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Res No 118-11-13432RESOLUTION NO. 118 -1 1 -13 4 3 2 A resolution authorizing the City Manager to enter into an agreement with Miami -Dade County for Urban County Qualification for Participation in the Community Development Block Grant (CDBG), Home Investment Partnerships (HOME) and Emergency Shelter Grant (ESG) Programs for Fiscal Year 2012, 2013 and 2014. WHEREAS, the City of South Miami desires to participate in Miami -Dade County's Urban County Community Development Block Grant (CDBG), Home Investment Partnerships and Emergency Shelter Grant programs for the years 2012, 2013, and 2014 ( "the Agreement "); and WHEREAS, the Community Development Block Grant ( "CDBG ") Program is authorized by the Housing and Community Development Act of 1974, as amended, with the primary objective of promoting and development of viable urban communities; and WHEREAS, the Home Investment Partnerships Program ( "HOME ") is authorized under Title II of the Cranston - Gonzalez National Affordable Housing Act, as amended. Program regulations are at 24 CFR Part 92; and WHEREAS, the Emergency Shelter Grant ( "ESG ") program is authorized by the McKinney -Vento Homeless Assistance Act, as amended. Program regulations are at 24 CFR Part 576; and WHEREAS, the City desires to participate in the CDBG, HOME and ESG programs as part of the County's Entitlement jurisdiction; and WHEREAS, the County is desirous of the City participating in the CDBG, HOME and ESG programs as part of the County's Entitlement jurisdiction; and WHEREAS, it is mutually beneficial to the City and the County for the County to administer and execute the provisions of the Agreement; and WHEREAS, the U.S. Department of Housing and Urban Development (HUD) has indicated that the County and City may cooperate as an Urban County Joint Entitlement Recipient in administration of CDBG, HOME, and ESG; and WHEREAS, County and City are required to execute a cooperation agreement, or renew an existing cooperation agreement, for the City's participation in the County's jurisdiction for CDBG, HOME and ESG funds for each three -year qualification period; and NOW, THEREFORE, BE IT RESOLVED BY THE MAYOR AND CITY COMMISSION OF THE CITY OF SOUTH MIAMI, FLORIDA THAT: Section 1. The City shall remain in the Miami -Dade County's Urban County Community Development programs for 2012, 2013, and 2014. Pg. 2 of Res. No. 118 -11 -13432 Section 2. The City Manager is authorized to execute the Urban Qualification Cooperation Agreement for the Miami -Dade County Community Development Block Grant, Home Investment Partnerships Program Funds and Emergency Shelter Grant Programs for fiscal years 2012, 2013 and 2014. Section 3. This resolution shall be effective immediately upon being approved. PASSED AND ADOPTED this 26 day of JulY , 2011 ATTEST: APPROVED: IL CITY CLE MAYOR Cornmission Vote: 4-0 READ AND AP OVED AS TO FORM Mayor Stoddard: absent AND SU NCY: / j Vice Mayor Newman: Yea y Commissioner Palmer: Yea Commissioner Beasley: Yea Commissioner Harris: Yea �� CIT A ORN j I South Miami A - ftedcaCity CITY OF SOUTH MIAMI 11111.7 OFFICE OF THE CITY MANAGER INTER- OFFICE MEMORANDUM 2001 To: The Honorable Mayor & Members of the City Commission Via: Hector Mirabile, Ph.D., City Manager 1 From: Jennifer Korth, Grants and Sustainable Initiatives Administrator Department of Grants & Sustainable Initiatives Date: July 26, 2011 Agenda Item No.: _I A resolution authorizing the City Manager to enter into an agreement with Miami - Dade County for Urban County Qualification for Participation in the Community Subject: Development Block Grant (CDBG), Home Investment Partnerships (HOME) and Emergency Shelter Grant (ESG) Programs for Fiscal Year 2012, 2013 and 2014. The City of South Miami has participated in the Miami -Dade County's configuration for the CDBG, HOME, and ESG programs in previous three -year Background: qualification periods. Under this program the City of South Miami has had the opportunity to receive grant funding for many projects, including the following open contracts: a) SW 66`h Street Improvements, Phase II, b) SW 641h Street Improvements, c) CRA Street Lighting Project, d) Murray Park Pool. Expense: $0.00 Account: N/A 1. Proposed Resolution 2. Letter dated July S, 2011 to Mayor Stoddard, Ph.D. from Rowena Crawford, Assistant Director of Housing and Community Development, Miami -Dade County 3. Urban Qualification Cooperation Agreement Attachments: 4. Letter dated June 30, 2011 from the City Manager Hector Mirabile, Ph.D. to Maria R. Ortiz, Director of Community Planning and Development Division, Miami -Dade County S. Letter dated June 21, 2011 to Mayor Stoddard, Ph.D. from Rowena Crawford, Assistant Director of Housing and Community Development, Miami -Dade County 6. US HUD Urban County Qualification CPD -11 -02 Notice MIAMI -pDADE Wamidade.gov July 5, 2011 The Honorable Phillip K. Stoddar, PhD, Mayor City of South Miami 6130 Sunset Drive South Miami, FI, 33143 Housing and Community Development 701 N.W. I st Court, 14th Floor Miami, Florida 33136 T786-469-2100 F786-469-2236 Re: Urban County Qualification Cooperation Agreement for participation In the Community Development Block Grant (CDBG) Program for Fiscal Year 2012 - 2014 Dear Mayor Stoddar: This is a follow -up to the Miami -Dade County Department of Housing and Community Development (DHCD) recent correspondence pertaining to The Housing and Community Development Act of 1974 requiring that every three years, all counties participating in the U.S. Department of Housing and Urban Development (US HUD), Community Development Block Grant (CDBG), Home Investment Partnerships (HOME) and Emergency Solutions Grant (ESG) programs must undergo US HUD's Urban County Qualification process, which includes inviting local jurisdictions to participate. We have received your confirmation to opt -into Miami -Dade County's Urban Qualification process and to participate in its federal CDBG, HOME and ESG Programs. Your jurisdiction's election to participate requires the execution of a Cooperation Agreement with the County, approval of the Cooperation Agreement by your governing body, execution of the Cooperation Agreement by the chief executive officer, and other documents and certifications required by US HUD. For your reference, a copy of the US HUD Urban County Qualification CPD -11 -02 Notice (4//2812011 through 4/2812012) is attached. Please execute the agreement and return the document to DHCD by Friday, July 8, 2011. As a reminder, in reviewing the Qualification Notice, please note that if the City of South Miami elects to be Included in Miami -Dade County's configuration, your municipality will not be eligible to apply for grants under the State Small Cities or the federal CDBG or HOME programs. As part of the urban county configuration, the City of South Miami may receive an allocation from Miami - Dade County through the County's annual competitive Request For Application (RFA) process. Please address your notifications to the following: Ms. Maria R. Ortiz, Director Community Planning and Development Division U.S. Department of Housing and Urban Development Region IV, Miami Field Office Brickell Plaza Federal Building 909 SE 1�tAvenue, Room 500 Miami, Florida 33131 -3042 Miami -Dade County Urban Qualification Cooperation Agreement Page 2 Mrs. Rowena Crawford Assistant Director Miami -Dade County Department of Housin and Community Development 701 N.W. 1$t Court, 14 Floor Miami, FL 33136 If you need further information regarding this request or on the Urban County Qualification Process, please contact Rickert Glasgow, Manager, Community Planning and Outreach Division, at (786) 469 -2130 or my office at (786) 469 -2100. Sincerely, Rowena Crawford Assistant Director Enclosures: Cooperation Agreement CPD Notice — 11 -02 cc: Howard Piper, Special Assistant to the County Manager Rickert Glasgow, Manager, Community Planning and Outreach Division, DHCD Resolution Number Awarded Amount $ URBAN QUALIFICATION COOPERATION AGREEMENT FOR THE MIAMI -DADE COUNTY COMMUNITY DEVELOPMENT BLOCK GRANT AND HOME INVESTMENT PARTNERSHIPS PROGRAM FUNDS FOR FISCAL YEARS 2012, 2093 AND 2014 . BETWEEN MIAMI -DADE COUNTY AND CITY OF SOUTH MIAMI This Agreement (hereinafter referred to as "Agreement" or "Contract "), by and between Miami -Dade County, a political subdivision of the State of Florida through its Department of Housing and Community Development hereinafter referred to as "DHCD" and having its principal offices at 701 N.W. 1 Court, 14 Floor,'Miami, Florida 33936, hereinafter referred to as "County", and CLty of South Miami, hereinafter referred to as "City" and having offices at 6130 Sunset Drive, South Miami, Florida 33143 and telephone number of 305 - 663 -6340, collectively referred to as the "Parties ", states, conditions and covenants for the participation of City in the - Community Development Block Grant, Home Investment Partnerships and Emergency Shelter Grant programs, which are administered by the Department of Housing and Urban Development ( "HUD "), as part of the County's jurisdiction. WHEREAS, the Home Rule Charter authorizes Miami -Dade County to provide for the uniform health and welfare of the residents throughout the County; and WHEREAS, the Community Development Block Grant ( "CDBG ") Program is authorized by the Housing and Community Development Act of 1974, as amended, with the primary objective of promoting and development of viable urban communities. Program regulations are at 24 CFR Part 570; and WHEREAS, -the Home Investment Partnerships program ( "HOME") Is authorized under Title it of the Cranston - Gonzalez National Affordable Housing Act, as amended. Program regulations are at 24 CFR Part 92; and WHEREAS, the Emergency Shelter Grant ( "ESG ") program is authorized by the McKinney -Vento Homeless Assistance Act, as amended. Program regulations are at 24 CFR Part 576. WHEREAS, the CDBG, HOME and ESG programs shall collectively be referred to as the "Federal Funds'; and WHEREAS, the City desires to participate in the CDBG, HOME and ESG programs as a participating municipality in the County's jurisdiction; and WHEREAS, the County is desirous of the City participating in the CDBG, HOME and ESG programs as part of the County's Entitlement jurisdiction; and WHEREAS, it is mutually beneficial to each of the Parties hereto for the County to administer and execute the provisions of this Agreement in accordance with the terms and conditions hereinafter provided and subject to local ordinances and state and federal law; and WHEREAS, the U.S. Department of Housing and Urban Development (HUD) has indicated that the County and City may cooperate as an Urban County Joint Entitlement Recipient in administration of CDBG, HOME and ESG; and WHEREAS, County and City are required to execute a cooperation agreement, or renew an existing cooperation agreement, for the City's participation in the County's jurisdiction for Federal Funds for each three -year qualification period ( "Qualification Period "); and WHEREAS, the governing bodies of the County and the City have authorized the execution of this Agreement by the Chief Executive Officer of the County and City, respectively, or where not approved prior to being signed by the Chief Executive Officer of the County and City, respectively, this Agreement shall be contingent upon ratification by the governing bodies of the County and the City, respectively, and evidence of such ratification shall be attached herewith; and WHEREAS, this Agreement shall be accompanied by a legal opinion from the County's counsel that the terms and provisions of this Agreement are fully authorized under State and local law and that the Agreement provides full legal authority for the County; and WHEREAS, the County intends to further include within the Urban County the City of South Miami NOW, THEREFORE, IT IS AGREED AS FOLLOWS: 1. The City, by executing this Agreement, agrees that: a. City may receive an allocation under the CDBG and HOME Programs through the County's, Request for Application Process. The County does not receive a HOME formula allocation, City cannot form a HOME consortium with other local governments. (Note: this does not preclude the County or the City from applying for State HOME funds.); and b. City may not apply for grants from appropriations under the State CDBG Program for the fiscal years City participates in the County's CDBG program; and c. City may receive an allocation under the ESG program only through the County, However, City may apply to the State for ESG funds, if the State allows. 2. This Agreement shall cover -the County Qualification Period for Fiscal Years 2012, 2013, and 2014 for which the County is to qualify to receive Federal Funds. This Agreement shall remain in effect until the Federal Funds and program income received (with respect to the three -year qualification period and any successive qualification periods pursuant to automatic renewal of this Agreement) are expended and the funded activates completed, and the County and the City cannot terminate or withdraw from this Agreement while the Agreement remains in effect. 3. This Agreement may be automatically renewed for successive three -year Qualification periods at the discretion of the County unless the County or the City provides written notice that it elects not to extend City's participation for the new Qualification Period. The City and County agree that a copy of such notice shall be timely sent to the HUD Field Office. 4. By the date specified in the HUD's Urban County Qualification Notice for each Qualification Period, the County will notify the City in writing of its right not to participate. A copy of the County's notification to City shall be sent to the HUD Field Office by the date specified in the Urban County Qualification schedule located in any applicable Urban County Qualification Notice for a Qualification Period. b. The Parties agree that they will timely execute any amendments to the Agreement necessary to comply witti the requirements for cooperation agreements set forth in the Urban. County Qualification Notice, attached as referenced (Exhibit A), for any Qualification Period governed by this Agreement. The Parties further agree that any amendment so executed will be timely submitted to HUD as required by the Urban County Qualification CPD Notice 11 -02 (04/28/11 - 04/28/2012). (See Attachment A, Section IV.E; Documents To Be Submitted To HUD). Failure to comply with the requirements of this section will void the automatic renewal for the applicable qualification period. z 6. The County and City agree to cooperate to undertake, or assist in undertaking, community renewal and lower- income housing assistance activities. 7. The County and .City shall take all actions necessary to assure compliance with the County's certification required by Section 104(b) if Title I of the Housing and Urban Development Act of 1974, as amended, including Title Vi of the Civil Rights Act of 1964, the Fair Housing Act, Section 109 of Title I of the Housing and Community Development Act of 1974, and other applicable laws. 8. under no circumstances shall the Federal Funds be used for activities in, or in support of, any participating municipality, including City, that does not affirmatively further fair housing within its own jurisdiction or that impedes the County's actions to comply with the County's fair housing certification. 9. The City acknowledges that the County has final responsibility and authority for selecting activities to fund with the Federal Funds and submitting the Consolidated Plan to HUD. The City agrees that during the term of this Agreement, the City will fully support the implementation of the County's Consolidated Plan and any amendments. 10. -The City affirms that it has adopted and is enforcing: a. A policy prohibiting the use of excessive force by law enforcement agencies within its jurisdiction against any individuals engaged in non - violent civil rights demonstrations, and b. A policy of enforcing applicable State and local Laws against physically barring entrance to or exit from a facility or location which Is the subject of such non - violent civil rights demonstration within the City. 11. Pursuant to 24 CFR 570.503, the City is subject to the same requirements'applicable to subrecipients, including the requirement of a written agreement as described in 24 CFR 570.503. 12. The County shall take the final responsibility and assume all the obligation of application for assistance under the provisions of the Housing and Community Development Act of 1974 and subsequent amendments, including the analysis of needs, the setting of objectives, the development of a HUD and Consolidated Plan, the HUD Consolidated Plan and Action Plans, and any other documents, assurances, or certificates as required by HUD, subject to change in legislation or regulations. 13. Funds for housing and community development activities shall be expended in a manner to reflect the needs of low to moderate - income groups pursuant to the Housing and Community Development Act 1974, as amended. 14. All records of the County or City related to this Agreement and any projects undertaken pursuant thereto shall, upon reasonable notice, be available for inspection by HUD, County and /or City auditors during the normal business hours. 15. This agreement shall be binding upon the Parties hereto and their successors and assigns. 16. The City and the County acknowledge that it may be necessary to dispose of real property that was originally acquired or improved in whole or in part using Federal Funds, The City agrees that it shall notify the County within thirty (30) days regarding any proposed modification or change in the use of real property form that planned at the time of acquisition or improvement, including disposition. The City acknowledges that federal regulations may require a public hearing or other process prior to modifying, changing the use or disposing of such real property. 17. Indemnification. The County shall not assume any liability for the acts, omissions to act or negligence of the City, its agents, servants or employees; nor shall the City exclude liability for its own acts, omissions to act, or negligence arising out of the City's performance pursuant to this Agreement. The City shall indemnify and hold harmless the County and its officers, employees, agents and instrumentalities from any and all liability, losses or damages, including attorneys' fees and costs of defense, which the County or its officers, employees, agents or instrumentalities may incur as a result of claims, demands, suits, causes of actions or proceedings of any kind or nature arising out of, relating to or resulting from the performance of this Agreement by the City or its employees, agents, servants, partners principals or subcontractors. The City shall pay all claims and losses in connection therewith and shall investigate and defend all claims, suits or actions of any kind or nature in the name of the County, where applicable, including appellate proceedings, and shall pay all costs, judgments, and attorney's fees which may issue thereon. The City expressly understands and agrees that any insurance protection required by this Agreement or otherwise provided by the City shall in no way limit the responsibility to indemnify, keep and save harmless and defend the County or its officers, employees, agents and instrumentalities as herein provided. Nothing herein is intended to serve as a waiver of sovereign immunity by the County or City nor shall anything herein be construed as consent by the County to be sued by third parties in any matter arising out of this Agreement. The provisions of this section survive the termination or expiration of this Agreement. Nothing herein shall be construed to extend any party's liability beyond that provided in section 768.28, Florida Statutes. 59 IN* WITNESS THEREOF, the parties hereto have caused this thiryy- -eight (38) pa a contract to be executed by their undersigned officials as duly authorized, this �y day of,, 201V AWARDEE: City of South Miami of BY: NAME: �h1I t• S'h�C�C�G.Y� TITLE: Mavor DATE: s t APPROVE TO FORM: BY- NAME: TITLE: County At orn v DATE: MIAMI -DA BY: NAME:_ZW1 1jz� TITLE:: 3V TITL Corr Passed, Adopted and approved this `u day of42011 ATTEST Maria M. Menendez BY: (Signature) Type or rin ame City Clerk AGREEMENT IS NOT VALID UNTIL SIGN 5 CITY OF SOUTH 1: P, /City anager South Miami 47 Mfr -. ,r ;ey All- Amerieo City CITY MANAGER'S OFFICE '4 x June 30, 2011 Certified Mail f#: 7010 3090 0001 5617 4488 Ms. Maria R. Ortiz, Director Community Planning and Development Division U.S. Department of Housing and Urban Development Region IV, Miami Field Office Brickell Plaza Federal Building 909 SE I st Avenue, Room 500 Miami,. Florida .33.13.1. -3042 RE: Urban County Qualification for Participation in the Community Development Block Grant (CDBG) Program for Fiscal Year 2012 — 2014 Dear Ms. Ortiz; The City of South Miami elects to participate in the Miami -Dade County's configuration for the Community Development Block Grant (CDBG) Program for Fiscal Year 2012 - 2014. Please do not hesitate to contact me if you have questions or need additional information. Sincerely, Hector Mirabile, Ph.D. City Manager 7D10 3090 0001 Dl k Co gn in 3 a N Spy M 3cno 9� w n' O ow —n< 3G U'. —7°m Q� 0 0 ° C o N � o 0 0� <n 5617 4488 N 0- 2k „� R N �o (G � a rw June 21, 2011 Honorable Mayor Phillip K. Stoddar, Phd. City of South Miami 6130 Sunset Drive South Miami, Florida 33143 Housing and Community Development 701 N.W. 1 st Court, 14th Floor Miami, Florida 33136 T786-469-2100 F786-469-2236 Re; Urban County Qualification for Participation in the Community Development Block Grant (CDBG) Program for Fiscal Year 2012 - 2014 Dear Mayor Phillip K. Stoddar, Phd.: The Housing and Community Development Act of 1974 requires that every three years, all counties participating in the U.S. Department of Housing and Urban Development (US HUD) Community Development Block Grant (CDBG) and Home Investment Partnerships (HOME) programs must undergo US HUD's Urban County Qualification process. This process, which involves counties working with units of general local government eligible to participate, (i.e. a municipality which is not entitled to receive its own federal or state entitlement), began on April 22, 2011 and will end on September 21, 2011. Miami -Dade County (the County) is currently qualified as an urban county and scheduled to re- qualify for the period that begins January 1, 2012 and ends December 31, 2014. This letter formally request that by June 24, 2011, City of South Miami indicate in writing, its intent to participate in Miami -Dade County's configuration. An election to participate will require the execution of a Cooperation Agreement with the County, approval of your governing body, a legal opinion, and other documents and certifications required by HUD as set forth in the attached CPD -11 -02 Notice. This agreement will be sent to you under separate cover. For your reference, a copy of the US HUD Urban County Qualification CPD -11 -02 Notice (4128/2011 thru 4/28/2012) is attached. As you review the Qualification Notice, please note that if the City of South Miami elects to be included in Miami -Dade County's configuration, your municipality will not be eligible to apply for grants under the State Small Cities or the Federal CDBG or HOME programs. As part of the urban county configuration, City of South Miami may receive an allocation from Miami -Dade County through the County's annual competitive Request - For - Application (RFA) process. Please address your notifications to the following: Ms. Maria R. Ortiz, Director Community Planning and Development Division U.S. Department of Housing and Urban Development Region IV, Miami Field Office Brickell Plaza Federal Building 909 SE 1St Avenue, Room 500 Miami, Florida 33131 -3042 1 Miami -Cade County Urban Country Qualification Mrs. Rowena Crawford, Assistant Director Miami -Dade County Department of Housing and Community Development 701 N.W. 1St Court, 14th Floor Miami, FL 33136 if you need further information regarding this request or on the Urban County Qualification Process, please contact Rickert Glasgow, Manager, Community Planning and Outreach Division, at (786) 469 -2100. Sincerely, Rowena r wford Assistant Director Attachments (CPD Notice - 11 -02) ATTACHMENT A Q��P.MEMt pFyOu * } U.S. Department of Housing and Urban Development Community Planning and Development Special Attention of All Regional Administrators All CPD Division Directors All CDBG Grantees Notice: CPD -11 -02 Issued: April 28, 2011 Expires: April 28, 2012 Supersedes: CPD Notice 10 -02 SUBJECT: Instructions for Urban County Qualification for Participation in the Community Development Block Grant (CDBG) Program for Fiscal Years (FYs) 2012 -2014 INTRODUCTION This Notice establishes requirements, procedures and deadlines to be followed in the urban county qualification process for FYs 2012 -2014. Information concerning specific considerations and responsibilities for urban counties is also provided. HUD Field Offices and urban counties are expected to adhere to the deadlines in this Notice. This Notice provides guidance for counties wishing to qualify or requalify for entitlement status as urban counties, as well as for existing urban counties that wish to include previously nonparticipating communities. Please send copies of this Notice to all presently qualified urban counties, to each county that can qualify for the first time or requalify for FYs 2012- 2014, and to each state administering the State CDBG program which includes a potentially eligible urban county. If you are notified of one or more new potential urban counties, each should be provided a copy of this Notice. This Notice includes six attachments which contain listings of: Attachment A, all currently qualified urban counties; Attachment B, counties that can potentially qualify for the first time or requalify this qualification period (2012- 2014); Attachment C, counties scheduled to qualify or requalify in FY 2012 for FY 2013-2015; Attachment D, counties scheduled to qualify or requalify in FY 2013 for FY 2014 -2016; Attachment E, currently qualified urban counties that can add nonparticipating units of government for the remaining one or two years of their qualification period; and Attachment F, list of counties that may qualify as urban counties if metropolitan cities relinquish their status. Additions to Attachment B may be provided separately. The schedule for qualifying urban counties is coordinated with qualifying HOME consortia in order to be able to operate both the CDBG and HOME programs using the same urban county configurations. The CDBG urban county qualification process for the FY 2012- 2014 qualification period will start April 22, 2011, and run through September 21, 2011. This will provide HUD sufficient time before the September 30 deadline for FY 2012 funding under the HOME Program to notify counties that they qualify as urban counties under the CDBG Program. Urban county worksheets will be accessible via CPD's Grants Management Process (GMP) system. The CPD Systems Development and Evaluation Division will provide guidance on completing, submitting and verifying urban county qualification data in the GMP system. New requirements were added in 2008 to the urban county qualification process concerning notification and submission of documents to HUD Headquarters. Jurisdictions that are qualifying as an urban county for the first time must submit all required documents outlined in Section IV to the Entitlement Communities Division in HUD Headquarters in addition to their local HUD offices (see Section IV for details). In addition, if new jurisdictions are seeking to qualify as urban counties because they contain metropolitan cities willing to relinquish their entitlement status, the Entitlement Communities Division in HUD Headquarters should be notified as soon as possible, but no later than two weeks after the jurisdictions notify the Field Office of their intent to qualify as an urban county (see Section VIII for details). Section IX was changed in 2008 to further clarify the actions required by HUD Field Office Counsel to complete Determinations of Essential Powers for new and requalifying urban counties. Policy questions from Field Offices related to this Notice should be directed to the Entitlement Communities Division at (202) 708 -1577. Data questions should be directed to the Systems Development and Evaluation Division at (202) 708 -0790. Requests for deadline extensions should be directed to the Entitlement Communities Division. The TTY number for both divisions is (202) 708 -2565. These are not toll -free numbers. The information collection requirements contained in this notice have been approved by the Office of Management and Budget (OMB) under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 -3520) and assigned OMB control number 2506 -0170, which expires 2/29/12. In accordance with the Paperwork Reduction Act, HUD may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection displays a currently valid OMB control number. DGBE: Distribution: W -3 -1 ATTACHMENT A TABLE OF CONTENTS I. GENERAL REQUIREMENTS .......................................................... ............................... 1 A. Threshold ................................................................................ ............................... 1 B. Consolidated Plan Requirements ............................................. ............................... 1 C. Consolidated Plan Requirements Where the Urban County is in a HOME Consortium.............................................................................. ............................... 2 D. Synchronization of Urban County and HOME Qualification Periods .............. 2 II. QUALIFICATION SCHEDULE ...................................... ..............................2 III. QUALIFICATION ACTIONS TO BE TAKEN BY COUNTY ......... ............................... 5 A. Cooperation Agreements /Amendments .................................. ............................... 5 B. Notification of Opportunity to be Excluded .............................. ..............................6 C. Notification of Opportunity to be Included ............................ ..............................7 D. Notification of Split Places .................. ............................... ................. .................. 7 E. Notification of Opportunity to Terminate Agreement ............ ............................... 8 IV. DOCUMENTS TO BE SUBMITTED TO HUD ........ ............................... V. COOPERATION AGREEMENTS ..................................................... ............................... 9 VI. PERIOD OF QUALIFICATION ....................................................... ............................... 12 A. General ..................................................................................... .............................12 B. Retaining Urban County Classification ................................. ............................... 13 VII. URBAN COUNTY PROGRAM RESPONSIBILITIES ................... ............................... 13 VIII. SPECIAL CONSIDERATIONS ........................................................ ............................... 14 A. Metropolitan City/Urban County Joint Recipients ................ ............................... 14 B. Subrecipient Agreements ....................................................... ............................... 15 C. Ineligibility for State and Small Cities CDBG Program ........ ............................... 15 D. Eligibility for a HOME Consortium ...................................... ............................... 15 E. Counties with Potential New Metropolitan Cities .................... .............................16 IX. DETERMINATIONS OF ESSENTIAL POWERS ............ .............................16 Attachments A — All Currently Qualified Urban Counties Attachment B -- Counties Scheduled to Requalify in 2011 for FYs 2012 -2014 Attachment C - Counties Scheduled to Requalify in 2012 for FYs 2013 -2015 Attachment D - Counties Scheduled to Requalify in 2013 for FYs 2014 -2016 Attachment E — Counties Qualified Through 2012 or 2013 That Contain Non-Participating Communities Attachment F — List of Counties That May Qualify as Urban Counties if Metropolitan Cities Relinquish Their Status COMMUNITY DEVELOPMENT BLOCK GRANT URBAN COUNTY QUALIFICATION Fiscal Years 2012 -2014 In accordance with 24 CPR 570.307(a) of the Community Development Block Grant (CDBG) regulations, the information below explains HUD's process for qualifying and requalifying urban counties for purposes of the CDBG program. 1. GENERAL REQUIREMENTS A. Threshold In order to be entitled to receive CDBG funds as an urban county, a county must qualify as an urban county under one of the following thresholds: 1. Have a total combined population of 200,000 or more (excluding metropolitan cities) from the unincorporated areas and participating incorporated areas; or 2. Have a total combined population of at least 100,000 but less than 200,000 from the unincorporated areas and participating incorporated areas, provided that, in the aggregate, those areas include the majority of persons of low and moderate income that reside in the county (outside of any metropolitan cities). Under this provision the county itself must still have a potential combined population of 200,000 (excluding metropolitan cities); or 3. Meet specific requirements of Sec. 102(a)(6)(C) or (D) of Title I of the Housing and Community Development Act of 1974, as amended. HUD must make a review to determine that an urban county possesses essential community development and housing assistance powers in any unincorporated areas that are not units of general local government (UGLGs). HUD must also review all of the UGLGs within the county to determine those, if any, in which the county lacks such powers. The county must enter into cooperation agreements with any such units of local government that are to become part of the urban county. Such agreements would bind an UGLG to cooperate in the use of its powers in carrying out essential activities in accordance with the urban county's program. See Section IX for additional information on Determinations of Essential Powers. B. Consolidated Plan Requirements In order to receive an Entitlement Grant in FY 2012, an urban county must have an approved Consolidated Plan (pursuant to 24 CFR 570.302 and Part 91). This includes urban counties newly qualifying during this qualification period; urban counties that continue to include the same communities previously included in the urban county; and those urban counties that are amending their urban county configurations to add communities that chose not to participate previously. Where an urban county enters into a joint agreement with a metropolitan city for CDBG purposes, a Consolidated Plan is submitted by the urban county to cover both governmental entities. Pursuant to 24 CFR Part 91, submission of a jurisdiction's Consolidated Plan may occur no earlier than November 15, and no later than August 16, of the Program Year for which CDBG, HOME, Emergency Shelter Grants (ESG) and Housing Opportunities for Persons With AIDS (HOPWA) funds are appropriated to cover the Federal fiscal period of October 1, 2011, through September 30, 2012. An urban county's failure to submit its Consolidated Plan by August 16, 2011, will automatically result in a loss of CDBG funds for the 2012 program year (24 CFR 570.304(c)(1)). The Consolidated Plan must meet all requirements of 24 CFR Part 91, including all required certifications. C. Consolidated Plan. Requirements Where the Urban County is in a HOME Consortium Where UGLGs form a "consortium" to receive HOME funding, the consortium submits the Consolidated Plan for the entire geographic area encompassed by the consortium (24 CFR 91.400). Therefore, if an urban county is a member of a HOME consortium, the consortium submits the Consolidated Plan, and the urban county, like all other CDBG entitlement grantees in the consortium, is only required to submit its own non- housing Community Development plan (24 CFR 91.215(f)), an Action Plan (24 CFR 91.220) and the required Certifications (24 CFR 91.225(a) and (b); 91.425 (a) and (b)), as part of the consortium's Consolidated Plan. If an urban county has a CDBG joint agreement with a metropolitan city, they must form a HOME consortium to become one entity for HOME purposes (For additional information on the requirements for consortia agreements, see 24 CFR 92.101 and the Notice of Procedures for Designation of Consortia as a Participating Jurisdiction for the HOME Program (CPD -08-01)). D. Synchronization of Urban County and HOME Qualification Periods The CDBG urban county's and HOME consortium's qualification periods are for three successive years. If a member urban county's CDBG three -year cycle is not the same as the HOME consortium's, the consortium may elect a qualification period shorter than three years to get in sync with the urban county's CDBG three -year qualification cycle, as permitted in 24 CFR 92.101(e). II. QUALIFICATION SCHEDULE The following schedule will govern the procedure for urban county qualification for the three -year qualification cycle of FYs 2012 -2014. Unless noted otherwise, deadlines may only be extended by prior written authorization from Headquarters. Deadlines in paragraphs D, E, G, and I may be extended by the Field Office as specified below. However, no extension may be granted by the Field Office if it would have the effect of extending a subsequent deadline that the Field Office is not authorized to extend. A. By May 13, 2011, the HUD Field Office shall notify counties that may seek to qualify or requalify as an urban county of HUD's Determination of Essential Powers (see Section IX) as certified by the Field Office Counsel (see Attachment B, Counties Scheduled to Qualify or Requalify in 2011 for the 2012 -2014 Qualification Period). B. By May 13, 2011, counties must notify split places of their options for exclusion from or participation in the urban county (see Attachment B and Section 111, paragraph D, for an explanation of split places). C. By May 13, 2011, counties must notify each included unit of general local government, where the county is authorized to undertake essential community development and housing assistance activities without the consent of the governing body of the locality, of its right to elect to be excluded from the urban county, and the date by which it must make such election (see Attachment B and paragraph E, below). Included units of government must also be notified that they are not eligible to apply for grants under the State CDBG program while they are part of the urban county, and that, in becoming a part of the urban county, they automatically participate in the HOME and ESG programs if the urban county receives HOME and ESG funding, respectively. Urban counties do not receive a direct HOPWA formula allocation. Moreover, while they may only receive a formula allocation under the HOME and ESG Programs as part of the urban county, this does not preclude the urban county or a unit of government participating with the urban county from applying for HOME or ESG funds from the State, if the State allows. A county that is already qualified as an urban county for FY 2012 (see Attachment E, Counties Qualified through 2012 or 2013 that Contain Nonparticipating Communities) may elect to notify nonparticipating units of government that they now have an opportunity to join the urban county for the remainder of the urban county's qualification period (see paragraph H, below). D. By May, 13, 2011, any county which has executed cooperation agreements with no specified end date is required to notify affected participating units of government in writing that the agreement will automatically be renewed unless the unit of government notifies the county in writing by June 3, 2011, (see paragraph F, below) of its intent to terminate the agreement at the end of the current qualification period (see Attachment B). Any extension of this deadline must be authorized in writing by the Field Office. An extension of more than seven days requires the Field Office to notify the Entitlement Communities Division by telephone. E. By June 3, 2011, any included unit of general local government, where the county does not need the consent of its governing body to undertake essential community development and housing assistance activities, that elects to be excluded from an urban county must notify the county and its HUD Field Office, in writing, that it elects to be excluded. Any extension of this deadline must be authorized in writing by the Field Office. An extension of more than seven days requires notification of the Entitlement Communities Division by telephone. F. By June 3, 2011, any unit of government that has entered into a cooperation agreement with no specified end date with the county and elects not to continue participating with the county during the FY 2012 -20.14 qualification period must notify the county and its HUD Field Office in writing that it is terminating the agreement at the end of the current period. The county may allow additional time provided any such extension does not interfere with the county's ability to meet the deadline in paragraph J, below. G. By June 3, 2011, any unit of general local government that meets "metropolitan city" status for the first time and wishes to defer such status and remain part of the county, or to accept such status and become a joint recipient with the urban county, must notify the county and the HUD Field Office in writing that it elects to defer its metropolitan city status or to accept its status and join with the urban county in a joint agreement. Any metropolitan city that had deferred its status previously or had accepted its status and entered into a joint agreement with the urban county, and wishes to maintain the same relationship with the county for this next qualification period, must notify the county and the HUD Field Office in writing by this date. A potential metropolitan city that chooses to accept its entitlement status, but chooses not to enter into a joint agreement with the urban county, or a current metropolitan city that chooses not to maintain a joint agreement with the urban county, must also notify the urban county and the HUD Field Office by this date. Any extension of this deadline must be authorized in writing by the Field Office. An extension of more than seven days requires the Field Office to notify the Entitlement Communities Division by telephone. H. By June 3, 2011, any unit of general local government that is not currently participating in an urban county and chooses to participate for the remaining second or third year of the county's qualification period must notify the county and the HUD Field Office in writing that it elects to be included. The county may allow additional time provided any such extension does not interfere with the county's ability to meet the deadline in paragraph J, below. 1. By July 1, 2011, HUD Field Offices must notify CPD's Systems Development and Evaluation Division via e -mail whether a potential new metropolitan city elects to defer or accept its status (as discussed in paragraph G, above). By July 15, 2011, any county seeking to qualify as an urban county (see Attachment B) or to include any previously nonparticipating units of general local government into its configuration (see Attachment E) must submit to the appropriate HUD Field Office all qualification documentation described in Section 1V, Documents to be Submitted to HUD by County. Any extension of this deadline must be authorized in writing by the Field Office and should not interfere with the Field Office's ability to meet the deadline in paragraph K. The Entitlement Communities Division must be notified by telephone if an extension of more than seven days is needed. K. By July 29, 2011, Field Office Counsel should complete the reviews of all cooperation agreements and related authorizations and certify that each cooperation agreement meets the requirements of Section V, Cooperation Agreements. AU delay in completion of the review must not interfere with the Field Office's ability to meet the deadline in paragraph M. The Entitlement Communities Division should be notified by telephone of any delay in the Field Counsel's review. Note: If a county is using a renewable agreement and has submitted a legal opinion that the terms and conditions of the agreement continue to be authorized (see Section IV, paragraph E), review of such opinion by Field Office Counsel is optional. L. During mid to late June, Headquarters will post the urban county worksheets for each qualifying and requalifying urban county (listed on Attachment B) on the CPD Grants Management Process (GMP) system. All information on included units of government must be completed via GMP. Specific instructions for completing these electronic worksheets will be provided by the CPD Systems Development and Evaluation Division at the time they are posted on GMP. M. By August 12, 2011, Field Offices shall update and complete the form electronically for each qualifying or requalifying county. The revised worksheet must be sent to the appropriate county for verification of data (either via FAX, email, or regular mail). The Systems Development and Evaluation Division will have access to the completed worksheets in GMP. Field Offices shall also concurrently make available to the Systems Development and Evaluation Division (and each affected urban county) a memorandum that identifies any urban coon already qualified for FY 2011 that is adding apy new units of government, together with the names of the.newly included units of government (see Attachment E). THIS DEADLINE MAY NOT BE EXTENDED WITHOUT PRIOR WRITTEN AUTHORIZATION FROM THE ENTITLEMENT COMMUNITIES DIVISION. N. By September 912011 (or soon thereafter), Headquarters will complete its review of the urban county status worksheets and memoranda for those urban counties adding new units of government. The Field Offices will have access to the updated worksheets and, where necessary, an indication of any apparent discrepancies, problems or questions — all noted in GMP. The Field Office is to verify the data (on the website at http: //hudatwork.hud.gov /po /d/ field /Participation/index.cfzn) and notify the Systems Development and Evaluation Division within seven days if any problems exist. If there are no problems, Field Offices will notify each county seeking to qualify as an urban county of its urban county status for FY 2012 -2014 by September 21, 2011. III. QUALIFICATION ACTIONS TO BE TAKEN BY COUNTY The following actions are to be taken by the urban county: A. Cooperation Agreements /Amendments Urban counties that must enter into cooperation agreements or amendments, as appropriate, with the units of general local government located in whole or in part within the county, must submit to HUD executed cooperation agreements, together with evidence of authorization by the governing bodies of both parties (county and UGLG) executed by the proper officials in sufficient time to meet the deadline for submission indicated in the schedule (see Section V, Cooperation Agreements, paragraph A). Cooperation agreements must meet the standards in Section V of this Notice. B. Notification of Opportunity to Excluded Units of general local government in which counties have authority to carry out essential community development and housing activities without the consent of the local governing body are automatically included in the urban county unless they elect to be excluded at the time of qualification or requalification. Any county that has such units of general local government must notify each such unit that it may elect to be excluded from the urban county. The unit of government must be notified: 1. That if it chooses to remain with the urban county, it is ineligible to apply for grants under the State CDBG program while it is part of the urban county; 2. That if it chooses to remain with the urban county, it is also a participant in the HOME program if the urban county receives HOME funding and may only receive a formula allocation under the HOME Program as a part of the urban county, although this does not preclude the urban county or a unit of government within the urban county from applying to the State for HOME funds, if the State allows; and That if it chooses to remain with the urban county, it is also a participant in the ESG program if the urban county receives ESG funding and may only receive a formula allocation under the ESG Program as a part of the urban county, although this does not preclude the urban county or a unit of government within the urban county from applying to the State for ESG funds, if the State allows; and 4. That if it chooses to be excluded from the urban county, it must notify both the county and the HUD Field Office of its election to be excluded by the date specified in Section II, Qualification Schedule, paragraph E. Such election to be excluded will be effective for the entire three -year period for which the urban county qualifies, unless the excluded unit specifically elects to be included in a subsequent year for the remainder of the urban county's three -year qualification period. Where urban counties do not have the authority to carry out essential community development and housing activities without the consent of the unit(s) of general local government located therein, urban counties are required to have executed cooperation agreements with these units of government. C. Notification of Opportunity to be Included If a currently qualified urban county has one or more nonparticipating units of general local government (see Attachment E), the county may notify, in writing, any such unit of local government during the second or third year of the qualification period that the local government has the opportunity to be included for the remaining period of urban county qualification. This written notification must include the deadline for such election, and must state that the unit of general local government must notify the county and the HUD Field Office, in writing, of its official decision to be included. If cooperation agreements are necessary, the unit electing to be included in the county for the remainder of the qualification period must also execute, with the county, a cooperation agreement meeting the standards in Section V, Cooperation Agreements. The agreement must be received by the HUD Field Office by the date specified in Section II, Qualification Schedule, paragraph J. D. Notification of Split Places Counties seeking qualification as urban counties and having units of general local government with any population located only partly within the county must notify these units of their rights by the date provided in Section II, Qualification Schedule, paragraph B. Specifically, the county must provide the following notifications: 1. Where a split place is partly located within only one urban county, one of the following rules applies: a. If it is a split place in which the county has essential powers, the entire area of the split place will be included in the urban county for the urban county qualification period unless the split place has opted out; or b. If the split place can only be included in the county upon the execution of a cooperation agreement, the entire area of the split place will be included in the urban county for the urban county qualification period upon execution of such an agreement. 2. Where the split place is partially located within two or more urban counties, the split place may elect one of the following: a. to be excluded from all urban counties; b. to be entirely included in one urban county and excluded from all other such counties; or c. to participate as a part of more than one of the urban counties in which it is partially located provided that a single portion of the split place cannot be included in more than one entitled urban county at a time, and all parts of the split place are included in one of the urban counties. E. Notification of Opportunity to Terminate Agreement Urban counties that have agreements that will be automatically renewed at the end of the current qualification period unless action is taken by the unit of government to terminate the agreement must, by the date provided in Section 11, Qualification Schedule, paragraph D, notify such units that they can terminate the agreement and not participate during the 2012 -2014 qualification period. IV. DOCUMENTS TO BE SUBMITTED TO HUD Any county seeking to qualify as an urban county for FY 2012 -2014 or that wishes to exercise its option to include units of government that are not currently in the urban county's CDBG program must submit the following to the responsible HUD Field Office: A. A copy of the letter. that notified applicable units of general local government (and a list of applicable units of government) of their right to decide to be excluded from the urban county along with a copy of letters submitted to the county from any such units of general local government requesting exclusion (see Section III, Qualification Actions to Be Taken by County, paragraph B). This does not apply to an already qualified urban county adding communities. B. A copy of the letter from any unit of general local government joining an already qualified county that officially notifies the county of its election to be included (see Section III, paragraph C). C. Where applicable, a copy of the letter from: 1. Any city that may newly qualify as a metropolitan city but that seeks to defer that status, or 2. Any city currently deferring metropolitan city status that seeks to continue to defer such status. (See Section II, Qualification Schedule, paragraph G.) D. For a county that has cooperation agreements in effect that provide for automatic renewal, a copy of the letter sent by the county that notified affected units of government that the agreement will be renewed unless the county is notified by the unit of government to terminate the agreement, and a copy of any such letter from any unit(s) of govermnent requesting termination (see Section III, paragraph E). E. Where applicable, copies of fully executed cooperation agreements or amended agreements between the county and its included units of general local government, including any cooperation agreements from applicable units of general local government covered under Section 111, Qualification Actions to be Taken by County, paragraph C, and the opinions of county counsel and governing body authorizations required in Section V, Cooperation Agreements, paragraphs B and C. For a county that has cooperation agreements in effect that provide for automatic renewal of the urban county qualification period as provided under Section V, Cooperation Agreements, paragraph E, at the time of such automatic renewal, the documents to be submitted are: (1) a legal opinion from the county's counsel that the terms and provisions continue to be authorized under state and local law and that the agreement continues to provide full legal authority for the county; (2) copies of any executed amendments to automatically renewed cooperation agreements (if any); and, (3) if locally required, governing body authorizations. F. Any joint request(s) for inclusion of a metropolitan city as a part of the urban county as permitted by Section VIII, paragraph A, Metropolitan City/Urban County Joint Recipients, along with a copy of the required cooperation agreement(s). If either the urban county or the metropolitan city fall under the "exception criteria" at 24 CFR 570.208(a)(1)(ii) for activities that benefit low - and moderate - income residents of an area, the urban county must notify, in writing, the metropolitan city of the potential effects of such joint agreements on such activities. See Section VIII, paragraph A, for further clarification. All jurisdictions seeking to qualify as an urban county for the first time must ensure that all documents outlined in this Section that are submitted to the HUD Field Office are also submitted to the Entitlement Communities Division in HUD Headquarters for review. The original documents should be submitted to the HUD Field Office and the copies to HUD Headquarters. V. COOPERATION AGREEMENTS All cooperation agreements must meet the following standards in order to be found acceptable: A. The governing body of the county and the governing body of the cooperating unit of general local government shall authorize the agreement and the chief executive officer of each unit of general local government shall execute the agreement. B. The agreement must contain, or be accompanied by, a legal opinion from the county's counsel that the terms and provisions of the agreement are fully authorized under State and local law and that the agreement provides full legal authority for the county. Where the county does not have such authority, the legal opinion must state that the participating jurisdiction has the authority to undertake, or assist in undertaking, essential community renewal and lower income housing assistance activities. A mere certification by the county's counsel that the agreement is approved as to form is insufficient and unacceptable. C. The agreement must state that the agreement covers the CDBG Entitlement program and, where applicable, the HOME Investment Partnership (HOME) and Emergency Shelter Grants (ESG) Programs (i.e., where the urban county receives funding under the ESG program, or receives funding under the HOME program as an urban county or as a member of a HOME consortium). D. The agreement must state that, by executing the CDBG cooperation agreement, the included unit of general local government understands that it: 1. May not apply for grants from appropriations under the State CDBG Program for fiscal years during the period in which it participates in the urban county's CDBG program; and 2. May receive a formula allocation under the HOME Program only through the urban county. Thus, even if the urban county does not receive a HOME formula allocation, the participating unit of local government cannot form a HOME consortium with other local governments. (Note: This does not preclude the urban county or a unit of government participating with the urban county from applying to the State for HOME funds, if the state allows. An existing renewable agreement need not be amended to add this Note. It is included here only for purposes of clarification.); and May receive a formula allocation under the ESG Program only through the urban county. (Note: This does not preclude the urban county or a unit of government participating with the urban county from applying to the State for ESG finds, if the state allows. An existing renewable agreement need not be amended to add this Note. It is included here only for purposes of clarification.) E. The agreement must specify the three years covered by the urban county qualification period (e.g., Federal FYs 2012 - 2014), for which the urban county is to qualify to receive CDBG entitlement funding or, where applicable, specify the remaining one or two years of an existing urban county's qualification period. At the option of the county, the agreement may provide that it will automatically be renewed for participation in successive three -year qualification periods, unless the country or the participating unit of general local government provides written notice it elects not to participate in a new qualification period. A copy of that notice must be sent to the HUD Field Office. Where such agreements are used, the agreement must state that, by the date specified in HUD's urban county qualification notice for the next qualification period, the urban county will notify the participating unit of general local government in writing of its right not to participate. A copy of the comity's notification to the jurisdiction must be sent to the HUD Field Office by the date specified in the urban county qualification schedule in Section 11. Cooperation agreements with automatic renewal provisions must include a stipulation that requires each party to adopt any amendment to the agreement incorporating changes necessary to meet the requirements for cooperation, agreements set forth in an Urban County Qualification Notice applicable for a subsequent three -year urban county qualification period, and to submit such amendment to HUD as provided in the urban county qualification notice (see Section IV, Documents to be Submitted to HUD, paragraph E), and that such failure to comply will void the automatic renewal for such qualification period. F. The agreement must provide that it remains in effect until the CDBG (and, where applicable, HOME and ESG) funds and program income received (with respect to activities carried out during the three -year qualification period, and any successive qualification periods under agreements that provide for automatic renewals) are expended and the funded activities completed, and that the county and participating unit of general local government cannot terminate or withdraw from the cooperation agreement while it remains in effect. G. The agreement must expressly state that the county and the cooperating unit of general local government agree to "cooperate to undertake, or assist in undertaking, community renewal and lower - income housing assistance activities." If the county does not have such powers, the agreement must expressly state that the cooperating unit of general local government agrees to "undertake, or assist in undertaking, community renewal and lower - income housing assistance activities." As an alternative to this wording, the cooperation agreement may reference State legislation authorizing such activities, but only with the approval of the specific alternative wording by HUD Field Counsel. H. The agreement must contain a provision obligating the county and the cooperating unit of general local government to take all actions necessary to assure compliance with the urban county's certification required by section 104(b) of Title I of the Housing and Community Development Act of 1974, as amended, including Title VI of the Civil Rights Act of 1964, the Fair Housing Act, section 109 of Title I of the Housing and Community Development Act of 1974, and other applicable laws. The agreements shall also contain a provision prohibiting urban county funding for activities in, or in support of, any cooperating unit of general local government that does not affirmatively further fair housing within its own jurisdiction or that impedes the county's actions to comply with the county's fair housing certification. This provision is required because noncompliance by a unit of general local government included in an urban county may constitute noncompliance by the grantee (i.e., the county) that can, in turn, provide cause for funding sanctions or other remedial actions by the Department. I. The agreement must expressly state "that the cooperating unit of general local government has adopted and is enforcing: 1. A policy prohibiting the use of excessive force by law enforcement agencies within its jurisdiction against any individuals engaged in non - violent civil rights demonstrations; and 2. A policy of enforcing applicable State and local laws against physically barring entrance to or exit from a facility or location which is the subject of such non - violent civil rights demonstrations within jurisdictions." J. The agreement may not contain a provision for veto or other restriction that would allow any party to the agreement to obstruct the implementation of the approved Consolidated Plan during the period covered by the agreement. The county has final responsibility for selecting CDBG (and, where applicable, HOME and ESG) activities and submitting the Consolidated Plan to HUD, although if the county is a member of a HOME consortium, the consortium submits the Plan developed by the county (see Section I, General Requirements, paragraph Q. K. The agreement must contain language specifying that, pursuant to 24 CFR 570.501(b), the unit of local government is subject to the same requirements applicable to subrecipients, including the requirement of a written agreement as described in 24 CFR 570.503 (see Section VIII, Special Considerations, paragraph B). L. A county may also include in the cooperation agreement any provisions authorized by State and local laws that legally obligate the cooperating units to undertake the necessary actions, as determined by the county, to carry out a community development program and the approved Consolidated flan and/or meet other requirements of the CDBG (and, where applicable, HOME and ESG) program and other applicable laws. VI. PERIOD OF QUALIFICATION A. General Any county that qualifies as an urban county will be entitled to receive funds as an urban county for three consecutive fiscal years regardless of changes in its population or boundary or population changes in any communities contained within the urban county during that period, provided funds are appropriated by Congress. However, during the period of qualification, no included unit of general local government may withdraw from the urban county unless the urban county does not receive a grant for any year during such period. The urban county's grant amount is calculated annually and will reflect the addition of any new units of general local government during the second and third years of the period of qualification. Any unincorporated portion of the county that incorporates during the urban county qualification period will remain part of the urban county through the end of the three -year period. Any unit of general local government that is part of an urban county will continue to be included in the urban county for that county's qualification period, even if it meets the criteria to be considered a "metropolitan city" during that period. Such an included unit of general local government cannot become eligible for a separate entitlement grant as a metropolitan city while participating as a part of an urban county (see Section VIII, paragraph E). B. Retaining Urban County Classification Any county classified as an urban county in FY 1999 may, at the option of the county, remain classified as an urban county. Any county that has been classified as an urban county after FY 1999 and is so classified for at least two years will retain its classification as an urban county, unless the urban county qualified under section 102(a)(6)(A) of Title I of the Housing and Community Development Act of 1974, as amended, and fails to requalify under that section due to the election of a currently participating non - entitlement community to opt out or not to renew a cooperation agreement (for reasons other than becoming an eligible metropolitan city). VII. URBAN COUNTY PROGRAM RESPONSIBILITIES The county, as the CDBG grant recipient, either for the urban county or a joint recipient (see Section VIII, paragraph A, Metropolitan City/Urban County Joint Recipients) has full responsibility for the execution of the community development program., for following its Consolidated Plan, and for meeting the requirements of other applicable laws (e.g., National Environmental Policy Act, Uniform Relocation Act, Fair Housing Act, Title VI of the Civil Rights Act of 1964, Sec. 504 of the Rehabilitation Act of 1973, Sec. 109 of Title I of the Housing and Community Development Act of 1974, the Americans with Disabilities Act of 1990, and for affirmatively furthering fair housing). The county's responsibility must include these functions even where, as a matter of administrative convenience or State law, the county permits the participating units of general local government to carry out essential community development and housing assistance activities. The county will be held accountable for the accomplishment of the community development program, for following its Consolidated Plan, and for ensuring that actions necessary for such accomplishment are taken by cooperating units of general local government. VIII. SPECIAL CONSIDERATIONS A. Metropolitan CiVILJrban County Joint Recipients Any urban county and any metropolitan city located in whole or in part within that county can ask HUD to approve the inclusion of the metropolitan city as a part of the urban county for purposes of planning and implementing a joint community development and housing assistance program. HUD will consider approving a joint request only if it is signed by the chief executive officers of both entities and is submitted at the time the county is seeking its qualification as an urban county. A joint request will be deemed approved unless HUD notifies the city and the county otherwise within 30 days following submission of the joint request and an executed cooperation agreement meeting the requirements specified under Section V, Cooperation Agreements. An urban county may be joined by more than one metropolitan city, but a metropolitan city located in more than one urban county may be a joint recipient with only one urban county at a time. Upon urban county qualification and HUD approval of the joint request and cooperation agreement, the metropolitan city becomes a part of the urban county for purposes of program planning and implementation for the entire period of the urban county qualification, and for the CDBG program, will be treated by HUD as any other unit of general local government that is a part of the urban county. When a metropolitan city joins an urban county in this manner, the grant amount is the sum of the amounts authorized for the individual metropolitan city and urban county. The urban county becomes the grant recipient. A metropolitan city in a joint agreement with the urban county is treated the same as any other unit of general local government that is part of the urban county for purposes of the CDBG program, but not for the HOME or ESG programs. If the metropolitan city does not qualify to receive a separate allocation of HOME funds, to be considered for HOME funding as part of the urban county, it must form a HOME consortium with the urban county. If the metropolitan city qualifies to receive a separate allocation of HOME funds, it has three options: (1) it may form a HOME consortium with the county, in which case it will be included as part of the county when the HOME funds for the county are calculated; (2) it may elect to continue to receive its separate HOME allocation but subgrant it to the county to administer; or (3) the metropolitan city may administer its HOME program on its own. NOTE: The execution of a joint agreement between an urban county and metropolitan city does not in itself satisfy HOME requirements for a written consortia agreement. For additional information on the requirements for consortia agreements, see 24 CFR 92.101 and the Notice of Procedures for Designation of Consortia as a Participating Jurisdiction for the HOME Program (CPD- 08 -01). The ESG program does not provide for either joint agreements or consortium agreements among grantees. (No CDBG joint agreement cities currently qualify for a formula ESG allocation.) Counties and metropolitan cities considering a joint request should be aware that significant effects could occur where either the urban county or the metropolitan city would otherwise fall under the "exception rule" criteria for activities that benefit low -and moderate - income residents on an area basis (see 24 CFR 570.208(a)(1)(ii)). Joint agreements result in a modification to an urban county's configuration, and a change in the mix of census block groups in an urban county is likely to change the relative ranking of specific block groups by quartile, thus affecting the minimum concentration of low- and moderate - income persons under the "exception rule." HUD will make a rank - ordering computer run available to counties and metropolitan cities considering joint participation to assist them in determining the possible effects of inclusion and how such an agreement may impact their respective programs. B. Subrecipient Agreements The execution of cooperation agreements meeting the requirements of Section V, Cooperation Agreements, between an urban county and its participating units of local government does not in itself satisfy the requirement for a written subrecipient agreement required by the regulations at 24 CFR 570.503. Where a participating unit of general local government carries out an eligible activity funded by the urban county, the urban county is responsible, prior to disbursing any CDBG funds for any such activity or project, for executing a written subrecipient agreement with the unit of government containing the minimum requirements found at 24 CFR 570.503. The subrecipient agreement must remain in effect during any period that the unit of local government has control over CDBG funds, including program income. C. Ineligibility for State CDBG Program An urban county's included units of general local government are ineligible to apply for grants from appropriations under the State CDBG Program for fiscal years during the period in which they are participating in the Entitlement CDBG program with the urban county. D. Eligibilfty for a HOME Consortium When included units of local government become part of an urban county for the CDBG Program, they are part of the urban county for the HOME Program and may receive a formula allocation under the HOME Program only as part of the urban county. Thus, even if the urban county does not receive a HOME formula allocation, the participating unit of local government cannot form a HOME consortium with other local governments. However, this does not preclude the urban county or a unit of government within an urban county from applying to the State for HOME funds, if the State allows. E. Counties with Potential Metropolitan Cities If a county includes one or more communities that believe their population meets the statutory threshold to enable them to receive CDBG entitlement funds as a metropolitan city directly, but the city and county have not yet received notification from HUD regarding metropolitan city eligibility, HUD has identified two options a county may use to address such situations: 1. The county and community can negotiate a schedule that will provide the community additional time to receive notification from HUD of its eligibility as a potential new metropolitan city and, if the community does not reach metropolitan city status (or becomes eligible and elects to defer its status), execute a cooperation agreement and still meet the deadlines identified in this Notice; or 2. If a county believes delaying the execution of a cooperation agreement until HUD provides such notification will prohibit it from meeting the submission deadlines in this Notice, the county may want to include a clause in the agreement that provides that the agreement will be voided if the community is advised by HUD, prior to the completion of the requalification process for FY 2011 -2013, that it is eligible to become a metropolitan city and the community elects to take its entitlement status. If such a clause is used, it must state that if the agreement is not voided on the basis of the community's eligibility as a metropolitan city prior to July 8, 2011 (or a later date if approved in writing by HUD), the community must remain a part of the county for the entire three -year period of the county's qualification. Option 1 is preferred. Option 2 is available if a county wishes to use it, although there is concern that a community may believe that the use of a clause that may void the agreement will enable it to "opt out" later in the - three -year period of qualification if it reaches the population during that time to be a metropolitan city. Therefore, any such clause must be clear that it applies only for a limited period of time. There are jurisdictions that may potentially qualify as urban counties for the first time because they contain one or more metropolitan cities that may consider relinquishing their status as entitlement grantees. If a county has a metropolitan city or cities that are willing to relinquish its /their status as entitlement grantee(s) and the county wants to begin the process of qualifying as an urban county, the Entitlement Communities Division in HUD Headquarters should be notified as soon as possible, but no later than two weeks after the county notifies the Field Office of its intent to qualify as an urban county. A list of these counties is provided as Attachment F. IX. DETERMINATIONS OF ESSENTIAL POWERS A. For new urban counties, HUD Field Office Counsel must initially determine whether each county within its jurisdiction that is eligible to qualify as an urban county has powers to carry out essential community renewal and lower - income housing assistance activities. For requalifying urban counties, the Field Office Counsel may rely on its previous determination(s) unless there is evidence to the contrary. In assessing such evidence, Field Office counsel may consider information provided by the county and its included units of general local government as well as other relevant information obtained from independent sources. In making the required determinations, Field Office Counsel must consider both the county's authority and, where applicable, the authority of its designated agency or agencies. Field Office Counsel shall make such determinations as identified below and concur in notifications to the county(ies) about these issues. B. For new and requalifying counties, the notification by the Field Office required under Section 11, paragraph A, must include the following determinations: Whether the county is authorized to undertake essential community development and housing assistance activities in its unincorporated areas, if any, which are not units of general local government. For these purposes, the term "essential community development and housing assistance activities" means community renewal and lower - income housing assistance activities. Activities that may be accepted as essential community development and housing assistance activities might include, but are not limited to: (1) acquisition of property for disposition for private reuse, especially for low - and moderate - income housing; (2) direct rehabilitation of or financial assistance to housing; (3) low rent housing activities; (4) disposition of land to private developers for appropriate redevelopment; and (5) condemnation of property for low- income housing. [Note: The phrase "specifically urban renewal and publicly assisted housing ", although in 24 CFR 570.307(c), is not included in this Notice because it does not appear in the text of the Housing and Community Development Act of 1974, as amended (the Act). Although not in the Act, the House Committee Report accompanying the CDBG legislation made specific reference to the term "renewal" and indicates that Congress intended eligible urban counties to be able to carry out all aspects of the urban renewal program (which was subsequently consolidated by the CDBG program)]; 2. In which of the county's units of general local government the county is authorized to undertake essential community development and housing assistance activities without the consent of the governing body of the locality. The population of these units of local government will be counted towards qualification of the urban county unless they specifically elect to be excluded from the county for purposes of the CDBG program and so notify both the county and HUD in writing by May 31, 2011 (see Section II, paragraph E); and, 3. In which of the county's units of general local government the county is either (a) not authorized to undertake essential community development and housing assistance activities or (b) may do so only with the consent of the governing body of the locality. The population of these units of local government will only be counted if they have signed cooperation agreements with the county that meet the standards set forth in Section V of this Notice. THIS PAGE INTENTIONALLY LEFT BLANK ATTACHMENT A ALL CURRENTLY QUALIFIED URBAN COUNTIES NEW ENGLAND FIELD OFFICES MAINE CUMBERLAND COUNTY NEW YORKINEW JERSEY FIELD OFFICES NEW JERSEY ATLANTIC COUNTY NEW JERSEY BERGEN COUNTY NEW JERSEY BURLINGTON COUNTY NEW JERSEY CAMDEN COUNTY NEW JERSEY ESSEX COUNTY NEW JERSEY GLOUCESTER COUNTY NEW JERSEY HUDSON COUNTY NEW JERSEY MIDDLESEX COUNTY NEW JERSEY MONMOUTH COUNTY NEW JERSEY MORRIS COUNTY NEW JERSEY OCEAN COUNTY NEW JERSEY PASSAIC COUNTY NEW JERSEY SOMERSET COUNTY NEW JERSEY UNION COUNTY NEW YORK DUTCHESS COUNTY NEW YORK ERIE COUNTY NEW YORK MONROE COUNTY NEW YORK NASSAU COUNTY NEW YORK ONONDAGA COUNTY NEW YORK ORANGE COUNTY NEW YORK ROCKLAND COUNTY NEW YORK SUFFOLK COUNTY NEW YORK WESTCHESTER COUNTY MID- ATLANTIC FIELD OFFICES DELAWARE NEW CASTLE COUNTY MARYLAND ANNE ARUNDEL COUNTY MARYLAND BALTIMORE COUNTY MARYLAND HARFORD COUNTY MARYLAND HOWARD COUNTY MARYLAND MONTGOMERY COUNTY MARYLAND PRINCE GEORGES COUNTY PENNSYLVANIA ALLEGHENY COUNTY PENNSYLVANIA BEAVER COUNTY PENNSYLVANIA BERKS COUNTY PENNSYLVANIA BUCKS COUNTY PENNSYLVANIA CHESTER COUNTY PENNSYLVANIA CUMBERLAND COUNTY PENNSYLVANIA DAUPHIN COUNTY PENNSYLVANIA DELAWARE COUNTY PENNSYLVANIA LANCASTER COUNTY PENNSYLVANIA LEHIGH COUNTY PENNSYLVANIA LUZERNE COUNTY PENNSYLVANIA MONTGOMERY COUNTY PENNSYLVANIA NORTHAMPTON COUNTY PENNSYLVANIA WASHINGTON COUNTY PENNSYLVANIA WESTMORELAND COUNTY PENNSYLVANIA YORK COUNTY VIRGINIA ARLINGTON COUNTY VIRGINIA CHESTERFIELD COUNTY VIRGINIA FAIR-FAX COUNTY VIRGINIA HENRICO COUNTY VIRGINIA LOUDOUN COUNTY VIRGINIA PRINCE WILLIAM COUNTY SOUTHEAST /CARIBBEAN FIELD OFFICES ALABAMA JEFFERSON COUNTY ALABAMA MOBILE COUNTY FLORIDA BREVARD COUNTY FLORIDA BROWARD COUNTY FLORIDA COLLIER COUNTY FLORIDA ESCAMBIA COUNTY FLORIDA HILLSBOROUGH COUNTY FLORIDA JACKSONVILLE -DUVAL COUNTY FLORIDA LAKE COUNTY FLORIDA LEE COUNTY FLORIDA MANATEE COUNTY FLORIDA MARION COUNTY FLORIDA MIAMI -DADE COUNTY FLORIDA ORANGE COUNTY FLORIDA OSCEOLA COUNTY FLORIDA PALM BEACH COUNTY FLORIDA PASCO COUNTY FLORIDA PINELLAS COUNTY FLORIDA POLK COUNTY FLORIDA SARASOTA COUNTY FLORIDA SEMINOLE COUNTY FLORIDA VOLUSIA COUNTY GEORGIA CHEROKEE COUNTY GEORGIA CLAYTON COUNTY GEORGIA COBB COUNTY GEORGIA DE KALB COUNTY GEORGIA FULTON COUNTY GEORGIA GWINNETT COUNTY NORTH CAROLINA NORTH CAROLINA NORTH CAROLINA SOUTH CAROLINA SOUTH CAROLINA SOUTH CAROLINA SOUTH CAROLINA SOUTH CAROLINA SOUTH CAROLINA TENNESSEE TENNESSEE MIDWEST FIELD OFFICES CUMBERLAND COUNTY MECKLENBURG COUNTY WAKE COUNTY CHARLESTON COUNTY GREENVILLE COUNTY HORRY COUNTY LEXINGTON COUNTY RICHLAND COUNTY SPARTANBURG COUNTY KNOX COUNTY SHELBY COUNTY ILLINOIS COOK COUNTY ILLINOIS DU PAGE COUNTY ILLINOIS KANE COUNTY ILLINOIS LAKE COUNTY ILLINOIS MADISON COUNTY ILLINOIS MCHENRY COUNTY ILLINOIS ST CLAIR COUNTY ILLINOIS WILL COUNTY INDIANA HAMILTON COUNTY INDIANA LAKE COUNTY MICHIGAN GENESEE COUNTY MICHIGAN KENT COUNTY MICHIGAN MACOMB COUNTY MICHIGAN OAKLAND COUNTY MICHIGAN WASHTENAW COUNTY MICHIGAN WAYNE COUNTY MINNESOTA ANOKA COUNTY MINNESOTA DAKOTA COUNTY MINNESOTA HENNEPIN COUNTY MINNESOTA RAMSEY COUNTY MINNESOTA ST LOUIS COUNTY MINNESOTA WASHINGTON COUNTY OHIO BUTLER COUNTY OHIO CUYAHOGA COUNTY OHIO FRANKLIN COUNTY OHIO HAMILTON COUNTY OHIO LAKE COUNTY OHIO MONTGOMERY COUNTY OHIO STARK COUNTY OHIO SUMMIT COUNTY OHIO WARREN COUNTY WISCONSIN DANE COUNTY WISCONSIN MILWAUKEE COUNTY WISCONSIN WAUKESHA COUNTY SOUTHWEST FIELD OFFICES LOUISIANA JEFFERSON PARISH LOUISIANA ST. TAMMANY PARISH OKLAHOMA TULSA COUNTY TEXAS BEXAR COUNTY TEXAS BRAZORIA COUNTY TEXAS DALLAS COUNTY TEXAS FORT BEND COUNTY TEXAS HARRIS COUNTY TEXAS HIDALGO COUNTY TEXAS MONTGOMERY COUNTY TEXAS TA.RRANT COUNTY TEXAS TRAVIS COUNTY TEXAS WILLIAMSON COUNTY GREAT PLAINS FIELD OFFICES KANSAS JOHNSON COUNTY MISSOURI MISSOURI MISSOURI JEFFERSON COUNTY ST LOUIS COUNTY ST. CHARLES COUNTY ROCKY MOUNTAIN FIELD OFFICES COLORADO ADAMS COUNTY COLORADO ARAPAHOE COUNTY COLORADO DOUGLAS COUNTY COLORADO EL PASO COUNTY COLORADO JEFFERSON COUNTY UTAH DAVIS COUNTY UTAH SALT LAKE COUNTY UTAH UTAH COUNTY PACIFIC/HAWAII FIELD OFFICES ARIZONA MARICOPA COUNTY ARIZONA PIMA COUNTY CALIFORNIA ALAMEDA COUNTY CALIFORNIA CONTRA COSTA COUNTY CALIFORNIA FRESNO COUNTY CALIFORNIA KERN COUNTY CALIFORNIA LOS ANGELES COUNTY CALIFORNIA MARIN COUNTY CALIFORNIA ORANGE COUNTY CALIFORNIA RIVERSIDE COUNTY CALIFORNIA SACRAMENTO COUNTY CALIFORNIA SAN BERNARDINO COUNTY CALIFORNIA SAN DIEGO COUNTY CALIFORNIA SAN JOAQUIN COUNTY CALIFORNIA SAN LUIS OBISPO COUNTY CALIFORNIA SAN MATEO COUNTY CALIFORNIA SANTA BARBARA COUNTY CALIFORNIA SANTA CLARA COUNTY CALIFORNIA SONOMA COUNTY CALIFORNIA STANISLAUS COUNTY CALIFORNIA VENTURA COUNTY NEVADA CLARK COUNTY NORTHWEST /ALASKA FIELD OFFICES OREGON CLACKAMAS COUNTY OREGON MULTNOMAH COUNTY OREGON WASHINGTON COUNTY WASHINGTON CLARK COUNTY WASHINGTON KING COUNTY WASHINGTON KITSAP COUNTY WASHINGTON PIERCE COUNTY WASHINGTON SNOHOMISH COUNTY WASHINGTON SPOKANE COUNTY ATTACHMENT B COUNTIES SCHEDULED TO REQUALIFY IN 2011 FOR FYS 2012 -2014 NEW YORK/NEW JERSEY FIELD OFFICES NEW JERSEY BERGEN COUNTY NEW JERSEY BURLINGTON COUNTY NEW JERSEY CAMDEN COUNTY NEW JERSEY ESSEX COUNTY NEW JERSEY HUDSON COUNTY NEW JERSEY MIDDLESEX COUNTY NEW JERSEY MONMOUTH COUNTY NEW JERSEY MORRIS COUNTY NEW JERSEY UNION COUNTY NEW YORK ERIE COUNTY NEW YORK MONROE COUNTY NEW YORK NASSAU COUNTY NEW YORK ONONDAGA COUNTY NEW YORK ORANGE COUNTY NEW YORK ROCKLAND COUNTY NEW YORK SUFFOLK COUNTY NEW YORK WESTCHESTER COUNTY MID - ATLANTIC FIELD OFFICES DELAWARE NEW CASTLE COUNTY MARYLAND ANNE ARUNDEL COUNTY MARYLAND BALTIMORE COUNTY MARYLAND HARFORD COUNTY MARYLAND MONTGOMERY COUNTY MARYLAND PRINCE GEORGES COUNTY PENNSYLVANIA ALLEGHENY COUNTY PENNSYLVANIA BEAVER COUNTY PENNSYLVANIA BERKS COUNTY PENNSYLVANIA BUCKS COUNTY PENNSYLVANIA CHESTER COUNTY PENNSYLVANIA DELAWARE COUNTY PENNSYLVANIA LANCASTER COUNTY PENNSYLVANIA PENNSYLVANIA PENNSYLVANIA PENNSYLVANIA PENNSYLVANIA VIRGINIA VIRGINIA LUZERNE COUNTY MONTGOMERY COUNTY WASHINGTON COUNTY WESTMORELAND COUNTY YORK COUNTY ARLINGTON COUNTY FAIRFAX COUNTY SOUTHEAST /CARIBBEAN FIELD OFFICES ALABAMA FLORIDA FLORIDA FLORIDA FLORIDA FLORIDA FLORIDA FLORIDA FLORIDA FLORIDA FLORIDA GEORGIA GEORGIA GEORGIA GEORGIA SOUTH CAROLINA SOUTH CAROLINA SOUTH CAROLINA TENNESSEE MIDWEST FIELD OFFICES ILLINOIS ILLINOIS ILLINOIS ILLINOIS ILLINOIS ILLINOIS JEFFERSON COUNTY BROWARD COUNTY ESCAMBIA COUNTY HILLSBOROUGH COUNTY LAKE COUNTY MIAMI -DADE COUNTY ORANGE COUNTY PALM BEACH COUNTY PINELLAS COUNTY POLK COUNTY VOLUSIA COUNTY CHEROKEE COUNTY COBB COUNTY DE KALB COUNTY FULTON COUNTY CHARLESTON COUNTY GREENVILLE COUNTY LEXINGTON COUNTY KNOX COUNTY COOK COUNTY DU PAGE COUNTY LAKE COUNTY MADISON COUNTY ST CLAIR COUNTY WILL COUNTY MICHIGAN GENESEE COUNTY MICHIGAN KENT COUNTY MICHIGAN MACOMB COUNTY MICHIGAN OAKLAND COUNTY MICHIGAN WASHTENAW COUNTY MICHIGAN WAYNE COUNTY MINNESOTA HENNEPIN COUNTY OHIO CUYAHOGA COUNTY OHIO FRANKLIN COUNTY OHIO HAMILTON COUNTY OHIO LAKE COUNTY OHIO MONTGOMERY COUNTY OHIO STARK COUNTY OHIO SUMMIT COUNTY OHIO WARREN COUNTY WISCONSIN MILWAUKEE COUNTY SOUTHWEST FIELD OFFICES LOUISIANA JEFFERSON PARISH TEXAS DALLAS COUNTY TEXAS HARRIS COUNTY TEXAS HIDALGO COUNTY TEXAS TARRANT COUNTY TEXAS TRAVIS COUNTY GREAT PLAINS FIELD OFFICES MISSOURI ST LOUIS COUNTY ROCKY MOUNTAIN FIELD OFFICES COLORADO EL PASO COUNTY COLORADO JEFFERSON COUNTY UTAH SALT LAKE COUNTY PACIFIC/HAWAII FIELD OFFICES ARIZONA MARICOPA COUNTY CALIFORNIA ALAMEDA COUNTY CALIFORNIA CONTRA COSTA COUNTY CALIFORNIA FRESNO COUNTY CALIFORNIA KERN COUNTY CALIFORNIA LOS ANGELES COUNTY CALIFORNIA MARIN COUNTY CALIFORNIA ORANGE COUNTY CALIFORNIA RIVERSIDE COUNTY CALIFORNIA SACRAMENTO COUNTY CALIFORNIA SAN BERNARDINO COUNTY CALIFORNIA SAN DIEGO COUNTY CALIFORNIA SAN JOAQUIN COUNTY CALIFORNIA SAN LUIS OBISPO COUNTY CALIFORNIA SAN MATEO COUNTY CALIFORNIA SANTA CLARA COUNTY CALIFORNIA SONOMA COUNTY NEVADA CLARK COUNTY NORTHWEST /ALASKA FIELD OFFICES OREGON CLACKAMAS COUNTY OREGON WASHINGTON COUNTY WASHINGTON CLARK COUNTY WASHINGTON KING COUNTY WASHINGTON PIERCE COUNTY WASHINGTON SNOHOMISH COUNTY WASHINGTON SPOKANE COUNTY ATTACHMENT C COUNTIES SCHEDULED TO REQUALIFY IN 2012 FOR FYS 2013 -2015 NEW ENGLAND FIELD OFFICES MAINE CUMBERLAND COUNTY NEW YORK/NEW JERSEY FIELD OFFICES NEW JERSEY ATLANTIC COUNTY NEW YORK DUTCHESS COUNTY MID - ATLANTIC FIELD OFFICES PENNSYLVANIA LEHIGH COUNTY PENNSYLVANIA NORTHAMPTON COUNTY VIRGINIA CHESTERFIELD COUNTY VIRGINIA LOUDOUN COUNTY VIRGINIA PRINCE WILLIAM COUNTY SOUTHEAST /CARIBBEAN FIELD OFFICES FLORIDA BREVARD COUNTY FLORIDA COLLIER COUNTY FLORIDA JACKSONVILLE -DUVAL COUNTY FLORIDA OSCEOLA COUNTY FLORIDA PASCO COUNTY FLORIDA SEMINOLE COUNTY GEORGIA CLAYTON COUNTY GEORGIA GWiNNETT COUNTY NORTH CAROLINA NORTH CAROLINA NORTH CAROLINA SOUTH CAROLINA TENNESSEE MIDWEST FIELD OFFICES CUMBERLAND COUNTY MECKLENBURG COUNTY WAKE COUNTY SPARTANBURG COUNTY SHELBY COUNTY ILLINOIS KANE COUNTY ILLINOIS MCHENRY COUNTY INDIANA HAMILTON COUNTY INDIANA LAKE COUNTY MINNESOTA RAMSEY COUNTY MINNESOTA WASHINGTON COUNTY SOUTHWEST FIELD OFFICES TEXAS BEXAR COUNTY TEXAS BRAZORIA COUNTY TEXAS FORT BEND COUNTY TEXAS MONTGOMERY COUNTY TEXAS WILLIAMSON COUNTY GREAT PLAINS FIELD OFFICES KANSAS JOHNSON COUNTY MISSOURI JEFFERSON COUNTY ROCKY MOUNTAIN FIELD OFFICES COLORADO COLORADO COLORADO ADAMS COUNTY ARAPAHOE COUNTY DOUGLASCOUNTY PACIFIC/HAWAII FIELD OFFICES CALIFORNIA CALIFORNIA SANTA BARBARA COUNTY VENTURA COUNTY NORTHWEST /ALASKA FIELD OFFICES OREGON MULTNOMAH COUNTY ATTACHMENT D COUNTIES SCHEDULED TO REQUALIFY IN 2013 FOR FYS 2414 -2016 NEW YORK/NEW JERSEY FIELD OFFICES NEW JERSEY GLOUCESTER COUNTY NEW JERSEY OCEAN COUNTY NEW JERSEY PASSAIC COUNTY NEW JERSEY SOMERSET COUNTY MID - ATLANTIC FIELD OFFICES MARYLAND PENNSYLVANIA PENNSYLVANIA VIRGINIA HOWARD COUNTY CUMBERLAND COUNTY DAUPHIN COUNTY HENRICO COUNTY SOUTHEAST /CARIBBEAN FIELD OFFICES ALABAMA MOBILE COUNTY FLORIDA LEE COUNTY FLORIDA MANATEE COUNTY FLORIDA MARION COUNTY FLORIDA SARASOTA COUNTY SOUTH CAROLINA HORRY COUNTY SOUTH CAROLINA RICHLAND COUNTY MIDWEST FIELD OFFICES MINNESOTA ANOKA COUNTY MINNESOTA DAKOTA COUNTY MINNESOTA ST LOUIS COUNTY OHIO BUTLER COUNTY WISCONSIN DANE COUNTY WISCONSIN WAUKESHA COUNTY SOUTHWEST FIELD OFFICES LOUISIANA ST. TAMMANY PARISH OKLAHOMA TULSA COUNTY GREAT PLAINS FIELD OFFICES MISSOURI ST. CHARLES COUNTY ROCKY FOUNTAIN FIELD OFFICES UTAH UTAH DAVIS COUNTY UTAH COUNTY PACIFIC/HAWAII FIELD OFFICES ARIZONA CALIFORNIA PIMA COUNTY STANISLAUS COUNTY NORTHWEST /ALASKA FIELD OFFICES WASHINGTON KITSAP COUNTY ATTACHMENT E COUNTIES QUALIFIED THROUGH 2012 OR 2013 THAT CONTAIN NON - PARTICIPATING COMMUNITIES NEW ENGLAND FIELD OFFICES CUMBERLAND COUNTY MAINE NEW YORK/NEW JERSEY FIELD OFFICES ATLANTIC COUNTY NEW JERSEY BURLINGTON COUNTY NEW JERSEY CAMDEN COUNTY NEW JERSEY MONMOUTH COUNTY NEW JERSEY MORRIS COUNTY NEW JERSEY SOMERSET COUNTY NEW JERSEY DUTCHESS COUNTY NEW YORK NASSAU COUNTY NEW YORK ORANGE COUNTY NEW YORK ROCKLAND COUNTY NEW YORK SUFFOLK COUNTY NEW YORK WESTCHESTER COUNTY NEW YORK MID - ATLANTIC FIELD OFFICES NEW CASTLE COUNTY DELAWARE ANNE AWtJNDEL COUNTY MARYLAND MONTGOMERY COUNTY MARYLAND PRINCE GEORGES COUNTY MARYLAND ALLEGHENY COUNTY PENNSYLVANIA BEAVER COUNTY PENNSYLVANIA DAUPHIN COUNTY PENNSYLVANIA LUZERNE COUNTY PENNSYLVANIA MONTGOMERY COUNTY PENNSYLVANIA WESTMORELAND COUNTY PENNSYLVANIA SOUTHEAST /CARIBBEAN FIELD OFFICES JEFFERSON COUNTY ALABAMA MOBILE COUNTY ALABAMA BREVARD COUNTY FLORIDA COLLIER COUNTY FLORIDA ESCAMBIA COUNTY FLORIDA JACKSONVILLE -DUVAL COUNTY FLORIDA LAKE COUNTY FLORIDA MANATEE COUNTY FLORIDA MARION COUNTY FLORIDA MIAMI -DADE COUNTY FLORIDA ORANGE COUNTY . FLORIDA PALM BEACH COUNTY FLORIDA PASCO COUNTY FLORIDA PINELLAS COUNTY FLORIDA POLK COUNTY FLORIDA VOLUSIA COUNTY FLORIDA CHEROKEE COUNTY GEORGIA DE KALB COUNTY GEORGIA GWINNETT COUNTY GEORGIA MECKLENBURG COUNTY NORTH CAROLINA WAKE COUNTY NORTH CAROLINA CHARLESTON COUNTY SOUTH CAROLINA HORRY COUNTY SOUTH CAROLINA RICHLAND COUNTY SOUTH CAROLINA SPARTANBURG COUNTY SOUTH CAROLINA KNOX COUNTY TENNESSEE MIDWEST FIELD OFFICES COOK COUNTY ILLINOIS KANE COUNTY ILLINOIS LAKE COUNTY ILLINOIS WILL COUNTY ILLINOIS HAMILTON COUNTY INDIANA GENESEE COUNTY MICHIGAN OAKLAND COUNTY MICHIGAN WASHTENAW COUNTY MICHIGAN HENNEPIN COUNTY MINNESOTA WASHINGTON COUNTY MINNESOTA CUYAHOGA COUNTY OHIO FRANKLIN COUNTY OHIO HAMILTON COUNTY OHIO LAKE COUNTY OHIO STARK COUNTY OHIO WARREN COUNTY OHIO DANE COUNTY WISCONSIN WAUKESHA COUNTY WISCONSIN SOUTHWEST FIELD OFFICES ST. TAMMANY PARISH LOUISIANA TULSA COUNTY OKLAHOMA BEXAR COUNTY TEXAS BRAZORIA COUNTY TEXAS DALLAS COUNTY TEXAS FORT BEND COUNTY TEXAS HARRIS COUNTY TEXAS MONTGOMERY COUNTY TEXAS TARRANT COUNTY TEXAS TRAVIS COUNTY TEXAS WILLIAMSON COUNTY TEXAS GREAT PLAINS FIELD OFFICES JOHNSON COUNTY KANSAS JEFFERSON COUNTY MISSOURI ST LOUIS COUNTY MISSOURI ST. CHARLES COUNTY MISSOURI ROCKY MOUNTAIN FIELD OFFICES ADAMSCOUNTY COLORADO ARAPAHOE COUNTY COLORADO EL PASO COUNTY COLORADO JEFFERSON COUNTY COLORADO DAVIS COUNTY UTAH UTAH COUNTY UTAH PACIFIC/IHAWAH FIELD OFFICES MARICOPA COUNTY ARIZONA FRESNO COUNTY CALIFORNIA KERN COUNTY CALIFORNIA LOS ANGELES COUNTY CALIFORNIA ORANGE COUNTY CALIFORNIA RIVERSIDE COUNTY CALIFORNIA SAN LUIS OBISPO COUNTY CALIFORNIA SANTA BARBARA COUNTY CALIFORNIA STANISLAUS COUNTY CALIFORNIA NORTHWEST /ALASKA FIELD OFFICES KING COUNTY WASHINGTON ATTACHMENT F LIST OF COUNTIES THAT MAY QUALIFY AS URBAN COUNTIES IF METROPOLITAN CITIES RELINQUISH THEIR STATUS STATE COUNTY ENTITLEMENT POP 2009 AL Madison County 327,744 AL Huntsville city (pt.) 178,193 AL Montgomery County 224,119 AL Montgomery city 202,124 AZ Yavapai County 215,686 AZ Peoria city (pt.) 419 AZ Prescott city 42,749 AR Benton County 225,504 AR Bentonville city 36,857 AR Rogers city 59,017 AR Springdale city (pt.) 5,877 AR Pulaski County 381,904 AR Jacksonville city 31,651 AR Little Rock city 191,933 AR North Little Rock city 60,140 AR Washington County 200,181 AR Fayetteville city 77,143 AR Springdale city (pt.) 62,613 CA Butte County 220,577 CA Chico city 84,880 CA Paradise town 26,448 CA Merced County 245,321 CA Merced city 76,273 CA Placer County 348,552 CA Rocklin city 53,568 CA Roseville city 115,677 CA Santa Cruz County 256,218 CA Santa Cruz city 56,810 CA Watsonville city 51,053 CA Solano County 407,234 CA Fairfield city 103,586 CA Vacaville city 91,991 CA Vallejo city 114,622 CA Tulare County 429,668 CA Porterville city 52,153 CA Tulare city 57,521 CA Visalia city 122,111 CO Boulder County 303,482 CO Boulder city 100,160 CO Longmont city (pt.) 88,373 CO Larimer County 298,382 CO Fort Collins city 138,733 CO Loveland city 66,214 CO Weld County 254,759 CO Greeley city 92,625 CO Longmont city (pt.) 52 CO Thornton city (pt.) 5 FL Alachua County 243,574 FL Gainesville city 116,616 FL Leon County 265,714 FL Tallahassee city 172,574 FL St. Lucie County 266,502 FL Fort Pierce city 42,596 FL Port St. Lucie city 154,410 GA Chatham County 256,992 GA Savannah city 134,699 ID Ada County 384,656 ID Boise City city 205,707 ID Meridian city 68,516 IL Winnebago County 299,702 IL Rockford city 157,280 IN Allen County 353,888 TN Fort Wayne city 255,890 IN Elkhart County 200,502 IN Elkhart city 53,060 IN Goshen city 32,425 IN St. Joseph County 267,613 IN Mishawaka city 50,126 IN South Bend city 104,215 IA Linn County 209,226 IA Cedar Rapids city 127,764 IA Polk County 429,439 IA Des Moines city (pt.) 200,379 IA West Des Moines city (pt.) 49,812 KS Sedgwick County 490,864 KS Wichita city 372,186 LA Caddo Parish 253,623 LA Shreveport city (pt.) 198,399 ME York County 201,876 ME Biddeford city 21,383 MD Frederick County 227,980 MD Frederick city 59,644 M1 Ingham County 277,633 MI East Lansing city (pt.) 44,851 MI Lansing city (pt.) 109,097 MI Kalamazoo County 248,407 Ml Kalamazoo city 72,825 MI Portage city 46,453 MI Saginaw County 200,050 MI Saginaw city 55,238 MS Hinds County 247,631 MS Jackson city (pt.) 174,283 MO Clay County 228,358 MO Independence city (pt.) 7 MO Kansas City city (pt.) 105,185 MO Greene County 269,630 MO Springfield city (pt.) 157,622 MO Jackson County 705,708 MO Blue Springs city 55,817 MO Independence city (pt.) 121,173 MO Kansas City city (pt.) 334,121 MO Lee's Summit city (pt.) 85,035 NE Douglas County 510,199 NE Omaha city 454,731 NE Lancaster County 281,531 NE Lincoln city 254,001 NV Washoe County 414,820 NV Reno city 219,636 NV Sparks city 89,346 NJ Mercer County 366,222 NJ Trenton city 83,242 Ewing township 36,324 Hamilton township 90,605 NM Bernalillo County 642,527 Albuquerque city 529,219 Rio Rancho city (pt.) 71 NM Dona Ana County 206,419 NM Las Cruces city 93,452 NY Albany County 298,284 NY Albany city 93,836 Colonie town 81,518 NY Niagara County 214,557 NY Niagara Falls city 51,295 NY Oneida County 231,044 NY Rome city 33,443 NY Utica city (pt.) 57,967 NY Saratoga County 220,069 NY Saratoga Springs city 29,126 NC Buncombe County 231,452 NC Asheville city 76,636 NC Durham County 269,706 NC Chapel Hill town (pt.) 2,299 NC Durham city (pt.) 229,133 NC Raleigh city (pt.) 1,076 NC ]Forsyth County 359,638 NC High Point city (pt.) 32 NC Winston -Salem city 229,828 NC Gaston County 208,958 NC Gastonia city 72,934 NC Guilford County 480,362 NC Burlington city (pt.) 131 NC Greensboro city 255,124 NC High Point city (pt.) 101,590 OH Lorain County 305,707 OH Elyria city 54,947 OH Lorain city 70,260 OH Lucas County 463,493 OH Toledo city 316,179 OH Mahoning County 236,735 OH Alliance city (pt.) 77 OH Youngstown city (pt.) 72,424 OH Trumbull County 210,157 OH Warren city 43,402 OH Youngstown city (pt.) 1 OK Cleveland County 244,589 OK Moore city 53,763 OK Norman city 109,062 OK Oklahoma City city (pt.) 56,902 OK Oklahoma County 716,704 OK Edmond city 81,093 OK Midwest City city 57,193 OK Oklahoma City city (pt.) 466,124 OR Jackson County 201,286 OR Ashland city 20,996 OR Medford city 73,485 OR Lane County 351,109 OR Eugene city 153,272 OR Springfield city 57,254 OR Marion County 317,981 OR Salem city (pt.) 133,520 PA Erie County 280,291 PA Erie city 103,571 MiIlcreek township 52,269 PA. Lackawanna County 208,801 PA Scranton city 71,944 SC York County 227,003 SC Rock Hill city 69,210 TN Hamilton County 337,175 TN Chattanooga city 171,350 TN Rutherford County 257,048 TN Murfreesboro city 105,209 TX Bell County 285,787 TX Killeen city 119,512 TX Temple city 60,120 TX Cameron County 396,371 TX Brownsville city 176,859 TX Harlingen city 65,289 TX San Benito city 25,365 TX Collin County 791,631 TX Allen city 84,253 TX Carrollton city (pt.) 25 TX Dallas city (pt.) 51,391 TX Frisco city (pt.) 83,837 TX Garland city (pt.) 6 TX McKinney city 127,672 TX Plano city (pt.) 270,437 TX Richardson city (pt.) 25,074 TX El Paso County 751,296 TX El Paso city 620,456 TX Galveston County 286,814 TX Galveston city 56,148 TX League City city (pt.) 70,944 TX Texas City city (pt.) 43,962 TX Jefferson County 243,237 TX Beaumont city 110,110 TX Port Arthur city (pt.) 56,579 TX Lubbock County 270,550 TX Lubbock city 225,859 TX McLennan County 233,378 TX Waco city 126,222 TX Nueces County 323,046 TX Corpus Christi city (pt.) 287,213 TX Smith County 204,665 TX Tyler city 98,872 TX Webb County 241,438 TX Laredo city 226,124 UT Weber County 231,834 UT Ogden city 83,292 WA Whatcom County 200,434 WA Bellingham city 80,055 WA Yakima County 239,054 WA Yakima city 85,832 W1 Brown County 247,319 WI Green Bay city 101,412 W1 Racine County 200,601 WI Racine city 82,009