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<br />. <br /> <br />. <br /> <br />. <br /> <br />. <br /> <br />, <br />'In drafting and discussing its proposed regulations, HUD appears to be <br />attempting a strict, urban interpretation of the amendments. The initial <br />proposed regulations were turned down by the Office of Management and Budget <br />(OMB) without comment, and sent back to HUD for a rewrite. Of particular <br />concern is that HUD used "the same manner and same extent" language in the Act <br />to require the "Small Cities" participants to meet all rather than some of the <br />provisions and requirements of the "entitlement" (large city) regulations. <br /> <br />For the Colorado program this would mean that: <br /> <br />1. A family of four with a $25,300 income in Eagle or Adams County could <br />have their home rehabilitated with CDBG funds, but a similar family in <br />Delta or Baca County must make not more than $14,900 to qualify for <br />the same aid. <br /> <br />2. All Colorado "non-entitl ement" communiti es woul d have to develop <br />"displacement" pol icies before applying to the CDBG program, whether <br />or not their project woul d di spl ace anyone. <br /> <br />3. A Colorado community would have to have a "community development plan" <br />and "local housing and community development needs assessment" already <br />in place in order to apply for a planning grant, a single building or <br />business/job aid project, or to build a senior center. These are <br />ineffective, meaningless, paperwork requirements given the public, <br />citizen comment and local formal actions that must be taken. <br /> <br />4. The state and small counties and communities receiving CDBG funds <br />would have to meet extensive prescribed recordkeeping and reporting <br />requirements (not required under other block grants and state <br />programs). (Remember, Flagler is the same as Los Angeles.) <br /> <br />Colorado's Community Development Block Grant Advisory Committee (five mayors <br />and other municipal officials and three county commissioners) and <br />representatives from CML, CCI and NAHRO, and state officials and legislators <br />have worked diligently over the past three years to design a State CDBG <br />program that responds to the needs and capabilities of smaller Colorado <br />communities and their low-income citizens. The "Small Cities" CDBG program <br />has been received with enthusiam and support throughout the state. We have <br />met all federal requirements and far exceeded the low-moderate income benefit <br />goals each year. <br /> <br />The actions of Congress and HUD regarding the Housing and Urban-Rural Recovery <br />Act of 1983 and the related regulations will have a negative effect on the <br />state's "Small Cities" CDBG program. In 1983, we trusted the federal <br />government's intent to give the State of Colorado, in consultation with local <br />governments, the flexibility to administer a CDBG program that would best meet <br />the needs of our small cDmmunities. That trust, we believe, has been broken. <br />And, the state now cannot withdraw from its administrative role because over <br />$9 million in essential community development and housing funds for local <br />governments would be lost. <br /> <br />If we are to return to the original 1981 intent, and resulting successes in <br />responding to pressing local objectives, we must make ourselves heard in <br />Washington. Our immediate Dbjective is to have the regulations being <br />rewritten by HUD as flexible for the state program as the Act will allow. The <br />next step is to amend the law to give back to the states a CDBG program that <br />is truly a small cities program. <br /> <br />- 2 - <br />