FLOOD07316

• County: Statewide
• Basin: Statewide
• Title: Community Block Grant Applications Review 1984
• Date: 3/19/1984
• Prepared For: State of Colorado
• Prepared By: CWCB
• Floodplain - Doc Type: Flood Documentation Report

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STATE OF COLORADO

DEPARTMENT OF LOCAL AFFAIRS
OFFICE OF THE EXECUTIVE DIRECTOR

1313 Sherman Street, Rm. 518
Denver, Colorado 80203
Phone [phone]

Richard D. lamm,
Governor

TO:

State CDBG Advisory Committee
State CDBG Applicants and Grantees
I'"'''''Jt!;:'''''tf''' .,d ,,"'"

:::g~n1tR:gU1ations for the "Small Cities"
comm~~ty Development Block Grant Program (CDBG)

March 12, 1985

Morgan Smilh
bec:u!ive Direclor

FROM:
SUBJECT:

DATE:

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The department has thoroughly reviewed the 1983 amendments to the U.S. Housing
and Community Development Act and a copy of the draft regulations prepared by
the Department of Housing and Urban Development (HUD) to implement the Act
amendments.

It is our opinion that the 1983 amendments add numerous, administratively-
burdensome requirements for small communities. In addition, the HUD
first-draft regulations gave a narrow and restrictive interpretation to the
amendments. We expressed our objections to the draft regulatiDns to the U.S.
Office of Management and Budget (OMB) and to HUD as did many other states.
OMB rejected HUD's first proposal and HUD is now drafting another. Should the
new version not be responsive to the concerns of small municipalities and
counties under the state-administered program, the Colorado CDBG program will
no 1Dnger be as appropriate to Colorado's small jurisdictions as the 1981 CDBG
Act and regulations allowed. It certainly wDuld not be the CDBG program with
"maximum, feasible deference" to state-local design and processes that we
committed to local governments and HUD to administer in 1983.

The attached paper describes the intent of the state's "Small Cities" CDBG
program and what we perceive to be negative impact of the 1983 amendments and
HUD's original draft regulations. Our intent is to provide you with
sufficient information to enable you to express your concern to the Secretary
of HUD, our Congressional delegation, OMB and other interested officials.

If your review of these and other materials, and your experience with
Colorado's program indicates that you have any concerns that may be a result
of our department's own acti ons as admi ni strator of the "Small Citi es" CDBG
prDgram rather than of federal regulations or law, please contact me or Hal
Knott, Deputy Director, or Bill Timmermeyer, CDBG Project Coordinator at
866-2771 or by letter.

Please call if you have any questions.