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HomeMy WebLinkAbout2027 CDBG Policy Plankit City of Bremerton Community Development Block Grant 2027 CDBG/HOME POLICY PLAN CDBG/HOME POLICY PLAN Contents Executive Summary ........................................................................................... 1 Community Development Block Grant Program ............................................. 2 CDBG Funding ................................................................................................... 3 HOME Funding ................................................................................................... 7 Allocation Process ............................................................................................. 9 Policies & Regulations for Use of Funds ....................................................... 10 Citizen Participation Plan ................................................................................ 17 Consolidated Plan ............................................................................................ 17 Appendix A – Citizen Participation Plan Appendix B- Funding Process Appendix C – CDBG Eligibility Requirements & Program Rules Appendix D - HOME Eligibility Requirements & Program Rules Appendix E – Conflict of Interest Policy Appendix F – Glossary CDBG/HOME Policy Plan 2027 1 The 2027 City of Bremerton CDBG/HOME Policy Plan provides guidance for applicants applying for 2027 funds on things such as eligibility, overview of the funding allocation process, regulatory requirements, and local policy decisions. The allocation of CDBG and HOME funds are guided by the Strategic Plan which is a part of the Consolidated Plan. Kitsap County and the City of Bremerton have prepared a Consolidated Plan for 2026-2030 in order to implement our community’s federal program funds. The purpose of the plan is to evaluate community needs and set goals for the five year plan period. Through a Community Needs Assessment, Housing Market Analysis and with community and stakeholder input, the City of Bremerton has developed a Strategic Plan. The City of Bremerton’s Strategic Plan outlines the priorities and goals which guide the allocation of funds over the five year period. The funds allocated for the 2027 grant application cycle will be included in the Year 2, Action Plan associated with the 2026-2030 Consolidated Plan. Funding amounts will be determined by strength of the application, project readiness, location and need for the type of housing being proposed: The priorities identified for the five-year period are as follows: Priorities The City will continue to fund CDBG Capital/Economic Development projects: • Preservation and/or rehabilitation of affordable housing including o Acquisition of housing to create or preserve units of affordable housing o Weatherization/repair of existing housing units • Infrastructure and public facilities projects including: o Street and Sidewalk improvements in low-income neighborhoods o Parks projects/facilities in low-income areas • Microenterprise Assistance Programs HOME Housing priorities are of equal importance. • Construction or acquisition of new rental housing units • Acquisition of homeowner housing through down-payment assistance Executive Summary CDBG/HOME Policy Plan 2027 2 Policy Changes for 2027: 1. Updated funding priority language to match Consolidated Plan priorities for 2026-2030. These priorities were adopted by City Council in November of 2025. • The City of Bremerton HOME Funding priority is to increase affordable housing stock. • The CDBG NOFA will be for, housing rehabilitation, economic development microenterprise assistance, and public facilities and infrastructure that meet the priorities outlined above and contained in the Consolidated Plan. 2. New applicants are required to meet with staff to discuss their projects. All capital projects will be asked to meet with Block Grant Staff to discuss project eligibility and federal requirements prior to applying. Technical assistance is available for all applicants by appointment. Information has been posted to the City’s website in addition to the Coordinated Grant Application website and included in the CDBG NOFA. CDBG/HOME Policy Plan 2027 3 WHAT IS THE COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM? The Community Development Block Grant Program is a source of funds used in the local community to provide decent housing, suitable living environments and economic opportunities primarily for low and moderate income households. The City of Bremerton is designated as an Entitlement Community by the Department of Housing and Urban Development (HUD) and receives federal funds in the form of Community Development Block Grant (CDBG). Kitsap County and the City of Bremerton together form a consortium and receive an allocation of HOME Investment Partnership Program (HOME) funds. Through an interlocal agreement between the County and the City a percentage (as determined by HUD) of the annual allocation of HOME funds is designated for the City and the remaining designated for the County. As the City of Bremerton is designated as a separate Entitlement Community and therefore the City receives its own CDBG funds directly. CDBG funds are allocated annually through the City in Requests for Funding Proposals. HOME funds are allocated annually through a competitive grant process coordinated by Kitsap County. Projects funded are included in the annual Action Plan submitted to HUD. Projects funded must address needs identified in the Consolidated Plan, which is updated every five years. COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM CDBG/HOME Policy Plan 2027 4 WHAT ARE CDBG FUNDS? The Community Development Block Grant (CDBG) program is a flexible program that provides communities with funding to address a wide range of unique community development needs. The program is authorized by Title I of the Community Development Act of 1974. Funds are used to assist in the development of decent housing, create suitable living environments, and expand economic opportunities primarily for persons of low and moderate income. All projects funded with CDBG must meet one of the three national objectives: 1. Principally benefit low and very low income households; 2. Reduce or prevent slum and blight; or, 3. Meet an urgent need (emergency or natural disaster) See Appendix C for more details. WHO IS AN ELIGIBLE APPLICANT/RECIPIENT? Eligible applicant/recipients include: • City or County governments • Public and private nonprofit organizations (501(c)3) • Section 301(d) small business investment companies • Local development corporations • Private for-profit organizations may implement certain capital, economic development and microenterprise activities (please contact the Block Grant Administrator to confirm if your activity is eligible). • Faith based organizations (restrictions may apply to ensure equal employment opportunity) • Additionally, applicants must: • Demonstrate an active governing body or board of directors or other applicable leadership within your organization with skills and experience to provide leadership and direction to the agency. • Demonstrate the legal, financial, and programmatic ability to administer the proposed program/project; and, • Meet the City requirements for contracting agencies such as insurance requirements, audit and financial requirements. CDBG FUNDS CDBG/HOME Policy Plan 2027 5 WHAT ARE ELIGIBLE ACTIVITIES? Eligible activities are defined in the CDBG program regulations at 24 CFR 570.201 and 570.207 and included in the list below. For the 2026-2030 plan period funds are prioritized for certain activities so not all eligible activities will be funded. Please see the Executive Summary of this document for priorities and specific eligible activities for 2027 funding: • Acquisition of real property by purchase, lease, or donation • Acquisition, construction, reconstruction, rehabilitation or installation of public facilities and improvements • Housing Rehabilitation • Code enforcement in deteriorated or deteriorating areas • Clearance, demolition and removal and rehabilitation of buildings and improvements • Removal of material and architectural barriers • Public services • Planning activities • Assistance to Community Based Development Organizations (CBDO) to carry out projects • Assistance to microenterprise businesses and economic development projects as defined under 24 CFR Part 570, Subpart C • Housing services such as housing counseling and energy auditing • Assistance to facilitate and expand homeownership opportunities for low and very low- income people • Lead based paint hazard evaluation and reduction The following activities are generally not eligible for CDBG funding: • New residential housing construction, except in special circumstances • Regular government operations • Buildings such as city halls, police stations, or other buildings primarily for the general conduct of government (except for the removal of architectural barriers) • Income payments such as payments to individuals or families for food, clothing, or rent, except in certain circumstances • Political activities • Vehicles and Equipment Appendix B provides additional information designed to assist you in defining the eligibility and national objective that your activity meets and the type of information you will need to provide in your application. CDBG/HOME Policy Plan 2027 6 FUNDING PRIORITIES All Projects MUST meet one of the following Consolidated Plan funding priorities: • Preservation and/or rehabilitation of affordable housing including o Acquisition of housing to create or preserve units of affordable housing o Weatherization/repair of existing housing units • Infrastructure and public facilities projects including: o Street and Sidewalk improvements in low-income neighborhoods o Parks projects/facilities in low-income areas • Microenterprise Assistance Programs HOW MUCH MONEY IS AVAILABLE? CDBG programs are federally funded through the Department of Housing and Urban Development. Funding levels are determined by HUD after the Federal Budget is finalized, which often occurs after the program year has begun. The City of Bremerton estimates funding levels in order to start the grant application process; therefore, funding amounts shown in the table below are estimates. If HUD allocates a different amount to these programs than what was estimated, actual funding awards will be increased or decreased to accommodate the discrepancy. The estimated funds below are based on 2026 allocations and historic funding trends. The following table (on next page) shows an overall view of the total estimated amount of funds available in this application cycle by the application type and funding sources. Please note that the City of Bremerton is basing this estimate on an amount of $375,000. There is no designated amount for application type, applicants are encouraged to apply for the amount of funding they need to complete a project. Please note that projects with multiple sources of funding will be more competitive than projects that are utilizing CDBG as their only funding source. CDBG/HOME Policy Plan 2027 7 WHAT IS THE DISTRIBUTION OF CDBG FUNDS? The CDBG program allows certain set-asides to further specific program goals. The City has set additional funding targets to help meet local objectives. The following is the distribution for the City of Bremerton: CDBG •Planning & Administration – 20% max •City-Wide Economic Development and Capital projects consistent with the 5 year funding priorities Appendix C provides additional information designed to assist you in defining the eligibility and national objective that your activity meets and the type of information you will need to provide in your application. Estimated Entitlement $ (375,000.00) Estimated Program Income $ (1,000.00) Estimated Prior Year Funding (capital projects) $ (25,192.00) TOTAL $ (401,192.00) Funding Available for Grant Administration $ 75,200.00 (20% of Entitlement + Program Income) = Estimated Funding Available for Grant Applications $ (325,992.00) *Review Executive Summary above for details on funding priorities for capital projects CDBG/HOME Policy Plan 2027 8 WHAT ARE HOME FUNDS? The HOME Program was created by the National Affordable Housing Act of 1990 (NAHA). The Housing and Community Development Act of 1992 and the Multifamily Property Disposition Act of 1994 made important changes to the Program. The intent of the HOME Program is to:  Expand the supply of decent, safe, sanitary, and affordable housing; • Strengthen the abilities of state and local governments to provide housing; • Expand the capacity of nonprofit community based housing development organizations; and, • Leverage private sector participation in financing affordable housing. Beneficiaries of HOME funds – homebuyers, homeowners, or tenants – must have incomes below 80% of the area median income. The HOME program also requires a match of 25% or greater in other non-federal funds for projects. WHAT ARE ELIGIBLE ACTIVITIES? The Eligible activities are defined in the HOME program regulations at 24 CFR 92.205. A list of some of the activities follows: • Rehabilitation of residential property where property is fully repaired • New construction of residential property • Acquisition of residential property • Rental assistance payments to tenants • Relocation associated with an eligible HOME project • A small part (up to 5%) of the annual HOME allocation may be used to help pay the operating expenses of designated Community Housing Development Organizations (CHDOs) within the guidelines established by HUD The following activities are generally not eligible for HOME funding: • Project reserve accounts, except for the initial 18 months of a HOME assisted new construction project • Emergency home repair programs • Public housing units • Commercial properties • Shelters, unless they meet Section 8 Housing Quality Standards and otherwise can be considered rental housing • Project based tenant assistance Note: The above lists are not comprehensive. For a complete list of eligible or ineligible activities refer to HOME regulations in 24 CFR 92.205 HOME FUNDS CDBG/HOME Policy Plan 2027 9 What are the HOME priorities for the City of Bremerton? • Construction or acquisition of new rental housing units • Acquisition of homeowner housing through down-payment assistance • HOW MUCH MONEY IS AVAILABLE? Priorities: Projects which create or support affordable housing Rental projects must serve households at or below 80% AMI. HOME assisted units must serve households at or below 60% AMI, with 20% serving at or below 50% AMI. HOME funds will be allocated via a separate process than CDBG funds. This process will be in coordination with Kitsap County of whom the City of Bremerton participates as a part of the Kitsap County HOME Consortium, however, the City will determine any prioritization of its own percentage of HOME funds. CDBG/HOME Policy Plan 2027 10 HOW ARE FUNDS ALLOCATED? The City of Bremerton, as a member of the Kitsap County HOME consortium will issue a joint RFP for use of City HOME funds. The RFP, issued jointly with the City of Bremerton, will be for HOME funded affordable housing and include both County and City HOME funds. Homebuyer assistance will be a lower priority and funding for new construction of homeowner housing will not be available. City of Bremerton HOME funds will be prioritized for rental and homeowner projects including acquisition, new construction, rehabilitation and homebuyer assistance. The City independent from the County will create a Competitive Funding Application for CDBG funds based on its priorities for use of funds which is separate from the process used for HOME funds. Funding proposal will be made available for public review and comment in late August/ early September. This process is detailed in the Citizen Participation Plan (Appendix A). The public is encouraged to participate in the process and its end product: the submission of an annual Action Plan to the Department of Housing and Urban Development. Additional policies and procedures for HOME funds can be found in the Kitsap County Community Development Block Grant and Kitsap HOME Consortium 2027 CDBG/HOME Policy Plan. HOW CAN MY ORGANIZATION APPLY? The annual application cycle begins in early spring with the posting of the City CDBG Calendar on the City’s Federal Grants web site and publication of the CDBG/Home Policy Plan. The Policy Plan is released for a 15 day public comment period on May 1st. The 2027 Policy Plan will go before City Council for a public hearing June 3rd. New applicants must submit an Applicant Intent Form. Capital projects will be asked to meet with Block Grant Staff to discuss project eligibility and federal requirements prior to applying. Technical assistance is available for all applicants by appointment. Interested organizations can find the funding application and all associated information on the City web site at https://www.bremertonwa.gov/198/Federal-Grants---CDBG. The schedule for the annual application cycle, including the due date for applications, is also available on the web site. Interested organizations may also contact Block Grant staff to request to be placed on the City interested parties list to receive automatic notices about these programs. WHEN WILL FUNDS BE AVAILABLE? Funds for the programs taking place in the January 1 – December 31 program year are generally not available until mid-summer of the program year. Timing is dependent on federal budget approval—which is often delayed—and how quickly HUD is then able to allocate funds to local jurisdictions. The City will not execute contracts with subrecipients until we have a contract from HUD. Once contracts are executed CDBG and HOME funds can only be disbursed on a reimbursement basis. ALLOCATION PROCESS CDBG/HOME Policy Plan 2027 11 CDBG and HOME funds are Federal funds. Use of Federal funds may affect the way your agency does business. If you are applying for Federal funds for the first time, you are strongly encouraged to familiarize yourself with the requirements. A Guidebook for recipients of CDBG and HOME funds can be found on the City web site at: http://www.bremertonwa.gov/213/Subrecipient-CDBG-HOME-Guidebook. You may also contact the City Block Grant Staff for additional assistance. A. GENERAL REQUIREMENTS 1. Consistency with applicable City, County, and/or State Codes and Policies To be considered for funding, projects must be consistent with adopted codes and other applicable policies, plans and standards. Agencies that are currently receiving County or City CDBG or HOME funds, who are applying for funds, must be in compliance with all terms of their current agreement(s) and must not have outstanding audit findings, monitoring findings or concerns related to prior year’s funding. 2. Contract Retainage for Federal Compliance City will withhold up to 10% of the award amount included in the written subrecipient agreement until all federal compliance requirements are met. All construction contracts between a subrecipient (i.e.: your agency) and contractor shall have 10% of payment retained until fulfillment of federal compliance is documented. 3. Definition of Income Most CDBG and HOME funded projects use income to determine who is eligible for services or housing. Per HUD, income must be defined in one of two ways under the CDBG and HOME programs; subrecipients must select one method which it will use for the duration of each program/project (rental housing projects must use the Part 5 definition): a. Annual income as defined in 24 CFR 5.609, referred to as “Part 5 annual income”, or; b. Adjusted gross income as defined for reporting purposes under the IRS Form 1040 long form (not IRS Forms 1040A or 1040EZ). For more information on determining income see the Technical Guide for Determining Income and Allowances for these programs. This guide and can be downloaded from: http://archives.hud.gov/offices/cpd/affordablehousing/modelguides/1780.pdf 4. Project/Activity Delivery Costs The City does not currently take project/activity delivery costs. 100% of funds will go to each project that is awarded funds. 5. Commitment and Timely Expenditure of Funds In order to meet regulatory requirements the City and County have established the following policies for CDBG and HOME funded projects: POLICIES & REGULATIONS FOR USE OF FUNDS CDBG/HOME Policy Plan 2027 12 a. CDBG: o Public Service Contracts: Organizations awarded CDBG funds for public service or micro enterprise programs must be ready to enter into a written agreement with the City during the award year and funds must be fully disbursed by Dec. 31st of that same year. o Capital Awards: i. Organizations with an award of CDBG funds for a capital project must enter into written agreement (contract) in the award year.  If there are extenuating circumstances beyond the organizations control and adequate progress is being made to resolve the issues, an additional year for execution of the written agreement will be granted to the organization. ii. The project must begin drawing grant funds within one year of the contract execution date. iii. The project must be completed within 2 years of the contract execution date and meet milestones included in the written agreement, including the schedule for completion. iv. The Agreement will not be amended to extend the term. Organizations unable to meet these requirements will lose their funding; funds will be reallocated to another eligible project.  The contract term may be considered for extension if there are extenuating circumstances beyond the organizations control and adequate progress is being made. v. In no circumstance can a project take more than 5 years to complete. b. HOME: o HOME regulations require commitment of funds within 24 months. Due to this requirement City of Bremerton and Kitsap County (who is the contracting agency) requires the project HOME funds be ready to commit no later than 18 months from HUD’s Funding Agreement execution date. If after 18 months all project funding has not been secured, the conditional commitment will be canceled and the funds will be reallocated. Staff will work with agencies during this time period to ensure the project is moving forward and can meet the timeline. o Organizations awarded HOME funds must have all other funding sources committed (documented with letters of commitment) and all HOME requirements for environmental review and project underwriting completed before funds can be committed. Commitment is defined as having a fully executed written agreement with Kitsap County (the contracting agency for City HOME funds) and funds committed in HUD’s Integrated Disbursement Information System (IDIS). o A conditional commitment of funds will be made for projects that do not have all project funds committed at the time of the funding recommendation. o HOME funds require project completion no later than four years from CDBG/HOME Policy Plan 2027 13 HUD’s Funding Agreement execution date. Projects using HOME funds to acquire vacant land must be under construction within 12 months of the commitment date. o Organizations must begin drawing funds within one year of the contract execution date (date the contract was executed) and at least annually thereafter. o Organizations unable to meet these requirements will lose their funding; funds will be reallocated to another eligible project. o Rental properties will be required to be leased up within six (6) months of project completion. Homeowner properties will be required to be sold within nine (9) months of project completion. For additional expenditure criteria and deadlines for use of 2027 (And any prior years CHDO’s will be found in the Affordable Housing RFP for use of City of Bremerton HOME funds). 6. On-going Restrictions for CDBG & HOME Funded Capital Projects Recipient of CDBG funds must agree to restrict the use of the property, which was acquired and/or improved using CDBG funds, to the intended purpose for which the funds were awarded. Projects awarded HOME funds are subject to an affordability period which places certain restrictions on occupancy, resale, and rent for rental properties. The City may require a recorded document to be attached to the property to ensure the appropriate provisions are secured. See Appendix C for CDBG eligibility requirements. B. HOME FUNDING - SPECIFIC REQUIREMENTS 1. For more information on specific rules and requirements of the HOME program, including determining whether your project is eligible, please see Appendix D. C. CDBG FUNDING - SPECIFIC REQUIREMENTS 1. For more information on specific rules and requirements of CDBG, including meeting a National Objective, please see Appendix C CDBG Eligibility & Program Requirements. D. FINANCIAL MANAGEMENT 1. Uniform Administrative Requirements Agencies must comply with 2 CFR 200 Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards. Agencies that do not meet the audit threshold for mandatory audits are encouraged to obtain an annual audit if their operating budget is $100,000 or greater. Smaller agencies are encouraged to obtain at least a third-party annual financial review. Block Grant Staff will review financial information closely for all agencies submitting application. CDBG/HOME Policy Plan 2027 14 2. Audit Requirements Private non-profit agencies expending $750,000 or more in federal funds annually (whether CDBG / HOME alone or CDBG / HOME in conjunction with other federal funds) must have an annual audit conducted by an independent auditor in accordance with OMB Circular A-133 Compliance Supplement. Agencies are responsible to meet this audit requirement. Agencies that do not meet the $750,000 threshold mandatory A-133 audit are encouraged to obtain an annual audit if their operating budget is $100,000 or greater. Smaller agencies are encouraged to obtain at least a third-party annual financial review. Block Grant staff will review financial information closely for all agencies submitting application. E. PROCUREMENT Any subrecipient using CDBG or HOME funds to purchase goods or services must have a formalized written procurement procedure in place prior to contracting for any goods or services. Procurement requirements are contained in 2 CFR Part 200. Additional information on procurement requirements can be found in Section E of the CDBG/HOME Guidebook on the City of Bremerton Block Grant Program Website. Build America Buy America Act Organizations awarded CDBG funds that include rehabilitation or construction work will be subject to the requirements of the Build America Buy America Act (BABA) if the following conditions are met: • Project contains iron and steel, and • The total federal (CDBG & any other federal funds) is $250,000 or greater. The Act requires all iron and steel used in the project be produced in the United States. This means all manufacturing processes, from the initial melting stage through the application of coatings, occurred in the United States. F. ENVIRONMENTAL REVIEW 1. Environmental Review (24 CFR Part 58) All CDBG/HOME projects must have a National Environmental Policy Act (NEPA) compliant environmental review process completed before any funds, including funds committed from other sources, can be spent on the project. Additional information on environmental review requirements can be found in Section F of the CDBG/HOME Guidebook on the City of Bremerton Block Grant Program web sites. The costs associated with conducting a NEPA compliant environmental review for Capital CDBG and HOME funded projects may be charged to the grant award as project costs (HOME) or activity delivery costs (CDBG). Cost will vary depending on the level of review and complexity of the project and include staff time, cost of publishing required legal ads and printing costs. CDBG/HOME Policy Plan 2027 15 The cost of any studies required to complete the environmental review (i.e. Phase I Environmental Site Assessment, Geotechnical. Report, Cultural Site Assessment, etc.) will be in addition to the costs associated with preparation of the NEPA environmental review and will be the responsibility of the subrecipient. G. EQUAL OPPORTUNITY & ACCESSIBILITY 1. Fair Housing and Equal Opportunity All CDBG/HOME projects must comply with all of the following Federal laws, executive orders and regulations pertaining to fair housing and equal opportunity: a. Title VI of the Civil Rights Act of 1964: No person may be excluded from participation in, denied the benefits of, or subjected to discrimination under any program or activity receiving Federal assistance on the basis of race, color or national origin (24 CFR Part 1). b. The Fair Housing Act: Prohibits discrimination in the sale or rental of housing, the financing of housing or the provision of brokerage services against any person on the basis of race, color, religion, sex, national origin, handicap or familial status (24 CFR Part 100-115). c. Equal Opportunity in Housing: Prohibits discrimination against individuals on the basis of race, color, religion, sex or national origin in the sale, rental, leasing or other disposition of residential property, or in the use or occupancy of housing assisted with Federal funds (24 CFR Part 107). d. Age Discrimination Act of 1975: Prohibits age discrimination in programs receiving Federal financial assistance (24 CFR Part 146). e. For more information on eliminating discrimination visit www.hud.gov/offices/fheo/progdesc/title8.cfm 2. Handicapped Accessibility CDBG and HOME funded projects are subject to the following regulations governing the accessibility of Federally-assisted buildings, facilities and programs. a. Americans with Disabilities Act: Provides comprehensive civil rights to individuals with disabilities in the areas of employment, public accommodations, state and local government services and telecommunications. The Act requires certain buildings or other facilities that receive Federal funds to be designed, constructed or altered in accordance with standards that insure accessibility to and use by physically handicapped people. b. Section 504: Section 504 of the Rehabilitation Act of 1973 prohibits discrimination in federally assisted programs on the basis of handicap. Additional information on equal opportunity and accessibility can be found in Section G of the CDBG/HOME Guidebook on the City of Bremerton Block Grant Program web sites. CDBG/HOME Policy Plan 2027 16 H. LABOR STANDARDS & CONSTRUCTION 1. Equal Opportunity for Employment and Contracting CDBG and HOME funded projects are subject to the following regulations governing employment and contracting opportunities. a. Equal Employment Opportunity: Prohibits discrimination against any employee or applicant for employment because of race, color, religion, sex or national origin. Provisions to effectuate this prohibition must be included in all construction contracts exceeding $10,000 (41 CFR Part 60). b. Section 3 of the Housing and Urban Development Act of 1968: Requires that, to the greatest extent feasible, opportunities for training and employment arising from CDBG or HOME funded projects will be provided to low-income persons residing in the program service area. c. Minority/Women’s Business Enterprise: Outreach to minorities and women in contracting for services (24 CFR 85.36(e)). 2. Labor Requirements CDBG and HOME projects must comply with certain regulations on wage and labor standards. Pursuant to the Davis-Bacon Act, federal wage rates apply to most (but not all) construction projects over $2,000. Applications that involve construction must consider Davis-Bacon wage rates in the budget. The costs associated with the review of Certified Payrolls and compliance with DBRA requirements may be charged to the grant award as project costs (HOME) or activity delivery costs (CDBG). Cost will vary depending on the complexity of the project. a. Davis-Bacon and Related Acts: Ensures that mechanics and laborers employed in construction work under federally assisted contracts are paid the Federal prevailing wage for the locality. b. Contract Work Hours and Safety Standards Act: Provides that mechanics and laborers employed on federally assisted construction jobs are paid time and one-half for work in excess of 40 hours per week. c. Copeland (Anti-Kickback) Act: Governs the deductions from paychecks that are allowable. More information on Davis Bacon requirements can be found in Section I of the CDBG/HOME Guidebook City of Bremerton Block Grant Program web site. 3. Lead-Based Paint Hazard (24 CFR Part 35) Housing built before 1978, assisted with HOME or CDBG funds, is subject to the Lead Based Paint Poisoning Prevention Act. The law imposes requirements related to: • Disclosure of known hazards and what has been done to reduce them; • Treatment, relocation during treatment, and ongoing inspection of units. Project feasibility is an important consideration for housing with lead-based paint. Recipients of CDBG or HOME funds will need to be aware of the potential for additional time and cost associated with lead-based paint hazards. Information on Lead-Based Paint requirements can be found in Section I of the CDBG/HOME Guidebook on the City of Bremerton Block Grant Program web site. CDBG/HOME Policy Plan 2027 17 4. Compliance with Codes & Standards for Rehabilitation and New Construction a. All capital projects funded with CDBG or HOME must comply with local building and fire codes. b. All HOME funded Rehabilitation projects must comply with the Rehabilitation Standards adopted by the City of Bremerton Block Grant Program. c. All rental housing units purchased and/or rehabilitated with CDBG or HOME must pass a Uniform Physical Conditions Standards inspection. d. All housing must comply with the applicable accessibility requirements for persons with disabilities. I. REPORTING & MONITORING All programs and projects funded with CDBG or HOME funds will be required to submit quarterly reports. Reports will be provided by the Block Grant Program and may be submitted electronically. Annual on-site monitoring is conducted by staff for all open contracts. A monitoring checklist is used by staff to review compliance with the requirements of the written agreement and federal regulations. Agencies will be contacted at the end of the program year to schedule the monitoring visit. J. ACQUISITION & RELOCATION 1. Uniform Relocation Assistance & Real Property Acquisition (49 CFR Part 24) These regulations apply to any federally-assisted project involving acquisition, demolition or rehabilitation. Proposals for CDBG and HOME funded projects that are likely to cause displacement of people or businesses are discouraged. Any project that is likely to cause displacement must include relocation assistance payments in the budget and be consistent with the Federal Uniform Relocation Act. Projects which trigger this regulation must follow the Anti-displacement and Relocation Assistance Plan which can be provided to you by request. If your project includes acquisition, rehabilitation or demolition you are strongly urged to discuss the requirements with Block Grant staff before entering into any legally binding agreements. 2. Minimizing the Loss of Low and Very Low Income Dwelling Units (24 CFR Part 42) Any CDBG/HOME proposal that would directly result in any occupied or vacant occupiable low and very low income dwelling units being (1) demolished, or (2) converted to a use other than as low and very low income housing must include a realistic plan to provide replacement housing within three years of the commencement of the demolition or rehabilitation relating to conversion. Projects which trigger this regulation must follow the Anti-displacement and Relocation Assistance Plan which can be accessed by making a request to City Block Grant staff. CDBG/HOME Policy Plan 2027 18 CONSOLIDATED PLAN HUD requires a Citizen Participation Plan be adopted by jurisdictions receiving CDBG and HOME funds. The plan details the process used by the City in development of the Consolidated Plan and annual application cycle which results in the Action Plan submission to HUD. The City of Bremerton Block Grant Program Citizen Participation Plan can be found in Appendix A. WHAT IS THE CONSOLIDATED PLAN? The Consolidated Plan rolls the planning, application and performance reporting requirements of several programs run by HUD into one process and one document. In our community the Consolidated Plan covers CDBG (Community Development Block Grants) and HOME (grant for affordable housing) programs jointly for the City of Bremerton and Kitsap County. The plan covers a 5-year period submittal of the 2027 action plan will be for year one. The Consolidated Plan requires a jurisdiction to identify all of its housing and community development needs, and then develop a long-term strategy for meeting those needs. A key part of the strategy is setting priorities. The Plan identifies priority housing needs, non-homeless special needs, homeless needs, economic development and community development needs. The Consolidated Plan also indicates what programs and resources will be used over the 5-year planning period. The plan contains objectives and strategies to address the identified needs and estimates the resources needed to fund activities to address the different needs. WHAT ARE THE KEY PARTS OF THE PLAN? A. Housing & Community Development Needs Assessment This is the part of the Plan that has U.S. Census Bureau information and other information which presents a picture of the jurisdiction. People are the focus of the “Needs” section of the plan. The emphasis is on the human side of housing and community development including the needs of homeless people, people with special needs and those who are low-income. B. The Housing Market Analysis This part of the Plan describes the physical “bricks and mortar,” side of housing – the supply side of housing. It looks at what housing exists. When the housing conditions in this part of the plan are lined up with human needs in the previous part of the plan, a clear picture of what must be done should emerge. C. The Strategic Plan The Strategy is the part of the Consolidated Plan where the County and City sets out how it intends to use its CDBG and HOME funds from HUD’s Department of Community Planning and Development over the next five years. The strategy must declare what priority the local government will give to the various housing and community development needs identified earlier in the Consolidated Plan; the activities designed to respond to those needs; and the different geographic areas where needs exist. CITIZEN PARTICIPATION PLAN CDBG/HOME Policy Plan 2027 19 GLOSSARY D. Annual Action Plan The Action Plan is the one-year plan a jurisdiction must have to show how it is carrying out its long-term Strategic Plan. It shows how the jurisdiction will spend its CDBG and HOME money in the upcoming year. The City of Bremerton use an annual application process through which funds are competitively awarded. Note: The full text of the Consolidated Plan is available on the City of Bremerton web sites and also available upon request. A Glossary of terms has been included in Appendix F. Appendix A 0 Appendix A Citizen Participation Plan (Updated 5/1/26) Appendix A 1 CITY OF BREMERTON CITIZEN PARTICIPATION PLAN Introduction The City of Bremerton receives both Community Development Block Grant (CDBG) and HOME Investment Partnership (HOME) funds. The City receives its own CDBG funds as an entitlement, and HOME funds through its membership in a Consortium with Kitsap County. The City of Bremerton is committed to assuring opportunities for citizen involvement in decisions concerning activities taking place within the community. Each year the City of Bremerton is eligible to receive CDBG and HOME funds. There are specific rules and regulations governing the allocation and use of the funds, including provisions for citizen involvement in decision making. In order to facilitate citizen involvement, the City has adopted a Citizen Participation Plan. Purpose The purpose of the Citizen Participation Plan is to provide an on-going mechanism to ensure widespread citizen participation whereby all citizens have an opportunity to fully express their needs and wishes for community improvement. Special efforts will be made to encourage participation by: • Low- and moderate-income persons • Residents of predominately low- and moderate-income neighborhoods. • Minorities and non-English speaking persons, as well as persons with disabilities. This plan provides opportunities for representation of all of the citizens of the City of Bremerton by allowing them to have a voice in the decision-making process and giving them greater power and control over activities taking place within their community. Annual Allocation Process / Action Plan Submission The City of Bremerton as an entitlement jurisdiction will conduct a competitive annual process to determine allocation of CDBG and HOME funds. The public is encouraged to participate in the process and its end product—the submission of an annual Action Plan to HUD. A. Notice of Funding Availability & Application Annually generally in the spring or early summer a legal ad will be published in the newspaper of record to announce funding availability and provide an opportunity for comment on the CDBG/HOME Policy Plan. This notice will begin a 15-day comment period on the Policy Plan (including the Citizen Participation Plan) and include the date and time of public hearings to take citizen comments. Appendix A 2 Notifications will also be sent to any agency or organization who requests to be placed on our interested parties email list. Upon approval of the Policy Plan by the Bremerton City Council, information about the Request for Funding Proposals and mandatory technical assistance session for first time applicants will be available by request in writing to: City of Bremerton, Community Development Block Grant 345 6th Street, Suite 100, Bremerton, WA 98337-1873 http://www.bremertonwa.gov/209/Consolidated-Planning or by contacting CDBG Staff by email at: CDBG@bremertonwa.gov or by phone at: 360-473-5375 B. Pre-Application Procedures Prospective applicants are asked to contact City CDBG Staff to discuss potential projects. Staff will meet with applicants to discuss eligibility and feasibility. Even if your organization is not certain they will apply in this funding round, you are encouraged to reach out. To request an appointment, applicants please reach out to Block Grant Staff. Staff is also available by appointment for one-on-one technical assistance to provide guidance to citizens and organizations regarding specific project considerations. C. Technical Assistance Technical assistance information for potential applicants for funding will be found in Appendix B. At any time, any citizen may contact the City Block Grant staff for technical assistance, help with an application or general information in relation to programs described in this Plan. The Department will help citizens understand CDBG and HOME funded programs, the procedures for submitting proposals, the Citizen Participation Plan and other program requirements so they can effectively participate in CDBG and/or HOME programs and the funding process. D. Funding Recommendations & Action Plan Organizations submitting applications will be notified whether or not the Project Review Committee (PRC) has recommended their proposal for funding. The City Council will consider the staff recommendation, will hold a public hearing on the proposal, will take public testimony and will adopt the funding package. Notifications will include the date, time and place of the public hearings. Appendix A 3 All projects approved for funding will be included in the City’s Action Plan. A summary of each Action Plan will be published in the newspaper of record and on the City’s website. The summaries will describe the contents and purpose of the Action Plans, and include a list of locations where copies of the entire proposed plans may be examined. Citizens will be provided a period of 30 days to review and comment on the plans. Comments or views of citizens will be considered, and a summary of any comments or views not accepted and the reasons therefore, will be attached to the final Action Plan which will be submitted to HUD. The City of Bremerton will submit the Action Plan, including the projects proposed to be funded, to HUD no later than November 15th of each calendar year, unless HUD instructs the City not to submit until an appropriations bill has been enacted and HUD has notified the City of Bremerton of our actual allocation amounts. Five Year Consolidated Plan The Consolidated Plan is the result of a process set forth by the Department of Housing and Urban Development (HUD) to provide a planning and application process for the CDBG and HOME programs within a single document. The Kitsap County HOME Consortium is required to submit the Consolidated Plan for the HOME participating jurisdiction (which consists of Kitsap County and the City of Bremerton). The Consolidated Plan is available online at:  http://www.bremertonwa.gov/209/Consolidated-Planning (scroll down for a link to the documents)  A printed copy may be requested from the City of Bremerton Block Grant Divisions There are a number of specific elements in the 5-Year Consolidated Plan, including: • Needs Assessment: an assessment of housing needs (primarily of low and moderate income people) and needs of homeless people; • Housing Market Analysis: an analysis of the City of Bremerton’s and Kitsap County's housing market; • Strategic Plan: a discussion of the City of Bremerton’s and Kitsap County's priority needs to establish goals and objectives for implementing strategies which address housing and community development activities; • Citizen Participation Plan (Updated within the annually updated Policy Plan) • Annual Action Plan: describes the activities that will be undertaken to address priority needs utilizing HOME and CDBG grant funds during the upcoming program year (Submitted Annually); and • Consolidated Annual Performance and Evaluation Report (CAPER): describes how funds were used in activities that provided benefits to low and moderate income individuals and families during the previous program year. (Submitted Annually) Appendix A 4 Governments, service providers, citizens, and non-profit/for-profit agencies are encouraged to identify needs and priorities, assist in the development of strategies, and to participate in the annual allocation process. The following are specific opportunities for citizens to participate in the development of the information to be incorporated in the Consolidated Plan, which is updated every five years: 1. At least one community meeting will be held to obtain the views of citizens, public agencies, and other interested parties concerning housing and community development needs, including non-housing community development needs and priorities during development of the plan. 2. The City of Bremerton will coordinate with the Bremerton Housing Authority (BHA) to encourage participation of residents of public and assisted housing and other low income residents of targeted revitalization areas, in the process of developing and implementing the Consolidated Plan. 3. Agencies working with low- and moderate-income persons, particularly those living in blighted areas and residents of predominately low- and moderate-income neighborhoods, minorities, non-English speaking persons, and persons with disabilities will be contacted to encourage participation in the development of the Consolidated Plan. Amendments to the Annual Action Plan Citizens will be notified and have an opportunity to comment on any substantial amendments proposed to the Annual Action Plan. Substantial Amendments will be published in the City’s newspaper of record and be subject to a 30-day public comment period to allow for comment prior to implementation of the proposed amendment. For any amendments made as a result of the COVID-19 Pandemic and as a response to use of any CDBG-CV funding the City will utilize a 5 day public comment period as outlined by HUD. Substantial Amendments may be forwarded for review by the appropriate PRC prior to submission to the Bremerton City Council for final approval. Comments or views of citizens will be considered at the public hearing, and a summary of any comments or views not accepted and the reasons therefore, will be attached to the substantial amendment of the final Action Plan which will be submitted to HUD. Substantial amendments include: • Changes in the use of CDBG or HOME funds from one eligible activity to another • Adding a new activity • A substantial change to the purpose, scope, location or beneficiaries of the project as defined in the application for funds and approved by the PRC. CDBG or HOME activities awarded funds which have a substantial change in the purpose, scope, beneficiaries, location or budget will be evaluated by Block Grant Staff and may be required to submit a new application for funding in the next application cycle. Appendix A 5 Projects not expending their full CDBG or HOME award will not trigger a substantial amendment. These funds will be re-obligated to new projects during the following year’s regular application cycle. Minor Changes: Any request for a change in the amount to be expended on a program or project budget line item, or a minor change to the purpose, scope, location or beneficiaries of the project as defined in the application for funds, shall not be considered a Substantial Change requiring citizen notification and Annual Action Plan amendment; however, prior written approval of these changes must be obtained from the appropriate Block Grant Administrator. Minor project changes may need to be formalized as an amendment to the subrecipient Agency’s contract with the City. The Agency will submit a written request for change to the Block Grant Administrator stating the specific reasons for the requested increase or decrease in funding, or change in purpose, scope, location or beneficiaries. All requests will be reviewed, and approved or denied by the Block Grant Administrator. Performance Reports 1. The City of Bremerton Block Grant Division will prepare and submit a Consolidated Annual Performance and Evaluation Report (CAPER) to HUD no later than March 31st of each year for the previous calendar year. 2. The CAPER will be made available for public review. Notice will be published in the newspaper of record and copies will be available on the City’s website: • City of Bremerton: http://www.bremertonwa.gov/198/Federal-Grants---CDBG scroll down to the year and CAPER file desired. 3. Citizens will be provided a period of at least 15 days to review and comment on the CAPER. Comments or views of citizens will be considered in the report, and a summary of any comments or views not accepted and the reasons therefore, will be attached to the CAPER and submitted to HUD. Public Hearings By law, public hearings are required in order to obtain the public’s view and to provide the public with the City’s responses to public questions and proposals. Annually a public hearing will be held in spring for the approval of the next year’s Policy Plan. A second hearing is held in November to review the proposed use of funds and adopt the Annual Action Plan. Notification of the public hearings and of comment periods will be published in the newspaper of record and will afford citizens, public agencies, and other interested parties a reasonable opportunity to examine the proposed plans and to submit comments. Appendix A 6 City of Bremerton public hearings will be held during Bremerton City Council meetings, which are held every first and third Wednesday of the month, at 5:30 pm in the meeting chambers of the Norm Dicks Government Center. Bremerton City Council agenda may be obtained at http://www.ci.bremerton.wa.us/155/City-Council. Public Comments Interested persons may submit comments in writing during the public comment periods, or orally at the public hearings. Written comments should be directed to: Sarah Lynam Community Development Block Grant Administrator City of Bremerton 345 6th Street, Suite 100 Bremerton, WA 98337 Complaints All written citizen complaints will be referred to the appropriate person(s) or agencies for action. Under normal circumstances, the Block Grant Division will respond to the person making the complaint within 15 days. All complaints and responses will be kept on file. Resources Newspaper of Record: Notification will be placed in the following newspaper under Legal Notices at least ten days before a public meeting is held concerning a program described in this plan: City of Bremerton Block Grant – The Kitsap Sun Notices may also be published on City website: City of Bremerton Block Grant Program: http://www.bremertonwa.gov/198/Federal- Grants---CDBG The notice will indicate when and where the public meeting will be held. Meetings are often held at the following location: Norm Dicks Government Center, 1st Floor Meeting Chambers 345 6th Street Bremerton, WA 98337 Appendix B 0 Appendix B Funding Process Appendix B 1 Introduction The City of Bremerton is an entitlement community, and uses a competitive application process to find the best subrecipients to implement programs and activities around the City. The City has an independent funding process for its CDBG funds based on the prioritization of the City Council and utilizes a Project Review Committee to assist in making funding determinations. For application submission an review the City has a joint application process with other Kitsap County grant programs including HOME, CIAH, Housing and Homelessness Program (which administers Homeless Housing (HHGP), Affordable Housing (AHGP), and Consolidated Homeless Grant (CHG) Program). The Kitsap County Grant Recommendation Committee (GRC) process funding recommendations for use of HOME, CIAH, and Homeless Housing Grant Programs. Funding recommendations are approved by the Kitsap Board of Commissioners for County CDBG/HOME funds and by the Bremerton City Council for City CDBG/HOME funds. For the 2027 application process the City of Bremerton will use the Survey Monkey Apply system. Applications will be made available in a format accessible to persons with disabilities upon request. Application submittal instructions and due date are included in the Notice of Funding Availability (NOFA). The NOFA will be published on May 23, 2025. Applications must be submitted online and require access to the internet. 2027 Program Year Funding Specifics: The 2027 Program Year will have the following competitive funding applications: • Capital - Rental Housing • Capital – Homeowner Housing • Capital - Public Facility, Infrastructure, Shelter • CDBG Public Services (Microenterprise) *Please review the Executive Summary for funding priorities included in these applications. Appendix B 2 Application Review & Project Review Committee Recommendation Process On May 29, 2026 the City will publish a Notice of Funding Availability. Within this document will be information about the funding applications which have the following priorities: CDBG Capital/Economic Development projects: • Preservation and/or rehabilitation of affordable housing including o Acquisition of housing to create or preserve units of affordable housing o Weatherization/repair of existing housing units • Infrastructure and public facilities projects including: o Street and Sidewalk improvements in low-income neighborhoods o Parks projects/facilities in low-income areas • Microenterprise Assistance Programs HOME Housing priorities are of equal importance. • Construction or acquisition of new rental housing units • Acquisition of homeowner housing through down-payment assistance The Grant Recommendation Committee (GRC) will be used to review applications for HOME funds through the coordinated grant process. The City of Bremerton uses a separate Project Review Committee to review applications for CDBG funds. The Project Review Committee must adhere to the Conflict of Interest Policy in Appendix C. Applications will be initially reviewed by Block Grant Staff to determine compliance with technical requirements including eligibility for CDBG and/or HOME funds. Applications which are found not eligible for CDBG, HOME, Homeless Grant Program or Affordable Housing funds, will be disqualified and the applicant will be notified. Eligible applications will be reviewed and evaluated by staff for organizational and financial capacity, will be interviewed by the Project Review Committee, and a recommendation will be provided by the Project Review Committee and forwarded to City Council. The Council will review all recommendations, and select the projects for funding based how they address needs & objectives identified in the 2026-2030 Consolidated Plan. The details of the multi-level review process are listed below: Appendix B 3 Stage 1: Completeness & Qualification Review Submitted applications are reviewed for potential disqualification using the following process: 1. Applications are reviewed for completeness, soundness, and eligibility against the following criteria. Applications meeting one or more will be disqualified. At least two different staff members must agree that an application should be disqualified. a. Amount requested is not consistent among narrative questions, Sources of Financing form, budget form, and/or applicant information; b. Missing or blank attachments or forms or using old versions of forms; c. Project or applicant organization is not eligible for any of the funding sources; d. Project does not meet a priority identified in the City of Bremerton Consolidated Plan (2026-2030) or does not meet a Bremerton City Council funding priority. e. Project does not meet a National Objective as defined by HUD. f. Wrong application type is submitted for project. 2. Applicants will be notified of the results of the Stage 1 Review via email, either: a. Application is moving to Stage 2 and the applicant will be contacted to schedule an interview; or b. Application is disqualified and the basis for disqualification is provided. Stage 2: Review and Scoring Applications are reviewed and scored for organizational capacity, financial soundness, and project priority. 1. Staff members review and score all areas of the application utilizing scoring criteria specific to each application type. 2. Project Review Committee (PRC) members make funding recommendations using the following process: a. Review, evaluate, and score each application using review and scoring guides specific to each application type; b. Conduct interview with each applicant and score applicant interviews; interview length will depend on application type. o CDBG Economic Development will have interviews consisting of the following: i. 20 minutes in length which includes 10 minute agency presentation and 10 minute question/answer. Appendix B 4 o Capital applications will have interviews consisting of the following: i. 35 minutes in length which includes 15 minute agency presentation and 20 minute question/answer. ** Joint interviews may be held for organizations that submit a project application for both City and County CDBG funding. c. Assign a priority ranking and recommend funding awards to applications. Stage 3: Funding Awards The funding recommendations go through a multi-step process, prior to finalizing the award amount. 1. Project Review Committee (PRC) – All Stage 2 applications will have a final score comprised of the staff application review score, PRC application review score, and PRC interview score. The PRC will use the finalized score of applications to assist in making the funding recommendations and contingencies. 2. City of Bremerton City Council- The City Council receives the recommendations from the Project Review Committee, holds a public comment period and a public hearing, and makes awards and contingencies. 3. Federal CDBG and HOME funds- Applications awarded CDBG and HOME funds must be included in an Action Plan associated with the 2026-2030 Consolidated Plan and submitted to HUD for approval. The Action Plan cannot be finalized until the City of Bremerton receives the federal award amounts from HUD. 4. Final Awards – Funding recommendations were made based on estimated funds. Once the actual amounts are known awards will be adjusted based on the contingency set by the PRC’s and approved by the Bremerton City Council. Project Review Committee The Project Review Committee (PRC) will be formed consisting of three City of Bremerton staff members (Director-Department of Community Development, Finance Director, Community Development Project Assistant), one member from City Council, one representative from the Planning Commission and two citizens at large. (If a representative from the Planning Commission is unavailable, another citizen representative will serve in their place). The role of this committee is to read all applications and complete independent, scored reviews, review projects for community need and benefit, review evaluations, conduct interviews, and discuss, rank and recommend projects for funding. The appointees to this committee are appointed by the Mayor and confirmed by Bremerton City Council. Appendix B 5 The PRC will provide recommendations to City Council and the Council will have the opportunity to approve all the final recommendations. Applicant interviews will be conducted with the PRC. Applicants will have the opportunity to present their project and the PRC will have an opportunity to ask questions. At the conclusion of the interviews the PRC will formulate a funding recommendation for approval by the City of Bremerton City Council. Appointments for PRC members are made annually. PRC members are appointed to serve a two year term and can be re-appointed to serve successive terms and/or additional terms. Conflict of Interest 1. No member of the Project Review Committee (PRC) shall be beneficially interested, directly or indirectly, in any grant applications which may be made by, through or under the recommendation of the PRC, in whole or in part, or which may be made for the benefit of his or her office, or accept, directly or indirectly, any compensation, gratuity or reward in connection with such contract from any other person beneficially interested therein (from RCW 42.23.030). 2. No member of the PRC shall engage in any activity, including participation in the selection, award, or administration of a grant award or contract if a conflict of interest, real or apparent, exists. 3. Additional information on Remote Interest can be found in the full Conflict of Interest Policy under Appendix D. Technical Assistance All applicants for funding who have never received City CDBG funding before, or have never used the SM Apply system will be required to attend the technical assistance session. During the session, staff will provide information to citizens concerning who can apply for funds, funds expected to be available, the range of activities that may be undertaken, priorities for funding, application submission requirements including technical assistance in filling out the application, the application deadline, and how decisions concerning funding will be made. There will also be a workshop on how to use the Survey Monkey Apply system if an applicant has not utilized the system before. In addition to the mandatory Technical Assistance described above, City Block Grant staff is also available by appointment for one-on-one Technical Assistance to provide guidance to citizens and organizations regarding specific project considerations. Please contact Block Grant staff to set up an appointment. Appendix B 6 At any time, any citizen may contact the City Block Grant staff for technical assistance, help with an application or general information in relation to programs described in this Plan. The Department will help citizens understand CDBG and HOME funded programs, the procedures for submitting proposals, the Citizen Participation Plan and other program requirements so they can effectively participate in CDBG and/or HOME programs and the funding process. Appendix C 0 Appendix C CDBG Eligibility Requirements & Program Rules Appendix C 1 CDBG NATIONAL OBJECTIVES AND ELIGIBILITY REQUIREMENTS Every CDBG activity must meet a national objective and must be eligible in order to be funded, and each CDBG applicant must be able to demonstrate eligibility based on data collected. The following information is provided to assist you in defining the eligibility and national objective that your activity meets and the type of information you will need to gather from the population you serve to provide to the City Block Grant office. Specific regulations that govern the CDBG program are available the Block Grant office. What are the National Objectives? (Benefit Criteria) An eligible CDBG activity must either I. Principally benefit low and very low income A. Area Benefit – a. Activity which is available to benefit all the residents of an area which is primarily residential. b. At least 51% of beneficiaries are low or very low income persons/households. c. Applicants will be responsible for defining the service area and City staff will checkto ensure that it meets the Low Moderate Income (LMI) criteria. B. Limited Clientele 1. At least 51% of beneficiaries are low or very low income persons/households a. Presumed Benefit b. Agency Requires Client Information c. Income Eligibility Requirement (Direct Benefit) d. Nature/location 2. Removal of Architectural Barriers 3. Assistance to Owners of Microenterprises 4. Employment Support Services C. Housing Activities (Residential) a. 51% of units must be occupied by low-and moderate-income households. b. Affordable rents must be maintained for 5 years Appendix C 2 D. Job Creation or Retention - Economic Development a. Must be located in a predominantly Low/Moderate (L/M) income neighborhood and serve the L/M income residents; or b. Involve facilities designed for use predominantly by L/M income persons; or c. Involve the employment of persons, the majority of whom are L/M income persons. II. Reduce or Eliminate Blight III. Meet an Urgent Need A. Urgent Need would be a natural disaster or federally declared disaster. NOTE: The vast majority of CDBG activities funded are designed to benefit low and very low income persons and households. How Does A Project Meet a National Objective? I. Principally benefit low and very low income To meet this national objective, an applicant must document that the proposed project will benefit predominantly low and very low income persons or households. A low income person/household is one whose annual income does not exceed 80% of area median income -- a very low income person/household is one whose annual income does not exceed 50% of the area median income. HUD Income Limits for Bremerton are included in the Application each year. There are several different ways that CDBG activities can benefit low and very low income persons: A. AREA BENEFIT This criteria allows a project located in principally residential area to meet a National Objective by demonstrating that, based on the demographics of a project’s defined service area, at least 51% of the residents are low or very low income. Certain activities are a natural fit for area benefit, as they serve a geographic area, such as parks, neighborhood facilities, community centers and streets/sidewalks. Please contact the City Block Grant office for maps and more information on documenting your service area and determining eligibility under Area Benefit. Applicants must:  Attach a map with the boundaries of the project's service area delineated (the surrounding geographic area in which all or most of the people benefiting from the project reside).  Explain why that particular geographic area is the service area for the project; Appendix C 3  Indicate on the map residential and commercial areas within the service area boundary; and  Provide documentation that 51%(City) or more of the residents within the service area are low and very low income persons/households utilizing the most recent census data as provided by HUD. Please contact the City or Block Grant office for maps and more information on documenting your service area. B. LIMITED CLIENTELE An activity which benefits a limited clientele, at least 51% of whom are low or very low income persons/households. There are four types of activities in this category: 1. Presumed Benefit -- An activity may benefit one of the following groups who are presumed by HUD to be principally low and very low income: abused children, battered spouses, elderly persons, handicapped persons, homeless persons, illiterate persons, migrant farm workers and persons living with HIV/AIDS. Applicants must:  Demonstrate that the facility or service is designed for and used predominantly by one of the groups identified above.  Demonstrate that your clientele meets HUD’s definition for the presumed group you serve, for example, homeless individuals must meet HUD’s definition and documentation requirements at https://www.onecpd.info/resources/documents/HomelessDefinition_Re cordkeepingRequirementsandCriteria.pdf 2. Require documentation on family size and income in order to show that at least 51 percent of the clientele are low income – This means your program can serve low and moderate income clientele if at least 51% of your clientele are low income. Agencies must keep information on client income and family size which can document whether or not 51% or more of the clientele are persons whose family income does not exceed low and moderate income limits for Kitsap County. Note: Income qualification criteria from other programs (such as state poverty guidelines) may be substituted provided those criteria are at least as restrictive as the HUD income limits. Appendix C 4 Applicants must:  Provide documentation of the total number of clients/households served in 2027 (if this is an existing service);  State what percent of the clients/households served in 2027 were low or very low income (or met criteria that are stricter);  Provide a copy of the income qualification criteria that were used to screen clients and to determine the percent that were low and very low income;  Provide a copy of the client intake form highlighting the questions regarding family size and income levels; and  Agree to maintain documentation of the client's incomes for the CDBG contract period. 3. Income Eligibility Requirements (Direct Benefit) -- This means that the agency uses income screening to limit the benefits of the CDBG funded activity to only those persons who are low and very low income. For example, a housing counseling program would screen potential clients and use the CDBG funds to pay for the counseling only of those who are income eligible. Applicants must:  Screen clients by family size and income;  Provide a copy of the income qualification criteria that were used to screen clients to determine low and very low income status;  Provide a copy of the client intake form highlighting the questions regarding family size and income levels; and  Describe how the program/project would limit the benefits of the CDBG funded activity exclusively to low and very low income persons/households. 4. Nature/Location of Activity Allows Conclusion of Primarily Low and Very Low Income Benefit -- This means that the activity is of such a nature and in such a location that it may be concluded that the clientele will be primarily low and very low income; for example, free childcare in an assisted housing project. Appendix C 5 In addition to the four activities described above, the following activities may qualify under the limited clientele national objective. Applicants must:  Explain how the nature, and if applicable, the location of the proposed project, establishes that it is used primarily for low and very low income persons. • Removal of Architectural Barriers A project which removes material or architectural barriers which restrict the mobility and accessibility of elderly or handicapped persons to publicly owned and privately owned non-residential buildings, facilities and improvements, and the common areas of residential structures containing more than one dwelling unit is considered a limited clientele activity. Note: This refers to the removal of existing barriers. It does not apply to new construction. • Assistance to Owners of Microenterprises When assistance is to be provided to a microenterprise (a commercial enterprise that has five or fewer employees, one or more of whom owns the enterprise) the owner must qualify as low or moderate income. Note: for microenterprise projects under the limited clientele national objective justification, the low income threshold applies only to the owner, there are no income requirements for the workers the owner employs. • Employment Support Services. If CDBG assistance is only provided for training or supportive services (peer support programs, counseling, child care, transportation, and other similar services) to assist business(es), the percentage of low and moderate income persons assisted may be less than 51% if the proportion of the total cost borne by CDBG funds is no greater than the proportion of the total number of persons assisted who are low or moderate income. For example: A new business moves into town and begins an on-site day care program for workers. The total cost of the day care is $10,000. There are 40 children, 3 of which meet qualifications as low and moderate income. The maximum amount chargeable to the CDBG program is $750.00. ($10,000/40 =$250 X 3 = $750). Applicants must:  Maintain data documenting the total cost of the service, Screen clients by family size and income; and provide a copy of the client intake form highlighting the questions regarding family size and income levels; Appendix C 6 C. Housing Activities These are activities providing or improving permanent residential structures which are or will be occupied by low and very low income households. It does not include group homes or shelters for the homeless, which are considered limited clientele activities. Applicants must:  Maintain a copy of the written agreement with each landlord or developer receiving CDBG assistance indicating the total number of dwelling units in each multi-unit structure assisted and the number of those units which will be occupied by low and moderate income households after assistance.  51% of these units must be available to low/moderate income.  Maintain records on the total cost of the activity, including both CDBG and non-CDBG funds.  Screen households for family size and income eligibility.  For rental housing, maintain records on rent charged (or to be charged) after assistance for each dwelling unit in each structure assisted.  Affordable rents must be maintained for a period of five years after CDBG assistance. D. Job Creation or Retention Activities These are economic development activities which are designed to create or retain permanent jobs, where at least 51% of the jobs, computed on a full-time equivalent basis, can be documented to employ low and very low income persons for the geographic area where it is located. There are very specific elements of this national objective. Please contact the Community Development staff to discuss your project prior to submitting an application. Appendix C 7 CDBG FUNDING - SPECIFIC REQUIREMENTS 1. Reversion of Assets / Change-of-Use of CDBG Assisted Property All recipients must agree to restrict the use of the property, which was acquired and/or improved using CDBG funds, to the intended purpose for which the funds were awarded. The restriction will be based on the dollars invested and follow the guidelines in the chart below. This is to ensure compliance with HUD requirements and to ensure continued public benefit. Activity Dollar Threshold* Minimum Years Restricted Rehabilitation or Acquisition of existing facilities or housing (including homeownership assistance) Less than $15,000 $15,000 - $40,000 Greater than $40,000 5 Years 10 Years 15 Years New Construction or Acquisition of land for new construction Any $ amount 20 Years * Dollar threshold is per facility, or if housing, per unit for single family housing Reversion of assets provisions require agency to transfer to the City any CDBG funds on hand at the time of expiration of the subrecipient agreement, any accounts receivable attributable to the use of CDBG funds, and any nonexpendable personal property that was purchased with CDBG funds 2. Restriction on Assessments CDBG funds may not be used for public improvement projects where a portion of the projects is to be financed by assessments to area property owners, unless the project is structured such that CDBG funds are used to pay the assessments of all low and very low income property owners. The analysis of incomes of affected persons must be done ahead of time and submitted as part of the application for CDBG funds. 3. Guidelines for Economic Development Projects (24 CFR 570.209) City will utilize the guidelines provided at 24 CFR 570.209 relative to project costs and financial requirements and standards for evaluating public benefit. 4. Supplanting (24 CFR 570.207) Federal regulations prohibit using CDBG funds to supplant (replace or substitute for) local funds for public services or ongoing responsibilities of general local government. The intent of this federal regulation is to prevent local government from using the availability of federal CDBG dollars as an excuse to reduce local funding commitments. Appendix D 0 Appendix D Conflict of Interest Policy Appendix D 1 Conflict of Interest Policy City of Bremerton Project Review Committee From time to time, community volunteers who are appointed to the Project Review Committee (PRC) have prior experience with one of the applicants or programs requesting grant funding. The following guidelines are intended to clarify what should happen in these cases to avoid real or perceived conflict of interest. 1) Conflict of Interest: a. No member of the PRC shall be beneficially interested, directly or indirectly, in any grant applications which may be made by, through, or under the recommendation of the PRC, in whole or in part, or which may be made for the benefit of his or her office, or accept directly or indirectly, any compensation, gratuity or reward in connection with such contract from any other person beneficially interested therein (from RCW 42.23.030) b. No member of the PRC shall engage in any activity, including participation in the selection, award, or administration of a grant award or contract if a conflict of interest, real or apparent, exists. 2) Remote Interest a. A PRC member is not interested in a contract, within the meaning of 1.a. above, if the member only has a “remote interest” in the contract and the extent of the interest is disclosed to the PRC and Staff at the beginning of the review process and is noted in the official minutes prior to the recommendation of the contract. (from RCW 42.23.040). i. As used in this section “remote interest” means: 1. That of a non-salaried officer of a non-profit corporation; 2. That of an employee or agent of a contracting party where the compensation of such employee or agent consists entirely of fixed wages or salary; 3. That of a landlord or tenant of a contracting party; 4. That of a holder of less than one percent of the shares of a corporation or cooperative which is a contracting party. ii. Even if the PRC member’s interest is only remote, the member cannot influence or attempt to influence any other PRC member in the award of a contract they are remotely interested in. For purposes of this provision, influence or attempt to influence includes any of the following: Appendix D 2 1. Scoring the grant application; 2. Discussing the grant application with other PRC members; 3. Joining the audience, acting on behalf of the applicant or interacting in any manner with members of the PRC. 4. PRC members should physically leave the room when the remaining PRC members discuss the matter. This removes any potential claim that the PRC member has attempted to exert undue influence over the other PRC members. 3) Potential Bias by Prior Association a. A PRC Member may have a “potential bias by prior association” if they have had an interest in the past, but do not meet these definitions during the time they are serving on the PRC, or who have personal prior experience with an applicant including serving as a board member in the past, being employed in the past, or being a current or past volunteer. In the event of a potential bias by prior association: i) The PRC member should disclose to the PRC and staff the nature of their prior association at the beginning of the application review process. 4) Conflicts Disclosed The staff should advise PRC members before the process begins that members need to disclose, in advance, any remote interest, potential bias by prior association that they have, or relatives serving as staff to any applicants. It is recommended that the disclosures be done in writing. 5) Voting and Recommendations a. The PRC member should recuse themselves from voting on any recommendation that would include applications in which they have a remote interest in or with whom they have a potential bias by prior association. b. If the final recommendations of the PRC are consolidated into a single motion, then the PRC member may participate in the vote so long as their participation in the discussion does not influence or attempt to influence the outcome with respect to the applicant in which they have a remote interest in or with whom they have a potential bias by prior association. c. Occasionally members of the City Council will sit on the Board of Directors of organizations which are proposed to receive funding. In this instance, the Council member with the conflict of interest will state their conflict, leave the Dias, and return when voting has been completed. Because the votes are passed as one resolution, the Council member with the conflict will not be allowed to vote on the resolution as a whole. Appendix D 3 6) Alternate PRC If there are two or more PRCs in a funding cycle or process, and a member has a conflict of interest, remote interest, or potential bias by prior association with an application that one of the PRCs is reviewing, that member may serve on a different PRC without reservation or restriction. Appendix F 0 Appendix F Glossary Appendix F 1 GLOSSARY Administrative Expenses. Those expenses directly associated with the recipient’s general administration of the CDBG or HOME programs, such as salaries, supplies, equipment, accounting, phones, audits, benefits, travel and indirect costs. Affordability. Affordability is achieved when a household’s rent or mortgage payment, plus utilities, does not exceed 30% of the monthly income for the targeted income group as adjusted for household size. Annual Action Plan: This document allocates one year’s funding to specific projects and activities for the CDBG and HOME programs. It is submitted annually to HUD, 45 days prior to the start of the City’s and County’s fiscal year or no later than November 15 and is developed in accordance with federal regulations (24 CFR Part 91). Architectural Barriers. Restrict mobility and accessibility of elderly or individuals with disabilities. Benefit Criteria. A CDBG activity must either principally benefit low or very low income persons, reduce or prevent slums and blight or meet a recent urgent need. These three objectives are the Benefit Criteria. Cash Flow. Gross income minus vacancy rate, operating expenses, reserves, debt service and taxes. Grant Recommendation Committee (GRC). A group of eight citizens meeting specific qualifications, who develop funding recommendations for City of Bremerton HOME funds. Citizen Participation Plan: This plan is prepared to facilitate and encourage public participation and involvement in the Consolidated Plan process and the City’s CDBG and HOME program, especially by low- and moderate-income persons. The plan identifies the public participation requirements as identified by federal regulations (24 CFR Part 91). Committed Funds. Funds committed to a project by a project funding source. The award amount, terms and uses of the committed funds are documented in a letter to the applicant. A copy of this award letter is included with the application for CDBG/HOME funds. Conditional Funds. Funds committed, with conditions, to a project by a project funding source. The conditions of the commitment, amount, terms, and uses are documented in a letter to the applicant. A copy of the letter is included with the application for Appendix F 2 CDBG/HOME funds. Consolidated Annual Performance Evaluation Report (CAPER): This document reports on the progress in carrying out the Consolidated Plan and Annual Action Plan. The report is prepared annually by both the City and County in accordance with federal regulations (24 CFR Part 91). It is due to HUD no later than 90 days after the end of the program year or March 31. Consolidated Plan: This document serves as the City’s and County’s application for CDBG and HOME funds. It sets forth the priorities and strategies to address the needs of primarily low- and moderate-income persons and areas in the county. It typically covers a five-year time period. It is submitted to HUD 45 days prior to the start of the program year or no later than November 15 and is developed in accordance with federal regulations (24 CFR Part 91). Consultant Fees. Fees paid to a third party developer consultant for costs associated with implementation of a project. Entitlement Community. A local jurisdiction that receives an allocation of Community Development Block Grant funds directly from HUD. All participating jurisdictions are entitlement communities; however, not all entitlement communities are participating jurisdictions. Household: all persons occupying a housing unit. The occupants may be a family, as defined in 24 CFR 5.403; two or more families living together; or any other group of related or unrelated persons who share living arrangements, regardless of actual or perceived, sexual orientation, gender identity, or marital status. Housing. Housing includes permanent housing units for sale or rent including; manufactured housing, permanent housing for disabled homeless persons, transitional housing, single-room occupancy housing, and group homes. Housing does not include emergency shelters or facilities such as nursing homes, convalescent homes, hospitals, residential treatment facilities, correctional facilities, halfway houses, housing for students or dormitories. Interlocal Agreement. Agreements made to ensure the cooperation of units of local government which form consortiums for the purpose of obtaining funding. Low- and Moderate-Income Households (LMI): These are households earning less than 80% of the area median income (AMI). They are broken down into the following income designations: • Extremely Low-Income: households with incomes less than 30% of the area median family income adjusted for household size. • Low-Income: households with incomes between 31% and 50% of the area median income, adjusted for household size. Appendix F 3 • Moderate-Income: households with incomes between 51% and 80% of the area median income, adjusted for household size. Low- and Moderate-Income Area Neighborhood (LMA): In general, this is defined as census tracts or block groups where a minimum of 51% of the residents have low or moderate incomes (i.e. not exceeding 80% of the area median income). Median Family Income: HUD releases income limits annually for its programs. Income limits are calculated using American Community Survey and Census data. Data for Kitsap County is based on the Bremerton-Silverdale Metropolitan Statistical Area (MSA). Incomes are indexed by household size. Neighborhood Revitalization Strategy Area: A specific neighborhood targeted by the City and approved by HUD. Communities with approved NRSA’s receive enhanced flexibility in undertaking economic development, housing, and public service activities with their CDBG funds. The City currently does not have an approved NRSA at this time. Operating Support. Financial assistance used to supplement the day-to-day operations of a project. Participating Jurisdiction. This term refers to cities, counties and consortia which receive an allocation of federal HOME funds directly from HUD. Persons with Disabilities. This term means a household composed of one or more persons, at least one of whom is an adult, who has a disability. A person is considered to have a disability if the person has a physical, mental, emotional or developmental impairment that is expected to be of long-continued and indefinite duration and substantially impedes his or her ability to live independently. Program Year: The program year for the City CDBG and HOME programs is January 1 through December 31, which is the same as the City’s fiscal year. Project Delivery Costs: Costs directly related to managing the project to the point of completion normally paid to a third party. Project Review Committee. This committee, made up of City of Bremerton staff, a member of the City of Bremerton City Council, Planning Commissioner and two citizen volunteers, evaluate, rank, and make funding recommendations to the Bremerton City Council for use of CDBG funds. Project Soundness. The feasibility, sensibility, and effectiveness of the project to meet a defined community need and the organizational strength and capacity to bring the project to completion. Appendix F 4 Proposed Funds. Funds which have been or will be requested from a potential project funding source. Relocation Expenses. Those costs paid to households or businesses when temporary or permanent relocation becomes necessary. Single family housing: one to four-family residence, condominium unit, cooperative unit, combination of manufactured housing and lot, or manufactured housing lot. Single room occupancy (SRO) housing: housing (consisting of single- room dwelling units) that is the primary residence of its occupant or occupants. The unit must contain either food preparation or sanitary facilities (and may contain both). Special Needs Housing. Housing for special needs populations who require special housing-related services. This is also referred to as supportive housing. Special Needs Population. This population of people includes elderly and frail elderly; persons with mental, physical or developmental disabilities; persons with HIV/AIDS; persons with alcohol or drug addiction; victims of domestic violence; persons discharged from institutions (prison, jail, mental hospital, foster care). Transitional housing: housing that is designed to provide housing and appropriate supportive services to person, including (but not limited to) deinstitutionalized individuals with disabilities, homeless individuals with disabilities, and homeless families with children. It has as its purpose facilitating the movement of individuals and families to independent living within a time period that is set. Uniform Physical Condition Standards (UPCS): Uniform national standards established by HUD pursuant to 24 CFR 5.703 for housing that is decent, safe, sanitary, and in good repair. Standards are established for inspectable items for each of the following areas: site, building exterior, building systems, dwelling units, and common areas.