Miami-Dade County's Proposed 5 Year
Consolidated Plan (2003-2007)
In the coming years, the South Florida Community Development
like consideration to the following policy items given to the
process for Maimi-Dade County:
Incorporate Certain Policy Elements of Carrie Meek's CDBG
Proposal with the Upcoming
Years Consolidated Plan
Last year, Representative Carrie Meek of Miami is introducing a bill to
the CDBG Program by: directing a minimum amount of CDBG to
and minimizing "benefit inflation"
of counting benefit to lower income people that are proportionate to
The Creation of a Rational Formula that Links Project Funding
and Service Delivery
- 1. Increase the "Primary Objective" to 80%
Benefit to Lower Income People: The "Primary Objective" of
CDBG always has been to "principally" benefit lower income people.
Currently, the law requires that at least 70% of a jurisdiction's CDBG
be used to benefit lower income people. The bill raises the minimum to
80%. The increase to 80%, especially in combination with other
provisions in the bill, highlights and strengthens Congressional intent
that, in the face of a severe affordable housing crisis and changes in
welfare law, CDBG must "principally" benefit lower income people. It
sends a signal to jurisdictions that use of CDBG for activities such as
airport runways, US Post Offices, museums, and untold miles of concrete
are not consistent with Congressional intent.
- 2. Direct a Minimum of 40% to "Low" Income
People: The Meek proposal requires that, at a minimum, 40% of
a jurisdiction's CDBG funds be spent on activities that directly
benefit people with incomes below 50% of the areawide median income.
Even though jurisdictions' Consolidated Plans universally state that
"extremely low" and "low" income people have the most acute needs, far
too often jurisdictions use most of their CDBG for activities
benefiting people with incomes at the relatively high level of 80% of
the areawide median income.
- 3. Proportional Treatment of "Benefit" to Lower
Income People: The bill diminishes "benefit inflation" by
introducing a method to more fairly count the degree to which lower
income people benefit from CDBG activities. CDBG expenditures will be
counted as benefiting lower income people based on the actual amount of
CDBG used, and only to the extent that lower income households are
assisted. Currently, if a jurisdiction spends $500,000 on a road in a
census tract where 52% of the households are lower income, that
jurisdiction reports to HUD that all $500,000 of the CDBG benefits
lower income people, rather than the proportional amount of $260,000
($500,000 x .52). The bill requires proportional counting for
activities that claim to benefit lower income people on an "area basis"
or through job creation/retention. For housing activities the law
already requires proportional counting; however, HUD's regulations
dilute the law's intent by using the "total development cost" rather
than the amount of CDBG in a project. The bill corrects this benefit
inflation practice. Activity by activity, without proportional
counting, jurisdictions readily give the impression that over 70% of
their funds "benefit" lower income people.
- 4. Prevent Use of the "Area Benefit Test" in
Central Business Districts: The bill adds to the law, the
current regulatory language which limits the use of the "area benefit
test" to areas that are "primarily residential in character". To
determine whether an activity serving anyone (eg, a road) "primarily"
benefits lower income people, the law requires that the activity be
"clearly designed to meet identified needs" of lower income people. HUD
regs use the "area benefit test" which looks at the service area of the
activity; if 51% of the residents are lower income, HUD judges the
activity to benefit lower income people. Downtowns generally have few
residents, but because most of those residents are low income,
jurisdictions claim that downtown roads, parks, streetscapes, and fire
protection primarily benefit low income people -- when in practice
daytime business visitors are the major beneficiaries. Years ago HUD
regs sought to prevent this abuse by limiting the "area benefit test"
to areas that are "primarily residential in character". Jurisdictions
and HUD are ignoring the spirit of the law and the letter of the
regulations. By placing the regulatory language in the law, the bill
intends to reinforce the spirit of "principal" benefit to lower income
- 5. Assess Whether Lower Income People Are the
Primary Beneficiaries: The Meek proposal adds current
regulatory language which looks at "the full range of direct effects"
of an activity in order to assess whether lower income people are
actually the primary beneficiaries. The mere location of an activity in
a service area where a minimum of 51% of the residents are lower income
does not mean that lower income people are the primary beneficiaries.
Roads and bridges are often located in low income neighborhoods, but
are designed to get the general population through the neighborhood on
their way into and out of the central business district. The law
currently requires that an activity "be clearly designed to meet
identified needs" of lower income people. HUD's regs reinforce this.
However, neither HUD nor jurisdictions are adhering to the law or regs.
The added language underscores Congressional intent that CDBG
principally benefit lower income people.
- 6. Improve Lower Income Benefit from Economic
Development Activities: The Meek proposal eliminates the
"presumption" that lower income people benefit from the use of CDBG for
economic development activities simply if employees live in areas that
have a 70% lower income concentration or meet the definition of an
empowerment zone (or if the business itself is in the latter).
Businesses getting CDBG assistance will have to ensure that at least
51% of any new or retained jobs are for lower income people, as is
generally the rule.
Too often there has been a consistent and profound disconnect between
(i.e.. brick and mortar funding) and service delivery (operational
There needs to be the creation of a formal policy that links
funding with adequate operational support in a rational and realistic
will take into consideration the administrative needs of grantees in
the number of units funded to produce.
Replace "20-40-40" with "50-50"
The Coalition seeks to further the effectiveness of the CDBG program by
the County's distributive "20-40-40" policy. Essentially, the policy
for 20% of the CDBG budget to be set aside for program administration,
40% to be
targeted for County Agency activities, and the remaining 40% to be
targeted to outside/non-governmental
agencies (non-profits, CDCs, CHDOs, CBOs, etc.). A suggested
alternative might be
a "50-50" policy where 50% of the overall CDBG total is targeted for
agencies; and the other 50% being targeted towards County agencies and
administration of the CDBG dollars.
Explore Options for Creating a Two- or Three-year Funding Cycle
Year by year RFAs and funding cycles are frustrating experiences for
grantees, County administration, and, most likely, the Board of County
The County might want to look to other communities that have
out their funding cycles. A multiyear funding application may be
the County and grantees alike.
The Implementation of an Pre-Application Process for Potential
and Support for Community Organizing/Leadership Development
Each year the number of organizations soliciting the County is growing
for a pool of development funds that is not growing. The County needs
a pre-application process that will determine which organizations have
track record of successful production and it in turn will fully
support. The County
should encourage and support those organizations that do not meet these
standards to engage in community organizing, planning, advocacy, and
development. Should there be a need for housing or real estate
organizations should partner with experienced housing/real estate