Community Development Block Grants Proposed for Elimination

By John Collier, GOPC Intern The Community Development Block Grant (CDBG) is one of the longest running programs of the US Department of Housing and Urban Development. Beginning in 1974, the program has provided communities with a source of flexible funds to aid in affordable housing and anti-poverty programs. The future of the program is unclear, as the Trump Administration, in its 2018 Budget Blueprint, is calling for the elimination of the CDBG program.

The flexibility of the CDBG program sets it apart from other grant programs provided by the federal government. With CDBG grants, state and local governments have a large amount of discretion in how the money is spent, and require less federal oversight.

CDBG funds are allocated in two separate funding streams.  One goes to states and the other directly to cities meeting certain requirements. Seventy percent of CDBG funds are allocated to what is referred to as the CDBG Entitlement Program. This program distributes funds directly to large cities and urban counties. Eligible communities receive CDBG funds determined by a formula based on population, poverty rates, and housing units. Since the funding is based on a formula and depends on a number of factors, CDBG funding can vary from year to year. 

The other 30 percent of CDBG funds are allocated to the State CDBG Program. States award the CDBG funds to smaller units of government for a wide array of purposes. The State CDBG Program allows non-entitlement cities (typically cities with populations fewer than 50,000) to benefit from this CDBG program. In Ohio, CDBG funds are administered by the Office of Community Development at ODSA. The Office of Community Development outlines four areas for CDBG funding in Ohio:

1. Community Allocation – projects including public facilities, services, housing, and economic development

2. Neighborhood Revitalization – targeted investment in low and moderate-income neighborhoods

3. Downtown Revitalization – targeted investment in façade improvements, streetscapes, and public infrastructure

4. Critical Infrastructure – high priority projects, typically single-component projects such as roads and drainage, which provide a community wide impact

In 2016, Ohio received $137,566,074 from HUD’s CDBG programs, $41,292,727 went to the State Program and $96,173,347 was distributed through the Entitlement Program. Forty-five communities in Ohio were eligible for the Entitlement Program. The breakdown of expenditures of the State Program funds is as follows:

• 55% for Public Facilities and Improvements

• 20% for Housing

• 14% for General Administration/Planning

• 7.5% for Economic Development

• 2% for Public Services

According to the State of Ohio’s 2014 Accomplishment Report submitted to HUD, state program funds benefitted an estimated 885,599 individuals through the various projects funded by CDBGs. One of these state projects took place in Preble County, which assisted the Village of Lewisburg in a revitalization of its downtown district. The funds helped repair building facades, install decorative brick pavers, decorative planters, sidewalks, etc. In Miami County, state CDBG funds were utilized in a critical infrastructure project. CDBG funds allowed Bradford Village to replace 1,250 feet of water lines as well as to install 3 fire hydrants. The project benefited the entire village.

While total CDBG disbursement has decreased every year since 2002, it may now be completely eliminated. President Trump’s proposed 2018 Budget requests a $6.2 billion or 13.2 percent decrease in discretionary funding for HUD from 2017 levels and a complete elimination of the CDBG program. The blueprint claims the program “is not well-targeted to the poorest populations and has not demonstrated results” and aims to redistribute the funds to other activities.  The CDBG remains a valuable source of flexible funding for community development, and there is no obvious replacement source for cash-strapped communities.  Federal lawmakers need to carefully consider the merit of the program before making any changes.

For more detailed information on the CDBG program visit the HUD Exchange.

President's Budget Blueprint Reduces Overall Federal Support for Water Infrastructure

By Jon Honeck, GOPC Senior Policy FellowIn March 2017, the Trump Administration released itssummary budget blueprintfor Federal Fiscal Year (FFY) 2018, which begins October 1, 2017.  The plan signals the administration’s overall intention to cut non-defense domestic programs in order to free up funds for increased military spending.  There is a long road to travel before any parts of the plan are enacted, and many members of Congress have already gone on record expressing reservations about specific elements of the proposal.  Nonetheless, the blueprint creates a starting point for agency budget plans that will be presented to Congress in the coming months.   

This blog discusses the administration’s proposed changes to how the federal government will support investments in water infrastructure.  The Trump Administration’s budget blueprint would eliminate the USDA Rural Development water and wastewater loan program, the Appalachian Regional Commission (ARC), the Community Development Block Grant (CDBG), and the U.S. Department of Commerce – Economic Development Administration (EDA).   The plan would preserve funding for the U.S. Environmental Protection Agency (USEPA) water and wastewater revolving loan funds, although the agency as a whole would face a 31 percent budget reduction, resulting in the elimination of 3,200 agency staff positions and a 45 percent reduction in categorical grant programs.  One of these categorical grant programs provides states with funding for the oversight of local drinking water systems.  It helps pay for the Ohio EPA to monitor local compliance with protocols for the control of lead and other contaminants. 

The budget proposal should be analyzed in the context of the nation’s critical need to modernize drinking water, wastewater, and stormwater infrastructure.  This issue is a high priority for Greater Ohio Policy Center (GOPC) because of its links to economic development, land use planning, and the potential for financial strain on Ohio families and communities (see our recentWater Infrastructurereports).  According to EPA estimates, Ohio water utilities (typically local governments) will need to make capital investments of $26 billion in drinking water and wastewater infrastructure to meet identified needs over the next 20 years.   User charges have been rising steadily, faster than the rate of general consumer inflation. 

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                           Photo courtesy of Wikicommons

The federal government plays a major role in financing water infrastructure investments, although the approach has changed significantly over the decades.  With the passage of the federal Clean Water Act in the early 1970s, Congress created a large grant program to assist local governments with the modernization of wastewater treatment plants and related infrastructure.  The federal government paid 75 percent of project costs in the initial program, which was changed to 55 percent in the 1980s.  This was one of largest federal infrastructure programs since the interstate highway program of the 1950s and 1960s. 

In the late 1980s, Congress phased out the wastewater grant program in favor of a revolving loan approach.  A revolving loan for drinking water infrastructure was added in the late 1990s.  Under the current policy, each year the U.S. EPA provides a capitalization grant to state revolving loan funds which lend directly to local governments at subsidized interest rates.  The state must provide a 20 percent match for the grant.  In FFY 2016, the Ohio EPA received a $75.2 million capitalization grant for its Water Pollution Control Loan Fund, and $23.1 million for the Drinking Water Assistance Fund.   Communities that want a market-rate loan with fewer administrative hurdles can approach the Ohio Water Development Authority, which runs a state-supported revolving loan fund.   

The result of this change in federal strategy is that local communities bear the largest responsibility for financing water infrastructure.  Communities that need a grant to complete their capital project must rely on other sources, which are extremely limited and competitive.  At the federal level, these sources include the USDA Rural Development – Water and Wastewater Loan program, the Appalachian Regional Commission (ARC), the Community Development Block Grant, and the Economic Development Administration.  The USDA and ARC programs are targeted at smaller, low income communities in rural counties that need them the most.  In FFY 2016, USDA Rural Development made 17 grants for a total of $14 million to Ohio communities, and an additional 16 loans for $44.6 million.  The ARC, a smaller agency, made 12 water infrastructure grants for a total of $2.7 million in Ohio.  The CDBG provides several million dollars in Ohio each year for water and infrastructure through its Critical Infrastructure Program.  (For more information on the challenges of water infrastructure in Ohio, seepanelist presentationsfrom GOPC’s Investing in Ohio’s Future 2017 Summit and our reportStrengthening Ohio’s Water Infrastructure). 

The Budget Blueprint asserts that the USDA and EDA programs are duplicative of the state revolving funds and other programs, and that the CDBG is “not well-targeted to the poorest populations and has not demonstrated results.” The ARC is part of a long list of small, independent agencies slated for elimination.  The administration’s claims deserve close scrutiny from Congress, however.  The underlying issue is whether the federal government has any responsibility to provide grants, and the importance of grants in sustaining investments by small communities.  For small towns, grant funding can provide the missing piece of capital that makes a project affordable.  In Ohio, state and federal agencies have worked together for decades and often find ways to share responsibility for financing projects in small communities.  An interagency Small Communities Environmental Infrastructure Working Group (SCEIG), meets regularly throughout the year to provide advice to local governments seeking financing, and coordinates technical assistance programs. 

The elimination of these three federal programs would make the Ohio Public Works Commission (OPWC) the only significant remaining source of grant funding for water infrastructure in the Buckeye state.  (The EPA revolving loan funds have a limited number of loans that allow partial principal forgiveness.)  Most OPWC projects are prioritized at the local district level, and must compete with transportation projects.  In the context of rising concerns in Ohio and nationally about the affordability of infrastructure, a “one size fits all” approach to financing may backfire. 

For further resources and reports, please visit GOPC’s Sewer and Water Infrastructure Resource Page

Congress considers changes to EPA revolving loan formulas: Ohio may lose ground

By Jon Honeck, GOPC Senior Policy Fellow Background

Each year Congress appropriates funds for the U.S. EPA to provide capitalization grants for state revolving loan funds for wastewater treatment.  In Ohio, this fund is known as the Water Pollution Control Loan Fund (WPCLF).   The Ohio EPA sets priorities for the fund according to state needs and federal guidelines.  Local communities submit applications for loans to help finance wastewater treatment plant, sewer system upgrades, or conversions of septic systems to centralized sewage collection.  Ohio’s allotment of the total appropriation is set at 5.7% of the total appropriation amount; the state received $78.5 million in 2016. The annual subsidy allows the WPCLF to offer interest rates below standard market rates.  When combined with loan repayments, the fund can offer substantial amounts of financing.  In 2015, it made a record $759.6 million in loans. 

Congress orders a review

In 2014, Congress passed a major overhaul to the Clean Water Act.  This legislation, known as the Water Resources Development and Reform Act, mandated that the EPA review the allocation formula for the Clean Water Act revolving loan program.  The formula had changed little since the program was created in 1987.  At that time, the formula roughly reflected states’ share of the national population and share of the Clean Watersheds Needs Survey. 

Congress asked the US EPA to determine whether the formula addresses the water quality needs of states based on: (1) the most recent Clean Watersheds Needs Survey (CWNS); and (2) other information that the agency determined appropriate.  The CWNS takes place every four years.  In the 2012 survey, Ohio wastewater utilities identified $14.6 billion in capital projects that needed to be addressed over a 20-year period.  (Click here to access the 2012 CWNS).

Potential Revisions to the Formula

The US EPA presented its report to Congress in May, 2016.  It can be accessed here.  The agency’s main conclusion is that “the current allotment does not adequately reflect the reported water quality needs or the most recent census population for the majority of States” (emphasis in original, p. 5).    The report considers four basic factors that could be used in a revised formula:

• Clean Watershed Needs Survey (CWNS, which the agency admits underestimates water quality needs)
• Resident Population from the 2010 U.S. Census
• Water Quality Impairment Component Ratio (WQICR), an existing database documenting pollution in rivers, lakes, and streams, derived from data submitted by the states; and,
• Ratio of revolving loan fund assistance to the federal capitalization grant over the past ten years (to reward states that have increased project funding by leveraging their federal grants as much as possible);

Using these factors, the report considers three possible options for a new formula.  Each option would limit a state’s potential loss to 25% and its potential gain to 200%. 

OPTION	FACTORS and FORMULA WEIGHTS
1	2012 Clean Watersheds Needs Survey (70%), 2010 population (30%)
2	2012 CWNS (50%), 2010 population (30%), WQICR (20%)
3	2012 CWNS (50%), 2010 population (30%), WQICR (10%), Ratio of assistance to federal grant (10%)

Ohio’s allocation would decline

Ohio fares poorly in all three scenarios, mostly because its share of the national population has fallen by over a full percentage point in the last 30 years, to about 3.7% of the national total.  Interestingly, Ohio’s share of the Clean Watersheds Needs Survey has fallen only slightly, reflecting the large amount of EPA-mandated combined sewer overflow work that must be done.   All three scenarios would yield double-digit declines in Ohio’s allotment, with option 1 creating an 18.2% decline, and options 2 and 3 at the maximum reduction of 25%.   In Program Year 2016, a 25% reduction would have meant a loss of nearly $20 million in federal funding. 

What happens now?

The scenarios in the report are only suggestions.  Congress would have to pass legislation to modify the current formula.  Formulas that did not have a “stop-loss” rule of 25% could have even greater effects on Ohio’s allocation.  Significant federal funding cuts would make it more difficult for the WPCLF to provide low interest rate loans to Ohio communities at a time when sewer rates are rising and affordability is becoming an issue.  It would become especially difficult to offer principal forgiveness options to Ohio’s poorest communities.  These communities already face reduced federal funding options from cuts to the Community Development Block Grant program.  Between 2000 and 2014, average Ohio sewer charges increased by 85 percent, more than twice the rate of consumer inflation.[1]  In a 2015 report on infrastructure needs, GOPC identified replacement and upgrades to water and sewer infrastructure as critical needs that span Ohio’s cities and villages of all population sizes.  Key stakeholders in the area should make every effort to inform Congress about the importance of maintaining Clean Water Act revolving loan program funding. 

[1] Author’s analysis of average user charges from Ohio EPA, 2014 Water and Sewer Rate Survey.  Consumer Price Inflation increased by 37 percent.