National Objectives

To meet a CDBG-DR national objective, all activities must:

• Benefit LMI persons;

• Aid in the prevention or elimination of slums or blight; or

• Meet other community development needs having an urgency because existing conditions pose a serious and immediate threat to the health or welfare of the community where other financial resources are not available to meet such needs (known as “Urgent Need”).

  

  Some activities are presumed to meet a national objective (e.g., general/non-project specific planning for local governments; program administrative costs). In most cases, however, CDBG-DR grantees must demonstrate that CDBG-DR assisted activities comply with regulatory criteria to demonstrate that they meet a national objective. The timing of documenting that an activity will meet a national objective is an important consideration. Compliance with national objectives are encouraged to be documented upfront, when possible. However, some national objectives can be documented over time. For example, it is likely that the future occupants of a rental rehabilitation activity cannot be identified up-front. Compliance with the LMI housing national objective requires that 51 percent of the occupants be LMI households, will require documentation demonstrating compliance during the leasing period until the national objective is met.

  When using the Urgent Need national objective for CDBG-DR activities, the requirements can be different from the regulatory criteria in CDBG depending on when the activity is included in the grantee’s Action Plan. The Consolidated Notice describes a waiver and alternative requirement for the use of the urgent need national objective during a 36-month period after the applicability date of the applicable Allocation Announcement Notice. This waiver and alternative requirement recognize how a CDBG-DR grantee is limited to spending funds for the benefit of areas that have received a presidential disaster declaration and the need to expedite the grantee’s recovery. When a grantee describes the urgency of the situation in its unmet needs assessment; identifies the program and activity to use urgent need; and documents how the activity responds to the urgency, type, scale, and location of the disaster-related impact within the allotted period, the grantee will not need to submit the documentation required under section 104(b)(3) of the HCDA. 
  

  
  To use this waiver within the 36-month period, a grantee should identify specific activities that will use Urgent Need to meet a national objective. The grantee is not required to identify the specific location of the activity to apply the waiver, but the grantee cannot apply Urgent Need to all activities within all programs. Urgent Need should not automatically be used when an activity does not meet the LMI requirements. Instead, a grantee should apply the Urgent Need national objective when there is a sense of urgency to complete an activity so that a community can recover. For example, reconstruction of a grocery store that was damaged by the disaster and located in an underserved area that has limited access to affordable and nutritious food. In this example, the residents might not meet the 51% threshold required to use the LMA national objective, but other factors demonstrate the urgency of the situation.

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  Unmet recovery needs change over time as resources from different sources have been expended. After 36 months, when the waiver and alternative requirement has expired, the CDBG-DR grantees should follow the criteria identified in section 104(b)(3) of the HCDA for any new activities added to the action plan without impeding the recovery. Grantees may request an extension for the established waiver and alternative requirement if the grantee’s request is accompanied by data and can demonstrate that following the criteria identified in section 104(b)(3) of the HCDA would impede recovery.
  
  Please note, the Consolidated Notice waives section 104(b)(3) of the HCDA in its entirety, where previous waivers for CDBG-DR grantees may have only temporarily waived the documentation requirements.