Make your Count, count

National Association for County Community & Economic Development

CPD FORMULA PROGRAMS

SIGNIFICANT AREAS

• Use of 2010 Census Data for Formula• Use of ACS Data for Formula• Use of ACS Data for LMISD• Use of ACS for Upper Quartile exception

GRANTEE ELIGIBILITY & FORMULA COMPUTATIONS

DATA SOURCES – CDBG FORMULA

• Previously, only population (& growth lag) were updated annually by Census. This will continue unchanged• Poverty, Overcrowding, Pre- ’40 Housing previously came from decennial census, stayed constant for 10 years• Poverty, Overcrowding, Pre-’40 Housing will now come from 5 year ACS rolling averages – will change every year

CDBG FORMULA

• Previously: Only minor shifts in formula allocation amounts for 10 years, then major shifts in 3rd year of decade with addition of new decennial data• Henceforth: More year-to-year fluctuations in allocations amounts, but allocation amounts will more closely track demographic changes over time

ISSUES WITH USING NEW DATA

• New data will affect FY 2012 allocations & thereafter. HCDA requires use of data in effect as of 90 days before the start of that fiscal year (e.g. 7/1/11 for FY12)• If HUD doesn’t receive Census or ACS data by 7/1, its use in formula would be delayed one year (but would still be more current than what we’ve had before)

CENSUS DATA AND ENTITLEMENT ELIGIBILITY

• Statutory Grandfathering even if population drops under 50,000 or no longer an OMB principal city• New city & county eligibility depends on when HUD gets Census population data• New city & county eligibility may depend on frequency of OMB designation of metro areas• New city eligibility still depends on Urban County participation/cycle

EFFECTS OF 2010 CENSUS/ACS DATA ON OTHER PROGRAMS

HOME:• Previously used decennial census for all six formula factors• Starting FY 2012, will use 2005 – 2009 American Community Survey data• Will result in more fluctuation in HOME grants from year to year• Appropriation level affects minimum grant size threshold

EFFECTS OF 2010 CENSUS/ACS DATA ON OTHER PROGRAMS

ESG:• Previously, statute mandates ESG allocations proportional to prior year’s CDBG allocations• Appropriation level affects minimum grant size threshold (.05%) • Hearth Act did not change these

EFFECTS OF 2010 CENSUS/ACS DATA ON OTHER PROGRAMS

HOPWA: • Formula Grant eligibility based on MSA status, definitions & population (500,000+)• Allocation amount based on CDC data• Some places waver just over/under the population threshold • Changes in MSA principal city designation can affect which locality is the grantee

METROPOLITAN AREA STATUS AND FORMULA ELIGIBILITY

• New city & county eligibility may depend on future OMB designation of metro areas• OMB considering changes to MSA definitions & to frequency of designating new metro areas & principal cities• New OMB criteria & designations typically published late fall – too late to affect that year’s funding (e.g. November 2011 issuance won’t affect FY12 funding)

COMPUTING LOW/MODERATE INCOME

SUMMARY DATA

How LMISD Is Produced

• Not Census data per se – HUD computes from a special Census data run + Section 8 income limits• Up to now, data came from decennial Census, issued 3 years afterward, stayed constant for 10 years• Last updated in 2007 to use current Section 8 Income Limit areas/definitions

Major Changes….

How and when LMISD is produced will change dramatically

• Census data will now come from ACS 5 year rolling averages – will change yearly• ACS Data not available at Block Group level – only at Census Tract level• ACS Data not available for Insular Areas

….Major Issues

LMISD Will only be available at Census Tract level

• Data won’t be useful for activity service areas smaller than Census Tracts or include parts of multiple Tracts• Grantees may have to do more surveys• Upper Quartile % also based on Census Tracts – e.g. 12 CT’s instead of 52 BG’s• What do we use for the territories?

….Major Issues

New LMISD data every year

• Areas that qualify could change every year – inhibits long term planning• Areas (or entire jurisdictions) that waver just above/below the line • Upper Quartile %s would change every year• On the other hand, you wouldn’t be stuck using outdated data or doing surveys in lieu of!

….Implementation Issues

HUD will get the new data sometime this fall. Before we can implement it, HUD needs to:

• Come up with transition policy on when to start using new data• Come up with policy on how long data can be used (deal with yearly fluctuations)• Revise regulations on Upper Quartile• Revise IDIS to accommodate annual/multi-year LMI data for activities• Revisit/revise survey methodology guidance