April 17, 2007

Steven Watts

1649 Edgehill Rd.

Lawrence, KS  66044

Dear Mr. Watts: 

Thank you for your written comments regarding the 2007 Action Plan of the City’s 2003-2007 Consolidated Plan.  Your comments will be included in the Update that is submitted to the U.S. Department of Housing and Urban Development (HUD).  

As you are no doubt aware, allocation of CDBG and HOME funds is made through a process defined by the City’s Citizen Participation Plan.  The Plan has been adopted by the City Commission and contains the parameters for citizen participation within the grant programs. 

By federal regulation, all CDBG funded activities must meet a national objective, the primary one of which is helping low and/or moderate income persons.  This is the objective that the City of Lawrence current CDBG programs and activities meet.  There are two ways of accomplishing this – direct benefit, where the individual or family is directly benefited by the activity or service, and indirect benefit, where the individual or family is benefited because they are in an “area” that is eligible for CDBG funded activities.  Although the individual or family may be individually benefited by the program or activity, it is considered indirect because it is available to a “group”. 

Examples of direct benefit would be the programs you noted such as the Comprehensive Housing Rehabilitation, LCLHT First Time Homebuyer Rehabilitation, Weatherization, and Furnace or Emergency Loans.  Indirect benefits would be funding neighborhood association activities, including payment of operating expenses and coordinator salaries, public service activities such as landlord/tenant counseling, provision of emergency shelter and related homelessness services, payment of utility or rental payments to preclude utility shutoff and eviction, accessibility improvements for renters with a qualified disability, and/or improvements to structures that house agencies that provide services to low and/or moderate income persons such as Penn House, the Social Service League, Ballard Community Center, Community Living Opportunities group homes, and or Accessible Residential Options rental units.

As noted above, there is a defined citizen participation process that is followed with respect to the grant programs.  Basically, interested parties are notified in September-October by the department that grant applications are due in the Neighborhood Resources office by December 1 at 5:00 pm.  Applications and supporting information are available on the NR website and NR staff provides technical assistance as requested by applicants. 

The allocation process begins in January when the Neighborhood Resources Advisory Committee (NRAC) begins meeting.  This eleven member body is authorized by the Citizen Participation Plan from specific groups, including one representative each from the five target neighborhoods, one landlord, one Practitioners Panel member, and four citizens at large.  The Mayor, with the consent of the City Commission, appoints all members to the NRAC.  Currently, the makeup of the NRAC is as provided by the Plan.  The NRAC meets twice per month through April reviewing all applications and finalizing their recommendation following a Public Hearing that is advertised in the Lawrence Journal World and conducted at City Hall (April 12, 2007), which opens a 30 day written comment period. 

The recommendation (2007 Action Plan including the Investment Summary) is then forwarded to the City Commission for their approval before being sent to the HUD office as part of the grant approval process.  The 2007 Action Plan is scheduled to be on the City Commission agenda for April 24, 2007.  All written comments received to date will be included, and any received after the meeting but within the 30 day period will be included in the final document.  Should the City Commission wish to make changes to the Investment Summary, or refer the item back to the NRAC for review and changes, they can exercise that option. 

In addition to the grant application process, the Citizen Participation Plan sets forth “Guidelines To Be Followed By CDBG Funded Neighborhood Associations” as well as parameters for all public service agencies.  NR staff regularly monitors these associations and agencies to ensure that they are operating according to the Plan.  Additionally, each funded neighborhood association and public service agency is required to sign a Subgrantee Agreement, which further defines the expectations and requirements of the funded entity.  

I hope this addresses your concerns and answers your questions regarding project eligibility and citizen participation.  Should you have further questions, please do not hesitate to contact me. 

Sincerely,

Margene K. Swarts

Community Development Manager

Neighborhood Resources Department

cc:  Victor Torres, Director, Neighborhood Resources