The Partners have shared their voice on the much-needed updated to the CDBG Section 108 program and the I-CDBG programs. PRT wants the Housing and Urban Development Department to hear our points clearly.
Please do not lock out our communities before they apply. We want the CDBG Program at large to re-consider the accessibility of the Section 108 Program, and all other CDBG Programs, especially for rural and Native communities that experience persistent poverty. Our communities have the highest need and would have the most impact from these dollars, but it’s nearly impossible to apply for and receive funding in our regions due to restrictive eligible communities and projects.
Apply all of the proposed changes to the entire CDBG system, not just the Section 108 Program. Many of the short-comings that the proposed rule aims to address are system-wide and would benefit communities across several sectors if these programmatic updates were to be implemented.
Increase accountability and transparency by following the FHFA’s lead in formally adopting the definition of the “colonia Census Tract.” Having a uniform definition across all federal agencies will allow more accurate representation of data for these communities and show a clear picture of what dollars are flowing, how many, and from where.
Decrease burden on states to pledge funds to secure CDBG Sect. 108 loans. In many of PRT regions, communities more often than not fall into the non-entitlement category. If 6 states in Communities Unlimited’s footprint provided loan guarantees for non-entitlement communities, an additional $758 million would be unlocked.
Read more about our main points in our full comment letter here.