Comment entitled "Redetermination of Slum and Blight Designation and revision of Slum and Blight definition" under the Department of Housing and Urban Development (HUD's) Proposed Rule submitted by Clifford W. Graves, General Manager, City of Los Angeles and James K. Hahn, Mayor, Community Development Department (submission incomplete)

CLIFFORD W. GRAVES GENERAL MANAGER City of Los Angeles CALIFORNIA JAMES K. HAHN MAYOR COMMUNITY DEVELOPMENT DEPARTMENT215 W. 6TH STREETLOS ANGELES, CA 90014 September 7, 2004 Office of the Rules Docket Clerk Office of the General Counsel, Room 10276 U.S. Department of Housing and Urban Development 451 Seventh Street, S.W. Washington, D.C. 20410-0500 SUBJECT: REDETERMINATION OF SLUM AND BLIGHT DESIGNATION AND REVISION OF SLUM AND BLIGHT DEFINITION DOCKET NO. FR-4699-P-01 (PROPOSED RULE) This letter serves to comment on the U.S. Department of Housing and Urban Development?s (HUD) Proposed Rule ?Community Development Block Grant Program Revision of CDBG Eligibility and National Objective Regulations? (Docket No. FR-4699-P-01). We are submitting our comments electronically through the EPA Federal Docket Site (http://www.epa.gov/feddocket). We have formulated several comments and questions regarding specific proposed amendments to 24 CFR Part 570 in the proposed rule. We support the addition and inclusion of environmental assessment and remediation of known or suspected environmentally contaminated sites in the Proposed Rule; inclusion of project-specific assessments and remediation of contaminated sites should expand the number and type of projects that would now qualify under the Final Rule. We oppose the Proposed Rule?s increase to using an arbitrary trigger of 33% of blighted or deteriorated properties for slum and blight designation. We would rather support a rule that would permit local governments flexibility in determining such a standard based upon their knowledge and experience of local conditions. The larger question regarding use of a percentage standard, in counting deteriorated or deteriorating properties, is how such a standard is considered met. We would request that HUD clarify what methodology grantees should use to determine whether a Br City of L.A. Community Development Department The comment submitted on (September 7. 2004) was incomplete