Community Infrastructure Program

Are resiliency hubs and emergency shelters allowable CI activities?

• Yes, but they are quite different from emergency command and operations centers, which are not permitted. CDBG-DR funds community resilience infrastructure, such as resilience hubs, but does not support government coordination centers, such as EOCs. eCFR: 24 CFR 570.207 – Ineligible activities.
  • Emergency Operations Center (Will Not Be Funded): Although eligible as a public facility or improvement under CDBG‑DR (§ 570.201(c)), to support government-wide coordination, communications, and emergency management personnel during disasters, NCDOC will not entertain requests to fund county or local government emergency operations centers (Reference Action Plan Page 78)
  • Emergency Shelter (Eligible): Considered a public facility for sheltering persons with special needs, including disaster victims. Eligible under the same public facility category (§ 570.201(c)) for acquisition, rehabilitation, reconstruction, or installation. A request for funding must be tied to disaster-related needs and must meet a national objective (e.g., low/moderate-income benefit or urgent need). 
  • Resilience Hub (Eligible - Low Priority): Resilience Hubs support community services daily and serve as emergency shelters for the community during disasters. They must comply with the CDBG-DR "mitigation set-aside" for infrastructure projects that reduce future disaster risk. These hubs should include features such as solar panels and climate control and fulfill a national objective. Unlike recovery-focused activities, they are funded for their future risk-reduction potential and don’t always require a link to past disasters.

Will DCR fund grant programs (as opposed to projects) in the first round of CDR funding?

• No, DCR is not considering funding subrecipient-led grant programs in the first round of funding.

Would the MOU between nonprofit organization and local government be required at the time of the application or after award?

• Some form of articulation of a partnership must accompany the application. That can be an MOU or letter of support or other option that articulates such. If a letter of support is submitted, whether we then require an MOU at full award will be decided on a case by case basis.

How should applicants answer the Part 1 Threshold Determination Questions on Form 2880?

• Applicants to this program should likely be answering yes to both questions (Yes to question 1, as everyone is applying for a specific project; Yes to question 2 as our lowest award amount is $500k, above the $200k in the question.) 

To clarify the Community Infrastructure Program vs the Mitigation Set Aside program requirements: if the Infrastructure program requires a national objective (such as 51% LMI benefit) for the project in order to be eligible. If the city ends up not being above the LMI threshold, are we still eligible in the mitigation set aside pool of funding? Will there be a separate application for set aside or will the initial application submitted under community infrastructure still be considered for the set aside funding pool?

• All applications must have a national objective. National objectives must prioritize LMA or LMC before considering UN or Slum/Blight. A NOFO will announce the opening of a funding round, and  will indicate whether mitigation-only (no tie-back to disaster) projects are a priority of the  funding round. 

Are public hearings required prior to application? 

• Yes, applicants must hold at least one public hearing prior to submitting their application, and a second by the signing of the award contract.

If the applicant is a nonprofit organization, what does the community input process need to look like?

• The nonprofit should work closely with the local government unit to raise awareness of the project and secure its support. The community should also be aware of the project through the nonprofit's standard communication channels, such as newsletters, board meetings, and social media. 

Do public hearings have to be specific to CDBG-DR in that consideration of the project(s) must be in the context of applying for CDBG-DR funding?

• The public hearing must cover the applicable project and envisioned CDBG-DR funds.

Can you provide clarification about providing a copy of the application during the public comment period? The concern being: giving citizens a copy of the application if it is not complete, because the public comment period would still be in progress.

• We are interpreting that line in the NOFO to require an applicant to identify a contact person for information related to the application/project.

What is the timeline to announce public comment?

• 10-25 days.

There is a mention in the NC Citizen Participation Plan that it is required to "Provide citizens the address, phone number, and times for submitting complaints and grievances, and provide timely written answers to written complaints and grievances, within 15 working days where practicable." Do we need a place for the entirety of the project where complaints and grievances can be submitted?

• Yes, a local government will need to be able to receive complaints and grievances for the entirety of the project.

Can a local government bring multiple CDBG-DR projects to the same public hearing, or is it required to have separate public hearings for each project?

• There is no requirement for a local government to hold a discrete public hearing for each project. So long as the purpose underlying the public participation requirement can still be accomplished – e.g., each project is clearly defined, the public is given an opportunity to ask questions/provide comment, the notice clearly indicates multiple projects will be discussed, the minutes reflect discussion of each project individually, and the timing of the hearings makes sense – there should be no issue.

Are public hearing advertisements required to be in the newspaper?

• We do not require notice be published in a traditional newspaper. However, it’s an option to publish in a newspaper.

What percentage of grant administration and project delivery costs are eligible within each of these program categories?

• There are no general administrative costs available. Project delivery costs are capped at 10% of the project. 

In other disaster recovery programs, the standard cap was 30%. Is there a standard cap, typical range, or recommended approach for budgeting administrative costs at the local project level?

• There are no general administrative costs available. Project delivery costs are capped at 10% of the project. For more details see section 7 of the program policies and procedures.

If an applicant can demonstrate that activity costs exceeding 10% are reasonable, necessary, and allocable due to project-specific conditions, will those costs remain eligible and competitive for funding consideration?

• DCR is not considering funding activity costs exceeding 10% at this time.

Are construction inspections and progress monitoring included in ADCs?

• No, direct cost category as an architectural and engineering service.

Will DCR provide cash advances?

• DCR is not considering providing cash advances at this time. These are reimbursement-based programs.

What happens to the remaining funds if the cost of Environmental Review is less than the amount allocated for such in the budget?

• The remaining funds will be added to contingency.

Is there a required type of professional cost estimate to submit a prescreen?

• No, as part of the prescreen, only an estimation of cost is needed. Upon application, a professional cost estimate is required. Cost estimate source examples include: 
  1. Considered industry gold standard: Professional engineer-stamped PER (preliminary engineering report) or cost estimate. 
  2. Cost estimates by an architect or professional estimator. 
  3. Cost estimates by a general contractor or local staff.

Does DCR have a standard budget and/or cost estimate template that applicants will be expected to use for each project?

• There is a budget template as part of the application, as well as an upload option for applicants who want to provide a more detailed budget document.

Will RSMeans be recognized as an acceptable methodology/source for developing project cost estimates?

• Yes, we will recognize and accept all types of professional cost estimates as part of the project application. The NOFO will include more on how the various professional cost estimates will be scored at the application.

Can multiple funding sources be used to support a single project? For example, if a project has already secured partial funding for certain components but requires additional funding to fully complete the overall project scope, would that still be eligible for consideration?

• Yes. Other funding sources are encouraged to fully fund the project. However, other funds may not duplicate or supplant requested CDBG-DR funding. 

How do we think about ADA and CDBG-DR funded projects?

• Projects will need to be ADA compliant. This will mean a host of requirements for various project types, and responsibility for identifying those requirements for each project falls to the subrecipient.

Are both units of government and government entities eligible to apply for the Community Infrastructure program?

• Yes.

Is an entitlement community eligible for the CDBG-DR Community Infrastructure program, if they are located in one of the designated MID counties?

• Yes.

What is the definition of Public Facilities?

• HUD’s standard definition of a public facility includes publicly owned or nonprofit-owned facilities accessible to the public. This encompasses infrastructure improvements such as streets, curbs, water, and sewer systems; neighborhood facilities such as public schools, libraries, parks, playgrounds, and recreation centers; and special-needs facilities such as homeless shelters, domestic violence shelters, nursing homes, and group homes. 

Is Wi-Fi an eligible activity? Can CDBG-DR funds fund broadband/Wi-Fi projects?

• Yes. Wi-Fi or broadband infrastructure qualifies under the CDBG-DR "community infrastructure" category if it meets regulatory standards and national goals. While this activity is permitted, it may not meet a funding round priority. It is suggested to submite a prescreening to fully evaluate the project.

Where can I find information on program income?

• Smart Management of CDBG Program Income Video - HUD Exchange

Are design costs allowable?

• Yes. Design costs are allowable pre-construction costs. However, DCR will only reimburse for cost accrued after a project has been selected for award and the date on the acknowledgment of selection. Additionally, reimbursements will be made after the full award (approval to spend funds).
   

If a project aligns with more than one of the DCR/Renew NC CDBG-DR funding buckets, would it be permissible to split funding for the project across multiple eligible categories/programs?

• No. A project may only be funded by one program.