Comment Submitted by Gloria Zacharias

Comments from the State of Oregon on the Proposed State Community Development Block Grant Program Administrative Rule Changes: Program Income Requirements – This proposed rule would revise Sec. 570.489 (e) (4) to require the annual Performance and Evaluation Reports (PERs) of states to include the use of program income retained by local governments. Comments: Using the PER as an instrument to track program income is adding another layer to an already exhaustive report. This appears to be excessive reporting, plus if a unit of local government is late reporting their program income would the PER need to be amended every time a new program income report came in? This requirement would duplicate records already prepared and reported by the states. The states are required to track and monitor program income held at the local level annually. Recipient program income tracking should discontinue five years after closeout of the grant between the state and the unit of general local government, to be consistent with the five year continued use requirements. Sec. 570.490 Recordkeeping Requirements would then be changed to require that program income be reported in IDIS. The IDIS system is extremely non-user friendly and forcing the states to use IDIS to track program income will add more problems to a system that is not adequate to begin with. The regional offices already monitor the use of program income for every state and their monitoring is very inclusive. The IDIS reporting would again be excessive and cumbersome. __ (Mary, we also talked about the 5 year continued use requirement that we cannot report in IDIS, but I can’t remember where that played in. I went through my notes but can’t find the correct section. If you can remember please feel free to add that in. We can submit this electronically via a web site and to COSCDA if you want. This is just rough, but I thought it would be a beginning.) 570.486(b) the proposed rule states that all State CDBG funded activities must significantly benefit residents of the grant recipient’s jurisdiction. This proposed rule would also permit the expenditure of state CDBG funds, if it provides no more than an incidental benefit to surrounding entitlement jurisdictions. This section also states HUD would not challenge the determination (or the state’s acceptance thereof) unless it is clearly unreasonable. Comment: The phrases “Must significantly benefit” and “incidental benefit” must be defined as used above. How HUD determines reasonableness and “reasonableness” as used above needs to be defined. __ 570.486(c) – States that residents of Entitlement jurisdictions may not receive more than an incidental benefit from the states expenditure of funds. Comment – The term incidental needs to be defined.