CDBG FFY 2026 Application Guidance.pdf
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- Solicitation number
- BD-26-1531-SWSPD-SWSPD-125181
- Issued by
- Hampden County, Massachusetts
About this file
This document is the Federal Fiscal Year 2026 Massachusetts Community Development Block Grant (CDBG) Program Application Guidance issued by the Executive Office of Housing and Livable Communities (EOHLC). The guidance provides comprehensive instructions for municipalities to apply for CDBG funding through either the Community Development Fund (CDF) for non-entitlement communities or the Mini-Entitlement (ME) program. Applications must be submitted through EOHLC's web-based application system by Monday, April 21, 2026, at 3:00 PM. The guidance covers five types of project packets: Construction Activities (including Architectural Barrier Removal, Demolition/Clearance, and Infrastructure); Design Activities; Planning Activities; Public Services Activities; and Rehabilitation Activities. Eligible projects include housing assistance, housing development, economic development, public facilities, infrastructure, public social services, and planning projects. All projects must meet one of three national objectives: benefit low- and moderate-income persons, prevent or eliminate conditions of slums or blight, or address urgent or critical community need. Mini-Entitlement communities must submit a Community Development Strategy demonstrating project consistency with community development goals, and Beverly, as a newly designated Mini-Entitlement, must submit their first Community Development Strategy with the FFY 2026 application.
The application framework requires municipalities to demonstrate project need and feasibility through scored competitive questions totaling 65 points, with projects needing a minimum combined score of 39 points to be considered fundable. General Administration costs are capped at 15 percent of total grant amount, while combined General Administration and Program Delivery costs cannot exceed 30 percent. Grant Preparation costs are limited to $9,000 for municipalities that have not received a Massachusetts CDBG grant in three prior years and $6,000 for all other municipalities. Current CDBG grantees must meet timely expenditure thresholds, requiring 90 percent expenditure of FFY 2022/2023 and earlier awards and 40 percent of FFY 2024 awards. The application requires submission of multiple supporting plans and certifications, including Anti-Displacement and Relocation Assistance Plans, Citizen Participation Plans, Management Plans, and compliance documentation for Build America, Buy America Act requirements for infrastructure projects. All applicants must hold at least one public hearing before submission and one during the grant cycle, with adequate notice and accessibility accommodations for persons with disabilities and non-English speaking residents.
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Federal FY 2026 Massachusetts CDF/ME Program Application Guidance - Page 1
APPLICATION GUIDANCE INFORMATION
This Application Guidance package explains how to apply to the Massachusetts Community Development Block Grant (CDBG) Program, including information on what to submit, deadlines, special eligibility standards, and the application review processes. This guidance material should be read in conjunction with the FFY 2026 One Year Action Plan, which should be read first. The One Year Action Plan takes precedence over language in all program components within this application guidance. The draft FFY 2026 Action Plan is available on EOHLC’s website at www.mass.gov/service-details/community-development-block-grant-cdbg .
The Executive Office of Housing and Livable Communities (EOHLC) provides technical assistance to cities and towns interested in applying to the Massachusetts CDBG program.
Applicants are strongly encouraged to email program staff with questions. In addition, Technical Assistance Memos are available on the CDBG webpage. These documents describe program design options and the regulations governing projects.
EOHLC reserves the right at any time and without penalty to cancel or recommence this Notice of Funding Availability (NOFA), narrow or amend its scope, or reject any and all responses if EOHLC determines that a fair and open competitive procurement has been compromised or that doing so is in the best interest of the Commonwealth. EOHLC reserves the right to use this NOFA and responsive applications to allocate CDBG awards without further notice.
APPLICATION SUBMISSION REQUIREMENTS
Community Development Fund / Mini-Entitlement Program The Community Development Fund (CDF) is a competitive program that is available to all municipalities that are not Entitlement Communities as identified by the United States Department of Housing and Urban Development (HUD) or Mini-Entitlement communities as identified by EOHLC. A complete description of the Community Development Fund can be found in the Draft FFY 2026 One Year Action Plan.
The Mini-Entitlement program descriptions in the Draft FFY 2026 One Year Action Plan detail the program and basis for the designation of communities.
All applications must be received by EOHLC’s web-based application system by Monday, April 21, 2026, at 3:00:00 PM. A signed copy of the required Application Cover page, and Joint Authorization page (if applicable), must be attached in the Other Attachments link of the application.
APPLICATION TRAINING AND TECHNICAL ASSISTANCE
Local officials or their designees are welcome to examine previously funded applications on-line.
Municipalities that seek EOHLC assistance generally write more competitive applications than those that do not. We strongly recommend that if a municipality plans to apply to the Massachusetts CDBG Program, a municipal representative contact CDBG program manager, Kathryn McNelis at Kathryn.McNelis@mass.gov or Patricia.Roushanaei@mass.gov.
It is extremely important for municipalities to understand that because the grant programs contained in this Application Guidance are competitive, Massachusetts CDBG does not discuss http://www.mass.gov/service-details/community-development-block-grant-cdbg mailto:Kathryn.McNelis@mass.gov mailto:Patricia.Roushanaei@mass.gov
Application Guidance - Page 2 applications with local officials or their agents after the application deadline. Therefore, please be sure that your application is accurate and complete before submission.
The Appendices referred to throughout this Application Guidance are available on EOHLC’s website. See the list of Available Appendices for details on how to access the information.
ELIGIBLE PROJECTS
Massachusetts CDBG grants can fund any project that is eligible under federal statute in Title I of the 1974 Housing and Community Development Act, as amended. Traditionally, communities use Massachusetts CDBG resources to carry out the following types of programs or projects through these programs. This is only a partial list:
Housing assistance rehabilitation of substandard dwelling units, repairs to maintain livability including minor repairs designed to help elderly residents stay in their homes, lead paint abatement, rehabilitation of shelters or transitional housing, site development costs for new housing projects (in very limited instances, new housing construction), and relocation.
Housing development: includes projects involving the rehabilitation of existing housing units in downtown and village center buildings, or the conversion to housing of upper story space in downtown and village center buildings, as well as other adaptive reuse projects (applicants thinking of this type of project must contact CDBG staff prior to applying). Total cost must not exceed $175,000 per unit. Design development drawings for the project must be included in an application (see appendix I for further guidance) The One-Stop application will not be required for these types of projects. However, detailed cost estimates and budgets must include a description of both sources and uses of funds.
Economic development/commercial rehabilitation: sign and facade improvements and other economic development related projects (applicants considering an economic development project for FFY 2026 must contact CDBG staff prior to moving forward).
Public facilities: senior centers, neighborhood centers, parks and playgrounds, youth centers, architectural barrier removal, and other types of facilities that serve the needs of low- and moderate-income persons.
Infrastructure: reconstruction of streets and sidewalks, drainage improvements, upgrade of water supply and distribution systems, and construction or repair of sewer lines, including infrastructure to housing projects.
Public social services: childcare subsidies, substance abuse counseling, community policing, elder services, first-time homebuyer counseling and down payment assistance, assistance for the homeless, disabled, illiterate adults, abused children, battered spouses and other predominantly low- and moderate-income clientele. Applicants should review the Limitations on the Use of Program Funds section of the FFY 2026 One Year Plan for more details regarding EOHLC’s preference for services that are designed to build economic security and self-sufficiency and overall requirements for public social services. No more than five public services may be requested in an application.
Application Guidance - Page 3
Planning Projects: planning and pre-development assistance; it must be demonstrated that upon implementation the planned activities will meet a national objective.
Appendix A provides the complete list of eligible activities. The list of eligible activities reveals the flexible design of the CDBG program. However, an activity retains its eligibility only if it meets one of the three national objectives of the CDBG program: (a) benefit low- and moderate-income persons; (b) prevent or eliminate conditions of slums or blight; or (c) address an urgent or critical community need. If it is not clear that a project presented in the application can meet a national objective, then the project cannot be funded regardless of the inclusion of the type of activity on the eligibility list. Detailed information about national objectives, including minimum compliance documentation, begins on page 10 of this Application Guidance.
GRANT ADMINISTRATION GUIDANCE
The Commonwealth is not responsible for a recipient's grant management. Every municipality that receives a Massachusetts CDBG award is responsible for hiring qualified staff or consultants, supervising these individuals, and ensuring that grant programs are implemented in accordance with federal, state and, where applicable, local requirements. Chief elected officials or executive officers in municipalities considering a Massachusetts CDBG application should determine how much additional staff capacity the municipality will need to implement the grant and then either budget for qualified personnel in the application or provide for compensation from locally appropriated resources. Municipalities should be aware that once a grant has been awarded, the municipality must establish a separate "designated bank account" for the receipt of Massachusetts CDBG funds. This account must be set up and maintained by the municipal Treasurer. For further information see the section on Management Plans.
Municipalities may propose one or more projects in an application. Applicants may also include requests for funds to cover both administration and program delivery costs, as follows:
General Administration Up to 15% of the total grant amount can be used for general administrative expenses. These include such personnel costs as financial/secretarial support and a grant manager to oversee program operations; and certain non-personnel expenses such as telephone, copying charges, an audit and other "overhead" types of costs.
Program Delivery The cost of delivering a program service, such as the time spent by a housing rehabilitation specialist to inspect dwelling units, develop work write-ups, obtain bids for homeowners, and supervise construction work, is a program delivery cost which is not included in the General Administration cap of 15%. The total combined (General Administration and Program Delivery) must not exceed 30% of the total grant amount.
Grant Preparation Costs If a municipality (or group of municipalities) has not received a Massachusetts CDBG grant in three prior years, up to $9,000 for grant application preparation can be charged as an allowable expense to the grant. For all other municipalities, the maximum allowable expense for grant application preparation is $6,000. During application development, technical assistance is available to guide local officials in determining appropriate costs.
Application Guidance - Page 4
Determining Reasonable Administrative Costs The General Administrative and Program Delivery budgets are designed to allocate grant management charges between general administration and service delivery costs. However, grantees can perform grant responsibilities through municipal staff, a consultant or a sub-contractor. In any case, a municipality assumes the responsibility, through its Procurement Officer, for conducting procurement in accordance with applicable federal and state requirements. It is ultimately the responsibility of the municipality’s Procurement Officer to establish procedures and monitor procurement operations to ensure that procurements are done properly.
Grant Awards and Administrative Costs Municipalities that receive Massachusetts CDBG awards must comply with all applicable federal and state laws, rules, regulations, guidelines, and executive orders, as may be further delineated in a contract with EOHLC and guidance that may be issued or amended from time to time by
EOHLC.
EOHLC reserves the right to increase or decrease the award of funds for a program when either the delivery or general administration costs are insufficient or unreasonably high or do not support the CDBG program objectives. Further, as we monitor a grant for federal compliance, municipalities must maintain sufficient documentation to show that costs charged to a program were service-related and not overhead or general administration-related. In any case it will be the grant recipient’s burden to prove the reasonableness and eligibility of program delivery costs in both the application, and later, in actual practice.
APPLICATION INSTRUCTIONS
This part of the Application Guidance provides guidance and instructions for completing the on-line application.
General Writing Guidelines and Page Limits for Applications
• There is a four (4) page limit for responses to the scored questions contained in each packet, except for a two (2) page limit for the planning packet. Reviewers will not read beyond the page limit for any section. Responses to the scored questions must use Times New Roman style with 12 pt font size and three-quarter (3/4) inch margins.
Responses with smaller margins will be considered to have exceeded the page limit.
Applicants should also use reasonable (1.04) line spacing in developing the narrative.
Page limits do not include the application cover sheets, threshold question responses, budget forms, project description summaries, or pertinent information that can be included in attachments or the appendix.
• Responses must be submitted online using the EOHLC’s web-based application system.
The easiest way to do this is to prepare, in advance, electronic versions of all narrative responses and then attach them to the corresponding section of the on-line application.
Application Guidance - Page 5
• Several application questions allow for attachments. Applicants should use descriptive names for the attached documents e.g. “Public hearing minutes”, “Waiting list summary” (do not include resident names on waiting lists). If more than five files are attached, applicants should create a list of attachments so that it is clear what information is available in the attachments. Do not use any symbols in the attachment file names. Be sure that attachment names match the name provided in the text. See page 23 for further guidance on the use of attachments.
MASSACHUSETTS CDBG’s FFY 2026 web-based application forms will be posted when they are available at https://maeohlc.intelligrants.com
The Login page should look like this:
As this was a new application form for the FFY 2025 funding round, all persons and organizations that did not apply in 2025 will be required to register. Please follow the instructions for New Users and if there are any issues contact Mark Southard via email at mark.southard@mass.gov and cc kathryn.mcnelis@mass.gov.
After successfully logging on to the system, applicants should look in My Opportunities on the Dashboard. Find the Community Development Fund (CDF) or Mini-Entitlement (ME) application for FFY 2026 and click on the link. Agree to create a new application when prompted and click Proceed on the prompt which will load the application form. Once you have created an application, it will show up in the My Tasks box on the Dashboard.
APPLICATION MENU
The application menu consists of a series of Forms which are the content of an application. The appropriate forms must be completed and saved to assemble a complete application.
mailto:mark.southard@mass.gov
Application Guidance - Page 6
COMPONENT SELECTION
On the side bar of the application is a list of forms and documents. The first form in the list is the Application Cover sheet. Click on the link to open the document. The first part of the Cover Sheet includes the five packet components which will be used to represent the activity(ies) that will be the subject of the application. Click the box next to the component(s) that will be included in the application. If the application has more than one of the same activity, applicants will create additional packets later.
APPLICATION COVER
The Application Cover Sheet must be printed and signed by the Chief Elected Official or by the Chief Executive Officer (if so authorized by the city or town). The individual who signs the cover sheet must be the official who is authorized to obligate the city or town to legal contracts.
If this is not the Chief Elected Official (i.e., Chair of the Select Board/Board of Selectmen or Mayor), furnish the appropriate documentation in an appendix, which verifies the contractual authority of the person who signs the application cover sheet. For joint applications, this would be the Chief Elected Official or Chief Executive Officer in the lead municipality.
Municipalities seeking a joint or regional grant, i.e., two or more municipalities, must also submit the Joint Authorization Form for the non-lead community(ies). It must be signed by the Chief Elected Official of every participating municipality. The Chief Elected Official of the lead municipality signs the Application Cover Sheet.
The individual who signs the Joint Application Authorization sheet must be the official who is authorized to obligate the city or town to legal contracts. If this is not the Chief Elected Official (i.e., Chair of the Select Board/Board of Selectmen or Mayor), furnish the appropriate documentation in an appendix, which verifies the contractual authority of the person who signs the sheet. The contact person identified on the Cover Sheet must be an employee of the municipality.
CEO/Signatory Post Application Submission Contact Information Form
EOHLC requires all applicants to submit a form confirming CEO/Signatory contact information post application submission, as this information may change between application submission and EOHLC review. The form will be available on the CDBG website in early July 2026 at https://www.mass.gov/info-details/community-development-block-grant-cdbg under the application section. It must be completed and returned to Kathryn McNelis at Kathryn.McNelis@mass.gov no later than August 1, 2026, in order to avoid a delay in CDBG funds being provided to the municipality, in the event an award is made. Please note, this is required of all applicants. However, if you are receiving an award, failure to provide by the deadline may negatively impact the CDBG contracting and funding timeline.
TIMELY EXPENDITURE THRESHOLD STANDARDS (For current Massachusetts CDBG grantees) https://www.mass.gov/info-details/community-development-block-grant-cdbg
Application Guidance - Page 7
MA CDBG requires that all lead applicants with open CDBG grants comply with a timely expenditure threshold. In order to apply for FFY 2026 CDBG funding, a municipality must demonstrate, using the most recent financial status report produced by EOHLC’s grant management system, at the time of submission of application for FFY 2026 funds that:
1. 90% of all grant funds awarded for FFY 2022/2023 and earlier FFYs have been fully expended.
2. 40% of all grant funds awarded to the municipality for FFY 2024 have been expended.
On a case-by-case basis, EOHLC reserves the right to waive strict compliance with the threshold standards for events beyond the control of applicants, which the applicants have the burden to demonstrate. Please note, however, that for this grant round, if a municipality is less than 75% expended in the FFY21 award, a waiver will not be granted unless good cause and a plan for expenditure of funds can be demonstrated. EOHLC is not inclined to grant a waiver unless a strong case is presented.
Municipalities must contact their program representative to learn how to apply for a waiver.
Waiver requests should be submitted no later than February 27, 2026, otherwise, it may not be considered. EOHLC may at its discretion review waiver requests submitted after, February 27, 2026, if the municipality demonstrates good cause for not submitting its request to EOHLC by such date.
All lead applicants must meet this threshold at the time of application for all MA CDBG components. Municipalities that do not meet this threshold will be eliminated from further MA CDBG funding consideration. Active grants include those for which project activities have yet to be completed and payments are outstanding. Unexpended CDBG funds are defined as funds awarded for eligible Massachusetts CDBG program costs but not expended.
A Mini-Entitlement community that cannot meet this threshold may have its award amount reduced based on defined grant limitations. EOHLC also reserves the right to limit the number of activities that a Mini-Entitlement can apply for beginning with the FFY27 round if this threshold is not met for the FFY26 round.
COMMUNITY BASED PLANNING REQUIREMENT
For FFY 2026, all communities will continue to be expected to discuss how community-based planning helped determine the need for projects when responding to competitive questions.
Mini-Entitlement communities must be able to demonstrate project consistency with a Community Development Strategy (CDS). This Strategy is based on various planning documents used by a community and outlines a plan of action intended to accomplish specific community development goals that will have an impact on the community. It identifies the goals and objectives of community development efforts over a 3-to-5-year period and explains how the community expects to address the priorities with CDBG and non-CDBG funds.
Mini-Entitlement CD Strategies that were prepared for and approved for the FFY 2024 application are valid through the FFY 2026 grant round. As a newly added Mini-Entitlement, Beverly must submit their first Community Development Strategy (CDS) with their FFY26 application. CDS strategies for all Mini-Entitlements must be uploaded to the FFY 2026
Application Guidance - Page 8 application. Each activity included in a Massachusetts CDBG ME application must relate to and be reflected in the Strategy. (CDF applicants do not need to submit a Strategy.)
AMERICANS WITH DISABILITIES ACT SELF EVALUATION SURVEY AND TRANSITION
PLAN
For FFY 2026, all municipalities participating in an application for CDBG funds that did not participate in an application between FFY 2018 and FFY 2025 will submit as part of the application, a copy of the municipality’s Americans with Disabilities Act (ADA) required Self Evaluation Survey and Transition Plan (Plan). If a municipality does not have a Plan, it will submit as part of the application a statement to this effect on municipal letterhead. All municipalities that do not have a Plan will be referred to Massachusetts Office on Disability (MOD) for execution of a Memorandum of Understanding (MOU) toward the development of a Plan. The Plan or the municipal letterhead should be attached on the forms page of the application under Other Attachments. Specific questions regarding the Plan should be directed to:
Director Massachusetts Office on Disability One Ashburton Place, Room 1305 Boston, MA 02108 Phone: (617) 979-7317
BUILD AMERICA BUY AMERICA ACT (BABA)
Build America, Buy America Act (BABA) Requirements under Title IX of the Infrastructure Investment and Jobs Act (“IIJA”), 41 U.S.C. Chapter 83 §§ 8301-8305, Pub. L. 177-58 and regulations at 2 CFR Part 184. Absent a general or project-specific waiver Contractor must apply a domestic content procurement preference (the “Buy America Preference” or “BAP”) for all iron, steel, manufactured products, and construction materials incorporated into the project.
All iron, steel, manufactured products, and construction materials used must be produced in the United States.
The Buy America Preference must be included in all subawards, contracts, and purchase orders for the work performed, or products supplied under the Federal award. Grantees are required to submit a BABA documentation form for each project that meets the definition of infrastructure. Definitions of iron, steel, manufactured products, construction materials, and infrastructure can be found in 2 CFR Part 184 and are incorporated herein by reference.
Examples of CDBG projects that are considered infrastructure projects include: rehabilitation, maintenance, and reconstruction of buildings and real property, including housing, and construction and repair of public facilities and improvements, such as water, sewer, or other utilities, roads, bridges, sidewalks, homeless shelters, or broadband infrastructure. For additional guidance, see the Office of Management and Budget’s Memorandum M-24-02, “Implementation Guidance on Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure;” HUD Notice CPD-2025-01: BABA Implementation Guidance for BAP;” and the HUD Quick Guide “Build America, Buy America Act: Buy America Preference for CDBG Grantees.” For additional information on HUD’s general and project-specific waivers, see HUD’s website https://www.hud.gov/hud-partners/baba .
https://www.hud.gov/hud-partners/baba
Application Guidance - Page 9
Grantees must determine for all projects that meet the definition of infrastructure1 whether BABA requirements apply to the project and must factor BABA requirements into cost estimates and include BABA language in contracts for these projects. Grantees will be required to submit a BABA documentation form for each project that meets the definition of infrastructure as defined in the footnote and BABA guidance. The BABA documentation form can be found on the CDBG webpage Community Development Block Grant (CDBG) | Mass.gov under FFY 2026 Information. The BABA documentation form(s) should be uploaded to the Other Attachments link in the application.
PROJECT PACKETS:
Communities apply for funds for specific activities by submitting information in project packets specific to the type of activity requested. There are five project packets. For each project proposed, an applicant must use a separate packet.
• Construction Activities: Architectural Barrier Removal, Demolition/Clearance, Infrastructure & Public Facilities/Improvements
• Design Activities (stand-alone)
• Planning Activities
• Public Services Activities
• Rehabilitation Activities (includes Housing or Commercial, and Other Housing)
A complete project packet is comprised of the following information:
• General information Participating Municipalities Name of Project Eligible Activity description
• National Objective information including beneficiaries
• Threshold Requirements
Consistency with Sustainable Development Principles (if applicable) Additional Project Thresholds (project specific)
• Project Description Project Location Information
• Project Budget Information including project and administrative costs and an attached, detailed budget.
• Competitive Questions (2) Project Need Project Feasibility
The following information will provide the applicant with guidance on how to complete the project packet component of the CDBG application. Applicants should use the project packets to provide
1 “Infrastructure” is defined broadly under 2 CFR § 184.4(d), and covers any project that includes construction, alteration, maintenance, or repair or infrastructure regardless of whether infrastructure is the primary purpose of the project. Examples of CDBG projects that are considered infrastructure projects include: rehabilitation, maintenance, and reconstruction of buildings and real property, including housing, and construction and repair of public facilities and improvements, such as water, sewer, or other utilities, roads, bridges, sidewalks, homeless shelters, or broadband infrastructure. See the HUD Quick Guide “Build America, Buy America Act: Buy America Preference for CDBG Grantees.”
https://www.mass.gov/info-details/community-development-block-grant-cdbg?_gl=1*de52ka*_ga*MjExMjQ0NTc0MS4xNjgzMjkxNDc4*_ga_MCLPEGW7WM*MTcwMTM1OTIxOC4yMC4wLjE3MDEzNTkyMTguMC4wLjA.
Application Guidance - Page 10 detailed information regarding proposed projects. Project Packets are first reviewed for compliance with the threshold requirements, and then for competitiveness. Please review the information in this guide closely and it is recommended that you have a copy available, along with the CDBG One Year Action Plan, when completing the on-line application.
General Information The first section of a project packet requests information to identify the participating community(ies), the project name and the eligibility of the activity requested. Based on this selection and the Project Description, EOHLC staff will confirm the eligibility of the requested activity.
The proposed project must be eligible for funding under the CDBG program. Both Appendix A and pages 2 to 3 of this guidance lists various types of CDBG-eligible projects.
Applicants should review this list to ensure that the proposed project is an eligible activity.
Eligibility will be evaluated in accordance with Title I, Section 105(a). Ineligible activities will not be scored.
National Objective Compliance
Each project must meet a national objective. National objectives and related documentation are discussed in detail in this section. National Objective responses will not be scored. The response will be evaluated as described below.
a) Identification of the national objective that will be met. Explain how it will be met in as much detail as possible. For example, a project could meet a national objective by benefiting low- and moderate-income persons on an area-wide basis. Please note, only one national objective needs to be selected.
b) Description of appropriate type(s) of documentation available to show that the project meets a national objective. Demonstrate how you will determine that the project will meet the national objective. See the guidance below.
National objectives are discussed in the CDBG Regulations for State Programs at 24 CFR Part
570.483. Each project must meet one of three national objectives:
1. Benefit to low- and moderate-income persons; or
2. Prevention or elimination of slums or blight; or
3. Urgent or critical community need.
Minimum requirements for documenting each type of national objective compliance are discussed below.
Benefit to Low- and Moderate-Income Persons
Documenting one of the following can satisfy this threshold:
A. Area-wide Benefit - A project will meet the national objective of benefit to low- and moderate-income persons if its benefits extend generally to all of the residents of the area in which the project is located, and 51% or more of those residents are low- and moderate-income persons.
Application Guidance - Page 11
It is critical, however, that the service area determined by the grantee is the entire area served by the project. In addition, the service area must be primarily residential. Area-wide benefit is often used to meet national objective requirements for certain types of infrastructure projects, such as street repairs in a largely low-income neighborhood. In any case, the application must clearly document and explain how this requirement will be met.
1. Explain the methodology for establishing geographical boundaries of the service area and the percentage of low- and moderate-income persons.
2. Applicants must prove the 51% low- and moderate-income residency standard by using either HUD-supplied low- and moderate-income data, which are based on the 2016-2020 American Community Survey 5-year estimates found online at https://www.hudexchange.info/programs/acs-low-mod-summary-data/; or a survey and its results consistent with the survey methodology included in Appendix C and available online at:
http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/notices/cpd (go to Notice #14-013). For further guidance, please see link to CDBG Income Survey Toolkit - HUD Exchange.
• If a community believes their project’s compliance with this national objective can be based upon the statistics for the Block Group in which the project will occur and is considering the use of American Community Survey data to substantiate a low and moderate income (LMI) area, please contact Massachusetts CDBG program staff for further discussion. The use of Block Group statistics to support compliance with national objectives must be approved by EOHLC prior to submission of an application. The link to the form is found here:https://www.mass.gov/doc/lmi-area-wide-block-group-information-documentation-form/download
• If a survey is used to substantiate an LMI area, a copy of the blank survey document and summary survey results must be included with the project packet. Applicants must also include the survey data broken down by street (total number of households on each street and the income distribution for LMI households and all other households for each street). Surveys must demonstrate an adequate sample size and response rate based on HUD’s guidance or they cannot be considered valid by EOHLC.
• A valid survey is no older than three years. If the survey is between three and five years old, EOHLC will consider the survey if the applicant demonstrates that the surveyed households are the same as when originally surveyed, and that no additional residences have been added to cause the survey to become statistically unreliable. Applicants should seek EOHLC’s advice in advance of using older surveys.
Note: surveys must be worded to not bias the results. For example, it is not appropriate to say, “In order for the municipality to receive desired funding, a survey must be conducted to show that most of the residents of the area have low- and moderate-income.”
3. Applicants must furnish a parcel map of the service area, showing:
• If applicable, the Census Block Groups and the corresponding LMI statistics.
• If applicable, surveyed streets and surrounding area;
https://www.hudexchange.info/programs/acs-low-mod-summary-data/ http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/notices/cpd https://www.hudexchange.info/programs/cdbg/cdbg-income-survey-toolkit/?utm_source=HUD+Exchange+Mailing+List&utm_campaign=04fe1b49d4-CDBG_INCOME_SURVEY_GUIDEBOOK_TOOLKIT_22%2F9%2F29&utm_medium=email&utm_term=0_f32b935a5f-04fe1b49d4-19458781 https://www.hudexchange.info/programs/cdbg/cdbg-income-survey-toolkit/?utm_source=HUD+Exchange+Mailing+List&utm_campaign=04fe1b49d4-CDBG_INCOME_SURVEY_GUIDEBOOK_TOOLKIT_22%2F9%2F29&utm_medium=email&utm_term=0_f32b935a5f-04fe1b49d4-19458781 https://www.mass.gov/doc/lmi-area-wide-block-group-information-documentation-form/download https://www.mass.gov/doc/lmi-area-wide-block-group-information-documentation-form/download
Application Guidance - Page 12
• The dominant land uses; and
• If applicable, current and proposed sewer or water lines, direction of flow, storage tanks, pump stations, treatment plants and well fields.
4. If the residential target area contains vacant land, applicants must;
• Show each vacant parcel of land on a parcel map; and
• Describe the potential future use of the land for the next five to seven years.
• Consider current zoning, subdivision plans, planning documents etc.; and
• Describe how potential future use could have an impact upon the national objective.
B. “Direct” Benefit for Housing Projects - CDBG-assisted housing projects (not to be confused with a “public housing project”) will meet the national objective if they predominantly benefit LMI persons by providing them with safe, decent and sanitary housing. Housing projects include rehabilitation loans or grants, first-time homebuyer loans, etc. For such projects, grantees must collect and maintain information on household size and income to demonstrate that a LMI household occupies assisted housing units. For buildings with two units, at least one eligible household must occupy one of the assisted units. For three or more units, at least 51% of the assisted units must be occupied by LMI persons. Applicants must describe the specific steps to be taken to ensure compliance with this requirement, including the income information that will be obtained from clients, and the standards used to determine eligibility at the time of application.
C. Limited Clientele Benefit. A CDBG-assisted project will meet this national objective if it can be demonstrated that the project is designed so that the benefits are limited to certain groups with characteristics, such as:
1. Groups presumed by HUD to be low- and moderate-income.2 These include the elderly;
severely disabled adults,3 abused children, battered spouses, homeless persons, persons with HIV/AIDS, illiterate adults, and migrant farm workers. No income verification is required for these groups unless an “income payment,” such as fuel assistance, childcare subsidies or tuition payments, is being provided. Projects limited in scope to the removal of architectural barriers for severely disabled adult(s) or elderly persons categorically meet national objective requirements.
2. Groups of persons already documented as low- and moderate-income. For example, a recreation program for the exclusive use of residents in a low-income housing development complies. Usually, no further income documentation is required for this type of project.
2 HUD accepts these presumptions unless there is evidence to the contrary.
3 Persons are classified as having a severe disability if they: (a) used a wheel-chair or had used another special aid for six months or longer; (b) are unable to perform one or more “functional activities” or need assistance with an “ADL or IADL”; (c) are prevented from working at a job or doing housework; or (d) have a selected condition including autism, cerebral palsy, Alzheimer’s disease, senility or dementia, or mental retardation. Also, persons who are under 65 years of age and who are covered by Medicare or who receive SSI are considered to have a severe disability.
NOTE: For purposes of this definition, the term “functional activities” includes seeing, hearing, having one’s speech understood, lifting and carrying, walking up a flight of stairs, and walking. An ADL is an “activity of daily living” which includes getting around inside the home, getting in or out of bed or a chair, bathing, dressing, eating, and toileting. An IADL is an “instrumental activity of daily living” and includes going outside the home, keeping track of money or bills, preparing meals, doing light housework, and using the telephone.
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3. Groups whose composition is such that it can be concluded that a majority of their clientele will be LMI persons. For example, projects involving homeless shelters will usually qualify under this provision without further proof of income eligibility. For application purposes, the clientele must be profiled so it is clear that beneficiaries of CDBG assistance will be LMI persons.
4. Groups that can be documented to be predominantly LMI (at least 51%). Such projects must be designed to collect information on household size and income so that the program will document clientele income eligibility. For example, a project that provides well-child medical care will meet the national objective if the program will collect income data to determine eligibility to receive CDBG-assisted services.
Limited clientele projects must document compliance by one of the following methods:
• For projects that do not provide “income payment” forms of assistance, beneficiaries may “self-declare” their eligibility, generally by completing and signing a form declaring household sizes and income ranges.
• For projects that offer income payments or subsidies, income must be documented.
• For projects where the user profile will be LMI, a description of the profile must be presented so that the conclusion, without a doubt, will be to benefit LMI persons.
D. Planning Projects. An activity involving planning will meet a national objective if it is demonstrated that at least 51% of the persons who would benefit from implementation of the plan are LMI.
Prevention or Elimination of Slums and Blight
A. Area basis - This national objective may be used for any activity designed to eliminate or prevent slum/blight on an area wide basis. Approval of the area will be based on documentation of all of the following criteria and submitted to EOHLC for approval at least 30 calendar days prior to the application deadline. Communities who have their designated slum and blight area approved prior to the application deadline should include the approval letter as documentation in the application.
1. The community must determine that the area meets the state’s definition of substandard, blighted or decadent areas as stated in MGL ch.121A and ch.121B. The community must describe how the conditions in the target area are consistent with these definitions. Please refer to MGL ch. 121A and ch. 121B. The Chief Elected Official or other authorized official must determine in writing that the area is in disrepair or there is a pattern of recognizable disinvestments thereby meeting one of the definitions ascribed above.
2. The community must also document that at least 25% of the properties throughout the area experience one or more of the following conditions:
Physical deterioration of buildings or improvements;
Abandonment of properties;
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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 OR the public improvements throughout the area are in a general state of deterioration.
Definitions
1) Physical deterioration of buildings and improvements are those buildings whose condition meets the definition of fair or poor under the rating criteria listed below.
Public Improvements must demonstrate that they are in a general state of deterioration. Please refer to the Public Improvements guidance below.
2) Abandonment of properties: are defined as residential, commercial or industrial buildings or lots that for the previous 24 months:
• Have been completely vacant;
• With owners who have not paid property taxes, utility bills or mortgage; or
• With owners who have not been responsive to notices or citations concerning the property from the municipality.
3) Chronic high occupancy turnover rates: refers to commercial or industrial buildings in which all commercial or industrial units have turned over 2 times within the previous 24 months prior to application submission. Chronic high vacancy rates: refers to commercial or industrial buildings that have been completely unoccupied for a total of 12 out of the previous 24 months prior to application submission.
4) Significant decline in property values relative to other areas in the community refers to buildings or lots in which assessed or market values, on a square foot basis, have declined by 25% relative to the change in average property values of other districts in the community with similar zoning or land uses. Abnormally low property values relative to other areas in the community refers to buildings or lots in which assessed or market values, on a square foot basis, are 25% lower than the average values of other districts in the community with similar zoning or land uses.
5) Known or suspected environmental contamination: refers to real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant or contaminant.
3. Because communities will receive a ten-year designation of their target area if EOHLC accepts the supporting documentation, EOHLC requires both the submission of the building inventory and the infrastructure inventory regardless of which will qualify the area as meeting the criterion. In addition to the determination by local inspection, applicants must provide each of the following items in a separate attachment:
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• A map clearly delineating the geographic area that is designated as slum/blighted and which shows the location of all buildings, properties and public improvements that are deteriorated or meet one of the criteria of disinvestment listed above.
• A parcel inventory of all buildings and properties in the slum/blight area. This inventory must include a Property Rating Sheet for each building and property located in the slum/ blight area. The rating sheet consists of photographic documentation for each building, a description of the condition of major building components and an overall property condition rating. The conditions are based upon definitions of standard criteria for classifying buildings as poor, fair, good and excellent as defined below.
• An infrastructure inventory that describes and quantifies the deterioration for each type of public improvement identified, e.g. linear feet of sidewalk, roadways, number of light fixtures. An Infrastructure Rating Sheet must be included with applicable photographs and description of conditions. The conditions are based upon the definitions as defined below.
• Appendix J that provides a summary of properties for the entire target area. This must include the total number of buildings, the type of buildings, and the percentage of buildings that are deteriorated in the area as a whole. Sidewalks, parking and other public improvements must be listed. The table must also include vacancy rates and the level of disinvestments, which has contributed to the deterioration of the area.
Rating criteria for buildings and public improvements
For buildings and infrastructure, the community must utilize EOHLC’s rating scale for measuring physical conditions in the slum/blight area. Communities must also use EOHLC’s Property Rating Sheet and Infrastructure Rating Sheet found in Appendix K of this guidance.
If you are qualifying a building or improvement using the criteria other than “physical deterioration” please provide information or appropriate documentation that meets the definition. This should be explained on the property rating sheet.
Rating Criteria definitions:
Excellent: Buildings that require little or no exterior work.
Buildings that are in excellent condition may be of any age or style. They demonstrate consistent, planned maintenance and repair, components appear to be code-compliant and energy efficient.
Public Improvements: Infrastructure is newer and/or improved and updated to meet current need and demand, is compliant with all applicable codes and requirements, and has no visual or physical evidence of deterioration or needed repair.
Good: Buildings that have cosmetic deficiencies or other early signs of aging and wear.
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Building components appear to meet code, but energy efficiency improvements such as storm doors and windows and caulking may be needed. Decorative features may need to be secured, but items are in place. Materials do not need replacement but do need some minor maintenance and repair. For example, roofs may be of older composition, but not yet deteriorated or leaking; siding may need spot painting or other “touch-up”; foundations and chimneys appear structurally sound but may show beginning signs of voids or loose mortar joints.
Public Improvements: Infrastructure such as streets and sidewalks show minor cracks, unevenness and patching. No visible or known evidence of deficiencies with water, sewer, or drainage systems.
Fair: A determination of fair for a building component means that the extent of defective conditions or deficiencies applies to at least 25% of the component.
Buildings with this designation show clear signs of deterioration indicative of a property that has not been maintained for 5 to 10 years. Some building components may be nearing the end of their serviceable life. Small wood and metal trim pieces of buildings may be lifting away from primary surfaces. At least 25% of roofing and related surfaces, including roofline, trim, flashing, and chimneys may be brittle, curled, cracked, and missing, with overall signs of aging, and exhibit levels of deterioration specific to this category. At least 25% of doors and windows may be old and worn, loose, ill-fitting, drafty, and otherwise energy inefficient and may have peeling paint or deteriorating vinyl or other surfaces. Exterior walls have at least 25% of surfaces with missing, broken or otherwise deteriorated siding, painted surfaces in progressed state of peeling, or brick surfaces needing repointing. At least 25% of porches, stairs, and decking show early signs of deterioration including worn, cracked, and warped components affecting components such as treads, balusters, rails, jousts, and support posts.
Foundations have cracks and voids over at least 25% of surface area. Storefronts and signage are aging, with architectural features that may have been covered with sheet metal, asbestos, asphalt, or other materials from renovations of earlier decades. These covering materials, as well as any exposed original surfaces, are now showing signs of deterioration over at least 25% of their surfaces.
Public Improvements: Infrastructure, including parks, playgrounds, and parking facilities, is older and needs regular maintenance and repair. Streets and sidewalks are cracked, uneven, patched, and not conducive to convenient pedestrian and or vehicular travel. Slow drainage causes some ponding to occur during heavy rains.
Poor: A determination of poor for a building component means that the extent of defective conditions or deficiencies applies to at least 50% of the component.
This category includes buildings that appear not to have been maintained for at least 10 years and have components which are beyond the end of their useful life. Exterior trim is missing altogether. One or more major building systems may be in danger of failure. The roof may be sagging with areas of extensive wear, exposed sheathing, and evidence of leaks over at least 50% of surfaces. Roofline trim, flashing, and chimneys exhibit levels of deterioration specific to this category. At least 50% of doors and windows may be rotted, broken, missing, and/or boarded up, with peeling paint or deteriorating vinyl or other surfaces. Exterior walls have at least 50% of surfaces with missing, broken, or otherwise
Application Guidance - Page 17 deteriorated siding; painted surfaces rotted or in advanced state of peeling paint or brick or other masonry surfaces needing repair or repointing. At least 50% of porches, stairs, and decking exhibit hazardous and unsafe conditions including sagging, rotted, and missing components, and separation from the main structure. Foundations are extensively cracked with missing stone or masonry over at least 50% of areas; indications of structural instability, and may require replacement and shoring up, including sill work. Storefronts and signage are nearing end of useful life with original or old replacement materials which are extensively deteriorated over at least 50% of their surfaces.
Public Improvements: Infrastructure, including parks, playgrounds, and parking facilities, show advanced stages of…
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