be lost due to the provision of CDBG assistance if the job is
relocated within three years of the provision of assistance to the business.

Notwithstanding the above definition, a loss of 25 jobs or fewer does not constitute a
significant loss of jobs.
Written Agreement

Before directly assisting a business with CDBG funds the grantee shall obtain a written
agreement from the assisted business. The written agreement shall include:

A statement from the assisted business as to whether the assisted activity will result in
the relocation of any industrial or commercial plant, facility, or operation from one
LMA to another, and, if so, the number of jobs that will be relocated from each LMA.

If the assistance will not result in a relocation covered by this section, a certification
from the assisted business that neither it, nor any of its subsidiaries, has plans to
relocate jobs at the time the agreement is signed that would result in a significant job
loss as defined in this rule; and

The agreement shall provide for reimbursement of any assistance provided to, or
expanded on behalf of, the business in the event that assistance results in a relocation
prohibited under this section.
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Please contact Grants Administration for assistance if a CDBG project involves an existing
business that is located outside of the locality or state.
Meeting a National Objective
Local Business Providing Essential Goods and Services
These types of projects will typically qualify either on the basis of LMI Area benefit or LMI Job
Creation/Retention. To qualify under the LMI Area Benefit National Objective, the service area
must be 51% LMI and primarily residential in nature. There must be documentation that the
business is providing essential goods and services to that service area population. Goods and
services might include grocery stores, dry cleaners, pharmacies, health care, etc. A high end
boutique or souvenir shop would not be considered as providing essential goods and services.
Job Creation/ Retention
A Job Creation/Retention activity is one that creates or retains permanent jobs, 51 percent of
which are held by persons from low and moderate income families. Jobs indirectly created by an
assisted activity (i.e., “trickle-down” jobs) may not be counted.

For job creation activities, the local government and the assisted business(es) must
document that permanent jobs have been created, and that at least 51 percent of the jobs,
computed on a full time equivalent (FTE) basis, involve the employment of low and
moderate income persons.

For job retention activities, the local government must document that the jobs would
actually be lost without the CDBG assistance, and that either or both of the following
conditions apply with respect to at least 51 percent of the jobs:

The job is known to be held by a low and moderate income person; or

The job can reasonably be expected to turn over within the following two years and
that it will be filled by an LMI person upon turnover.
A written commitment to hire or retain LMI persons must be obtained for each assisted business.
The business must also provide a hiring plan which details the number of jobs to be created, the
number of jobs held or to be filled by LMI persons, the type of job, average wage, any special
skills or training required, the timetable for hiring, and whether or not health care will be
provided for the position. The plan must indicate who will be responsible for hiring and
collecting required data and for any training to be provided. Generally, it is expected that initial
hiring by the business will be completed within twenty-four (24) months from the time of the
assistance. Projections for future expansions or growth are generally not considered for purposes
of determining the number of jobs to be created.
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Job Creation Requirements
The business must submit a commitment letter and hiring plan identifying the number of jobs to
be created and /or retained and the number of jobs to be filled by LMI persons during the initial
hiring phase.
The job commitment should be realistic in the total number of jobs, the number of jobs to be
filled by LMI persons and the time frame for hiring.

Grants Administration uses the commitment letter to qualify the proposed project under
HUD regulations and will monitor the hiring to verify that job commitments have been
fulfilled.

Failure to comply with the requirement to benefit at least 51 percent LMI persons could
result in the State requiring repayment of all or a pro rata share of the CDBG funds spent
on the project.
Grants Administration staff must meet with appropriate representatives of the business to discuss
hiring commitments, LMI job requirements and documentation prior to CDBG funds being
awarded. These meetings can be coordinated with state employment services and Technical
Schools representatives (if appropriate), the project administrator and appropriate local officials.
State employment services are available to assist the business in taking applications for
employment and in obtaining the required information from applicants for employment. Income
eligibility of both applicants for employment and the employees actually hired is determined
using the Applicant/Employee Information form, also known as an Income Survey. Income
Surveys and EEO information should be completed at the time an applicant completes a
business's application for employment. (See the Applicant/Employee Information form in the
Attachments.) Where a business utilizes state employment services or Technical Schools to assist
in recruiting and training employees, the entity that obtains the employment applications from
applicants should also obtain the income surveys and EEO information.
As a general rule, each assisted business shall be considered individually for purposes of
determining if at least 51 percent of the jobs created or retained will be for LMI persons.
However, when CDBG funds are used to acquire, develop or improve real property (e.g., a
shopping center or an industrial park), the 51 percent requirement may be met by measuring jobs
in the aggregate for all the businesses that locate on the property as a direct result of the CDBG
assistance.
Other businesses in the service area, or which may locate in the service area that benefit from the
public facility/improvement need not be considered. (Note: The principle business(es) must meet
the 51% requirement when hiring is completed and the total number of jobs actually created
should not raise the cost per job above $10,000 unless there are documented circumstances
beyond the control of the business(es) which prevented the hiring of the total number of
employees committed.)
The general rule is that if the CDBG “cost per job” of the public facilities or improvements
exceeds $10,000 then all jobs created or retained by all businesses in the service area must be
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tracked for the purpose of determining that at least 51% of the aggregate total jobs are for LMI
persons.
This aggregation must include businesses which, as a result of the public facility/improvement,
locate or expand in the service area of the public facility/improvement between the date the State
awards the CDBG funds and the date one year after the physical completion of the public
facility/improvement. This rule will rarely have any applicability, since it is not the State's intent
to fund projects that exceed $10,000 per job, except under special circumstances.
When counting jobs, the following policies apply:

Part-time jobs must be converted to full-time equivalents.

Part-time jobs may only be counted to the extent that the job requires at least 20 hours per
workweek or half of business’ workweek, whichever is greater.

Only permanent jobs may be counted.

Transferred jobs may not be counted.

Seasonal jobs may be counted only if the season is long enough for the job to be
considered the employee's principal occupation.

Jobs indirectly created by an assisted activity (i.e., “trickle-down” jobs) may not be
counted.
The business should track its employees by positions, such that when a position is created and an
employee is hired, the LMI status of the employee in that position can be determined. Regardless
of the number of jobs committed by the business, 51 percent of the total jobs created when hiring
is complete must have been taken by LMI persons. For example, a business is committed to
creating 100 jobs and to filling 51 percent with LMI persons. If the business actually creates 150
jobs, at least 76 must be filled by LMI persons.
The business should maintain applicant and employee income surveys and EEO information,
along with payrolls or employee lists, to document compliance with CDBG requirements. It is
recommended that these records be maintained separately from a business's individual personnel
records.
The recipient is required to monitor on-site the business's progress in fulfilling the hiring and
LMI job requirements and report to Grants Administration on a quarterly basis. When all jobs
have been created, Grants Administration will monitor the hiring and LMI job documentation at
the business. Records should continue to be kept by the business until notified by Grants
Administration that the CDBG requirements have been fulfilled. In general, the business should
plan to maintain CDBG records for a period of five years after the recipient’s final grant closeout has been completed. (See CDBG Implementation Manual, Chapter 15.)
The level of documentation required for demonstrating benefit to LMI persons when using the
Job Creation/Retention National Objective is significantly reduced for jobs/businesses located in
areas meeting certain poverty levels and for employees living in those areas. The current
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regulations allow for a person to be presumed LMI under certain circumstances. See
Presumption Criteria below for more information.
Generally, it is expected that initial hiring by the business will be completed within 24 months of
the time of assistance. Projections for future expansions or growth are generally not considered
for purposes of determining the number of jobs created.
Job Retention Requirements
For projects proposing the retention of jobs that would otherwise be lost without CDBG
assistance, at least 51 percent of the jobs to be retained must be held by persons from low and
moderate income families. HUD requires that there be clear, objective evidence and
documentation that jobs would be lost without the CDBG assistance; therefore, using job
retention as a basis for meeting the LMI National Objective is difficult. Consequently, in the
past, few projects have qualified as benefiting LMI through job retention.
The business should track its employees by position, such that the LMI status of the employee in
that position can be determined. Documentation is easier if employees live in, or the job and
business is located in, certain high poverty areas. See Presumption Criteria below for more
information.
Presumption Criteria
The level of documentation required for demonstrating benefit to LMI persons when using the
Job Creation/Retention National Objective is significantly reduced for businesses located in
areas meeting certain poverty levels and for employees living in those areas. The regulations
allow for a person to be presumed LMI under certain circumstances.
A presumption can be made about a person’s LMI status (only for job creation/retention
activities) if either:

The person filling the job resides within a census tract that either has at least 70 percent
of its residents who are LMI or meets the criteria listed below.

The assisted business and the job under consideration is to be located within a census
tract that is part of a Federally-designated Empowerment Zone or Enterprise Community
or meets the following requirements:

Has a poverty rate of at least 20 percent (as determined by the most recently available
decennial census information and does not include any portion of a central business
district, as this term is used in the most recent Census of Retail Trade, unless the tract
has a poverty rate of at least 30 percent as determined by the most recently available
decennial census information); and

It evidences pervasive poverty and general distress by meeting at least one of the
following standards:

All block groups in the census tract have poverty rates of at least 20 percent;
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
The specific activity being undertaken is located in a block group that has a
poverty rate of at least 20 percent; or

Upon written request, Grants Administration and HUD determines that the census
tract exhibits other objectively determinable signs of general distress such as high
incidents of crime, narcotics use, homelessness, abandoned housing, and
deteriorated infrastructure or substantial population decline.
Contact Grants Administration for a listing of census tracts, BNAs and block groups qualifying
on the basis of poverty and LMI percentage.
Generally, the presumption must be made at the time a CDBG application is submitted and
cannot be used retroactively. At the application stage, the business must submit a commitment
letter and hiring plan identifying the number of jobs to be filled during the initial hiring phase.
Performance Agreement
In order to formalize the relationship between the state, the local entity, and any assisted business
proposing job creation, a Performance Agreement must be signed and executed by all parties.
The Performance Agreement is the State’s method of ensuring that not only are all program
requirements strictly followed by local recipients and subrecipients, but that users of CDBG
funds are making sound investments to result in the desired outcomes. The performance
agreement and/or loan agreement will provide for the repayment of all or a pro rata share of the
CDBG funds awarded for a project if the job creation/retention commitment, LMI hiring
requirement, and other requirements of assistance are not met.
Project Timetable
It is important to determine a timetable for the project as early in the planning process as
feasible. The applicant local government should determine when CDBG assistance will be
needed by the business and when the business plans to begin its construction activities. For
public facilities projects, determine when the public facilities must be available and operational
to the business and identify the necessary parameters of the public facilities requirements (i.e.,
size of lines, amount and type of treatment capacity, etc.). This project timetable, along with
other information about the business, its product, the planned capital investment, and the number
of new and LMI jobs to be created will be needed for the application.
Most economic development projects are on a "fast track". In such cases, the environmental
review process should be started as quickly as possible. The environmental review process may
take 120 days.
The environmental review should address the CDBG improvements as well as any business
construction activities, air emissions from the plant, and waste generation and disposal as part of
the overall project. This environmental review process must be carried out in a manner
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prescribed by HUD and has no direct relationship to environmental analyses, which may have to
be carried out to meet the business's concerns regarding possible site contamination.
The environmental process may begin prior to grant award and prior to submission of an
application. The costs for the environmental review, which is conducted prior to grant award, are
reimbursable under the CDBG program if the costs are identified in the application, if all CDBG
requirements are followed and if the project is awarded. Generally, no public or private
construction activities may begin prior to release of environmental conditions.
Requesting an Application
The chief elected or administrative official of the unit of local government must request
applications for Business Development Assistance from Grants Administration. Such requests
should include as appropriate, the following:

Name of the business.

Its product or service.

Estimated initial capital or private investment.

Number of jobs to be created or retained,

Brief description of the project for which CDBG funds are being requested.

Estimated total cost of the project. (If a preliminary engineering cost report is available, it
should be included.)

Amount of CDBG funds being requested.

Sources of all other funds necessary to complete the project.
Best efforts should be made to accurately estimate the amount of CDBG funds necessary. Grants
Administration may request a meeting with the potential applicant or may conduct a site visit to
determine the eligibility and feasibility prior to mailing an application.
Grants Administration may issue commitments at any time for project funding contingent upon
receipt of an acceptable written commitment from the business (if job creation or retention is
involved), acceptable application information, compliance with CDBG program guidelines and
HUD regulations, and continued program funding.
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Application Process (Job Creation Projects)
A brief outline of the steps involved during the Application Process for Business Development
Program Assistance is as follows:
Phase One:
Determine
Community Needs
Develop a Citizen Participation Plan



Identify citizens and organizations that can provide assistance, guidance,
and input into the needs assessment and application process.
Solicit input from broad community and conduct outreach to LMI persons.
Research, analyze and compile documentation on community development
needs, including obstacles to community competitiveness.
Hold Needs Assessment Public Hearing



Phase Two:
Project
Identification
Meet With Company




Phase Three:
Project
Development
Publicize and conduct needs assessment public hearing with assistance of
citizens and other partners.
Prioritize needs.
Prepare needs assessment document.
Determine assistance needed.
Determine if activities are eligible and if a national objective can be met.
Establish timetable.
Coordinate with Grants Administration staff.
Request an Application from Grants Administration






Start Environmental Review Process.
Obtain written hiring commitment, financial information, and capital
investment from company.
Develop cost estimates.
Prepare maps.
Compile documentation for application.
Meet with state employment services.
Phase Four:
Apply for CDBG
Funding
Complete the Application
Phase Five:
Project Selection
Process
Project Reviewed by Grants Administration






2015 – 2016 Application Guidelines
Publicize and conduct public hearing on proposed application.
Complete final application requirements and certifications.
Submit application to Grants Administration.
Respond to Grants Administration questions.
If grant is awarded, return signed grant award to initiate project.
If activities must begin prior to grant award in order to meet company’s
timeframe, request permission to incur “pre-agreement” costs.
104
_________________________ OTHER PROGRAM CATEGORIES _________________________
Project Selection Process
Applications will be considered in the order received. Funding may be limited or delayed if
necessary to ensure funding availability for prior commitments for economic development
assistance. Grants Administration will review the applications for completeness and for
compliance with the above criteria, and applicable HUD regulations. Applications not meeting
these requirements will not be recommended for funding.
Grants Administration may request other state agencies to assist in evaluating projects and
activities. Grants Administration may request additional information from the applicant or other
sources as necessary to evaluate the application and the proposed project.
Grants Administration will utilize the HUD guidelines at 24 CFR 570.482(e) and Appendix A in
evaluating and selecting projects to be recommended for assistance to businesses under the
Business Development Grant Program. The objectives of these guidelines are to ensure: (1) That
project costs are reasonable; (2) That all sources of project financing are committed; (3) That to
the extent practicable, CDBG funds are not substituted for non-Federal financial support; (4)
That the project is financially feasible; (5) That owner’s equity return is not unreasonably high;
and (6) That to the extent practicable, CDBG funds are disbursed on a pro-rata basis with other
finances provided to the project. The following factors will also be considered, as appropriate, in
making a determination to recommend funding approval on all projects recommended by the
Secretary:
Market Conditions (Need)

Availability and utilization of local government or other public resources to assist the
project and the relative need for CDBG assistance. Evidence of local economic distress
such as recent plant closings and/or lay-offs and local unemployment rate. Evidence of
market need for essential goods and services.
Economic Impact

Number of permanent, full time jobs created or retained; CDBG cost per job (LMI and
non-LMI); average wages, health benefits, capital investment; potential future growth;
potential for catalyzing area economic development activity or cluster activity.
Leveraging

Ratio of private and/or public funds to CDBG funds. Generally, private investment is
expected to significantly exceed the amount of the CDBG and other public assistance.
Viability/Level of Public Risk

Public costs are reasonable, all funding sources are committed and available, private
funding to be spent before public funding to the extent practical, security provided, as
appropriate (assets, guarantees, etc.), and potential of the project to achieve the proposed
public benefits within proposed timeframe.
2015 – 2016 Application Guidelines
105
_________________________ OTHER PROGRAM CATEGORIES _________________________
The Secretary will approve funding as recommended, unless the Secretary's consideration of the
above factors results in a determination that such funding is not necessary or appropriate.
In the event funds are not available to fully fund all Business Development applications under
consideration at the same time, priority will be given to applications with prior commitments,
and then preference will be given to projects based upon a consideration of the following factors:
(1) level of job creation or retention, (2) economic impact on the local economy, (3) level of
capital investment and (4) distress level of the county where the project is located.
Under unusual circumstances, Grants Administration may consider a waiver of any CDBG
program requirements, set by the State, for projects that are determined to meet urgent or
compelling needs or where the Secretary of the Department of Commerce determines it
necessary to implement the objectives of the Department of Commerce.
2015 – 2016 Application Guidelines
106
ATTACHMENTS
Eligible Activities
Eligible Activities from the Housing & Community Development Act of 1974
Requesting an Application
Community Development
Business Development
Determining Community Needs
Notice of Citizen Participation Plan Public Hearing
Notice of Citizen Participation Plan Availability for Review
Notice of Public Hearing Concerning Needs Assessment
Notice of Public Hearing Concerning Application
Meeting a National Objective
2014 Income Limits - Updated July 2014 (effective until updated by HUD)*
Local Income Survey for CDBG Applications
Sample Ordinance Defining Slum and Blighted Area Sample Resolution
Declaring Slum and Blighted Area
Preparing Budgets
CDBG Engineering Fee Schedule
CDBG Housing Initial Property Assessment
Other Requirements
Residential Anti-Displacement and Relocation Plan
Determination to Demolish (H-1)
Business Development Assistance Program
2015 County Development Status Designations
County Per Capita Incomes & Average Wages
Business Development Applicant/Employee Information and EEO Reporting Requirements
* The 2015 income limits are expected to be published by HUD by late February 2015 and will supersede the 2014 limits.
Eligible Activities
Activities assisted under Title I of the Housing and Community Development Act of 1974, as
amended, may include only:
105(a)(1)
The acquisition of real property (including air rights, water rights, and other
interests therein) which is (A) blighted, deteriorated, deteriorating, undeveloped,
or inappropriately developed from the standpoint of sound community
development and growth; (B) appropriate for rehabilitation or conservation
activities; (C) appropriate for the preservation or restoration of historic sites, the
beautification of urban land, the conservation of open spaces, natural resources,
and scenic areas, the provision of recreational opportunities, or the guidance of
urban development; (D) to be used for the provision of public works, facilities,
and improvements eligible for assistance under this chapter; or (E) to be used for
other public purposes;
105(a)(2)
The acquisition, construction, reconstruction, or installation (including design
features and improvements with respect to such construction, reconstruction, or
installation that promote energy efficiency) of public works, facilities (except for
buildings for the general conduct of government), and site or other improvements;
105(a)(3)
Code enforcement in deteriorated or deteriorating areas in which such
enforcement, together with public or private improvements or services to be
provided, may be expected to arrest the decline of the area;
105(a)(4)
Clearance, demolition, removal, reconstruction, and rehabilitation (including
rehabilitation which promotes energy efficiency) of buildings and improvements
(including interim assistance, and financing public or private acquisition for
reconstruction or rehabilitation, and reconstruction or rehabilitation, of privately
owned properties, and including the renovation of closed school buildings);
105(a)(5)
Special projects directed to the removal of material and architectural barriers
which restrict the mobility and accessibility of elderly and handicapped persons;
105(a)(6)
Payments to housing owners for losses of rental income incurred in holding for
temporary periods housing units to be utilized for the relocation of individuals and
families displaced by activities under this chapter;
105(a)(7)
Disposition (through sale, lease, donation, or otherwise) of any real property
acquired pursuant to this chapter or its retention for public purposes;
105(a)(8)
Provision of public services, including but not limited to those concerned with
employment, crime prevention, child care, health, drug abuse, education, energy
conservation, welfare or recreation needs, if such services have not been provided
by the unit of general local government (through funds raised by such unit, or
received by such unit from the State in which it is located) during any part of the
twelve-month period immediately preceding the date of submission of the
statement with respect to which funds are to be made available under this chapter,
Eligible Activities
and which are to be used for such services, unless the Secretary finds that the
discontinuation of such services was the result of events not within the control of
the unit of general local government, except that not more than 15 percent of the
amount of any assistance to a unit of general local government (or in the case of
nonentitled communities not more than 15 percent statewide) under this chapter
including program income may be used for activities under this paragraph unless
such unit of general local government used more than 15 percent of the assistance
received under this chapter for fiscal year 1982 or fiscal year 1983 for such
activities (excluding any assistance received pursuant to Public Law 98-8), in
which case such unit of general local government may use not more than the
percentage or amount of such assistance used for such activities for such fiscal
year, whichever method of calculation yields the higher amount, except that of
any amount of assistance under this chapter (including program income) in each
of fiscal years 1993 through 2001 to the City of Los Angeles and County of Los
Angeles, each such unit of general government may use not more than 25 percent
in each such fiscal year for activities under this paragraph, and except that of any
amount of assistance under this chapter (including program income) in each of the
fiscal years 1999, 2000, and 2001, to the City of Miami, such city may use not
more than 25 percent in each fiscal year for activities under this paragraph;
105(a)(9)
Payment of the non-Federal share required in connection with a Federal grant-inaid program undertaken as part of activities assisted under this chapter;
105(a)(10)
Payment of the cost of completing a project funded under title I of the Housing
Act of 1949 [42 U.S.C. 1450 et seq.];
105(a)(11)
Relocation payments and assistance for displaced individuals, families,
businesses, organizations, and farm operations, when determined by the grantee to
be appropriate;
105(a)(12)
Activities necessary (A) to develop a comprehensive community development
plan, and (B) to develop a policy-planning- management capacity so that the
recipient of assistance under this chapter may more rationally and effectively (i)
determine its needs, (ii) set long-term goals and short-term objectives, (iii) devise
programs and activities to meet these goals and objectives, (iv) evaluate the
progress of such programs in accomplishing these goals and objectives, and (v)
carry out management, coordination, and monitoring of activities necessary for
effective planning implementation;
105(a)(13)
Payment of reasonable administrative costs related to establishing and
administering federally approved enterprise zones and payment of reasonable
administrative costs and carrying charges related to (A) administering the HOME
program under title II of the Cranston-Gonzalez National Affordable Housing Act
[42 U.S.C. 12721 et seq.]; and (B) the planning and execution of community
development and housing activities, including the provision of information and
resources to residents of areas in which community development and housing
Eligible Activities
activities are to be concentrated with respect to the planning and execution of
such activities, and including the carrying out of activities as described in section
461(e) of title 40 on August 12, 1981;
105(a)(14)
Provision of assistance including loans (both interim and long-term) and grants
for activities which are carried out by public or private nonprofit entities,
including (A) acquisition of real property; (B) acquisition, construction,
reconstruction, rehabilitation, or installation of (i) public facilities (except for
buildings for the general conduct of government), site improvements, and utilities,
and (ii) commercial or industrial buildings or structures and other commercial or
industrial real property improvements; and (C) planning;
105(a)(15)
Assistance to neighborhood-based nonprofit organizations, local development
corporations, nonprofit organizations serving the development needs of the
communities in nonentitlement areas, or entities organized under section 681(d)
of title 15 to carry out a neighborhood revitalization or community economic
development or energy conservation project in furtherance of the objectives of
section 5301(c) of this title, and assistance to neighborhood-based nonprofit
organizations, or other private or public nonprofit organizations, for the purpose
of assisting, as part of neighborhood revitalization or other community
development, the development of shared housing opportunities (other than by
construction of new facilities) in which elderly families (as defined in section
1437a(b)(3) of this title) benefit as a result of living in a dwelling in which the
facilities are shared with others in a manner that effectively and efficiently meets
the housing needs of the residents and thereby reduces their cost of housing;
105(a)(16)
Activities necessary to the development of energy use strategies related to a
recipient's development goals, to assure that those goals are achieved with
maximum energy efficiency, including items such as (A) an analysis of the
manner in, and the extent to, which energy conservation objectives will be
integrated into local government operations, purchasing and service delivery,
capital improvements budgeting, waste management, district heating and cooling,
land use planning and zoning, and traffic control, parking, and public
transportation functions; and (B) a statement of the actions the recipient will take
to foster energy conservation and the use of renewable energy resources in the
private sector, including the enactment and enforcement of local codes and
ordinances to encourage or mandate energy conservation or use of renewable
energy resources, financial and other assistance to be provided (principally for the
benefit of low- and moderate-income persons) to make energy conserving
improvements to residential structures, and any other proposed energy
conservation activities;
Provision of assistance to private, for-profit entities, when the assistance is
appropriate to carry out an economic development project (that shall minimize, to
the extent practicable, displacement of existing businesses and jobs in
neighborhoods) that (A) creates or retains jobs for low- and moderate-income
persons; (B) prevents or eliminates slums and blight; (C) meets urgent needs; (D)
105(a)(17)
Eligible Activities
creates or retains businesses owned by community residents; (E) assists
businesses that provide goods or services needed by, and affordable to, low- and
moderate-income residents; or (F) provides technical assistance to promote any of
the activities under subparagraphs (A) through (E);
105(a)(18)
The rehabilitation or development of housing assisted under section 17 of the
United States Housing Act of 1937;
105(a)(19)
Provision of technical assistance to public or nonprofit entities to increase the
capacity of such entities to carry out eligible neighborhood revitalization or
economic development activities, which assistance shall not be considered a
planning cost as defined in paragraph (12) or administrative cost as defined in
paragraph (13);
105(a)(20)
Housing services, such as housing counseling in connection with tenant-based
rental assistance and affordable housing projects assisted under title II of the
Cranston-Gonzalez National Affordable Housing Act [42 U.S.C. 12721 et seq.],
energy auditing, preparation of work specifications, loan processing, inspections,
tenant selection, management of tenant-based rental assistance, and other services
related to assisting owners, tenants, contractors, and other entities, participating or
seeking to participate in housing activities assisted under title II of the CranstonGonzalez National Affordable Housing Act;
105(a)(21)
Provision of assistance by recipients under this chapter to institutions of higher
education having a demonstrated capacity to carry out eligible activities under this
subsection for carrying out such activities;
105(a)(22)
Provision of assistance to public and private organizations, agencies, and other
entities (including nonprofit and for-profit entities) to enable such entities to
facilitate economic development by (A) providing credit (including providing
direct loans and loan guarantees, establishing revolving loan funds, and
facilitating peer lending programs) for the establishment, stabilization, and
expansion of microenterprises; (B) providing technical assistance, advice, and
business support services (including assistance, advice, and support relating to
developing business plans, securing funding, conducting marketing, and
otherwise engaging in microenterprise activities) to owners of microenterprises
and persons developing microenterprises; and (C) providing general support (such
as peer support programs and counseling) to owners of microenterprises and
persons developing microenterprises;
105(a)(23)
Activities necessary to make essential repairs and to pay operating expenses
necessary to maintain the habitability of housing units acquired through tax
foreclosure proceedings in order to prevent abandonment and deterioration of
such housing in primarily low- and moderate-income neighborhoods;
Eligible Activities
105(a)(24)
Provision of direct assistance to facilitate and expand homeownership among
persons of low and moderate income (except that such assistance shall not be
considered a public service for purposes of paragraph (8)) by using such
assistance to (A) subsidize interest rates and mortgage principal amounts for lowand moderate-income homebuyers; (B) finance the acquisition by low- and
moderate-income homebuyers of housing that is occupied by the homebuyers; (C)
acquire guarantees for mortgage financing obtained by low- and moderate-income
homebuyers from private lenders (except that amounts received under this chapter
may not be used under this subparagraph to directly guarantee such mortgage
financing and grantees under this chapter may not directly provide such
guarantees); (D) provide up to 50 percent of any downpayment required from
low- or moderate-income homebuyer; or (E) pay reasonable closing costs
(normally associated with the purchase of a home) incurred by a low- or
moderate-income homebuyer; and
105(a)(25)
Lead-based paint hazard evaluation and reduction, as defined in section 1004 of
the Residential Lead-Based Paint Hazard Reduction Act of 1992.
Community Development Block Grant
Community Development Program Application Request
2/2015
Locality requesting application:
Briefly describe the proposed project (address need and impact), including how CDBG funds will be used:
Identify location of activities, including the local government jurisdiction and service area of beneficiaries.
Project or significant # of beneficiaries located outside applicant’s jurisdiction. May require an intergovernmental
agreement and joint application.
Identify Program Category:
Community Infrastructure
Community Enrichment
*Neighborhood Revitalization
Ready to Go
*Neighborhood Revitalization applications require a neighborhood plan (see Application Guidelines for details)
List any CDBG projects that are not programmatically closed:
CDBG Funds Requested:
$
National Objective:
10 % Match:
$
Proposed Beneficiaries:
Other Funds Required:
$
Total Project Cost:
$
LMI*
Slum & Blight
Urgent Need
*Est. Nbr. & % LMI Beneficiaries:
Source:
Survey
Census
List Other Sources of Funding:
Attach:
Project map with jurisdictional boundaries and service area
Attach requests and rationale for waivers of:
Send application:
Forms
Cost estimate or preliminary engineering report
Maximum Grant Amount
Match
Threshold
Email to:
Contact Name:
Telephone:
Address:
Name / Title of Chief Elected / Administrative Official
Signature and Date
Complete and mail to:
SC Department of Commerce, Grants Administration
1201 Main Street, Suite 1600, Columbia, SC 29201
Community Development Block Grant
Business Development Program Application Request
2/2012
Local Government:
Project Administrator:
Phone:
CDBG amount requested:
$
Is project in a qualified presumption area?:
The business to be assisted is:
New Start-Up Company
Yes
No
Census tract/block group where business is located:
New to SC
Expanding at existing site
Local - Providing essential goods and services to a service area that is
Service area name/description:
Expanding at new site
% LMI
Company Name:
Company Product:
# Current Employees:
Capital/Private Investment:
# Retained Employees:
Company Contact:
# Transferred Employees:
Telephone:
$
# Proposed New Employees:
(Indicate Type and Estimate Cost of Assistance needed)
CDBG
Requested
Estimated
Amount
Assistance
Total Cost
Requested
Other Funds
to be
Committed
Source of
Other Funds
Date Improvements to be
Available to Company
Water
Sewer
Rail
Roads
Admin
*Other
Total
$
*Identify Other:
Project Map/Site Plan
Attach:
Cost Estimate or Preliminary Engineering Report
Briefly describe proposed CDBG assistance:
Send application:
Forms
Email to:
Contact Name:
Telephone:
Address:
Name/Title of Chief Elected/Administrative Official
Signature and Date
Waiver requests must be completed and submitted with this form to:
SC Department of Commerce, Grants Administration
1201 Main Street, Suite 1600, Columbia, SC 29201
Applications due within 45 days
2/2005
Sample
Notice of Citizen Participation Plan Public Hearing
Communities anticipating participation in the State of South Carolina's Community
Development Block Grant (CDBG) Program must provide for participation of their citizens in
the planning and implementation of community and economic development projects which
involve CDBG funds, in accordance with Title I of the Housing and Community Development
Act of 1974, as amended through 1987. Therefore, a Citizen Participation Plan has been
developed by [Locality] for the purpose of providing the citizens of [Locality] with a written,
detailed plan for their participation in the planning and implementation of community and
economic development projects which may involve CDBG funds.
NOTICE IS HEREBY GIVEN that on [Date] at [Time] in [Location], [Name of Local
Government] will hold a public hearing to review and solicit public comment on the before
mentioned Citizen Participation Plan. The Citizens Participation Plan is available for review at
[Locality] [Time]. Persons with questions or comments concerning the public hearing or the
Citizen Participation Plan may contact [Person, Title, Address, Telephone Number].
The [Name of Local Government] does not discriminate on the basis of age, color, religion, sex,
national origin, familial status or disability in the admission or access to, or treatment or
employment in its federally assisted programs or activities. [Person, Title, Address, Voice and
TDD Telephone Numbers] has been designated to coordinate compliance with the
nondiscrimination requirements contained in the U. S. Department of Housing and Urban
Development's regulations.
Note: If the location where the public hearing is to be held is not accessible to the disabled, the
public notice must state that assistance will be provided to accommodate the special needs of
disabled persons, upon request.
10/2007
Sample
Notice of Availability of Citizen Participation Plan
Communities anticipating participation in the State of South Carolina's Community
Development Block Grant (CDBG) Program must provide for participation of their citizens in
the planning and implementation of community and economic development projects which will
involve CDBG funds in accordance with Title I of the Housing and Community Development
Act of 1974, as amended, through 1987. Therefore, a Citizen Participation Plan has been
developed by [Locality] with a written. detailed plan for their participation in the planning and
implementation of community and economic development projects which may involve CDBG
funds. This plan is available for review at [Location] [Times]. Persons with questions or
comments concerning the Citizen Participation Plan may contact [Person, Title, Address,
Telephone Number].
The [Name of Local Government] does not discriminate on the basis of age, color, religion, sex,
national origin, familial status or disability in the admission or access to, or treatment or
employment in its federally assisted programs or activities. [Person, Title, Address, Voice and
TDD Telephone Numbers] has been designated to coordinate compliance with the
nondiscrimination requirements contained in the U. S. Department of Housing and Urban
Development's regulations.
Note: If the location where the public hearing is to be held is not accessible to the disabled, the
public notice must state that assistance will be provided to accommodate the special needs of
disabled persons, upon request.
2/2005
Sample
Notice of Public Hearing Concerning Needs Assessment
NOTICE IS HEREBY GIVEN that on [Date] at [Time] in [Place] [Name of Local Government]
will hold a public hearing to solicit public input on community needs and priorities for housing,
public facilities, and economic development. At this public hearing [Name of Local Government]
will provide the results of its needs assessment and the activities which might be undertaken to
meet identified needs, including the estimated amount proposed to be used for activities that will
benefit persons of low and moderate income.
This public hearing and the matters to be discussed are subject to the provisions of the
[Locality's] Citizen Participation Plan, developed in anticipation of participation in the State of
South Carolina's Community Development Block Grant (CDBG) Program, providing for the
participation of the citizens of [Locality] in the planning and implementation of community and
economic development projects which will involve CDBG funds. The Citizen Participation Plan
is available for review at [Location] [Times]. Persons with questions or comments concerning
the public hearing or the Citizen Participation Plan may contact [Person, Title, Address,
Telephone Number].
The [Name of Local Government] does not discriminate on the basis of age, color, religion, sex,
national origin, familial status or disability in the admission or access to, or treatment or
employment in its federally assisted programs or activities. [Person, Title, Address, Voice and
TDD Telephone Numbers] has been designated to coordinate compliance with the
nondiscrimination requirements contained in the U. S. Department of Housing and Urban
Development's regulations.
Note: If the location where the public hearing is to be held is not accessible to the disabled, the
public notice must state that assistance will be provided to accommodate the special needs of
disabled persons, upon request.
10/2007
Sample
Notice of Public Hearing Concerning Application
NOTICE IS HEREBY GIVEN that on [Date] at [Time] in [Place] [Name of Local Government] will hold a
public hearing concerning an application to be submitted to South Carolina Department of Commerce, Grants
Administration on or about [Date], for a Community Development Block Grant. [Name of Local Government]
is requesting [Amount of Money] to carry out the following activities.
[Project description which must include: a detailing of the activities to be undertaken, the estimated amount of
funds for each, and their location; the amount and source of local matching and other funds; the number of
beneficiaries; and, if persons will be displaced, that financial assistance will be available for relocation.]
This public hearing and the matters to be discussed are subject to the provisions of the [Locality's] Citizen
Participation Plan, developed in anticipation of participation in the State of South Carolina's Community
Development Block Grant (CDBG) Program, providing for the participation of the citizens of [Locality] in the
planning and implementation of community and economic development projects which will involve CDBG
funds. The Citizen Participation Plan is available for review at [Location] [Times]. The Citizen Participation
Plan and the application are available for review at [Location] [Times]. Persons with questions or comments
concerning the public hearing or the Citizen Participation Plan may contact [Person, Title, Address, Telephone
Number].
The [Name of Local Government] does not discriminate on the basis of age, color, religion, sex, national origin,
familial status or disability in the admission or access to, or treatment or employment in its federally assisted
programs or activities. [Person, Title, Address, Voice and TDD Telephone Numbers] has been designated to
coordinate compliance with the nondiscrimination requirements contained in the U. S. Department of Housing
and Urban Development's regulations.
Note: If the location where the public hearing is to be held is not accessible to the disabled, the public notice
must state that assistance will be provided to accommodate the special needs of disabled persons, upon
request.
14
2014 Income Limits
July 2014 Update (0-30% - Very Low Income Figures REVISED) **
Abbeville County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$26,300
$28,250
$30,200
$32,150
50% Limits
$17,050
$19,500
$21,950
$24,350
$26,300
$28,250
$30,200
$32,150
80% Limits
$27,300
$31,200
$35,100
$38,950
$42,100
$45,200
$48,300
$51,450
7 Person 8 Person
Abbeville County, SC
Median Family
Income
$ 48,700
Aiken County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
Augusta-Richmond County, GA-SC
MSA
30% Limits
Median Family
50% Limits
Income
$11,750
$15,730
$19,790
$23,850
$27,910
$31,970
$34,700
$36,900
$19,600
$22,400
$25,200
$27,950
$30,200
$32,450
$34,700
$36,900
$ 55,900
$31,300
$35,800
$40,250
$44,700
$48,300
$51,900
$55,450
$59,050
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$27,910
$31,450
$33,650
$35,800
50% Limits
$19,000
$21,700
$24,400
$27,100
$29,300
$31,450
$33,650
$35,800
80% Limits
$30,350
$34,700
$39,050
$43,350
$46,850
$50,300
$53,800
$57,250
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
80% Limits
Allendale County
7 Person 8 Person
7 Person 8 Person
Allendale County, SC
Median Family
Income
$ 27,200
Anderson County
7 Person 8 Person
Anderson, SC MSA
Median Family
Income
$ 54,200
Bamberg County
7 Person 8 Person
Bamberg County, SC
Median Family
Income
$ 43,200
Barnwell County
7 Person 8 Person
Barnwell County, SC
Median Family
Income
$ 46,000
** Issued by HUD in July 2014 per the FY 2014 Consolidated Appropriations Act. Effective until replaced by HUD.
1
2014 Income Limits
July 2014 Update (0-30% - Very Low Income Figures REVISED) **
Beaufort County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$13,400
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$40,090
50% Limits
$22,300
$25,500
$28,700
$31,850
$34,400
$36,950
$39,500
$42,050
80% Limits
$35,700
$40,800
$45,900
$50,950
$55,050
$59,150
$63,200
$67,300
7 Person 8 Person
Beaufort County, SC
Median Family
Income
$ 63,400
Berkeley County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
Charleston-North
Charleston-Summerville, SC MSA
30% Limits
Median Family
50% Limits
Income
$13,000
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$40,090
$21,700
$24,800
$27,900
$30,950
$33,450
$35,950
$38,400
$40,900
$ 61,900
$34,650
$39,600
$44,550
$49,500
$53,500
$57,450
$61,400
$65,350
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$12,250
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$38,500
50% Limits
$20,450
$23,350
$26,250
$29,150
$31,500
$33,850
$36,150
$38,500
80% Limits
$32,700
$37,350
$42,000
$46,650
$50,400
$54,150
$57,850
$61,600
80% Limits
Calhoun County
7 Person 8 Person
7 Person 8 Person
Columbia, SC HUD Metro FMR Area
Median Family
Income
$ 58,000
Charleston County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
Charleston-North
Charleston-Summerville, SC MSA
30% Limits
Median Family
50% Limits
Income
$13,000
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$40,090
$21,700
$24,800
$27,900
$30,950
$33,450
$35,950
$38,400
$40,900
$ 61,900
$34,650
$39,600
$44,550
$49,500
$53,500
$57,450
$61,400
$65,350
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
80% Limits
Cherokee County
7 Person 8 Person
7 Person 8 Person
Cherokee County, SC
Median Family
Income
$ 47,300
Chester County
7 Person 8 Person
Chester County, SC
Median Family
Income
$ 42,700
** Issued by HUD in July 2014 per the FY 2014 Consolidated Appropriations Act. Effective until replaced by HUD.
2
2014 Income Limits
July 2014 Update (0-30% - Very Low Income Figures REVISED) **
Chesterfield County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
7 Person 8 Person
Chesterfield County, SC
Median Family
Income
$ 43,400
Clarendon County
7 Person 8 Person
Clarendon County, SC
Median Family
Income
$ 42,800
Colleton County
7 Person 8 Person
Colleton County, SC
Median Family
Income
$ 42,900
Darlington County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
Darlington County, SC HUD Metro
FMR Area
30% Limits
Median Family
50% Limits
Income
$11,670
$15,730
$19,790
$23,850
$26,900
$28,900
$30,900
$32,900
$17,450
$19,950
$22,450
$24,900
$26,900
$28,900
$30,900
$32,900
$ 49,800
$27,900
$31,900
$35,900
$39,850
$43,050
$46,250
$49,450
$52,650
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
80% Limits
Dillon County
7 Person 8 Person
7 Person 8 Person
Dillon County, SC
Median Family
Income
$ 31,900
Dorchester County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
Charleston-North
Charleston-Summerville, SC MSA
30% Limits
Median Family
50% Limits
Income
$13,000
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$40,090
$21,700
$24,800
$27,900
$30,950
$33,450
$35,950
$38,400
$40,900
$ 61,900
$34,650
$39,600
$44,550
$49,500
$53,500
$57,450
$61,400
$65,350
80% Limits
7 Person 8 Person
** Issued by HUD in July 2014 per the FY 2014 Consolidated Appropriations Act. Effective until replaced by HUD.
3
2014 Income Limits
July 2014 Update (0-30% - Very Low Income Figures REVISED) **
Edgefield County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
Augusta-Richmond County, GA-SC
MSA
30% Limits
Median Family
50% Limits
Income
$11,750
$15,730
$19,790
$23,850
$27,910
$31,970
$34,700
$36,900
$19,600
$22,400
$25,200
$27,950
$30,200
$32,450
$34,700
$36,900
$ 55,900
$31,300
$35,800
$40,250
$44,700
$48,300
$51,900
$55,450
$59,050
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$12,250
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$38,500
50% Limits
$20,450
$23,350
$26,250
$29,150
$31,500
$33,850
$36,150
$38,500
80% Limits
$32,700
$37,350
$42,000
$46,650
$50,400
$54,150
$57,850
$61,600
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$27,450
$29,500
$31,500
$33,550
50% Limits
$17,800
$20,350
$22,900
$25,400
$27,450
$29,500
$31,500
$33,550
80% Limits
$28,500
$32,550
$36,600
$40,650
$43,950
$47,200
$50,450
$53,700
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,900
$15,730
$19,790
$23,850
$27,910
$31,970
$35,200
$37,450
50% Limits
$19,850
$22,700
$25,550
$28,350
$30,650
$32,900
$35,200
$37,450
80% Limits
$31,750
$36,300
$40,850
$45,350
$49,000
$52,650
$56,250
$59,900
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$12,250
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$38,450
50% Limits
$20,400
$23,300
$26,200
$29,100
$31,450
$33,800
$36,100
$38,450
80% Limits
$32,600
$37,250
$41,900
$46,550
$50,300
$54,000
$57,750
$61,450
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$27,910
$30,300
$32,400
$34,500
50% Limits
$18,300
$20,900
$23,500
$26,100
$28,200
$30,300
$32,400
$34,500
80% Limits
$29,250
$33,400
$37,600
$41,750
$45,100
$48,450
$51,800
$55,150
80% Limits
Fairfield County
7 Person 8 Person
7 Person 8 Person
Columbia, SC HUD Metro FMR Area
Median Family
Income
$ 58,000
Florence County
7 Person 8 Person
Florence, SC HUD Metro FMR Area
Median Family
Income
$ 50,800
Georgetown County
7 Person 8 Person
Georgetown County, SC
Median Family
Income
$ 56,700
Greenville County
7 Person 8 Person
Greenville-Mauldin-Easley, SC MSA
Median Family
Income
$ 58,200
Greenwood County
7 Person 8 Person
Greenwood County, SC
Median Family
Income
$ 52,200
** Issued by HUD in July 2014 per the FY 2014 Consolidated Appropriations Act. Effective until replaced by HUD.
4
2014 Income Limits
July 2014 Update (0-30% - Very Low Income Figures REVISED) **
Hampton County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$26,850
$28,850
$30,850
$32,850
50% Limits
$17,400
$19,900
$22,400
$24,850
$26,850
$28,850
$30,850
$32,850
80% Limits
$27,900
$31,850
$35,850
$39,800
$43,000
$46,200
$49,400
$52,550
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
7 Person 8 Person
Hampton County, SC
Median Family
Income
$ 43,800
Horry County
Myrtle Beach-North Myrtle
Beach-Conway, SC MSA
Median Family
Income
$ 49,300
Jasper County
7 Person 8 Person
7 Person 8 Person
Jasper County, SC
Median Family
Income
$ 45,000
Kershaw County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
Kershaw County, SC HUD Metro
FMR Area
30% Limits
Median Family
50% Limits
Income
$11,670
$15,730
$19,790
$23,850
$27,910
$31,450
$33,650
$35,800
$19,000
$21,700
$24,400
$27,100
$29,300
$31,450
$33,650
$35,800
$ 54,200
$30,350
$34,700
$39,050
$43,350
$46,850
$50,300
$53,800
$57,250
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$27,450
$29,500
$31,500
$33,550
50% Limits
$17,800
$20,350
$22,900
$25,400
$27,450
$29,500
$31,500
$33,550
80% Limits
$28,450
$32,500
$36,550
$40,600
$43,850
$47,100
$50,350
$53,600
80% Limits
Lancaster County
7 Person 8 Person
7 Person 8 Person
Lancaster County, SC
Median Family
Income
$ 52,600
Laurens County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
Laurens County, SC HUD Metro FMR
Area
30% Limits
Median Family
50% Limits
Income
$11,670
$15,730
$19,790
$23,850
$26,000
$27,900
$29,850
$31,750
$16,850
$19,250
$21,650
$24,050
$26,000
$27,900
$29,850
$31,750
$ 44,900
$26,950
$30,800
$34,650
$38,500
$41,600
$44,700
$47,750
$50,850
80% Limits
7 Person 8 Person
** Issued by HUD in July 2014 per the FY 2014 Consolidated Appropriations Act. Effective until replaced by HUD.
5
2014 Income Limits
July 2014 Update (0-30% - Very Low Income Figures REVISED) **
Lee County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$12,250
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$38,500
50% Limits
$20,450
$23,350
$26,250
$29,150
$31,500
$33,850
$36,150
$38,500
80% Limits
$32,700
$37,350
$42,000
$46,650
$50,400
$54,150
$57,850
$61,600
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$26,000
$27,900
$29,850
$31,750
50% Limits
$16,850
$19,250
$21,650
$24,050
$26,000
$27,900
$29,850
$31,750
80% Limits
$26,950
$30,800
$34,650
$38,500
$41,600
$44,700
$47,750
$50,850
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$27,910
$31,970
$34,200
$36,400
50% Limits
$19,300
$22,050
$24,800
$27,550
$29,800
$32,000
$34,200
$36,400
80% Limits
$30,900
$35,300
$39,700
$44,100
$47,650
$51,200
$54,700
$58,250
7 Person 8 Person
Lee County, SC
Median Family
Income
$ 43,200
Lexington County
7 Person 8 Person
Columbia, SC HUD Metro FMR Area
Median Family
Income
$ 58,000
McCormick County
7 Person 8 Person
McCormick County, SC
Median Family
Income
$ 48,100
Marion County
7 Person 8 Person
Marion County, SC
Median Family
Income
$ 42,100
Marlboro County
7 Person 8 Person
Marlboro County, SC
Median Family
Income
$ 33,600
Newberry County
7 Person 8 Person
Newberry County, SC
Median Family
Income
$ 55,100
** Issued by HUD in July 2014 per the FY 2014 Consolidated Appropriations Act. Effective until replaced by HUD.
6
2014 Income Limits
July 2014 Update (0-30% - Very Low Income Figures REVISED) **
Oconee County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$27,910
$31,400
$33,550
$35,750
50% Limits
$18,950
$21,650
$24,350
$27,050
$29,250
$31,400
$33,550
$35,750
80% Limits
$30,350
$34,650
$39,000
$43,300
$46,800
$50,250
$53,700
$57,200
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$12,250
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$38,450
50% Limits
$20,400
$23,300
$26,200
$29,100
$31,450
$33,800
$36,100
$38,450
80% Limits
$32,600
$37,250
$41,900
$46,550
$50,300
$54,000
$57,750
$61,450
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$12,250
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$38,500
50% Limits
$20,450
$23,350
$26,250
$29,150
$31,500
$33,850
$36,150
$38,500
80% Limits
$32,700
$37,350
$42,000
$46,650
$50,400
$54,150
$57,850
$61,600
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$12,250
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$38,500
50% Limits
$20,450
$23,350
$26,250
$29,150
$31,500
$33,850
$36,150
$38,500
80% Limits
$32,700
$37,350
$42,000
$46,650
$50,400
$54,150
$57,850
$61,600
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$27,910
$30,450
$32,550
$34,650
50% Limits
$18,400
$21,000
$23,650
$26,250
$28,350
$30,450
$32,550
$34,650
80% Limits
$29,400
$33,600
$37,800
$42,000
$45,400
$48,750
$52,100
$55,450
7 Person 8 Person
Oconee County, SC
Median Family
Income
$ 54,800
Orangeburg County
7 Person 8 Person
Orangeburg County, SC
Median Family
Income
$ 42,700
Pickens County
7 Person 8 Person
Greenville-Mauldin-Easley, SC MSA
Median Family
Income
$ 58,200
Richland County
7 Person 8 Person
Columbia, SC HUD Metro FMR Area
Median Family
Income
$ 58,000
Saluda County
7 Person 8 Person
Columbia, SC HUD Metro FMR Area
Median Family
Income
$ 58,000
Spartanburg County
7 Person 8 Person
Spartanburg, SC MSA
Median Family
Income
$ 52,500
** Issued by HUD in July 2014 per the FY 2014 Consolidated Appropriations Act. Effective until replaced by HUD.
7
2014 Income Limits
July 2014 Update (0-30% - Very Low Income Figures REVISED) **
Sumter County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$26,900
$28,900
$30,900
$32,900
50% Limits
$17,450
$19,950
$22,450
$24,900
$26,900
$28,900
$30,900
$32,900
80% Limits
$27,900
$31,900
$35,900
$39,850
$43,050
$46,250
$49,450
$52,650
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
30% Limits
$11,670
$15,730
$19,790
$23,850
$25,800
$27,700
$29,600
$31,500
50% Limits
$16,700
$19,100
$21,500
$23,850
$25,800
$27,700
$29,600
$31,500
80% Limits
$26,750
$30,550
$34,350
$38,150
$41,250
$44,300
$47,350
$50,400
7 Person 8 Person
Sumter, SC MSA
Median Family
Income
$ 51,100
Union County
7 Person 8 Person
Union County, SC
Median Family
Income
$ 44,400
Williamsburg County
7 Person 8 Person
Williamsburg County, SC
Median Family
Income
$ 36,800
York County
1 Person
2 Person
3 Person
4 Person
5 Person
6 Person
Charlotte-Gastonia-Rock Hill, NC-SC
HUD Metro FMR Area
30% Limits
Median Family
50% Limits
Income
$13,500
$15,730
$19,790
$23,850
$27,910
$31,970
$36,030
$40,090
$22,500
$25,700
$28,900
$32,100
$34,700
$37,250
$39,850
$42,400
$ 64,200
$35,950
$41,100
$46,250
$51,350
$55,500
$59,600
$63,700
$67,800
80% Limits
7 Person 8 Person
** Issued by HUD in July 2014 per the FY 2014 Consolidated Appropriations Act. Effective until replaced by HUD.
8
2/2015
Sample Local Income Survey
for CDBG Applications
City:
County:
1. Name:
2. Street Address:
3. Ethnicity and Race:
Ethnicity (select only one) :
Hispanic or Latino
Not Hispanic or Latino
Race (select one or more):
American Indian or Alaska Native
Asian
Black or African American
Native Hawaiian or Other Pacific Islander
White
4. Total persons living in household
5. Number of Elderly (62 years or older)
6. Number of Disabled
7. Female Head of Household
8. Number of Children under 7 years of age
9. Number of Children 7-17 years of age
10. Total household income (based on adjusted gross income – find your corresponding household size and then CIRCLE
range in that section that fits your total household income)
1 person household:
2 person household:
3 person household:
4 person household:
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 50-80% range)
(Insert 50-80% range)
(Insert 50-80% range)
(Insert 50-80% range)
(Insert income over 80%)
(Insert income over 80%)
5 person household:
6 person household:
(Insert income over 80%)
(Insert income over 80%)
7 person household:
8 person household:
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 50-80% range)
(Insert income over 80%)
(Insert 50-80% range)
(Insert 50-80% range)
(Insert 50-80% range)
(Insert income over 80%)
(Insert income over 80%)
(Insert income over 80%)
(ADMINISTRATIVE USE ONLY:
0-30%
30-50%
50-80%
Over )
11. Does your house have?
Well
Connection to public water
Septic tank
Connection to sanitary sewer
Indoor Bathroom
yes
yes
yes
yes
yes
no
no
no
no
no
For projects involving work on private property (exterior housing rehabilitation or water/sewer connection):
12. Do you own or rent?
Owner
Renter
All information provided is strictly confidential.
Additional questions may be asked.
2/2010
Sample Ordinance
Defining Slum and Blighted Area
WHEREAS, Community Development Block Grants and other sources of funding may be available
from time to time for redevelopment of slum and blighted areas; and
WHEREAS, it is appropriate to define “blighted area” for purposes of designation of such areas for
which funds may be granted for preservation, improvement, and redevelopment in a manner
consistent with CDBG program requirements and State law;
NOW, THEREFORE, BE IT ORDAINED by the Mayor and Council of the City/Town of
, duly
assembled this
day of
, 20
that the following definition of a “Slum and Blighted
Area” is adopted for purposes of designating areas, making application for funds, and expenditure of
funds for the improvement, preservation, conservation, or redevelopment of such areas as may be
identified by Resolution of Council describing the area and identifying the conditions which meet the
standards in the definition.
In accordance with State law, a “Slum and Blighted Area” means any improved or vacant area within
identified boundaries located within the territorial limits of the municipality, which meets state law and
the following CDBG definition:
Public improvements are in a general state of deterioration in the designated area, or
a substantial number of buildings in the designated area are deteriorated or deteriorating,
and at least 25% of properties in the area have one or more of the following characteristics:




Physical deterioration of buildings or improvements
Abandonment of properties
Chronic high turnover or vacancy rates in commercial/industrial buildings
Significant decline in property values or abnormally low property values in relation to other
areas in the community; or
 Known or suspected environmental contamination
Approved this
Witnessed
day of
, 20
Signed
10/2013
Sample Resolution
Declaring Slum and Blighted Area
WHEREAS, the City of
is concerned about the economic viability of slum and
blighted area within its corporate limits, and
WHEREAS, the slum and blighted area projects a negative visual image of the
community, and
WHEREAS, the economic, social, physical, and cultural well-being of the City is
adversely affected by the conditions of this slum and blighted area, and
WHEREAS, there exists the opportunity to improve, preserve, and re-develop this slum
and blighted area to the benefit of the community, and
WHEREAS, the slum and blighted area qualifies under the provisions of ordinance
number
passed in Council on
, 20
.
WHEREAS, the following detrimental conditions have been identified which qualify the
area under State law and Community Development Block Grant Program requirements:
1) Public Improvements are in a general state of deterioration; or
2) At least 25% of the buildings are deteriorated or deteriorating, and have the
following characteristics: (check one or more boxes that apply)
Physical deterioration of buildings or improvements
Abandonment of properties
Chronic high turnover or vacancy rates in commercial/industrial buildings
Significant decline in property values or abnormally low property values in
relation to other areas of the community
Known or suspected environmental contamination.
NOW THEREFORE, BE IT RESOLVED, that the following area is designated a “Slum
and Blighted Area”
(Include the name of the designated area and describe the location and
boundaries)
(Describe and quantify the selected characteristics of the area and quantify the
specific conditions causing the blight)
Resolved and agreed upon this
Witnessed
day of
, 20
.
Signed
Attach the following:
 Map of the area boundaries
 Map showing location of all buildings and public improvements that are deteriorated
 Inventory and description of public improvements or
 Inventory and description of deteriorated buildings which do not comply with local codes
CDBG Engineering Fee Schedule
(As a Percentage of Net Construction Costs)
Fees are to be adjusted to suit special conditions stated in the contract.
Table I ordinarily will apply to that portion of a construction project which is unusually complex because it included a water
treatment plant, wastewater treatment plant, sewer lines, and rehabilitation of an existing facility. It covers preliminary
engineering services, design and contract administration services.
Table II ordinarily will apply to all other work, including wells, water distributions systems, package pumping stations,
package treatment plants and water storage tanks. It covers preliminary engineering services.
Table IR and IIR apply to resident inspections. The applicable percentages will be allowed for full-time resident inspection.
Table IR will be used for complex (Table I) projects. Table IIR will be used for all other projects. Part-time resident
inspection is to be used only when the complexity and scope does not require full-time inspection and requires Rural
Development approval. Ninety-five percent (95%) of compensation for resident inspection will be payable periodically
during the construction period. The final five percent (5%) will be payable upon final approval of the project by the owner
and Rural Development.
WWTP, SEWER, REHAB
TOTAL ACTUAL
CONSTRUCTION
COST
100,000
200,000
300,000
400,000
500,000
600,000
700,000
800,000
900,000
1,000,000
2,000,000
3,000,000
4,000,000
5,000,000
10,000,000
15,000,000
WATER LINES, WELLS, TANKS, PS, ETC.
TABLE I
TABLE IR
TABLE II
TABLE IIR
%
FEE
(DESIGN)
12.3
11.2
10.5
9.8
9.4
9.0
8.8
8.6
8.5
8.3
7.9
7.5
7.1
6.6
6.2
5.9
%
FEE
(INSPECTI
ON)
8.8
7.4
6.6
6.1
5.7
5.5
5.3
5.2
5.0
4.8
3.9
3.4
3.2
3.0
2.9
2.8
%
FEE
(DESIGN)
9.9
8.9
8.5
8.0
7.7
7.5
7.3
7.1
6.9
6.8
6.3
6.0
5.7
5.6
5.1
5.0
%
FEE
(INSPECTION)
7.7
6.3
5.5
5.0
4.6
4.4
4.2
4.1
3.9
3.7
2.8
2.3
2.1
1.9
1.7
1.7
The fee for project cost falling between the figures shown on these Tables shall be interpolated to the nearest one-tenth of one
percent. Compensation may be negotiated on a lump-sum basis for all projects less than $100,000.
Additional costs for contract administration engineering services and resident inspection due to project not being completed
on schedule will be items included in determining the amount of liquidated damages. Additional Engineering compensation
for projects not finished on schedule shall be as calculated on the attached sheet.
2/2009
CDBG Housing Initial Property Assessment
Complete all fields. Duplicate and submit for each house.
Locality:
Unit ID Nbr:
Property Owner Name:
Telephone:
Property Address:
Approximate Sq. Ft.:
Housing Tenure:
Owner Occupied
Rental
Approximate Age:
Only exterior work is eligible. Check the items in this unit that are in need of painting and repair:
Exterior Surface,
Paint or Siding
Porches
Front or Visible
Side Windows
Exterior Front Doors,
repair or replace
Roof, repair or
replace
Gutter, Fascia
or Eave
Crawl Space Door
or Vent
Lead Work
Handrails, Guardrails, or handicapped ramp
repair or installation
Other (specify):
Initial Cost Estimate
CDBG Assistance is limited to $10,000 per unit
Estimated CDBG Cost:
$
+ Estimated $ from other resources:
$
Indicate source(s):
= Estimated Total Cost:
$
After an on-site assessment of the above-stated property, this cost range opinion is based on my professional understanding
of the program requirements, construction practices, material costs, labor costs, and all other considerations that may be
relative in this rehabilitation estimate.
Signature and Title
Date
2/2003
Residential Anti-Displacement and Relocation Plan
Under Section 104(d) of the
Housing and Community Development Act of 1974, as amended
The jurisdiction will replace all occupied and vacant occupiable low and moderate income dwelling units
demolished or converted to a use other than as low and moderate income housing in connection with an activity
assisted with funds provided under the Housing and Community Development Act of 1974, as amended, as
described in 24 CFR 570.488 (c) in Subpart I.
All replacement housing will be provided within three years after commencement of the demolition or
conversion. Before entering into a contract committing the jurisdiction to provide funds for an activity that will
directly result in demolition or conversion the jurisdiction will make public Describe how, e.g., by publication
in a newspaper of general circulation and submit to the Division of Community Grant Programs the following
information in writing:
A. A description of the proposed assisted activity;
B. The location on a map and number of dwelling units by size (number of bedrooms) that will be
demolished or converted to a use other than as low and moderate income dwelling units as a direct
result of the assisted activities;
C. A time schedule for the commencement and completion of the demolition or conversion;
D. The location on a map and the number of dwelling units by size (number of bedrooms) that will be
provided as replacement dwelling units. If such data are not available at the time of the general
submission, the [jurisdiction] will identify the general location on an area map and the approximate
number of dwellings units by size and provide information identifying the specific location and
number of dwelling units by size as soon as it is available;
E. The source of funding and a time schedule for the provision of the replacement dwelling units;
F. The basis for concluding that each replacement dwelling unit will remain a low and moderate
income dwelling unit for at least 10 years from the date of initial occupancy;
G. Information demonstrating that any proposed replacement of dwelling units with smaller dwelling
units (e.g., a 2-bedroom unit with two 1-bedroom units) is consistent with the housing needs of
lower income households in the jurisdiction.
The name and phone number of jurisdiction's office responsible for the replacement of housing is responsible
for tracking the replacement of housing and ensuring that it is provided within the required period.
The name and phone number of the jurisdiction's office responsible for relocation is responsible for ensuring
requirements are met for notification and provision of relocation assistance, as described in 570.488 (c), to any
lower income person displaced by the demolition of any dwelling unit or the conversion of a low and moderate
income dwelling unit to another use in connection with an assisted activity.
Consistent with the goals and objectives of activities assisted under the Act, the jurisdiction will take the
following steps to minimize the displacement of persons from their homes:
2/2003
To be completed by jurisdiction
Examples of steps the grantee might include in the plan for purposes of minimizing the direct and indirect
displacement of persons from their homes:
A. Coordinate code enforcement with rehabilitation and housing assistance programs.
B. Evaluate housing codes and rehabilitation standards in reinvestment areas to prevent their placing
undue financial burden on long-established owners or tenants of mult-family buildings.
C. Stage rehabilitation of apartment units to allow tenants to remain during and after rehabilitation by
working with empty units or buildings first.
D. Establish facilities to house persons who must be relocated temporarily during rehabilitation.
E. Adopt public policies to identify and mitigate displacement resulting from intensive public
investment in neighborhoods.
F. Adopt policies which provide reasonable protections for tenants faced with conversion to a
condominium or cooperative.
G. Adopt tax assessment policies such as deferred tax payment plans to reduce impact or rapidly
increasing assessments on low income owner occupants or tenants in revitalizing areas.
H. Establish counseling centers to provide homeowners and renters with information on the assistance
available to help them remain in their neighborhood in the face of revitalization pressures.
Revised 2/2015
DETERMINATION TO DEMOLISH
(H-1)
This form must be completed prior to utilizing grant funds to demolish any vacant, dilapidated
housing unit in the CDBG funded project.
Property Address____________________________________________________________
Current Occupancy Status_____________________________________________________
* Date Unit Became Vacant____________________________________
(Property must have been vacant for at least 3 months prior to the unit being demolished.)
This unit has been determined to be not feasible for rehabilitation.
Signature of Determination Official
Printed Name: ______________________________________________________________
Signature:
Title: _______________________________________________________________
Date: _____________________________
Attach inspection report detailing major structural and system deficiencies.
Attach exterior and interior (if possible) photographs.
Attach documentation of vacancy such as evidence of the date utilities were disconnected.
Remember the unit must have been vacant for a period of at least 3 months prior to the
demolition.
If the owner has given permission for the demolition, also attach a statement (from the
property owner) that the unit has been vacant since what date and that the previous occupant was
not displaced as a result of possible CDBG demolition assistance to the property.
Community Development Block Grant
2015 County Development Status Designations
Tier IV
Tier III
Tier II
Tier I
Allendale County
Abbeville County
Anderson County
Aiken County
Bamberg County
Cherokee County
Calhoun County
Beaufort County
Barnwell County
Chester County
Edgefield County
Berkeley County
Chesterfield County
Colleton County
Florence County
Charleston County
Clarendon County
Darlington County
Greenwood County
Dorchester County
Dillon County
Fairfield County
Laurens County
Georgetown County
Hampton County
Horry County
Newberry County
Greenville County
Marion County
Jasper County
Oconee County
Kershaw County
Marlboro County
Lancaster County
Pickens County
Lexington County
McCormick County
Lee County
Spartanburg County
Richland County
Union County
Orangeburg County
York County
Saluda County
Williamsburg County
Sumter County
Source: South Carolina Department of Commerce
Community Development Block Grant
County Per Capita Income Average Hourly Wage
County
Average
Per Capita Income
Average Hourly Wage
(based on 2000 hours)
Abbeville County
Aiken County
Allendale County
Anderson County
Bamberg County
Barnwell County
Beaufort County
Berkeley County
Calhoun County
Charleston County
Cherokee County
Chester County
Chesterfield County
Clarendon County
Colleton County
Darlington County
Dillon County
Dorchester County
Edgefield County
Fairfield County
Florence County
Georgetown County
Greenville County
Greenwood County
Hampton County
Horry County
(Myrtle Beach)
Jasper County
Kershaw County
Lancaster County
Laurens County
Lee County
Lexington County
Marion County
Marlboro County
McCormick County
Newberry County
Oconee County
Orangeburg County
Pickens County
Richland County
Saluda County
Spartanburg County
Sumter County
Union County
Williamsburg County
York County
$29,902
$35,047
$26,991
$32,818
$28,040
$26,662
$43,688
$34,462
$38,540
$46,686
$29,401
$31,050
$26,939
$27,358
$31,505
$31,122
$24,872
$34,913
$36,148
$29,500
$36,377
$39,655
$40,257
$32,495
$28,118
$30,810
$28,593
$35,819
$30,834
$32,477
$29,460
$37,956
$26,470
$26,784
$29,551
$32,595
$34,684
$31,067
$29,887
$38,346
$36,460
$34,482
$33,310
$29,448
$29,376
$36,688
$14.95
$17.52
$13.50
$16.41
$14.02
$13.33
$21.84
$17.23
$19.27
$23.34
$14.70
$15.53
$13.47
$13.68
$15.75
$15.56
$12.44
$17.46
$18.07
$14.75
$18.19
$19.83
$20.13
$16.25
$14.06
$15.41
$0.00
$14.30
$17.91
$15.42
$16.24
$14.73
$18.98
$13.24
$13.39
$14.78
$16.30
$17.34
$15.53
$14.94
$19.17
$18.23
$17.24
$16.66
$14.72
$14.69
$18.34
South Carolina
$35,831
$17.92
Source: SC Department of Revenue SC Information Letter #14‐15 10/2007
Business Development: Applicant/Employee Information
POSITION NUMBER: _________
CONFIDENTIAL
The following information is being collected solely for the purpose of meeting reporting requirements of a
Community Development Block Grant being provided to assist the company to whom you are applying
for employment. This information will remain strictly confidential and will only be used for federal
reporting requirements.
COUNTY OF RESIDENCE:
NAME OF BUSINESS:
NAME:
ADDRESS:
Total household income (based on adjusted gross income – find your corresponding household size and then
CIRCLE range in that section that fits your total household income):
1 person household:
2 person household:
3 person household:
4 person household:
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 50-80% range)
(Insert 50-80% range)
(Insert 50-80% range)
(Insert income above 80%)
(Insert income above 80%)
(Insert income above 80%)
5 person household:
6 person household:
7 person household:
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 0-30% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 30-50% range)
(Insert 50-80% range)
(Insert 50-80% range)
(Insert 50-80% range)
(Insert 50-80% range)
(Insert income above 80%)
(Insert income above 80%)
(Insert income above 80%)
(Insert income above 80%)
(Insert 50-80% range)
(Insert income above 80%)
8 person household:
I certify the above information is correct to the best of my knowledge and I understand this information may be
subject to verification.
Signature
(ADMINISTRATIVE USE ONLY:
Date
0-30%
30-50%
50-80%
Over )
10/2007
Notice to Applicant: Separate this form from the application and return to the company.
Applicant/Employee Information Federal EEO Reporting Requirements
CONFIDENTIAL
This information will be separated from your job application and will not be used to evaluate your
application for employment. All information provided below is strictly confidential. This information is
collected solely for the purpose of meeting Federal reporting requirements of a Community Development
Block Grant used to assist the company to whom you are applying for employment.
NAME OF APPLICANT:
Please check the applicable categories below:
ETHNICITY: (select only one)
PRIOR EMPLOYMENT:
Were you unemployed immediately prior to
applying for this job?
Hispanic or Latino:
Yes
Not Hispanic or Latino:
No
RACE: (select one or more)
American Indian or Alaska Native:
Asian:
Black or African American:
Native Hawaiian or Other Pacific Islander:
White:
ELDERLY (62 or older)
Yes
No
DISABLED:
Yes
No
FEMALE HEAD OF HOUSEHOLD:
Yes
No
TO BE COMPLETED BY THE COMPANY AFTER EMPLOYMENT
COMPANY NAME:
JOB POSITION #
# HOURS IN COMPANY WORK WEEK:
# HOURS THIS POSITION:
DATE HIRED:
JOB TYPE:
Full Time
Initial Hire
or
or
Part Time
Replacement
Company-sponsored health care benefits
HEALTH CARE:
EDA JOB CLASSIFICATION: (see attached definitions)
Officials & Managers
Professional
Technician
TRAINING PROVIDED:
Ready SC
Technical Colleges
Date:
Sales
Office & Clerical
Craft Worker (skilled)
Company
Other (Identify):
or
Operative (semi-skilled)
Laborer (unskilled)
Service Worker
No health care benefits
COMPANY DUNS #:
__________________
(Required)
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