Montana Administrative Register Notice 8-94-131 No. 11   06/11/2015    
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In the matter of the amendment of ARM 8.94.3727 pertaining to the administration of the 2015-2016 Federal Community Development Block Grant (CDBG) Program










TO: All Concerned Persons


          1. On April 30, 2015, the Department of Commerce published MAR Notice No. 8-94-131 pertaining to the public hearing on the proposed amendment of the above-stated rule at page 402 of the 2015 Montana Administrative Register, Issue Number 8.


2. The department has amended the above-stated rule as proposed.


3. The department has thoroughly considered the comments and testimony received. A summary of the comments received and the department's responses are as follows:


Comment #1: A comment was received – having gone through the planning process for housing, the increase in funding amount is completely reasonable and appreciated, and the corresponding match requirements make sense as well.


Response #1: The proposed increase to award amount and corresponding match requirements are intended to encourage quality planning projects, given current cost estimates for certain planning activities.


Comment #2: A comment was received – in the form of a question to staff – similar to the consolidation of the planning activities and guidelines; will a similar process be in place for project grants in the future?


Response #2: The department intends to consolidate the project grant guidelines in a similar manner as the planning grant guidelines, but this process is taking longer due to the level of detail involved in project grant guidelines and applications. The Community Development Division will be holding webinars and training sessions in the near future, and working with community development and economic development representatives to gain insight and determine what specific changes will be helpful to both programs, with the intent to launch the consolidated document in early 2016.


Comment #3: Comment was received – in the form of a letter to staff - from the Cancer Action Network, the American Lung Association, and the Montana Department of Public Health and Human Services, encouraging the department to consider adopting smoke-free requirements as a threshold for new housing development receiving grant funds.


Response #3: The comments provided are appreciated but pertain more specifically to the project grant application guidelines – when housing is being constructed – as opposed to the planning grant stage.


Comment #4: A comment was received – in the form of a question to staff - indicating the commenter was excited to see the planning grant amount increased to $50,000, and was wondering if a combination of planning activities could be applied for and funded under one CDBG application; for instance, if the community wished to hire an architect to design a senior/community center and also retain a grant writer to prepare a CDBG Public Facility grant for the project designed by the architect, would this be eligible?


Response #4: The CDBG Application Guidelines for Housing, Public Facilities and Economic Development Planning Grants will continue to consider funding multiple, related planning activities, so long as the activities proposed are eligible pursuant to the guidelines and are related to one project. 


Comment #5: A comment was received – in the form of a question to staff - are planning grants accepted year round? The guidelines suggest this is the case; however, that seems very generous so I just wanted to be sure. Is there a specific deadline they must be submitted by?


Response #5: The department will accept applications for the FFY 2015 CDBG planning grant cycle on a first-come, first-served basis, beginning July 1st, until all FFY 2015 funds have been allocated.


Comment #6: A comment was received suggesting the inclusion of the development of an independent water and/or sewer district, including public outreach, legal assistance, development of bylaws, cost estimating and user rates estimating, boundary establishments, and elections per Title 7, parts 22 and 23, MCA, as an eligible activity under "Section II Eligible Planning Projects and Cost."


Response #6: The 2015 CDBG Application Guidelines for Housing, Public Facility and Economic Planning Grants allows applicants to propose a planning project other than those listed under eligible activities, which may be appropriate under special circumstances or was not contemplated in the development of the guidelines. Applicants should work with Planning Bureau staff to determine whether a proposed project meets the eligibility requirements under this section of the guidelines. 







/s/ Kelly A. Lynch                                  /s/ Douglas Mitchell          

KELLY A. LYNCH                                  DOUGLAS MITCHELL

Rule Reviewer                                       Deputy Director

                                                             Department of Commerce


Certified to the Secretary of State June 1, 2015.


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