City working to formulate Action Plan for use of CDBG-DR funds
Posted on 4/23/2012
The U.S. government recently published in the Federal Register the official requirements, guidelines and allocations for the City of Minot's Community Development Block Grant-Disaster Recovery (CDBG-DR) funds. With this publication the City of Minot has 90 days to formulate and approve an Action Plan for the roughly $67.5 million in 2012 CDBG-DR funds.
"We've been taking all the necessary steps in the three months since CDBG-DR dollars were first announced, but this publication of the Federal Register gives us the official and final ruling on guidelines for use of these funds," said Cindy Hemphill, City of Minot finance director. "We are just a few days away from putting our Citizen Participation Plan before the City Council and we expect to be hiring a consulting firm soon that will handle much of the administrative services associated with these dollars."
According to the Federal Register, before the City of Minot can use these funds they have to submit a plan detailing their proposed use including the criteria for eligibility and how particular activities will address long-term recovery. This constitutes an Action Plan. The Housing and Urban Development Department, the federal government agency overseeing the funds, expects the City of Minot "to conduct an assessment of community impacts and unmet needs to guide the development and prioritization of planned recovery activities."
To assist Minot in an appropriate assessment the City Council approved staff bid out requests for proposals for administrative services and project delivery services associated with the CDBG-DR funds. Staff expects to bring a recommendation to a City committee next week for hiring one of the firms that submitted a proposal for services.
As well, next week a City committee will be able to review a Citizen Participation Plan that outlines how residents can participate in the process of developing the Action Plan. One expected component of the plan includes the City of Minot posting its Action Plan for disaster recovery on the official City website for at least seven days for public comment.
The City has no more than 90 days to respond to all public comments and submit its Action Plan to HUD. At this point HUD has no more than 45 days to expedite its review of the Action Plan and return it to the City before Minot can access any of the $67.5 million CDBG-DR funds.
HUD recognizes that the Action Plan and the needs assessment "may be considered as a living document" and will be periodically updated over time based on the recovery needs that remain as funds are being spent.
"I think it is important to note that HUD has intentionally designed these funds to be flexible and not limited to just returning our City to pre-disaster conditions," said Hemphill. "In the Federal Register is states the ‘grantees are encouraged to undertake activities in such a way that not only addresses the disaster-related impacts, but leaves communities better positioned to meet the needs of their post-disaster populations and prospects for growth.' We are hoping to be able to use these funds to have the greatest overall impact for the recovery and development of our City."
A key stipulation in the requirements and use of CDBG-DR funds is that at least 50 percent of the entire award must be used for activities that benefit low- and moderate-income persons.
HUD did agree to grant Minot's waiver request to allow reimbursement for pre-agreement costs. This means that part of the Action Plan could include the City being reimbursed for flood recovery activities that happened after the flood, but prior to HUD's acceptance of the Action Plan.
The federal duplication of benefits rule applies for use of the CDBG-DR funds. Prior to receiving financial assistance for a disaster related loss, other benefits will need to be taken into consideration when determining any unmet needs. To comply with this law, the City of Minot will need to show that those individuals or businesses receiving assistance from CDBG-DR have "a disaster recovery need that has not been fully met."
To view the 17-page Federal Register document that explains the allocations, waivers and alternative requirements for CDBG-DR grantees, go to the Resources section.