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CIA OF SAN BERNARDQO - REQ~T FOR COUNCIL A~ION
From:
Kenneth J. Henderson, Director .,; .',." ~'biget: nr:,SUBSTANl'IAL CHANGE
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FOLlCY FOR COBG PROGRAM
Dept:
Community Development
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Date: July 6, 1989
Synopsis of Previous Council action:
None.
Recomrnended motion:
That the "substantial change" policy and related definitions for the purpose of
the Community Development Blcx::k Grant (COBG) program be adopted. Further, that
staff be directed to submit same in a=rdance with newly amended federal
regulations to the U.S. Depart:roent of Housing and Uman Development.
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Contact person:
Ken Henderso'Y.~~.!:J"ores
Phone:_~65,
Supporting data attached:
staff Report
Ward:____~-]__,
FUNDING REOUIREMENTS:
Amount:___NL~,_, ,
Source: (Acct. No,L ~~ ___,.___ _ _
(AccLDescriQ!ion)
Finance:
Cou nci I Notes:
7<;._n?s-;.?
Ammrli=l Itpm No
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Clff' OF SAN BERNARDlio - REQUSsT FOR COUNCIL AC'?ION
STAFF REPORT
In September of 1988, the U.S. Department of Housing and Urban
Development (HOD) revised its guidelines for the operation of the
Comrmmity Development Block Grant (COa;) program. 'Ihese
guidelines consolidated several modifications that occurred in
recent years.
Three new rules and regulations stipulate that each entitlement
municipality take action within one-hundred, twenty (120) days
upon adoption of said guidelines. Section 570.305 states that
each grantee "... shall develop and make public its =iteria f=
what constitutes a substantial change..." under the coa; program.
In the past, a grantee was required to amend its final statement
of Comrmmity Development Objectives and Projected Use of FUnds
when it decided to "substantially change" the purpose, scope,
location and/or beneficiaries of a particular activity. In
addition, HOD has always allowed cities to use discretion in
deciding what constitutes a "substantial change". With the new
requirements that each grantee must develop criteria pertaining to
this matter, ,staff recormnends the Mayor and CoI11lron council adopt
the following "substantial change" policy:
For the purpose of complying with Section 570.305 of Title 24 CFR,
Part 570, the Mayor and CoI11lron Council of the City of San
Bernardino establish that change to an activity under the City'S
coa; program shall be considered substantial if (i) over fifty
percent (50%) of the original locations or beneficiaries are
impacted by the change, or; (ii) the description of the activity
is modified to the point whereby the general public would consider
it to be a new activity.
A substantial change is considered to have occurred under the
following circumstances:
1. 'Ihe amount to be expended for an activity is proposed to be
increaseci or decreased fram the amount in the final "statement"
by more than twenty-five percent (25%).
2. 'Ihe location of the activity is changed fram the location as
described in the final "Statement".
3. 'Ihe addition of a proposed activity which is not described in
the final "statement".
4. 'Ihe deletion of a proposed activity which' is described in the
final "statement".
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STAFF REPORT CDNl'INtlED...
July 6, 1989
Page -2-
I recommend that the Mayor am Cammon Council approve am adopt
said recommended policy relative to the definition of "substan-
tial change" am, further, that staff be authorized to submit said
policy am related definitions to the U.s. Depart ment of Housing
am U:rban Development.
Klli/ELF /lab/3255
July 6, 1989